Appendix C Flat Preliminary EA Comment Analysis Flat Project Comment Analysis
Comment Analysis
for the
Flat Vegetation Management Project Environmental Assessment
The 30-day comment period for the Flat Vegetation Management Project Environmental Assessment was initiated on June 15, 2017 and concluded on July 21, 2017. A total of 8 comment letters or e-mails were received.
Comments Received 1. Mailed Letter, postmarked July 5, 2017, Karen Coulter (Pages 2-20) 2. E-Mailed Letter, dated July 18, 2017, Jack Southworth (Pages 21) 3. E-Mailed and Postal Letter, dated July 18, 2017, Frances M. Preston (Pages 22-26) 4. E-Mailed Letter, dated July 18, 2017, Zach Williams, Consultant, Iron Triangle LLC (Pages 27-29) 5. E-Mailed Letter, dated July 20, 2017, Dick Artley, Retired (Pages 30-245) E-Mailed Letter, dated July 21, 2017, Irene Jerome, American Forest Resource Council (Pages 246-251) 6. E-Mailed Letter, dated July 21, 2017, King Williams, President, King Inc. (Pages 252-253) 7. E-Mailed Letter, dated July 21, 2017, Doug Heiken, Oregon Wild (Pages 254-303)
Comment Analysis
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Comment Letter #1 – Ms. Karen Coulter, Blue Mountains Biodiversity Project Ms. Coulter includes about 102 pages of the Flat Vegetation Management Project Preliminary EA with hand written notes in the margins as her comments. Rather than include all those pages, we have summarized her comments in a table and responded as appropriate. A copy of Ms. Coulter’s comments is scanned and available on the web at http://www.fs.usda.gov/project/?project=47364.
Responses to Comment Letter #1
Response to Comment 1-1: 1-1 The forest service acknowledges a site-specific The U30 aspen treatment has been reduced ‘scarcity’ of large trees in the Flat project area. in the Final EA to 173 acres. See the EA at This argues against any Forest Service rationale 1-18. Also see the EA at 1-9. “Aspen for amending the Forest Plan based on site- inventories in the Flat project area specific conditions, to allow the logging of large identified less than 3% of the project area trees to resume-especially as the current contains aspen…. Many aspen stands are condition (too many small trees, not enough less than 3 acres in size. The small size of large trees) is part of the purpose and the need most aspen stands demonstrates the for the Flat project timber sale. urgency needed for treatment.” See also 3- 25. “Removal of competing conifers is considered essential for strong aspen regeneration (jones et al. 2005). Managers in our area agree that all conifers should be removed in treated aspen stands, except for those that must be retained to meet other management objectives (e.g., large-tree conservation or stream shading). The EA at 2-7 states “Conifer trees between 21” and 30” DBH would first be converted to snags and down wood to meet forest plan standards, then any excess trees would be available to be removed and utilized as biomass. Conifers greater than 30” DBH would not be cut. No tree that is stabilizing the bank of a stream would be removed regardless of size or relation to aspen trees.” The treatment would at most occur on at most 0.3 percent of the project area. 1-2 The Forest Plan is outdated with regard to the See the EA at 1-8 “Studies completed at the objective (never revised for effects of heavy Starkey Experimental Station since the logging) of maximizing economic returns despite Forest Plan was established suggest that the ever decreasing amount of available saw-log the energetic benefits of cover may be size trees. Continuing to “maximize outputs” inconsequential to elk performance, and and planning to log large trees in violation of the that forage or nutritional effects may have Eastside Screens and to violate the Forest Plan the greater impact on individual animal standards for elk and deer cover is not “being performance…. The Flat project is primarily sensitive to resource conditions” as required by (97%) dry upland forest. Modeling suggest the Forest Plan. We are strongly opposed to the that forest plan cover levels may both be
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proposed Forest Plan amendment to reduce elk sustainable; it is not within the inherent and deer cover below Forest Plan standards. capability of these sites to maintain high levels of cover….. Winter range is usually at lower elevations and in drier forest types and scablands.” 1-3 So why don’t satisfactory and marginal cover The numbers for both satisfactory and requirement add up to the total cover marginal cover are the minimum for those requirements? Is the rest of the total cover not types of cover. Total cover is the even marginal for elk and deer? combination of satisfactory and minimum cover. 1-4 See our photos in Flat sale units of heavy See the EA at 2-6 “Fencing or downed wood browsing of aspen sprouts, likely by cattle. would be utilized to prevent ungulate Without stopping the severe destruction of browse.” aspen sprouts by cattle, there will be no aspen recovery. 1-5 Where aspen areas are within RHCAs, logging See the EA at 2-8 “Trees cut would be left removal of large trees would violate INFISH, as it on site as downed wood and utilized as is highly unlikely there would be enough large large woody debris for stream restoration.” wood structure left to meet INFISH RMOs. Also design criteria on page 2-21 are in place to protect INFISH RMOs. “Apply silvicultural practices for Riparian Habitat Conservation Areas to acquire desired vegetation characteristics where needed to attain Riparian Management Objectives. Apply silvicultural practices in a manner that does not retard attainment or Riparian Management Objectives and that avoids adverse effects on inland native fish. Treatments in Category 4 streams would first have biomass placed in the stream in order to maintain and enhance large woody debris before removal” 1-6 We want to know what specific project design Those design criteria mentioned in criteria were developed to address effects to TES response to comment 1-5, as well as design and MIS species? criteria for protection of wildlife resources on page 2-20 of the EA, as well as botany specific design criteria are all for the protection of those species. 1-7 40 square feet of basal area should be the low The Flat project is 96.8% dry upland forest, end of the variable density basal area range, not and as a result “Ponderosa pine most the average, as this leaves too few trees for commonly occurred in pure or nearly pure natural mortality over time to create needed stands with densities of 20 to 30 trees per snags and logs. We are also opposed to logging acres, trees in pure stands were widely all trees within double the dripline of older spaced apart”. EA at 3-20 Ponderosa pine and western larch, as this is not a natural effect since trees often grow in clumps. 1-8 Two acre mini clearcuts would be created by See the EA at 2-21 “Gaps would not be removing all trees less than 21” dbh, for the situated around snag patches in order to
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most part, as there are very few large trees in protect snags in the project area.” The thin the Flat sale units. We are opposed to removing from below patches, or gaps, would be all trees less than 21” dbh over 2 acres, unless situated around areas that are already that 2 acres is already mostly a natural opening naturally open, and expand on these (e.g w/NCT-size encroachment from the edges.) existing openings to create variability. 1-9 Drop the 185 acres of steep slope logging. This All treatments >35% are concentrated in would both be very uneconomical to log since one area to facilitate the economics of that the vast majority of trees in Flat are small, and treatment. Design criteria ensure the also incredibly destructive to soils, which have protection of soil resources, and the little vegetation holding them together and are treatment is designed to use cable or aerial very marginal and damaged already. logging systems to protect soils. The No Action alternative addresses your concerns. 1-10 ROGS and PWFAs must be managed for Pileated See the EA at 3-110, “While some of the woodpecker suitability which means NCTing stands did not meet snag densities the only, allowing for snag and down log average snag densities for the proposed recruitment over time, retaining sufficient feeding areas were above Malheur Forest canopy closure, and retaining all snags and down minimum snag densities. Young forest logs. multi-stratum (YFMS) stands contain adequate habitats for species like pileated woodpeckers when they occur in a mixed conifer stands. Old growth 014 feeding area and ROG’s were in pure ponderosa pine stands, which are not as favorable habitat for pileated woodpeckers and other old growth species requiring complex stand structure.” See also effects to ROGs and PWFAs table 46, which displays that 75% of these areas would not be treated. Additionally, design criteria protect snags and down logs from harvest activities. 1-11 Either drop the 210 acres of old growth Refer to response to comment 1-10. enhancement or leave it at least as suitable Pileated woodpecker and potential marten as it is now, which requires 40-60% canopy closure. 1-12 Down wood (“biomass”) must be retained for See the EA at 2-3 “No down wood or snags Pileated and marten. would be removed as biomass.” 1-13 We ask for lower dbh limit for logging, such as Thank you for your comment. The eastside 16-18” dbh depending on the tree species. We screens, which amended the Forest Plan, want this to apply to the entire timber sale. set the limit at 21” dbh. 1-14 We can’t agree to a “biomass thin” that is Thank you for your comment. The IDT actually logging up to 11,755 acres up to 21” reviewed those areas in order to more dbh. appropriately categorize these into either commercial thin units or pre-commercial units. The final EA will demonstrate these changes. Additionally the biomass thin treatment will be changed to up to 12” only.
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1-15 Consider leaving all lodgepole snags and logs, See response to comment 1-12 regarding leaving all other tree species seedlings, and just snags and logs. NCT the lodgepole by hand to reduce risk to overstory ponderosa pine. 1-16 Any commercial removal of wood from RHCAs, See response to comment 1-5. including for aspen restoration should be limited to what is available after all RHCA RMOs are met. 1-17 We are strongly opposed to logging conifers See the EA at 1-9, 3-16, 3-23, 3-25, 3-125 greater than or equal to 21” dbh in aspen areas for discussions on the biological urgency in as there is no real ecological need to do this, and regards to aspen stands. The U30 aspen as the Flat area (as with many areas on the treatment has been reduced in the Final EA Malheur) has a profound scarcity of large wood to 173 acres. See the EA at 1-18. structure across the landscape. RHCAs are one of the few areas where large trees still exist for wildlife in Flat. Notably the marten sightings in Flat were in all drainages. 1-18 How are shrub-steppe habitats defined? Under natural conditions, shrub-steppe lands are covered with grasses and shrubs. The most common shrub, or woody plant, is big sagebrush. Other shrubs include: rabbitbrush, greasewood, hopsage, bitterbrush, and buchwheat. They grow in communities with grasses such as bluebunch wheatgrass and Sandberg’s bluegrass. Usually found on loamy, wind- deposited (loess) soils. Added to EA at 2-7. 1-19 See our enclosed riparian science summary as Thank you for your comment. Changes part of these comments, which reflects scientific have been made to the Final EA in response controversy not being disclosed by the Forest to your additional science submission. Service. 1-20 Drop all commercial size logging in category 4 Thank you for your comment. The No INFISH buffers. Action Alternative would not treat in category 4 streams. 1-21 We support the proposed additions of ROGs, See response to comment 1-10. and PWFAs to existing DOGs. However we oppose commercial size logging of these ROGS and PWFAs as logging above 8-9” dbh and any biomass removal is likely to eliminate habitat suitability for the intended species beneficiaries. 1-22 We are opposed to prescribed burning in See the EA at 2-27 “Mimic low intensity suitable and active pileated woodpecker and burning in special wildlife areas including American marten habitat, as burning largely DOG’s, ROG’s, and pileated feeding areas.” destroys the suitability of habitat for these species. 1-23 We are opposed to the re-opening of so many While closed roads would be opened for closed roads (60.5 miles). use during timber harvest and log haul, they are still closed roads and would be
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closed again at the completion of those activities. 1-24 Closed roads that have grown over and are See response to comment 1-23. Roads effectively blocked and or that were closed to would only be opened and used under protect wildlife habitat or other ecological permit, such as to haul logs. After use, the values or that are no longer needed for other roads would be re-closed. uses or are redundant, should not be re-opened. 1-25 We are opposed to the construction of any See the EA at 2-11 “Temporary roads are “temporary” roads. roads authorized by contract, permit, lease, or other written authorization, or emergency operation not intended to be part of the forest transportation system and not necessary for long-term resource management. Temporary roads are not intended to be included as part of the forest road atlas, as they are managed by the projects or activities under which they are authorized and decommissioned at the conclusion of the authorized activity. Temporary roads would be closed and restored after harvest and related activities are complete. Potential temporary roads in RHCAs must follow BMPs and be approved on a site specific basis by hydrologist or fish biologist. Less than 8 miles of temporary roads would be constructed and rehabilitated after use.” 1-26 This is an inadequate range of alternatives under See the EA starting at 2-2 for a discussion NEPA. on alternatives, both developed and eliminated from detailed analysis. 1-27 There is inadequate cumulative effects analysis See the EA at 3-74 “The cumulative effects for Primary Cavity Excavators at the Forest level area for Williamson’s sapsucker include the to allow for the conclusion (e.g. for Williamson’s watershed and the entire Malheur Forest Sapsucker) that cumulative effects are because Management Indicator Species immeasurable at the forest level. Since there is (MIS) viability assessments are done forest no analysis of the effects of all the other timber wide. At the watershed level about 28 sales, effects including snag reduction and percent of potential habitat could be habitat loss, across the forest. impacted with vegetation treatments. Some treatments are expected to be beneficial such as aspen treatments. Since most of the habitat would not receive any vegetation treatment the cumulative effects are minimal at the watershed level. Retention of snag habitat is more an issue than vegetation treatments since this PCE requires high density of snags.
At the forest scale less than two percent of the habitat would be treated with the
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proposed action. Cumulative effects are immeasurable at the forest level and any of the action alternatives would not contribute to a negative trend in population viability.” 1-28 It is not at all clear, as claimed in the PEA, that See the EA at 3-78 “Application of for Blackbacked and Three-toed woodpecker prescribed fire benefits these fire dependent creation of source habitat from prescribed fire species by creating foraging and nesting offsets negative impacts from thinning and habitat due to the tree mortality of smaller timber harvest. diameter trees and the influx of insects drawn to the burn units. Where a stand replacement fire may benefit these two species for up to five years, it would take a century or more to replace the forest, where a prescribed fire applied over time can create a pulse of snags both spatial and temporal… Prescribed fire can convert secondary habitat into primary habitat by creating an abundance of snags and insects needed for reproduction and feeding of young birds…. The degree of tree mortality determines the amount of source habitat created by the prescribed fire. Fall season burning may provide more primary habitat for these woodpeckers than spring burns, possibly if smaller tree mortality occurs in relative high densities. Prescribed fire is recommended by Hutto (1995) to sustain habitat for blacked-backed woodpeckers and is necessary to offset conversion of habitat by thinning and/or harvesting.”
1-29 Drop the 900 acres of lodgepole pine logging The No Action Alternative would not treat within estimated secondary blackbacked within secondary blackbacked woodpecker woodpecker habitat. habitat. 1-30 The 7,600 acres for pileated woodpecker See the EA at 3-85.Pileated Woodpecker Habitat assumed to be above HRV by Wales in 2011 are Affected by Recent Landscape Scale Projects, Forest undoubtedly gone by now on the Malheur, Level thanks to a great escalation in the scale and pace Acres PIWO of logging, with timber sale commercial logging Project area affected from 4,000 to over 20,000 acres planned per Wolf 2,695 sale, and still largely seeking to greatly reduce Dove 456 grand fir preferred by pileated for foraging and Elk 16 4,957 with increased targeting of large trees for Magone 3,223 removal especially grand fir needed by pileated. Big Mosquito 3,000 Canyon Creek Fire 4,538 Total Acres Affected 18,869
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Acres Acres as of 2014 Remaining 148,508 129,639
1-31 Drop the 80 acre sale unit on North aspect The No Action Alternative would not treat slopes in the Jump Creek drainage that would these units. displace Pileated woodpeckers from suitable habitat. Also drop commercial logging in the 390 acres in Pileated habitat. 1-32 The cumulative effects analysis for Pileated See response to comment 1-30. woodpecker somehow manages to avoid disclosing telling specifics, such as the great acreage of Pileated habitat being rapidly degraded or eliminated from suitability by a large number of sales targeting Pileated habitat across the forest. 1-33 When there have been four marten sightings in The No Action Alternative would not treat the Flat project area it is logical or justifiable to these areas. Additionally, “The Flat project conclude that there were just “incidental area has no habitat for marten and the sightings” (whatever that means) and therefore Upper Silvies River watershed has irrelevant, and that there would be no effects to approximately 70 acres of which is not marten, even from removal of large wood enough habitat for marten (Table 35). structure in aspen areas and from significant Stringers of lodgepole and mixed conifer reduction in down wood and existing and future stands are present but not in any snags along drainage corridors (where marten contiguous size to provide habitat for were sighted). We are opposed to logging and marten.” EA at 3-85. any biomass removal in the drainages marten were sighted or in similar habitat in the Flat area. 1-34 Habitat may be created in the mid to long term See the EA at 3-84 “The cumulative effects from vegetation treatments in the northwestern area for American marten includes the portion of the planning area, especially in the watershed and the entire Malheur Forest stands containing lodgepole pine. After because Management Indicator Species thinning, timber stands would need time to (MIS) viability assessments are completed develop to create features needed for marten forest wide. The Flat project is not expected habitat. Headwaters of Camp and Crooked to have cumulative effects to marten Creeks may develop into future habitat for habitat since no measurable amount is marten once old structure exists. This available at the watershed level. The represents failure to use the best available estimated 70 acres of potential habitat is science and a lack of professional integrity. not large enough for a marten territory. Obviously more logging of suitable habitat will At the forest level, wildfires are the primary have cumulative effects to marten, but this is reason habitat has been lost for marten. denied through cursory dismissal of the issue Past logging practices that removed old rather than adequate cumulative effects growth was also a contributing factor. The analysis. The Marten’s need for dispersal Flat project would reduce the potential for habitat between good blocks of habitat stand replacement fire that could spread elsewhere is ignored. north into habitat for marten.”
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1-35 Reintroduction of prescribed fire back in the The No Action Alternative would not ecosystem offsets the cumulative effects of fire prescribe burn. suppression. While reintroduction of fire back into the ecosystem may certainly be helpful for eventually allowing wildfire to play it’s natural role by ending back country wildfire suppression, it is unlikely that it offsets the cumulative effects of fire suppression, as prescribed fire only mimics (at best) low intensity fire, and as it usually follows removal of many trees through logging, thus not returning carbon that is lost to the ecosystem as wildfire does through ash and leaving many snags and down logs. Thus the current deficit in snags and pulses of snags for primary cavity excavators, yet the Flat sale would continue this trend. 1-36 The model does not take into account snag See the EA at 3-90 “High road densities removal for human consumption such as coupled with liberal fire wood cutting firewood and does not factor in the high road policies is contributing to a decline in large densities which are associated with low snag size snag densities. Overstocked stands limit recruitment. The FS should not be using such a tree growth and development of larger flawed model. trees for future snag habitat.” 1-37 This discussion does not take into consideration Future projects are outlined in the probable planned future logging (as with the Flat summary of reasonable foreseeable actions sale) again reducing trees available to become on page 3-4 of the EA. snags. 1-38 Some of these snag density results could be also See the EA at 3-87. “Snags smaller than 10 misleading, in that fewer small and medium inches DBH are numerous throughout the sized snags could be used to artificially increase planning area, but these smaller snags are the percentage of existing large snags compared not evaluated in DECAid and therefore are to other size classes and much of the future snag not displayed in the graphs.” Additionally, density increase would be from recovery from there are no future timber sales planned in the logging, not from the logging itself, and both the project area at this time. Any future results would be based on the assumption of no timber sales would also require NEPA, and future logging in the same areas for 50 years, would take into account the activities from which is longer than the Forest Service current this project as existing conditions. The IDT logging rotation. Without greater transparency is currently observing large pulses of snag as to the assumptions that went into the model, patches across the district due to insect it is impossible to know how or if we are being activities, with large snags included. deceived, which is why it’s important to fully disclose methodologies used the EA so the public can see how the data or assumptions were derived. 1-39 The Forest Service uses highly simplified models See the terrestrial wildlife section in the EA in order to claim that proposed logging will for viability for PCEs. Prescribed burning increase snag densities, despite the obvious would be the greatest increase in snag logical fallacies involved in that assumption, and creation, not specifically “logging”. science to the contrary, such as studies cited in
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the last paragraph of PEA p 3-91. Further the Additionally road closures will help retain near and mid-term viability of MIS PCEs will not snags as a result of less firewood cutting. benefit from long-term snag increases if the species lose their viability sooner from lack of snag structure. 1-40 After reading the analysis regarding snag and log See response to comment 1-12. Also, see densities, cover, and effects to these, we remain the EA at 3-94 “All the downed log structure concerned that overall the Flat sale will types meet Regional Foresters direction contribute a significant reduction to an already with the exception of the small/medium existing scarcity, as the PEA admits on p. 3-94 to stands in the mixed conifer plant a “lack of large downed wood and snags within associations.” about half the planning area”, “lack of large snags in the project area limits future recruitment of downed logs”. 1-41 Table 38 is confusing. Are there figures (with the The number of downed logs and snags are exception of DecAID and Forest Plan standards summaries of our transects collected in the drawn from Flat transects? Does “Open” field by our crews by habitat types. Open structure refer to clearings, or to open, park-like structure is basically stand initiation, stem stands, or to what? exclusion open canopy or stand re- initiation. Usually reflects managed stands. Some of the park-like stands may fit in there also, and pine expansion where the canopy is open. Past fire such as the grapple fire fit into open structure. 1-42 This seems to be very incomplete analysis of See EA at 3-95 for effects to down log, and direct, indirect, and cumulative effects of the 3-93 for snag distribution for future down action alternatives as down wood cover, as the logs. two short paragraphs do not attempt to quantify losses versus gains, or compare these to timelines re: lag time in created snags becoming additional logs. 1-43 Fire suppression would continue to retain The sentence has been re-worded for the abundance of cover and forage for mule deer in final EA. “Fire suppression would continue the non treated areas would decline over time. to retain an abundance of cover, and forage What is missing in this sentence? 3-97 for mule deer in the non-treated areas would decline over time.” 1-44 Actually, it seems there is already a negative Both mule deer and Rocky Mountain elk are population trend for mule deer, especially if it species that are hunted, with tags and does not show a surplus. Also this ignores populations controlled by Fish and Wildlife. security cover considerations as related to See effects to populations on page 3-97 of population viability- especially important for an the EA. actively hunted species. So it is not clear that the Flat timber sale would not cause or contribute to population decline for rocky mt. elk or mule deer. 1-45 We are greatly concerned by proposed logging Thank you for your comment. The No of large trees in aspen areas in DOGs, ROGs, and Action Alternative would not treat these an RF as this seems to be a back door approach areas.
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to commercially logging large trees essential to DOG, ROG, and PWFA old growth habitat structure for OG associated wildlife. 1-46 This is very ambiguous and biased analysis See EA at 3-114 “Approximately eight regarding effect to wildlife connectivity percent of connectivity (535 acres) would corridors. Logging these areas does not receive vegetation treatments with either preserve vertical and horizontal complexity or action alternative.” Only aspen and conifer lead to connectivity benefits for marten, as encroachment treatments occur in claimed. connectivity corridors. 1-47 Human caused thinning and burning are not Thank you for your comment. Please see “necessary for sustainability of large ponderosa the purpose and need for the project in the pine”. In fact, stands are naturally thinned EA at 1-2. In addition to “Improve through pine bark beetle, pine butterfly, and vegetation resilience and resistance to wildfire. insects, disease and wildfire, and increase the diversity and structure of forest vegetation communities” there is also the need to “Capture the economic value of harvested timber”. 1-48 There is no quantified analysis of how many All aspen treatments that are U30 do not large trees (and future large snags and large fall in LOS or designated old growth. All logs) would be lost through direct logging of aspen treatments U30 were selected large trees up to 30” dbh in aspen stands and because of the amount of large trees in the how all of this would affect old growth stands, and there will be large snags left in dependent species. the stands. Lastly, the U30 aspen treatment has been reduced in the Final EA to 173 acres. See the EA at 1-18. 1-49 The Flat analysis should have been done more And EIS is necessary when there are thoroughly in an EIS, not just in and EA, given significant effects. The analysis is chapter 3 the virtually unprecedented scale of the of the EA do not find significant effects. commercial logging for one timber sale regarding the geographic extent of acreage to be logged in one way or another, but mostly up to 21” dbh. 1-50 Greenwald et al is a credible review of the See the EA at 3-124 “Variable density scientific literature regarding goshawk habitat prescriptions with incorporating “skips and needs, yet is casually dismissed from gaps” create more edge producing a higher consideration based on only one finding re: prey base for goshawks. Proposed harvest goshawks only foraging in high canopy closure prescriptions comply with guidelines stands. suggested by Reynolds (1992). Goodell and Seager (2015) re-emphasized goshawks as generalists and stated that protection measures in Regional Foresters Amendments are outdated and not supported by science; however the known goshawk nests found through field surveys would be protected and required PFA established. Goodell and Seager’s recommendations of incorporating PFA’s
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into old growth, connectivity, and RHCA’s were implemented allowing for planned dry forest restoration activities to occur, yet high density stands would remain for foraging and rearing young.” 1-51 Drop all proposed logging in goshawk primary Snags and downed wood are protected, see habitat and PFAs, and drop all logging of large EA at 2-3 “No down wood or snags would trees greater than or equal to 21”dbh including be removed as biomass.” See also response snags. to comment 1-1. 72% of primary habitat would not be in any mechanical treatment units. 95% of PFAs would not receive mechanical treatment. 51% of secondary habitat in the proposed action, and 64% in alternative 3 would not receive mechanical treatment. From EA at 3-123. 1-52 Drop all proposed commercial logging and con- See response to comment 1-51. commercial thinning or biomass thinning Additionally see the EA at 2-20 where adjacent to goshawk nest stands and PFAs and goshawks nest trees are protected by leave all large line trees and snags greater than seasonal restrictions. or equal to 21” dbh in aspen conifer encroachment sale units, including those in five goshawk nest stands. 1-53 Prohibit prescribed burning in nest areas and See the EA at 2-27 “If spring burning occurs PFAs during the spring reproductive season and in burn blocks that contain goshawk nests, during the fledgling rearing period. no ignition within ½ mile of active goshawk nest site. Mimic very low intensity burning in wildlife connectivity and goshawk PFA’s except in lower elevation ponderosa pine sites in the south or west slopes.” 1-54 Cumulative effects to aspen and not similar as See the EA at 3-126 (emphasis added) “Past direct and indirect because they include the activities such as fire suppression, grazing, combined effects of aspen restoration projects, road construction, and associated activities livestock damage to aspen stands, the effects of degrading watershed conditions have fire suppression to aspen, lowering of water contributed to decline of aspen across the tables by livestock use, road impacts to aspen, landscape. Conifer reduction has proven to etc., all of which should have been analyzed. be effective in enhancing aspen stands where shading has occurred and where sucker browsing is not extensive. Some protected stands have increased aspen suckering and regeneration where livestock damage is extensive.
Cumulative effects to aspen are similar as direct and indirect because no other vegetation treatments are planned within the watershed. All proposed aspen treatments have been implemented on the Malheur Forest and are recommended in Swanson et. al,(2010). Increase in aspen regeneration
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and wildlife diversity are expected with implementation of conifer reduction projects, mainly conifer thinning, prescribed fire, protection fences or structures, and offsite water development.
Aquatic restoration projects designed for fisheries habitat or to improve stream morphology may benefit aspen if occurs near aspen. Any projects potentially raising the water table, like placement of log structures in the drainages, benefit aspen.”
1-55 The cumulative effects analysis for Neotropical See EA at 3-135, “Livestock grazing can migratory songbirds completely fails to have detrimental effects on nesting birds in acknowledge or analyze any potential negative some areas where livestock concentrate by effects from combined effects of the Flat project either direct mortality on eggs, chicks, or logging, roading, canopy layer removal, etc. and grazing all the hiding cover for nests. onging livestock grazing, herbicide use, etc., and Proposed vegetation treatments can help to is thus inadequate cumulative effects analysis re-distribute livestock use, which could under NEPA. benefit some nesting birds such as juncos or poorwills that are ground nesters. Livestock water sources benefit some migratory birds but some benefits are negated by livestock concentrations around water sources. Fencing to omit livestock in riparian areas can benefit nesting birds.”
1-56 Decommission fully all roads within RHCAs. See the EA at 2-10. “Closing and Reduce overall road density to less than Forest decommissioning roads would reduce the Plan standards, based on best available science. current level of motorized access within the watershed but not eliminate it. Proposed changes would allow for resource management, fire suppression, recreation and other uses…. Roads proposed for decommissioning would have activities that result in the stabilization and restoration of unneeded roads to a more natural state. Decommissioned roads are permanently closed and no longer maintained. Road decommissioning treatments are designed to improve hydrologic and ecologic function.” Those roads that are causing resource damage were targeted for decommissioning. Not every road within RHCAs could be decommissioned, as some of them are main roads, and some would be closed. 1-57 The lack of pool within all streams and reaches is See the EA at 3-146 “Many RHCAs are open another reason not to fell and remove large meadow systems dominated by willows and
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trees from within aspen areas, as these not only the encroachment of conifers due to provide habitat for birds using aspen stands, but suppression of wildfires could be also provide long-term wood recruitment (large) degrading….. Removal of conifers from into riparian areas. aspen stands within RHCAs would increase riparian plant diversity and allow shrubs with fine rooted systems to stabilize banks, and increase cover habitat for aquatic species and insects. This would be a benefit to aquatic species and their riparian habitat…. In aspen stands, any created biomass not utilized for commercial purposes would be left on site as downed wood, utilized as large wood for stream restoration, piled and burned, or jackpot burned in areas of light fuel loads.” 1-58 We are concerned by widespread high water See the EA at 3-146 “Slash and tops of trees temperatures in streams exceeding INFISH and would be utilized as barriers to ungulate state standards. grazing around residual hardwoods. Some of these activities would occur on category 1 streams and would result in small insignificant, short-term (1-5 years) increases in solar radiation. However, effects are expected to be minor and not affect downstream temperatures since aspen sites are small non continuous stands dispersed throughout the drainage and riparian enhancement would occur in phases. Thus very little shade would be removed. Additionally these projects are generally implemented over a 5 year period, which further reduces any sudden impacts. Aspen, cottonwoods and other hardwoods would continue to shade the stream and over time shade from these species would increase since these trees would no longer be competing with conifers. Treating aspen sites associated with intermittent streams would have no effect on stream temperature since these streams have ceased flow during the warmest months. Restoring aspen stands would increase floodplain water storage and increase riparian shade levels.” 1-59 Retain all primary and total shade contributing See EA at 3-146 “Trees selected to be cut trees in streams within aspen groves by would not be the source for primary shade retaining aspen, large conifers, riparian of the watercourse they are located near. hardwoods, and trees anchoring stream banks No trees that are stabilizing banks would be and more trees if necessary. removed.”
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1-60 So is there any aquatic restoration being See the EA at 3-4, there is a Crooked Creek done/planned for the Flat area? Aquatic Restoration project that overlaps the project area. 1-61 How would the Flat project move conditions Refer to effects to both Fisheries and toward moving to attainment of INFISH RMOs Watershed and Soils in chapter 3 of the EA. and state water quality standards? 1-62 Are Malheur Mottled sculpin present in the Flat Malheur mottled sculpin are likely present analysis area? Aren’t they a sensitive listed fish in the analysis area. They are not on the species and possibly endemic to the Malheur? regional forester’s sensitive species list. Why is there no EA discussion of Malheur They require similar quality habitat as Mottled Sculpin, in that sculpin are present in redband trout. the Flat area? 1-63 Could redband trout in the Flat area be Redband trout are no doubt genetically genetically connected to steelhead trout? connected to Steelhead trout, however the fish in the Flat project area have become geographically isolated in the Malheur basin, and are no longer able to connect to the Pacific Ocean. 1-64 Is summer distribution of Redband trout limited Redband trout are somewhat limited in to headwater areas due to fish passage barriers movement within their current habitat, or lack of water connectivity and pools? depending on the stream and the water year. Addition of large woody debris, and other stream restoration techniques are currently being employed in degraded streams to improve fish habitat. 1-65 Which proposed management practices are in See the EA at page 2-8 for a table of RHCAs? treatments in RHCAs. 1-66 Drop planned stream crossings and landing in Refer to the design criteria for protection RHCAs. during stream crossings. Landings in RHCAs would be used only after approval from the hydrologist or fish biologist, and usually only as a way of preventing further disturbance creating a new landing elsewhere. 1-67 We are strongly opposed to any commercial Thank you for your comment. The No wood removal from RHCA’s as 1) the RHCAs are Action Alternative would not remove wood already at a great deficit for large wood for from RHCAs. See the EA at 2-8. “This forming pools, and 2) creating commercial treatment is assigned to selected category 4 incentive for removing logs from RHCAs will lead RHCA sites where stand densities are to increased local pressure to log RHCAs and excessive. Category 4 streams adjacent to renewed logging and roading impacts to RHCAs other vegetation treatments described above and fish populations. would be thinned according to the prescription of the adjacent vegetation treatment. Stands would be thinned to the higher end of the basal area range where slopes are less than 20 percent and no riparian vegetation is present (with exception of aspen). No gaps would be located within Category 4 RHCA treatment
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areas. For all Category 4 streams, no trees acting as a primary source of stream shading would be cut. No trees that are stabilizing banks would be removed.
Trees cut would be left on site as downed wood and utilized as large woody debris for stream restoration. Any biomass that is excess after those activities would be available for biomass removal, piled and burned, or jackpot burned in areas of light fuel loads. Category 4 streams that are not adjacent to other vegetation treatments would be pre-commercially thinned up to 10 inches DBH.” EA at 2-21 “Treatments in Category 4 streams would first have biomass placed in the stream in order to maintain and enhance large woody debris before removal.” 1-68 There should be no off road removal equipment EA at 2-23 “Draw bottoms are not in RHCAs. appropriate for skidding or forwarding. If the only way to log a particular part of a unit is to skid in the draw bottom, that part of the unit would be excluded from harvest.” 1-69 We are opposed to allowing/creating increases Category 1 streams have no treatment in solar radiation to Category 1 streams. Any proposed except for aspen treatments. EA logging in RHCAs must move the RHCAs toward at 2-21 “Apply silvicultural practices for attaining RMOs, not away from attaining RMOs. Riparian Habitat Conservation Areas to acquire desired vegetation characteristics where needed to attain Riparian Management Objectives. Apply silvicultural practices in a manner that does not retard attainment or Riparian Management Objectives and that avoids adverse effects on inland native fish.” 1-70 Many decommissioned roads on the Malheur See the EA at 2-10, “Roads proposed for are not fully decommissioned, let alone planted decommissioning would have activities that with conifers and hardwoods. Many are result in the stabilization and restoration of ineffectively closed and continue to be used by unneeded roads to a more natural state. motor vehicles, and lately there has been a Decommissioned roads are permanently trend in the Forest Service of re-opening closed and no longer maintained. Road decommissioned and “temporary” roads decommissioning treatments are designed to contrary to the FS claims of removing them from improve hydrologic and ecologic function. the road system yet the EA does not discuss Decommissioning includes applying various these problems. treatments, which may include one or more of the following:
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• reestablishing former drainage patterns, stabilizing slopes and restoring vegetation, • blocking the road entrance, • removing culverts, reestablishing drainage ways, removing unstable fills, pulling back road shoulders and scattering slash or boulders on the roadbed, • eliminating the roadbed by restoring natural contours and slopes, or • other methods designed to meet the specific conditions associated with the unneeded roads.”
1-71 We ask the Forest Service to stop reopening See the EA at 2-10, footnotes. A closed “permanently closed”, “decommissioned”, and road is still a road that can be opened and “temporary” roads for future timber sales or used under permit. A decommissioned otherwise. road is no longer a road. Temporary roads are not roads. See the EA at 2-11 for more about temporary roads. 1-72 Define “meaningfully measurable effects”. This Meaningful measurable effects means we is ambiguous language that is used to avoid may be able to measure the effects of quantitative analysis of potential environmental something, but will not be able to draw effects, and is being used in the Flat EA to avoid meaningful conclusions based on the data detailed analysis of potential logging, roading, received due to the wide variability in the and log-hauling related further sedimentation of sampling. For example, the stream streams and further reduction in available large temperatures may rise after project wood for stream recruitment under Flat action implementation, but we will not know alternatives. exactly what factors contributed to the rise in temperature (bad water year, early high temps, etc.). 1-73 Where is “thinning within riparian areas” other See the other vegetation treatments map in than in aspen areas and meadows planned? It’s the EA, or the online interactive map as unclear where or how much riparian logging is well as the table on page 2-8 of the EA. proposed, which we find alarming. 1-74 We want the Forest Service to completely avoid See the EA at 2-8 “For all Category 4 any shade reduction to streams in aspen streams, no trees acting as a primary source restoration and meadow restoration areas. of stream shading would be cut.” That is for all types of mechanical treatment. 1-75 The Flat analysis fails to examine the impacts of Design criteria specific to log haul begins on heavy equipment tree felling in RHCAs and log page 2-31 of the EA. Effects are described hauling along roads in RHCAs, as well as of re- in Chapter 3 at 3-148 and 3-187. opening closed roads in RHCAs and building “temporary” roads in RHCAs. 1-76 There should be discussion in the EA of the Refer to page 2-18 in the EA regarding Best relative effectiveness of specific project design Management Practices. criteria claimed to control sediment and prevent
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a measurable increase in sedimentation and embeddedness. 1-77 RMOs for large wood in RHCAs need to be met See response to comment 1-5. in aspen and meadow areas, rather than conifers being removed “harvested if economical”. 1-78 Drop sale units 116 and 213 from heavy See EA at 2-22 for design criteria to protect equipment use and commercial logging to soil resources. See also 2-34 “Region 6 prevent violation of Forest Plan detrimental soil Best Management Practice (BMP) impact standards. monitoring would occur within the Flat project area to ensure design criteria and BMPs are being utilized. Methods would be following the USFS National Best Management Practices for Water Quality Management (USDA 2012) for ground- based harvest activities. This monitoring would address erosion effects from heavy machinery including sediment runoff, overland flow scour, as well as mitigation effectiveness. Summer water temperature sites would continue to be installed at the downstream end of Camp Creek, Crooked Creek, Burnt Cabin Creek, Bridge Creek and House Creek. This should support expected benefits or effects can be observed over the long-term (5-15 years).
Soil monitoring would occur in the two specified units with high susceptibility of impacts as well as any harvesting in current wet conditions to ensure Forest Plan Standard is not exceeded.” 1-79 Drop logging of slopes greater than 35% to See response to comment 1-78. reduce soil damage and as these sale units are unlikely to support economic return from yarding. 1-80 Road subsoiling and decommissioning and any Thank you for your comment. See mitigations for skidtrails may not be 100% response to comment 1-78 regarding effective or fully implemented, so there is no hydrology and soil monitoring. guarantee that Forest Plan standards for detrimental soil impacts would not be violated. 1-81 Although we are not sure where these See the EA at 3-230 “No special or unique undeveloped lands are, were very concerned resource values in undeveloped lands have that 47-48% of those that now exist in the Flat been identified by project resource area would be managed in some way. Drop specialists in their environmental analysis “biomass reduction” to only noncommercial for the implementation of any alternative thinning by hand to greatly reduce the amount analyzed in detail.” The undeveloped of undeveloped lands with lasting management character analysis is done through a GIS impacts. exercise, and harvest activity older than 1980 are not included in the database. This
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does not mean that activities didn’t occur before then, and many of these areas contain stumps and other visual reminders of the past activities. 1-82 Drop all commercial size logging and biomass Thank you for your comment. See the EA extraction, roading, logging of large trees in at 2-2 for an alternative considered but aspen stands, and any other management eliminated from detailed analysis. “A “non- impacts other than prescribed burning and commercial size” restoration alternative NCTing by hand up to 8-9” dbh on all that restricts tree removal to 8-10” DBH undeveloped lands. was considered but eliminated from detailed analysis because it does not meet the purpose and need. By not treating all sizes of conifers up to 21 inches DBH, Alternative A would not meet the component of the purpose and need to “capture the economic value of harvested timber” and would not fully meet the components of the purpose and need to “Improve vegetation resilience and resistance to insects, disease and wildfire” and “Increase the diversity and structure of forest vegetation communities”.” Also the No Action alternative addresses your concerns.
1-83 The Flat EA fails to address the consequences to See the EA at 3-243, and Appendix B of the conditions in the broader landscape of removing EA. large trees greater than or equal to 21” dbh, given the great deficit in the large tree structure in the Flat project area. 1-84 The Flat EA fails to address the site specific See the EA at 3-152, effects to large woody conditions of the Flat area re: the pronounced debris in RHCAs. lack of large wood structure in RHCAs. 1-85 The Flat EA does not address the need to restore The purpose of the Flat project includes large tree structure to the Flat landscape. “Increase the diversity and structure of forest vegetation communities” which includes restoring large tree structure. 1-86 The Flat EA fails to analyze in depth the See response to comment 1-83. cumulative effects of large tree removal of the Flat project combined with the many similar amendments to remove large trees across the Malheur National Forest to wildlife species associated with large tree structure, to fish, to public recreational values, to soil nutrient cycling, and to carbon storage. 1-87 Once again, the Forest Service fails to accept See the EA at 3-249 for climate change responsibility for their increasing contributions information. to climate change through the increasing scale and pace of incremental deforestation and carbon storage reduction with timber sales now
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at 4000 to more than 20000 acres each of heavy commercial logging to low basal areas. 1-88 Blue Mountain Biodiversity Project also The EA states “Riparian treatments of submitted a summary of opposition and science overstocked stands…following proper to the RHCA treatments in Flat. There is concern design criteria and best management with water quality, temperature, sediment, practices, and utilizing recommended roads, wildlife habitat, climate change, fire and stream buffers (as described by INFISH) forest density. would greatly reduce and potential negative impact on water quality.” “Road maintenance by the timber purchaser will reduce the effects of log haul on sediment input by maintaining road surfaces and drainage structures and using dust abatement on haul roads. Temporary roads would be constructed outside of RHCAs and follow BMP guidelines. Temporary roads would be decommissioned at the completion of activities following BMP procedures, which would minimize the ground disturbing activities and potential erosion.” “The removal of commercially valuable material would be accomplished without bringing equipment into perennial RHCAs, such as line yarding. There would be no yarding across stream course. Trees located in and along the stream channel will not be cut as part of this treatment and will be reserved for maintaining Riparian Management Objectives for that stream reach.”
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Comment Letter #2 – Jack Southworth From: Jack and Teresa Southworth Sent: Tuesday, July 18, 2017 10:20:50 PM (UTC) Coordinated Universal Time To: FS-comments-pacificnorthwest-malheur-emigrantcreek Subject: Flat Vegetation Management Environmental Assessment
Hello Ms. Bailey and Ms. Ward;
I am very impressed with the intent of the Flat Project. It decreases small diameter timber, enhances aspen, meadows and riparian areas while at the same time creating a more fire tolerant forest. I support the Proposed Action, Alternative 2.
Sincerely, Jack Southworth Southworth Bros. Inc.
Responses to Comment Letter #2
Response to Comment 2-1: Thank you for your comment and your support.
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Comment Letter #3 – Frances M. Preston July 18, 2017
I am Frances M. Preston and I reside in Grant County, Oregon in the City of Prairie.
Because I am not sure how my comments were responded to during the scoping period I am resubmitting my original scoping comments plus comments during the Environmental Assessment comment period.
Below are my original scoping comments:
The Title is misleading in that it says Vegetation Management Project when in fact this Vegetation Management project will have impacts on roads in the form of 3-1 Closures and Decommissioning your title is not complete and needs to include all intended work. Please correct accordingly.
It is my opinion that roads marked for closure or decommissioning are currently used roads by either hunters, firewood cutters, motorized recreationalist, or subsistence 3-2 food gathers. Please remove the road closures/decommissioning as these actions will be a negative impact on those users.
3-3 Additionally, NEPA requires the project be coordinated with local governments.
• Have or will local governments be involved (County, Soil and Water, NRCS, others)? • Will their positions be taken into account. Will they be discussed, and analyzed? • If there are items needing to be resolved; i.e., inconsistencies between the local government and the federal agencies how and when would that occur? • What is the plan for discussion of any conflicts that cannot be resolved? • How will those discussions be documented in the final document?
Has an analysis been done or will one be done to show the “impact this proposed 3-4 action” will have on the productive use of our land and local economy?
3-5 How do I obtain Data Quality information:
• Quality
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• Objectivity • Utility • Integrity
Of information disseminated to the public on the Flat Project. Referencing the Data Quality Act or Information Quality Act of 2001.
Was or will an analysis of the economic and social impact on the small communities 3-6 as required by “the Regulatory Flexibility Act” be done to the extent to make a decision? If so, please can that report be made available and if not, why not? Was the data used local”? What are the data sources and what was the outcome?
Here are my Environmental Assessment comments:
This project does not meet the intent of the USDA’s mission of meeting it’s high standard of Environmental Justice when dealing with low-income populations. I 3-7 request that all roads in the project area be left open so that the populations in Grant and Harney Counties that depend on their open and free motorized access to the natural resources of the area can continue access to do so to sustain their families.
Executive Order 12898, Federal Actions to Address environmental Justice in Minority Populations and Low-income Populations (February 11, 1994), requires each Federal agency to achieve environmental justice as part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations (hereinafter “environmental justice communities”). At the USDA, environmental justice refers to meeting the needs of these under served communities by reducing disparate environmental burdens, removing barriers to participation in decision making, and increasing access to environmental benefits that help make all communities safe, vibrant, and healthy places to live and work. (See page 14 for definitions of commonly used terms.)
This project as currently described does not meet the intent of “increasing access to environmental benefits that help make all communities safe, vibrant, and healthy places to live and work” and actually goes one step further to actually reduce access to those benefits that the executive order calls for specifically.
The roads you have identified for closure or decommissioning serve as ingress and egress points for local search and rescue crews in a very isolated region of both counties. By allowing roads to grow over more with vegetation, and openly
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destroying other roads the Malheur National Forest, the Forest Supervisor and Regional Forester are putting the public in jeopardy of undo harm, and possibly death by not allowing timely access to residents if they come into harms way. For these reasons I request that all road closure and decommissioning be removed from the project.
3-8 Please do not close or decommission road #3770496
Specifically, I request that all roads identified for closure or decommissioning be removed from this project and that the vegetation treatment work be allowed to continue. Per Forest Supervisor, the forest will be doing travel management later in calendar 2018. There is no need to complete such a large scope of closures on the forest when the forest supervisor has openly stated and committed to keeping an open forest system on the Forest.
It is my understanding that I will receive responses to my individual comments. That is expected and will be appreciated; as I want to know what your responses are to my comments. Please let me know where I can go to read those or on what page of the various documents my comment answers can be located.
Respectfully Submitted,
/s/ Frances M. Preston
Frances M. Preston P.O. Box 3 121 South Washington St Prairie City, OR 97869
541-820-4463 907-723-7613
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Responses to Comment Letter #3
Response to Comment 3-1: The title of the Flat Vegetation Management Project is such because the main purpose of the project is to manage vegetation. When vegetation is managed by thinning or harvesting, cover is reduced for big game. In order to compensate for the reduction in cover, road densities need to be reduced to allow big game areas to move in response to disturbance. Therefore road activities are considered a connected action.
Response to Comment 3-2: Not all roads proposed for closure or decommissioning are drivable. Please refer to the Final EA, Chapter 3, Transportation System section for a description of the existing road condition.
The No Action alternative does not propose to close or decommission roads and therefore addresses your concerns.
Response to Comment 3-3: Please see the public involvement section in Chapter 1 of the Final EA and documents filed on the project website. Harney County and Grant County courts were briefed during the scoping period and the 30-day comment period. Additionally, other agencies received the scoping and 30-day comment documents.
Response to Comment 3-4: Please see the Socio-Economics section of the Final EA, Chapter 3 for a description of the effects on socio-economics. See also the Other Disclosures section of the Final EA, Chapter 3 for a description of the effects on productivity.
Response to Comment 3-5: The Data Quality Act (DQA) is an attempt by Congress to ensure that federal agencies use and disseminate accurate information. Please refer to the EA for data on this project. Also refer to Chapter 3 of the EA, the use of “best available science”. If you have any questions concerning specific data, please advise us.
Response to Comment 3-6: Please see the Socio-Economics section of the Final EA, Chapter 3 for a description of the effects on socio-economics. Additionally, specialist reports will be available on the website when finalized.
Response to Comment 3-7: The Final EA, Chapter 3, Socio-Economics section on page 3- xxx states “Each Federal agency is required to make environmental justice part of its mission (CEQ 1997, p. 1). The National Environmental Policy Act (NEPA) and the forest planning process are the primary ways the Forest Service incorporates environmental justice into its activities. Executive Order 12898 on environmental justice requires federal agencies to identify and address any disproportionately high and adverse human health or environmental effects on minority and low-income populations. The Forest Service defines environmental justice in accordance with USDA departmental regulations (USDA 1997). Environmental justice includes the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies (U.S. EPA 2013).”
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“An environmental justice population is a group of people that meets the criterion for low- income or minority under Executive Order 12898 (Clinton 1994). An environmental justice population may be both low income and minority. Fair treatment means that environmental justice populations do not bear a greater burden of environmental harms and risks than the general population from Forest Service programs and policies. Meaningful involvement has four parts: (1) potentially affected environmental justice populations have opportunities to participate in decision making processes affecting their environment or health; (2) the contributions of environmental justice populations may influence the agency’s decision; (3) the concerns of all participants are considered in the decision- making process; and (4) the decision makers seek out and facilitate the involvement of environmental justice populations (U.S. EPA 2010).” Minority and low income populations and the effects to them have been described in the Final EA, Chapter 3, Socio-Economics section. “Although the data suggests that neither Grant nor Harney Counties have a meaningfully greater minority population than the adjacent geographic areas, Harney County’s American Indian population may indicate a minority population because the Burns Paiute Reservation is a small-scale minority community located within a larger county that is predominantly non-minority. American Indians therefore may be vulnerable to disproportionate negative impacts of this project.” Final EA at 3-191. Additionally, “The data suggests that Harney County has a low-income population that may be vulnerable to disproportionate negative impacts of this project.” Final EA at 3-192.
Additionally, the no action alternative would not close or decommission any roads in the project area and therefore addresses your concerns.
Response to Comment 3-8: If you are referring to the road identified in the power point presentation that was labeled a closed road but being driven, that road was mislabeled. It is the 3770492 road. This road has been administratively closed with pole gates on both ends. The pole gate on the south end of the 3770492 road at the junction with the 3770 road has been breached, thus providing motorized travel on about ¼ to ½ mile of a closed road to the junction of the 493 road. At that point, neither the 3770492 road nor the 493 road are drivable and the 493 road crosses a creek, which is producing sediment into the stream. All of these closed roads are less than a mile of the 3100 road, which provides motorized access to that part of the forest. These roads are already closed and the closures would be reinforced as stated below.
The Final EA, Chapter 2, at 2-13 states “There are 80.6 miles of roads in the project area currently designated in the transportation system as closed to vehicular travel and 8.3 miles decommissioned based on prior planning decisions or administrative actions. However, many of these roads are ineffectively closed/decommissioned so their existence and use are potentially impacting habitat and security for wildlife, soil and timber productivity, and water quality. Previously closed or decommissioned roads would be monitored for effectiveness and if the closure or decommission is determined to not be effective, the closure/decommission would be reinforced. These activities would occur during implementation of this project.”
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Comment Letter #4 – Zach Williams, Iron Triangle LLC
4-1
4-2
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4-3
4-4
4-5
4-6
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Responses to Comment Letter #4
Response to Comment 4-1: The EA covers mechanical slash removal to describe effects of such treatments. After treatment, monitoring may determine that slash piling is not necessary due to the low amount of slash created. These units may be treated by jack pot burning. Rx burn only would be considered if slash levels are at a level that it can be burned safely.
Response to Comment 4-2: The project silviculturist has determined that no skips and gaps would be located in units less than 50 acres in size. This is because units less than 50 acres are small enough that edge effects from adjacent stands gives them their variability.
Response to Comment 4-3: During the development of the Proposed Action and Alternative 3, all roads were analyzed. In fact 2 roads or segments of roads totaling 1.8 miles would be opened. The analysis for past road closures has already been completed. The EA is just reiterating that “Previously closed or decommissioned roads would be monitored for effectiveness and if the closure is determined to not be effective, the closure/decommission would be reinforced. These activities would occur during the implementation of this project.” Final EA at 2-13.
Response to Comment 4-4: Thank you for your comment. The Final EA has been updated with this information. Final EA at 2-20.
Response to Comment 4-5: The Final EA has been updated with the following information. Species composition of the sales: • Ponderosa Pine – 45% • Douglas-fir – 20% • Grand fir – 10% • Lodgepole pine – 25%
Response to Comment 4-6: The Final EA, Chapter 3, Socio-Economics section states “It is estimated that approximately 20 percent of the total volume is green convertible biomass (ponderosa pine 7 to 10.9 inches diameter at breast height.”
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Comment Letter #5 – Dick Artley, Retired July 19, 2017
Dear Ranger Cheyne and selected IDT members,
Please accept these comments on the preliminary EA for the proposed Flat timber sale.
Ranger Cheyne, I will do all I can to assure you and your IDT members will all be jailed for Reckless Endangerment of the American public --- a gross misdemeanor. A person who is guilty of reckless endangerment creates a substantial risk of death or serious physical injury to another person. Your witless quest for volume caused you to withhold from the public the most effective fire risk reduction method used world wide developed by a USFS fire physicist. Dr. Cohen’s research conclusions show commercial logging to remove “hazardous fuels” is a waste of the taxpayer’s dollar compared to removing fine fuels within several hundred feet of a structure at risk.
Of course the USFS rejects this science because fine fuels reduction that requires no commercial logging does not produce timber volume. You will all be infamous. You will not be able to claim “I didn’t know” in court because I am presenting this information to you below and in Opposing Views Attachment 11.
I suggest you prepare yourself. Soon the WUI-related parts of these comments will be emailed to the John Day City Council. Mr. Miller and Mr. Hasher will give them to the city attorneys to address.
Who are you people? The USFS does not own the Malheur National Forest.
Comment #: Why am I not surprised that the project area maps label National Forest land as “US Forest Service.” The Malheur National Forest is public land owned by 321 million America. Based on the tragic natural resource impacts to publically owned land that will be caused by your logging and roading, the Emigrant Ranger District employees feel it’s their job to have your way with public land they are paid to protect and preserve for future generations to generate corporate profit opportunities. You should all hang your heads in shame.
FS Response: Effects to all resources can be found in Chapter 3 of the EA.
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------Issue #1 ----- What type of person hides important information from the public. Wouldn’t you want to know if your family might be exposed to a carcinogen? Federal Officials who knowingly put the public at risk are subject to civil laws and if convicted they face prison, fines or both. Normal, mentally stable people would never knowingly take action that might injure (or even kill) other people just because their employer says it’s OK.
Ranger Cheyne, incredibly, the preliminary EA tells the public you will apply a herbicide chemical in the Malheur National Forest without identifying the brand name or formulation of the chemical. What is the agency coming to? Are they hiring unthinking robots who believe the public doesn’t care if they die from cancer? Who are you?
Even casual exposure to glyphosate could kill and maim terrestrial wildlife, birds and will kill aquatic life with water concentrations of just a few parts per million.
Your description of the Weed Prevention Plan at page 2-33 states:
“This allows for some use of herbicides in addition to manual and mechanical methods of treatments at infestation sites.”
You must have read about Monsanto in the news. Do you trust them to put safety ahead of profit? America has the highest cancer rate of any industrialized country in the world. Red the obituaries and you will learn most people died of cancer. In spite of the warnings you applied glyphosate in the past just because the USDA said it was safe. Perhaps in a few years you might be responsible for the death of the person named in the obituary.
Many carefully designed studies link glyphosate to horrendous bodily harm. How will you be at ease with yourself over the rest of your life knowing you planted the cancer seed where families will camp or hike?
If glyphosate is safe why would herbicides that contain the chemical be bannedDenmark, England, Italy, El Salvador, Sri Lanka, France, Holland, Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan, Chile, South Africa, Luxembourg, Madeira, Cameroon, New Zealand, Peru, South Australia, Russia, France,Switzerland, Columbia, and Costa Rica?
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Ms. Foster, wouldn’t you want to know when you and your family members would be exposed to a potent carcinogen?
Here’s the latest on this lethal chemical. Anyone, I repeat, anyone who applies herbicides containing glyphosate to public land after reading the articles below should be indicted and appear in a court of law.
Most normal, civilized people would never take action if there were even a tiny chance it might kill someone.
Article title: California to Officially List Key Ingredient in Monsanto's Roundup as Cancer-Causing Published online by Organic Consumer’s Assn, June 26, 2017 Link to full article: https://www.organicconsumers.org/news/california-officially-list-key-ingredient-monsantos- roundup-cancer-causing
Excerpts:
“Glyphosate, the main ingredient in Monsanto's widely used herbicide Roundup, will be added July 7 to California's list of chemicals known to the state to cause cancer, according to a Reuters report Tuesday. This news comes after the company's unsuccessful attempt to block the listing in trial court and requests for stay were denied by a state appellate court and California's Supreme Court.”
Article title: OF MICE, MONSANTO AND A MYSTERIOUS TUMOR Published in Truthout, June 16, 2017 Link to full article: http://www.environmentalhealthnews.org/ehs/news/2017/june/of-mice-monsanto-and-a- mysterious-tumor
Excerpts:
“It's been 34 years since Monsanto Co. presented US regulators with a seemingly routine study analyzing the effects the company's best-selling herbicide might have on rodents. Now, that study is once again under the microscope, emerging as a potentially pivotal piece of evidence in litigation brought by hundreds of people who claim Monsanto's weed killer gave them cancer.
This month, tissue slides from long-dead mice in that long-ago research study are being scrutinized by fresh eyes as an expert pathologist employed by lawyers for cancer victims looks
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for evidence the lawyers hope will help prove a cover-up of the dangers of the weed killer called glyphosate.”
“But EPA toxicology experts were unconvinced. EPA statistician and toxicology branch member Herbert Lacayo authored a February 1985 memo outlining disagreement with Monsanto's position. A "prudent person would reject the Monsanto assumption that Glyphosate dosing has no effect on kidney tumor production," Lacayo wrote. "Glyphosate is suspect. Monsanto's argument is unacceptable." “
Article title: Patients: Roundup gave us cancer as EPA official helped the company Published online by CNN, May 16, 2017 Link to full article: http://www.cnn.com/2017/05/15/health/roundup-herbicide-cancer-allegations/
Excerpts:
“Christine Sheppard fantasizes about her life before cancer. Before she had to take painkillers "all the time." Before she had to seriously worry about when she might die.”
“For 12 years, Sheppard had no idea what might have caused her non-Hodgkin's lymphoma -- until a group of cancer researchers reported (PDF) that glyphosate, the key ingredient in the popular weed killer Roundup, is "probably carcinogenic to humans" (PDF).”
“Sheppard is one of more than 800 cancer patients suing Monsanto, the maker of Roundup, claiming the company failed to warn consumers about the risk of cancer associated with Roundup products.”
Article title: The Monsanto Tribunal’s Legal Opinion Reinforces Movements’ Struggle for Basic Human Rights Published online by Common Dreams, April 19, 2017 Link to full article: https://www.commondreams.org/views/2017/04/19/monsanto-tribunals- legal-opinion-reinforces-movements-struggle-basic-human-rights
Excerpt:
"The Monsanto Tribunal confirmed how poisonous products and toxic chemicals such as Round Up (Glyphosate) & Basta (Glufosinate), neonicotinoids, atrazine, and other pesticides have led to the destruction of soils, to desertification, to the extermination of bees, to the rise in health epidemics such as cancer, birth defects, and respiratory disease, to name just a few. They are contaminating people by polluting areas and poisoning our food systems. The recent UN’s Report of the Special Rapporteur on the right to food, Hilal Elver, provides a clear account on the negative effects of global pesticide use in agriculture and its impact on human rights. Last September, the International Criminal Court declared it would prioritise crimes that result in the “destruction of the environment”, “exploitation of natural resources” and the “illegal dispossession” of land 33
Flat Project Comment Analysis
and that it would now take many crimes that have been traditionally under-prosecuted into consideration. The ICC , though not formally extending its jurisdiction, will assess existing offences, such as crimes against humanity, in a broader context.”
Article title: GLYPHOSATE: HEALTH CONCERNS ABOUT THE MOST WIDELY USED PESTICIDE Published online by Truthout, April 5, 2017 Link to full article: http://www.truth-out.org/news/item/40106-glyphosate-health-concerns- about-the-most-widely-used-pesticide
Excerpts:
“More than 50 lawsuits against Monsanto Co. are pending in US District Court in San Francisco, filed by people alleging that exposure to Roundup herbicide caused them or their loved ones to develop non-Hodgkin lymphoma, and that Monsanto covered up the risks. The litigation has been consolidated as multidistrict litigation (MDL) for more efficient processing. Several hundred similar actions are pending in state courts.
In March 2017, the federal court judge overseeing the MDL unsealed some internal Monsanto documents that raised new questions about Monsanto's influence on the EPA process and about the research regulators rely on. The documents suggest that Monsanto's long-standing claims about the safety of glyphosate and Roundup do not necessarily rely on sound science as the company asserts, but on efforts to manipulate the science.”
Article title: USDA drops plan to test for Monsanto weed killer in food Published online by Nation of Change, March 28, 2017 Links to full article: http://www.nationofchange.org/2017/03/25/usda-drops-plan-test-monsanto- weed-killer-food/
http://gmwatch.org/news/latest-news/17519-usda-drops-plan-to-test-for-glyphosate-residues-in- food
https://www.organicconsumers.org/news/usda-drops-plan-test-monsanto-weed-killer-food
http://todayeco.com/pages/91671667-usda-drops-plan-to-test-for-monsanto-weed-killer-in-food
http://ecotopical.com/ecowatch/171587/usda-drops-plan-to-test-for-monsanto-weed-killer-in- food/
Excerpt:
“The USDA does not routinely test for glyphosate as it does for other pesticides used in food production. But that stance has made the USDA the subject of criticism as controversy over glyphosate safety has mounted in recent years. The discussions of testing this year come as U.S. and European regulators are wrestling with cancer 34
Flat Project Comment Analysis
concerns about the chemical, and as Monsanto, which has made billions of dollars from its glyphosate-based herbicides, is being sued by hundreds of people who claim exposures to Roundup caused them or their loved ones to suffer from non-Hodgkin lymphoma. Internal Monsanto documents obtained by plaintiffs’ attorneys in those cases indicate that Monsanto may have manipulated research regulators relied on to garner favorable safety assessments and last week, Congressman Ted Lieu called for a probe by the Department of Justice into Monsanto’s actions.”
Article title: BEHIND A CORPORATE MONSTER: HOW MONSANTO PUSHES AGRICULTURAL DOMINATION Published online by Truthout, March 19, 2017 Link to full article: http://www.truth-out.org/news/item/39904-behind-a-corporate-monster-how- monsanto-pushes-agricultural-domination
Excerpts:
“Independent studies on Roundup found that the full formulation was much more toxic than glyphosate, the active ingredient, itself. Monsanto's tests were only conducted on glyphosate, not Roundup.
Public laboratories are reluctant to conduct research on Roundup and other product toxicity because most biotechnology research is only funded by the biotechnology companies. Researchers know their careers will suffer if they do this type of research. Monsanto refuses to supply GM seeds for independent research.”
Article title: Lawsuit accuses Monsanto of manipulating research to hide Roundup dangers Published online by CBS News, March 16, 2017 Link to full article: http://www.cbsnews.com/news/lawsuit-accuses-monsanto-of-manipulating- research-to-hide-roundup-dangers/
Excerpt:
“Court documents also reveal conversations between Monsanto executives and an EPA director about a federal glyphosate review. “I doubt EPA and Jess can kill this, but it’s good to know they are going to actually make the effort,” a Monsanto executive wrote.”
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Article title: California can require a cancer warning label on Roundup weed killer, judge rules Published online by the Los Angeles Times, March 14, 2017 Link to full article: http://www.latimes.com/business/la-fi-roundup-california-20170314- story.html
Excerpts:
“A Fresno County Superior Court judge issued her final ruling Friday in the failed attempt by chemical giant Monsanto to stop California from listing a key ingredient in its popular herbicide, Roundup, as a carcinogen.
Judge Kristi Culver Kapetan had issued a tentative ruling on Jan. 27, denying Monsanto’s request. In her final ruling, the judge said that none of Monsanto’s objections were viable.
The multinational agrochemical company sued the state Environmental Protection Agency’s Office of Environmental Health Hazard Assessment last January after the agency issued a notice of intent to add glyphosate to its Proposition 65 list of chemicals known to cause cancer. The company has denied any link to cancer through the use of glyphosate, the active ingredient in Roundup.”
Article Title: Monsanto Weed Killer Roundup Faces New Doubts on Safety in Unsealed Documents Published in the New York Times, March 14, 2017 Link to full article: https://www.organicconsumers.org/news/monsanto-weed-killer-roundup- faces-new-doubts-safety-unsealed-documents
Excerpts:
“Court records show that Monsanto was tipped off to the determination by a deputy division director at the E.P.A., Jess Rowland, months beforehand. That led the company to prepare a public relations assault on the finding well in advance of its publication. Monsanto executives, in their internal email traffic, also said Mr. Rowland had promised to beat back an effort by the Department of Health and Human Services to conduct its own review.
Dan Jenkins, a Monsanto executive, said in an email in 2015 that Mr. Rowland, referring to the other agency’s potential review, had told him, “If I can kill this, I should get a medal.” The review never took place. In another email, Mr. Jenkins noted to a colleague that Mr. Rowland was planning to retire and said he “could be useful as we move forward with ongoing glyphosate defense.” “
Article title: EPA Official Accused of Helping Monsanto ‘Kill’ Cancer Study
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Published online by Bloomberg, March 14, 2017 Link to full article: http://www.latimes.com/business/la-fi-roundup-california-20170314- story.html
Excerpts:
“The Environmental Protection Agency official who was in charge of evaluating the cancer risk of Monsanto Co.’s Roundup allegedly bragged to a company executive that he deserved a medal if he could kill another agency’s investigation into the herbicide’s key chemical.
The boast was made during an April 2015 phone conversation, according to farmers and others who say they’ve been sickened by the weed killer. After leaving his job as a manager in the EPA’s pesticide division last year, Jess Rowland has become a central figure in more than 20 lawsuits in the U.S. accusing the company of failing to warn consumers and regulators of the risk that its glyphosate-based herbicide can cause non- Hodgkin’s lymphoma.”
“A federal judge overseeing the glyphosate litigation in San Francisco said last month he’s inclined to order Rowland to submit to questioning by lawyers for the plaintiffs, who contend he had a "highly suspicious" relationship with Monsanto. Rowland oversaw a committee that found insufficient evidence to conclude glyphosate causes cancer and quit last year shortly after his report was leaked to the press.”
Article title: Monsanto Weed Killer Roundup Faces New Doubts on Safety in Unsealed Documents Published online by the New York Times March 14, 2017 Link to full article: https://www.nytimes.com/2017/03/14/business/monsanto-roundup-safety- lawsuit.html?_r=0
Excerpts:
“The reputation of Roundup, whose active ingredient is the world’s most widely used weed killer, took a hit on Tuesday when a federal court unsealed documents raising questions about its safety and the research practices of its manufacturer, the chemical giant Monsanto.”
“The court documents included Monsanto’s internal emails and email traffic between the company and federal regulators. The records suggested that Monsanto had ghostwritten research that was later attributed to academics and indicated that a senior official at the Environmental Protection Agency had worked to quash a review of Roundup’s main ingredient, glyphosate, that was to have been conducted by the United States Department of Health and Human Services.”
Article title: Unsealed Court Documents Suggest Monsanto Ghostwrote Research to Coverup Roundup Cancer Risk Published online by the Ecowatch, March 10, 2017 Link to full article: http://www.ecowatch.com/monsanto-cancer-roundup-coverup- 2317043832.html
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Excerpts:
“Monsanto suffered a major setback Tuesday when a federal judge in San Francisco unsealed documents that call into question the agrichemical giant's research practices and the safety of its best-selling herbicide, Roundup, the world's most-produced weedkiller. The documents counter industry-funded research that has long asserted Monsanto's flagship product—used by home gardeners, public park gardeners and farmers and applied to hundreds of crops—is relatively safe.
The court documents included Monsanto's internal emails and email traffic between the company and federal regulators. The records suggested that Monsanto had ghostwritten research that was later attributed to academics and indicated that a senior official at the Environmental Protection Agency had worked to quash a review of Roundup's main ingredient, glyphosate, that was to have been conducted by the United States Department of Health and Human Services.”
Article title: Monsanto Isn’t Feeding the World—It’s Killing Our Children Published online by the Organic Consumers Assn. March 9, 2017 Link to full article: https://www.organicconsumers.org/blog/monsanto-isn%E2%80%99t- feeding-world%E2%80%94it%E2%80%99s-killing-our-children
Excerpts:
“Two new reports published in recent weeks add to the already large and convincing body of evidence, accumulated over more than half a century, that agricultural pesticides and other toxic chemicals are poisoning us.
Both reports issue scathing indictments of U.S. and global regulatory systems that collude with chemical companies to hide the truth from the public, while they fill their coffers with ill-gotten profits.
According to the World Health Organization, whose report focused on a range of environmental risks, the cost of a polluted environment adds up to the deaths of 1.7 million children every year.”
Other science articles that would convince any intelligent, caring human being to use an alternative to herbicides that contain glyphosate are contained in the Glyphosate 1 attachment.
Request for changes to be made to the final NEPA document: If it does not clearly indicate herbicides that contain glyphosate will not be used anywhere, at any time, for any reason I suggest you find a good attorney. You see, my letters to the editor to the Blue Mountain Eagle that will describe several articles above. Ranger Cheyne my letters will divulge your name and office phone number. They will indicate you ignored best science and spewed Roundup anyway. My letters will suggest the public contact you.
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Failure to tell the public this chemical will not be applied to your forest leaves the door open for glyphosate application.
Federal Officials who knowingly put the public at risk are subject to civil laws and if convicted they face prison, fines or both.
Not telling the public they will likely be exposed to a chemical that sometimes causes cancer violates:
18 U.S.C. § 1001(c) because the Responsible Official relied on a single (emphasis added) research conclusion that glyphosate is safe made by a lab with possible ties to Monsanto (Syracuse Environmental Research Associates--SERA) knowing the research conducted by hundreds of independent scientists reveals glyphosate exposure may cause birth defects, miscarriages, premature births, cancer - non-Hodgkin’s lymphoma and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning disabilities, ADHD and other neurological disorders (especially in children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, decrease in the sperm count and chromosomal damage
40 CFR 1501.2 (b), 40 CFR 1502.16(a) and (b), and 40 CFR 1508.8(b) because Chapter 3 omits important environmental effect disclosures related to glyphosate research (i.e. glyphosate exposure is statistically correlated to birth defects, miscarriages, premature births, cancer - non-Hodgkin’s lymphoma and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning disabilities, ADHD and other neurological disorders (especially in children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, decrease in the sperm count and chromosomal damage cancer)
40 CFR §1508.27(b)(2) because the intensity discussion fails to discuss the degree to which the proposed action affects public health or safety.
The Apr. 21, 1997 Executive Order No. 13045 because the Responsible Official does not ensure that this project will not disproportionately expose children to environmental health risks and safety risks.
40 CFR §1508.27(b)(2) because the FOIA intensity discussion will not discuss the degree to which the proposed action affects public health or safety.
FS Response: The Flat project does not propose the use of herbicide. See the EA at 3-52 “See the 2005 Pacific Northwest Region Preventing and Managing Invasive Plants Final Environmental Impact Statement and Record of Decision and the 2015 Malheur National Forest Site-Specific Invasive Plants Treatment Project Final Environmental Impact Statement and Record of Decision for details on the planning, environmental effects, and implementation strategy for invasive plant treatments.
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------Issue #2 ----- Ranger Cheyne, please apply Dr. Jack Cohen’s fine fuels removal methods to further reduce the risk to people’s homes and the lives of family members in the WUI areas that are at risk should a wildfire start nearby.
Without changes between draft & final you will risk people’s lives. There are severe civil penalties for federal officials convicted of knowingly putting the public at risk.
The Flat timber sale pre-decisional EA tells the public at page 3-43 that private property in the WUI near this sale is at risk of burning. I have quoted this information below:
“Reducing the fuel loadings, fuel continuity, and the availability of ladder fuels keeps fire confined as a surface fire and reduces the occurrence of firebrands, which increases the ability to control fires. In the Wildland Urban Interface (WUI), reducing the threat of ignition from firebrands requires reducing fuels both near and at some distance from the structures. Proposed treatments reduce the likelihood of firebrands being lofted onto private land and structures. This improves our ability to protect life and property.”
The research conclusions of Dr. Jack Cohen (a USFS employee) explaining why and how logging is an ineffective way to reduce fire intensity and rate of spread are contained in Opposing Views Attachment #11.
When you are confronted with this information in a court of law how will you refute the independent scientists’ findings?
This 2014 High Country News article describes the effectiveness Dr. Cohen’s fine fuels removal methods: http://www.hcn.org/articles/the-loss-of-homes-to-wildfire-is-as-much-a-sociopolitical- problem-as-it-is-a-physical
Comment #: Ranger Cheyne, one of your fellow USFS employees’ research conclusions indicates fine fuels removal is far superior to commercial hazardous fuels logging farther away from the WUI than 100 yards, yet your draft EA doesn’t mention Dr. Cohen’s research conclusions. Dr. Cohen states several times in the many scientific papers he authored that commercial fuels removal farther than “100 to 200” feet from the WUI in ineffective. Why then do you propose widespread fuels logging? Of course I know the answer … you want the volume. What type of person would allow people to burn up for volume?
Request for changes to be made to the final NEPA document: Analyze another action alternative that will educate people about Dr. Cohen’s methods and use USS employees to help
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Flat Project Comment Analysis people living in the WUI to implement Dr. Cohen’s methods if they are unable to do the work themselves. This alternative would require you to do the following:
• distribute handouts to WUI residents describing Dr. Cohen’s fine fuels removal methods (where and how).
• contact the people living in the WUI and announce fine fuels removal workshops will be held to answer questions. These workshops will present Dr. Cohen’s research conclusions that prove commercial hazardous fuels logging farther than 100 yards from the WUI is ineffective.
• offer to remove the fine fuels (with written permission) on private property owned by elderly and disabled homeowners who cannot do the work themselves.
• Assure your Cohen alternative P&N is something like this “reduce the chance that homes will burn in the WUI should a wildfire start in the area by 1) applying Dr. Cohen’s fine fuels removal methods, and 2) removing hazardous fuels within 100 yards of the WUI boundary.
This issue is too serious to sweep under the rug.
If this does not occur, you will violate:
• 40 CFR 1500.2(e) because you were unable to avoid or minimize adverse effects of the project upon the quality of the human environment without complete knowledge of all likely adverse effects. Most adverse effects of project activities described by scientists in the Opposing Views Attachment #11 and the Logging and Fire Spread attachment was not mentioned in the draft EA.
• 40 CFR 1500.2(f) because you were unable to avoid or minimize any possible adverse effects upon the quality of the human environment without knowledge of the adverse effects. Had you known about these effects you would have acknowledged the existence of some adverse effects described in the Opposing Views Attachment #11 and the Logging and Fire Spread attachment in the draft EA.
• NEPA Sec. 101(b)(2) because the you do not “assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings;”
• NEPA Sec. 101(c) because “The Congress recognizes that each person should enjoy a healthful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment.”
• Ex. Ord. No. 13045, Apr. 21, 1997 [section 1-101(a)] because you do not “make it a high priority to identify and assess environmental health risks and safety risks that may disproportionately affect children.”
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• The draft FONSI will violate 40 CFR §1508.27(b)(2) because the intensity discussion will not discuss the degree to which the proposed action affects public health or safety.
FS Response: The purposes for the Flat project are: • Improve vegetation resilience and resistance to insects, disease and wildfire • Increase the diversity and structure of forest vegetation communities • Improve meadow, aspen, riparian habitats, and overall watershed condition • Enhance sagebrush steppe habitats and upland shrubs • Promote low severity fire on the landscape as a natural disturbance regime • Reduce road related impacts to the watershed (terrestrial and aquatic habitat, and water quality) • Capture the economic value of harvested timber Nowhere is the purpose to reduce hazardous fuels. All good information for protecting structures in the WUI.
------Conclusion
Ranger Cheyne and IDT members, your indoctrination started during your first week with the USFS. They knew new employees all had different backgrounds and land ethics. They didn’t want employees who didn’t all embrace the unwritten agency mission --- get-out the cut. They wanted “team players” who believed timber harvest will correct and solve most forest problems … real, but mostly contrived. They borrowed the industrial tree farm goals and taught you this is how the national forest’s conifer tree species must be managed. You were taught natural, biodiverse forests must be manipulated. Most importantly, you were taught doing nothing and monitoring the natural resources in the forest is unacceptable.
In spite of the fact the USFS claims biodiversity is a goal, they told you to “manage” (a.k.a. commercially log) to create park-like, neat and tidy stands that are the antithesis of biodiversity. Some of you know this but turn your back. Why? Money!!!!!!!!!!!!
If you and your IDT members have the courage to seriously examine the best science contained in Opposing Views Attachments #1 and #4 it won’t take long to become aware that independent scientists recognized as experts in their fields describe multiple tragic resource effects that result from the “forest management” you were taught was the right thing to do.
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Both can’t be right can they? You know what to do. Redo this draft NEPA document to eliminate the corporate-friendly destructive “treatments.” This could be the first day of real satisfaction with your jobs.
------Sincerely,
Dick Artley’s scanned signature is contained in the “signature” attachment.
Dick Artley (retired forester, logging engineer and forest planner - Nez Perce National Forest) 415 NE 2nd Street Grangeville, Idaho 83530 [email protected]
CC: Supervisor Beverlin Ranger Halemeier Mr. Dixon
Note: I am filing these comments etc. in my own individual capacity, as well as on behalf of WildLands Defense in Boise, Idaho. I am a member of the group. It retains full-time attorneys. I fully expect the Deputy Regional Forester to reject the parts of my objection that aren’t trivial. When that happens other action will be necessary including involvement by Democratic members of Congress. “Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has.”
Margaret Mead
Science showing Logged Areas do not affect Fire Spread and Intensity
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1) Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats
Published by the Government Accounting Office, GAO/RCED-99-65
Link: http://www.gao.gov/archive/1999/rc99065.pdf
Excerpts:
“In recent years, the number of people living along the boundaries of the national forests has grown significantly. As a result, the increasing numbers of larger, more intense fires pose grave hazards to human health, safety, property, and infrastructure in these areas, which are referred to as “wildland/urban interface” areas. Not only do the fires take lives, but also, because the smoke from them contains substantial amounts of fine particulate matter and other hazardous pollutants, they can pose substantial health risks to people living in the wildland/urban interface.” (page 5)
"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." (page 7)
“The agency relies on timber production to fund many of its programs and activities, and all three of its budget allocation criteria for timber activities relate solely to the volume of timber produced or offered. As a result, as forest officials told us, they tend to (1) focus on areas with high-value commercial timber rather than on areas with high fire hazards or (2) include more large, commercially valuable trees in a timber sale than are necessary to reduce the accumulated fuels. Similarly, an interagency team that reviewed the implementation of the Emergency Salvage Timber Sale Program observed that some Forest Service personnel focused more on harvesting timber than on protecting forested ecosystems.” (page 43) FS Response: Relevant. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels. Design criteria are in place to protect wildlife and special habitats.
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2) “Sierra Nevada Ecosystem Project: Final Report to Congress -- Volume 1, Chapter 4 – Fire and Fuels. Source for quote above: University of California; SNEP Science Team and Special Consultants http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf
Excerpts:
"Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62)
"Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes. In general, rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds."
"As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high.”
FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37.
3) Testimony to the Agriculture, Nutrition and Forestry Committee United State Senate. Hearing to Review Healthy Forests Restoration Act, HR 1904 on June 26, 2003 By:, Arthur Partridge Ph.D., Professor Emeritus, University of Idaho Link: http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml
Excerpt:
“The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire
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are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.”
FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
4) A USFS scientist comments on logging and fire behavior
By Tom Kuglin, writing about Dr. Mark Finney’s research
Published in the Helena Independent Record newspaper, June 17, 2015
Link: http://helenair.com/news/local/researcher-finds-need-for-more-prescribed- burning/article_4a58c3c3-a7bb-5905-a505-4567e8107600.html
Mark Finney, Ph.D., a research forester with the U.S. Forest Service Fire Lab in Missoula.
Excerpts:
“Finney presented his research on fire behavior in landscapes of varying levels of logging and prescribed burning at last week’s “Fire on the Landscape” lecture series in Helena. While logging or thinning is often touted as a means to mitigate fire, he has found it does little to stop a wildfire.”
“There’s a confusion that if you do timber management you’re doing fuel management -- you’re not,” Finney said. “We’re not going to cut our way out of the problem, but there are ways to do this strategically, get the benefits and have a sustainable fire management approach.”
“Finney found that fire “ripped through logged areas,” and only units where prescribed fire was introduced showed effectiveness in stopping or mitigating wildfire spread.” FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
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5) Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States?
ABSTRACT: "There is a widespread view among land managers and others that the protected status of many forestlands in the western United States corresponds with higher fire severity levels due to historical restrictions on logging that contribute to greater amounts of biomass and fuel loading in less intensively managed areas, particularly after decades of fire suppression. This view has led to recent proposals—both administrative and legislative—to reduce or eliminate forest protections and increase some forms of logging based on the belief that restrictions on active management have increased fire severity. We investigated the relationship between protected status and fire severity using the Random Forests algorithm applied to 1500 fires affecting 9.5 million hectares between 1984 and 2014 in pine (Pinus ponderosa, Pinus jeffreyi) and mixed-conifer forests of western United States, accounting for key topographic and climate variables. We found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. Our results suggest a need to reconsider current overly simplistic assumptions about the relationship between forest protection and fire severity in fire management and policy."
Authors: Curt Bradley, Dr. Chad Hanson and Dr. Dominick Della Sala
Published in the October 26, 2016 Ecological Society of America publication Ecosphere
Link: http://onlinelibrary.wiley.com/doi/10.1002/ecs2.1492/full
FS Response: The Flat project’s purpose is not to reduce fuels, but “• Improve vegetation resilience and resistance to insects, disease and wildfire • Increase the diversity and structure of forest vegetation communities • Improve meadow, aspen, riparian habitats, and overall watershed condition • Enhance sagebrush steppe habitats and upland shrubs • Promote low severity fire on the landscape as a natural disturbance regime • Reduce road related impacts to the watershed (terrestrial and aquatic habitat, and water quality) • Capture the economic value of harvested timber” EA at 1-1.
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6) Study challenges views about Western forest fires
Published by the Daily World, July 23, 2012
By Scott Sonner AP
Link: http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views-about- western-forest-fires.html
Excerpts:
“RENO, Nev. — Scientists using field notes from surveys first conducted by the government before the Civil War believe they’ve gained a better understanding of how Western wildfires behaved historically.
Researchers at the University of Wyoming studied historical fire patterns across millions of acres of dry Western forests. Their findings challenge the current operating protocol of the U.S. Forest Service and other agencies that today’s fires are burning hotter and more frequently than in the past.”
“More highly intense fire is not occurring now than historically in dry forests,” said William Baker, who teaches fire ecology and landscape ecology in Laramie, Wyo., where he’s been doing research more than 20 years. “These forests were much more diverse and experienced a much wider mixture of fire than we thought in the past, including substantial amounts of high-severity fire.”
“The major surprising finding was … areas of high density of forest and higher severity fires in really all dry forests across the West,” said Mark Williams, who co-authored two of the three studies with Baker.
“Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes.
“We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.” “ FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape. Additionally, see the EA at 3-19 “Studies from many areas that have looked at historic data suggest that these frequently burned forests had very low tree densities, a greater proportion of ponderosa pine, a clustered stem pattern with highly variable canopy cover, and the majority of growing space taken up by fire- resistant, large-diameter trees (Collins and Stephens 2010, Covington and Moore 1994,
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Hagmann et al. 2013, Hessburg et al. 2005, Kaufmann et al. 1998, Minnich et al. 1995, North et al. 2009, Smith and Fischer 1997, Wright and Agee 2004). Historic fire regimes favored low tree density (28-40 trees per acre), simple canopy structures with little understory, and patchy fuels, and were dominated by ponderosa pine with some Douglas-fir that would escape the frequent surface fires; severe fires were uncharacteristic and rarely occurred except during region-wide extreme climatic events (Agee 2003, Hessburg et al. 2005).”
7) Forest health concepts out of date
Published in the Helena Independent Record, November 13, 2016
By George Wuerthner Ph.D., ecologist and author of 42 books
Link: http://helenair.com/news/opinion/guest/forest-health-concepts-out-of-date/article_d063df30-af9c- 523b-b320-5d9290a624e3.html
Excerpts:
“In a recent IR editorial, former Forest Service foresters, Dale Bosworth and Jack Blackwell, promoted numerous out-of-date concepts and paradigms about forest health and management. Their editorial demonstrated that they are unfamiliar with the latest science regarding the ecological value of large wildfires, bark beetles and other natural ecological disturbance processes
Ecologists view large mixed to high severity fires, bark beetles, and other natural processes as critical to maintaining healthy forest ecosystems. The dead snags and down wood produced by such events are vital to many wildlife and plants. Indeed, some 2/3 of all wildlife species depend on dead trees at some point in their lives.
One example of their outmoded concepts is the idea that fuels drive large wildfires, even though numerous scientific studies suggest that severe climate/weather is what powers large wildfires. High winds, for instance, typically blow embers miles ahead of fire fronts, making fuel breaks largely ineffective at reducing fire spread and intensity.
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A growing body of scientific evidence calls into question their assertions that logging can preclude large high severity blazes. For instance, a study published in Ecosphere last month did a review of wildfire on 23 million acres of public lands over the past few decades. The authors found that ponderosa pine and mixed conifer forests under active timber management had the highest percentage of high severity blazes, while lands without any management like wilderness and parks had the lowest percentage of high severity fires.” FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37.
8) Commercial Logging Causes Forest Fires Published in FOREST CONSERVATION NEWS TODAY, July 20, 2002 OVERVIEW & COMMENTARY by Forests.org
Link: http://forests.org/archived_site/today/recent/2002/grgrurge.htm
Excerpts:
“It is well known scientifically that “commercial logging actually increases fire severity by removing large, fire- resistant trees and leaving behind very small trees and flammable "slash debris"--branches, twigs and needles from felled trees. The removal of mature trees also decreases the forest canopy, creating hotter, drier conditions on the ground. The additional sun exposure encourages the growth of flammable brush and weeds. Reduction of flammable underbrush can reduce fire severity, and environmental groups have encouraged such projects. However, the Bush administration has grossly misused the funds that Congress appropriated for brush reduction near homes. In Sierra Nevada national forests last year, more than 90% of these funds were instead earmarked for preparation of large timber sales focused on the removal of mature and old-growth trees miles from the nearest town.”
"The Forest Service, Bush administration and anti-environmental members of Congress are spreading a great deal of misinformation about wildfire, hoping to capitalize on public fire hysteria and minimize public opposition to increased logging and roadbuilding in our national forests," said Jake Kreilick of the National Forest Protection Alliance based in Missoula, Montana. "With virtually all new timber sales couched in terms of 'reducing fuels' or 'restoring forest health,' fire hysteria has emerged as the driving force behind the Forest Service's logging program and the administration's efforts to 'streamline' our nation's environmental laws," Kreilick said.”
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FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
9) Fight Fire With Logging?
By Dan Okoand Ilan Kayatsky Published by Mother Jones magazine, Wed Jul. 31, 2002 Link: http://www.motherjones.com/politics/2002/08/fight-fire-logging
Excerpts:
“Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk."
Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.
"The plan consists mostly of complaining about forest fires and ginning up more money for logging," Lawrence says.”
FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
10) A Burning Issue: Helping Loggers, Hurting Forests
By Dr. Chad Hanson
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Published on Monday, July 15, 2002 in the Los Angeles Times
Link: http://www.commondreams.org/views02/0715-04.htm
Excerpts:
“Scores of scientists and the federal government's own national fire plan have concluded that the removal of mature trees from forests increases the severity of forest fires. Why then would the Bush administration use the threat of fires to try to increase logging of mature and old-growth trees in our national forests?
That is clearly the administration's intention, as outlined in two recent memos on revising the Northwest Forest Plan and the "Sierra Nevada Framework" plan to allow logging companies increased access to ancient forests on public lands. The move is being led by Mark Rey, a former timber industry lobbyist and a President Bush appointee who oversees the Forest Service.”
“Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) FS Response: The Flat project proposes to treat fuels associated with activities proposed. Effects to fire and fuels can be found in the EA at 3-37. Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
11) The wildland fires of 2002 illuminate fundamental questions about our relationship to fire By Dr. Timothy Ingalsbee Published in the Winter 2002 issue of the The Oregon Quarterly Link: http://www.fire-ecology.org/research/wildfire_paradox.pdf
Excerpts:
“The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a
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very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.”
“Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.” FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
12) A Report to the President in Response to the Wildfires of 2000.
By Lyle Laverty USDA Forest Service and Tim Hartzell U.S. Department of the Interior, September 8, 2000
Link: http://frames.nacse.org/6000/6269.html
Excerpts:
"Most of the trees that should be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."
"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities (including reducing fuels) it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
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13) Dead trees aren't a wildfire threat, but overlogging them will ruin our forest ecosystems
By Chad Hanson, Ph.D., research ecologist
Published in the LA Times, June 27, 2016
Link: http://www.latimes.com/opinion/op-ed/la-oe-hanson-dead-trees-fires-vilsack-20160627-snap- story.html
Excerpts:
“Trees larger than just a few inches in diameter are not consumed in fires — only the outer bark layer and the needles actually burn up — so the great majority of the dead trees in the forest do not significantly influence fire behavior, even if they are dry. Besides, once trees die, the combustible oils in the needles quickly begin to dissipate and the needles fall, making it more — not less — difficult for flames to spread through the forest canopy.”
“On June 22, 2016 Secretary Vilsack argued that large-scale “tree die-offs” put “property and lives at risk,” and urged Congress to act. Specifically, he recommended passage of a bill backed by the timber industry that would fund a large expansion of the federal wildland fire suppression program, and increase commercial logging on federal public lands — all in the name of removing supposedly dangerous dead trees.”
“When trees die naturally due to drought, native beetles or fire, the snags and downed logs contribute to forest rejuvenation and become microhabitats for wildlife. Birds, mammals, amphibians, reptiles and fish all use snags and logs for food, nesting or shelter. The logging Vilsack wants to encourage, on the other hand, will leave behind only stumps, which produce none of these benefits. In the long term, then, the proposed legislation will degrade our forests and, in a cruel twist, lead to even more tree deaths.
Ignorance and shameless economic opportunism will destroy our forest ecosystems if we are not careful.” FS Response: See the EA at 2-3 “No down wood or snags would be removed as biomass.”
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14) Timber Industry Fails to Convince Judges that Logging Levels Linked to Wildfires Published in a New Century of Forest Planning, September 29, 2015 Link: http://forestpolicypub.com/2015/09/29/timber-industry-fails-to-convince-judges-that- logging-levels-linked-to-wildfires/
Excerpts:
“In a decision dismissing three lawsuits intended to compel more federal land logging in western Oregon, DC federal district court judge Richard Leon found that the timber industry failed to show that less logging means more wildfires (see page 7’s footnote).”
Judge Leon’s ruling likely ends a two-decades long legal skirmish by the timber industry to compel federal agencies to increase logging levels from Northwest Forest Plan lands. The campaign has been led by the Portland-based American Forest Resource Council. For 20 years AFRC chose primarily the courts as its strategy to increase logging. Today’s decision suggests that AFRC may change its focus from the courts to Congress FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
15) Commercial Logging for Wildfire Prevention: Facts Vs Fantasies
By Dr. Timothy Ingalsbee
Link: http://www.fire-ecology.org/citizen/logging_and_wildfires.htm
Excerpt:
"Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity." FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
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16) More Logging Won’t Stop Wildfires
By Dr. Chad Hanson and Dr. Dominick DellaSala
Published in the New York Times on July 23, 2015
Link: http://www.nytimes.com/2015/07/23/opinion/more-logging-wont-stop-wildfires.html?_r=0
Excerpt:
“In the case of the Rim Fire, our research found that protected forest areas with no history of logging burned least intensely. There was a similar pattern in other large fires in recent years. Logging removes the mature, thick-barked, fire-resistant trees. The small trees planted in their place and the debris left behind by loggers act as kindling; in effect, the logged areas become combustible tree plantations that are poor wildlife habitat.”
FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
17) Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production
By: Mark H. Huff; Roger D. Ottmar; Ernesto Alvarado; Robert E. Vihnanek; John F. Lehmkuhl; Paul F. Hessburg; Richard L. Everett, 1995
Link: https://www.frames.gov/rcs/6000/6691.html
Excerpts:
"As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire
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behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon."
"Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes…In general, rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds."
FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
18) Study challenges views about Western forest fires
By: Scott Sonner, AP
Published in the Daily World, July 23, 2012
Link: http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views-about- western-forest-fires.html
Excerpts:
“More highly intense fire is not occurring now than historically in dry forests,” said William Baker, who teaches fire ecology and landscape ecology in Laramie, Wyo., where he’s been doing research more than 20 years. “These forests were much more diverse and experienced a much wider mixture of fire than we thought in the past, including substantial amounts of high-severity fire.” “
“If he’s right, he and others say it means fuel-reduction programs aimed at removing trees and shrubs in the name of easing fire threats are creating artificial conditions that likely make dry forests less resilient.”
“Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes.”
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“We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.”
FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
19) "Healthy Forests" and Wildfire Control: Accumulating Scientific Evidence By Dr. Thomas Power A Montana Public Radio Commentary, December 11, 2006
Link: http://forestcouncil.org/so-called-healthy-forests-and-wildfire-control/
Excerpts:
“But the Bush Administration and some of the leadership of the Forest Service want to use logging techniques in places far removed from homes and communities to reduce the threat of wildfire. The basic idea is that most of our forests are far too dense. There are way too many trees per acre. This, we are told, not only makes them "unhealthy" but also reduces their productivity for wood production and makes them prone to frequent and severe wildfires that damage the forests even further. Cutting down many or most of those trees is the proposed solution.”
“Most of the dense forests that the Bush Administration and some in the Forest Service want to thin to return them to "health" are not unhealthy at all. Forest scientists have been studying the fire histories of our forested landscapes in more and more detail to try to understand their densities and fire behaviors in the centuries before we began grazing cows, harvesting trees, and suppressing fires in them. What they are finding is that a significant part of the forest landscape regularly had very dense stands of trees that every few centuries burned in large natural conflagrations. It was only the lower elevation forests that featured park-like mixes of large, almost inflammable, trees and open grasslands.”
“This is not a pessimistic story. It means that we need to focus our forest fire protection where our homes, communities, and lives are threatened. We do not have to spend tens of billions of dollars trying to save our forests from themselves. The forests do not need it, thank you, and those billion dollar efforts would not work anyway. If we are careful where and how we live in forests and learn to accept fire as a natural part of a healthy forested landscape, both prescribed fire and natural fires, we can both protect ourselves and enjoy the benefits of diverse natural forests.”
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FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
20) Study challenges views about Western forest fires
By Scott Sonner AP
Published in the Daily World, July 23, 2012
Link: http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views-about- western-forest-fires.html
Excerpts:
“Researchers at the University of Wyoming studied historical fire patterns across millions of acres of dry Western forests. Their findings challenge the current operating protocol of the U.S. Forest Service and other agencies that today’s fires are burning hotter and more frequently than in the past.
“It means we need to rethink our management of Western dry forests,” said Baker, a member of a U.S. Fish and Wildlife Service working group that is developing plans to help bolster northern spotted owl populations in dry forests.
Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes.
“We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.”
FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
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21) Colorado: Front Range forest thinning may be misguided Posted online on February 24, 2012 by Bob Berwyn
Link: https://summitcountyvoice.com/2012/02/24/colorado-front-range-forest-thinning-may-be- misguided/
Excerpts:
“Many recent forest management efforts along Colorado’s Front Range ponderosa pine belt have been aimed at creating widely spaced stands of trees, based on the conventional wisdom that those forests were historically shaped by low-intensity ground fires”
“The research suggests that current efforts to uniformly thin Front Range ponderosa forests and reduce fire intensity may be misguided and may not restore them. Instead, the aggressive management could take even farther from the natural historic range of variability with potential negative consequences for wildlife.”
FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape.
22) Statement of Norman L. Christensen, Jr., Ph.D. Before the Senate Committee on Agriculture, Nutrition and Forestry Regarding H.R. 1904—the Healthy Forests Restoration Act of 2003, 26 June 2003
“First, larger-diameter woody materials do not pose a significant threat for wildfire ignition or spread. It is largely the finer fuels (a few inches and less in diameter) that carry fire. More important, large, old trees actually provide protection from fire spread because they are resistant to fire and their shade maintains favorable moisture conditions in the understory fuels. Too much thinning of the forest canopy can produce more rapid drying of such fuels and, thereby, more frequent and severe wildfire risk. Furthermore, big, old trees provide critical habitat and maintain key ecosystem functions.’ (pg 4)
Link: https://wwwpaztcn.wr.usgs.gov/fire/hr_1904_testimony_christensen.pdf 60
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FS Response: Effects to fire and fuels can be found in the EA at 3-37. The Flat project does not only propose timber harvest, but also treatment including thinning dense stands and treating fuels Prescribed fire is also part of the proposed actions, in order to reintroduce fire on the landscape. Glyphosate Dangers
This document contains links to Monsanto and glyphosate safety literature. Of course we cannot believe everything posted on the web, but you will get 765,000 hits when you search for websites that contain the words “glyphosate” and “cancer.” ------Non-native invasive plant spread in the national forests is one of the largest threats to the proper functioning forest ecosystem. I commend you for recognizing this and spending taxpayer’s money to deal with it. There are many methods to address this threat. They include different types of herbicides, hand pulling and biological control.
Please allow me to point out something you and your staff should already know. You propose to apply a potentially lethal chemical to your national forest. I suggest you read the information authored by independent scientists below. Then ask your USFS invasive plant eradication expert who assisted you with this project why they suggested an herbicide containing the chemical glyphosate be applied to public land.
In the next 50 pages I will present irrefutable research-based evidence that casual exposure to the chemical glyphosate is one of the causes of birth defects, miscarriages, premature births, cancer - non-Hodgkin’s lymphoma and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning disabilities, ADHD and other neurological disorders (especially in children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, decrease in the sperm count and chromosomal damage. Regardless of what your agency says, no human being would take action that independent research scientists (not affiliated with the USFS) show sometimes causes these horrific physical conditions.
Here’s a very recent (January 27, 2017) article published in Your Newswire.
Link to entire article: http://yournewswire.com/france-bans-sale-of-monsanto-herbicide-roundup/
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France Bans Sale Of Monsanto Herbicide Roundup
Excerpt:
“The week-killer will no longer be available in garden centres in France, following French Ecology Minister Segolene Royal’s announcement on national television,“I have asked garden centres to stop putting Monsanto’s Roundup on sale“ “
Here’s another recent (January 24, 2017) article published in Truthout.
Link to entire article: http://www.truth-out.org/news/item/39197-monsanto-epa-seek-to-keep- talks-secret-on-glyphosate-cancer-review
MONSANTO, EPA SEEK TO KEEP TALKS SECRET ON GLYPHOSATE CANCER REVIEW
Excerpts:
“Monsanto Co. and officials within the Environmental Protection Agency are fighting legal efforts aimed at exploring Monsanto's influence over regulatory assessments of the key chemical in the company's Roundup herbicide, new federal court filings show.
The revelations are contained in a series of filings made within the last few days in the U.S. District Court for the Northern District of California as part of litigation brought by more than 50 people suing Monsanto. The plaintiffs claim they or their loved ones developed non-Hodgkin lymphoma (NHL) after exposure to Roundup herbicide, and that Monsanto has spent decades covering up cancer risks linked to the chemical.”
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“The EPA has spent the last few years assessing the health and environmental safety aspects of glyphosate as global controversy over the chemical has mounted. The World Health Organization's International Agency for Research on Cancer (IARC) declared in March 2015 that glyphosate is a probable human carcinogen, with a positive association found between glyphosate and NHL. Monsanto has been fighting to refute that classification.”
Please do not ignore or reject the information below thinking it’s your duty as a loyal USFS employee to do so. Remember, you are a human being. As you will see I have done extensive research on the chemical glyphosate. Why? My granddaughter died of cancer in 2013. It was tragic to watch her die. Cancer caused by glyphosate exposure is preventable. You can accomplish your land management goals using alternatives to herbicides that contain glyphosate: mechanical methods, biological methods and other herbicides.
Please explore the Monsanto website(s) available at the link below that deny any relationship between glyphosate and cancer. Roundup generates $15.9 billion dollars for Monsanto from worldwide sales each year. Might this explain their denial? Please see: https://www.bloomberg.com/news/articles/2015-03-20/who-classifies-monsanto-s-glyphosate- as-probably-carcinogenic-
FS Response: Effects to invasive plants are discussed in the Flat EA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
Here are the results of my research:
Why Glyphosate Should Be Banned – A Review of its Hazards to Health and the Environment
Published by, Permaculture Research Institute, November 1, 2012
Note: the USDA has known this for 4 years and still looks the other way to please Monsanto.
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Excerpts:
“The use of glyphosate-based herbicides, especially Monsanto’s Roundup formulation, has increased dramatically since the introduction of genetically modified (GM) glyphosate-tolerant crops, resulting in the contamination of our food, environment and water supplies.
Glyphosate-based herbicides are now the most commonly used herbicides in the world. It is still promoted as ‘safe’, despite damning evidence of serious harm to health and the environment.”
“Evidence of harm to health • Monsanto and the European Commission (EC) have known about birth defects since the 1980s. Industry studies found statistically significant skeletal and/or visceral abnormalities as well as reduced viability and increase in spontaneous abortions in rats and rabbits exposed to high doses of glyphosate. Lower doses were later shown to cause dilated hearts. The EC dismissed all the findings.
• Independent studies have since found caudal vertebrae loss in rats treated with sub-lethal doses of the herbicide; as well as craniofacial abnormalities, increased embryonic mortality and endocrine disruption, abnormal onset of puberty, and abnormal sexual behaviour and sperm count in male offspring of mothers exposed during gestation.
• GM soybean-fed female rats gave birth to excessive numbers of severely stunted pups, with over half of the litter dead by three weeks, and the surviving pups were sterile.
• Non-mammalian animals exposed to glyphosate resulted in increased gonad size, increased mortality, craniofacial abnormalities correlating with abnormal retinoic acid signalling, and reduced egg viability.
• In vitro exposure to glyphosate resulted in endocrine disruption and death of cells of the testis, placenta, and umbilical cord.
• A long term in vivo study on rats found females exposed to Roundup and/or Roundup Ready GM maize were two to three times as likely to die as controls and much more likely to develop large
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mammary tumours, while males presented large tumours four times controls and up to 600 days earlier.
• Clinical data from Argentina are consistent with lab findings of increases in birth defects and cancers in regions with large areas cultivating glyphosate-tolerant soybean.
• Endocrine disruption has been observed in both in vivo and in vitro studies in the laboratory, including abnormal levels of testosterone, aromatase enzyme, testosterone and oestrogen receptors, leutinising hormone, follicle-stimulating hormone. Endocrine disruption can lead to cancers and reproductive problems.
• Epidemiological studies have found links to cancer including non-Hodgkin lymphoma and increased plasma cell proliferation. Cancer rates have risen in in glyphosate-use zones in Argentina. Lab studies found significant increases in interstitial cell tumour incidence in rats as well as skin tumour-promoting activity. Numerous lab studies including those performed by industry showed glyphosate damages DNA of cells in culture as well as in humans living in glyphosate-sprayed regions of Argentina. Non-mammalian studies found defects in cell cycle checkpoints and DNA damage repair machinery. DNA damage is a major prelude to cancers. AMPA, the glyphosate metabolite, also has genotoxic effects.
• Neurotoxicity effects include Parkinsonism have emerged following acute exposure. Exposure to glyphosate resulted in oxidative stress in lab animals and death of neuronal cells, correlating with Parkinsonian pathology. Acute exposure in fish resulted in acetylcholine esterase (AChE) inhibition. An epidemiological study linked glyphosate -exposure to Attention-Deficit-Hyperactive disorder in children, a disorder associated with AChE inhibition. The original neurotoxicity studies carried out by industry were ruled invalid by the US Environment Protection Agency and urgently need re-examining by independent scientists.
• Internal organ toxicity has been documented in animal feeding studies with glyphosate-tolerant soybean. Rats suffered kidney abnormalities including renal leakage and ionic disturbances, and liver pathology including irregular hepatocyte nuclei, and increased metabolic rates.
• Acute toxicity of glyphosate is officially declared low by government agencies; however agricultural workers have reported many symptoms including skin irritation, skin lesions, eye irritation, allergies, respiratory problems and vomiting. Ingestion of large volumes causes systemic toxicity and death.”
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Link to full report: http://permaculturenews.org/2012/11/01/why-glyphosate-should-be-banned-a- review-of-its-hazards-to-health-and-the-environment/
Monsanto’s Roundup linked to fatty liver disease
Published by: Nation of Change, January 11, 2017
Excerpts:
Glyphosate – the controversial active ingredient in Monsanto’s top-selling weedkiller Roundup and other herbicides – can cause non-alcoholic fatty liver disease in rats at very low, real-world doses, according to a peer-reviewed study published in Nature.”
“The groundbreaking research is the first to show a “causative link between an environmentally relevant level of Roundup consumption over the long-term and a serious disease,” stated lead author Dr. Michael Antoniou of King’s College London, who described the findings as “very worrying.” “
Link: http://www.nationofchange.org/2017/01/11/monsantos-roundup-linked-fatty-liver-disease/
Monsanto spends an incredible amount of money each year to suppress real science and manipulate the media. This corporation even invents its own science that the USFS chooses to embrace as I will show later.
Monsanto undermines EPA's scientific review
Published by: Pesticide Action Network, December 8, 2016
Excerpts:
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“After halting the process in October, the Environmental Protection Agency (EPA) recently put its review of glyphosate back on the calendar for December 13-16. Scientists will gather on behalf of the agency to review the carcinogenic properties of the key ingredient in Monsanto’s flagship herbicide RoundUp.”
“EPA originally postponed the meeting after Monsanto publicly attempted to discredit participating scientists chosen by the agency. While the Scientific Advisory Panel (SAP) will convene next week, it’s notably missing Peter Infante — an expert epidemiologist Monsanto publicly accused of bias.”
“Caving to industry pressure
A few days before the SAP meeting was supposed to start in October, Monsanto sent a letter to EPA claiming that Infante was “biased” because he had historically defended plaintiffs in chemical exposure cases against Monsanto and affiliated agrichemical corporations — and challenged the legitimacy of industry-funded studies.
Given that Infante is no longer participating in the review process, it seems Monsanto’s tactics to undercut independent, non-industry science were effective.”
Link: http://www.panna.org/blog/monsanto-pushing-silence- science?utm_source=blog&utm_campaign=gt-12-09&utm_medium=groundtruth
Ask yourself why the poison called glyphosate is banned for use in 3rd word countries and still allowed in the United States if Monsanto does not control the regulatory agencies in this country. Now ask yourself why Congress included Section 735 in the 2013 spending bill (HR 933) that was signed by President Obama. Section 735 is known by many as the "Monsanto Protection Act." See: http://www.ibtimes.com/monsanto-protection-act-5-terrifying-things-know-about-hr-933- provision-1156079
As I will show, the USDA has been snuggling with Dow, Syngenta, Monsanto, Bayer, and DuPont for decades. It’s not surprising the USFS receives untrue information from the USDA about the chemicals these corporations manufacture. Please see Section #1 below.
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My father and mother both died of cancer. Their pain was unimaginable. This is why I have taken time to investigate the chemical glyphosate … that’s sold over the counter as Roundup to misinformed consumers.
My comments are structured using the following sections:
Section 1) Monsanto exerts unacceptable influence over the USDA
Section 2) The USFS depends on a single (emphasis added) research conclusion that glyphosate is safe by a lab with clear ties to Monsanto (Syracuse Environmental Research Associates--SERA) knowing the research conducted by thousands of independent scientists reveals glyphosate exposure is lethal.
Section 3) Glyphosate is especially toxic to children
Section 4) Herbicides that contain glyphosate are prohibited in 26 countries and the state of California classifies glyphosate as a “”
Section 5) California classifies glyphosate as a“
FS Response: Effects to invasive plants are discussed in the Flat EA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
------Section 1
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The USDA has been in bed with Monsanto for decades
It’s well known that in the United States today corporate executives and lobbyists sometimes control the behavior of 1) some government agency employees and 2) the information made available to these employees.
Clearly, Monsanto controls the USDA’s herbicide science and conclusions. Here are papers& articles that should be read by all Americans:
Six Reasons Why Obama Appointing Monsanto's Buddy, Former Iowa Governor Vilsack, for USDA Head Would be a Terrible Idea
Published by Organic Consumers Association, November 12, 2008
Excerpt:
“Vilsack has a glowing reputation as being a schill for agribusiness biotech giants like Monsanto. Sustainable ag advocated across the country were spreading the word of Vilsack's history as he was attempting to appeal to voters in his presidential bid.”
Link: https://www.organicconsumers.org/news/six-reasons-why-obama-appointing-monsantos- buddy-former-iowa-governor-vilsack-usda-head-would
Monsanto Receives Full Deregulation From Vilsack's USDA For Roundup Ready Alfalfa Published by Alabama Confidential, January 31, 2011
Excerpt:
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“Monsanto shill supreme, USDA Head Tom Vilsack pushed hard for his favorite corporate demon, the dreaded Monsanto, to further gain total control of US agriculture with this latest power bestowal by granting full deregulation for Monsanto's genetically modified Alfalfa:”
“Vanity Fair covered this issue in an investigative piece from May 2008 aptly entitled "Monsanto's Harvest of Fear" that is a compelling read and an in-depth probe into the frightening power that Monsanto has and wants.
And thanks to this latest ruling from the USDA, in conjunction with the false Food and Safety Bill that passed in the lame duck session of Congress, they are well on their way to getting it.” Link: http://alabamacorruption.blogspot.com/2011/01/monsanto-recieves-full- deregulation.html
Tom "Monsanto" Vilsack Must Go. Published by Daily Kos, April 25, 2011
Excerpt:
“He should go to Monsanto, that is, where we know he'll end up in a cushy job making bushels of money following his adventure as Secretary of Agriculture. Why waste our time? Why not just do it now Tom? You're already working for them:”
“Who needs the federal agency responsible for ensuring food safety for Americans? In our brave new world we rely on the "invisible hand" of the market place to regulate itself! So it's only natural that Vilsack would approve a program allowing companies like Monsanto to review itself. I'm sure Monsanto will do the environmental assessments and find that "Oh My Gosh!", GMO's are perfectly safe!” Link: http://www.dailykos.com/story/2011/04/25/969976/-Tom-Monsanto-Vilsack-Must- Go
Ag Secretary Tom Vilsack: Too much Monsanto in the Mix?
Published by OpEdNews, December 17, 2008
Excerpt:
“Iowans also remember the rides on Monsanto's corporate jet that Vilsack - the Biotech "Governor of the Year" - enjoyed during his time in office. He repayed Monsanto by working with
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the Republican floor manager in the House, promising to do everything he could to get a seed bill to pass. This bill took away county power to regulate GMOs within county borders.”
Link: http://www.opednews.com/articles/Ag-Secretary-Announced-To-by-Jill-Hamilton-and- 081216-596.html
How did Barack Obama become Monsanto’s man in Washington?
Published by Infowars, April 29, 2013
Excerpts:
“After his victory in the 2008 election, Obama filled key posts with Monsanto people, in federal agencies that wield tremendous force in food issues, the USDA and the FDA:”
“At the USDA, as the director of the National Institute of Food and Agriculture, Roger Beachy, former director of the Monsanto Danforth Center.”
“As commissioner of the USDA, Iowa governor, Tom Vilsack. Vilsack had set up a national group, the Governors’ Biotechnology Partnership, and had been given a Governor of the Year Award by the Biotechnology Industry Organization, whose members include Monsanto.”
“As the new counsel for the USDA, Ramona Romero, who had been corporate counsel for another biotech giant, DuPont.”
“Obama’s signing of the Monsanto Protection Act, making that corporation senior in power to the US court system, wasn’t an accident. It was taken in keen awareness of his duty to his Globalist betters.”
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Link: http://www.infowars.com/how-did-barack-obama-become-monsantos-man-in-washington/
Monsanto Has Tom Vilsack Under Its Thumb
Broadcast by Ring of Fire Radio, LLC, March 25, 2013
Excerpt:
“The Agricultural Department sent a budget to the White House last week, with orders from the meat industry and agricultural giant Monsanto on how Secretary Tom Vilsack should do his job. Monsanto, a company known for its controversial and potentially dangerous genetically engineered crop seeds, has been under fire for years for putting profit over consumer need and safety.”
Link: https://trofire.com/2013/03/25/monsanto-has-tom-vilsack-under-its-thumb/
USDA Forces Whole Foods to Accept Monsanto
Published by Reader Supported News, February 3, 2016
Excerpts:
“In a cleverly worded, but profoundly misleading email sent to its customers last week, Whole Foods Market, while proclaiming their support for organics and "seed purity," gave the green light to USDA bureaucrats to approve the "conditional deregulation" of Monsanto's genetically engineered, herbicide-resistant alfalfa.
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Beyond the regulatory euphemism of "conditional deregulation," this means that WFM and their colleagues are willing to go along with the massive planting of a chemical and energy-intensive GE perennial crop, alfalfa; guaranteed to spread its mutant genes and seeds across the nation; guaranteed to contaminate the alfalfa fed to organic animals; guaranteed to lead to massive poisoning of farm workers and destruction of the essential soil food web by the toxic herbicide, Roundup; and guaranteed to produce Roundup-resistant superweeds that will require even more deadly herbicides such as 2,4 D to be sprayed on millions of acres of alfalfa across the U.S.”
Link: http://readersupportednews.org/opinion2/265-34/34968-usda-forces-whole-foods-to-accept- monsanto
GMO Science Deniers: Monsanto and the USDA The Huffington Post, May 20, 2015
Excerpt:
“Perhaps no group of science deniers has been more ridiculed than those who deny the science of evolution. What you may not know is that Monsanto and our United States Department of Agriculture (USDA) are among them. That’s right: for decades, Monsanto and its enablers inside the USDA have denied the central tenets of evolutionary biology, namely natural selection and adaptation. And this denial of basic science by the company and our government threatens the future viability of American agriculture.”
“Now Monsanto and Dow Chemical have received government approval to market new genetically engineered corn, soy and cotton, that are “stacked” with engineered DNA that make them resistant to Roundup as well as 2,4-D (one of the chief elements of “Agent Orange”). Monsanto has also gained approval from the USDA for the same three crops that can tolerate Dicamba. 2,4-D and Dicamba are older, more toxic herbicides than Roundup, and these companies are reverting to them because they have brought us to the point of peak herbicides. They simply don’t have any new ones, similar to the current crisis in antibiotics.”
Link: http://www.huffingtonpost.com/andrew-kimbrell/gmo-science-deniers-monsanto- and-the-usda_b_6904606.html
There is not enough room to print quote excerpts from them all. Here are the links to the rest for those who are interested in reading about Monsanto controlling the USDA … and of course the USFS.
Is the USDA a wholly owned subsidiary of Monsanto? Link: http://www.cornucopia.org/is-the-usda-a-wholly-owned-subsidiary-of-monsanto/
Obama's Highly Corrupt USDA: END Monsanto.
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Link: http://www.thomhartmann.com/users/telliottmbamsc/blog/2013/10/obamas-highly-corrupt- usda-end-monsanto
A Government of Monsanto, by Monsanto, and for Monsanto Link: http://farmwars.info/?p=5860
USDA to Give Monsanto’s New GMO Crops Special ‘Speed Approval’ Link: http://naturalsociety.com/usda-to-give-monsantos-new-gmo-crops-special-speedy- approval/
Monsanto’s GMO Policy Infecting All Levels of Government Link: http://www.nationofchange.org/monsanto-s-gmo-policy-infecting-all-levels-government- 1373204831
Another Monsanto man in a key USDA post? Obama’s ag policy’s giving me whiplash Link: http://grist.org/article/2009-09-24-usda-obama-monsanto-organic/
GMO Science Deniers: Monsanto and the USDA Link: http://www.wanttoknow.info/a-gmo-science-deniers-monsanto-the-usda
USDA Forces 'Whole Foods' To Accept Monsanto Link: http://humansarefree.com/2012/02/usda-forces-whole-foods-to-accept.html
In Defiance of Sanity, USDA Approves Dow's Agent Orange GMO Link: http://www.sustainablebusiness.com/index.cfm/go/news.display/id/25907
Is the USDA Covering Up Potential Dangers That Affect Your Health? Link: http://www.liveinthenow.com/article/is-the-usda-covering-up-dangers-that-affect-your- health
USDA and Monsanto “Biotech” Industry Collusion Link: http://www.truthwiki.org/usda-and-monsanto-biotech-industry-collusion/
Corruption at the USDA Link: https://newhomeeconomics.wordpress.com/2010/03/09/corruption-at-the-usda/
USDA Admits Exterminating Birds, Crops, and Bees Link: http://worldtruth.tv/usda-admits-exterminating-birds-crops-and-bees/
USDA: Stop Killing Bees and Butterflies (CCD) While Saving Monsanto (Round-Up) Link: https://www.change.org/p/usda-stop-killing-bees-and-butterflies-ccd-while-saving- monsanto-round-up
U.S.D.A. infiltrated by Monsanto. Link: https://legacy.minds.com/blog/view/460310689387388940/usda-infiltrated-by-monsanto
STOP the Corrupt FDA and USDA Madness Once and For All! Link: https://www.change.org/p/athena-telos-stop-the-corrupt-fda-and-usda-madness-once-and- for-all
Are you aware that the USDA is attempting to corrupt organic standards?
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Link:http://www.carbonproduct.net/Health_and_Fitness/Are_you_aware_that_the_USDA_is_att empting_to_corrupt_orangic_standards/_17096
NEW SCANDAL FOR USDA & MONSANTO: Whistle Blowers at USDA say MONSANTO Influences Agency Suppression of Critical Science. Link: http://mauicauses.org/new-scandal-for-usda-monsanto-whistle-blowers-at-usda-say- monsanto-influences-agency-suppression-of-critical-science/
USDA moves to let Monsanto perform its own environmental impact studies on GMOs Link: http://axisoflogic.com/artman/publish/Article_62860.shtml
Monsanto’s GMO Crops Ravage US, USDA Ignores Dangers Link: http://www.alipac.us/f19/monsanto%92s-gmo-crops-ravage-us-usda-ignores-dangers- 247146-print/
THE BITTER TRUTH ABOUT THE USDA AND MONSANTO SUGAR BEETS Link: http://geneticallyengineeredfoodnews.com/monsanto-sugar-beets
USDA Approves Toxic Herbicide Amidst Great Public Outcry
Link: http://healthimpactnews.com/2014/usda-approves-toxic-herbicide-amidst-great-public-outcry/
USDA Gives Green Light to 2,4-D Resistant GM Crops
Link: http://sustainablepulse.com/2014/01/03/usda-gives-green-light-pesticide-promoting-gm- crops/#.VlIUtJbTm1s
USDA approves the second generation of GMOs resistant to more toxic herbicide
Link: http://www.seattleorganicrestaurants.com/vegan-whole-food/usda-approves-second-generation-of- GMOs-resistant-to-toxic-herbicide-isoxaflutole-IFT.php
USDA refuses to test foods for glyphosate contamination, says pesticides are safe to eat. Link: http://www.naturalnews.com/048237_glyphosate_contamination_USDA.html
USDA Secretary Vilsack's proposal for product labeling: companies will voluntarily, use barcodes to tell consumers if their products contain GMOs. This would require you to scan the product, then be directed to the company’s website where you’d have to wade through the advertising and search the fine print. Link: https://www.organicconsumers.org/essays/%E2%80%98qr%E2%80%99-barcodes-latest- plot-keep-you-dark-about-gmos
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Herbicide Use To Increase Dramatically
Link: http://www.enn.com/agriculture/article/47711
USDA Approval of Second-Generation of GMOs
Link: http://undergroundhealthreporter.com/usda-approval-of-second-generation-of- gmos/#axzz3sFaNPdRd
You are probably wondering what to do. Should you do the ethical, caring thing by not applying glyphosate or are you worried about your job? There are alternatives to glyphosate: hand pulling, biological eradication methods and other herbicides. Please use them. What kind of person takes a chance on killing someone because their employer says its OK?
FS Response: Effects to invasive plants are discussed in the Flat EA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
------Section 2
As is the case here, USFS EAs and EISs that propose to apply glyphosate cite research conclusions from the Human Health and
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Ecological Risk Assessment prepared by Syracuse Environmental Research Associates’ (SERA).
As I will show below, an examination of the SERA Risk Assessment denies or does not address the causal relationship between glyphosate exposure and human health problems disclosed by hundreds of independent scientists worldwide. The USFS ignores this science. Section #1 above explains why. Its not surprising the agency embraces the SERA conclusion.
Please open your mind and find out the corporation or agency that sanctioned and funded the so- called SERA research. Here’s a hint: it wasn’t the USFS … although considerable effort was made to make it appear the project was driven by the agency.
The safety conclusions of most USFS EAs and EISs that analyze and approve application of herbicides that contain glyphosate are based in the SERA report below.
Report Name: Glyphosate -Human Health and Ecological Risk Assessment Final Report, 2011
Prepared by: Syracuse Environmental Research Associates, Inc.
Prepared for: USDA Forest Service, Contract Number: AG-3187-C-06-0010
Link to Report: http://www.fs.fed.us/foresthealth/pesticide/pdfs/Glyphosate_SERA_TR- 052-22-03b.pdf
My examples of SERA deception shown below use the following format:
I have selected 9 tragic physical conditions caused by casual glyphosate exposure. First, I present a few links to the many examples of independent science conclusions that discuss how glyphosate causes these conditions. Then I quote the SERA report’s discussion denying the “best science” conclusions.
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On page xviii the SERA Report makes ridiculous, untrue claims.
Executive summary
“This risk assessment on glyphosate is dominated by three considerations: the extensive literature available on glyphosate, the availability of numerous glyphosate formulations, and the use of surfactants either as components in glyphosate formulations or as adjuvants added to glyphosate formulations prior to application.”
Comment: After reading the information below, intelligent, unbiased people would conclude “the extensive literature available on glyphosate” reveals glyphosate exposure causes tragic, catastrophic physical conditions in mammals including humans. I challenge you to find science literature besides the SERA Report that concludes glyphosate is safe that’s not authored by 1) USFS employees, 2) the corporation that manufactures the chemical glyphosate, or 3) scientists with ties to Monsanto.
Human Health
“The preponderance of the available data, however, clearly indicates that the mammalian toxicity of glyphosate is low, and very few specific hazards can be identified.”
After reading the information below, intelligent, unbiased people would conclude claims that “the mammalian toxicity of glyphosate is low, and very few specific hazards can be identified” is a lie intended to increase the sales of Roundup and Monsanto profits. This in itself would cause anyone to reject the rest of the SERA conclusions.
The statements quoted from the SERA Report below intended to disprove independent research conclusions linking glyphosate to tragic health effects are highlighted in brown font.
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In most cases, the SERA report denies glyphosates connection with health problems. In a few cases, a word search of the SERA report indicates the tragic physical conditions caused by glyphosate that are disclosed by multiple independent scientists below isn’t even addressed. ***************************************** #1 Birth Defects
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Roundup: Birth Defects Caused By World’s Top-Selling Weedkiller, Scientists Say
The Huffington Post, August 24, 2011
Excerpts:
“Our examination of the evidence leads us to the conclusion that the current approval of glyphosate and Roundup is deeply flawed and unreliable,” wrote the report’s authors. “What is more, we have learned from experts familiar with pesticide assessments and approvals that the case of glyphosate is not unusual.
“They say that the approvals of numerous pesticides rest on data and risk assessments that are just as scientifically flawed, if not more so,” the authors added. “This is all the 80
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more reason why the Commission must urgently review glyphosate and other pesticides according to the most rigorous and up-to-date standards.”
Monsanto spokeswoman Janice Person said in a statement that the Earth Open Source report presents no new findings.”
“The study, published in the journal Chemical Research in Toxicology in 2010, found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying. It also found that malformations caused in frog and chicken embryos by Roundup and its active ingredient glyphosate were similar to human birth defects found in genetically modified soy-producing regions.”
Link: http://www.huffingtonpost.com/2011/06/24/roundup-scientists-birth- defects_n_883578.html
Lab Study Establishes Glyphosate Link to Birth Defects
Institute of Science in Society, April 10, 2010
Excerpt:
“In regions where glyphosate-based herbicides are used, specific neural defects and craniofacial malformations were reported. This prompted Prof. Andrés Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires Medical School into action. He and his colleagues carried out a laboratory study on the effects of glyphosate on the development of frog embryos. They found the same kinds of abnormalities in frog embryos incubated with a 5 000 fold diluted solution of the Roundup herbicide [2]. The findings were so serious that Carrasco decided to release the results before publication [3] (Glyphosate Herbicide Could Cause Birth Defects Glyphosate Herbicide Could Cause Birth Defects, SiS 43), and in May 2009, the Environmental Lawyers Association of Argentina initiated a lawsuit to ban the herbicide.”
Link: http://www.i-sis.org.uk/glyphosateCausesBirthDefects.php
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The inside story on Monsanto and the glyphosate birth defect data
The Ecologist, June 13, 2011
Excerpts:
“The report reveals that industry’s own studies (including one commissioned by Monsanto itself) showed as long ago as the 1980s that Roundup’s active ingredient glyphosate causes birth defects in laboratory animals. Industry submitted these studies to the European Commission in support of its application for glyphosate’s approval for use in Europe. As the 'rapporteur' member state for glyphosate, liaising between industry and the Commission, Germany took an active role in minimising the problems with glyphosate and must shoulder a chunk of the responsibility for allowing it onto the market.”
“Monsanto also repeats the usual industry claim that the studies that show problems with glyphosate are 'flawed'. But as our report proves, studies that show glyphosate causes birth defects include industry’s own, Monsanto’s among them. Is Monsanto saying its own studies are flawed? If so, we have all the more reason to worry, as these are the studies on which the current approval of glyphosate rests.”
Link:http://www.theecologist.org/blogs_and_comments/commentators/other_comments/ 938661/the_inside_story_on_monsanto_and_the_glyphosate_birth_defect_data.html
Monsanto's Roundup Herbicide Threatens Public Health
Rachel's Environment and Health News, issue 751, Sept. 5, 2002.
Reprinted by Organic Consumers Association, September 25, 2001
Excerpt:
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“Two new studies indicate that Monsanto's herbicide, Roundup, is a hormone-disruptor and is associated with birth defects in humans. Farm families that applied pesticides to their crops in Minnesota were studied to see if their elevated exposure to pesticides caused birth defects in their children. The study found that two kinds of pesticides -- fungicides and the herbicide Roundup -- were linked to statistically significant increases in birth defects. Roundup was linked to a 3-fold increase in neurodevelopmental (attention deficit) disorders. [EHP Supplement 3, Vol. 110 (June 2002), pgs. 441-449.]
Link: http://www.organicconsumers.org/Monsanto/roundup92502.cfm
I invite you to search the WEB using “glyphosate” and “birth defects.” You will get several hundred thousand hits.
Why does the USFS ignore hundreds sources of science information and make life threatening decisions based on the conclusions of a single (emphasis added) SERA report? Why do you go along with their scheme to please Monsanto?
Here is the SERA Report’s denial of the fact that glyphosate exposure causes birth defects:
The 2011 SERA glyphosate safety report at page 19 states: “There is no indication that glyphosate causes birth defects.” ***************************************** #2 Miscarriages
Is Glyphosate Responsible for your Health Problems?
from Health Impact News, December 6, 2015
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Excerpts:
“But, what about that other modern advance made in the 1970s? Has Roundup stood the test of time, or is it also another failed experiment? The short answer is that Roundup/glyphosate can easily be ranked together with DDT, because of its chemical similarity and its toxicity. [9]”
“A U.S. government study measured the amount of glyphosate in air and rain samples in the agricultural area of the Mississippi delta between 1995 and 2007. Results found Roundup and its toxic metabolite called AMPA in over 75% of the air and rain samples tested in 2007. (AMPA is the toxic residue that is left after glyphosate degrades into other chemical forms.) Glyphosate in the air is absorbed directly into the blood by way of the lungs. Even though the daily exposure is low, we now know that extremely low exposure, measured in parts per trillion, can disrupt the human endocrine system and stimulate cancer growth. The air and rain samples were taken in locations that were 3 miles away from the fields where Roundup was used. [16]”
“The endocrine disrupting properties of glyphosate can lead to reproductive problems: infertility, miscarriage, birth defects, and sexual development. Fetuses, infants and children are especially susceptible because they are continually experiencing growth and hormonal changes. For optimal growth and development, it is crucial that their hormonal system is functioning properly…. The endocrine disrupting properties also lead to neurological disorders (learning disabilities (LD), attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer’s, schizophrenia and bipolar disorder). Those most susceptible are children and the elderly. [25]”
Link: http://healthimpactnews.com/2014/is-glyphosate-responsible-for-your-health- problems/
Glyphosate Weedkiller in Our Food and Water? from Infowars, June 17, 2013
Excerpts:
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“In 2011, Earth Open Source said that official approval of glyphosate had been rash, problematic and deeply flawed. A comprehensive review of existing data released in June 2011 by Earth Open Source suggested that industry regulators in Europe had known for years that glyphosate causes birth defects in the embryos of laboratory animals. Questions were raised about the role of the powerful agro-industry in rigging data pertaining to product safety and its undue influence on regulatory bodies (2).”
“With some hugely powerful players involved here, many of whom have successfully infiltrated important government and official bodies (9), much of the science and the ensuing debate surrounding glyphosate is being manipulated and hijacked by vested interests for commercial gain.”
Link: http://www.infowars.com/glyphosate-weedkiller-in-our-food-and-water/
Glyphosate, pathways to modern diseases II: Celiac sprue and gluten intolerance.
From Interdisiplinary Toxicology , 2013 Dec;6(4):159-84. doi: 10.2478/intox-2013-0026
Excerpts:
“Deficiencies in iron, cobalt, molybdenum, copper and other rare metals associated with celiac disease can be attributed to glyphosate's strong ability to chelate these elements. Deficiencies in tryptophan, tyrosine, methionine and selenomethionine associated with celiac disease match glyphosate's known depletion of these amino acids. Celiac disease patients have an increased risk to non-Hodgkin's lymphoma, which has also been implicated in glyphosate exposure. Reproductive issues associated with celiac disease, such as infertility, miscarriages, and birth defects, can also be explained by glyphosate. Glyphosate residues in wheat and other crops are likely increasing recently due to the growing practice of crop desiccation just prior to the harvest. We argue that the practice of "ripening" sugar cane with glyphosate may explain the recent surge in kidney failure among agricultural workers in Central America. We conclude with a plea to governments to reconsider policies regarding the safety of glyphosate residues in foods.”
Link: http://www.ncbi.nlm.nih.gov/pubmed/24678255
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I invite you to search the WEB using “glyphosate” and “miscarriage.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes miscarriages:
The 2011 SERA glyphosate safety report at page 57 states:
“One study analyzed self-reported spontaneous miscarriages of 3984 pregnancies among 1898 couples who self-reported exposures to glyphosate formulations within a period beginning 2 months before pregnancy and ending the 29 month of conception (Savitz et al., 1997). Risk of miscarriage was unrelated to self-reported exposure to glyphosate formulations.” ***************************************** #3 Cancer
Roundup and Glyphosate Toxicity Have Been Grossly Underestimated
Published by Mercola.com
Excerpt:
“The true toxicity of glyphosate—the active ingredient in Monsanto’s broad-spectrum herbicide Roundup—is becoming increasingly clear as study after study is published demonstrating its devastating effects. In June, groundbreaking research was published detailing a newfound mechanism of harm for Roundup.
This was immediately followed by tests showing that people in 18 countries across Europe have glyphosate in their bodies,1 while yet another study revealed that the chemical has estrogenic properties and drives breast cancer proliferation in the parts-per-trillion range.2
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This finding might help explain why rats fed Monsanto’s maize developed massive breast tumors in the first-ever lifetime feeding study published last year. Other recently published studies demonstrate glyphosate’s toxicity to cell lines, aquatic life, food animals, and humans.”
Link: http://articles.mercola.com/sites/articles/archive/2013/07/30/glyphosate- toxicity.aspx#!
RoundUp--Lymphoma Connection
From a June 22, 1999 Press Release by Sadhbh O' Neill, author of Genetic Concern.
Excerpts:
“A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].
In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “
Link: http://www.naturescountrystore.com/roundup/page8.html
"RoundUp Ready" nears end of the line...
From GroundTruth, July 7, 2014
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Excerpts:
“With these dramatic increases in use, the frequency and level of human exposures to these herbicides have also gone up. As usage of glyphosate increases — for instance, as a wheat "dessicant" used at harvest-time to ensure that all of the crop is conveniently dry enough to harvest — glyphosate will continue to show up in everyday food items such as bread, and also in our surface water.”
“Striking increases in the incidence of non-Hodgkin lymphoma cancer have occurred over the past 30 years. A 2014 systematic review and meta-analysis of epidemology studies broke down the relationship between non-Hodgkin lymphoma and occupational exposure to agricultural pesticides by group and by active ingredient.
Among the findings — a handful of those studies identified a positive association between glyphosate and B cell lymphoma (a type of non-Hodgkin lymphoma).”
Link: http://www.panna.org/blog/roundup-ready-nears-end-line
Study: Glyphosate Doubles Risk of Lymphoma
From AgMag BLOG, May 23, 2014
Excerpt:
“Scientists at the International Agency for Research on Cancer have found what appears to be a strong link between pesticide exposure and a blood cancer called non-Hodgkin lymphoma.
Analyzing 44 individual research projects published since 1980, the scientists, writing in the International Journal of Environmental Research and Public Health, said that people exposed to the weed killer glyphosate, marked by Monsanto under the brand name Roundup, had double the risk of developing non-Hodgkin’s lymphoma.”
Link: http://www.ewg.org/agmag/2014/05/study-glyphosate-doubles-risk-lymphoma
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Cytotoxic and DNA-damaging properties of glyphosate and Roundup in human-derived buccal epithelial cells.
From Arch Toxicol. 2012 May;86(5):805-13. doi: 10.1007/s00204-012-0804-8. Epub 2012 Feb 14.
Excerpt:
“Glyphosate (G) is the largest selling herbicide worldwide; the most common formulations (Roundup, R) contain polyoxyethyleneamine as main surfactant. Recent findings indicate that G exposure may cause DNA damage and cancer in humans. Aim of this investigation was to study the cytotoxic and genotoxic properties of G and R (UltraMax) in a buccal epithelial cell line (TR146), as workers are exposed via inhalation to the herbicide. R induced acute cytotoxic effects at concentrations > 40 mg/l after 20 min, which were due to membrane damage and impairment of mitochondrial functions. With G, increased release of extracellular lactate dehydrogenase indicative for membrane damage was observed at doses > 80 mg/l. Both G and R induced DNA migration in single-cell gel electrophoresis assays at doses > 20 mg/l.”
Link: http://www.ncbi.nlm.nih.gov/pubmed/22331240
Roundup is tied to infertility and cancer; herbicide’s maker calls it safe
Published in the Washington Post, April 29, 2013
By Carey Gillam
Excerpts:
“Roundup, may be linked to a range of health problems and diseases, including Parkinson’s, infertility and cancers, according to a new study.”
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“Jerry Steiner, Monsanto’s executive vice president of sustainability, reiterated that when questioned about the new study. “We are very confident in the long track record that glyphosate has. It has been very, very extensively studied,” he said.
Link:
https://www.washingtonpost.com/national/health-science/roundup-is-tied-to-infertility-and- cancer-herbicides-maker-calls-it-safe/2013/04/29/ac86ced6-ae71-11e2-98ef- d1072ed3cc27_story.html
I invite you to search the WEB using “glyphosate” and “cancer.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes cancer:
The SERA report at page 61 cites 23-year old U.S. EPA/OPP literature that concludes there is “evidence of non-carcinogenicity for humans.” The SERA report then goes on to say thus, “no quantitative risk assessment for cancer is conducted.” ***************************************** #4 DNA Damage
Glyphosate Toxic to Mouth Cells & Damages DNA, Roundup Much Worse
From an Institute of Science Publication, March 3, 2012
Excerpts:
“New research finds that glyphosate causes cell and DNA damage to epithelial cells derived from the inside of the mouth and throat [1]. It raises concerns over the safety of inhaling glyphosate, one of the most common ways in which people are exposed to the herbicide.
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Siegfried Knasmueller and his colleagues the Medical University of Vienna, Austria, found that Monsanto’s formulated version of glyphosate called Roundup Ultra Max caused cellular damage and DNA damage including chromosomal abnormalities and ultimately killed the cells at higher concentrations. Importantly, DNA damage occurred at concentrations below those required to induce cell damage, suggesting that the DNA damage was caused directly by glyphosate instead of being an indirect result of cell toxicity.”
Link: http://www.i-sis.org.uk/Glyphosate_Toxic_to_Mouth_Cells.php
Evaluation of DNA damage in an Ecuadorian population exposed to glyphosate from Genetics and Molecular Biology, 30, 2, 456-460 (2007)
Excerpts:
“We analyzed the consequences of aerial spraying with glyphosate added to a surfactant solution in the northern part of Ecuador. A total of 24 exposed and 21 unexposed control individuals were investigated using the comet assay. The results showed a higher degree of DNA damage in the exposed group (comet length = 35.5 μm) compared to the control group (comet length = 25.94 μm). These results suggest that in the formulation used during aerial spraying glyphosate had a genotoxic effect on the exposed individuals.”
Link: http://www.scielo.br/pdf/gmb/v30n2/a26v30n2.pdf
Monsanto’s Roundup is Causing DNA Damage from Natural Society, March 30, 2012
Excerpts:
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“There is a reason that masks are worn while applying herbicides and warning signs are erected upon recently sprayed land plots — herbicide exposure is known to cause serious health complications. New research has recently been released showing that glyphosate, the main active ingredient found in Monsanto’s Roundup Ultra Max, is causing both DNA and cellular damage to cells found in the mouth and throat. Seeing as the inhalation of herbicides and ingredients like glyphosate is very common, this research alone is enough to raise concern over the safety of such substances which are used on a major scale.”
Link: http://naturalsociety.com/monsantos-roundup-is-causing-dna-damage/
Roundup: The "Safe" Garden Product that Can Destroy Your DNA from Mercola.com, March 13, 2012
Excerpts:
“Instead, new research is showing that glyphosate, the active ingredient in Monsanto's Roundup herbicide, is contaminating everything from food and air to groundwater and even human beings.”
“Other independent scientific research has also found that glyphosate has the potential to cause grave health damage, including a 2009 study that tested formulations of Roundup that were highly diluted (up to 100,000 times or more) on human cells, and even then the cells died within 24 hours!”
“This can wreak havoc with your health as 80 percent of your immune system resides in your gut (GALT – Gut Associated Lymph Tissue) and is dependent on a healthy ratio of good and bad bacteria! Separate research has also uncovered the following effects from glyphosate: DNA damage, Neurotoxicity, Cancer, Endocrine disruption, Developmental toxicity and Reproductive toxicity.”
Link: http://articles.mercola.com/sites/articles/archive/2012/03/13/active-ingredient-glyphosate-in- roundup-herbicides-found-in-peoples-urine.aspx
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Carcinogenic Glyphosate Linked to DNA Damage as Residues are found in Bread
from Beyond Pesticides, July 22, 2015
Excerpts:
“The new report, Glyphosate: Unsafe on Any Plate, found high levels of glyphosate contamination in popular American food brands, such as Cheerios, Doritos, Oreos, Goldfish and Ritz Crackers, and Stacy’s Pita Chips. According to the report, the levels that found in these products are above the levels associated with organ damage (above 0.1 parts per billion(ppb)). Among 29 different foods tested, the highest levels detected were found in General Mills’ Original Cheerios, at 1,125.3 ppb. Stacy’s Simply Naked Pita Chips were the next highest, at 812.53 ppb. The testing and analysis was performed by Anresco Laboratories, which is an FDA registered laboratory.”
“Given its widespread use on residential and agricultural sites, its toxicity is of increasing concern. Roundup formulations can induce a dose-dependent formation of DNA adducts (altered forms of DNA linked to chemical exposure, playing a key role in chemical carcinogenesis) in the kidneys and liver of mice. Human cell endocrine disruption on the androgen receptor, inhibition of transcriptional activities on estrogen receptors on HepG2, DNA damage and cytotoxic effects occurring at concentrations well below “acceptable” residues have all been observed.”
Link: http://beyondpesticides.org/dailynewsblog/2015/07/carcinogenic-glyphosate-linked-to-dna- damage-as-residues-are-found-in-bread/
I invite you to search the WEB using “glyphosate” and “DNA” and “damage.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes DNA damage:
The SERA report at page 64 states:
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More serious limitations in the Paz-y-Mino et al. (2007) study involve the failure to demonstrate either temporal or spatial associations between exposure and effect. Paz-y-Mino et al. (2007) simply tested two groups of individuals after a spray and noted a difference. If the individuals at both sites had been tested before and after spraying, a temporal association could have been detected. Similarly, Paz-y-Mino et al. (2007) note that the exposed group consisted of individuals who lived at the spray site as well as individuals who lived as many as 3 miles away from the spray site. If Paz-y-Mino et al. (2007) had assessed responses based on proximity to the spray and noted some positive correlation in the responses, confidence in their assertion that the glyphosate spray caused the observed effect would be enhanced. In the absence of these types of analyses, the assertion that the differences (i.e., chromosomal damage) between the two populations are due to glyphosate exposure is weak. ***************************************** #5 Cell Death
The Hidden Dangers of Roundup
From Natural News, February 05, 2009
Excerpts:
“The researchers also reported that G acted very quickly at concentrations 500 to 1000 times lower than present agricultural levels to induce programmed cell death. G alone was found to induce mitochondrial toxicity without cell membrane damage. Furthermore, the researchers tested very weak concentrations (.005%) of Roundup and reported cell death, lack of adhesion, shrinking and fragmentation in the cells undergoing apoptosis. The embryonic cells were the most sensitive indicating another major reason to eat only organic foods while pregnant.”
Link: http://www.naturalnews.com/025534_Roundup_research_toxic.html
Endocrine disruption and cytotoxicity of glyphosate and roundup in human JAr cells in vitro
from Integr Pharm Toxicol Gentocicol, 2015 doi: 10.15761/IPTG.1000104
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Excerpts:
“Endocrine disruption effects were secondary to cytotoxicity. Roundup was more cytotoxic than the same concentration of glyphosate alone, indicating that the other constituents of the herbicide are not inert. There is a compelling need to conduct in vivo studies to characterise the toxicity of glyphosate in a Roundup formulation, to facilitate re-evaluation of existing public health guidelines.”
Link: http://www.gmoevidence.com/wp-content/uploads/2015/03/IPTG-1-104.pdf
Roundup Weed Killer Dangers from Garden Guides.com, January 2013
Excerpts:
“Monsanto's Roundup weed killer was originally marketed as being "biodegradable" and "environmentally friendly." However, in response to complaints from the New York Attorney General's office, the company agreed to stop using those terms in marketing and advertising. Roundup herbicide uses the active ingredient glyphosate, sometimes called "G." Glyphosate has been implicated in a number of potential dangers.”
“Excessive exposure to the active ingredient of Roundup, glyphosate, can cause a range of symptoms. Some of the 23 symptoms of glyphosate poisoning include reduced urination, cough, diarrhea, drowsiness, difficulty swallowing and breathing, nausea and vomiting, sore throat, blood in vomit or urine, stomach inflammation, and reduced blood pressure. Continued exposure can result in destruction of red blood cells, respiratory failure, and permanent kidney damage. Poisoning by Roundup requires a visit to a doctor or other professional chemical decontamination specialist. If you suspect acute glyphosate poisoning, contact your local poison control center or emergency room.”
Link: http://www.gardenguides.com/127538-roundup-weed-killer-dangers.html
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Monsanto's Roundup is Causing DNA and Cellular Damage
from Health and Wellness, March 30, 2012
Excerpts:
“There is a reason that masks are worn while applying herbicides, and warning signs are erected upon recently sprayed land plots; herbicide exposure is known to cause serious health complications.
New research has recently been released showing that glyphosate, the main active ingredient found in Monsanto's Roundup Ultra Max, is causing both DNA and cellular damage to cells found in the mouth and throat.”
Link: http://www.sott.net/article/243580-Monsantos-Roundup-is-Causing-DNA-and-Cellular- Damage
I invite you to search the WEB using “glyphosate” and “cell damage.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes sell death:
The SERA report at page 62 states:
“Rank et al. (1993) also note that these exposure levels are near to those that cause cell death. The study does not provide information regarding the volume of the test solution in each plate. Assuming that Rank et al. (1993) used standard methods, the volume of the test solution in this type of assay is approximately 2-3 mL (U.S. EPA/OPPTS 1998a). Based on the upper range of 3
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mL (0.003 L), the estimated concentrations in the test solutions are about 120- 240 mg/L [0.360 mg to 0.72 mg/plate ÷ 0.003 L/plate]. These concentrations would be plausible in the gastrointestinal tract following acute oral exposure to a nontoxic dose of glyphosate (Table 10) but are from about 140 to 280-fold greater than peak plausible concentrations in plasma (≈0.86 mg/L).” ***************************************** #6 Autism
MIT Researcher: Glyphosate Herbicide will Cause Half of All Children to Have Autism by 2025
Posted on December 23, 2014 at: Alliance for Natural Health
Excerpt:
“At a [recent] conference, in a special panel discussion about GMOs, she took the audience by surprise when she declared, “At today’s rate, by 2025, one in two children will be autistic.” She noted that the side effects of autism closely mimic those of glyphosate toxicity, and presented data showing a remarkably consistent correlation between the use of Roundup on crops (and the creation of Roundup-ready GMO crop seeds) with rising rates of autism. Children with autism have biomarkers indicative of excessive glyphosate, including zinc and iron deficiency, low serum sulfate, seizures, and mitochondrial disorder.”
Here are other links explaining how research shows the mother’s exposure to glyphosate likely causes her to have autistic babies.
Links: http://healthimpactnews.com/2014/mit-researcher-glyphosate-herbicide-will-cause-half-of- all-children-to-have-autism-by-2025/
http://circleofdocs.com/community/topic/4106-mit-researcher-glyphosate-herbicide-will-cause- half-of-all-children-to-have-autism-by-2025/
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http://circleofdocs.com/community/topic/4106-mit-researcher-glyphosate-herbicide-will-cause- half-of-all-children-to-have-autism-by-2025/
http://www.livingforlonger.com/mit-researcher-glyphosate-herbicide-will-cause-half-of-all- children-to-have-autism-by-2025/
http://sensoryswim.com/autism-roundup
http://www.infowars.com/half-of-all-children-will-be-autistic-by-2025-warns-senior-research- scientist-at-mit/
http://robinwestenra.blogspot.com/2015/02/warning-half-of-all-children-will-be.html
http://www.medicaldaily.com/autism-rates-increase-2025-glyphosate-herbicide-may-be- responsible-future-half-316388
http://www.vibrationsofhealth.com/gmos-will-cause-half-of-all-children-to-be-autistic-by-2025/2/
There is not enough room to quote excerpts from them all. Here are the rest for those who are interested in the autism-glyphosate links.
http://www.healthnutnews.com/mit-researcher-glyphosate-herbicide-will-cause-half-children-autism-2025/ http://www.getholistichealth.com/41171/mit-researcher-glyphosate-herbicide-will-cause-half-of-all-children-to- have-autism-by-2025/ http://beforeitsnews.com/alternative/2015/03/mit-researcher-glyphosate-herbicide-will-cause-half-of-all-children-to- have-autism-by-2025-3130842.html http://gmoinside.org/mit-researcher-glyphosate-herbicide-will-cause-half-of-all-children-to-have-austim-by-2025- health-impact-news/
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https://zedie.wordpress.com/2014/12/28/half-of-all-children-will-be-autistic-by-2025-warns-senior-research- scientist-at-mit-the-alliance-for-natural-health-usa/
https://usahitman.com/mshcmba/
http://www.liveleak.com/view?i=d36_1422305199
http://soundofheart.org/galacticfreepress/content/mit-states-half-all-children-may-be-autistic-2025-due-monsanto
http://www.thelibertybeacon.com/2014/12/26/half-of-all-children-will-be-autistic-by-2025-warns-senior-research- scientist-at-mit/
http://www.blacklistednews.com/Half_of_All_Children_Will_Be_Autistic_by_2025,_Warns_Senior_Research_Scie ntist_at_MIT/40301/0/38/38/Y/M.html
http://medicsindex.ning.com/forum/topics/medical-news-half-of-all-children-could-be-autistic-by-2025-due
I invite you to search the WEB using “glyphosate” and “autism.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that pregnant women are exposed to glyphosate they have autistic children at a statistically significant higher rate than normal:
Incredibly, the SERA report does not contain the word “autism.” ***************************************** #7 Neurological disorders such as: learning disabilities, attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer's, schizophrenia and bipolar disorder. Those most susceptible are children and the elderly.”
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GMO's & Neurological Disease: ADHD, Autism, Alzheimer's, Schizophrenia, Bipolar
From Health and Wellness, October 8, 2013
Excerpt:
“The endocrine disrupting properties of glyphosate can lead to neurological disorders (learning disabilities (LD), attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer's, schizophrenia and bipolar disorder). Those most susceptible are children and the elderly.”
Link: http://www.sott.net/article/267227-GMOs-Neurological-Disease-ADHD-Autism- Alzheimers-Schizophrenia-Bipolar
Roundup herbicide linked to Parkinson’s-related brain damage from Health, April 21, 2012
Excerpt:
“This month a new and alarming study has been published in the journal Neurotoxicology and Teratology which supports the emerging connection between glyphosate, Roundup's active ingredient, and the emergence of neurodegenerative conditions including Parkinson's disease and Parkinsonian disorders.
The new study, entitled "Glyphosate induced cell death through apoptotic and authophagic mechanisms," was arranged to investigate potential brain-damaging effects of herbicides which authors of the study stated "have been recognized as the main environmental factor associated with neurodegenerative disorders, such as Parkinson’s disease."
Link: http://www.digitaljournal.com/article/323391
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Neurotoxins?
from the Detox Project sponsored by the World Health Organization, 2015
Excerpt:
“Some studies suggest that both glyphosate and Roundup are possibly neurotoxins (toxic to the nervous system). Neurological diseases in humans include Parkinson’s disease, Alzheimer’s disease, and some forms of depression. Neurodevelopmental toxicity to the growing foetus or to babies can result in autism and attention deficit hyperactivity disorder (ADHD).”
Link: http://detoxproject.org/glyphosate/neurological-disease/
I invite you to search the WEB using “glyphosate” and “neurological disorders.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes neurological disorders:
The 2011 SERA glyphosate safety report states:
“In the Reregistration Eligibility Decision (RED) document for glyphosate (U.S. EPA/OPP1993a), the U.S. EPA notes that standard toxicity studies of glyphosate do not suggest that this pesticide is neurotoxic and that specific toxicity tests for neurotoxicity are not necessary:
The acute and 90-day neurotoxicity screening battery in the rat (guidelines 81-8-SS, 82-7) is not being required since there was no evidence of neurotoxicity seen in any of the existing studies at very high doses and this chemical lacks a leaving group; therefore, it would not seem likely to inhibit esterases (the presumptive neurotoxic mechanism of concern for all organophosphates). U.S. EPA/OPP 1993a, p. 18”
(page 41 on the SERA report)
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“Thus, effects reported in Schiffman et al. (1995) cannot be classified clearly as a glyphosate- induced neurological effect.” (page 43)
“As noted above, extreme and sometimes fatal over-exposures to glyphosate are not generally associated with neurologic effects.” (page 45) ***************************************** #8 Irreparable kidney and liver damage
Unique Gene Expression Study Shows Roundup Causes Massive Kidney and Liver Damage at Low Doses
From Sustainable Pulse, Aug 26, 2015 at:
Excerpts:
“A new ground-breaking peer-reviewed study has been published in Environmental Health Journal that shows the levels of glyphosate-based herbicides which the general public are commonly exposed to in drinking water, altered the gene function of over 4000 genes in the livers and kidneys of rats.”
“Dr. Antoniou stated; “The findings of our study are very worrying as they confirm that a very low level of consumption of Roundup weedkiller over the long term can result in liver and kidney damage. Our results also suggest that regulators should re-consider the safety evaluation of glyphosate-based herbicides.” “
Link: http://sustainablepulse.com/2015/08/26/unique-roundup-study-shows-massive-kidney-and- liver-gene-function-alterations/#.Vd8p0Zbn_IX
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More evidence of Roundup's link to kidney, liver damage
From Environmental Health News, September 1, 2015
Excerpts:
“Long-term exposure to tiny amounts of Roundup—thousands of times lower than what is permitted in U.S. drinking water—may lead to serious problems in the liver and kidneys, according to a new study.
The study looked at the function of genes in these organs and bolsters a controversial 2012 study that found rats exposed to small amounts of the herbicide Roundup in their drinking water had liver and kidney damage.
It is the first to examine the impacts of chronic, low exposure of Roundup on genes in livers and kidneys and suggests another potential health impact for people and animals from the widely used weed killer.”
Link: http://www.environmentalhealthnews.org/ehs/news/2015/aug/monsanto-roundup- glyphosate-pesticide-kidney-liver-toxic-gmo
MONSANTO'S HERBICIDE LINKED TO FATAL KIDNEY DISEASE EPIDEMIC: COULD IT TOPPLE THE COMPANY? from Truthout, July 10, 2014
Excerpts:
“For years, scientists have been trying to unravel the mystery of a chronic kidney disease epidemic that has hit Central America, India and Sri Lanka. The disease occurs in poor peasant farmers who do hard physical work in hot climes. In each instance, the farmers have been exposed to herbicides and to heavy metals. The disease is known as CKDu, for Chronic Kidney Disease of unknown etiology. The "u" differentiates this illness from other chronic kidney diseases where the cause is known. Very few Western medical practitioners are even aware of CKDu, despite the terrible toll it has taken on poor farmers from El Salvador to South Asia.”
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“Dr. Catharina Wesseling, the regional director for the Program on Work and Health (SALTRA) in Central America, which pioneered the initial studies of the region's unsolved outbreak, put it this way, "Nephrologists and public health professionals from wealthy countries are mostly either unfamiliar with the problem or skeptical whether it even exists." “
“We know that political changes in Sri Lanka in the late 1970s led to the introduction of agrochemicals, especially in rice farming. The researchers looked for likely suspects. Everything pointed to glyphosate. This herbicide is used in abundance in Sri Lanka. Earlier studies had shown that once glyphosate binds with metals, the glyphosate-metal complex can last for decades in the soil.”
Link: http://www.truth-out.org/news/item/24876-monsantos-herbicide-linked-to-fatal-kidney- disease-epidemic-will-ckdu-topple-monsanto
Other sites also discuss glyphosate and kidney failures: http://www.truth-out.org/news/item/32585-more-evidence-of-roundup-s-link-to-kidney-liver-damage http://www.democraticunderground.com/10027132287 http://www.chemwatch.net/185836/more-evidence-of-roundups-link-to-kidney-liver-damage http://gmwatch.org/news/latest-news/16377-more-evidence-of-roundup-s-link-to-kidney-liver-damage http://www.infowars.com/evidence-mounts-on-roundups-link-to-liver-and-kidney-damage/ http://www.sej.org/headlines/more-evidence-roundups-link-kidney-liver-damage http://www.globalhealingcenter.com/natural-health/evidence-mounts-on-roundups-link-to-liver-and- kidney-damage/ http://wakeup-world.com/2015/10/15/evidence-mounts-on-roundups-link-to-liver-and-kidney-damage/ https://protestationdotorg.wordpress.com/2015/09/01/more-evidence-of-roundups-link-to-kidney-liver- damage/ https://authenticallymale.wordpress.com/2015/09/02/more-evidence-of-roundups-link-to-kidney-liver- damage/ https://clinicpress.com/blog/more-evidence-of-roundups-link-to-kidney-liver-damage-environmental- health-news/
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http://cureliver.info/liver/more-evidence-of-roundups-link-to-kidney-liver-damage-environmental-health- news
http://www.thesleuthjournal.com/evidence-mounts-on-roundups-link-to-liver-and-kidney-damage/
http://todayeco.com/pages/59185402-more-evidence-of-roundups-link-to-kidney-liver-damage
http://article.wn.com/view/2015/08/28/More_evidence_of_Roundups_link_to_kidney_liver_damage/
https://www.pinterest.com/pin/206602701633503702/
http://gmwatch.eu/news/latest-news/16377-more-evidence-of-roundup-s-link-to-kidney-liver-damage
http://www.grbnews.net/more-evidence-of-roundups-link-to-kidney-liver-damage-scientists-report- worrisome-changes-to-liver-and-kidney-genes-in-rats-adding-to-evidence-that-a-popular-herbicide-may- be-toxic.html
http://www.collective-evolution.com/2014/07/15/new-study-links-gmos-to-cancer-liverkidney-damage- severe-hormonal-disruption/
http://have-anticipated.beforeitsnews.com/christian-news/2015/08/roundup-link-to-kidney-liver-disease- dupont-shit-hit-the-fan-latvia-greece-win-opt-out-from-monsanto-gm-crop-2516448.html
I invite you to search the WEB using “glyphosate” and “liver damage.” You will get several hundred thousand hits.
Here is the SERA Report’s denial of the fact that glyphosate exposure causes kidney and liver damage:
The 2011 SERA glyphosate safety report states:
“Signs of kidney toxicity, which might be expected based on observations from human suicide attempts (Appendix 2, Table 6), have not been reported consistently and are not severe (e.g., MRIDs 00130406 and 00150564; NTP 1992).” (pages 38 and 39)
As discussed by U.S. EPA/OPP (1993b), the multi-generation study in rats by Reyna (1985) failed to note any adverse kidney effects at a dose of 500 mg/kg bw/day, which is about 17 times greater than the presumed LOAEL of 30 mg/kg bw/day in study by Schroeder and Hogan (1981).
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Consequently, U.S. EPA/OPP (1993b) concurred with the assessment by Schroeder and Hogan (1981) and considers the finding of kidney tubule dilation a spurious effect.” (page 104)
By the end of the 65-day exposure period, there was no apparent inhibition of liver esterase (Li and Kole 2004, Table II).” (page 142) ***************************************** #9 Parkinson's-Related Brain Damage
Monsanto’s Roundup, Glyphosate Linked to Parkinson’s and Similar Diseases
From Natural Society, October 30, 2012
Excerpt:
“We already know the links between herbicides and sterility in men, birth defects, mental illness, obesity and possibly cancer—but now we have something new to add to the nasty effects of pesticides list — Parkinson’s disease and similar neurodegenerative conditions.
New research, published in the journal Neurotoxicology and Teratology, indicates a connection between a component in Monsanto’s Roundup and Parkinson’s disease. Glyphosate is said to induce cell death, with frightening repercussions.”
Link: http://naturalsociety.com/monsantos-roundup-glyphosate-parkinsons-neurodegenerative/
Roundup, An Herbicide, Could Be Linked To Parkinson’s, Cancer And Other Health Issues, Study Shows
From Huffington Post, January 25, 2013
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Excerpt:
“Those residues enhance the damaging effects of other food-borne chemical residues and toxins in the environment to disrupt normal body functions and induce disease, according to the report, authored by Stephanie Seneff, a research scientist at the Massachusetts Institute of Technology, and Anthony Samsel, a retired science consultant from Arthur D. Little, Inc. Samsel is a former private environmental government contractor as well as a member of the Union of Concerned Scientists.
“Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body,” the study says.
We “have hit upon something very important that needs to be taken seriously and further investigated,” “Seneff said.
Link: http://www.huffingtonpost.com/2013/04/25/roundup-herbicide-health-issues- disease_n_3156575.html
Pesticides and herbicides like glyphosate now strongly linked to Parkinson's disease and other neurological disorders
From Natural News, March 8, 2016
Excerpt:
“(NaturalNews) The genes of the human race have never been under such intense pressure from their surrounding environment. Pesticide and herbicide chemicals that confuse, distort and destroy the natural chemistry of life and microbiology, are being sprayed directly on the foods that people eat. The ill effects are being measured all the way down to the genetic level. In the presence of pesticides and herbicides like glyphosate, healthy genes that were meant to be expressed are being turned off, and genes that were intended to lie dormant are being turned on. The human race is experiencing a shift like never before, and the epigenetic changes are occurring silently, without human understanding.”
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Link: http://www.naturalnews.com/053226_herbicides_gene_expression_Parkinsons.html
Roundup herbicide linked to Parkinson’s-related brain damage
From the National Parkinson Foundation, April 21, 2012
Excerpts:
“Monsanto's controversial herbicide, Roundup, has now been linked to Parkinsonism related disorders according to research reported in the Neurotoxicology & Teratology journal.
This month a new and alarming study has been published in the journal Neurotoxicology and Teratology which supports the emerging connection between glyphosate, Roundup's active ingredient, and the emergence of neurodegenerative conditions including Parkinson's disease and Parkinsonian disorders. The new study, entitled "Glyphosate induced cell death through apoptotic and authophagic mechanisms," was arranged to investigate potential brain-damaging effects of herbicides which authors of the study stated "have been recognized as the main environmental factor associated with neurodegenerative disorders, such as Parkinson’s disease." With the current wide use of Roundup herbicide in the U.S.A., it is considered to be a contaminant in air, groundwater, rain and food, making it virtually impossible to avoid. Researchers in the new study found that glyphosate inhibited the viability of differentiated test cells (PC12, adrenal medula derived), in both dose-and-time dependent manners. They also discovered "glyphosate induced cell death via authophagy pathways in addition to activating apoptotic pathways." “
Link: http://forum.parkinson.org/index.php?/topic/12649-roundup-herbicide-linked-to- parkinson%e2%80%99s-related-brain-damage/
Monsanto's Roundup Weedkiller Linked to Alzheimer's, Parkinson's and ALS
From Alternet, July 19, 2016
Excerpt:
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“According to the most recent review, Glyphosate pathways to modern disease V: Amino acid analogue of glycine in diverse proteins, conducted by independent scientists Anthony Samsel, Ph.D. and Stephanie Seneff, Ph.D., a scientist at Massachusetts Institute of Technology (MIT), glyphosate acts as a glycine analogue that incorporates into peptides during protein synthesis. In this process, it alters a number of proteins that depend on conserved glycine for proper function. According to the authors, glyphosate substitution for glycine correlates with several diseases, including diabetes, obesity, asthma, Alzheimer’s disease, amyotrophic lateral sclerosis (ALS), and Parkinson’s disease, among others.”
Link: http://www.alternet.org/food/monsantos-roundup-weedkiller-changes-dna-function-causing- chronic-disease
Monsanto's Roundup, Glyphosate Linked to Parkinson's and Similar Diseases
From Reader Supported News, October 13, 2012
Excerpt:
“We already know the links between herbicides and sterility in men, birth defects, mental illness, obesity and possibly cancer - but now we have something new to add to the nasty effects of pesticides list - Parkinson's disease and similar neurodegenerative conditions.
New research, published in the journal Neurotoxicology and Teratology, indicates a connection between a component in Monsanto's Roundup and Parkinson's disease. Glyphosate is said to induce cell death, with frightening repercussions.”
Link: http://readersupportednews.org/news-section2/312-16/14279-monsantos-roundup- glyphosate-linked-to-parkinsons-and-similar-diseases
I invite you to search the WEB using “glyphosate” and “Parkinsons.” You will get several hundred thousand hits.
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Here is the SERA Report’s denial of the fact that glyphosate exposure causes Parkinson’s-related brain damage:
The 2011 SERA glyphosate safety report states:
“At this point, there is no evidence to conclude that glyphosate can produce or exacerbate Parkinsonism; indeed, the Barbosa et al. (2001) observation stands in contrast to the abundant case literature which suggests that glyphosate is not a neurotoxicant in humans. The possible connection between the onset of Parkinsonism and the exposure to glyphosate cannot be established from the single case reported by Barbosa et al. (2001), as the apparent concurrence of the two effects could be coincidental. A coincidental association is suggested by the fact no other cases of glyphosate-related Parkinsonism have been reported in the literature in the nearly 10- year period since the Barbosa et al. (2001) publication. Thus, as with the report by Ptok (2009) on speech disorder, the report by Barbosa et al. (2001) is essentially anecdotal and does not demonstrate a causal relationship between glyphosate and the development of Parkinsonism.” (pg 45)
This would be enough to discredit and invalidate the 2011 SERA “Glyphosate -Human Health and Ecological Risk Assessment Final Report” in the minds of reasonably intelligent, thinking, kind USFS people who would not kill other human beings just because the USDA says it’s OK.
You can believe one dubious glyphosate safety study (SERA), or you can be responsible and act according to hundreds of independent scientists’ research conclusions. The SERA safety report is the only source among hundreds of other safety research conclusions available that shows glyphosate exposure is safe..
FS Response: Effects to invasive plants are discussed in the Flat PEA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
------
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Section 3
Children are especially susceptible to glyphosate poisoning
Here is information that won’t please you.
Concerns Over Glyphosate Use
Published in The Sun (Malaysia), Friday August 20, 1999
Excerpt:
“The establishment of the World Health Organization’s (WHO's) Acceptable Daily Intake (ADI) is based on limited studies using limited parameters which do not account for vulnerable groups such as children, the elderly, the sick and other groups that might have increased susceptibility to glyphosate exposure.”
Link: http://www.poptel.org.uk/panap/archives/glywb.htm
Photo images of glyphosate and children
Link: http://www.bing.com/images/search?q=glyphosate+children&qpvt=glyphosate+children&qpvt=glyphosat e+children&FORM=IGRE
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Are Your Children Roundup-Ready?
Published by the Cornucopia Institute, October 1, 2015
Excerpt:
“Feeding herbicide-tolerant GE corn and soy to children gives them a dose of glyphosate with every bite. Glyphosate is often portrayed by the manufacturers as safe for human exposure while being deadly to weeds. However, scientific research indicates that the herbicide is not as harmless as it has been portrayed. Rather, evidence shows that glyphosate may be the most important factor in the development of multiple chronic diseases and conditions now prevalent in Westernized societies.”
Link: http://www.cornucopia.org/2015/10/are-your-children-roundup-ready/
Alleged Glyphosate Poisoning Kills 2 Children, 33 More in Hospital
Published by Natural Society, August 2, 2014
Excerpt:
“Two children (ages 3-yrs, and 6 mos.) from the same family suddenly died last week, one en route to the hospital, another just after being released due to a poisoning outbreak of glyphosate in the Huber Duré settlement. Their bodies have been sent to the capital of Paraguay, Asunción, for detailed autopsies which could confirm that glyphosate was the cause of death.”
The reported poisoning outbreak in Huber Duré is not the first case. Over the past few years, there have been many reports of poisoning, increased abortions, and the death of farm animals in the areas where heavy pesticide spraying is conducted. Following these cases, local residents protested, but authorities took no action to address their concerns.”
Link: http://naturalsociety.com/alleged-glyphosate-poisoning-kills-2-children-33-hospital/
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Glyphosate toxicity – impacts on the environment and non-target species
Published by the Pemaculture College Australia
Excerpt:
“Studies on human cells showed toxicity and hormone disruption at sub agricultural levels with effects within 24 hours caused by concentrations as low as 0.5 parts per million. And DNA damage at 5 parts per million. The impact of glyphosate-based herbicides residues in food, feed or in the environment now has thus to be considered real. PMID: 19539684
The exposure of children to glyphosate should be avoided as recent animal studies have shown that commercial formulation of glyphosate is a potent endocrine (hormone) disruptor, causing disturbances in reproductive development when the exposure was during the puberty period (5)”
Link: http://permaculture.com.au/glyphosate-toxicity-impacts-on-the-environment-and-non-target-species/ FS Response: Effects to invasive plants are discussed in the Flat PEA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
------Section 4
Herbicides that contain glyphosate are banned in Denmark,
England, Italy, El Salvador, Sri Lanka, France, Holland,
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Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan,
Chile, South Africa, Luxembourg, Madeira, Cameroon,
New Zealand, Peru, South Australia, Russia, France,
Switzerland, Columbia, and Costa Rica.
If Monsanto didn’t control the regulatory agencies in America we would be among the countries listed above.
Please open the link below to learn about more countries that protect their citizens and America doesn’t. http://www.bing.com/search?q=Roundup+Banned+in+What+Countries&first=1&FORM=PERE
Who would believe Cameroon, Sri Lanka and Russia would protect their citizens when America ignores the tragic effects of glyphosate.
Monsanto Has Been Removed And Banned By: Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan, Luxembourg, Madeira, New Zealand, Peru, South Australia, Russia, France, and Switzerland!
Published by Political Vel Craft, March 23, 2013
Excerpts:
“Now we know without a doubt that smoking and lung and throat cancer are kissing cousins. Because GMOs have been around for 15 years or so, with no long-term studies other than Monsanto’s being done, we only have Monsanto’s word that GMOs are safe.”
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“We know that when Obama campaigned in 2008, he promised he would label GMOs. When elected, not only did he renege on that promise but immediately appointed former Monsanto VP and attorney Michael Taylor, aka “Monsanto Mike”, as the Head of Food Safety at the Fraud and Drug Administration and Tom Vilsack, another biotech hooker, as the Secretary of Agriculture.”
Link: https://politicalvelcraft.org/2013/03/23/monsanto-has-been-removed-and-banned-by-austria-bulgaria- germany-greece-hungary-ireland-japan-luxembourg-madeira-new-zealand-peru-south-australia-russia- france-and-switzerland/
El Salvador bans glyphosate
Published by Natural News, October 22, 2013
Excerpts:
“While the U.S. Environmental Protection Agency (EPA) was busy doubling (and in some cases quadrupling) the amount of allowable glyphosate residue on certain foods, the nation of El Salvador actually heeded the grim data surrounding the herbicide's disastrous effect on our environment and everything in it and decided to outright ban the chemical.”
“A wealth of independent (read: not funded by Monsanto or Big Agra interests) research been published over the last year to further affirm the havoc wreaked by the now ubiquitous chemical, most notably, award-winning scientist Gilles-Eric Seralini's genetically modified corn toxicity study published in the journal Food and Chemical Toxicity last fall. Seralini and his team found that feeding rats Monsanto's glyphosate-resistant GMO corn resulted in massive bodily system failures, including chronic hormone and reproductive disruption, severe liver and kidney damage and the formation of large tumors which may have been, according to the study, a result of endocrine disruption linked to Roundup.
Other recent research continued to confirm the link between glyphosate and Colony Collapse Disorder, the mass wipeout of America's honeybee population. This is especially troubling, considering the fact that bees are responsible for pollinating every third bite of food on our forks in this country.”
Link: http://www.naturalnews.com/042608_El_Salvador_glyphosate_ban_Monsanto.html#
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Sri Lanka bans leading Monsanto herbicide citing deadly disease fears
Published by The International Consortium of Investigative Journalists, March 14, 2014
Excerpts:
“An investigation carried out by medical specialists and scientists has revealed that kidney disease was mainly caused by glyphosate,” Special Projects Minister S.M Chandrasena told reporters in Sri Lanka. “President Mahinda Rajapaksa has ordered the immediate removal of glyphosate from the local market soon after he was told of the contents of the report.” “
Link: https://www.icij.org/blog/2014/03/sri-lanka-bans-leading-monsanto-herbicide-citing-deadly-disease- fears
France Bans the World’s Leading Herbicide From Garden Stores
Published by Takepart, June 15, 2015
Excerpts:
“On Sunday, Ségolène Royal, the environment and energy minister, announced a plan to ban Roundup from all garden=store shelves in the country.
“The reason? The world’s most popular weed killer contains glyphosate—a chemical the World Health Organization in March determined to be “probably carcinogenic to humans.” “
“ “France must be on the offensive with regards to the banning of pesticides,” Royal said Sunday on French 3TV.”
Link: http://www.takepart.com/article/2015/06/15/france-bans-herbicide
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On the Offensive' Against Monsanto, France Removes Roundup from Store Shelves
Published by Common Dreams, June 15, 2015
Excerpts:
“It's the newest development in the growing international movement against Monsanto in general and Roundup in particular. French Ecology Minister Segolene Royal announced on Sunday that she had instructed garden centers to stop putting the herbicide on the shelves of their self-service aisles, stating, "France must be on the offensive with regards to the banning of pesticides." “
Colombian officials made similar statements in May, when they put a halt to U.S.-backed toxic fumigation of coca fields in the country, noting that a previous ruling by the Colombian Supreme Court called for an end to the aerial spraying program if health concerns over glyphosate were discovered.”
Link: http://www.commondreams.org/news/2015/06/15/offensive-against-monsanto-france-removes- roundup-store-shelves
Dutch Ban Roundup, France and Brazil to Follow
Published by The Healthy Home Economist,
Excerpts:
“The dominoes are starting to fall.
The evidence damning glyphosate, the active ingredient in Roundup, the world’s number one herbicide for weed control, has become too enormous to ignore.
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While it won’t kill you immediately as demonstrated by foolish Monsanto reps who have been known to drink Roundup in product demonstrations to convince unwitting farmers to use it, the long term effects to health are nothing short of devastating.”
Link: http://www.thehealthyhomeeconomist.com/roundup-banned-netherlands-france-brazil-likely-soon- follow/
5 Countries That are Throwing Monsanto Out on its Ass
Published by Ultraculture
Excerpt:
“The world may have had enough of Monsanto, if the events of this month are anything to go by. We’ve just seen no less than five countries—South Africa, France, Chile, Brazil and Sri Lanka—either outright banning the sale of toxic weedkillers or GMO strains produced by the country, or demanding the company hold to truth in advertising standards.”
Link: http://ultraculture.org/blog/2014/04/01/5-countries-throwing-monsanto-ass/
The Netherlands Says “No” to Monsanto, Bans RoundUp Herbicide
Published by Inhabitat, September 29, 2014
Excerpt:
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“The Netherlands is the latest country—after Russia, and Mexico—to say no to Monsanto. The Dutch Parliament recently decided that the sale of glyphosate-based herbicides to private parties will be prohibited as of late 2015. This means that people who spray RoundUp on their gardens and lawns will have to find another form of pest control: glyphosate is the main ingredient in RoundUp, and it has been directly linked to all manner of severe health issues, from bird defects and nervous system damage to kidney failure and various forms of cancer.”
Link: http://inhabitat.com/the-netherlands-says-no-to-monsanto-bans-roundup-herbicide/
3 More European Countries Begin Banning Glyphosate and Monsanto’s Roundup
Published by ANTI MEDIA, June 24, 2015
Excerpt:
“The chemical giant Monsanto has been garnering lots of necessary backlash for their glyphosate products lately. There’s worldwide concern because Monsanto’s glyphosate-containing herbicides are known to cause cancer in animals and have been labeled likely carcinogenic to humans. Monsanto representatives are feeling the pressure — and even asked the World Health Organization to retract their study which hinted at glyphosate being a human carcinogen.”
Link: http://theantimedia.org/more-european-countries-banning-glyphosate-monsantos-roundup/
GLyphosate (Round UP) is Banned in DENMARK and will be banned in Brazil and France
Published by Lanka Newspapers,
Excerpts:
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“Monsanto`s Secret Formula : Dangerous Chemicals in Glyphosate Herbicide Slip Past EU Regulators Due to Data Confidentiality
The only Europeans to ban glyphosate (the main active ingredient in Monsanto`s herbicide roundUp) and its dangerous additions (surfactants) thus far are the Dutch, with Brazil and France to follow. Yet Germany, keeping their evidence of these toxic chemicals secret, pressures EU regulators to allow these unhealthy compounds to be sprayed liberally over the continent.”
“A major qualitative difference between the effect of glyphosate and glyphosate formulations on aquatic and terrestrial organisms concerns the surfactant used in Roundup. The surfactant is much more toxic than glyphosate to aquatic organisms. Unlike glyphosate, the surfactant is more toxic in alkaline water than in acidic water. Thus, the relative potency of the surfactant with respect to glyphosate is pH dependent. There is relatively little information regarding the toxicity of Roundup Pro to aquatic species. Nonetheless, the acute lethal potencies of Roundup and Roundup Pro are similar.”
Link: http://www.lankanewspapers.com/news/2014/9/89870_space.html
FS Response: Effects to invasive plants are discussed in the Flat PEA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area.
------Section 5
California classifies glyphosate as a “”
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California Classifies Glyphosate As Cancer-Causing, FDA Tests Crops For Residue
Published by CBS SF Bay Area, July 7, 2017
Excerpts:
“SAN FRANCISCO (CBS SF) — California added a controversial chemical found in the world’s most popular weedkiller to the list of chemicals known to the state to cause cancer, and the FDA is now testing U.S. crops for residues from that same chemical.
Glyphosate, a key ingredient in hundreds of products including Monsanto’s best-selling herbicide Roundup, was added to the state’s Prop 65 list on Friday. The list was created by The Safe Drinking Water and Toxic Enforcement Act of 1986 and includes hundreds of chemicals known to the state to cause cancer or reproductive toxicity.”
Link: http://sanfrancisco.cbslocal.com/2017/07/07/california-glyphosate-monsanto-cancer-causing-fda- crops/
Glyphosate causes cancer, rules California -- All California retailers are required to add cancer warning labels to all products containing glyphosate from July 7, 2017
Published by Pgurus, July 15, 2017
Excerpts:
“In a major setback to the multinational seed and chemical company, Monsanto, the US State of California declared glyphosate, the main ingredient in its weed killer Roundup, as a toxic cancer-causing chemical, effective July 7, 2017. This decision by the California Office of Environmental Health Hazard Assessment (OEHHA) is a triumph of environmentalists, farmers who have long fought losing battles with the giant corporations, consumer rights activists and health activists.
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Declaring glyphosate as a known, cancer-causing carcinogen, the California Office of Environmental Health Hazard Assessment said it would be added to the state’s warning list under the “The Safe Drinking Water and Toxic Enforcement Act of 1986,” also known as Proposition 65. This law protects California drinking water from toxic, cancer-causing substances and those known to cause birth defects.”
Link: https://www.pgurus.com/glyphosate-causes-cancer-california/
Monsanto Is Suing California for Trying to Inform People That Roundup Causes Cancer
Published by Alternet, March 2, 2016
Excerpts:
“Once again, Monsanto is trying to take away our right to know, this time about carcinogenic chemicals used in household products and places all around us. In January, Monsanto filed a lawsuit against the state of California for its intent to list glyphosate, the main chemical used in Monsanto’s flagship Roundup herbicide, under California's Proposition 65, a law that mandates notification and labeling of all chemicals known to cause cancer, birth defects or other reproductive harm, and prohibits their discharge into drinking waters of the state.
Enacted by California voters via ballot initiative in 1986, Prop 65 prohibits any business from knowingly or intentionally exposing any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving a clear and reasonable warning, and the discharge of such chemical into a source of drinking water is prohibited. The State relies on the findings of the International Agency for Research on Cancer (IARC) of the World Health Organization (WHO) — the world’s leading authority on cancer — as the basis for listing chemicals that are known or probable carcinogens under Prop 65. In 2015, IARC concluded, by a unanimous decision, that glyphosate is “probably carcinogenic.” “
Link: http://www.alternet.org/environment/monsanto-suing-california-trying-inform-people-roundup- causes-cancer
FS Response: Effects to invasive plants are discussed in the Flat PEA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area. 123
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------Indeed, this is not a trivial issue.
With the knowledge contained in the last 46 pages, most people wouldn’t think of applying herbicides that contain glyphosate (Roundup etc.) because they would not be at peace with themselves knowing they may have planted the cancer seed in a forest visitor … maybe a child.
Ask yourself how a Federal District Court judge would rule when the plaintiff introduces the information above and the USFS’s OGC attorney tries to refute it with information from the SERA report.
FS Response: Effects to invasive plants are discussed in the Flat PEA starting on page 3-51. The Flat project contains no proposed herbicide treatments of noxious weeds in the project area. Opposing Views Attachment #4
Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest
Road Construction Opposing View #1 - “Fragmentation has been considered as one of the most major factors that lead to the decline of many wildlife species (Brittingham and Temple 1983, Yahner 1988, Winslow et al. 2000) because fragmentation tends to decrease population productivity (Robinson et al. 1995). Therefore, Meffe states that “fragmentation has become a major subject of research and debate in conservation biology” (Meffe et al. 1997, p. 272). Forest fragmentation usually occurs when large and continuous forests are divided into smaller patches as a result of road establishment, clearing for agriculture, and human development (Robinson et al. 1995, Meffe et al. 1997).” (Pg. 1)
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“Generally, habitat fragmentation is an ecological process in which a large patch of habitat is divided into smaller patches of habitats. Usually, this process is caused by human activities (roads, agriculture, and logging). It also reduces the value of the landscape as habitat for many species (plants and animals). Fragmentation alters natural habitat in many ways, including reduction of patches’ sizes, increment of distances between similar patches, and increment of edges and predation (Brittingham and Temple 1983, Robinson et al. 1995).” (Pp. 2 and 3)
Al-jabber, Jabber M. 2003
“Habitat Fragmentation: Effects and Implications” http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pdf
FS Response: Not peer reviewed, Cascadia Wildland Project publication, the Flat project does not have described ‘fragmentation’.
------Road Construction Opposing View #2 - "Debris slides over a 20-year period were inventoried on 137,500 acres of forested land in the Klamath Mountains of southwest Oregon. Frequency during the study period was about one slide every 4.3 years on each 1,000 acres-an erosion rate of about 1/2 yd3 per acre per year. Erosion rates on roads and landings were 100 times those on undisturbed areas, while erosion on harvested areas was seven times that of undisturbed areas. Three-quarters of the slides were found on slopes steeper than 70 percent and half were on the lower third of slopes."
"Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests."
Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr and R. R. Ziemer Ph.D. "Logging and forest roads related to increased debris slides in southwestern Oregon." Journal of Forestry Vol. 83, No. 4. 1985. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF
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FS Response: Relevant scientific document. The Flat project manages for soil erosion.
------Road Construction Opposing View #3 - " ‘Roads may have unavoidable effects on streams, no matter how well they are located, designed or maintained. The sediment contribution to streams from roads is often much greater than that from all other land management activities combined, including log skidding and yarding.’ (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.”
“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.watertalk.org/wawa/ecosci.html
FS Response: Citation is actually from 1973 Publication, not 2006 report. The Flat project does not propose road construction. The Flat project recognizes effects from temporary road construction.
------Road Construction Opposing View #4 - “Plot-level studies have demonstrated the ability of forest roads to intercept and route both subsurface and surface overland flow more efficiently to the stream network. Significant amount of subsurface throughflow can be intercepted by the road, as a function of the road cut depth and the current saturation deficit, and then redirected, concentrating the flow in particular areas below the road. Road drainage concentration increases the effective length of the channel network and strongly influences the distribution of erosional processes. The concept of wetness index has been used in the study as a surrogate for subsurface throughflow, and the effect of forest roads on subsurface throghflow rerouting has been assessed by evaluating the changes in terms of draining upslope areas. A threshold model for shallow slope instability has been used to analyse erosional impacts of drainage modifications. In the model, the occurrence of shallow landsliding is evaluated in terms of drainage areas, ground slope and soil properties (i.e., hydraulic conductivity, bulk density, and friction angle). The model has been used to generate hypotheses about the broader geomorphic effect of roads. Modelling results have been compared with available field data collected in north-eastern Italy.”
Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi
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“Evaluating the Effects of Forest Roads on Shallow Landsliding”
Geophysical Research Abstracts, Vol. 5, 13312, 2003 http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf
FS Response: Relevant document. The Flat project proposes to close 42.8 miles of road and decommission 3.2 miles of road in the proposed action and Alternative 3 which will enhance the drainage and watershed flow of the surrounding area.
------Road Construction Opposing View #5 - “A large scale land use experiment has taken place over the last 40 years in the mountainous areas of the northwestern U.S. through timber harvesting. This land use change effects the hydrology of an area through two mechanisms:
• Clear-cut logging which causes changes in the dynamics of Rain-On-Snow (ROS) events due to changes in the accumulation and ablation of snow caused by vegetation effects on snow interception and melt; and
• Construction and maintenance of forest roads which channel intercepted subsurface flow and infiltration excess runoff to the stream network more quickly.”
Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins
“Predicting the Effects of Forest Roads on Streamflow using a
Distributed Hydrological Model”
from a poster presented at the fall meeting of the American Geophysica Union, San Francisco, CA, December 1996.
http://www.ce.washington.edu/~lxb/poster.html
FS Response: Not published or peer reviewed.
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------Road Construction Opposing View #6 - "American rivers and streams face destruction by sedimentation. Clearcutting, along with the vast network of logging roads, result in sedimentation and soil erosion into our national forest’s rivers and streams. Sedimentation degrades the water quality, impairs the habitat for fish and macroinvertebrates, and limits the ecosystem functions and services of streams.
By Dr. Seth Reice is Associate Professor of Biology in the Department of Biology and Curriculum in Ecology, University of North Carolina.
From Press Conference with Senator Robert Torricelli, April 28, 1998, U.S. Capitol regarding the proposed Act to Save America’s Forests (S. 977, HR 1376)
FS Response: The Flat project does not propose clearcutting.
------Road Construction Opposing View #7 - "Surface erosion from road surfaces, cutbanks, and ditches represents a significant and, in some landscapes, the dominant source of road-related sediment input to streams. Increased sediment delivery to streams after road building has been well documented in the research literature in the Pacific Northwest and Idaho (Bilby and others 1989, Donald and others 1996, Megahan and Kidd 1972, Reid and Dunne 1984, Rothacher 1971, Sullivan and Duncan 1981) and in the Eastern United States (Kochenderfer and others 1997, Swift 1985, 1988). Rates of sediment delivery from unpaved roads appear highest in the initial years after building (Megahan and Kidd 1972)” (pg 23)
“Roads interact directly with stream channels in a variety of ways, depending on orientation to streams (parallel, orthogonal) and landscape position (valley bottom, midslope, ridge). The geomorphic consequences of these interactions, particularly during storms, are potentially significant in terms of erosion rates, direct and off-site effects on channel morphology, and drainage network structure, but they are complex and often poorly understood.” (pg 24)
“Findings: Habitat loss has broader effects than just the conversion of a small area of land to road surfaces. Roads fragment by changing landscape structure and by directly and indirectly affecting species. Habitat effects of roads on the landscape include dissecting vegetation patches, increasing the edge-affected area and decreasing interior area, and increasing the uniformity of
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patch characteristics, such as shape and size (Reed and others 1996). Whenever forest roads are built, changes in habitat and modified animal behavior will lead to changes in wildlife populations (Lyon 1983).” (pgs 30 and 31)
“The effects of roads are not limited to those associated with increases in fine-sediment delivery to streams; they can include barriers to migration, water temperature changes, and alterations to streamflow regimes.” (pg 34)
“Findings: Roads contribute more sediment to streams than any other land management activity (Gibbons and Salo 1973, Meehan 1991), but most land management activities, such as mining, timber harvest, grazing, recreation, and water diversions depend on roads. Most of the sediment from timber harvest activities is related to roads and road building (Dunne and Leopold 1978, Megahan and others 1978, MacDonald and Ritland 1989, Chamberlain and others 1991, Furniss and others 1991) and the associated increases in erosion rates (Swanson and Dyrness 1975, Swanston and Swanson 1976, Beschta 1978, Gardner 1979, Reid and Dunne 1984, Meehan 1991, Reid 1993, Rhodes and others 1994).” (pg 36)
Forest Service Roads: A Synthesis of Scientific Information, June, 2000
Edited by: Hermann Gucinski, Pacific Northwest Research Station Corvallis, OR
Michael J. Furniss, Rocky Mtn Res. Station, Stream SystemsTechnology Center, Fort Collins, CO.
Robert R. Ziemer, Pacific Southwest Research Station, Arcata, CA
Martha H. Brookes, Pacific Northwest Research Station, Portland
https://www.fs.fed.us/eng/road_mgt/science.pdf
FS Response: The Flat project acknowledges that roads contribute sediment. No new roads will be constructed, and roads activities propose to close and decommission roads. The Flat project manages for sedimentation and soil erosion.
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------Road Construction Opposing View #8 - "Sediment input to freshwater is due to either the slower, large-scale process of soil erosion, or to rapid, localized “mass movements,” such as landslides. Forest practices can increase the rate at which both processes occur. Most sediment from forestry arises from landslides from roads and clearcuts on steep slopes, stream bank collapse after riparian harvesting, and soil erosion from logging roads and harvested areas. Roads, particularly those that are active for long periods of time, are likely the largest contributor of forestry-induced sediment (Furniss et al. 1991)."
"Sediment can increase even when roads comprise just 3% of a basin (Cederholm et al. 1981)."
"More than half the species present in the study area will likely be negatively impacted by sedimentation from logging roads."
"In areas made highly turbid (cloudy) from sedimentation, the foraging ability of adults and juveniles may be inhibited through decreased algal production and subsequent declines in insect abundance, or, for visual-feeding taxa dependent on good light, through their inability to find and capture food. Highly silted water may damage gill tissue and cause mortality or physiological stress of adults and juveniles."
Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 "Evaluating effects of large-scale salvage logging for mountain pine beetle on terrestrial and aquatic vertebrates." Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest Service. http://warehouse.pfc.forestry.ca/pfc/25154.pdf
FS Response: Working paper from Natural Resources Canada. Exerts taken out of context, document evaluates effects of logging on vertebrates. The Flat project manages for sedimentation and soil erosion.
------Road Construction Opposing View #9 - "The road construction and right-of-way logging were immediately detrimental to most aquatic invertebrates in South Fork Caspar Creek"
"Salmonid populations decreased immediately after the road construction."
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"Sustained logging and associated road construction over a period of many years do not afford either the stream or the 'fish population a chance to recover."
Burns, James W., "Some Effects of Logging and Associated Road Construction on Northern California Streams." Transactions of the American Fisheries Society, Volume 1, Number 1, January 1972. http://www.fs.fed.us/psw/publications/4351/Burns72.pdf
FS Response: Scientific article not relevant in time or space to the Flat project.
------
Road Construction Opposing View #10 – “Road construction in the steep, often unstable terrain of Oregon's mountains is both, difficult and hazardous. It is also costly, both in terms of direct construction and damage to the aquatic environment. We know that in Oregon, forest roads are our greatest source of problems with mass soil movement ( Brown and, Krygier, 1971;Fredriksen, 1970; Dyrness, 1967 ). Yet we do not understand the processes well enough to be able to predict with reasonable certainty where road failures will occur or how alternative road designs will affect mass movements except in the most obvious places.”
Brown, George W. Ph.D., The Impact of Timber Harvest on Soil and Water Resources
Dr. BROWN is the Forest Hydrologist, School of Forestry, Oregon State University http://andrewsforest.oregonstate.edu/pubs/pdf/pub1695.pdf
FS Response: The Flat project acknowledges that roads contribute sediment. No new roads will be constructed, and roads activities propose to close and decommission roads. The Flat project manages for sedimentation and soil erosion.
------
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Road Construction Opposing View #11 - “Forested watersheds typically release clean water, yet forest roads and trails can drastically impact water quality. Increased stream sedimentation from road and skid trail crossings represent the most significant water quality threat associated with forestry operations.”
From Forest Roads and Sediment Project
PROJECT DURATION:1 January 2011 to 30 November 2019
Published by Virginia Tech University
By W. Mike Aust,Ph.D., Kevin McGuire, Ph.D., M. Chad Bolding, Ph.D. and Scott Barrett, Ph.D.
http://hydro.vwrrc.vt.edu/research/projects/forest-roads-and-sediment-project/
FS Response: Link to a project that will test the modeling for sediment into streams. Relevant. Study not completed, but will compare BMPs to roads constructed without BMPs. The Flat projects incorporates BMPs in additions to more site specific design criteria outlined in the EA.
------Road Construction Opposing View #12 - "Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road."
Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks made to Forest Service employees and retirees at the University of Montana. February 1998. https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dombeck%27 s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm
FS Response: Opinions. The Flat project proposes to close and decommission roads which will increase the water quality, habitat, and decrease sedimentation levels in the area. Temporary roads will be closed and rehabilitated after completion of project.
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------Road Construction Opposing View #13 - "Few marks on the land are more lasting than roads."
"The negative effects on the landscape of constructing new roads, deferring maintenance, and decommissioning old roads are well documented. Unwanted or non-native plant species can be transported on vehicles and clothing by users of roads, ultimately displacing native species. Roads may fragment and degrade habitat for wildlife species and eliminate travel corridors of other species. Poorly designed or maintained roads promote erosion and landslides, degrading riparian and wetland habitat through sedimentation and changes in streamflow and water temperature, with associated reductions in fish habitat and productivity. Also, roads allow people to travel into previously difficult or impossible to access areas, resulting in indirect impacts such as ground and habitat disturbance, increased pressure on wildlife species, increased litter, sanitation needs and vandalism, and increased frequency of human-caused fires."
EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, "National Forest System Road Management."
https://www.federalregister.gov/documents/2000/03/03/00-5002/national-forest-system-road-management
FS Response: Relevant document. The Flat project plans to mitigate the effects of roads. The project proposes to close and decommission roads which will increase the water quality, habitat, and decrease sedimentation levels in the area. Temporary roads will be closed and rehabilitated after discourse of project.
------
Road Construction Opposing View #14 - “Fragmentation caused by roads is of special interest because the effects of roads extend tens to hundreds of yards from the roads themselves, altering habitats and water drainage patterns, disrupting wildlife movement, introducing exotic plant species, and increasing noise levels. The land development that follows roads out into rural areas usually leads to more roads, an expansion process that only ends at natural or legislated barriers.”
“Forest Fragmentation and Roads”
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Eastern Forest Environmental Threat Assessment Center
U.S. Forest Service - Southern Research Station
http://www.forestthreats.org/publications/su-srs-018/fragmentation
FS Response: Relevant document. Flat project plans to mitigate the effects of roads. The project proposes to close and decommission roads which will reduce fragmentation.
------Road Construction Opposing View #15 - “A huge road network with vehicles ramifies across the land, representing a surprising frontier of ecology. Species-rich roadsides are conduits for few species. Roadkills are a premier mortality source, yet except for local spots, rates rarely limit population size. Road avoidance, especially due to traffic noise, has a greater ecological impact. The still-more-important barrier effect subdivides populations, with demographic and probably genetic consequences. Road networks crossing landscapes cause local hydrologic and erosion effects, whereas stream networks and distant valleys receive major peak-flow and sediment impacts. Chemical effects mainly occur near roads. Road networks interrupt horizontal ecological flows, alter landscape spatial pattern, and therefore inhibit important interior species. Thus, road density and network structure are informative landscape ecology assays. Australia has huge road-reserve networks of native vegetation, whereas the Dutch have tunnels and overpasses perforating road barriers to enhance ecological flows. Based on road- effect zones, an estimated 15–20% of the United States is ecologically impacted by roads.”
Forman, Richard T. and Lauren E. Alexander “Roads and their Major Ecological Effects” Annual Review of Ecology and Systematics, Vol. 29: 207-231, November 1998
http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&journalCode =ecolsys.1
FS Response: Relevant document. The Flat project manages road density by closing roads and decommissioning roads.
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------Road Construction Opposing View #16 - “Questions to consider: Roads dramatically alter forest ecosystems
1. Does the management prescription account for the ecological effects of the road construction and maintenance activities associated with carrying out such activities?
2. Have alternatives to road building been considered? How does the plan attempt to address the effects of roads?” (page 37)
Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf
FS Response: Repeated article. Relevant, we are using science outlined in paper. Project accounts for effects of roads and has alternatives.
------Road Construction Opposing View #17 - “The authors warned that cutting roads into current roadless areas could bring much more harm to wildlife, soil and fisheries than the beetle-killed trees pose to the forest.”
Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/
FS Response: Opinion. No proposed roads in inventoried roadless areas.
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------Road Construction Opposing View #18 - "Rarely can roads be designed and built that have no negative impacts on streams. Roads modify natural drainage patterns and can increase hillslope erosion and downstream sedimentation. Sediments from road failures at stream crossings are deposited directly into stream habitats and can have both on-site and off-site effects. These include alterations of the channel pattern or morphology, increased bank erosion and changes in channel width, substrate composition, and stability of slopes adjacent to the channels."
"All of these changes result in important biological consequences that can affect the entire stream ecosystem. One specific example involves anadromous salmonids, such as salmon and steelhead, that have complex life histories and require suitable stream habitat to support both juvenile and adult life stages."
"A healthy fishery requires access to suitable habitat that provides food, shelter, spawning gravel, suitable water quality, and access for upstream and downstream migration. Road-stream crossing failures have direct impacts on all of these components."
Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan "Diversion Potential at Road-Stream Crossings." USDA Forest Service. 9777 1814—SDTDC. December 1997. http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf
FS Response: Relevant document. The Flat project mitigates all effects of temporary road construction and monitors all sensitive species.
------Road Construction Opposing View #19 - “Barry Noon, a professor of wildlife ecology at Colorado State University, noted that scientific research has consistently shown the adverse effects of roads on hydrologic processes and fish and wildlife populations.
“ “One of the key things to recognize is the effects of the roads extend far beyond their immediate footprint,” Noon said. For example, “in terms of hydrology, the roads are leading to faster runoff of water, often with great increases in sedimentation, particularly following storm events, and roads in watersheds often lead to increases in the intensity of floods.” “
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These changes degrade fish habitat because of the increased sedimentation that leads to decreases in water quality, Noon said. And roads fragment wildlife habitat and create areas that animals avoid, often as result of increased hunting, he said.”
Gable, Eryn “Battling beetles may not reduce fore risks – report” Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/
FS Response: Opinion piece.
------Road Construction Opposing View #20 - "Roads and skid trails have been identified as a major contributor to increased turbidity of water draining logging areas resulting in increases from 4 to 93 parts per million (Hoover, 1952). Forest roads have been found to have erosion rates from one to three orders of magnitude greater than similar undisturbed areas (Megahan, 1974) and perhaps account for as much as 90 percent of all forest erosion (Megahan, 1972). Forest roads can also cause soil erosion and stream sedimentation, which adversely impact on the nation’s water quality (Authur et al., 1998).
Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the forest road system." In: Proceedings of the conference 34 international erosion control association; ISSN 1092-2806. [Place of publication unknown]: International Erosion Control Association: 301-310. http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf
FS Response: Conference proceedings. The Flat project recognizes and mitigates the effects of temporary roads.
------Road Construction Opposing View #21 - "Roads have well-documented, short- and long-term effects on the environment that have become highly controversial, because of the value society now places on unroaded wildlands and because of wilderness conflicts with resource extraction."
"(Road) consequences include adverse effects on hydrology and geomorphic features (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic
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species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, use conflicts, destructive human actions (for example, trash dumping, illegal hunting, fires), lost solitude, depressed local economies, loss of soil productivity, and decline in biodiversity."
Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of Scientific Information." USDA Forest Service, General Technical Report PNW-GTR-509. http://www.fs.fed.us/pnw/pubs/gtr509.pdf
FS Response: Relevant. Project is designed to increase water quality and habitat in the long term. The Flat project recognizes and mitigates effects of temporary roads.
------Road Construction Opposing View #22 - "Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands."
Hann, W.J. et al. 1997 Landscape dynamics of the Basin. Pp. 337-1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405 http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf
FS Response: Characteristics described in exert not relevant to the Flat project.
------Road Construction Opposing View #23 - “Many forested landscapes are fragmented by roads, but our understanding of the effects of these roads on the function and diversity of the surrounding forest is in its infancy. I investigated the effect of roads in otherwise continuous forests on the macroinvertebrate fauna of the soil. I took soil
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samples along transects leading away from the edges of unpaved roads in the Cherokee National Forest in the Southern Appalachian mountains of the United States. Roads significantly depressed both the abundance and the richness of the macroinvertebrate soil fauna. Roads also significantly reduced the depth of the leaf- litter layer. These effects persisted up to 100 m into the forest. Wider roads and roads with more open canopies tended to produce steeper declines in abundance, richness, and leaf-litter depth, but these effects were significant only for canopy cover and litter depth. The macroinvertebrate fauna of the leaf litter plays a pivotal role in the ability of the soil to process energy and nutrients. These macroinvertebrates also provide prey for vertebrate species such as salamanders and ground-foraging birds. The effect of roads on the surrounding forest is compounded by the sprawling nature of the road system in this and many other forests. My data suggest that even relatively narrow roads through forests can produce marked edge effects that may have negative consequences for the function and diversity of the forest ecosystem.”
Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Macroinvertebrate Soil Fauna of the Southern Appalachian Mountains” http://www.jstor.org/stable/2641904
FS Response: Relevant. The Flat project is designed to increase water quality and habitat in the long term. The Flat project recognizes and mitigates effects of temporary roads.
------
Road Construction Opposing View #24 - “Roads remove habitat, alter adjacent areas, and interrupt and redirect ecological flows. They subdivide wildlife populations, foster invasive species spread, change the hydrologic network, and increase human use of adjacent areas. At broad scales, these impacts cumulate and define landscape patterns.”
Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D.,
Murray K. Clayton Ph.D., Roger B. Hammer Ph.D.,
and Charlotte E. Gonzalez-Abraham Ph.D.
“Road Development, Housing Growth, and Landscape
Fragmentation In Northern Wisconsin: 1937–1999”
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Ecological Applications: Vol. 16, No. 3, pp. 1222-1237. http://www.esajournals.org/doi/abs/10.1890/1051- 0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journalCode=ecap
FS Response: Relevant. The Flat project proposes to close roads and decommission roads.
------Road Construction Opposing View #25 - “Last winter was unusually wet in the Pacific Northwest. The result was landslides all over caused by logging roads; five people died, spawning streams were ruined, water supplies were contaminated and the flooding was tremendously aggravated. According to David Bayles, conservation director of the Pacific Rivers Council, aerial surveys documented more than 650 landslides in February in Washington and Oregon alone. The stupidest and most dangerous practice is allowing logging roads on steep slopes — that's really asking for it.
You may ask yourself why the taxpayers are expected to pony up to build roads for profitable logging companies. Build roads for the timber companies in order to stimulate the U.S. logging, paper and building industries. There's just one problem. A lot of U.S. logs get shipped overseas, mostly to Japan. We're actually subsidizing Japanese companies while doing terrible damage to our environment and not helping the U.S. job scene much except when it comes to cutting
Start with the assumption that the U.S. Forest Service a component of the Department of Agriculture, is simply an auxiliary branch of the timber industry and you'll pretty much have the picture of what's going on. Last winter, the Forest Service refused a bid at a timber auction from an environmentalist who wanted to save, not harvest, a stand of evergreens in the Okanogan National Forest in Washington. Instead, the Forest Service accepted a bid of $15,000 from a logging company that cut 3.5 million board-feet of lumber in that stand. Try to find a price like that at Home Depot.”
Ivins, Molly
Creators Syndicate, August 3 1997 08 03
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http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html
FS Response: Opinion.
------Road Construction Opposing View #26 - "Although disturbance patches are created by peak flow and debris flow disturbances in mountain landscapes without roads, roads can alter the landscape distributions of the starting and stopping points of debris flows, and they can alter the balance between the intensity of flood peaks and the stream network's resistance to change."
Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of roads on hydrology, geomorphology, and disturbance patches in stream networks." Conservation Biology 14, No. 1. 2000. http://www.jstor.org/stable/2641906
FS Response: Relevant. The Flat project proposes to close roads and decommission roads to improve habitat quality and resilience in the long term.
------Road Construction Opposing View #27 - "In the Pacific Northwest, the two main processes that contribute to sediment production are mass failure and surface erosion from forest roads (Fredriksen 1970, Reid and Dunne 1984). In the Clearwater River basin in the State of Washington, as much as 40 percent of the sediment produced in the watershed was attributed to logging roads (Reid 1980)."
Kahklen, Keith. "A Method for Measuring Sediment Production from Forest Roads." Pacific Northwest Research Station, USDA Forest Service. Research note PNW-RN-529, April 2001. http://www.fs.fed.us/pnw/pubs/rn529.pdf
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FS Response: Relevant. The Flat project manages for these effects.
------Road Construction Opposing View #28 - "It is indisputable that roads are one of the greatest threats to the ecological integrity of forested systems and associated river, wetland, lake, and coastal ecosystems. Yet, the USFS has failed to adopt a policy that mandates reversing the worst ecological effects of roads, or that precludes incursion of roads into roadless areas. Despite widespread recognition of these facts, the USFS diverts staff and money to extraordinarily costly salvage logging projects at the expense of reducing the extent of the road network or undertaking needed fine-fuels reductions in unburned forests."
Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt from a letter to the Subcommittee on Forests & Forest Health U.S. House of Representatives. 3 July, 2002. http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from_beschta.htm
FS Response: Opinion
------Road Construction Opposing View #29 - “Forest fragmentation, as scientists call the intentional felling of woodland, is actually two processes. In populated areas such as the Atlantic seaboard, it means reduction in the size of forest tracts, usually due to suburbanization and development. In less inhabited areas--northern New England, for example--forest fragmentation refers to isolation of one patch of forest from another by logging, or by the building of roads or power lines.”
Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament as experts ponder the decline of dozens of forest species”
National Wildlife
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http://www.nwf.org/News-and-Magazines/National-Wildlife/Birds/Archives/1992/Singing-the-Blues-for- Songbirds.aspx
FS Response: Opinion
------Road Construction Opposing View #30 - "The compaction of forest road soils is known to reduce aeration, porosity, infiltration rates, water movement, and biological activity in soils. Research indicates that soil bulk density, organic matter, moisture, and litter depths are much lower on roads than on nearby forest lands. Macropores, which provide soil drainage and infiltration, have been shown to significantly decrease in size as a result of road construction and use. Reduced infiltration and increased compaction promote soil erosion, especially during the seasonal southwestern monsoon rains (Elseroad 2001)."
"Physical disturbances caused by road construction and vehicle use create ideal conditions for colonization by invasive exotic plant species. The use of roads by vehicles, machinery, or humans often aids the spread of exotic plant seeds. Once established, they can have long-term impacts on surrounding ecosystems and can be difficult to remove."
"Roads are known to cause habitat fragmentation. Many create ecological 'edges' with different plant species, light levels, and hiding cover, all of which may alter animal survival, reproductive success, and movement patterns. The introduction of exotic plants can disrupt the availability of native vegetation used by wildlife for food and shelter (Trombulak and Frissell 1999)."
"Forest roads often develop a water-repellent soil layer caused by lack of vegetative cover and changes in soil composition. This can substantially influence how runoff is processed. Erosion, the formation of water channels beside the road, and increased sediment loads in nearby streams are common results of this process (Baker 2003)."
"Because they provide easier access to many forest tracts, forest roads often allow more human- caused fires to be ignited."
Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona University Ecological Restoration Institute publication Working Paper 12. June, 2005. http://www.eri.nau.edu/en/information-for-practitioners/restoring-forest-roads
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FS Response: Not published/peer reviewed. The Flat project manages for sedimentation and soil erosion.
------Road Construction Opposing View #31 - "Almost everywhere people live and work they build and use unimproved roads, and wherever the roads go, a range of environmental issues follows."
"Among the environmental effects of unimproved roads, those on water quality and aquatic ecology are some of the most critical. Increased chronic sedimentation, in particular, can dramatically change the food web in affected streams and lakes."
"The nearly impervious nature of road surfaces (or treads) makes them unique within forested environments and causes runoff generation even in mild rainfall events, leading to chronic fine sediment contributions."
"If we look at the issue of what we need to learn or the research priorities for forest road hydrology, I would argue that the areas of cutslope hydrology and effectiveness of restoration efforts are perhaps most critical."
"At a few sites in the mountains of Idaho and Oregon a substantial portion of the road runoff (80–95%) came from subsurface flow intercepted by the cutslope (Burroughs et al., 1972; Megahan, 1972; Wemple, 1998)."
Luce, Charles H. Ph.D., 2002. "Hydrological processes and pathways affected by forest roads: what do we still need to learn?" Hydrologic Processes: 16, 2901–2904. http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%20HP.pdf
FS Response: USFS Commentary, relevant. The Flat project address described effects.
------Road Construction Opposing View #32 - "Roads in the watershed contribute to sediment production by concentrating runoff, thereby increasing sediment load to the stream network. Most unimproved (dirt) roads connect either directly or indirectly with streams and, therefore, act as extensions of stream networks by effectively increasing watershed drainage density and
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subsequently sediment loads to streams. In the South Fork subwatershed of Squaw Creek, road connectivity has resulted in an increase in effective drainage density of approximately 250%. Throughout the Squaw Creek watershed, it is estimated that dirt roads potentially contribute as much as 7,793 metric tons/year to the watershed sediment budget."
Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Road Effects on Stream Channel Networks in an Eastern Sierra Nevada Watershed." Journal of the Nevada Water Resources Association, Volume 2, Number 2, Fall 2005. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_article4.pdf
FS Response: Relevant if truly published. The Flat project address and manages effects from roads.
------
Road Construction Opposing View #33 - “One of the greatest impacts of roads and (especially motorized) trails is their effect on the hydrology of natural landscapes, including the flow of surface and ground water and nutrients. These hydrologic effects are responsible for changes to geomorphic processes and sediment loads in roaded areas (Luce and Wemple 2001).” (pg. 12)
Malecki, Ron W. “A New Way to Look at Forest Roads: the
Road Hydrologic Impact Rating System (RHIR)”
The Road-RIPorter, Autumn Equinox, 2006 http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf
FS Response: Magazine/opinion. The Flat project addresses and manages effects from roads.
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------Road Construction Opposing View #34 - "A study was made on 344 miles of logging roads in northwestern California to assess sources of erosion and the extent to which road-related erosion is avoidable. At most, about 24 percent of the erosion measured on the logging roads could have been prevented by conventional engineering methods. The remaining 76 percent was caused by site conditions and choice of alignment. On 30,300 acres of commercial timberland, an estimated 40 percent of the total erosion associated with management of the area was found to have been derived from the road system."
McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging roads in northwestern California: How much is avoidable?" Journal of Forestry 8(1): 23-26. http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf
FS Response: Scientific document, not relevant. Research article is specific to area and outdated.
------Road Construction Opposing View #35 - "Research has shown that roads can have adverse impacts on the water quality on the forest landscape (Authur et al. 1998; Binkley and Brown 1993; Megahan et al. 1991). The forest road system has been identified by previous research as the major source of soil erosion on forestlands (Anderson et. al 1976; Patric 1976; Swift 1984; Van Lear et al. 1997). Furthermore, roads are cited as the dominant source of sediment that reaches stream channels (Packer 1967; Trimble and Sartz 1957; Haupt 1959)."
McFero III, Grace, J. "Sediment Plume Development from Forest Roads: How are they related to Filter Strip Recommendations?" An ASAE/CSAE Meeting Presentation, Paper Number: 045015, August 1-4, 2004. http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf FS Response: Not published/peer reviewed. The Flat project manages effects for water quality, sediment and soil erosion. ------
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Road Construction Opposing View #36 - “Overall, roads had a greater impact on landscape structure than logging in our study area. Indeed, the 3-fold increase in road density between 1950–1993 accounted for most of the changes in landscape configuration associated with mean patch size, edge density, and core area.”
McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and logging on landscape structure in the San Juan Mountains, Colorado (USA)”
Landscape Ecology, Volume 16, Number 4 / May, 2001
http://www.springerlink.com/content/w12557624742tv77/
FS Response: Relevant article. The Flat project manages for road impacts. Overall project will decrease sedimentation levels, increase water quality, and increase habitat quality.
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Road Construction Opposing View #37 - “Road construction in remote areas appears to be the major long term impact of resource extraction industries and the most significant problem facing grizzly bears in most locations. Open roads are an influence in all 5 ways that people affect bears. Vehicles on roads can harass bears, displace them from quality habitats, and cause reduced bear use of altered habitats, such as cutting units. Bears that are displaced from roads may cause social disruption in areas away from roads. Finally, roads permit access for many people and some of these will shoot bears.” (Pg. 62)
McLellan, Bruce N. “Relationships between Human
Industrial Activity and Grizzly Bears”
Bears: Their Biology and Management, Vol. 8
International Conference on Bear Research and Management
February 1989 (1990), pp. 57-64
147
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FS Response: Relevant or not, all temporary roads will be closed after project and an additional 3.2 miles of road in the proposed action and Alternative 3 will be decommissioned.
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Road Construction Opposing View #38 - “Erosion from forest roads can be a large source of sediment in watersheds managed for timber production.”
Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from
Forest Roads in Washington State” from a presentation presented at the 2003 Geological Society of America meeting. http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm
FS Response: Not peer reviewed or published article.
------Road Construction Opposing View #39 - “Today, addressing the adverse impacts of forest roads is consistently identified as one of the highest watershed restoration priorities in U.S. forests—in many forested watersheds in the western United States there is a greater road density than stream density. It is simply irrational to spend millions of dollars subsidizing further forest road construction when we are simultaneously spending millions of dollars to offset detrimental effects associated with similar actions in the past.”
Montgomery, David Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests
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April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm
FS Response: Opinion/statement.
------Road Construction Opposing View #40 - “Nothing is worse for sensitive wildlife than a road. Over the last few decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity - habitat destruction and fragmentation, edge effects, exotic species invasions, pollution, and overhunting - are aggravated by roads. Roads have been implicated as mortality sinks for animals ranging from snakes to wolves; as displacement factors affecting animal distribution and movement patterns; as population fragmenting factors; as sources of sediments that clog streams and destroy fisheries; as sources of deleterious edge effects; and as access corridors that encourage development, logging and poaching of rare plants and animals.”
"Most public agencies disregard the ecological impacts of roads, and attempt to justify timber roads as benefiting recreation and wildlife management. Even when a land manager recognizes the desirability of closing roads, he or she usually contends that such closures would be unacceptable to the public."
“The Forest Service and other public agencies will claim that road closures, revegetation, and other restorative measures are too expensive to be implemented on a broad scale. But much of the approximately $400 million of taxpayers' money squandered annually by the Forest Service on below-cost timber sales goes to road-building. Road maintenance is also expensive. Virtually all of this money could be channeled into road closures and associated habitat restoration. This work would be labor-intensive, and providing income to the many laid off loggers, timber sale planners, and road engineers -- for noble jobs, rather than jobs of destruction!”
Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the Road to Destruction” Wildlands CPR http://www.wildlandscpr.org/ecological-effects-roads
FS Response: Opinion/news review.
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------Road Construction Opposing View #41 - “Numerous studies have reported lower densities of breeding Ovenbirds (Seiurus aurocapillus) adjacent to forest edges. However, none of these studies has considered habitat use and reproductive success to address mechanisms underlying the observed pattern, and most were conducted in fragmented landscapes and ignored juxtapositions of forest with narrow openings such as roads. We studied the influence of forest roads on Ovenbird density in an extensively forested region of Vermont, evaluating habitat use and reproductive success relative to mechanisms proposed to explain the density-edge relationship. Territory densities on seven study plots were 40% lower within edge areas (0 to 150 m from unpaved roads) than within interior areas (150 to 300 m from roads). We simulated the distribution of Ovenbird territories and concluded that passive displacement, where birds perceive habitat interfaces as boundaries and limit their territories entirely to forest habitat, did not account for the observed density-edge pattern. Territory size was inversely related to distance from roads, providing an alternative explanation for reduced densities near edges and suggesting that habitat quality was higher away from roads. Pairing success was lower within edge areas than within interior zones, but the difference was not statistically significant. The proportion of males that produced fledglings did not differ between edge and interior areas. We conclude that habitat quality for Ovenbirds may be lower within 150 m of unpaved roads in extensive forested landscapes, affecting territory density and possibly reproductive success.”
Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): 937-946. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html
FS Response: Not relevant. No Seiurus aurocapillus within the project or surrounding area.
------Road Construction Opposing View #42 - “Increasingly, previously extensive, continuous tracts of forest are being reduced to widely dispersed patches of remnant forest vegetation by logging and road-building, but few measures of the effects of roads on forest fragmentation are available. Fragmentation affects animal populations in a variety of ways, including decreased species diversity and lower densities of some
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animal species in the resulting smaller patches. This study seeks to quantify the effects of roads and logging activities on forest habitat.”
“Roads precipitate fragmentation by dissecting previously large patches into smaller ones, and in so doing they create edge habitat in patches along both sides of the road, potentially at the expense of interior habitat. As the density of roads in landscapes increases, these effects increase as well. McGurk and Fong (1995) considered the additive effects of clearcuts and roads, but did not measure the amount of associated edge habitat. Thus a more direct measurement of the impacts of roads on landscapes is needed.”
Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution of Roads to Forest Fragmentation in the Rocky Mountains."
Conservation Biology 10: 1098-1106. http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm
FS Response: Relevant. The Flat project will decommission 3.2 miles of road in the proposed action and Alternative 3.
------Road Construction Opposing View #43 - “Erosion on roads is an important source of fine-grained sediment in streams draining logged basins of the Pacific Northwest. Runoff rates and sediment concentrations from 10 road segments subject to a variety of traffic levels were monitored to produce sediment rating curves and unit hydrographs for different use levels and types of surfaces. These relationships are combined with a continuous rainfall record to calculate mean annual sediment yields from road segments of each use level. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface.”
Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Forest
Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. 151
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http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml
FS Response: Relevant and agreed. The Flat project aims to close roads and decommission roads at the conclusion of the project. Effects of roads are addressed.
------Road Construction Opposing View #44 - "Roads are associated with high sediment inputs and altered hydrology, both of which can strongly influence downstream channel habitats. Roads are also important as a source of indirect human impacts and as an agent of vegetation change and wildlife disturbance."
"Any ground disturbance increases the potential for erosion and hydrologic change, and roads are a major source of ground disturbance in wildlands. Compacted road surfaces generate overland flow, and much of this flow often enters the channel system, locally increasing peak flows. Localized peak flows are also increased where roads divert flow from one swale into another, and where roadcuts intercept subsurface flows."
"Overland flow from the road surface is a very effective transport medium for the abundant fine sediments that usually are generated on road surfaces. Road drainage also can excavate gullies and cause landslides downslope in swales. Cut and fill slopes are often susceptible to landsliding, and road-related landsliding is the most visible forestry-related erosional impact in many areas."
Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss 1994. "What do we know about Roads?" USDA Forest Service. http://www.fs.fed.us/psw/publications/reid/4Roads.htm
FS Response: Relevant and agreed. The Flat project aims to close roads and decommission roads at the conclusion of the project. Effects of roads are addressed.
------Road Construction Opposing View #45 - "Disturbances from roadbuilding and logging changed the sediment/discharge relationship of the South Fork from one which was supply
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dependent to one which was stream power dependent, resulting in substantial increases in suspended sediment discharges."
"Road construction and logging appear to have resulted in increases in average turbidity levels (as inferred from suspended sediment increases) above those permitted by Regional Water Quality Regulations."
Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. 1979. "Watershed's Response to Logging and Roads: South Fork of Caspar Creek, California, 1967-1976." USDA Forest Service, Research Paper PSW-146. http://www.fs.fed.us/psw/publications/rice/Rice79.pdf
FS Response: USDA publication. Agreed. Paper discusses specific case.
------Road Construction Opposing View #46 - "Sediment eroded from gravel roads can be a major component of the sediment budget in streams in this region (Van Lear, et al, 1995)."
Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road Erosion, Sediment Transport and Model Validation in the Southern Appalachians." Presented at the Second Federal Interagency Hydrologic Modeling Conference, July 28 – August 1, 2002. http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf
FS Response: USDA Publication. Agreed. Sediment issues will be mitigated in the project.
------Road Construction Opposing View #47 - “Early studies of elk were among the first to address effects of roads on wildlife, establishing a precedent for subsequent research on a wide range of terrestrial and aquatic species. These early elk-roads studies included those reported in a symposium on the topic in 1975 (Hieb 1976), the seminal studies of Jack Lyon in Montana and northern Idaho (Lyon 1979, 1983, 1984), the Montana Cooperative Elk-Logging Study (Lyon et
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al. 1985), and work by Perry and Overly (1977) in Washington and Rost and Bailey (1979) in Colorado.
As research and analysis techniques have become more sophisticated, particularly with the advent of geographic information systems (GIS) and high-resolution remote imagery, the study of effects of roads on terrestrial and aquatic communities has evolved into a unique discipline of “road ecology” (Forman et al. 2003). Road effects are far more pervasive than originally believed and include such disparate consequences as population and habitat fragmentation, accelerated rates of soil erosion, and invasion of exotic plants along roadways. Indeed, “in public wildlands management, road systems are the largest human investment and the feature most damaging to the environment” (Gucinski et al. 2001:7). Summaries of the effects of roads on wildlife habitats and biological systems in general have been compiled by Forman and Alexander (1998), Trombulak and Frissell (2000), Gucinski et al. (2001), Forman et al. (2003) and Gaines et al. (2003).”
Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger
2005. “Effects of Roads on Elk: Implications for Management in
Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor,
The Starkey Project: a synthesis of long-term studies of elk and mule deer
Reprinted from the 2004 Transactions of the North American Wildlife and
Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf
FS Response: USDA publication. Agreed. Project manages for road impacts.
------Road Construction Opposing View #48 - “The consequences of road construction to wildlife are generally negative. Roads result in increased human access, habitat fragmentation, disturbance, and in some cases direct mortality due to vehicle collisions.”
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“Research has documented an 80% decline in grizzly bear habitat use within 1 km of open roads used by motorized vehicles in Montana9. This has been ascribed either to bears avoiding humans or to the selective over-harvest of bears habituated to humans that would otherwise more fully use areas heavily influenced by people.”
Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads”
The Interagency Forest Ecology Study Team (INFEST) newsletter http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm
FS Response: Alaska F&W interagency study. Agreed. Project manages for road impacts.
------Road Construction Opposing View #49 - “The effects of forest roads on hydrology are related to the effects of forest clearing. Most logging requires road access, and the roads often remain after the logging, so there are both short and long-term effects.94 Forest road surfaces are relatively impermeable. Water readily runs over the road surface and associated roadside ditches, often directly to a stream channel, with the net effect of extending channel networks and increasing drainage density.95 In addition to providing conduits for overland flow, forest roads involve slope-cuts and ditching that may intersect the water table and interrupt natural subsurface water movement.96 This diversion of subsurface water may be quantitatively more important than the overland flow of storm water in some watersheds.97 The importance of roads in altering basin hydrology has been underscored in paired-watershed studies and recent modeling studies.98 “ (Pgs. 730 and 731)
Shanley, James B. and BeverleyWemple Ph.D.
“Water Quantity and Quality in the Mountain Environment”
Vermont Law Review, Vol. 26:717, 2002
http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf
FS Response: Relevant and agreed. Project manages for road impacts.
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------Road Construction Opposing View #50 - "Roads are often the major source of soil erosion from forested lands (Patric 1976)."
"Generally, soil loss is greatest during and immediately after construction."
Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in the Southern Appalachian Mountains." Southern Journal of Applied Forestry 8: 209-216. 1984. http://cwt33.ecology.uga.edu/publications/403.pdf
FS Response: Scientific article. Agreed and project manages for road impacts.
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Road Construction Opposing View #51 - “More subtle causes of habitat loss include the construction of roads and power lines. These linear barriers also have been correlated with a decline in neotropical migrant songbirds (Berkey 1993; Boren et al. 1999; Ortega and Capen 2002). Whether by forest conversion or the construction of roads and power lines, fragmentation subdivides habitat into smaller and smaller parcels. The result is an increase of edge habitat, or the boundary between intact forest and surrounding impacted areas. Small forests with large amounts of edge habitat are a hostile landscape for nesting neotropical migratory songbirds. In these areas, songbirds face two great threats: 1) the loss of eggs and nestlings to predators and, 2) parasitism by cowbirds.”
Switalski, Adam “Where Have All the Songbirds Gone? Roads, Fragmentation, and the Decline of Neotropical Migratory Songbirds”
Wildlands CPR, September 8, 2003
http://www.wildlandscpr.org/node/213
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FS Response: Not peer reviewed.
------Road Construction Opposing View #52 - “Roads are a widespread and increasing feature of most landscapes. We reviewed the scientific literature on the ecological effects of roads and found support for the general conclusion that they are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads of all kinds have seven general effects: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans. Road construction kills sessile and slow-moving organisms, injures organisms adjacent to a road, and alters physical conditions beneath a road. Vehicle collisions affect the demography of many species, both vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly successful. Roads alter animal behavior by causing changes in home ranges, movement, reproductive success, escape response, and physiological state. Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all species and ecosystems are equally affected by roads, but overall the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems. More experimental research is needed to complement post-hoc correlative studies. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic biota.”
Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. “Review of
Ecological Effects of Roads on Terrestrial and Aquatic Communities”
Conservation Biology, Volume 14, No. 1, Pages 18–30, February 2000
http://www.transwildalliance.org/resources/200922144524.pdf
FS Response: Agreed. Project address issues related to roads.
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------Road Construction Opposing View #53 - "Roads are a major contributor to habitat fragmentation because they divide large landscapes into smaller patches and convert interior habitat into edge habitat. As additional road construction and timber harvest activities increase habitat fragmentation across large areas, the populations of some species may become isolated, increasing the risk of local extirpations or extinctions (Noss and Cooperrider 1994)."
"Habitat fragmentation creates landscapes made of altered habitats or developed areas fundamentally different from those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994 in Meffe et al. 1997). Adverse effects of habitat fragmentation to both wildlife populations and species include:
"Increased isolation of populations or species, which leads to:
• Adverse genetic effects; i.e. inbreeding depression (depressed fertility and fecundity, increased natal mortality) and decreased genetic diversity from genetic drift and bottlenecks,
• Increased potential for extirpation of localized populations or extinction of narrowly distributed species from catastrophic events such as hurricanes, wildfires or disease outbreaks,
• Changes in habitat vegetative composition, often to weedy and invasive species,
• Changes in the type and quality of the food base,
• Changes in microclimates by altering temperature and moisture regimes,
• Changes in flows of energy and nutrients,
• Changes in the availability of cover and increases edge effect, bringing together species that might otherwise not interact, potentially increasing rates of predation, competition and nest parasitism, and
• Increased opportunities for exploitation by humans, such as poaching or illegal collection for the pet trade."
Watson, Mark L. "Habitat Fragmentation and the Effects of Roads on Wildlife and Habitats." Background and Literature Review 2005. http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/2004EffectsofRoadsonWil dlifeandHabitats.pdf
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FS Response: NM F&W publication. Agreed. The Flat project will decommission 3.2 miles of road in the proposed action and in Alternative 3.
------Road Construction Opposing View #54 - "Our analysis also indicated that >70 percent of the 91 species are affected negatively by one or more factors associated with roads."
"Roads in forested areas increase trapping pressures for martens and fishers, resulting in significantly higher captures in roaded versus unroaded areas (Hodgman and others 1994) and in logged versus unlogged areas, in which the difference was again attributed to higher road densities in logged stands (Thompson 1994). Secondary roads also might increase the likelihood that snags and logs will be removed for fuel wood. This could impact fishers, martens and flammulated owls, and also could have a negative effect on the prey base for goshawks (Reynolds and others 1992)."
"An additional, indirect effect of roads is that road avoidance leads to underutilization of habitats that are otherwise high quality."
Wisdom, Michael J., Richard S. Holthausen Ph.D. Barbara C. Wales Ph.D., Christina D. Hargis Ph.D. Victoria A. Saab Ph.D., Danny C. Lee Ph.D. Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000. http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wisdom_et_al_2000/Vol_2a.pdf
FS Response: USDA publication. Agreed and project manages for impacts from roads and sensitive species.
------Road Construction Opposing View #55 - “According to the DEIS, the Forest now manages a total of 5,914 miles of roads across the Forest. Scientific literature has established that roads have numerous widespread, pervasive and, if left untreated, long-lasting biological and physical
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impacts on aquatic ecosystems that continue long after completion of construction. (Angermeier et al. 2004). Roads increase surface water flow, alter runoff patterns, alter streamflow patterns and hydrology, and increase sedimentation and turbidity. Roads are the main source of sediment to water bodies from forestry operations in the United States. (US EPA 2002). Road construction can lead to slope failures, mass wasting and gully erosion. Road crossings can act as barriers to movement for fish and other aquatic organisms, disrupting migration and reducing population viability. (Schlosser and Angermeier 1995). Chemical pollutants that enter streams via runoff, such as salt and lead from road use and management, compound these impacts. Most of these adverse effects are persistent and will not recover or reverse without human intervention. The techniques for road remediation are well established, agreed upon and readily available. (Weaver et al. 2006).” (Pg. 2)
Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council
Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou
National Forest Travel Management Team
http://www.pacificrivers.org/protection-defense/comment- letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf
FS Response: Opinion letter.
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Road Construction Opposing View #56 - “Fires do not leave a large road network in place (assuming the blaze was not suppressed otherwise there may be dozer lines, etc.). Logging creates roads that fragment habitat and generally increase human access, both of which affect the use of the land by wildlife. Moreover, roads and logging equipment can become vectors for the dispersal of weeds.”
Wuerthner, George 2008 “Ecological Differences
between Logging and Wildfire”
http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html
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FS Response: Opinion blog.
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Road Construction Opposing View #57 - “Forest fragmentation occurs when large, contiguous blocks of forest are broken up into isolated islands by development, roads, or clearing for agriculture. Just as inbreeding among the royal families of Europe spread hemophilia, forest fragmentation negatively impacts the long term sustainability of both plant and animal communities. Geographic isolation results in inbreeding and diminishes biodiversity.”
Zimmerman, E.A. and P.F. Wilbur “A Forest Divided”
New Roxbury Land Trust newsletter, 2004 http://www.ourbetternature.org/forestfrag.htm
FS Response: Opinion. Opposing Views Attachment #11
Caring USFS Officials will Always Take the Most Effective Action Available to Reduce the Risk Of Homes Burning and Loss of Life should a Wildfire Start Near Neighborhoods Located in the Woods
Not Analyzing an Alternative in Detail that Applies Dr. Cohen’s Fine Fuels Removal Methods Discussed below Indicates the Responsible USFS Official Believes Timber Removal resulting from Hazardous
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Fuels Reduction Logging is more Important than Preventing Homes from Burning
Dr. Cohen’s background
Dr. Jack Cohen is a research fire physicist who does his research in the Forest Service's Missoula Fire Sciences Laboratory at the Rocky Mountain Research Station. Dr. Cohen is a Forest Service employee. His research findings clearly show that commercial logging to reduce fuels will not protect homes from wildfire damage in the Wildland Urban Interface (WUI).
Dr. Cohen’s Research Findings Represent Best Science and Empirical Evidence Shows his Fire Damage Risk Reduction Methods that remove the Fine Fuels Near the Home are Far Superior to Hazardous Fuel Removal Dr. Cohen Is likely the only Ph.D. fire physicist in America who specializes in determining the best actions to reduce the risk of wildfire damage to homes. Dr. Cohen is a well published scientist-author. He has published 12 peer-reviewed scientific papers summarizing his research findings. ------
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Independent Sources Emphasize the Effectiveness of Dr. Cohen’s Fire Damage Risk Reduction Methods
“Homeowners are their own first line of defense. Saving a home from wildfire depends primarily on two factors: roofing material and the quality of the “defensible 8 space” surrounding it. Research Physical Scientist Jack Cohen noted after visiting homes that survived the Rodeo-Chediski Fire and those that were consumed, that had homeowners followed guidelines for creating defensible space—described as creating an area around a structure where fuels and vegetation are treated, cleared, or reduced to slow the spread of fire—more homes would have survived.”
Fact Sheet: Understanding Fire and Fire Behavior Ontario Aviation and Forest Fire Management http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf ------Dr. Cohen’s opposing view #1 - “Research results indicate that the home and its immediate surroundings within 100-200 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 http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf ------Dr. Cohen’s opposing view #2 - “A senior physicist at the Stanford Research Institute, C.P. Butler (1974), coined the term "urban-wildland interface" and described this fire problem as follows:
"In its simplest terms, the fire interface is any point where the fuel feeding a wildfire changes from natural (wildland) fuel to man-made (urban) fuel.” (Pg. 1)
Dr. Cohen’s opposing view #3 - “The results of the diverse analytical methods are congruent and consistently indicate that ignitions from flames occur over relatively short
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distances--tens of meters not hundreds of meters. The severe-case estimate of SIAM indicates distances of 40 meters or less. Experimental wood walls did not ignite at 10 meters when exposed to experimental crown fires. And, case studies found that vegetation clearance of at least 10 meters was associated with a high occurrence of home survival.” (Pg. 4)
Dr. Cohen’s opposing view #4 - “Analyses of southern California home losses done by the Stanford Research Institute for the 1961 Belair-Brentwood Fire (Howard and others 1973) and by the University of California, Berkeley, for the 1990 Painted Cave Fire (Foote and Gilless 1996) are consistent with SIAM estimates and the experimental crown fire data. Given nonflammable roofs, Stanford Research Institute (Howard and others 1973) found a 95 percent survival with a clearance of 10 to 18 meters and Foote and Gilless (1996) at Berkeley, found 86 percent home survival with a clearance of 10 meters or more.” (Pgs. 3 and 4)
Dr. Cohen’s opposing view #5 - “Extensive wildland vegetation management does not effectively change home ignitability.” (Pg. 5)
Dr. Cohen’s opposing view #6 - “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.” (Pg. 5)
Dr. Cohen’s opposing view #7 - “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.” (Pg. 5)
Dr. Cohen’s opposing view #8 - “Home ignitability implies that homeowners have the ultimate responsibility for WUI home fire loss potential. As shown, the ignition and flammability characteristics of a structure and its immediate surroundings determine the home fire loss potential. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for WUI home fire loss, is the homeowner's choice and responsibility.” (Pg. 5)
Dr. Cohen’s opposing view #9 - “However, public and management perceptions may impede homeowners from taking principal responsibility. For example, the Federal
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Wildland Fire Management, Policy and Program Review (1995) observes, ‘There is a widespread misconception by elected officials, agency managers, and the public that wildland/urban interface protection is solely a fire service concern.’ In a Journal of Forestry article, Beebe and Omi (1993) concur, stating that, ‘Public reaction to wildfire suggests that many Americans want competent professionals to manage fire flawlessly, reducing the risks to life, property, and public lands to nil.’ These statements agree with Bradshaw's (1988) description of the societal roles in the WUI problem. He observes that homeowners expect that fire protection will be provided by others. Contrary to these expectations for fire protection, the fire services have neither the resources for effectively protecting highly ignitable homes during severe WUI fires, nor the authority to reduce home ignitability.” (Pg. 6)
Source for quotes #2 to #9 above: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf ------Dr. Cohen’s opposing view #10 - “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)
Dr. Cohen’s opposing view #11 - “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-UI fire problem must initially focus on residential fire resistance.” (Pg. 5 – Conclusion)
Dr. Cohen’s opposing view #12 - “Instead of all fire protection responsibilities residing with fire agencies, homeowners take responsibility for assuring firewise conditions and the initial fire defense of their residences during wildland fires. The fire agencies become a community partner that provides information, coordinates and assists in meeting firewise requirements, and provides fire suppression assistance.” (Pg. 5)
Source for quotes #10 to #12 above: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf
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------Dr. Cohen’s opposing view #13 - “My examination suggests that the abundance and ubiquity of pine needles, dead leaves, cured vegetation, flammable shrubs, wood piles, etc. adjacent to, touching and or covering the homes principally contributed to the residential losses.” (Pg. 4)
Source: Examination of the Home Destruction in Los Alamos Associated with the Cerro Grande Fire July 10, 2000 Source: USDA Forest Service, Rocky Mountain Research Station, Missoula, Montana, 2000. http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20copy.pdf ------Dr. Cohen’s opposing view #14 - "The wildland fire management approach for preventing WUI fire disasters largely addresses the wildfire outside the home ignition zone rather than a home's ignition potential as determined by the conditions within the home ignition zone. Since 2000, agency fire management policy initiatives have emphasized fire suppression." (Pg. 24)
Dr. Cohen’s opposing view #15 - "Preventing WUI fire disasters requires that the problem be framed in terms of home ignition potential. Because this principally involves the home ignition zone, and the home ignition zone primarily falls within private ownership, the responsibility for preventing home ignitions largely falls within the authority of the property owner. Preventing wildfire disasters thus means fire agencies helping property owners mitigate the vulnerability of their structures. The continued fire management focus on fire suppression suggests the WUI fire problem persists largely as a consequence of framing the WUI fire problem primarily in terms of the fire exclusion paradigm." (Pg. 25)
Dr. Cohen’s opposing view #16 - "The continued focus on fire suppression largely to the exclusion of alternatives that address home ignition potential suggests a persistent inappropriate framing of the WUI fire problem in terms of the fire exclusion paradigm." (Pg. 25)
Source for quotes #14 to #16 above: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf ------Dr. Cohen’s opposing view #17 - “For the same reason, mitigating home ignition potential during extreme wildland fires must focus activities within and immediate to the residential area, i.e. the home ignition zone. But the home ignition zone largely corresponds to private property. Thus, with minor exception, the authority for effectively reducing the home ignition potential belongs to homeowners. Public land management
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agencies can facilitate homeowner mitigations and these agencies may be able to reduce fire intensities and the extent of burning around communities. But these agencies cannot accomplish the necessary and sufficient actions necessary to prevent residential fire disasters during extreme fire conditions by treating beyond the home ignition zone.” (Pg. 2)
Source: Thoughts on the Wildland-Urban Interface Fire Problem, June 2003 http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf ------Dr. Cohen’s opposing view #18 - “A home with its immediate surroundings (about 100-150 feet from the structure) is called the Home Ignition Zone. Many factors about the HIZ determine the potential for ignition during a wildland fire, such as flammable wood roofs and materials like trees, grass, decks, or adjacent structures leading up to a home.” (Pg. 1)
Source: Saving Homes from Wildfires: Regulating the Home Ignition Zone
Published in Zoning News, May 2001 http://www.battle-creek.net/docs/fire/Zoning.pdf ------Dr. Cohen’s opposing view #19 - “SIAM calculations indicate that large wildland flame fronts (e.g., forest crown fires) will not result in piloted wood ignitions (e.g., the typical variety of exterior wood walls) at distances greater than 40 meters (Cohen and Butler [In press]).” (Pg. 4)
Dr. Cohen’s opposing view #20 - “Field studies conducted during the International Crown Fire Modeling Experiment (Alexander et al. 1998) provided measured data for comparisons with SIAM model estimates. Total heat transfer (radiation and convection) and ignition data were obtained from heat flux sensors placed in wooden wall sections. The instrumented walls were located on flat, cleared terrain at 10, 20, and 30 meters downwind from the edge of the forested plots. The forest was variably composed of an overstory of jack pine (Pinus banksiana) about 13 meters high with an understory of
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black spruce (Picea mariana). The spreading crown fire produced flames approximately 20 meters high.” (Pg. 5)
Dr. Cohen’s opposing view #21 - “Five burns were conducted where wall sections were exposed to a spreading crown fire. As the crown fires reached the downwind edge of the plot, turbulent flames extended into the clearing beyond the forest edge. In two of the five burns, flames extended beyond 10 meters to make contact with the wall section placed at 10 meters from the forest edge. When flame contact occurred, the walls ignited; however, without flame contact, only scorch occurred. The wooden panels at 20 and 30 meters never ignited and the panel at 30 meters never scorched.” (Pg. 6)
Dr. Cohen’s opposing view #22 - “Case studies of actual W-UI fires provide an independent comparison with SIAM and the crown fire experiments. The actual fires incorporate a wide range of fire exposures. The case studies chosen examine significant factors related to home survival for two fires that destroyed hundreds of homes. The Bel Air fire resulted in 484 homes destroyed (Howard et al. 1973) and the Painted Cave fire destroyed 479 homes (Foote 1994). Analyses of both fires indicate that home ignitions depend on the characteristics of a home and its immediate surroundings. Howard et al. (1973) observed 95 percent survival for homes with nonflammable roofs and a vegetation clearance of 10 to 18 meters. Foote (1994) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 7)
Dr. Cohen’s opposing view #23 - “The high survival rate for homes with nonflammable roofs and 10-20 meter vegetation clearances included firebrands as an ignition factor, thus indicating that firebrand ignitions also depend on the ignition characteristics of the home and the adjacent flammable materials.” (Pg. 8)
Dr. Cohen’s opposing view #24 - “Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-UI fire loss problem.” (Pg. 9)
Dr. Cohen’s opposing view #25 - “Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction.” (Pg. 10)
Dr. Cohen’s opposing view #26 - “Fire losses depend on home ignitions and home ignitions depend on home ignitability. Thus, home ignitability, being limited to a home and its immediate surroundings, offers us the opportunity to separate the W-UI structure fire loss problem from other landscape-scale fire management issues. This conclusion
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Dr. Cohen’s opposing view #27 - “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)
Dr. Cohen’s opposing view #28 - “The extent of the home ignition zone corresponds more to specific home and community ownership than to the landscapes of federal, state and local land management agencies. This suggests a corresponding responsibility for W-UI home fire loss potential residing with homeowners and communities. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for W-UI home fire loss, is a homeowner and community choice and responsibility.” (Pg. 11)
Source for quotes #19 to #28 above: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf ------Dr. Cohen’s opposing view #29 - “Model results indicate that ignitions from flame radiation are unlikely to occur from burning vegetation beyond 40 meters of a structure. Thinning vegetation within 40 meters has a significant ignition mitigation effect.” (Pg. 81)
Dr. Cohen’s opposing view #30 - “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 for quotes #29 and #30 above: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management
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Presented at the 13th Fire and Forest Meteorology Conference. Lorne, Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf ------Dr. Cohen’s opposing view #31 - “Miracles aside, the characteristics of the surviving home and its immediate surroundings greatly influenced its survival.” (Pg. 15)
Dr. Cohen’s opposing view #32 - “Based on severe-case assumptions of flame radiation and exposure time, SIAM calculations indicate that wild-land flame fronts comparable to crowning and torching trees (flames 20 meters high and 50 meters wide) will not ignite wood surfaces at distances greater than 40 meters (Cohen and Butler, in press). Figure 2 shows the radiant heat a wall would receive from flames depending on its distance from the fire. The incident radiant heat flux, defined as the rate of radiant energy per unit area received at an exposed surface, decreases as the distance increases.” (Pg. 17)
Dr. Cohen’s opposing view #33 - “Analyses of both fires indicate that home ignitions depend on the characteristics of a structure and its immediate surroundings. Howard et al. (1973) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 19)
Dr. Cohen’s opposing view #34 - “Using the model results as guidance with the concurrence of experiments and case studies, we can conclude that home ignitions are not likely unless flames and firebrand ignitions occur within 40 meters of the structure. This finding indicates that the spatial scale determining home ignitions corresponds more to specific home and community sites than to the landscape scales of wildland fire management. Thus, the W-UI fire loss problem primarily depends on the home and its immediate site.” (Pg.20)
Dr. Cohen’s opposing view #35 - “Thus, the W-UI fire loss problem can be defined as a home ignitability issue largely independent of wildland fuel management issues. This conclusion has significant implications for the actions and responsibilities of homeowners
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and fire agencies, such as defining and locating potential W-UI fire problems (for example, hazard assessment and mapping), identifying appropriate mitigating actions, and determining who must take responsibility for home ignitability.” (Pg.20)
Dr. Cohen’s opposing view #36 - “The W-UI fire case studies indicated approximately 90 percent survival with a vegetation clearance on the order of 10 to 20 meters for homes with nonflammable roofs. Thus, the case studies support the general flame-to-structure distance range of 10 to 40 meters as found through modeling and experiments.” (Pg.20)
Dr. Cohen’s opposing view #37 - “A change needs to take place in the relationship between homeowners and the fire services. Instead of home-related presuppression and fire protection responsibilities residing solely with fire agencies, homeowners must take the principal responsibility for ensuring adequately low home ignitability.” (Pg.21)
Source for quotes #31 to #37 above: Preventing Disaster Home ignitability in the Wildland-Urban Interface
Published in the Journal of Forestry 98(3): 15-21, 2000
http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf ------Dr. Cohen’s opposing view #38 - “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)
Dr. Cohen’s opposing view #39 - “Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ‘‘fire-proof’’ important areas. It would be virtually impossible to exclude fire from most temperate terrestrial
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Dr. Cohen’s opposing view #40 - “Treating fuels to facilitate suppression is an example in circular logic. If fuel treatment makes suppression more successful in general, then less area will be burned in the short run and more acreage will tend to burn under extreme conditions, when suppression is ineffective. The inevitable result is that more area is burned in fewer, more unmanageable events with greater consequences. In addition, fire suppression leads to continued fuel accumulation and, in turn, more difficult conditions for suppression. This phenomenon has been described as ‘‘the wildland fire paradox’’ (Brown and Arno, 1991). Rather than creating conditions where fire is easier to suppress, fuel treatments should strive to create conditions where fire can occur without the need for suppression.” (Pg.1998)
Dr. Cohen’s opposing view #41 - “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)
Dr. Cohen’s opposing view #42 - “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999)
Dr. Cohen’s opposing view #43 - “Since the home ignition zone largely occurs on private lands, most land management agencies do not have the authority to mitigate the WUI ignition potential directly (Cohen, 2000b). However, the opportunity exists to explicitly define responsibilities for the WUI fire potential (i.e. the home ignition zone) consistent with areas of jurisdiction and separately from ecological wildfire issues.” (Pg.1999)
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Dr. Cohen’s opposing view #44 - “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)
Dr. Cohen’s opposing view #45 - “WUI fuel treatments can be designed such that an extreme wildfire can occur in the WUI without having a residential fire disaster. Although general wildfire control efforts may not benefit from fuel treatments during extreme fire behavior, fuel modifications can significantly change outcome of a wildfire within a treatment area. Research has shown that a home’s characteristics and its immediate surroundings principally determine the WUI ignition potential during extreme wildfire behavior (Cohen, 2000a,c, 2003, 2004). The area that primarily determines WUI ignition potential is called the home ignition zone (Cohen, 2001). WUI fuel treatments can address the home ignition zone by removing flammable materials immediately adjacent to residences.” )Pg. 1999)
Dr. Cohen’s opposing view #46 - “Treating fuels may not reduce suppression expenditures. It is a natural mistake to assume that a successful fuel treatment program will result in reduced suppression expenditures. Suppression expenditures rarely depend directly on fuel conditions, but rather on fire location and on what resources are allocated to suppression. The only certain way to reduce suppression expenditures is to make a decision to spend less money suppressing fires.” (Pg. 2000)
Dr. Cohen’s opposing view #47 - “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 al., 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)
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Dr. Cohen’s opposing view #48 - “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)
Dr. Cohen’s opposing view #49 - “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 et al., 2004; Kauffman, 2004).” (Pg.2000)
Dr. Cohen’s opposing view #50 - “Conversely, some fuel treatments can reduce fuels but create stands that are quite dissimilar from their historical analogs. Examples include mastication treatments that break, chip, or grind canopy and surface woody material into a compressed fuelbed and thinning treatments that remove the fire adapted species and leave shade-tolerant, late successional species.” (Pg.2000)
Source for quotes #38 to #50 above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States
Published in Forest Ecology and Management 256, 2008
http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf
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------
Concluding Comments
Nearly all Forest Service projects that claim to lessen the risks to homeowners living in the WUI propose to reduce hazardous fuels. The NEPA documents that analyze these fuels reduction treatments conveniently do not mention Dr. Cohen’s methods because the Purpose & Need is to reduce fuels … not (emphasis added) to protect homeowners as it should be.
Reducing hazardous fuels is an alternative way to lessen the risks to homeowners living in the WUI. It is definitely not a goal or objective unto itself and should never appear in the Purpose & Need.
However there is a reason most USFS line-officers deal with WUI risks this way. They know hazardous fuels reduction treatments include the logging of merchantable trees which produces volume and helps them meet their supervisor’s volume expectations and spends the allocated “timer” money each FY.
Line-Officers who propose hazardous fuels reduction projects are clearly more interested in accumulating volume than they are protecting the public in the WUI.
There are laws that prohibit such actions by a public servant whose salary is partially paid by the families living in the WUI.
FS Response: The purposes for the Flat project are: • Improve vegetation resilience and resistance to insects, disease and wildfire • Increase the diversity and structure of forest vegetation communities
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• Improve meadow, aspen, riparian habitats, and overall watershed condition • Enhance sagebrush steppe habitats and upland shrubs • Promote low severity fire on the landscape as a natural disturbance regime • Reduce road related impacts to the watershed (terrestrial and aquatic habitat, and water quality) • Capture the economic value of harvested timber Nowhere is the purpose to reduce hazardous fuels. All good information for protecting structures in the WUI. Opposing Views Attachment #1
This document contains quotes authored by Ph.D. scientists who are world-class experts in forest ecology. Their statements describe how logging activities harm recreation opportunities and many natural resources in the forest ------Timber Harvest Opposing View #1 - The following document contains pertinent color pictures showing logging damage, thus the article text is not shown here. Please use the link below to access the article.
Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and Implications” Clearcuts and forest fragmentation, Willamette NF, Oregon. From: Cascadia Wildland Project, Spring 2003 http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pdf
FS Response: Not peer reviewed, Cascadia Wildland Project publication, Flat project does not have the described ‘fragmentation’.
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------Timber Harvest Opposing View #2 - “Timber harvest operations have been shown to have many effects on adjacent watercourses and on the aquatic ecosystems they support. This may occur from introductions or loss of woody debris, loss of riparian vegetation, accelerated stream bank and bed erosion, the alteration of natural channel form and process, and the reduction of stream habitat diversity. However, the existing literature indicates one of the most insidious effects of logging is the elevation of sediment loads and increased sedimentation within the drainage basin.
Sediment generation from various forestry practices has been studied extensively in the past. Forestry practices which generate suspended sediments include all operations that disturb soil surfaces such as site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road construction and maintenance.”
Anderson, P.G. 1996. “Sediment generation from forestry operations and associated effects on aquatic ecosystems” Proceedings of the Forest-Fish Conference: Land Management Practices
Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta. http://www.alliance-pipeline.com/contentfiles/45____Sediment_generation.pdf
FS Response: Opinion and proceeding. The EA, discloses the effects to aquatics (pages 3-137 to 3-158), and watershed and soils (pages 3-159 to 3-188).
------Timber Harvest Opposing View #3 - “Timber harvest will remove dead and dying material from the site and inhibit the recruitment of downed woody material as time progresses. Timber harvest and associated reduced structural complexity and reduced age and size class diversity are all known to reduce population abundance and diversity of ants and a number of birds. For instance, ants are documented to require downed woody material in a variety of sizes and in all stages of decomposition (Torgersen and
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Bull, 1995). This is an attribute that is negatively correlated with harvest of the dead and dying trees and positively correlated with natural succession, especially after disturbance. Ants and birds are known to predate on insect species which cause mortality to trees, serving as a potentially important population control in the case of epidemics or before they occur (Campbell, Torgersen and Srivastava, 1983). Structural and functional characteristics associated with unlogged forests are also important for canopy arthropods, which play an important role in regulating pest outbreaks (Schowalter, 1989).
Structural complexity, functional diversity, diversity of ecological process and diversity of structure in roadless areas are all expected to be less susceptible to the outbreak of pests and regulate insect activity in surrounding homogenized forests (Schowalter and Means, 1989; Franklin, Perry, Schowalter, Harmon, McKee and Spies, 1989).
A large body of scientific evidence also indicates that increased edge effect and increased sunlight into stands, resulting from reduced canopy cover associated with timber harvest, can directly promote the population abundance, productivity and persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989).”
“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf
FS Response: Taken out of context. The EA, page 2-3 states “No down wood or snags would be removed as biomass”. Effects to down wood and snags are discussed in the EA on pages 3-86 to 3-95. ------Timber Harvest Opposing View #4 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.”
Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires”
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Published by the Portland Independent Media Center, August 2002.
http://portland.indymedia.org/en/2002/08/17464.shtml
FS Response: Opinion. ------Timber Harvest Opposing View #5 - “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.”
“Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ "
“But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.”
Barry, John Byrne. “Stop the Logging, Start the Restoration” from The Planet newsletter June 1999, Volume 6, Number 5 http://vault.sierraclub.org/planet/199905/ecl1.asp
FS Response: Opinion. ------179
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Timber Harvest Opposing View #6 - “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.
After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that ’immediate corrective action is needed.’
A new report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out.
The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.”
Cushman, John H. Jr. “Audit Faults Forest Service on Logging Damage in U.S. Forests” New York Times, February 5, 1999 http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A35751C0A96F958260&sec=&spon=&page wanted=print
http://www.ncpa.org/sub/dpd/index.php?Article_ID=12468
FS Response: Taken out of context. Particular to 12 specific timber sales from 1995-1998.
------Timber Harvest Opposing View #7 – “Logging on national forest land creates more economic harm than good, according to a recent study by the National Forest Protection Alliance and the Forest Conservation Council.
The 75-page report, three years in the making, notes there are dramatic economic and social losses when forests are logged under the U.S. Forest Service's timber-sale program.
The report, "The Economic Case Against Logging National Forests," states that national forest lands are far more valuable to rural communities when trees are left standing, and that the federal logging program creates billions of dollars in unaccounted costs for communities, businesses, and individuals. This expense comes in addition to timber industry subsidies, which cost American taxpayers approximately $1.2 billion a year.”
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“Talberth said both reports lend support to current efforts in Congress to end the federal timber- sale program. Introduced by Rep. Cynthia McKinney (D-Georgia) in April 1999, the National Forest Protection and Restoration Act (H.R. 1396) would put an end the federal timber-sale program.”
Higgins, Margot, “National forest logging is bad business, study says” Posted on CNN.com-Nature, March 16, 2000 http://www.colorado.edu/AmStudies/lewis/west/costlogging.pdf
FS Response: Link does not work. Opinion.
------Timber Harvest Opposing View #8 - “I recently read a letter from a line officer who chided local managers for being behind schedule relative to meeting the region’s ‘timber targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.”
“We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.”
"Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations."
Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to all USFS employees on July 1, 1998 http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.html
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FS Response: Opinion, communication between employees.
------Timber Harvest Opposing View #9 - “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.”
“The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.”
Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Scientists Seek Logging Ban on U.S.-Owned Land” New York Times, April 15, 2002 http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm
FS Response: Opinion, letter written to President.
------Timber Harvest Opposing View #10 - “The Bush administration has announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large- diameter trees that they can sell, rather than just the small trees and brush that can make fires
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more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.”
“Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm
FS Response: Opinion.
------Timber Harvest Opposing View #11 - "The proposition that forest values are protected with more, rather than less logging, and that forest reserves are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base. (page 2)"
"On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they reduce traditional sources of timber income. (page 2)"
Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." http://www.coastrange.org/documents/forestreport.pdf
FS Response: Agreed, the Flat project does not solely consider economically desirable harvests. Qualified Scientific Panel, not published document.
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------Timber Harvest Opposing View #12 - “Consequently, we specifically criticize the “simplified structure-based management” approaches derived from simple structural models and traditional silvicultural systems such as clearcutting. In our view, the assumptions underpinning simplified structure-based management (SSBM) are not supported by the published scientific literature on structural development of natural forests, disturbance ecology, landscape ecology and conservation biology, or by the relationships between ecosystem structures and processes. In this report, we review scientific findings associated with each of these areas with particular attention to the over-simplified structural models associated with SSBM and the importance and viability of forest reserves to achieve various ecological goals. (page 2)
“We do not believe, however, that scientific literature or forestry experience supports the notions that intensively managed forests can duplicate the role of natural forests, or that sufficient knowledge and ability exist to create even an approximation of a natural old-growth forest stand.” (page 3)
Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 2007. “Forging a Science-Based National Forest Fire Policy.” Issues in Science and Technology. A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf
FS Response: Relevant, we are using science outlined in paper.
------Timber Harvest Opposing View #13 - “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.”
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“According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’”
Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style:
Cut Down the Trees!” Environmental News Service, 2008.
www.ens-newswire.com/ens/aug2002/2002-08-23g.asp
FS Response: Opinion.
------Timber Harvest Opposing View #14 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."
"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."
Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf
FS Response: Government publication. Quotes from article NOT relevant due to publication date (1999). Forest management policies have changed.
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------Timber Harvest Opposing View #15 - “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs, logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred during the decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partially created by past timber sales.”
“A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)”
“One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed. (10)”
Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems.” A Congressional Research Service (CRS) report, October 30, 1995. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215
FS Response: Not peer reviewed, letter to Congress. Quotes are not relevant to current Forest management policies.
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------Timber Harvest Opposing View #16 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “
“As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high- value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).”
“The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.”
“After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire- resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.”
Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://yeoldeconsciousnessshoppe.com/art6.html
FS Response: Taken out of context, this report refers to clearcuts.
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------Timber Harvest Opposing View #17 - "But all of these benefits are harmed by one activity— commercial logging on national forests through the Forest Service’s timber sale program, in which private timber companies pay the Forest Service to be allowed to cut down trees on public land.”
“In other words, the timber sales program functions as a particularly destructive form of government subsidy to private logging companies. This subsidy is so large that if the government ended the Forest Service timber sales program, a portion of the money saved could be used employ every timber worker that is currently involved in cutting down national forests to instead work on ecological restoration, repairing the damage that has been done to our forests, and there would still be millions of dollars remaining in taxpayers savings.”
Hanson, Chad, Ph.D. “National Forest Protection” Environment Now (see picture on last page) http://www.environmentnow.org/forest.html
FS Response: Opinion. ------Timber Harvest Opposing View #18 - “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing wildland fires …”
Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and Forest Fires.” Guest Commentary in New West, July 11, 2008 http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest_fires/C41/L41/
FS Response: Opinion, taken out of context.
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------Timber Harvest Opposing View #19 - "Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes."
Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in Western Montana” Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-398(6) http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsessionid=l2sdf2hphia2.alexand ra
FS Response: Scientific article, not relevant due to date published (1976) and study location.
------Timber Harvest Opposing View #20 - "For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do."
Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public." Evergreen magazine, October 1997. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public-v2.html
FS Response: Opinion.
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------Timber Harvest Opposing View #21 - "SEC. 3. FINDINGS.
Congress finds the following:
Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries."
H. R. 1494 text. April 4, 2001 http://www.gpo.gov/fdsys/pkg/BILLS-107hr1494ih/content-detail.html
FS Response: Congressional Session, not scientific research article. Flat project uses management techniques to mitigate the indirect costs.
------Timber Harvest Opposing View #22 - "Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences."
Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Biodiversity Sustains Us” from his book review of The Work of Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997 Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 http://www.mikehudak.com/Articles/FromPrairieDogs9902.html
FS Response: Opinion, published in newsletter.
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------Timber Harvest Opposing View #23 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9)
“As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.”
Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D.
Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D.
Everett, Richard L. Ph.D. 1995. “Historical and current forest
landscapes in eastern Oregon and Washington. Part II: Linking
vegetation characteristics to potential fire behavior and related
smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA
Forest Service, Pacific Northwest Research Station.
https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessionid=C8DDB611DB29D 3716BBF313AADBA2E70?sequence=1
FS Response: Report reflects outdated science. Stated finding are well-known by our fuels managers and are the reason that we treat activity-generated fuels as a connected action.
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------Timber Harvest Opposing View #24 - "The Quincy Library Group's (QLG's) fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review."
"The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management expertise."
"In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects."
"Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires."
"And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution."
"The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of 'cut and run' logging, many of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets … a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs."
Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan." Unpublished research paper. 1997. http://www.fire-ecology.org/research/logging-for-firefighting_2.htm
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FS Response: Not published research. Content outdated and not relevant to the Flat project.
------Timber Harvest Opposing View #25 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.”
“How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.”
Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm
FS Response: Opinion paper – not a fire scientist.
------
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Flat Project Comment Analysis
Timber Harvest Opposing View #26 - "Since the 'New Perspectives' program of the early 1990s, the agency has tried to dodge public opposition to commercial logging by using various euphemisms, such as this gem from the Siskiyou National Forest: Clearcuts are called 'minimum green tree retention units.' Accordingly, Forest Service managers have believed that if they simply refer to logging as 'thinning,' or add the phrases 'fuels reduction' or 'forest restoration' to the title of their timber sale plans, then the public will accept these projects at face value, and business-as-usual commercial logging can proceed. In the face of multiple scandals and widespread public skepticism of the Forest Service's credibility, it seems that only Congress is buying the agency's labeling scheme."
Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to Wildfires” published in the Portland Oregonian, August 6, 2002 http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.html
FS Response: Opinion, newspaper article. Not a fire scientist.
------Timber Harvest Opposing View #27 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5)
Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://www.fire-ecology.org/research/wildfire_paradox.pdf
FS Response: Opinion paper, not peer-reviewed science. Not a fire scientist.
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Flat Project Comment Analysis
Timber Harvest Opposing View #28 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards."
"Decades of encouraging private logging companies to take the biggest, oldest, most fire- resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands."
"In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks."
Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html
FS Response: Opinion, newspaper article. Not a fire scientist.
------Timber Harvest Opposing View #29 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire- resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.”
“Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer
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needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.”
Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm
FS Response: Opinion, newspaper article. Many practices described in quotes are not used on the Malheur National Forest.
------Timber Harvest Opposing View #30 - “Linear developments may result in habitat avoidance for grizzly bears. Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non- hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.”
“The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.”
Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of Linear Developments on Wildlife: A Review of Selected Scientific Literature.” Prepared for Canadian Association of Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. http://www.arlis.org/docs/vol1/A/65937142.pdf
FS Response: Not scientific article. Issues around mentioned species are being managed in the Flat project.
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------Timber Harvest Opposing View #31 - “History, not science, refutes the claim that logging helps to prevent forest fires.
The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests.
Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot.
More logging will not fix this.”
Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.thefreelibrary.com/Logging+does+not+prevent+wildfires.-a0192070397
FS Response: Opinion – guest editorial comment in a newspaper.
------Timber Harvest Opposing View #32 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds.
Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?”
Keene, Roy Restorative Logging? “More rarity than reality”
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Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html
FS Response: Opinion – guest editorial comment in a newspaper.
------Timber Harvest Opposing View #33 - "Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low-ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest."
Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata "Effects of Human-Induced Changes on Hydrologic Systems." An American Water Resources Association publication, June 1994 http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF
FS Response: Relevant article. The Flat project recognizes potential effects on soil and manages for them. Most soil damaging operations are minimized. See the Design Criteria in the EA, pages 2-22 to 2-25.
------Timber Harvest Opposing View #34 - "Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)."
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"Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain."
"Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources less than four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools."
Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest. http://www.nd.edu/~underc/east/education/documents/AKlein2004Pre- loggingsurveyofamphibianlarvaeinvernalpools.pdf
FS Response: Not peer reviewed, thesis work. Sensitive species are managed for in the Flat project.
------Timber Harvest Opposing View #35 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.”
“Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.”
Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior
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Flat Project Comment Analysis
“A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. https://www.frames.gov/rcs/6000/6269.html
FS Response: CRS report pertained to plantations, not thinning projects. CRS concerns also emphasized the need to treat activity fuels, which the Flat project proposes.
------Timber Harvest Opposing View #36 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.”
“How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.”
Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp
FS Response: Science in this testimony is dated. Current thinking refutes many of these claims, which are exaggerated. Mr. Lawrence is not a fire scientist.
------Timber Harvest Opposing View #37 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine
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Flat Project Comment Analysis
needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground.
Leitner, Brian. “Logging Companies are Responsible for the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html
FS Response: Opinion.
------Timber Harvest Opposing View #38 - "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11)
Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf
FS Response: USDA report. Quote taken out of context. Any timber sales related to the Flat project have other land management objectives.
------Timber Harvest Opposing View #39 - “In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.”
Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998 http://www.sciencemag.org/content/283/5410/1996.summary
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FS Response: News focus piece, not peer reviewed. Forest manages for ecological sustainability.
------Timber Harvest Opposing View #40 - "Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system."
Maser, C. Ph.D., and J. M. Trappe Ph.D. “The Seen and Unseen World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW-164 http://www.fs.fed.us/pnw/publications/pnw_gtr164/
FS Response: USDA publication. Agree with quote. The Flat project manages for sensitive species, recognizing all components of the ecological system are important.
------Timber Harvest Opposing View #41 - "Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5)
"Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44)
Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA Forest Service, GTR-PNW-GTR-229 http://www.fs.fed.us/pnw/publications/pnw_gtr229/
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FS Response: Outdated publication. Forest no longer uses described logging practices.
------Timber Harvest Opposing View #42 - "In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by:
a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.”
McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of eastside ecosystems: changes in fish habitat over 50 years, 1935-1992.” 1994 GTR-321 93-181 http://www.fs.fed.us/pnw/publications/pnw_gtr321/
FS Response: USDA publication. No longer relevant to current FS practices. The Flat project minimizes habitat loss and damages to the ecosystem.
------Timber Harvest Opposing View #43 - “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams.
The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in
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surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution of fishes, reduction in fish numbers, and reduction in total biomass.”
Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of
Logging on the Aquatic Resources of Three Headwater Streams of the Alsea River, Oregon – Part III.” Fishery Report Number 9
Oregon Department of Fish and Wildlife. http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf
FS Response: State Department of Fish and Wildlife publication outdated. FS practices have changed and all effects on biological components of streams are managed and monitored.
------Timber Harvest Opposing View #44 - "Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling."
"All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in functioning can be particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations."
"Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levels typical of managed ecosystems."
Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining Natural Life Support Processes." Issues in Ecology No. 4. Fall 1999. http://cfpub.epa.gov/watertrain/pdf/issue4.pdf
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FS Response: Report not scientific research. Relevant information, the Flat project manages for biodiversity and total ecological function. ------Timber Harvest Opposing View #45 - "As a result of the Forest Service's well-documented mismanagement over many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry."
Nappier, Sharon. Lost in the Forest: How the Forest Service's Misdirection, Mismanagement, and Mischief Squanders Your Tax Dollars. Taxpayers for Common Sense, 2002. http://www.ourforests.org/fact/lostintheforest.pdf
FS Response: Opinion.
------Timber Harvest Opposing View #46 - "Agroforestry does reduce biodiversity. In forests used for logging, whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and catchment purposes. Management strategies for sustainable forestry are being developed, but there is a need for further interaction among foresters, ecologists, community representatives, social scientists, and economists."
Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human-Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997. http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow=&HITS=10&hits=10&RESULTFORMAT= &fulltext=logging&searchid=1136659907310_5043&FIRSTINDEX=0&journalcode=sci
FS Response: Agreed. Accurate article but current management practices on the Forests use an interactive approach for ecologically sustainable forestry.
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------Timber Harvest Opposing View #47 - "The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees."
"The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non-material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning."
"The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed."
"For example:
• 82 percent wanted to ban clearcutting, • 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining undisturbed forest; and • 72 percent urged prohibition of logging if bear or other wildlife habitat would be harmed."
"Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more important than protection of endangered species."
"'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'."
Northup, Jim. 1999. "Public Wants More Wilderness, Less Logging on Green Mountain NF". Press Release by Forest Watch, a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10
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FS Response: Opinion.
------Timber Harvest Opposing View #48 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk."
“Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.”
Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://motherjones.com/politics/2002/08/fight-fire-logging
FS Response: Opinion piece. Not written by fire scientists.
------Timber Harvest Opposing View #49 - “In response to catastrophic wildfires, wide- reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore
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historic forest structure in those forest types that are outside of their historic range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then aggregated by land management classes.
Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations.
Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.”
Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are
Wildfire Mitigation and Restoration of Historic Forest Structure Compatible?
A Spatial Modeling Assessment” Published Online: by the by Association
of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001
FS Response: Peer reviewed article but NOT relevant to the Flat project. Research article only discusses Forests in Boulder County, Colorado.
------Timber Harvest Opposing View #50 - "Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands."
Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of the United States." USDA Forest Service. Rocky Mt. Forest and Range Experiment Station.
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Gen. Tech. Rep. RM-234. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html
FS Response: USDA report. Quote generalizes all areas of the Forest Service and is taken out of context.
------Timber Harvest Opposing View #52 - “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades.
We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems.
The Act to Save America's Forests will:
• Make the preservation and restoration of native biodiversity the central mission of Federal forest management agencies.
• Ban extractive logging in core areas of biodiversity and the last remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value.
• Protect sensitive riparian areas and watershed values by banning extractive logging in streamside buffer zones.
• End clearcutting and other even age logging practices on federal land.
• Establish a panel of scientists to provide guidance to federal forest management.
We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery into the 21st century and beyond.”
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Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Ph. D. and over 600 other leading biologists, ecologists, foresters, and scientists from other forest specialties. From a 1998 letter to congress. http://www.saveamericasforests.org/resources/Scientists.htm
FS Response: Opinion letter addressing outdated practices.
------Timber Harvest Opposing View #53 - “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologically-sound plan for protecting and restoring the entire federal forest system.
If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.”
Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Carnahan http://www.saveamericasforests.org/Raven.htm
FS Response: Opinion letter. The Flat project does not jeopardize “America’s ancient and roadless wild forests”.
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------Timber Harvest Opposing View #54 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).”
Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf
FS Response: Comment letter, opinion. The Flat project will plan to reduce fuel loading and certain fire risks.
------Timber Harvest Opposing View #55 - “I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect this threatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.”
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“Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In my experience the most pervasive and severe impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasive changes due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.”
Roelofs, Terry D. Ph.D. Testimony for the California State Water Board and Regional Water Quality Control Boards Regarding Waivers of Waste Discharge Requirements on Timber Harvest Plans. August 2003. http://www.docstoc.com/docs/20957789/EXPERT-WITNESS-REPORT-OF-TERRY-D
FS Response: Not peer reviewed document. Stream health and habitat will be managed for in the Flat project. ------Timber Harvest Opposing View #56 - “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, protective strategies made up 76 percent of the preferred management strategies and commodity-based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.”
Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural Development Perspectives, vol. 14, no. 2 http://www.colorado.edu/AmStudies/lewis/west/amenities.pdf
FS Response: Non-technical article. The Flat project manages for watershed and ecosystem protection.
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------Timber Harvest Opposing View #57 - “Once clear-cutting has occurred, regulation and human silvicultural practices become responsible for the revegetation that follows. The creation of new forest succession patterns are the result of human control over the growing environment. Rather than proceeding at a natural pace, humans attempt to speed up the forest succession process to quickly return to a situation where harvesting is again possible. Reforestation of the disturbed area after clear-cutting also emphasizes maintaining control over the distribution and quality of forest species.
Simplification is a state that results from the forest being harvested before it reaches maturity. Logging simplifies forest ecosystems (Dudley et al 1995) by narrowing the age range of the stand and suppressing diversification through repeated harvesting, burning to remove slash, and replanting with hybrid seedlings. Simplification affects the health and productivity of the forest because simplified forests lack the variety found in older stands, including species diversity, vertical structure, and microhabitat. From an ecological standpoint, a simplified forest of a particular age has less overall bio-mass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of merchantable timber.
Scott, Mark G.
“Forest Clearing in the Gray’s River Watershed 1905-1996” A research paper submitted in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE in GEOGRAPHY Portland State University, 2001 http://www.markscott.biz/papers/grays/chapter1.htm
FS Response: Thesis paper, not published/peer reviewed. Paper not relevant to current Forest practices.
------Timber Harvest Opposing View #58 - “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest
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Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.”
Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D.
"Physicians of the Forest": A Rhetorical Critique of the
Bush Healthy Forest Initiative”
Electronic Green Journal, Issue #19, December 2003 http://escholarship.org/uc/item/4288f8j5
FS Response: Opinion.
------Timber Harvest Opposing View #59 - “Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact, the justification for the Weeks Act in 1911 which established national forests in the east, was watershed protection.
(A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.)
“Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, as well as homes for a myriad of plants and wildlife that can live nowhere else.”
Sierra Club. 2005 “Ending Commercial Logging on Public Lands” http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html
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FS Response: Opinion/comment letter.
------Timber Harvest Opposing View #60 - “Timber harvesting in British Columbia influences (a) forest hydrology; (b) fluvial geomorphology; (c) terrain stability; and (d) integrated watershed behavior. Impacts on forest hydrology are well understood and include increased average runoff, total water yield, increased storm runoff and advances in timing of floods. Stream channels and valley floors are impacted differently by fine sediment, coarse sediment and large woody debris transport. Terrain stability is influenced through gully and mass movement processes that are accelerated by timber harvesting. Impacts on integrated watershed behavior are assessed through disturbed sediment budgets and lake sediments.”
Slaymaker, Olav Ph.D. “Assessment of the Geomorphic
Impacts of Forestry in British Columbia”
AMBIO: A Journal of the Human Environment 29(7):381-387. 2000 http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381
FS Response: Research article. NOT relevant to the Flat project. Research references B.C.
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Timber Harvest Opposing View #61 - “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and communities.”
“Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.”
Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to
Central Oregon Communities and the Surrounding Environment.”
Testimony before the House Committee on Resources, August 25, 2003
http://www.propertyrightsresearch.org/2004/articles6/testimony_of_andy_stahl.htm
FS Response: Testimony and opinion.
------Timber Harvest Opposing View #62 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.
The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity. Logging, especially clear cutting, can change the fire climate so that fires start more easily, spread faster, further, and burn
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As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make more money from our losses. Just like big tobacco.”
Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm
FS Response: Opinion article.
------Timber Harvest Opposing View #63 - “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotes nearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1)
“Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9)
“Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19)
“Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach
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the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20)
“Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20)
Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000 http://www.taxpayer.net/library/article/from-the-ashes
FS Response: Not peer reviewed document. Not relevant to the Flat project.
------Timber Harvest Opposing View #64 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.”
Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php
FS Response: Opinion of a reporter – not peer-reviewed science. Mistakes science findings.
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Timber Harvest Opposing View #65 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62)
University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://www.alibris.com/Sierra-Nevada-Ecosystem-Project-Final-Report-to-Congress-Status-of-the-Sierra-Nevada- University-of-California/book/9814335
FS Response: Taken out of context – refers to clearcuts. ------Timber Harvest Opposing View #67 - "The development of sound forest-management policies requires that consideration be given to the economic benefits associated with competing uses of forest resources. The benefits that may be provided under different management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasi-option value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices and costs."
Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public Forestlands: A Survey of the Literature. A study conducted on behalf of the U.S. Forest Service, January 31, 1995 http://icbemp.gov/science/vincent.pdf
FS Response: FS supported document. Comment not relevant to the Flat project. The Forest does not only recognize benefits in prices and costs.
------Timber Harvest Opposing View #68 - “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalists at odds with the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue
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Flat Project Comment Analysis even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees.
Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires.
In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “
Voss, René, Ph.D. “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml
FS Response: Opinion.
------Timber Harvest Opposing View #69 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.”
Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html
FS Response: Opinion on blog.
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------Timber Harvest Opposing View #70 - “Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitive wildlife. Logging typically requires roads and skid trails which create chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who suggests that logging is a benefit or benign is not doing a full accounting of costs.”
Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.”
Wuerthner, George “Who Will Speak For the Forests?” NewWest, January 27, 2009 http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/
FS Response: Opinion on blog.
------Timber Harvest Opposing View #71 - "After logging, peak pipeflow was about 3.7 times greater than before logging."
"The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)."
Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow and erosion: coastal northern California, USA." Proceedings of the Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992 http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF
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FS Response: Document not relevant to the Flat project or current Forest management policies.
------Timber Harvest Opposing View #72 - “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, but also numerous other services such as recreation and clean water.”
“Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat.”
“It is now widely recognized that commercial logging has damaged ecosystem health, clean water, and recreational opportunities-- values that are highly appreciated by the American public. The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service and independent economists have estimated that timber accounts for only 2.7 percent of the total values of goods and services derived from the National Forests, while recreation and fish and wildlife produce 84.6 percent.”
From an April 16, 2002 letter to President Bush asking him
to stop all logging in the national forests. http://www.wvhighlands.org/Voice%20PDFs/VoiceAug02.pdf
The names of the 221 Ph.D. level scientists that signed the letter are listed below:
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Dr. E.O. Wilson, Ph.D. Auburn University, Department Organismal Biology, Professor Harvard University, Department of Biology, Assistant Professor Emeritus of Biology, Professor of Biology, Curator of Fishes ------Dr. Benjamin Blount, Ph.D. Dr. Anne Ehrlich, Ph.D. Dr. David R. Atkinson, Ph.D. University of Georgia, Stanford University, Department Cornell University, Professor of Department of Anthropology, of Biological Sciences, Sr. Ecology & Evolutionary Professor Research Associate, Center for Biology Conservation Biology ------Dr. Dee Boersma, Ph.D. ------Michelle A. Baker, Ph.D. University of Washington, Dr. Peter Raven, Ph.D. Utah State University, Department of Zoology, Missouri Botanical Garden, Department of Biology, Professor Director, 2000 National Medal Assistant Professor of Science winner ------Dr. Eric Bolen, Ph.D. ------Dr. Henry L. Bart, Jr., Ph.D University of North Carolina- Dr. David R. Foster, Ph.D. Tulane University, Museum of Wilmington, Department of Harvard University, Director Natural History, Director and Biology, Professor of Wildlife Harvard Forest Curator of Fishes Ecology ------Dr. Kenneth P. Able, Ph.D. Dr. Fakhri Bazzaz, Ph.D. Dr. Herb Boschung, Ph.D. University at Albany, SUNY Harvard University, Department University of Alabama- Department of Biological of Biology, Mallinckrodt Tuscaloosa, Department of Sciences, Professor Professor of Biology Biological Sciences, Professor ------Emeritus Dr. Kraig Adler, Ph.D. Dr. Donald L. Beaver, Ph.D. ------Cornell University, Vice Provost Michigan State University, Dr. Richard Bradley, Ph.D. for Life Sciences, Professor of Department of Zoology/The Ohio State University, Biology Michigan State University Department of Evolution, Museum, Professor Emeritus Ecology, and Organismal ------Biology, Professor Dr. Steven C. Anderson, Ph.D. ------University of the Pacific, Dr. David L. Bechler, Ph.D. ------Department of Biological Valdosta State University, Dr. Greg Brown, Ph.D. Sciences, Professor Emeritus Department of Biology, Alaska Pacific University, Department Head Department of Environmental ------Science, Associate Professor Dr. William D. Anderson, Jr., ------Ph.D. Dr. Chris Benkman, Ph.D. ------Grice Marine Biological New Mexico State University, Dr. David M. Bryant , Ph.D. Laboratory Department of Biology, Harvard University, Department Associate Professor of Earth and Planetary Science, ------Member, Zi Sigma Pi, the Dr. Robert Angus, Ph.D. ------Honorary Fraternity of Foresters University of Alabama- Dr. Brad Bergstrom, Ph.D. Birmingham, Department of Valdosta State University, ------Biology, Professor Department of Biology, Dr. Deborah Buitron, Ph.D. Professor North Dakota State University, ------Department of Biological Dr. Jonathan W. Armbruster, ------Sciences, Adjunct Professor Ph.D. Dr. Tim M. Berra, Ph.D. Dr. Rabel J. Burdge, Ph.D. Ohio State University, Western Washington University, Evolution, Ecology & Department of Sociology, and
223
Flat Project Comment Analysis
Environmental Studies, Kellogg Biological Station, Services: Societal Dependence Professor Emeritus, Associate Editor Evolution on Natural Ecosystems ------Dr. Nancy M. Butler, Ph.D. Carol Conway, Ph.D. Dr. James Danoff-Burg, Ph.D. Gustavus Adolphus College, University of California-Davis, Columbia University, Center for Department of Biology, Department of Ecology Environmental Research and Assistant Professor Conservation, Associate ------Research Scientist ------Dr. Joseph Cook, Ph.D. Dr. William Calder, Ph.D. University of Alaska, Curator of ------University of Arizona, Professor Mammals and Professor of Dr. Margaret B. Davis, Ph.D. of Ecology and Evolutionary Biology University of Minnesota, Biology Department of Ecology, ------Evolution and Behavior, ------Dr. Jeffery D. Corbin, Ph.D. Regents Professor of Ecology, Kevin Caldwell, Ph.D University of California- retired Appalachian Ecological Berkeley, Department of Consultants, Botanist Integrative Biology, Post------Doctoral Fellow/ Lecturer Dr. Larry Dew, Ph.D. ------University of California-Davis, Dr. Todd Campbell, Ph.D. ------Department of Anthropology University of Tennessee, Dr. Richard G. Coss, Ph.D. Department of Ecology and University of California- Davis, ------Evolutionary Biology, Post- Graduate Groups in Psychology, Dr. Calvin B. DeWitt, Ph.D. Doctoral Research Associate Ecology, and Animal Behavior University of Wisconsin- The Institute for Biological Professor Madison Professor of Invasions Environmental Studies Director, ------Au Sable Institute of ------Dr. Tom Cottrell, Ph.D. Environmental Studies Kai Chan, Ph.D. Central Washington University, Princeton University, Department of Biology, Plant ------Department of Ecology and Ecologist Dr. Janis L. Dickinson, Ph.D. Evolutionary Biology University of California------Berkeley Museum of Vertebrate ------Dr. Tom Cottrell, Ph.D. Zoology, Assistant Research Dr. Jiquan Chen, Ph.D. Central Washington University, Zoologist Hastings Natural Michigan Tech University, Department of Biology, Plant History Reservation School of Forestry and Wood Ecologist Products, Associate Professor, ------Landscape Ecology & ------Dr. C. Kenneth Dodd, Jr., Ph.D. Ecosystem Science Dr. Brian I. Crother, Ph.D. University of Florida Southeastern Louisiana Department of Wildlife Ecology ------University, Department of and Conservation, Courtesy Dr. Joel E. Cohen, Ph.D. Biology, Associate Professor Associate Professor, President, Rockefeller University, The Herpetologists' League Professor of Populations ------Dr. Thomas W. Culliney, Ph.D. ------Hawaii Department of Dr. David Edds, Ph.D. Cormac Collier, Ph.D. Agriculture, population Emporia State University, Cape Cod National Seashore, ecologist Department of Biological Biological Technician ------Sciences, Professor ------Dr. Gretchen C. Daily, Ph.D. ------Dr. Jeff Connor, Ph.D. Stanford University, Department Dr. Joan Edwards, Ph.D. Michigan State University, of Biological Sciences, Bing Williams University, Department of Botany and Plant Interdisciplinary Research Department of Biology, Pathology, Associate Professor, Scientist, Editor, Nature's Professor of Biology
224
Flat Project Comment Analysis
University of North Carolina, University of Texas- Austin, ------Professor of Biology, President Texas Natural History Dr. Timothy J. Ehlinger, Ph.D Botanical Society of America Collections, Texas Museum of University of Wisconsin- Science and History, Curator of Milwaukee, Department of ------Ichthyology Biological Sciences, Assistant Dr. Cameron Ghalambor, Ph.D. Professor University of California------Riverside, Department of Dr. Andrew Hendry , Ph.D. ------Biology University of Massachusetts- Dr. Paul Ehrlich, Ph.D. Amherst, Organismic and Stanford University, Department ------Evolutionary Biology Program of Biological Sciences, Dr. Barrie K. Gilbert, Ph.D. Professor of Biological Sciences Utah State University, ------Department of Fisheries and Dr. James D. Hengeveld, Ph.D. ------Wildlife-- Ecology Center, Indiana University, Department Dr. W. Hardy Eshbaugh, Ph.D. Senior Scientist of Biology, Assistant Professor Miami University, Department & Lab Coordinator of Botany, Professor Emeritus ------Dr. Douglas S. Glazier, Ph.D. ------Juniata College, Department of Dr. Frank H. Heppner, Ph.D. Dr. William J. Etges, Ph.D. Biology, Professor of Biology University of Rhode Island, University of Arkansas, Department of Biological Department of Biological ------Sciences, Professor of biological Sciences Dr. Robert H. Gray , Ph.D. sciences Umatilla Chemical Agent ------Disposal Facility, Principal ------Dr. Joseph E. Faber, Ph.D. Investigator Dr. David M. Hillis, Ph.D. West Virginia University- University of Texas- Austin, Parkersburg, Division of Natural ------Director, School of Biological Sciences, Assistant Professor Dr. Jay Greenberg, Ph.D. Sciences University of Rochester Medical ------Center, Department of ------Elizabeth Fensin, Ph.D. Biochemistry and Biophysics Dr. Mark Hixon, Ph.D. N.C. Division of Water Quality, Oregon State University, Environmental Biologist ------Department of Zoology Dr. Correigh Greene, Ph.D. ------University of California- Davis, ------Dr. G. Edgar Folk, Ph.D. Section of Evolution and Dr. Karen Holl, Ph.D. Iowa State University, Ecology University of California- Santa Department of Physiology, Cruz, Department of Professor of Environmental ------Environmental Studies Physiology Dr. Ed Grumbine, Ph.D. University of California- Santa ------Cruz, Extension Sierra Institute Dr. Robert W Howarth, Ph.D. Dr. Johannes Foufopoulos, Environmental Defense Ph.D. ------Oceans Program, Senior Princeton University, Dr. David G. Hankin, Ph.D. Scientist and Program Manager Department of Ecology and Humboldt State University, Evolutionary Biology, Visiting Telonicher Marine Lab ------Assistant Professor Professor of Fisheries Biology Dr. Bruce Hungate, Ph.D. Northern Arizona University, ------Department of Biological Dr. ElizaBeth A. Fox, Ph.D. Dr. Robert B. Hastings, Ph.D. Sciences, Assistant Professor Princeton University, Southeastern Louisiana Department of Ecology and University, Department of ------Evolutionary Biology, Lecturer Biology, Professor of Biological Dr. Alan Hutchcroft, Ph.D. Sciences Rockford College, Bartels ------Professor of Chemistry Patricia Gensel, Ph.D. ------Dr. Dean A. Hendrickson, Ph.D ------
225
Flat Project Comment Analysis
Dr. David W. Inouye, Ph.D. Sciences, Postdoctoral Research Stephen P. Kunz , Ph.D. University of Maryland, Associate Certified Senior Professor & Director, Graduate Ecologist,Certified Wetland Program in Sustainable ------Scientist Development and Conservation Dr. Keith T. Killingbeck, Ph.D. Biology Univeristy of Rhode Island, ------Department of Biological Dr. Doug LaFollette, Ph.D. ------Sciences Wisconsin Secretary of State Dr. Charles Jackson, Ph.D. ------Dr. David R. Klein, Ph.D. Dr. Robert O. Lawton, Ph.D. Dr. Dan Janzen, Ph.D University of Alaska- Fairbanks, University of Alabama- University of Pennsylvania, Institute of Arctic Biology, Huntsville, Department of Professor Professor Emeritus Biological Sciences Estella Leopold, Ph.D. ------University of Washington, Dr. Robert L. Jeanne, Ph.D. Dr. Walter Koenig, Ph.D Department of Botany, University of Wisconsin- University of California- Professor Madison, Department of Berkeley, Museum of Vertebrate Entomology, Professor of Zoology ------Entomology and Zoology Dr. John J. Lepri, Ph.D. ------University of North Carolina, ------Dr. Alan Kohn, Ph.D. Department of Biology, University of Washington, Associate Professor of Biology Dr. Paul A. Johnsgard, Ph.D. Department of Zoology, University of Nebraska- Professor Emeritus, Formerly ------Lincoln, Department of President of Society for Dr. Malcolm P. Levin, Ph.D. Biological Sciences, Foundation Integrative and Comparative University of Illinois at Professor of Biological Sciences Biology Springfield, Department of Environmental Studies, ------Department Chair Dr. Erik S. Jules, Ph.D. Dr. Arthur H. Kopelman, Ph.D. Humboldt State University, State University of New York, ------Department of Biological Department of Science and Dr. John Lichter, Ph.D. Sciences, Assistant Professor Mathematics, Professor of Bowdoin College, Biology Science, President Coastal Department and Environmental ------Research and Education Society Studies Program, Assistant Dr. James R. Karr, Ph.D. of Long Island Professor University of Washington, Department of Environmental ------Health, Professor of Aquatic Dr. Don Kroodsma, Ph.D. Dr. William Z. Lidicker, Ph.D. Sciences and Zoology, Adjunct University of Massachusetts, University of California, Professor of Civil Engineering Department of Biology, Berkeley, Professor of ------Professor Integrative Biology, Emeritus Dr. Sylvan R. Kaufman, Ph.D. ------Harvard University, Biological Dr. Kenneth Krysko, Ph.D. Dr. David R. Lighthall, Ph.D. Labs, Postdoctoral Fellow University of Florida, Florida California Institute for Rural Museum of Natural History, Studies, Executive Director ------Collections Manager, Division Dr. Sterling Keeley, Ph.D. of Herpetology ------University of Hawaii- Manoa, Dr. John T. Lill, Ph.D. Department of Botany, ------University of Missouri-St.Louis Professor and Chair Bernard Kuhajda, Ph.D. University of Alabama------Tuscaloosa, Department of Dr. Randy Linder, Ph.D. Dr. Melody J. Kemp, Ph.D. Biological Sciences University of Texas- Austin, University of Notre Dame, School of Biology Department of Biological ------
226
Flat Project Comment Analysis
Sciences/Section of Integrative Canterbury Christ Church University of Hawaii- Manoa, Biology University College, Department Department of Botany, of GeographyMarine Fisheries ProfessorCenter for ------GIS Unit Conservation Research and Dr. Robin A. Matthews, Ph.D. Training Western Washington University, ------Huxley College of Dr. Bruce Means, Ph.D. ------Environmental Studies, Florida State University, Dr. Timothy C. Morton, Ph.D. Professor, Director, Institute for Department of Biological University of Chicago, Watershed Studies Sciences, Adjunct Professor of Department of Biology, visiting Biological Science, Executive Assistant Professor, Ecological ------Director Coastal Plains Institute Society of America Dr. Thomas P. Maxwell, Ph.D. University of Maryland, ------Institute for Ecological Dr. Robert J. Meese, Ph.D. Dr. Peter B. Moyle, Ph.D. Economics, Professor University of California, University of California- Davis, Department of Environmental Department of Wildlife, Fish, ------Science and Policy and Conservation Biology, Dr. Audrey Mayer, Ph.D. Professor of Fish Biology University of Cincinnati, ------Department of Biological Dr. Gary K. Meffe, Ph.D. ------Sciences University of Florida, Dr. Helmut C. Mueller, Ph.D. Department of Wildlife Ecology University of North Carolina, ------and Conservation, Adjunct Department of Biology & Dr. Terrence P. McGlynn, Ph.D. Professor, Editor, Conservation Curriculum in Ecology, University of San Diego, Biology Professor Emeritus Assistant Professor of Biology ------Dr. DeForest Mellon, Ph.D. Dr. Steven Mullin, Ph.D. Dr. James B. McGraw, Ph.D. University of Virginia, Eastern Illinois University, West Virginia University, Department of Biology, Department of Biological Department of Biology, Eberly Professor of Biology Sciences, Professor Professor of Biology & Aldo Leopold Leadership Program ------Fellow Dr. John Miles, Ph.D. Dave Neely, Ph.D. Western Washington University, University of Alabama, ------Huxley College of Biodiversity and Systematics Don McKenzie, Ph.D. Environmental Studies, University of Washington, Professor, Director Center for ------College of Forest Resources, Geography and Environmental Dr. Richard Niesenbaum, Ph.D. Research Ecologist Social Sciences Muhlenberg College, Department of BiologyAssociate ------Professor of Biology, Donald Dr. John McLaughlin, Ph.D. Dr. Arlee M. Montalvo, Ph.D. and Anne Shire Distinguished Western Washington University, University of California- Teaching Professor Huxley College of Riverside, Department of Environmental Studies,- Botany and Plant Sciences, Asst. ------Department of Environmental Res. Plant Population Biologist Dr. Elliott A. Norse, Ph.D. Sciences, Assistant Professor & Lecturer President, Marine Conservation Biology Institute, Author: ------Ancient Forests of the Pacific Dr. David McNeely, Ph.D Dr. Harold Mooney , Ph.D. Northwest Langston University, Stanford University, Department Department of Biology, of Biological Sciences, Paul S. ------Professor Achilles Professor of Dr. M. Philip Nott, Ph.D. Environmental Biology The Institute for Bird ------Populations Dr. Geoff Meaden, Ph.D. ------Dr. Cliff Morden, Ph.D. ------
227
Flat Project Comment Analysis
Dr. Gary Nuechterlein, Ph.D. University of California- North Dakota State University, Riverside, Department of ------Department of Biological Biology, Professor of Biology Dr. Barry Rosenbaum, Ph.D. Sciences, Professor University of Colorado, ------Research Associate, Institute of ------Dr. Mark Pyron, Ph.D. Arctic and Alpine Research Dr. Philip Nyhus, Ph.D. Ball State University, Franklin & Marshall College, Department of Biology, ------Department of Geosciences, Assistant Professor Dr. Scott D. Russell, Ph.D. Assistant Professor University of Oklahoma, George ------Lynn Cross Research Professor ------Dr. Peter A. Quinby , Ph.D. of Botany, Director, Samuel Dr. Dennis Ojima, Ph.D. Paul Smith's College, Natural Roberts Noble Electron Natural Resource Ecology Resources, Science and Liberal Microscopy Laboratory Laboratory, Colorado State Arts, Assistant Dean and University, Senior Research Associate Professor ------Scientist, Aldo Leopold Dr. John M. Rybczyk, Ph.D. Leadership Fellow ------Western Washington University, Dr. John T. Ratti, Ph.D. Huxley College of ------University of Idaho- Moscow, Environmental Studies, Dr. Gordon H. Orians, Ph.D. Department of Fish and Wildlife Assistant Professor University of Washington, Professor Emeritus of Zoology ------Dr. Stuart Reichler, Ph.D. Dr. Karin Sable, Ph.D. ------University of Texas- Austin, University of Puget Sound, Dr. Michael Ort, Ph.D. School of Biology Sciences Department of Economics University of Northern Arizona, Department of Geology, ------Associate ProfessorCenter for Dr. Janita Rice, Ph.D. Dr. Edward Saiff, Ph.D. Environmental Sciences and California State University Ramapo College of New Jersey, Education Department of Biology, ------Professor of Biology, Fellow, ------Dr. Carol Riley, Ph.D. American Association for the Dr. Richard S. Ostfeld, Ph.D. ------Advancement of Science Institute of Ecosystem Studies Dr. Caroljane B. Robertson, ------Ph.D. Dr. Alan H. Savitzky, Ph.D. Dr. Ken Parejko, Ph.D. ------Old Dominion University, University of Wisconsin, Dr. George Robinson, Ph.D. Associate Professor of Department of Biology, State University of New York at Biological Sciences Associate Professor Albany, Department of Dr. John O. Sawyer, Ph.D. Biological Sciences, Associate Humboldt State University, ------Emeritus Professor of Botany Dr. Dennis Paulson, Ph.D. Professor University of Puget Sound, ------Slater Museum of Natural Joe Rocchio, Ph.D. Dr. William H. Schlesinger, History, Director Colorado Natural Heritage Ph.D. Program, Wetland Ecologist Duke University, Dean, ------Nicholas School of the Dr. Ann Phillippi, Ph.D. ------Environment and Earth ------Dr. Charles Romesburg, Ph.D. Sciences, James B. Duke Dr. Stuart Pimm, Ph.D. Utah State University, Professor of Biogeochemistry Columbia University, Center for Department of Forest Resources, Professor ------Environmental Research and Dr. Stephen H. Schneider, Ph.D Conservation, Professor of ------Stanford University, Department Conservation Biology Dr. Thomas Rooney, Ph.D. of Biological Sciences ------University of Wisconsin------Dr. Mary V. Price, Ph.D. Madison, Department of Botany
228
Flat Project Comment Analysis
Dr. Peter Schulze, Ph.D. Carnegie Mellon University, North Dakota State University, Austin College, Associate Department of History, Department of Zoology, Professor of Biology, Director, Assistant Professor of History Assistant Professor Center for Environmental and Policy Studies ------Dr. Phillip K. Stoddard, Ph.D. ------Dr. Stefan Sommer, Ph.D. Florida International University, Burton Shank, Ph.D. Idaho State University, Department of Biological Florida Fish and Wildlife Department of Biological Sciences Conservation, Sciences, Research Assistant, AssociationResearch Biologist Professor, Director Natural ------Heritage Center Dr. Philip C. Stouffer, Ph.D. ------Southeastern Louisiana Dr. Sharron K. Sherrod, Ph.D. ------University, Department of University of Denver, Dr. Lisa G. Sorenson, Ph.D. Biological Sciences, Associate Department of Biology, Union of Concerned Scientists, Professor Professor Global Environment Program, Adjunct Research Assistant ------Professor- Biology Department, Dr. Boyd R. Strain, Ph.D. Dr. Fraser Shilling, Ph.D. BostonUniversity Duke University, Department of University of California- Davis, Biological Sciences, Professor Section of Microbial and ------Emeritus Cellular Biology, Chair Dr. Michael Soule, Ph.D. Committee on Conservation, Wildlands Project ------Society for Integrative Dr. Michael C. Swift, Ph.D. andComparative Biology ------St. Olaf College, Department of Dr. Larry T. Spencer, Ph.D. Biology, Department of ------Plymouth State College, Biology- University of Virginia, Erin A. Shope, Ph.D. Professor of Biology sabbatical Brevard University, Environmental Educator ------Dr. Timothy P. Spira, Ph.D. Dr. Douglas W. Tallamy, Ph.D. ------Clemson University, University of Delaware, Dr. Clifford Slayman, Ph.D. Department of Biological Department of Entomology and Yale School of Medicine Sciences, Associate Professor Applied Ecology, Professor Cellular and Molecular Physiology, Professor of ------Physiology Dr. Alan Springer, Ph.D. Dr. Eric J. Taylor, Ph.D University of Alaska-Fairbanks, Fish and Wildlife Biologist ------Institute of Marine Science, Dr. Christoper C. Smith, Ph.D. Professor ------Kansas State University, Dr. John Terborgh, Ph.D. Division of Biology ------Duke University, Center for Dr. Robert D. Stevenson, Ph.D. Tropical Conservation, James B ------University of Massachusetts- Duke Professor Dr. Bradley F. Smith, Ph.D. Boston, Department of Biology, Western Washington University, Associate Professor of Biology ------Huxley College of Dr. Andrea S. Thorpe, Ph.D. Environmental Studies, Dean ------University of Montana, Division Dr. Glen R. Stewart, Ph.D. of Biological Sciences ------California State Polytechnic Dr. Youngsinn Sohn, Ph.D. University- Pomona, ------University of Maryland- Department of Biological Dr. Harry M. Tiebout, Ph.D. Baltimore, Geography & Sciences, Professor of Zoology West Chester University, Environmental Systems, Department of Biology Assistant Professor ------Dr. Craig Stockwell, Ph.D. ------Dr. Gordon Ultsch, Ph.D. Dr. John Soluri, Ph.D.
229
Flat Project Comment Analysis
University of Alabama- Department of Environmental Colorado State University, Tuscaloosa, Department of Sciences, Associate Professor Department of EPO Biology Biological Sciences ------Dr. Glen Walsberg, Ph.D. Dr. Ernest J. Willoughby, Ph.D. Dr. Loraine Utter Kohorn, Ph.D. Arizona State University St. Mary's College of Maryland, Duke University, Department of Professor of Biology Department of Biology, Biology/Nicholas School of the President, Cooper Professor of Biology Environment, Visiting Assistant Ornithological Society Professor Dr. Nickolas M. Waser, Ph.D. ------University of California- Dr. Michael Windelspecht, ------Riverside, Department of Ph.D. Dr. Daniel M Vernon, Ph.D. Biology, Professor of Biology, Appalachian State University, Whitman University, President, Rocky Mountain Department of Biology, Department of Biology Biological Laboratory Assistant Professor of Biology ------Dr. Richard A. Wahle, Ph.D. Dr. Judith S. Weis, Ph.D. Dr. Marti Witter, Ph.D. Bigelow Laboratory for Ocean Rutgers University, Sciences, Research Scientist ------Department of Biological Dr. Helen Young, Ph.D. ------Sciences, Professor of Biology, Middlebury College, Dr. David B. Wake, Ph.D. Past President American Department of Biology University of California, Institute of Biological Sciences Professor Professor of Integrative Biology, ------Curator, Museum of Vertebrate Dr. John F. Weishampel, Ph.D. Zoology Dr. Joy B. Zedler, Ph.D. University of Central Florida, University of Wisconsin------Department of Biology Madison, Department of Botany Dr. Skip Walker, Ph.D. ------and Arboretum, Aldo Leopold University of Alaska- Fairbanks, Dr. Gregory Welch, Ph.D. Professor of Restoration Institute of Arctic Biology University of Maine, Professor Ecology ------Darling Marine Center ------Dr. Lawernce R. Walker, Ph.D. ------Dr. Marion Klaus, Ph.D. University of Nevada- Las Dr. Robert G. Wetzel, Ph.D. Sheridan College Vegas, Department of Biology, University of Alabama- Professor of Biology Tuscaloosa, Department of FS Response: Opinion ------Biological Sciences, Bishop and testimony. Excerpts Dr. Diana H. Wall, Ph.D. Professor of Biology not relevant to the Flat Colorado State University, ------project restoration College of natural Resources, Dr. Peter S. White, Ph.D. projects or Professor, Director, Natural University of North Carolina- Resources Ecological representative of forest Chapel Hill, Department of values. Laboratory Biology, Professor, Director ------North Carolina Botanical Dr. Donald M. Waller, Ph.D. Garden University of Wisconsin------Madison, Department of Botany, Dr. Bill Willers, Ph.D. Editor, Evolution University of Wisconsin------Oshkosh, Department of Dr. David O. Wallin, Ph.D. Biology, Emeritus Professor of Western Washington University, Biology Huxley College of ------Environmental Studies- Dr. Joe Williams, Ph.D.
230
Flat Project Comment Analysis
------Timber Harvest Opposing View #73 - “Recently, so called "salvage" logging has increased on national forests in response to a timber industry invented "forest health crisis" which points the finger at normal forest processes of fire, fungi, bacteria, insects and other diseases. In fact the crisis in the national forests is habitat destruction caused by too much clearcutting.
My long-term studies of forest diseases in Idaho show the loss by disease and insect activity in all age classes of forests to be less than or slightly more than 1 percent per year over the past thirty-eight years. These findings are consistent with Forest Service national level data.
Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.”
Partridge, Arthur Ph.D., professor emeritus, University of Idaho Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm
FS Response: Opinion and testimony. Excerpts not relevant to the Flat project.
------Timber Harvest Opposing View #74 – “In our overview of the impacts of forest management activities on soil erosion and productivity, we show that erosion alone is seldom the cause of greatly reduced site productivity. However, erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term site productivity and may lead to sustained periods of extended erosion that could exacerbate degradation.
231
Flat Project Comment Analysis
Managers should be concerned with harvesting impacts, site preparation disturbances, amount of tree that is removed, and the accumulation of fuel from fire suppression. On erosion-sensitive sites, we need to carefully evaluate such management factors.”
Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on erosion and soil productivity. Proceedings of the Symposium on Soil Quality and Erosion Interaction, Keystone, CO, July 7, 1996. Ankeney, IA: Soil and Water Conservation Society. 16 p. http://forest.moscowfsl.wsu.edu/cgi-bin/engr/library/searchpub.pl?pub=1999c
FS Response: Agree. The Flat project analyzes the impact to soils from project activities in the EA on page 3-186. Additionally, prescribed fire as described is proposed for this project.
------Timber Harvest Opposing View #75 - “Logging often destroys natural habitats, resulting in the loss of biodiversity and sometimes leading to the local, and possibly global, extinction of species. Although estimates of the rates of loss vary, few deny the reality of the current losses of both flora and fauna.177 “
According to a joint report by the Worldwide Fund for Nature and the Sarawak Forest Department, "Logging causes immediate forest disturbances, long-term habitat changes (e.g. damage to food trees and salt-licks), increased hunting by timber company workers and availability of logging roads as hunting routes. The destruction of wildlife from habitat loss must be recognised to be on an enormous scale".178 In Central Africa, the opening-up of the forest by logging facilitates the illegal hunting of wildlife, including protected species such as primates, and is leading to a decline in wildlife populations.179 Deterioration in water quality has caused a decline in fish stocks and has affected aquatic biological diversity because indigenous animals and plant life are highly vulnerable to oxygen depletion, suspended particulate matter and a lack of light.180
Even so called selective logging severely affects the complex and rich biodiversity of forests through excessive damage to residual stands, destruction of other plant and tree species and the creaming-off of species which are the most valuable for timber. An FAO study in Malaysia has shown that as much as 50% of the standing forest may be damaged and the surface soil destroyed when up to 30% of the ground surface is exposed. During silvicultural treatment in logging operations in Sarawak, so-called uneconomic forest species are deliberately poisoned. 232
Flat Project Comment Analysis
This reduces the complexity and species diversity of the tropical forests to only 10% of the original condition, resulting in the systematic elimination of tree genetic resources and contamination of the environment.181 According to the IUCN the most frequently recorded of all threats to globally endangered tree species is 'felling'.182 “
Forests Monitor, Environmental Impacts of Logging, 2006 (with photos) http://www.forestsmonitor.org/en/reports/550066/550083
FS Response: Opinion piece. Not relevant to the Flat project as the cited places are not spatially near or similar to the Flat project.
------Timber Harvest Opposing View #76 - Major report findings:
1) If we ended the timber sales program on national forests and redirected the logging subsidies we could provide over $30,000 for each public lands timber worker for retraining or ecological restoration work - - and still have over $800 million left over for taxpayer savings in the first year alone.
2) We don’t need to log national forests for our timber supply, given the fact that the timber cut annually from national forests nationwide now comprises only 3.3% of this nation’s total annual wood consumption, and less than 4% of the sawtimber used for construction.
3) Logging on national forests INCREASES the risk of forest fires more than any other human activity.
4) A bipartisan nationwide poll conducted in 1998 found that 69% of Americans now oppose allowing timber companies to log our national forests.
233
Flat Project Comment Analysis
Hansen, Chad, Ph.D., Ending Timber Sales on National Forests: THE FACTS (FY ’97) Published in the Earth Island Journal, 1999 http://www.johnmuirproject.org/pdf/Fy-1997-Economic-Report-Ending-Timber-Sales.pdf
FS Response: Opinion piece. Not relevant to the Flat project as the cited places are not spatially near or similar to the Flat project.
------Timber Harvest Opposing View #77 – “However, I believe that their support for logging represents a failure to challenge many of the flawed assumptions that are guiding federal logging programs and in some cases even repeating many of the same pejorative language helps to undermine in the long term conservation efforts. After all if the public believes our forests are sick and unhealthy; that logging will cure them; that logging will preclude wildfires and eliminate beetle kill, and that rural economies are dependent on public lands logging to survive, than they are, in my view, contributing to the wrong message.”
“There may be legitimate rationales for logging, but it’s not the one usually given for logging public forests today. Indeed, the major justifications given for logging public lands is typically some social or ecological benefit—to reduce fires, clean up bug killed trees, fix watersheds, restore forest health or provide for “economic stability” to rural communities. In far too many cases, all of these are just cover to hide the main reason for logging—to maintain the local timber industry at the expense of our forest’s ecological integrity and taxpayer dollars.”
WUERTHNER, GEORGE, “Why are Conservation Groups Advocating Logging Public Forests?” Published by Counterpunch, September 27, 2012 http://www.counterpunch.org/2012/09/27/why-are-conservation-groups-advocating-logging-public-forests/
FS Response: Opinion.
------234
Flat Project Comment Analysis
Timber Harvest Opposing View #78 – “Because of the current government shutdown, the public is being kept out of all National Parks and many other federal lands. But ironically, oil, mineral, and timber companies are still allowed to drill, mine, and log on federal lands while the shutdown is going on. Officials in the US Department of Interior and Department of Agriculture, which oversee National Park and National Forest lands respectively, have given us an unusually clear glimpse of where their priorities lie. Federal lands are supposed to be managed for the benefit of the American people, and resource extraction shouldn’t be going on while the public is barred from our National Parks.
During the shutdown, which was caused because Congress has been unable to pass a budget, almost all “nonessential” federal government services are temporarily unavailable. The fact that the Departments of Interior and Agriculture have apparently found the resources to keep public lands open to drilling and logging, but can’t keep National Parks and other recreational areas open, shows resource extraction in being prioritized over public access to our lands. It’s time for this to change.”
“Stop Drilling and Logging on Federal Lands While the Public is Kept Out” A petition targeted for Secretary of the Interior Sally Jewel and Secretary of Agriculture Tom Vilsack Posted at FORCECHANGE.COM, 2013 http://forcechange.com/86223/stop-drilling-and-logging-on-federal-lands-while-the-public-is-kept-out/
FS Response: This is a petition to the chief of the Forest Service to stop logging. Not relevant to the Flat project.
------Timber Harvest Opposing View #79 – “"We tried for the past 18-months to work with Supervisor Bull to implement an effective community fuel reduction project up the East Fork. Our proposal - which was favored by 98% of the 13,000 public comments received on this project would have reduced fuels on 1,600 acres of national forest land, pumped $1 million into the local economy and provided 45 local jobs. Unfortunately, this common sense plan was rejected by Supervisor Bull," stated Koehler.”
“ "The attempt by Supervisor Bull to cover-up public knowledge of excessive soil damage in the project area by altering the best-available scientific data and by purging project file documents related to soils is a blatant attempt to white-wash this damaging proposal and cannot go unchallenged," explained Campbell.”
“The East Fork project area is still recovering from historic Forest Service mismanagement including clearcutting, terracing and excessive roadbuilding. 33% of the entire analysis area has already been logged. The analysis area averages 5.2 miles of road per square mile, not including jammer roads. These roads contribute 151.2 tons of sediment per year to streams within the project area. The East Fork, running through the middle of the project area, is officially classified as an impaired stream because its excessive 235
Flat Project Comment Analysis sediment load has compromised its ecological integrity. Several watersheds already exceed established thresholds for clearcutting, which threatens stream channel stability with increased runoff.”
Conservation Groups Look to Hold Forest Service Accountable for Middle East Fork Logging Plan Published by Lowbagger, April 25, 2006 http://www.lowbagger.org/mideast.html
Note: In April of 2009, the Forest Service's Northern Region rewarded Supervisor Bull for his mismanagement of public land with a promotion to the Director of Recreation.
FS Response: Link does not work. The excerpt appears to be opinion. Effects of access and travel management are discussed on page 3-6 of the EA. Effects to soil and watershed are discussed on page 3- 186 of the EA.
------Timber Harvest Opposing View #80 –“Photosynthesis is one of only two significant mechanisms for removing carbon dioxide from the atmosphere (the other being dissolution into water, leading to destructive ocean acidification). Carbon dioxide is released when trees are cut down, and deforestation accounts for at least 15 percent of global carbon emissions. Thus, cutting down trees is a double-whammy because we not only lose carbon capture capacity, but we release more carbon, too.
An erroneous conventional view holds that young trees capture more dioxide than mature trees; therefore, we should cut down mature trees. However, for most species -- 97 percent of 403 tropical and temperate species -- the biggest trees increase their growth rates and sequester more carbon as they age. This conclusion is based on repeated measurements of 673,046 individual trees, some going back more than 80 years, on six continents
We need all levels of government to start preserving forests -- and fast. In addition to switching from dirty to clean energy, President Obama should halt commercial logging on federal lands, eliminate biomass power plant subsidies that drive forest destruction, and permanently protect forests for carbon capture (in addition to forests' many other public benefits).”
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Trees Are Our Climate Saviors - So Stop Logging on Public Land
02/12/2014
The Huffington Post http://www.huffingtonpost.com/ellen-moyer-phd/trees-are-our-climate-logging_b_4775894.html
FS Response: This an article to stop logging in pristine forests. Not relevant to the Flat project.
------Timber Harvest Opposing View #81 –“Logging activities have numerous impacts on aquatic systems in the Sierra Nevada. The end result of logged landscapes is a highly altered forest system which creates significant problems related to erosion, sedimentation and altered stream flow patterns. Logging removes large trees that normally fall into streams and provide shelter and thermal cover, raises water temperatures and pH, and degrades the chemical and ecological conditions and food webs that fish need to survive. Logging and the roads created to facilitate logging also significantly degrade stream ecosystems by introducing high volumes of sediment into streams, changing natural streamflow patterns, and altering stream channel morphology. Areas that have been logged are far more likely to suffer from major landslides and erosion events which deposit abnormally high levels of sediment into area streams. Roads, ditches, and newly created gullies form new, large networks of flow paths across the landscape. These logged areas therefore, sustain much higher discharge volumes after a storm event than they ever did when the forest was intact.
The changes in stream habitat caused by this increase in sediment loads greatly affects the health of aquatic organisms. The survival rates of many fish species are known to significantly decrease as fine sediment levels and temperatures in the water increase. The deposition of fine sediment on the stream bed degrades spawning areas, reduces pool refuge habitat, decreases winter refuge areas for juveniles, and impedes feeding visibility. Likewise, sensitive amphibian and invertebrate species are also adversely affected by increased sediment loads, decreasing in abundance and diversity as sediment levels rise. The drastic changes in the health of aquatic species brought on by logging has far reaching impacts for general forest ecology as well. Invertebrates, amphibians, and fish are important prey species for many mammals, birds and bats that are vital to the biological integrity of the forest.”
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Published by Sierra Forest Legacy, 2012 http://www.sierraforestlegacy.org/FC_FireForestEcology/FFE_LoggingImpacts.php
FS Response: This is a general website advertising the Sierra Forest Legacy group, whom is opposed to logging. All opinion.
------Timber Harvest Opposing View #82 –
“Natural resource use and extraction leading to habitat modification can have significant direct and indirect impacts to salmon populations. Land use activities associated with logging, road construction, urban development, mining, agriculture, and recreation have significantly altered fish habitat quantity and quality. Associated impacts of these activities include: alteration of streambanks and channel morphology; alteration of ambient stream water temperatures; degradation of water quality; reduction in available
Forestry food supply; elimination of spawning and rearing habitat; Photo: NOAA fragmentation of available habitats; elimination of downstream recruitment of spawning gravels and large woody debris; removal of riparian vegetation resulting in increased stream bank erosion; and increased sedimentation input into spawning and rearing areas resulting in the loss of channel complexity, pool habitat, suitable gravel substrate, and large woody debris. Studies indicate that in most western states, about 80 to 90 percent of the historic riparian habitat has been eliminated. Further, it has been estimated that during the last 200 years, the lower 48 United States have lost approximately 53 percent of all wetlands. Washington and Oregon's wetlands have been estimated to have been diminished by one third, while it is estimated that California has experienced a 91 percent loss of its wetland habitat.
Pacific Salmonids: Major Threats and Impacts
Published by NOAA fisheries Office of Protecte Resources, May 15, 2014
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FS Response: Broken link. Aquatic species and their habitat are discussed in Chapter 3.
------Timber Harvest Opposing View #83 – “It is impossible to overstate the importance of humankind's clearing of the forests. The transformation of forested lands by human actions represents one of the great forces in global environmental change and one of the great drivers of biodiversity loss. The impact of people has been and continues to be profound. Forests are cleared, degraded and fragmented by timber harvest, conversion to agriculture, road-building, human-caused fire, and in myriad other ways. The effort to use and subdue the forest has been a constant theme in the transformation of the earth, in many societies, in many lands, and at most times. Deforestation has important implications for life on this planet.
Just think, originally, almost half of the United States, three-quarters of Canada, almost all of Europe, the plains of the Levant, and much of the rest of the world were forested. The forests have been mostly removed for fuel, building materials and to clear land for farming. The clearing of the forests has been one of the most historic and prodigious feats of humanity.”
“Since 1600, 90% of the virgin forests that once covered much of the lower 48 states have been cleared away. Most of the remaining old-growth forests in the lower 48 states and Alaska are on public lands. In the Pacific Northwest about 80% of this forestland is slated for logging.”
Global Deforestation
Published by the University of Michigan, 01/04/2010 http://www.globalchange.umich.edu/globalchange2/current/lectures/deforest/deforest.html
FS Response: Link does not work.
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------Timber Harvest Opposing View #84 –“The Forest Service’s proposed Spotted Bear logging project would jeopardize the area’s wildife, which are already teetering on the edge of survival. The project would use helicopters, ground-based equipment, and skylines to remove approximately 11 million board foot of timber across 1,853 acres of pristine wildlife habitat adjacent to the Great Bear and Bob Marshall Wilderness areas. An additional 1,347 acres would be burned. Most of the units slated to be logged are mature, 75-140 year old stands of Doug-fir, western larch, spruce, and lodgepole pine that have never been logged (this area burned in the late 1800s and early 1900s). The project would require 2,200 log truckloads traveling back and forth on a narrow dirt road over 55 miles from the nearest town.
To access the remote area, the Forest Service is proposing to open 9.7 miles of roads that were closed to provide security for elk and grizzly bears and build 6.6 miles of new “temporary” roads that will be used over the next 6 years. The Forest Service also proposes to increase motorized access to the project area by extending the season of use by an additional five weeks. Motorized users will now be allowed to access the area in early June causing added trauma to the grizzlies who will have just recently emerged from their dens and will be nutrionally stressed.
“The Spotted Bear area is a critical wildlife connector”, said Keith Hammer, Chair of Swan View Coalition. “Calving elk and nutritionally stressed bears need more springtime and early summer security, not more motor vehicle traffic.” “
Groups Challenge Industrial Logging of Pristine Wildlife Habitat Along South Fork Flathead River
A Western Environmental Law Center Press Release, 2/28/2012 http://www.westernlaw.org/article/groups-challenge-industrial-logging-pristine-wildlife-habitat-along-south-fork-flathead-rive
FS Response: Outlines a law suit in Montana. Not relevant to the Flat project area.
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------Timber Harvest Opposing View #85 –“Four conservation groups — Alliance for the Wild Rockies, Swan View Coalition, Friends of the Wild Swan and Native Ecosystems Council — sued to halt the sale in June 2013. The groups claimed the project would harm grizzly bear, lynx, wolverine and other species and plants while damaging the forest’s remaining old growth.”
“The project area is within the designated “grizzly recovery zone” of the Northern Continental Divide Ecosystem. It is also considered critical habitat for other species listed under the ESA, including bull trout.”
“The Forest Service published its Environmental Assessment in August 2012 and concluded that the Glacier-Loon Timber Sale would have no effect on grizzly bears, Canada lynx, bull trout, bull trout critical habitat and water howellia, a threatened plant species under the ESA.”
“The judge ordered the project be stopped and said these Forest Service lands have to be managed under federal environmental laws to protect native species just like all other national forests, Garrity said.
“It’s unfortunate that we had to once again take the federal government to court to force them to follow the law,” Garrity said. “We had no other choice if we want to conserve the last remaining habitat for bull trout, grizzly bears, lynx and other old growth dependent wildlife since the Forest Service insists on being serial law breakers.” “
Judge Halts Glacier Loon Timber Sale in Swan Valley
Published in the Flathead Beacon, Sep 26, 2014 http://flatheadbeacon.com/2014/09/26/judge-halts-glacier-loon-timber-sale-swan-valley/
FS Response: Outlines a law suit in Montana. Not relevant to the Flat project area.
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------Timber Harvest Opposing View #86 –“That makes four timber projects since May in which U.S. District Judge Dana Christensen found fault with the U.S. Forest Service and the U.S. Fish and Wildlife Services' conclusion that cutting and burning in those areas would not significantly harm the big cats' territory.”
“Christensen ruled the Endangered Species Act requires the agencies to determine whether lynx "may be present" there, which is a lesser standard than what the agencies used in concluding lynx don't "occupy" the area.”
“The judge said the government approved those projects based on an unreliable conclusion they would not harm the lynx's critical habitat.”
Judge stops 3 Montana logging projects over lynx
By Matt Volz, Associated Press June 26, 2013 http://news.yahoo.com/judge-stops-3-montana-logging-141919567.html
FS Response: Outlines a law suit in Montana. Not relevant to the Flat project area.
------Timber Harvest Opposing View #87 –“A federal judge has blocked logging proposed for the Klamath National Forest in Siskiyou County, chiding the U.S. Forest Service for its review of the environmental damage that would result.”
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“The service should have done a full environmental review and done a better job projecting the impact on wildlife and forest conditions, ruled U.S. District Judge Frank C. Damrell Jr.”
Judge blocks Klamath logging plan By Don Thompson,Associated Press October 16, 2004 http://www.wildcalifornia.org/media/epic-in-the-news/judge-blocks-klamath-logging-plan/
FS Response: Outlines a law suit in Northern California. Not relevant to the Flat project area. Effects to all resources are disclosed in Chapter 3 of the EA.
------Timber Harvest Opposing View #88 –“The fact is, commercial logging doesn't prevent catastrophic fires; it causes them. In the latter part of the 19th century, this was common knowledge. Relentless clearing of forests in the Great Lakes region left huge areas largely devoid of the cooling shade of trees, replacing moist natural forest microclimates with the hotter, drier conditions characterized by stump fields. Flammable logging "slash debris" covered the landscape.”
It was in this setting that a massive, cataclysmic fire started near Peshtigo, Wisconsin in 1871. More than 1,200 people were killed. Similar blazes erupted in subsequent years.”
One of the primary reasons that the national forest system was established in 1891 was to prevent the destructive fires caused by logging. It was not until 1897 that, under industry pressure, our national forests were first opened up to timber sales by an appropriations rider. The first timber sale was offered in 1899-- 100 years ago.
“Like the timber industry, the Forest Service also recognized an emerging public relations dilemma several years ago. It knew that it would no longer be able to justify its timber sales program on economic grounds. Instead of dropping the program, it simply gave it a sexy new name--"Forest Stewardship."
The Forest Stewardship program was born in 1993 and was marketed fraudulently as a series of management activities supposedly conducted primarily for the health of the forests. The USFS attempted to distinguish this new program from its Timber Commodity program, which clearly was concerned with nothing more than commercial resource extraction.” 243
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“In April 1999, the US General Accounting Office (GAG) released a report on the Forest Service's approach to fire management that called into serious question the use of the timber sales to address fire issues.
The GAO noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."
The report also found that Forest Service managers "tend to (1) focus on areas with high-value commercial timber rather than on areas with high fire hazards or (2) include more large, commercially valuable trees in a timber sale than are necessary to reduce the accumulated fuels." The "low value materials," observed the GAG, "are unattractive to timber purchasers." “
Hansen, Chad Ph.D., The Big Lie: Logging and Forest Fires Published by the Earth Island Journal, spring 2000 issue http://yeoldeconsciousnessshoppe.com/art6.html
FS Response: Opinion. Additionally, more acres are identified as needing thinned as compared to the acres of commercial harvest, as outlined in the EA.
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Comment Letter #6 – Irene Jerome, AFRC
Via Email: [email protected]
July 21, 2017
Christy Cheyne, District Ranger Emigrant Creek Ranger District 265 Highway 20 South Hines, OR 97738
Dear Christy:
On behalf of the American Forest Resource Council (AFRC) and its members, thank you for the opportunity to comment on the Flat Vegetation Management (Flat) Environmental Assessment (EA).
AFRC is a regional trade association whose purpose is to advocate for sustained yield timber harvests on public timberlands throughout the West to enhance forest health and resistance to fire, insects, and disease. We do this by promoting active management to attain productive public forests, protect adjoining private forests, and assure community stability. We work to improve federal and state laws, regulations, policies and decisions regarding access to and management of public forest lands and protection of all forest lands. Many of our members have their operations in communities within and adjacent to the Malheur National Forest and management on these lands ultimately dictates not only the viability of their businesses, but also the economic health of the communities themselves.
The key issues identified on Flat are:
1) Effects on Big Game Cover: “Studies indicate that Rocky mountain elk and mule deer need a mixture of hiding and thermal cover as well as forage areas, calving/fawning and rearing areas. Forest Plan cover standards are specific to thermal cover. Biomass removal activities would reduce thermal cover.”
2) Effects of Roads on Big Game Security: “Internal scoping discovered that there was a need for more big game security as the Proposed Action alternative did not create enough areas away from roads to provide security during hunting seasons.”
Studies at the Starkey Experiment Station have revealed that “thermal cover” is not a viable issue. The authors conclude, “(W)e found no significant, positive effect of thermal cover on condition of elk during any of the 6 experiments. In contrast, dense cover provided a costly energetic environment, resulting in significantly greater overwinter mass loss, fat catabolism, and (in 1 winter) mortality.”
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John G. Cook, Larry L. Irwin, Larry D. Bryant, Robert A. Riggs and Jack Ward Thomas Wildlife Monographs, No. 141, Relations of Forest Cover and Condition of Elk: A Test of the Thermal Cover Hypothesis in Summer and Winter (Oct., 1998), pp. 3-61
The Rocky Mountain Elk foundation has been working with the Oregon Department of Fish and Wildlife (ODFW) and determined that the issue with roads is not a matter of elk “security” but is actually 6-1 elk distribution on the landscape that is critical. The Emigrant District should utilize the best available science by incorporating the findings of the most current research.
6-2 Please indicate that western juniper will be removed and made available commercially when the logs are suitable.
AFRC fully supports enhancing aspen clones by removing conifers. The PEA provides this description of aspen treatments under U10: “For this treatment all conifers up to 10” DBH would be cut within 150 feet of the last live or remnant aspen tree. No tree that is stabilizing the bank of a stream would be removed regardless of size or relation to aspen trees. No conifers greater than 10” DBH would be cut.”
Aspen treatments described in U21 are confusing and contradictory: “This treatment would consist of removing conifers within 150 feet of the last live or remnant aspen tree. Conifers up to 21” DBH would first be converted to snags and down wood to meet forest plan standards, then any excess trees would be available to be removed and utilized as biomass. Some or all of these treatment units fall within LOS stands, therefore conifers greater than 21” DBH would not be cut. No tree that is stabilizing the bank of a stream would be removed regardless of size or relation to aspen trees . . . . Any created biomass not utilized for commercial purposes would be left on site as downed wood, utilized as large wood for stream restoration, piled and burned, or jackpot burned in areas of light fuel loads.”
We find it inconsistent that is it acceptable to girdle conifers greater than 21” DBH in LOS stands yet it is unacceptable to remove these trees for commercial harvest. A forest plan amendment should 6-3 be requested to remove trees greater than 21” DBH once snag and down wood requirements have been met.
We question the wisdom of removing e trees in excess of those needed for snags and down wood as biomass 6-4 (a product which there is no market for) rather than as merchantable material to help fund the aspen restoration efforts? What is the purpose of leaving conifers greater than 10” DBH in aspen clones? Have other methods of bank stabilization besides leaving conifers been explored?
Aspen treatments under U30 are similarly confusing. Why is it acceptable to remove conifers greater than 21 inch DBH from aspen clones that have been converted to down wood as biomass, which is 6-5 considered a commercial product by the Forest Service, but it is not acceptable to remove then as merchantable sawlogs?
AFRC opposes the restriction that only trees less than 21” DBH within 30 feet of curl-leaf mountain mahogany patches and aspen clones are to be removed. Trees 21” DBH and larger compete with 6-6 mahogany and aspen just like their smaller counterparts. With regard to aspen, please refer to Forest Service General Technical Report, PNW-GTR-806, May 2010, Aspen Biology, Community
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Classification, and Management in the Blue Mountains. AFRC does not support arbitrary diameter limits, such as leaving all trees greater than 30” DBH near curl-leaf mahogany patches and aspen clones. Where was the 30” DBH limit derived from? Is there any science that supports this?
AFRC opposes leaving any conifers in areas that were historically meadows and shrub step 6-7 areas.
The Flat project proposes to log approximately 185 acres with a cable or aerial system. These types of logging systems are very expensive and require a minimum of about five thousand board feet (MBF) per acre for removal to make them marginally viable economically. Further, the five MBF per acre must be of an average diameter of over 14” to make treating these areas economically viable.
It appears that these steeper areas will also have prescriptions requiring variable density thinning, skips and gaps, and “removal of created biomass for commercial purposes” if feasible. These requirements 6-8 will add expense and complicate logging on cable ground. AFRC requests that you consider more straight forward silvicultural prescriptions that will allow these steeper slopes to be treated to improve stand health and reduce fuels and fire risk.
Any “biomass” removal should also be designated as “subject to agreement” in the contract. There is 6-9 not enough value in the material removed to “require” biomass removal. Biomass will be removed if it is economically viable to do so.
The Flat project proposes to implement 46,728 acres of prescribed burning. This does not appear to be a realistic goal since as of December 2016, the Malheur National Forest had over 300,000 acres of burning 6-10 waiting to be implemented. Given the number of both imposed and natural restrictions on prescribed burning it would be appropriate to provide some alternative methods of accomplishing fuels reduction.
AFRC advocates allowing as much flexibility as possible within the contract while still meeting the management goals and guidelines contained in the NEPA document. This flexibility allows the purchaser to use the most economically viable systems thus the ability to pay higher stumpage rates. 6-11 Placing restrictions on the specific machinery to be used severely impacts the economic viability of the timber sale while not improving the end result. Descriptions should be limited to “ground based” or “cable” with a description of the objectives and outcomes desired. Locking in the specific type of logging system in the NEPA document removes flexibility during the implementation stage.
Riparian habitat conservation areas (RHCA) must be treated to return them to the desired conditions. Commercially valuable material that is cut in the RHCAs should be removed to help pay for the project 6-12 and other restoration work in the area. Please work with forest industry to identify suitable methods of removing this material.
Contractual design and packaging on Flat should be as flexible as possible. It is critical that industry 6-13 be allowed to develop and provide plans to suitably meet objectives and implement projects to make them more cost effective.
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Established road infrastructure provides access for fire and future management. Decommissioning roads is not appropriate. Please find methods of mitigating the impacts of established roads that 6-14 do not require formal decommissioning and allow for re-opening in the future.
Humans are an integral part of the ecological process regardless of what the forest plan says. 6-15 Please see the attached article discussing the influences humans have had on the environment for over 10,000 years.
Project design criteria do not belong in the environmental assessment document. Reprinting your 6-16 contracts in these documents is not appropriate. Please provide these in an appendix or incorporate by reference.
I look forward to the decision on the Flat project, which has the potential to provide significant ecological, social and ecological benefits to the local area and the region. Please feel free to contact me if I can assist you with determining the economic feasibility of silviculture treatments and logging system requirements.
Sincerely,
Irene K. Jerome AFRC Consultant 408 SE Hillcrest Rd John Day, OR 97845
enc
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Responses to Comment Letter #6
Response to Comment 6-1: The EA uses best available science. The Final EA at 1-8 states “Studies completed at the Starkey Experimental Station since the Forest Plan was established suggest that the energetic benefits of cover may be inconsequential to elk performance, and that forage or nutritional effects may have the greater impact on individual animal performance (Cook 1998). However, these studies do not dispute elk’s preference for dense forest stands or the numerous studies that show elk using dense stands disproportionately to their availability. Dense conifer stands can contribute to better distribution of elk across available habitat, but this may be more of a disturbance or security issue than a thermal regulation issue.” Additionally, Forest Plan standards need to be considered.
Response to Comment 6-2: Thank you, the Final EA has been revised.
Response to Comment 6-3: In the U21 aspen treatment areas, no trees 21 inches or greater would be cut or girdled. Aspen stands are for the most part associated with RHCAs (Riparian Habitat Conservation Areas). Any activities in RHCAs must show that they will not retard RMOs (Riparian Management Objectives). By creating snags and downed wood in aspen stands, we would not be retarding RMOs.
Response to Comment 6-4: The term biomass in this document is defined as “Harvesting the wood product obtained as lumber or from in-woods chipping of all or some portion of trees including limps, tops, and unmerchantable stems.” Final EA at 1-1.
Response to Comment 6-5: Refer to the response to Comment 6-4.
Response to Comment 6-6: The project silviculturist has determined there is no biological need to remove trees greater than 21 inches within 30 feet of curl-leaf mountain mahogany patches. With regards to treating trees greater than 21 inches in aspen stands, refer to the Aspen treatment U30 in the EA, Chapter 2 at 2-7. PNW-GTR-806 is cited in the EA. Refer also to the aspen section of the Final EA, Chapter 3 at 3-16 and 3- 26.
Response to Comment 6-7: Thank you for your comment.
Response to Comment 6-8: “Removal of created biomass for commercial purposes” is not required in this treatment. That is only written in as an option in case of future expansion of the biomass market. It is highly unlikely that we would ever consider making biomass removal mandatory on steep ground when you consider the large amount of biomass that could first be taken from more gradual terrain. In future planning I will consider removing this option all together for harvest treatments on steep slopes.
“Skips and Gaps” are required for every 25 acres harvested only when the entire harvest unit is greater than 50 acres. Currently planned harvests on steep ground only includes 249
Flat Project Comment Analysis one unit over 50 acres, thus limiting the number of required skips and gaps for harvest on steep slopes. Furthermore, when restoring larger chunks of contiguous ground (> 50 acres) we still need create structural heterogeneity to mimic reference conditions regardless of the slope percentage.
Response to Comment 6-9: Contract specifications are outside the scope of this NEPA document. The Final EA, Chapter 2 page 2-3 states “Thinning activities would be accomplished using chainsaws or ground-based equipment to cut and either skid biomass to be utilized or piled. The intent is to remove created biomass from the site. However, some biomass may be piled (machine and/or hand piled) and burned or occasionally lopped and scattered and in areas of light fuel concentrations may be jackpot burned.”
Response to Comment 6-10: Fuels reduction would be accomplished both mechanically and through the use of prescribed fire. Future budgets are outside the scope of this document.
Response to Comment 6-11: Contract specifications are outside the scope of this NEPA document.
Response to Comment 6-12: Any activities in RHCAs must show that they will not retard RMOs (Riparian Management Objectives).
Response to Comment 6-13: Contract specifications and design are outside the scope of this NEPA document.
Response to Comment 6-14: Roads that are proposed for decommissioning have been determined as not needed for future management. FSM 7703.25 states “Unauthorized roads, temporary roads, and any NFS roads no longer needed for the use and management of NFS lands should be decommissioned.”
Response to Comment 6-15: This is outside the scope of this document
Response to Comment 6-16: Project design criteria can easily be included in the EA or an appendix to the EA. They are included in the EA, Chapter 2 because of their importance.
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Comment Letter #7 – King Williams, King Inc.
King Inc PO Box 3310 John Day, Oregon 97845 541-575-0597 [email protected]
July 19, 2017 Christy Cheyne District Ranger Emigrant Creek Ranger District 265 Hwy 20 South Hines, OR 97738
Re: Comments on Flat Vegetation Management Project Preliminary Environmental Assessment
Dear Christy,
7-1 King Inc herein provides the following comments on the Flat Project Preliminary Environmental Assessment.
Alternative 2 (Proposed Action)
Page 2-3 under “Vegetation Treatments” it states that harvest-generated logging slash will either be machine and/or hand piled and burned in the unit where cut-to-length (CTL) logging systems are used. We have been discussing at length in both collaborative groups on the Malheur how to make dollars go further. We have taken several tours to treated units where CTL systems were used to discuss the possibility of allowing for a little more slash to be left behind on the landscape and burned with prescribed fire. This would allow, under the right circumstances, savings on piling and possibly PCT as fire could carry and provide the heterogeneity we are looking for while not spending the extra money on those interim steps. A “park like” finished product is not necessary to achieve the outcomes we are looking for and may allow us to treat more acres with the money generated from timber sales as well as appropriated dollars. Similar wording occurs in the next bullet down with respect to “thinning activities”.
In all sections pertaining to commercial harvest we would ask that the size limit for units where skips and patches would not be required be increased to 100 acres. Again, we have discussed this at length on field trips. With the amount of “untreated acres” in this project, and the desire for heterogeneity it seems like we are attempting to get everything we want on every acre. We would like to see us treat the acres we are treating and allow the leave patches to be taken care of in all the other acres that for one reason or another (rhca’s, wildlife corridors, nest patches, steep slopes, rocky areas, etc.) are left untreated. In reality, there will be acres in some units that are 251
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skipped for various reasons based upon on the ground situations so often this will be taken care of anyway.
We commend the Silviculture staff providing for variability with the commercially treated stands and making the basal area range from 30-120 sq. ft. with an average of 40 sq. ft.
On page 2-13 under “past road closures” the document states that previously closed or decommissioned roads would be monitored for effectiveness and if the closure or decommission is determined to be not effective, then the closure/decommission would be reinforced. As with previous projects, we would ask that if analysis is being done under this document to authorize the closure or decommissioning then an option should also be to re-open the road if it is found to be a well-used road that is not causing hydrologic function issues.
Page 2-20 under “design criteria for protection of wildlife resources” seasonal restrictions for goshawk nests is stated as March 1-September 30. We realize that it says “generally” but it is our understanding that the Forest wildlife biologist has signed a document to narrow those restrictions to April 1-August 31. A clarification of this topic would be appreciated.
Economics:
On page 3-197 under the heading “Effects on Timber Sale Economics” it states that the species composition of the sale is 45 percent Ponderosa Pine and 55 percent Douglas-Fir and other species for the sale as a whole. We would not question this assertion, but comment that the difference in economic value between Douglas-fir and white-fir is significant and therefore it would be helpful to know what the breakout is between those two (2) species as well. Logic would say that the Douglas-fir being named would infer that it’s the dominate species of the “other species” but from the little time I have spent on the project, I would actually think that white-fir is more than likely the dominant “other species.”
Respectfully,
/signed by King
King Williams, President King Inc
Responses to Comment Letter #7
Response to Comment 7-1: This comment letter is identical to Comment Letter #4. Please refer to the responses to Comment Letter 4.
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Comment Letter #8 – Doug Heiken, Oregon Wild
21 July 2017
TO: [email protected]; [email protected]
Subject: Flat Project Preliminary Environmental Assessment — comments
Dear Forest Service:
Please accept the following comments from Oregon Wild concerning the Flat Project Preliminary Environmental Assessment, https://www.fs.usda.gov/project/?project=47364. These comments supplement our detailed scoping comments which remain largely unaddressed. Oregon Wild represents 20,000 members and supporters who share our mission to protect and restore Oregon’s wildlands, wildlife, and water as an enduring legacy. Our goal is to protect areas that remain intact while striving to restore areas that have been degraded. This can be accomplished by moving over-represented ecosystem elements (such as logged and roaded areas) toward characteristics that are currently under-represented (such as roadless areas and complex old forest).
The proposed action alternative involves: o 9,005 acres of “treatments” in stands that have never been logged o 2,642 acres of “treatments” directly affecting unroaded areas larger than 1,000 acres o 4,162 acres “stand improvement” commercial thin - variable 30-120 ft2 basal area retained (avg 40 ft2), 2-acre skips and gaps o 11,755 acres “stand improvement” biomass thin - free thinning below 21” dbh, favoring Ponderosa pine and larch, variable 30-120 ft2 basal area retained (avg 40 ft2), 2-acre skips and gaps o 3,690 acres conifer encroachment treatment – remove non-old growth juniper and all conifers <21” dbh in non-forested areas o 2,166 acres Lodgepole treatments – lodgepole smaller than 21” dbh would be removed, ppine >18” dbh would be retained, o 1,386 acres aspen restoration – 99 acres U10, 356 acres U21, 943 acres U30 (“All conifer trees up to 20.9” DBH would be cut. Conifer trees between 21” and 30” DBH would first be converted to snags and down wood to meet forest plan standards, then any excess trees would be available to be removed and utilized as biomass. Conifers greater than 30” DBH would not be cut.”)
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o 1,923 acres LOS “enhancement” – free thinning below 21” dbh, favoring Ponderosa pine and larch, variable 30-120 ft2 basal area retained (avg 40 ft2), 2-acre skips and gaps o 949 acres RHCA treatment – treated “according to the prescription of the adjacent vegetation treatment” but retaining basal area at the higher end of the range o 185 acres of logging on slopes >35% o 210 acres old growth “enhancement” - variable 40-120 ft2 basal area retained (avg 60 ft2), retain two >16” dbh replacement ppine tree for each existing tree with OG character, o 789 acres of Replacement OG designated o 234 acres of pileated woodpecker feeding areas designated o 46,728 acres landscape prescribed fire, expecting 70% affected by fire o All juniper that does not exhibit old growth characteristics would be cut in all treatment units. o Biomass would be skidded out of units. o 8 miles of new temporary roads o 42.8 miles of Roads closed o 3.2 miles of roads decommissioned o 1.8 miles of closed roads reopened and left open o 60.5 miles of closed roads reopened, then reclosed o Plan amendments will be required to: o Remove large trees 21-30” dbh in and near aspen stands o Reduce Big Game Summer Range and Winter Range Cover below Forest Plan Standards, o Designate replacement old growth and pileated woodpecker feeding areas
We support the road closures, the removal of small young trees that are encroach on meadows and encroaching in aspen stands and under legacy trees, but overall this project reduces stand density too aggressively. We agree that white-headed woodpeckers need some more open pine stands for nesting but many other sensitive wildlife rely on more dense forest. Even white- headed woodpecker use dense forest for foraging. This large project goes too far in pushing a large fraction of the landscape toward low density conditions.
Purpose and Need
The FS should adopt purpose and need to comply with the LRMP as amended by the Eastside 8-1 Screens. What’s the point of having a forest plan if you are not going to follow it?
The FS obviously ants to aggressively reduce stand density, but the agency has not explained 8-2 why it is so important to reduce conifer density at the expanse of big game and snag associated species. These trade-offs are significant.
The EA says the purposes of this project include: • Improve vegetation resilience and resistance to insects, disease and wildfire • Increase the diversity and structure of forest vegetation communities
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These are vague purposes that do not lend themselves to clear management objectives. Insects, disease, and wildfire are natural processes that help create diverse landscapes. Managing against these natural features of the ecosystem could causes problems. EA (p 3-79) admits “Direct and Indirect Effects of the Action Alternatives to Black-Backed and Three-Toed Woodpeckers. These species are dependent on fire to create a pulse of insect outbreaks for foraging.” And EA (p 3-90) “High pulse of snags from a stand replacement fire would benefit fire dependent cavity excavators and secondary cavity nesters such as bluebirds ...” So the Forest Service is managing against natural mortality processes that create desired habitat resiliency for native wildlife. This makes no sense.
It is not clear that the proposed large-scale logging will achieve the intended goals. Logging can make fire hazard worse by making the forest hotter, dryer, windier, creating lots of dangerous 8-3 slash, and by stimulating the growth of future ladder fuels. Logging will degrade forest structure by significantly reducing recruitment of snags and dead wood over the long term.
Maintaining resilience requires more respect for the natural processes that kill trees. When humans kill trees they are being selected for traits unrelated to evolutionary fitness. To achieve the FS purposes related to resilience, the FS needs to retain and restore genetic diversity of trees.
Natural mortality from drought, insects, and fire have shaped the genetic make-up of the forest for millennia, favoring more fit individuals and increasing the resilience of forest stands. Logging is a novel cause of mortality that does not favor the fittest individuals. The agency must carefully consider the consequences of logging that decouples mortality from fitness, survival and resilience.
The agency must recognize that natural mortality provides an important ecological function – that is, it promotes evolutionary adaptation which is critical right now in the face of climate change.
[R]esearchers were surprised to find that the mortality of established trees considerably promotes the adaptation of forests to the changing environment. … Evolution is promoted by the mortality of established trees. The researchers assumed that demographic characteristics of the trees would have a notable impact on their adaptability. Tree species differ for example so that birch matures at a considerably younger age than pine, and birch seeds spread more effectively than pine seeds. However, the results showed that these differences had only minor impacts. Instead, the mortality of established trees played a large role in the evolutionary adaptation.
Northern forests do not benefit from lengthening growing season. UNIVERSITY OF HELSINKI. PUBLIC RELEASE: 12-JAN-2010. http://www.eurekalert.org/pub_releases/2010- 01/uoh-nfd011210.php.
Importantly, for natural selection to occur, mortality must be caused by natural events like drought, insects, and fire, rather than through human choices about which trees will live and which will die.
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Biologist Derek Lee points out that … logging schemes are the latest in a series of Forest Service attempts to chainsaw their way out of a perceived problem. However, forests in the western United States have evolved to naturally self-thin uncompetitive trees through forest fires, insects, or disease. Forest fires and other disturbances are natural elements of healthy, dynamic forest ecosystems, and have been for millennia. These processes cull the weak and make room for the continued growth and reproduction of stronger, climate-adapted trees. Remaining live trees are genetically adapted to survive the new climate conditions and their offspring are also more climate-adapted, resistant, and resilient than the trees that perished. Without genetic testing of every tree in the forest, indiscriminate thinning will remove many of the trees that are intrinsically the best-adapted to naturally survive drought, fire, and insects. Derek Lee. January 14, 2017. Blog post: Proposed Forest Thinning Will Sabotage Natural Forest Climate Adaptation and Resistance to Drought, Fire, and Insect Outbreaks. http://dereklee.scienceblog.com/34/proposed-forest-thinning-will-sabotage-natural-forest- climate-adaptation-and-resistance-to-drought-fire-and-insect-outbreaks/
The bottom line is that nature does a good job of picking trees that are fit for survival in a stressful world. Foresters cannot predict which trees will survive drought and insects, so they will kill some trees that are relatively more fit and retain trees that are relatively less fit. This indicates that natural mortality will lead to greater forest resilience, while logging will lead to reduced forest resilience.
e360: So by trying to fix the problem, we sometimes only make it worse. Six: As humans, we have this feeling that if something goes awry, we need to fix it, and that somehow we can. I don’t think that we necessarily always know what needs to be done, or that when we do apply management that we are always actually doing the right thing. Sometimes we just need to realize that nature can sort itself out perhaps better than we can. … [M]odels assume that the forest is genetically homogenous, that everything is the same. And they are not. I suspect that there is a lot more genetic variability out there that will allow for more adaptation and greater persistence than we currently anticipate.
e360: You are suggesting that evolution will kick in and help to a degree? Six: If we let it. If we don’t go out and replant with stock that may not be genetically correct, if we don’t thin or cut down trees that may have been selected by beetles or drought to survive. We have to get smart about how we are treating our forest if we’re going to help nature’s process of adaptation to proceed. Richard Shiffman interview with Diana Six. 04 JAN 2016: INTERVIEW- How Science Can Help to Halt The Western Bark Beetle Plague http://e360.yale.edu/content/feature.msp?id=2944
George Wuerthner often reminds public land managers that
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… there is significant genetic variation in individual trees, and thinning the forest can reduce the genetic diversity of the remaining stand, in effect, reducing its "resilience" and the ability of the forest ecosystem to adapt to changing conditions. [Studies] show that ponderosa pine seedlings have tremendous variation in their adaptation to drought and mature trees ability to fend off bark beetles. Under natural conditions, the beetles and drought would [selectively] eliminate the trees without these adaptations. But the average forester with his or her paint gun marking trees has no idea of the genetic makeup of the trees they are logging. Yet I do not even hear any sense of caution from the collaborative about this matter. They are of the belief that logging creates resilience. In fact, it impoverishes the forest ecosystem. Wuerthner, George. 3-28-2017 Email to Deschutes Collaborative via Vernita Ediger, citing Kolb, T.E., Grady, K.C., McEttrick, M.P., and A. Herrero 2017. Local-Scale Drought Adaptation of Ponderosa Pine Seedlings at Habitat Ecotones. For. Sci. 62(6), pp.641-651. http://dx.doi.org/10.5849/forsci.16-049 (“The large amount of phenotypic variation within populations suggests the potential for future evolution of stress tolerance…”) and Pinnell, Sean, 2016. MS Thesis: "Resin Duct Defenses In Ponderosa Pine During A Mountain Pine Beetle Outbreak: Genetic Effects, Mortality, And Relationships With Growth" (2016). Paper 10709. http://scholarworks.umt.edu/cgi/viewcontent.cgi?article=11753&context=etd. (“Analyses at both the phenotypic and genetic levels indicated that drought significantly predisposed some trees and families to mortality …”).
Note also, Pinnell (2016) found that fast growing trees are not necessarily more fit to survive drought and insects. (“I found no evidence of a resin duct defense-growth tradeoff. … [F]aster growing families did not suffer lower mortality.”) Foresters often identify stands for thinning based on their growth rate as measured by annual growth rings/inch, and they identify trees for retention based on observed vigor and form. This study indicates that these factors may not be associated with resistance to mortality. Again, foresters think they are improving forest resilience, but they may be removing trees that are more fit, and retaining trees that are less fit, leaving more ill-fitting genes in the stand to reproduce and leaving the stand less resilient over the long term.
Basal Area Retention
Most acres will be reduced to an average of 40 ft2 basal area which is not enough to sustain all the important values associated with these public forests, including wildlife habitat for many species associated with large unfragmented blocks, dense complex forests, recruitment of large trees and snags over the long term; watershed integrity; carbon storage/climate stability; etc.
Basal Area retention is an important ecological consideration that must be disclosed quantitatively in the NEPA analysis. The NEPA analysis should disclose basal area retention levels that provide assurance that enough trees are being retained to meet ecological needs for live and dead trees now and in the future.
Where there are lots of small trees we recommend variable density thinning to 60-80 sq ft/acre basal area, retaining the largest trees that will become the next generation of old growth. Since
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larger trees have a higher ratio of basal area to leaf area, sites with abundant large trees can sustain higher basal areas, and we recommend retaining 100-140+ sq ft/acre.
Basal area retention should be variable but not be too low in any one unit. Enough trees need to be retained to retain and recruit large and old trees and snags now and in the future. Basal area targets should be adjusted higher to account for the following actors: • Prescribed basal area retention should be weighted to accommodate relatively greater retention in stands with large trees and desirable clumps of trees that contribute to LOS structural conditions. • All things being equal, large and old trees are more sustainable and resilient than small trees, so where large and old trees are abundant, the site can sustain higher basal area and the mature and old trees do not need to be thinned. • Retention patches should be excluded from the basal area calculation. Basal area should not be averaged across the stand, but rather across the treated portion of the stand. We recommended 3-4 clumps per acre of 2-10 individual trees as well as the skips to emulate natural historic stand structures. • Basal area can be higher in riparian areas, area with higher water table, north slopes, etc...
The agency should avoid reducing stand density lower than is appropriate to meet the full suite of ecological objectives, including wildlife cover, perpetuating mortality processes that create and sustain valuable habitat features, etc.
We are concerned that the agencies’ stocking guides were created and intended to be used as a tool to avoid mortality which is clearly inconsistent with ecosystem management. (“To preclude serious tree mortality from mountain pine beetle, western dwarf mistletoe and perhaps western pine beetle, stand densities should be maintained below the upper limit of the management zone” Powell 1999, https://fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev7_016034.pdf) Healthy forests require dead trees, sometimes in abundance, in order to meet the needs of diverse wildlife and provide full suite of ecosystem functions. Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., Waddell, K.L., Lindely, D.L., and B. Schrieber. 2001. Decaying Wood in Pacific Northwest Forests: Concepts and Tools for Habitat Management, Chapter 24 in Wildlife-Habitat Relationships in Oregon and Washington (Johnson, D. H. and T. A. O’Neil. OSU Press. 2001) http://web.archive.org/web/20060708035905/http://www.nwhi.org/inc/data/GISdata/docs/chapte r24.pdf
A comprehensive restoration approach requires focusing not just on live trees, but also on the full suite of ecological processes including density dependent mortality processes that create and recruit snags and dead trees as a valuable feature of eastside forests. We urge the agency not to manage for tree vigor and minimum stocking levels because it will not provide enough green trees for recruitment of snags through time. This is a critical issue given that the current standards for snag habitat are outdated and fail to provide adequate levels of snags and dead wood, and adequate levels of green trees needed to recruit those snags through time.
Cutting basal area down to 30-40 ft2/acre is too low. We urge the agency to retain at least 60-120 8-4 ft2/acre of basal area. 30-40 ft2/acre might be OK in small patches within units as part of a
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variable prescription, but the average over a unit must be much higher than that in order to ensure adequate cover for wildlife, and adequate dead wood recruitment through time.
Weak Relationship Between Stand Density and Forest Health or Resilience
The relationship between stand density and mortality may be intuitively appealing but is not well-supported by the evidence. Recent comments from the Center for Biological Diversity to the California Department of Forestry explained -- A study in the Douglas fir forests of northeastern Washington found that competition [i.e., higher density] did not affect tree responses to extreme drought. Importantly, trees with more competition from neighbors appeared to have higher drought resistance (i.e., a significantly higher proportion of sapwood area in latewood, which is a trait associated with drought resistance). The authors suggested that “a tree’s ability to cope with environmental variability is driven not just by the proximate effects of neighbours on resource availability, but also by phenotypic plasticity and long-term adaptations to competitive stress.”
A study that directly investigated the lack of fire on the physiological status of oldgrowth ponderosa pine trees in unlogged forests in Idaho found that, contrary to predictions, oldgrowth trees in stands that were unburned for at least 70 years showed no significant differences in multiple stress indicators compared to non-fire-suppressed stands, indicating that these trees may be “more resilient to increased stand density associated with the lack of fire than previously thought.” Center for Biological Diversity et al., March 17, 2017 comments on the California Forest Carbon Plan (January 20, 2017 Draft). http://www.biologicaldiversity.org/campaigns/debunking_the_biomass_myth/pdfs/Forest_Carbo n_Plan_Comments.pdf citing Carnwath, G.C. and C.R. Nelson. 2016. The effect of competition on response to drought and interannual climate variability of a dominant conifer tree of western North America. Journal of Ecology 104: 1421-1431, and Keeling, E.G. et al. 2011. Lack of fire has limited physiological impact on old-growth ponderosa pine in dry montane forests of north- central Idaho. Ecological Applications 21: 3227-3237.
The CBD comments cited above provided several useful excerpts from the literature-- Recent studies of epidemic forest mortality events have not found stand density to be a significant contributor to tree death and instead, have attributed forest declines to the effects of top-down drivers such as moisture stress and drought, and associated spread and proliferation of bark beetle populations (Ganey and Vojta, 2011; Lines et al., 2010; Sánchez-Martínez and Wagner, 2002; van Mantgem and Stephenson, 2007). During episodic forest mortality events, the role of site environment, spatial proximity and landscape configuration can become more important than stand characteristics for predicting mortality patterns (MacQuarrie and Cooke, 2011; Powers et al., 1999; Simard et al., 2012). Differences in the importance of tree vigor and spatial aggregation may help explain why hazard ratings based on stand characteristics have little predictive power when applied to landscapes (Logan et al., 1998; Nelson et al., 2007). A comprehensive understanding of the role of density dependence during both epidemic and non-epidemic (‘‘background”) mortality periods remains elusive (Stamp, 2003).
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Van Gunst, K.J. et al. 2016. Do denser forests have greater risk of tree mortality: a remote sensing analysis of density-dependent forest mortality. Forest Ecology and Management 359: 19- 32.
Recent findings that stands with higher density do not necessarily exhibit greater physiological stress (Keeling, Sala & DeLuca 2011) or experience lower tree mortality in extreme drought events (e.g. Floyd et al. 2009; van Mantgem et al. 2009; Ganey & Vojita 2011) lend support to this idea but other studies have shown the opposite relationship between density and mortality (Negron et al. 2009; Kane & Kolb 2014) or that this relationship is inconsistent and context dependent (Meddens et al. 2015; Van Gunst et al. 2016). Carnwath, G.C. and C.R. Nelson. 2016. The effect of competition on response to drought and interannual climate variability of a dominant conifer tree of western North America. Journal of Ecology 104: 1421-1431.
However, the available evidence suggests that density-dependent mortality is not as typical of old and large tree subpopulations in conifer forests (Acker et al., 1996; Das et al., 2011; Aakala et al., 2012; Silver et al., 2013; Larson et al., 2015) as it is in the smaller size classes (Das et al., 2011; Lutz et al., 2014). Clyatt, K.A. et al. 2016. Historical spatial patterns and contemporary tree mortality in dry mixed- conifer forests. Forest Ecology and Management 361: 23-37.
Better to Rely on Fire Rather Than Mechanical Fuel Reduction
The agencies are moving across the landscape aggressively managing fuels and reducing stand density which causes significant cumulative impacts on soil, water, wildlife habitat, carbon storage, and other values. These public resources are now exposed to the unprecedented compound effects of both logging and fire. The agency thinks it has found great alignment between its desire for timber production, risk reduction, and other restoration goals, but this view is just too convenient. It requires constant validation and reassessment. The view that everything aligns may be hiding significant trade-offs and causing the agency to overlook other viable options, such as decreasing reliance on logging and increasing reliance on fire as tools for forest management. The accumulation of evidence does not support logging for fuel reduction as a sound strategy to manage fuel and fire. • Only a small fraction of needed density reduction can support an economically viable timber sale. See Rainville, Robert; White, Rachel; Barbour, Jamie, tech. eds. 2008. Assessment of timber availability from forest restoration within the Blue Mountains of Oregon. Gen. Tech. Rep. PNW-GTR-752. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 65 p. http://www.fs.fed.us/pnw/pubs/pnw_gtr752.pdf (“Hoping to boost their economies and also restore these forests, local leaders are interested in the economic value of timber that might be available from thinning treatments on these lands. … [W]e found that on lands where active forestry is allowable, thinning of most densely stocked stands would not be economically viable.”) • Removing commercial sized logs as part of fuel reduction degrades habitat while doing little to modify fire behavior. If conducted at large scales, the effects of commercial logging for fuel reduction will be socially and ecologically unacceptable. Lehmkuhl, John; Gaines,
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William; Peterson, Dave W.; Bailey, John; Youngblood, Andrew, tech. eds. 2015. Silviculture and monitoring guidelines for integrating restoration of dry mixed-conifer forest and spotted owl habitat management in the eastern Cascade Range. Gen. Tech. Rep. PNW- GTR-915. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 158 p. http://www.fs.fed.us/pnw/pubs/pnw_gtr915.pdf. (“Tradeoffs between fire resistance and NSO habitat quality are real. Our results demonstrate that balancing the goals of increasing fire resilience while maintaining habitat function, especially nesting and roosting, for the NSO in the same individual stand is a difficult, if not an impossible, task. Even lighter thinning treatments typically reduce canopy cover below 40 percent. The reality is that nesting and roosting NSO habitat is by definition very susceptible to high-severity fire; owl habitat value and fire risk are in direct conflict on any given acre. …”); • Most fires are climate driven, rather than fuel driven. The warming climate is likely to make this effect even more pronounced. Schoennagel et al 2017. Adapt to more wildfire in western North American forests as climate changes. PNAS 2017; published ahead of print April 17, 2017. www.pnas.org/cgi/doi/10.1073/pnas.1617464114; https://headwaterseconomics.org/wp-content/uploads/Adapt_To_More_Wildfire.pdf; Odion, D.C. et al 2014. Examining Historical and Current Mixed-Severity Fire Regimes in Ponderosa Pine and Mixed-Conifer Forests of Western North America. PLOS One. February 2014 | Volume 9 | Issue 2 http://www.californiachaparral.org/images/Odion_et_al_Historical_Current_Fire_Regimes_ mixed_conifer_2014.pdf; See also, Alisa Keyser and Anthony Westerling, 2017. Climate drives inter-annual variability in probability of high severity fire occurrence in the western United States, Environmental Research Letters. Accepted Manuscript online 4 April 2017 https://doi.org/10.1088/1748-9326/aa6b10. • There is a low probability that fuel treatments will interact with wildfire. William L. Baker, Jonathan J. Rhodes. 2008. Fire Probability, Fuel Treatment Effectiveness and Ecological Tradeoffs in Western U.S. Public Forests. pp.1-7 (7). The Open Forest Science Journal, Volume 1. 2008. http://api.ning.com/files/1kp0vDW*F1cqOeO4- GdXE1AHOATghmIAN2x9qLpH3aA_/FireandFuelTreatments.pdf; • The effects of fuel reduction are modest. Even extensive fuel reduction reduces the extent of wildfire by less than 10 percent. See M. A. Cochrane, C. J. Moran, M. C. Wimberly, A. D. Baer, M. A. Finney, K. L. Beckendorf, J. Eidenshink, and Z. Zhu. 2012. Estimation of wildfire size and risk changes due to fuels treatments. International Journal of Wildland Fire. http://dx.doi.org/10.1071/WF11079. http://www.publish.csiro.au/?act=view_file&file_ id=WF11079.pdf. • Commercial logging will often make fire hazard worse, not better. Reducing the forest canopy will make the stand hotter, dryer, and windier, produce more activity fuels, and stimulate the growth of ladder fuels. Jain, Theresa B.; Battaglia, Mike A.; Han, Han-Sup; Graham, Russell T.; Keyes, Christopher R.; Fried, Jeremy S.; Sandquist, Jonathan E. 2012. A comprehensive guide to fuel management practices for dry mixed conifer forests in the northwestern United States. USDA Forest Service Gen. Tech. Rep. RMRS-GTR-292. 2012 http://www.firescience.gov/projects/09-2-01-16/project/09-2-01-16_09-2-01- 16_rmrs_gtr292web.pdf.
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• There are still a lot of good reasons to maintain forest density – to provide habitat for a wide variety of wildlife that prefer relatively dense forests and abundant dead wood habitat, to store carbon, to protect soil and watershed values, etc.
Considering all of this, forest managers need to recognize that they cannot log their way out of the fuel predicament they are in. Forest managers will eventually come to realize that the vast majority of the ecological work will be accomplished by wild and prescribed fire.
Oregon Wild supports the objective of preparing the forest for wildfire, but this does not mean that extensive logging is required. Preparing for fire can often be done best by applying 8-5 prescribed fire at the appropriate time, when the weather and fuels are relatively cool and moist. Fire is preferable because it has a lighter ecological footprint on soil, water, and large wood habitat.
Schoennagel et al (2017) make a compelling case for a new approach to managing fire and fuel with a greater emphasis on using wild and prescribed fire instead of mechanical fuel reduction. Key aspects of an adaptive resilience approach are (i) recognizing that fuels reduction cannot alter regional wildfire trends; (ii) targeting fuels reduction to increase adaptation by some ecosystems and residential communities to more frequent fire; (iii) actively managing more wild and prescribed fires with a range of severities; and (iv) incentivizing and planning residential development to withstand inevitable wildfire. … Managing ecosystems, people, and wildfire in a changing climate is a complex but critical challenge that requires effective and innovative policy strategies. Our key message is that wildfire policy and management require a new paradigm that hinges on the critical need to adapt to inevitably more fire in the West in the coming decades. … Three primary factors have produced gradual but significant change across western North American landscapes in recent decades: the warming and drying climate, the build-up of fuels, and the expansion of the wildland–urban interface. … Increasing the use of prescribed fires and managing rather than aggressively suppressing wildland fires can promote adaptive resilience as the climate continues to warm. … Strategic planning for more managed and uncontrolled wild fires on the landscape today may help decrease the proportion of large and severe wildfires in the coming decades and may enhance adaptive resilience to changing climate. Prescribed fires, ignited under cooler and moister conditions than are typical of most wildfires, can reduce fuels and minimize the risk of uncontrolled forest wildfire near communities. In contrast to wildfires, prescribed fire risks are relatively low, and more than 99% of prescribed fires are held within planned perimeters successfully. … We need to develop a new fire culture. Despite these and various legal and operational challenges, the benefits of prescribed fire and managed wildfires to ecosystems and communities are high. Promoting more wildfire away from people and prescribed fires near people and the WUI are important steps toward augmenting the adaptive resilience of ecosystems and society to increasing wildfire. … [T]he effectiveness of this [fuel reduction] approach at broad scales is limited. Mechanical fuels treatments on US federal lands over the last 15 y (2001–2015) totaled almost 7 million ha (Forests and Rangelands, https://www.forestsandrangelands.gov/), but the annual area burned has continued to set records. Regionally, the area treated has little relationship to trends in the area burned, which is influenced primarily by patterns of
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drought and warming. Forested areas considerably exceed the area treated, so it is relatively rare that treatments encounter wildfire. … [R]oughly 1% of US Forest Service forest treatments experience wildfire each year, on average. The effectiveness of forest treatments lasts about 10–20 y, suggesting that most treatments have little influence on wildfire. … [T]he prospects for forest fuels treatments to promote adaptive resilience to wildfire at broad scales, by regionally reducing trends in area burned or burn severity, are fairly limited. … Home loss to wildfire is a local event, dependent on structural fuels (e.g., building material) and nearby vegetative fuels. Therefore, fuels management for home and community protection will be most effective closest to homes, which usually are on private land in the WUI where ignition probabilities are likely to be high. … The majority of home building on fire-prone lands occurs in large part because incentives are misaligned, where risks are taken by homeowners and communities but others bear much of the cost if things go wrong. Therefore, getting incentives right is essential, with negative financial consequences for land-management decisions that increase risk and positive financial rewards for decisions that reduce risk. … Schoennagel et al 2017. Adapt to more wildfire in western North American forests as climate changes. PNAS 2017; published ahead of print April 17, 2017. www.pnas.org/cgi/doi/10.1073/pnas.1617464114; https://headwaterseconomics.org/wp- content/uploads/Adapt_To_More_Wildfire.pdf
Wildfire policy is costly and complex. In an effort to provide context and promote effective and comprehensive policy discussions, ten wildfire experts from across the West came together to help link relevant science to ongoing debates about why so much of the West has been burning, and what policies and solutions may help deter the rising costs and risks of wildfire.
The paper presents seven key insights from wildfire science that should inform future fire policy: 1) Fire size and frequency will increase under a warmer and drier climate 2) Fuel reduction on federal lands will do little to reduce acreage burned and homes lost 3) Not all forests need restoration 4) High-severity fires often have ecological benefits 5) Insect outbreaks do not necessarily make fires worse 6) Land-use planning can reduce wildfire risk 7) Managing more fires to burn safely can reduce risk and increase ecological benefit … Because fire is a mechanism of ecological renewal and diversity, allowing space and time for fire-adapted forests and shrublands to burn and recover from fire is important to maintain the landscapes we and other species depend on. Given the natural role of fire in the West, managing prescribed and naturally ignited fires to burn will help reduce future wildfire threats and increase ecological benefits in many systems. Better fire and forest management is part of the solution, but the most effective changes in terms of protection of people and property, will be near homes and on private property. Fire-smart land-use planning, building, and landscaping are essential to creating fire-adapted communities that can survive and thrive despite inevitable wildfire.
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Tania Schoennagel, Penny Morgan, Jennifer Balch, Philip Dennison, Brian Harvey, Richard Hutto, Meg Krawchuk, Max Moritz, Ray Rasker, and Cathy Whitlock. 2016. Insights from wildfire science: A resource for fire policy discussions. January 2016. http://headwaterseconomics.org/wphw/wp-content/uploads/wildfire-insights-paper.pdf
Max A. Moritz, Enric Batllori, Ross A. Bradstock, A. Malcolm Gill, John Handmer, Paul F. Hessburg, Justin Leonard, Sarah McCaffrey, Dennis C. Odion, Tania Schoennagel & Alexandra D. Syphard. 2014. REVIEW: Learning to coexist with wildfire. NATURE | VOL 515 | 6 NOVEMBER 2014. doi:10.1038/nature13946
See also, Dominick A. DellaSala, Richard L. Hutto, Chad T. Hanson, Monica L. Bond, Timothy Ingalsbee, Dennis Odion, and William L. Baker. 2017. Accommodating Mixed-Severity Fire to Restore and Maintain Ecosystem Integrity With a Focus on the Sierra Nevada of California, USA. Fire Ecology in press. (“We discuss a fire management approach in the mid-elevations of the Sierra Nevada that may exemplify similar challenges in fire-adapted regions of the western USA. We also discuss how managing for pyrodiversity through mixed-severity fires can promote ecosystem integrity … At the coarse-filter level, pyrodiverse mixed-severity fires provide landscape heterogeneity. Species and ecosystem characteristics associated with pyrodiversity can be maintained or enhanced by accommodating moderately severe fires, which hasten restoration by recreating a complex vegetation mosaic otherwise at risk from suppression … Managers face substantial political and public pressure to suppress fires through the use of aggressive firefighting tactics, but such tactics do little to contain fires under extreme fire weather conditions (Lydersen et al. 2014, Moritz et al. 2014, Ingalsbee and Raja 2015, Carey et al. 2016). Instead, managers could be encouraged to use prescribed and naturally ignited fires that yield both cost savings and ecosystem benefits. … The ecosystem benefits of accommodating mixed- severity fires for ecosystem benefits pertain to both ends of the fire continuum: large fires with high-severity effects that generate unique biological pulses (e.g., complex structures) and lower- severity systems that may have been homogenized through management and suppression. This suggests an important opportunity for expanding fire management beyond traditional kinds of prescribed burning to include prescriptions that benefit a broader suite of species associated with pyrodiverse landscapes (Moritz et al. 2014, DellaSala and Hanson 2015, Moritz and Knowles 2016). … We argue that expanding natural fire ignitions for ecosystem benefits in combination with strategic use of defensible space, directed suppression, and active fuels management in appropriate areas provide untapped potential to enhance ecosystem integrity while protecting people and infrastructure with the potential for lower financial costs. Our approach is based on an ecological understanding of the importance of mixed-severity fires (DellaSala and Hanson 2015), and the need to reconsider “catastrophe” biases regarding natural disturbance processes (Lindenmayer et al. 2017).”)
Another benefit of increasing efforts to reintroduce fire in fire-dependent dry forests is that it may help stabilize carbon storage. Krofcheck, D. J., M. D. Hurteau, R. M. Scheller, and E. L. Loudermilk. 2017. Restoring surface fire stabilizes forest carbon under extreme fire weather in the Sierra Nevada. Ecosphere 8(1):e01663. 10.1002/ecs2.1663. http://onlinelibrary.wiley.com/doi/10.1002/ecs2.1663/pdf.
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There are many benefits that flow from restoration of fire regimes. Wildfire is positively associated with plant diversity and the ecoregional scale. “Fire regime is a primary factor explaining plant diversity around the globe, even after accounting for [site] productivity. Fires delay competitive exclusion, increase landscape heterogeneity and generate new niches; thus, they provide opportunities for a large variety of species.” Pausas JG, Ribeiro E. Fire and plant diversity at the global scale. Global Ecol Biogeogr. 2017;00:1– 9. https://doi.org/10.1111/geb.12596.
RHCA, Fish Habitat, Wood Recruitment,
EA (p 2-37) says “Redband trout would have short-term negative impacts but long-term beneficial impacts…” This is not supported by the evidence. Fish are generally adversely affected by both ground-disturbing activities that increase erosion and stream sedimentation, as 8-6 well as by removal of trees that serve a wide variety of hydrologic, geomorphic, thermodynamic, and biophysical functions, both as live trees and dead and down wood. The EA failed to take a hard look at the adverse effects of logging on fish.
Category 4 HCAs only get a 50 foot buffer and unlike in other parts of the state, there is not a dense network of small streams in this relatively dry landscape. So, why can’t the FS just leave them alone, or thin non-commercially? In addition to help watershed values, protecting RHCAs will help mitigate snag deficits and enhance landscape diversity.
We are concerned about logging in RHCAs, especially using the same prescriptions are adjacent uplands. Stream need abundant wood. Logging will “capture mortality” and deprive streams of the wood they need. Keep in mind that large wood is not the end-all and be-all. Small wood can be functional in small streams. “The effect that wood has on [fish] habitat is related to the size of the piece of wood relative to the channel size and gradient.” East Alsea Landscape Management Project – EA Appendix H - Fish BE, 4-18-2011. The NEPA analysis should therefore disclose the effects of logging not only on absolute size of wood but on the size of wood relative to stream size and gradient. Dead wood of all sizes is important to streams and riparian function. In small streams, small wood can even perform the ecological and hydrological functions normally thought to require large wood. If the goal of logging is to create large trees faster, the NEPA analysis should document the size, gradient, and other characteristics of streams adjacent to each logging area and determine the size of wood that can serve key ecological and hydrological functions, then disclose the effects of logging relative to those relevant wood sizes.
Looking at the total miles of streams, small streams dominate, therefore most logging takes place along small streams. BLM has admitted that small wood can be functional in small streams.
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BLM 2014. Planning Criteria - Western Oregon RMP Revisions, p 49. http://www.blm.gov/or/plans/rmpswesternoregon/plandocs.php
Rosenfeld & Huato (2003) found that large wood formed pools more reliably than small wood. Wood >24” dbh formed pools 42% of the time, while wood 6-12” dbh formed pools 6% of the time. However, from this one can conclude that the cumulative influence of several pieces of small wood can approach the pool-forming function of large wood. For instance, seven pieces of small wood are just as likely to form a channel-spanning pool as a large piece of wood. Rosenfeld, J. S., and Huato, L. 2003. Relationship between LWD characteristics and pool formation in small coastal British Columbia streams. North American Journal of Fisheries Management 23:928–938. http://www3.telus.net/jordanrosenfeld/Home%20Page/Publications/Rosenfeld%20and%20Huato %202003.pdf. Similarly, Bilby and Ward (1989) surveyed characteristics of large wood in western Washington streams and found that size of stable pieces of large wood increases with stream size. Their values suggest that streams under 5 m in width require trees of about 30–35 cm in diameter to be useful as fish habitat and to be able to persist as stable LWM in the channel. Streams of about 10 m in width require larger trees of about 45 cm (1.5 ft) in diameter. Bilby, R. E.; Ward, J. W. 1989. Changes in characteristics and function of woody debris with increasing size of streams in western Washington. Transactions of the American Fisheries Society 118: 368-378. These publications show the direct and cumulative value of small wood (which is often captured and exported by logging). This means that the agency cannot ignore or discount the value of small wood recruitment to streams. In sum, NEPA analyses must account for the effects of logging on both the quantity and quality of wood.
The EA (p 3-152) says “Vegetation treatments and prescribed burning in RHCAs would accelerate the attainment of RMOs for Large Woody Debris in the affected stream reaches.” The FS needs to distinguish between the effects commercial logging in RHCA versus the effects of prescribed fire in RHCAs. The EA can’t lump these two activities and hide the adverse effects of logging which are exactly opposite of what the EA concludes. Logging will retard attainment of RMOs related to dead wood. Thomas Spies, Michael Pollock, Gordon Reeves, and Tim Beechie 2013. Effects of Riparian Thinning on Wood Recruitment: A Scientific Synthesis - Science Review Team Wood Recruitment Subgroup. Jan 28, 2013, p 36. http://www.mediate.com/DSConsulting/docs/FINAL%20wood%20recruitment%20document.pdf. (“Conventional [i.e., commercial] thinning generally produces fewer large dead trees. Thinning with removal of trees (conventional thinning) will generally produce fewer large dead trees across a range of sizes over the several decades following thinning and the life-time of the stand relative
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to equivalent stands that are not thinned. Generally, recruitment of dead wood to streams would likewise be reduced in conventionally thinned stands relative to unthinned stands”)
8-7 Logging Does Not Benefit Goshawks – Less Aggressive Alternatives (and No Action) are Not Adverse to Goshawks
EA (p 2-37) says “[PFA’s [goshawk post-fledging areas] protected by thinning to reduce fire risk …” This is not supported by the evidence. EA (pp 3-122 - 3-124) says the no-action alternative “would reduce the development of large tree structure and leave stands at a high risk of a stand replacement fire eliminating goshawk habitat. … High potential for insect mortality is a concern that may affect goshawk habitat. … Another concern with the No Action Alternative is the potential to lose goshawk nesting territories to stand replacement fires. … Variable density prescriptions with incorporating “skips and gaps” create more edge producing a higher prey base for goshawks.” First, it is not at all clear that goshawks are harmed by wildfire and insects. They evolved and persist in ecosystems affected by fire and insects. The agency is not permitted to saddle the no action alternative with a worst case scenario in terms of future fire. The NEPA document describes the no-action alternative in terms of its inherent high risk of intense future fire, but the NEPA document lacks any recognition: (a) that the probability of high severity fire is far less than certain, (b) if a high severity fire does occur during hot-dry-windy conditions, the environmental effects will be similar whether the area is treated or not, and (c) that during favorable conditions of weather and fuel moisture a low-severity or mixed-severity fire could occur in the project area and such as fire would likely accomplish much of what this project is attempting to accomplish without all the adverse consequences from ground disturbance. This shows a strong bias against the no-action alternative.
Fire in fact has beneficial impacts. For instance: • Fire creates snags and down wood which are essential ecological features, • Fire makes available light, moisture, nutrients, and growing space for diverse organisms; • Fire makes nutrients available and cycles nutrients; • Growth of cutthroat trout was positively correlated with wildfire severity in the Oregon Coast Range. Heck & Gresswell. 2006. CFER News. • A study of the historic fire pattern in the Boundary Water Canoe Area showed that only large fires at the scale of the historic disturbance regime would truly restore the landscape vegetation pattern. Small fuel reduction treatments (both mechanical or prescribed fire) would probably not restore the historic landscape pattern, and might in fact continue the habitat fragmentation effect caused by recent management. Baker, William. 1994. Restoration of Landscape Structure Altered by Fire Suppression. Conservation Biology. vol 8, no. 3, Sept. 1994. Baker concluded that mechanical pre-treatment may not be required to restore fire adapted ecosystems. The NEPA analysis for this project should recognize the adverse impacts of mechanical fuel reduction on soil, water, weeds, wildlife, scenery, and must recognize that mechanical fuel reduction may not only not aid landscape restoration objectives but might actually conflict with them. Baker seems to say that the only legitimate value of small scale fuel treatments is to protect very specific resources such as homes, communities, and specific stands of old-growth, and then only
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when the treatments are very narrowly targeted to the immediate vicinity of the structures to be protected.
Second, wildlife such as goshawks that are associated with relatively dense, complex forests are not benefitted by logging, even when that logging is intended to reduce the effects of fire. This is because, the FS cannot predict the location, time, or intensity of future fires. Based on simple probabilities, one can see that fuel treatments will degrade far larger areas of habitat, than will be adversely affected by fire.
There is a strong interest among the federal land management agencies to conduct widespread logging in high quality dense forest habitat in order to reduce the effect of fire. The agencies view fuel reduction logging as beneficial to habitat because some modeling shows that fire behavior is moderated by fuel reduction, but proponents never seem to conduct a careful evaluation of the relative probability, and the relative harms, of logging versus wildfire. This is an example of the “base rate fallacy” or “neglecting priors” from Bayesian statistics. The probability of a forest stand NOT burning are far greater than the probability of a forest stand burning. Attempts to address a problem that is unlikely to occur, such as by thinning a forest that is unlikely to burn, runs a high risk that unintended negatives effects will overwhelm beneficial effects. https://en.wikipedia.org/wiki/Base_rate_fallacy.
Strangely, the probabilistic aspects of this issue have been largely ignored in the forest habitat science literature, but recently explored in greater depth the forest-carbon literature which clearly shows that although thinning can modify fire behavior, logging to reduce fire effects is likely to remove more carbon by logging than will be saved by modifying fire. Mitchell, Harmon, O'Connell. 2009. Forest fuel reduction alters fire severity and long-term carbon storage in three Pacific Northwest ecosystems. Ecological Applications. 19(3), 2009, pp. 643–655 http://www.fs.fed.us/pnw/pubs/journals/pnw_2009_mitchell001.pdf. By extension, logging habitat to save it from fire is more likely to destroy more habitat than it saves. See Heiken, D. 2010. Log it to save it? The search for an ecological rationale for fuel reduction logging in Spotted Owl habitat. Oregon Wild. V 1.0. May 2010. https://www.dropbox.com/s/pi15rap4nvwxhtt/Heiken_Log_it_to_save_it_v.1.0.pdf?dl=0
Third, there is little evidence that fire is “out-of-whack.” Fire severity over the last several decades has not shown a significant trend toward unnaturally severe fire. As it has for millennia, wildfire fire remains a mix of light, moderate, and severe fire. An analysis of trends in burn severity in the Northwest over the last 20 years found that “there is a [statistically] significant increase in average fire size between 1984-1999 and 2000-2005 [yet] there is still no trend toward higher burn severity… MTBS data does not support the assumption that wildfires are burning more severely in recent years.” The majority of fire effects remain low severity and the proportion of high severity fire is not showing an increasing trend, therefore one could conclude that the increased incidence of fire on the landscape is just a re-establishment of a natural process. Natural fire is not a problem, but a solution to decades of fire suppression. The majority of area burned falls within the unburned to low severity range, with relatively low annual variation in these severity classes. The high and moderate severity classes show higher relative variation between years, suggesting that these classes may be most influenced by variation in climate, weather, and seasonal fuel conditions. …
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Percentage of Area by Burn Severity–PNW & PSW • 28 percent—unburned to low severity • 36 percent—low severity • 21 percent—moderate severity • 15 percent—high severity …
… The Unburned-to-Low and Low severity classes are also interesting because their proportions are relatively stable from year to year. The Unburned-to-Low class averages approximately 28 percent of the burned area with only ±6 percent variation from year-to- year (one exception in 1995) for the entire data record. This compares with the high severity class, which averages 15 percent of the area with ±11 percent variation. Also, in 82 percent of the years the combination of the Unburned-to-Low and Low severity classes was 60 percent of the burned area. The lower end of the burn severity spectrum appears to be fairly consistent across the data record and regularly comprises a majority of the burned area. MTBS: Monitoring Trends in Burn Severity: Report on the Pacific Northwest and Pacific Southwest Fires (1984 to 2005). http://mtbs.gov/reports/MTBS_pnw-psw_final.pdf.
Fourth, wildfire severity is mostly driven by climate and weather, not fuels. The warming climate is likely to make this effect even more pronounced. Schoennagel et al 2017. Adapt to more wildfire in western North American forests as climate changes. PNAS 2017; published ahead of print April 17, 2017. www.pnas.org/cgi/doi/10.1073/pnas.1617464114; https://headwaterseconomics.org/wp-content/uploads/Adapt_To_More_Wildfire.pdf; Odion, D.C. et al 2014. Examining Historical and Current Mixed-Severity Fire Regimes in Ponderosa Pine and Mixed-Conifer Forests of Western North America. PLOS One. February 2014 | Volume 9 | Issue 2 http://www.californiachaparral.org/images/Odion_et_al_Historical_Current_Fire_Regimes_mixe d_conifer_2014.pdf; See also, Alisa Keyser and Anthony Westerling, 2017. Climate drives inter- annual variability in probability of high severity fire occurrence in the western United States, Environmental Research Letters. Accepted Manuscript online 4 April 2017 https://doi.org/10.1088/1748-9326/aa6b10.
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Fifth, there is little evidence that logging is effective at changing the fire behavior on a landscape scale. Widespread logging for fuel reduction has at best a modest effect on fire behavior. Even extensive fuel reduction reduces the extent of wildfire by less than 10 percent. See M. A. Cochrane, C. J. Moran, M. C. Wimberly, A. D. Baer, M. A. Finney, K. L. Beckendorf, J. Eidenshink, and Z. Zhu. 2012. Estimation of wildfire size and risk changes due to fuels treatments. International Journal of Wildland Fire. http://dx.doi.org/10.1071/WF11079. http://www.publish.csiro.au/?act=view_file&file_id= WF11079.pdf
Sixth, there is no clear evidence that variable thinning increases prey base in a way that is beneficial to goshawks. A 2015 science review focused on the southern Blue Mountains f Oregon highlights several key points about goshawks: • New goshawk science calls for protecting more habitat - e.g., recruitment habitat AND active nest cores; mid-AND-late seral forest; • New science indicates that the Eastside Screens can be improved if FS would identify and protect more and larger reserve areas for goshawks AND other wildlife; • Science affirms that goshawk require closed canopy forest, raising questions about increasing the pace and scale of density reduction; • The Eastside Screens have slowed logging rates and successfully averted a conservation crisis for the goshawk. Increasing the pace and scale of logging could undermine this success story; Goodell, J. M. and Seager, ST. 2015. The Northern Goshawk on the Southern Blue Mountains and Malheur National Forest: A Technical Review of its Status, Ecology and Management. The Nature Conservancy, Portland, OR. 93 p. http://hdl.handle.net/1957/57413; http://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/57413/Goshawk%20on%20Souther n%20Blue%20Mountains_Goodell%20and%20Seager%202015.pdf
Rickabaugh (201x) conducted extensive surveys of goshawks in eastern Oregon and found that density reduction treatments were not favorable. FOREST MANAGEMENT OF TERRITORIES In 1993, the USFS wisely began implementation of goshawk guidelines in their planning process, based on work by Reynolds et al (1992). On this forest the attempted directions for management (as specifically stated in the “East Side Forest Plan Amendment 2”) is to protect every known active and historically used goshawk nest site from disturbance; and that 30 acres of the most suitable nesting habitat surrounding all active and historical nest trees will be deferred from harvest. A 400-acre PFA has been established around a majority of the known nests sites but not all. … Most of the management activities (timber harvest, thinning, etc.) on this study area at the nest stand level have proven to be deleterious to occupancy of those nest stands. Even though the directives in the “East Side Forest Plan Amendment 2” (C. Kranich, pers. com.) is to defer from harvest 30 acres of the most suitable nesting habitat surrounding all active and historical nest trees, this has not been implemented (for various reasons deemed by forest managers at the time) in all cases. In these cases (for examples see Burntcabin Creek, Dipping Vat, LP Dog, Steagall Springs), nesting goshawks moved to
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adjacent areas or were seemingly extirpated from that nest stand. Though the harvest prescriptions may change in the future, I have observed that the overall management activities in the goshawk nest stands and surrounding areas have had the effect of reducing the canopy layer and opening up the forest structure. Goshawks are more likely to be found in areas with a high percentage of mid-aged to late succession forest in closed canopy conditions. A reduction in large trees and canopy cover, either through short-term high volume logging or repeated entry into stands over time, reduced the suitability of those stands for occupancy by breeding goshawks (DeStefano et al. 2006). There is a need for long-term monitoring of the results of these management procedures; however, funding and personnel will probably continue to be deficient for this forest, particularly in the current budget climate. In the 32 core territories with the longest monitored record, only 13 have remained relatively unaltered by any timber activity or disturbance other than natural occurrences (e.g., wind throw, deadfall). Seventeen have been altered by cuts in or around the nest clusters, and two have been burned … SKYLAR J. RICKABAUGH with THEODORE J. FREMD. NORTHERN GOSHAWKS IN THE MALHEUR NATIONAL FOREST EASTERN OREGON 1992 TO 2011. p 429-430 https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/12197/A_Final_Goshawk_doc_ May_10.pdf
A 2005 review of the most accurate information on goshawk habitat selection confirms that goshawks select stands with complex forest structure (e.g. high canopy closure, large tree for forest type, canopy layering, abundant course woody debris). However, protecting just late successional forest and just the active nest sites may not be enough. The agency should be protecting more mid-and late seral forests and should be protecting both recruitment habitat and active nest cores, i.e., the agencies should be managing for a landscape that is suitable for goshawks and other late successional wildlife to thrive and move around in.
This review also does not find support for a few of the assumptions underlying Reynolds’ 1992 management recommendations. • Goshawks are habitat generalists only in the sense of using forests with a variety of tree species, but they are not habitat generalists in terms of selecting forest structure. They disproportionately select for late successional forest. • Goshawks are not opportunistic foragers. Rather they appear to select for prey availability as determined by late successional forest structure. • Goshawk are not limited by prey abundance. They select for prey availability, with absolute prey abundance being only a component of availability, late successional forest structure being an important determining factor.
Some relevant excerpts from this review include: Boal et al (2001) found that stands used by goshawks contained 1.6 to 2.4 km of down woody debris per hectare with an average diameter of 17-19 cm, depending on forest type, and Bloxton (2002) documented that goshawk kill sites has greater numbers of snags >12.5 cm dbh/ha (u=77) than random sites. …
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… the consistency of results in demonstrates goshawk selection for late successional forest structures (e.g. high canopy closure, large tree for forest type, canopy layering, abundant course woody debris) when using areas within their studies home ranges. … … A majority of studies found selection for stands with >40% canopy closure and greater densities of trees over 40 cm dbh. … … goshawks may be broad habitat generalists in terms of tree species but are habitat specialists with respect to forest structure. … … prey abundance is not the most important factor is selecting foraging sites... Several studies determined that goshawks select foraging habitat based not on prey abundance but rather prey availability as determined by habitat structure. … [R]ecommendations focusing on increasing prey abundance at the expense of forest structure within occupied home ranges are not likely to improve goshawk occupancy rates. … goshawks avoided open areas, particularly logged open areas, and none found selection for openings. … current information does not conclusively support a contention that creating openings through logging will benefit the goshawk. Given the history of clearcutting in much of the western United States range of the goshawk, we very much doubt that forest clearing are a limiting factor for the species. … Occupancy rates were reduced by removing forest cover in the home range… … We have no way of knowing assessing whether 40% of the landscape in mature and old- growth forests is sufficient to sustain goshawks. … we recommend protecting existing mature and old-growth forest characteristics and ensuring that such forests are allowed to develop in proportions similar to pre-settlement conditions. This can be accomplished by restricting cutting to small trees and prohibiting large reductions in canopy closure. A similar proposal was recently adopted by Region 5 of the United States Forest Service for the Sierra Nevada. Greenwald, Crocker-Bedford, Broberg, Suckling, and Tibbitts. 2005. A review of Northern goshawk habitat selection in the home range and implications for forest management in the western United States. Wildlife Society Bulletin 33(1):120-129. http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_021122.pdf.
This comprehensive review of telemetry studies does not find support for the hypothesis that thinning improves goshawk foraging habitat. Absent clear scientific support, the agency should clearly label the statement as an unsupported hypothesis.
Even though the speculations in Reynolds (1992) about the benefits of logging have been discredited by subsequent science we still see the agencies inappropriately relying on Wisdom (2000) which in turn relies on Reynolds (1992). (e.g. Jackson Vegetation Management Project FIES. Ochoco NF. 2012).
Timber sales that emphasize removal of shade tolerant trees will likely adversely affect goshawk habitat. Minta et al (1993) found that goshawk territories in NE Oregon tend to be located in
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stands dominated by Grand fir, while they prefer to nest in large Douglas fir trees. Minta, Steven, Ralph Anderson and Tracy Fleming. 1993(fall). Trends in historic goshawk data, Wallowa (Whitman) National Forest, Oregon. Unpublished 2 page typescript summary. Report on file at National Council of the Paper Industry for Air and Stream Improvement. (“The dominant trees in the nest stand were grand fir (38.4%, n=159), Douglas Fir (22.6%), Ponderosa pine (14.5%), western larch (12%), and lodgepole pine (10.7%). Secondarily dominant trees included Douglas fir (46.6%, n=131), western larch (16.8%), Ponderosa pine (14.5%), and grand fir (10.7%). The USFS plant community designation was most frequently grand fir/twinflower (35.9%, n=117), grand fir/big huckleberry (27.4%), Douglas fir/common snowberry (13.7%), …”)
The agency sometimes argues that logging helps create flying space for goshawks. This generally not necessary or beneficial. Goshawks prefer relatively dense, complex forest and they have the ability to fly through complex forests, as shown in the following videos: https://youtu.be/_bXHLznnQmY?t=37s; https://youtu.be/7WurNq4q0K0?t=2m46s; https://www.facebook.com/atmacaalemi.sparrowhawkworld/videos/121267271547623/
In conclusion, the best available evidence shows that the combined effects of logging plus the unavoidable effects of wildfire are more adverse to goshawks (and other wildlife that live in complex forests) than the effects of fire alone. In short, logging makes things worse, not better. The EA failed to take a hard look at the adverse effects of logging on goshawks and other wildlife that depend on complex forests.
8-8 Conservation of Unroaded / Undeveloped Areas
In discussing undeveloped resources, the EA (p 3-230) says “Any areas with unique ecological values within the project area are currently maintained for those values with Forest Plan standards and guidelines for management area allocations …” This is not supported by the evidence. The LRMP was developed when undeveloped areas larger than 5,000 acres were given some minor recognition, but before new science emerged showing that unroaded areas less than 5,000 acres are ecologically significant. Such areas provide disproportionate values such as clean and abundant water, soil conservation, carbon storage, high quality habitat, unfragmented landscapes, intact plant communities, scenic vistas, recreation, and quality of life. The existing Forest Plan cannot have adequately protected undeveloped lands because the forest plan was written before their full values were widely known. The EA failed to take a hard look at the adverse effects of logging on the important values provided by unroaded areas larger than 1,000 acres, but less than 5,000 acres.
The EA (p 3-230) says “No special or unique resource values in undeveloped lands have been identified by project resource specialists … The affected environment for each of these resources is the same as disclosed in previous sections of this chapter and not reiterated here.” It is simply unsupported to say that the resource values in areas that have been previously logged and roaded are indistinguishable from the resources values in undeveloped areas. Our scoping comments, under the heading “New information on Unroaded Areas >1,000 acres” included at least 5 pages of excerpts from scientific analyses that should help the FS distinguish undeveloped and developed areas. The FS provided no documentation that they read and understood these analysis
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and took a hard look at whether the undeveloped areas in this project area provide disproportionate resource values compared to logged and roaded areas.
The NEPA analysis blurred the distinction between the effect of logging on roaded areas and unroaded areas. The effects of logging unroaded areas are qualitatively different and more significant than logging areas previously affected by roads and logging. The NEPA analysis must clearly disclose the fact that water quality, habitat, scenic values, soil quality, and carbon storage are all better in unroaded areas than roaded areas, and logging will have disproportionately adverse effects on those values.
The EA shows that there are 2,642 acres of “treatment” in undeveloped areas larger than 1,000 acres. The EA does not disclose if “treatment” here include both logging and prescribed fire? The NEPA analysis needs to distinguish between commercial logging and heavy equipment use which is almost certainly adverse to roadless values versus prescribed fire and other non- commercial removal of very small trees, which might arguably have restoration benefits.
One of the under-appreciated values of unroaded areas where natural process are allowed to flourish is the long-term creation and maintenance of dead wood habitat. Unroaded areas are one of the few places where trees are allowed to fulfill their entire “lifecycle” (including their life- giving role as snags, dead wood, and soil builders) in the forest. Korol et al (2002) found that large snag habitat is below historic range of variability across the Interior Columbia Basin and they estimated that even if the agencies apply enlightened forest management on federal lands in the Interior Columbia Basin for the next 100 years, we will still reach only 75% of the historic large snag abundance, and most of the increase in large snags will occur in roadless and wilderness areas. Jerome J. Korol, Miles A. Hemstrom, Wendel J. Hann, and Rebecca A. Gravenmier. 2002. Snags and Down Wood in the Interior Columbia Basin Ecosystem Management Project. PNW-GTR-181. http://www.fs.fed.us/psw/publications/documents/gtr- 181/049_Korol.pdf.
Wisdom et al (2008) found that snag abundance in the Pacific northwest forests is inversely related to past harvest and proximity to roads. Wisdom, M.J., and Bate, L.J. 2008. Snag density varies with intensity of timber harvest and human access. For. Ecol. Manage. 255: 2085–2093. doi:10.1016/j.foreco.2007.12.027. http://www.fs.fed.us/pnw/pubs/journals/pnw_2008_wisdom001.pdf (“Our highest snag density … occurred in unharvested stands that had no adjacent roads. … Stands with no history of timber harvest had 3 times the density of snags as stands selectively harvested, and 19 times the density as stands having undergone complete harvest. Stands not adjacent to roads had almost 3 times the density of snags as stands adjacent to roads.”)
8-9 The FS Should Follow LRMP Big Game Standards
We oppose efforts to amend the forest plan to allow severe reduction in big game cover. We are concerned that taking thousands of acres of forest down to an average of 40 ft2 basal area will leave far too little hiding cover in a pattern that is far from optimal for big game (and other wildlife that benefit from the big game standards). Based on the proposed logging prescriptions, it will be very hard to find places that can hide 90% of deer or elk at 200 feet as required by the
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LRMP. The prescribe “skips” are too small to function as high quality cover, especially for elk. The FS has not explained why it is so important to reduce conifer density at the expanse of big game and snag associated species.
We appreciate that the FS has developed an alternative that maintains big game cover as required by the LRMP, but the EA does not do enough to highlight the benefits of that alternative relative to the proposed action. Big game and many other species would benefit from greater retention of trees.
The EA (p 3-103) admits that this area provides important cover for big game, especially in the landscape context, since nearby areas lack cover: Cover reduction has occurred in the past decade affecting the distribution, increase in vulnerability, and displacement of mule deer and elk in the Silvies River drainage. With the reduction in cover and the lack of abundance of security cover in adjoining project areas, elk have moved into the Flat project area where cover is abundant during autumn hunting when human disturbance increases. The EA does not adequately disclose the cumulative consequences from aggressive density reduction in one of the last refuges for big game. The EA lacks internal consistency. “[L]andscape restoration projects contain large treatment blocks with harvest prescriptions leaving more trees on the landscape but cover patches are not large enough to secure elk during certain seasons. Skips and gaps will enhance habitat by providing some hiding cover and better foraging opportunities.” This says that prescribed skips are not big enough but says that they will enhance habitat. This is confusing. The FS needs to redesign this project to better harmonize density reduction with other objectives such as big game cover and long-term recruitment of snag habitat.
The EA analysis of the effects of this huge logging project on big game populations is only two paragraphs. This is not the “hard look” required by NEPA. This is especially troubling in light of the proposed plan amendment waving big game cover requirements. EA (p 3-97) says “Mule deer populations are below management objectives and the proposed treatments could increase populations where quality forage is enhanced and security allows for good fawn production.” (emphasis added). The EA does not provide a spatially explicit analysis of the juxtaposition of improved forage and retention of sufficient high-quality cover to allow a reasonable person to conclude that this project is beneficial to big game.
While the agency embarks on an ambitious effort to reduce fuels and reduce forest density, the agency must also conserve habitat for diverse wildlife that depend on dense forest canopy cover, complex understories, and dead wood. Carbon storage and watershed values are also enhanced when forest cover is maintained. We urge the agency to carefully consider whether there is enough habitat provided for these species, including goshawk, black-backed woodpecker, three- toed woodpecker, and pileated woodpecker. The current distribution of recognized and protected habitat areas may be inadequate, especially considering the need for redundancy to account for expected habitat loss from fire, logging, fuel reduction, and natural forest succession. The fact that big game cover requirements need to be amended to accommodate many projects like this raises concerns not just for big game, but for the wide variety of other species that depend on canopy cover, complex understory, and dead wood. Before conducting large-scale density
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reduction efforts or amending big game cover standards, the agency should carefully consider all the other wildlife that were intended to be sheltered by the "umbrella" of big game cover standards in the RMP. The cover and forage requirements of big game is another lens through which to think about optimizing the mix of treated and untreated stands, as well as the scale and extent of skips and heavily-thinned “gaps” within treated stands. The NEPA analysis should consider alternatives with different mixes of treated and untreated areas for this purpose. The agency should use a state-and-transition model to project future dense forest habitat recruitment under a reasonable set of assumptions about disturbance and succession.
Snags and Dead Wood – Inadequate Analysis – Lack of Credible Standards.
EA (p 2-37) summarizes the effects analysis saying “Primary Cavity Excavators would benefit from restoration treatments” This is not supported by the evidence. Cavity dependent species 8-10 need more snags and dead wood but logging will reduce the population of green trees and therefore reduce the recruitment of dead wood over the long term. The EA failed to take a hard look at the adverse effects of logging on snags and dead wood over time.
Contradicting the summary of effects, EA (pp 3-81, 3-82, 3-90, 3-91) says about pileated woodpecker impacts – loss of foraging and nesting habitat is highly probable, especially with late season burning, when moisture content of decadent wood is low. Research in northeastern Oregon indicates pileated woodpecker foraging declined in treated units compared to untreated areas. The amount of unharvested stands and closed canopy stands in home ranges were positively correlated with reproductive success in Bulls study in northeastern Oregon (Bull, et. al. 07). Reduction in canopy cover can expose birds to predation. Moving stands to historic open canopy conditions is not favorable for this species of woodpecker, except in stands lacking large structure. Conversion of stands dominated by grand fir to stands dominated by ponderosa pine likely reduces suitable habitat for pileated woodpecker (Bull, in Marshall, 2003). Since carpenter ants are primary prey and ants are found in downed logs, management activities affecting downed logs can adversely affect pileated woodpecker. Logs are expected to be minimally impacted with the mechanical treatments, but prescribed fire in the mixed conifer stands can reduce the existing downed logs and reduce foraging habitat. … roads in pileated woodpecker habitat would remain susceptible to snag removal, potentially reducing nesting habitat for this woodpecker. … … High road densities coupled with liberal fire wood cutting policies is contributing to a decline in large size snag densities. … … The majority of research studies report that thinning or thinning and burning fuel reduction treatments result in decrease in populations of cavity nesters owing to loss of dead trees used for nesting and roosting (Pilliod, et. al. 2006).
So, this project is not beneficial to cavity species. Given the size of this project, and the fact that the pileated woodpecker is a management indicator species, this project may n=have significant
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Flat Project Comment Analysis effects requiring an EIS. This project should be modified to mitigate these adverse effects, by, for instance, retaining greater basal area in harvest areas that may be potentially suitable for pileated woodpeckers.
EA (p 3-92) says “It could be surmised that large scale vegetation projects reduce snags recruitment in the mid-term due to reducing stocking rates of trees thinned. The larger snags, which are most important to wildlife, can be created over time from prescribed fire. Moreover, recruitment of these larger snags in the long term (>50 years) is enhanced due to increase in growth rates of remaining trees.” This poses several problems. First, it is not speculation that large-scale tree removal reduces snag recruitment. It’s simple math! Logging subtracts trees that can never fulfill their life-cycle and be recruited as snags. Second, recruitment of large trees is NOT “enhanced” by thinning, because thinning removes many stems that would otherwise grow to become large snags. The EA analysis is not supported by the facts. Third, this is a great opportunity to compare more alternatives. Retaining 40 ft2 of basal area will definitely cause a severe reduction of large snag habitat but thinning small trees and retaining 80-100 ft2 of basal area will be much more likely to provide for desired levels of natural mortality and snag habitat over the long term.
“Two common consequences of conventional thinning practices have been increased uniformity of forest structure and composition, and removal or delay in the development of dead wood as snags or down wood to meet decadence and habitat functions. … Over the past several decades our ecological understanding of decadence and its importance to habitat and biogeochemical processes has increased substantially, but translation of the fundamental knowledge into coherent goals is lagging.”
Paul D. Anderson 2013. Two Decades of Learning about Thinning in the Ecosystem Management Era. http://www.fs.fed.us/pnw/pubs/pnw_gtr880/pnw_gtr880_001.pdf in Density Management in the 21st Century: West Side Story PNW-GTR-880. http://www.treesearch.fs.fed.us/pubs/44695
There is a widely held belief that growing big trees faster by thinning, also benefits snag associated wildlife and fish because if there are bigger trees, there must also be bigger snags faster. This assumption does not hold up under scrutiny. Thinning captures mortality and removes it from the forest to the mill. It also increases the vigor of trees and delays mortality. BLM says “Thinning ‘captures’ much of the snag recruitment that results from inter-tree competition and very little density mortality … is expected to occur for 25 years after treatment.” Salem BLM, South Scapoose EA. http://www.blm.gov/or/districts/salem/plans/files/SSC_EA.pdf. See this online slideshow which shows the modeled effects of thinning on dead wood habitat. http://www.slideshare.net/dougoh/effects-of-logging-on-dead-wood-habitat. Stand simulation models clearly show that we need to count the effects of thinning on dead wood as a “cost” instead of the “benefit”, so we need to consider appropriate methods to avoid and mitigate impacts.
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The NEPA analysis should help illuminate trade-off between snag quality (snag size) and snag quantity (number of snags) that follows from the choice between thinning and not thinning. This critically important trade-off may be amenable to quantitative analysis if the agency would conduct a stand simulation model. This is one of the key functions of NEPA to illuminate the consequences of alternative management approaches. With respect to dead wood habitat, what mix of treated and untreated areas will result in the best mix of thinned areas with later-fewer- larger snags, and unlogged areas where dead wood recruitment is more rapid, more abundant, only slightly smaller?
The agencies often claim (erroneously) that thinning increases dead wood or improves dead wood habitat, but the laws of conservation of mass prevent the agencies from claiming that they can simultaneously send millions of board feet of wood to the mill and still increase wood in the forest over the long term. The agencies often present the issue of dead wood as if the objective is to produce the first large tree (aka “the hare”), rather than to produce a continuous flow of large trees over the long-term (aka “the tortoise”). By focusing on the treatment that produces a few big trees fast, the agencies ignore important aspects of the decision, including (a) the fact that recruiting dead wood requires two things large trees AND mortality. Logging produces vigorous trees that are less likely to die and produce snags in the near term, and thinning removes less vigorous trees that are more likely to be recruited as forest structure in the near term, and (b) the fact that thinning reduces the absolute number of trees that can ever be recruited as snags and dead wood. Every tree that leaves the forest on a log truck has an alternate future as a snag and dead wood. The agency ignores this opportunity cost of logging. When forest scenarios are put through an accurate model of stand growth and mortality, in almost all cases thinning will result in a reduced flow of large wood over the long-term. For instance, in a thinning project on the Siuslaw National Forest “modeling stand #502073 over a 100-year cycle [using ORGANON] predicts a total stand mortality of 202 trees (>10 inches dbh) for the unthinned stand, while mortality for the thinned stand was two trees. Therefore, thinning will reduce density-dependent mortality within the stand by 99%.” NOAA 2006. Magnuson Act consultation on Essential Fish Habitat and Response to Siuslaw NF Lobster Project BA. April 4, 2006.
This graph from the Curran Junetta Thin EA shows that heavy thinning delays by more than 60 years the attainment of habitat objectives for large snags (i.e. mid-point of the gray band representing 30-80% tolerance level).
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http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne pa/32805_FSPLT2_053506.pdf.
The Flat Project might be in a different forest type than Curran Junetta, but the effects of logging are substantially similar. No matter how you slice it, logging is a subtractive endeavor that reduces the population of green trees and therefore unavoidably reduces the number of trees available for future snag recruitment. These adverse effects are long-lasting.
See also, the vigorous debate on the westside regarding the effects of thinning on wood recruitment to streams. In January 2013, the Science Review Team Wood Recruitment Subgroup reported their “Key Points” regarding the effects of commercial thinning on wood recruitment in riparian reserves:
… In general, there is very little published science about the effects of thinning on dead wood recruitment and virtually none on thinning effects on wood recruitment in riparian zones. We conducted some limited simulation modeling to illustrate some of the relationships between thinning and dead wood recruitment. The simulations (and comparison of models) were not comprehensive or a rigorous analysis of thinning effects and should be viewed as preliminary. Below we provide 15 key points from our efforts:
Key Points
1. Thinning is most beneficial in dense young stands. Existing literature and stand development theory suggest that the greatest potential ecological benefits of thinning to accelerate the development of older forest structure (e.g. large trees, large dead trees, spatial structural and compositional heterogeneity, etc.) comes in dense uniform plantations less than 80 years and especially less than 50 years old. The benefits of
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thinning for older forest ecological objectives are less clear in stands over 80 years of age. Hence, our report focused primarily on plantations less than 50 years of age.
2. Results may not be applicable to all stand conditions. For this synthesis, many of our conclusions were based on modeling the effects of thinning 30 to 40 year old Douglas-fir plantation stands that range in density from 200 to 270 trees per acre (tpa). We consider such stands moderately dense, as young plantation stand densities range from less than 100 to greater than 450 tpa. In terms of dead wood production, higher density stands are likely to see more benefits from thinning, and lower density stands less benefits. [Portions of this project are probably less dense and less in need of thinning, compared to the very dense, very young stands addressed in this report.]
3. Accurate assessments of thinning effects requires site-specific information. The effects of thinning regimes on dead wood creation and recruitment (relative to no-thinning) will depend on many factors including initial stand conditions, particularly stand density, and thinning prescription—it is difficult to generalize about the effects of thinning on dead wood without specifying the particulars of the management regime and stand conditions. [The NEPA analysis needs to provide a site-specific, quantitative analysis to show that silviculture is needed to meet ACS objectives in these riparian reserves.]
4. Conventional [i.e., commercial] thinning generally produces fewer large dead trees. Thinning with removal of trees (conventional thinning) will generally produce fewer large dead trees across a range of sizes over the several decades following thinning and the life-time of the stand relative to equivalent stands that are not thinned. Generally, recruitment of dead wood to streams would likewise be reduced in conventionally thinned stands relative to unthinned stands. [This result is highly relevant to the proposed logging to meet ACS objectives.]
5. Conventional [i.e., commercial] thinning can accelerate the development of very large diameter trees. In stands that are conventionally thinned, the appearance of very large diameter dead trees (greater than 40”) may be accelerated by 1 to 20 years relative to unthinned plantations, depending on thinning intensity and initial stand conditions. Trees of such sizes typically begin to appear 5 to 10 decades after thinning 30 to 40 year old stands. [Note: The appearance of a few “very large” trees in the decades after thinning comes with the loss of a much larger volume of “large functional” trees that were exported from the site before they were allowed to grow and recruit to the stream. Any small gains in very large trees, comes at the expense of large numbers of large trees, so net benefits to ACS objectives are highly unlikely.]
6. Nonconventional [i.e., non-commercial] thinning can substantially accelerate dead wood production. Stands thinned with prescriptions that leave some or all of the dead wood may more rapidly produce both large diameter dead trees in the short-term and very large diameter dead trees (especially greater than 40”) in the long-term, relative to unthinned stands. Instream wood placement gets wood into streams much sooner than by natural recruitment, and can offset negative effects of thinning on dead wood production.
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7. Assessments of thinning effects may vary depending on the forest growth model. The previous statements are supported by three stand simulation models (FVS, ORGANON, and ZELIG). However, the magnitude and timing of effects of thinning on dead wood recruitment and stand growth varied among models.
8. Dead wood in streams comes from multiple sources. Dead wood in streams is primarily recruited through near-stream inputs (e.g. tree mortality and bank erosion) and landslides and debris flows. All types of recruitment are important and the relative importance varies with site and stream characteristics.
9. 95% of near-stream wood inputs come from within 82 to 148 feet of a stream. The distance of near-stream inputs to streams varies with forest conditions and geomorphology. Empirical studies indicate that 95% of total instream wood (from near- stream sources) comes from distances of 82 to 148 feet. Shorter distances occur in young, shorter stands and longer distances occur in older and taller stands. [Don't forget: riparian reserves were established to serve both aquatic and terrestrial objectives, and many terrestrial wildlife depend on abundant snags and dead wood.]
10. Thinning can increase the amount of pool-forming wood under certain conditions. Thinning can increase the amount of pool-forming wood only when the thinned trees are smaller in diameter than the average diameter of pool-forming wood (which varies with stream size). [Smaller wood is functional in smaller streams, which means that thinning any commercial-sized trees near small streams is unlikely to advance ACS objectives.]
11. The function of instream wood varies with size and location. Large instream wood can serve as stable “key” pieces that create instream obstructions and form wood jams by racking up numerous smaller pieces of wood that are mobile during high flows. Such wood jams typically consist of a wide range of piece sizes and provide multiple ecological functions that vary with stream size and gradient.
12. Effects of thinning on instream wood needs to be placed in a watershed context. Assessing the relative effect of riparian thinning on instream wood loads at a site and over the long term requires an estimation of the likely wood recruitment that will occur from the opposite bank, from upstream transport, and the rate of decay and downstream transport of wood from the site.
13. The ecological effects of thinning needs to be placed in a watershed context. Watershed-scale perspectives are needed to restore streams and riparian vegetation. The ecological effects of thinning on instream habitat will vary depending upon location in the stream network. Riparian management practices can be varied to match the ecological functions of streams.
14. Variation in thinning is essential (i.e. don’t do the same thing everywhere). Variation in thinning prescriptions will produce more variable forest and wood recruitment conditions, which may more closely mimic natural forest conditions. Using a variety of
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treatments is also consistent with the tenets of adaptive management in situations where the outcomes of treatments are uncertain.
15. Healthy, diverse forests contain many dead trees. Numerous terrestrial forest species require large dead or dying trees as essential habitat. Some directly, others indirectly; to support the food web within which they exist. Abundant large snags and large down wood on the forest floor are common features of natural forests and essential for the maintenance of biological diversity. Thomas Spies, Michael Pollock, Gordon Reeves, and Tim Beechie 2013. Effects of Riparian Thinning on Wood Recruitment: A Scientific Synthesis - Science Review Team Wood Recruitment Subgroup. Jan 28, 2013, p 36. http://www.mediate.com/DSConsulting/docs/FINAL%20wood%20recruitment%20document.pdf
The statement in #5 that "thinning can accelerate development of very large diameter trees" should be kept in proper perspective: • The alleged gain in very large trees is very minor, compared to not logging; • The alleged gain in very large trees is overwhelmed by the significant loss of functional wood in smaller size classes (including “large” wood), and even “medium “ and “small” wood that serves vital functions in small streams that are typical in most projects; and • The alleged gain in very large trees is in the distant future and more speculative; while the loss of smaller functional wood is in the near-term and more certain. Predicting future mortality in thinned stands is difficult. If the trees do not die and fall down there is no benefit in terms of down wood.
Figures 24 and 25 (EA p 3-93) purport to show effects of snag habitat compared to DecAID tolerance levels, but these figure do not make sense. First, which wildlife species are represented by these tolerance levels? The FS needs to show the tolerance levels for species such as pileated woodpecker, three-toed woodpecker, black-backed woodpecker, and possibly goshawk that need abundant dead wood, not just an average levels of dead wood. Second, what geographic scale was the analysis done on? Are the data averaged over treated and untreated areas? Third, the FS fails to extend the analysis long enough to show the snag gap caused by the removal of so many stems via logging and biomass removal. Logging is a subtractive process. There is simply no way to conclude that logging will produce more snags than not logging (if the analysis is honest and extends to include the time periods when the adverse effects of logging are most acute). The FS needs to show their work and explain how they arrived at the conclusions they did. Fourth, the model used unreasonable assumptions - “The model does not take into account snag removal for human consumption such as firewood and does not factor in the high road densities which are associated with low snag recruitment.” (EA p 3-85). The FS can’t take credit for meeting future snag objectives on a fictional landscape where roads and firewood gathering does not occur. The FS needs to mitigate for anticipated losses of snags due to normal events on the forest such as firewood gathering and hazard tree removal. The FS needs to leave extra green trees in order to meet the needs of snag associated wildlife after accounting for snag losses associated with firewood and roads.
EA (p 3-80) concludes that there is no concern for the population viability of three-toed woodpecker and black-backed woodpecker “[d]ue to abundance of snag habitat and periodic
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prescribed fire on the forest.” This is perplexing because in order to prescribed fire to create abundant snag habitat over time there must be enough green trees on the landscape. This project and many others like it are removing so many trees that there may not be enough green trees to ensure long-term recruitment of desired snag levels. This problem is compounded by the fact that the LRMP snag standards are outdated and discredited and we know that wildlife need more snags than previously recognized, and forest managers need to retain far more green trees to recruit those snags. See below analysis of the U30 prescription. The EA failed to explain how it reached the viability conclusions in light of these concerns and failed to take a hard look at this issue. This same problem exists for other species that depend on dense forests and abundant snags and dead wood.
The EA admits that snag habitat is deficient. Figure 18 shows that the landscape is over- represented by acres with low snag numbers (<2/acre), and under-represented with acres of higher snag abundance (<2/acre).
The DecAID reference snag numbers (in Ponderosa pine stands for instance) need to be taken with a grain of salt because they were not collected during a period when fire and other disturbances were operating naturally and the unmanaged reference stands may not have included recent post-disturbance stands where snags are more abundant. This is clearly explained in the “caveats” section of DecAID. DecAID snag levels for “unharvested” stands represent snags levels from a world where disturbances (e.g. fire, insects, disease) are artificially suppressed. The goal should not be to conduct a disturbance (such as thinning) that results in snag levels similar to an undisturbed stand. That makes no sense. Natural stands have periodic disturbances and pulses of snags that go along with those disturbances. The agencies need to get creative and learn to mimic natural disturbance which would always leave behind lots of dead
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trees. Logging that leaves behind only a few snags per acre is an UNusual disturbance event. The agencies need to learn to share the bounty of the forest with the forest itself.
EA (p 3-87) says “The mixed conifer stands do not meet Forest Standards of 2.39 snags per acre in the large and small/medium structures as illustrated in (Figure 18 and Figure 19). Lack of disturbance and past harvest practices have contributed to lower than desired snag densities.” However, the EA fails to properly disclose that (i) existing snag standards under-estimate how many snags are needed, and (ii) how logging will make a bad situation worse in terms of snag habitat.
8-11 U30 Prescription - Can’t Identify “Excess” Down Wood without a Plan Amendment
Oregon Wild opposes the plan amendment allowing removal of large trees up to 30 inches. Aspen can co-exist with mature conifers. The FS needs to harmonize goals related to both conservation of aspen and conservation of large trees. Aspen will be adequately conserved by removing trees less than 21” dbh. We urge the FS to consider an alternative to the U30 prescription for aspen. A better alternative is to limit the removal to trees 21-26 inches dbh, and only remove trees that are younger than 150 years old, and only certain species, like grand fir. This would accomplish the objectives related to aspen conservation while still meeting equally important objectives related to large tree conservation.
Removing large trees in “excess” of down wood requirements is fraught with peril. First, the FS does not have scientifically supportable forest plan standards for determining excess biomass. The existing standards are outdated and discredited. The FS has not gone through proper NEPA/NFMA procedures to adopt new standards, so how can they determine minimum down wood levels or what excess wood is? Second, this requires an EIS because the FS is not only removing large trees, they are also deciding how many to retain based on outdated standards.
The Forest Service cannot provide any assurance that its plans and projects will assure viable populations of native wildlife that depend on dead trees. The Forest Service does not know how many snags are necessary to support viable populations of cavity associated species. The Forest Service has provided no credible link between DecAID tolerance levels, potential population levels, and/or viable populations. The Forest Service has also failed to reliably quantify existing and projected habitat for snag associated species.
The federal forest agencies now recognize that current methods and assumptions concerning snag habitat standards are outdated, and the old snag standards do not ensure enough snags to meet the intent of the standard, yet the agencies have not adjusted their management plans to account for this new information nor have they developed new standards that are consistent with the latest scientific information.
As explained on the DecAID website: Why is DecAID needed? National Forest LRMP standards and guidelines for management of snags and down wood in the Pacific Northwest were based on wildlife species models and tools that were developed in the 1970s and 1980s (Thomas et al. 1979, Neitro et al. 1985, Marcot 1992,
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Raphael 1983). New information about the ecology, dynamics, and management of decayed wood has been published since then, and the state of the knowledge continues to change. Rose et al. (2001) report that results of monitoring indicate that the biological potential models are a flawed technique (page 602). There has been an evolution from thinking of large woody material as habitat structures, to thinking of decaying wood as an integral part of complex ecosystems and ecological processes.
This paradigm shift has made the management of dead wood a much more complex task. We can no longer expect to go to our LRMPs or the biological potential model to get one number for the amount or size of snags and down wood that we can apply to all projects and to all acres. We are directed to use the best available science to manage ecosystems, and the best available science simply will not support business as usual for managing dead wood. http://www.fs.fed.us/r6/nr/wildlife/decaid-guide/
A few of the problems with the old standards are: • They failed to account for the fact that the number of snags needed for roosting, escape, and foraging can exceed the number of snags needed for nesting; • They failed to recognize that the number of snags needed to support viable populations of secondary cavity users may exceed the needs of primary cavity excavators; • The old standard failed to account for the size height of snags favored by some species; • In applying the old standards the agencies often fail to account for rates of snag fall and recruitment; • The old standards fail to recognize non-equilibrium conditions in our forests, i.e. some species rely on the natural large pulses of snags associated with large disturbances; • The old standards fail to account for the differential use of space and population density of different species; • The old standards ignore other important habitat features of dead wood, e.g. loose bark, hollow trees, broken tops, etc.
More than 15 years ago, Rose et al (2001) explained the problems with the current LRMP standards. The Forest Service has still not amended its forest plans to address this significant flaw in its plans. Lessons Learned During the Last Fifteen Years … Several major lessons have been learned in the period 1979-1999 that have tested critical assumptions of these earlier management advisory models: • Calculations of numbers of snags required by woodpeckers based on assessing their ‘biological potential’ (that is, summing numbers of snags used per pair, accounting for unused snags, and extrapolating snag numbers based on population density) is a flawed technique. Empirical studies are suggesting that snag numbers in areas used and selected by some wildlife species are far higher than those calculated by this technique.226 • Setting a goal of 40% of habitat capability for primary excavators, mainly woodpeckers,369 is likely to be insufficient for maintaining viable populations.
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• Numbers and sizes (dbh) of snags used and selected by secondary cavity-nesters often exceed those of primary cavity excavators. • Clumping of snags and down wood may be a natural pattern, and clumps may be selected by some species, so that providing only even distributions may be insufficient to meet all species needs. • Other forms of decaying wood, including hollow trees, natural tree cavities, peeling bark, and dead parts of live trees, as well as fungi and mistletoe associated with wood decay, all provide resources for wildlife, and should be considered along with snags and down wood in management guidelines. • The ecological roles played by wildlife associated with decaying wood extend well beyond those structures per se, and can be significant factors influencing community diversity and ecosystem processes. Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., Waddell, K.L., Lindely, D.L., and B. Schrieber. 2001. Decaying Wood in Pacific Northwest Forests: Concepts and Tools for Habitat Management, Chapter 24 in Wildlife-Habitat Relationships in Oregon and Washington (Johnson, D. H. and T. A. O'Neil. OSU Press. 2001) http://web.archive.org/web/20060708035905/http://www.nwhi.org/inc/data/GISdata/docs/chapte r24.pdf
The Forest Service recognizes that Forest Plan standards were based on a model that did not account for snags required for foraging (EA p. 68 and Appendix K p. 45). There is general consensus in the scientific and professional community that using the biological potential model (which was used in developing the Forest Plan standard) is flawed and does not provide adequate nesting, roosting, or foraging structure for cavity excavating birds … North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project DN. http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne pa/53012_FSPLT2_055455.pdf.
Bull et al. (1997) states current direction for providing wildlife habitat on public forest lands does not reflect the new information available, which suggests that to fully meet the needs of wildlife, additional snags and habitat are required for foraging, denning, nesting, and roosting. Rose et al. (2001) suggests that calculation of numbers of snags required by woodpeckers based on assessing their “biological (population) potential” is a flawed technique (Rose et al. 2001) due to the fact that empirical studies are suggesting that snag numbers in areas used and selected by some wildlife species are far higher than those calculated by this technique. There is general consensus that the biological potential model does not provide adequate nesting, roosting, or foraging structure for cavity excavating birds (Bull et al. 1997, Johnson and O’Neil 2001). This suggests the current direction of managing for 100 percent population levels of primary excavators may not represent the most current knowledge of managing for cavity nesters.
North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project EA, Appendix K – Terrestrial Wildlife Specialist Report. p K-45.
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http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne pa/53012_FSPLT2_055426.pdf.
Similarly, the Fremont-Winema NF’s Barry Point Fire Salvage EA says:
Bull et al. (1997) states current direction for providing wildlife habitat on public forest lands does not reflect the new information available, which suggests that to fully meet the needs of wildlife, additional snags and habitat are required for foraging, denning, nesting, and roosting. Rose et al. (2001) also state that several major lessons have been learned in the period 1979 to 1999 that have tested critical assumptions of earlier management advisory models, including some assumptions used to develop current recommendations in the LRMP Standards and Guidelines. Some assumptions include:
• Calculation of numbers of snags required by woodpeckers based on assessing their “biological (population) potential” is a flawed technique (Rose et al., 2001). Empirical studies are suggesting that snag numbers in areas used and selected by some wildlife species are far higher than those calculated by this technique (Rose et al., 2001).
• Numbers and sizes (DBH) of snags used and selected by secondary cavity nesters often exceed those of primary excavators (Rose et al., 2001).
This suggests the current direction of managing for 100 percent population levels of primary excavators may not represent the most current knowledge of managing for cavity nesters and that these snag levels, under certain conditions, may not be adequate for some species.
http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne pa/91686_FSPLT3_1450222.pdf
8-12 Limitations of Existing Approaches for Assessing Wildlife-Dead Wood Relations. Models of relationships between wildlife species and snags in the Pacific Northwest typically are based on calculating potential densities of bird species and expected number of snags used per pair. This approach was first used by Thomas et al. (1979). Marcot expanded this approach in Neitro et al. (1985) and in the Snag Recruitment Simulator (Marcot 1992) by using published estimates of bird population densities instead of calculating population densities from pair home range sizes. This approach has been criticized because the numbers of snags suggested by the models seem far lower than are now being observed in field studies (Lundquist and Mariani 1991, Bull et al. 1997). In addition, the models provided only deterministic point values of snag sizes or densities and of population response ("population potential") instead of probabilistic estimates that are more amenable to a risk analysis and risk management framework.
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In addition, existing models have focused on terrestrial vertebrate species that are primary cavity excavators. Thomas et al. (1979) and Marcot (1992) assumed that secondary snag-using species would be fully provided for if needs of primary snag-excavating species were met. However, McComb et al. (1992) and Schreiber (1987) suggested that secondary cavity nesting birds may be even more sensitive to snag density than are primary cavity excavators.
Furthermore, existing models do not address relationships between wildlife and down wood, nor do they account for species that use different types of snags and partially dead trees, such as hollow live and dead trees used by bats (Ormsbee and McComb 1998, Vonhof and Gwilliam 2007), Vaux's swift (Chaetura vauxi) (Bull and Hohmann 1993), American marten (Martes americana) (Bull et al. 2005), and fisher (Martes pennanti) (Zielinski et al. 2004).
Bruce G. Marcot , Janet L. Ohmann, Kim L. Mellen-McLean, and Karen L. Waddell. Synthesis of Regional Wildlife and Vegetation Field Studies to Guide Management of Standing and Down Dead Trees. Forest Science 56(4) 2010. http://www.fs.fed.us/pnw/pubs/journals/pnw_2010_marcot002.pdf
The agencies need to prepare a EIS to consider a replacement methodology for maintaining species and other values associated with dead wood. This is especially critical because adequate dead wood is recognized as an essential feature of healthy forests and the Forest Service has identified lots of “management indicator species” associated with dead wood habitat.
Back in the early 1990s the Forest Service recognized the their forest plans were not adequate to maintain populations of spotted owls and they tried to develop plans to conserve spotted owl without following NEPA and NFMA procedures. The courts said they had to stop cutting owl habitat until they had complied with environmental laws. This is the same situation we find ourselves in today with dead-wood associated species. The agencies should stop harming dead wood habitat until they have a legal plan to conserve associated species over the long-term. Seattle Audubon Society v. Epsy, 998 F.2d 699, 704 (9th Cir. 1998) (an agency must re-examine its decision when the EIS "rests on stale scientific evidence and false assumptions").
8-13 Significant Impacts Require an EIS
This is a huge project with very large amounts of commercial logging and biomass removal, and includes several plan amendments that increase the likelihood that this project will have potentially significant impacts on important resource values like wildlife habitat, as well as the many values associated with unroaded areas.
The proposed plan amendment allowing removal of large trees is conditioned on removing only “excess” large down wood, but the forest plan standards to be used to determine what is needed and what is excess are outdated and scientifically discredited.
This project therefore requires an EIS.
Native Juniper Plays an Important Role in the Ecosystem
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We urge the FS to reconsider the plan to remove all but the oldest junipers in this project area. 8-14 We are concerned about the unwarranted "war on juniper" (under the guise of sage grouse recovery). Juniper is a native species that plays an important role in the ecosystem.
Juniper encroachment is a minor issue for sage grouse. Only a fraction of sage grouse habitat is adversely affected by conifer expansion. Most of those places are not high priority for sage grouse recovery.
http://greatnorthernlcc.org/sites/default/files/documents/Inter-LCC%20Greater%20Sage- grouse%20Research%20Projects%20slides_0.pdf
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http://map.sagegrouseinitiative.com/
Severson et al (2017) recommend focusing treatments around existing treeless area in order to maximize the contiguous area of treeless habitat as opposed to patchy treatments. Severson JP, Hagen CA, Tack JD, Maestas JD, Naugle DE, Forbes JT, et al. (2017) Better living through conifer removal: A demographic analysis of sage-grouse vital rates. PLoS ONE 12(3): e0174347. https://doi.org/10.1371/journal.pone.0174347
On federal lands we recommend the following: (i) Focus juniper removal in areas that are a high priority for sage grouse restoration. Also, if sage grouse recovery is the purpose of juniper removal be sure to implement an integrated effort that simultaneously reduces livestock grazing to ensure that 7-15” of grass is available for sage grouse to hide in, and keep livestock out of moist meadows and riparian areas where sage grouse raise their broods. And eliminate livestock fences that also provide perches for predators. There is no point in removing juniper for sage grouse if threats associated with livestock grazing continue to reduce cover, expose grouse to increased predation, and degrade brood habitat. Sage Grouse Initiative. 2014. Private Lands Vital to Conserving Wet Areas for Sage Grouse
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Summer Habitat. Science to Solutions Series Number 4. Sage Grouse Initiative. 4pp. http://www.sagegrouseinitiative.com/wp-content/uploads/2014/09/Science-to- Solutions-Conserving-Wet-Areas-FINAL-LOW-RES-091614.pdf; (ii) Retain all large juniper AND all old juniper trees. Use an inclusive definition of “old” juniper. Old juniper character should be based primarily on tree characteristics, rather than site characteristics (although on rocky sites, old juniper trees can be short and gnarly). Do not limit retention of old juniper to rocky sites. Old juniper can exist anywhere. Some typical characteristics of older juniper are the following: • Crown is flat, rounded, broad at top, or irregular (as opposed to the more pointed tops of younger trees) • Dead “spike” top • Numerous dead branches • Branches covered with a coarse, bright yellow-green lichen (Letharia, or wolf lichen) • Large diameter lower branches • Large diameter trunk relative to height • Trunk has spirally-twisted bark, deep furrows • Hollow trunk. Trees with two or more of these characteristics should be retained. In addition, junipers with cavities and or wood rat middens (adjacent to or in tree) shall be retained. (iii) Small, young junipers might need to be killed, but they do not need to be removed. Just cut juniper by hand and leave the trees on site. DO NOT develop or support new juniper or biomass industries that will remove juniper trees regardless of their ecological benefits; (iv) Protect soil, avoid weeds, protect unroaded areas, avoid new roads, avoid heavy equipment off of existing roads. Avoiding the spread of weeds and exotic grasses may require forgoing juniper treatments in weed infested areas, because planting natives has not proven effective. Kerns & Day (2013) found that juniper treatments may do more harm than good. • In the short term, fuel reduction activities (cutting, slash pile burning, skid trail formation) may have facilitated further conversion of this woodland to an exotic grassland. • Maintaining juniper may be a better option in some cases to preserve ecological function and key species such as bluebunch wheatgrass and native bunchgrass richness, and to avoid exotic annual grass invasion • If juniper canopies must be removed, extensive management intervention prior to and after treatment to lower exotic species propagule pressure and continue to reestablish native perennial species may be critical in obtaining restoration goals. Kerns, B.K., and M.A Day. 2013. Powerpoint: The Crooked River National Grassland Westside Wildland Urban Interface Fuel Reduction Project Effect of Juniper Cutting and Seeding on Vegetation. http://www.firescience.gov/projects/05-2-1-05/project/05-2-1- 05_Kerns_ppt_for_051513.pdf (v) Focus juniper removal on areas where they are just starting to encroach, and where healthy native grass, shrub, and forb communites are still present. This will help minimize the risk of cheatgrass invasion. Rachel Williams, Bruce Roundy. 2016. Ecological Consequences of Pinyon and Juniper Removal; Six Years Later. SageSTEP News. 1 Issue 30, Spring 2016. http://www.sagestep.org/pdfs/newsletter/SageSTEP_News_Issue_30.pdf (vi) Focus on the underlying causes of juniper expansion, e.g., reduce grazing, reintroduce fire, reduce atmospheric CO2 (CO2 makes juniper more drought tolerant). Poulter, B., and D. Frank. Rising CO2 levels are changing how fast forests cycle water. The Conversation, May 12, 2105. http://theconversation.com/rising-co2-levels-are-changing-
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how-fast-forests-cycle-water-40746 citing http://dx.doi.org/10.1038/nclimate2614 (“We found that the effects of increasing atmospheric CO2 alone led to broadleaf species increasing the carbon gain per unit water lost by 14%. Needleleaf species increased carbon gain per water lost by 22%.”)
USGS says, "This woodland expansion is largely a result of a combination of fire suppression and overgrazing. These factors lead to a decline of browse and grass species that competitively exclude juniper and provide the fuels to carry fires that restrict junipers to rocky sites (Burkhardt and Tisdale 1976)." USGS, Status and Trends of the Nation's Biological Resources, Great Basin- Mojave Region. http://web.archive.org/web/20060216143536/http://www.ccsn.nevada.edu/science/Charlet/GRE AT-BN.PDF. The agency should focus on addressing the root causes of juniper expansion, rather than the symptoms. The NEPA analysis (and decision) should consider potential changes to livestock grazing and fire suppression practices.
Extensive livestock grazing began in the late 1800s in many parts of the western U.S. (Wooton 1908, Oliphant 1968, Dahms and Geils 1997, Scurlock 1998, Allen et al. 2002, Hessburg and Agee 2003) and extensive infill and expansion of piñon and juniper began at the same time in many areas (e.g., Miller and Rose 1999, Fuchs 2002, Landis and Bailey 2005; C. D. Allen unpublished data). The coincidence in time between the onset of grazing and of increasing tree density suggests a direct cause-effect relationship, the mechanism presumably being that heavy grazing reduced herbaceous competition with tree seedlings and thereby enhanced seedling survival. Support for this mechanism comes from Johnsen’s (1962) report of markedly better growth of juvenile Juniperus monosperma in places where grass had been removed.
… the indirect effect of livestock grazing also may have been important because sustained heavy grazing reduces grasses and other herbaceous fuels which foster fire spread under both modal and extreme fire weather conditions. In some western ponderosa pine and dry mixed conifer forests, exclusion of low-severity fires has been a principal mechanism driving tree density increases during the twentieth century (e.g., Allen et al. 2002, Hessburg and Agee 2003) … … A logical argument can be made that fire exclusion since the mid-1800s is a primary cause of piñon and juniper infill in savannas and wooded shrublands, and of tree expansion into former grasslands and shrublands. … Grazing intensity was greatly reduced in most of the West after 1930, but effective governmental fire suppression began to be more effective at about that time (Pyne 1982), … … The onset of extensive infill and expansion of piñon and juniper in the late nineteenth century in many areas coincided not only with the beginning of fire exclusion, but also with the end of the “Little Ice Age” and the beginning of a general warming trend and changes in precipitation patterns that continued through the twentieth century. Occupying as they do the transition zone between mesic forests at higher elevations and environments too dry for trees at lower elevations, piñon-juniper
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communities may be especially sensitive to even subtle changes in temperature and precipitation.
It is possible that some or even much of the infill and expansion of piñon and juniper that has occurred during the past 150 years is a more-or-less natural response to short-term and long-term climatic fluctuation. William H. Romme, Craig D. Allen, John D. Bailey, William L. Baker, Brandon T. Bestelmeyer, Peter M. Brown, Karen S. Eisenhart, Lisa Floyd-Hanna, David W. Huffman, Brian F. Jacobs, Richard F. Miller, Esteban H. Muldavin, Thomas W. Swetnam, Robin J. Tausch, Peter J. Weisberg. Historical and Modern Disturbance Regimes, Stand Structures, and Landscape Dynamics in Piñ on-Juniper Vegetation of the Western U.S. Coloroado Forest Restoration Initiative. June 2008. http://oregonstate.edu/dept/range/sites/default/files/Synthesis_on_P-J_Woodlands.pdf.
Juniper trees, along with their berries, provide food and shelter to over sixty species of birds. The Townsend's Solitaire is highly dependent on juniper berries for winter food. The scientific basis for juniper control is highly questionable. Juniper will take care of itself after you remove livestock and reintroduce fire.
Many ranchers, rangeland managers, and range scientists in the Pacific Northwest consider western juniper (Juniperus occidentalis Hook.) to be an invading weed that reduces water infiltration, dries up springs and streams, increases erosion, reduces biodiversity, and reduces the quality and quantity of forage for livestock and wildlife species. Although there is little scientific evidence supporting most of these beliefs, they are currently being used as rationales for controlling juniper on public and private lands. Similar views were held about pinyon-juniper woodlands in the Southwest and Great Basin from the 1940's through the 1960's, when efforts were also made to control woodland expansion.
Pressures to control the further spread of western juniper and reduce its density in woodlands are increasing. Because of the paucity of information on the environmental effects of western juniper expansion in the Northwest, this paper primarily reviews evidence from earlier studies of pinyon-juniper woodlands in the Southwest and Great Basin. These studies rejected similar assumptions about the deleterious effects of pinyon-juniper expansion on ecosystem properties and call into question current rationales for controlling western juniper in the Northwest. These studies also suggest that while the expansion of juniper might alter species composition and decrease herbaceous biomass in grasslands and shrublands, they have few detrimental effects on streamflow, aquatic organisms, soil properties, or wildlife habitat.
... while the expansion of juniper might alter species composition and decrease herbaceous biomass in grasslands and shrublands, they have few detrimental effects on
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streamflow, aquatic organisms, soil properties, or wildlife habitat.... [P]opular conclusions about junipers ignore many of the complexities of natural ecosystems, including the following: 1. In arid and semi-arid climates, most snow- and rain-water simply recharges the soil column; little excess is available to move downslope to streams (Hibbert 1983, West 1984), 2. Herbaceous plants and shrubs that replace trees also intercept rain and snow, reducing the amount of water reaching the ground; 3. Replacement plants also transpire and deplete soil water (Clary et al. 1974, Brown 1987a); 4. Tree removal exposes the soil and understory plants to direct sunlight, causing elevated temperatures and increased evapotranspiration (Clary et al. 1974, Everett and Sharrow 1985); 5. Tree removal exposes soils and understory plants to more wind, which increases evapotranspiration (Everett and Sharrow 1985); and 6. In areas where water is in excess of that needed to recharge the soil, this water may go to shallow aquifers rather than to streams (Hibbert 1983). In other words, studies showing that junipers intercept precipitation and transpire water (Young and Evans 1987, Eddleman and Miller 1992) cannot be used to conclude that this lost water would have ended up in streams and springs. To do so, water budgets of juniper-dominated and juniper-free sites would have to be compared, or long-term changes in streamflow following juniper removal measured. A. JOY BELSKY, Viewpoint: Western juniper expansion: Is it a threat to arid northwestern ecosystems? Journal of Range Management 49:53-59 January 1996, pp. 53-59. http://web.archive.org/web/20001025053434/http://onda.org/Archives/BelskyJuniper.html.
Birds depend on juniper. One study compared bird abundance in four dry ecotypes: 1) recently burned (grassland), 2) shrub steppe, 3) mid-successional woodland (juniper –shrub steppe), and 4) open old growth woodland. "During mid-winter the greatest abundance of birds were observed in the two juniper structural types, with few birds measured in the shrub steppe and grassland communities. The number of observations, however, was highly variable, with the most birds found in the mid-successional stands " Bird Populations in Juniper. http://web.archive.org/web/20060910203801/http://oregonstate.edu/dept/EOARC/researchhome/ currentresearch/wildlifeforestry/birds.html. See: Richard F. Miller, Jon D. Bates, Tony J. Svejcar, Fred B. Pierson, Lee E. Eddleman. June 2005. Western Juniper Biology, Ecology, And Management Of. Technical Bulletin 152. http://web.archive.org/web/20060505042124/http://eesc.orst.edu/agcomwebfile/edmat/html/TB/ TB152/tb152.pdf.
Juniper treatments tend to increase invasion by invasive plants. See Coop & Magee 2016. Integrating Fuels Treatments and Ecological Values in Piñon-Juniper Woodlands: Fuels, Vegetation, and Avifauna Final Report to the Joint Fire Science Program. Agreement number L13ACOO237. https://www.firescience.gov/projects/13-1-04-45/project/13-1-04- 45_final_report.pdf (“Treatments exhibited rapid, large, and persistent increases in the frequency, richness, and cover of 20 non-native plant species including cheatgrass (Bromus tectorum). Exotic plant expansion appears linked to the disturbance associated with treatment activities, reductions in tree canopy, and alterations to ground cover. … [I]ncreased herbaceous
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surface fuels including exotic annuals are expected to alter potential fire behavior via … increased surface fire intensity, flame length, and rate of spread. … We encourage managers carrying out P-J mastication projects to explicitly consider 1) potential trade-offs between desired treatment outcomes and potentially unwelcome impacts …”)
On the other hand, Kerns and Day (2014) found that areas with higher juniper abundance to begin with seemed to show a resistance to invasion by exotic annual grasses, perhaps because the exotics are intolerant to shade. Their work has important lessons for conservation efforts and land management goals, especially given the strong push from ranchers and sage grouse advocates to remove junipers. If a juniper woodland is already invaded by exotic grasses, thinning treatments and their associated disturbances such as slash pile burning and skid trail formation— even if followed by seeding—may not be enough to restore native grasslands in the short term. http://www.fs.fed.us/pnw/research/2015/apr/index.shtml#thinning citing B. K. Kerns and M. A. Day. 2014. Fuel Reduction, Seeding, and Vegetation in a Juniper Woodland. Rangeland Ecology & Management 67(6):667-679. 2014; doi: http://dx.doi.org/10.2111/REM-D-13-00149.1 http://www.bioone.org/doi/abs/10.2111/REM-D-13-00149.1
Contrary to common assumptions there is often a positive relationship between juniper basal area and native grass/forb cover (e.g., bluebunch wheatgrass, Sandberg bluegrass, and richness of native perennial) relative to exotic grasses, while juniper removal tends to increase exotic annual grasses relative to native plants. Even with follow-up seeding with native plants, the treated area was “highly invaded by exotic grass!” Kerns, B.K., and M.A Day. 2013. Powerpoint: The Crooked River National Grassland Westside Wildland Urban Interface Fuel Reduction Project Effect of Juniper Cutting and Seeding on Vegetation. http://www.firescience.gov/projects/05-2-1-05/project/05-2-1-05_Kerns_ppt_for_051513.pdf
Removing juniper can increase cover of weeds such as cheatgrass at the expense of other native plants. Coultrap D, Fulgham K, Lancaster D, Gustafson J, Lile D, et al. (2008) Relationships Between Western Juniper (Juniperus Occidentalis) and Understory Vegetation. Invasive Plant Science and Management: Vol. 1, No. 1 pp. 3–11. http://www.bioone.org/doi/abs/10.1614/IPSM-07-008.1. In fact, juniper is associated with native vegetation cover, while removing juniper tends to spread and increase weeds.
[I]t is a significant challenge for land managers to apply thinning and burning fuel treatments in a manner that does not exacerbate existing weed and associated resource problems. The potential for weed problems is greater at the wildland urban interface (WUI), where diverse source propagules are abundant. We evaluated the effects of fuel reduction activities (thinning, slash pile burning, skid trail formation) and two native seeding treatments (cultivar and local seed) on exotic weed populations and native vegetation in an eastern Oregon juniper woodland … We found that the fuel reduction activities and post-treatment seeding introduced and spread exotic Species … [O]ur data indicated that pretreatment juniper abundance was positively associated with native perennial cover, and negatively associated with exotic species cover. These patterns, coupled with the impact of fuel reductions activities, suggest that reducing juniper
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abundance may not lead to the restoration of native plant community composition even if native treatments are used post-disturbance. Our results suggest that high rates of post fuel reduction seeding in highly invaded juniper woodlands with high propagule pressure, which might be prohibitively expensive for normal management operations, may be effective at establishing high total and native cover, but may still be ineffective at controlling exotic species in areas. … Management Implications … While the historic increase in juniper is viewed as a problem for maintaining native biodiversity, our data suggest that juniper abundance may be the solution in our study area. We found that exotic species cover was negatively associated with juniper basal area; therefore, juniper cover may be limiting exotic species establishment and spread. Moreover, we found in some cases that juniper basal area was positively associated with some native perennial species. These patterns, coupled with the impact of fuel reductions activities, suggest that reducing juniper abundance may not lead to desired future conditions. Kerns, B.K. 2005. Management Options to Control Exotic Invasive Plant Species in Association with Fuel Reduction Treatments in a Wildland Urban Interface, Crooked River National Grassland. FINAL REPORT. JFSP Project ID: 05-2-1-05. http://web.archive.org/web/20130222090427/https://www.firescience.gov/projects/05-2-1- 05/project/05-2-1-05_final_report.pdf
A significant portion of the nutrients in juniper-rangeland ecosystems are contained in the Juniper trees. Cutting and removal of the juniper trees can cause long term depletion of the critical nutrients. We typically recommend that juniper killing be limited to trees under 12 inches diameter and waist height (and retain the largest third of the trees regardless of size). Trees that are killed should be retained on site in a variety of configurations— some scattered, some piled, some burned in place. Where there is a real fuel concern (e.g., near communities) some of the killed juniper could be used for off-site restoration projects or firewood.
Contrary to common assumptions about trees and water yield, new science indicates that moderate tree cover might actually benefit hydrology. Deanna Ramsay 2016. Finding water amid the trees More trees in arid areas could lead to more water access—which is good news for hundreds of millions of the world’s poorest people. http://blog.cifor.org/40702/finding-water- amid-the-trees?fnl=en (“In arid places where water is scarce, the planting of trees is often discouraged out of the belief that trees always reduce the availability of much-needed water. Yet scientists working in Burkina Faso found that when a certain number of trees are present, the amount of groundwater recharge is actually maximized. The study is a “game changer”, according to one of the study’s authors, … ‘The most important point of our study is to show that a trade-off between water and tree cover doesn’t always exist, and that more trees can actually improve groundwater recharge.’ Aida Bargués Tobella”) citing Ilstedt, U.; Tobella, B.; Bazié, H.R.; Verbeeten, E.; Nyberg, G.; Benegas, S.L.; Murdiyarso, D.; Laudon, H.; Sheil, D.; Malmer, A. 2016. Intermediate tree cover can maximize groundwater recharge in the seasonally dry tropics. Scientific Reports 6: 21930. DOI: 10.1038/srep21930 http://www.cifor.org/publications/pdf_files/articles/AMurdiyarso1601.pdf
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New science indicates that the alleged hydrologic impacts of juniper may be miscalculated. The water resources used by trees may be much more segregated than previously thought from the water resources discharged to streams. Once the root zone is recharged, which happens every winter, the trees have little impact on the annual discharge of water to streams. See Oregon State University (2010, January 23). Water hits and sticks: Findings challenge a century of assumptions about soil hydrology. ScienceDaily. Retrieved March 15, 2010, from http://www.sciencedaily.com/releases/2010/01/100121173452.htm. BROOKS, J., H. Barnard, R. COULOMBE, AND J. McDonnell. Ecohydrologic separation of water between trees and streams in a Mediterranean climate. Nature Geoscience. 3, 100 - 104 (2010).Published online: 20 December 2009 | doi:10.1038/ngeo722. http://www.nature.com/ngeo/journal/v3/n2/abs/ngeo722.html http://ore gonstate.edu/ua/ncs/archives/2010/jan/water-hits-and-sticks-findings-challenge-century- assumptions-about-soil-hydrology
Anecdotal information indicating that streams used to be perennial before juniper expansion often overlook other contributing factors such as decadal climate fluctuations. “Our results indicated that removing most PJ in the basin would not produce a perennial stream given climatic conditions of 1981–2013. Instead, anecdotal evidence suggesting consistent stream flow at the beginning of the 20th century was more likely related to wetter and cooler climatic conditions than to changes in upland PJ.” Carroll, RWH., Huntington, JL., Snyder, KA., Niswonger, RG., Morton, C., Stringham, TK. Evaluating mountain meadow groundwater response to Pinyon-Juniper and temperature in a great basin watershed. Ecohydrol. 2017;10:e1792. doi:10.1002/eco.1792. http://onlinelibrary.wiley.com/doi/10.1002/eco.1792/full
If there is an intent to remove juniper to enhance groundwater recharge in mountain meadows for instance, relatively small scale treatments are effective. Landscape scale treatments are not necessary. “Even a small-scale removal of PJ (0.5 km2) proximal to the meadow will promote a stable, shallow groundwater system resilient to droughts.” (See Carroll et al 2017, above).
The agency should carefully consider the trade-offs associated with juniper removal. One of those trade-offs involves the lost opportunity to store carbon that mitigates global climate change. Landscape scale expansion of juniper woodlands is providing an ecosystem service (carbon storage via natural afforestation) and juniper removal erases that benefit. Campbell, J.L., R. Kennedy, W.B. Cohen, and R. Miller. 2012. Regional carbon consequences of Western Juniper encroachment in Oregon. Journal of Rangeland Ecology and Management. 65(3):223- 231. http://larse.forestry.oregonstate.edu/sites/larse/files/pub_pdfs/Campbell_etal_2012.pdf (“unlike forest growth which is balanced by natural disturbance, timber harvest, and land conversion, woody encroachment is assumed to be largely one-directional with the potential result of a [significant] North American net carbon sink. … [T]he highest biomass shrubs with which juniper competes in Oregon (namely, Artemisia spp.) have an average biomass per unit crown cover of only 8% that of juniper (derived from juniper allometry of Sabin [2008], and sage allometry of Rittenhouse and Sneva [1977]). This means that even when juniper cover replaces sage cover on a one-to-one basis (as reported by Miller et al. 2005), aboveground biomass lost in shrubs is less than 8% that gained in aboveground juniper biomass. … This
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study illustrates the capacity of woody removal, over very small areas, to offset encroachment over very large areas …”); See also Barger, N.N., A.R. Archer, J.L. Campbell, C. Huang, J.A. Morton, and A.K. Knapp. 2011. Woody plant proliferation in North American drylands: A synthesis of impacts on ecosystem carbon balance. Journal of Geophysical Research. 116, G00K07, doi:10.1029/2010JG001506. http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/Barger_2011_JG R.pdf (“The greatest tree biomass response occurred in Great Basin sagebrush steppe sites encroached upon by western juniper (J. occidentalis), sites strongly dominated by winter precipitation. … Changes in [above ground biomass] pools were greatest in systems experiencing Juniperus and Pinus spp. Encroachment …”]
Livestock, by annual elimination of herbaceous cover, can cause many of the same effects as juniper encroachment, and many other effects that are far more deleterious. We propose the agency remove livestock and reintroduce fire before controlling juniper. By removing livestock maybe the herbaceous component can increase enough to carry fire and kill some of the juniper trees to reestablish a mosaic of fire driven seral development.
An EIS should be prepared to discuss whether removing livestock, reintroducing fire, and removing roads would be as effective or more effective than juniper control in restoring hydrologic function, fire ecology, and vegetation composition.
Some of the adverse effects ecological of removing juniper might be mitigated by retaining a large proportion of the cut juniper onsite. Adrian D. Manning, , Ross B. Cunningham , David B. Lindenmayer. 2013. Bringing forward the benefits of coarse woody debris in ecosystem recovery under different levels of grazing and vegetation density. Biological Conservation. Volume 157, January 2013, Pages 204–214. http://dx.doi.org/10.1016/j.biocon.2012.06.028
We urge the agency to retain all old juniper trees include those that exhibit the following characteristics: non-symmetrical tops, deeply furrowed bark, twisted trunks or branches, dead branches and spike tops, large lower limbs, trunks containing narrow strips of cambium, hollow trunks, large trunk diameters relative to tree height, and branches covered with bright yellow green lichen (Miller 1999). We urge the agency to be inclusive and retain all juniper that exhibit some (not necessarily all) of the characteristics listed above.
Note: If any of these web links in this document are dead, they may be resurrected using the Wayback Machine at Archive.org. http://wayback.archive.org/web/
Sincerely,
Doug Heiken [email protected]
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Responses to Comment Letter #8
Response to Comment 8-1: Alternative 3 was developed to meet Forest Plan standards. Additionally the Forest plan was developed to be amended as needed.
Response to Comment 8-2: Refer to the Final EA, Chapter 1, Vegetation Condition Need statement and Chapter 3, Vegetation section.
Response to Comment 8-3: Refer to the Final EA, Chapter 3, Fire, Fuels, and Air Quality section.
Response to Comment 8-4: The Final EA, Chapter 2, Vegetation treatments section describes the basal area treatments for each prescription. Most prescriptions describe a “variable density and irregular stand structure would be achieved by varying the residual basal area with a range of 30-120 ft² (basal area would remain higher in clumps of large ponderosa pine and on north facing slopes) with an overall average of 40 ft² per acre”. Less than ½ of the project area have mechanical vegetation treatments proposed. Alternative 3 would treat fewer acres than the Proposed Action. The No Action alternative would not treat any acres.
Response to Comment 8-5: The Final EA at 3-40 states “Proposed treatments would help return the forest to a more resilient and sustainable condition. The overall effect would be a reduction of canopy, ladder, and surface fuels, which would contribute to the success of suppression and protection under most fire scenarios.” Refer to the Final EA, Chapter 3, Fire, Fuels and Air Quality section.
Response to Comment 8-6: The effects to Redband trout are described in the Final EA, Chapter 3, Fisheries section. Mechanical vegetation treatments are not proposed in category 1 or 2 RHCAs unless associated with aspen restoration. Mechanical vegetation treatments proposed in category 4 RHCAs is limited to less than 2 percent of the project area (less than 1,000 acres) and design criteria described in the Final EA, Chapter 2, Design Criteria, would avoid, minimize, reduce or eliminate impacts to RHCAs. Additionally, trees cut would first be left on site as downed wood and utilized as large woody debris for stream restoration. Any biomass that is excess after those activities would be available for biomass removal, piled and burned, or jackpot burned in areas of light fuel loads.
Response to Comment 8-7: The Final EA, Chapter 3, Northern Goshawk section describes the effects to goshawk and their habitat. Refer to Table 48 that shows exactly how much habitat is proposed for treatment. Under the Proposed Action alternative, 72 percent of primary habitat, 51 percent of secondary habitat, and 95 percent of PFAs (post fledging areas) are left UNTREATED. Proposed harvest prescriptions comply with guidelines suggested by Reynolds (1992). Proposed harvest methods are expected to enhance goshawk habitat because of the
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Flat Project Comment Analysis variable density prescriptions. These prescriptions create openings and leave a patchy tree distribution. Variable density prescriptions with incorporating “skips and gaps” create more edge producing a higher prey base for goshawks.
Response to Comment 8-8: The Flat project area was reviewed for areas of undeveloped character using GIS generated maps. This means that past harvest activity older than about 1980 are not included in GIS databases. Therefore, these areas may have been harvested prior to 1980. In fact, many of these areas contain stumps and other visual reminders of the past activities.
The Final EA, Chapter 3, Areas with Undeveloped Character section describes that 3,665 acres of other undeveloped lands greater than 1000 acres occur in the project area. Of the 3,665 acres, 1,040 acres of it is non-forested. The EA states “Under the Proposed Action and Alternative 3, biomass removal and associated activities would occur on approximately 2,642 acres and 2,396 acres of other undeveloped lands greater than 1,000 acres, respectively. Prescribed burning in other undeveloped lands would have no impact to the designation of other undeveloped lands.”
Response to Comment 8-9: Alternative 3 address your concerns and meets Forest Plan standards for big-game cover. Additionally, the Final EA at 1-8 states “The Forest Plan goal for big-game is to provide for the maintenance and enhancement of habitat so as to sustain elk and deer populations at the state management objective level. Studies completed at the Starkey Experimental Station since the Forest Plan was established suggest that the energetic benefits of cover may be inconsequential to elk performance, and that forage or nutritional effects may have the greater impact on individual animal performance (Cook 1998). However, these studies do not dispute elk’s preference for dense forest stands or the numerous studies that show elk using dense stands disproportionately to their availability. Dense conifer stands can contribute to better distribution of elk across available habitat, but this may be more of a disturbance or security issue than a thermal regulation issue.
The Flat project area is primarily (97%) a dry upland forest landscape. Modeling results from Forest Vegetation Simulator suggest that forest plan cover levels may not be sustainable; it is not within the inherent capability of these Hot Dry and Warm Dry sites to maintain high levels of cover. Retaining canopy closures greater than 50 percent within these dry forest types is not sustainable and would not fully meet the purpose and need of the project. Being below cover standards is necessary to maintain sustainable functions and forest health (Powell, 2012) by having the stands in the warm dry and hot dry PAG meet cover they would be well within the zone of eminent mortality thus increasing probability of insect and disease problems due to high density (Cochran and James, 1999). Summer range in the Flat project is estimated at about 45,775 acres in four subwatersheds.” Also the effects to big-game are broken out by population, cover, forage, roads and HEI; see the Final EA, Chapter 3, Rocky Mountain Elk and Mule Deer section from pages 3-96 through 3-109.
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Response to Comment 8-10: See the EA at 3-93 for effects to snags. “The larger snags, which are most important to wildlife, can be created over time from prescribed fire. Moreover, recruitment of these larger snags in the long term (>50 years) is enhanced due to increase in growth rates of remaining trees. Snag pulses are anticipated from prescribed fire moving snag distributions closer to reference conditions where these high snag densities are below desired levels.” See also the EA at 2-2 “A “non-commercial size” restoration alternative that restricts tree removal to 8-10” DBH was considered but eliminated from detailed analysis because it does not meet the purpose and need. By not treating all sizes of conifers up to 21 inches DBH, Alternative A would not meet the component of the purpose and need to “capture the economic value of harvested timber” and would not fully meet the components of the purpose and need to “Improve vegetation resilience and resistance to insects, disease and wildfire” and “Increase the diversity and structure of forest vegetation communities”.” Response to Comment 8-11: The U30 aspen treatment has been reduced in the Final EA to 173 acres. See the EA at 1-18. See the EA at 1-9. “Aspen inventories in the Flat project area identified less than 3% of the project area contains aspen…. Many aspen stands are less than 3 acres in size. The small size of most aspen stands demonstrates the urgency needed for treatment.” See also 3-25. “Removal of competing conifers is considered essential for strong aspen regeneration (jones et al. 2005). Managers in our area agree that all conifers should be removed in treated aspen stands, except for those that must be retained to meet other management objectives (e.g., large-tree conservation or stream shading). The EA at 2-7 states “Conifer trees between 21” and 30” DBH would first be converted to snags and down wood to meet forest plan standards, then any excess trees would be available to be removed and utilized as biomass. Conifers greater than 30” DBH would not be cut. No tree that is stabilizing the bank of a stream would be removed regardless of size or relation to aspen trees.” The treatment would at most occur on at most 0.3 percent of the project area.
Response to Comment 8-12: The Final EA, Chapter 3 at 3-88 clearly states that “Since the publication of Thomas et al. (1979), new research indicates that more snags are needed to provide needs for some wildlife species and other ecosystem functions.” The Final EA, Chapter 3 at 3-92 also references DecAid, “which is a compilation of research by Mellen (2012) which determined tolerance levels for certain species of MIS cavity nesting birds based upon snag densities estimated within desirable habitats.” See also the Final EA, Chapter 3 at 3-95, Figures 24 and 25, which demonstrate the short and long term changes to snag densities by alternative.
The Malheur NF is currently in the process of revising the forest plan, with the final EIS scheduled to be released in 2017.
Response to Comment 8-13: The type of NEPA document, whether EA or EIS, is dependent on the effects of the project. Projects that would have significant effects would require and EIS. The effects to all resources are discussed in Chapter 3 of the EA, and support a Finding of No Significant Effects (FONSI) which is included in the Draft Decision Notice.
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Response to Comment 8-14: We are not proposing to remove all but the oldest junipers in the project area. We are proposing to reduce the number of juniper in Vegetation Treatment units which is less than one half of the project area acreage. See the EA at 3-28 for effects to juniper.
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