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Log Cabin Environmental Consulting, [email protected]
Website: logcabinec.com
Theresa J. Bla:z.icevich113 Log Cabin LaneStevensville, MT 59870(406)370-8902
April 6, 2009
Forest Supervisor's Office1801 North 1"' SI.Hamilton, MT 59840-3114
Subject: Lower West Fork Project Draft Environmental Impact Statement (DEIS)
Dear Forest Supervisor:
First. I would like to compliment the Forest Service for trying to improve forest health,fisheries and soil stability on 5,100 acres in the lower West Fork. The majority of thisproject appears to be well-planned for the benefit of the forest and wildlife and will havelittle impact on the public with the exception of the use of fire. I am concerned that theForest Service continues to use prescribed fire, underburns of slash and slash piteburns. I would like for you to adopt a "no prescribed burns or slash bums or openburning policy' in Ravalli County.
As a career environmental health specialist, I am concerned about air pollution from anysource. And, I am very concerned that government agencies continue to use openburning when Ravalli County has been knocking on the door of air quality nonattainment status for several years. I know exceeding the air quality standards forparticulates mainly occurs in the winter months, but recently the air monitoring resultsshowed unhealthy health effects for hourly air monitoring in March. As you know,March is the beginning of the open burning season in Ravalli County and many peopledo not follow the best available control technology for conducting open burning like theForest Service does.
More importantly, I believe that our government should set a good example for thepublic by implementing practices that aggressively protect our environment and publichealth. Since Ravalli County is near non-attainment status (has exceeded or is close toexceeding NAAQS for fine particulates for many of the last 5 years) and subject toinversions in a narrow mountain valley, why should a government agency, or anyone forthat matter, continue to voluntarily burn and cause air pollution.
As a landowner with training in natural resources and wildlife habitat, I believe you canaccomplish your fuel reduction goals without prescribed burning and slash burning. If itIs manpower you need to harvest and thm the forest, I would be more than willing tolobby for more forest service funds if volunla!)' burning were to cease. If you wanltotalk economic stimulus, I"m sure we could create more jobs by cutting the trees andchipping the slash rather than burning il.
I am also curious why the environmental impact analYSiS did not provide statistics onhow many wildfires were caused by slash piles or prescribed bums or open burning.Are you really reducing the wildfire potential by burning? Would thinning, harvesting,composting, chipping or other methods work just as well or beller than burning? Whereis the economic analysis that compares the cost of burning to the cost to our health?The heallh impacts should not just be an evaluation of hospital visits. It should includethe cost of missed sports workouts, young chitdren with asthma with increased costs ofmedicaltreatrnent, young athletes having heart attacks, children without resplrato!)'disease having bronchitis and having to use inhalers after poor air days, adults witheven mild respirato!)' disease that have to stay inside or miss work when someone isburning slash or conducting prescribed burns.
If wildfires are started by acts of God beyond our control, we can deal with these asappropriate, but volunteer burning we can control. Our government agencies can helpus start Ihe long education process that open burning is probably already impacting ourhealth and will continue to do so, if it continues In the Bitterroot. When we discussedthe air monitoring data and results that exceeded air quality standards for 2004 and2005, many Ravalli County residents pointed at the Forest Service as the pollutionsource. If the Forest Service was not conducting voluntary burns, this would eliminatethe need to defend your position on open burning.
Thank you for the opportunity to comment on the DEIS. Please consider eliminatingprescribed burns and the practice of slash burning. The DEIS does not even mentionthat Ravalli County is near non-attainment status for air quality. I believe the OEISneeds to more seriously address the alternatives to burning with our health in mind.
If you have any questions, please let me know.
~C9~id4C~Theresa J. Blazicevich
"[email protected]" <[email protected]>
05/14/2009 02:34 PM
cc
Subject Lower West Fork-Comments
COMMENTS on D.E.I.S. Lower West Fork and how it affects BITTERROOT ADVENTURES and other forest visitors. ALTERNATIVE 2: A. General Comments: Piquette Cr. Rd. 49 with some adjoining roads is the only place in the BNF that BITTERROOT ADVENTURES (BA) can take NOVICE ATV riders on a dedicated trail. The dedicated trail is wide enough for beginners and eliminates possibility of encounters with full size highway vehicles. This is, in fact, an important ingredient for any citizen novice rider, families, and the older population. This trail could be considered for over 50" width OHV's, since it is already wide enough for 2 highway vehicles to pass one another. Trail 49 is short (about 24 miles round trip). It is currently difficult for us (B A) to get a full day /6 hour ride using it (about 35-50 miles is needed for a full day). My hope is that there could be a loop created--enough to make the ride a little longer. The views of the mountains are excellent. My clients (almost) always comment on that aspect. PRECISE COMMENT: Alternative 2 does not appreciably degrade the quality of the ride or the length of it. ALTERNATIVE 3: A. General Comments: While #3 does not appreciably affect B A's currently permitted routes, it does permanently eliminate some possibilities of looping routes together in the future. Loops and destinations are very important for a quality forest experience. PRECISE COMMENT: Alternative #3 is the LEAST desirable change to Forest Travel Plan for all forest visitors. We would, of course, support closures of roads that contribute to stream degradation. But, I do not believe wild life is impacted by the roads or the travel on those roads. There is ample roadless area in the vicinity. REQUEST FOR CONSIDERATION: Near the upper end of Road 74606 is a posted (closed) trail that could be considered for a Loop. I have not personally walked this path, but have spoken with others who have. The feeling is that it could be joined with Trail #49 to created approximately a 5 mile loop. BRENT NELSON RCE, Inc. d/b/a BITTERROOT ADVENTURES
E-MAIL TO: [email protected]
Lower West Fork-Comments 20 May 2009
Forest Supervisor’s Office
Bitterroot National Forest
1801 North Street Hamilton,
Montana 59840-3114
Re: Comments on Proposed Lower West Fork Draft Environmental Impact Statement
I am submitting the following comments on the Lower West Fork (LWF) Draft EIS pursuant to an extension provided to me by Ms. Grove on May 13, 2009.1 I have considered the Forest Service’s four stated “purposes and objectives” for the LWF project including:
1. Reduce Crown Fire Potential - Reduce the area with high potential for stand-replacing crown fires in the suitable timber base and wildland urban interface. This will reduce the risk from fires harming human life (fire fighters and the public), private property, and natural resources in the Lower West Fork analysis area.
2. Improve Forest Resilience and Provide Forest Products - Provide economic opportunity to the community and provide funding opportunities for the activities related to reducing sediment contributions, and fuel reduction by capturing economic value of insect or disease killed and/or infested trees as well as green tree thinning in plantations and at risk areas to improve resiliency to insects and disease.
3. Increase Ponderosa Pine Forest Component and Maintain Larger Size Classes – Thin from below to reduce stand competition from shade-tolerant understory trees, improve growing space for the larger size classes and favor large, ponderosa pine as the dominant site component.
4. Watershed Improvement - Reduce sediment contribution in the West Fork of the Bitterroot River from identified high-priority road segments and crossings. Improve aquatic connectivity in tributaries of the West Fork of the Bitterroot River. Rehabilitate detrimental soil disturbance in historic timber harvest and terrace units.
See LWF DEIS Abstract. I have very serious concerns, however, that neither the preferred alternative nor either of the other alternatives fully analyzed in the DEIS will achieve these stated goals.
As discussed below, I have provided comments and a sivlicultural prescription which will achieve the desired results. Accordingly, I request that the FS analyze my silvicutural prescription as a separate, proposed alternative or, failing that, the FS incorporate my harvest prescription and as many of my comments as possible into the alternative that is ultimately selected by the FS.
I believe that my more than four decades of experience performing forest management in western Montana provide me with the practical experience necessary to provide these comments. Specifically, I am a practicing forester, having received my forestry degree from the University of Montana, School of Forestry in 1971. Since that time I have worked full time in forest management on both public and private lands in western Montana, including successfully completing many projects in similar areas. Additionally, I have been involved in literally hundreds of meetings with the FS in Montana in an effort to help craft better projects. Moreover, I have designed and carried out other jobs on private lands in western Montana that have actually achieved the FS stated goal for the LWF of creating open stands of large tree species with fuel loads that would be less likely to transition fire into the canopy and be carried by crowns. The following comments are based on my experience in conjunction with leading forest scientists of the day.
Comments:
As stated in the DEIS 1.3 “Purpose” to effectively obtain the desired conditions the USFS will need to prioritize all mitigation factors in a descending order of importance. Some mitigation factors, however, cannot be implemented and therefore will not achieve the Purpose as stated. In order to correct this serious deficiency in the DEIS, I suggest that the USFS apply the following silvicultural prescription:
Reduce the BAF to 40-80 (10 foot between crowns absolute minimum crown closure) in a varied mosaic including the removal of large and small tress favoring retention of the larger, healthy trees. All treatment methods that meet the Purpose and Need and that can be safely operated, as is normal industry practice, shall be allowed (see Mimicking Nature’s Fire by Arno and Fielder). Ground based systems should be preferred. Care shall be taken to remove as many of the limbs and needles as possible to reduce the fuel loading. Areas may be clumped, thereby creating openings that break the fuel continuity. Specifically, large PP that have overlapping canopies may be retained in groups with no skidding under those crowns. Openings shall be created next to such clumps to average the BAF for the area.
All trees with two or more bug hits shall be removed as biomass. All chimneys that adjoin the private must have at least two breaks in the fuel continuity. Snags shall be
retained at a density of 1.5-3 per acre average or less. Alternate thickets of small trees shall be retained and removed as necessary to meet the BAF specifications while also providing habitat for smaller wildlife. Particular care should be used to avoid the corn field effect.
Fire shall be reintroduced into the area responsibly, and care shall be taken to avoid returning fire to the area in the manner used in the Frazer Draw Project. Specifically, care shall be taken to avoid impact or damage to retained trees during the reintroduction of fire. Additionally, no large brush piles or concentrations shall remain on the treatment area at the conclusion of the treatment.
All ground based off-road operators shall complete a soil moisture test on a daily basis or anytime varying soil moisture conditions exist. This test shall consist of digging a hole that locates the most available soil moisture in the area of proposed operation. From the moistest soil a ball shall be formed in the hand and a ribbon of soil shall be squeezed from it. Anytime an unsupported ribbon consistently exceeds 1 1/2 inches in length, all ground-based operations shall be suspended in the area of the test. Any time these conditions exist the contractor shall notify the sale administrator that the contractor has suspended the ground-based operation.
THE VEGETATIVE PRESCRIPTION SHALL ALSO BE APPLIED IN THE RIPARIAN AREAS. The most important areas proposed in the treatment area contain water and have been invaded by conifers, which must be removed to restore the natural function of the stream and its vegetation. Aspen restoration must be a priority as well as beaver reintroduction neither of which are emphasized in the DEIS. The USFS shall follow the Montana BMPs to accomplish this.
Finally, it is absolutely necessary to prescribe a method for checking the silvicultural prescription during and after the project to determine whether the objective has been met. Specific methods must be written into the final EIS to insure that the silvicultural prescription is met.
Conclusion: The Draft LWF EIS Does Not Comply With The FS’s Duties Under the Environmental Law.
In light of the environmental impacts of the considerable magnitude at issue here, the draft EIS issued by the FS does not comply with the requirements of NEPA. That is, NEPA requires the agency, among other things, to “study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternate uses of available resources.” 42 U.S.C. § 4332(E). Here, however, the FS has only fully addressed two alternatives to taking no action and, of course, one of those is the alternative preferred by the agency. More importantly, there is not a meaningful difference between the two alternatives that were analyzed with respect to the key issues I have set forth above in my comments. In light
of my comments, it is impossible to conclude that there existed just two reasonable alternatives to taking no action in this case. By failing to fully assess a range of reasonable alternatives, the FS has avoided its obligations under NEPA to take a hard look at the environmental consequences of its actions -- this is not appropriate.
Moreover, as set forth in my comments above, I have provided an alternative which allow the FS to fully meet its stated objectives for the project, to fully comply with its obligations under the Healthy Forest Restoration Act, National Forest Management Act and the Forest Plan for the Bitterroot National Forest, including but not limited to the FS obligation to manage for multiple use and to provide habitat for the full range of management indicator species (MIS) and threatened and endangered species.
The silvicultural methods set forth in my comments are the result of decades of on the ground experience in the relevant environment of western Montana forests and were prepared in consultation with some of the most preeminent forest scientists of the day. To the extent the FS rejects the use of any of the methods proposed in my comments it must be on the basis of clearly reasoned, publicly available analysis, and not the product of arbitrary and capricious agency action.
In conclusion, I reiterate my request that the Forest Service analyze at least one additional alternative containing all of the comments I have set forth above. Failing that, I urge the Forest Service to incorporate as many of my comments as possible into the alternative that is ultimately selected so that the alternative complies with the FS obligations under the law and fully explain why any comment that was not included has been rejected by the FS.
Finally, I note that after attending hundreds of FS meetings and helping provide alternatives to the FS on past projects, I have found little of the public’s input in any completed project. I sincerely hope this project will be different. It often appears that the FS uses the public comment to get through the process and then discards this input to simply do as the specialists please. See “Regurgitations of a Montana Woodsman”. This was very apparent in the recent Frazer Draw Project, which was a failure regarding public comment and implementation.
Thank you again for the opportunity to provide comments on this important project. __________________________
Craig E. Thomas
Forester
Stevensville, Montana 59870
406-363-8742 [email protected]
Forest Resources May 22, 2009 Lower West Fork – Comments Forest Supervisor’s Office Bitterroot National Forest Hamilton, MT 59840-3114 RE: Lower West Fork Project To Whom It May Concern: On behalf of Smurfit-Stone Container Corporation, I wish to thank you for the opportunity to comment on the proposal to address the forest health issues on the Bitterroot NF within the Wildland Urban Interface along the Lower West Fork River drainage. Your proposal to address fuel loading, stand health and composition and the other issues within this landscape are worthy ones. It is good to see the Forest take a proactive stance in addressing these needs before catastrophic events such as fire and insect out breaks occur. With that in mind, I offer the following comments. Projects such as these are vital in numerous ways. First, it addresses the real threat of wildland fires. The Bitterroot well knows what the devastating effects of wild fires can cause on both resources and humans. Our forests have become increasingly overcrowded with ladder fuels that make fire suppression an increasingly difficult task. Second, it will improve forest health by removing suppressed and diseased trees. Even without considering wildfire risks, no one wants to see thousands and thousands of acres of beetle and diseased killed trees. The FS has as a mandate to manage these lands and the activities proposed does just that. Thirdly, and very important to me, is the economic benefits. Not only will this project employee people in removing the overcrowded trees, it also provides needed material for our paper mill. Smurfit-Stone can utilize these small trees as we can chip them up to use in our paper-making process. Additionally, there is the opportunity to grind the left over slash which can be burned in our boiler creating steam and electricity for our use. This helps in removing potential fuel from off the forests as well burning clean bio-fuel. In these tough economic times, it is important to provide material close to our mill which this project does. I also would state that, from an economic standpoint, the amount of skyline logging may make this project borderline to a purchaser. I understand these can of systems will need to be put in play do to the ground conditions. However, current market conditions make it difficult to add cost. I would recommend including more ground based areas to help offset the higher cost skyline units. Other benefits from this project include improving transportation systems by addressing BMP’s on existing roads and eliminating unnecessary roads. It will also improve wildlife habitat and water quality.
P.O. Box 929, Frenchtown, MT 59834 406-626-5293 Fax 406-626-5839
P.O. Box 929, Frenchtown, MT 59834 406-626-5293 Fax 406-626-5839
Again, I thank you for the chance to offer my comments to you on the Lower West Fork Project. I recommend that this project be moved forward. If I can be of any assistance in terms of what Smurfit-Stone can offer to you, than please contact me. My phone number is 406-626-5295 (office) or 406-531-1693 (cell). Sincerely, Jim Mountjoy Area Manager Smurfit-Stone Container P.O. Box 929 Frenchtown, MT 59834 [email protected] 406-626-5295
Friends of the Bitterroot PO Box 442 Hamilton, Montana 59840 WildWest Institute PO Box 7998 Missoula, MT 59807 Lower West Fork – Comments Forest Supervisor’s Office Bitterroot National Forest 1801 N. First Hamilton, MT 59840-3114 [email protected] May 25, 2009 Re: Comments on the Lower West Fork DEIS Dear West Fork Ranger Dave Campbell, The following comments on the Lower West Fork Draft Environmental Statement (LWF DEIS) are submitted by Friends of the Bitterroot and Wildwest Institute. As conservationists we advocate for nature and its many facets. One of its more awesome facets is the ability to heal itself. We note that nature, if allowed to work its wonders, could accomplish all of the listed purposes and needs of this project, and at no taxpayer expense. That would be a truly conservative alternative. Alternative 1 (no action), with the addition of restoration activities that would remove manmade impediments to natural recovery, could approximate this approach. The road restoration and culvert work described in Alternative 3 addresses that issue better than that in Alternative 2. Vegetation management in Alternative 3 is quite similar to Alternative 2. Knowing that you do not propose this project with the intent of no action, we will address our comments to Alternative 2, the proposed action, and, largely they will be relevant to Alternative 3. We fully support the proposed watershed restoration activities and believe much more is required in many areas to allow future logging to occur within legal limitations. We disagree with the rationale for the supposed need to remove fuel beyond the Home Ignition Zone (HIZ) or Community Protection Zone (CPZ) for the purpose of protecting human safety or private property. Cohen and Butler (2005) made recommendations regarding fuel treatment in an interface zone in the Boulder River canyon on the Gallatin NF. Based upon research, and investigation following instances of wildland fire, they specify the need to focus primarily on the HIZ, stating: “(W)e cannot mitigate a highly vulnerable HIZ with fuel reduction activities beyond the HIZ; a highly vulnerable HIZ remains highly vulnerable even when surrounded by a fuel
break. …The high intensity wildfire has no direct flame effect on the building ignition potential outside the HIZ.” Site-specific Forest Plan Amendments It appears that this project requires an amendment for each of four Forest Plan Standards. It has become routine to amend the Forest Plan for these standards on recent BNF timber sale proposals. Since revising the entire Forest Plan is long overdue and has proven to be problematic, perhaps NEPA analysis should be given to forest-wide amendments to the Forest Plan regarding these standards. That analysis would provide a larger scale, more comprehensive and updated assessment of the various situations not available with the piecemeal approach now being used. Important, difficult to repair or replace resources and values are at stake. The BNF Forest Plan Snags retention standard requires retention of all large snags, not just the gerrymandered formula proposed in its stead. Large snags are one of the most difficult vegetation components of the forest to replace. Only a lucky tree gets large and most large trees end their lives on the ground by way of wind, fire or chainsaw. We would like to see protection of all large standing snags. The amendment proposed for Winter Range Thermal Cover standard reads, “Existing thermal cover will be maintained within the Lower West Fork treatment units to the extent it does not conflict with meeting the project’s objectives.” Now, that is a manager’s dream “standard”. It is totally elastic, designed, a priori, to fit any desired timber removal. As such, it appears to be arbitrary regarding protecting elk. Given that you use new information and conditions to justify Forest Plan amendments, this standard should be evaluated in light of protecting elk security from wolves. Because of wolf predation elk security is increasingly dependent on thick timber next to their open grazing slopes. The amendment proposed for Elk Habitat Effectiveness (EHE) standard reads, “Existing elk habitat effectiveness will be maintained or improved within the Lower West Fork analysis area.” (DEIS, p.1-12) Given that the EHE standard regarding road density (security from human hunters) is not being met and can not be met in parts of the project area according to DEIS p.1-12, it would seem especially important to allow for more security from wolves, by leaving “thermal cover” where it exists, especially near meadows, within the project area. The FEIS must disclose the recently available spring 2009 elk count numbers, which show a significant decline from the 5,950 elk in 2008, which shows a significant decline from the 8,169 elk in 2005. As the LWF DEIS admits (p.3.8-21), “No management activity can replace hiding cover in the immediate future”. The amendment proposed for Course Woody Debris (CWD) is arbitrary insofar as the definition of CWD is arbitrary. Lumping all wood 3 inches and larger into one category, CWD, does not distinguish the huge differences in fire behavior, soil building, moisture retention and wildlife values between a 3 inch branch and a 30 inch log. Forest Service scientist James Brown confirmed this verbally in a video-taped public meeting in 2001. Generally this failure to make important size distinctions leads to accumulating damage from loss of the more ecologically important larger logs and boles.
Prescribed fire We do not see much discussion about the ecological impacts of prescribed fire other than the possibility of killing non-target trees. The FEIS should include analysis and disclosure of potential impacts of prescribed burning, especially in spring, to ground nesting birds or animals and impacts on plants, especially rare or sensitive plants. Spring burning goes against the rhythm of fire season and fire cycles that have shaped the forests and associated components over many thousands of years. It stands to reason that there are unforeseen and unintended consequences. Monitoring needs to be done. Given the relative speed and ease of treating large areas by prescribed fire, the potential threat of widespread ecosystem damage occurring before adequate understanding of negative consequences is a distinct possibility. Road building So-called temporary roads are only temporarily used but the damage to soils, weeds, watershed and wildlife can last a long time. They should not be considered simply erased off the land as easily as they can be erased off a map or a spreadsheet. Even after rehabilitation, the residual impacts of roads need to be recognized. Proposed ‘temporary’ roads need to be shown on a map in the FEIS. Soils It bears reminding because it is so often forgotten; soils are the foundation of all life on dry land. NFMA requires the Forest Service to “ensure that timber will be harvested from National Forest System lands only where—soil, slope, or other watershed conditions will not be irreversibly damaged.” [16 U.S.C. 1604 (g)(3)(E).] Clearly the term “irreversible damage” is intended to be judged on a human time scale, not the geological time scale wherein even total loss of soil, from glacial scouring for example, can be reversed. The 60 plus years of lasting detrimental soil damage, compaction from logging, on the Bitterroot National Forest (BNF) would seem to fit the term ‘irreversible’ on a human time scale. Rather than assure adherence to NFMA by directly measuring and regulating loss of productivity of soils, the USFS uses the surrogate measurement of Detrimental Soil Disturbance (DSD). The accuracy of the supposed linkage of this substitution has not been adequately evaluated or disclosed. Region 1 of the USFS developed a soil quality standard (SQS) whereby only soil damage over a certain intensity/degree threshold qualifies as Detrimental. Thus much measurable soil damage does not even show up on the radar. The R1 SQS reads:
“Design new activities that do not create detrimental soil conditions on more than 15 percent of an activity area. In areas where less than 15 percent detrimental soil conditions exist from prior activities, the cumulative
detrimental effect of the current activity following project implementation and restoration must not exceed 15 percent. In areas where more than 15 percent detrimental soil conditions exist from prior activities, the cumulative detrimental effects from project implementation and restoration should not exceed the conditions prior to the planned activity and should move toward a net improvement in soil quality.”
That standard is totally inadequate; it throws the gate wide open. No amount of existing, logging-legacy, soil damage would preclude reentry for more logging. And the mitigation offered by the supposedly limiting clause, “should move toward a net improvement in soil quality”, will be provided by nature as soon as the heavy machinery leaves. The mechanical de-compaction proposed for restoration is experimental, with little known efficiency coefficients and may not go as deep as some existing compaction, thereby potentially masking compaction in the root zone. The heavy de-compaction machinery itself causes compaction and other types of soil damage. To our knowledge, the R-1 SQS has never received public review and comment nor has it been peer reviewed. It seems to have been simply adopted by fiat. Please disclose substantiation by scientific reports. The effectiveness of R-1 SQS needs validation monitoring to see if it leads to protecting soil conditions that truly satisfy NFMA requirements. The 15% soil quality standard simply measures aerial extent and does not incorporate the degree of detrimental soil damage beyond the thresholds of the definition of ‘detrimental’. For example, in order to qualify as detrimental, compaction must exceed 15% increase of bulk density (a measure of degree, coincidentally the same percent as the SQS number, an aerial measure). The amount of increase in any degree beyond that is routinely not disclosed, nor is the depth of compaction disclosed. This information is necessary to determine the actual extent of damage and the degree of irreversibility. The information would also be necessary to design adequate mitigation and amelioration implementation. Discovery that an activity area has 15% or more detrimental soil damage should disqualify the area from further ground disturbing activities. The still experimental soil compaction amelioration techniques proposed are only partially effective and may in fact add to soil damage by way of mixing mineral soil into top soil, aerating soil organic matter (and thereby ‘burning’ it up more quickly), spreading weeds, fragmenting mychorizae or otherwise disrupting the soil community. It is admitted in the DEIS, p.3.5-16, that the proposed soil amelioration technique “does not immediately restore soils to pre-disturbance levels”. As discussed and disclosed in the DEIS, the anticipated increase in DSD due to proposed activities is significantly lower than the best available science indicates. There is available agency science quite specific to the conditions here in the Bitterroot. This underestimation in the LWF DEIS runs counter to the best available agency science of expectable DSD. It risks exceeding R1 SQS in certain units.
Ken McBride, former BNF soils scientist with long professional experience on the BNF states, “Over the past 14 years monitoring of summer, ground-based logging effects on soils conducted on the Bitterroot National Forest by the Forest Soil Scientist has shown that 75% of the units failed to meet R-1 SQS. Over this period of monitoring the average detrimental soil damage from ground-based summer logging was 30%.” (2005, MEF DEIS p.3.5-20) This contrasts significantly with the 10% DSD factor used (LWF DEIS, p.3.5-15) to project new DSD from ground based skidding. Similarly the LWF DEIS, (p.3.5-17) uses indefensibly low estimates, 8% increased DSD, due to skyline skidding. This does not agree with the best BNF specific, long-term DSD monitoring reported in 2005 (MEF DEIS) by McBride. The LWF DEIS (p.2-10) states, “Units 1, 3, and 12 have levels of detrimental disturbance from historic logging that are near or exceed the Region 1 Soil Quality standards.” Use of experimental soil de-compaction machinery is proposed to ameliorate soil damage in Unit 3 (with 34% DSD), parts of Unit 1 (19% DSD) and Unit 12. No depths of existing compaction are disclosed nor are areas and depths of proposed mechanical amelioration disclosed in the DEIS. No accounting of net soil conditions expected after the timber sale include any efficiency factors for the proposed de-compaction devices. If it is only 30% efficient then 3 times as much area would need to be treated to come out equal, and that discounts entirely the additional damage of various types caused by the de-compaction machinery. Where will deep compaction remain after the project? It is impossible for the public or the Decider to tell if R1 SQS will be met. The net effectiveness of mechanical de-compaction soil amelioration techniques needs to be analyzed and disclosed, as well as the degree of above mentioned ancillary impacts to the soil, (mixing mineral soil into top soil, aerating soil organic matter and thereby ‘burning’ it up more quickly, spreading weeds, fragmenting mychorizae or otherwise disrupting the soil community). These effectiveness factors would be necessary to determine the net benefit to the soil resource after project amelioration activities are implemented. McBride reports,”It is acknowledged that the effectiveness of soil restoration treatments may be low, often less than 50 percent.” (MEF DEIS p.3.5-20) He used a 30% effectiveness factor, using compaction as the only yardstick. It appears the LWF DEIS fails to disclose analysis of DSD caused by burning slash piles. The MEF DEIS (p.3.5-25) reports that about 2% DSD can be expected from this cause. This damage can not be ameliorated immediately and so would add to the DSD caused by the project and remaining after implementation. This factor must be included in LWF EIS soils analysis. Mitigation proposed to reduce DSD and prevent spread of noxious weeds states, “The entire duff profile should be moist to the touch in the pile locations.” (LWF DEIS, p.2-16) Unless this condition is met directly under the piles it may be meaningless because the piles intercept precipitation potentially leaving the ground under them drier than ground at that location not under the piles.
As requested in our scoping comments, total acreage of road surface, including temporary, in each activity area should be displayed alongside the detrimental soils condition information. Soil conditions, including roads and areas with detrimental soil damage, should be mapped and disclosed on a sub-watershed basis within the project area in order to assess cumulative impacts. This is important in the disclosure of cumulative watershed impacts because detrimental soil compaction would add to impacts from road compaction, ECAs and hydrophobic soils (DEIS, p.3.5-7) in increased and flashier water runoff, which causes higher high flows, lower low flows, and bank instability. (See esp. Lavene Creek section below) The DEIS discusses (p.3.5-9) Soil Erosion and Mass Movements, “In summary, if future fires are within the historic range of variability, long-term effects of erosion and mass movement are likely to be relatively small. Fire severity exceeding the historic range of variability could have detrimental effects on erosion and mass movement…” This discussion is used to rationalize logging in order to avoid “fire severity exceeding the historic range of variability”, and thereby save the soils. We appreciate not reading in this EIS about “catastrophic” forest fire, but high severity fire “exceeding historic range” seems to be overplayed for dramatic effect. In fact almost every debris flow on the BNF after the 2000 fires spread its fan of alluvium as a thin layer on top of an existing much deeper, bajada-like, fan at the break in slope below the blowout. These ancient debris flow relics tell us that the 2000 fires were not outside the range of historic variability. There have been many such events over thousands of years. These land forms silently disagree with your rationale for logging to save the soil from dreaded “highly severe” forest fire “outside the historic range of variability”. Even after the 2000 debris torrents tried to shout out about this recurrent, natural phenomenon, these debris fans are still magnets for new homes. Soils – Unit 1 Unit 1 has existing DSD on 19% of the unit. Even with the proposed mitigation of ground skidding only in winter conditions, an increase in soil compaction is inevitable. Ken McBride reports, “monitoring…over the past 14 years has shown that 58% of the ground-based winter logged units failed to meet R-1 SQS. Winter logging resulted in an average of 16% detrimentally damaged soil. This observation means winter logging mitigations have been unexpectedly ineffective. Newer, more stringent requirements may also be unexpectedly ineffective and should not be relied upon in areas already over SQS “limits”. (MEF DEIS, p.3.5-21) Additionally, “soils in unit 1 are not conducive to subsoiling treatments because the coarse fragment content is high.” (LWF DEIS, p.2-10). And so the proposed “amelioration” technique is, “Higher levels of woody debris will enhance the development of organic soil horizons, microbial populations, and other soil functions essential to restoring pre-disturbance conditions.” It is not clear in the DEIS if only the 55 acres of winter ground skidding or all of Unit 1 would receive the slash blanket treatment.
The DEIS does not appear to disclose the additional DSD attributable to the new “temporary” road planned for Unit 1 nor does it appear to disclose the additional 2% DSD expectable from burning slash piles (MEF DEIS, p. 3.5-25) Because of the many undisclosed factors (unspecified amelioration techniques, lack of amelioration effectiveness coefficients, unaccounted temporary road and slash burning DSD), it is impossible for the Decider or public to intelligently anticipate the soil conditions in Unit 1 upon implementation. Thus, Unit 1, with 19% existing DSD would receive additional (even more than the DEIS reports) DSD from proposed logging, new roads and slash pile burning followed by only the cursory rehabilitation of leaving slash, which admittedly “does not immediately restore soils to pre-disturbance levels”. This does not satisfy R1SQS requirement that “the cumulative detrimental effects from project implementation and restoration should not exceed the conditions prior to the planned activity”. If the BNF assertion that this proposed activity in unit 1 fits within the R1 SQS is allowed to stand, it clearly shows that the R1 SQS is arbitrary and capricious and is not sufficient to protect soils per the NFMA mandate. The legitimacy of the R1 SQS needs to be challenged in specific cases. Unit 1 is a good example. Watersheds As requested in our scoping comments please disclose on maps and discuss all site specific watershed work, road restoration and road use restrictions that were planned under previous NEPA decisions within the proposed project area. What activities or road use restrictions were implemented and what activities or road use restrictions were not? We have seen numerous NEPA projects where planned restoration work was never done. In cases where the planned restoration was required to bring the project area into compliance with Forest Plan standards, the result has been that projects outside legal limits defined by Forest Plan standards have been implemented in anticipation of restoration benefits that never arrived. The negative social effects of loss of public trust and increasingly on betrayed local job expectations are accumulating. The information requested would be an indicator measurement. It will give the public and decision maker tools to help measure the likelihood that various aspects of the project will actually get done within the “Temporal Scope” described as 10 years at DEIS p.1-13. FOB would like to see that “assumption” of 10 years for project implementation rationalized in the FEIS with the easily available administrative paper work research information we have requested. The LWF DEIS states on p. 2-7, “Almost 19 miles of road would be stored and another 10 miles would be decommissioned. Twenty-two culverts would be removed at road-stream crossings, 16 of which deliver sediment to streams and two that block fish
passage… “(emphasis added). Note the DEIS does not say could be. We assume that work would be done within the ‘temporal scope” of ten years if the project is implemented. The LWF FEIS should disclose which restoration activities are needed to bring the project into compliance with applicable standards and laws and which restoration activities are magnanimously meant to improve the situation over and above legally defined limits in the project area. The former should be mandatory; the latter might be optional. The routine failure by the BNF to deliver on what are publicly perceived to be NEPA Decision restoration commitments has become quite controversial. Some results of this apparent nonfeasance are: loss of public trust, accumulating watershed damage, depression of future logging opportunities (limited by excessive and un-restored damage, especially where TMDLs are in place), along with the obvious loss of restoration jobs. The DEIS discloses, “Soil disturbance is an unavoidable consequence of forest management activities.” (p.3.5-8) Other damage to watersheds and wildlife would also unavoidably result from commercial logging. Given that additional certain damage, FOB wants solid, dependable assurance in the FEIS and Record of Decision that the restoration work described in the LWF project will be done in a timely manner if the commercial logging is done. Stewardship contracts may offer one possible avenue. However it gets done, allocation of money and political attention are routinely strongly influenced by the Forest Service’s chosen priorities. Table 3.6-2 on DEIS p.3.6-8 should include a column disclosing the expected increase in sediment delivery to each stream from log hauling. Watershed function is affected by water quality and water yield. The West Fork is listed as impaired (MT 303d) water quality primarily due to sediment. Temperature is also an important quality of water; colder is better for the resident fish. Roads are the primary source of sediment in streams, both from runoff as well as dust. Loss of riparian vegetation and over-widening channels causes warming streams. Equivalent clearcut area (ECA) is a metric used to determine the probability of a harvest-related water yield increase. (LWF DEIS, p. 3.6-5) Sediment and water yield are interrelated in their effects and can behave in a synergistic fashion on the stability of stream channels/stream banks. The effect of increased water yield due to harvest can be multiplied by the increase in sediment due to log haul. Critical information necessary to estimate impacts of project activities on water yield, sediment delivery and their cumulative effect on channel stability is missing from the LWF DEIS. Water yield and sediment delivery are both affected by soil conditions in addition (or multiplication?) to the ECA measurement. Sub-basin Detrimental Soil Damage maps, and analysis need to be made available to know where potential for cumulative problems with areas of high ECAs, burned/hydrophobic soils, high road densities (open and closed) and otherwise compacted soils.
These are all significant factors contributing to the behavior of water runoff. The effects can be flashier yield – higher high flows and lower availability of late season water flows. Watershed - Lavene Creek Lavene Creek has an ECA listed as 27%. (LWF DEIS, p.3.6-11). Proposed logging would increase ECA to 28% (DEIS, p.3.6-27). This exceeds the 20 – 25% ECA threshold of channel stability. Unit 3 appears to be within the Lavene Creek watershed. It has 55 acres of DSD compaction, 34% of the unit, and is slated for 98 acres of summer ground skidding and 65 acres of skyline. According to the best available DSD history on the BNF (see McBride ref above) about 30% DSD on the 98 acres of summer ground skidding can be expected. That would add about 30 acres to the existing 55 acres, bringing the total DSD to about 49%. With the additional 8% DSD expectable from skyline logging (LWF DEIS, p.3.5-17) of 65 acres, over 50% of the unit would suffer DSD. This excessive soil compaction will add to the increased volume and flashier runoff attributable to the, already over threshold, 27% ECA. Log hauling over the 6 stream crossings will contribute an undisclosed amount of additional sediment over and above the usual 10.2 tons per year sediment entering Lavene Creek from those 6 stream crossings. The haul road, NFR 5630, follows within 300 feet of fish bearing Lavene Creek for 0.4 miles (DEIS, p. 3.7-14) Road 5630 will have 404 log truck trips (one-way or round?) (DEIS, p.3.7-15) How much additional sediment from dust and runoff at crossings is expected from hauling unit 4? The potential for adding sediment to the impaired, 303d listed West Fork is minimized on DEIS p.3.6-13, where it says, “but water does not flow into the West Fork at all flow levels” (emphasis added). Of course it is the higher flow levels that are the issue, when it presumably does reach the West Fork. Channel instability in Lavene Creek as well as sediment fro dust and runoff could carry sediment into the West Fork at high water events in Lavene Creek. Additional sediment would violate the TMDL prescription for the West Fork and thereby violate the Clean Water Act. Some critical factors are missing in this thinly sliced risky calculus. Fisher FOB is currently a co-petitioner to the USFWS for listing of the Northern Rockies fisher as a threatened species. The Northern Rockies fisher has been shown to be a genetically distinct population that is not well connected to other fisher populations, and is therefore more precarious than even their low numbers suggest. They require large snags and dense forest. The Bitterroot NF along with the Idaho forests to the west is the stronghold of these rare animals. Alternative 2 treats about 3,200 acres of potential and suitable marten and fisher habitat, about 18% of suitable habitat in the project area. (DEIS, p2-25). This seems like a lot to take away from the fisher, when they are having such a hard time. Additionally, after thinning the accessibility to snowmobiles will increase, further diminishing fisher habitat effectiveness. This impact needs to be disclosed in the FEIS and mitigation via area closures analyzed. Recreation
LWF DEIS p.3.12-2 under Travel Management Direction, claims, “The Bitterroot National Forest Visitor Map (2005) displays motorized travel management restrictions established under current federal laws and regulations on National Forests.” In fact this is not entirely true. The 2005 map made changes to road designations without proper environmental analysis, and therefore illustrates many roads as open to vehicles up to 50” in width where those vehicles were in fact prohibited by previous NEPA decisions. The 2005 BNF Visitor and Travel Map appears to incorporate a spreadsheet released by the BNF titled, “Roads Open to OHV’s and Closed Yearlong to Full size Vehicles.” This spreadsheet lists roads with map codes R-4, R-6, R-7, and 90. According to the BNF Visitor and Travel Map, these codes mean:
• R4 – “Reduce soil erosion or protect wildlife, and provide wildlife security during hunting season.”
• R6 – “Reduce soil erosion” • R7 – “Protect wildlife and provide wildlife security during hunting season.” • Code “90” roads are not defined and are part of the forest’s internal coding.
It is apparent that the BNF did not comply with NEPA requirements when it updated its Visitor and Travel Map in 2005, as it changed the protections established in prior decision documents that ensured compliance with NEPA, NFMA, and other environmental mandates. Many miles of roads in the project area that were closed yearlong, in prevailing original NEPA documents, to motorized use for the purpose of protecting wildlife and wildlife security or for preventing erosion, have been opened seasonally to ATV, motorbike and/or snowmobile use by the Travel Map, see especially Road Restrictions # 4 and #6 in this project area. These changes were done by fiat with no NEPA analysis or public process and no science to show any differences in impacts between full-sized vehicles and smaller motorized vehicles. regarding the resources in question. Where is the science? This is not a question of dueling science; we do not know of any supporting science. Rather, there is a growing body of scientific literature that demonstrates ORV impacts to a variety of forest resources, very similar to that of full sized vehicles. In your discussion of Travel Management Direction you should identify the authority and make available in the LWF FEIS documentation of the decision to open code “90”, R-4, R-6 or R-7 roads to ORVs. Roads coded “90”, R-4, R-6 or R-7 were designated and maintained at maintenance level 1 (ML 1). In regards to this maintenance level, the Forest Service Transportation System Maintenance Handbook 7709.58 Chapter 12.3(2)(a) states:
“Level 1. Assigned to intermittent service roads during the time they are closed to vehicular traffic. The closure period must exceed 1 year. Basic custodial maintenance is performed to keep damage to adjacent resources to an acceptable level and to perpetuate the road to facilitate future management activities. Emphasis is normally given to maintaining drainage facilities and runoff patterns. Planned road deterioration may occur at this level. Appropriate traffic management strategies are ‘prohibit’ and ‘eliminate.’ Roads receiving level 1 maintenance may be of any type, class, or construction standard, and may be managed at any other maintenance level
during the time they are open for traffic. However, while being maintained at level 1, they are closed to vehicular traffic, but may be open and suitable for nonmotorized uses.”
The BNF appears to have opened up a large amount of ML 1 roads to ORV use without NEPA and without changing the maintenance level designations. In doing so, the BNF created an existing system that is in violation of NEPA and Forest Service Directives. In order to have an existing system in line with current the Forest Service handbook, the BNF should list all ML 1 roads as closed to vehicular traffic. This situation must be disclosed and discussed within the LWF FEIS. How many miles of R-4, R-6, R-7, code 90 roads fall within the LWF project area? What were the purposes of original NEPA closures? What are the names of the original NEPA documents that authorized the original yearlong closures? All modeling of watershed, wildlife and soils impacts applied to the LWF EIS should reflect the reality that the R-4, R-6, R-7, code 90 roads are not closed yearlong. Specifically we ask that you disclose if these roads have factored into the LWF EIS resource impact analyses just as they would if they were open seasonally to full size vehicles. If not, why not. In order to account for cumulative impacts to the resources involved this situation must be disclosed and discussed in the FEIS. For example, Piquett Creek does not meet EHE standards (DEIS p3.8-16) and purportedly can not, without closing access roads to trailheads. There is a very high road density of R-4 and R-6 roads in this area. How does the opening of these roads impact the watershed problems that caused their former closure after NEPA analysis and authorization? How does their opening affect wildlife security regarding hunting, calving and winter forage? Reference to specific original NEPA documents needs to be part of disclosure. The original purpose of such closures needs to be disclosed and discussed, if it is within the project area. Allowing ORVs to go around locked gates directly causes damage by forcing vehicles off the road prism. It also trains-in and sends a clear message that reinforces the already prevalent notion that it’s OK to drive off road and around locked gates. The FEIS must disclose any impacts to fisher from increased snowmobile use due to improved accessibility after thinning. Mitigation by area closures should be part of the project. Roadless/Unroaded Any categorical distinction between roadless land and unroaded land is divorced from the land itself. It is simply administrative, certainly not ecosystem oriented. Our concern is for the biological value of the land and water.
Another false distinction arises where DEIS P.3.12-9 states, “…there are areas totaling approximately 9,995 acres, which some members of the public have considered “unroaded” within the analysis area.” In our view these 9,995 acres either are or are not unroaded. Please identify those acres that actually are unroaded on the ground and use that for your analysis. It appears dismissive to say “considered” and to put “unroaded” in quotes in the DEIS. With your language and approach, you cloud important ecological considerations about the land by sowing doubt with allusions to the credibility of the messenger. Whatever acres of land are unroaded (no quotes) on the ground have the same potential values as any other roadless land. Sixteen years ago the Buck-Little Boulder EIS on the West Fork RD analyzed impacts to actual unroaded land (no quotes in original) and not just land “considered” unroaded by some third party. It appears that laudable Forest Service approach has changed. Some activities within IRAs and “Friends of the Bitterroot Unroaded” areas are shown on a map at DEIS p.3.12-5 and a Table 3.12-3 at DEIS p.3.12-13. Where is the 1.4 miles of “temporary” road that would be built in unroaded land, according to Table 3.12-3? It does not seem to be on the map. This information should be disclosed on a map in the FEIS. FOB strongly opposes road building in both unroaded and roadless areas No analysis or disclosure of impacts to the special regionally important biological corridor values of the Allan Mountain IRA are found on p.3.12-8. This area has been identified by FOB and American Wildlands as an important biological corridor. See the “West Fork Bitterroot” zone of “The Hub” map from American Wildlands’ Priority Linkage Assessment for the Hub Conservation Area, available at www.wildlands.org Allan Mountain IRA is part of a critical hub of linkages connecting the Salmon Selway ecosystem with the Sapphire Crest route to the Northern Continental Divide ecosystem as well as the route south along the Divide to the Yellowstone ecosystem. Failure to disclose impacts on biological corridor values in the DEIS is a serious flaw. We believe that road prisms make the most identifiable and manageable boundaries for roadless and unroaded areas. Areas without roads are then truly identified as roadless areas. That sensible approach stays true to the English language as well as the ecological values of areas without roads. According to p.3.12-9, stumps within areas without roads reduce the Apparent Naturalness of an area, thereby diminishing Wilderness Characteristics. This policy is misdirected, but given its use, we therefore oppose thinning in areas without roads identified on the FOB roadless/unroaded map. Submitted for Friends of the Bitterroot by, Jim Miller, president Submitted for WildWest Institute by,
Matthew Koehler, Executive Director
