APPENDIX B Letters from Other Agencies

Transcription

1 APPENDIX B Letters from Other Agencies

2 Oregon Kate Brown, Governor Department of Fish and Wildlife Deschutes Watershed District East Region Parrell Road Bend, Oregon (541) FAX (541) April 4, 2016 Stacey Forson, Ochoco National Forest Supervisor 3160 NE 3 rd Street Prineville, OR RE: Ochoco Summit Trail System Project Supplemental Draft Environmental Impact Statement Dear Ms. Forson, This provides Oregon Department of Fish and Wildlife (Department) comments on the Ochoco Summit Trail System Project (OSTS) Supplemental Draft Environmental Impact Statement (SDEIS) dated February The project proposes to develop a mile off-highway vehicle (OHV) trail network across more than 300,000 acres on the Ochoco National Forest (ONF). The trails will accommodate a variety of motorized OHVs including motorcycles, ATVs, Jeeps and 4x4 trucks, and side-by-side buggies. It is the policy of the State of Oregon, as mandated by Statute, that fish and wildlife resources be managed to prevent serious depletion of indigenous species and to provide optimum recreational and aesthetic benefits for present and future generations of the citizens of Oregon (ORS ). Thus, Department comments focus on impacts to fish and wildlife by the OSTS. In various iterations, planning for the OSTS has been ongoing since The Department has participated in every phase and consistently recommended ONF select the No Action Alternative (Alternative 1). The Department acknowledges development of the preferred alternative (Alternative 5) in this most recent SDEIS as an attempt to minimize resource impacts with the OSTS. However, while this alternative exhibits modest improvements over the previously proposed Alternative 2, Alternative 5 will continue to result in substantial negative impacts on watersheds, fish and wildlife within the planning area. Therefore, after evaluating all action alternatives, the Department again recommends Alternative 1, No Action, due to the following concerns about the long term negative impacts of the OSTS to fish and wildlife resources:

3 Page 2 of 5 Aquatic Impacts: o Redband trout (State of Oregon and USFS Region 6 sensitive species) populations in the Crooked River subbasin are genetically distinct (Currens 1994). Basin wide, these populations are not well distributed and in low abundance. This is a function of a multitude of anthropogenic factors. Populations on ONF, particularly the North Fork/Deep Creek watersheds are considered strongholds for the species (ODFW 1996, Stuart 2007). However, monitoring conducted by the Department from indicate that most populations exhibit a declining trend. Multiple factors impact fish abundance, however, frequently the primary influence is degraded habitat. This is manifested in streams through poor width/depth ratios, high sediment load and elevated temperatures, resulting from the cumulative impacts of past and present livestock grazing, timber harvest and high road density. Implementation of the OSTS will continue further degradation of habitat and stress sensitive redband trout populations. o The OSTS proposes closures/rehabilitation of user-created roads as mitigation for increases in sediment delivery but there is no mention of specific plans or dedicated funding for that purpose. o The sediment analysis states that when compared to natural background sedimentation the action alternatives are estimated to contribute insignificant amounts to alter instream width/depth ratios (SDEIS p. 180). However, no quantitative estimates are given and there is no mention of whether background levels take into account the sediment currently being delivered by grazing and other disturbance causing activities. o The SDEIS is lacking analysis of potential runoff associated with summer thunderstorms. These brief, acute pulses are frequently an important contributor to sediment delivery. o The SDEIS acknowledges that ONF is currently not meeting federal Clean Water Act and State water quality standards and that all alternatives have potential negative impacts to water resources (p. 449). Wildlife Impacts: o Under the action alternatives, ~40% of the project area is within 200m (e.g. SDEIS p. 304) of a motorized route. Almost 2/3 of the project area is classified as summer range which provides important fawning and calving habitat. The OSTS poses the potential for long-term disturbance to Rocky Mountain elk and deer (ONF Management Indicator Species) seeking to

4 Page 3 of 5 raise their young on ONF and could have wider negative population effects. o Despite previous Department recommendations, the SDEIS does not use the USFS Blue Mountain Elk Nutrition and Habitat Model (Model) to predict elk habitat use in the OSTS project area under any of the action alternatives. The Department recommends that the OHV trails mapped in the action alternatives be classified in the Model as Class 2 to reflect higher traffic volumes that will result from the OSTS. o The Resource Report and Biological Evaluation for Terrestrial Wildlife (Report) that accompanies the SDEIS provides an analysis of the OSTS s impacts to elk movement onto private land (p. 63). As stated in the Report, elk tend to move from ONF onto private properties in the fall and winter as summer forage declines with the season. This analysis states that the OSTS will not further displace elk onto private land because they will have adequate security cover on bordering ONF lands. This analysis is unsubstantiated. However, if elk were to utilize these areas as the Report predicts, they would likely be enticed to visit the private agricultural properties just across the ONF boundary. Furthermore, as OHV use will be allowed throughout the summer, elk will likely move onto private lands 2-3 months earlier than is occurring currently. The Department s mission includes working with landowners to ameliorate loss of agricultural crops to wildlife (as described in ORS ). By increasing use of private lands in summer, elk will be depleting resources traditionally available for their winter maintenance. This will further strain forage availability as well as the patience of landowners who have been tolerating moderate elk use of their lands. o For the above reasons, a thorough analysis of the potential effects of the OSTS on elk and deer is lacking. There are no assurances that wildlife will not be further displaced from ONF onto surrounding private properties resulting in more agricultural damage and loss of public hunting opportunities. o The Department appreciates the consultation of the U.S. Fish and Wildlife Service (USFWS) regarding the presence of the federally listed gray wolf (Report p. 12). However, this consultation is dated In the four years since, wolf abundance and distribution in Oregon has changed substantially. According to Department records, from , the wolf population more than doubled and areas occupied by wolves expanded toward the OSTS project area. Therefore, the Department recommends ONF consult with USFWS again regarding the OSTS s effects on the gray wolf.

5 Page 4 of 5 Habitat Impacts: o Development of an extensive OHV trail system runs counter to the ONF Land and Resource Management Plan (LRMP) objective to maintain or enhance ecosystem functions. There are currently 674 miles of open mixed-use roads on the Forest. Alternative 5 proposes an addition of 135 miles, a 20% increase. o Existing user-created roads are not considered by the SDEIS (p. 60). Therefore, all provided analyses of effects of road densities are flawed and inaccurate. o The SDEIS does not mention the recently proposed USFS Blue Mountains Resiliency Project which will impact 120,000 acres of ONF. This project has the potential to reduce hiding cover for wildlife and increase road density in the OSTS project area with a coincidental negative impact on fish and wildlife resources. Recreation Impacts: o The project would not serve the majority of the users of ONF. According to a National Visitor Use Monitoring Survey, many more respondents cited participation in hunting (22%), fishing (25%) and viewing wildlife (59%) than OHV use (4%) (SDEIS p.433). o Enforcement of OSTS use is dependent primarily on Central Oregon's Combined Off Highway Vehicle Operations (COHVOPS) volunteers and OHV users self-policing. There is no dedicated funding identified for monitoring and enforcement. Furthermore, there is no analysis provided to show the effectiveness of this model for curtailing unauthorized OHV use (e.g. construction of user-created roads or use outside of the designated riding season). o The OSTS project area effectively occupies half of the ONF and will likely negatively impact non-motorized recreation activities throughout that area. In the areas of ONF without OHV trails, existing user-created trails are likely to persist with unregulated OHV use. The OSTS project is therefore additive in terms of OHV use, not compensatory. o The Department has serious concerns about the level of OHV use that will occur on ONF as result of this project. The SDEIS mentions that ridership on the OSTS will increase at a rate of 2-5% per year and will provide alternative summer riding options when other lower elevation trail systems are too dry, hot and dusty to enjoy (SDEIS p.98). This analysis is weak, unsubstantiated and provides little or no reliable information.

6 Page 5 of 5 Throughout, the SDEIS discusses Alternative 1, No Action, as detrimental to the condition of ONF under the rationale that if no trail system is developed then user-created roads will increase and OHV presence on the landscape will be unmanaged. In fact, many actions can and should be occurring according to the goals of the ONF LRMP to improve forest condition (e.g. rehabilitating user-created roads). In addition, ONF should demonstrate effective funding and complete implementation of the nationally mandated Travel Management Plan prior to considering expansion of motorized recreational use through an OHV trail system that has the potential to negatively impact fish and wildlife resources as well as other forest user groups. If ONF takes these actions, it will be on track to minimize damage to public natural resources as outlined in Executive Order Thank you for the opportunity to comment. If you have questions or want information that the Department can provide, please contact me. Sincerely, Sara Gregory Wildlife Habitat Biologist Deschutes Watershed District sara.c.gregory@state.or.us

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