MANUAL FOR THE ENVIRONMENTAL REVIEW
OF FOREST SERVICE LAND MANAGEMENT
PLANS AND RELATED ACTIONS
USEPA
Contract No. 68-01-4710
Final Report
Submitted to:
U.S. Environmental Protection Agency
Office of Federal Activities (A-104)
401 M Street, S.W.
Washington, D.C. 20460
Attn: Dale Manty
Project Officer
Submitted by: Curran Associates, Inc.
Engineers and Planners
182 Main Street
Northampton, Massachusetts
Telephone (413) 584-7701
01060
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TABLE OF CONTENTS
I. INTRODUCTION 1
I.A. Purpose and Organization of the Guidelines 1
I.B. A Perspective on Forest Service Planning 4
I.C. Forest Service Planning Levels and Relationships 7
I.D. Land and Resource Management Planning Process 9
I.E. Forest Service Land Management Activities and Issues 11
II. LAND MANAGEMENT PLAN REVIEW 18
II.A. Pre-EIS Activity 18
II.B. Initiating the EIS/NEPA Process 19
II.C. Review of the Draft EIS 20
II.C.I. Purpose and Need 21
II.C.2. Alternatives Including the Proposed Action 22
II.C.3. Affected Environment 25
II.C.4. Environmental Consequences 26
II.D. Project Rating 28
III. IMPACT IDENTIFICATION AND ASSESSMENT 32
III.A. Review of Water Quality and Quantity Impacts 33
III.A.I. Sources of Impacts 33
III.A.2. Review of Information Adequacy and 38
Impact Quantification
III.A.3. Assessment of Water Quantity and 64
Quality Impacts
III.B. Review of Solid Waste Management Impacts 66
III.B.I. Sources of Impacts 67
III.B.2. Review of Information Adequacy and 67
Impact Quantification
III.B.3. Assessment of Solid Waste Impacts 68
III.C. Review of Air Impacts 69
III.C.I. Sources of Impacts 69
III.C.2. Review of Information Adequacy and 70
Impact Quantification
III.C.3. Assessment of Air Impacts 71
III.D. Review of Noise Impacts 73
111. D.I. Sources of Impacts -7-3-
III.D.2. Review of Information Adequacy and 73
Impact Quantification
III.D.3. Assessment of Impacts 74
III.E. Review of Pesticide Impacts
III.E.I. Sources of Impacts 74
III.E.2. Review of Information Adequacy and 75
Impact Quantification
III.E.3. Assessment of Pesticide Impacts 76
REFERENCES
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APPENDICES
Appendix A: Reference Bibliography for Review of Forest Service
Land Management Plans and EISs
Appendix B: April 2, 1976 Agreement between USDA and EPA
Appendix C: Memorandum of Understanding Between Environmental
Protection Agency and U. S. Department of Agriculture,
January 18, 1979
Appendix D: Statement of Intent - FS-EPA Forestry Water Quality Management
Appendix E: Forest Service Procedures for Implementing the National
Environmental Policy Act
Appendix F: CEQ Regulations for Implementing the Procedural Provisions
of the National Environmental Policy Act
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LIST OF ILLUSTRATIONS
Table No.
1 Organization and Use of Guidelines 5
2 Categories for Rating EISs 29
3A EPA Standards, Criteria and Regulations Related 31A
to Forest Service Land Management Plans
3B Rating Forest Service EISs 31B
4 Summary of Forest Service Land Management Activities 36
and Nature of Potential Water Quality Impacts
5 Characteristics and Potential Impacts of 45
Various Logging Methods
6 Topographical Influences on Logging Road Location 51
7 Framework For Water Pollution Control Practices 54
Used In Connection With Silvicultural And Other
Land Management Activities
8 Guidelines for Pollution Prevention Practices - 56
Location of Activities
9 Guidelines for Pollution Prevention Practices - 57
Scheduling of Activities
10 Guidelines for Pollution Prevention Practices - 60
Nature of Activities
11 Guidelines for Pollution Reduction Practices 62
Figure No.
1 Forest Service and EPA Regions 8
2 Logging Systems with Optimum Yarding 48
Distances and Slope
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I. INTRODUCTION
The U.S. Forest Service has the responsibility for management of the lands and
resources in the National Forest system, which totals 187 million acres in 44
states, Puerto Rico and the Virgin Islands. The 155 National Forests and 19
National Grasslands in the system contain some of the country's most valuable
natural resources, including timber, minerals, grassland, wilderness, water,
fish and wildlife. The Forest Service manages the lands and resources in accor-
dance with the principles of sustained yield and multiple use, established as
national policy in the Multiple-Use and Sustained Yield Act of 1960. Although
demands for forest resources, including both commodity and non-commodity items,
are steadily increasing, the capacity of the national forests to supply those
resources without unacceptable environmental impacts is limited. Indeed, most
of the major issues affecting management of the national forest system involve
conflicts among competing uses of the lands and resources arising from supply/
demand imbalances.
Planning and management of Forest Service lands are complex tasks due to the
diversity of uses and resources involved and the competition among them. Some
uses may be conflicting or incompatible, further complicating the Forest Service's
management responsibilities. The array of possible uses for national forest
lands also results in a wide range of potential environmental impacts which must
be identified and evaluated as part of the forest land management planning pro-
cess. Impacts may occur which affect nearly all areas of EPA's substantive
responsibilities including water, air, noise, solid wastes and pesticides. Fur-
ther, these plans may also involve EP\'s procedural responsibilities for inclu-
ding public involvement throughout the NEPA review -process, and satisfaction of
other federal policies which affect the environment such as the Executive Orders
for floodplain management and wetlands protection. In addition EPA has the
responsibility to officially receive, review and comment on
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(a) The Administrator shall review and comment in writing on the environ-
mental impact of any matter relating to duties and responsibilities
granted pursuant to this chapter or other provisions of the authority
of the Administrator, contained in any (1) legislation proposed by any
Federal department or agency, (2) newly authorized Federal projects for
construction and any major Federal agency action (other than a project
for construction) to which section 4332(2)(C) of this title applies,
and (3) proposed regulations published by any department or agency of
the Federal Government. Such written comment shall be made public at
the conclusion of any such review.
(b) In the event the Administrator determines that any such legislation,
action, or regulation is unsatisfactory from the standpoint of public
health or welfare or environmental quality, he shall publish his de-
termination and the matter shall be referred to the Council on Environ-
mental Quality.
Section 309 directs the Administrator to make environmental referrals to the
Council on Environmental Quality of matters which are "unsatisfactory from the
standpoint of public health or welfare or environmental quality." To imple-
ment these responsibilities, the EPA manual Review of Federal Actions Impacting
the Environment (hereafter referred to as the "309 Review Manual") has estab-
lished detailed policies, responsibilities and administrative procedures for the
Agency's review of Federal actions impacting the environment.
The 309 Review Manual provides that, where an environmental impact statement
(EIS) has been submitted to EPA for comment, EPA's comments on the EIS shall
also constitute its comments for purposes of the Section review. Furthermore,
it is EPA policy to use the Section 309 review process in conjunction with
EPA's other authorities to: (a) provide technical assistance to Federal, State,
regional, and local governmental entities; (b) assist the environmentally re-
lated activities of EPA and other Federal, State, regional, and local entities;
and (c) assist Federal agencies in meeting the objectives of the National En-
vironmental Policy Act.
Other Responsibilities
i
Further, under several agreements with the Department of Agriculture and the U.S.
Forest Service, EPA has both responsibility and authority to cooperate and pro-
vide specific assistance to the Forest Service in carrying out several major
functions. The EPA/DOA agreement, signed in 1979 by Secretary of Agriculture
Bergland and EPA Administrator Costle (see Appendix B), provides for a continuing
working relationship between the two agencies to:
1. Cooperate in establishing processes for coordinating activities and
communications.
2. Encourage, guide and coordinate individual agencies of the DOA and
regional offices and research laboratories of EPA in developing working
arrangements for joint program efforts. •
3. Encourage and direct programs and activities toward balanced improve-
ment and maintenance of the quality of the Nation's natural resources
and environment.
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4. Encourage dialogue and exchange of information and program development
including cooperative undertakings.
On February 14, 1979, EPA Deputy Administrator Blum and Forest Service Chief
McGuire signed an agreement committing both agencies to cooperate in achieving
water quality protection. As part of the FS-EPA Water Quality Agreement, EPA
is participating in a multi-year review of the implementation of the newly re-
vised Land Management Planning Regulations. This review will include both the
implementation of the new Forest Land management planning process and the co-
ordination of this process with related EPA procedures. As a result of this
effort, recommendations will be made to the FS to improve the land management
planning process, so that it will better protect the environment. Similarly,
recommendations will be made to EPA to improve EPA coordination with the land
management plan, its review and implementation. The user should be alert for
new technical guidance, policies or procedures for EPA involvement in the planning
process that may be forthcoming from EPA/FS coordination.
Further, as a result of 1978 amendments to the Clean Water Act, (CWA), the so-
called "Culver Amendments" to the CWA, and subsequent funding in 1979, the Rural
Clean Water Program has developed. As part of these later two agreements, the
Forest Service is actively promoting the implementation of silvicultural Best
Management Practices (BMP).
Further, under provisions of amendments to NEPA in 19 , EPA and its Office of
Environmental Review was designated as the'agency for officially filing EISs.
The 309 review conducted by EPA includes two specific subcomponents. The first
is a review of the quality of the environmental assessment included in the draft
EIS filed with EPA. Second, a review and evaluation is prepared which indicates
the relative severity of the likely impact upon the environment. (See Table 2
in" the following chapter).
Because the 309 Review Manual does not provide guidance for applying the Section
309 review process to specific types of projects, the Office of Environmental
Review, in conjunction with the EPA program and regional offices, has prepared
a series of detailed review guidelines for several major project categories.
As one of the documents in that series, this manual provides detailed guidance
for applying the EPA NEPA review process to Forest Service land management plans
and related actions. Chapter II of this manual further expands upon the guidance
for implementing the EPA policy described above. Chapter III provides a synthe-
sis of the possible impacts associated with a variety of forms of national forest
management and land use. Information on the analysis and assessment of such im-
pacts is also presented. A reference bibliography is provided to permit the re-
viewer to explore specific problem areas in greater depth.
This manual has been developed principally to aid in reviewing environmental
impact statements prepared for forest land and resource management plans at
the national forest level. However, other related land management planning
activities of the Forest Service at the regional and national levels are closely
related to forest planning, differing mainly in geographic scope, specificity
and amount of detail. Therefore, the guidelines can also serve as a means to
understand and evaluate the environmental and other issues associated with the
development and implementation of such plans.
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How this manual can be used depends on several factors. Important among these
is the level of familiarity of the user with the Forest Service planning and
the environmental impacts that may result from plan implementation. Table 1 on
the following page poses a series of questions representing steps in the environ-
mental assessment process. It identifies specific sections in parentheses which
provide guidance on each of the topics.
I^J3. A Perspective on Forest Service Planning
The scope and intensity of land and resource planning by the Forest Service
have been increasing. The increase has generally corresponded with and in-
deed been stimulated by, first, the rising demands for goods and services from
the national forests and, more recently, continued demands coupled with in-
creasing scarcity of resources and greater conflicts among resource uses. Ad-
ministration policy directives to the Forest Service and legislative requirements
and directions from Congress have been increasing. What has resulted is a na-
tional Forest System which is constantly undergoing adjustments in response to
the dynamic nature of the forest land resource, the competing demands for various
uses, and occasional erratic political pressures which reflect public needs and
desires.
Early Planning^
In the early years of this century national forest planning and use were di-
rected primarily to local needs. Pressures on the land were slight and activi-
ties were decentralized without a great need for overall national coordination
and policy direction. As the importance of national forest renewable resources
to the national interest became more evident by the late 1930's, Forest Service
policies focused on more intensive resource management.
Multiple Use - Sustained Yield Act
Although not formalized in legislation until I960, the concepts of multiple use
and sustained yield generally guided the Forest Service's management programs
in the 1940's and 1950's. The Multiple Use - Sustained Yield Act of 1960, P.L.
86-517, set forth the basic policy for management of all national forest re-
sources: that the national forests be managed for multiple use and sustained
yield of products and services, with no one use predominating to the exclusion
of other uses. Uses specifically mentioned in the Act are outdoor recreation,
range, timber, watershed, and wildlife and fish. After passage of this act the
Forest Service set up a process of "multiple use planning" under which separate
multiple use plans were prepared for each National Forest Ranger District. At
the National Forest level, resource development plans established the goals and
objectives to be addressed in the Ranger District plans. This planning process
continued until shortly after passage of the National Environmental Policy Act
of 1969 (NEPA).
In the early 1970's Ranger District multiple-use plans were replaced by con-
siderably more detailed land management "unit plans" which apply to geographic
areas with similar resources and characteristics rather than to Ranger Districts.
All unit plans were accompanied by and integrated with EISs which served as the
analytic frame for comparing and evaluating the various components of land
management unit plans. Also in the early 1970's the Forest Service undertook
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Table 1: Organization and Use of Guidelines
Topic
Concerns
Pages
Forest
Service
Planning
Process
Forest
Service
Activities
Initiating the
EIS Process
Review of
Draft EIS
Identification
of Impacts
Quantification
of Impacts
Assessment of
Impacts
EIS rating
How did the present process develop? (I.B.)
What are the levels of planning? (I.C.)
What is the nature of the process? (I.D.)
What environmentally related actions
are undertaken by the Forest Service? (I.E.)
What are the first steps in the
EIS/NEPA process? (II.A,B)
What standards, criteria, and regulations
need to be considered in relation to
Forest Service activities? (II.D)
4
7
9
11
18-19
What is the purpose of the proposed
action? (II .C.I.)
What are the alternatives that should
be considered? (II.C.2)
What is the nature of the affected
environment? (II.C.3)
What is the nature of the environmental
consequences? (II.C-4)
What kinds of impacts are associated with
Forest Service actions? Have they been
identified in the EIS?
What information is required to properly
evaluate the impacts?
What techniques are appropriate for
quantifying the impacts?
What mitigation measures are applicable
to reducing the impacts?
How should the reviewer judge the signifi-
cance of impacts?
(III. A.I)
(III. B.I)
(III. C.I)
(III. D.I)
(III. E.I)
(III. A. 2)
(III.B.2)
(III.C.2)
(III.D.2)
(III.E.2)
(III.A.3J
(III.B.3)
(III.C.3)
(III.D.3)
(III.E.3)
21
22
25
26
33
67
69
73
74
38
67
70
73
75
64
68
71
74
76
28
On what should the EIS rating be based?
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nationwide inventories and assessments of National Forest resources, including
timber, rangelands and roadless areas. These and other studies formed the basis
for a comprehensive plan, Environmental Program for the Future, which covered
all Forest Service activities for the decade 1975-1984.The draft of the plan
was issued in June 1974 just before Congress passed the Forest and Rangeland Re-
newable Resources Planning Act (RPA).
Resources Planning Act
The RPA was a response to the recognition by the Forest Service, Congress and
others of the need for a long-term national program and policies for management
of the. National Forest lands and renewable resources, especially with regard to
the supply and demand for such resources which reflected the national interest,
as interpreted by Congress as well as the administration. For the first time,
the specific management of the national Forest System was subject to congressional
approval. The President and the Forest Service no longer have independent authori-
ty to manage the resources of the National Forest System.*
In terms of land management planning for units of the National Forest System,
RPA had little effect on existing procedures but made land and resource manage-
ment plans a legal requirement and called for a systematic, interdisciplinary
approach in their development. The heart of the RPA is the requirement that
the Secretary of Agriculture prepare a Renewable Resource Assessment and a
Renewable Resource Program for the national forests and rangelands. The first
Assessment and Program documents were prepared in 1975, and updated documents
submitted to Congress in 1980. Thereafter, revisions are required every ten
years for the Assessment and every five years for the Program. In addition, the
RPA requires that a Report of Nation's Renewable Resources, including both pri-
vate and non-private resources be made.
The Assessment is to include as a minimum:
(1) an analysis of present and anticipated uses, demand for, and
supply of the renewable resources, with consideration of the interna-
tional resource situation, and an emphasis of pertinent supply and
demand and price relationship trends;
(2) an inventory, based on information developed by the Forest Service
and other Federal agencies, of present and potential renewable re-
sources, and an evaluation of opportunities for improving their yield
of tangible and intangible goods and services, together with esti-
mates of investment costs and direct and indirect returns to the
Federal Government;*
(3) a description of Forest Service programs and responsibilities in re-
search, cooperative programs and management of the National Forest
System, their interrelationships, and the relationship of these pro-
grams and responsibilities to public and private activities; and
*This revolutionary legislation could well be the subject of a historic drama.
The Office of Management § Budget had recommended that President Nixon veto the
RPA, primarily for its incursion into the Executive Authority of the President.
However, the RPA along with OMB's recommendation reached the President's desk
late in the morning of August 13, 1974. Given the flurry of activity associated
with the President's resignation on noon of that day, he did not act on the RPA.
Newly inaugurated President Ford, sensitive to the mood of Congress, disregarded
OMB's recommendation, and signed RPA into law.
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(4) a detailed study of personnel requirements as needed to satisfy exist-
ing and ongoing programs.
The Renewable Resource Program is to provide for the protection, management and
development of the National Forest System in accordance with the Multiple Use -
Sustained Yield Act and NEPA and in relation to the findings of the Assessment.
Contents include but are not limited to:
(1) an inventory of specific needs and opportunities for both public and
private program investments. The inventory shall differentiate be-
tween activities which are of a capital nature and those which are of
an operational nature;
(2) specific identification of Program outputs, results anticipated and
benefits associated with investments in such a manner that the antici-
pated costs can be directly compared with the total related benefits
and direct and indirect returns to the Federal Government;
(3) a discussion of priorities for accomplishment of inventoried Program
opportunities, with specified costs, outputs, results and benefits;
and
(4) a detailed study of personnel requirements as needed to satisfy exist-
ing and ongoing programs.
National Forest Management Act
The National Forest Management Act of 1976 amended RPA to provide more defini-
tive statutory direction for land and resource management planning and to
strengthen public participation in the planning process. The Act also expanded
the scope of issues to be addressed in the Renewable Resource Assessment and
Renewable Resource Program. Section 6 which deals with National Forest System
Resource Planning includes directives for comprehensive multiple-use resource
planning, guidelines for timber harvesting and sales, provisions for public
participation in forest planning and requirements for preparation of regula-
tions that set out the process for developing and revising land management
plans. Land management plans for all units of the National Forest system are
to be completed by 1985 and revised at least every fifteen years. The final
planning regulations and procedures in response to the National Forest Manage-
ment Act were published in the September 17, 1979 Federal Register.
I.C. Forest Service Planning Levels and Relationships
National forest planning is carried out at three levels: national, regional
(9 USFS regions) and designated forest planning area. See Figure 1. The plan-
ning processes set up by the Resources Planning Act as amended require close
coordination among all three planning levels. The Chief of the Forest Service
is responsible for developing the Renewable Resource Assessment and Renewable
Resource Program required by RPA. These documents provide service-wide goals,
objectives and policies for national forest management. These documents are
also closely related to specific forest units. They are based on resource in-
formation aggregated and summarized by the regions from individual national
forests and in turn provide goal targets for these forests. The national goals
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11 Northern
21 Rocky Mountain
3. Southwestern
^, Intermountain
5t California
6, Pacific Northwest
8, Southern
9, Eastern
10, Alaska
EPA Region Boundaries
(I - X)
Forest Service
Region Boundaries
(I - 10)
1: Forest Service and EPA Regions
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and objectives, expressed as a range of outputs, are then allocated to the regions
on the basis of supply capabilities and market conditions. The RPA Assessment
was updated in 1979 and will be updated every ten years. The Renewable Resource
Program is to be updated every five years. The Program.contains
all of~the elements required for an environmental impact statement under NEPA,
and is filed as an EIS. Therefore, as part of the forest management and planning
process, the requirements of NEPA must be satisfied (including scoping, circu-
lation and review, etc.)
Each regional forester develops a regional plan which is responsive to the RPA
Program directives. Regional objectives are assigned to designated forest plan-
ning areas based on supply capabilities, socioeconomic assessments, potential
environmental effects, economic efficiency criteria, community stability objectives
and resource management standards and guidelines. An environmental impact state-
ment is prepared as part of the regional plan development or revision process.
The planning regulations require that regional plans be reviewed for possible
amendment in conjunction with the development of the national Assessment and
Program or whenever implemented programs differ significantly from those called
for in the plan. The regional forester is responsible for determining whether
conditions or public demands have changed sufficiently to warrant plan revision.
Regional planning provides a link between Service-wide planning and planning at
the forest level, providing guidelines and direction for land management planning
as well as summarizing local information for input to the national Renewable
Resource Assessment and Program.
Forest land management plans are to be developed for all lands in the National
Forest System. The plans may be prepared for individual national forests, or
a combination or all of the forests within the jurisdiction of a forest super-
visor. Forest plans are to be revised at least every ten years. As with
regional plans, preparation of an environmental impact statement is an integral
part of the forest planning process. National and regional goals, objectives
and management directions guide the development of land management plans, as
do the forest planning criteria set forth in the National Forest Management
Act and planning regulations (33 CFR Part 210).
Certain activities of the Forest Service do not fall into the regional or for-
est planning/EIS process but rather are handled separately in project-specific
or program EISs. For instance, major new recreational developments require de-
tailed environmental impact analyses and preparation of a separate project EIS.
Similarly, certain Forest Service operational programs affecting large areas,
such as pesticide applications to control insect infestations, may be evaluated
in generic EISs covering such programs. Such specific project EISs should, how-
ever, include by reference appropriate analyses prepared as part of generic and
land management plan EISs. These analyses should be summarized and any tierings
with existing environmental analyses indicated during the scoping process.
I.D. Land and Resource Management Planning Process
Because of the newness of the National Forest Management Act and implementing
regulations, their impact on land management planning is not yet strongly evident.
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However, the management plans and EISs developed first in certain "lead forests"
will set precedents for future planning and environmental anal/sis. It is thus
critically important for EPA to conduct thorough, substantive and constructive
reviews of these early EISs.
Forest land and resource management planning and environmental assessment under
NEPA are carried out as a single process. The process consists of a systematic
set of interrelated actions that lead to management direction and fulfillment
of NEPA requirements, incliding:
... Identification and evaluation of public issues, management concerns and
resource use and development opportunities
.. Preparation of planning criteria to guide the planning process and
management direction
.. Direction offered by national and regional forest management directives
and policies, such as RPA
.. Inventory data and information collection
.. Analysis of the management situation by local Forest Service staff.
.. Formulation of alternatives
.. Estimation of effects (including environmental) of implementing al-
ternatives
.. Evaluation of effects of management alternatives
.. Selection of alternative (after publication of draft EIS)
.. Implementation of plan
.. Monitoring and evaluation
Inputs to the land management planning process include public input during the
scoping process for the EIS as well as technical inputs from several sources.
The targets set in the RPA Program for a wide range of commodity and non-commodity
resources and values are allocated to Forest Service regions. Then, the propor-
tions of goods and services assigned to national forests within the Region are
developed in the regional planning process through negotiations with the indivi-
dual forests, considering the cost and environmental impact trade-offs among
all the forests in the Region. In this way the regional plan provides the basic
direction for management planning at the national forest level.
Information and evaluations developed under the RARE II Program (Roadless Area
Review and Evaluation) are also important planning inputs. In RARE II, roadless
areas in the National Forest system have been rated according to their capability
and value for various uses. The basic data and evaluations used in the Forest
Service's Wilderness Area Rating System (WARS) and Development Opportunity Rating
System (DORS) should be incorporated into the land management plan and the plan
should be consistent with the results of such analyses.
EPA's involvement in the Forest Service planning process is important not only
during review of environmental impact statements but also during development
of plans and associated environmental assessments. The first opportunity is at
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the beginning of the planning process when the responsible Forest Service official
and interdisciplinary team are required to meet with representatives of Federal
agencies and other persons to develop procedures for coordination of the planning
effort. The forest planning regulations require additional confer-
ences after public issues and management concerns have been identified, and prior
to recommendation of the selected alternative.
I.E. Forest Service Land Management Activities and Issues
To help the user better understand what to expect to find in a FS land management
plan for activities undertaken on national forests and the environmental impacts
that may result, the principal areas of Forest Service concern are described
briefly. Included below are discussions of timber, recreation, range, fish and
wildlife, watershed and wilderness.
Timber. About 87 million acres of the national forests are classified as commer-
cial forests. While Forest Service land comprises only 18 percent of the total
commercial forest acreage in the U.S., it contains more than 50 percent of the
country's timber inventory. Some segments of the public feel that the cutting
levels established by the Forest Service should be increased mainly for economic
reasons, while others contend that timber removal should be reduced to minimize
adverse environmental, recreational and other impacts. In spite of arguments
both ways, the Forest Service's management of the timber resources is directed
primarily toward even-flow sustained yield of lumber and forest products. This
policy ensures a continuous supply of high quality timber for the future. Be-
cause of the long growth cycles of forests, increases in allowable cut above
the rate of growth for short-term gain effectively reduce future yields of forest
products. However, with amendment to Section 16 of the NFMA and an administration
directive to the FS to consider temporary departures from even flow, problems of
such proposed increased cuts must be reviewed carefully.
Timber management on the national forests involves the questions of not only how
much to cut but also how, when, and where to cut. Moreover, silvicultural prac-
tices for regeneration, thinning and disease and pest control all affect the
decisions made with regard to timber harvesting. Timber cutting often conflicts
in some way with other perceived uses of the national forests but such conflicts
can and should be minimized during development of land management plans. The
diverse resource base necessitates compromise in its use and management.
Of all the uses of national forests, silvicultural activities generally have the
greates.t..potential to adversely impact the environment, both' locally and over
large areas. The principal area of concern is water quality. Solid waste, noise,
air, pesticide and socio-economic impacts are also likely to occur. Water pollu-
tion from forestry activities comes mainly from nonpoint sources; a variety of
management practices, both structural and nonstructural, are thus required to
prevent or reduce water quality degradation. EPA prescribed Best Management Prac-
tices should be considered carefully in such situations.
Site disturbances caused by logging, skidding, logging road construction, heavy
equipment operation, burning, and other silvicultural activities can all lead to
erosion and sediment pollution. Topography, precipitation, soil conditions and
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other factors have a strong influence on sediment generation. Under conditions
of steep slopes, unstable and erodible soils, and heavy rainfall, the risk of
sediment pollution as measured by stream bed sedimentation is high for any site-
disturbing activities. Such factors need to be carefully evaluated for sites
that will be affected by road building, lumbering, and other silvicultural prac-
tices. Of all such factors, road building generally has the greatest impact.
Many of the practices required for timber management on the national forests in-
volve only short-term disruption followed by long periods when no management is
undertaken and ponational output is low. The scheduling of timber-related
activities is also important in the short run, as the potential for water pollu-
tion may vary seasonally with differences in precipitation, runoff, and ground
conditions. A complete evaluation of impacts should include consideration of the
timing of activities in the short term and over the planning period. Special
attention should be given to departures from sustained yield/even flow timber
management under the exemption provisions of Section 16 of the NFMA and the
June 12, 1979 administration directive emphasizing the utilization of the
exemption provision.
Management of residues from timber harvesting, including slash, brush, tree tops ,
and other debris, is a major problem in some national forests. Forest residues
are not solid wastes in the usual sense of residential-type refuse, but some of
the management needs are similar. Volumes can be large and proper disposal can
be important for. aesthetic and water quality reasons. Often an overriding con-
cern in residue management is reducing heavy accumulations of woody debris.
Wildfires can be particularly dangerous, difficult to control and damaging if
they start or spread in areas where sizable volumes of residue exist from thinning
or logging. Under controlled conditions, however, fire can be an effective
management tool for slash disposal and reducing the risk of uncontrollable for-
est fires. If burning in an area is severe enough, considerable quantities of
litter and soil organic matter may be consumed. Erosion may then become a pro-
blem in these areas. Soil disturbances caused by mechanical treatment or piling
of slash may also induce erosion and sedimentation, creating an oxygen demand and
increasing the possibility of channel blockage and erosion. Whenever timber har-
vesting or thinning is proposed, slash will be generated and plans must be for-
mulated for management and disposal of the material in an environmentally accept-
able manner.
Pesticides used in timber management include herbicides, insecticides, fungi-
cides and rodenticides. Herbicides are by far the most widely used in terms of
both quantity and area treated. They are used mainly for suppression of unwanted
vegetation in the preparation of brush fields and cutover areas for reforesta-
tion and for the control of undergrowth and competing species in young stands.
Herbicides and insecticides are applied by aerial and ground methods whereas
aircraft are not generally used for rodenticides and fungicides. With aerial
application, introduction of pesticides to water bodies and drift to nontarget
areas are possible. Special precautions are necessary in planning and carrying
out aerial spraying to minimize such occurrences. On-the-ground methods, in-
cluding hand injection or spraying, use of rodenticides in bait, seed treatment
and others, pose little risk for water quality degradation or environmental damage
due to the small quantities of pesticides used and the high level of control
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possible during application. A few pesticide chemicals tend to bio-accumulate
in the tissues of animals at higher food chain levels, in addition to potential
problems of toxicity and persistence in the environment. Separate EISs are
prepared for proposed major pesticide programs of the Forest Service, although
smaller scale usage of pesticides should be addressed in the land management
plan and EIS.
Recreation. The national forests are an important, valuable and popular recrea-
tion resource for millions of people. The Forest Service provides a variety of
recreational facilities, including 7,000 camp and picnic grounds for accommoda-
tion of half a million people, 1,100 boating and swimming sites, over 1,000 ob-
servation and interpretation sites, and several hundred ski areas. Nevertheless,
activities such as sightseeing, hiking, mountain climbing, hunting and fishing
that require limited or no special facilities account for about 60 percent of
the visitor days spent in the national forests. Usage of the national forests
currently exceeds 200 million visitor days each year.
Water is a focal point for many outdoor recreational activities. The national
forests contain 84,000 miles of fishing rivers and streams and 2.5 million acres
of lake surface in thousands of natural lakes and reservoir impoundments. To
orovide access to the forests, there are more than 200,000 miles of forest high-
fays and development roads and 100,000 miles of trails.
Lapid growth in recreation use has created additional pressure on national forest
resources. Much of the problem centers around distribution of visitation rather
:han total numbers of visitors, especially in regard to wilderness lands. Some
areas are overutilized (often those located near large metropolitan areas} while
others in more remote areas have relatively few visitors.
Not all of the recreational facilities on the national forests are developed and
operated by the Forest Service. For example, most of ski areas, organization
camps, resorts, commercial recreation facilities and other establishments on
national forest lands are privately operated under special use permits issued
by the Forest Service. The Forest Service attempts to retain sufficient adminis-
trative control over facility design, construction and operation so that environ-
mental and other values can be protected. And in the case of major developments,
such as new ski areas, separate EISs are required to ensure a comprehensive
evaluation of potential environmental impacts and measures for mitigation of
impacts.
Much of the recreational activity on national forests causes few if any environ-
mental problems. The potential does exist, however, for adverse impacts in the
areas of water, air, noise and solid wastes. Soil compaction and destruction of
gound cover are common problems at heavily used recreation sites such as picnic
and camp grounds and hiking trails and may cause soil erosion and sedimentation
of nearby streams. These possible impacts can be minimized during the planning
of new recreation facilities by avoiding areas with steep slopes and poor soils.
For existing facilities where erosion1has occurred, remedial measures including
revegetation and installation of drainage and slope stabilization structures may
be necessary. In addition, temporary closure or reduction of use of eroding
areas may need to be considered. Hiking trails and ski areas, because they
frequently traverse steep slopes and potentially unstable soils, are particularly
susceptible to erosion. It is essential that programs for regular maintenance
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and erosion control in such areas are fully addressed in the management plan and
EIS.
Recreational use of national forests is accompanied by generation of solid waste
which must be properly managed to avoid undesirable environmental impacts. The
Forest Service has little direct control over littering and solid waste disposal
outside of established picnic, camping, and other recreational areas where re-
fuse containers can be conveniently maintained and emptied regularly. Provisions
should be made for solid waste storage, collection, and disposal in all areas of
concentrated recreational use.
Off-road vehicle (ORV) usage poses the threat of severe erosion, vegetation
damage, and other environmental degradation unless carefully regulated and moni-
tored. Snowmobiles, motorcycles, and four-wheel drive vehicles are the major
types; the total number in use is estimated to exceed 10 million. Executive
Order 11989 issued in 1977 amends an earlier order (11644) and directs federal
agencies to control the use of off-road vehicles where they have caused or are
likely to cause environmental damage. Controls may include complete prohibition
of ORV use in sensitive environments, restriction of use to designated trails
and restrictions on the time or season of operation. Besides the potential for
physical damage to the environment, off-road vehicles are a source of noise
pollution. Noise probably represents the greatest area of conflict between off-
road recreational vehicle users and other recreationists in the national forests.
Reduction of noise pollution from recreational vehicles can be accomplished
in two ways: (1) limiting noise levels of individual vehicles and (2) segrega-
ting off-road vehicle use geographically from other recreational land uses to
minimize interactions between the potentially conflicting activities. Motor-
ized vehicles are barred from using lands designated as part of the National
Wilderness Preservation System, thus avoiding noise impacts in those areas.
Range. Certain areas of the national forests and national grasslands in the
western United States are open to grazing by domestic livestock. Concern has
been expressed that the low costs of grazing on public lands, consistently
about one-third of the average commercial costs, have led to overgrazing and
environmental deterioration (CEQ, 1978). Grazing can lead to soil compaction,
degradation of herbaceous vegetation, soil erosion, stream sedimentation, and
fecal pollution. There has not been a great deal of research on the nature and
extent of grazing impacts on land and water resources. It is clear, however,
that regular inspection and monitoring of grazing lands for signs of deterio-
ration are important in preventing adverse environmental effects.
Demand for range grazing has grown in recent years and is expected to continue
increasing in the future. Greater use of the national forest lands for grazing
is likely; therefore, management plans need to address the environmental con-
sequences that such increased use would have.
Fish and Wildlife. Management programs for fish and wildlife resources on the
national forests often involve the restoration and enhancement of habitat for
terrestrial and aquatic species. Whereas fish and wildlife management activi-
ties do not in general adversely impact the environment, other national forest
land uses and land management practices are very much interrelated with and
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can affect fish and wildlife resources. What is best for timber production, for
instance, may adversely impact fisheries or wildlife. In managing for multiple
uses, trade-offs and compromises among resources are frequently necessary, and
the broader implications of all activities should be recognized and Balanced in
the land management planning process. Planned actions having potential effects
on fish and wildlife must be coordinated with the Fish and Wildlife Service as
required in the Pish and Wildlife Coordination Act.
Watershed. National forest system lands produce more than one-quarter of the
total amount of water that flows from watersheds throughout the country. Water
from forested watersheds is usually of high quality but can be degraded by both
point and nonpoint pollution from other forest management activities as well as
from sources outside of the national forests. Maintenance of water quality is
an integral part of all Forest Service land management planning. The Environ-
mental Protection Agency is also involved through administration of federal water
pollution control programs. Management and use of the national forests must be
carried out in a manner consistent with national water quality goals and ob-
jectives. Management actions in the national forests should represent Best
Management Practices and serve as a model for similar actions on private lands
under the Rural Clean Water Program, authorized by Section 208 of P.L. 92-500
as amended. Often EPA's responsibilities for water quality in both ground and
surface waters are affected by actions taken in managing the national forests.
Wilderness. The National Wilderness Preservation System, established with pas-
sage of the Wilderness Act of 1964, presently includes 16.5 million acres of
public lands. The potential exists for considerable expansion of the system in
the future. The Forest Service has developed an inventory of national forest
lands for consideration for wilderness. The inventory, known as RARE II (Road-
less Area Review and Evaluation) follows an earlier review (RARE I) and deter-
mines which areas to propose for wilderness and nonwilderness uses and which
need further study before determinations can be made.
Visitation to wilderness areas has grown rapidly in recent years. Backpacking
is the most popular of wilderness activities and, in some wilderness areas re-
ceiving heavy use, has contributed to soil erosion along trails and other ad-
verse effects. As more and more people use wilderness areas and the reduction
of de facto wilderness areas continue, the potential for environmental degrada-
tion will increase. Means for identifying environmental problems and carrying
out needed maintenance should be addressed in management planning for wilder-
ness areas.
Other National Forest Resources. National forests contain large economically
recoverable deposits of mineral and energy resources. A substantial portion of
these resources lies in a mineral-rich belt extending from North Dakota to south-
ern Arizona.
Mineral and energy resource extraction on national forest lands is an important
enterprise. Major known resources on the national forests include phosphate,
coal, oil shale, oil, gas, uranium, copper, nickel, lead and geothermal energy.
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Most of these lands are open for mineral extraction and development. However,
the Forest Service has no direct responsibility in the control, development, and
leasing of mineral rights on the national forests. Such authority belongs to
the Secretary of the Interior. Currently, hard rock mining on federally owned
lands is goverened by provisions of the 1872 Mining Law, which allows miners to
enter federal lands without a permit or license, claim any marketable body of
ore, sell it without paying royalty and take title to the land itself where a
valuable mineral deposit exists. The lack of clear authority to protect these
lands creates the potential for environmental damage. Reforms of the mining law
have been proposed by the Administration but not yet passed.
Although the Forest Service is not directly involved in mining issues, the en-
vironmental effects that may result are important in overall forest management.
As mineral and energy deposits become increasingly scarce, pressure to accelerate
mineral extraction from national forests is likely. The need for effective en-
vironmental controls will also increase.
Issues
The complexities inherent in the management of national forests for multiple
uses are reflected in a number of difficult issues facing the Forest Service
and other Federal agencies. Many of these issues concern EPA in view of its
responsibilities for environmental protection. The Forest Service's 1980 RPA
Program discusses fifteen significant overall issues, a few of which are high-
lighted in the following paragraphs.
Level of production of wood and wood products from National Forest System Lands.
Timber harvesting must be carried out in conformance with statutory constraints,
such as those specifying sustained yield and even flow management. Increases
in timber harvesting, whether through more intensive management, accelerated
cutting of old growth timber or departures from sustained yield, almost cer-
tainly necessitate trade-offs with respect to nontimber outputs and environ-
mental impacts. In some cases creation of new access roads would be essen-
tial to permit increased harvesting levels. Socioeconomic and environmental
effects of increased harvesting must be analyzed over both the short and long
terms. There is strong public opposition in many areas to any deviations from
the policy of nondeclining even-flow management.
Wood fiber as an energy source. In many parts of the country public pressure
to have access to National Forest lands for firewood is increasing dramatically.
-This—p-re-s-sur-e— is—panicjilarly strong in northern areas in New England, the Great
Lakes and the Northwest7 Adminis-tra.tion_of xordwood programs is difficult but
proper supervision is necessary to ensure that concomitant silvicultural bene-
fits are realized (through selectively culling dead and inferior trees, thinning
etc.) and environmental impacts are minimized. Localized air pollution problems
from wood burning could result from such Forest Service actions.
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Herbicides and Pesticides in National Forest System Management. Possible long-
term and secondary effects of pesticides are not well understood. Herbicides
to control undesirable vegetation are often less costly than alternative non-
chemical methods. Pesticides currently available may not be the best way to
control insect infestations, but nonchemical methods often are not equally as
effective. Options include continuing use of registered pesticides after care-
ful environmental review, restricting use to only certain limited critical
areas, discontinuance and research to develop nonchemical controls.
The user should try to keep informed of substantive forest management issues
in his/her region and expect them to be addressed in the management plan and EIS.
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II. LAND MANAGEMENT PLAN REVIEW
As described in the 309 Review Manual, the EPA EIS review process consists of
pre-EIS activities, scoping, review of draft EISs, pre-final EIS liaison, re-
view of final EISS and post-EIS follow-up. While it is recognized that unique
situations within each region may dictate emphasis on one phase of the review
process over another, all phases should be conducted to the fullest extent
allowed by the region's resources.
The goal of the review process is to maximize the effectiveness of EPA in-
volvement in management planning for national forest lands. Generally, this
goal is accomplished when the EPA involvement: (1) reflects the total environ*
mental responsibilities of EPA; (2) is part of a continuing working relation-
ship with the Forest Service to improve national forest land use and manage-
ment in accord with environmental quality objectives; (3) focuses sharply on
environmentally unsatisfactory actions; (4) lends EPA support to management
decisions having beneficial impacts on the environment; and (5) produces review
responses which are expressed in constructive language, pointing out specific
environmental problems and possible ways of avoiding or mitigating those prob*
lems.
II.A. Pre-EIS Activity
Pre-EIS activity is extremely important in preventing potential environmental
problems from occurring. It is at the very earl); pre-EIS stages of project
development that environmental problems are most accessible to EPA-recommended
mitigation measures. Similarly, the consideration of project alternatives is
most open when done early in the planning process, before any single alterna-
tive is essentially selected and defended by project planners. The EIS re-
view function is one of the few agency programs by which EPA practices pre-
vention and proactive involvement rather than abatement of environmental
problems and reactive involvement. To secure the greatest benefit from this
program, effective Pre-EIS liaison is essential.
"Pre-EIS activity" includes pre-EIS coordination within EPA as well as coor-
dination and information exchanges with Federal, State, and local agencies
responsible for project planning or licensing. Pre-EIS activity within
EPA involves the coordination of EIS review with other EPA actions which may
affect or be affected by Forest Service land use and management decisions such
as discharge permits (NPDES), review of 404 permits, non-point source manage-
ment under Sections 208 and 303, Federal facilities pollution control under
Section 313 and solid waste management at Federal facilities under Section 211
of the Solid Waste Disposal Act as amended. Additionally, EPA positions ex-
pressed previously as might be contained in reviews of earlier EISs (on pesti-
cide programs, for example), congressional correspondence, or other agency
statements, must be considered in developing a consistent EPA position. Further,
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the priority environmental problems identified by the state's governor as part
of the State-EPA Agreement should be considered in evaluating Forest Service
land management plans.
External pre.EIS activity includes a wide range of activities outlined in the
309 Review Manual: (1) review of an applicant's environmental report or agen-
cy pre-draft EISs; (2) review of negative declarations; (3) participation
at agency meetings describing the project; (4) substantive discussions with
agency officials responsible for a proposed action, with emphasis on alterna-
tive mitigation measures; (5) provision of background materials for use in
developing the EISsj (6) review of basin plans (Level B studies); (7) site
visits. In order to fully realize such opportunities for pre-EIS liaison it
is important that EIS Coordinators maintain frequent and regular contact with
appropriate personnel at the Forest Service regional and national forest levels.
EIS Coordinators should understand planning processes and associated outputs
that might be useful in determining an early environmental assessment of de-
veloping land management plans.
In several technical areas — for instance, water quality management and pes-
ticides — the responsibilities and interests of the EPA and the Forest Ser-
vice intersect. The two agencies cooperate informally, and formally through
Inter-agency Agreements, in technical studies dealing with the identification
and control of nonpoint sources of water pollution from silvicultural activi-
ties, development and implementation of best management practices for silvicul-
tural nonpoint sources and pesticide use and management. As a result of this
cooperation there is general agreement between the Forest Service and EPA on
the state of the art of management strategies for forest-related nonpoint source
water pollution. Regional differences in the nature of forest management activi-
ties, physical and biological characteristics of forests, hydrology and other
factors still necessitate site-specific evaluations of pollution potential
and methods for minimizing adverse impacts. Nevertheless, the reviewer should
be aware of the cooperative efforts being made for more effective environmen-
tal management of the national forests. Several of the publications described
in the appended Reference Bibliography represent joint involvement of both
the Forest Service and the EPA. Such documents provide the reviewer with
technical information of value in guiding EPA's early participation in the
forest planning process before an EIS is prepared.
II.E. Initiating the EIS/NEPA Process
I
The CEQ regulations for implementing the procedural provisions of NEPA
(40 CFR 1500), published in the November 29, 1978 Federal Register, emphasize
agency cooperation early in the NEPA process. Specifically, the EPA or any
Federal agency having special expertise with any environmental issues posed
by a project may request or be asked by the lead agency to be a "cooperating
agency". The regulations require each cooperating agency to (a) participate
in the NEPA process at the earliest possible time, (b) participate in the
scoping process and (c) assist at the lead agency's request in developing en-
vironmental information and preparing environmental analyses relating to
areas in which the cooperating agency has special expertise.
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"Scoping", as defined in the CEQ regulations, is an early and open process
for determining the scope of issues to be addressed and for identifying sig-
nificant issues.related to a proposed action. Scoping also involves identi-
fying and eliminating from detailed study issues which are not significant or
which have been covered by prior environmental review. The NEPA regulations
encourage "tiering" of EISs to eliminate repetitive discussions of the same
issues. Tiering refers to the coverage of general matters in broader environ-
mental impact statements (such as Forest Service program or plan statements
at the national or regional level) with subsequent narrower statements (such
as statements for individual forest land management plans) incorporating by
reference the general discussions and concentrating solely on the issues
specific to the statement subsequently prepared. As part of the scoping pro-
cess issues that have been adequately addressed in earlier, broader EISs
should be eliminated from detailed study. They must, however, be summarized
in the narrower EIS and appropriately referenced.
Other material may also be incorporated by reference into an EIS for a land
management plan, with the purpose of reducing bulk and repetition without
impeding review of the action. The material could include EISs prepared for
a specific action affecting the national forest, such as a major new recrea-
tional facility or large scale pesticide applications, as well as other data
or studies pertinent to evaluation of impacts of the land management plan.
Attention should be given in the scoping process to material that will be
incorporated into an EIS in this manner.
By participating in the scoping process, EPA can ensure that important con-
cerns of water, air, solid waste, pesticides and other impact areas will
be identified at an early stage and addressed in the EIS. This early involve-
ment can contribute to resolving major environmental issues before the EIS
is prepared and avoid or minimize problems later during EPA's review of the
Draft EIS.
II.C. Review of the Draft EIS
EPA's purpose in review of the EIS is to ensure that proposed Federal actions
are consistent with the attainment of national environmental goals and policies.
The Administrator has specific responsibilities under Section 309 of the Clean
Air Act to review proposed Federal actions and, to determine if any such action
is unsatisfactory from the standpoint of public health, welfare, or environmen-
tal quality, to publish this determination and refer the matter to the Council
on Environmental Quality.
In order to carry out these objectives, it is essential that the EPA reviewer
assess the impacts related to air, water, noise, solid waste management and
other environmental areas within EPA's jurisdiction. Review of the EIS must
indicate whether the document adequately identifies, quantifies and evaluates
the impacts associated with implementation of the proposed Plan and various
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alternatives to it. EPA's EIS review responsibilities are substantive and not
limited to critiquing the way in which the EIS is organized or written. How-
ever, the ability of the EIS to be understood and its availability by the
public are concerns which can be addressed in the review by EPA. The EIS is
to "provide full and fair discussion of significant environmental impacts and
shall inform decision-makers and the public of the reasonable alternatives which
would avoid or minimize adverse impacts or enhance the quality of the human en-
vironment. Statements shall be concise, clear, and to the point, and shall
be supported by evidence that the agency has made the necessary environmental
analyses." (40 CFR 1502.1). Similarly, EPA's comments on an EIS should be as
specific as possible in identifying adequacy of the statement, merit of the
alternatives and need for additional information.
The EIS format recommended in the new CEQ Regulations includes four major
sections dealing with: (1) purpose and need for proposed action, (2) al-
ternatives, (3) affected environment, and (4) environmental consequences.
Guidance for reviewing each of these topics in Forest Service land management
plan EISs follows.
II.C.I. Purpose and Need
The use and management of the national forests serve multiple purposes and
needs, ranging from commodity items such as lumber and minerals to non-commodity
items such as wilderness recreation experience. Although land and resource
management generally implies some sort of action or activity, it may also in-
volve the choice of doing little or nothing in an area which does not need
improvement. For example, dispersed recreational use may not involve any
specific action.
A primary purpose of land management plans is to provide for multiple use
and sustained yield of the commodity and non-commodity values provided by the
resources af the national forests in accordance with the Multiple-Use Sus-
tained-Yield Act of 1960. The mix of uses that can be supported is unique
for every national forest because of the diversity of physical features, loca-
tion, climate, vegetation, population, economic and other factors. ' Thus, al-
though the same planning and evaluation methodologies can be applied in a
general way throughout the national forest system, the resulting plans are
specific to the particular resources, conditions, needs and problems of in-
dividual planning units.
The EIS should provide a clear understanding of the needs, in terms of both
commodity and non-commodity values that national forest land management is
intended to meet. Although management decisions are generally governed by
Forest Service policies specified in legislation and regulations, there is
considerable flexibility at the local level to tailor specific management
programs to meet the perceived needs within the constraints of the land's
capability to meet those needs. The EIS should also distinguish among alter-
native management plans with respect to the types and degrees of benefits
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they would provide. They should also indicate the trade-offs that would be
made to satisfy various needs. When this has been done accurately and com-
parably for the available alternatives, the environmental impacts can be
evaluated relative to other benefits and costs of alternative land manage-
ment plans.
II.C.2.' Alternatives Including the Proposed Action
As stated in the CEQ § FS Regulations, this section is the heart of the environ-
mental impact statement. Environmental impacts of the proposal and alternatives
should, be presented in comparative form to define the issues and trade-offs and
provide a clear basis for choice among the alternatives. Impacts should be
described quantitatively if possible or qualitatively in such a manner as to
illustrate the differences and related impacts, along with the relative mag-
nitude of such impacts for the alternatives that are considered.
Alternatives generally involve how, where and when various management prac-
tices are implemented to meet multiple use and sustained yield objectives and
at the same time satisfy environmental quality objectives. The many differ-
ent resource values and land uses possible in managing Forest Service lands,
present a wide range of alternative management approaches.
Management for diverse uses can be complicated, and intensive management for
one purpose may reduce or preclude other land use opportunities in an area.
For each alternative considered in an EIS, the contributions to a particular
management objective and the implications for other land uses as well as the
environmental effects must be presented to permit evaluation of their compara-
tive impact. Also, the Forest Service's rules for national forest system land
and resource management planning (36 CFR 219.5(h)) state that at least one
alternative must be identified as environmentally preferable. The range of
alternatives presented should include a reasonable range of practical alter-
natives which consider various combinations of possible subcomponents. These
should include a wider range than "all development", "no development" and
i'a balanced approach."
EPA's review of alternatives should compare the plan components, such as the
various options for timber or recreation management, as well as the integrated
land management plans and associated impacts. Such plan components which are gen-
erally applicable to forest management activities and which should usually be
considered in detail in the EIS comparison of alternatives include:
Timber Management Alternatives
- Method of harvesting, including clearcutting, shelterwood, seed-tree
and selection methods. The cutting alternatives result in differing
levels of site disturbance. Choices may also be made in the size of
individual cutting areas.
- Method of logging. Options may include tractors, various cable systems,
or aerial logging, each having different pollution potential. Require-
ments for logging road layout and density differ for the various logging
systems.
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- Timing. Weather, soil, and atmospheric conditions can strongly influ-
ence the potential for adverse environmental impacts from timber manage-
ment activities. Seasonal or even daily variations in these factors may
need to be considered in scheduling logging, road or other construction,
burning and related activities in order to reduce pollution hazards.
- Location. Options normally exist for the choice of road locations and
areas that will be harvested or subjected to other silvicultural treat-
ments. Location decisions should be made with a view toward avoiding
sites where disturbances would cause or contribute to erosion, water
pollution, and other environmental problems. Alternative locations for
some management practices, such as pesticide applications to control
widespread insect infestations, are limited.
- Pesticides. Pesticide alternatives include the type of chemical, sub-
stitution of other controls, and the rates and methods of application
employed. "Integrated pest management" (IPM) approaches involving com-
binations of biological, chemical, cultural and other methods are be-
ing developed for forestry and may reduce pesticide usage in certain
situations.
- Residue management. Alternatives include do nothing, prescribed burn-
ing (several methods), mechanical treatment such as chipping, crushing
or rearranging and leaving the debris, all with differing potentials
for air and water pollution.
- Road Building. Road alternatives relate to density, location, design,
construction and pollution control methods, maintenance and other factors
which need to be evaluated in the context of site conditions, access re-
quirements and other uses served by the forest lands. A further con-
sideration is the secondary impact which will likely occur as access
permits new uses. •
- No action. The option of not carrying out timber management activities
has to be evaluated, and may be the most desirable approach in areas
having steep slopes, unstable soils, unique biota or other environmen-
tally sensitive features. The EIS must clearly define "no action,"
whether it represents no change from present conditions or continuation
of present management programs.
Recreational Alternatives
- Location. Location alternatives for recreational facilities, particular-
ly those sustaining heavy, concentrated use, should be considered in the
EIS. Soil conditions, topography, proximity to environmentally sensitive
areas and other site characteristics all affect land suitability for
recreational development and the potential for pollution. Recreational
alternatives should be consistent with RARE II evaluations for particular
areas.
- Scale of development. The potential for adverse environmental impacts
increases with the scale of recreational development and use in an area.
The size and capacity of proposed recreational developments should be
based not only on projected needs in the region but also on the capabil-
ity of land and water resources to support varying levels of use.
- Types of recreation. Recreational activities on national forest lands
are many and varied, ranging from low density to high density uses with
facility requirements ranging from essentially none to quite elaborate
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developments for specialized uses such as skiing. Generally, though not
always, lower density uses requiring few or no facilities cause less
environmental impact than higher density uses.
No Action. The consequences of foregoing development and management
for particular recreational uses must be addressed along with the devel-
opment alternatives in order to permit comparative evaluations of impacts,
Range Alternatives
Management systems. A variety of grazing systems can be used to regu-
late intensity of use, involving seasonal grazing, rest periods and rota-
tion arrangements. Structural measures can also be used to mitigate
adverse grazing impacts. These include fencing and providing water
supplies away from streams and other measures. Erosion and other impacts
are usually associated with overgrazing in an area, as well as animal
waste runoff.
Soil treatment. Furrowing, trenching, pitting, waterspreading and reten-
tion basins are alternatives for increasing infiltration capacity and
reducing erosion and sedimentation from range lands. The need for and
applicability of such methods depend on the specific characteristics
of individual areas.
Vegetation management alternatives. These may include seeding to es-
tablish or re-establish desirable herbaceous species, fertilization,
burning and other practices.
No action. Properly managed grazing can actually result in beneficial
effects in terms of stimulating denser, more vigorous vegetative cover
and minimizing soil losses. The consequences of closing areas to
grazing as well as foregoing any management activities should be evalua-
ted.
Fish and Wildlife Alternatives
- Selected species. Management is generally tailored to the habitat re-
quirements of certain species of fish or wildlife. Habitat modifications
are likely to benefit other wildlife as well, but may also be detrimental
to species having different needs.
- Structural measures. Management of the aquatic habitat may involve con-
struction of small impoundments, flow retarding structures, devices for
water level regulation and other facilities. Hydrologic and other
modifications brought about by impoundments can impact on surface water
quality.
- Mitigation. Protection is often necessary for some species which may
suffer adverse impacts as a result of forest management actions. Many
actions can be recommended or required in the forest management program
which could benefit fish and wildlife. Such mitigation measures are
often developed through negotiation and consultation with the Pish and
Wildlife Service through the Fish § Wildlife Coordination Act procedures.
The results of such consultation should be included in the plan and BIS.
- No action. Although most fish and wildlife management activities will
produce beneficial environmental effects, the alternative of no action
must also be considered.
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Watershed Management Alternatives
Watershed management is an integral part of other Forest Service management
activities. The quantity and quality of water supplied as surface runoff from
the national forests are affected by the ways in which silvicultural and other
management practices are carried out. Whereas most management activities
and land uses may affect water quality, timber harvesting, particularly clear-
cutting, may also result in increases in the rate and total volume of runoff
from a watershed. Although such effects decrease with time as new vegetation
becomes established, consideration must be given to the possible impacts on
stream flows and flood potential.
Special or Critical Areas or Resource Management Alternatives
Management alternatives for wilderness, wetlands, floodplains, endangered or
threatened species habitat and other critical areas should be oriented toward
protection and conservation rather than development and intensive use. Such
areas are by their nature especially vulnerable to disturbances from human
activity. 'The supply of de facto wilderness as well as other critical areas
nationwide is shrinking, and management alternatives of limited scope and
impact deserve consideration in such areas. Of primary importance is the
monitoring of use levels and environmental conditions to prevent damage to
vegetation, erosion, water pollution and other deterioration.
Socio-Economrc Alternatives
In some areas of the country, most notably the Pacific Northwest and Rocky
Mountain states, the national forests have important and sometimes predomi-
nant influence on local and regional economies. Alternatives for timber har-
vesting, recreation and other programs can have economic consequences which
vary according to the emphasis given to the programs. Occasions may arise
where, for example, short-term departures from sustained yield effect signifi-
cant socio-economic benefits to depressed wood processing industries in an
area. It is important that the socio-economic implications, both favorable
and adverse, of management alternatives are pointed out in the EIS. At
the same time, the EIS should identify any environmental trade-offs associated
with departures from sustained yield of both products and services.
II.C.3. Affected Environment
This section of the EIS should contain descriptions of the environment of the
area to be affected by the components of the plan alternatives under considera-
tion. The data and analyses should not include extraneous material that is
not relevant to important impacts and issues, and should include all of the
concerns identified in the scope of the EIS. The characteristics of land
and water resources included in the area strongly influence the nature and
magnitude of impacts associated with forest land management and use alternatives.
The physical and other features need to be described sufficiently to understand
the similarities and differences in environmental conditions from one area to
another within the planning unit. Also, descriptions should be thorough
enough to permit identification and evaluation of sensitive areas which are
susceptible to the effects of pollution or hazardous areas which are apt to
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contribute to the generation of pollutants if disturbed. A number of critical
areas,including wetlands, floodplains, historic sites, wilderness, wild and
scenic rivers and rare and endangered species, are subject to special pro-
tection procedures set forth in national policy, legislation and regulations.
The EIS must address such critical areas and demonstrate that land management
planning actions will meet the requirements of those special protection pro-
cedures. Information on the affected environment basic to impact assessment
includes:
- Socio-economic considerations
- Topography, including slope lengths, steepness, aspect and elevation
- Soil properties, such as permeability, texture and susceptibility to
erosion
- Precipitation amounts, intensity and seasonal variation
- Vegetative cover
- Stream flow and variations
- Nature of stream beds and banks
- Existing water quality in relation to applicable water quality standards,
stream classifications and uses
- Point and nonpoint sources of pollution
- Stream biota including rare or endangered species and sensitive species
- Wetlands
- Floodplains
- Unique/fragile resources (endangered species, historic sites, scenic and
wild rivers etc.)
Information describing the affected environment has two basic uses. First,
it may be necessary in determining the likelihood and quantifying the impacts
in a given area as a result of certain management activities. For example,
clear-cutting timber in a generally flat and level area is not likely to in-
duce significant erosion or soil movement problems, whereas the same activity
in steep, mountainous terrain presents a much higher risk of erosion and
sedimentation. Second, information describing the affected environment is
needed to characterize the relative significance of environmental impacts
generated by forest management activities. For in-
stance, introduction of sediment or other pollutants to a stream supporting
anadromous fisheries, or species that are rare or endangered may be of more
critical concern than the comparable water quality effects in a watercourse
not having these special characteristics. Also, a good understanding of
baseline environmental conditions is essential for monitoring changes and
impacts resulting from ongoing management activities.
II.C.4. Environmental Consequences
The environmental consequences section of the EIS should form the scientific
and analytic basis to compare alternatives including the proposed action.
In this section, discussions of the elements required by NEPA should be pre-
sented. These include the sections dealing with environmental impacts,
adverse environmental effects which cannot be avoided, relationship between
short-term uses of man's environment and maintenance and enhancement of long-
term productivity and irreversible or irretrievable commitments of resources.
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Both direct and indirect environmental impacts must be considered, as well
as possible conflicts between the proposed action and objectives of land use
plans, policies and controls for the area concerned, energy and resource re-
quirements and conservation potential and means to mitigate adverse environ-
mental effects.
Review of probable impacts should include evaluations that all potentially
significant impacts have been identified, adequately quantified (within the
limits of state-of-the-art techniques and commensurate with the expected
severity of the impact), and measured against applicable standards, criteria
and regulations. The identification of potential impacts should be based on
adequate descriptions of proposed activities, characteristics of the affected
environment and their relationships. The reviewer should particularly eval-
uate whether sufficient information is presented to identify all potentially
affected sensitive areas and areas highly susceptible to erosion or other
problems.
Many of the impacts of Forest Service activities, especially nonpoint source
air and water pollution, are difficult or impossible to predict quantitative-
ly. However, this does not mean that certain impacts cannot be evaluated.
Adverse effects from a given activity may differ in severity from one area
to another depending on the presence of critical fish and wildlife habitats,
for example, or differing vulnerabilities of the areas to erosion induced
by site disturbances. Again, site-specific information in conducting impact
evaluations, either quantitative or qualitative, is important.
•
Mitigation measures for both the prevention and reduction of adverse impacts
are essential for minimizing the impacts of Forest Service management activi-
ties. Most mitigating techniques involve management practices for dealing
with nonpoint sources of water pollution, qareful planning of how, when and
where various activities are carried out is the key to effective mitigation.
The discussion of environmental consequences must also cover the mitigating
measures that are necessary to reduce the probable impacts. Mitigation
measures are appropriate wherever site conditions indicate a high probability
of erosion or other impacts and where special fish, wildlife or other re-
source values could be adversely affected. Also, mitigation measures should
be representative of best management practices to conform with areawide water
quality goals set forth in state or areawide water quality management plans.
The information in Chapter III of these guidelines identifies the range of
water, solid waste, air, noise and pesticide impacts that may arise from
various Forest Service land management activities. The emphasis is on char-
acterization of the environmental conditions that are likely to contribute
to pollution problems as well as alternative approaches that can be taken
in the location, timing and nature of activities to prevent or mitigate
adverse impacts.
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II.D. Project Rating
The basis for the EPA comments on the environmental impact of land management
plans is quite broad. As stated in the Clean Air Act, Section 309(a), EPA
comments on"...any matter relating to duties and responsibilities granted
pursuant to this Act or other provisions of the authority of the Administrator..."
NEPA, section 102(2) (C) states"...the responsible Federal official shall
consult with and obtain the comments of any federal agency which has jurisdic-
tion by law or special expertise with respect to the environmental impact
involved."
The above mandates have been interpreted to mean that the EPA comments should
be related to the impact of projects on water quality, air quality, solid
waste management, noise, radiation control and pesticide and other toxic sub-
stances use and control. Water quality concerns include protection of bene-
ficial water uses, floodplains and wetlands, aquatic life and habitat and
water-related wildlife. Comments related to land use, terrestrial wildlife,
aesthetics, recreation and other areas must be related to areas of expertise,.
In addition with responsibility for being the official receiver of filed
EISs, EPA has certain specific responsibilities concerning EIS filing pro-
cedures. For example, EPA must be assured that an EIS document is in fact
available to the public before it can officially begin the 90 day review
period for draft EISs, or the 45 day review period for final EISs.
As detailed in the 309 Review Manual, the EPA rating scheme is different for
draft EISs, final EISs and pre-Clean Air Act Amendments EISs. At the draft
stage comments shall be designated by an environmental impact rating of LO
(Lack of Objections), ER (Environmental Reservations) or EU (Environmentally
Unsatisfactory), Category 2 (Insufficient Information), or Category 3 (In-
adequate). See Table 2. Draft EIS comments which the principal reviewer is
contemplating rating EU or 3 must be cleared by OER prior to release. If a
draft EIS is assigned a Category 3, normally no rating will be made on the en-
vironmental impact of the proposed project or action since a basis does not
generally exist on which to make such a determination. When there is a basis
for assessing the environmental impact of a proposed action, such as inde-
pendent documents or on-site surveys, such a rating may be established at the
discretion of the principal reviewer after consultation with OER.
EPA's comments on the draft EIS should be constructive and aid the environmental
decision-making process. Comments should address, as appropriate, environmental
impacts and alternatives that need further discussion and other ways to improve
the EIS.
Also, reasons for assigning a particular rating should be stated with reference to
any laws, regulations, or policies which support EPA!s judgment. The specific basis for
EPA assessment of environmental impacts and rating of the EIS consists of the
standards, criteria, EPA policy decisions and consistency requirements with
other EPA program responsibilities as shown in Table 3 a.
At the final stage, no alpha-numeric designations are made since only the proj-
ect impact is considered and not the completeness of the EIS. The project im-
pact rating assignments for the final EIS consis of: Lack of Objection, En-
vironmental Reservations and Environmentally Unsatisfactory. A rating assign-
ment of Unresponsive Final Impact Statement can be made if the final EIS has
not responded adequately to comments made by EPA on the draft EIS. Such com-
ments may also be offered if new environmental concerns have been brought to
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Table 2: Categozies for Rating EISs
Category 1 (Adequate). The draft EIS adequately sets forth the environmental
impact of the proposed action as well as alternatives reasonably available to
the project or action.
Category 2 (Insufficient Information). EPA believes that the draft EIS does
not contain sufficient information to assess fully the environmental impact of
the proposed action. However, from the information submitted, EPA is able to
make a preliminary determination of the impact on the environment. EPA has
requested that the originator provide the information that was not included in
the draft EIS.
Category 3 (Inadequate). EPA believes that the draft EIS does not adequately
assess the environmental impact of the proposed project or action, or that
the statement inadequately analyzes reasonably available alternatives. EPA
has requested more information and analysis concerning the potential environ-
mental hazards and has asked that substantial revision be made to the draft EIS.
Evaluation of Environmental Impact of Proposed Actions
LO (Lack of Objections). EPA has no objections to the proposed action as
described in the draft EIS or suggests only minor changes in the proposed
action.
ER (Environmental Reservations). EPA has reservations concerning the environ-
mental effects of certain aspects of the proposed action as described in the
draft EIS. EPA believes that further study of suggested alternatives or modi-
fications is required and has asked the originating Federal agency to reassess
these aspects.
EU (Environmentally Unsatisfactory). EPA believes that the proposed action
is unsatisfactory because of its potentially harmful effect on the environ-
ment. Furthermore, EPA believes that the potential safeguards which might be
utilized may not adequately protect the environment from hazards arising from
this action. EPA recommends that alternatives to the action be analyzed fur-
ther (including the possibility of no action at all).
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EPA's attention since the review of the draft EIS and the originating agency
does not adequate!/ evaluate these factors in the final EIS.
Criteria for assigning the Environmental Reservations, Environmentally Unsatis-
factory, or Category 3 rating are given in Table 35. The reviewer should note
that these criteria are intended to be used as guidelines rather than strict
rules. The decision regarding the impact of each land management plan must in-
corporate all the mitigating factors affecting the plan. The sensitivity of the
environment to the changes imposed by implementation of the plan as well as the
effectiveness of mitigation measures must be taken into account.
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TABLE 3A: EpA standards, Criteria and Regulations
Related to Forest Service Land Management
Plans
Standards
--Latest version of primary drinking water standards prepared
by EPA pursuant to the Safe Drinking Water Act (PL 93-523)
--Water Quality: State adopted water quality standards con-
sisting of water quality criteria and plans for the enforce-
ment and implementation as referenced in 40 CFR Part 120.
--Air Quality: National primary and secondary ambient air
quality standards as specified in 40 CFR Part 50
Criteria. Regulations and Policy
--Criteria for Water Quality, Volume I (Proposed) U.S. EPA,
October 1973
--Water Quality Information, Volume II (Proposed), U.S. EPA,
October 1973
--Information on Levels of Environmental Noise Requisite to
Protect Public Health and Welfare with an Adequate Margin
of Safety, U.S. EPA, March 1974
--Regulation for the Disposal and Storage of Pesticides and
Pesticide Containers, 40 CFR Part 165
—EPA Policy to Protect the Nation's Wetlands, Administrator's
.Decision No. 4
--Navigable Water, Procedures and Guidelines for Disposal of
Dredged or Fill Material, 40 CFR Part 230
--Latest regulations prepared by EPA pursuant to Section 1424
(e) of the Safe Drinking Water Act regarding Federal proj-
ects in a recharge area of an aquifer designated as a sole
source aquifer
--Amended FIFRA Act. The Federal Environment Pesticide Control
Act of 1972 (FEPCA)
--Thermal Processing and Land Disposal of Solid Waste Guide-
lines, 40 CFR, Parts 240, 241
Consistency with Other EPA Programs
--Statewide Water Quality Management Plans "208" plans
--Areawide Waste Treatment Management Plans ("208" Plans),
--Water Quality Management Basin Plans (306(e)" plans), 40
—CFR Parr 1.3J..
--National'Pollutant Discharge. Elimination System permits, 40
CFT Part 135
--State Air Implementation Plans, 40 CFR, Parts 50 and 51
--State/EPA Agreement, and identified priority environmental
problems
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Table 5B: Rating Forest Service
Category EU: Environmentally Unsatisfactory
General Criteria (from
509 Review Manual)
a. Where it is highly probable that a
violation of standards will occur.
Federal, State, and local standards
are included; also includes EPA re-
gulations and guidelines
b. Where a Federal agency violates its
own substantive environmental re-
quirements.
c. Where there is a violation of an
EPA policy declaration
d. Where ther are no applicable stand-
ards or where applicable standards
will not be violated but there is
potential for significant and
severe environmental degradation:
1. which could be mitigated by other
feasible alternatives, or
Specific Criteria for
Land Management Plans
.Violations of water quality stand-
ards, including noncompliance by
Federal facilities with require-
ments for pollution abatement and
control (section 313);
..violations of water quality criteria
for the uses designated in stand-
ards;
..violations of flow requirements
required by water quality stand-
ards;
..violation of State antidegradation
provision or EPA's antidegradation
policy;
.'.violation of State mixing zone-
policy;
..violations of air quality stand-
ards, including requirements for
prevention of significant deteriora-
tion.
.Violation of informational guide-
lines, such as those for non-point
source control (304 (e)).
.As applicable
.Violation of EPA's Statement of Policy
on Protection of Nation's Wetlands
(38 FR 10834).
.Where adverse environmental effects
are beyond EPA's jurisdiction and
expertise (e.g., historic site, wild
and scenic rivers), but there exists
a feasible alternative (i.e., one
that would substantially accomplish
project purposes) which would sig-
nificantly reduce adverse environ-
mental effects.
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Table 3b: (Continued)
2. which relates to EPV s area of
jurisdiction or expertise.
.Where aquatic biota, water supply,
or recreational areas are threatened,
but no -104 permit is involved.
Category 5: Inadequate
General Criteria (from
309 Review Manual)
a. Insufficient information to permit a
reasonable review of project features,
thus precluding evaluation of project
effects on EPA standards regulations
or policies.
b. EIS's which, whether intended or not,
are overview EIS's covering a broad
class of actions for which the initiat-
ing agency either does not intend to
prepare detailed project-by-project
EIS's, or where the inadequate rating,
coupled with specific comments, would
substantially aid the initiating ag-
ency in its useful project-by-project
EIS's.
Specific Criteria for
Land Management Plans
-Inadequate description of water
quality parameters and their effects
on uses (e.g., aquatic biota, water
supply).
.Inadequate description of plan pur-
poses, benefits and costs, implementa-
tion techniques, and other features
necessary to allow comparison of
project effects with area Water
Quality Management Plans (and, per-
haps, Air Quality Maintenance Plans).
.Plans which have individual com-
ponents (timber, range, etc.) not
adequately described to determine
local effects on water quality,
aquatic biota, or other areas of
EPA jurisdiction and" expertise.
Category ER: Environmental Reservations
General Criteria (from
309 Review Manual
a. Reservations exist concerning the
environmental effects of certain
aspects of the proposed project.
Specific Criteria for
Land Management Plans
.Rare natural resources could be
directly or indirectly destroyed by
implementation of the plan and these
resources are unprotected by Federal
or state regulations.
.Long-term effects of proposed actions
are serious and have not been adequately
considered.
.Further study of alternatives to or
modifications of the plan is required.
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III. IMPACT IDENTIFICATION AND ASSESSMENT
The purpose of this chapter is to offer technical guidance and reference ma-
terial necessary to evaluate impacts of national forest land management actions.
The chapter is arranged according to the several impact categories (for which
EPA is responsible), and further organized to address the major areas of For-
est Service actions in three subsections. "Sources of Impacts" (1) identifies
types of activities and the nature of potential impacts which they may cause.
"Review of Impact Quantification " (2) deals with the appropriateness and
validity of techniques to estimate various environmental effects that may
result from forest land uses. Tne "Assessment of Impacts" (3) sections should
be used as a guide to formulate comments on a land management plan and accom-
panying EIS, and in assessing alternatives and mitigation measures. , It should
be emphasized that not necessarily all of the following impact analyses will
be included in each land management plan EIS. Individual forests will include
unique problems, and the EIS scoping process may further limit the analyses
presented in the EIS. However, care should be taken to assure that where cer-
tain issues are covered by reference to other EISs or are tiered with other
analyses, that these responsibilities are faithfully carried out, and appro-
priate summaries offered.
All Federal agencies must follow CEQ's regulations to implement the procedural
provisions of NEPA. The regulations are designed to make the NEPA process
more useful to decisionmakers and the public; to concentrate environmental
analyses on significant issues; to reduce paperwork and delays; and to produce
better decisions.
It is important in review of the draft EIS to consider several major issues
which relate to its usefulness and effectiveness, and which are stressed in the
NEPA regulations. These include:
Is the EIS understandable? NEPA policy requires that EISs "shall be con-
cise, clear, and to the point . . ." (40 CFR. 1500.2 (b)). Also, "Environmen-
tal impact statements shall be written in plain language ... so that de-
cisionmakers and the public can readily understand them." (40 CFR 1502.8).
Are differences among alternatives apparent and addressed both quantitatively
and qualitatively? The EIS "should present the environmental impacts of the proposaJ
ana alternatives in comparative form, thus sharply defining the issues
and providing a clear basis for choice among options ..." (40 CFR 1502.14).
Is the no action alternative defined and evaluated? Due to the nature of
Forest Service land management actions, it is especially important that
the basis for the no action alternative be clearly stated. For certain
actions covered by a land management plan "no action" could mean doing
nothing while for others it may represent a continuation of current land
management practices over the planning period. These distinctions must
be made.
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Does the EIS contain a complete, well developed summary? Care should be taken
in reviewing the summary that it fully and accurately addresses the issues
in the body of the EIS and stresses "the major conclusions, areas of con-
troversy (including issues raised by agencies and the public) and the
issues to be resolved (including the choice among alternatives)."
(40 CFR 1502.12) .
While this chapter addresses substantive issues which may be relevant to EPA's
review of draft EISs, the reviewer may also find the information useful in
carrying out other NEPA responsibilities, in particular (1) participation in the
scoping process to determine the scope of issues to be addressed and identify
significant issues related to the proposed action and (2) participation as a
cooperating agency at the request of the Forest Service to prepare environmen-
tal analyses or make available staff support in areas of EPA's special exper-
tise.
111.A. Review of Water Quality and Quantity Impacts
Most land uses and land management activities have the potential to affect the
quality and sometimes the quantity of water that runs off or through the water-
sheds of National Forest System lands. The degree of adverse impacts depends
various factors, including nature and extent of human activities in an area,
physiographic and climatic conditions and the degree to which potential problems
are recognized and appropriate protective measures taken. This section examines
what is probably the most important area of EPA concern related to forest land
management, the broad category of water-related impacts. The water quality im-
plications of solid waste management and pesticides are addressed largely in
separate sections dealing with those impact categories.
III.A.I. Sources of Impacts
The variety of land use activities which take place on national forests may
have both beneficial and adverse impacts on water quality and quantity. The
reviewer should use this section as an aid to understanding the kinds of im-
pacts which may result from land management plans and programs under the
responsibility of the U.S. Forest Service.
Types of Water Pollutants
Generally, surface watercourses and ground water in forested areas are of high
quality. However, management activities and land uses can cause temporary or
longer-lasting deterioration of water quality. The following paragraphs des-
cribe the types of water pollutants of concern to the reviewer in evaluating
Forest Service Land Management Plans and EISs.
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Sediment. Sediment is the most obvious pollutant from forest management acti-
vities.Production of sediment from undisturbed, forested watersheds is nor-
mally very low. Most of the uses of national forest lands have the potential
to cause erosion and subsequent sedimentation of surface water courses. The
nature and extent of sediment pollution are dependent on a complex set of en-
vironmental and other variables. Besides their physical effect on the water
quality by increasing turbidity, sediments may also carry chemical and bac-
teriological pollutants into streams. Overall this criterion is often the
most significant indicator of ecological integrity and general well being of
streams.
Nutrients. Nutrients, primarily nitrogen and phosphorus, may accompany run-
off in the forest environment. Sources may be natural or created by human
activity. Applications of fertilizers and fire retardants in connection with
silvicultural management can result in nutrients being transported to streams.
Also, erosion, timber harvesting, and burning (prescribed or otherwise) inter-
rupt natural nutrient cycling and may contribute to increased nutrient load-
ings in surface waters. Whether a pollution hazard results depends on the
nutrient levels, stream uses, and other factors.
Organic matter. Organic matter is present in the forest in great quantities.
In the absence of natural or human-caused disturbances, the amounts of organic
matter introduced to streams in forested watersheds are not usually high enough
to cause objectionable pollution. All phases of forest management can generate
residues of leaves, bark, slash, and other herbaceous and woody organic matter
which may be transported to water courses and cause water quality degradation.
Once in the aquatic system, such organic matter not only has adverse physical
impacts but also exerts an oxygen demand which can have deleterious effects on
stream ecology.
Bacteriological pollution. Bacteria and other microorganisms are present in
soil, vegetative debris, and human and animal wastes. While most of these are
harmless, pathogenic organisms may be transported to streams along with soil
bacteria. Bacterial pollution usually emanates from diffuse, nonpoint sources
of overland runoff.
Pesticides. Although pesticides are treated in a separate section of this
manual,tKey should be recognized as potential water pollutants in conjunc-
tion with forest management activities. As used here, the term pesticides
includes silvicides, herbicides, insecticides, fungicides, rodenticides and
any other chemical (or biological") agent used to control undesirable species
of plants or animals. Pesticides applied in the- forest-environment, may _enter
surface waters directly if precautions are not taken to limit applications
along streams and indirectly via erosion and surface runoff. The toxicity,
persistence and hazard of different pesticides vary greatly and must be as-
sessed on an individual basis. The value of integrated pest management should
be stressed and encouraged by EPA in reviewing land management plan EISs where
appropriate.
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Thermal pollution. Thermal pollution in the context of forest management re-
sults from the removal of trees and ocher vegetation along streams, exposing
the water surface to direct sunlight und solar warming. The effects on water
temperature can be substantial. Elevated temperatures are of concern with
respect to effects on physical, chemical and biological processes in an
aquatic ecosystem.
Other pollutants. The above-described categories of pollutants are those nor-
mally associated with forest land uses and forest management. In special cir-
cumstances other pollutants may be important. The land management plan and
EIS should identify any conditions such as mineral leasing activities which
could result in other forms of pollution.
Impact-Producing Activities and Land Uses
Forest Service land management plans and EISs cover a range of land uses and
activities, all of which can potentially affect water quality. Table 4
lists the major areas of Forest Service responsibility, various land manage-
ment activities and the water quality effects which may be associated with the
various activities. Generally, the reviewer will be concerned with water
quality impacts stemming from disturbance of the natural soil and vegetative
cover. Where application of fertilizers, pesticides and other chemicals or
disposal of wastewater is involved, effects of these substances on the aquatic
environment must also be considered.
Identification of water impacts necessitates consideration of:
1. the nature of the land resource involved, that is, topography,
climate, soils, geology, groundwater hydrology, etc.;
2. the nature of the water resource involved, including hydrology,
water quality, water quantity, water uses and other factors;
3. the nature of the land use activities which may affect the land
and water; and
4. the nature of the physical, chemical and biological processes
involved, such as those influencing erosion, sedimentation and
changes in water quality or quantity.
The nature of potential water impacts is determined by the interactions
among these categories. Knowing that tractor logging will be employed to
harvest clearcut timber, for example, is not a sufficient base for identify-
ing and characterizing water quality impacts, which depend also on slope,
soils, precipitation patterns and a host of other factors. The following
section presents more detailed guidance on the information and techniques
necessary fo.r adequate quantification of impacts that are generally identi-
fied in Table 4, as well as rules of thumb concerning the effects of
various factors on pollution potential.
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Table 4: Summary of Forest Service Land Management Activities and Nature
of Potential Water Quality Impacts
Activity or
Land Use
Nature of Potential Water Quality
Impacts
Timber
Silvicultural Activities
Thinning (precommercial and
commercial)
Herbicide and other pesticide
applications
Fertilizer and fire retardant
applications
Prescribed burning (for slash
disposal or site.preparation)
Harvesting Activities
Felling, log handling and
residue disposal
Road Construction
Range
Domestic animal grazing
Recreation
Camping and picnicking areas
Disturbance of soil and organic
layer by equipment may increase
erosion potential
Chemicals may be introduced directly
or transported to watercourses
Nutrients may enter watercourses and
promote undesirable algae growths
Burning may increase erosion potential;
sediments and nutrients may be eroded
into streams
Exposure and compaction of bare soil
may lead to erosion and sedimenta-
tion; bark, slash and other organic
debris may reach watercourses and
exert an oxygen demand with de-
composition; removal of canopy *
trees near streams may increase
solar radiation and raise stream
temperatures; removal of timber may
increase peak runoff rates
Road construction is usually the
single most important cause of ero-
sion and sedimentation in forested
areas; bank instability and mass
soil movement may result from road
cuts.
Soil compaction, reduction of vege-
tative cover, erosion, fecal con-
tamination and sedimentation of
streams may be attributable to over-
grazing on range lands.
Intensive use of recreation sites
may increase erosion and sedimenta-
tion due to soil compaction and
damage to vegetation; sanitary wastes
may adversely affect water quality if
improperly managed.
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Table 4
(Continued)
Activity or
Land Use
Nature of Potential Water Quality
Impact s
Hiking trails
Off-road recreational vehicle
(ORRV) use
Wildlife and fish
Wilderness
Recreational use (primitive
camping, hiking, etc.)
Hiking trails may be highly sus-
ceptible to erosion, especially on
steep slopes and areas with thin
soil and sparse vegetation; careless
disposal of wastes may result in
stream pollution.
ORRV's may cause significant soil
disturbance and damage to vegetation,
resulting in greater potential for
erosion and sedimentation.
Management activities specifically
for wildlife and fish generally im-
prove or have no effect on water
quality.
Soil erosion, compaction, and sedi-
mentation may be associated with
wilderness hiking and camping, de-
pending on the intensity of use.
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III.A.2. Review of Information Adequacy and Impact Quantification
The activities undertaken by the Forest Service in managing National Forest
Lands have the potential to impact water quality and quantity to varying
degrees. Careful planning and management offer significant opportunities to
prevent or reduce the pollution hazard, in many cases to the point where fur-
ther reductions are not feasible without curtailing activities completely.
In such instances, the reviewer has to judge whether the residual impacts
will cause violation of applicable water quality standards, existing water
quality or otherwise impair the intended use of the water resource. Also,
the reviewer may frequently be faced with evaluation of impacts which cannot
be quantified- except in a very general descriptive fashion. In these situa-
tions, the importance of potential impacts may have to be judged by: the
nature of effects experienced under similar circumstances, the value,
quality and sensitivity to degradation of the water resource involved, and
changes in water resource related use' demands expected within the affected
area.
Information Review Guidelines
The following guidance should aid the reviewer in determining the adequacy of
information in the EIS as a basis for impact quantification.
Nature of the Land Resource. Certain information and data concerning the na-
ture of the land resource are applicable to the assessment of all forest land
uses and management activities. The kinds of information having relevance to
impact evaluations are discussed below and should be contained in the land
management plan or accompanying EISs.
Topography: Topographical information includes slope length, steepness,
aspect and elevation. Slope length and steepness directly influence the
velocity of surface runoff and thus sediment-carrying capacity and erosion
potential.
Elevation and aspect affect erodibility indirectly through their influences
on soil and vegetation development. This information is readily available from
USGS maps but must be interpreted in the context of other site factors and the
proposed land management activities in order to be useful for impact assess-
ments. For silviculture, it is important that topographical characteristics
are fully described in all areas where logging, road construction and other
activities would take place. Similarly, topographic features in areas for
recreation, grazing and other uses should be described. Factors that should
be kept in mind in reviewing the information include:
.. Erosion potential increases with increasing slope length and slope
steepness
.. The majority of mass soil movements [landslides, mud flows, and creep)
occur on slopes greater than 35° or so; sliding may be imminent on such
slopes if forces holding soil in place are interrupted (as by clear-
cutting or road construction, for example)
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Sites at higher elevations are apt to be more erodible than lower
sites due to poorer soil development and differing vegetation
Aspect (exposure) may affect organic content of the soil, and thus
credibility; some studies have shown erosion rates to be higher on
south-facing slopes due to frost heaving and sparser vegetation.
Soils: The properties of soils must be considered in assessing potential
water quality impacts of forest land uses. Most important are such character-
istics as texture and aggregation, nature of parent material, organic matter
content, chemical properties and moisture content. The reviewer should make
sure that information on soils is included in the land management plan and EIS
for all areas like.ly to be disturbed by the proposed activities. Examples are
areas to be logged, corridors for proposed logging or other access roads and
proposed camping or other recreational development sites. Also, local soil
conditions should be investigated in detail if subsurface sewage disposal sys-
tems are to be installed in connection with recreational facilities construc-
tion. Sources of information on soil characteristics may include the Soil Con-
servation Service, U.S. Geological Survey and the Forest Service itself.
Several rules of thumb regarding the influence of soil properties on potential
erosion hazard and water quality impacts follow:
.. Resistance to erosion normally increases as the organic content of
soils increases, due to its binding effect on holding soil particles
together
.. Silts and very fine sands are more vulnerable to detachment and trans-
port than larger or smaller particles, but become less erodible as the
proportion of sand and gravel or clay increases
.. Erodibility is inversely related to permeability (e.g., soil compac-
tion by heavy equipment increases runoff and the potential for ero-
sion.
The relationships between soils and erosion are described in greater detail in
Forest Harvest, Residue Treatment, Reforestation and Protection of Water Quali-
ty_, Chapter 4 (EPA 910/9-76-020). Good discussion of soil and other factors
affecting surface erosion and mass wasting processes, as well as evaluation
procedures, is also contained in Logging Roads and Protection of Water Quality,
the section on Route Planning and Reconnaissance (EPA 910/9-75-007).
Precipitation: Although temperature, wind, humidity, solar radiation and
other climatic factors have effects on erosion, precipitation characteristics
are the most important. Precipitation and subsequen-t—rune^-f—p-ro-vide—t-he—en.er^-y-
for the detachment and transport of soil particles. The intensity and amount"
of rainfall, both during short-term events and over longer periods, are key in-
dicators of potential pollution problems resulting from forest disturbances.
The nature of information that should be presented in an EIS depends on the
methods used for quantifying or describing potential erosion problems. Some
of the empirical approaches to estimating soil loss include factors based on
certain characteristics of precipitation. Seasonal variations in precipitation
and associated effects on soil moisture content may be especially critical in
planning and scheduling of land use activities. General guidelines concerning
precipitation are given below:
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.. precipitation usually causes little or no overland flow in undisturbed
forests, particularly in the East, and thus low rates of erosion, ex-
cept under conditions of excessively high rainfall.
.. Soil mass movements arc most likely to occur under high soil moisture
conditions and during abnormally heavy rainfall.
Vegetation and Cover: Vegetation has several major effects in reducing
erosion, among them (Schwab, et al. 1966):
1. Interception of rainfall by absorbing the energy of the raindrops
and thus reducing runoff,
2. retardation of erosion by decreased surface velocity,
3. physical restraint of soil movement,
1 /
4. improvement of aggregation and porosity of the soil by roots and plant
residue,
5. increased biological activity in the soil, and
6. transpiration, which decreases soil moisture, resulting in increased
storage capacity.
Existing vegetative cover as well as planned modifications to the cover should
be described in the land management plan. Of special concern is the nature of
vegetation in stream-side ar-sas, in areas where various disturbances would
occur, and up- and down-slop^ from such areas. Information on vegetation type
and density may be used, with other data, to make quantitative estimates of
soil loss or to judge the ability of areas to resist erosion.
Nature of the Water Resource. The planning and environmental assessment of
national forest land uses require sufficient knowledge and understanding of
existing stream, lake, and other water body characteristics to: (1) establish
baseline conditions from which potential changes can be predicted or measured,
(2) identify water resources likely to be impacted by specific activities, and
(3) determine the relative sensitivities of various water courses and water
bodies to pollution. The types of information required can be categorized
generally as water quantity, that is, relating to the hydrology of the stream
systems of concern, and water quality, dealing with the physical, chemical,
and biological characteristics of the water as well as the associated legal
and institutional requirement. Guidance for reviewing the adequacy of such
information follows.
Water Quantity (Hydrologic) Information: The reviewer should expect the
EIS to characterize the physical nature and condition of streams in the plan-
ning area and to describe the hydrology with respect to runoff and its typical
variation throughout the year. For streams near or downstream from areas of
potential disturbance due to silviculture, grazing, or other activities,
descriptions of the following are relevant to impact assessment:
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Nature of the stream bed and banks - Which streams or what proportion
of the streams are characterized by stable biids of rock and gravel?
By erodible sands and silts? Are stream gradients steep or relatively
flat? What are the conditions of stream banks, which may range from
very stable and well vegetated to highly erosion-prone due to under-
cutting, meandering, cohesionless or silty soils, or poor vegetative
cover? The Forest Service and several state> have stream classifica-
tion systems incorporating these characteris :ics (described in Processes,
Procedures, and Methods to Control Pollution Resulting from Silvicultural
Activities. EPA 430/9-73-010, Section 4.1.4) .
Stream flow and variations - Are the streams intermittent or perennial?
What are the characteristics of peak flows, .ind what times of year do
they usually occur? Do flood hazards exist downstream 'from areas to
be logged? What are the low-flow characteristics of perennial streams?
In many cases the kinds of information alluded to above will be presented in
basically qualitative or descriptive terms. Howiver, more quantitative data
on flood flows and frequencies and other factors is necessary for actual
design of drainage structures, river crossings, .ind other facilities. Al-
though such information may not have been developed at the EIS stage, the re-
viewer should expect the EIS to indicate the criteria that would be applied
to the location, sizing, spacing, and installation of drainage, flow control,
river crossing and other structures based on stream channel and flow charac-
teristics.
Water Quality Information: One of EPA's fundamental concerns with respect
to uses of national forest lands is the protection and enhancement of water
quality. Due to the nonpoint nature of pollutan:s emanating from the forest
environment and the difficulty in predicting the magnitude of impacts, the
review process must focus mainly on the prevention and reduction of pollution
to the greatest feasible extent, rather than on allowable pollutant loads or
concentrations. EPA's "Best Management Practices" (BMP) approach recognizes
that nonpoint source pollution cannot be dealt with in the ways traditionally
applied to point source discharges.
The adequacy of water quality information can be judged by the extent to which
it fulfills two basic purposes: (1) provision of a suitable baseline from
which future changes can be predicted or actually monitored and, more impor-
tantly, (2) provision of a means for determining differing vulnerability or
sensitivity to degradation (due to stream uses, biota present, or other con-
straints). Pertinent water quality information includes:
.. Existing water quality and quantity - Results of water quality surveys
that have been carried out on streams in the planning area should be
summarized verbally and in tabular form. The most critical parameters
are dissolved oxygen, suspended solids, turbidity, coliform bacteria,
nutrients, and pesticides. Historical trends and effects of past dis-
turbances should be described, i£ data are available, including trends
in stream flow.
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Existing stream classifications, standards, and uses - Classifications
and corresponding EPA-approved State water quality standards should be
delineated for water courses and warer bodies in the areas of concern.
The reviewer should be familiar with the State's antidegradation poli-
cy as well as any regulations having specific applicability to silvi-
culture or other forest activities. Water and stream uses should be
identified as well, particularly those requiring high quality such as
water supply, water-contact recreation, and fishing. Further designa-
tion as sensitive or critical areas or inclusion in state or federal
scenic and wild river programs should be noted, and compliance with
the floodplain management and wetlands protection Executive Orders
assured.
.. Existing stream biota - Information on fishery resources is essential.
As a minimum requirement, an inventory of the species present and
description of their economic or recreational importance are necessary.
The U.S. Fish and Wildlife Service and state fish and wildlife agen-
cies are sources of such information. In addition, the EIS should
contain information on, and the reviewer should be familiar with,
critical water quality and habitat requirements of fish and other
sensitive species. Often salmonids (salmon and trout) are of major
concern with regard to maintenance of water quality in national forests,
and sedimentation of spawning gravels, reduction of dissolved oxygen
and increases in water temperature are the" greatest hazards posed by
silviculture and other activities in the national forests. For de-
tailed guidance, refer to Water Quality Criteria 1972 (National Academy
of Sciences, 1973). Evidence should also be provided which indicates
compliance with the consultation requirements of the Fish and Wildlife
Coordination Act as well as possible impact on any endangered species
or supportive habitat.
.. Water quality management plans (Section 208 and Section 303(e) plans)
- All areas are or will be included in 208 or 303(e) water quality
management plans, unless the State certifies that particular water
quality problems do not exist or are not likely to develop (40 CFR
130.11 (b)). Information contained in the plans on nonpoint sources
of pollutants and control measures relevant to the national forest
areas should be referenced in the EIS.
Point sources of wastewater discharge - Any existing or proposed point
sources of pollution in the vicinity of the forest planning area, in-
cluding discharges from campground sanitary facilities or other govern-
ment buildings, should be identified and characterized and NPDES permit
conditions described.
The information presented should be sufficient to give the reviewer an under-
standing of the present levels of water quality and the relative importance
and value of the various water resources in the planning area. Information
should be quite specific for larger streams while more general observations
may suffice for headwater tributaries and intermittent streams known to have
exceptionally high quality. If the EIS has omitted consideration of any of
the types of information described above, the reviewer should request that
further documentation be provided.
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Nature of Proposed Activities. The potential for water pollution and other
adverse impacts depends a great deal on the nature of proposed activities
and land uses and the interactions between those uses and the land and water
resources. This section discusses the types of information that are necessary
to adequately characterize various activities on national forest lands.
Also, the material is a guide to understanding the significance of site
characteristics in relation to the activities and attendant pollution hazards.
Timber: Activities associated with timber resources can be grouped into
three main categories of silviculture, harvesting, and road construction.
The silviculture category includes thinning, pesticide, fertilizer and fire
retardant use and prescribed burning. These can also be termed intermediate
practices whose purpose is to increase productivity and quality of the growing
forest. Information presented in the forest management plan should address
the issues of how, when and where such activities will be carried out,
specifically:
.. Amounts and locations of land areas on which the various practices
would take place.
.. Nature of the terrain, especially slopes, that would be subjected to
thinning and other practices.
.. Methods proposed for thinning, including equipment requirements and
potential site disturbance, means of disposing slash and merchantable
material, scheduling and frequency of entry into stands.
.. Methods proposed for applying pesticides [broadcast versus hand selection
and application of herbicides, for example), including description
of special precautions near water courses or other sensitive areas, if
any (pesticide use may be covered by a program EIS, in which case the
document should be referenced].
.. Methods proposed for fertilizer applications, including special pre-
cautions to protect water quality (forest fertilization is practiced
mainly in the Southern pine and Pacific Northwest Douglas-fir regions
at present).
Harvesting activities involve the felling, yarding and transport of timber
from the forest and disposal of residues left after cutting. Regeneration
of cut-over sites, by either natural or artificial methods, is not actually
a harvesting activity but will also be considered since it is often dependent
on the harvesting and residue disposal methods employed.
Four basic harvesting systems are used in the U. S.: (1) clearcutting, (2)
seed tree, (3) shelterwood, and (4) selection. With site conditions being
equal, the amount of soil disturbance generally decreases for the systems in
the order listed. Characteristics and applicability of the methods are as
follows (U.S. EPA, 1973):
Clearcutting:
- Virtually all trees (or all trees larger than specified minimum size)
removed from harvesting area.
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- Applicable to even-aged management of intolerant or subclimax speciesf
including shortleaf and loblolly pine in the South, red and jack pine
in Lakes states, red and white spruce and balsam fir in Northeast,
lodgepole pine in Rocky Mountains and Douglas-fir in Pacific North-
west, among others.
Seed Tree:
- Most trees removed with a few of the most desirable trees left as a
seed source and harvested after reproduction is established.
- Applicable to even-aged management of light-seeded species that re-
quire minimum competition and bare mineral soil for establishment, such
as longleaf, loblolly, slash and shortleaf pine in the South.
-.Potential for erosion and sedimentation similar to clearcutting.
Shelterwood:
- Trees removed in a series of partial cuttings over a fraction of the
rotation; regeneration is established before the final harvest cut.
- Applicable to even-aged management of heavy-seeded and intermediately
tolerant species, including Appalachian and Central hardwoods, and
white and red pine in the Lakes States. Even-aged management by shelter-
wood cutting is being increasingly employed in hardwood stands of north-
eastern national forests as well.
- Used mainly on flatter ground where tractors can operate.
- Sediment generation potential may be less than for clearcutting or seed-
tree methods.
Selection:
- Individual or small groups of the oldest or largest trees removed per-
iodically.
- Adapted to maintenance of all-aged forest and species tolerant of shade
and competition.
- Operations normally restricted to sites where tractors can be used, al-
though cable logging of selection cuts is sometimes used in the West.
- Slash volumes considerably less but site disturbance necessary more
frequently than with other harvest systems.
- Often applied to sensitive areas where clearcutting would be undesirable
for aesthetic or water quality reasons, such as along streams and roads
or near recreational areas.
Information on not only the harvest methods but also the logging systems is
necessary for impact assessment. The three basic methods of primary log trans-
port are tractor, various cable systems and aerial (helicopter or balloon).
These can differ quite substantially in their applicability to the harvesting
methods, road requirements, topographical (slope) constraints and amount of
site disturbance. Table 5 compares several logging methods on the basis
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Table 5 : Characteristics and Potential.Impacts of Various Logging Methods
Logging Method
Use
Road Requirements
Nature and Relative
Amount of Site
Disturbance
Tractor (rubber-tired
and crawler skidders)
Jammer
High Lead Cable
For clear or partial cuts
on slopes less than 30%;
most common harvest method
in Northeast and South,
but also used in West;
less expensive than other
methods
For uphill yarding of
clearcuts on slopes up
to 55%
For uphill or downhill
yarding; suitable for
clearcuts only; 30-70%
slopes
Dense network of logging
roads and skid trails
necessary; more than for
other systems
Fairly intense system
of roads generally para-
llel to contours is re-
quired; maximum spacing
about 400 ft.
requirements are
less than for above
methods; maximum yard-
ing distances are ap-
proximately 1,000 ft.
uphill and 500 ft. down-
hill
Compaction, exposure,
and displacement of
soil
Soil disturbance likely
over 20-30% or more of
logged area
Generally more damaging
than cable methods
Various attachments may
be used to reduce contact
of logs with ground, thus
reducing disturbance
Disturbances result primarily
from log skidding
Soil may be exposed and
compacted over 15-20% of
clearcut area
Soil disturbance generally
less than that caused by trac-
tor logging, but more than
for other cable methods
Soil compaction and dis-
turbance may occur on up to 15%
of area
Partial suspension of logs
tends to reduce soil dis-
turbance by skidding
When logs are pulled uphill
toward boom, skid paths tend
to fan out and disperse sur-
face runoff
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Table
Characteristics and Potential Impacst of Various Logging Methods
Logging Method
Use
Road Requirements
Nature and Relative
Amount of Site
Disturbance
High Lead Cable
(continued)
Skyline Cable
(numerous types)
Balloon and Helicopter
For yarding up or down
hill and laterally over
short distances; used
principally on clearcut
operations but also ap-
plicable to certain
partial cuts
Road requirements may be
as little as 1/3 those
necessary for high lead
logging and 1/10 those for
tractor logging; yarding
distances of 3,000-4,000 ft.
are possible
For logging of steep or Road density is held to
inaccessible areas; high a minimum because of the
concentrations of merchant- long yarding distances
able timber are generally and versatility of the
required to justify use; methods
used principally in the
Northwest
More landings are required
than with skyline systems
Logs are usually lifted
off the ground, thus mini-
mizing soil disturbance ex-
cept at felling, yarding,
and loading areas
Erosion potential is less
than with tractor 07- other
cable methods
Amount of soil disturbance
is the least of all logging
methods
Helicopter logging requires
large landing and yarding
areas which may contribute
to erosion
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of such factors and can be used ,is a guide in reviewing EIS information on
timber harvesting. Figure - illustrates the optimum distances and slopes
for logging systems in use in thu northwestern United States. Chapter 3 in
Forest Harvest, Residue Treatment, Reforestation and Protection of Water Quality
(James M. Montgomery, Inc., 19761 gives" more detailed descriptions of the
various log transport systems.
The EIS must indicate the harvesting and logging practices to be used as well
as the nature of pollution control measures that will be employed. Although
detailed site-by-site descriptions may not be appropriate at this stage, it
is important that categories of activities are characterized for the planning
unit. The information should identify:
.. Types of harvesting methods (e.g., clearcutting, selection cutting,
etc.) and the land areas involved for each.
.. Types of logging systems to be employed with the various harvesting
methods and areas.
.. Typical and maximum sizes of areas which will be harvested at one
time.
.. Methods for managing timber harvest activities near streams and other
sensitive areas such as steep slopes and wetlands.
.. Scheduling and duration of harvest activities.
.. Methods for residue disposal (chipping, burning, and yarding un-
merchantable material for example).
.. Methods for regeneration, including site preparation measures (e.g.,
•scarification, burning, or herbicide treatment).
An EIS which contains these kinds of information should convey a good overall
understanding of the timber-related aspects of a land management plan. The
reviewer needs to insure that the basic methods of harvest, logging, residue
management and regeneration or reforestation are discussed. The potential
water quality significance of timber activities is to a degree inherent in
the nature of the activities but also dependent on interactions with the land
and water resources. Land and water data should be integrated sufficiently
with information on timber activities so that critical pollution hazards can
be identified and the suitability of activities to site conditions properly
assessed. For example, clearcutting and tractor logging are likely to result
in unacceptable erosion and sedimentation on fairly steep, unstable slopes but
might be carried out with minimal problems on gently rolling or level terrain.
Roads are apt to be the principal source of environmental problems such as
sediments in forest lands, especially when improperly constructed or located
in steep or unstable topography. Road requirements are closely related to
the harvest and log transport mehtods chosen, as described in Table 5.
It is often difficult and costly to correct erosion and sedimentation problems
from logging roads after they occur. Careful location and design along with
incorporation of adequate drainage and stabilization features can prevent or
minimize water quality impacts of roads. Such ,m approach is increasingly
important as logging takes place in less accessible areas that present greater
pollution hazards and construction problems.
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Section 8 (b) of the National Forest Management Act requires that any road con-
structed in connection with a timber contract or other permit or lease be de-
signed with the goal of reestablishing vegetative cover on the roadway and
disturbed areas within ten years, unless the necessity for a permanent road is
set forth in the forest development road system plan. The EIS should indicate
whether proposed roads are to be temporary or permanent, provisions that will be
made to revegetate temporary roads and the design, construction and maintenance
methods that will be employed for permanent roads.
Information describing forest roads should include soils engineering, geology,
forest engineering, silviculture, socio-economic, historical, and others.
These specialist areas will be involved in route planning during which road
needs and locations are generally identified, route reconnaissance including
data collection and field investigations for alternative corridors, and design
of the roads, appurtenant structures and mitigating measures. Generally, the
EIS for a land management plan will be developed before details of road location
and design are specified. The amounts of field data available on alternative
corridors will depend on the extent to which such reconnaissance is conducted in
conjunction with planning of timber management activities. Whether or not
detailed field investigations have been completed for areas where roads are
proposed, there still is a variety of information that the EIS should contain
relating to road construction and impacts, including:
.. Estimates of road length, type (permanent versus temporary), spacing,
stream crossings and general layout for proposed and alternative
. harvest/logging methods and areas.
.. Description of erosion control measures to be employed.
.. Description of criteria used in choice of road density and route
location.
.. Description of plans and procedures for road maintenance and abandon-
ment.
.. Assessment of likely secondary impacts associated with providing
access to new areas.
.. Description of any special or unique problems such as location or
impact on a flood plain or wetlands area, or scenic or wild river.
Assessing the adequacy of this information involves judging whether reasonable
assurances are given that:
• .. Road construction will be held to a minimum given the constraints
imposed by topography, sensitive areas and logging methods.
Roads will be located so as to avoid, to the extent possible, areas
presenting high-risks of erosion and mass soil movement.
Pollution prevention and reduction measures, both structural and non-
structural, will represent the best management practices for forest
road construction and maintenance.
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Table 6 lists some of the considerations in road location, as a guide to
reviewing EIS information and impact discussions. The publication Logging
Roads and Water Quality (U.S. EPA, Region X a£_a_L., 1975) is an up-to-date
and quite complete reference document which the reviewer should consult for
details on specific approaches to road planning, design, construction and
maintenance.
Range: Permitting grazing on forest or grasslands may, over a period
of time, cause soil compaction, reduced infiltration rates and vegetative
cover, and increased soil erosion. Also, entry of livestock into streams
constitutes a pollution hazard. Few studies have been made of the nature and
extent of these potential problems. Often grazing systems include various
rotation and deferment schemes allowing different areas to go ungrazed for
a season or longer. Information in the EIS should describe plans for use of
forest lands for grazing, addressing in particular such aspects as:
Amounts of land area involved.
Present condition of rangelands.
History of grazing use and erosion or water quality problems en-
countered, if any.
.. Nature of proposed grazing systems (rotations, deferment, etc.)
.. Nature of streams in grazing areas and provisions for preventing
animals from entering streams, if any.
.. Provisions for periodic inspection to detect incipient, erosion,
deterioration of cover, or water pollution problems.
•
Past experience with grazing may be a useful indicator of the potential for
adverse water quality impacts. If the land has been used for pasture without
incident, then comparable future uses should not result in unacceptable pollu-
tion. However, significant changes in the nature of use, animal density or
other factors should be carefully observed for possible detrimental effects on
water quality.
Recreation: The national forests attract large numbers of visitors for-camping,
picnicking,hTking, hunting, fishing, swimming, skiing, off-road recreational
vehicle use and many other activities. Some of these activities result in
high concentrations of people in small areas while others are widely dispersed.
In general, areas of heavy use are the most vulnerable to degradation which may
lead to erosion, sedimentation and other environmental problems. In addition,
the need for proper disposal of sanitary wastes arises in areas subject to
intensive use.
Major new recreational developments, such as ski areas or campgrounds, may
be subjects of separate environmental statements; if so, reference should be
made to such other studies. For recreational activities and land uses that
are covered in the land management plan and EIS, the information presented
should address:
location, characteristics, and proximity to streams of intensive-
use recreational sites (campgrounds, picnic areas, etc.)
-50-
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Table 6 : Topographical Influences on Logging Road Location
Locational
Characteristic
Advantages
Disadvantages
Special Precautions
Valley bottom
Hillside
Ridge
Low gradient
Good alignment
Minimal excavation
No flood hazard
Greater distance to
streams reduces
potential for
sedimentation
Good drainage
Less excavation
Large amounts of
vegetation or logg-
ing slash to act as
buffer between road
and streams
Flood hazard
Number of stream
crossings
Proximity to stream
channels
Higher grades
More excavation
Longer slopes
Poor alignment from
following grade con-
tours
Exposed cuts and
banks
Possibility of soil
mass movement
Poor alignment along
dissected ridges
Possibly adverse
grades for connect-
ing roads
Avoid road location in or adjacent to
stream channel
POiSition so as to protect from flooding
Minimize channel disturbance, cuts, and
fills at stream crossings; construct
crossings at right angles to stream axis
Avoid very flat gradients that would
cause ponding of water
Avoid steep, unstable, dissected slopes
Stabilize exposed cuts and slopes im-
mediately by seeding, mulching, or other
methods
Provide for drainage and dispersal of run-
off from road prism
Locate to minimize earth moving
Avoid narrow, precipitous ridges
Revegetate cut and fill areas as soon as
possible after disturbance
Provide adequate roadway drainage
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provisions for sanitary waste treatment/disposal areas
nature of off-road vehicle use and pertinent regulations for protect-
ing soil, vegetation and water quality
methods for monitoring, prevention and control of erosion and sedi-
mentation from recreational use areas
Water pollution from recreational use is largely nonpoint in nature and is
likely to be a long-term rather than an immediate problem, caused by soil
compaction and deterioration of vegetative cover in camping areas, along
trails and at other regularly used sites. Information in the EIS should
be sufficient to demonstrate that sensitive areas with steep slopes, erodible
soils, or other hazardous features will be avoided, to the greatest extent
possible, as sites for recreational development and use. The reviewer should
also ensure that any waste water point sources are managed in conformance with
the requirements of the National Pollutant Discharge Elimination System.
Quantification Review Guidelines
The state of the art in predicting the magnitude of pollution from silviculture
and other forest activities is not well developed. Basically, the available
methods deal with the estimation of soil erosion 'and sediment production and
with prediction of thermal effects from removal of trees along watercourses.
EPA has published an assessment of nonpoint water quality modeling in wild-
land management (Forest Service, 1977). Although the report reviewed numerous
physical, biological and chemical models, only a few were found to be suitable
for use by field personnel in land management planning. Generally, the report
concluded that local or regional regression models represent the state of the
art, and that their validity and utility cannot be determined without calibra-
tion or testing in the environment where they would be used. Also, there are
relatively few national forest areas for which a sufficient date base exists
for testing and applying many of the modeling techniques. Another major
limitation of many nonpoint water quality models is the difficulty or inability
to predict pollutant loadings and resulting concentrations in water courses.
The Universal Soil Loss Equation and Musgrave Equation, originally developed
for predicting agricultural erosion, have been applied to forest lands in
some cases. These equations and their use are described in detail in Methods
for Identifying the Nature and Extent of Nonpoint Sources of Pollution
(U.S. EPA, 1973J.The estimates of erosion and sediment production rates
yielded by these equations do not indicate the resulting water quality effects.
Predictions of suspended sediment concentrations can be made by a method
called First Approximation of Suspended Sediment, which is also described in
the above-referenced EPA publication. The method combines hydrologic infor-
mation (for example, storm flow, base flow and annual flow) with sediment
production estimates for a watershed to arrive at suspended sediment concen-
trations for various flow conditions.
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Use of all of these techniques requires data on soil characteristics, topography,
vegetative cover, rainfall and other features specific to the area being eval-
uated. Because silvicultural and other forest management activities often in-
volve large and noncontiguous land areas and diverse environmental conditions,
application of predictive methodologies is likely to be difficult. It will
rarely be feasible to conduct detailed predictions of erosion and sedimentation
for all areas affected by a forest land management program. Studies may ra-
ther be carried out on experimental watersheds or sample plots within the
management area. The reviewer should recognize that results from study areas
may not hold for other forest lands, except in a very general way given similar
site conditions. Where feasible, the reviewer should note opportunities to
recommend that indicators such as stream bed sedimentation be monitored, and
encourage joint review with the state Water Quality Management Program.
An approach to predicting stream temperature changes is also discussed in the
previously referenced EPA document. The method enables estimation of the maxi-
mum temperature change in a stream as a result of exposure to solar radiation
by removing streamside vegetation. The reviewer should refer to Methods for
Identifying the Nature and Extent of Nonpoint Sources of Pollution for details
on data requirements and use of the method.
Methods for predicting water quality effects of other pollutants, such as
pesticides, bacteria and nutrients do not exist. Generally, site-specific
studies must be undertaken to monitor water quality changes associated with
forest land use activities. Since predictive tools for estimating nonpoint
pollution from forest lands are limited, the reviewer should evaluate the
management plan and EIS with a view toward: (1) the inherent risks of pollu-
tion presented by site factors and nature of proposed activities; and (2) the
extent to which the risks will be reduced by application of best management
practices and specific impact mitigation measures. The discussions of the
nature of the land resource, water resource, and proposed activities in the
previous "Information Review Guidelines" section should help the reviewer to
recognize those situations posing relatively greater or lesser risks of pollu-
tion.
The following discussion reviews ways to mitigate impacts and should help to
determine whether reasonable precautions for safeguarding water quality are
addressed in the Forest Service Plan and EIS. If quantitative impact pre-
diction methods are employed, such as for estimating erosion and sedimentation
rates, they should be documented in the EIS. Conclusions derived from data
pertinent to specific study locations should not be generalized for whole
management areas or categories of land use activities.
Mitigation- -Review- Guidelines: __ _
The reviewer will be required to evaluate potential water quality impacts
which are largely nonpoint in origin and likely to be described largely in
qualitative terms. Moreover, the impact-producing activities associated with
national forest management are apt to be spread out both spatially and tem-
porally. Given these aspects of water quality management in forested areas,
it is critically important that EPA's review be concerned with the nature and
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Table
Framework For Water Pollution Control Practices Used In Connection With
Silvicultural And Other Land Management Activities
PREVGNT10N
REDUCTION
Limiting, through prevention or management decision
measures, the generation of conditions that could
add materially to the pollution potential.
Advance planning to avoid, to the extent feasible,
potential problems through identification of, and
allowance for: (1) natural hazards such as areas
of natural mass earth movement, highly unstable soils,
and unstable stream channels, (2) limitations imposed
by landform, climate, topography, soil moisture, channel
characteristics, etc., (3) land capabilities in terms
of soil productivity, vegetation recovery potential, etc.
Consistent with overall land management objectives,
including due consideration for the other resource
values of the area and the technical, economic,
institutional and social feasibility and practicality
of alternatives:
minimize type and magnitude of disturbance
in high hazard areas.
select appropriate operational methods,
standards, and equipment with due consideration
of relevant limitations
optimize size and shape of areas and
the sequence, timing, spacing, and in-
tensity of activities.
Applying physical, biological, or chemical measures
to help reduce the unavoidable pollution potential
created by activities and/or prevention or potential
pollutants to receiving waters.
. Erosion Control
.. on-site
Revegetation
Dispersion of concentrated runoff
Physical or chemical treatment of the
land or temporary soil treatment
(mulching, etc.)
.. In-channel
Debris removal
Structural measures
Nutrient Management
Prudent use of fertilizers
Treatment of forest residues
Pesticides Managerr-ent
Prudent use of pesticides
Water Temperature Control
Streamside vegetation management
Source: U.S. EPA, office of Water Planning and Standards, Nonpoint Source Control Guidance--Silviculture,
EPA WPD Tech 37-3-77, March 1977.
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extent of measures planned for mitigating or eliminating potential quality
problems. Judgments as to the appropriateness of such measures should be
made according to the relative pollution hazard of the land use and management
activities involved, and the sensitivity, value and susceptibility to pollu-
tion of the water resources that could be affected.
Mitigation of water quality impacts can be accomplished through application
of prevention and reduction practices. Table 7 • gives an overview of
prevention and reduction practices and guidance for each of the two approaches
follows.
Prevention Practices. Prevention practices are generally concerned with care-
ful planning of the nature, location and scheduling of activities to minimize
the potential for pollution. As such, prevention practices are decided upon
prior to the implementation of any forest land management program. The choices
of how, when and where various activities are to be carried out should be
made with full recognition of the consequences in terms of either increasing
or decreasing the potential for pollution to occur. Usually it is more
effective to plan land management to avoid situations conducive to the gener-
ation of pollution than to take remedial actions once problems have been cre-
ated.
Location' of Activities; The factor of location has an important bearing
on the planning, design, implementation and resulting environmental impacts
of all forest uses and activities. Table 8 identifies review considera-
tions relevant to evaluating locational choices in an EIS, Basically, for
any activity or land use, the reviewer needs to consider (1) whether the EIS
presents sufficient information to differentiate among areas with respect to
topography, soils, and other conditions influencing the potential for non-
point source pollution, and (2) the extent to which land uses are planned to
avoid or minimize activity in areas identified as posing high pollution hazards,
If the data are insufficient to characterize the settings for proposed land
uses, the deficiency should be reflected in the EIS adequacy rating. Simi-
larly, the reviewer should expect the EIS to state specific criteria that have
been or will be used in planning the location of various land management
activities to prevent or reduce the threat of pollution.
Scheduling of Activities: The "when" aspect of land and resource manage-
ment may also influence the potential for pollution. As a pollution preven-
tion practice scheduling generally entails any of the following: limitation
or prohibition of activities during certain times of the year or weather con-
ditions, coordination of activities to minimize the extent of soil and other
disturbances at any one time, and prompt completion of activities such as
residue management, site preparation and reforestation to accelerate the
recovery of disturbed areas.
Table 9 outlines some of the ways that scheduling or timing may be applied
to various management activities to limit pollution potential. In order to be
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Table 8;
Guidelines for Pollution Prevention Practices - Location of Activities
Activity/Land Use
Timber
Road Construction
Timber Harvesting
Fertilizer and
pesticide application
Prevention Practices
Avoid high-hazard areas (steep slopes,
erodible soils, sensitive stream
channels, and areas susceptible to
soil mass movements)
Minimize intensity of activities on
high-hazard areas, particularly ad-
jacent to stream channels
Avoid direct applications on or near
Review Considerations
Does the data contained or referred to
in the E1S demonstrate adequate identifi-
cation and consideration of physical
limitations to road building? Are road
location plans and design criteria described
in the EIS? To what extent do they indi-
cate avoidance of identified high hazard
areas?
Does the HIS describe plans for leaving un-
disturbed buffer strips along stream
courses? To what extent will logging and
yarding be restricted in biicli sensitive
areas? Are the harvest operations planned
to avoid logging of steep, unstable slopes
as much as possible?
Do the methods of silvicultural chemical
use include specific measures to avoid
application near streams and other water
bodies?
Recreation
Camping and picnic
areas; hiking trails
Off-road recreational
vehicle use
Avoid sites susceptible to soil com-
paction, erosion, and drainage
problems
Control vehicle use in areas of steep
slopes, highly.erodible soils, and
unstable slopes
Have the physical characteristics of
potential sites for recreational facil-
ities been thoroughly investigated? Does
the ElS-address trade-offs among alterna-
tive sites and adequately state the
rationale for selecting the proposed plan?
Has an off-road vehicle plan been pre-
pared for the forest? Is use of off-road
vehicles confined, insofar as possible,
to areas that have low pollution hazards?
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Table 9:
Guidelines for Pollution Prevention Practices - Scheduling of Activities
Activity/Land Use
Timber
Road Construction
Harvesting and post-
harvest activities
Prevention Practices
Schedule road construction activities for
the appropriate season to avoid adverse
runoff and other site conditions
Schedule stream crossing construction to
minimize impacts (may be low-flow con-
dition or depend on fish spawning, for
example)
Coordinate excavation and erosion con-
trol work to minimize area of ex-
posed soil subject to uncontrolled
runoff during heavy rainfall periods
Close roads when not being used for
timber activities
Schedule harvesting to control the
amount of disturbance in any given
watershed at any one time
*
Initiate and complete post-harvest op-
erations as soon as possible after
logging (particularly regeneration,
residue management, and stabilization
of disturbed areas)
Schedule harvesting and post-harvest
activities so as to prevent operations
on high-hazard areas during periods of
high rainfall and runoff
Review Considerations
Is scheduling of road construction activ-
ities specified in the EIS?
Will the scheduling prevent undertaking
construction activities when soil moisture
conditions are excessive and provide for
suspending activities underway if adverse
conditions arise?
Will the scheduling insure that temporary
and permanent drainage facilities are
installed as soon as practicable follow-
ing site disturbance?
Do the harvesting schedules provide for
temporal distribution of logging activities
in given areas?
Will requirements be imposed for site pre-
paration and regeneration activities to
proceed soon after logging?
Will requirements be imposed for prompt
stabilization of landings, skid trails,
temporary roads, and other disturbed areas?
Do the harvesting schedules prohibit or
limit activities when pollution potential
is high (due to runoff or other site
factors)?
Will use of heavy equipment for logging or
residue management (slash piling, for ex-
ample) be avoided when soils are wet?
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Table 9 (Continued)
in
Co
Activity/Land Use
Silvicultural chemical
use (fertilizers,
herbicides, and other
pesticides)
Range
Crazing
Recreation
Off-road vehicles
Preventive Practices
Schedule applications to take advantage
of favorable meteorological conditions
Schedule rotations of grazing lands
to prevent excessive soil compaction
and deterioration of vegetative cover
due to overgrazing
Restrict snowmobile use tt times when
a certain minimum snow cover is pre-
sent; implement seasonal or other
periodic closures to ORV use. if nec-
essary
Review Considerations
Are criteria for application of chemicals
discussed in the EIS?
Do the criteria provide for scheduling
chemical use when rainfall and runoff and
the potential for wind drift are low?
Will grazing programs be adequately moni-
tored and scheduled to prevent overgrazing?
Are use schedules for ORV's addressed in
the EIS?
Will restrictions be instituted during
critical periods of the year or if erosion
or other problems are observed?
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effective, it is important that scheduling be addressed explicitly in the EIS
and incorporated into specifications and management directives for various
siivicultural and other activities. .In most cases, careful attention to the
timing of activities can significantly reduce the potential for water quality
impacts with little or no additional cost. The reviewer should insure that
schedules for all important activities are established and will be adhered to
in accordance with seasonal and other criteria for protecting water quality.
Nature of Activities: The manner in which management activities are car-
ried out can greatly affect the potential for water quality problems. Table
10 describes, for several activities and land uses, some approaches that
may be taken in preventing or reducing the likelihood of pollution. The re-
view considerations in Table 10 indicate the kinds of things the reviewer
should look for in the EIS to judge whether and how well activities have been
planned to reduce the risk of impairing water quality. It is important not
only that reasonable prevention practices are recognized in the management plan
and EIS, but also that adequate specifications, inspections and other measures
will be taken to insure their implementation.
Reduction Practices. Reduction practices are remedial in nature and are appli-
cable to controlling pollution in situations where its occurrence is unavoid-
able through use of preventive measures. Several such practices are described
in Table 11 which is based on best management practice (BMP) information
in EPA1 s Nonpoint Source Control Guidance--Silviculture.
The general functions of reduction practices are protection of exposed soil
and retarding movement of runoff and pollutants to water courses. Protection
of soil may be accomplished by vegetation establishment, mulching, riprap,
paving (roads); physical and chemical treatment and other means. Structural
measures such as debris basins, sediment ponds and other drainage structures
may be used to control runoff and intercept eroded sediments and other pollu-
tants before they enter receiving waters.
The need for such measures is dependent on the nature and extent of land
management activicies and on site-specific characteristics of topography,
soils, drainage patterns and proximity to streams. It is not necessary or
even possible in .1 land management plan and EIS for all pollution control
measures to be specifically identified and located, since some control require-
ments may become evident only when road construction, logging or other activi-
ties are underway. However, it is important that the general specifications
and criteria that will apply to the activities are fully described. In sen-
sitive areas, for example, in the vicinity of recreationally or ecologically
important streams, the plans should provide for special precautions to protect
water quality.
Basically, all areas disturbed to the extent that protective vegetation and
litter are removed and bare soil is exposed should he treated to minimize
erosion. Planting of grasses with or without mulching, scarification and
other physical treatments is applicable to sites such as cut and fill embank-
ments, log landings, intensive-use recreational areas and others where stabil-
ization is necessary but reforestation is not desired.
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uuj.uci J.UC& LUI rui i UL .lull r 1 CVCIIL AUII
Act iv it y/Land Use
Timber
Road Construction
Timber harvest
Residue management
and site prepara-
tion
Pesticides and
other forest"
chemical usage
Prevention Practices
Minimize the length and density of roads
through careful planning and layout, con-
sistent with management objectives
Design roads to fit topography and mini-
mize disturbances from cuts and fills
Adopt low-impact logging methods, par-
ticularly in areas with high pollution
hazards (skyline and aerial logging
cause the least disturbance of the
methods currently used)
Select logging methods and equipment
that are adapted to specific site
conditions
For cable systems, permit only uphill
yarding
Fell trees uphill and away from water
courses
Select methods for managing slash that
minimize the movement and compaction of
soil (for example, avoid use of bull-
dozers with scraper blades)
Minimize accumulation of fuel to reduce
the threat and severity of wildfires
and associated water quality impacts
•
Minimize chemical usage through reduced
application rates and greater reliance
on natural and cultural pest control
methods
Review Considerations
Are road requirements quantified for areas
to be harvested? Will roads be laid out in
orderly patterns to reduce the construction
required? Does the EIS discuss criteria
used in determining road density and layout?
Have alternative road schemes been identified
and considered to reduce construction and
associated impacts?
Are the harvest and logging methods to be
used identified in the EIS? Are they com-
patible with the site conditions? Have har-
vest systems that would allow a lower road
density been considered? Will various opera-
tional controls such as directional felling
of trees, uphill yarding, and regular in-
spections of activities be specifically re-
quired during timber harvesting operations?
Does the EIS identify methods that will be
used for site preparation and residue manage-
ment? Will restrictions to minimize dis-
turbance during yarding or other slash handl-
ing be placed on logging contractors?
Will the proposed residue management con-
tribute to reducing fuel volumes?
Are the background and rationale for pesti-
cide use adequately described?
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Table 10 (Continued)
cr>
H-«
I
Activity/Land Use
Pesticides and
other forest
chemical usage
(continued)
Kan fie
Graz
Range
Grazing
Recreation
Intensive-use areas
(campgrounds, pic-
nic sites, etc.)
Prevention Practices
Select pesticides for effectiveness,
minimum toxicity, low persistence,
selectivity for target species, and
low mobility
Restrict animal entry to stream courses
by fencing or other means
Control level of use to prevent soil and
plant deterioration and to allow recovery
of damaged areas. Provide for proper
waste disposal
Review Consideration
Have potential alternatives been ident-
ified and studied? Do pesticides to be
used represent the least harmful options?
Are there provisions to protect stream
segments having high water quality require-
ments froip fecal and other pollution caused
by grazing livestock?
Does the EIS discuss management and mainten-
ance plans for intensively used recreational
areas? Are the safeguards adequate to pro-
tect water quality? Do sanitary and solid
waste disposal facilities conform with ap-
plicable requirements?
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Table 11:
Guidelines for Pollution Reduction Practices
Reduct ion Pract i ce
Seeding or planting of
grass.es or other her-
baceous vegetation
Seeding or planting trees
Dispersal of runoff (by
constructing water bars
and dips in roads, energy
dissipators at culvert
outlets, berms, and
benches, for example)
Physical treatment of land
surface (contour trenching,
furrowing, scarification,
etc.)
Debris removal or dis-
persal
Mulching
Application
Bare soil or soil with in-
adequate vegetative cover,
including any areas dis-
turbed by forest management
activities
t
Bare soil or soil with in-
adequate vegetative cover
Tractor roads, skid trails,
and logging roads
Areas where soil moisture
or rapid runoff inhibits
plant establishment and
growth
Stream channels
Bare soils or soils with
inadequate cover where
slope or soil moisture is
critical.
Advantages
Relatively quick cover.
Improves infiltration ca-
pacity. Reduces overland
runoff.
Improves infiltration
capacity. Reduces overland
flow after a litter layer
develops
Retards runoff by reduc-
ing slope length and area
of concentration. Permits
infiltration over larger area
Limitations
May require fertiliza-
tion. May impede re-
forestation. Not effec-
tive in controlling
mass soil movements.
Only effective after
several years. May
reduce water yields.
May require fertilization
Can increase erosion if
water directed to unstable
areas.
Retards runoff by reducing
slope length and increases
infiltration. Aids plant
establishment
Reduces concentrations of
organic matter. Lessens
chance of debris dams, sedi-
ment deposits, and subsequent
bank erosion
Aids maintenance of soil
moisture. Reduces overland
runoff. Increases infiltra-
tion. Aids establishment
of herbaceous vegetation.
Can lose effectiveness
and increase soil loss.
High Cost.
May damage stream banks,
bottoms and fish habitat
Moderate to high cost.
May increase BCD load if
organic mulches are washed
into streams. May increase
need for fertilization.
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Table 11 (Continued)
o
oj
i
Reduction Practice
Road surface protection
(gravel or crushed rock
surfacing, asphaltic
concrete or bituminous
paving)
Structural measures such
as debris basins, sedi-
ment ponds, retaining
walls, flow retarding
structures, culverts,
ditches, and others
Chemical treatment of
soil (flocculants or
surficants)
Application
For steep road segments,
stream crossing approaches
and permanent or other
roads designed for heavy
use
Stream channels, areas of
mass soil movement, and
downstream from drainage
areas affected by con-
struction, roads, and
other activities
Fine textured soils and/or
soils which are difficult
to wet.
Advantages
Protects subgrade by re-
ducing water infiltration.
Eliminates or reduces rutt-
ing and road surface
erosion.
Retard water and pollutant
movement from land to re-
ceiving waters
Improves infiltration
capacity and reduces
overland flow
Limitations
Decreases time of con-
centration for runoff.
Requires nearby source
of suitable construction
materials.
May cause some sediment
pollution during con-
struction. Require
periodic maintenance.
Moderate to high cost.
Effectiveness decreases
with increasing clay con-
tent for some flocculants.
Chemicals may pose pollu-
tion hazard.
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Reforestation should be carried out on cut-over areas as soon as possible
after harvesting is completed, and on other areas which have been disturbed
by raining, fire or other natural or man-made causes. Trees can help to
maintain slope stability in areas susceptible to mass soil movements where-
as herbaceous cover may not. Because tree planting or other reforestation
requires several years to become effective in erosion control, interim
structural measures may still be necessary for slope stabilization.
Structural measures include a wide variety of devices to intercept and dis-
perse runoff, retain soil and sediment, prevent mass wasting, alter subsurface
drainage and otherwise modify surface and ground-water movement so as to re-
duce erosion and sedimentation. The use of structural measures for reducing
pollution from logging, road building and other forest management activities
should be addressed in the land management plan and EIS. Location, size
and other details would normally be identified in design plans and specifica-
tions for the work. However, the Forest Service should generally discuss the
kinds of pollution reduction measures that would be employed for particular
types of activities and the situations in which they would be applied. Such
practices should, as a minimum, be implemented in areas having steep or erodible
soils, in the vicinity of streams and in other areas with high pollution
hazards.
III.A.3 Assessment of Water Quantity and Quality Impacts
Many of the water pollution and other water-related impacts stemming from for-
est management and use tend to be variable and often unpredictable with respect
to time and space, nonpoint in nature, and quantifiable in only a fairly general
way. Due to these factors the reviewer will in many cases not be able to re-
late water quality impacts to specific numerical standards or criteria, [lather,
the more general language of state water quality regulations must also be con-
sidered, which requires judgments by the reviewer as to the potential magni-
tude of impacts. In addition, careful planning of pollution prevention and
mitigation measures and flexibility in their implementation become especially
important given the uncertainty and inability in predicting some impacts.
State adopted water quality standards form one basis for assessing water im-
pacts. Such standards, however, have been designed to apply primarily to
lower reaches of streams which receive point source wastewater discharges.
Small headwater streams typical of many in national forest areas are often of
high quality and affected by few if any point source discharges. Moreover,
water quality in small streams is apt to be highly variable naturally and data
are seldom available to establish baseline conditions for interpretation of
water quality standards.
Whether or not potential water quality impacts can be related to specific cri-
teria in the standards, it is important that forest land uses and activities
be conducted so as to not violate the state's antidegradation policy. Under
EPVs Policies and Procedures for Continuing Planning Process (40 CFR 130), the
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antidegradation policy must at a minimum provide for the maintenance and pro-
tection of existing instream water uses, and further degradation which would
interfere with those uses is not allowable. In addition, "no degradation shall
be allowed in high quality waters which constitute an outstanding national
resource, such as waters of National and State parks and wildlife refuges and
waters of exceptional recreational or ecological significance."
Clearly waters with high quality and special significance are to be afforded
protection from degradation. The reviewer's assessment of impacts should in-
volve judgments of the following:
. . Does the EIS satisfactorily identify stream segments and their classi
fication, recreational and ecological significance and use?
special provisions be made to minimize pollution-causing activi-
ties near streams and in watersheds that have high quality and support
valuable uses?
If activities in such areas are proposed, does the EIS fully describe
the prevention and reduction practices to be applied, and will they
be sufficient to prevent injury to instream water uses?
If the information provided for these points is insufficient to assess poten-
tial impacts, the reviewer should request further data and discussion of pollu-
tion control approaches. Particularly for headwaters areas the analysis should
be based on .maintenance of the overall ecological integrity of the area, and its
ability to maintain existing populations dependent on existing water quantity
and quality.
The Water Quality Management and River Basin Plans prepared under Section 208
and 303(e) contain assessments of nonpoint sources of pollution, including
silvicultural sources where applicable and an identification and evaluation of
measures necessary to achieve nonpoint source water pollution control. Under
EPA's Regulations on Preparation of Water Quality Management Plans (40 CFR 131)
the controls, regulatory programs, and management agencies are to be identified
for each nonpoint source category.
Actions proposed by the Forest Service are subject to best management practice
(BMP) criteria and other requirements of EPA-approved water quality management
programs. EPA's nonpoint source control guidance documents and the information
in Section III. A. 2 of these guidelines generally identify prevention and reduc-
tion practices. The state regulations will normally be more specific and'^rer^—
haps differ from area to area depending on the extent of water quality problems.
The reviewer should compare the prevention and reduction practices addressed in
the EIS with the applicable BMP requirements for the planning area to ensure
that activities will be carried out without unacceptable water quality impacts.
If information for making this comparison is lacking or certain activities
would conflict with state regulations, the concerns should be raised in the
reviewer's comments. The regional and state-wide water quality management
coordinators may have been involved in the development and review of state
nonpoinc source programs and therefore able to assist the reviewer.
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The environmental impacts of alternative courses of action should be carefully
reviewed. Under the CEQ's new NEPA regulations (40 CPR Parts 1500-1508),
effective July 29, 1979, and adopted July 30, 1979 by the USFS/DSDA, impacts
of the alternatives should be presented in comparative form to provide a clear
basis for choice among the options. Alternatives other than those preferred
by the Forest Service may have different water quality consequences and per-
haps less impact. In areas of outstanding water resource value and other lo-
cations where water quality is critically important, the reviewer should en-
sure that activities will be conducted in the most environmentally beneficial
way consistent with management and other objectives. The reviewer's assess-
ment should include consideration of alternatives in four general categories:
Do nothing - Some activities, no matter how carefully managed, may
pose risks of water quality degradation that are unacceptable in
certain areas. For example, clearcutting or road-building on un-
stable slopes draining to a stream with a valuable fishery might
have to be totally avoided due to major problems of preventing
stream sedimentation.
Do, but at a different location - Recreational facilities or other
developments can be located at alternative sites to reduce potential
water quality impacts in sensitive areas.
Do, but in a different manner - Alternative choices may exist for
harvest methods (selection instead of clearcutting), logging methods
(various cable techniques, tractor, etc.), and other management
activities, which afford substantially greater protection for water
quality.
Do, but at a different time - The scheduling of almost all land-
disturbing or other pollution-causing activities can be adjusted
to avoid impacts at times when the ecology or use of a stream is
highly susceptible to damage from sediments and other pollutants.
In cases involving water resources with high quality and value likely to be
adversely affected by a preferred alternative, it is important that other less
harmful actions be supported in the EPA review. The discussion of location,
scheduling and nature of activities and pollution reduction practices in
Section III.A.2 should help in understanding the range of alternatives avail-
able for various activities as well as the probably magnitude of impacts.
III.B. Review of Solid Waste Management Impacts
Solid waste often has only minor importance with regard to Forest Service
land management. However, proper management of solid wastes is essential in
national forests because of their intrinsic natural, aesthetic and recreational
values. EPA's review should insure that acceptable solid waste management
practices will be used.
*.£.
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III.B.I Sources of Impacts
Human activity is the basic source of solid waste impacts. In national forests
two types of solid wastes need to be considered: (1) refuse, garbage, trash
and other foreign material brought by recreationists, workers and other visi-
tors to the forest, and (2) native material such as logging debris and slash,
generated as a result of logging, clearing, road construction, mining or
other human activities. Although the latter originates from the forest itself,
it still may cause problems and necessitate specific management practices to
minimize adverse impacts.
Campgrounds, picnic areas, swimming areas, ski areas, hiking and snowmobiling
trails and other recreational facilities are the principal locations of solid
waste generation in national forests. All of these areas may attract large
numbers of visitors. Solid waste generation may be localized and concentrated
in relatively small areas as at picnic grounds, or widely dispersed along
trails and virtually any other areas traveled by humans. The-Forest Service
has little direct control over the solid waste management disposal practices
of individuals outside of established recreational areas, except through routine
policing of trails and the general forest. Impacts from improper solid waste
disposal are likely to be largely aesthetic, as the concentration of wastes
would not generally be sufficient to create significant water pollution
problems.
At more intensively developed and utilized recreational sites, solid waste
management needs are greater and regular collection and disposal are necessary
to minimize the potential for adverse impacts. In addition to litter, impacts
could include attraction of flies and rodents if refuse is not properly con-
tained and effects on surface or ground-water quality at disposal sites.
Materials such as slash, bark and other woody and herbaceous debris generated
from various silvicultural activities, collectively termed residue, constitute
a quite different solid waste problem. Quantities of forest residue may be
substantial although largely non polluting, except when oxygen-demanding organic
debris is introduced to water courses. Also, burning of the material may im-
pact on air quality.
III.E.2 Review of Information Adequacy and Impact Quantification
In existing developed recreational areas adequate solid waste management
practices are probably already being employed. In the case of new develop-
ment proposed in the land management plan, solid waste storage, collection
and disposal needs should be described. Projected visitation, waste quan-
tities and landfill space requirements should also be addressed in the EIS.
Guidance for estimating waste generation rates is contained in Design Criteria
for Solid Waste Management in Recreational Areas (Little, 1972)"! Also, simi-
lar guidance is available in Solid Waste Management in Recreational Forest
Areas (Spooner, 1971), a report prepared with specific applicability to
national forests.
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Regular collection of solid wastes is necessary to avoid adverse impacts. Fre-
quency of collection is dependent on the numbers of visitors and the density
of refuse containers in recreational areas. Collection at least twice weekly
is highly desirable. Collection practices for existing recreational manage-
ment areas as well as those proposed for new developments should be described
in the EIS. It is important that sufficient numbers of containers are used
to avoid overfilling between pick-ups. The reviewer should be able to judge
the reasonableness of proposed refuse storage and collection by reference to
waste generation rates and other information in the reports mentioned in the
previous paragraph.
The sanitary landfill is the most common-method of disposal of solid wastes.
Disposal of wastes generated at a national forest could be accomplished at a
landfill operated by the Forest Service, a private contractor or a municipal-
ity and located either on or off federal land. For new landfills, the EIS
should contain information on the sites considered, including proximity to
surface waters and to developed areas, topography, water table depth, soils,
waste quantities to be disposed, availability of suitable cover material and
proposed operating characteristics. The reviewer should object to sites posing
a threat of pollution due to susceptibility to flooding, high ground-water
levels, closeness to streams or other factors. While a landfill is in use,
impacts are dependent principally on the mode of operation. The EIS "should
provide assurances that accepted practices will be followed to minimize im-
pacts, including daily covering of refuse, proper grading, prevention of open
burning and vector control.
The major impacts potentially associated with forest residues are water pollu-
tion and, if burning is involved, air pollution. Water pollution may be
caused by organic debris introduced to water courses. Also, rearranging,
mechanically treating or removal of residues may cause erosion and sedimen-
tation due to disturbance and exposure of soil by equipment. Such impacts
cannot be evaluated quantitatively; however, potential effects are in general
related to the kinds of residue management practices employed and the extent
of site disturbances associated with the practices. In cases where no special
residue treatment is anticipated, measures still must be taken to minimize
entry of logging debris to water courses and to remove material which does
accumulate. Windrowing, piling, or mechanically treating forest residues may
affect water quality through erosion of disturbed sites, with potential im-
pacts dependent on the areal extent, severity, and location of the disturbances.
Steep slopes and areas near streams are often more vulnerable to erosion than
other locations.
III.B.3. Assessment of Solid Waste Impacts
Basically, solid waste management practices on national forests should be in
compliance with applicable state and local regulations, EPA Guidelines for
the Thermal Processing and Land Disposal of Solid Wastes (40 CFR, Parts 240,
241) and EPA Guidelines for Solid Waste Storage and Collection (40 CFR Part
243). These guidelines explicitly exclude solid wastes generated as a result of
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mining and agricultural (including silvicultural) activities, and thus are
relevant to wastes from campgrounds, recreational areas and other Federal
installations on national forest lands.
The land disposal guidelines are mandatory for Federal agencies and delineate
minimum levels of performance required of any solid waste land disposal site
operation. Similarly, the solid waste storage and collection guidelines also
apply to Federal agencies generating solid waste. The guidelines set forth
required and recommended procedures for waste storage and collection. The
EIS should indicate the nature of existing and proposed storage, collection
and disposal practices and discuss how the requirements of the EPA guidelines
will be met. Little's Design Criteria for Solid Waste Management in Recreational
Areas may be referred to for more detailed guidance. If the information pre-
sented is insufficient to permit an evaluation of compliance with the guide-
lines, the reviewer should request additional discussion and documentation.
EPA's solid waste management guidelines do not apply to forest residues, and
assessment criteria are therefore imprecise. The reviewer should expect an
accounting of the land areas involved and methods that will be used to deal
with debris from logging, thinning, and other forestry operations. It is
particularly important that measures to avoid debris accumulations in and
near surface waters and to reduce erosion hazards are identified. If burn-
ing is required, it must be carried out in conformance with pertinent Federal
and state air quality regulations (see Section III.C following). Adequate
specifications of contractor responsibility and frequent field inspection of
all work are necessary to reduce environmental impacts from residue management,
and should be provided for in the plan implementation.
III.C. Review of Air Impacts
Although air pollution does result from various forest land management activi-
ties, impacts are likely to be minor in most cases. Nevertheless, it is im-
portant that the reviewer be aware of the kinds of impacts which could occur
and ensure that they are considered in the EIS.
III.C.I. Sources of Impacts
Potential sources of air pollution can be readily identified; their occur-
rence depends on the nature of planned land management activitites in a
national forest area. Air impacts may be associated with the following:
Exhausts from motorized equipment and vehicles, including tractors,
skidders, logging trucks, automobiles and off-road recreational
vehicles.
Dust generated by equipment movement and use.
Incineration of solid wastes from recreational or other areas.
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Burning of slash, brush, and other forest debris.
.. Uncontrolled forest fires
Pollutants from vehicles and equipment include unburned fuel vapors, hydro-
carbons, carbon monoxide, nitrogen oxide, sulfur oxides and particulates.
Vehicular emissions in national forests are unlikely to result in measurable
impacts on air quality, however, due to the small numbers of vehicles and
their widely scattered usage. At work sites, exhausts and dust may cause
very localized problems.
Combustion products from open burning are primarily smoke, carbon monoxide,
and unburned distillation and pyrolysis products. The amounts, of emissions
depend on the type of fuel, stage of burning (start-up, full-fire, or die-down)
and the size of fire. For example, area or broadcast burning with low fuel con-
centrations will likely result in less complete combustion and emission of more
potential pollutants than piling and burning. And larger piles of forest resi-
due will burn hotter and more completely than smaller piles.
Paniculate matter and also sulfur dioxide and nitrogen oxides contribute to
lowering visibility, discoloring the atmosphere, and producing haze. The 1977
Amendments to the Clean Air Act contain requirements to protect visibility in
Class I areas, which include many of the national forests. EPA has published
a final rule (40 CFR Part 81, effective November 21, 1979) identifying manda-
tory Class I Federal areas where visibility^ is an important value.
III.C.2. Review of Information Adequacy and Impact Quantification
Predictive methods of the sort used in evaluating air quality impacts of high-
ways and motor vehicle emissions would not generally be applicable to national
forest situations, where vehicle usage is unconcentrated and irregular both
spatially and temporally. Impacts are unlikely to be significant in any case
and no special quantitative analysis is required. Automobile and other ve-
hicle emission standards would indirectly serve as a control on some air pollu-
tants.
Burning of slash and other forest debris is an important management practice
in many national forests. Burning is used for several purposes including dis-
posal of residue, reduction in fuel accumulations to reduce forest fire hazard,
preparation of sites for forest regeneration and removal of competing vegeta-
tion underneath established stands.
Air quality impacts attributable to burning of forest residues are not generally
predictable in a quantitative sense, although qualitative inferences are possi-
ble based on relationships among fire behavior, fuel characteristics and meteoro-
logical conditions, topography and other environmental variables. The use of
fire should be "prescribed" in order to minimise, potential air pollution while
accomplishing a desired management objective.
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In prescribed burning critical factors that must be planned are timing of the
burn to correspond v»ith favorable weather and atmospheric conditions, and con-
trols to confine and regulate the intensity of the fire. Careful planning and
administration of burning programs should minimize both the production of smoke
and other air pollutants and the transport of pollutants to sensitive areas,
particularly Class I areas designated under PSD (Prevention of Significant
Deterioration). Proposed methods of conducting and controlling forestry uses
of fire should be clearly delineated in the management plan and EIS.
Some general guidelines to help the reviewer evaluate characteristics of
burning programs include the following (Cramer, 1974) :
The more concentrated the fuel the more complete will be the combustion.
Thus, piling and burning of slash may produce lower emissions than area
burning of an equivalent amount of fuel.
Greater emissions are produced during the start-up and die-down stages
than during the full-fire stage. Higher concentrations of fuel will
reduce the start-up and die-down stages, particularly if fuel is added
to a full fire to maintain high combustion temperatures.
In area burning, a "backing" fire (that is, against the wind) is likely
to be more efficient than a more rapidly moving head fire.
Any controlled burn is apt to be more efficient and produce lower emis-
sions than an uncontrolled wildfire.
The damper the fuel, the less efficient is combustion and the denser
the smoke produced. Thus, slash and debris to be burned should be as
dry as possible.
Uncontrolled wildfires may contribute significantly to air pollution, although
the effects are unpredictable as to time, location or magnitude. Neverthe-
less, forest fires could be cause to prohibit controlled or prescribed burn-
ing in an area, at least temporarily until air quality returned to more normal
levels. In order to carry out burning in such a way as to minimize air impacts,
predictions are necessary of wind speeds and directions, mixing layer character-
istics, stability and other meteorologic factors as well as the prevailing air
quality conditions. Of course, such predictions must be made just before burn-
ing; however, the EIS should describe the criteria that would be applied to
determine how and when burning would be done.
III.C.3 Assessment of Air Impacts
The reviewer's assessment of air impacts should focus mainly on prescribed
burning plans, if any are involved. Vehicular emissions are likely to arise
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from a relatively small number of widely dispersed sources and not cause iden-
tifiable problems. Reduction of dust resulting from logging, truck traffic,
and other equipment operations should be required as part of contract specifi-
cations.
Forestry uses of fire can be managed to control air emissions within acceptable
limits if proper precautions are taken. In assessing potential impacts and
adequacy of the EIS, the reviewer should ensure that:
Burning programs will be fully coordinated with the state air pollu-
tion control agency.
Alternatives to burning have been explored and described, their im-
pacts identified and reasons stated for not selecting such options.
Conditions under which burning will or will not be allowed are iden-
tified in the EIS in conformance with ambient air standards (especially
for particulates).
Some states, and the Forest Service itself in some regions, have smoke manage-
ment plans or systems in which location, extent, timing, meteorological condi-
tions and other factors influencing particulate production and transport may
be prescribed to minimize potential air pollution. Other more general regula-
tions may apply to open burning. The EIS should address these requirements as
well as management plans to comply with the requirements. If this information
is lacking, the reviewer should request additional descriptions of planned
management approaches. It is essential that controls be sufficient to allow
termination of burning in the event of adverse changes in wind or other condi-
tions.
Under the 1977 Amendments to the Clean Air Act, large Wilderness Areas (in
excess of 5,000 acres) are designated as Class I areas, in which very little
deterioration of air quality is allowed. Other national forest areas where
the existing air qualny is better than the national ambient air quality
standards may also be designated as Class I, or Class II or III areas. EPA
has identified mandatory Class I areas where visibility is an important value
(CFR Part 31). The Forest Service has also issued a list of IS National
Forest primitive areas recommended for redesignation as Class I (44 F.R. 24116,
April 24, 1979).
The reviewer should be familiar with EPA's regulations pertaining to prevention
of significant deterioration of air quality (40 CFR 51.24) which specify maxi-
mum allowable increases for particulate matter and sulfur dioxide in such clean
air areas. These requirements could necessitate special controls on slash
burning to prevent violation of particulate standards. The EIS should indi-
cate the class designations of planning areas, particularly where burning is pro-
posed, and demonstrate that burning will be carried out in conformance with the
applicable standards. The 24-hour maximum allowable increases over the base-
line for particulate matter (40 CFR 51.24) are;
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Class I 10 micrograms per cubic meter
Class II 37 micrograms per cubic meter
Class III 75 micrograms per cubic meter
The reviewer should ascertain whether the Forest Service has made a determina-
tion that the plan does or does not conform with the requirements of an EPA-
approved State Implementation Plan. A few of the national forests are located
in nonattainment areas where national ambient air quality standards are not
being met although most are in areas subject to PSD. Either the state's regu-
lations for preventing the significant deterioration of air quality or EPA's
requirements in 40 CFR Part 52.21 if the state plan for PSD has not been approved,
are applicable in areas where air is cleaner than the standards.
EPA is currently in the process of drafting regulations for protection of vis-
ibility in Class I areas (see Advance Notice of Proposed Rulemaking, November
30, 1979 Federal Register, p. 69116). When promulgated, these regulations will
specify requirements to be met in regard to Class I areas.
III.D. Review of Noise Impacts
Noise is not generally of critical concern in national forests, except to the
extent that it may be annoying to recreational and other users of the Federal
lands. This section briefly discusses aspects of noise which should be ad-
dressed in the forest plan and EIS.
III.D.I. Sources of Impacts
Noise sources of possible concern are predominantly motor vehicles and machines,
including skidders, tractors, trucks, chain saws, motorcycles, snowmobiles,
automobiles and others. Although the potential for adverse health effects
is minimal, noise may be important in national forests simply due to its being
"out of place" in the natural environment and likely disturbing to recreational
visitors.
III.D.2 Review of Information Adequacy and Impact Quantification
The impacts of noise in national forests are not amenable to quantification or
prediction, since reactions to noise are apt to be very subjective-and differ-
ent for different individuals. Problems can be reduced by providing for geo-
graphic separation of certain potentially incompatible uses. Mot only the
distance but also the nature of the separation are important; for instance,
noise levels will be attenuated more rapidly in forested areas than on open
land, and noise may carry long distances over open water. Topography also in-
fluences sound travel.
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III.D.5. Assessment of Impacts
In general assessment of noise impacts will be qualitative without reference to
specific standards for noise levels. The principal issue is the compatibility
of noise-producing activities with other recreational uses of the forest. Con-
flicts are most apt to arise between recreational vehicle users and persons
visiting the forest for hiking, nature study, photography, snowshoeing and
similar pursuits. It is important that ways of minimizing these conflicts are
recognized and planned for. One approach is to provide for geographic separa-
tion of uses, for example, prohibiting use of recreational vehicles on or near
hiking trails. Motorized vehicles are presently not allowed to operate on
designated wilderness areas. Time restrictions, such as banning use of snow-
mobiles or motorbikes after sunset, could also lessen noise disturbances. Re-
creational land use plans should be designed to reduce, to the extent possible,
noise problems and impacts caused by off-road vehicles.
III.E. Review of Pesticide Impacts
Pesticide usage in national forests is generally not addressed in detail in
Forest Service land management plans. Rather, separate EISs are required for
operational programs involving use of pesticides. The reviewer should, however,
have a basic understanding of the nature and potential impacts of pesticides
used in silviculture. The following sections should provide a brief orientation
to silvicultural uses of pesticides and potential impacts.
III.E.I. Sources of Impacts
Pesticides used in forestry fall into two major groups; (1) herbicides, which
are used to control various undesirable trees, shrubs and other plants; and
(2) insecticides and rodenticides, applied to control insect and animal pests
and thereby protect commercially desirable tree species. Although pesticides
are important in both forestry and agriculture, the patterns of use differ
considerably. Most forest lands are never treated with pesticides and those
that are rarely receive more than one treatment over a cutting cycle of sev-
eral decades. Also, only a relatively few pesticides (fewer than 10 principal
ones) are used in silvicultural applications as opposed to the larger numbers
for agricultural purposes. Forestry accounts for slightly more than 1 percent
of total pesticide use in the U.S. (Forest Service, 1977). These facts are
not meant to minimize potential problems with silvicultural use of pesticides,
but rather to indicate the relative scope of such uses.
When applied at registered rates, herbicides directly affect only green plants,
although animals dependent on primary producers for food and cover may be in-
directly-impacted. In general forest use herbicides are normally applied by
aircraft. Broad treatments are generally required only once or twice in an
area which is being brought under management. Ground application of herbicides
is practiced for more selective treatment of smaller areas.
Ground application methods can be carried out with negligible effects on water
quality. The greatest concern with aerially applied herbicides is the potential
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for. introducing the chemicals to watercourses. Avoidance of spraying along
creeks and streams and near populated areas is the principal pollution control
technique for aerial herbicide application.
EPA temporarily banned the use of the herbicides 2, 4, 5-T and Silvex on forests,
pastures, and powerline rights of way in March 1979 after a study showed a sig-
nificantly high rate of miscarriages in the town of ALsea, Oregon shortly after
nearby forest areas had been sprayed with 2, 4, 5-T. This pesticide is cur-
rently being reviewed under the EPA's RPAR (Rebuttable Presumption Against Regis-
tration) process. 2, 4, S-T is an important silvicultural tool used to suppress
hardwoods and clear weed species from intolerant softwood'stands. The reviewer
should be aware of the status of restrictions on herbicide and other pesticide
usage, which may change through EPA action as a result of studies of health
hazards or other impacts of particular chemicals.
•
Insecticides are mainly used to control widespread epidemics of defoliating
insects that affect commercially valuable timber. Insecticide applications
often involve large infested areas, since partial treatment could allow further
spreading of insect populations and damage to timber. Insecticides and rodenti-
cides used on the ground are applied in very small quantities and usually away
from open water. Few if any incidents of stream ecosystem damage from ground
application of insecticides and rodenticides have been reported in the litera-
ture. With proper use of the chemicals and barring accidental spills, water
quality effects are likely to be undetectable.
The reviewer should refer to Silvicultural Chemicals and Protection of Water
Quality (Oregon State University, 1977) for a listing of silvicultural pesticides
and descriptions of the nature and extent of their use. No matter what pesticide
is used, the greatest water quality threat is posed by direct applications to
watercourses during aerial spraying. Also, insecticides are potentially more
hazardous than herbicides due to their toxicity to animals and, in some cases,
their tendency to bioaccumulate in the food chain. Because runoff from forest
lands is slight and pesticides are very rapidly absorbed and bound up in forest
soils, the risk of pesticide pollution from treated areas not adjacent to
streams or lakes is usually quite low.
III.E.2. Review of Information Adequacy and Impact Quantification
It is important that all proposed pesticide uses for a planning area are iden-
tified and described in the land management plan and accompanying E1S. If oper-
ational programs involving pesticides are addressed in a separate EIS, the docu-
ment should be incorporated by reference and the proposed programs described.
Also, the EIS should delineate, for pesticide uses not covered in a programmatic
EIS, the areas that would be"treated, the chemicals that would be used and the
methods that would be used to minimize chemical drift to nontarget areas, safe-
guard against accidental spills and monitor operations and water quality. Table
6 in Silvicultural Chemicals and Protection of Water Quality gives recommended
rules on the size and treatment of buffer strips based on the potential hazards
of several forest chemicals and for monitoring of water quality. The text
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provides more detailed guidance on these topics and should aid the reviewer
in'evaluating the adequacy of planned control measures.
III.E.3 Assessment of Pesticide Impacts
Because of the toxicity and other potential hazards associated with pesticides,
their use is carefully planned, regulated and monitored, particularly when
treatment of large areas is called for. The EI5 should demonstrate that appli-
cable federal and state laws and regulations concerning pesticides will be ad-
hered to, and that all reasonable means of preventing and minimizing adverse
impacts will be employed. The basis for federal involvement is the Federal
Insecticide, Fungicide, and Rodenticide Act as amended by the Federal Environ-
ment Pesticide Control Act of 1972 and accompanying EPA regulations. All
pesticides to be used in silviculture must be registered for that use, applied
by certified pesticide applicators and used in strict conformance with regis-
tered application rates.
In addition, the reviewer should ensure that special precautions will be taken
in the vicinity of streams and other water bodies to minimize the possibility
of introducing pesticides directly to open water. Aerial applications of pes-
ticides should be carried out when weather conditions are favorable for minimizing
drift and assuring that a maximum amount reaches target species. Proper handling
and disposal of all pesticide containers and residues are also essential in mini-
mizing pollution. Waters used for drinking water supply or irrigation, in par-
ticular, require a high degree of protection from contamination by pesticides.
In some cases reasonable alternatives to the use of chemical pesticides may
exist and should be considered. For large-scale insect infestations, there may
be no choice but to use pesticides, although considerable research is underway
into biological control methods for specific insect pests. Options may be'
available in pesticide selection, however, to accomplish the desired objective.
That is, one suitable type of pesticide may have lower persistence and toxicity
or higher selectivity for target species, and thus pose less environmental risk
in its use than another. Such choices should be fully evaluated in the EIS.
Possible alternatives to herbicides may include fire (light broadcast burning,
for example) and removal of competing vegetation either by machine or by hand.
These options and their environmental consequences should be discussed and
compated in the EIS along with the no-action alternative.
Recommended maximum concentration levels for silvicultural chemicals, including
allowances for variation in stream size and use, are presented in Silvicultural
Chemicals and Protection of Water Quality. This report expands somewhat on in-
formation in EPA's Quality Criteria for Water and should be used as a guide
for assessing impacts of pesticides used in national forests.
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REFERENCES
Council on Environmental Quality, 1978, Environmental Quality: The Ninth Annual
Annual Report of the Council on Environmental Quality, Washington, D.C., U.S.
Government Printing Office.
Cramer, O.P., 1974, "Air Quality Influences," in Environmental Effects of Forest
Residue Management in the Pacific Northwest: A State-of-Knowledge Compendium,
USDA For. Serv.. General Tech. Report PNW-24.
Forest Service, 1977, Nonpoint Water Quality Modeling in Wildland Management:
A State-of-the-Art Assessment, EPA-600/3-77-036.
James M. Montgomery, Inc., 1976, Forest Harvest. Residue Treatment, Reforestation
and Protection of Water Quality, EPA 910/9-76-020.
Little, H.R., 1972, Design Criteria for Solid Waste Management in Recreational
Areas, U.S. Environmental Protection Agency, Solid Waste Management Series
Report (SW-91ts).
National Academy of Sciences and National Academy of Engineering, 1973 Water
Quality Criteria 1972, EPA R3-73-033, March 1973.
Oregon State University, 1977, Silvicultural Chemicals and Protection of Water
Quality, EPA 910/9-77-036.
Schwab, et al., 1966, Soil and Water Conservation Engineering, Second Edition,
New York: John Wiley S Sons, Inc.
Spooner, C.S., 1971, Solid_ Waste Management in Recreational Forest Areas,
U.S. EPA, Solid Waste Management Office Report (SW-16ts).
U.S. EPA1973, Methods for Identifying the Nature and Extent of Nonpoint Sources
of Pollution, EPA-430/9-73-014.
U.S. EPA, Region X, et al., Logging Roads and Protection of Water Quality,
EPA 910/9-7S-007.
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