Summit Gulch Vegetation Management Project Idaho Sporting Congress # A215

Transcription

1 Summit Gulch Vegetation Management Project Idaho Sporting Congress # A215 APPEAL ISSUE 1: The Environmental Assessment (EA) fails to meet requirements of the National Environmental Policy Act (NEPA), National Forest Management Act (NFMA) and the Administrative Procedures Act (APA) because no Environmental Impact Statement (EIS) was done, and should have been done for this project due to its size and the certainty of adverse impacts. RESPONSE: The Decision Notice and Finding of No Significant Impact (DN/FONSI) discloses impacts for the 10 significance factors required by Council on Environmental Quality (CEQ) Regulations (DN/FONSI, pp ). The responsible official concluded, the Selected Alternative will not have a significant effect on the human environment. For this reason, no Environmental Impact Statement (EIS) will be prepared. Detailed rationale to support the FONSI is contained in the project record. The record contains a clear explanation of how the project was designed to improve soil productivity and water quality, reduce sediment delivery, improve water quality, and improve aquatic habitat (DN/FONSI, pp ; EA, pp to 3-61; 3-72 to 3-84). The project was designed to provide long-term benefits to several key wildlife species in the project area including the Northern Idaho Ground Squirrel (NIDGS), Flammulated Owls, Northern Goshawk, Great Gray Owls and the Pileated Woodpecker (DN/FONSI, p. 4; Addendum to Biological Assessment/Biological Evaluation (BA/BE), p. 4). A primary purpose for the proposed project is to enhance suitable habitat for NIDGS commensurate with the habitat Recovery Plan prepared for NIDGS (United States Department of Interior, FWS, 2003). An Addendum to the 2006 BA has been prepared and a determination made that the activities associated with this project may affect, but are not likely to adversely affect the species (BA, p. 4). The Addendum also determined that the action will have no effects on the Canada lynx and Yellow Billed Cuckoo (BA, p. 4). The BE determined no effect or may impact individuals or habitat, but would not likely contribute to a trend towards federal listing for the 15 species listed on the Region 4 Sensitive Species (BE Addendum, p. 4). The BE for Fisheries disclosed there are no species or critical habitat present in the project area or downstream. A no effect determination was documented on November 14, 2005 (BE, pp. 1-3). In 2005 a BE for sensitive plant species was also prepared. The project area contains habitat for two sensitive plant species that could be impacted by the proposed project activities. There are 12 known sites of seven devils onion within the project area. No known sites of bank monkeyflower were found, but potential habitat for this species exists. Project design features have been incorporated in order to avoid or minimize any impact to sensitive plants or habitat. Post-project monitoring is planned to observe any effects and recovery from project impacts. The determination is that the proposed project activities could impact individual plants and habitat, but would not likely result in a trend toward Federal listing or loss of viability (BE, p. 2).

2 The cumulative effects of the alternatives and the past, present, and reasonable foreseeable future actions are disclosed in Chapter 3 of the EA. The EA properly discloses there will be no significant cumulative impacts by implementing the Summit Gulch Vegetation Management Project, including foreseeable future actions (EA, Chapter 3; Appendix H). The project is consistent with all applicable Federal, State, and local laws (EA, 3-86 to 3-90). The EA discloses how the project meets the requirements of the Idaho Nonpoint Source Management Plan and the Clean Water Act (CWA) (EA, Appendix D). It also meets Forest Plan direction and applicable standards and guidelines (Forest Plan Activity Checklist) and complies with the Payette Travel Management Plan. In conclusion, the EA discloses that there will be short-term negative impacts, but predicts these effects will not be significant. As a result, an EIS is not required. APPEAL ISSUE 2: The appellant alleges the EA violates NEPA, APA and NFMA because it does not analyze economic information clearly. RESPONSE: FSH gives the Responsible Official the responsibility to determine which issues to be analyzed in depth by the interdisciplinary team in the environmental analysis. The Responsible Official considered the issues of economics and social/economics to be non-key issues and addressed it in the Issues Not Analyzed in Detail of the EA (EA, p. 1-11). The Economic Analysis included $4000 for the road decommissioning mitigation (Economic Analysis, p. 5). Costs for noxious weed treatments are included in the K-V Plan (Botany BE, p. 7). If funds are insufficient, the District would treat weeds with appropriated funds (Response to Comments, p. 7). All other project design and mitigation measures are Best Management Practices required in the provisions of the timber sale contract and project work plans, at no additional cost to the Forest (DN, Tables 1& 2). The Forest adequately disclosed the economic effects of the project decision in terms of jobs, revenue, receipts and project costs (Economic Analysis, pp. 2-5). APPEAL ISSUE 3: The appellant alleges the EA violates NEPA, NFMA, the APA and the CWA. Specifically, a. It fails to disclose Equivalent Clearcut Acres (ECA) figures for the project area, and the Wildhorse River drainage...there is no disclosure, discussion, analysis of ECA literature and science. b. The watershed analysis area is too small, encompassing only the lower Bear River Drainage... You should analyze not only the subwatershed and effects, but also the entire Wildhorse Watershed. c. Increasing temperature and sediment impacts bull trout and violates the ESA. The EA fails to disclose this eventuality.

3 RESPONSE: NEPA requires a disclosure of effects for key issues. Appendix B of the Payette National Forest Plan provides guidance for ECA analysis of project proposals by using a Matrix methodology. The Water Resources Specialist Report addresses ECA, and includes references in support of the analysis (Water Resources Specialist Report, pp. 9-12l; Table B-1). The analysis includes the identification and rationale for scale of the analysis area (Lower Bear Creek subwatershed). The EA found that changes in ECA were not considered a significant issue given the relatively small changes predicted with either action alternative, the lack of reasonably foreseeable actions that would contribute to ECA, and because the resultant cumulative ECA at the sub-watershed and watershed scales would be at levels that are unlikely to result in observable changes in water yields or observable changes in timing/magnitude of peak flows (EA, p. 1-10). The CEQ guidance document, Considering Cumulative Effects Under NEPA (1997) states that in identifying geographic boundaries choosing the appropriate scale to use is critical and will depend upon the issue or system. The EA describes the rationale for the scale of the analysis (EA, pp to 3-52). In addition, the EA states, Analysis of effects at a scale beyond the Summit-Calf Pen Gulch drainage or Lower Bear Creek sub-watershed was not considered, as any effects beyond this scale would likely be immeasurable and indistinguishable from existing background levels (EA, p. 3-51). Additionally, the specific soil and water project design features associated with this proposal are designed to minimize effects beyond the project, drainage, or sub-watershed scale. Bull trout are not known to exist in Lower Bear Creek downstream from Bear Creek Falls (Fisheries Specialist Report, p. 5). The Fisheries Short Form BE Determination of Effects Worksheet found no effect to bull trout (BE, p. 1). The BE, EA and DN/FONSI all address potential risks of increased temperatures and sedimentation. The EA states, Due to the implementation of RCA buffers on all stream channels, the limited amount of fish habitat available, the project design features and mitigation measures, it was determined the proposed action will maintain or improve existing fish habitat. The analysis and supporting documents contained in the DN/FONSI, EA, BE, and Specialist Reports, show an appropriate level of analysis for watershed effects was completed. ECA figures and calculations were disclosed. The EA provides adequate rationale for the scale and the geographic area used for the cumulative effects analysis. Documentation in the project files shows that the forest analyzed potential effects to bull trout in compliance with the Endangered Species Act (ESA). APPEAL ISSUE 4: The EA violates NEPA, NFMA, and the APA by failing to disclose and analyze grazing increases, projected grazing and attendant cattle damage to slopes and streams and riparian areas due to opening of the canopy.... Increased forage predicted for the project, and the projected increase in grazing should have been analyzed. Cumulative grazing effects of this project together with others scheduled for the watershed and area were not analyzed and disclosed. Degree of compliance of grazing allotments with requirements of allotment management plans was not analyzed and disclosed.

4 RESPONSE: The EA discloses that the rangeland resource is an issue not further analyzed since grazing management will not change as a result of this decision (EA, p. 1-12). The Range Specialist Report, documents that transitory ranges will provide more forage than before the timber harvest, however livestock grazing capacities are not based on transitory range (Range Specialist Report, 2006, pp. 6-7). Increased forage amounts, even temporary, will not lead to increased livestock grazing numbers. Some of the proposed harvest units will be temporarily excluded from grazing for at least two years following this project to reduce potential impacts to Northern Idaho ground squirrels (DN, p. 16). The EA discloses in the cumulative effects of continued livestock grazing on various resources (EA, Chapter 3). The potential impacts of decreases in the distribution and abundance of fine fuels is discussed (EA, p. 3-24). Cumulative effects to wildlife including effects to northern Idaho ground squirrel, rocky mountain elk, white-headed woodpecker, pileated woodpecker, northern goshawk, Flammulated owls, bald eagles, gray wolves, migratory birds and wild turkeys are disclosed (EA, pp through 3-49). Potential effects to water resources are disclosed and impacts to the soil resource are disclosed with assessment of continued livestock grazing (EA, pp and 3-63; 3-81 and 3-83). Appendix H has a list of actions considered for cumulative effects. Livestock grazing was considered as a past, present, and future activity in the area. Identification of cumulative effects was completed, and the EA adequately addresses cumulative effects of ongoing livestock grazing activities. Grazing management will continue as currently permitted under the existing allotment management plan (AMP) and annual operating plan (EA, p. 1-12). Management of the allotment was not considered as part of the scope of this project, and other than excluding livestock grazing for at least two years on four units to reduce potential impacts to NIGS, does not change with this decision. APPEAL ISSUE 5: The EA violates NEPA, NFMA and the APA by failing to disclose the project s effects to bird species (flammulated owl, goshawk, pileated woodpecker, great gray owl and white-headed woodpecker) and their habitat. RESPONSE: The EA and Wildlife Specialist Report discuss effects by alternative for each of these species (white-headed woodpecker, flammulated owl, goshawk, pileated woodpecker, and great gray owl) as does the Wildlife Specialist Report (EA, pp 3-29 to 3-30, and 3-43 to 3-47; Wildlife Specialist Report, pp ). The project will have no effects on the great gray owl because there is a low probability of occurrence and limited isolated habitat (EA, p. 3-29). In the Need for the Proposal discussion in the EA, it states; The white-headed woodpecker and flammulated owl are Forest sensitive species (EA, pp. 1-5). The white-headed woodpecker is a sensitive species and also a Forest Management Indicator Species (MIS). This management area has particular Forest Plan objectives and guidelines (0242, 0243 and 0244) to improve whiteheaded woodpecker and flammulated owl habitat. Both of these species populations have declined throughout their range in the Interior Columbia Basin due to loss of habitat. This project would improve long-term habitat quality for both species, by thinning dense stands to promote development of future large tree forest structure.

5 The EA discusses positive and negative effects on white-headed woodpecker and flammulated owl habitats under all three alternatives (EA, pp to 3-44, and 3-46 to 3-47). Alternative 2 reduces currently suitable flammulated owl habitat by 376 acres, and treats stands to promote the development of large trees, which would benefit both flammulated owl and white-headed woodpecker in the long-term. The selected alternative may impact individuals or habitat, but would not likely contribute to a trend towards federal listing for both species. The DN/FONSI also states that improvement cutting/commercial thinning on 570 acres will promote development of large tree structure (stands dominated by trees 20 inches and larger in diameter), and white-headed woodpecker and flammulated owl habitat will be improved (DN/FONSI, p. 2). Effects to pileated woodpeckers and northern goshawk are addressed in the EA (EA, pp to 3-46). Neither action alternative modifies currently suitable habitat to an unsuitable condition. Both action alternatives treat stands to promote the development of large trees, which would benefit both species in the long-term. Both action alternatives also propose decommissioning and placing roads in long term closure condition, which would reduce public fuelwood harvest and increase snag and coarse woody debris levels, which would improve foraging and nesting conditions for pileated woodpeckers. The selected alternative may impact individuals or habitat, but would not likely contribute to a trend towards federal listing. The EA and supporting documents appropriately disclose the effects of the proposed action on flammulated owl, goshawk, pileated woodpecker, great gray owl and white-headed woodpecker. APPEAL ISSUE 6: The EA violates NEPA, NFMA and the APA by failing to support the contention that opening up the forest by logging will reduce fire. No disclosure of the information of Huff, et al. and the effects of clear cutting, and other studies regarding thinning and fire was done in the EA. RESPONSE: The Purpose and Need for the project included fuels objectives to reduce understory (seedlings/saplings) densities, and fuel laddering to lower the risk of uncharacteristic or undesirable wildland fires (EA, p. 1-7). The EA describes the fuel models applied to the treatment proposals and the results (EA, p. 3-20). The Fuels Specialist Report further compares the potential effects of the alternatives and uses two predictive models for the conclusions (Fuels Specialist Report, pp ; Fuels Management Technical Report Lewis, 2005). BEHAVE, a fire behavior prediction and fuel modeling system (Andrews 1986), which links models of surface and crown fire behavior, was used to assess potential flame lengths, rates of spread, and potential crown fires at a stand level. Crown Mass (Fire Program Solutions/Acacia Services, ) was used to determine canopy bulk density, canopy fuel loading, and canopy base height from the fuel plot data. Crown Mass was also used to make additional predictions about tree mortality. These models provide an exceptional means to compare alternatives and are the best science available for this analysis (Lewis, 2005). The Vegetation Technical Report discusses treatment goals and was followed through in the EA through comparison of alternatives and cumulative effects (Vegetation Technical Report, p. 7; EA, pp. 3-9 to 3-13).

6 Public involvement is documented in the project record and none of the comments received requested (Huff et. al.) analysis be incorporated. The forest incorporated science from specialist reports by reference, and the fuels and vegetation specialists comparison of alternatives were adequately summarized in the EA. The DN acknowledged the degree to which the preferred alternative accomplished the Purpose and Need for the project when compared to the other analyzed alternatives (DN, p. 4). APPEAL ISSUE 7: The EA violated NEPA, NFMA and the APA by failing to disclose who will identify where nesting areas and roost trees are located so that they aren t destroyed by logging and burning. RESPONSE: Based on the wildlife analysis, a Project Mitigation and Design Feature describes how northern goshawks and occupied goshawk nest habitat will be protected the (DN/FONSI, p. 15). If a new active goshawk nest is found during harvest, harvest would be halted until after the nesting season and the unit boundary modified such that the nest is contained within a 30-acre block of suitable nesting habitat. The timber sale contract, timber sale administrator, and wildlife biologist would be responsible for enforcement (DN/FONSI, p. 15). APPEAL ISSUE 8: The EA does not include justification for your conclusions. Justification for your project can t be buried in your files, but must occur within the four corners of the EA. Therefore, considering the above claims, the EA violates NEPA, NFMA and the APA. RESPONSE: Chapter 3 of the EA discloses the effects of each alternative and did not identify any significant effects. Documentation supporting the determinations of effects is referenced throughout the EA. The EA complies with NEPA; it addresses and analyzes proposed effects of the project and reaches conclusions that are well supported by the record. APPEAL ISSUE 9: The EA violates NEPA, NFMA and the APA by failing to analyze and discuss and disclose why the new soil standards have been changed from the previous Forest Plan. There are no disclosures of detrimental disturbance (DD) and total soil resource commitment (TSRC) percentages. RESPONSE: Changes to the Forest Plan standards for soils are contained in the record for the Forest Plan revision. The current Forest Plan went though the NEPA process and the appellant had an opportunity to appeal the Forest Plan decision at that time. It is appropriate that the current Forest Plan Standards be used in project level planning. In an effort to prevent degradation or exceeding a threshold of unacceptable effects, the Forest Plan sets standards for protection of the soils to allow maintenance and restoration of soil conditions through time. The Forest Plan requires all management activities that may affect soil productivity to meet standards for DD and TSRC (Forest Plan p. III-21). The EA identifies the current amounts of TSRC and DD (acres and percentage of project area) due to past activities (EA, pp to 3-71; Soil Scientist Report, p. 6). Levels of DD are above the Forest Plan standards within the project area, so further soil impacts need to be carefully controlled and rehabilitated (EA, p. 3-70; Soil Scientist Report, pp ). Estimated TSRC for the Proposed Action are quantified, analyzed, and displayed in the EA (EA, pp to 3-74). Overall, the Proposed Action reduces TSRC by an estimated 11 acres or 0.3% of the project area

7 (EA, p. 3-74; Soil Scientist Report, pp ). The proposed action identifies a number of BMP/SWCP and site specific project design requirements to limit the probable extent of DD within treatment areas. Requirements to re-use existing trails and rehabilitate all disturbed trails and landings would facilitate recovery of existing areas of DD and lead to a reduction in levels of DD across treatment activity areas (EA, pp ; Soil Scientist Report, pp ). Appendix A (Total Soil Resource Commitment (TSRC) Assumptions and Worksheets) of the Soil Scientist Report contains all TSRC data presented above (Soil Scientist Report, pp ). Appendix B (Soil Disturbance Assessment Information) of the Soil Scientist Report identifies soil disturbance assessment procedures and soil disturbance class indicators (Soil Scientist Report, pp ). The EA and Soil Scientist Report identify the Forest Plan Standards for TSRC and DD. The EA and Soil Scientist Report analyze and disclose the TSRC and DD effects under the Proposed Action and identify that Forest Plan Standards will be met. APPEAL ISSUE 10: The EA violates NEPA, NFMA, the APA and the CWA by failing to disclose cumulative effects to water quality from this project and others in the Wildhorse and Weiser River watersheds. It also fails to disclose how cumulative effects in both watersheds will affect compliance with TMDL. RESPONSE: The EA discusses the rationale for the scale of the analysis and states: Analysis of effects at a scale beyond the Summit-Calf Pen Gulch drainage or Lower Bear Creek subwatershed was not considered, as any effects beyond this scale would likely be immeasurable and indistinguishable from existing background levels (EA, pp to 3-52). Additionally, the specific soil and water project design features associated with this proposal are designed to minimize effects beyond the project, drainage, or sub-watershed scale (EA, p. 3-51). Cumulative effects from the proposed action on water quality are displayed in the EA and Water Resources Technical Report (EA, pp to 3-63; Water Resources Technical Report, pp ). There are no water quality limited 303(d) listed water-bodies within the project area or Bear Creek Watershed. Beneficial uses for streams in the project area have not been specifically designated. As non-designated surface waters it is presumed that most waters in the state will support cold water aquatic life and primary or secondary contact recreation beneficial uses. Based on this, the most applicable beneficial uses would include cold-water aquatic life and secondary contact recreation (Water Resources Technical Report, p. 9). The EA and Water Resources Technical Report adequately discuss cumulative effects to water quality and explain the rationale for choosing the appropriate scale to use. The EA and Water Resources Technical Report also adequately discuss compliance with State and Federal water quality requirements.

8 APPEAL ISSUE 11: The EA does not analyze the effects of sedimentation. RESPONSE: The Water Resource Technical Report identifies potential sources from within the proposed project area and their effects and finds both alternatives 2 and 3 would result in temporary increases in road related sediment due to increased traffic and maintenance near streams during the life of the timber sale. The potential temporary increases in sediment under either action alternative are not expected to inhibit water bodies in the project area or downstream from meeting their designated beneficial uses given the application of project design features and BMP s (Water Resource Technical Report, pp ). The Fisheries Specialist Report also identifies impacts of sedimentation on fisheries, and finds Harvest activities (felling and skidding) are unlikely to affect riparian areas or stream channels under either alternative 2 or 3. Because increasing sediment production can decrease habitat diversity, degrade spawning and rearing habitat and reduce aquatic insect production, the proposed road decommissioning could involve short-term impacts to fish. Based on monitoring of other road decommissioning projects on the Payette National Forest the increase in turbidity and sedimentation is of a very short duration. The long term benefits of reducing water routing and sediment input would outweigh the short-term effects of the roadwork (Fisheries Specialist Report, p. 6). The EA states Application of 120 and 240 foot RCA s on intermittent and perennial streams respectively is expected to protect floodplains, maintain existing stream shading and large woody debris (LWD), and provide for future sources of LWD for stream channels across the project area (EA, p. 3-56). Additionally, the requirement that no ground disturbance (outside of existing roads) is permitted within 200 feet of channels will limit potential ground disturbance and sediment generated from harvest activities from entering stream channels. These buffer widths along with the requirement to locate skid trails and landings at least 200 feet from channels are expected to provide ample vegetative cover between harvest units and stream channels to filter non-channelized sediment resulting from ground disturbance in harvest units. The EA and supporting documents adequately analyze the effects of sedimentation and identify mitigation to improve conditions in the watershed. APPEAL ISSUE 12: There is no cumulative effects analysis of impacts to elk habitat viability. The analysis area should have included the surrounding big game units and indeed the entire west side of the forest. RESPONSE: The analysis of effects on elk is based on the proposed modifications to the current condition of elk habitat quality, winter thermal cover, and elk security in the Analysis Area and at an Elk Analysis Unit scale (EA, pg. 3-28). The EA specifically addressed cumulative effects and found that the Upper Bear Timber Sale, and Lick Creek Vegetation Management Project combined with the Summit Vegetation Management Project will improve elk habitat quality and security for the Bear watershed (EA, p. 3-43). The current total elk population is currently exceeding State management objectives (2,521 vs. 1,350-2,050) (EA, p. 3-34). The capability of the analysis area to provide sufficient habitat security to maintain elk populations at levels for the State to meet their herd management objectives would be maintained in the short term with either action alternative. Long-term habitat security would somewhat improve with growth of vegetation (EA, p. 3-42).

9 The EA analyzed effects (including cumulative effects) to elk and provides adequate rationale for the scale and the geographic area used for the analysis. APPEAL ISSUE 13: The Forest is violating NFMA and the Forest Plan by failing to ensure for the viability of certain species because there is no old growth requirement and no requirement to maintain the specific habitats needed by pileated woodpecker and flammulated owl. RESPONSE: See response to Issue 5, which addressed the project s effects to bird species including the white-headed woodpecker, flammulated owl, goshawk, pileated woodpecker, and great gray owl. Three species, the flammulated owl, northern goshawk, and pileated woodpecker, are widely distributed in appropriate habitats and the Payette National Forest provides habitat that contributes to viable populations on a larger scale (Status Of The Flammulated Owl, Great Gray Owl, Northern Goshawk, and Pileated Woodpecker on the Payette National Forest Report of the Findings, August, 2009, p. 8). APPEAL ISSUE 14: Logging to create large tree habitat is untested hypothesis. RESPONSE: The Forest documents in the DN/FONSI that the treatments in small and medium size treestands have been designed to promote large tree structure throughout the project area (DN/FONSI, p. 4). The EA explains how the large tree component of timber stands will improve after the project (EA, pp. 3-10): The trees in medium size class stands that are treated will take advantage of the increased water, nutrients, and sunlight. These thinned stands will maintain growth and vigor longer, be more resistant to insect and disease infections and fire, and will live longer than trees in stands that are not treated. These stands will eventually develop into the large tree size class. Some large grand fir (climax species) trees and other large trees with poor vigor will be cut where stand densities are high and resources are limited. However, large trees will be favored to leave in almost all instances and less than 1 percent of the trees cut will be large trees. The Vegetation Specialists Report documents the basis for expecting forested stands to improve over time after various types of stand treatments (Vegetation Specialists Report, pp. 8-10). There is an adequate and rational basis in the DN/FONSI and EA for concluding that the project will promote large tree structure. APPEAL ISSUE 15: The data used by the forest for the vegetation analysis is outdated and incomplete. There is no inventory of old growth habitat. The Forest s scientific models are not reliable either. RESPONSE: The 2006 Vegetation Technical Report describes the data sources and methods used to analyze the existing vegetation (2006 Vegetation Technical Report, p. 4-6). Exhibits A- D include data collected by Forester, Mike Coggin in 2005 to field verify the 1994 Landsat Imagery. Stream habitat in the drainage was surveyed in 2005 by the West Zone Fisheries crew using the Region 1/Region 4 stream habitat inventory protocol. Data collected included sedimentation and surface fines (Fisheries Specialist Report, pp. 3-5). The EA used current data for both existing vegetation and in stream sedimentation.

10 APPEAL ISSUE 16: The PNF went out and marked trees for cutting before completing NEPA thus prejudicing the outcome of the NEPA process in favor of logging. RESPONSE: Markings and field designations of proposed activities during the planning phase of a project are not in violation of NEPA (see 40 CFR Limitations on actions during the NEPA process). Identification in the field allows for accurate field measurements and also allows the interdisciplinary team members, interest groups, and the general public to better visualize and understand the proposed project before any action actually occurs. The predecisional marking and cruising on the project did not have any adverse environmental impact and did not prejudice the ultimate decision on the project. APPEAL ISSUE 17: The EA violates NFMA, NEPA and the APA because the Forest Plan standards for water quality, elk habitat, wildlife protection, and old growth are not binding, as required by NFMA. RESPONSE: The EA identifies that the analysis is tiered to the FEIS for the 2003 Payette Forest Plan and identified Management Area and Management Prescription Category from the Forest Plan (EA, pp. 1-6). The EA also identifies the applicable Forest Plan Standards and Guidelines for each of the mitigation measures in Table 2-4. The EA and specialist reports appropriately identify that the project complies with the Forest Plan Standards as related to water quality, elk habitat, wildlife protection and old growth. See response to Issues 1, 3, 5, 10, 12, 13 and 15.