Appendix F : Comment Period Input and Forest Service Responses

Transcription

1 Appendix F : Comment Period Input and Forest Service Responses Appendix F: Comment period Input and Forest Service Response D - 1

2 1. Dick Artley We will be addressing here the issues identified in your comment letter or text body. The comments you requested we address, for the most part relate to the opposing views documents and responses will be in separate documents. 1.1 Comment: Logging road construction causes significant ecological harm. You know this yet you consider it necessary collateral damage to removing your precious volume. Please analyze an action alternative in detail that does not construct any new roads (temporary or system). 1.1 Response: The Forest Service incorporates a wide variety of Best Management Practices, Forest Plan Standards and Guidelines and engineering design standards to reduce soil compaction, erosion, and displacement. Addressed in the EA, section 3.9 are the effects of temporary roads in the project on soils and is section 3.4 the effects on aquatics. Appropriate mitigation measures for soils and aquatics are in Appendix C to the EA. No permanent (system) road construction was proposed. All temporary roads are removed after all proposed activities are completed (EA, Sec 2.5.3). 1.2 Comment: Clearcutting the land owned by 321 million Americans directly assaults them and future generations. 1.2 Response: The EA section explains why clearcutting is optimal harvest method for some stands. In making our management decisionswe listen to and evaluate what the public contributes, we consider best available science,professional experience, and Forest Plan management direction to achieve a balance of resource objectives. The Proposed Action (alternative B) would result in 1,264 acres of clearcutting with reserves with most of the acreage in aspen forest type, which provides the light condition required to regenerate aspen (USDA FS 2004b, Chapter 3.4 and USDA FS 2004a, p.2-20). Clearcutting with reserves, retains reserve trees in a clumped or scattered pattern to enhance structural and compositional diversity in the new stand. Detailed analysis of the effects from harvesting on watersheds, soils and recreation is in the Long Lake EA (EA Sections 3.4, 3.9 and 3.6). 1.3 Comment: NEPA requires federal officials to produce professional NEPA documents using resource specialists with the education necessary to disclose accurate predictions of the environmental effects of implementing a Proposed Action. Throwing together a NEPA document with whoever might be available for convenience and to save money is unacceptable. A responsible, competent line-officer examines scoping comments, identifies major issues and staffs the IDT with people having the education to address the issues. D - 2

3 1.3 Response: Resource specialists with college degrees in their resource area, years of professional experience, and local knowledge and expertise prepared this EA and analyzed the effects of proposed activities; see Chapter 5, p Comment: The pre-decisional EA indicates there will be seedtree prescriptions associated with the proposed action. 1.4 Response: This Project addresses the optimality and appropriateness of regeneration harvest or even-aged management (EA Section 3.1.5, Vegetation Section) which includes a seedtree prescription. This project is consistent with Forest Plan direction and follows Forest Plan standards, guidelines, best management practices, and identifies mitigation measures to protect wildlife, water quality, and retention of soil productivity. It is also designed to increase species, structural, and functional diversity, minimize the spread of NNIS (including worms), resilience to climate change, and provide for gathering opportunities. Chapter 3 of the Environmental Assessment discloses the effects of even-aged harvest and all the proposed treatments on these resources in addition to the recreational values and scenic integrity. 1.5 Comment: The pre-decisional EA does not discuss how the timber sale s logging and slash/rx burning activities will be mitigated to assure protected bird species individuals and their habitat are not harmed in any way. 1.5 Response: Effects of the project activities on forest wildlife species (including birds) is evaluated by looking at effects to Management Indicator Habitats (MIH). These type and age groupings represent the broad spectrum of habitat used by the forest bird community. The MIH analyses and the project effects are discussed in the Biological Evaluations (PR BE) and reported in the EA. See Appendix C mitigation tables and analyses in EA, sections 3.2 Wildlife. No prescribed fire treatments were proposed in this project. 1.6 Comment: Increases in National forest logging do not stabilize or enhance the economy of small communities located near them Consider the following excerpts from a research paper that examined community stability vs. increased logging. The study was done on small communities near national forests in Washington State: "The relationship between timber harvest and the overall economic health of Washington communities assumed to be most dependent on logging and forest products runs counter to commonly held assumptions." "Despite a 93 percent decline in National Forest timber harvests and the loss of 7,300 forest products jobs statewide between 1988 and 1998, the number of people employed outside of forest products D - 3

4 expanded by 726,000 (total employment increased 33 percent), total real income expanded by almost 50 percent, and population rose by 23 percent Request for changes to be made to the final NEPA document: Either: 1) remove the following section from the P&N: Provide Sustainable Forest Products OR 2) offer the sale as an SBA sale, OR 3) include the following papers (referenced above) in their entirety in an Appendix to the NEPA document. 1.6 Response: The clearly states that part of the Purpose and Need is to Provide for commercial wood in support of the local and regional economy. Providing for wood products as well as numerous other resources is inherent in the direction provided in our 2004 Chippewa National Forest Plan. Our Forest Plan emphasizes restoration and ecological approaches through desired conditions, goals and objectives, and standards and guidelines (FP, p 2-21 through 2-24) to ensure that ecosystems are capable of providing a sustainable flow of beneficial goods and services to the public. Harvest prescriptions incorporate variable tree spacing; require retention of non-featured species, most often hardwoods, and planting or seeding to increase species and structural diversity. We believe these treatments move stands and the landscape towards the desired conditions and the direction stated in our Forest Plan. The EA presents the economic issues (Section 3.11 pgs ). Our Forest Plan FEIS recognizes and addresses the importance of the timber industry to the local and regional economy (FEIS, Volume I, Section 3.9.1). In addition, our annual Monitoring and Evaluation Reports addresses the contribution of timber in our area (Section 2. Timber). The papers cited are not scientific, peer reviewed studies or literature. Peer review as well as the strength and specificity of the relationship between ideas, data and inference distinguish scientific insights from opinion. Other than a general correlation of a small community near a national Forest, the comments do not explain how the studies of the economy in Washington State are relevant to the economy in northern Minnesota. An example of the differences in the economic setting is, the study says population rose by 23 percent". Population in Cass County also rose but only by.5%. 1.7 Comment: The USFS spends the public s tax dollars to take action to eliminate beneficial (emphasis added) natural disturbance agents such as insects, disease, and fire that are essential to assure the proper functioning of natural resources in the forest that have evolved to depend on such events. 1.7 Response: This comment is general in nature and not specific to the Long Lake project. Treatment of insects or diseases is not part of the purpose and need or an internal issue in this project. The purpose and need does include reduce hazardous fuel build up in the red pine stands. Hazardous fuels are an important D - 4

5 consideration given the intermingled ownership pattern and the historically high incidence of human caused fire. The Forest recognizes the importance of natural processes, dead and dying trees on the landscape, structure such as snags and course woody debris to a properly functioning ecosystem. The Long Lake Project follows Forest Plan Standards and guidelines to ensure snag and coarse woody debris and other structural components remain on site providing for dead and dying trees in the forest. 1.8 Comment: The range of alternatives in the pre-decisional EA is inadequate. There are reasonable alternatives to the Proposed Action that you conveniently overlook. Analyzing a single action alternative as has been done here is clearly intended to hardwire selection of the proposed action for implementation in violation of the NEPA. Do you really think there is only 1 possible action that might satisfy your P&N? 1.8 Response: Alternatives are developed in response to public comments that identify issues with the proposed action that need to be resolved. The public did not provide comments that resulted in any key issues that would result in an additional alternative (EA, section 1.8, p 12). (see 36 CFR 220.7(b)(2)(i) Proposed Action and Alternatives.) Rationale for issues dismissed is also provided in this section or in the Response to Scoping Comments. 1.9 Comment: Noise and Dust caused by Timber Harvest Adversely Affects Recreation and Wildlife, thus these Adverse Social and Environmental Impacts must be Analyzed in Chapter 3 with follow-up changes made to the timber sale design to eliminate these adverse effects 1.9 Response: Noise and dust were not raised as issues during scoping nor were they determined to be an issue by the wildlife biologist or recreation specialist on the project. The project is also within a roaded area with a lot traffic for a rural area. Historically, noise and dust have not been issues on the Chippewa National Forest Comment: The predecisional EA fails to evaluate project impacts to climate change and climate change impacts to forest resources and ecosystem services in the sale area Response: The ID team participated in a Climate Change Vulnerability Assessment in July The assessment covered projected changes in suitable habitat for tree species and adaptation strategies and approaches. The effect of forest management activities holds greater uncertainty due to multiple D - 5

6 climate change scenarios. These changes will occur on a landscape scale and are beyond the scope of this project. However, efforts to promote healthy, resilient stands at the project-level during this entry may help to maintain diverse vegetation and species habitat in the future. (PR 5.5, 5.6 & 5.7) (EA, 1.8 Other Issues, p 12) 1.11 Comment: Please respond to the opposing views contained in the Opposing Views Attachments to these comments and each comment Response: Each of the references provided has been reviewed with regard to relevance for the Chippewa National Forest and this project. Please refer to the responses in these Opposing View documents. The District Ranger and the Interdisciplinary Team considered all information provided in the attachments. These documents were considered as potentially useful information to guide the analysis and the decision. It is worth noting that only some of the documents were peer-reviewed scientific literature; many were opinion documents and many were web-sites. Most of the submitted documents describe commonly recognized impacts that can result from forest management activities. The Forest Service is aware of this information, recognizes that these potential impacts can exist in certain environments and landscapes, and considers them in the decision making process Comment: The Proposed Action will clearly cause the resource degradation and destruction described in the ATTACHMENTS to these comments Response: The resource specialists have presented the effects of any proposed activities on their resources in the EA. The reviewed attachments responses are part of separate documents Comment: Competent Responsible Officials do not hide important project-related information from the public in the project file Response: Any project file information is available upon request and noted in several places in the EA. The EA provides a summary of the resource effects which is supported by more detailed analysis and best available science. Specific electronic files can be obtained by contacting the project leader or District Ranger. 2. Sierra Club D - 6

7 2.1 Comment: How will clearcutting patterns mimic the complicated disturbances created in nature, such as fire? Why are there so many units slated for clearcutting without the benefit of any secondary treatments? Why clearcut aspen stands just to let them naturally regenerate back to aspen? Timber harvesting is a poor substitute for, naturally occurring stand replacing disturbances, the negative effects often outweigh any benefits that are achieved. 2.1 Response: Commercial timber harvest treatments (including clearcuts) are described in the EA (pp , 97) and effects to multiple resources are disclosed in Chapter 3 of the EA. The treatment used on our Forest is more correctly called clearcut with reserves. Although it is acknowledged that clearcutting tends to create stands that are more simplified in terms of structure and composition (FEIS, Vol I, P ), this treatment was selected for a number of our forest types since it provides the necessary light and other conditions needed for desired species to be established. Clearcuts with reserves would move toward Forest Plan Vegetation Composition and Age Class objectives while retaining individual reserve trees and reserve areas to provide species and structural diversity, similar to natural disturbances. Treatments for each individual stand were influenced by existing stand conditions, Forest Plan direction, silvicultural requirements of species on each site, issues raised during the analysis, and local experience. Aspen stands identified for natural regeneration back to aspen would not need secondary treatments such as planting. These aspen stands are located in areas that are not conducive to conversions (i.e. stands would require frozen ground access or are located in high deer population areas) or are desired near Wildlife Management Areas. In addition, anticipated climate changes influenced adaptation and enhancement efforts in this project area during harvest (by retaining species diversity) and reforestation (via planting species that are expected to be better adapted to a warmer climate). This Project also addresses the optimality of clearcutting (EA, Vegetation Section). This project is consistent with Forest Plan direction and follows Forest Plan standards, guidelines, best management practices, and identifies mitigation measures to protect wildlife, water quality, visuals, and retention of soil productivity. It is also designed to minimize the spread of NNIS (including worms). 2.2 Comment: How much and what types of biomass does the Agency plan to sell and which units will it come from? How will this removal of biomass affect wildlife? How will this removal of biomass affect soils, and the future health of vegetation that will be deprived of these nutrients? 2.2 Response: Biomass harvest would be allowed in stands where mechanical site prep for natural regeneration, seeding, or planting was identified. In these stands, biomass harvest would achieve objectives of slash removal, soil exposure, and soil scarification while retaining residual trees and inclusions as described above (e.g. results would be similar to other mechanical site preparation treatments) (EA pp ). D - 7

8 Biomass harvest would retain 20 percent of the logging slash (i.e. non-merchantable treetops and branches, etc.) generated from harvest operations in these stands (Minnesota Voluntary Site Level Forest Management Guidelines, Forest Biomass Harvesting chapter, p. 29). Therefore, about 80 percent of the slash would be available (but not be required) for timber purchasers to buy. Biomass removal was included in the analysis of effects in the Biological Evaluation (project record), p. 10 following harvest, some of these acres are planned for site preparation to be accomplished by mechanical scarification and or biomass harvest. This will generally occur on sites that are being converted from one forest type to another (611 acres), including 482 acres of aspen forest types to other forest types. The BE (p. 9) concluded that neither of the Long Lake project alternatives would result in a trend to federal listing or loss of viability to a population or species. Of the 25 sensitive animal species on the Chippewa, the Long Lake project would have no impact to 20 species; a finding of may impact is associated with 5 species. Harvesting trees and removing the merchantable bole and bark would remove some nutrients from the treatment area. However, less than a third of the nutrients are immobilized in the merchantable stem wood and bark. The remainder returns to the soil reserve in foliage, branches, fruits, and roots (Pritchett & Fisher, 1987, p. 427). Should biomass harvest occur, State BMPs addressing soil productivity during forest biomass harvesting would apply and would aid in maintaining nutrients on site. Nutrient losses by conventional harvests from even the most productive sites are relatively small on an annual basis. Such losses can likely be replaced by soil weathering and natural inputs, except for some particularly infertile soils. Most soils can replace the nutrients in the harvested timber without a long term decrease in productivity (Pritchett & Fisher, 1987, p. 427). There are several ways to mitigate nutrient removal impacts from whole tree harvest areas, including harvesting trees in the fall or winter when branches are more brittle, leaving broken tops on-site, thinning after leaf-drop, considering species specific nutrient requirements, redistributing any remaining slash across the harvest area, and by extending the reentry period between treatments (Busse, et al., 2014, p ). Recent research resulting in updated nutrient budgets indicates that for most mineral soils in Minnesota, the nutrient capital is sufficient to support biomass harvest (MFRC, 2013, FBH p. 13). Exceptions include coarse, nutrient poor sands, areas that are shallow to bedrock, and deep organic soils. Forest Plan limitations have been specifically developed to minimize the removal of woody material from treatment stands on those areas. 2.3 Comment: How many plantations are located within the project area? Where are they and how large are they? Are existing plantations being expanded? How do these tree plantations contribute to the many goals and objectives in the Forest Plan aimed at restoring health, vigor and diversity to the forest? Tree plantations have little structural or species diversity. They are ecologically unstable and more susceptible to weather, fire and pests. They do not promote healthy diverse forests. D - 8

9 2.3 Response: The Long Lake Proposed Action includes 105 stands that are classified as red pine and 24 stands that are typed as white spruce. They are located throughout this project area, and they range from acres in size, totaling about 2930 acres. Most stands are interspersed with other forest types, although one area of 46 adjacent red pine stands totals over 1500 acres. Some of these stands more monotypic in nature with very little species or structural diversity while others have desired levels of species and structural diversity. Existing plantations are not being expanded. Mature and older coniferous stands contribute to age class, scenic integrity, riparian, Management Indicator Habitat, and other Forest Plan objectives. Thinning red pine and white spruce stands provides more growing space for residual trees, thus increasing stand vigor. See 2.4 Response below for information regarding a project to enhance diversity in some red pine stands. 2.4 Comment: The EA states, Alternative B includes patch enhancement treatments in red pine plantations, intended to foster structural and compositional diversity (48). What does this mean? Is the primary objective of the treatment commercial or rehabilitation? Managing a stand or plantation with any sort of consideration for its future merchantability of timber cannot be reconciled or integrated with returning a stand back to its historical diversity which is what is best and healthiest for the forest. These are two opposite goals and cannot coexist. 2.4 Response: Patch enhancement treatments are described in the EA (pp ) and BE (p. 22). In one very large patch (over 1900 acres in size), enhancement treatments are proposed in some 70+ year old red pine stands of plantation origin that currently have low levels of species and structural diversity. The treatments include variable density thinning, and the creation of small gaps in which other species would be planted, including white pine, Northern red oak, bur oak, white spruce, hackberry, bitternut hickory, balsam fir and jack pine. Most of these species are already present in the Chippewa National Forest, but lacking from this planted area, however, a couple of species (hackberry, bitternut hickory) are species which are thought to be potentially better adapted to warming climate conditions. 2.5 Comment: Referring to large mature patches, the EA states, Alternative B removes 2 patches through clear-cut harvest, resulting in less connectivity between areas of mature forest (44). The Sierra Club is concerned with the reduction in acres to large mature patches in the project area. Many sensitive species such as lynx, Northern goshawk, black-throated blue warbler, bay-breasted warbler, and boreal owl rely on mature forest for habitat. For many species, reductions in current and potential habitat could lead to disastrous future results. Reduction in large, mature upland patches or forest interior habitat conditions is less favorable for species like the northern goshawk, red-shouldered hawk, and D - 9

10 great grey owl (45). This project contributes to the forest-wide trend of declining mature upland spruce-fir habitat (BE, 4). The number of large mature patches needs to be maintained, as should their size in terms of acreage. Habitat which, occurs in larger blocks, or patches, is likely to have higher quality than that which does not (45). 2.5 Response: A modification to Alternative B (Addendum to BE of Sensitive Animal Species, in project record) would reduce some harvest proposed in large, mature upland patches. It would also remove harvest in mature spruce-fir stands in the BHC LE. This modification would result in better meeting Long Lake Purpose and Need statements relating to conifer-dependent forest birds, and wildlife species that need large tracts of mature forest habitat. This modification would cause the Long Lake project to no longer contribute to a forest-wide trend of declining mature upland spruce-fir habitat in the BHC LE.As indicated in the EA (p. 42) and BE (p. 9), neither of the Long Lake project alternatives would result in a trend to federal listing or loss of viability to a population or species. Of 25 animal species evaluated, the Long Lake project would have no impact to 20 species; a finding of may impact is associated with 5 species. A detailed analysis of large, mature forest patches is provided in the BE (pp ; 50). Habitat which occurs in larger blocks, or patches, is likely to have higher quality than that which does not. Large, mature upland patches would increase under both project alternatives due to forest aging. Both project alternatives would help to meet forest-wide standards and guidelines establishing minimum amounts of large, mature upland patches, as well as the objective to maintain or increase large, mature upland patches across the Forest. Both alternatives would also result in meeting Purpose and Need statements intended to foster mature forest habitat conditions. Alternative A would allow more acres of mature forest habitat to develop than would Alternative B, and allows somewhat more connectivity between acres of mature forest in the project area. Alternative B would remove 1 patche due to clear-cut harvesting of aspen stands (BE p. 44). Alternative B includes patch enhancement treatments in red pine plantations designed to increase species and structural diversity within the patch. 2.6 Comment: Temporary roads are supposed to be obliterated when logging is completed. However, the Agency actually has up to 10 years after the end of road use to decommission a temporary road. Even then, temporary roads are often forgotten about and never decommissioned, or they are not decommissioned adequately, which results in their continued use by motor vehicles. Just because a road is termed temporary does not mean it will not have any impacts on the forest. In this project there are almost 10 miles of existing temporary roads that were never decommissioned. How did this happen? When will they finally be decommissioned? 2.6 Response: The 2004 Forest Plan states in O-TS-8: The Forest will decommission approximately 200 miles of road within 10 years. The Forest successfully met that objective, with over 200 miles of system roads decommissioned in that decade. Additional miles of road continue to be reviewed in the NEPA process as decommissioned eligible, and will be addressed as future projects. D - 10

11 There are many miles of roads that have decisions to decommission but were not completed. Reasons include the Forest has already decommissioned over 200 miles of road, staffing shortages and workload increases have not prioritized further projects. Activity is again planned requiring access via these ten roads. These roads can then be decommissioned if no further access is needed. A minimal amount (approximately 1.0 miles) of new temporary roads would need to be built; these would be effectively closed when the project is completed. 2.7 Comment: The Biological Evaluation (BE) explains, In a general sense, what this means for wildlife is that habitats are abundant for early successional- and young forest-associated species, such as white-tailed deer and ruffed grouse. A reflection of widespread current habitat conditions, these species are generally quite common in the modern landscape. Species more typical of upland conifers and mature forests have far less available habitats, and as a result, are less common (BE,3). So why does so much of the focus of this project seem to center around enhancing habitat for game species, whom are abundant compared to sensitive species who are declining? Why has so little effort been put forth to improve habitat for sensitive species? Instead this project results in decreasing habitat for several sensitive species. 2.7 Response: The project is a balance of a variety of objectives. Wildlife and botanical enhancement projects are described in the EA (pp. 8 10), and would benefit a variety of game, nongame species and sensitive species. These projects include oak management, deer wintering area management, maintenance of a minor amount of permanent openings, increasing habitat for conifer-dependent birds, and maintaining and improving the quantity and quality of older forest habitat. The effects of the proposed activities are analyzed in detail in the BE (pp , 51) (project record) and summarized in the EA (pp 42 46). 2.8 Comment: Both LAU s are over the 2 mile/square mile threshold. This project proposes no roads for decommissioning, instead building an additional mile of roadway. As a result, this project is not in compliance with Forest Plan Objectives to: maintain and improve lynx habitat, seek opportunities to benefit lynx, reduce or eliminate adverse effects to lynx, minimize road building, promote the conservation and recovery of the lynx, provide foraging habitat in proximity to denning habitat, maintain habitat connectivity to reduce road mortality, and maintain road density at or below 2mi/mi2. No new roads should be built. Temporary roads will affect lynx the same as permanent roads. Increases in snow compacted routes adversely affect lynx by allowing bobcat and coyotes to access areas of deep snow and compete with lynx. Instead of adding roads to the system, roads need to be decommissioned. This project is in compliance with the 2004 Forest Plan O-TS-2: Few new OML 3, 4, 5 roads will be constructed, O-TS-3: New roads built to access land for resource management will be primarily OML1 or temporary and not intended for public motorized use. Temporary roads will be decommissioned after D - 11

12 their use is completed. All newly constructed OML 1 roads will be effectively closed to motorized road and recreation vehicles following their use unless they are needed for other management objectives. The 2004 Forest Plan also states in O-TS-8: The Forest will decommission approximately 200 miles of road within 10 years. The Forest successfully met that objective, with over 200 miles of system roads decommissioned in that decade. 2.8 Response: As indicated in Table 3-7 of the EA and p. 20 of the Biological Assessment (BA, project file), Alternative B received a determination of not likely to adversely affect Canada lynx or its habitat. The rationale is that small reductions in habitat would occur, which are unlikely to adversely affect Canada lynx. The U.S. Fish and Wildlife Service concurred with this determination (project file). The BA (pp ) provides a detailed analysis of potential impacts of proposed activities on Canada lynx habitat components. Table C (BA pp ) indicates Alternative B is in compliance with Forest Plan Guidance, including O-WL-4, O-WL-6, O-WL-7, O-WL-8, O-WL-10, O-WL-11, and G-WL-8, which are the objectives referenced in comment 2.8. As indicated on pp of the BA, LAU s 18 and 19 are currently above the 2 mile per square mile road density threshold. The proposed action would not involve any road decommissioning, and a minimal amount (about 1.0 mile) of new temporary road would be built for this project, and then effectively closed when the project is completed. This project is in compliance with the 2004 Forest Plan O-TS-2: Few new OML 3, 4, 5 roads will be constructed, O-TS-3: New roads built to access land for resource management will be primarily OML1 or temporary and not intended for public motorized use. Temporary roads will be decommissioned after their use is completed. All newly constructed OML 1 roads will be effectively closed to motorized road and recreation vehicles following their use unless they are needed for other management objectives. The 2004 Forest Plan also states in O-TS-8: The Forest will decommission approximately 200 miles of road within 10 years. The Forest successfully met that objective, with over 200 miles of system roads decommissioned in that decade. D - 12