FOREST SERVICE PROJECTS IN ROADLESS AREAS IN CALIFORNIA
Overall, we’re concerned that significant activities are being proposed more and more frequently in IRAs and in some cases, using minimal or inadequate NEPA. Our hope is that the Regional Office will issue guidance, or otherwise, that would limit the use of Categorical Exclusions in IRAs unless the projects truly involve minor, non-controversial activities. We don’t think CEs are appropriate for most proposed projects within IRAs.
1. Reyes Peak Forest Health and Fuels Reduction Project Los Padres National Forest
755-acre project that involves creating fuel breaks by the removal of trees up to 64” in diameter (FS says it’ll primarily remove those 24” inches or less) and the clearing of chaparral. The FS is proposing to remove about 11,000 trees with this project.
The 30-day comment period on the proposed action was originally going to expire on 6/30/2020, but the FS extended the deadline to 8/14/2020 at the request of many of us, including Rep. Salud Carbajal who represents the area in which the project is located. It’s my understanding that there have already been about 12,000 comments submitted on this proposed project.
This project would negatively impact the Sespe-Frazier IRA.
In addition, this IRA is proposed for Wilderness, in legislation that the House already passed in February and in Senator Harris’ PUBLIC Lands Act (S. 3288), which is pending in the Senate. It was also included as an Amendment to the National Defense Authorization Act which the House just passed yesterday.
The project will impact sensitive plant species, Native American cultural resources and uses, scenery and recreation values all in an area that is truly beloved by local residents.
The FS used a Categorical Exclusion for this project because they say the project falls within two categories of actions that don’t require an EA or EIS (insect and disease infestation and wildfire resilience) and they don’t have any “extraordinary circumstances” present. However, we believe that the impacts to the IRA, the pending legislation, and other values are “extraordinary circumstances” which require a full scale EIS.
2. Hyampom Fire Resilient Community Project Shasta-Trinity National Forest
This project is in the pre-scoping stage. CalWild participated in a meeting last week with Forest Sup. Scott Russell. We were pleased to hear that the FS was committed to working with the Community and Fire Safe Council of Hyampom and conservationists, in order to create a good project.
Permanent fuel breaks could be established by this project in portions of the Pattison and South Fork IRAs which are proposed for Wilderness in the same legislation I mentioned for the prior project, which already passed the House in February and is pending in the Senate (Senator Harris’ PUBLIC Lands Act) and was also included as an Amendment to the National Defense Authorization Act which the House passed yesterday.
Permanently established fuel breaks could also be located in the Forest Service recommended Hayfork Creek Wild and Scenic River, the existing South Fork Trinity Wild and Scenic River, and in Olsen Creek (a Hayfork Creek tributary). All three streams are proposed for WSR designation (although in the case of the SF Trinity, re-designation). All of this is included in the same legislation I’ve mentioned a few times – which has already passed the House two times and is pending in the Senate.
It’s unknown what level of NEPA review the FS will choose. The potential significant impacts to IRAs, WSRs, and areas/rivers proposed for protection in require legislation, should be considered “extraordinary circumstances” and require a full EIS.
3. Lake Tahoe West Restoration Project Lake Tahoe Basin Management Unit
The scoping comment deadline closed 5/26/2020. Work continues on a “joint environmental document.”
Portions of the Granite Chief and Pyramid Peak IRAs would be impacted by permanent roads and fuel treatments.
The Stanford Rock Backcountry Management Area as well as another BMA that incorporates a part of the Pyramid Peak IRA adjacent to the Desolation Wilderness, will be impacted by permanent roads and fuel treatments. The Stanford Rock BMA was specifically established in response to objections to the Forest Plan in order to assure conservationists that the roadless qualities of the Granite Chief IRA would be protected, in lieu of a formal wilderness recommendation by the Forest Service.
The project proposes mechanical operations on slopes up to 50%, removal of large trees, reduction of canopy cover, impacts to Pacific marten and California spotted owl habitat, and erosion/sedimentation run-off into Lake Tahoe (a state-designated Outstanding National Resource Water).
The level of NEPA review that will be used with this project is unknown at this time. Impacts to IRAs, BMAs, sensitive wildlife, and Lake Tahoe water quality, necessarily require a full scale EIS.
4. Motorized Recreation Project Sierra National Forest
Draft EA comment deadline will expire 7/27/2020 (next Monday).
The project will probably impact the Dinkey Lakes IRA (which was not analyzed in the EA).
The project will cause about 3/4 of a mile of motorized trail to intrude into the recommended Bear Mountain Wilderness (recommended in the 2019 Draft Forest Plan Revision, in Alternative C).
There will be potential impacts to eligible WSRs and their outstandingly remarkable values, including segments of California and Owl Creeks.
The FS used an EA, which we believe was inadequate. The roadless/wilderness impacts should have been analyzed in a full scale EIS.
5. Lakes Basin and Sherwins Area Trail Enhancement Project Inyo National Forest
The scoping comment deadline was 7/8/2020. That proposed project actually involves two separate trails projects -- one of which is a non-controversial trail improvement project and the other is a controversial proposal to build a new trail. The FS scoping letter inaccurately described these two distinct projects, in two separate areas, as one trail enhancement project.
The controversial one involves building a new multi-use trail in Solitude Canyon atop the Sherwin Ridge, which would be within an IRA, with the use of a CE only. The proposed project would have significant impacts to important habitat for sensitive species including possibly threatened and endangered Forest Service species. An EIS was done for a proposed ski area in that area back in 1990, but that was 30 years ago and does not obviate the need for more recent studies and data. We’ve asked the FS to prepare a new scoping notice that separates these two distinct trail projects and to prepare an EA for the controversial trail building project.
Going forward, we ask that the FS work with stakeholders like us to put together projects that won’t degrade the wild qualities of roadless areas and that when projects are proposed in roadless areas, they get a higher level of NEPA analysis than a CE.