APPENDIX F: Response to Comments

Transcription

1 APPENDIX F: Response to Comments The Forest Service notified the public of the opportunity to comment on the proposed Bunker Area Derecho Fuels project in on March 8, Eleven parties responded with comments. Comments and agency responses are presented below in the order received. F. MARTIN FEE, Tribal Historic Preservation Officer, Iowa Tribe of Kansas and Nebraska September 17, 2012 Comment 1: Tribe has interest in the area geographically. Response: No response necessary; information only. SUE HAGAN/MICK SUTTON, Cave Research Foundation September 17, 2012 Comment 1: Cave locations identified Response: No response necessary; information only. The proposed action was modified to exclude fuel treatments near the known caves.. JAMES H. WEIBLE, trustee, James H. Weible Living Trust September 17, 2012 Comment 1: Adjacent landowner concerned that planned Grasshopper Hollow Prescribed Burn may escape on to adjacent public and private lands. Response: Federal land managers take great efforts, some mandated by law, to avoid the escape of forest fires used by the Forest for resource management. Prescribed burn plans will be written to guide and direct how the burns proposed in this project will be conducted. The burn plan specifies the exact range of weather conditions that must exist before ignition can be initiated, and the numbers or firefighters that must be available to safely execute the burn. The prescribed burn plan also determines a contingency force of firefighting equipment that must be available to react to the prescribed burn should it become uncontrolled. The prescribed burn plan is created and reviewed by fire experts and resource specialists to insure the specific burn parameter will achieve the desired results while minimizing the risks of an escape or uncontrolled burn. F-1

2 JACK WILLIAMS September 17, 2012 Comment 1: Adjacent landowner wants to be kept informed concerning future project developments. Response: Comment noted. The landowner is on project mailing list. DICK ARTLEY September 20, 2012 Comment 1: "The Bunker Area Derecho Fuels project clearly deceives and tricks the public into believing the logging (a.k.a. fuels reduction) will help reduce the risk of their house burning should a wildfire occur. I am outraged that you would place public safety in jeopardy to increase the chances that you will get your cut out this FY. The safety of those citizens living in the WUI is in your hands. How would you feel if someone died and you did not take advantage of the most effective fire damage risk reduction methods that exist? The scoping report P&N at page 5 states: "Decrease wildland fire risk to the community of Bunker and surrounding WUI areas by removing, reducing, and/or rearranging hazardous fuels" Hazardous fuels reduction projects are not the most effective way to reduce the risk of fire damage to homes in the WUI... yet you Ranger Haines propose it anyway." Response: The Bunker Area Derecho Fuels EA analyzes the efficacy of the proposed action and any alternatives for providing safer conditions for the public and our firefighters as well as any potential impacts to public safety and the environment. Comment 2: "Dr. Jack Cohen is a USFS fire physicist working in Missoula, Montana. He has devoted his entire working career researching methods to reduce the risk of fire damage to homes located in the WUI. If you aren't familiar with Dr. Cohen's research, please see attachment #11. If after reading Dr. Cohen's research conclusions you still believe fuels reduction logging is the way to go then please see attachment #3." Response: Thank you for providing this source document information. The impacts of not implementing mechanical fuels treatments in the project area are described under Alternative 1, the No Acton alternative. The Forest Service agrees with the commenter in regards to the agency s obligation to thoroughly analyze all information and opposing science brought forth from the public that relates to the project. A review of the documents referenced in the commenter s Attachments # 3 and # 11 are located in the project file for the Bunker Area Derecho Fuels project file (Vol. 2, Tab A, Document 7). Comment 3: "Dr. Cohen s fire damage risk reduction methods are the most effective that exist. He does not recommend logging merchantable trees near the WUI to reduce fire risk as is being proposed with this commercial timber sale (a.k.a. a fuels reduction project). This is why he is a black-sheep in the USFS. The USFS does not want the public to learn about Dr. Cohen s research because this would eliminate another excuse to commercially log our national forests. Here are 3 of many statements made by Dr. Cohen related to fuels reduction logging. Extensive wildland vegetation management does not effectively change home ignitability. F-2

3 Home ignitability also dictates that effective mitigating actions focus on the home and its immediate surroundings rather than on extensive wildland fuel management. Because homeowners typically assert their authority for the home and its immediate surroundings, the responsibility for effectively reducing home ignitability can only reside with the property owner rather than wildland agencies. As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses. Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? (page 5 of transcript) Presented as the Fire Economics Symposium in San Diego, California on April 12, Dr. Cohen recommends removing fine flash fuels within a few hundred feet of a home at risk. That s why kindling is used to start a fire in the fireplace,if the pre-decisional EA for the Bunker Area Derecho Fuels project does not analyze a Dr. Cohen alternative in detail it will be necessary to inform the public in your area about Dr. Cohen s fire risk reduction methods myself. The Responsible Official would propose the following activities as part of a Cohen alternative: educate the public living in and near the WUI using written material that summarizes Dr. Cohen s findings and public meetings to answer questions. educate the public living in and near the WUI using public meetings to answer questions and distribute information. offer USFS labor to help elderly and disabled people living in the WUI to remove the fine fuels near their home(with their written permission) as Dr. Cohen suggests. Response: Jack Cohen is a Research Physical Scientist at the Rocky Mountain Research Station in Missoula, MT. His work is widely recognized by scientists and practitioners in the field of fuels management within the WUI. Many of his publications are supported on the Firewise Website that the USDA Forest Service has partnered with to provide the public with Jack Cohen s publications. In Chapter 3 of the EA on page 45, home ignitability as described by Cohen is discussed. The EA states from Cohen that Because homeowners typically assert their authority for the home and its immediate surroundings, the responsibility for effectively reducing home ignitability can only reside with the property owner rather than wildland agencies. The suggestion to limit the project to treatments within a few tens of meters from homes was not considered for the following reasons: Treating only near individual home sites on a limited basis does not fully meet the intent of breaking up fuel continuity generally within the project area to allow firefighters to move safely, tactically, and strategically address a fire in the interface area. This would limit the ability of fire- fighting efforts to more effectively and safely fight a fire in the area as a whole. Such an approach would leave significant areas of fuel buildup and dense canopies with ladder fuels within the WUI area. As described above, leaving such stand conditions untreated would limit options that firefighters would have for safely stopping a moving fire within the interface area, and would leave many areas where crown fire potential could have been reduced within the urban interface. Bypassing the opportunity to treat such areas would not be consistent with the purpose of the project. While individual home-by-home treatments can help reduce the risk of loss of individual homes, relying solely on such treatments could forego strategic opportunities for controlling fires within this WUI area. F-3

4 Limiting treatments to a smaller area immediately adjacent to homes or structures would only allow for a small subset of the interface area to be treated in the project area. In addition, it would not meet the broader purpose of the proposal in treating fuels in the WUI area. Federal land management agencies are not responsible for the reduction of hazardous fuels on private property. However, we are responsible to manage the vegetation within the WUI based on the Land and Resource Management Plan (Forest Plan, pp. 1-4 and 1-5). These findings are consistent with Forest Service Manual directives regarding WUI fire protection. Section 5137 of the manual defines Forest Service structure protection measures in terms of wildfire control. Therefore the Forest Service has responsibility to suppress fires before they reach structures. Based on our policy for fire suppression, it is necessary to reduce the hazard within and adjacent to the WUI so that firefighters can safely execute the tactics necessary to effectively suppress wildfire. Sources: The wildland-urban interface fire problem: A consequence of the fire exclusion paradigm, Jack Cohen FOREST HISTORY TODAY FALL Policy for Structure Fire Suppression 1. Fire Suppression for Non-Forest Service Structures. Structure fire suppression, which includes exterior and interior actions on burning structures, is the responsibility of State, tribal, county or local fire departments. a. Forest Service Officials shall avoid giving the appearance that the agency is prepared to serve as a structure fire suppression organization. b. Forest Service Employees shall limit fire suppression actions to exterior structure protection measures as described in FSM The overall crown fire potential as well as the flame lengths will be reduced as a result of the treatments, providing a greater likelihood that the fire can be managed with ground forces, reducing the potential for the fire behavior to become extreme. Comment 4: "Any manager of public land with knowledge of Dr. Cohen s methods (which this letter indicates is the case would be subject to arrest should a fire break out and people living in the WUI are hurt and/or their homes are damaged. This is explained below. E. Personal Liability For Violation of Environmental Laws. In most cases, Federal employees are named as defendants in their official capacities because the actions in question are usually undertaken by virtue of their official authority. These cases generally proceed without risk of personal liability for the employee. In some cases, however, a Federal employee may be sued in his/her individual capacity for injuries or damages to persons or property. Individuals who violate environmental laws or who injure or damage the persons or property of others as a result of carelessness may be personally liable for the consequences. Environmental cases involving the USGS may be brought against the USGS itself, some smaller component, or individual employees. The individual employees may be named because the USGS can act only through its employees. (1) Personal Liability for Injuries or Damages to Persons or Property. Where the actions of a Federal employee cause injuries or damage to the person or property of another, the injured party may bring an action to recover the cost of the damage. Source: USGS Manual Chapter 3 This also applies to USFS employees. F-4

5 This letter will also be useful in court by people (i.e. plaintiffs) who have been burned-out" Response: In The Wildland-Urban Interface fire problem: a consequence of the fire exclusion paradigm, Cohen (2008) states that 1) wildfires and thus extreme wildfire behavior conditions are inevitable, and 2) home destruction is principally determined by Home Ignition Zone (HIZ) conditions given extreme wildfire behavior. Thus, residential fire destruction during extreme wildfires can be considered a home ignition problem. Cohen s main point is that WUI fire destruction is not a wildfire problem but rather is a home ignition problem. It suggests that our effectiveness depends on appropriately defining and approaching the problem. The citation of policy is directed at generating discussion of possible changes of approach toward the facilitation of homeowner engagement in reducing home ignition potential and thereby enhancing our ability to more effectively manage wildland fire as an appropriate ecological occurrence. In addition, federal land management agencies are not responsible for the reduction of hazardous fuels on private property. However, we are responsible to manage the vegetation within the WUI based on the Land and Resource Management Plan (Forest Plan, pp. 1-4 and 1-5). These findings are consistent with Forest Service Manual directives regarding WUI fire protection. Section 5137 of the manual defines Forest Service structure protection measures in terms of wildfire control. Therefore the Forest Service has responsibility to suppress fires before they reach structures. Based on our policy for fire suppression, it is necessary to reduce the hazard within and adjacent to the WUI so that firefighters can safely execute the tactics necessary to effectively suppress wildfire. The wildland-urban interface fire problem: A consequence of the fire exclusion paradigm, Jack Cohen FOREST HISTORY TODAY FALL Policy for Structure Fire Suppression 1. Fire Suppression for Non-Forest Service Structures. Structure fire suppression, which includes exterior and interior actions on burning structures, is the responsibility of State, tribal, county or local fire departments. a. Forest Service Officials shall avoid giving the appearance that the agency is prepared to serve as a structure fire suppression organization. b. Forest Service Employees shall limit fire suppression actions to exterior structure protection measures as described in FSM Comment 5: My Pending Media Contact Unless the final EA analyzes a Cohen alternative in detail I will write a letter to the editor briefly describing Dr. Cohen s methods and will contain the link to the WEB site which explains Dr. Cohen s methods and shows photos of burned homes adjacent to areas that had fuels reduction treatments implemented by a USFS contractor. The striking thing about these photos is that they show unburned homes next to burned homes. The difference? The unburned homes had the fine fuels removed within 300 feet of the home per Dr. Cohen s recommendations. My letter will suggest that the public contact you Ranger Haines and ask why a Cohen alternative was not analyzed in the Bunker Area Derecho Fuels pre-decisional EA. It won t take long to compose and a letter to the editor to the following newspaper(s): Springfield Community Free Press letters@cfpmidweek.com Springfield News-Leader F-5

6 If a Dr. Cohen alternative is not honestly analyzed in detail it will also be necessary to contact the aides for Senators Blunt and McCaskill. They will frown on a USFS official providing corporate profit opportunities which preclude taking action to reduce the fire risk to residents of Missouri. Indeed, the court of public opinion does more to motivate USFS line-officers to crawl out of bed with their corporate masters than any District Court Judge. Don t make the mistake of underestimating me. Sincerely, Dick Artley 415 NE 2nd Street Grangeville, Idaho Da99333@gmail.com PS: Sleep by your telephone if you decide to ignore the public. Response: The treatment methods described by Jack Cohen address the area within the home ignition zone (HIZ). The HIZ is generally located on private land that is not under the jurisdictional authority of the Salem Ranger District to manage hazardous fuels. Agency WUI fuel treatments largely do not address home ignitability but rather areas outside the home ignition zone. Fuel treatments are designed to reduce the fuel hazards and increase opportunities to safely engage with fire suppression operations. October 8, 2012 Comment 1: "The Bunker Area Derecho Fuels Project Scoping Report was clearly written to deceive the public. I am disappointed that you choose to place public safety in jeopardy to increase the chances that you will get your cut out and meet Supervisor Chase's volume expectations. I know what a wildfire does to people's homes and their lives. The Scoping Report at page 5 states: "Decrease wildland fire risk to the community of Bunker and surrounding WUI areas by removing, reducing, and/or rearranging hazardous fuels" Clearly the most important (emphasis added) responsibility of a manager of public land is to protect the public living near national forest land should a wildfire occur. Fuels reduction timber sales have become a favorite of line-officers. They supply volume and they provide good PR with the lay public. However, hazardous fuels reduction projects are not the most effective way to reduce the risk of fire damage to homes in the WUI... yet the USFS does it any way. Why? It's an excuse to log merchantable trees to achieve volume expectations. You know this Ranger Haines. Line-officers that consider the USFS timber agenda a higher priority than the safety of the public have no business being called public servants. Bush and Rey did a number on the American public when they sent the HFRA to congress. The USFS lineofficers have learned to exempt timber sales from appeal by declaring it an HFRA sale because it's a sale to remove hazardous fuels. Since all vegetation in the forest will bum, a line officer can analyze any (emphasis F-6

7 added) commercial timber sale using the HFRA process. Thus, line-officers often violate the Appeals Reform Act of 1992 with impunity. Response: The Bunker Area Derecho Fuels EA (pp ) analyzes the efficacy of the proposed action and any alternatives for providing safer conditions for the public and our firefighters as well as any potential impacts to public safety and the environment. Comment 2: Dr. Jack Cohen is a USFS fire physicist working in Missoula, Montana. He has devoted his entire working career researching methods to reduce the risk of fire damage to homes located in the WUI. If you aren't familiar with Dr. Cohen's research, please see attachment #11 and #3. Response: Thank you for providing this source document information. The impacts of not implementing mechanical fuels treatments in the project area are described under Alternative 1, the No Acton alternative. The Forest Service agrees with the commenter in regards to the agency s obligation to thoroughly analyze all information and opposing science brought forth from the public that relates to the project. A review of the documents referenced in the commenter s Attachments # 3 and # 11 are located in the project file for the Bunker Area Derecho Fuels project file (Vol. 2, Tab A, Document 7). Comment 3: Dr. Cohen's fire damage risk reduction methods are the most effective that exist. He does not recommend logging merchantable trees near the WUI as is being proposed with this commercial timber sale (a.k.a. a fuels reduction project). This is why he is a black-sheep in the USFS. The USFS does not want the public to learn about Dr. Cohen's research because this would eliminate another excuse to commercially log the national forests. Some of Dr. Cohen's research conclusions are quoted below. You owe it to the public to divulge this information "Research results indicate that the home and its immediate surroundings within feet (30-60 meters) principally determines the home ignition potential during severe wildland-urban fires. Research has also established that fire is an intrinsic ecological process of nearly all North American ecosystems. Together, this understanding forms the basis for a compelling argument for a different approach to addressing the wildland urban fire problem." (Pg. 1 - abstract) Source: Wildland-Urban Fire-A different approach "Extensive wildland vegetation management does not effectively change home ignitability. " (Pg. 5) "As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUJ home fire losses. " (Pg. 5) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented at the Fire Economics Symposium in San Diego, California on April 12, otherlrmrs 1999 cohen jool.pdf "Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands. " (Pg. 4) F-7

8 "Past reports and recommendations as well as experimental research and modeling suggest that W-UI fire-loss mitigation should concentrate on the residence and its immediate surroundings. Any strategy for effectively reducing the W-Ul fire problem must initially focus on residential fire resistance." (Pg. 5- Conclusion) Source: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, other/rmrs _1997_ cohen _ j001.pdf "Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-Ul fire loss problem." (Pg. 9) "Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction." (Pg. 10) "Thus, wildland fuel reduction that is effective for reducing the wildland fire intensity might be insufficient for reducing the destruction of highly ignitable homes. In contrast, a low home ignition potential reduces the chances of fire destruction without extensive wildland fuel reduction. These findings indicate that the W-UI home fire loss problem is a home ignitability issue largely independent of landscape fuel reduction issues." (Pg. 10) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, wildlandfirethreat.pdf "Vegetation management to prevent ignitions from radiation does not require extensive vegetation removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for a 20 meter flame height."(pg. 86- Conclusions) Source: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management Presented at the 13th Fire and Forest Meteorology Conference. Lome, Australia, "Many scientists and natural resource agencies suggest extensive fuel treatments to reduce the possibility of severe and intense wildfires that could damage ecosystems, destroy property, and take human life (USDA Forest Service, 2000; GAO, 2003a,b). However, there are a number of misconceptions and misunderstandings about fuel treatments and their use as a panacea for fire hazard reduction across the United States (Finney and Cohen, 2003; Franklin and Agee, 2003)."(Pg.1998) "Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ''fireproof'' important areas. It would be virtually impossible to exclude fire from most temperate terrestrial ecosystems because ignition sources are prevalent and fuels cannot be eliminated. Ignition is rarely affected by fuel treatment." (Pg.1998) "Bessie and Johnson (1995) show weather (fuel moisture and wind) is far more important than fuels in determining fire behavior; reducing fuels may have a limited impact on fire occurrence." (Pg.1999) "Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counterproductive." (Pg.1999) "It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, and the degree to which the residential structures themselves can ignite that determine if the residences are vulnerable." (Pg.1999) "Thinning to reduce crown fire potential requires careful evaluation of the tradeoffs in treatment effects on potential surface fire behavior and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result in increased potential surface fire behavior, for several reasons. First, thinning reduces the moderating effects of the canopy on windspeed, so surface windspeed will increase (Graham et at., 2004). It also results in increased solar radiation on the forest floor, causing drier surface fuels. It may also cause an increase in flammable grassy and shrub fuels over time, due to the reduced tree competition." (Pg.2000) F-8

9 "Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire." (Pg.2000) "Treating fuels may not improve ecosystem health. Ecosystem restoration treatment and fuel treatment are not synonymous. Some ecosystem restoration treatments reduce fuel hazard, but not all fuel treatments restore ecosystems. Ecosystem restoration treatments are often designed to recreate presettlement fire regimes, stand structures and species compositions while fuel treatment objectives are primarily to reduce fuels to lessen fire behavior or severity- this is known as "hazard Reduction." Achieving fuel hazard reduction goals in the absence of ecosystem restoration is insufficient (Dombeck eta/., 2004; Kauffman, 2004)."(Pg.2000) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, rewise.org/lnformation/research-and-guidance/w-u- I-Home- Ignition Research/~/media/Firewise//Files/Pdfs/Research/CohenFuelTreatment Dr. Cohen recommends removing fine flash fuels within a few hundred feet of a home at risk. That's why kindling is used to start a fire in the fireplace, Response: See response to Artley, September 20, 2012, Comment 3 Comment 4: If the Scoping Report for the Bunker Area Derecho timber sale is not changed and the new Scoping Report does not contain a Dr. Cohen alternative analyzed in detail it will be necessary to inform the public in your area about Dr. Cohen's fire risk reduction methods myself. Any manager of public land with knowledge of Dr. Cohen's methods (which this letter provides for a Federal District Court judge) would be subject to arrest should a fire break out and people living in the WUI are hurt and/or their homes are damaged. This is explained below. "E. Personal Liability For Violation of Environmental Laws. In most cases, Federal employees are named as defendants in their official capacities because the actions in question are usually undertaken by virtue of their official authority. These cases generally proceed without risk of personal liability for the employee. In some cases, however, a Federal employee may be sued in his/her individual capacity for injuries or damages to persons or property. Individuals who violate environmental laws or who injure or damage the persons or property of others as a result of carelessness may be personally liable for the consequences. Environmental cases involving the USGS may be brought against the USGS itself, some smaller component, or individual employees. The individual employees may be named because the USGS can act only through its employees. (1) Personal Liability for Injuries or Damages to Persons or Property. Where the actions of a Federal employee cause injuries or damage to the person or property of another, the injured party may bring an action to recover the cost of the damage." Source: USGS Manual- Chapter 3 This also applies to USFS employees. Response: See response to Artley, September 20, 2012, Comment 4 Comment 5: My Pending Media Contact F-9

10 Unless this Decision is withdrawn I will write a letter to the editor describing Dr. Cohen's methods and your choice to keep them secret from the public. You might want to check the following newspaper daily: The Houston Herald editor@houstonherald.com My letter will suggest that the public contact you Ranger Haines and ask you why a Cohen alternative was not analyzed in the Bunker Area Derecho draft NEPA document. The public knows your responsibility to protect their safety transcends any merchantable tree manipulation you might want disguised as fuels reduction. Channeling public outrage is much more effective than the worthless objection process. I will expect to be notified as soon as you have decided to proceed with this project after all objections have been dealt with. Sincerely, Dick Artley (USFS- retired... Nez Perce National Forest) 415 NE 2nd Street Grangeville, Idaho Da99333@gmail.com CC: Acting Supervisor Chase Response: No decision has been made at this point. The treatment methods described by Jack Cohen address the area within the home ignition zone (HIZ). The HIZ is generally located on private land that is not under the jurisdictional authority of the Salem Ranger District to manage hazardous fuels. Agency WUI fuel treatments largely do not address home ignitability but rather areas outside the home ignition zone. Fuel treatments are designed to reduce the fuel hazards and increase opportunities to safely engage with fire suppression operations. KENNETH SWINEY September 21, 2012 Comment 1: Proposed prescribed burning will kill insects that are harmful to timber and will improve overall timber conditions. Response: Thank you for your support. RONALD MULACH, Office of the General Counsel September 24, 2012 Comment 1: Please add name to project mailing list. Response: Name added to mailing list. Response sent. September 28, 2012 F-10

11 Comment 1: Thank you for adding name to the list Response: No response necessary. KENNETH PARKER September 24, 2012 Comment 1: Please remove name from mailing list. Response: Name removed from mailing list. No response needed. LOUIS CLARKE, U.S. Army Corps of Engineers, Little Rock District September 25, 2012 Comment 1: Concerns with fuel breaks planned near nine ponds and one intermittent stream. No permit needed if these areas are mitigated. Response: Response sent; ID Team will look at mitigating these features. October 24, 2012 Comment 1: Initial assignment letter for project. Review action number is #SWL Response: Thank you. The proposed action has been modified to exclude the features of concern. BRUCE DARNEL September 25, 2012 Comment 1: Please send future mailings electronically. Response: No response needed; any future mailings will be electronic only. AMANDA/SAM GORDON September 27, 2012 Comment 1: Attended public meeting. The project is a "well thought out plan, that will give the best chance to curb a major wildfire." Response: Thank you for your support. Comment 2: Has concerns that fuel breaks will open illegal access (ATV, etc.) to private lands. F-11

12 Response: Mark Twain National Forest personnel will work with individual landowners that have illegal access concerns so that the proposed fuel breaks will still restrict access, particularly from forest system roads, to their property. Comment 3: Would like to see fuel treatment units opened to woodcutters after the service contracts have ended. Response: Most payment units, after timber contracts are closed, are usually opened to woodcutters under a valid wood permit. This would also be the case with the service units proposed in this project. Comment 4: We are still removing blowdown fuels from our property. What can we do to help the Forest Service on our property Response: Removal of blowdown fuels from private property will extend the benefits of the proposed fuels break treatments in this project. For more information on how you can better protect your property from wildfires, visit the homeowners education section of the firewise website at: Comment 5: "There are a lot of landowners that are not cutting and removing the blown down timber. Maybe after this plan is completed then educating landowners and offering advice for the landowners who are not removing the fuels that are there, would be something that should be looked into." Response: The Forest cooperates with state and county governments to educate the public on how they can reduce fire risk around their properties. The Mark Twain National Forest has a history of working with local agencies, authorities, and media in the Bunker area to educate the public on homeowner wildfire protection (Project Record, Vol. 1, Tab A, Document 3). For more information on how you can better protect your property from wildfires, visit the homeowners education section of the firewise website at: Comment 6: I believe that if everyone works together then we can solve this problem before it becomes a disaster. Please keep me informed on your progress, any changes that you come up with and any way we can help. Response: Thank you for your support. We will keep you informed on project developments. JACK SADLER, J98 Radio September 27, 2012 Comment 1: Please add J98 radio to the project mailing list. Response: Name added to the mailing list. SARA VANDERFELTZ, Administrative Assistant, State of Missouri, Office of Administration, Commissioner s Office October 2, 2012 Comment 1: "The Missouri Federal Assistance Clearinghouse, in cooperation with state and local agencies interested or possibly affected, has completed the review on the above project application. None of the agencies involved in the review had comments or recommendations to offer at this time. This concludes the Clearinghouse's review." F-12

13 Response: Thank you for your participation. JOY TUCKER October 5, 2012 Comment 1: Feels that the project is a good idea. Response: Thank you for your support. CRAIG WILLIAMSON/ALICE STERKEL October 10, 2012 Comment 1: Mr. Williamson and Ms. Sterkel are local landowners who are concerned that the proposed fuel breaks will open illegal ATV access to their property that were previously blocked by blowdown. Response: Mark Twain National Forest personnel will work with individual landowners that have illegal access concerns so that the proposed fuel breaks will still restrict access, particularly from forest system roads, to their property. MICHAEL J. HASSERT October 15, 2012 Comment 1: "Thank you for including and informing adjacent landowners of the meeting in Bunker, regarding the Bunker Area Derecho Fuels." Response: Thank you for your attendance at the meeting and your interest in the project. Comment 2: "I agree with the need to control fuel loads in this area." Response: Thank you for your support. Comment 3: "As stated in the meeting, my concerns as an adjacent landowner are sealing and controlling access roads after the NFS have dozed Fire Lines and Timber Reclamation access roads. I have had numerous Trespass Violations from "A" highway, down to Gordon and Sinking creeks to County Road 5610 and across my front yard. Please address this in your plan." Response: Mark Twain National Forest personnel will work with individual landowners that have illegal access concerns so that the proposed fuel breaks will still restrict access, particularly from forest system roads, to their property. Comment 4: "It would help also to provide landowners in this area of dates of prescribed bums... a simple call or letter would alleviate many concerns from landowners, when the smoke starts to build in the hollows. Response: The Mark Twain attempt to contact those landowners who request notification of prescribed burn scheduling. Usually, prescribed burn implementation is dependent upon development of the weather parameters called for in the burn F-13

14 plan. It is, therefore, difficult to give an exact date for burn implementation as these weather parameters may or may not develop. The Mark Twain contacts local 911 dispatch centers to make them aware of any prescribed burn activity so that they can better respond to calls from the public. TOD KINERK October 15, 2012 Comment 1: "Glad to see you are doing something. P.S. An active timber sale program is the best." Response: Comment noted. Thank you for your support. WILLIAM MACKEY October 18, 2012 Comment 1: Supports project goals. Response: Thank you for your support. Comment 2: Would like to be contacted in advance of the Hodge Hollow Burn implementation. Response: The Mark Twain attempt to contact those landowners who request notification of prescribed burn scheduling. Usually, prescribed burn implementation is dependent upon development of the weather parameters called for in the burn plan. It is, therefore, difficult to give an exact date for burn implementation as these weather parameters may or may not develop. The Mark Twain contacts local 911 dispatch centers to make them aware of any prescribed burn activity so that they can better respond to calls from the public. DAVID PATTERSON, The Doe Run Company October 18, 2012 Comment 1: "I am in full support of the suggested treatments of prescribe burning and timber salvage on the USFS lands around Bunker, Missouri. This plan is well thought out concerning the best management of the forest resource following the devastating storm of My hope is the USFS will follow through with the prescriptions recommended by professional resource managers. My only concern is how can we speed this process up when the next disaster occurs! These treatments have been needed for the last 3 + years." Response: Thank you for your support of the project. The effect of the 2009 derecho have forced the USFS to adapt some of its land management strategies on the Mark Twain. MTNF personnel are developing strategies based on this event to make the types of adjustments which will allow us to respond to future events in a more expedited manner. ALLISON J. VAUGHN, Natural Resource Steward, Missouri Department of Natural Resources (MDNR) October 18, 2012 F-14

15 Comment 1: "The expansion of the prescribed fire program into high quality, restorable woodlands such as those found in the Grasshopper Hollow Unit, among others, represents an important and positive decision that promotes and supports the goals and objectives of the 2005 Forest Plan. The Mark Twain National Forest's award winning 2005 Forest Plan guides ecosystem restoration efforts in a manageable fashion that also supports sustainable timber management as a goal coincident with the mission of the United States Forest Service. I strongly support the objectives of the 2005 Forest Plan and its ecosystem-based management goals. The prescribed fire program, combined with the proposed thinning projects, will affect the now out-of character red oakblack oak association that exists today in the project area, thereby accomplishing the goals of achieving the desired condition for Ozark woodlands which were historically dominated by white oak species and shortleaf pine. All of the units designated for prescribed fire, including the expansion into parts of the Medley Hollow project and Grasshopper Hollow, offer prime opportunities for ecosystem restoration. All of the areas identified in the Scoping Report possess a high level of natural integrity and will undoubtedly respond positively with restoration efforts if implemented properly." Response: Thank you for your support. The ecosystem restoration effects that the commenter discusses are an important secondary benefit of the proposed fuel treatments. Most of the project area falls within Management Prescription 1.1 which the 2005 Forest Plan designates for ecosystem restoration. Many of the prescibed burns in this proposal were previously developed with the primary goal of restoration, but are now proposed to also reduce hazardous fuel load from the derecho event. Comment 2: "I recommend that salvage logging should be accomplished during dry conditions to avoid creating a situation as recently occurred in tornado blowdown areas in the Poplar Bluff Ranger District." Response: Comment noted. All mechanical fuel treatments will adhere to Forest Plan Standards & Guidelines regarding timber management (Forest Plan, 2-27 through 2-32; and EA, Appendix E). Comment 3: "I am very pleased to learn of the interest in the proposed activities to reduce fuels and to initiate largescale ecosystem restoration projects on the Mark Twain National Forest. The concepts expressed in the Scoping Report for the Bunker Area Derecho Fuels are similar to the goals and mission of the Division of State Parks and the Resource Management Section. I look forward to witnessing the results of these efforts in future years. Thank you for the opportunity to comment and I wish you well in your endeavors." Response: Thank you for your support. MTNF personnel will be contacting you to address any questions you may have. HANK DORST, Mark Twain Forest Watchers October 22, 2012 Comment 1: "Here are some comments on the project. I hope to visit with District personnel about this more today, and in days to come. Please excuse the brevity of these comments, I know they will be expanded upon in conversation. We support the concept of salvaging the Derecho blowdown if there is any value left in it. We also are aware of the need to control wildfires (or escaped prescribed fires) in a safe and effective manner, but we have some questions about the fuel break proposal." Response: Thank you for your support. MTNF personnel will be contacting you to address any questions you may have. Comment 2: "Salvage Harvest F-15

16 The stands along and off Highway A near Bunker that I looked at have already had the Derecho blowdown Harvested. (I noted they also have something I've never seen before: blank Payment Unit signs with no Sale Name or Unit#.)There is little to no red oak group species left in them, possibly a result of derecho salvage, but also possibly from previous thinning in the area. Examples of this condition include Comp 169/Std 2,4+5 and C 170/2. I'm led to wonder if this because of my admittedly small sample area or is the condition for other stands proposed for salvage harvest similar?" Response: The stands along and off Highway A were harvested as a part of the 2010 Salem Blowdown Roadside Salvage project with harvest blowdown timber from a 300 ft corridor on each side of most forest system roads in the project area. We will check with our sale administration staff about the payment unit signs. Since this project was scoped, it has been determined that there are not enough standing specimens left in these stands to constitute salvage harvest through commercial timber contracts. Instead, these fuel breaks and those located on the ridgetops will be accomplished through service contracts with salvage rights to the material available to the contractor. Comment 3: "There is little if any marketable product in these stands, so I'm wondering why they are included in the project. To answer that question, possibly, did I not go far enough off the roads to get past the 300' roadside salvage of the last few years? I was focused on getting into as many stands as possible in a short time and maybe didn't get far enough off the roads. However, I do recall that there was a proposal on the District the map of which included whole stand boundaries in Derecho salvage rather than only roadsides." Response: Since this project was scoped, it has been determined that there are not enough standing specimens left in these stands to constitute salvage harvest through commercial timber contracts. Instead, these fuel breaks and those located on the ridgetops will be accomplished through service contracts with salvage rights to the material available to the contractor. Comment 4: "There are no Burn Units in the salvage harvest areas-why is that?" Response: The salvage harvest units were originally proposed to remove hazardous fuels from areas where there are large private land inholdings that would make prescribed burning infeasible without permission from the land owner. Since this project was scoped, it has been determined that there are not enough standing specimens left in these stands to constitute salvage harvest through commercial timber contracts. Instead, these fuel breaks and those located on the ridgetops will be accomplished through service contracts with salvage rights to the material available to the contractor. Comment 5: "What is the estimated volume to be harvested?" Response: With the transition from accomplishing the fuel treatments through timber sale contracts to service contracts, it is difficult to make volume estimates of how much material may be salvaged. A conservative estimate would be about 4 mmbf. Comment 6: "Is any blowdown in these stands really commercially viable given the 3+1/2 years since the blowdown event?" Response: While the merchantability of the blowdown timber has declined considerably, there continues to be a viable market for salvaged material. However, since the proposed fuel treatments are now to be accomplished through service contracts rather than timber sale contracts. The salvage rights to blowdown material are a secondary benefit to the contractor. F-16

17 Comment 7: "Is the proposed salvage harvest focused more on capturing red oak mortality than to remove blowdown?" Response: Since this project was scoped, it has been determined that there are not enough standing specimens left in these stands to constitute salvage harvest through commercial timber contracts. Instead, these fuel breaks and those located on the ridgetops will be accomplished through service contracts with salvage rights to the material available to the contractor. The project has always been primarily focused on reducing blowdown fuel loading. The lack of standing specimens greatly reduces any benefit for treating red oak mortality. Comment 8: "The proposal notes a dozer line around the salvage harvest units ({at a width of 20' to allow...marking personnel to safely layout boundaries around sale blocks." Since boundaries are marked from the inside of the stand, we don't see the need for this amount of ground disturbance (a projected total of 20 miles.) Could you explain the logic here? Is this really intended as a fire break?" Response: Since this project was scoped, it has been determined that any improvement to safety conditions for timber marking personnel by this connected action would be negligible. Therefore, it is no longer included in the modified proposed action. Comment 9: "Fuel Breaks The project proposal states, on ridgetops, ({Fuel continuity will be broke up by mechanically or hand piling the slash for burning, mastication, or hauling off-site." The total fuel break acreage is about 7300 acres. I noted on the Bunker West Burn Unit that this includes all the main ridgetops, and that appears to be the case in the other burn units. These actual activities are somewhat hard to visualize given the conditions I observed. Looking at the old ridge roads and ridge skid trails in the Bunker West Burn Unit, which as stated has been burned before, I saw old clearcuts and thinnings with some blowdown off the ridgetops, but not much. Along the ridge road south of ({A" nearly directly across from County Road 562 there is some scattered blowdown on the east side, little if any on the west side." Response: Based on further field review and comments from the public, several areas that were proposed fuel treatments in the project scoping report were excluded from the modified proposed action due to the identification of alternate means access for firefighters to areas in the blowdown interior. Several proposed locations with steep topography, unstable slopes, or other implementation concerns were also dropped from the modified proposed action. In addition to these modifications, a few of the areas proposed for ridgetop fuel breaks were identified as requiring more intensive fuel removal treatments based on the arrangement and amount of fuel loading and proximity to values at risk. The total fuelbreak acreage in the modified is approximately 9,309 acres, but includes approximately 4,453 acres that were originally proposed for salvage harvest. Comment 10: "We trust the idea is not to entirely doze off 300' widths along all of these ridge roads/skid trails/ ridgetops?" Response: That is correct. In most cases, the fuel breaks would be a maximum of about 20' in width and will usually be much less. In most cases, the dozer will push blowdown material off the fuel break while trying to minimize soil disturbance. Comment 11: "Creating and burning multiple fuel piles from scattered downed trees across that many acres sounds problematic. Hauling it off sounds pretty expensive. Mastication, presumably onsite chipping, sounds like the most practical of the methods listed. F-17