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Comment Analysis
for the
Dairy Project Environmental Assessment
The 30-day comment period for the Dairy Project Environmental Assessment was initiated on
October 26, 2011 and concluded on November 25, 2011. A total of 3 comment letters or e-mails
were received.
Comments Received
1. E-Mailed Letter, dated November 16, 2011, Dick Artley
2. E-Mailed Letter, dated November 22, 2011, Doug Heiken, Oregon Wild
3. E-Mailed Letter, dated November 25, 2011, Irene K. Jerome, American Forest Resource
Council
Comment Analysis
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Comment Letter #1
November 16, 2011
Are Attachments Attached?
Dear Ranger Jones,
I have reviewed the Predecisional EA for the Dairy Project.
I am concerned that commercial timber removal and road construction will harm to the countless
natural resources within the cutting units and miles downstream from the cutting units.
I will show that based on best science, commercial logging is not the action that should be taken
to restore the natural resources in the Dairy project area.
The attachments to these comments will include the views of over 300 independent, unbiased
Ph.D. biological scientists who describe the resource damage inflicted by commercial timber sale
activities taken in any location. Indeed, there is no location where a commercial timber sale
could be implemented that‘s exempt from the resource damage they describe.
After reading the quotes in the attachments the Responsible Official should understand that the
scientists intend for their professional views to apply to all commercial timber sales. One cannot
find scientific conclusion literature that is site specific, yet the science should drive individual
projects.
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The Predecisional EA for the Dairy Project Indicates that
1,296 Acres of National Forest Land will be Commercially
Logged
The majority of the American public does not want any timber harvest to occur in their national
forests. Less than 5% of the wood fiber used in America comes from national forests. There is
not a softwood shortage in America. Currently there is a surplus of raw material which drives
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the lumber market down. The decades-old claim by the Forest Service that a timber famine is
eminent has not materialized.
It‘s clear that the Organic Act that allowed Tree farms on private land generate more than
enough wood fiber raw material to supply the domestic demand.
The MULTIPLE-USE SUSTAINED-YIELD ACT OF 1960 (Public Law 86–517; Approved
June 12, 1960) clearly directs the Forest Service to consider the health of all resources when
designing projects:
―SEC. 4. ¿16 U.S.C. 531À As used in this Act, the following
terms shall have the following meanings:
(a) ‗‗Multiple use‘‘ means: The management of all the various renewable surface
resources of the national forests so that they are utilized in the combination that will best
meet the needs of the American people; making the most judicious use of the land for
some or all of these resources or related services over areas large enough to provide
sufficient latitude for periodic adjustments in use to conform to changing needs and
conditions; that some land will be used for less than all of the resources; and harmonious
and coordinated management of the various resources, each with the other, without
impairment of the productivity of the land, with consideration being given to the relative
values of the various resources, and not necessarily the combination of uses that will give
the greatest dollar return or the greatest unit output.‖
Comment: Given the damage to the natural resources caused by the timber sale clearly
described in Attachment #1 this project does not reflect and is not consistent with ―harmonious
and coordinated management of the various resources, each with the other, without impairment
of the productivity of the land, with consideration being given to the relative values of the
various resources, and not necessarily the combination of uses that will give the greatest dollar
return or the greatest unit output.‖
Please review Attachment #1 and Attachment #13.
Comment: The log extraction activities that will occur on the Dairy project will remove dead
and dying material from the site and inhibit the recruitment of downed woody material as time
progresses.
Comment: The log extraction activities that will occur on the Dairy project will increase the
edge effect and increase sunlight into stands, resulting from reduced canopy cover associated
with timber harvest. This will directly promote the population abundance, productivity and
persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland,
1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989). This
ecological damage cannot be mitigated nor can the damage be ignored by claiming it will not
occur.
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Comment: The log landings, temporary roads, skid trails and skyline chutes created for the
Dairy project logging activities will be a source of sediment during precipitation events. The
only way to prevent erosion from bare soil created by logging activities is to place sediment traps
between all bare soil created and live water.
Comment: The log extraction activities that will occur on the Dairy project will reduce the
organic parent material (duff and woody residues) available for soil-formation processes. This
ecological damage cannot be mitigated nor can the damage be ignored by claiming it will not
occur.
Comment: The log extraction activities that will occur on the Dairy project will damage
recreational opportunities and harms visual quality in the vicinity. This ecological damage
cannot be mitigated nor can the damage be ignored by claiming it will not occur.
Comment: The log extraction activities that will occur on the Dairy project will adversely
affect hydrologic processes by reducing canopy interception and evapotranspiration. This
ecological damage cannot be mitigated nor can the damage be ignored by claiming it will not
occur.
Comment: The log extraction activities that will occur on the Dairy project will decrease
hydraulic conductivity and increases bulk density in forest soils after harvest. This ecological
damage cannot be mitigated nor can the damage be ignored by claiming it will not occur.
Comment: The log extraction activities that will occur on the Dairy project will collapse
some of the subsurface pipes, increasing local pore water pressure which increases the chance of
landslides. (Sidle, 1986) This ecological damage cannot be mitigated nor can the damage be
ignored by claiming it will not occur.
Comment: The log extraction activities that will occur on the Dairy project will remove
material that harbors a myriad of organisms, from bacteria and actinomycetes to higher fungi.
These organisms play an important role in the forest. This ecological damage cannot be
mitigated nor can the damage be ignored by claiming it will not occur.
Comment: The log extraction activities that will occur on the Dairy project will remove dead
and dying trees. This will eliminate the habitat required by bird species that feed on insects that
attack living trees resulting in more frequent and larger insect outbreaks (Torgersen et al. 1990)
Comment: ―However, the forest is worth much more living than dead. To believe that you
must only recognize that money is not the only valuable thing on the planet. Forests make
immeasurably valuable contributions to our well being, from water filtration to clean air, from
biodiversity to aesthetic delight.‖
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Source: The Timber Scam by Keith Wright 6/25/2000 http://www.jacksonprogressive.com/issues/misspolitics/timberscam.html
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The Pre-Decisional EA Indicates there will be 2.1 Miles of
Temporary Road Construction Associated with this Timber
Sale
In spite of the clearly established long-term aquatic resource damage caused by forest road
construction on slopes greater than 20%, the Responsible Official proposes to build roads to
make log extraction possible for this timber sale.
Comment: The map of the sale area shows a road density that‘s so high it‘s obscene. The
bare earth exposed by all newly constructed road will be the source of sediment during
precipitation events.
Comment: The argument that the aquatic damage is acceptable because it will be short term
is precluded by the other existing roads in the area that have been pumping sediment for decades.
Comment: At the present time there is enough system road in the national forests of America
to stretch to the moon and halfway back. No more should be constructed. Constructing
temporary road is not the answer!
Comment: Most Forest Service engineers know how temporary roads are located and
constructed. Those who wish to keep the forest ecosystem functioning properly and are not
afraid to speak the truth will argue against all road construction. This includes temporary roads.
Comment: Sometimes temporary roads create more sediment per mile during precipitation
events than system roads. This is because:
1) Temp roads are "designed" by a logger on a cat with no knowledge of hydrology and
the logger is under pressure to work quickly.
2) Most temp roads are outsloped, thus, the water on the road drains off the road at
random places.
3) Temp roads have no surfacing to slow the water velocity. High water velocity picks
up more sediment particles.
4) Temp roads have no ditch. Ditches adjacent to system roads control the water until the
road designer calls for an appropriate outlet culvert location.
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Comment: The forest service claims that temporary roads are ecosystem benign because
these roads will be obliterated after use. Best science contained in the attachments indicates
otherwise.
Attachment #4 contains 54 statements by independent scientists that discuss the natural
resources that are harmed (and some destroyed) by road-related work in the forest. These
opposing views should drive the project design to eliminate or significantly reduce the predicted
harm to the ecosystem created by forest road construction.
Comment: The new temporary road construction planned for the Dairy Project will have
compacted road surfaces which will generate overland flow during precipitation events. Much of
this flow often enters the channel system, locally increasing peak flows.
Comment: The new temporary road construction planned for the Dairy Project will fragment
wildlife habitat. Forest road avoidance leads to underutilization of habitats that are otherwise
high quality.
Comment: The new temporary road construction planned for the Dairy Project will alter
animal behavior by causing changes in home ranges, movement, reproductive success, and
escape response.
Comment: The new temporary road construction planned for the Dairy Project will divide
large landscapes into smaller patches and convert interior habitat into edge habitat.
Comment: The new temporary road construction planned for the Dairy Project will increase
the isolation of populations or species which causes adverse wildlife genetic effects (i.e.
inbreeding, depressed fertility/fecundity, and increased natal mortality) and decreased genetic
diversity from genetic drift and bottlenecks.
Comment: The new temporary road construction planned for the Dairy Project will increase
the likelihood of poaching, overhunting, overfishing, excessive trapping and passive harassment
of animals.
Comment: The new temporary road construction planned for the Dairy Project will adversely
alter the subsurface hydrology of the area. They road‘s slope-cuts and ditching is likely to
intersect the water table and interrupt natural subsurface water movement.
Comment: The new temporary road construction planned for the Dairy Project will change
the microclimate by altering temperature and moisture regimes. This adversely affects wildlife.
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Comment: The description of how the new temporary roads will be ―closed and restored‖
after use at pages 2-8 and 2-9 clearly indicates that the so-called temporary roads that will be
build for the dairy project are not temporary. The temporary roads will be rendered un-driveable
but can be put back in use with little effort.
Real temporary roads are obliterated by pulling the fill material back into the cuts so the soil
resembles the preconstruction angle of repose.
Final Road Construction Comment: Chief Dombeck recognized the long-term
ecological damage caused by forest road construction. To date, Responsible Officials have
ignored Dr. Dombeck‘s prophetic wisdom.
"Roads often cause serious ecological impacts. There are few more irreparable marks we
can leave on the land than to build a road."
Dr. Mike Dombeck, US Forest Service Chief
Remarks to Forest Service employees
and retirees at the University of Montana
February 1998
Source: https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dom
beck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm
Thank you for responding honestly to these comments and not denying that ecosystem harm will
could occur as a result of road construction sanctioned by the Responsible Official that will
occur with the Dairy project. These honest responses will assist the public to understand the
tradeoffs of timber harvest activities with the maintenance of ecological integrity.
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Justifying natural resource harm caused by logging because
it is short-term is an unjustified reason to propose to log the
public land. Comment: The ecological harm inflicted by the Dairy project that the Responsible Official
justifies because the damage will be short term is not supported by science. Neither is there any
mitigation and/or BMP effectiveness data.
The justification for inflicting short term harm is located at the following pages:
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sediment generation caused by biomass removal -- page 3-79
adverse effects to soils, watershed, range, fisheries, wildlife, and recreation from the
action alternatives – page 3-107
Short term harm to resources accumulates over time. The pre-decisional EA dies not analyze the
cumulative effects of the short term harm deemed acceptable by the Responsible Official.
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Reasonable Alternatives Suggested by the Public Owners of
the Malheur National Forest must Never be Rejected and
not Analyzed in Detail because they do not Respond to the
Purpose & Need
This pre-decisional EA indicates that alternatives suggested by the public owners of the Malheur
National Forest will not be analyzed in detail. Developing a reasonable range of alternatives is
essential to NEPA compliance.
The pre-decisional EA at page 2-2 describes the following alternative suggested by a member of
the public in their scoping comments:
“Alternative B
An alternative that proposed additional road closures to
enlarge the unroaded area was brought forward in response
to scoping. This proposal was considered but eliminated
from detailed analysis because it would not meet the
purpose and need for the project.‖
Comment: Not analyzing the citizen generated alternatives in detail because ―it would not
meet the purpose and need for the project‖ indicates that the P & N was written so narrow as to
exclude other reasonable alternatives. Indeed the only action alternative analyzed in detail is the
Proposed Action described in the scoping package. This indicates that the Proposed Action for
this pre-decisional EA was determined prior to the scoping process before the NEPA process had
begun.
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If the Responsible Official is interested in Stabilizing the Local Community Economy and Providing Jobs Proposing a Timber Sale is not the Way
Comment: Logging areas that are used by the public for recreation will harm the stability of
local communities. The stability of local businesses actually suffers when recreationists choose
to go elsewhere for their forest experiences.
The P&N for the pre-decisional EA at page 1-1 states:
―3. Capture the economic value of those trees that are surplus to other
resource needs on lands identified in the Ochoco Forest Plan as suitable for
harvest (Forest Plan, 4-27, 4-28).‖
Comment: Once again, this is not a project goal but an action. This reflects a narrow P&N
constructed after the Responsible Official had selected the alternative. It excludes actions to
bolster the tourism dollars in the area.
Comment: Even the Forest Service discloses that private profits from national forest recreation
create jobs and economic community stability.
“Recreation Contribution to Gross Domestic Product Recreation on national forestlands also results in a boost to local economies and the creation of jobs. The 2010 National Visitor Use Monitoring Report found that spending by recreation visitors in areas surrounding national forests amounts to nearly $13 billion each year. As visitor spending ripples through the U.S. economy, it contributes over $14 billion to GDP, and sustains a more than 224,000 full and part time jobs. Recreation is also one of the easiest and most natural ways to connect people to the outdoors. In FY 2012, the Forest Service will directly create jobs in by accelerating work to maintain, create, and repair recreational infrastructure including trails and campgrounds. This work aligns with the goals of the America’s Great Outdoors initiative.” (Pg. 12)
Source: “Fiscal Year 2012 Budget Overview” USDA Forest Service Link to document: http://www.fs.fed.us/aboutus/budget/2012/justification/FY2012-USDA-
Forest-Service-overview.pdf
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Comment: Seldom does logging affect local employment.
―Long-term trends in commodity-based industries are a factor in the changing conditions
in rural areas, including increased efficiency in resource use, increased labor efficiency,
and reduced labor requirements for resource-processing manufacturing. For example, as
wood products manufacturing has grown more capital intensive, capital has been
substituted for labor and jobs have been lost (Young and Newton 1980). Idaho sawmills
produced the same amount of lumber (two billion board feet) in 1977 and 1999 (Western
Wood Products Association, annual). However there were 25% fewer mill workers in
1999 (13,410) than in 1977 (17,830). West-wide, the number of sawmills
has declined since 1970, but the output per mill has increased (Figure 4-1).‖ (Pgs. 21-22)
Source: Harris. Charles Ph.D. May 2003 ―Forest Resource-Based Economic Development in Idaho: Analysis of Concepts, Resource Management Policies, and Community Effects‖ Report No. 22, Policy Analysis Group, U of I College of Natural Resources Link to document:
http://www.cnrhome.uidaho.edu/documents/PAG%20Commun%20Report22.pdf?pid=104240&d
oc=1
Comment: Nationally the profits made by private individuals involved in timber harvest are a
small fraction of the $13 billion in private profits from recreational use of the national forest. All national surveys indicate that the recreating public dislikes logging in their national
forests.
Comment: Logging does not contribute to the economic stability of local communities and
industries. It would return those communities to the boom and bust cycle of the timber industry.
And it focuses on only one local industry—the timber industry—while ignoring the many other
local industries. And it is unable to control the stability of the timber industry, as that industry is
dependent upon national and global economic factors.
The Dairy project will harm tourism, the recreational industry, fishing and a long list of other
industries. It will harm the economic stability of local communities: those whose municipal
drinking water systems will be impacted by increased sediment from logging; those whose real
estate prices will drop due to nearby logged areas; and those whose ability to attract and keep
local residents who want a high quality of life will be diminished.
Please examine Attachment #13.
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The Responsible Official should not Propose a Timber Sale
to Eliminate or Reduce a Natural Disturbance Event that
Benefits the Forest’s Natural Resources
The P&N at page 1-1 states:
―2. Improve the health, vigor, and resiliency of vegetation to insects, disease,
wildfire, and other disturbances, to more closely resemble historical
conditions in order to promote long-term forest sustainability and wildlife
species diversity; and meet requirements of the Ochoco National Forest Plan
(Recommendation from Silver Creek WA, pp.62),‖
Comment: Attachment #8 describes how Fire benefits the countless natural resources in the
forest besides conifer tree species. The Responsible Official does not recognize this ecological
fact.
Comment: As Attachment #5 shows, insect activity is a beneficial natural disturbance event
in the forest. Of course insects kill trees. A forest has countless other natural resources in
addition to conifer trees. The Responsible Official does not recognize this ecological fact.
Comment: The Responsible Official should not attempt to take action that negates the proper
functioning of the forest‘s natural resources to generate corporate profit.
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Legal Precedent Requires the Forest Service
to Base their Proposed Projects on Best
Science
A Federal Register notice and an opinion handed down in the Tenth Circuit Court of Appeals
indicate that the Forest Service must base their projects on best science. Please see below.
―The purpose of this interpretative rule is to clarify that, both for projects implementing
plans and plan amendments, paragraph (a)‘s mandate to use the best available science
applies.‖
Source: Federal Register / Vol. 69, No. 188, page 58056 Wednesday, September 29, 2004
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Rules and Regulations http://www.fs.fed.us/r1//projects/plan_rule/intrpretative-rule.pdf
―The 1982 forest planning regulations at 36 C.F.R. Part 219 were superseded in
November 2000, when new regulations were promulgated. 65 Fed. Reg. 67,568 (Nov. 9,
2000). Under the transition provision of the 2000 regulations, the Forest Service was
required to consider the "best available science" when implementing site-specific projects
within a forest plan. 36 C.F.R. 219.35(a) (2001).‖
Source: The Ecology Center, Inc., v. United States Forest Service United States Court of
Appeals, Tenth Circuit, June 29, 2006 An Appeal from the United States District Court
for the District of Utah (D.C. No. 2:03-CV-589-TS) http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=search&case=/data2/circs/10th/0
54101.html
Clearly the attachments to this comment letter constitute ―best science.‖
Comment: For decades Forest Service leaders have told the public that agency projects are
based on and are consistent with best science. This is clearly indicated in the words of Forest
Service leaders shown in Attachment #15.
Comment: The Responsible Official must not require the literature containing the opposing
views or the opposing views themselves to be site-specific because the citations and references
contained in the References section of the pre-decisional EA on pages 4-20 to 4-28 used to build
the pre-decisional EA are not site-specific to the Dairy project.
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Please Take Appropriate Action if any of the New
Species Proposed for listing May Exist or have
Habitat … in, Near or Downstream from the Sale
Area.
On September 11, 2011 a federal judge today approved a legal agreement between the Center for
Biological Diversity and the U.S. Fish and Wildlife Service requiring the agency to make initial
or final decisions on whether to add 757 imperiled plants and animals to the federal endangered
species list by 2018.
The following are proposed for listing: 26 birds, 31 mammals, 67 fish, 22 reptiles, 33
amphibians, 197 plants and 381 invertebrates.
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The 757 species are listed in alphabetical order at:
http://www.biologicaldiversity.org/programs/biodiversity/species_agreement/species_list.html
The species listed by occurrence by state are at:
http://www.biologicaldiversity.org/programs/biodiversity/species_agreement/species.html#Mont
ana
Please provide links to survey information showing the basis for the Responsible Official‘s
decision.
Source: http://www.courthousenews.com/2011/09/13/39728.htm
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Conclusion
Comment: Clearly, this member of the public has established that the Dairy commercial
timber sale will inflict long-term harm the forest‘s natural resources more than they improve the
conifer vegetation. Indeed, on public land conifer tree species must never be manipulated to
resemble fast-growing vigorous trees that are the goal of employees to tend private industrial tree
farms.
Comment: At page 3-17 the Responsible Official claims that the project will ―restore‖ vigor
and sustainability of the conifer vegetation in the Dairy project area. Trees in a tree-farm are
managed to provide profitable logs as soon as possible, thus they are manipulated to increase
vigor.. Tree farms are the antithesis of a real biodiverse forest that is able to sustain the natural
resources we all love.
Comment: Because the agency is dominated by a timber-extraction culture, Forest Service
employees are taught to believe that if the merchantable conifer trees are manipulated (usually
logged) the health of the countless other natural resources in the forest will also be improved.
This is sad.
Comment: It is highly likely that the resource damage caused by logging that‘s discussed in
the attachments to these comments will result from implementing this timber sale. NEPA
requires the Responsible Official to analyze cumulative effects. The final EA must describe the
condition of the many natural resources in and downstream from the sale area before and after it
is logged and the roads have been built.
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For the natural resources that the Responsible Official determines might or could be degraded by
the tree removal activities please describe the future restoration projects that will be necessary
and how these projects will be funded.
Comment: This timber sale is being prepared in spite of the fact that over 70% of the adults
in the United States don‘t want their national forests logged.
Comment: Even with the low interest rates, the recession has caused the new housing starts
are down. There is no need for the raw material to be forced on the lumber market. The mill-
yards are full of logs. They are not being cut until the market improves. There is no place to put
the logs.
Comment: Those members of the public who are familiar with the Forest Service timber-
centered culture know market conditions are irrelevant when a USFS Responsible Official
decides to sell timber. They are motivated to damage the natural resources in the forest because:
1) they strive to meet the volume production expectations of their supervisors, and
2) they know that if they don‘t spend their timber dollars allocated to their forest their
budget could be reduced the following year.
Comment: In the Forest Service decisions to remove merchantable conifer tree species are
not based on the science of forest ecology, they are based on politics.
Final Comment: In order to take action that is consistent with Mr. Pinchot‘s ideals instilled
the Forest Service a century ago the Responsible Official can only provide “The greatest good
for the greatest number of people‖ by implementing everything in the Dairy Proposed Action
except commercial timber harvest and ―temporary‖ road construction.
Sincerely,
Dick Artley’s scanned signature is contained in the
“signature” attachment.
Dick Artley (retired forest planner, NEPA legal compliance reviewer, 1900-1 NEPA instructor,
forest NEPA coordinator, and forest appeals/litigation coordinator --- Nez Perce National Forest,
Idaho)
415 NE 2nd
Street
Grangeville, Idaho 83530
(208)-983-0181
Note: If you wish to verify my past USFS employment, I invite you to call the Nez Perce
National Forest SO at (208)-983-1950
Hardcopy CC to: USDA Secretary Vilsack
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U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250
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Responses to Comment Letter #1
Comment 1-1: The EA, Chapter 3, discloses the effects of the alternatives. Please also refer to
responses to attachments 1 and 13.
Comment 1-2: The EA, page 2-4 states ―Thinning and biomass activities would manage live
trees less than 21 inches diameter at breast height (DBH), with an emphasis on stocking level
controls, removing mistletoe-infected trees, and reducing stocking of grand fir.‖ ―Biomass
removal/reduction does not include removal of downed logs or dead trees over 12‖ DBH.‖
Comment 1-3: The EA, page 3-12 describes the existing condition of forest pests. Effects to
forest pests are described in the EA pages 3-17 to 3-19.
Comment 1-4: The EA, page 3-77 describes the existing condition of detrimental soil
conditions. Effects to watershed and soil are described in the EA pages 3-78 to 3-81.
Comment 1-5: The EA, pages 3-78 to 3-81 describes the effects to watershed and soil.
Comment 1-6: The EA, pages 3-90 and 3-92 to 3-93 describes the effects to scenery
management and recreation.
Comment 1-7: The EA, pages 3-78 to 3-81 describes the effects to watershed.
Comment 1-8: The EA, pages 3-78 to 3-81 describes the effects to watershed and soil.
Comment 1-9: The EA, pages 3-78 to 3-81 describes the effects to watershed and soil.
Comment 1-10: The EA, page 1-9 to 1-12 describes the issues identified during scoping.
Organisms like bacteria and actinomycetes were not identified as an issue during the scoping
process. Sensitive plants suspected to occur on the district are derived from the 2008 Region 6
Sensitive Plant List (EA page 3-85). The 2008 Sensitive Species List does not contain any
sensitive fungi for the Malheur National Forest, therefore none are addressed. Sensitive mosses,
liverworts and lichens documented or suspected to occur on the Malheur National Forest are
addressed in the EA, pages 3-85 to 3-89.
Comment 1-11: The EA, page 2-4 states ―Thinning and biomass activities would manage live
trees less than 21 inches diameter at breast height (DBH), with an emphasis on stocking level
controls, removing mistletoe-infected trees, and reducing stocking of grand fir.‖ ―Biomass
removal/reduction does not include removal of downed logs or dead trees over 12‖ DBH.‖
Additionally, the EA, page 3-12 describes the existing condition of forest pests. Effects to forest
pests are described in the EA pages 3-17 to 3-19.
Comment 1-12: The EA, page 1-1 describes the purpose and need for action.
Comment 1-13: The EA, page 3-36 states ―The Forest Plan requires minimum road densities at
1.0 mi/mi2 in winter range and 3.0 mi/mi
2 in summer range. Current road densities are 2.2 mi/mi
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in winter range and 2.4 mi/mi2 in summer range which meet Forest Plan standards with the
exception of winter range.‖ The EA, page 2-4 states ―No new permanent road construction is
proposed. Temporary roads are roads authorized by contract, permit, lease, or other written
authorization, or emergency operation not intended to be part of the forest transportation system
and not necessary for long-term resource management.‖ The EA, page 3-72 also states
―Proposed temp roads would be used to remove trees on several units. Since these roads are not
located in RHCAs, are on relatively flat ground, and would be closed, seeded and slashed with
vegetation when the project is completed there are no expected negative effects to aquatic
species or their habitat.‖ The EA, page 3-72 also states ―Direct beneficial effects from road
closures and decommissioning would be a decrease in chronic sediment input to streams and
improved spawning and rearing habitat for redband trout, Columbia spotted frogs and other
aquatic species. Indirect long term beneficial effects would be an increase in large woody
material recruitment and an increase canopy closure (shade) along streams as closed and
decommissioned road segments re-vegetate with native conifers and hardwoods.‖
Comment 1-14: Please refer to the response to comment 1-13.
Comment 1-15: The EA, page 2-4 states ―No new permanent road construction is proposed.
Temporary roads are roads authorized by contract, permit, lease, or other written authorization,
or emergency operation not intended to be part of the forest transportation system and not
necessary for long-term resource management.‖
Comment 1-16: The EA, page 2-5 discusses temporary roads. See also the Design Criteria in the
EA, pages 2-7 to 2-10
Comment 1-17: The EA, page 3-72 also states ―Proposed temp roads would be used to remove
trees on several units. Since these roads are not located in RHCAs, are on relatively flat ground,
and would be closed, seeded and slashed with vegetation when the project is completed there are
no expected negative effects to aquatic species or their habitat.‖
Comment 1-18: Please refer to responses to attachment 4.
Comment 1-19: Please refer to the response to comment 1-17.
Comment 1-20: A map in the EA, page 2-13 demonstrates that rarely does a proposed
temporary road exceed ¼ mile in length. Additionally, effects to terrestrial wildlife species is
described in the EA on pages 3-45 to 3-60. See also the response to comment 1-15.
Comment 1-21: Please refer to the response to comments 1-15 and 1-20.
Comment 1-22: Please refer to the response to comments 1-15 and 1-20.
Comment 1-23: Please refer to the response to comments 1-15 and 1-20.
Comment 1-24: Please refer to the response to comments 1-15 and 1-20.
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Comment 1-25: The EA, pages 3-79 to 3-81 describes the effects to watershed and soils.
Comment 1-26: Please refer to the response to comments 1-15 and 1-20.
Comment 1-27: The EA, page 2-5 states ―Temporary roads are not intended to be included as
part of the forest road atlas, as they are managed by the projects or activities under which they
are authorized and decommissioned at the conclusion of the authorized activity.‖ The EA pages
2-8 and 2-9 describes the activities needed to close and restore temporary roads.
Comment 1-28: The EA, page 2-5 states ―No new permanent road construction is proposed.‖
Comment 1-29: The EA, page 3-106 describes the relationship between short-term uses and
long-term productivity. The EA, page 3-107 describes unavoidable adverse effects. Additionally,
chapter 3 of the EA describes the effects of the alternatives. The EA, page 3-79 states ―During
road decommissioning, culverts would be removed. Removing culverts may result in short-term
(< 1 year) sediment increases to stream channels; however, design features and BMPs would
minimize these impacts. Long-term effects would include improvements to water quality and the
reestablishment of natural stream channel morphology and riparian vegetation.‖
Comment 1-30: One aspect of the purpose and need for the project is to ―improve soil and
watershed conditions by reducing road related impacts to water quality, fish habitat, and wildlife
habitat; and meet requirements for the Ochoco National Forest Plan‖ (EA page 1-1). Therefore
closing additional roads to enlarge an ―unroaded area‖ does not meet the purpose and need.
Comment 1-31: The EA, page 1-1 states that the purpose and need for the project is to ―Capture
the economic value of those trees that are surplus to other resource needs on lands identified in
the Ochoco Forest Plan as suitable for harvest (Forest Plan, 4-27, 4-28).‖ Refer also to the
response to comment 1-6.
Comment 1-32: Please refer to the response to comment 1-30.
Comment 1-33: The EA, page 3-84 describes the effects to socio-economics.
Comment 1-34: The EA, page 3-84 states ―The Proposed Action would support the highest level
of contract-related jobs and timber harvesting related jobs. The alternative with the highest jobs
would support the highest potential incomes.‖
Comment 1-35: Please refer to the response to comments 1-30 and 1-33.
Comment 1-36: Please refer to the response to comment 1-34.
Comment 1-37: The EA, discloses the effects to recreation (pages 3-92 to 3-93), aquatics (pages
3-70 to 3-75), watershed and soils (pages 3-78 to 3-81) and socio-economics (page 3-84). Please
also refer to the responses to attachment 13.
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Comment 1-38: The EA discloses the effects to fire, fuels and air quality on pages 3-24 to 3-25.
Please also refer to the responses to attachment 8.
Comment 1-39: Forest pests are discussed in the EA, pages 3-12 to 3-13. Additionally the
effects to forest pests are disclosed in the EA, pages 3-17 to 3-19. Please also refer to the
responses to attachment 5.
Comment 1-40: Please refer to the response to comment 1-39.
Comment 1-41: The EA, page 3-1 describes the use of best science. Please also refer to the
responses to attachment 15.
Comment 1-42: Please refer to the response to comment 1-41.
Comment 1-43: The EA, page 1-9 states ―Forest Service Manual 2672.4 requires the Forest
Service to review all its planned, funded, executed or permitted programs and activities for
possible effects on proposed, endangered, threatened or sensitive species. On January 31, 2008,
Regional Forester Linda Goodman released an updated Sensitive Species List which includes
federally listed, federally proposed and sensitive species lists. In the cover letter for the updated
species list (Regional Forester Linda Goodman, January 31, 2008) the Regional Forester states
that projects initiated prior to the date of this letter may use the updated sensitive species list or
the list that was in effect when the project was initiated. The Responsible Official for the project
has authority to decide which list to use. The Responsible Official has decided to use the 2008
Regional Forester Sensitive Species list as documented in the EA.‖
Comment 1-44: The EA, pages 2-14 to 2-16 discloses a summary of the effects of the
alternatives. See also chapter 3 for more detailed effects.
Comment 1-45: The EA, page 3-17 to 3-18 states ―In stands that were harvested and
precommercially thinned prior to about 1980, proposed treatments would restore vigor and
sustainability, and the stands would move toward HRV sooner than untreated stands.‖
Comment 1-46: This is outside the scope of this project.
Comment 1-47: The EA discloses the cumulative effects of the alternatives for each resource on
the following pages, Access and Travel Management page 3-6, Vegetation page 3-18 to 3-19,
Fire, Fuels and Air Quality page 3-25, Range Resources pages 3-26 to 3-28, Invasive Plant
Species page 3-30 to 3-31, Terrestrial Wildlife page 3-55 to 3-60, Fisheries page 3-72 to 3-75,
Watershed and Soils page 3-80 to 3-81, Socio-Economics page 3-84, Sensitive Plants page 3-86
and 3-88, Scenery Management page 3-90, Recreation page 3-92 to 3-93, Heritage Resources
page 3-94 to 3-95, Inventoried Roadless, Potential Wilderness, Areas with Undeveloped
Character, and Research Natural Areas pages 3-98 to 3-99.
Comment 1-48: The EA, page 2-2 to 2-3 describes the No Action Alternative. Under the no
action alternative, no vegetation restoration activities would occur; no additional roads would be
closed or decommissioned. Road densities would remain at the current levels.
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Comment 1-49: The EA, page 3-82 to 3-84 describes the socio-economics and effects of the
alternatives.
Comment 1-50: This is outside the scope of this project.
Comment 1-51: The EA, pages 4-20 to 4-28 lists the literature cited to support the analysis.
Comment 1-52: Please refer to the response to comment 1-48.
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Comment Letter #2
FROM: Doug Heiken, Oregon Wild | PO Box 11648, Eugene, OR 97440 | 541-344-0675 |
ATTN: Doug Jones, Emigrant District Ranger
DATE: 22 November 2011
RE: Dairy EA comments
Please accept the following comments from Oregon Wild regarding the proposed Dairy EA
dated October 2011 involving:
1296 acres of commercial harvest
15 miles of road closure
4.9 miles of road decommissioning
In the Silver Creek watershed, on the Ochoco NF, located NW of Riley
one big unit (#15) located within an unroaded area <1,000 acres.
We encourage valid and necessary restoration actions such as:
culturing large and old trees;
reducing encroachment of small/young conifers around old growth trees and under-
represented species like aspen;
forests highly altered by past management may require careful variable thinning of small
trees, favoring fire resilient species like ponderosa pine;
retaining generous untreated "skips" scattered both within and between treatment units
(e.g. the unroaded area);
retain all large and all old trees regardless of species (including juniper and white fir);
decommissioning roads;
limit grazing to restore healthy and diverse understory vegetation and watershed
conditions;
removing weeds;
reintroducing fire;
managing for ongoing recruitment of appropriate levels of snags and dead wood in
different forest types.
While we encourage these restoration treatments, we also perceive risks and trade-offs associated
with logging that must be recognized and weighed. We do not dismiss the capacity of natural
systems to self-organize and self-correct many of the adverse changes that have been caused by
past fire suppression, grazing, logging and roading, if we allow natural processes to operate.
We noted the presence of an unroaded area in our scoping comments but now we see that unit
15, in section 3, appears to be located in an unroaded area >1,000 acres known as Lower Buck
Mountain (shown in semi-transparent green on the map below). There are also three adjacent
unroaded areas to the south which together comprise an low-road-density areas over 4,000 acres
(as shown by the map in our scoping comments). Such areas harbor remnants of historic
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conditions that are now rare on the landscape, and they should be carefully conserved. Adverse
effects from past management are less prevalent in unroaded ares, so the need for intervention in
the form of commercial logging is less clear. Using non-commercial restoration methods such as
pre-commercial thinning and prescribed fire would be preferred in this area, so as to avoid
adverse impacts from heavy equipment required to cut, process, and remove commercial sized
logs.
The summary of effects of the action and no action alternative oversimplifies the effects of
logging, by overstating the benefits of logging, and understating the risks of logging. NEPA
requires balanced analysis that honestly confronts adverse impacts and trade-offs.
The summary claims that no action will cause harm to aquatic systems via wildfire. This is
highly speculative. Wildfire is not always uncharacteristic. No action is not very likely to cause
adverse aquatic impacts because the actual likelihood of high-severity wildfire is low; the effects
of treatments are complex and could make fire effects worse or better; treatments have only
a temporarily effect; and fire is a natural feature of this landscape so the aquatic effects of fire
may not be uncharacteristic. The FS should use a probabilistic analysis to properly evaluate the
effects of events like fire that are unlikely to influence these stands during the relatively brief
time that the treatments are effective. On the other hand, commercial logging does not really
have a natural analog, so it is more likely to cause uncharacteristic effects on habitat, soil, and
water.
The summary of effects also asserts that logging will result in beneficial effects to large snags.
This is implausible because logging will remove trees that would otherwise continue to grow and
someday be recruited as large snags. This unavoidable effect means that logging will result in
fewer large snags, not more large snags. A proper analysis must account for both the quality of
snags which might increase slightly versus the quantity of snags which will decline significantly
as a result of logging.
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The EA relies on the outdated potential population methodology for determining how many
snags are needed to meet the needs of primary cavity excavators. This methodology is outdated.
Science now tells us that snag associated species need far more snags and far more green trees to
ensure that those snags are recruited and available over time. See below, "New information on
snags." The EA needs to provide a more explicit description of the effects of logging in terms of
reducing snag recruitment. BLM should prepare an EIS before relying on DecAID and carefully
consider all of its caveats and cautions. Once this is done, BLM will find they need to be
managing for at least 5-80% DecAID tolerance levels after logging and over time.
P 3-46 says that large tree habitat would be jeopardized under the no action alternative. This is
not substantiated. Previous studies show that unlogged forests will generally recruit more large
snags over time. See Heiken, D. 2010. Dead Wood Response to Thinning: Some Examples from
Modeling Work. http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf. If BLM this this
forest is different then they should provide clearly quantitative analysis to support their assertion.
The nearby Egley Fire is not a reason to be complacent but rather a reason to provide for greater
snag recruitment. This is because the most significant effect of a stand replacing fire is to create a
"snag gap" in the future, after most of the snags from the fire have fallen and before the new
stands begin to recruit large trees and snags. This means that nearby green stands need to retain
more trees that can serve as potential snag recruitment. The unroaded area in Unit 15 is a perfect
place to recruit snags because there is less risk that snags will be poached for fire wood or face
other threats. Korol et al (2002) pointed out the significant value of unroaded areas in this regard.
They estimated that even if we apply enlightened forest management on federal lands in the
Interior Columbia Basin for the next 100 years, we will still reach only 75% of the historic large
snag abundance, and most of the increase in large snags will occur in roadless and wilderness
areas. Jerome J. Korol, Miles A. Hemstrom, Wendel J. Hann, and Rebecca A. Gravenmier. 2002.
Snags and Down Wood in the Interior Columbia Basin Ecosystem Management Project. PNW-
GTR-181. http://www.fs.fed.us/psw/publications/documents/gtr-181/049_Korol.pdf Page 3-56
of the EA recognizes the importance of the Dairy Project area for snag recruitment to mitigate
for the snag gap likely to be caused by the Egley fire. However, the EA erroneously assumes that
logging is good for snags when the opposite is more likely true. See Heiken, D. 2010. Dead
Wood Response to Thinning: Some Examples from Modeling Work.
http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf We are not aware of
any quantitative studies showing that commercial logging in forests like these will increase the
number of large snags over a long series of future decades.
In conclusion, we want to see this project move forward, especially the road work and careful
thinning of mall trees outside of the unroaded area. We encourage the FS to consider some
adjustments to make this project better.
Sincerely,
/s/
_____________________________________
Doug Heiken, Oregon Wild
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PO Box 11648, Eugene OR 97440
[email protected], 541.344.0675
New Information on Snags
The federal forest agencies now recognize that current methods and assumptions concerning
snag habitat standards are outdated, and the old snag standards do not ensure enough snags to
meet the intent of the standard, yet the agencies have not adjusted their management plans to
account for this new information nor have they developed new standards that are consistent with
the latest scientific information.
A few of the problems with the old standards are:
They failed to account for the fact that the number of snags needed for roosting, escape,
and foraging can exceed the number of snags needed for nesting;
They failed to recognize that the number of snags needed to support viable populations of
secondary cavity users may exceed the needs of primary cavity excavators;
The old standard failed to account for the size height of snags favored by some species;
In applying the old standards the agencies often fail to account for rates of snag fall and
recruitment;
The old standards fail to recognize non-equilibrium conditions in our forests, i.e . some
species rely on the natural large pulses of snags associated with large disturbances;
The old standards fail to account for the differential use of space and population density
of different species;
The old standards ignore other important habitat features of dead wood, e.g. loose bark,
hollow trees, broken tops, etc.
Forest Plan standards were based on a model that did not account for snags required for
foraging (EA p. 68 and Appendix K p. 45). There is general consensus in the scientific and
professional community that using the biological potential model (which was used in
developing the Forest Plan standard) is flawed and does not provide adequate nesting,
roosting, or foraging structure for cavity excavating birds …
North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project DN.
http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne
pa/53012_FSPLT2_055455.pdf
Bull et al. (1997) states current direction for providing wildlife habitat on public forest lands
does not reflect the new information available, which suggests that to fully meet the needs of
wildlife, additional snags and habitat are required for foraging, denning, nesting, and roosting.
Rose et al. (2001) suggests that calculation of numbers of snags required by woodpeckers based
on assessing their ―biological (population) potential‖ is a flawed technique (Rose et al. 2001) due
to the fact that empirical studies are suggesting that snag numbers in areas used and selected by
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some wildlife species are far higher than those calculated by this technique. There is general
consensus that the biological potential model does not provide adequate nesting, roosting, or
foraging structure for cavity excavating birds (Bull et al. 1997, Johnson and O‘Neil 2001). This
suggests the current direction of managing for 100 percent population levels of primary
excavators may not represent the most current knowledge of managing for cavity nesters.
North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project EA,
Appendix K – Terrestrial Wildlife Specialist Report. p K-45.
http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne
pa/53012_FSPLT2_055426.pdf
The agencies need to prepare a EIS to consider a replacement methodology for maintaining
species and other values associated with dead wood. This is especially critical because adequate
dead wood is recognized as an essential feature of healthy forests and the Forest Service has
identified lots of ―management indicator species‖ associated with dead wood habitat.
Back in the early 1990s the Forest Service recognized the their forest plans were not adequate to
maintain populations of spotted owls and they tried to develop plans to conserve spotted owl
without following NEPA and NFMA procedures. The courts said they had to stop cutting owl
habitat until they had complied with environmental laws. This is the same situation we find
ourselves in today with dead-wood associated species. The agencies should stop harming dead
wood habitat until they have a legal plan to conserve associated species over the long-term.
Seattle Audoban Society v. Epsy, 998 F.2d 699, 704 (9th Cir. 1998) (an agency must re-examine
its decision when the EIS "rests on stale scientific evidence and false assumptions").
Bull et al. states that the current direction for providing wildlife habitat on public forest lands
does not reflect the new information that is available which suggests that to fully meet the
needs of wildlife, additional snags and habitat are required for foraging, denning, nesting,
and roosting (1997). Johnson and O‘Neil (2001) and Rose et al. (2001) also state that several
major lessons have been learned in the period 1979 to 1999 that have tested critical
assumptions of earlier management advisory models (2001), including some of the
assumptions used to develop the current recommendations in the LRMP Standards and
Guidelines, as amended by the Regional Forester‘s Amendment #2. Some assumptions
include:
• calculation of numbers of snags required by woodpeckers based on assessing their
―biological (population) potential‖ is a flawed technique (Johnson and O‘Neil 2001).
Empirical studies are suggesting that snag numbers in areas used and selected by
some wildlife species are far higher that those calculated by this technique (Johnson
and O‘Neil 2001).
• numbers and sizes (dbh) of snags used and selected by secondary cavity nesters
often exceed those of primary excavators (Johnson and O‘Neil 2001).
This suggests the current direction of managing for 100 percent population potential levels of
primary excavators may not represent the most meaningful measure of managing for cavity-
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nesters and that these snag levels, under certain conditions, may not be adequate for some
species.
Fremont-Winema NF. Barnes Valley-Long Branch Restoration and Enhancement Project EA
Appendix B – DecAID Information.
http://www.fs.fed.us/r6/frewin/projects/analyses/barneslong/ea/appb.pdf
Lessons Learned During the Last Fifteen Years
…
Several major lessons have been learned in the period 1979-1999 that have tested critical
assumptions of these earlier management advisory models:
. Calculations of numbers of snags required by woodpeckers based on assessing their
‗biological potential‘ (that is, summing numbers of snags used per pair, accounting
for unused snags, and extrapolating snag numbers based on population density) is a
flawed technique. Empirical studies are suggesting that snag numbers in areas used
and selected by some wildlife species are far higher than those calculated by this
technique.226
. Setting a goal of 40% of habitat capability for primary excavators, mainly
woodpeckers,369
is likely to be insufficient for maintaining viable populations.
. Numbers and sizes (dbh) of snags used and selected by secondary cavity-nesters
often exceed those of primary cavity excavators.
. Clumping of snags and down wood may be a natural pattern, and clumps may be
selected by some species, so that providing only even distributions may be
insufficient to meet all species needs.
. Other forms of decaying wood, including hollow trees, natural tree cavities, peeling
bark, and dead parts of live trees, as well as fungi and mistletoe associated with wood
decay, all provide resources for wildlife, and should be considered along with snags
and down wood in management guidelines.
. The ecological roles played by wildlife associated with decaying wood extend well
beyond those structures per se, and can be significant factors influencing community
diversity and ecosystem processes.
Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., Waddell, K.L., Lindely, D.L., and B.
Schrieber. 2001. Decaying Wood in Pacific Northwest Forests: Concepts and Tools for Habitat
Management, Chapter 24 in Wildlife-Habitat Relationships in Oregon and Washington
(Johnson, D. H. and T. A. O'Neil. OSU Press. 2001)
http://web.archive.org/web/20060708035905/http://www.nwhi.org/inc/data/GISdata/docs/chapte
r24.pdf
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The potential population models are based on the number of trees needed for nesting cavity-
excavator birds, however, ―[t]he high value of large, thick-barked snags in severely burned
forests has as much to do with feeding opportunities as it does with nesting opportunities they
provide birds.‖ (Hutto. ConBio 20(4). 2006.
http://avianscience.dbs.umt.edu/documents/hutto_conbio_2006.pdf ). The number of snags
needed to support bird feeding, escape from predators, and other life functions, is different than,
and likely higher than, the number of snags needed to support nesting, so the agencies‘ existing
―potential population‖ snag standards are arbitrary and capricious.
There is evidence that retaining more than the minimum number of snags has significant benefits
for cavity dependent species. Comparing two sites in Northern California, Blacks Mountain
Experimental Forest (BMEF) with little past logging and lots of snags, and Goosenest Adaptive
Management Area (GAMA) with lots of logging and fewer snags, the author‘s found ―… three
times as many snags (6.38/acre vs. 2.04/acre, respectively) … The use of snags by cavity-nesting
bird species was dramatically different between the sites. Thirty-one cavity-nesting pairs from 10
species were detected at BMEF, while only one pair each of two species were detected at
GAMA…. This fifteenfold difference is much greater than any measure of snags or cavities
reported. …‖
We feel that forest managers may well be asking a misleading question. ―Snags per acre‖
requirements implicitly assume an equilibrium condition and reflect only one ecological
requirement for a given cavity-nesting species. … [C]onsideration of foraging habitat and
other ecological requirements must be part of the ―snags per acre‖ management
considerations. This is an important, but somewhat daunting proposition, as potential
cavity-nesting species are diverse, and each species likely has very different foraging
ecologies, as well as other differences in habitat requirements. … [C]avity nesters at
BMEF used larger snags on average … [T]he loss of large trees due to logging in eastside
pine and other forests, over the past century has major implications for cavity-nesting
birds. … [F]orest managers must have a sense of snag recruitment in relationship to snag
fall, and the patterns and processes that underlie them, when addressing wildlife needs.
… We view the understanding of these complexities to be of primary importance in forest
management for wildlife.
Steve Zack, T. Luke George, and William F. Laudenslayer, Jr. 2002. Are There Snags in the
System? Comparing Cavity Use among Nesting Birds in ―Snag-rich‖ and ―Snag-poor‖ Eastside
Pine Forests. USDA Forest Service Gen. Tech. Rep. PSW-GTR-181.
http://www.fs.fed.us/psw/publications/documents/gtr-181/017_Zack.pdf
Another recent science publication asked that the agencies salvage polices be brought up to date
with current science.
Inadequacy of Current Snag Guidelines
Current snag-retention guidelines for most North American plant community types fall
between 1 and 8 snags/ha. These guidelines emerged primarily from a consideration of
the nesting requirements of cavity-nesting vertebrate species in the now classic Blue
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Mountains book (Thomas 1979). The retention of 8 snags/ha was judged to support 100%
of the maximum population density of any of the woodpecker species that occur in the
Blue Mountains area (Thomas 1979: Appendix 22). Bull et al. (1997) concluded that
about 10 snags/ha in ponderosa pine and mixed-conifer forests should support viable
populations of cavity-nesting birds. Thus, most current U.S. National Forest guidelines
generally converge on the recommendation to retain 6–10 trees/ha, as do guidelines for
Washington State, the Ontario Ministry of Natural Resources, the U.S. Army Corps of
Engineers, and many other land management agencies.
It has been acknowledged that snag guidelines should be sensitive to forest type and
forest age because ―the wildlife species that use snags are influenced by the stage of
forest succession in which the snag occurs‖ and by the breakdown stage of the snag
(Thomas et al. 1979). Moreover, snag types, sizes, and densities vary significantly with
vegetation type (Harris 1999; Harmon 2002; White et al. 2002). Therefore, it follows
necessarily that the desired snag types and densities will differ with both plant
community type and successional stage and that we need as great a variety of guidelines
as there are community types and successional stages (Bull et al. 1997; Everett et al.
1999; Rose et al. 2001; Kotliar et al. 2002; Lehmkuhl et al. 2003). Unfortunately, we
have generally failed to adjust snag-retention recommendations to specific forest age, and
nowhere is that failure more serious than for those special plant community types that
were ignored in the development of the generic guidelines—recently burned conifer
forests. Such forests are characterized by uniquely high densities of snags (Angelstam &
Mikusinski 1994; Hutto 1995; Agee 2002; Drapeau et al. 2002), and snag use by most
woodpeckers in burned forests requires high snag densities because they nest in and feed
from burned snags.
These facts have been overlooked in the development and implementation of meaningful
snag-management guidelines. Indeed, these guidelines have generally converged toward
an average of 6–7 trees/ha because that number was deemed more than adequate to meet
the nesting requirements of cavity-nesting wildlife species (Thomas et al. 1979:69). Snag
guidelines were not originally developed with an eye toward non-nesting uses of snags or
from an attempt to mirror snag densities that typically occur on unmanaged reference
stands. Snag guidelines are still much narrower than numerous authors have suggested
they ought to be, and we currently run the risk of managing coarse woody debris with
uniform standards across historically variable landscapes, which is entirely inappropriate.
Instead, we should be managing for levels of coarse woody debris that more accurately
mirror levels characteristic of the natural disturbance regime (Agee 2002). Clearly, we
need more data on what might constitute meaningful snag targets for all forest types and
successional stages, and those targets should be set on the basis of reference conditions
from natural post disturbance forests, not from managed forest stands and certainly not
from consideration of only a single aspect of an organism‘s life history.
Newer guidelines that are appropriate for snag dependent species that occupy standing
dead forests at the earliest stage of succession are beginning to trickle in (Saab & Dudley
1998; Haggard & Gaines 2001; Saab et al. 2002; Kotliar et al. 2002), and authors suggest
that 200–300 snags/ha may better address the needs of wildlife in burned forests. The
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issue has yet to receive the serious management attention it deserves, but the
comprehensive review of habitat needs of vertebrates in the Columbia River Basin
(Wisdom et al. 2000) and the recently developed DecAID modeling effort in Washington
and Oregon represent important efforts toward providing that kind of management
guidance (Marcot et al. 2002).
Hutto, R.L., 2006. Toward Meaningful Snag-Management Guidelines for Postfire Salvage
Logging in North American Conifer Forests. Conservation Biology Volume 20, No. 4, 984–993.
http://avianscience.dbs.umt.edu/documents/hutto_conbio_2006.pdf
―In general, wildlife species that use dead wood for nesting, roosting, or foraging prefer
larger diameter logs and snags (>20 inches). Although we tallied dead wood in this size
class throughout Oregon, the estimated density may not be sufficient for some wildlife
species. For example, inventory results show a mean of almost 3 snags per acre in this
size class in western Oregon and 1 per acre in eastern Oregon. This may indicate that
large-diameter snags are currently uncommon in Oregon habitat and that management
may be necessary to produce a greater density of large snags.‖
Donnegan, Joseph; Campbell, Sally; Azuma, Dave, tech. eds. 2008. Oregon‘s forest resources,
2001–2005: five-year Forest Inventory and Analysis report. Gen. Tech. Rep. PNW-GTR-765.
Portland, OR: U.S. Forest Service, Pacific Northwest Research Station. 186 p.
http://www.fs.fed.us/pnw/publications/gtr765/pnw-gtr765b.pdf
The bottom line is that current management at both the plan and project level does not reflect all
this new information about the value of abundant snags and down wood. The agency must avoid
any reduction of existing or future large snags and logs (including as part of this project) until the
applicable management plans are rewritten to update the snag retention standards. See also PNW
Research Station, ―Dead and Dying Trees: Essential for Life in the Forest,‖ Science Findings,
Nov. 1999 (http://www.fs.fed.us/pnw/sciencef/scifi20.pdf) (―Management implications: Current
direction for providing wildlife habitat on public forest lands does not reflect findings from
research since 1979; more snags and dead wood structures are required for foraging, denning,
nesting, and roosting than previously thought.‖) and Jennifer M. Weikel and John P. Hayes,
HABITAT USE BY SNAG-ASSOCIATED SPECIES: A BIBLIOGRAPHY FOR SPECIES
OCCURRING IN OREGON AND WASHINGTON, Research Contribution 33 April 2001,
http://www.fsl.orst.edu/cfer/snags/bibliography.pdf.
Most managers have a skewed conception of how many snags a healthy forest is supposed to
have. For instance, the old-growth Douglas-fir/western hemlock forest at the site of the Wind
River Canopy Crane has 59.5 snags/hectare larger than 51 cm dbh. Shaw, David C.; Franklin,
Jerry F.; Bible, Ken; Klopatek, Jeffrey; Freeman, Elizabeth; Greene, Sarah; Parker, Geoffrey G.
2004. Ecological setting of the Wind River old-growth forest. Ecosystems. 7: 427-439.
http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_shaw001.pdf
Another important ecological function provided by mortality is that it promotes evolutionary
adaptation which is critical right now in the face of climate change.
2-19
2-20
2-21
2-22
2-23
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[R]esearchers were surprised to find that the mortality of established trees considerably promotes
the adaptation of forests to the changing environment. … Evolution is promoted by the mortality
of established trees. The researchers assumed that demographic characteristics of the trees would
have a notable impact on their adaptability. Tree species differ for example so that birch matures
at a considerably younger age than pine, and birch seeds spread more effectively than pine seeds.
However, the results showed that these differences had only minor impacts. Instead, the
mortality of established trees played a large role in the evolutionary adaptation.
http://www.eurekalert.org/pub_releases/2010-01/uoh-nfd011210.php
Importantly, for natural selection to occur, mortality must be caused by natural events like
drought, insects, and fire, rather than through human choices about which trees will live and
which will die.
2-24
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Responses to Comment Letter #2
Comment 2-1: The EA, Chapter 3, page 3-98 states that ―During scoping for the Dairy Project,
Oregon Wild mentioned four blocks of land within the Dairy Project Area they identified as
potential wilderness. Only the northern most block is (for the most part) completely within
National Forest System lands. The majority of the southern three blocks are on BLM
administered land. Oregon Wild‘s areas all fall within areas that have had previous harvest that is
still evident or fall within the areas with undeveloped character discussed next.‖
In the analysis file it shows only 21.73 acres of other undeveloped character in Unit 15. The EA,
Chapter 3, page 3-99 states that ―Biomass removal and associated activities would occur on
approximately 141 acres of other undeveloped lands. In areas where proposed project activity
would occur on other undeveloped lands, the impacts to soil, water quality, air quality; plant and
animal communities; habitat for threatened, endangered, and sensitive species; recreation;
noxious weeds; and cultural resources, etc. are the same as disclosed for areas of proposed
project activity in previous resource sections of this chapter and are not reiterated here.
Environmental effects to resources in other undeveloped lands due to the implementation of
proposed project activities would be consistent with applicable laws, regulations, and Forest Plan
management area standards and guidelines.‖
Comment 2-2: The EA, Chapter 3 discloses the effects of proposed activities and the no action
alternative. See also the EA, Chapter 2, pages 2-14 to 2-16 for a summary of effects.
Comment 2-3: The EA, Chapter 3, page 3-70 states that ―A stand-replacement wildfire could
have negative effects on soils and hydrology of the watershed, depending upon the intensity and
severity of the fire and result in a loss of stream shade and increased sediment input to streams.
Wildfires can have short-term (1-5 years) adverse affects on fish and aquatic macroinvertebrates
by heating streams to lethal temperatures, changing water chemistry, removing riparian cover,
increasing fine and coarse sediment, and changing LWD (Brown 1990). High intensity wildfires
can cause extirpation of fish at the reach scale (Rieman et al. 1997) and may result in the
complete extirpation of fish in a stream (Rinne 1996). However, fire is a natural process in the
Pacific Northwest and post-wildfire studies have shown that salmonids often survive high
intensity wildfires and rapidly repopulate stream reaches where they were eliminated during fires
(Novak and White 1990, Rieman et al. 1997).‖
Comment 2-4: The EA, Chapter 3, page 3-49 states ―The proposed prescription for vegetation
treatment would promote growth and allow for future large snag development. At least 80% of
the trees harvested would be less than 16 inches dbh and no trees over 21 inch dbh would be
harvested allowing for future snag recruitment (pers. comm., Schwenke).‖
Comment 2-5: The EA, Chapter 3, page 3-39 states ―The HRV (historic range of variability)
derived from DecAid (Mellen et al. , 2003-11) is considered reference conditions based on snag
data collected on un-managed stands. However, due to decades of fire suppression, the un-
managed stands may not be representative of historic stand snag densities. The current estimate
of snags on the landscape indicates snags are more distributed on the landscape and higher
concentrations of snags are above reference conditions. The high concentration of snags provides
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the highest quality of nesting and roosting habitat for most of the primary cavity excavators
(PCE) occurring in the Silver Creek watershed. The high mortality from past wildfires and recent
mortality from insects has contributed to high snag pulses in the Silver Creek watershed.‖
Comment 2-6: The EA, page 3-46 states ―The No Action Alternative would enhance
recruitment of snags in the short to mid-term due to overstocking of pole size trees, but long term
recruitment of larger snags would be jeopardized.‖
In response to your ―Some Examples from Modeling Work.‖
http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf. Taken out of context. These are
examples specific to certain projects, many of them appear to be even aged plantations or
managed stands. There is little to no information given on the type of stands, prescriptions, etc…
Therefore this does not apply to the Dairy project.
Garman, Steven L.; Cissel, John H.; Mayo, James H. 2003. Taken out of context, paper refers to
a 40-year old managed Douglas-fir stand. Not relevant to the Dairy project.
Comment 2-7: The EA, page 3-50 states ―Several recent uncharacteristic fires have created an
abundance of PCE habitat for Picoides and other woodpeckers in the Silver Creek watershed
(Silver Fire, 2007) and on the Emigrant Creek Ranger District (Egley Complex, 2007). Because
snag habitat for most PCE‘s is above HRV in about one-half of the different snag classes and
snags are better distributed on the landscape, only incidental snags would be removed and all
trees over 21 inches would be recruited for future snag habitat, the Proposed Action would
reduce mortality in the treatment units in Dairy, the proposed vegetation treatments would not
contribute to a negative trend in PCE habitat and viability would be maintained for PCE‘s in the
Silver Creek watershed.‖
Jerome J. Korol, Miles A. Hemstrom, Wendel J. Hann, and Rebecca A. Gravenmier. 2002 is
taken out of context. Although no definition of unroaded areas is given, this document refers to
unroaded areas and wilderness areas as unmanaged areas. The Dairy EA, page 3-97 clearly states
that ―There are no Inventoried Roadless Areas within the Dairy Project area‖ and no areas within
the Dairy project area meet potential wilderness criteria. Dairy EA, page 3-100 clearly states that
―about 1% (141 acres) of other undeveloped lands would be impacted by the proposed action‖.
Comment 2-8: Please refer to the response to comments 2-4, 2-5, 2-6 and 2-7.
In response to Heiken, D. 2010 ―Some Examples from Modeling Work.‖
http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf. Taken out of context. These are
examples specific to certain projects, many of them appear to be even aged plantations or
managed stands. There is little to no information given on the type of stands, prescriptions, etc…
Therefore this does not apply to the Dairy project.
Comment 2-9: The EA, page 3-33 and 3-34 states ―While Ochoco Forest Plan recommends a
forest-wide objective of 47 percent population objectives based on Thomas et. al 1979, the
current snag levels were amended to the 100 percent population levels or 2.25 snags per acre in
the dry ponderosa pine sites.‖ ―Evaluation of snag habitat was used in lieu of PCE surveys.
Based on snag inventories, compared to data in DecAid for cavity nest birds, the snag levels are
between the 30 and 50 percent tolerance levels (See DecAid, Mellen-McLean et. al, 2002 for
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information on tolerance levels and snag densities for ponderosa pine forest)‖. DecAid is the
most up to date information on snags.
Comment 2-10: Not applicable to the Dairy Project. There is no EA p. 68 or Appendix K in the
Dairy Project Analysis.
Comment 2-11: Not applicable to the Dairy Project, effects stated are specific to the Mirage
Vegetation Management Project.
Comment 2-12: Please refer to response to comment 2-9.
Comment 2-13: Please refer to response to comment 2-11. These are existing conditions for the
Mirage Vegetation Management Project, not applicable to the Dairy Project area.
Comment 2-14: Please refer to response to comment 2-9.
Comment 2-15: Link does not work, could not find document. Document is most likely specific
to the Barnes Valley-Long Branch Restoration and Enhancement Project and not applicable to
the Dairy project.
Comment 2-16: Relevant. The EA, page 3-38 states ―In 1994 the Regional Foresters
Amendment was adopted to raise management level of snags to the 100 percent PPL (potential
population level). In dry ponderosa pine sites 100% PPL equates to 2.25 snags per acre from the
largest trees available in the stand.‖ See also the EA Design Criteria, pages 2-6 to 2-11. The EA,
page 3-56 also states that ―Prescribed fire would create some large snags, but primarily kill
smaller diameter trees, increasing a food pulse for species like hairy woodpecker.‖
Comment 2-17: Link does not work, could not find document. Please refer to the response to
comment 2-16.
Comment 2-18: Agree. The EA, page 3-49 states ―The proposed prescription for vegetation
treatment would promote growth and allow for future large snag development. At least 80% of
the trees harvested would be less than 16 inches dbh and no trees over 21 inch dbh would be
harvested allowing for future snag recruitment (pers. comm., Schwenke). Snag recruitment
would not affect PCE reproduction due to the untreated areas including approximately 1,000
acres of allocated old growth including associated woodpecker feeding areas.‖
Comment 2-19: Link does not work, could not find document. Not applicable to the Dairy
project because it is not a postfire salvage project.
Comment 2-20: Agree. However this is forest inventory and analysis report. The EA, page 3-32
to 3-44 describes the existing conditions of terrestrial wildlife habitat in the Dairy Project.
Comment 2-21: 1999 publication, outdated. Please also refer to comment 2-9.
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Comment 2-22: This publication is a comprehensive bibliography of published literature on
ecology of species of wildlife closely associated with snags presented in a user-friendly format.
Comment 2-23: Not applicable to the Dairy project. This publication is specific to cool, moist,
500-year old Douglas fir/western hemlock forests. The Dairy project is dry ponderosa pine sites.
Comment 2-24: Not applicable to the Dairy project. This publication is specific to southern to
northern Finland areas that are stunted and verging on the edge of survival. The Dairy project is
dry ponderosa pine sites.
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Comment Letter #3
November 25, 2011
Doug Jones, District Ranger
Emigrant Creek District
Malheur National Forest
265 Hwy 20 South
Hines, OR 97738
VIA Email: [email protected]
Re: Dairy EA Comments
Dear Doug,
Thank you for the opportunity to comment on the Dairy Environmental Assessment (EA). These
comments are on behalf of the members of the American Forest Resource Council (AFRC).
AFRC represents nearly 60 forest product businesses and forest landowners in five states. Our
mission is to create a favorable operating environment for the forest products industry, ensure a
reliable timber supply from public and private lands, and promote sustainable management of
forests by improving federal laws, regulations, policies and decisions that determine or influence
the management of all lands.
While AFRC strongly supports the Purpose and Need of the project, I have concerns that these
are adequately addressed through the Proposed Action. Directly from the Dairy EA, the purposes
of this project are to:
1. Improve soil and watershed conditions by reducing road related impacts to water quality, fish
habitat, and wildlife habitat; and meet requirements for the Ochoco National Forest Plan
(Recommendation from Silver Creek WA, pp.58 61, and 63),
2. Improve the health, vigor, and resiliency of vegetation to insects, disease, wildfire, and other
disturbances, to more closely resemble historical conditions in order to promote long-term
forest sustainability and wildlife species diversity; and meet requirements of the Ochoco
National Forest Plan (Recommendation from Silver Creek WA, pp.62),
3. Capture the economic value of those trees that are surplus to other resource needs on lands
identified in the Ochoco Forest Plan as suitable for harvest (Forest Plan, 4-27, 4-28).
The need for action is based on the current conditions of resources within the project area,
specifically vegetation condition needs, watershed condition needs, economic value needs.
(Dairy EA pages 1-1 through 1-4).
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The Dairy Project Area consists of 18,242 acres in various subwatersheds in the Buck Creek and
Headwaters Silver Creek Watersheds. The actual acres of forested stands treated to move them
toward historic ecosystem conditions is 1296 or about 7 percent of the analysis area even though
the EA states that approximately 6980 acres are in MA F22 General Forest and 4174 acres are in
MA F21 General Forest Winter Range. I question whether treating such a small acreage meets
the purpose and need for restoring the undesirable vegetative conditions described in the project
area. Further, although there are no specifics in the EA surrounding the size, species and volume
of the commercial material to be removed I question the viability of ―capturing economic value‖
when treating this small acreage given the remote location of the project area. The EA makes
numerous references to ―removing biomass‖. While this is certainly a desirable outcome, the
stark reality is no markets for biomass are located within a feasible distance of this project area
unless the Forest Service is planning on subsidizing that activity which is not a viable alternative
in these difficult economic times.
The Proposed Action calls for seasonally closing, closing or decommissioning 20.17 miles of
road, which is acceptable to AFRC as long as the long term transportation needs of the area have
been carefully analyzed. Do these road closures still allow strategic access in the event of
wildfire? Are plantations or other areas that might require treatment or road access in the future
accessible without reconstructing roads that have been decommissioned?
Page 2-9 of the EA lists operational design criteria designed to protect wildlife habitat. Have
these criteria been carefully analyzed to determine their actual feasibility for implementation?
Design criteria to protect botanical resources requires a ―50 foot area to protect (ATP) around
documented/mapped sensitive plant sites‖. Directional felling is required around these areas.
Design criteria to protect range resources requires gates be closed May through October. Slash
pull back from roads, fences, and other improvements must be ongoing with vegetation activities
regardless of eventual slash treatment.
Road closure and decommission activities are listed on page 2-11 of the EA. Will this be
included as part of the commercial vegetative treatment activities? Following road
decommissioning are standards required as part of the forest weed prevention plan. Included in
these standards are the following requirements:
All heavy equipment would be cleaned prior to entering National Forest System Lands.
Seed, straw, and other materials used for road decommission and erosion control would
be certified to be free of noxious weed seed.
Use only gravel, fill, sand, and rock that are judged to be weed free by District weed
specialists if needed for the project.
Does the public clean their vehicles before entering National Forest System Lands? Do Forest
Service personnel clean their vehicles each time they enter National Forest System Lands? Does
the Forest Service have ―on Forest‖ sites for obtaining gravel, fill, sand and rock that are weed
free?
Fire Regime Condition Class is discussed on page 3-22 of the EA. Although specific acreage is
not identified the EA says that ―a high proportion of the Dairy project area is in Fire Regime
Condition Class 3‖. The Proposed Action treats 1296 acres in the project area and moves those
acres from Condition Classes 2 and 3 to Condition Class 1. The concern is the remaining 16,946
3-1
3-2
3-3
3-4
3-5
3-6
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or 93% of the project area. Once again the concern is that enough acres are being treated under
this Proposed Action to meet the ―long term sustainability‖ criterion identified in the Purpose
and Need and to warrant the time and expense that the government has invested.
On page 3-1 of the EA the following statement is made ―The best available science is considered
in preparation of this EA.‖ Although a caveat follows that, no one can lay claim to the best
science, especially when science about natural resource management is continually and rapidly
evolving. The NFMA does not use or require use of the term "best available science" or "best
available scientific information.‖ Neither does NEPA. The Ninth Circuit Court of Appeals has
affirmed that these statutes do not require a determination of whether a project-level NEPA
document is based on "best" available science or methodology, that disagreements among
scientists are routine, and that requiring the Forest Service to resolve or present every such
disagreement could impose an unworkable burden that would prevent the needed or beneficial
management. Lands Council v. McNair, 537 F.3d 981, 991 (9th Cir. 2008)(en banc); Salmon
River Concerned Citizens v. Robertson, 32 F.3d 1346, 1359 (9th Cir. 1994). The Ninth Circuit in
the Mission Brush involving a restoration project in Idaho the Ninth Circuit emphasized that,
"[t]o require the Forest Service to affirmatively present every uncertainty in its EIS would be an
onerous requirement, given that experts in every scientific field routinely disagree; such a
requirement might inadvertently prevent the Forest Service from acting due to the burden it
would impose.‖ McNair, 537 F.3d at 1001. The Forest Service should recognize as the Ninth
Circuit finally has, that there is no holy grail of the "best" or ―most accurate‖ science. Even
NEPA does not require such impossible divining of the ―best‖ science. The Ninth Circuit
emphasized that ―NEPA does not require [that we] decide whether an [environmental impact
statement] is based on the best scientific methodology available, nor does NEPA require us to
resolve disagreements among various scientists as to methodology.‖ Salmon River Concerned
Citizens, 32 F.3d at 1359.
In summary, AFRC fully supports the Purpose and Need for Action in the Dairy Project Area.
However, because of the small number of actual acres being treated comprising only 7 percent of
the analysis area, I do not believe that the Purpose and Need is being met. The acres moved
toward HRV are minimal and the reduction in Fire Regime Condition Class 3 acres is minimal,
indeed the EA states that the potential for stand replacing fire remains a significant factor in the
area after potential implementation of the Dairy project. Of further significant concern is the
ability to ―capture economic value‖ in the project area. The remote location of the Dairy Project
Area requires that the commercial volume removed be of a suitable species and average diameter
for economic feasibility. From the junction at Riley on Highway 20 it approximately 100 miles
to Collins Pine in Lakeview, to Interfor Pacific in Gilchrist, and to Malheur Lumber Company in
John Day. Further numerous criteria are associated with the vegetative operations on the project
including but not limited to:
All heavy equipment would be cleaned prior to entering National Forest System Lands.
Seed, straw, and other materials used for road decommission and erosion control would
be certified to be free of noxious weed seed.
Use only gravel, fill, sand, and rock that are judged to be weed free by District weed
specialists if needed for the project.
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―50 foot area to protect (ATP) around documented/mapped sensitive plant sites‖
requiring directional felling around these areas.
Range resources require identified gates be closed May through October.
Slash pull back from roads, fences, and other improvements must be ongoing with
vegetation activities regardless of eventual slash treatment in range areas.
Borax applications on pine stumps with diameters ≥ 12 inches.
Various potential seasonal restrictions for avian species and big game hunting.
While none of these restrictions are overly onerous individually, the cumulative effects can be
paralyzing if coupled with a project of marginal economic value.
Once again, thank you for the opportunity to comment on the Dairy EA.
Sincerely,
Irene K. Jerome
AFRC Representative, Eastern Oregon/Southwest Idaho
Dairy Project Comment Analysis
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Responses to Comment Letter #3
Comment 3-1: The EA, Chapter 3, page 3-3 states that ―6,900 acres have been harvested since
1970, 3,000 acres have been precommercially thinned in the last 10 years, 2,200 acres have been
prescribed burned and prescribed burning will occur in the near future on about 13,400 acres.‖
The EA, Chapter 2, page 2-2 states that an ―alternative (Alternative C) that proposed to treat the
maximum allowable acres was brought forward in response to scoping. This proposal was
considered but eliminated from detailed analysis because there were no additional acres that
were economical.‖
Comment 3-2: The EA, page 3-24 states ―Closure of roads would limit access for fire
suppression personnel. This effect may be negligible as fuels treatments would reduce fire
intensity, thus enabling suppression activities (Agee et al. 2005).‖ The EA, page 3-6 also states
―The distance between open roads after the planned closures or decommissioning is generally
not more than one mile. The cumulative effects of the action alternative combined with past road
closures and decommissions would be fewer roads to maintain, less money needed for
maintenance, increased response time for fire crews, less disturbance to wildlife and reduced
motorized access for all users.‖
Comment 3-3: The EA, page 2-6 states ―Design criteria would be implemented to avoid,
minimize, reduce or eliminate impacts caused by implementation of the Proposed Action.‖
Similar design criteria have been implemented for over ten years on the Emigrant Creek Ranger
District.
Comment 3-4: The EA, page 2-4 states ―Year long road closures may be implemented on the
ground with an earth berm, sign, gate or no physical closure. Seasonal closures may be
implemented on the ground with a sign, gate, or no physical closure. Roads closed with no
physical closure would be implemented thru the Motor Vehicle Use Map (MVUM) when it is
published.‖ Some roads may be closed by the purchaser and some roads may not.
Comment 3-5: The EA, page 2-11 describes the weed prevention plan for the project. Currently,
only those activities regulated by contract or permit have weed prevention strategies applied.
Only gravel, fill, sand, and rock that are judged to be weed free by District weed specialists
would be used for the project (EA page 2-11).
Comment 3-6: The EA, page 2-16 states that ―Activities would move condition class from 3 and
2 towards condition class 1 on about 1,296 acres.‖ See also the response to comment 3-1.