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Corsair Project Response to 30-day Comments: March, 2014

The following are the response to comments received during the 30-day comment period for the Corsair

Project located on the Huron Shores Ranger District of the Huron-Manistee National Forests;

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1. The district has a bias toward logging that results in failure to disclose the effects on aquatic

resources, visual quality, recreation opportunities, soils, fish, water quality, economic and

wildlife.

Response: The Forest Service (FS) uses a variety of tools in order to meet its management

objectives. The Huron-Manistee National Forests’ Plan (as amended—hereby referred to as the

Forest’s Plan) states “The Huron-Manistee National Forests vegetation management program is

the primary tool for restoring and providing a diverse range of sustainable habitats for many

species, supporting forest health and providing wood fiber (Forests’ Plan pg I-1). “The Forests’

will reach their desired conditions for vegetation through natural ecological processes and by

using a diverse range of management tools and techniques. To the extent practical, timber

management will be used to emulate naturally-occurring disturbances (Forests’ Plan pg I-9).”

The Corsair EA is tiered to the Forests’ Plan and Final Environmental Impact Statement (FEIS).

The Forest Service is also bound by laws such as the Multiple-Use Sustained-Yield Act.

The Multiple-Use Sustained-Yield Act of 1960 made it clear that the Forest Service was

responsible for managing non-timber values as well, such as recreation, range, watershed,

wildlife and fishery purposes, but it wasn't until the National Forest Management Act (NFMA),

that these uses were embodied by the forest planning process.

Chapter 3 of the Corsair EA complies with the Multiple Uses Sustained Yield Act and NFMA by

disclosing the effects of the project actions on non-timber resources. This includes effects to

resources such as aquatic resources (pg 77-81), visual quality, (pg 116-121), recreation

opportunities (pg 45-55) soils (pp 114-116) fish (pg 55-77) economics (pg 122-125) and wildlife

(pg 55-77).

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2. The Analysis failed to include non-shelterwood non-seed tree prescriptions.

Response: The Forests’ Plan allows several cutting methods to be used in Management Area 4.2.

and states: “Standard cutting methods such as single-tree and group selection, shelterwood,

seed tree and clearcutting may be used” (pp III-4.2-5). The silviculturist uses professional

judgment to choose which method is appropriate to regenerate an area based on silvicultural

characteristics of the species and takes into consideration aesthetics, site conditions, economics,

insects and disease, wildlife, etc.

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The regeneration of oak by the shelterwood method is a common practice. Alternative methods

of regeneration, such as planting of oak after a site has been clearcut have been tried and met

with very little success on the Huron National Forest whereas the shelterwood method has

repeatedly proven successful.

They further add: “The advantage of the uniform shelterwood method (which is what would be

done in the Corsair project) can be listed as follows: 1) it allows ultimate control of site

conditions for the regeneration of even-aged stands; 2) it is the best method for heavy-seeded

species; 3) it provides the best control over regeneration composition, amount, and distribution;

4) it is the most flexible method since it is applicable to tolerant and intolerant species; 5) good

soil protection is provided; 6) high aesthetic qualities are produced; and (7) there are no

biological constraints on its application to large areas.” Smith (1986) states: “The shelterwood

method is ordinarily aimed at securing natural regeneration from seed”. Sander (1977) states:

“Planting oaks after clearcutting has generally been unsatisfactory because planted seedlings do

not grow fast enough to compete with the new sprouts”.

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3. The document fails to use the best available science.

Response: The Forest Service is required to use the Best Available Science (BAS) for any

proposed project (40 CFR 1500.1(b)). The regulation at 36 CFR 220.7(b)(3)(i) directs an EA to

“…briefly provide sufficient evidence and analysis, including the environmental impacts of the

proposed action and alternative(s), to determine whether to prepare either an EIS or a FONSI

(40 CFR 1508.9).” The regulation at 40 CFR 1500.1 (b) explains the NEPA process must have

“high quality information” and concentrate on “truly significant” issues. The Corsair Project

from proposed action to implementation is a collaborative of input, field review, analysis work,

and additional contributions from resource specialists that considers best available science. We

ensure that BAS is incorporated through the scientific integrity of resource specialist discussions

and analyses in the project document and project file. To be more precise, the project

document indicates methods used, includes peer reviewed scientific resources, discusses

opposing views, divulge incomplete or unavailable information, and discloses uncertainty and

risk (40CFR, 1502.9(b), 1502.22, 1502.24). For a full listing of references and BAS used in

preparation of this analysis, refer to the Project File.

BAS was used for this analysis. The “opposing view” attachments provided by the commenter

were reviewed for content and did not provide additional information relevant to the project.

The results of this review are located in the project file.

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4. The ID team didn’t include the proper specialists resulting in failure to use best science. There

should have been a fisheries biologist and landscape architect.

Response: Members of the Corsair Project ID Team are considered professionals in their field of

study by way of academic achievement, agency training, years of experience, and in many cases,

certification programs. While the Corsair Project did not specifically have a fisheries biologist or

landscape architect on the ID Team, effects to fisheries and visuals were documented in the EA

using the ID Team approach, the Forests' Plan standards and guidelines, Best Management

Practices, Visual Quality Objectives, and a collaborative effort that included resource

professionals at the District and at the Supervisory Office level.

District Biologist consulted directly with the Forests Fisheries Biologist and Hydrologist and

mutually developed proposed actions for fisheries following a field review on August 29, 2012.

The Corsair ID Team collaboratively worked with District and Supervisory Office Recreation and

NEPA staff to develop the effects analysis on visuals in lieu of an appointed Landscape Architect.

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5. The proposed action failed to disclose the extent of road building or the road locations (temp

and system) failing to inform the public.

Response: There are no new system roads slated to be built in the Corsair Project. There would

be few temporary roads built, if any, due to the high number of system roads that already exist

in the project area.

Temporary roads are different from system roads. Temporary roads are roads that are

authorized by contract, permit, lease, or other written authorization or emergency operation

not intended to be a part of the Forest transportation system. They are not intended for long-

term use or resource management and are not open to the general public for vehicle travel. In

the Corsair Project, temporary roads may be constructed with the implementation of

management activities however, they would be closed within a year after harvesting (Corsair EA

pg 111). Calculated road densities in the Corsair Project did not include temporary roads since

they are of short duration and would be obliterated upon the completion of the activity.

Locations of temporary roads are not disclosed in the EA because their locations depend on

when timber sales are offered (time of year) and how the timber sales are bundled and

packaged. The Forest Service works closely with timber sale contractors to plan temporary

roads and also obliterate them.

The Corsair EA, Appendix B, Maps; identifies the inventory of roads and location within the

project area. Each project map displays road locations in relation to the proposed and

alternative treatments.

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6. The document failed to adequately disclose the effects of temp roads, skid trails and landings

on soil, water, wildlife and fish. (both existing: current condition, and proposed (direct,

indirect and cumulative).

Response: There are no temporary stream crossings planned in the Corsair Project EA. All road

courses including temp roads and skid trails are laid out to avoid water resources as part of the

timber contract. They follow Best Management Practices (BMP’s), the Forests’ Plan Standards

and Guidelines, (pg II-40), and provide special restrictions for transportation system for water

quality.

Corsair EA Chapter 3.8 Soils, pages 114-116; Addresses transportation which include temp

roads, skid trails and landings, and identifies the potential of soil compaction and soil

disturbance. The Specialist determination is that the proposed treatments would have minor

adverse effects to soils as the Forest has established guides to minimize the effects of

transportation on soil resources.

Corsair Chapter 3.5 Aquatic Resources, pages 77-81; Addresses effects to water quality from

timber harvesting, road building, and road decommissioning. Due to the predominance of

sandy soils within the watershed, stream bank erosion potential is high. “Impacts to water

quality are expected to be negligible when project designs features are properly implemented

and maintained. Sedimentation would not be expected to occur because equipment operations

would not take place beyond the slope break adjacent to water bodies. Some of the streams

also have a wide alder and grass floodplain that is excluded from the treatment areas. These

floodplains further separate the streams from areas of operation, thereby providing extra

protection” (pg 80).

The Forests’ Plan states “Minimum Streamside Management Zone width should be 100 feet from

each side of the stream or lakeshore. Width should be increased with increases in slope percent

as illustrated in Table II-11” (Forests’ Plan II-17).

Corsair Chapter 3.4 Fish and Wildlife 3.4 pages 55-77; The action alternatives would reduce

potential for sedimentation impacts to brook trout and other fisheries in conjunction with

ongoing road maintenance projects.

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7. The team/decision maker should have considered an alternative that has no road building

(temp or system) to compare harmful effects of road building (including economic).

Response: The No Action Alternative considers a no road building option. No system roads are

slated to be built. Due to the high number of system roads that already exist within the project

area temporary roads would be minimal. Temporary roads would be closed within a year after

harvest as part of the timber sale contract.

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8. The proposed action fails to meet the purpose and need of improving local economy- no

analysis showing the benefit to the local economy was included. (recreation vs. timber for

local economy).

Response: Forests are an important source of employment and rural development. Close to

three million Americans have forest-related jobs in fields ranging from forest management to

outdoor recreation to the forest products industry. In addition, the FS provides services

contracts for many types of resource activities including tree planting, timber harvesting,

reducing Non Native Invasive Species (NNIS), culvert and bridge replacement and road

reconstruction which further play into the local economy.

The restoration of large natural areas, sustainable forest management, and the development of

markets for timber and recreation jobs to communities in northeast Michigan and benefit rural

economies in ways that cannot precisely represent industry employment and earnings at the

local and community level. This is because additional layers of assumption and estimation

beyond basic county data are required.

The broad supply timber and the local economy is difficult to directly tie into the purpose and

need of the Corsair Project because the Forest Service cannot say who will get the timber

contract—local or not. What we do know however, is that from 2011-2013 there were 49

timber sale purchases across the HMF and all of them were local purchasers. Information

regarding the number of timber purchasers per bid and the locations of the purchasers is

located in the project file.

It is difficult to discern how much recreation adds to revenue in the Corsair Project area. We

know that the numbers of recreationists is increasing over time and that the primary

recreational activities in the project area include cross country skiing, hiking, driving for

pleasure, motorized and non-motorized trail use, hunting, fishing and camping (NVUM 2012).

Multi- resource management activities continue to occur across the forest and temporarily

displace certain types of recreation.

Management activities in the Corsair Project area include trail construction, jack pine

regeneration, fuel break creation and maintenance, and road realignment projects. It is the

professional judgment of recreation staff that a reduction in recreation visits occurs after certain

management activities while other recreation activities remain constant. For example, after

harvesting jack pine, hunting and camping decline in the treatment area for several years until

the jack pine grows to create habitat for hunting, while opportunities for activities such as

blueberry picking increase. Other activities such as trail use remain constant regardless of

management activities. Effects are disclosed in the recreation section of Chapter 3 of the

Corsair EA (pg 45).

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9. The document should have included a cost benefit analysis for all actions including post sale

restoration.

Response: Post sale remediation is not discussed in the Corsair EA because none are

anticipated. If they were anticipated, they would have been discussed in Chapter 3 of the EA.

BMP’s, Forests’ Plan standards and guidelines will be adhered to. If remediation were necessary

due to unforeseen circumstances, they would be handled under the terms and conditions of

timber sale contracts.

Revenue generated from timber sales is the only source of income generated as a direct result

of the proposed actions. The revenue of timber sale receipts is divided. A portion of the timber

sale receipts (25%) are paid to local governments within Iosco County for the sale of federal

timber. The primary uses of the receipts are used for road infrastructure and public schools

projects. A portion goes into the national treasury while another portion is available for

accomplishing projects within the timber sale boundary under the Knutson-Vandenberg Act (KV

funds).

The majority of projects proposed in the Corsair EA would be financed through KV funds. KV

eligible projects are prioritized with reforestation required to occur first. This ensures that

harvested lands are fully stocked within three to five years after completion of the sale. Full

stocking is ensured through a series of activities such as site preparation, planting of trees,

stocking surveys, plantation survival surveys, and final certification. Remaining KV funds would

then be used for projects proposed in the Corsair project area such as bridge and trail

reconstruction, wildlife and habitat improvements, fuel reduction, prescribed burning, and

fisheries structure maintenance.

If there are projects remaining after KV funds are no longer available, the FS can use outside

sources of funding such as special grants and agreements like the National Forest Fund,

partnership dollars, and to a smaller degree, appropriated funds. Refer to the economics report

in the project file for additional information.

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10. The effects of Glyphosate were not adequately considered (there will be effects on humans,

mammals, bees, fish and birds).

Response: The Forests’ Plan sets Forest-wide Goals and Objectives that include: “Reduce non-

native invasive species infestation and prevent new invasive species from becoming established,

when possible” (Forests’ Plan, pg. II-4).

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The Forest Service prepared a programmatic EA, the Huron-Manistee National Forests Non-

Native Invasive Plant (NNIP), that addressed the effects of using herbicides including glyphosate.

In the Decision Notice/Finding of No Significant Impact for the NNIP, glyphosate is listed as an

herbicide that is acceptable for use on Forest System lands (USDA Forest Service, 2008). Effects

on humans, mammals, bees, fish and birds were considered (Section 4.1.3). The types of NNIP

management activities that are undertaken on Forest System lands were determined by the

NNIP Interdisciplinary Team and the NNIP Deciding Official (Forest Supervisor), to be routine and

acceptable.

Human Health and Ecological Risk Assessments have been prepared for glyphosate (Syracuse

Environmental Research Associates, Inc., 2011). In these documents, risk analyses are used to

quantitatively evaluate the probability that glyphosate and any adjuvants (agents which aid the

function of the herbicide) use might impose harm on humans or other species in the

environment. Measures of risk were based on typical Forest Service use of the herbicide. For

glyphosate, The EPA uses 2.0 mg/kg/day as a level of exposure that would not result in any

adverse effects in any individual to measure both short and long-term exposure. Typical

estimates of applicator’s exposure are small, ranging between 0.026 and 0.045 mg/kg/day.

Most long-term estimates of exposure for the general public are much lower than for

applicators. The proposed use of glyphosate would be minimal. Any invasive plant treatment

utilizing glyphosate would be spot treatment of individual plants or stumps. The proposed

concentration of herbicide applied is well below 2.0 mg/kg/day; potential effects are well below

the exposure established by the EPA.

All herbicide application will be done in accordance with label direction (FSH 2109.14, 52.11)

and the specifications in the Forest Service Manual 2150, Pesticide Use Management and

Coordination (USDA Forest Service, 1994), and in the Forest Service Handbook 2109.14,

Pesticide Use Management and Coordination Handbook (USDA Forest Service, 1994). Also,

compliance with all federal, state, and local regulations regarding herbicide use would be

followed. Herbicide application would be conducted and/or overseen by certified personnel

(FSM 2154.2).

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11. There should have been an alternative to herbicide use considered.

Response: Alternatives to the use of herbicide were included in the Corsair Project

Environmental Assessment under the No Action Alternative (Corsair EA). The Modified

Proposed Action Alternative and Alternative III include alternative treatments such as

“mechanical, hand-pulling treatments and/or prescribed burning (pp 17-20).”

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12. The analysis failed to include a disclosure of the effects of climate change on the project and

the projects effects on climate change.

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Response: We do not agree that the Forest Service is required to address the effects of

individual projects on climate change. A February 2010 memo from the Council on

Environmental Quality (CEQ) specifically excludes land management agencies because “land

management techniques, including changes in land use or management strategies, lack any

established Federal protocol for assessing their effect on atmospheric carbon release and

sequestration at a landscape scale.”

Forest Service analysis of this issue (Climate Change Considerations in Project-level Analyses,

2009) concludes that, “It is not currently feasible to quantify the indirect effects of individual or

multiple projects on global climate change and therefore determining the significant effects of

those projects or project alternatives cannot be made at any scale.”

Agencies apply the rule of reason to ensure that their discussion pertains to the issues that

deserve study and deemphasizes issues that are less useful to the decision regarding the

proposal, its alternatives, and mitigation options. 40 CFR 1500.4(f), (g), 1501.7, 1508.25. In

addressing greenhouse gases (GHG) emissions, consistent with this proposed guidance, CEQ

expects agencies to ensure that such description is commensurate with the importance of the

GHG emissions of the proposed action, avoiding useless bulk and boilerplate documentation, so

that the NEPA document may concentrate attention on important issues (40 CFR 1502.5,

1502.24).

Since it is not possible to predict the actual effects of a particular project on global climate

change or local climate, a baseline comparison of climate change cannot generally be made

using the no action alternative and comparison of alternatives is generally not essential to a

reasoned choice among them.

However it should be noted that Forests in our region continue to be a net carbon sink. That is,

they take up more carbon than they release. This is true of U.S. forests generally (Baseline

Assessment for Carbon Stocks including Harvested Wood Products- USDA Forest Service, Eastern

Region, Climate Change Advisors Office, Office of the Chief, October 30, 2013.) “Total forest

ecosystem carbon stored in the Eastern Region slowly increased from 1990 to 2001, after which

period the increase was more rapid…. During this period the Huron-Manistee, Mark Twain,

Ottawa, Shawnee, Hiawatha….. generally increased in total forest ecosystem carbon….”

(Baseline Assessment for Carbon Stocks including Harvested Wood Products- USDA Forest

Service, Eastern Region, Climate Change Advisors Office, Office of the Chief, October 30, 2013. )

Huron-Manistee National Forests timber harvest levels are expected to be similar to what they

were during this time frame (which ranged from a low of approximately 26,784 MBF in 2003 to a

high of 57,176 MBF in 2010), and the Forests position as carbon sink would be expected to

continue. Further, much of the wood harvested from the Forests still stores carbon after it is

cut. Using the IPPC/EPA production accounting approach the eastern region had 11,958,121

MgC total carbon stored in harvested wood products in 2000. In 2005 the region had

12,358,148 MgC and in 2010 the region had 12,552,233 MgC, (Estimates of carbon stored in

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harvested wood products from United States Forest Service, Eastern Region, 1911-2012 Dan

Loeffler et. al. July 2013).

The cited cases pertain to major sources of GHG emissions (coal-fired power generation and

automotive fuel economy standards). We believe that the scope of our analysis is, in fact,

commensurate with the effects of our proposal. The proposal is for sustainable forestry, which is

considered to contribute to carbon sequestration.

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13. The EA fails to divulge that the 1982 NFMA (National Forest Management Act) requires the Forest Service to provide for adequate fish and wildlife habitat to maintain viable populations of existing native vertebrate species. The pre-decisional EA does not discuss how the timber sale’s harvest and slash/Rx burning activities will affect protected bird species or if there will be adverse effects how they will be eliminated.

Response: The wildlife section (pg 56) addresses NFMAs viability requirement and tiers the

analysis to the Forest Plan’s EIS as follows, “the Huron-Manistee National Forests are required to

maintain the viability of all native and desirable non-native species. The Forests ensure that this

requirement is met through the Species Viability Evaluation (SVE) process. Detailed evaluation

occurs only for those species, identified on the “Species Viability Evaluation List” which may have

viability concerns. Following development of this list, species were grouped by associated

habitat and a focal species was selected for each of these habitat groups. The effects of action

alternative proposals on the viability of wildlife species were addressed utilizing these habitat

groups and focal species. A detailed discussion of the Species Viability Process can be found in

the Final Environmental Impact Statement (FEIS) Appendix B, to the 2006 Forests’ Plan revision

(USDA Forest Service 2006).”

Viability is first addressed in Chapter 1, Table 3 Desired Condition versus Existing Condition of

the Corsair EA, where the Desired Condition for the project area (#2) says, “Maintain or restore

community diversity and forest health and to provide for wildlife and plant viability.” Chapter 3,

(pp 56-73) provides an in depth analysis of the effects of each alternative on wildlife species

viability. Effects of the projects proposed activities, including timber sale harvests and

prescribed burning, on protected bird species are mentioned throughout this section including,

neo-tropical migrants (pp 58, pp 60); chestnut-sided warbler (pp 58); white-winged crossbill (pp

58); woodpeckers (pp 60); bald eagle (pp 61-63); Kirtland’s warbler (pp 61, 62, 67,71, 72, 76, 77);

red-headed woodpecker (pp 67-68); whip-poor will (pp 67, 69); northern goshawk (pp 67, 69-70,

75, 76); spruce grouse (pp 67, 72, 73); and eastern bluebird (pp 69, 71).

The effects from proposed project activities on federally listed species receiving protection

under the Endangered Species Act are described in detail in the Biological Evaluation (BE) for the

Corsair Project (appendix BE) and are summarized in the EA (pg 73).

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The BE also analyzes the potential impacts from proposed project activities on birds protected

as Regional Forester Sensitive Species by the Forest Service. Table 11 Regional Forester

Sensitive Species Considered (pg 73) lists the birds and all wildlife and plant species considered

in this evaluation. A summary of the determinations for protected birds from the Biological

Evaluation are summarized in the Corsair EA (pp 76-77) for each alternative.

Design criteria are intended to lessen or eliminate potential impacts from proposed activities.

Chapter 2 of the EA (pp 25-27) describes project design criteria that are used to reduce adverse

impacts to resources as part of each action alternative.

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14. Amenity resources in and downstream from the sale areas are discounted.

Response: The following amenity values are addressed in the EA: Timber Sale effects on Visual Quality, Recreation Values, Water quality, and Fisheries. Amenity resources, such as Visual Quality are addressed throughout the document. Project

design criteria addresses visuals by giving consideration to dispersing treatments across the

spatial and temporal scales, scheduling treatments during low visitor use seasons, and giving

consideration to blending cleared areas into the surrounding landscape and rehabilitate at

completion of the project (pg 25).

Protecting recreational uses, scenic and visual integrity are a priority for the Corsair Project

proposed activities. This is demonstrated in Chapter III, (pg 93). The effects of not harvesting

would be visually unappealing to the public (pg 119).

Regarding the effects of timber sales would likely contribute to improved visual effect over the

long term EA (pg 120).

Amenity values for recreation are addressed throughout the document, project design criteria

addresses recreation measures by addressing visuals and safety, (pg 26). Amenity resources are

further analyzed under the recreation section (pp 51-55). These amenity resources were

similarly analyzed for timber sales proposed under Alternative III, in Chapter 3, (pp 54-55) with

comparable results.

Amenity resources for water quality were addressed at a scale that included areas downstream

from the project area and proposed timber sales. The analysis bounds for water quality are

discussed in Chapter III (pg 61).

Water quality is protected through project design criteria (pp 27). Water quality effects from

timber sales are also addressed again on pg 80.

Amenity resources such as fisheries are also addressed. Effects to fisheries are documented

under the Management Indicator Species Section of Chapter III (pg 65).

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Effects from timber sales on brook trout and mottled sculpin as well as water quality are

addressed in Chapter III, (pg 66).

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15. The document failed to include an analysis of steam connectivity to evaluate effects of roads

on streams (including water temperature).

Response: This comment expresses concern that “road-stream connectivity” was not

appropriately analyzed and that there is potential for associated effects on aquatic ecosystems.

The term “road-stream connectivity” refers to the situation where precipitation that falls on a

road enters a stream channel directly through surface water flow. The flow path of precipitation

from road to stream can be 1) along the road itself; 2) along a roadside ditch; or 3) along gullies

created by concentrated flow at “relief culverts.” This can potentially result in: 1) changes to

the volume or timing of precipitation entering stream channels (seasonal or storm

hydrographs); 2) increases in sediment delivered to stream channels; or 3) increases in stream

temperature. The scientific papers cited by the commenter regarding stream connectivity are

summarized in the Attachment 4 in the project file.

Implementation of either action alternatives (Alternatives II and III) would: 1) reduce overall

road mileage within the management area; and 2) improve the condition of improperly planned,

poorly designed or poorly maintained roads (road reconstruction) compared to the existing

condition (see also Table 4, pg 25). Implementation of the action alternatives would therefore

be expected to reduce the potential for adverse impacts on aquatic systems.

The Huron-Manistee National Forests recognize that improperly planned, poorly designed, user-

created, or degraded roads and roads systems can result in many types of environmental

degradation. The EA mentions this directly (pg 78). The issue of stream temperatures is also

addressed, (pp 65-66).

Correction of sedimentation, barriers to aquatic organism passage, and adverse hydrologic

impacts associated with roads are among the top priorities of the HMF Fisheries and Watershed

programs. The HMNF also recognizes that localized areas of high road density exist and has

Forests’ Plan goals and objectives to attain appropriate densities through management (Forests’

Plan Table 11-13, pp 11-40). The HMF, along with its partners, have invested substantial

resources and made encouraging progress correcting road related resource issues over recent

decades.

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16. The analysis failed to identify methods and procedures required by Section 102(2)(B) of NEPA

to ensure that presently unquantified environmental amenities and values may be given

appropriate consideration.

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Response: 40 CFR 1507.2 (b) required agencies to "identify methods and procedures required by

section 102(2)(B) to insure that presently unquantified environmental amenities and values may

be given appropriate consideration. The requirements in 40 CFR 1507 regarding agency

compliance with NEPA regulations were added by the Forest Service through the development

of the Forest Service NEPA regulation at 36 CFR 220. NEPA procedures for the agency are also

outlined in the Forest Service NEPA Handbook at FSH 1909.15. The agency meets the

requirements of the 40 FR 1507 regulations through the implementation of the 36 CFR 220

regulations, the NEPA Forest Service Handbook and the Forests’ Plan. The methods and

procedures through which concerns (including quantified and unquantified environmental

amenities and values) are evaluated for "appropriate consideration" include the requirement for

analysis through regulations (such as the Forests’ Plan and FSH). These methods and procedures

are reflected in the analysis in individual NEPA documents, such as the Corsair EA. The

appropriately considered quantified and unquantified environmental amenities and values are

those written in Chapter 3 of the document.

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17. Commenter wants to know timeline of closing roads FR 4170 and 4173 and fuel break work.

Response: The commenter is referring to fuel break work that was signed under the Brittle II

document. The fuel break is being created as part of a sale slated for implementation in 2015.

The road closures, FR 4170 and FR 4173 are proposed as a part of the actions in Corsair Project.

The anticipated signature date of a Decision Notice/FONSI for Corsair is estimated in March

2014 with implementation occurring over the next 5-10 years.

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18. Wants to know what oak regeneration would look like in the east portion of project area.

Sees there has already been oak cutting in that area.

Response: The proposed Corsair Project oak treatments would be very similar to the Tawas 5

oak shelterwood sale (in the east central portion of the Corsair Project area). This sale is the

only oak shelterwood treatment that has been implemented on the east side of the project

within the last ten years. The Corsair oak treatments are designed to help recruit and

regenerate oak in the understory. Currently these stands do not have enough oak in the

understory to sustain the oak forest type. Treatments include removing most of the red maple

and thinning the remaining oak. This would open up the forest canopy and allow diffuse

sunlight to reach the shade intolerant oak in the understory. Prescribed fire may also be used to

stimulate suppressed oak, prepare seedbed for oak germination and set back the shade tolerant

red maple. Without these treatments, the oak would eventually be replaced with red maple

and white pine.

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19. Supportive of Alternative III and no ATV trail designation.

Response: Comment noted.

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20. There is a greater need for additional work a Buck Creek Pond to rid it of invasive Yellow Perch

fish species. Would like to see the FS restock Buck Pond with Brook Trout.

Response: Buck Creek Pond is established as a trout fishery. While the Forest Service is the

agency that manages the habitat of the pond, the Michigan Department of Natural Resources

(Fisheries Division) has jurisdiction for managing the fisheries resource (brook trout). Recently,

the Forest Service has renewed the process of conferring with the Michigan Department of

Natural Resources, Fisheries Division, discussing options on how to best enhance the Buck Pond

brook trout fishery.

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21. Suggests that trash cleanup be done in conjunction with each project. This is usually

overlooked and trash remains after proposed actions completed.

Response: The ID Team is aware of this problem in the project area and across the district as a

whole. Trash cleanup is not normally planned as an action in an EA. The district plans and

sponsors trash cleanup events to address this districtwide problem. Trash cleanup is outside the

scope of the Corsair EA.

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22. Suggests there is more fish structure maintenance along Silver Creek to be done (planning

team under estimated number of fish structures in document). Also suggests the entire length

of Silver Creek be included for fish structure rehab.

Response: This comment is expressing the concern that the planning team under estimated the

number of fish structures available for maintenance in Silver Creek. As described in the

document, Alternative II Modified Proposed Action makes reference to the number of structures

proposed for maintenance: “Maintain existing fish structures: There are approximately 50 fish

structures over the course of a one (1) mile segment of Silver Creek running from Monument

Road to the north.”

Alterative III proposes to expand the work proposed in the Modified Proposed Action to include

maintaining an additional mile of existing fish structures. This additional maintenance would

begin at the Silver Valley trailhead and is proposed along the south side of Silver Creek to what

is locally referred to as the Little Mack Bridge in the Corsair Trail System. Alternative III

proposes to maintain approximately two (2) miles of fish structures. Fish structures would be

maintained using handwork, brush and logs (pg 22).

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Fish structures were built with native materials to enhance trout habitat. Since then, ice

damage and weathering have diminished the effectiveness of many of these structures, and

obliterated others so that while more structures were created originally, the ID Team feels the

number remaining today is closer to 50 after a stream inventory and evaluation was conducted

on August 29, 2012. It was decided that maintenance was needed to replace the brush and logs

and restore the suitability of the remaining structures, and that the natural recruitment that has

occurred over time was adequate in areas of the creek where manmade structures were no

longer evident. The reference to the number of structures, “approximately 50” was not

intended to be a maximum or limiting number, but to reflect and disclose what the ID Team

observed in the field. The additional area proposed under Alternative III did not list any

approximate number of structures since this alternative was created in response to comments

like this one, from the public and no inventory was conducted.

While fish structure rehab could be implemented on the entire creek, the ID Team feels that the

areas of Silver Creek represented by the proposed actions represent the highest priority for

management at this time, when considered with similar needs to enhance trout habitat on

other trout streams across the District.

_____________________________________________________________________________________

23. Shellenbarger Rd stream crossing at Buck Creek needs improvement to reduce water runoff

and sediment into Buck Creek.

Response: Stream crossings in the Corsair Project area were analyzed. This particular stream

crossing does not warrant replacement at this time. Stream crossing maintenance is

implemented annually on a case by case basis in cooperation with Forest Engineers and local

county road commissions.

_____________________________________________________________________________________

24. More acres of wildlife openings need to be treated than proposed.

Response: This comment is expressing the concern that the planning team under estimated the

number of wildlife openings available for maintenance in the Corsair Project area. As described

in the document, Alternative II Modified Proposed Action proposes only one specific opening for

maintenance. This particular opening was singled out for special treatment due to the presence

of Regional Forester Sensitive species (wildlife and plants) and the concern that the habitat

suitability is being compromised by NNIS. The ID Team felt that special treatment was required

here to suppress the NNIS, including utilizing herbicides.

The ID Team acknowledges that there are openings scattered across the project area,

management of these areas is incorporated at the landscape scale into the treatments for low

site oak and prescribed fire. Generally speaking, these openings are located interior to roads

and do not have advanced invasion from NNIS, so maintenance with prescribed fire is all that is

15

proposed to suppress encroachment of woody plants and enhance conditions for native warm

season grasses. The Modified Proposed Action says, Shelterwood cut and apply prescribed fire

on approximately 1,770 acres of low site oak: “… Dead and downed oak has created heavy fuel

loading across the low site oak stands. Prescribed burning and or mechanical treatment would

occur to reduce fuel loading and the potential of wildfire, and regenerate oak while it is still vital.

Burning would also suppress red maple, encourage native warm season grasses, nectaring

sources, and associated wildlife species.” It is also cost effective to incorporate these areas into

a larger scale prescribe fire treatment rather than individually by mechanical treatments, when

either treatment can accomplish the same objective.

_____________________________________________________________________________________

25. Waterhole maintenance needs to be in proposed action.

Response: This comment is expressing the concern that the planning team did not propose any

waterhole maintenance in any of the Proposed Actions. While some waterholes were created in

the past within the project area, management of these structures individually, is not deemed a

priority at this time. Some management is planned, such as reduction of encroachment of

woody plants around these structures, and is being addressed through other management

techniques, such as landscape scale underburning.

_____________________________________________________________________________________

26. Corsair warming shed use has limited and narrow usage. Need alternative method of

management to make available to public more frequently.

Response: The building of the warming shed was proposed by the Corsair Trails Council. The FS

agreed to the building of the shed with the condition that the Trails Council would take care of

the maintenance and management. The FS has a Challenge Cost Share Agreement with the

Trails Council that establishes the cooperation between the parties to maintain the Corsair ski

trails and ancillary facilities. The FS contributes approximately $5,700 per year in services while

the Corsair Trails Council contributes over twice as much in services.

The agreement between the FS and Corsair Trails Council reads in Section II (H) that The Corsair

Trail Council “shall conduct maintenance on the warming shelter by the terms of a Special Use

Permit.” It also states that the Trail council will “monitor public access of the Corsair warming

shelter.”

The Special Use Permit between the Corsair Trail Council and the Forest Service is a ten year

permit. It states one of the purposes of the permit is that the Holder is responsible for the

operation and maintenance of the Corsair warming shelter for general public use. The

responsibilities of the warming shelter, including when it is open to the public, is that of the

Corsair Trails Council. The permit does not require or denote frequency of usage of the facility.

_____________________________________________________________________________________

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27. Monument Trailhead proposed action is overkill for the amount of use it gets.

Response: The proposal to increase the size of the parking lot at Monument Trailhead is to

provide appropriate space for trailhead use and to create uniformly sized trailhead parking lots

across the District. Currently, Monument Trailhead provides space for 6 or 7 vehicles with

trailers. During snowy years when snowmobile use increases, the Monument Trailhead does

not provide adequate parking. As a result, snowmobilers park at other parking lots not intended

for snowmobile use (Corsair Ski Trailhead and Lumberman’s Monument) which is a safety issue.

In recent years northeast Michigan has been experiencing below average snow accumulations.

Hence, use at the Monument Trailhead has been low. The ID Team feels it is important to plan

for the long-term use of the area.

_____________________________________________________________________________________

28. Number of toilets at Corsair should be limited to one unisex toilet at each trailhead, not two

at each trailhead as currently proposed.

Response: The Corsair EA states in the Proposed Action and Modified Proposed Action that the

number of toilet buildings proposed for replacement at the Corsair Trailheads would be five.

The Corsair EA should read in the action alternatives that the number of toilet buildings

proposed for replacement at the trailheads would be UP TO five. This clarification will be made

in the Final EA.

_____________________________________________________________________________________

29. Shore to Shore Trail--be sure to include in abandonment proposal that trash be removed,

removal of two bridges over Gordon Creek, removal of trail assurance markers and

intersection markers.

Response: This comment refers to the implementation of how horse trail abandonment would

occur. Comment noted.

_____________________________________________________________________________________

30. Personal observation is that once an area is prescribed burned, recreation use of that area

diminishes.

Response: Personal observation. Comment noted.

_____________________________________________________________________________________

31. When discussing mechanical vs. burning to treat an area for fuels, why is cost/acre the only

consideration?

Response: All project proposals for fire and fuels included the alternative of prescribed fire or

mechanical treatments to reduce the dangerous accumulations of fuels within the project

17

boundary. Cost per acre, seasonality, reintroduction of fire into a fire-adapted ecosystem,

vegetative age diversity in all vegetation classes, specific wildlife species concerns, specific plant

and silvicultural concerns and archeological concerns were all considered when proposing

prescribed burning versus mechanical treatments within the Corsair EA.

_____________________________________________________________________________________

32. How do you weigh environmental effects of burning (smoke, toxic fumes, gasses, pollution,

CO2) against the small factors of mechanical treatment?

Response: The Forest Service considers the existing conditions, project objectives, and desired

future condition of the area. We evaluate the effectiveness, costs, safety, likelihood of

implementations (prescribed burns often have a narrow window of opportunity), landscape

restoration, potential for adverse effects for each treatment, and best approach to emulate

natural processes. Prescribed burning is less expensive per acre, accomplishes project objectives

and has the added benefit of replacing soil nutrients. Prescribed burning does add particulate

matter into the atmosphere (smoke, fumes, gasses) and has a narrow window for

implementation.

Mechanical treatments can be accomplished over a wider timeframe, are typically utilized to set

back succession, are safer, produce less particulate matter however, do not restore soil

nutrients, do not emulate natural processes and are typically much more expensive per acre to

implement.

The use of prescribed burning presents the need to weigh the trade-offs associated with the

ecological benefits of fire versus the impacts of a short term increase in emissions from current

and accelerated burning programs. Part of this trade-off involves the careful consideration of

and application of smoke management techniques to minimize the amount and/or impact of

emissions while still meeting ecological needs. An example of this trade-off to be considered is

the increased fuel consumption from a wild fire burning under severe meteorological conditions

vs. the reduced fuel consumption of a prescribed fire ignited that might burn under moderate

weather conditions.

Tools such as the Smoke Management Plan, Burn Plans, and computer modeling help the Forest

Service evaluate potential impact areas, establish mitigation strategies and techniques to reduce

impacts and develop contingency plans for adverse impacts of prescribed burning. One item

burn plans identify is acceptable ventilation indexes (see Table 11) in the effort to minimize

smoke impacts on surrounding areas.

_____________________________________________________________________________________

33. What is considered an effective burn-- when fuel consumption is the 1.5 inch material or

mechanical treatment that grinds and mulches all material?

18

Response: For the purpose of the proposed fire and fuels treatments “effective” is defined as

reaching goals and objectives identified within the Forests’ Plan to lower the Vegetation

Condition Class to 1 and to:

Implement fuels reduction and fuelbreak projects where conditions warrant for the protection

of life, property and safety. High risk areas adjacent to private land will receive treatment

priority (II-3).

Restore and maintain savannahs, prairies, dry grasslands, mesic grasslands, shrub/scrub and

oak-pine barrens in areas where they were known to previously occur, to provide for habitat

diversity and to meet species viability needs (II-4).

Maintain or improve the populations of endangered, threatened or sensitive species or

communities (II-4).

Utilize prescribed fire to meet management direction as appropriate for the ecosystem involved

(II-4).

Prescribed fire would be used alone or with silvicultural treatments to mimic the effects of

natural fire. Management-ignited fire and lightning caused fire will help maintain, enhance and

restore natural ecological processes on the Forests (I-9).

Integrate historical, environmental and cultural information into plans, assessments, analyses

and decision documents as appropriate (II-6).

_____________________________________________________________________________________

34. Mechanical treatment needs to be examined on its own basis and not as a quick solution for

multi-project analysis.

Response: Comment noted. Please refer to comment #32.

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References:

Baseline Assessment for Carbon Stocks including Harvested Wood Products- USDA Forest

Service, Eastern Region, Climate Change Advisors Office, Office of the Chief, October 30, 2013

http://www.fs.fed.us/climatechange/updates/September%202013%20Climate%20Update.pdf

Climate Change Considerations in Project-level Analyses, 2009;

http://www.fs.fed.us/emc/nepa/climate_change/includes/cc_nepa_guidance.pdf

Council on Environmental Quality; February 2010 Memo;

https://www.google.com/#q=Council+on+Environmental+Quality%3B+February+2010+Memo++

Code of Federal Regulations; (40 CFR 1500.1(b)); (40 CFR, 1502.9(b), (40 CFR 1500.4(f), (g), (40

CFR 1501.7),(40 CFR 1508.25) (40 CFR 1502.5) (40 CFR 1502.24) (40 CFR 1502.22), (40 CFR

1502.24); (40 CFR 1508.9); 36 CFR 220.7(b)(3)(i); http://www.ecfr.gov/cgi-bin/text-

idx?c=ecfr&tpl=%2Findex.tpl

Corsair Environmental Assessment (Draft) 2014

Daniel, Theodore W., John A. Helms, and Frederick S. Baker. 1979. Principals of Silviculture

McGraw-Hill Book Company, 500p.

Forest Service Handbook (2109.14, 52.11); http://www.fs.fed.us/im/directives/

Forest Service Manual 2150; Pesticide Use Management and Coordination (USDA Forest Service,

1994); http://www.fs.fed.us/im/directives/

Forest Service Handbook (2109.14) Pesticide Use Management and Coordination Handbook

(USDA Forest Service, 1994); http://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsh?2109.14!..

Forest Service Manual 2154.2

Huron Manistee National Forest FEIS;

http://www.fs.usda.gov/main/hmnf/landmanagement/planning

National Visitor Use Monitoring (2012); http://www.fs.fed.us/recreation/programs/nvum/

Decision Notice and FONSI; Huron-Manistee National Forests Non Native Invasive Plant Control

Project; (USDA Forest Service 2008)

Sander, Ivan L. and David L. Graney. 1992. Regenerating Oaks in the Central States. In

Symposium Proceedings: Oak Regeneration: Serious Problems, Practical Recommendations.

Edited by David L. Loftis and Charles E. McGee USDA Forest Service General Technical Report

SE-84

Sander, Ivan L. 1977. Managers Handbook for Oaks in the North Central States. USDA Forest

Service General Technical Report NC-37

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Smith, David M. 1986. The Practice of Silviculture 7th ed. John Wiley and Sons, 527p.

Teply, Mark E. and Stephen R. Hoffman, 1983. Management of the Scrub Oak Type in

Michigan's Lower Peninsula

Glyphosate: Human health and Ecological Risk Assessment Final Report. Syracuse

Environmental Research Associates, Inc; 2011

United States Forest Service, Eastern Region, 1911-2012 Dan Loeffler et. al. July 2013)