PLUMAS FOREST PROJECT
A Tides Foundation Project
P.O. Box 903
Blairsden, CA 96103-0903
March 23, 2000
Wayne Johannson, Project Leader
Beckwourth Ranger District
P.O. Box 7
Blairsden, CA 96103
Dear Mr. Johannson:
This is in response to the February 16, 2000, scoping letter on the Red Clover Group Selection Project. Please note that Plumas Forest Project's (PFP) comments outlined below are in addition to those submitted on March 17, 2000, titled "Comments on the Red Clover DFPZ and Group Selection Projects" (RCDFPZ).
Comments on the Red Clover Group Selection Project (RCGSP)
Forest Openings and Seral Stage Diversity
1.) The HFQLG FEIS notes that on Eastside forests within the project area, there currently exist openings outside the natural range of variability. That is, "mid-seral and uneven-aged eastside mixed conifer and pine stands have far more and larger anthropogenic openings...than in the past," (page 3-58). Additionally, the FEIS notes, "it is probable that stands having mid-seral size class and density attributes...would be adversely impacted by group selection because these areas would be targeted for treatment," (page 3-58). The group selection cutting proposed in the RCGSP would by its very nature likely increase, in both the short- and mid-term, early seral stage attributes, "creating a further imbalance in the quantity of land now occupied by the various seral stages" (FEIS, 3-58).
Consequently, the RCGSP EA must analyze to what extent the creation of more openings within the project area will "further imbalance" seral stage diversity.
2.) Currently across eastside forest types, including within and surrounding the project area, late seral stage 6 and 7 stands occur in only small remnant patches. The FEIS notes that the acreage of such seral classes fall below the minimum 5 percent required by the Forest Plan (3-58). It is also PFP's observation that such forest types are rare on the eastside of the Plumas and in the management area encompassing the project area. As such, the Forest Service needs to analyze to what extent group selection cutting will adversely impact the preservation and recruitment of seral stage class 6 and 7 forest types.
3.) The National Forest Management Act (NFMA) requires that Forest planning efforts "shall provide for diversity of plant and animal communities and tree species (36 CFR, 219.26). NFMA also requires that:
Management prescriptions, where appropriate and to the extent practicable, shall preserve and enhance the diversity of plant and animal communities, including endemic and desirable naturalized plant and animal species, so that it is at least as great as that which would be expected to occur in a natural forest and the diversity of tree species similar to that existing in the planning area. (36 CFR, 219.27(g)) (Emphasis added.)
As such, the Forest Service must analyze in the EA whether and to what extent the proposed group selection cutting prescription will meet the foregoing NFMA requirement to "preserve and enhance" seral stage diversity and diversity of plant and animal species within the natural range of variability, both within the project area and within the management area.
Desirability of Group Selection
The Forest Service needs to evaluate in the EA whether a group selection cutting prescription is desirable or appropriate for the management area and project area. The following excerpt from a letter from Dennis Clemens (Silviculturalist, Mt. Hough District, PNF), to Tom Simonson (Silviculturalist, HFQLG EIS Team) illustrates our point:
The legislation requires us to apply group selection on approximately 45,000 acres over five years. Viewing this in the context of the conceptual framework for ecosystem management, the effect of the legislation (whether intended or not) was to establish a desired condition, i.e., that it is desirable within five years to have 45,000 acres more of early successional habitat than exists today. By implication the legislation also established that it is desirable to have 45,000 acres less of some other successional stage(s). Why this is desirable has not been documented to my knowledge. If the rationale had been documented it would help in determining where to do it. Regardless of the reasons for lack of documentation (if that truly is the case), there is a wide range of interested parties, internally and externally, who have something to say about where it should be done. The NEPA process provides that opportunity. This is a textbook example of a NEPA "significant issue" that needs to be examined and debated in a collaborative spirit by the public and interdisciplinary resource specialists during the environmental analysis." (Emphasis in original.)
Group Selection: Location and Amount
To address concerns about openings and seral stage diversity the location of individual group selections needs to be part of the environmental analysis. Additionally, in order to better assess environmental effects, the analysis should determine the number of acres of group selection that will be based on forest health and the number of acres that will be economically based.
New Road Construction and Road Reconstruction
In addition to the comments outlined below, please refer to PFP's March 17 comments on the RCDFPZ that discuss reasons for not constructing new roads.
Since the proposed RCGSP proposes constructing new roads in RHCAs, the Forest Service must complete a SAT Level II watershed analysis which requires a road condition survey and transportation plan, also referred to in SAT as a Road Management Plan. The Road Management Plan in turn must comply with 10 requirements listed under "Road Management," SAT pages 449-451. For example, when considering construction of new roads as proposed in the RCGSP, SAT states: "Valley bottom and mid-slope locations may be used only when analysis indicates that roads can be constructed and maintained in these locations and meet Riparian Management Objectives" (page 449). Since appropriations currently fund maintenance on only 20 percent of Forest Service system roads, the Road Management Plan (and the EA) needs to show what mechanism will ensure that the new road segments will not be among the 80 percent of the roads that will go unmaintained.
Further, the Road Management Plan needs to thoroughly analyze the road reconstruction described in the RCGSP scoping letter. In this regard, the Road Management Plan should comply with the following SAT guideline:
Inventory and evaluate all existing roads in Riparian Habitat Conservation Areas. Through an interdisciplinary team review process, determine the influence of each road upon the Riparian Management Objectives. Roads that are found to pose a substantial risk to riparian conditions will be improved or obliterated. Priority will be based on the potential impact to riparian resources, the ecological value of the riparian resources affected, and the need for each road. Roads not needed for future management activities will be closed, obliterated, and stabilized. All obliteration work will meet Riparian Management Objectives and provide for adequate long-term drainage and stability. (Page 449.)
Generally, SAT describes a watershed analysis as being a "large task," (page 456). Given its requirements, a substantial part of that task is the Road Management Plan. In this instance, the short environmental analysis period for the RCGSP EIS combined with the project area's wintertime inaccessibility makes completing an adequate watershed analysis/Road Management Plan virtually impossible.
Level II Watershed Analysis
1.) The RCGSP analysis should tier to, and come after, a SAT Level II watershed analysis. The purpose of such an analysis is to determine watershed standards and guidelines to fit specific landscape conditions and limitations, and to establish goals and set priorities regarding all aspects of potential Forest Service projects (SAT, page 457). That is, potential project objectives and activities should come from the Level II analysis. In this instance no Level II analysis has been completed, yet project objectives have already been established and are being analyzed, including stream restoration, timber cutting, and road building and reconstruction. In contrast, when proposed activities trigger a Level II analysis, then such an analysis should be completed prior to commencement of further project planning or analysis.
The Forest Service, then, needs to halt the current planning process and conduct a thorough Level II analysis and from that determine potential project activities.
2.) The watershed analysis for the RCGSP should determine if group selection-created openings in excess of the natural range of variability for forest openings will comply with SAT Riparian Management Objective 2, to:
Maintain or restore the stream channel integrity, channel processes, and sediment regime under which the riparian and aquatic ecosystems developed. Elements of the sediment regime include the timing, volume, and character of sediment input and transport. (SAT, page 441.)
Aspen Regeneration
Please include by reference our concerns regarding aspen regeneration expressed in our comments on the recent Prospect Project Draft Environmental Assessment dated, May 28, 1999, pages 3 and 4. This document is on file at the Beckwourth Ranger District.
Compliance with HFQLG FEIS Record of Decisions (ROD)
The ROD for the HFQLG FEIS requires that over the course of the pilot project "suitable habitat for old forest-dependent species and aquatic/riparian-dependent species (including amphibians) shall not be reduced by more than 10 percent below 1999 levels," (ROD, page 9). In order to assure compliance within the RCGSP EA, it will be necessary for the Forest Service to conduct the necessary analyses to determine the extent to which such suitable habitat may be reduced by project activities. Subsequently, the Forest Service needs to establish a "running total" of the reduction in suitable habitat throughout the entire pilot project area, reductions due directly to both Forest Service activities and to "natural" occurrences such as flooding, wildfire, insect infestation and other disturbances.
Goshawk
The RCGSP EA needs to analyze project effects on goshawks. The analysis should include identification of all suitable habitat and the effects of openings and potential habitat fragmentation cause by project activities. The goshawk survey protocol should be described along with an analysis of whether or not the protocol is sufficient to assure goshawk viability. We also reference as part of these comments, the goshawk section of the Sierra Nevada Forest Campaign appeal of the HFQLG FEIS, at pages 13-49.
Cumulative Environmental Effects
The EAs for the Red Clover DFPZ and Red Clover Groups Selection projects should be combined in order to properly address the cumulative environmental effects of both projects.
Maximum Growth Requirement
The RCGSP EA needs to evaluate whether group selection cutting prescription is in accordance with the Forest Service silvicultural requirement to maximize growth.
Alternative to the Proposed Action
The RCGSP EA should evaluate and present an alternative that sets group selection targets based on the need for openings that meet the project area's natural range of variability for openings.
The RCGSP EA should evaluate and present and alternative that sets appropriate group selection acre targets based on the need, within eastside forests and within the project area, to move stands in a continuous fashion from earlier to later seral stages.
The RCGSP EA should evaluate and present an alternative that does not include new road construction.
Thank you for this opportunity to comment:
John Preschutti Neil G. Dion
C.: Dave Peters, HFQLG Project Manager
Mark Madrid, Plumas National Forest Supervisor
Brad Powell, Regional Forester, Region 5
Mike Dombeck, Chief, USDA Forest Service