Appendix G – Response to Public Commentsa123.g.akamai.net/7/123/11558/abc123/forestservic.download.akam… · Appendix G – Response to Public Comments Appendices 591 Elk Rice

Appendix G – Response to Public Comments

Appendices 590

Appendix G – Response to Public Comments Note that only comments related to the Elk Rice project are displayed. General introductions, requests to remain on the mailing list, or general

information about the commenter have not been included. The entirety of each commenter’s letter is included in the project file. Letter 4 was a

request for information and is not listed here.

Letter 1 – Dick Artley

Letter 2 – Steve Jorgensen

Letter 3 – Don and Maggie Gillingham

Letter 4 – Jim Greiner

Letter 5 – Anthony B. Cox (Sanders County Commissioner)

Letter 6 – Dave and Debbie Lyman

Letter 7 – Alliance for the Wild Rockies (Michael Garrity)

Letter 8 – Chris Wellman

Letter 9 – Cabinet Forestry Collaborative (Doug Ferrell, Shawn Morgan, William Meadows, Judy Hutchins, Kim Matthew, Mike Petersen)

Elk Rice Public Comment Summary

Letter 7 / Comment 8 / 2015 Forest Plan Direction

AWR fully participated in the public process during the development of the KNF’s 2015 revised Forest Plan (RFP), including commenting at every stage and submitting a

formal Objection. Because the Forest Service provided essentially none of the requested remedies in response to our RFP objection, AWR incorporates the documentation of

its participation in the RFP public process within these comments on the Elk Rice PA. With the Elk Rice PA and other actions, we believe that the FS is implementing a forest

plan that is not consistent with laws and regulations.

Response: Comment submitted during Forest Plan revision have no context relative to the Elk Rice project.

Letter 9 / Comment 7 / 2015 Forest Plan Direction

We also note that this project will not affect any road less areas or areas of designated Old Growth, and that in fact all project activities will take place within Management

Area #6, General Forest. In this sense this project is in line with guidelines set forth in the Kootenai Forest Plan.

Response: Thank you for your support.

Letter 1 / Comment 1 / Analysis, Best Science, Data, & Modeling

USFS leaders have repeatedly told the public agency projects are based on “best science.” Please see attachment #15. In the space below I will cite best science and show it is

the antithesis of the actions being proposed as part of this timber sale. After 31 years in the USFS I learned line-officers can be placed into 2 categories regarding their

understanding and comprehension of science. Some know the so-called USFS science conclusions relating to natural resources in the forested ecosystem are contradicted by

independent scientists not affiliated with the USDA … and they don’t care. Some are unaware of this inconsistency.


Appendices 591


Response: Attachment 15 quotes various Forest Service leaders in public comments and interviews supporting the use of best science. Some of these comments date back

more than 20 years. The agency does make use of best science in project analysis including that done for the Elk Rice project. Scientific studies used in the analysis are cited

throughout the document and listed in the Literature Cited section of the EA. No specific challenge is made to the science used for the Elk Rice project.

Letter 1 / Comment 3 / Analysis, Best Science, Data, & Modeling

Can you and your IDT members understand why there is a world of difference between the real science I offer you and statements made by USFS employees claiming to

represent science. Why is this so? Independent science is accurate, truthful and reflects the real world most of the time. USFS science is skewed to always support the agency’s

timber agenda. Best science teaches us that private industrial tree farm conditions (as you will create with this sale) are so devoid of biodiversity they aren’t real forests. They

are sterile log factories.

Response: See response to Letter 1, Comment 1.

Letter 1 / Comment 9 / Fire, Fuels, Air Quality

You propose to log merchantable-sized trees claiming the need to remove hazardous fuels and you fail to address fine fuels (most likely to burn) near homes in the WUI using

methods derived from research by an employee of your own agency.

Are you comfortable knowing your inaction could result in people being burned to death as their houses are destroyed?

Hundreds of homes were destroyed as part of the horrific August 2015 fires in the northwest. It can and will happen. When this occurs in the WUIs near the Elk Rice sale, the

survivors will litigate when they find out you rejected the most effective fire damage risk reduction method that exists developed by a USFS employee. The judge will

determine that USFS line-officers who knew about the effectiveness of Dr. Cohen fine fuels removal methods and rejected them were guilty of criminal negligence. A copy of

this issue of these scoping comments will be mailed to the Heron city council for distribution.

Response: The Elk Rice project includes activities within the WUI including the reduction of fine fuels and ladder fuels. Commercialy thinned harvest units reduce crown fire

potential in four ways: It increases spacing between the crowns within the harvest unit which reduces heat transfer from tree to tree. It Raises crown base height by removing

smaller trees and selecting larger fire tolerant trees as leave trees thus reducing heat transfer from surface fuels to the crowns. It reduces ladder fuels by removing the

understory particularly with follow-up slashing. Fuels treatment post-harvest and slashing reduces surface fire intensity and duration limiting crown fire initiation. Strategically

placed roads and harvest units provide access and control points during fire suppression activities. This provides a safer work environment for fire suppression resources in the

WUI.


At page 7 your Proposed Action Report states: “Where feasible, fuel loads would be reduced along private property and other areas in the WUI within the project area.”

Ranger Gubel, please assure that the pending draft NEPA document analyzes an alternative in detail that uses USFS employees to apply Dr. Cohen’s fine fuels removal

methods near homes in the WUI owned by the elderly and handicapped who are unable to do the work themselves. I know these homeowners will grant permission. The

Cohen alternative would describe how the USFS will organize/host workshops and distribute handouts to other WUI homeowners so they can do the fine fuels removal work

themselves according to Dr. Cohen’s well researched methods and procedures. The workshops should disclose and discuss Dr. Cohen’s research conclusions summarized in

Opposing Views Attachment #11. that clearly indicate removing merchantable-sized trees to reduce fuels and reduce the risk of wildfire damage (as is being proposed here) is

ineffective. A small sample of Dr. Cohen’s statements and information from other reputable sources on this subject are included below: “As stated, the evidence indicates that

home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel

characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5) Source: Cohen, Jack, Transcript of Reducing the Wildland Fire Threat to

Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. Link to source document:

http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf


Appendices 592


Response: It is well understood that the immediate area surrounding a home and the characteristics of the building material are potentially the most critical elements in

determining its survivability. The Forest Service, other agencies, and the Cabinet Ranger District encourage homeowners to do their part in making their homes fire safe. There

are additional reasons for wildland fuels management outside of the home ignition zone. This includes firefighter and public safety to improve ingress and egress routes, to

reduce potential fire behavior thereby reducing spotting distance of lofted firebrands, to increase the effectiveness of suppression efforts near homes, and to increase the

effectiveness of aerial delivered fire suppressants. In addition to helping protect values at risk, the Elk Rice project proposes fuel reduction treatments within the wildland

urban interface for other reasons such as the reintroduction of fire to the landscape, improve wildlife habitat and browse, and move toward 2015 Forest Plan desired conditions.

Commercially thinned harvest units reduce crown fire potential in four ways: It increases spacing between the crowns within the harvest unit which reduces heat transfer from

tree to tree. It raises crown base height by removing smaller trees and selecting larger fire tolerant trees as leave trees thus reducing heat transfer from surface fuels to the

crowns. It reduces ladder fuels by removing the understory particularly with follow-up slashing. Fuels treatment post-harvest and slashing reduces surface fire intensity and

duration limiting crown fire initiation. Strategically placed roads and harvest units provide access and control points during fire suppression activities. This provides a safer

work environment for fire suppression resources in the Wildland Urban Interface.

The IDT considered an alternative that would just treat fine fuels within the WUI for homeowners however did not carry it forward for detailed analysis. Such an alternative

would not address all the fuels related concerns and would not address other elements of the purpose and need for the proposal other than fire and fuels. It would be cost

prohibitive as a stand-alone project. It would not reintroduce fire on the landscape and convert stands to fire adaptive species. This type of treatment would not reduce canopy

bulk density (CBD) which is an indicator of canopy spacing thus would not reduce the potential for the treated stands to sustain a crown fire entering from an adjacent stand.


You propose to log merchantable-sized trees claiming the need to remove hazardous fuels and you fail to address fine fuels (most likely to burn) near homes in the WUI using

methods derived from research by an employee of your own agency.

Are you comfortable knowing your inaction could result in people being burned to death as their houses are destroyed?

Hundreds of homes were destroyed as part of the horrific August 2015 fires in the northwest. It can and will happen. When this occurs in the WUIs near the Elk Rice sale, the

survivors will litigate when they find out you rejected the most effective fire damage risk reduction method that exists developed by a USFS employee. The judge will

determine that USFS line-officers who knew about the effectiveness of Dr. Cohen fine fuels removal methods and rejected them were guilty of criminal negligence. A copy of

this issue of these scoping comments will be mailed to the Heron city council for distribution.

Response: The Elk Rice project includes activities within the WUI including the reduction of fine fuels and ladder fuels. Commercialy thinned harvest units reduce crown fire

potential in four ways: It increases spacing between the crowns within the harvest unit which reduces heat transfer from tree to tree. It Raises crown base height by removing

smaller trees and selecting larger fire tolerant trees as leave trees thus reducing heat transfer from surface fuels to the crowns. It reduces ladder fuels by removing the

understory particularly with follow-up slashing. Fuels treatment post-harvest and slashing reduces surface fire intensity and duration limiting crown fire initiation. Strategically

placed roads and harvest units provide access and control points during fire suppression activities. This provides a safer work environment for fire suppression resources in the

WUI.


Appendices 593



At page 7 your Proposed Action Report states: “Where feasible, fuel loads would be reduced along private property and other areas in the WUI within the project area.”

Ranger Gubel, please assure that the pending draft NEPA document analyzes an alternative in detail that uses USFS employees to apply Dr. Cohen’s fine fuels removal

methods near homes in the WUI owned by the elderly and handicapped who are unable to do the work themselves. I know these homeowners will grant permission. The

Cohen alternative would describe how the USFS will organize/host workshops and distribute handouts to other WUI homeowners so they can do the fine fuels removal work

themselves according to Dr. Cohen’s well researched methods and procedures. The workshops should disclose and discuss Dr. Cohen’s research conclusions summarized in

Opposing Views Attachment #11. that clearly indicate removing merchantable-sized trees to reduce fuels and reduce the risk of wildfire damage (as is being proposed here) is

ineffective. A small sample of Dr. Cohen’s statements and information from other reputable sources on this subject are included below: “As stated, the evidence indicates that

home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel

characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5) Source: Cohen, Jack, Transcript of Reducing the Wildland Fire Threat to

Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. Link to source document:

http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf







Commercially thinned harvest units reduce crown fire potential in four ways: It increases spacing between the crowns within the harvest unit which reduces heat transfer from

tree to tree. It raises crown base height by removing smaller trees and selecting larger fire tolerant trees as leave trees thus reducing heat transfer from surface fuels to the

crowns. It reduces ladder fuels by removing the understory particularly with follow-up slashing. Fuels treatment post-harvest and slashing reduces surface fire intensity and

duration limiting crown fire initiation. Strategically placed roads and harvest units provide access and control points during fire suppression activities. This provides a safer

work environment for fire suppression resources in the Wildland Urban Interface.

The IDT considered an alternative that would just treat fine fuels within the WUI for homeowners however did not carry it forward for detailed analysis. Such an alternative

would not address all the fuels related concerns and would not address other elements of the purpose and need for the proposal other than fire and fuels. It would be cost

prohibitive as a stand-alone project. It would not reintroduce fire on the landscape and convert stands to fire adaptive species. This type of treatment would not reduce canopy

bulk density (CBD) which is an indicator of canopy spacing thus would not reduce the potential for the treated stands to sustain a crown fire entering from an adjacent stand.


Ranger Gubel, a fire physicist employed by the USFS (Dr. Jack Cohen) published 5 science papers between, 2001 and 2009 that summarized his research findings. The papers

describe the most effective measures that can be taken to reduce or eliminate structure damage should a wildfire occur nearby. He is one of your own. His fine fuels removal

methods are used worldwide. Don’t you think it’s strange that USFS NEPA documents for fuels removal projects that are intended to protect people living in the WUI don’t

mention Dr. Cohen? The reason is clear. Removing fine fuels does not produce volume.

You are using fuels reduction as an excuse to log in order to produce volume so you are able to please Supervisor Savage by achieving his annual volume expectations for your

district and spend all your NFTM dollars in the same FY they were allocated.

You had better hope a future fire does not occur in or near the sale area. How will you sleep and function knowing you set the stage for someone to die trying to save their

home?


Appendices 594








See Response to Letter 1, Comment 10.


It’s too bad your fuels specialist didn’t have time to review the Purpose and Need and Proposed Action document. If one of your Purpose & Need statements in the draft NEPA

document does not include “take action to protect homes and human lives in the WUI” which would guarantee a Dr. Cohen alterative be analyzed in detail, it will be necessary

to force you to do your job. None of your IDT members wants to participate in an analysis that lies by omission that might potentially kill innocent families so you can “get-

out-your-cut.”

Response: See Response to Letter 1, Comment 10.


I will write letters to the editor telling the public that you ignore and reject an alternative that USFS research shows to be the most effective at reducing the risk that homes

located in the WUI will burn should a wildfire come close. These letters will be sent to the Missoulia. I won’t stop there. It will also be necessary to send hardcopies of Dr.

Cohen’s research conclusions to the Sanders County Commissioners and point out you rejected a Dr. Cohen alternative. They will also receive aerial photos taken after the

2002 Rodeo-Chediski fire in Arizona showing a home with minor damage near homes that were completely destroyed. The newspaper that published these photos indicated in

the accompanying article that homeowners removed “small kindling-like” fuels near their home prior to the fire. Dusting a Cohen alternative under the rug by including it in

your Alternatives Considered and Not Carried Forward for Detailed Analysis will not strengthen your position. You can’t possibly justify disposing of this alternative.

Response: See Response to Letter 1, Comment 10.


Your collaborative group expresses legitimate concerns that reflect the feelings of most Americans. What do you do? You say nothing that really addresses their concerns. You

placate and trick the public to amass your precious volume. Concerns Raised During the Collaborative Process Prior to Scoping Collaborative group member’s concern: “Fuel

loads on National Forest System lands bordering private property” Your response: “Where feasible, fuel loads would be reduced along private property and other areas in the

WUI within the project area.” Comment: The response should have told the public the conditions that would make fuels removal unfeasible. They want detail and specifics.

Their homes are at risk.

Response: The Elk Rice project proposes Fuels Units 34, 35B, and 36F which were developed to reduce fine fuels and ladder fuels along private property. In Alternative 3

these treatments would reduce fuels along approximately 2 miles of National Forest System land which borders private property (not including private industrial property).


We support burning projects described in this proposal, as well as a continuing effort to use controlled burning to reduce fuel loads and improve habitat for elk and other

wildlife.



Appendices 595


Letter 1 / Comment 17 / Forest Health

Best science clearly indicates bark beetle activity does not increase fire danger and is a beneficial natural disturbance. The scoping package at page 44 states: “Tree mortality

from the bark beetles is elevating the hazardous fuels in numerous stands in the project area as well as decreasing the productivity of the stands.” Please read real best science

contained in Opposing Views Attachment #17 to learn the truth about bark beetles in the forest and their connection to fire risk. You will notice that best science shows this

type of insect activity is a beneficial disturbance event. Here are 2 research conclusions contained in Opposing Views Attachment #17 and #5: “While research is ongoing and

important questions remain unresolved, to date most available evidence indicates that bark beetle outbreaks do not substantially increase the risk of active crown fire in

lodgepole pine (Pinus contorta) and spruce (Picea engelmannii)-fir (Abies spp.) forests under most conditions. Instead, active crown fires in these forest types are primarily

contingent on dry conditions rather than variations in stand structure, such as those brought about by outbreaks. Preemptive thinning may reduce susceptibility to small

outbreaks but is unlikely to reduce susceptibility to large, landscape-scale epidemics. Once beetle populations reach widespread epidemic levels, silvicultural strategies aimed

at stopping them are not likely to reduce forest susceptibility to outbreaks. Furthermore, such silvicultural treatments could have substantial, unintended short— and long-term

ecological costs associated with road access and an overall degradation of natural areas. Black, Scott H. Ph.D., Kulakowski, Dominik Ph.D., Barry R. Noon Ph.D., Barry R.,

DellaSala, Dominick A. Ph.D. “Do Bark Beetle Outbreaks Increase Wildfire Risks in the Central U.S. Rocky Mountains? Implications from Recent Research” Published in

Natural Areas Journal, January 2013 http://www.bioone.org/doi/abs/10.3375/043.033.0107 “Tree thinning and logging across millions of acres of Western lodgepole pine and

spruce-fir forest is unlikely to reduce fire risk or alleviate future large-scale epidemics of bark beetles, according to a new report prepared by forest ecologists. “Extensive areas

of dead trees have understandably led to widespread concern about the increased risk for forest fires,” said Dominik Kulakowski, one of the report’s authors and a professor of

geography and biology at Clark University in Worcester, Mass. “This is a logical concern, but the best available science indicates that the occurrence of large fires in lodgepole

pine and spruce-fir forests is mainly influenced by climatic conditions, particularly drought.” “Although the scale of the recent beetle outbreak is unprecedented in modern

times, experts note that insect outbreaks and fires are a natural part of Western forest ecosystems. As such, the report found no causal link between insect outbreaks and the

incidence of wildfire.” Eryn Gable “Battling beetles may not reduce fire risks – report” Land Letter, March 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-

reduce-fire-risks-report/ I will expect the draft NEPA document to analyze an alternative in detail that uses pheromones to deal with these insects.

Response: The use of pheromones (MCH repellents) was discussed during IDT meetings and will be considered for some units.

These articles presented discusse the influence of epidemic level bark beetle activity on fuel loading and how that may influence future fire behavior. The Elk Rice project was

not developed to address fuel loadings related to wide spread, epidemic level bark beetle activity, but rather is focused on addressing the resilience of individual forest stands

to enhance within-stand resistance to accelerating mortality. Therefore, these citations are not directly applicable to the Elk Riceproject.

Letter 1 / Comment 20 / Forest Vegetation: Over-40 acre Openings

Collaborative group member’s concern: “Impacts from large, over-40 acre openings” Your response: “Over-40 acre openings would be created in conjunction with wildlife

movement corridors, watershed protection, and visual concerns.” Comment: This response is sad. There is no way the massive impact to watershed health and visual concerns

created by eleven openings greater than 40 acres ranging in size from 46 to 262 acres can be mitigated. Telling the public massive openings are necessary to provide wildlife

movement corridors is untrue. The IDT knows you have no intention of complying with the 40 acre size limitation. They knew they had to respond with something even if it

makes no sense rather than telling the public “too bad, live with it.”

Response: The Forest Service never claimed for the Elk Rice project that openings greater than 40 acres were necessary to provide wildlife movement corridors. Rather large

openings would be located in areas that still provide wildlife movement corridors that are not logged. Large openings may alter wildlife movement across the landscape. The

magnitude of the impact is dependent on the location of the openings, harvest regime, and species affected. We expect untreated areas within the project boundary as well as

about 17,000 acres of IRAs would provide mobile species like large carnivores and ungulates more secure areas to move through. For greater detail on the responses of

different species to large openings and potential impacts to connectivity see the Environmental Consequences section by species in the Wildlife section of this EA.

http://www.bioone.org/doi/abs/10.3375/043.033.0107

http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/

http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/


Appendices 596


Letter 8 / Comment 1 / Forest Vegetation: Pre-commercial Thinning

Some of the land in that area needs pre-commercial thinning before it is logged. If the trees are not thinned prior to logging, you end up crushing and breaking hundreds of

young trees. The trees are so thick in some of those areas, that it is impossible to see what is growing on the site.

Response: These non-commercial treatments are designed to reduce competition among younger trees and manage species composition within a plantation setting. Plantations

range in age from 15-30 years in age and are experiencing mortality due to reduced individual tree vigor, high stand densities, and insects/ disease. Stands with western white

pine would be pruned to reduce the likelihood of blister rust infections. Typically this is one-third of the overall height of the trees starting at ground level. Based on 2015

cruise data, these plantations range from 750-2500 trees per acre and have representation of all commercial tree species found on the Cabinet Ranger District. The objectives

within these stands are to reduce stand densities and promote seral tree species such as ponderosa pine, western larch, western white pine, and lodgepole pine. The target trees

per acre after treatment would range from 150-300 trees per acre and have a natural “irregular” appearance. Topography in these stands range from flat to greater than 50

percent and trees would typically be cut using chainsaws, piled by hand, and burned the following season to reduce fuel loadings.

All of the PCT units are below 4,000 feet elevation and not within lynx habitat.

Alternative 2 would include 103 acres of pre-commercial thinning and Alternative 3 would include 118 acres of pre-commercial thinning.

Letter 1 / Comment 27 / Forest Vegetation: Regeneration Harvest

A clearcut is a clearcut!!!!!!!!!!!!!!!!!!!!!!!!!!!! You know the public does not want their land clearcut. Your collaborative group told you so. Otherwise you would not be

proposing clearcuts with reserves and leave trees having feathered boundaries to emulate natural edge patterns with a minimum of geometric lines. I have seen clearcuts with

reserves. A clearcut with a few unmerch trees is still a clearcut. You say this for 5 of your clearcuts in Table 2: “Regenerate- Clearcut with leave trees, generally leaving < 10%

of the existing trees.” Even a child would recognize the fact that you plan to strip the clearcuts clean with no leave trees. Are you unable to understand that 1) < 10% includes

0% and 2) generally means only sometimes? A competent land manager would specify the size and number of leave trees per acre and eliminate the word “generally.” The

way to serve the public is clear. Eliminate all clearcuts and replace them with shelterwood Rx.

Response: See response to Letter 1, Comment 12.


Please understand, we are in total agreement with making our forests more diversified, fire-resistant and healthy which we believe is the forest service’s goal with this three-

pronged project. We diverge, however, on the issue of the two types of clear cut options for sections which are clearly visible to Heron residents and to people traveling

highway 200. Heron residents revel in living in a spectacularly beautiful spot and should you quarry them, they will largely say they moved to this remote location precisely

because of that spectacular beauty. I have seen your artist’s renderings of the anticipated views we will have of our hilltops and how many of the sites are colored in dark green

and chartreuse for clear-cutting methods. They literally run the faces of the mountains nearly from the border at the Clark Fork Road on the west to the east end of Upper River

Road. That encompasses all the views of Heron from highway 200. And, I have lived with the results of previous clear cuts which the designer “thought” would look from a

distance like lovely meadows with copses. When residents first saw them we were screaming. Gone were the green hills and the fall golden swaths of tamarack. We personally

saved three 8’ white pine when we cleared a home site in 1976. In 2015 those trees reached 35’ a height at which they would be clearly visible on a hilltop from downtown.

This experience makes us not believe anything with “clear cut” in its description will leave Heron residents happy with our views for the foreseeable future or, in the case of

we older residents, in our lifetimes. We do not wish to spend our remaining years entering Heron and driving home with a view of our mountains clear-cut from the middle to

the crest and what looks from a distance like a lone tree here and there, until that tree is blown down in a strong wind. We also travel the back country and have seen sites on

which under-burning got away leaving scorched hillsides with black silhouettes. We can’t risk that result anywhere but we particularly can’t risk it on visible slopes.


Appendices 597


Response: Please refer to the Scenic Resource section of the EA. In the short term, the proposed harvest activities would result in created openings with some clumps of trees

as well as single trees remaining. The effects would be noticeable. By tying into existing openings and utilizing topographical breaks, the edges of the openings would be less

noticeable. In the clearcut with reserves units the openings would be planted with disease resistant species to contribute to a healthier, more resilient forest. Over the long term,

as the vegetation recovers, the harvest units would blend in with the existing background landscape as seen from the viewing areas leaving the activities noticeable but

subordinate to the landscape character.


So, these are our comments: We prefer gentler thinning plans for sections with viewable mountain faces; something like 12’ between crowns whereby you’ll end up with space

for wildlife habitat and traffic and sun through the over story. Pull out the ladder fuels. Leave the clear cut methods for the back-country. And assign responsible, third-party

monitors during under burning regardless of where to insure it does not get away from the loggers as they clear out ladder fuels and undesirable timber.

Response: In order to address forest resiliency, insect and disease considerations, and to trend toward desired conditions based on the 2015 Forest Plan, appropriate

silvicultural prescriptions were utilized to address the vegetative conditions on the ground. This included the use of improvement harvest where the forest stand conditions

warranted this prescription and the use of regeneration harvest (clearcut with leave trees, clearcut with reserves, and Seed-tree) where the existing condition did not warrant the

use of improvement harvest. The 2015 Forest Plan states, “FW-GDL-VEG-08. All silvicultural practices may be used to manage forest vegetation. This includes silvicultural

systems (e.g., even-aged, two-aged or uneven-aged), regeneration methods (e.g., clearcutting, seed-tree, shelterwood, and group or single-tree selection), as well as other

practices such as improvement cutting, commercial or pre-commercial thinning, use of planned or unplanned ignitions, planting, pruning, invasive terrestrial plant species

control, cone collection, tree improvement, insect or disease control, site-preparation, and fuel reduction. Appropriate practices for a given situation depend on numerous

factors, including the current and desired forest vegetation conditions at the stand and landscape scales, the biophysical setting, and the management direction and emphasis for

the area. Silvicultural practices should generally trend the forest vegetation towards conditions that are more resistant and resilient to disturbances and stressors, including

climate change.”


We do note with some concern the large portion of the silvicultural treatments that are designated as "Clearcut with leave trees". We understand these treatments are intended

to help meet project goals including to increase species diversity and minimize impacts from root disease which is prevalent in these stands, and these are goals we support.

The silvicultural treatments are intended to "increase the representation of western larch, western white pine and ponderosa pine", as described on page 40 of the scoping

document.

Response: Regeneration harvest (clearcuts, Seed-tree, shelterwood, and group or single tree selection) is used when it is professionally determined that this is the best method

to meet desired vegetation conditions for that particular site. For the Elk Rice project, the Forest Service realizes that the clearcuts will be visible from certain locations. The

IDT endevoured to design the shape of the regeneration units to mimic naturally occuring openings and took into consideration key viewpoints within the project area. Please

refer to the Scenic Resource section of this EA.

Forest Plan Guideline FW-GDL-VEG-08. All silvicultural practices may be used to manage forest vegetation. This includes silvicultural systems (e.g., even-aged, two-aged or

uneven-aged), regeneration methods (e.g., clearcutting, seed-tree, shelterwood, and group or single-tree selection), as well as other practices such as improvement cutting,

commercial or pre-commercial thinning, use of planned or unplanned ignitions, planting, pruning, invasive terrestrial plant species control, cone collection, tree improvement,

insect or disease control, site-preparation, and fuel reduction. Appropriate practices for a given situation depend on numerous factors, including the current and desired forest

vegetation conditions at the stand and landscape scales, the biophysical setting, and the management direction and emphasis for the area. Silvicultural practices should

generally trend the forest vegetation towards conditions that are more resistant and resilient to disturbances and stressors, including climate change.


Appendices 598



District personnel have described to us your intention to leave scattered clumps of trees in these large openings, to feather the edges, and to generally lay out cutting units as

irregular shapes. We encourage an emphasis on these approaches, with the goal of ending up with a landscape that functions and appears as if it were shaped by the forces of

nature. This approach is outlined in the KFSC Vegetative Management Recommendations in Section II C.) Project Level sideboards for regeneration harvests. Our

collaborative group endorses the application of these vegetative recommendations.

Response: Thank you for your comment and support. Alternative 3 was developed with the intent to address the conerns of clearcuts. As a result, 20 regeneration unit’s

silvicultural prescriptions were changed to retain more trees; 13 shelterwood units were prescribed to retain 20-40 trees per acre; the size of 21 similar units was reduced, and

ten unit shapes were altered to create more irregular edges.

Regeneration harvest (clearcuts, Seed-tree, shelterwood, and group or single tree selection) is used when it is professionally determined that this is the best method to meet

desired vegetation conditions for that particular site. For the Elk Rice project, the Forest Service realizes that the clearcuts will be visible from certain locations. The IDT

endevoured to design the shape of the regeneration units to mimic naturally occuring openings and took into consideration key viewpoints within the project area. Please refer

to the Scenic Resource section of this EA.







Letter 9 / Comment 1 / General Comment

We are in support of this project as presented.


Letter 7 / Comment 7 / Inventoried Roadless Areas (IRA)

We are opposed to further management manipulations in roadless areas—whether “inventoried” or left out of the official inventory during some arbitrary previous FS process.

Response: Thank you for your comment. There are no actions proposed in roadless areas in the Elk Rice project area .

Letter 1 / Comment 8 / Monitoring

The scoping package is silent on monitoring. I ask that at least the following resources be included in the monitoring plan that will be contained in the draft NEPA document: ·

for aquatic health: turbidity and temperature, for possible harm to recreational opportunities: logging units or road construction visible from locations where the public might

congregate (overlooks, roads, trails campgrounds etc.), for public safety hazards (making sure to include locations where toxic herbicides have been sprayed, for wildlife:

habitat that is damaged by logging and road construction … especially T&E species habitat for species that may exist in or near the sale area, for soils damage: compaction at

random locations throughout the units, and for water quality … specifically chemical or petroleum pollutants. Consider this a request for you to assure the draft NEPA

document includes the following: What will be monitored, Why it’s being monitored, The frequency of monitoring, Monitoring data that will be collected, and What will be

done if monitoring shows the timber sale is causing harm to the resource being monitored.


Appendices 599


Response: The EA includes the “Elk Rice Monitoring Activities” section and the specialist sections within the EA also disclose applicable monitoring efforts if applicable.

The Elk Rice Monitoring Plan is in Appendix E of this EA. In addition, the 2015 Forest Plan objectives (and monitoring program) are intended to measure improvement in

resilience. The objectives are tied to actions taken on the forest to “increase the resilience of forest vegetation by reducing the potential severity of wildfire and insect

outbreaks” (KIPZ Climate Change Report). Resilience is measured at forestwide scale rather than project by project. Management actions are measured which are consistent

with 2015 Forest Plan direction to restore or maintain a diversity of structure and composition within the range of desired conditions (based on HRV and consideration of

future climates) as current science supports this method to support ecological integrity in our managed landscapes: (“Ecosystems with greater ecological integrity will be more

resistant and resilient to the effects of changing patterns and types of disturbance” (Parrish et al. 2003).

Letter 7 / Comment 1 / NEPA Process

We are alarmed that the Forest Service (FS) wants to proceed with final project approval without completing detailed analysis and disclosure required under the National

Environmental Policy Act (NEPA). Although your “Opportunity” letter states that you understand you are not exempt from complying with NEPA, your chosen process

contradicts that expressed understanding. One of the reasons why we say that is that the Elk Rice proposal area is adjacent to the Pilgrim Creek Timber Sale project area, and

that project hasn’t even been finished. The public needs explanation on how this new proposal integrates in with Pilgrim Creek project goals and objectives—or doesn’t—and

deserves the opportunity to comment upon your explanations and get responses to those comments. This will not happen with your chosen combination HFRA/Farm Bill

process.

Response: The Forest Service does not want to “proceed with final project approval without completing detailed analysis and disclosure required under NEPA”. The existing

Pilgrim Creek decision and associated activities will be analyzed in the context of cumulative impacts, as required by law, regulation and policy.


Furthermore, the FS likes to tout its “adaptive management” skills, but how can you adapt if you haven’t even completed the required monitoring and evaluation of Pilgrim? In

multiple places the Pilgrim Creek EIS states things like, “Secure habitat is available within Inventoried Roadless Areas within the Pilgrim PSU and the adjacent Elk Creek

drainage.” This Elk Rice proposal invalidates such claims. At the very least, the FS must halt the Pilgrim Creek project, complete a Supplemental EIS considering the

cumulative effects of the giant clearcuts (and other features of) the Elk Rice proposal, and involve the public at each step.

Response: The environmental analysis for the Elk Rice project will include a comprehensive analysis of past, present and reasonably foreseeable actions, as required by law,

regulation and policy. Disclosure and consideration of these potential cumulative effects is routine in these types of analyses.


We incorporate, and refer you to, AWR’s comments and objection to the Pilgrim Creek project within these comments. Those previous AWR submissions describe in very

much detail the very same issues that arise with this Elk Rice proposal.

Response: AWR’s comments on the Pilgrim Creek Timber Sale project have been considered in the context of that project. They are not applicable to Elk Rice, nor will they

be considered as applicable.


A genuine NEPA process would state all of the Forest Plan direction applicable to the project and provide an analysis of how the project would be consistent with that

direction. And allow the public to comment on that analysis. You propose to bypass this process, not “expedite” it.

Response: The NEPA analysis will include disclosure of Forest Plan compliance, as required by law, regulation and policy .


Appendices 600


Letter 1 / Comment 22 / Noxious Weeds

Collaborative group member’s concern: “Impacts of noxious weeds” Your response: “Noxious weed locations have been noted and additional surveys have been conducted.

Design features for minimizing the spread of, controlling the amount of, or in some cases eradicating populations of noxious weeds would be enacted.” Comment: This

unambiguous response is given because it will not reduce volume.

Response: See the Invasive Plant Species section of this EA.

Letter 7 / Comment 5 / Principle Laws and Regulations

Other laws, such as the HFRA, the Clean Water Act, the Endangered Species Act, and others have provisions the FS must address under NEPA. Your PA doesn’t adequately

explain how the project would be consistent with such laws, regulations, and policy.

Response: The description of the proposed action is not intended to include a comprehensive disclosure of environmental analyses. The NEPA document and associated

project file will address compliance with associated laws. Scoping of a proposed action is not intended to include a comprehensive disclosure of effects, but to present a

proposal and to seek comments on it.

Letter 1 / Comment 7 / Proposed Action

Ethical, principled, responsible USFS line-officers never take action that violates the Precautionary Principle. Please allow this wisdom to guide your changes to the draft

NEPA document based on scoping comments. “The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to

the public or to the environment, in the absence of scientific consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking an

action.” Links: http://www.sehn.org/ppfaqs.html; http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1240435/; http://www.precautionaryprinciple.eu/; Comment: Will you apply

the Precautionary Principle to your actions? Certainly clearcuttng 2.6 square miles of public; and used for recreation harms the public. John, if you insist on treating the KNF

like a private industrial tree farm I suggest you seek employment with a company that owns timberland and profits by tending its industrial tree farm.

Response: The IDT carefuly considered the effects of the proposed action to the physiscal and socio-economic environment, as well as water, wildlife, soils, recreation and

scenic resources. The specialists utilized the best available science, adhered to the Precautionary Principle, and developed this Environmental Analysis to be consistent with the

desired conditions of the 2015 Forest Plan for all resources. The project was also developed under the collaborative process with the Cabinet Forestry Collaborative. The IDT

also worked with the Elk Creek Watershed Council.

Letter 1 / Comment 2 / Purpose and Need

Ranger Gubel, the next time you fly a scoping report for public comment I suggest yo include a clear, well defined Purpose & Need

Response: The Purpose and Need was unintentionally omitted from the scoping document, but is clearly described within the Elk Rice Environmental Analysis.

http://www.sehn.org/ppfaqs.html

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1240435/

http://www.precautionaryprinciple.eu/


Appendices 601


Letter 1 / Comment 28 / Purpose and Need

There is no Purpose and Need. Why? Because your P&N is to generate volume. You didn’t want to tell the truth so you left it out. Nationwide, 99.9% of the Scoping Packages

contain P&N statements. A word search in your Proposed Action for Scoping document for “Purpose and Need” reveals this: “The purpose and need statement for a Title VI

project should include a need to reduce the risk or extent of, or increase the resilience to, insect or disease infestation in a designated landscape area.” (page 5) “Silvicultural

prescriptions would be designed to promote within-stand resilience (as described in the purpose and need), create a variety of patch sizes on the landscape, and provide species

diversification.” (page 8) “Proposed silvicultural treatments depend upon numerous factors, including the current and desired forest vegetation conditions at the stand and

landscape scales, the biophysical setting, the management direction and emphasis for the area, and the purpose and need of the project.” (page 41) Why do you discuss a P&N

statement as if it exists when it does not? The public wants to know why you propose to hammer their land. You hide this fact from them. By not allowing the public to

examine the P&N during scoping you will receive incomplete (sometimes meaningless) scoping comments. Don’t forget the Alliance for the Wild Rockies has full-time

attorneys. I suggest you modify your Proposed Action for Scoping document to include the P&N and allow the public another chance to comment.

Response: The Purpose and Need was unintentionally omitted from the scoping document, but is clearly described within the Elk Rice Environmental Analysis.

Letter 1 / Comment 26 / Roads (General)

Public concern: Roads open to the public – will they be left open? Your response: “Open roads would remain open to the public.” Comment: Of course the roads that were

open before the timber sale will be open. The public is asking about your newly constructed roads and your IDT members knew it. The collaborative group members did not

enthusiastically support the Elk Rice timber sale as expected so the IDT rejected their concerns with the responses above. Never before have I seen such trickery and disdain

for the public by an IDT. John, suggest you contract your future NEPA and strive to implement projects that serve people who use the national forests for recreation rather than

spending our money to serve the natural resource extraction corporations.

Response: The public concern was presented during a public meeting and the comment, and its intent, were exactly as stated above, that is, would roads currently open to the

public motorized access remain open, and that answer was, “yes.” Temporary roads would not be open to public motorized access. Three NFS roads, 2747, 2748, and 2749

have year-round gate closures. These roads will be opened for harvest operations but are closed to the public motorized access. As stated previously, temporary roads would be

decommissioned by the purchaser immediately following completion of harvest.

Letter 8 / Comment 2 / Roads (General)

I like road closures for wildlife security. Very few people will walk out behind gated roads, because of the numerous types of ATV’s that are available to the public.

Response: About 17.6 miles of roads will be decommissioned in the Elk Rice project. Also, all temporary roads would be These roads would be decommissioned by the

purchaser immediately following completion of harvest. The status of about 12.6 miles of undetermined road would be changed to the NFS of roads. Adding the undetermined

to the Forest Service system of roads would contribute to progress toward FW-DC-AR-07, providing administrative access for the management of forest lands with minimal

impact on natural resources. This action would directly and beneficially affect the efficiency and practicality of the transportation system. Adding the undetermined road miles

to the National Forest System would not increase total miles in the transportation atlas, it would change 12.6 of those miles from undetermined status to NFS roads in the data

base of record. (see Chapter 2).

Letter 7 / Comment 6 / Roads: Access Management

The PA doesn’t explain how your various categories of roads mesh with the Access Amendments/Forest Plan requirements for the Clark Fork BORZ.

Response: The environmental analysis for the Elk Rice project will include a comprehensive description of existing conditions, and analysis of the potential impacts of roads

related to the proposed actions, as required by law, regulation and policy. Disclosure and consideration of these potential effects is routine in this type of analyses.


Appendices 602


Letter 9 / Comment 6 / Roads: BMPs (culverts and other roadwork)

We note the plans to reroute sections of Road #2273A and this seems like a good effort to protect water quality in the East Fork and main stem of Elk Creek.


Letter 1 / Comment 5 / Roads: Decommissioning

Page 35 states: “About 17.8 miles of road decommissioning is proposed, while about 11.4 miles of undetermined road would be added to the National Forest System.” Never

before have I encountered an IDT who referred to temporary roads as “undetermined” roads. Comment: Competent USFS line-officers obliterate temporary roads after use.

True obliteration returns the land to the angle of repose before the road was constructed. The fill is returned to the cut such that there is no longer a running surface. You

propose to add 11.4 miles of “undetermined” (a.k.a. temporary roads to the National Forest System. Temporary roads are outsloped with no ditch which make them linear

sediment sources. How long have these “undetermined” roads been pumping sediment? You are dangerously close to violating the ESA for T&E fish.

Response: Temporary roads are not undetermined. The term “Undetermined” is assigned to roads whose purpose has yet to be determined. Temporary roads are authorized by

contract, permit, lease, other written authorization, or emergency operation not intended to be part of the forest transportation system and not necessary for long-term resource

management. (36 CFR 212.1). The Kootenai National Forest Transportation Atlas includes some road segments identified as undetermined. These unauthorized road segments

are road prisms on NFS lands that were either constructed for previous management activities but were never documented as NFSRs or have been created by users. Although

these routes are tracked in the transportation atlas to provide baseline resource information (road densities), they are not currently considered part of the National Forest route

system. During the travel analysis process these roads were reviewed and the interdisciplinary team determined whether any are needed for current or future land management

activities. Chapter 2, lists those roads brought forward in this environmental analysis to consider for additions as NFSRs. If the decision-maker approves, the roads would be

reclassified in the transportation atlas from undetermined to NFSR. There are no proposed public access changes. Those roads which are impassable and not proposed to be

used for immediate project activities would remain in their current impassable condition. Those roads used for currently proposed project activities would be gated during

implementation of harvest activities and would either remain gated or barriered after those activities are complete. See the Access Management Table and Map in Appendix D.

Gated roads would be available for limited administrative use. For further discussion of undetermined roads please refer the Transportation section of Chapter 3 of this EA.

The undetermined roads that were identified as not needed for long-term forest management would be administratively reclassified as decommissioned in the forest

transportation atlas (recorded in the Infra Roads Database). Chapter 2 lists these roads. Site visits were made to the road segments with potential resource concerns and it was

determined that three roads need active work to reduce potential water quality impacts. These segments are included in the proposed active decommissioning. The other roads

are currently stable with no identified sediment or resource concerns and are grown in with vegetation. No ground-disturbing actions would occur on those roads, so physical

conditions would be unchanged. Access to the public would not change because these roads are not currently drivable, nor are they legal for motor vehicle use.

Temporary roads would be decommissioned by the purchaser immediately following completion of harvest. For further discussion of temporary roads please refer to Chapter 2

and the Transportation section in Chapter 3 of this EA. Also see response to Letter 1, Comment 4.

Letter 1 / Comment 24 / Roads: Decommissioning

Collaborative group member’s concern: “Road decommissioning – Is it possible to allow “grown-in” roads to be left alone?” Your response: “Grown-in, brushed-in roads

might be left in that condition if they are hydrologically stable.” Comment: Might? If they are hydrologically stable will they or will they not be left in that condition?

Response: If hydrologically stable brushed-in roads would be left in that brushed-in condition.


Appendices 603


Letter 1 / Comment 21 / Roads: Log Hauling

Collaborative group member’s concern: “Impacts from increased traffic on area roads during logging operations” Your response: “Logging traffic would be estimated and

provided to the public.” Comment: Will the impacts from increased logging truck traffic be minimized if the public knows how much logging traffic there will be? Of course

not. The IDT knows you have no intention of regulating logging traffic. They knew they had to respond with something even if it makes no sense rather than telling the public

“too bad, live with it.”

Response: The timber sales are appraised with a haul route to the mill that is the shortest available. Logging traffic will occur on NFS roads, county roads, and state highways.

With the volume estimate from the cruise we can give a rough estimate of the amount of traffic. This is only a very rough estimate because we cannot predict the exact time or

year or even purchaser who will be hauling the timber out. We include road maintenance in the timber sale contract which includes maintenance on NFS roads. The county and

state jurisdiction roads are not the responsibility nor are they under jurisdiction of the Forest Service except under special agreement. The Forest Service would determined

timing and speed restictions and required signage to alert the public.

Logs will be hauled over approximately 58.1 miles of NFS roads and approximately 10 to 20 miles of Sanders County roads. Road maintenance on NFS roads would be

provided under the timber sale contract. Road maintenance on county roads would be the responsibility of Sanders County. "Payments in Lieu of Taxes" (PILT) are federal

payments to local governments that help offset losses in property taxes due to non-taxable federal lands within their boundaries. Since 1908, when Congress enacted what is

commonly known as the Twenty Five Percent Fund Act to compensate local governments for the tax-exempt status of the national forests, the Forest Service has shared 25

percent of gross receipts, including timber sales from national forests with states. The so-called “25 percent payments” were made to the states for the benefit of public schools

and public roads in the counties in which national forests are located.

Letter 2 / Comment 1 / Roads: Log Hauling

I am a resident of Heron, MT and have concerns about the proposed Elk Rice Project. Hopefully you are familiar with the roads that are around Heron and that feed into the

small downtown area. The roads are comprised of loose gravel and dirt. These roads will be utilized by logging trucks, equipment trucks, crew trucks and any assortment of of

necessary vehicles to complete this project. I have lived here for 2 plus years and have lived elsewhere on dirt roads for a total of 12 years. During that time, I encountered the

same vehicles mentioned above due to construction and logging. I had to replace 2 windshields, 5 head lights and pretty much had the front of my vehicles dented from flying

debris that the construction/forest vehicles threw out while they were driving. Almost all of the aforementioned vehicles were exceeding the posted speed limits. By speeding,

they were, in my opinion, causing dangerous situations for oncoming traffic and had a total disregard for safety. Additionally, the dust that these vehicles created became a

health issue for many folks that I knew, including myself. It became a nightmarish situation. We as concerned citizens raised our concerns, but it fell on deaf ears. What I have

outlined above is what will happen here, I am afraid. At the very least, Elk Creek Road and Upper River Road should be paved to alleviate flying debris and eliminate the

dusting conditions. These 2 roads will be heavily utilized for this project. If you can take a tour out here and drive these roads, you will know what I am writing about. Again,

this is a safety and health issue of extreme importance. Hopefully some resolution will be accomplished concerning this serious situation. I really don't think that USDA would

want to negatively impact local residents due to their projects; that in my opinion goes against the nature of their mission. I and my neighbors will be at the meeting this

coming Thursday, September 1, 2016 at 5:30pm to raise these and others concerns. And just so you know, these same concerns of our roads have been brought to the attention

of our County Commissioner, but as of yet, nothing has been done to help us as citizens of Sanders County. I don't hold out much hope of the County stepping up and helping

us. History proves this point.


Appendices 604













Letter 1 / Comment 25 / Roads: New Construction

Collaborative group member’s concern: “Roads – Impacts from new roads” Your response: There was no response to this concern Comment: It’s well known that new road

construction (system or Temp) causes major aquatic resource damage and wildlife habitat fragmentation. Chief Dombeck tried to tell this to USFS employees to no avail:

"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, Chief, US Forest

Service Remarks to Forest Service employees and retirees at the University of Montana February 1998 Link to statement:

https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dombeck%27s%20Rem

arks%20to%20Forest%20Service%20Employees%20and%20.htm A responsible IDT would have said this in their response to this very real concern.

Response: Alternative 2 proposes 3 miles of new NFS road construction. Alternative 3 proposes zero (0) miles of new NFS road construction. This new construction has been

analyzed by each resource area in the Elk Rice EA. There is also a proposed 1.1 mile reroute of NFSR 2273 to alleviate resource concerns along that portion of the East Fork

of Elk Creek. Please refer to the Water Resource and Aquatic Species and Habitat sections for a more thorough discription of the rationale for this reroute.

Implementation of default RHCAs would protect stream habitat from non-channelized sediment inputs, maintain large woody debris recruitment, and ensure nutrient delivery

and storage. The surface flow and sediment that is channeled to the streams by roads would be reduced with BMP work and waterbarring the road surface, accelerating

hydrologic recovery of affected watersheds and reducing the potential for further degradation of native salmonid habitat.

The primary effects of the action alternatives on aquatic resources center on the watershed restoration and project-related road work that would occur at stream crossings. In

addition, road work occurring within RHCAs would likely contribute short-term sedimentation to stream channels. There would be short-term increases of sediment expected

with road relocation (NFSR 2273), storage and decommissioning and BMP road reconstruction leading to short-term effects to native salmonids and aquatic habitat. However,

sediment production would decrease in the long-term through stream crossing stabilization and implementation of BMP design criteria. Stream channels and fish habitat would

begin to be restored and improved. The long-term benefits of reducing water routing and sediment input to stream channels and restoring fish passage would outweigh the

short-term negative effects caused by the roadwork.

Letter 5 / Comment 1 / Roads: Reconstruction and Maintenance

We do ask that dust abatement be included in contracts for county maintained roads that will be used during this proposed project.

https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dombeck%27s%20Rem


Appendices 605














County roads – increased maintenance and repair of our roads should be accounted for before the project begins. Much of the log truck traffic will be over roads that are

already marginal (especially when wet or during a thaw). Please consider the costs to the county and the residents who live on these roads. These costs should be borne in part

by the contractors who profit from the log hauling. I wish to reiterate our concern about the roads as a result of the traffic. We live on Beaver Peak Road and it will be

subjected to 5 million board feet of logging travel. This means approximately 1111 truck loads (one way). What ‘comes down, first went up’ and this small county road will be

brutalized with no compensation for repair, unless the County signs on to a ‘contract agreement’ with the Forest Service and the logging companies before any work begins.

This is a very big deal and the County should be part of the project in reference to the roads they maintain.













We encourage you to confer with county officials to address potential damage to county roads and to cooperate to maintain the roads in good condition.

Response: Logs will be hauled over approximately 58.1 miles of NFS roads and approximately 10 to 20 miles of Sanders County roads. Road maintenance on NFS roads

would be provided under the timber sale contract. Road maintenance on county roads would be the responsibility of Sanders County. "Payments in Lieu of Taxes" (PILT) are

federal payments to local governments that help offset losses in property taxes due to non-taxable federal lands within their boundaries. Since 1908, when Congress enacted

what is commonly known as the Twenty Five Percent Fund Act to compensate local governments for the tax-exempt status of the national forests, the Forest Service has

shared 25 percent of gross receipts, including timber sales from national forests with states. The so-called “25 percent payments” were made to the states for the benefit of

public schools and public roads in the counties in which national forests are located.


Appendices 606


Letter 1 / Comment 4 / Roads: Temporary

The information in the Proposed Action for Scoping document indicates so-called temporary roads on the KNF are really linear sediment sources left to pump sediment into

streams for decades. Comment: A report authored by Gerald Coghlan, WO Acting Director of Engineering in 1998 (17 years ago) indicated there are 372,956 miles of national

forest system road (page 5). The agency currently constructs 2,170 miles of system road per year. At this rate there are 410,000 miles now. In addition to that, there is at least

double this amount in unsurfaced, sediment producing, outsloped, temporary roads. The average distance to the moon (it varies) is 384, 403 miles … and you propose more?

Go figure! See: http://www.fs.fed.us/eng/road_mgt/roadsummary.pdf

Response: The aim of watershed restoration components for the Elk Rice Project would promote a trend toward desired conditions by reducing sediment contribution derived

from road related sources and to reduce road bed impacts to riparian areas. About 15 miles of roads will be decommissioned and temporary roads will be recontoured.

Recontouring involves the full obliteration of the road prism (top of cut to toe of fill) by restoring the natural slope and contours. Recontouring also involves the removal of all

corrugated metal pipes (CMPs) and restoration of all watercourses to natural channels and floodplains. See the Water Resources section of the EA for a full description of

analysis watersheds.

Letter 6 / Comment 1 / Timber Harvest

We have two general comments concerning your prescription for whole tree yarding on some units and for the project’s impact on our county roads. Whole tree yarding – You

state that there will be no fuels treatment for units where the harvested trees are yarded with the top intact. This will rob the site of the harvest of the greatest portion of

nutrients required for healthy soil. If you must yard the trees tops and all, make an effort to use the grapple skidder to transport light slash back to the unit so the needles and

small branches which hold the greatest amount of nutrients can be utilized for the regeneration.

Response: Not yarding tops in some units can affect the ability to conduct safe prescribed burning. Modeling runs display a sharp spike in surface flamelengths that are not

conducive to direct attack under extreme conditions. The tops remaining are a concern as they primarily consist of fine fuels. Location is critical especially the short term risks

associated with treatments in the WUI. In a Douglas-fir habitat you can expect 25 percent yarded loss of branchwood post-harvest. With limited burn windows due to weather,

because the Elk Rice project area is at the wet end of the district, it is anticipated that some units may not come into the appropriate prescribed burn prescription conditions 2-3

years post-harvest. This could present a hazardous situation for several years if the tops were not yarded.

Letter 1 / Comment 6 / Visual Resource

You backhand the public by trying to trick them into believing the scenery in this recreational area will not be harmed. John, you know there is no way you can hide 2.6 square

miles of clearcut (with one being nearly ½ of a square mile) hidden from the public. At page 61 you say: “To protect the scenic quality, design of proposed harvest units may

include grouping of reserve trees to emulate natural retention patterns.” Comment: “May include” of course means will not include. “Harvest units in highly visible areas

would be designed to emulate natural edge patterns with a minimum of geometric lines and feathering of the unit boundaries.” Comment: Do you actually believe minimizing

geometric lines and feathering edges will turn a clearcut into a non-clearcut? There are an infinite number of viewpoints where the sale area can be seen. Your visual

simulations of post harvest scenery at pages 52 and 53 have carefully chosen 2 viewpoints (Gem Peak and Amber Bear Lodge) where the clearcuts are nearly hidden. I could

write scores of pages suggesting roads open to the public and streams used for fishing (from the sale area maps on pages 65, 66 and 67) that have viewpoints that should have

been run through the simulation model. There are many of these areas where the forest visitor is inundated by clearcuts in the foreground no matter which direction they are

facing. Do you serve the public by deceiving and tricking them?


Appendices 607


Response: Regeneration harvest (clearcuts, Seed-tree, shelterwood, and group or single tree selection) is used when it is professionally determined that this is the best method

to meet desired vegetation conditions for that particular site. As mentioned by the commentor, regeration units cannot be hidden as if they don’t exist. For the Elk Rice project,

the Forest Service realizes that the clearcuts will be visible from certain locations. The IDT endevoured to design the shape of the regeneration units to mimic naturally

occuring openings and took into consideration key viewpoints within the project area. Please refer to the Scenic Resource section of this EA.








Collaborative group member’s concern: “Impacts from clearcuts to visual and other resources” Your responses: 1) Clearcuts would be designed to provide species conversion,

where appropriate, adding to diversity in the project area. 2) Clearcuts would be designed to protect the watershed and provide forage for wildlife. 3) Clearcuts would be

designed in sensitive viewsheds to “blend” into the landscape. Comment: Telling the public why the area is being clearcut and “blending” will only occur in sensitive

watersheds does not respond to their concern. They are saying clearcuts in watersheds that harm the scenery are unacceptable regardless of whether the USFS claims the

watershed is sensitive. The IDT knows you have no intention of eliminating your planned clearcuts. They knew they had to respond with something even if it makes no sense

rather than telling the public “too bad, live with it.”

Response: In order to address forest resiliency, insect and disease considerations, and to trend toward desired conditions based on the 2015 Forest Plan, appropriate

silvicultural prescriptions were utilized to address the vegetative conditions on the ground. This included the use of improvement harvest where the forest stand conditions

warranted this prescription and the use of regeneration harvest (clearcut with leave trees, clearcut with reserves, and Seed-tree) where the existing condition did not warrant the

use of improvement harvest. The 2015 Forest Plan states, “FW-GDL-VEG-08. All silvicultural practices may be used to manage forest vegetation. This includes silvicultural

systems (e.g., even-aged, two-aged or uneven-aged), regeneration methods (e.g., clearcutting, seed-tree, shelterwood, and group or single-tree selection), as well as other

practices such as improvement cutting, commercial or pre-commercial thinning, use of planned or unplanned ignitions, planting, pruning, invasive terrestrial plant species

control, cone collection, tree improvement, insect or disease control, site-preparation, and fuel reduction. Appropriate practices for a given situation depend on numerous

factors, including the current and desired forest vegetation conditions at the stand and landscape scales, the biophysical setting, and the management direction and emphasis for

the area. Silvicultural practices should generally trend the forest vegetation towards conditions that are more resistant and resilient to disturbances and stressors, including

climate change.”

Please refer to the Scenic Resource section of the EA. In the short term, the proposed harvest activities would result in created openings with some clumps of trees as well as

single trees remaining. The effects would be noticeable. By tying into existing openings and utilizing topographical breaks, the edges of the openings would be less noticeable.

In the clearcut with reserves units the openings would be planted with disease resistant species to contribute to a healthier, more resilient forest. Over the long term, as the

vegetation recovers, the harvest units would blend in with the existing background landscape as seen from the viewing areas leaving the activities noticeable but subordinate to

the landscape character.


Another concern is about the ‘visuals’ that we will live with once the proposed project is complete. The amount of clear cutting with ‘leave trees’ is huge. I know the project is

smaller than the original plan we were presented with, but it is still huge. The impact on Beaver Peak will be ugly and I would much prefer smaller cuts that blend in better

than what your maps display. I believe ‘thinning’ is a better way to deal with fire suppression rather than ‘clear cuts’ even though it is a more expensive option.


Appendices 608


Response: Please refer to the Scenic Resource section of the EA. In the short term, the proposed harvest activities would result in created openings with some clumps of trees

as well as single trees remaining. The effects would be noticeable. By tying into existing openings and utilizing topographical breaks, the edges of the openings would be less

noticeable. In the clearcut with reserves units the openings would be planted with disease resistant species to contribute to a healthier, more resilient forest. Over the long term,

as the vegetation recovers, the harvest units would blend in with the existing background landscape as seen from the viewing areas leaving the activities noticeable but

subordinate to the landscape character.

Letter 1 / Comment 23 / Water Resource

Collaborative group member’s concern: “Protection of a spring and aspen grove in Pew Gulch area” Your response: “No activities were proposed in the area of the aspen

grove and spring in Pew Gulch.” Comment: This unambiguous response is given because it will not reduce volume.

Response: Thank you for our comment.

Documents

Appendix G – Response to Public Commentsa123.g.akamai.net/7/123/11558/abc123/forestservic.download.akam… · Appendix G – Response to Public Comments Appendices 591 Elk Rice