1- Wilkins Project Response to Comments

Transcription

1 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : I would suggest increasing the size/area of this project to make it a landscape scale type of project. Since NEPA costs are the same whether the project is 6,000 acres or 60,000 acres, it would be more cost efficient and effective to create a landscape scale project. BC-1 1 NEPA, SILV Response: As each new project is developed, we carefully consider why we need to enter or treat an area, considering the current conditions and the desired future conditions as outlined in our Forest Plan. Through this process we define the purpose and need for an activity. The economics of analyzing a project (including economies of scale) do play a role in considering a proposed action but they are not the main driving factor, it is the resource conditions that carry a heavier weight on what area to treat. In this specific case, while we could have looked at a much larger area, a larger area would have increased the complexity of the analysis. After considering all the information at hand, the District Ranger decided to focus on the approximately 6,000 acres that is the Wilkins Project area. It is within the line officer s decision space to designate the project area. : I appreciate the new approach that the Forest Service is taking with this project in soliciting comments prior to the full analysis. This approach is more efficient in addressing specific areas of concern. BC-2 1 NEPA Response: Thank you for your comment. : Economics should always be a key issue when formulating alternatives. BC-3 1 ECON Response: Economics are considered as alternatives are developed, but they do not drive the alternatives. An economic analysis is part of the Wilkins environmental analysis (see pages ). Economics were not identified as a key issue for this project (see pages 8-9 for Key Issues Identified During Scoping). BC-4 1 ECON, TM : It is increasingly important that the Forest Service work to ensure that these infrastructures [timber industry] remain viable in order to maintain management on the national forests. Response: It is important to distinguish the effects of a single project from those of a forest program. Addressing the issue of maintaining infrastructure in the timber industry is a Forest Plan level decision, not that of a single project, such as we are analyzing in the Wilkins Dry Forest Restoration Project. However, the Umatilla National Forest recognizes that the wood products industry is important to the economy of the surrounding communities. Part of the purpose and need for this project recognizes this situation (see pages 4-5 for purpose and need). 1- Wilkins Project Response to s

2 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : Without a sustainable supply of wood, the infrastructure will continue to decline and Northeast Oregon will face the same situation that New Mexico and Arizona face, uncharacteristic wildfires and no timber infrastructure. BC-5 1 ECON Response: It is important to distinguish the effects of a single project from those of a forest program. Addressing the issue of maintaining a sustainable supply of wood over time is a Forest Plan level decision, not that of a single project, such as we are analyzing here in the Wilkins Dry Forest Restoration project. However, we recognize that the wood products industry is important to the economy of many of the communities in and around the Forest. Part of the purpose and need for this project recognizes this situation (see pages 4-5 for purpose and need). : Please include an economic analysis of the number of jobs created/maintained by this project. BC-6 1 ECON Response: An economics analysis containing an economic viability analysis is located on pages of the. An analysis of the indirect benefits of the Wilkins Project (such as the number of jobs created/maintained) is located in the project file ( Wilkins.Economics.Indirect Benefit Calculation.xls document). The estimated number of jobs per million board feet (jobs/mmbf) is between 16 and 20 (20 for Alternative 2, and 16 for Alternative 4). : Please make the proposed masticated material optional for the purchaser. BC-7 1 TM Response: Thank you for your comment. There are options for allowing an interested purchaser to buy the small material. : Treating only 15% of the project area through commercial harvest is not appropriate. BC-8 1 SILV Response: This is the opinion of the commenter. The decision of how much of the project area to treat is made by the Forest Service responsible official. This decision is based on the careful consideration and hard look of scientific analysis of effects of the purpose and need for action, and the various alternatives being considered. : The document states that 1,990 acres were removed because they were not a priority for harvest. Will they become a priority in the next years? BC-9 1 SILV Response: Largely, these acres did not have a great need for dry forest restoration in the form of thinning. In the initial stages of planning a project, the silviculturist considers all the forested acres and then determines the potential for moving forward with some sort of treatment to meet the Purpose and Need. In the case of Wilkins, these 1,990 acres were considered less of a priority due to their current condition, i.e. they were already less dense or of appropriate species mix for the potential vegetation group. The acres are still within proposed prescribed burning areas which will reintroduce fire into these drier 2- Wilkins Project Response to s

3 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; stands. Some stands are in the condition that they may have large openings with a few clumps of trees which could benefit from commercial thinning, but the actual area is so small that it would be unfeasible economically to commit the resources to accomplish it. In some cases, acres were dropped as proposed unit boundaries were fine-tuned on the ground, considering RHCA locations, access, logical harvest operations, etc. : If they are not treated now, what will the future structural class be for these non-priority stands? BC-10 1 SILV Response: All stands could potentially reach OFSS on their own where trees exist, especially if prescribed fire is used and maintained on a scheduled basis. Some of the drier ponderosa pine stands that we chose not to treat are on the very dry/rocky end of the spectrum and may not have the capacity to grow large trees unless individual site conditions or water availability changes. Many stands are likely to remain in the stem exclusion stage as trees compete for scarce moisture. BC-11 1 NEPA, SILV : Treating this additional acreage will increase the economies of scale for the project as well as provide NEPA shelf-stock for future timber harvest targets for the Umatilla. Response: See responses to BC-8, BC-9, and BC-10. : Under the proposed action it states that the stands that are commercially thinned followed by non-commercial thinning will remain fully stocked. What will these stands look like years from now? Will they need additional entries for maintenance purposes? BC-12 2 SILV Response: Combining the commercial and non-commercial thinning is a way to allow us flexibility in treating the individual stand conditions. If a stand has a large portion of commercial sized trees, we have the ability to thin and remove these trees and realize the economic benefits of the thinning as well as increasing the growing capabilities of the remaining trees. However, if a portion of this same unit has a large area of non-commercial size trees, we have the flexibility to thin these as we would in any NCT unit. All thinning stands, whether commercial or non-commercial or both together, will have a stocked stand after all treatments are completed. BC-13 2 SILV, FUELS : Creating moderately stocked stands will further reduce fuels as well as allow the stands to grow into a fully stocked state instead of allowing them to become overstocked again the future. Response: The need to further reduce stand densities was not identified in the Wilkins area. Reducing stand density below fully stocked would be considered a regeneration harvest, and the need for this treatment was not identified in the project area. 3- Wilkins Project Response to s

4 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : Please describe the potential volume and type of wood fiber slated to be removed via commercial harvest. What is the saw to non-saw ratio of for this material? BC-14 2 SILV, TM Response: Potential volume removed is expected to be 2 to 2.5 million board feet. Based on field samples, an estimated 10% of the total removed is expected to be non-saw. Estimates of volume by alternative are found in the economics analysis, Table 3-21, page 129 of the. (saw to non-saw ratio located in Wilkins.Economics.Indirect Benefit Calculation.xls document in the project file). : What is the current tree species composition in the project area? What is the species composition of the material slated for removal? BC-15 2 SILV Response: See Appendix A Silviculture, Table 11 for current forest cover types. The material slated for removal is primarily ponderosa pine and Douglas-fir, with relatively small amounts of grand fir, western larch and other species. : Trees larger than 21 dbh do not necessarily meet the definition of old growth (trees older than 150 years). BC-16 2 SILV Response: We agree with this statement. However, removing trees greater than 21 inches diameter at breast height (DBH) was not identified by the T as an action necessary to meet the purpose and need for action in the Wilkins Project area. See, Chapter 1, pages 4 and 5. : Recently, the Wallowa-Whitman amended their forest plan for the Snow Basin Project that allowed for the removal of Grand Fir and disease infested trees larger than 21. I am attaching the resolution language that allowed for these exceptions. BC-17 2 NEPA Response: Removing trees greater than 21 inches diameter at breast height (DBH) was not identified by the T as an action necessary to meet the purpose and need for action in the Wilkins Project area. See, Chapter 1, pages 4 and 5. Resolution language was not received. BC-18 2 SILV, WILD : Please allow the removal of trees larger than 21 in order to fully meet the purpose of restoring the dry upland conditions and keep the desired mix of species for this site. Response: The purpose and need of this project is to promote the development of late and old structure stands in the dry upland forest potential vegetation group (see, Chapter 1, pages 4 and 5). Large diameter trees (>21 inches dbh) are an important component of these habitats. Removing trees greater than 21 inches dbh was not identified by the T as an action 4- Wilkins Project Response to s

5 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; necessary to meet the purpose and need for action in the Wilkins Project area. : One way to mitigate these costs [layout and marking costs] is to implement designation by description (DxD) or designation by prescription (DxP) methods. BC-19 2 TM Response: Thank you for your comment. : Please select the tree selection vehicle [leave tree or individual tree] that will be the most cost effective. BC-20 2 TM Response: Thank you for your comment. : Please identify the forest type and structural classes (stem exclusion, OFSS, OFMS) in the proposed project area and confirm that the prescriptions will bring the area into the desired future condition. BC-21 2 SILV Response: See Appendix A Silviculture. s A-10 thru A-19, current conditions; pages A-26 thru A-27, direct/indirect effects of action alternatives. All alternatives are designed to move stands toward the desired future condition, however the desired future condition is not attainable in one step with one set of treatments. The treatments proposed for Wilkins are designed to start individual stands on the path toward desired future condition, by influencing species composition, favoring healthy/large trees, and improving growing conditions. BC-22 2 BC-23 2 SILV, WILD, FISH, HYDRO SILV, TM, WILD, HYDRO, : The FS should define a desired outcome or condition for the acres treated commercially rather than define the type of equipment necessary. Response: The Wilkins Project purpose and need (see, pages 4-5) defines the desired outcome of the project. Additionally, each management area has desired future conditions defined in the Forest Plan. Desired future conditions may include restorative actions and mitigations. In analyzing the potential effects of a project, the method by which mechanical treatments will be done (i.e. ground based, skyline, etc.) is defined, not necessarily the type of equipment. Defining these methods is important in determining and narrowing down potential effects of the action. : The FS needs to allow the contractor to determine the best and most economical way to harvest the trees that will achieve the desired condition. Response: In order for the NEPA document to adequately evaluate the effects of a proposed action, the analysis needs to be 5- Wilkins Project Response to s

6 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; SOILS project and site specific. However, if a purchaser were to define more efficient ways to perform the work, NEPA does allow for changes to be made under Chapter 18 of FSH , provided that the effects of such a change are still within the bounds of the analysis. If the change is of such scope that the must be revised a new decision and FONSI would need to be prepared. : By properly laying out the sale, the FS can address the high costs of treating non-commercial areas and accomplish the goal of the project while being economically positive. BC-24 2 SILV, TM Response: Thank you for your comment. : Moving the area towards desired future conditions through the use of HRV is a necessary goal and will increase the overall stand health by reducing the competition between trees. BC-25 2 SILV Response: This is part of the purpose and need of the Wilkins Project. See pages 4-5 of the. : A study from the Starkey Elk Experimental Station indicates that thermal cover is not necessary for Elk; please take this into account when designing this sale. BC-26 2 WILD Response: The paper cited (Cook et al. 1998) found that the weather-moderating effects of thermal cover are too small, occur too in- frequently, or are too variable to provide meaningful benefit to elk during the winter and thermal cover fails to improve performance of elk in the summer. This research does not state that cover is not necessary for elk; it states that the observed selection of cover by elk cannot be attributed to thermal (thermoregulatory) reasons. The authors go on to say that despite the fact that they found no significant thermoregulatory benefits of thermal cover to elk, the observed selection of elk for cover stands likely involves the need for security and reduced vulnerability to hunters, energy savings from reduced snow deposition and associated costs of locomotion, or forage conditions, and that managers should refocus from thermal cover to these other aspects of forest cover. Regardless of the findings of this research, the Forest Plan contains standards for cover habitat in the E2 management area. These standards would be amended under all 3 of the action alternatives to move the analysis area toward the desired future condition for vegetation. See, Chapter 2, and MIS (elk) effects analysis in Chapter 3 (pages 86-89) and Appendix F (pages F-31 through F-40). : Please consider using variable density thinning to emulate the natural forest. BC-27 2 SILV Response: See Appendix A, page A-20. Variable density thinning is considered in both commercial and non-commercial treatments. 6- Wilkins Project Response to s

7 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : Please manage the lands adjacent to private land as the priority for fuels reduction. These stands should be managed near the lower management zone of the stand density index for the site. This buffer should be at least ½ mile wide and should allow the removal of all diseased and insect infested trees (regardless of size) that threaten the adjacent private land. BC-28 2 BC-29 2 SILV, FUELS NEPA, HYDRO, SOILS Response: There are no thinning or harvest units adjacent to private land, however the project area would be burned adjacent to these private lands. Protecting private land was not identified as a key issue for the Wilkins Project. The few stands proposed near property boundaries are prescribed to have treatments that will bring them into the lower management zone. Many stands were dropped from treatment for various reasons, including wildlife corridors, RHCA buffers, logging feasibility, management area restrictions, etc. : Please define what best management practices you will use when building/using the temporary roads. Response: See Appendix O, Table 1. Measures WQ5, WQ6, WQ12, WQ19, WQ27, WQ34, SL4, WQ42, WQ43 and WQ45 relate to temporary roads. : While treatments will not meet the HEI index for elk, it is appropriate to reduce the cover as this reduction will be mitigated by the increased forage opportunities. BC-30 2 WILD Response: This is the opinion of the commenter. However, HEI currently meets the Forest Plan standard in the E2 management area, and would continue to do so under all of the action alternatives. See Chapter 3 (pages 86-89) and Appendix F (pages F-26 through F-40) for effects analysis for elk. Forage improvement would occur in the short term, and would largely be limited to the spring and very early summer, as the affected stands are in the dry upland forest PVG and are ponderosa pine-dominated. Without low disturbance areas and cover (which may also moderate the curing out of forage during the summer), elk would likely move off of NFS lands to adjacent private lands regardless of season (hunting and non-hunting season) for a larger proportion of the year and for longer periods. : I did not see a mention of fire condition class, is there a goal to move this project area into a specific condition class? BC-31 3 FUELS Response: Yes, the goal is to move acres in condition classes 2 and 3 towards condition class 1. See pages 44-45, of the for discussion; Appendix B pages 8, BC-32 3 FISH, : I am pleased that management is proposed for the RCHAs. These are very sensitive areas that can be detrimentally altered in the event of a wildfire as they have higher than normal fuel loads. It is acceptable to have short term effects in these 7- Wilkins Project Response to s

8 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; HYDRO areas in order to meet the long-term fuels reduction objectives. Response: Thank you for your comment. : Currently the old forest single story (OFSS) structural class is below HRV, it is appropriate to work in the old forest multi-story (OFMS) structural class to bring the OFSS back within HRV. BC-33 3 SILV Response: Thank you for your comment. : What percentage of the current project area is in OFMS and UR? BC-34 3 SILV Response: See Appendix A Silviculture, page A-10. OFMS = 16%, UR = 60%. : I am disappointed that the Forest felt they had to issue a draft after innovatively working to speed up the NEPA process. BC2-1 1 NEPA Response: Please see response to OW-78. : Why was economics not identified as a key issue? We are continuing to lose timber processing infrastructure in this area, from forest contractors (down 26 operators since 2005) to milling infrastructure (17 mills lost in 20 years). The main reason that these companies are leaving/closing is because of the lack of federal timber available for harvest. Eastern Oregon has experienced double digit unemployment; this should be a high priority for all Forest Service Projects. Response: Key issues are identified based on comments received from the public and internal scoping. The Forest Service identifies issues related to project proposals by using the direction located in FSH , section This section states: Issues serve to highlight effects or unintended consequences that may occur from the proposed action and alternatives, giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the decision maker and public to understand. Issues are best identified during scoping early in the process to help set the scope of the actions, alternatives, and effects to consider; but, due to the iterative nature of the NEPA process, additional issues may come to light at any time. BC2-2 1 ECON An issue should be phrased as a cause-effect statement relating actions under consideration to effects. An issue statement should describe a specific action and the environmental effect(s) expected to result from that action. Cause-effect statements 8- Wilkins Project Response to s

9 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; provide a way to understand and focus on the issues relevant to a particular decision. There is no set of standard issues applicable to every proposal, so it is important for the responsible official to consider a variety of laws, regulations, executive orders and input, with the help of the interdisciplinary team. The responsible official approves the issues to be analyzed in depth by the interdisciplinary team in the environmental analysis (FSM ). It is often helpful to organize and group similar issues by common resource, cause-effect relationships, same or common geographical area, or those linked to the same action. A scoping letter was sent out in December, 2011 to the mailing list of parties who have identified themselves as interested in timber activities on the North Fork John Day Ranger District (see Chapter 1 of the, page 7 Public Involvement, and Chapter 4 Supporting Information, pages ). The project has also been listed on the Umatilla National Forest Schedule of Proposed Actions since October, The interdisciplinary team worked with the District Ranger to identify key issues. These issues were approved by the District Ranger on March 8, 2012 (see project file IssuesMeasures document). Also, see responses to BC-3, BC-4, BC-5. : Please include an economic analysis of the number of jobs created/maintained by this project. This should drive one of the alternatives. BC2-3 1 ECON Response: Economics are considered as alternatives are developed, but they do not drive the alternatives. An economic analysis is included the Wilkins environmental analysis (see pages ). However, economics were not identified as a key issue for this project (see pages 8-9 for Key Issues Identified During Scoping). Also see response to BC-6 and BC2-2. : There was a significant amount of acreage dropped from one of the alternatives (1,990 acres). It states that these acres were not a priority for harvest. What makes an acre a priority for harvest? Why were these acres dropped from the final plan? BC2-4 1 SILV Response: An alternative that treats more acres with commercial harvest is described under the Alternatives Considered but Eliminated From Detailed Study section of the, located on pages Under this description, the states that these acres were dropped for several reasons, including providing wildlife connectivity corridors as directed by Eastside Screens, and because some acres already display an appropriate species composition and stand structure for the project area. Also see 9- Wilkins Project Response to s

10 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; response to BC-9. : One of the Forest Plan Goals (15) that is applicable to this project is To provide a sustained yield of wood fiber and insofar as possible meet projected production levels consistent with the various resources objectives, standards and guidelines, and cost efficiency. With more than 5,500 acres in the Forest Plan designation of E2, Timber and Big Game, it seems that the emphasis on most of the acreage is timber production and forage enhancement. Since this area was designated for commercial harvest and wood fiber production, why is so much being left behind? Response: The goal of the E2 Timber and Big Game Management Area is to manage forest lands to emphasize production of wood fiber (timber), encourage forage production, and maintain a moderate level of big game and other wildlife habitat (Forest Plan page 4-182). Within this overarching goal, there are also specific standards and guidelines for each resource area, including wildlife. The wildlife standards and guidelines for E2 state that a minimum of 10% of the area will be managed as satisfactory cover. The current condition of the area is 7% for satisfactory cover. Additionally, the area is deficient in total cover- the Forest Plan calls for 30%, the current condition is 18% (see Table 2-1, page 16). While the Wilkins Project proposes a Forest Plan amendment to modify satisfactory and total cover, it is still within the goal of the management area to manage for a moderate level of big game habitat. Additionally, the Wildlife standards in the Regional Forester s Forest Plan Amendment 2, or Eastside Screens (USDA 1995) require late and old structural stands and designated old growth areas to be connected to each other across the landscape. Stands with the highest canopy closure and complexity in the Wilkins Project area were identified to provide the best connections between late and old structure habitat and Forest Plan old growth. Where proposed commercial thinning (conventional and skip-gap) and shelterwood harvest activities would impact the quality of these connections, treatment acres were dropped in order to maintain old growth connectivity and to meet the standards provided by the Forest Plan, as amended by the Eastside Screens (USDA 1995). See Appendix F Wildlife, pages F-13 to F-15 for further discussion on connectivity. Furthermore, there are other wildlife concerns that are considered when designing vegetation treatment units. The Forest Plan gives direction to retain or protect other habitats and their important characteristics, including raptor nests and roost sites, cliffs, talus slopes, caves, seeps, springs, bogs, wallows, and other unique habitats, calving and fawning habitat, migrational corridors, and key big game use areas. BC2-5 1 SILV Other issues, such as Riparian Habitat Conservation Areas also must also be considered, and can result in acreage being dropped from a project. It is also important to note that the Wilkins Project area of approximately 6,000 acres is not entirely forested- a large percentage of the area is actually scab flats. For all of these reasons, the acreage identified for treatment is a 10- Wilkins Project Response to s

11 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; smaller percentage of the entire project area. Also, see response to BC-9. : Please describe the potential volume and type of wood fiber slated to be removed via commercial harvest. What is the saw to non-saw ratio of for this material? BC2-6 2 SILV, TM Response: See response to BC-14. : Layout costs for the project area may be prohibitive and require extensive work from a marking crew. Paint for marking is also expensive. One way to mitigate these costs is to implement designation by description (DxD) or designation by prescription (DxP) methods. Our studies show virtually 100% success in Leave Tree Marking (LTM) units and 60-70% success in Individual Tree Marking (ITM) units in meeting NEPA Basal Area targets. Please select the tree selection vehicle that will be the most cost effective. BC2-7 2 TM Response: See responses to BC-19 and BC-20. : Appendix B states that 2,788 acres within the project area are in FRCC Class 3, meaning that the fire regime has been substantially altered. Cram et al concluded that mechanical treatments followed by prescribed fire had the greatest impact towards mitigating fire behavior (Cram et al, 2). Please consider increasing the acreage treated mechanically to move more the mixed conifer from FRCC 3 towards FRCC1. BC2-8 2 FUELS Response: The need to treat more acreage mechanically was not identified for the Wilkins Project. While a full citation to the Cram et al. reference was not provided in this comment, science by Cram is cited in the and in Appendix B. This work supports the actions proposed for the Wilkins Project. : Moving the area towards desired future conditions through the use of HRV is a necessary goal and will increase the overall stand health by reducing the competition between trees. BC2-9 2 SILV Response: Thank you for your comment. 11- Wilkins Project Response to s

12 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : Please consider using variable density thinning to emulate the natural forest. BC SILV Response: See response to BC-27. : Please manage the lands adjacent to private land as the priority for fuels reduction. These stands should be managed near the lower management zone of the stand density index for the site. This buffer should be at least ½ mile wide and should allow the removal of all diseased and insect infested trees (regardless of size) that threaten the adjacent private land. BC FUELS Response: See response to BC-28. : While treatments will not meet the HEI index for elk, it is appropriate to reduce the cover as this reduction will be mitigated by the increased forage opportunities. BC WILD Response: See response to BC-30. BC SILV, FISH : I am pleased that management is proposed for the RCHAs. These are very sensitive areas that can be detrimentally altered in the event of a wildfire as they have higher than normal fuel loads. It is acceptable to have short term effects in these areas in order to meet the long-term fuels reduction objectives. Response: Thank you for your comment. See response to BC-32. : In Appendix A, it states that Understory Reinitiation is the structural class for most of the area, it goes on to state that this structural class is over-represented in every PVG within the project area. Why is the amount of acreage set to be harvested so low? BC SILV Response: See responses to BC-9 and BC2-5. BC SILV, WILD : Why is the forest only utilizing skips and gaps in the 4th alternative? Please consider using this practice in all of the alternatives. It has been successfully implemented on the Malheur National Forest. Response: Alternatives were developed to address key issues identified during the scoping process (see, Chapter 2 Alternative Development Process ). Among these issues was loss of heterogeneity, complexity, and structure associated with shelterwood harvest and commercial thinning, and elk vulnerability/habitat quality. This issue was further developed into what 12- Wilkins Project Response to s

13 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; is identified as Issue 4 in the. To address these concerns, skip-gap commercial thinning was proposed in a small number of units in order to maintain stand heterogeneity and complexity, provide areas that would provide for density dependent tree mortality (produce snags) to a greater degree than proposed commercial thinning and shelterwood harvest units, and reduce sight distances (address elk vulnerability) to some degree. This was the basis for development of Alternative 4. The T and district ranger discussed the possibility of using skips and gaps thinning across the entire project area. A review of the existing conditions and species mix indicated that this treatment would not be appropriate across the entire project area. See page for further discussion of this alternative that was considered, but eliminated from detailed study. : On the map that was given to me, there are a great many stands of trees that are denser than the stands identified for treatments, why were these stands not identified for mechanical treatment? Can you please include a map with all of the identified wildlife corridors and special management areas in the Final? BC SILV Response: noted. There are many different reasons why individual stands were not included in the Proposed Action, including management area standards, eastside screens compliance, RHCA buffers, logging system/operations challenges, access. See responses to BC-9 and BC2-5. A map with the identified wildlife corridors is available in the wildlife section of the project file (available upon request at the North Fork John Day Ranger District). It is not included in the because the is only distributed to the public in black and white print, and the scale of the map would be distorted in small print. RI-1 1 RI-2 1 SILV, TM, WILD RD, WILD : Please ensure that maximum firewood is available after this project is completed. Too often, all species are taken for various commercial uses, leaving very little to no good quality firewood (larch, red fir, lodgepole) along roads after harvest. Snags, etc. should be left for firewood gathers within appropriate distance from open roads. Response: Personal and commercial use firewood availability is not part of the purpose and need of this project, and was not identified as a key issue. Separate decisions unrelated to this project have been made on the North Fork John Day Ranger District regarding firewood. Only those trees (live and dead) that have been designated a danger to operations would be felled along roads open to firewood gathering. Snags within proposed treatment units would largely be retained, as only those that are a hazard to operators would be felled (not removed); all others would be retained. See discussion of Project Design Criteria in Appendix O, Table 1, and the discussion of snag habitat in Chapter 3 of the (MIS: Primary Cavity Excavators - pages 90-93; MIS: Pileated Woodpecker pages 93-95) and Appendix F pages F-48 through F-73. : Please ensure that all roads are left open to the public during the dry months of the year after harvest with only seasonal/temporary closures for wet periods, big game escapement during general hunting seasons, etc. Response: As the Wilkins analysis area has open road densities in excess of Forest Plan desired future conditions, lifting 13- Wilkins Project Response to s

14 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; existing road closures was not considered under any of the action alternatives to meet the purpose and need for action identified in the, Chapter 1, pages 4 and 5. This activity was outside the scope of the Wilkins Project. To mitigate for potential impacts to elk habitat through activities designed to meet or move toward the purpose and need, road closures have been proposed under all of the action alternatives to varying degrees. See, Chapter 2, pages for a description of these activities. : Please consider enlarging the size of this project. Along with additional employment opportunity, additional funding for schools and counties will emerge with a larger project with more timber harvested! RI-3 1 SILV Response: See response to BC-1. : Along with additional employment opportunity, additional funding for schools and counties will emerge with a larger project with more timber harvested! RI-4 1 ECON Response: See responses to BC-1 and BC-3. RI-5 1 RI-6 1 SILV, ECON SILV, WILD : It appears that only 15% of the total area will be considered for harvest. This seems to be a mistake in planning and thought. Certainly, even in this size of a project, more opportunity to provide timber for employment exists! Response: See responses to BC-1 and BC-6. Harvest is not the only consideration for a forested acre in the project area; meeting the purpose and need, management area standards, compliance with eastside screens, RHCA buffers, logging systems/operations challenges, and access, are just some of the other considerations that affect whether or not that forested acre is included within the proposed action. : Please include larger trees than those of 21 for harvest when those trees are diseased or damaged. Response: Removing trees greater than 21 inches dbh was not identified by the T as an action necessary to meet the purpose and need for action in the Wilkins Project area. The purpose and need for action (see, Chapter 1, page 4-5) is to promote the development of late and old structure dry forest stands. A component of late and old structure stands is large diameter trees and snags with broken tops, decay, wind/ice/fire damage, mistletoe brooms, and other features indicative of decadence. These features are vital to a suite of wildlife species, including Region 6 Sensitive Species, Forest Plan Management Indicator Species, Neotropical Migratory Birds, and others. Additional information regarding the importance of damaged and diseased vegetation to old growth associated wildlife species is included in Appendix F. 14- Wilkins Project Response to s

15 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; RI-7 1 SILV, WILD : It is not sound scientific policy to leave unhealthy trees. Response: Thank you for your comment. See response to RI-6. : The additional harvest will also yield more jobs and more revenue for schools and counties. RI-8 1 ECON Response: See responses to BC-1 and BC-3. : Elk and deer populations increase and become stronger when feed increases in vigor and quantity. Opening the forest canopy serves that purpose. Please ensure that openings are created via timber harvest that will increase vigor and quantity of grasses and forbs while producing high-quality feed for ungulates which will equate to healthier fawns and calves and will increase recruitment of younger animals into the herds. RI-9 2 WILD Response: The effect of treatment activities on forage quantity and quality is described in the on page 88 and Appendix F, pages F-33 and F-34. While treatment activities that reduce canopy closure would improve forage quantity and quality in the spring and early summer in the short term, the loss of satisfactory and marginal cover would increase elk vulnerability to hunting, reduce areas potentially used by elk when disturbance (e.g. road use not associated with hunting) occurs during other times of year, and would likely result in elk spending less time (and shorter periods) on National Forest System lands. See the analysis of effects for elk on pages of the, and pages F-31 through F-41 of Appendix F. : I am writing to support the proposed alternative for this project from the perspective of treating the maximum volume of acres. I believe that by adopting this alternative for acres treated that the greatest good will be realized on the ground. I believe that issues of overstocking and poor stand health could be achieved through the proposed alternative. RI2-1 1 NEPA Response: Thank you for your comment. RI2-2 1 ECON, TM : Unless I ve missed something, the proposed alternative should deliver the highest volume of saw log quality wood to local sawmills. I support ensuring an adequate supply of timber available for our local economies for our timber industry for harvest. Please do an excellent job of ensuring that you follow all criteria for improving stand health, such as: take all size classes, any tree that is dead, weak, mistletoed, multi-topped, over stocked, etc. and ensure that those trees are harvested for the sake of our local economies and for the sake of the forest. 15- Wilkins Project Response to s

16 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; Response: See response to BC-6, BC-14, RI-6, and RI-7. : I do not support any proposal to close road sections as a part or portion of this alternative however. One of the issues that I deal with during firewood cutting season is that the F.S. has sold so many hazard reduction sales and has cleared so much of the available roadside wood that it is becoming increasingly difficult to locate an adequate supply of suitable firewood for my household. I do not have any other form of heat in my home so wood is it! The present direction of the F.S. regarding 1) the elimination of roadside wood; 2) the limitation of only 300' of travel off of open road (which was initiated without proper NEPA input); 3) the extreme number of miles of roads being closed by the F. S.; 4) the huge volume of area closed for old growth, riparian protection, snag retention, etc. have made the job of acquiring an adequate wood supply difficult at best. So, please do not close any additional roads, do leave all wood trees within the 300' road access distance so that those trees will be available to the wood burning public, do allow cutting of all tree species that are dead or down in all size classes and finally, stop taking all of the roadside wood from us!! Clearly, fossil fuels burning is being shown as being hard on the environment whereas burning wood has been shown to be much more environmentally friendly. Hence, burning wood is the right way to go and you (the F.S.) are making wood cutting for wood burning darn near impossible! RI2-3 1 RD, TM Response: See Response to RI-1 and RI-2. The No Action Alternative (Alternative 1) would maintain the existing road system in the Wilkins analysis area. Decisions regarding personal use firewood gathering (such as allowing cutting of currently prohibited ponderosa pine and trees larger than the existing 24 inch diameter limit) are outside the scope of this project. RI2-4 1 NEPA, TM : It is vital that the F.S. make timber harvest an integral part of providing for the health of our forests, families and communities! Our forests need the work, our members of local chambers of commerce need the business and our mills need volume to survive. The F.S. must have the present infrastructure of mills and harvest operators in tact in order to carry out the work that needs to be accomplished. If adequate timber volume isn't available for the industry to survive the infrastructure that exists will disappear and opportunity to provide the needed work in the forests will disappear with the infrastructure loss. Response: See response to BC-4. RI2-5 2 NEPA : Finally, please address the issue of the Forest Service actually making all of our national forest system that of wilderness designation (pseudo-wilderness at least) by stopping all motorized vehicle usage beyond 300-feet from open roads! Clearly if you lock all of the national forest up beyond the 300-foot zone, it isn t multiple use and must be considered as wilderness designation. The direction that the F.S. is taking to stop all motorized vehicle use outside the 300-foot zone must be stopped for the benefit of all who use the forest for other than wilderness use! Response: This comment is not specific to the Wilkins Project. There is no proposal to designate any of the Wilkins Project 16- Wilkins Project Response to s

17 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; area as wilderness. Reconsideration of the 300-foot rule (36 CFR Motor Vehicle Use designations for the Umatilla National Forest, and Umatilla National Forest Personal Use Firewood Permit Regulations) is outside the scope of the Wilkins Project. : While we believe that the Wilkins Dry Forest Restoration Project is important, we were disappointed in the scale of the project. UC-1 1 SILV Response: See response to BC-1. : We understand that the Forest Service has a finite budget and we believe that landscape scale projects that provide NEPA "shelf-stock" should be the focus of the Umatilla National Forest. By investing NEPA funds in larger project, the funds are more efficiently used which allows the forest to do more with less. That being said, we would like to offer the following comments on the Wilkins Dry Forest Restoration Project. UC-2 1 NEPA Response: See response to BC-1. : We are interested in the new approach that the Forest Service has taken with regards to this project. We look forward to seeing the results of this experiment. The Forest Service needs to continue to look for additional efficiencies within the NEPA process. Thinking outside the box is necessary in order to maintain the viability of our region and its resources. UC-3 1 NEPA Response: See response to OW-78. : In reviewing the project we noticed that economics was not a key issue in the formation of alternatives. UC-4 1 ECON Response: See response to BC-2. : We disagree with this [economics not a key issue], our rural economies are depressed an these projects are an opportunity for the Forest Service to provide jobs in the woods as well as sustainable supply of fiber to our local mills. UC-5 1 ECON Response: See response to BC Wilkins Project Response to s

18 : Identifier given to each comment beginning with the initials of the individual or organization the comment was submitted by. : The page in the comment letter received where the comment is found. Key: Specialist assigned to review comment. NEPA= NEPA, other policy, FS Plan, etc; SILV= Silviculture; FUELS= Fuels; WILD=Wildlife; FISH=Fisheries; : Forest Service Projects have a significant impact and the Forest Service needs to acknowledge their role in sustaining the local economy. UC-6 1 ECON Response: See response to BC-4. : Please include an economic analysis of the number of jobs created/maintained by this project. UC-7 1 ECON Response: See response to BC-6. : We were disappointed that only 15% of the project area was scheduled for commercial harvest. UC-8 1 SILV Response: See response to BC-1. UC-9 1 SILV, ECON : To our point above [only 15% of project area scheduled for harvest], we believe that the FS should increase the acreage treated through commercial harvest in order to increase job opportunities and material for the mills located in Union County. Response: See response to BC-1. : Why are you leaving fully stocked stands in the commercial harvest units? Wouldn't it be more efficient to take more trees and leave a stand that is not fully stocked? UC-10 1 SILV Response: Commercial thinning is an intermediate cut, designed to improve growing conditions for the existing trees, as this is the stand we would carry into the future. In this case, the proposed thinnings are designed to reduce stand densities to their lower management zones. This means they will still be fully stocked without leaving the stands understocked. The shelterwood harvest cut is a regeneration harvest, designed to remove all but the shelter trees and then reforest by planting. UC-11 1 SILV, WILD : We are of the firm belief that the 21" rule is arbitrary and all future NEPA projects should be amended to allow for the removal of trees larger than 21" in order to fully meet the silvicultural prescription for the proposed area. Response: noted. Removing trees >21 inches dbh was not identified by the T as an action necessary to meet the purpose and need for action in the Wilkins Project area (see, Chapter 1, pages 4 and 5). Large diameter trees and older trees are an important feature that contributes to existing and future habitat for old forest-associated wildlife. These features 18- Wilkins Project Response to s