Southern California National Forests Land Management Plan Amendment

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Final Supplemental Environmental Impact Statement

Appendix 4 Response to Comments on the Draft Supplemental Environmental Impact Statement

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Table of Contents Response to Comments ...... 1 Introduction ...... 1 The Content Analysis Process ...... 1 Development of Concerns and Selection of Sample Statements ...... 2 Response to Comments ...... 2 Demographics ...... 3 Agency and Elected Official comments ...... 3 Organized Response (Form Letters) ...... 5 Late Filed Comments ...... 6 Attachment 1 – Response to Comments with Sample Statements ...... 7 Section 1. Comments supporting or opposing the alternatives, and general comments about the analysis and maps ...... 7 Section 2. Comments about the decision-making process, public involvement, and conformance with laws and regulations...... 21 Section 3. Comments about the alternatives considered...... 24 Section 4. Comments about funding, monitoring, and adaptive management...... 34 Section 5. Comments on the effects analysis...... 45 Section 6. Comments about resource and infrastructure management...... 49 Section 7. Comments about transportation systems and recreation management...... 81 Section 8. Comments about wilderness and wild and scenic rivers...... 101 Section 9. Comments on economic and social considerations...... 123 Section 10. Specific comments on the IRA Evaluations ...... 129 Attachment 2 – Agency and Elected Official Letters ...... 149

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response to Comments Introduction Comments on draft environmental documents play an important role in the environmental review process. The Forest Service accepted comments during a 90 day comment period that ended on May 16, 2013. The Forest Service response to those comments is guided by the Council on Environmental Quality (CEQ) Regulations that implement the National Environmental Policy Act (NEPA). Those regulations require: § 1503.4 Response to comments (a) An agency preparing a final environmental impact statement shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed below, stating its response in the final statement. Possible responses are to: (1) Modify alternatives including the proposed action. (2) Develop and evaluate alternatives not previously given serious consideration by the agency. (3) Supplement, improve, or modify its analyses. (4) Make factual corrections. (5) Explain why the comments do not warrant further agency response, citing the sources, authorities, or reasons which support the agency's position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or further response. (b) All substantive comments received on the draft statement (or summaries thereof where the response has been exceptionally voluminous), should be attached to the final statement whether or not the comment is thought to merit individual discussion by the agency in the text of the statement. Because of the volume of comments received, this appendix presents a summary of the comments and the Forest Service response. All comments filed during the comment period are available online in the public comment reading room on the project website. The Content Analysis Process Comments on the Southern California National Forests Land Management Plan Amendment Project were analyzed and categorized using a process called content analysis. The content analysis process consists of sorting comments, analyzing them, entering the analysis into a database, and using database reports to write a Summary of Public Comment that summarizes the concerns raised in the comments. The work was completed by a contractor supervised by the Forest Service NEPA Services Group located in Salt Lake City. A copy of their report is available in the project record. The goals of the analysis process are to: • Ensure that every comment is considered. • Identify the concerns raised by all commenters. • Represent the breadth and depth of the public’s viewpoints and concerns as fairly as possible. • Present those concerns in such a way as to facilitate the Forest Service’s consideration of comments. A comment can be a single statement within a submission, or a whole submission, which may have been delivered by letter, email, the web portal, or a comment card completed at a public meeting. Comments are sorted to identify all unique content. Some letters are signed by different individuals but have identical content; these are called “form letters,” and only one example of each form letter type (called the master form letter) is analyzed as a unique comment.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Some individuals have submitted form letters but have added information to them; these are called “form plus letters.” For form plus letters, only the added information that is not redundant to the content of the form and adds substance is analyzed as a unique comment. Form letters are usually associated with an organized mail campaign that is described later in this Appendix. Names, contact information, and letter text for all parties who submit comments are entered into the Forest Service Comment Analysis and Response Application (CARA) database. Analysts then read and code unique and form plus comments using a coding structure in CARA. Each comment is coded by subject and verified though a quality control process for accuracy and consistency. This process and resulting documentation do not replace comments in their original form. Rather, they provide a map to the comments. It is important to recognize that the consideration of public comment is not a vote-counting process in which the outcome is determined by the majority opinion. Relative depth of feeling and interest among the public can serve to provide a general context for decision-making. However, the appropriateness, specificity, and factual accuracy of comment content provides the basis for the agency response. Development of Concerns and Selection of Sample Statements The NEPA Support Group analysts use database reports to track all input, identify the public’s concerns, and analyze the relationships among them. The final analysis document includes a list of public concern statements. Each concern usually represents several comments, and in some cases the concern represents many comments. When a concern represents multiple comments, the concern is accompanied by one or more sample statements excerpted from the original comment letters. These sample statements form the basis of the Forest Service response to the concern. Each letter, email, or comment form received is assigned a unique number, and each comment identified within that letter or email is also assigned a number. The combination of the letter and comment number allow the analysts to track the comments assigned to the concerns. There is a database report available in the project record that identifies the relationship between each letter and the concerns. The local interdisciplinary team (IDT) assigned to the project refined and edited the concerns and sample statements. The result of that work is incorporated in this appendix. The NEPA Services Group grouped the concerns into nine sections. These nine sections address comments on the Draft SEIS. The IDT completed an additional review of comments related to the IRA Evaluations included in the SEIS Appendix 2. Substantive comments related to the SEIS Appendix 2 are addressed in Section 10. The full review of IRA specific comments is available in the project record. Response to Comments The Forest Service used all the approaches identified in the CEQ regulations to respond to comments. This section summarizes how those approaches were applied. The complete agency response is in Attachment 1 of this appendix. Modify alternatives – The Forest Service modified alternatives to revise the land use zone mapping when a comment identified a feature that was missed in the Draft SEIS. Some of these corrections included facilities under permit, roads, or trails. Correcting the land use zones around the Mount Baldy Ski Area is one example of this type of correction. The Forest Service

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

also modified specific alternatives to add areas to the analysis. For example, areas of RW zoning were added around the Salt Creek and Fish Canyon IRAs in response to comments. Evaluate additional alternatives – The Forest Service developed Alternative 2a in response to comments and new information. While Alternative 2a is very similar to Alternative 2, the differences in the LUZ allocations for the Salt Creek, Fish Canyon, Raywood Flat, and Eagle Peak IRAs were important to capture as a separate alternative. Other suggested alternatives, such as an alternative to reduce restrictions in the IRA, were considered but eliminated from detail study as described in Chapter 2 of the Final SEIS. Supplement, modify, or improve the analysis – The Forest Service clarified text as needed to respond to comments. As an example, the introduction section of Chapter 4 was edited to address the analysis assumptions, the types of effects caused by forest plan decisions, and the relationship to activities allowed “by exception”. Make factual corrections – the document was corrected as necessary when factual errors were pointed out. Explain why no response was needed – Comments that support or oppose certain alternatives, or advocate specific approaches to management of the National Forest do not require a response, because they do not indicate a conflict with the underlying analysis. They are an important part of the process, and the range of comments received in support or opposition is represented in the concerns included in Section 1 of the Response to Comments. If a response was not required for a substantive comment on the analysis, the Forest Service provided a reason why a response was not required. Demographics The Forest Service received over 11,000 comment letters, emails, or comment cards, including 1,739 postcards that were delivered together in a box (represented by letter #9415 in the CARA database). As described below, over 96% percent of the filings are associated with an organized response, more commonly referred to as form letters. There were also 338 duplicate letters. Duplication can occur when an individual submits comments using a combination of mail, email, and/or the web portal. After accounting for the form and form plus letters and duplication, there were 456 unique letters received. A more complete review of the demographics is available in the NEPA Services Group report available in the project record. Agency and Elected Official comments Letters received during the comment period from elected officials and federal, state, and local governments are listed in Table 1 and included in Attachment 2.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Table 1. Letters received from elected officials and agencies. Letter Elected Official Title Area Number Hannah-Beth Senator, 19th District California State Senate, 7999 Jackson Nineteenth Senate District Salud Carbajal First District Supervisor County of Santa Barbara 9406 Doreen Farr Third District Supervisor County of Santa Barbara 9407 Steve Bennett Supervisor, First District County of Ventura 9271 Kathy I. Long Supervisor, Third District County of Ventura 7466 Federal Agency Letter Title Agency Official Number Penny Ruvelas Southern California Area National Marine Fisheries 9430 Office Supervisor Service Kathleen Martyn Manager, Environmental United States 7192 Goforth Review Office Environmental Protection Agency, Region 9 Steve Kirkland California Condor Field USDOI Fish and Wildlife 8737 Coordinator Service Patricia Sanderson Regional Environmental USDOI, Office of (Late filed Port Officer Environmental Policy and on 5/17) Compliance State Agency Letter Title Agency Official Number John Bunce Chief, Southern Field California Department of 9297 Division Water Resources County Agency Letter Title Agency Official Number Frank Vidales Acting Chief, Forestry County of Los Angeles 8880 Division, Prevention Fire Department Services Bureau Joan Rupert Section Head, County of Los Angeles 8870 Environmental and Department of Parks and Regulatory Permitting Recreation Section Matthew Dubiel P.E. Los Angeles County 8864 Department of Public Works Chandra L. Wallar County Executive Officer County of Santa Barbara 8718 Christney Barilla Senior Planner County of San 8666 Bernardino Land Use Services Department Brian Albright Director County of San Diego 8736 Department of Parks and

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Recreation Tricia Maier Manager, Planning County of Ventura 8750 Programs Section Resource Management Agency, Planning Division City Agency Letter Title Agency Official Number Charles Holloway Manager of Environmental Los Angeles Department 9191 Planning and Assessment Of Water And Power Mike Bell Fire Chief Rancho Cucamonga Fire 8818 Protection District Michael Smith Associate Planner City of Rancho 8818 Cucamonga Other Agency Letter Title Agency Official Number Anthony C. Executive Officer Main San Gabriel Basin 9189 Zampiello Watermaster Deirdre West Manager, Environmental Metropolitan Water 9405 Planning Team District of Southern California Alan J. De Salvio Supervising Air Quality Mojave Desert Air 8983 Engineer Quality Management District Organized Response (Form Letters) Organized responses represent 96 percent of the total responses received during the public comment period (i.e., 10,373 out of 10,829 total, non-duplicate letters). Responses received from different individuals but containing identical text, or identical text plus brief additional comments that are similar in content, are defined as organized response campaigns. Once an organized response campaign letter is identified, a “master” is entered into the database with all of the content information. All responses with matching text are then linked to this master within the database. Only the master form letter is included in the analysis of comments. The following table (Table 2) presents the total number of form and form plus letters received for each organized response campaign and summarizes the concerns found therein.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Table 2. Summary of form and form plus letters. Organized Response Total Summary of Organized Response Campaign Letter Campaign Form Received Number Form Master General request to adopt Land Use Zone Alternative 3 to designate wilderness and protect natural resources and recreation #9194 177 opportunities. Form Master General request to adopt Land Use Zone Alternative 1 and retain public Petitions # 7927 117 access to lands. Form Master 35 Variation of Form Master #100. #95 Form Master Support for additional wilderness designation in Los Padres National 23 #100 Forest. Form Master #101 33 Variation of Form Master #100. Form Master Request to designate Simi Hills-Santa Susana Mountains and 24 #103 recommended wilderness area. Form Master Support for Land Use Zone Alternative 3 for Fish Canyon, Tule, and Salt #104 3 Creek IRAs. Form Master 29 Variation of Form Master #100. #107 Form Master 32 Variation of Form Master #100. #112 Form Master #142 3 Variation of Form Master #100. Form Master General request to adopt Land Use Zone Alternative 3 and Monitoring #243 4,680 Alternative C. Form Master Support for Land Use Zone Alternative 2 to protect natural resources and #394 59 provide recreation opportunities. Form Master Support for wilderness and wild and scenic river designation in the 3,324 #3953 Southern California National Forests. Form Master General request for greater protection of roadless areas in the Trabuco 67 #8916 District. Form Master Support for Land Use Zone Alternative 1 or modified Land Use Zone #9277 6 Alternative 2 with mountain biking access. General request to recommend wilderness designation (Land Use Form Master Zone Alternative 3) for all IRAs in the Land Management Plan, 4 #9355 as Land Use Zone Alternative 2 allows for development and resource extraction. Form Master 1,739 Postcards supporting additional wilderness on the Los Padres #9415 National Forest. Late Filed Comments The Forest Service planning regulations (36 CFR 219.56) establish the standards used to determine if a comment was submitted within the comment period. The Forest Service review relies on evidence that a comment was sent prior to or on the last day of the comment period. For this plan amendment, any comment postmarked, time stamped, or hand delivered after May 16, 2013 is considered late filed, and that comment is not included in the public comment reading room. There were approximately 40 late filed comments.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Attachment 1 – Response to Comments with Sample Statements

Section 1. Comments supporting or opposing the alternatives, and general comments about the analysis and maps. Concern # 1 Concern: The Forest Service should adopt the supplemental environmental impact statement for the Southern California National Forests Land Management Plan. Sample Comment #7917-1 - San Diego Gas & Electric Company (SDG&E) appreciates Statements: the opportunity to comment on the Draft Supplemental Environmental Impact Statement (DSEIS) for the Southern California National Forests Land Management Plan (LMP) Amendment. SDG&E supports and commends the USFS on its efforts to amend the LMP and is generally supportive of the effort. [Utility Group (water, electrical, gas)] Comment #12-1 - I whole-hardheartedly support the Draft Land Management Plan Environmental Impact Statement. [Individual] Response: Comments that support (or oppose) the SEIS or any particular alternative are noted for the record and are considered by the responsible official as part of the decision making process. These comments in particular do not require a change or a specific response in the Final SEIS because the factual basis of the analysis is not being questioned. Concern # 2 Concern: The Forest Service should not adopt the proposed amendments for the Southern California National Forests Land Management Plan because of the impact on mountain bike use. Sample Comment #8028-1 - These are my comments on the Draft Supplemental Statements: Environmental Impact Statement, Southern California National Forests Land Management Plan. I will focus on the Angeles National Forest. As a mountain bicyclist, I was extremely pleased with the original Land Management Plan. The Forest's use of Backcountry Non-Motorized zones was an elegant, balanced approach that provided high levels of resource protection while allowing for responsible outdoor recreation. The Forest plans acknowledged that recreation was the primary use of the SoCal forests. As such, recreation should be encouraged. I consider the BCNM zone to be superior to Wilderness designation because it allows bikes on trails and because it gives the Forest more discretionary management options. I was disappointed when the Forest was forced to begin this costly amendment process. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #8814-7 - Instead of addressing the real management issues what we have is this ridiculous proposal that locks in the existing management scheme by designating the area as a federal wilderness area. I cannot think of a worse management guide for the future than the ones being proposed here. [Individual] Response: We recognize that Alternatives 2, 2a, and 3 will have an impact on mountain bikes, and those impacts are described in the roads and trails section of Chapter 4. Concern # 3 Concern: The Forest Service should not adopt Land Use Zone Alternative 1. Sample Comment: 394-3 - I do not believe Alternative #1 “No Change” is appropriate Statements: because it provides no additional protection for our Forest’s wildlands. (Individual) Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comment listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern # 4 Concern: The Forest Service should adopt Land Use Zone Alternative 1. Sample Comment #2237-1 - The LPFA supports Alternative 1. Expansion of wilderness Statements: is an increase in cost to the Forest Service Recreation dollars, which continue to shrink. We support all user groups and we would like to see our recreational forest continue to support all groups. There should be a proposed plans to keep our recreational trails open to all before we make changes that make them harder to maintain. [Environmental Conservation/ Preservation] Comment #59-1 - No More Restrictive Land Use. Putting Wilderness or any more restricted zones around OHV trails invites increased scrutiny in those areas and more stipulations for further closures, which can negatively affect our local economy. Alternative "A" [Individual] Comment #46-1 - I support Alternative 1 which means I think the current plan as it stands is an adequate compromise between multiple use and wilderness protection in the Southern California National Forests. With over 48 percent of the Los Padres national Forest having wilderness designations there is more than enough wilderness. I especially do not like any alternative that changes Back country designation to back country non-motorized designation as I feel motorized recreation can play a vital part for recreating in back country designated areas and motorized and power equipment plays a vital role in fire suppression that would be eliminated with the change of back country non- motorized designations. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern # 6 Concern: The Forest Service should adopt Land Use Zone Alternative 1 to maintain current mountain bike access opportunities. Sample Comment #8550-28 - CNF - Barker Valley IRA: I support Alternative 1 and Statements: oppose Alternatives 2 and 3. The main issue I have with the proposed Recommended Wilderness is that there are very few trails in the Palomar Ranger District that are open to bikes. To my knowledge, there are only three: Barker Spur Trail, Oak Grove Trail, and Cutca Trail. The District Manager present at the scoping meeting held in Ramona in March said this is not true, that all trails outside of Wilderness in the Palomar Ranger District are open to bikes; however, she could not name any other such trails. For this reason I think it is unreasonable to cut off further mountain bike access by putting one of these trails into Recommended Wilderness. [Individual] Comment #8550-4 - CNF - Caliente IRA: I support Alternative 1 and oppose Alternatives 2 and 3. There is little in this IRA in the way of trails. Only the Pacific Crest Trail crosses this area as far as I know. And there are no trails currently open to bikes. However, as you may or may not have heard some members of the mountain bike community are campaigning to open the PCT to bikes. Whether this is doable or not is a matter of opinion; however, there are many, myself included, who believe the PCT is a perfect trail for mountain biking with many 20-30 mile segments which are well suited for bikes, sustainably built trail, and few users on the trail. In the event the trail is opened to bikes eventually, this small patch of Wilderness in the Caliente IRA would become a huge roadblock on what is now a continuous 156mile segment of PCT which is not blocked by Wilderness and would represent the best long- distance bike route in Southern California, if not all of California. On that basis I object to proposing this IRA as primarily Recommended Wilderness. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #7 Concern: The Forest Service should adopt Land Use Zone Alternative 1 or 2 to maintain current mountain bike opportunities within the existing land use zones or within corridors that allow mountain bike trails. Sample Comment #51-1 - I live and work in Ventura County. I am a regular user of Los Statements: Padres National Forest; mostly mountain bike use and hiking. I am in favor of "no change" or "backcountry non-motorized use." [Individual] Comment #8875-5 - In summary I would encourage you to not adopt the complete Recommended Wilderness Area option. The mountain bikers that would be using the Salt Creek, Fish Creek areas of the Angeles National Forest are outdoors to enjoy the beauty, remoteness and history of these areas while also getting exercise and participating in outdoor activities in a responsible manner. Either option of "No Change" or providing corridors along the old trails for non motorized vehicles would be what our organization would like to see. [Recreational (incl. permittees)] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comment listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #8 Concern: The Forest Service should adopt Land Use Zone Alternative 2 to maintain mountain bike opportunities in key areas, particularly the Fish Canyon and Salt Creek IRAs on the Angeles National Forest. Sample Comment #8870-1[Sample Statement] Alternative 2 The Department and the Statements: ANFS share a common goal of protecting the environment and permitting prudent, responsible public access to public lands for recreational uses. Both the Department and the ANFS non-motorized, multi-use (equestrian, hiking, and mountain bicycling) trails provide trail connectivity which also creates important recreational corridors that should remain open in perpetuity. In 2007, the County Board of Supervisors adopted a Trails Plan for the Santa Clarita Valley and a portion of the Antelope Valley. Among other things, this Plan created trail connectivity north from the Castaic Lake Trail to the ANFS trails as identified in Alternative 2, "Proposed Action". Proceeding north on the ANFS trails, there is additional connectivity to the federal Pacific Crest Trail (PCT) and other County proposed trails north and northeast of the PCT. It is important that the connectivity of this carefully crafted trail system remain in place so future generations can access County, ANFS and other jurisdictional, non-motorized trails as well. As such, the Department supports Alternative 2, Proposed Action. [County Government Agency /Elected Official]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #9272-1[Sample Statement] In my opinion, Alternative 2 - The Proposed Action, best meets the needs of protecting and managing the land, everyone living and recreating in the affected area, the intent of NEPA, and complying with the appellate court's decision. [Academic/Professional Society] Comment #129-1[Sample Statement] I am writing in support of Alternative 2 for the US Forestry plans for the Angeles National Forest. Mountain biking is a sport enjoyed by many, and I think it is a reasonable compromise to accommodate them [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. As the sample comments recognize, Alternative 2 was designed to accommodate mountain bike use in the Salt Creek and Fish Canyon area. Concern #9 Concern: The Forest Service should adopt Land Use Zone Alternative 2 (designate areas as Back County, Non-Motorized) for the IRAs identified in the comments. Sample Comment #232-1 - R.E. Cactus Springs B & Pyramid Peak A Inventoried Statements: Roadless Areas. I support ALT-2 regarding this area. I do a lot of work on the PCT in this area and brush is a big problem. This will allow us to continue to use the tools we need to keep these trails open. As an equestrian, I like the non- motorized designation. [Multiple Use or Land Rights Organization] Comment #6008-33 - Raywood Flat B IRA: We support Alternative 2 for this IRA. We would also like all Wildland Conservancy lands therein to be added when that organization is agreeable to that designation. General description: The Forest Service has already recommended a 3,890 acres of this IRA. This proposed San Gorgonio Wilderness Addition is best known as Yucaipa Ridge or Oak Glen Divide. It traverses from the south wall of Mill Creek Canyon, a tributary of the Santa Ana River, a candidate wild and scenic river, to the north wall above Oak Glen’s high plateau apple country. From west to east, the area rises in gentle hills just east of the Mill Creek Ranger Station, becoming progressively higher and more welted as it leads eastward to Galena Peak. It climaxes in a steep rampart of jagged pinnacles before joining the San Gorgonio massif at the head of Mill Creek. The Wildlands Conservancy has purchased the lands surrounding Wilshire Peak and Birch Mountain since the LMP was published. Thus, it now makes since to add lands east of Yucaipa Ridge Road (1S09) including the following sections: Sections 19 (portion owned by Wildlands Conservancy), 20, 21, and 30 T 1S R 1E. [Environmental Conservation/ Preservation] Comment #8718-3 - The Fox Mountain IRA is located near the South Cuyama Oil Field and unincorporated town of New Cuyama to the north. The maintenance or future provision of recreational activities such as mountain biking would be desired. In addition, the nearby active South Cuyama Oil Field may suggest the potential for future leasing within the LPNF in exceptional

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

circumstances only. This area serves as a transitional area between the valley floor and the San Rafael Wilderness beyond. Therefore, we support the proposed action (Alternative 2) to designate this area as Back Country, Non- Motorized (BCNM), with the retention of existing peripheral road access within the BC and BCMUR designations. [County Government Agency /Elected Official] Comment #8876-28 - Tequepis IRA: We support Alternative 2 for this area. The BCNM LUZ, in conjunction with the RACR, would provide adequate protection for its social and ecological values. Please also see the comments on this IRA offered by Los Padres ForestWatch. Those comments are incorporated by reference. [Environmental Conservation/ Preservation] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support Alternative 2 based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #10 Concern: The Forest Service should adopt Land Use Zone Alternative 2 or 3. Sample Comment #240-3 - I also support wilderness protections in option 2 and option Statements: 3 , most notably Barker Valley and Aqua Caliente at Warner Springs. [Environmental Conservation/ Preservation] Comment #160-1 - I would seriously encourage this agency to select either alternatives #2 or #3 for implementation in order to preserve these forests. We have to protect what little wilderness and pristine forest land without more roads or trails added for the OHV users to abuse or ignore. Those like myself, do not mind hiking into an area especially because we enjoy the solitude and pristine nature we find there, without the roar of off road vehicles or trash they bring. Let those who want to ride go ATVs to a designated site like Hungry Valley or the many others in the area. I do not want to see our forests start to look like what has happened to all of the hillsides(private or public) along the drive on from Santa Barbara to San Diego, any of the highways in socal. This devastation did not happen until the last decade or so and it should never happen in our forests. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #11 Concern: The Forest Service should not adopt Land Use Zone Alternative 3 because of the impacts to mountain biking and motorized use. Sample Comment #8879-2 - I am opposed to the U.S. Forest Service proposal to Statements: reclassify 525,472 acres as wilderness areas in Southern California. This classification would prohibit additional road construction, commercial development, mountain biking as well as the banning of motorized vehicles as proposed under Alternative 3. [Individual] Comment #394-4 - I do not support the Alternative #3 “Recommended Wilderness” land designations because it eliminates many non-motorized recreational opportunities like mountain bicycling, it more than doubles the cost of trail maintenance while severely limiting maintenance resources, and it breaks up a community of Forest care stewards. [Individual] Comment #8028-7 - I am completely opposed to Alternative 3 which re- designates most of the roadless BCNM zones as RW. There are many trails in those areas that are enjoyed by mountain bicyclists. The only practical result of Alternative 3 would be eliminating mountain bicyclists from those trails.. That would be very injurious to the bike community and the increasing number of cyclists in Southern California, especially in the Santa Clarita area. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #12 Concern: The Forest Service should adopt Land Use Zone Alternative 3. Sample Comment #2300-1 - Alternative 3 is the best choice to become a part of the Statements: revised forest management plan for Los Padres National Forest. We need to have more land to be preserved as wilderness area. This designation would help to protect us from more oil drilling, timber clearcutting, roadbuilding, and off- road vehicle trails. We need to protect our natural areas to keep the earth and ourselves healthy. [Individual] Comment #8904-1 - Although I am an avid cyclist, over the years, my love for nature transcends the brief exhilaration of riding. It is my opinion that land management Alternative 3 will best preserve the undeveloped areas. Cell phone towers, mining, and off road vehicles are not part of a wilderness. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #9194-1 - Please adopt land management Alternative 3, which includes wilderness recommendations for all 67,715 acres of the undeveloped roadless areas under consideration in the San Gabriel Mountains. Alternative 3 will best protect wildlife, habitat and varied recreational opportunities. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #13 Concern: The Forest Service should adopt Land Use Zone Alternative 3 (designate areas as recommended wilderness) for the inventoried roadless areas identified in the comments. Sample Comment #8658-1 - OCCNPS believes that Land-Use Alternative 3 and Statements: Monitoring Alternative C for the Trabuco District are environmentally superior to the other Alternatives in the specifics of what’s appropriate in the Inventoried Roadless Areas (IRAs) and also in what’s monitored for. Most importantly, their underlying assumptions about what the National Forests’ purposes are and how their management should be done is much more in line with current ecological research and resource-management thinking. [Environmental Conservation/ Preservation] Comment #8832-3 - In Angeles National Forest I would like to see all four areas in the northwest as Recommended Wilderness: Fish Canyon, Salt Creek, Red Mountain and Tule. The hiking trails should be included in Wilderness as in Alternative 3. All of the areas along the West Fork San Gabriel River should be Recommended Wilderness as in Alternative 3. [Individual] Comment #6008-20 - Cucamonga C IRA: We support Alternative 3 for this IRA. General Description: The LMP did not recommend any portion of Cucamonga C as wilderness leaving 4,102 acres as non-wilderness even though the adjacent Angeles National Forest recommended adjacent IRA lands to the west as recommended wilderness. Cucamonga C’s southern boundary is San Sevaine Road 1N34. The southwest boundary to Cucamonga C begins at the boundary between the Angeles and San Bernardino NFs in Sections 6 and 7, T 1N R 8W. The boundary for our recommended Cucamonga Wilderness Addition follows the border from its contact point with the southern boundary of the Cucamonga Wilderness to Forest Service System Road 1N35. Then, the boundary follows both 1N35 and 1N34 eastward at a distance of 300 feet from the centerline. The boundary continues east like this until 7W04 and the Joe Elliot Tree Memorial cherry-stemmed road is met. This is where the proposed wilderness addition meets the Forest Service recommended wilderness boundary for Cucamonga B IRA. [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #8876-4 - Antimony IRA: This key IRA supports historic condor nest sites and habitat for other rare species. It borders the San Andreas Fault, serves as a habitat connection between the national forest and the Wind Wolves Preserve, one of the state’s key condor reintroduction sites. The IRA also contains several rock art sites and other areas of cultural significance. Because of these values, we encourage the USFS to select Alternative 3 for this area. Please also see the comments on this IRA offered by Los Padres ForestWatch. Those comments are incorporated by reference. [Environmental Conservation/ Preservation] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #14 Concern: The Forest Service should adopt Land Use Zone Alternative 3 and Monitoring Alternative C. Sample Comment #2167-1 - I urge you to support Alternative 3 and I Monitoring Statements: Alternative C in the Land Management Plan Amendment. The successful recovery and restoration of endangered species (such as the southern steelhead) depend on pristine and protected headwater streams for spanning and rearing. Keeping these areas free of new roads and development, and the resulting erosion, is critical for federal recovery efforts to be successful. Wilderness additions to the Sespe, Matilja, and other wilderness areas will help to ensure this recovery while providing unique and low impact recreation for generations to come. Safeguarding these locations and maintaining them as roadless will also help reduce backcountry fires and maintenance costs to the Forest Service. [Individual] Comment #1807-1 - I support the maximum about of wilderness protection. We need to protect all we can for future generations and wilderness is the best protection. I support for Alternative 3 in the LMP Amendment because this alternative maximizes the amount of recommended wilder your support for Monitoring Alternative C. I also support Monitoring Alternative C. Thank you for your wilderness recommendations.' [Individual] Comment #5327-1 - After reading through the “Draft Supplemental Environmental Impact Statement(SEIS), Southern California National Forests Land Management Plan (LMP) Amendment” we have come to the conclusion that we support Alternative 3 in the LMP Amendment as it will protect the largest area of land in its current road less condition. I know the Los Padres Forrest motto is “Land of Many Uses”, but we really don’t like roads as it leads to ultimate degradation of pristine forest environments which we hold dear. We also support Monitoring Alternative C to protect and preserve as much of the

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

back country area as possible for future generations. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #15 Concern: The Forest Service should adopt Monitoring Alternative C. Sample Comment #7916-13 - CNPS finds that Monitoring Alternative C addresses the Statements: integration of management (monitoring) with natural processes that is more in line with current ecological research and resource management thinking, and incorporates sampling and analysis processes that will help protect native plant resources more than Monitoring Alternatives A or B. We support the adoption of Monitoring Alternative C. [Environmental Conservation/ Preservation] Comment #6008-59 - Of the alternative monitoring scenarios provided in the SDEIS, we strongly support Alternative C, the Conservation Alternative for monitoring and evaluation requirements, because it: • Capitalizes on data sets that have already been collected and/or that are already being collected to analyze and allows them to be evaluated in numerous ways (ex. by watershed, by fire history, by development); • Supports annual monitoring and reporting on management activities and as well as incorporating new inventory data and other scientific and technical information. Keeping the data sets up to date will facilitate the opportunity to evaluate and analyze the best management decisions for managers; and • provides statistically robust annual implementation monitoring of new projects and ongoing activities as well as a strong validation protocols that will be able to detect problems with implementation of the best management practices and design criteria in a timely manner in order to determine whether those design criteria are in fact effective. [Environmental Conservation/ Preservation] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #16 Concern: The Forest Service should adopt existing or revised Monitoring Alternative B. Sample Comment #7916-14 - We also recognize the modifications to Monitoring Statements: Alternative B as proposed in a joint comment letter submitted by a coalition of conservation organizations, including CNPS. We would support our coalition's proposed Revised Alternative B as a second option if Alternative C is not

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

adopted. [Environmental Conservation/ Preservation] Comment #8814-11 - For the Monitoring and Evaluation Requirements, Alternative B, the proposed action alternative. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #17 Concern: The Forest Service should restrict motorized and mountain biking use or separate these activities from non-motorized activities on forest lands. Sample Comment #6-1 - As a forest user, and a trail repair and maintainer, I must ask Statements: that the designations for combining Mountain Bikes, and other wheeled vehicles with horses and hikers is not a good plan. Most OHV users, and most Mountain bike users, do NOT know the trail correct ways to approach, or pass an animal like a horse, or a person on foot. For instance they don't know to pass on the downhill side of the trail when passing a horse, and to STOP and let a hiker, or equestrian pass or move off the trail before continuing. [Multiple Use or Land Rights Organization] Comment #7-2 - I have very strong thoughts about allowing bicycles on the mountain trails in the forest. I am an equestrian and have ridden forest trails many of which are so narrow at points only one horse can navigate safely. If a bicyclist happened to be rounding the corner of a narrow trail at the same time a horse and rider were on it most likely the horse and rider will be in for an accident. I have passed hikers on the trail while I have been on horse back and they have had to step off of the trail to make room. What do you think will happen when the bicyclist is coming down hill with head phones on going very fast only to look up and see a horse and rider or a group of horses and riders which is more probable to be the case? If bicyclists are allowed to share the trail with horses and there is a fatality I am very certain litigation will come about and the state of California Forestry department will be questioned regarding the decision to allow this dangerous situation to come about. Bicyclist have the choice to ride on most of the roads and highways of this great state, while equestrians do not. We are restricted to more rural settings with ever increasing restrictions on our access to trails. This is due to development on the city state and local levels. Please hear my plea to keep our forest land safe for equestrians and available for our continued enjoyment. [Multiple Use or Land Rights Organization] Comment #7926-2 - When considering the formation of trails, I believe the bicyclist should be able to enjoy the trails, but to do so safely, they should have own designated trail. Allow the equestrian, hiker and other users of the trail to

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

share their own designated trail. [Multiple Use or Land Rights Organization] Comment #69-1 - I am very concerned over the possibility of allowing mountain bikes or any mechanical apparatus on National Forrest Trails or any mountain trails. These areas are to be seen and heard not roared through at high velocity. There is documentation that bikers are not policing themselves and that they have injured numerous people on trails. Please read http://www.culturechange.org/mountain_biking_impacts.htm This article disseminates the ecological, environmental and safety issues of why mountain biking should not be allowed on Forrest trails. Please keep our trails safe for not only hikers, equestrians but for the local flora and fauna. [Individual] Response: Unless otherwise restricted through the travel management regulations or closed by Forest Order, highway licensed vehicles may use any National Forest System road or motorized trail open to public use. Vehicles licensed for off- road use are permitted only on certain backcountry roads and motorized trails. Mountain bikers may use any National Forest System road or trail except where restricted or prohibited (this includes the Pacific Crest National Scenic Trail and designated wilderness). Forest Service non-motorized trail use policy is generally for hikers, equestrians and mountain bikers to courteously and safely share the trail in accordance with locally established Trail Management Objectives. Potential changes to road or trail use policies and user conflicts are outside of the scope of the SEIS. Travel management maps that display forest roads and trails and information about the types of activities they are designated for are available at all forest supervisor and district ranger offices as well as their internet sites. New road and trail closures or restrictions would require a site-specific analysis prior to undertaking any proposed action. Enforcement of regulations that affect National Forest System land uses are generally day-today operational issues that are addressed at a local forest or ranger district level. Concern #18 Concern: The Forest Service should further protect forest resources through wilderness designation (general statements). Sample Comment #118-1 - I came to this area because of the opportunity to live near a Statements: national forest and the Pacific Ocean. I have witnessed the many natural changes in the forest from horrific wildfires to beautiful fields of wildflowers in an open meadow. With the forest comes an array of wild animals I have encountered and have great respect - California Black; Bobcat; Grey and Red Foxes; California Condor; Rattlesnakes; deer; wild turkey; Jack rabbits, cottontails and numerous other species. These encounters have made my life richer and gave me the true meaning of the "great outdoors". We need to broaden our areas of protected wilderness, not shrink it. [Individual] Comment #2283-1 - We must protect them. Our mountains are a cherished area to Los Angeles residents. They are an iconic part of the Los Angeles basin. We need to keep them pristine. Permitting mining and off-roading will destroy what little of our natural, historical wildlife areas left. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #80-1 - It is my firm opinion that Wilderness designation is extremely important for most of our wild park lands. We are now the protectors of these lands for future generations, must understand that there will be more and more intrusions over time into these areas which will detract from their natural state. It is our responsibility to preserve these lands in a natural state so many generations to come can benefit from their use. Hiking is the most natural and least intrusive use. Horseback riding is next least intrusive and natural. Any vehicles, motorized or propelled by human action. will lead to deterioration and destruction of the natural environment and wildlife. Please be aware of precedent setting with your current decisions. Please be far sighted in seeing your responsibility and preserve our Wilderness and park lands in their natural state now and for the future. [Individual] Response: The responsible officials will review and consider all comments filed on the Draft Supplemental Environmental Impact Statement. Many comments, such as the sample comments listed above, support or oppose particular alternatives based on the values held by the commenter. While these comments are considered they do not require a change in the analysis, because the factual basis of the analysis was not questioned. Concern #19 Concern: The Forest Service should promote multiple use and public land access, as well as limit additional wilderness designation. Sample Comment #1-1 - Please leave the land open to the people! We have a right to Statements: use our public lands, even to use off road vehicles on the land. The government keeps taking more and more open space away from the people. This is not right! [Recreational (incl. permittees)] Comment #229-1 - I am against wilderness designation for the Angeles, Cleveland, Los Padres, and San Bernardino National Forests because it would not allow mountain bikes to use trails in these national forests. Wilderness designation would allow hikers and horseback riders to continue to use the trails. I feel that mountain bikers should be considered the same as hikers and horseback riders. Mountain bikes are no more of a mechanical aide than the hikers shoes, the hikers backpack, or the horse's saddle. I suspect that the motivation of some is to have fewer people in the national forests. If restrictions are needed, they should be for reasonable and specific reasons to specific areas, and not blanket restrictions for a class of users. [Individual] Comment #9410-2 - I believe the preservation of the Angeles National Forest is of utmost importance, but at the same time, believe that complete elimination of all existing bike trails would be a tragic misuse of the land. I am not an avid mountain biker who has used any of the trails under threat of closure. However, I do enjoy hiking with my family or riding fire roads through the Angeles National Forest and can appreciate the various forms of recreation which take advantage of the terrain. A general argument can be made that people feel the need to preserve natural habitats based on their connections and experiences

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

within them. Indeed, our knowledge and appreciation for the forest naturally inspires the desire to protect it. To eliminate an important group of users, such as the mountain bike community, would further reduce the experiential impact that takes place in the lives of those who truly appreciate the outdoors. It is in everyone's best interests to continue to encourage the respectful enjoyment of such important natural landscapes. [Individual] Comment #3408-3 - Given the LPNF is approximately at least 40% designated wilderness, more designation of same would be a meaningless administration action of what are already defacto wilderness-like areas which are very, very rugged areas which have very little human impact other than the repeated adverse affects of man-caused wildfires harming watersheds and posing threats to the public with landscape fires. [Individual] Response: Consistent with the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528- 531) (MUSYA), the Forest Service manages the national forests to sustain the multiple use of its renewable resources in perpetuity while maintaining the long-term health and productivity of the land. Resources are managed through a combination of approaches and concepts for the benefit of human communities and natural resources. Section 2 of the MUSYA provided that the establishment and maintenance of areas of wilderness are consistent with the management of the national forests for multiple uses. Concern #21 Concern: The Forest Service should address technical and mapping edits identified by commenters. Sample Comment #8645-2 - Vegetation Analysis Speaking personally, as someone with Statements: a PhD in plant community ecology, I must correct the usage here: vegetation and plant community are synonymous. There is no such thing as a "vegetation community" in vegetation science. The preferred term is vegetation [1], and given the importance of this work, it would be heartening to see proper use of technical terms in a science-based document. [Environmental Conservation/ Preservation] Comment #8658-4 - The maps have visually confusing color coding: • In all the maps but especially those for Alternatives 2 and 3, areas that might be non-FS lands or might be BCMUR or DAI or proposed BCMUR are shown in one or another of several grayish/tannish/brownish shades. But the legend shows only one key each of gray/ tan (BCMUR) and tan/brown (DAI), plus one for “Non- FS Land” color. This is confusing. It appears that the “Non-FS Lands” color has been overlaid on the others, changing their colors so that it is difficult to distinguish BCMUR from DAI in some places, DAI from proposed BCMUR in others, BCMUR from non-FS lands in still others. Perhaps the basic “BCMUR” and “DAI” colors could be altered to be more different from each other? • Similarly, the “Non-FS Lands” color overlay gives three tones of “BC” and “BCNM” colors, making it difficult to distinguish non-FS lands from non-IRA BC. • The combination of dense “proposed RW” color and hatching makes it

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

difficult to see what’s in the IRA, thus to compare to corresponding areas on the other Alternatives. Perhaps the hatching could be removed? The other “proposed” colors and hatching create a similar comparison problem. • None of the maps’ legends include “developed-area pink” or the light tan that appears to signify gravel mines. Although those areas lie almost all outside the FS boundary, they should be keyed in the legends. Where the light tan extends inside the boundary and is overlaid with “Non-FS Lands” color, it becomes confusable with BCMUR. • BC, BCNM, and BCMUR zones are shown as extending into the non-FS lands. Why are these zones, intended to signify how the FS’ lands are to be managed, be extended into these privately-owned lands? [Environmental Conservation/ Preservation] Comment #9003-2 - Please correct within the document(s) incorrect spelling of Ritchie Creek (referred to as Richie Creek) [Environmental Conservation/ Preservation] Response: The use of vegetation communities over vegetation or plant communities is a matter of author preference. Please refer to the Existing Vegetation Classification and Mapping Technical Guide Version 1.1 (Forest Service General Technical Report WO-67, http://www.fs.fed.us/emc/rig/documents/protocols/vegClassMapInv/EV_TechG uideV1-1-2.pdf) for an example of how the terms plant communities and vegetation communities are used in the same context. The maps in the Final SEIS have been revised to reduce confusion. Private lands are not shaded in the revised maps, and the hatching patterns were adjusted to make the changes in land use zones more visible. The spelling for Ritchie has been corrected in the Final SEIS. Section 2. Comments about the decision-making process, public involvement, and conformance with laws and regulations. Concern #22 Concern: The Forest Service should make their decision in an open, inclusive manner that meets the public's needs. Sample Comment #8550-27 - Please stop giving in to bully tactics such as the lawsuits Statements: by anti-access groups such as Center for Biological Diversity. The Forest Service is expert in managing land and should be left along to manage lands in the best interest of the American People. [Individual] Comment #189-1 - Please survey the public to discover the strongest needs of our National Forests. The current process that recommends no new wilderness for the Los Padres National Forest does not reflect the will of the public. Please update your process to include the public’s wishes from the very beginning. [Individual] Comment #8879-4 - Banning motorized vehicles would severely limit "mobility challenged" people from accessing and enjoying our national forest. Not everyone is physically able to walk or hike in the backcountry. I feel that it is

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

unfortunate that the various environmental groups and organizations want to control or influence access to our national forest that is be enjoyed by everyone. I also don't believe that banning previously mentioned activities or those activities as mentioned in the Federal Register will adversely affect watershed values as well as the health of the ecosystem which I believe are overly exaggerated as purported by the various groups. The U.S. Forest Service should seriously consider not complying with all of the demands of the various environmental groups. They don't speak for everyone. [Individual] Response: The process used to complete the Final SEIS was done in a manner that is consistent with regulations that implement the National Environmental Policy Act. As evidenced by these sample statements, as well as the full range of comments available for public viewing on the project website, there is a considerable range in opinion on how the National Forest System Lands in question should be managed. Concern #23 Concern: The Forest Service should add respondents to the mailing list and respond to requests for information. Sample Comment #6580-6 - There was no significant ‘record’ noted in the course of Statements: my review of the many documents supplied by the FS in connection with the proposed revision to the DSEIS; if such a record exists, please bring it to my attention. [Individual] Comment #62-1 - I contacted the forest service at 858-673-6180 the number listed on the plan web site last week about this and so far they have not returned my call. Correct this problem and properly re-notice and re-start the comment period [Individual] Comment #9191-4 - As we are concerned with actions that may affect our properties, we would like to have an opportunity to discuss these items as needed prior to the EIS being finalized to minimize impacts to the LADWP's water and electrical transmission infrastructure. We therefore request that you include the LADWP in the mailing list for the Forest Service LMP SEIS. [Municipal/City Government Agency /Elected Official] Response: The record includes the Draft SEIS, the appendices, and other supporting documents that were posted on the project website. The Forest Service was able to respond to information requests that were either submitted to the project email account or by phone, and did contact the author of comment #62-1 by email. The final mailing list will include the email addresses or postal addresses for respondents to the Draft SEIS when that information was provided in the comment.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #24 Concern: The Forest Service should increase outreach efforts to the public. Sample Comment #9394-2 - I want to see some more rangers and people educating us Statements: about the forest, just like this guest speaker that came to my school today but at the forest. [Individual] Comment #9374-2 - I also think they should put it out more in the internet, etc. People need to know more about the forest and nature. [Individual] Comment #9358-2 - We, the community, need better educated staff members, which means more employees who can reach out to any citizen have a conversation with them in order to warn them or salutate them. Preferably Spanish speakers would be most efficient since the Hispanic population is so high. In any case we need your support so we can establish a public forest area where people or the community can be more involved for generations to come. [Individual] Response: While the Forest Service supports and conducts community outreach activities, general Forest Service outreach activities are outside the scope of the plan amendment. Community members interested in community outreach can contact their local Forest Service unit for assistance. Concern #25 Concern: The Forest Service should ensure that the supplemental environmental impact statement and the associated decisions conforms to federal laws and mandates, particularly Executive Order 13443 and the Americans with Disabilities Act. Sample Comment #8814-4 - The American Disability Act has created a new category Statements: of mobility aides known as “other powered driven mobility devices” (OPDMD). These new mobility aides would provide access for many of the disabled that cannot now access this area. While understanding that the Forest Service is not bound completely by the ADA, the Service should participate at least in spirit with the Act. The existing Back Country Non-motorized LUZ or Recommended Wilderness LUZ would not allow this new category of mobility aides. [Individual] Comment #8625-2 - In my review of the Proposed Amendment to the CNF LMP as part of the Settlement Agreement, there was a conspicuous lack of any evidence of planning for compliance with the mandates of EO 13443; this is a matter that must be remedied, or at least properly explained. [Individual] Comment #8626-15 - RW will interfere with the Forest Services Congressionally ordered multiple use mandate. [Recreational (incl. permittees)] Response: The 2006 Southern California National Forest Plans, Part 3, Appendix A describes the relevant laws, regulations, agreements and other management direction that was in place when the plans were revised. Within the hierarchy of direction, compliance with laws and regulations takes precedent over other

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

direction. Implementation of the forest plan is based on the laws, regulations, and policy in place when the implementing action is taken. Executive Order (EO) 13443 was not included the Appendix as the EO was signed after publication of the Forest Plans. EO 13443 directs federal agencies to facilitate the expansion and enhancement of hunting opportunities, to consider the effect of their actions on trends in hunting participation, and to consider the economic and recreational value of hunting. A Federal Lands Hunting, Fishing, and Shooting Sports Roundtable Memorandum of Understanding was developed in 2006 by the Forest Service to facilitate implementation of the EO. A discussion of this EO was included in the SEIS and analyzed in Chapter 4, Environmental Consequences. Forest Plan Appendix 3 references the Wilderness Act of 1964 and the Americans with Disabilities Act (ADA) of 1990. In a recent regulation, the U.S. Department of Justice (DOJ) created a new category of other power driven mobility devices (OPDMDs). This DOJ rule requires that managers of public lands allow OPDMDs to be used by a person who needs such a mobility device because of his or her mobility disability, unless use of that class of motorized device is prohibited in that location due to a risk to safety, environmental, cultural or natural resources or poses a conflict with Federal land management laws and regulations. In designating roads, trails and areas for motor vehicle use and publishing motor vehicle use maps, the southern California national forests meet this requirement. However this DOJ rule does not change the restrictions pertaining to wheelchairs/mobility devices that are allowed to be used in Federal wilderness areas. Wheelchairs in such areas are defined in section 508 (c) (2) of the ADA as follows:(1) IN GENERAL – Congress reaffirms that nothing in the Wilderness Act prohibits wheelchair use in a wilderness area by an individual whose disability requires its use. The Wilderness Act requires no agency to provide any form of special treatment or accommodation or to construct any facilities or modify any conditions of lands within a wilderness area to facilitate such use.(2) Definition – for the purposes of paragraph (1), the term wheelchair means a device designed solely for use by a mobility impaired person for locomotion, that is suitable for use in an indoor pedestrian area.” The Forest Plan Appendix also references the Multiple-Use Sustained Yield Act of 1960. Section 2 of the act provides that establishment and maintenance of areas of wilderness designation are not inconsistent with multiple-use. Section 3. Comments about the alternatives considered. Concern #27 Concern: The Forest Service should provide a "true" No Action Alternative. Sample Comment #6006-1 - I'm very upset the public is being duped on this process, Statements: they are not offering a no action Alternative as required by Law anyone saying I support Alternative 1 may think their supporting a no action plan but that's not the case.[...]Compare the acreage in the 2 attached documents the one named 4a is what a no action plan should look like, the one named New1_2&3 show the 24

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

new 3 Alternatives none of which are even similar to the selected plan 4a in 2005. [Individual] Comment #6006-2 - Sounds like you are saying there is no Alternative being offered with NO action, it is my believe that a true No action Alternative should be offered, so the public can get a full and honest prospective of just what the proposed action plan is. It is my believe the CRF's require this for that reason not that an agency has any obligation to select it, one Alternative showing the land zone acreage in the 2005 selected plan 4a (see attached files) should clearly be included, most of the public is not aware of what you just told me. After doing this the Comment period should be extended, at least the minimum amount required by Law. [Individual] Response: For a plan analysis, "No Action" means no change in current management. The current management situation reflects the LMPs approved in 2006, and as corrected, amended, or altered by statute. The land ownership has also changed since 2006 through donation, purchase, or exchange. The SEIS references several changes since 2006, including designation of wilderness and wild and scenic rivers, as well as utility corridor designations. Alternative 1 represents the No Action alternative for the National Forest System lands being evaluated in the proposed amendment. The amendment is focused on a part of each of the four forests. If one of the alternatives that would change the land use zones (Alternatives 2, 2a, and 3) is not selected, then the current land use zones included in Alternative 1 would remain the same. When you compare the size of the area included in Alternative 1 with the forest as a whole, the acres of the various land use zones in Alternative 1 will be smaller than the acres shown for Alternative 4a. Table 120 in the Final SEIS displays the areas involved in the amendment. As shown in the table the amendment covers 7% of the San Bernardino National Forest but 24% of the Los Padres National Forest. Although the amendment covers only a portion of each forest, Alternative 1 does reflect "No Action" for the area studied. Concern #28 Concern: The Forest Service should expand the range of evaluated land use and monitoring alternatives. Sample Comment #8814-2 - The LUZ alternatives being presented are inadequate Statements: choices that simply do not meet the basic NEPA provisions requiring a viable range of actions. The options are either No Action or Recommended Wilderness, leaving No Action as the preferred alternative. [Individual] Comment #6008-37 - We believe that additional monitoring alternatives should be considered that include the best features of the proposed alternatives and other components necessary to ensure an adequate monitoring regime. A robust and transparent monitoring plan is a critical component of the Forest Service’s long-term management plan of the four forests because it will significantly

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

shape how adaptive management is utilized to meet the plans’ goals. NEPA requires that an EIS contain a discussion of the “alternatives to the proposed action.” 42 U.S.C. §§ 4332(C)(iii),(E). The discussion of alternatives is at “the heart” of the NEPA process, and is intended to provide a “clear basis for choice among options by the decisionmakers and the public.” 40 C.F.R. §1502.14; Idaho Sporting Congress, 222 F.3d at 567 (compliance with NEPA’s procedures “is not an end in itself . . . [but] it is through NEPA’s action forcing procedures that the sweeping policy goals announced in § 101 of NEPA are realized.”) (internal citations omitted). NEPA’s regulations and Ninth Circuit case law require the agency to “rigorously explore” and objectively evaluate “all reasonable alternatives.” 40 C.F.R. § 1502.14(a) (emphasis added); Envtl. Prot. Info. Ctr. v. U.S. Forest Serv., 234 Fed. Appx. 440, 442 (9th Cir. 2007). [Environmental Conservation/ Preservation] Comment #6008-39 - As the SDEIS is currently configured, Monitoring Alternative C, which we support, may have very little chance of actually being adopted due to Forest Service budget/resource limitations, which make it appear to be an “unreasonable” alternative. Therefore, we believe that a greater range of reasonably implementable alternatives should be included in a revised Draft SEIS and recirculated to the public for comment. [Environmental Conservation/ Preservation] Comment #9189-15 - NEPA and the Council on Environmental Quality regulations require that the Forest Service, like other federal agencies, "[r]igorously explore and objectively evaluate all reasonable alternatives." 40 C.F.R. § 1502.14(a) (emphasis added). The requirement that agencies consider all reasonable alternatives "is at the heart of the environmental impact statement." 40 C.F.R. § 1502.14. The purpose of this requirement is to "sharply defin[e] the issues and provid[e] a clear basis for choice among options by the decisionmaker and the public" Id. Agencies that consider too narrow a range of alternatives violate NEPA. Klamath-Siskiyou Wildlands Ctr. v. US. Forest Service, 373 F. Supp. 2d 1069 (D. Cal. 2004). The EIS considers three alternatives: Alternative 1, the No Action alternative; Alternative 2, the Proposed Action, which will change make the LUZ allocations more restrictive on 380,000 acres (300,000 acres changed to BCNM and 80,000 acres changed to RW1); and Alternative 3, which will redesignate hundreds of thousand of acres to RW. Draft EIS at 14-15, 138, 220-21. These alternatives are insufficient to constitute a reasonable range of alternatives. [Other] Response: The range of alternatives is based on the purpose and need and the issues raised during scoping. Alternatives can also be developed in response to comments on the Draft SEIS, and Alternative 2a is an example of an alternative that was developed in response to comments. Monitoring Alternative C was designed to be within the capability of the Forest Service to implement. It may not be the agency preferred alternative, and it may not be selected in the final decision, but those are not the tests of a reasonable alternative. By the nature of the process, there are always going to be reasonable alternatives that are not selected. According to the 40 most asked

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

NEPA questions (#2a) "reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant." Several commenters suggested an alternative that would allocate less restrictive land use zones to the roadless areas considered in the amendment. This included recommendations for Developed Area Interface (DAI) zones around Cogswell Reservoir in the Angeles National Forest so that the area could be considered in the future for sediment disposal. The less restrictive alternative was considered but eliminated from detailed study, and the rationale is documented in the Final SEIS in Chapter 2. The DAI land use zone is not consistent with the Roadless Area Conservation Rule (RACR), and the rule does not allow LMP amendments to reduce the restrictions in the roadless rule. Generally an agency can consider an alternative that is inconsistent with a law or regulation if that alternative is reasonable (see the NEPA 40 most asked questions, questions 1, 2, and 3 http://ceq.hss.doe.gov/nepa/regs/40/1-10.HTM#2 . As explained in Chapter 2, an alternative that proposes land use zones in conflict with the RACR is not reasonable given the purpose and need of the amendment. Concern #29 Concern: The Forest Service should further justify their selection of a preferred land use and monitoring alternative. Sample Comment #8645-11 - Monitoring We are concerned at the cavalier dismissal of Statements: Alternative 3 as too difficult and too expensive. Yes, we are quite aware of logistics issues, but we are concerned that the Forest Service is not keeping track of current technology. One simple example is that an iPhone 4s (retail about $200), plus a $15 app (Field Assets) has most of the functionality of an old Trimble field computer (retail about $5000). Plus, if there is phone service, the data can be emailed out of the phone in the field, mitigating against the memory crashes that plague many Trimble units. Similarly, we used the free California Consortium of Herbaria website to find all herbarium specimens within the project site, and the free CNPS rare plant inventory to check their status. The point to all this is that the costs of monitoring are dropping radically, in conjunction with the drop in computer prices and the increasing availability highly functional smart phones. Has the Service experimented with new technology, and does the Service incorporate these continually decreasing costs in its logistics estimates? [Environmental Conservation/ Preservation] Comment #8645-1 - Choice of Alternatives How, specifically, does the inventoried roadless areas analysis, as amended, support the claim that Alternatives 2 and B is preferable to Alternative 3 and C? Having read the document from a botanical perspective, we find the evidence so sparse that simple prudence would suggest a more conservation-oriented approach. In particular, the lack of a vegetation map an incomplete list of sensitive species and invasive non-native species provides a shaky basis for preferring

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Alternative 2. Additionally, many of the monitoring surveys proposed in Alternative C seem required to provide evidence for the more general questions of Alternative B, suggesting that Alternative B, contrary to assertions, requires more work and more surveys than Alternative C. While we do not desire a recapitulation of the entire document, we would like to see additional language explicitly (and quantitatively, where possible) supporting the best alternatives. Based on what we have read, we believe the best alternatives are 3 and C. [Environmental Conservation/ Preservation] Comment #8645-12 - With regard to the specifics of Alternative C, we are honestly confused by the contention that these are difficult. For example, Goals 1.1 (fire break acreage), 2.1 (non-native trends), 4.1 (resource development), 5.1 (watershed management), 6.1 (rangeland allotments), and 7.1 (forest natural areas management) should be reported as a matter of course, and many of these are simply explicit call-outs of data that would have to be collected to meet the required evaluations of the preferred Alternative B. Given the evidence, we cannot accept the dismissal of Alternative C as too difficult based on the evidence presented. Does the Forest Service have detailed logistic evidence to support its contention that Alternative C is too much work? If so, why was this evidence not provided? If the evidence does not exist, how can the Forest Service refuse to pursue the environmentally favorable alternative? [Environmental Conservation/ Preservation] Response: The environmental analysis (either the draft or final documents) is intended to be an analytical document that focuses on factual information and the consequences of actions. It is not intended to justify any particular alternative, and should evaluate each alternative on an equal basis. The Record of Decision is where the agency rationale for the selected alternative is described. In the Draft SEIS, Land Use Zones Alternatives 1, 2 and 3, and Monitoring Alternatives A, B and C were considered in detail as reasonable alternatives. The analysis concludes that Alternative 3 would provide more protection for various resources while restricting other uses such as mountain biking and special uses. The analysis also documents that Alternative C would cost more than Alternative B, primarily on the basis of staff time, and not technology. The trade-offs between the alternatives will factor into the decision rationale that will be described in the Record of Decision. Concern #30 Concern: The Forest Service should modify Monitoring Alternative A to include adaptive management. Sample Comment #7043-6 - CA4WDC recommends that the Monitoring Alternative A Statements: be modified to include the Adaptive Management components as defined in Alternative B. The remainder of the Alternative A provides the required management as defined within the LMP and the National Strategic Plan desired conditions, goals and objectives that apply to the planning area in the forest plan and to use common criteria and indicators as appropriate in the forest plan. While the monitoring described within Alternative B may be more “robust”, it

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

does not appreciably increase the knowledge available for ecosystem management. It does increase the overall cost to collect data which is a labor intensive activity. During the era of reduced manpower and budgets, increasing the costs provides no real benefit. Indeed, it does provide an avenue for future litigation should the increased level of monitoring not be fulfilled due to man- hour/budget short-falls. CA4WDC appreciates the opportunity to comment on these important plans. [Recreational (incl. permittees)] Response: Monitoring Alternative A is the No Action alternative, that represents the current LMP monitoring strategy. It does include Adaptive Management, as discussed in the LMP, Part 3, Appendix C. It is provided as a basis for comparison to Alternative B to show exactly what the agency is proposing to change. For this reason it would not be appropriate to make changes to Monitoring Alternative A. Alternative B was developed in an effort to make monitoring, evaluation, and reporting more efficient given limited agency resources, while still complying with the 1982 regulations under which the Southern California Forest's LMP's were developed. Alternative B does not increase the number of indicators (monitoring questions) and only makes changes to three out of 19 of them. Alternative B sets a minimum number of projects to be reviewed annually instead of a percentage, and therefore may actually result in fewer projects being reviewed annually for Part 3 monitoring than under the current LMP strategy. The monitoring strategy proposed in Alternative B is not expected to increase the time, budget, or likelihood of litigation compared to the current monitoring strategy, Alternative A. Concern #31 Concern: The Forest Service should modify Land Use Zone Alternative 2 to incorporate more mountain bike trail opportunities. Sample Comment #2173-1 - I am writing to express my support for a modified Statements: Alternative 2 in the Land Management Plan Amendment currently being considered. I encourage you to protect the forest lands under study from extractive industries, such as logging and mining, and inappropriate motorized recreational use. But as a mountain biker, I also ask that you leave open all trails we are currently permitted to ride, as this is an appropriate use for them and a highly popular form of recreation. [Individual] Comment #8550-31 - I could support Alternative 2 if Fish Canyon IRA is removed from proposed Recommended Wilderness in place of Red Mountain and Tule IRA’s, which contain no known recreational trails. Or, at least, remove the portion of land which contains the two trails. The Fish Canyon IRA has at least two trails on it of value to mountain bikers: Fish Canyon Trail and Burnt Peak Trail. In addition to forming a nice backcountry loop along with Road 7N23, each of these trails forms a critical connector from Liebre Mountain and Sawmill Mountain down to Cienga Campground and Castaic Lake State Recreation Area via Warm Springs Road and Necktie Trail. It is disappointing to see the one IRA with bike-accessible trails included in 29

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Wilderness when two IRAs without any trails are excluded. I would ask that either the entire Fish Canyon IRA or at least the section which contains Fish Canyon and Burnt Peak Trails be removed from the proposed Recommended Wilderness in Alternative 2. There are very few mountain bike opportunities in this area north of Los Angeles, so these are trails which are quite important to mountain bikers. I have never seen a hiker on either trail. [Individual] Comment #9277-4 - If the Forest Service chooses to pursue Alternative 2, we would urge the Forest Service to amend this alternative as follows: I. A cherry stem should be provided for Cienega Canyon, a decommissioned road used by the Crank n Stein cycling group and other cyclists. In fact, it seems to us that the very existence of this old road should be sufficient to split the Salt Creek and Fish Canyon proposed Wilderness areas which we would support. II. The Forest Service should ensure that the Golden Eagle trail which runs just to the north of this proposed Recommended Wilderness is entirely excluded from the Recommended Wilderness. This is a very popular trail for cyclists. It appears that the Golden Eagle trail may overlap the Recommended Wilderness in a few places. III. A cherry stem should be provided for Forest Route 7N13.1 from Forest Route 7N32 on the south all the way up to Sawmill Motor Way on the north. IV. The cherry stems should be wider than the proposed 25' to provide for trail maintenance and accurate mapping. V. A provision should be made to move or adjust cherry stems in case of a need to re-route a trail on account of erosion or other similar problems that would prohibit cyclists and others from using these trails. [Multiple Use or Land Rights Organization] Response: All the areas listed in these comments were reviewed, and the information was used to revise Alternative 2. Some minor modifications to the Liebre Mountain boundaries were made to provide a more manageable boundary. Concern #32 Concern: The Forest Service should apply land use and monitoring alternatives separately across the four forests based on public feedback Sample Comment #54-2 - Also, Bob Hawkins mentioned in the Mt Pinos R.D. project Statements: meeting ( April 9th 2013) that it is the Forest Service’s recommendation that only 1 of the 3 plans be adopted as the entire land management proposal for all the areas in all 4 So Cal forests. After looking over some of the comments and personally visiting many of the areas that will be affected by a change in LUZ, It would be beneficial if each proposal (Map) could be considered on it's own merit. Include the different user groups in a decision over which areas would receive further restrictions and proposed protection while leaving other areas and their current LUZ unchanged. In this fashion it may be possible to include enough user input to preclude further litigation? [Individual] Response: The planning for the four forests was done in an integrated manner using a consistent approach between the forests for each alternative. Even with that integrated approach, the balance of land use zones between alternatives varies between forests because of the characteristics of the IRAs being studied.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Alternative 2a was developed in response to comments, and provided an additional opportunity to customize the approach for each forest. Although it is possible to build a matrix where each of the 37 roadless areas is evaluated individually, the possible combination of alternatives is unreasonable and does not facilitate integrated forest planning. Concern #33 Concern: The Forest Service should not reject land use zone alternatives without additional analysis. Sample Comment #9189-14 - The rejection of any alternative that considers new LUZ Statements: allocations on the basis that that is not required by the Settlement Agreement (EIS at 19) also supports the argument that the Forest Service has precommitted to a particular action or very narrow range of actions prior to performing NEPA review. On the other hand, if the Settlement Agreement does not foreclose the consideration of new LUZ allocations, then there is no reason to dismiss that alternative without analysis. [Other] Comment #9189-16 - In addition to the alternatives analyzed in the EIS, the EIS mentions then eliminates a handful of other suggested alternatives from study, including any alternative that would change less land to more restrictive LUZs. Draft EIS at 18-20. It also does not analyze any alternative that would change any land to a less restrictive LUZ. However, unless the Forest Service has precommitted to some specific, restrictive action prior preparing the EIS, such options are reasonable, feasible alternatives that could potentially eliminate the action's significant impacts to the human environment and impacts related to environmental justice. For this reason, eliminating such alternatives without full analysis violated NEPA. [Other] Response: As described in response to concern #28, the alternatives considered in detail are determined by the project purpose and need, the issues raised during scoping, and the comments received on the Draft SEIS. The analysis is narrow in scope because it is designed to remedy two of the lawsuits related to the revised forest plan (see Chapter 1, Purpose and Need). The range of alternatives is reasonable given the project purpose and need. The Settlement Agreement did not commit the Forest Service to any particular decision, and any of the four alternatives considered in the Final SEIS could be selected, including the No Action alternative. The Roadless Area Conservation Rule (RACR) does set some limits on what forest plan amendments can do relative to management within roadless areas, particularly as it relates to lessening the restrictions associated with the RACR. The response to concern #28 explains this limitation in greater detail.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #34 Concern: The Forest Service should evaluate suggested new alternatives in the supplemental environmental impact statement. Sample Comment #2232-2 - We contend that zoning only 10% of Los Padres DAI and Statements: BC does not allow sufficient area for the Forest Transportation System to provide reasonable public access. The Los Padres National Forest Record of Decision (2005) addresses wilderness additions and BCNM designations. The Decision provides an approach to land use planning “that makes sense managerially… and that adds 32,273 acres to the Dick Smith Wilderness, 2,822 acres to the Matija Wilderness, and 726 acres to the Chumash Wilderness. These acres add to the 48.3 per cent of the Forest that is already wilderness bringing the total to 50.3 per cent. With 9.6% BCNM and 18 percent BCMUR, 77.9% of the Forest is managed for non-motorized public access with limited potential for further development.” The Forest Plan indicates that the approach to motorized travel will be to limit travel to existing designated routes. Routes would be added “when a site specific analysis determines there is a public need for the road, and that it is consistent with other ecosystem needs” Furthemore there is a management strategy to reduce the number of unnecessary and redundant unclassified roads and restore landscapes. Surely this provides adequate protection to NFS lands through the zoning established in the 2005 Forest Plans. Although the Court has given the forest Service direction to increase restrictive land use zoning we submit that although the Settlement Agreement does not remove the possibility of adding motorized routes that this will be much more difficult with the increase in BCNM zoing proposed as part of the Preferred Alternative. The draft SEIS indicates that with Alternative 2 there will be “a future emphasis on non motorized recreation” (Table, dSEIS page 25) and “a reduction in development for motorized use” (dSEIS page 139). This approach is planned in spite of the fact that there will be increased demand for motorized recreation with an increasing population (dSEIS page 276). The results of increased use on a limited trail system are already being seen, with increases in user conflict and resource impacts due to intensive use of a limited motorized trail system that has not had any additions in many years. We submit that a better strategic approach would be to allow some limited expansion of the motorized trail system through less BCNM zoning as well as less BCMUR zoning, particularly on the Los Padres. A reduction of resource impacts and maintenance costs can also be accomplished by allowing zoning provisions for selected reroutes and relocation of problem trail sections. This would not require a significant increase in trail mileage. [Recreational (incl. permittees)] Comment #9189-17 - The relevant LUZ allocations are defined in the Draft EIS at pages 135 through 137. Under the current, insufficiently narrow range of alternatives, significant impacts will likely be caused by designating the West Fork of the San Gabriel River under the LUZ's identified for either Alternative 2 or Alternative 3. In fact, even Alternative 1's designation of the area is problematic because it does not reflect existing permitted use of the area around 32

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Cogswell Reservoir. Because motorized access is needed and is currently permitted and being utilized in this area, the area upstream of Cogswell Dam should be designated Developed Area Interface (DAI). In addition, as discussed above, other methods of dealing with the accumulating sediment have greater environmental impacts than SPS's and have been objected to by stakeholders. Because the current sediment placement site will fill up, additional sediment placement sites will also be needed in the future. Under the proposed LUZ designations in Alternatives 2 and 3 (and• potentially even under the existing designation), this may not be permitted, leading to significant impacts to flood control, water supply, and others. To facilitate the need to continue receiving vital flood control benefits and 12,000 acre-feet per year of much-needed water supply, Watermaster requests that an alternative be analyzed that designates the area upstream of Cogswell Dam as DAI; that the south slope area of Cogswell Reservoir, west from the existing Cogswell Sediment Placement Site, be included in the area designated DAI; and that the areas downstream of the Dam keep their current designation (as in Alternative 1). Watermaster requests that the Forest Service meaningfully evaluate such an alternative (which could be categorized as a change to the EIS that prevents undisclosed significant impacts, or it could be identified as a new alternative or subalternative ), because it would prevent conflict with existing uses and state and local policy, allow for continuation of vital benefits, and prevent many of the action's significant impacts, while overall meeting the identified purpose and need for the action. [Other] Comment #8912-4 - The ideal final solution would be to either maintain the BCNM classification or to create a negotiated classification similar to wilderness but that allows for bicycles and the potential for a limited amount of future trails to meet the growing recreation needs of area users. Such a solution could substantially preserve these wild and sensitive areas, while providing future opportunities for area residents. [Multiple Use or Land Rights Organization] Response: Although these comments apply to two different areas, they illustrate the challenge in balancing competing future uses of the national forest. The proposed BCNM areas on the Los Padres were modified in response to comments received during scoping and again in response to comments on the Draft SEIS. Refer to the description of Alternative 2a in Chapter 2 of the Final SEIS for more details on where these adjustments were made. New roads are already prohibited by the Roadless Area Conservation Rule (RACR) for all of the IRAs and this is disclosed in the roads and trails effects analysis in Chapter 4. The RACR provides exceptions to this prohibition, including but not limited to cases of imminent threat to life and property, or when necessary pursuant to reserved or outstanding rights. The road and trails analysis also recognizes that the addition of BCNM areas would reduce the potential for future motorized trails which would otherwise be allowed by the RACR. Given the project purpose and need, the difference in approach between Alternatives 1, 2, 2a and 3 provide a reasonable range of alternatives for the

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

decision makers. The Cogswell Dam situation within the Angeles National Forest has two facets that were addressed separately. The first situation concerns the existing permit issued for the sediment placement site in the Westfork IRA. The land use zones were corrected to BCMUR in Alternatives 2, 2a, and 3 to recognize the occupancy granted through the existing authorization. The permit is valid through the current planning period and operation within an IRA under permit is consistent with the RACR. These corrections are consistent with the design criteria for each of the alternatives. The proposed future sediment placement site in the West Fork IRA or the change in zone to Developed Area Interface, are outside the scope of this analysis, and would be better addressed through a site specific proposal. Any proposal would have to be consistent with the RACR to be considered in detail, and the prohibition on new road construction would make development of a new sediment placement site difficult. The analysis in Chapter 4 will be updated to reflect the interest in this area for sediment placement. Because the purpose and need is tied to the Settlement Agreement, which does not include the development of any new LUZ's, the suggestion of a "negotiated classification similar to wilderness but that allows for bicycles" is outside the scope of this analysis. The BCNM zone is the closest to what the comment describes, and it is included in Alternative 1 to present a range of alternatives that includes retention of bicycle use. Section 4. Comments about funding, monitoring, and adaptive management. Concern #35 Concern: The Forest Service should ensure sufficient enforcement, agency staffing, funding, and volunteer support for the forests. Sample Comment #8626-16 - RW will cause additional monitoring costs for the Forest Statements: Service in managing illegal use of the areas. [Recreational (incl. permittees)] Comment #7806-1 - I would like to see more enforcement of the regulations and laws we already have in place and especially if new ones are adapted with the Plan of Management. All the wilderness that can be set aside won't mean much if it can't be protected from harm with better enforcement. [Individual] Comment #8223-13 - Are trends in resource conditions indicating that habitat conditions for fish, wildlife, and rare plants are in a stable or upward trend? How are you going to know? The few listed native plants mentioned in this DSEIS prove that you do not have enough botanists to do the field research necessary to get a complete inventory of rare, threatened or endangered native plants and native habitats in these areas. How many botanists are on the staff of each of these four forests? How many biologists? [Environmental Conservation/ Preservation] Comment #8874-8 - Cedar Creek Road If the CNF is going to have an OHV road in the middle of this area, the CNF MUST patrol this activity. Current

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

state of this area has these off-highway green sticker vehicles racing up and down Boulder Creek Road with no enforcement. Calls to CNF Monta Vista dispatch are not responded to, the San Diego Sheriff department claims it's not their job, and the California Highway patrol is dispatched out of El Cajon and will not drive the hour plus each way to enforce the law. If the CNF is to continue having an OHV road in the middle of a proposed wilderness, CNF needs to come up with a plan to control it. Law enforcement presence is rare to non-existent at current state. Future state of this area should include a law enforcement visit to the trail head of Three Sisters Waterfall and Cedar creek road every Saturday and Sunday during peak seasonal use. [Individual] Comment #9374-1 - I recommend the San Gabriel Forest to get more volunteers and helpers to clean the mountains. [Individual] Response: Enforcement and staffing are key components for forest plan implementation. Volunteer support is also a critical component of forest management, and many individuals and organizations have donated countless hours to help the Forest Service serve the public and care for the land. It is not possible for the Forest Service to ensure any level of funding, because funding levels are established by Congress. Chapter 3 looked at funding trends, which reflect increases and decreases over the years as the emphasis in various programs changes. One of the assumptions made for the analysis was that funding would be stable or would slightly decline in the future. Staffing decisions are made based on the forest plan, other agency direction, and current and expected funding. While the forest plan decision does not set staffing levels, forest plan direction does influence the overall balance of skills available on the staff, commensurate with funding levels. The Draft SEIS addressed the law enforcement issue as it relates to the land use zones and concluded that there would be minimal change for enforcement actions because access to the various areas on the national forests would not change. The impact to volunteer groups was also discussed in the recreation and roads and trails sections of Chapter 4. Volunteer groups will continue to be an important part of forest management. Concern #36 Concern: The Forest Service should address the goals related to vegetation and watershed condition, and describe their relative importance. Sample Comment #8223-3 - Is the forest making progress toward increasing the Statements: percentage of montane conifer forests in Condition Class I? Why, when the major vegetation types in these four forests are not “montane conifer forests” is this an overriding goal of the four National Forests? [Environmental Conservation/ Preservation] Comment #8223-10 - Is the forest making progress toward sustaining Class 1 watershed conditions while reducing the number of Condition Class 2 and 3 watersheds? How can you meet goals (a), (b), and (h) if the goal is to sustain

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Class 1 watershed conditions? Since water is the most valuable and necessary resource southern California needs to survive, isn’t watershed health, which is tied to ecosystem health and to native biodiversity, the most important goal to monitor in these four forests? [Environmental Conservation/ Preservation] Response: National forests are managed for many resources. Part 1 of the integrated land management plans describes the 11 main goals identified for the four southern California national forests. As described in Part 1, these goals respond to national priorities and local management challenges. Monitoring is designed to inform managers if progress is being made to achieve those goals. The plan does not rank the goals in terms of importance, but does recognize the challenge associated with implementing the goals. The purpose of the amendment was to examine how monitoring was accomplished based on the existing goals. Montane forests and watersheds are both components of those goals, and would be included in any monitoring strategy. The amendment was not focused on the actual monitoring trends, but those are reported by the individual forests and published on the internet. Concern #37 Concern: The Forest Service should encourage ongoing monitoring efforts and use of existing baseline data for Monitoring Alternatives A and C. Sample Comment #6008-40 - Alternative A (No Action Alternative). The on-going Statements: monitoring that the forests are already doing collect data that help to answer many of the questions about important ecological and development issues on the forests. These data sets that are currently being collected include: • Tracking the acres treated for fire hazard reduction in Wildland Urban Interface (WUI) Defense Zone (App. 3 pg. 3), areas no longer in WUI (App. 3 pg. 3) and areas that have converted to high fire hazard in the WUI or where new development has occurred nearby creating a new WUI(App. 3 pg. 3); • Tracking acres that have been treated or had fire history by vegetation community type (App. 3 pg. 3); • Establish baseline acres of invasive plants/animals, subtracting areas of treatment and adding newly invaded acres (App. 3 pg. 3); • Tracking acres of wilderness (App. 3 pg. 4); • Tracking acres of mineral and energy development and resultant mitigation (App. 3 pg. 4); • Tracking the number and acres of utility corridors (App. 3 pg. 4); • Tracking the number of “impaired streams” (303d list) (App. 3 pg. 4); • Tracking the MIS habitat condition (App. 3 pg. 4); • Tracking the road miles, types and resultant density (App. 3 pg. 5); These important data sets track many of the issues that are of concern to us and to the forest decision makers as well. All of these issue areas are fundamental to evaluating if the goals of the forest plans are being met. By continuing to acquire and track these data sets the forests will also have opportunities to analyze these data sets in useful ways to help answer additional management questions with minimal effort (see below). [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #6008-60 - One concern we have is that Alternative C proposes to “restart” the baseline conditions with five years of data collection establishing a new baseline (Appendix 3 at pg. 14). We believe this “baseline” data collection (Appendix 3 at pg. 14) is unnecessary and that baseline acreages from the 2006 Southern California Land Management Plan analysis should be used as the “baseline” (as it is in the other alternatives) to compare to subsequent data collection on changed conditions. [Environmental Conservation/ Preservation] Response: The existing baseline data established when the plans were revised would continue to be available and used if it was related to the monitoring questions described in Alternatives B and C. If the amendment changes the monitoring questions and indicators, as is the case with some of the Alternative C indicators, then a new baseline would need to be established. Concern #38 Concern: The Forest Service should require monitoring program coordination with other monitoring and reporting requirements. Sample Comment #6008-42 - We urge the Forest Service to revise Alternative C to Statements: incorporate the requirement to explicitly coordinate the forest monitoring program with any consultation monitoring and reporting requirements for listed species, cultural resources, or other resources as indicated in Alternative B (Appendix 3 at pg. 11). [Environmental Conservation/ Preservation] Response: Monitoring Alternative C has been edited to include coordination of other program monitoring with overall LMP monitoring, similar to Alternative B. Concern #39 Concern: The Forest Service should make suggested revisions to monitoring goals and questions for Monitoring Alternative B or C. Sample Comment #6008-44 - Ecological systems are complex and there are a number Statements: of ways to evaluate them and their condition. Many of the indicators in Alternative C – Part 1 are basic GIS desktop exercises – looking at different “filters” or ways to look at the data sets once they are collected. For example, Goal 1.1 identifies the monitoring action as calculating the number of acres of fuel breaks constructed/maintained in the WUI and is common to all Alternatives. Alternative C also adds a requirement of evaluating the number of acres of fuel breaks constructed and maintained by watershed. This is an additional, important way to look at the data – in this instance to evaluate if one watershed is experiencing unsustainable clearing that could affect erosion and hydrological functions yet it requires no new data collection, just an additional analysis that will yield important information. These types of simple GIS exercises are informative and easy to implement based on existing data sets that the Forest Service has and data it is already committed to collect going forward. These types of requirements should be included or retained in any monitoring regime that the Forest Service chooses as part of this decision. Requiring managers to use these relatively simple and effective analysis tools to assist in

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

review of impacts to these complex systems will support more informed management decisions and provide defensible science based decisions. Minimizing the way data sets are analyzed will not serve the health of the forests or save significant time and energy of staff—indeed these tools are time and cost efficient ways to increase the usefulness of the data already being collected. [Environmental Conservation/ Preservation] Comment #6008-54 - Add Goal 8 – Monitoring Question – Are the National Forests protected and preserving cultural resources? Indicators – Coordination with SHPO Monitoring Action – Use cultural site reports and compare the miles of roads/trails and acres of recreational facilities in culturally sensitive areas and compare to the 2006 Southern California Land Management Plans; Report the number of tribal coordination meetings each year. [Environmental Conservation/ Preservation] Comment #6008-55 - For Part 2 – Monitoring - we believe that each of the indicators associated with a monitoring goal should be included in the Monitoring Summary in addition to the Indicators in Table 5 where they are not duplicative. [Environmental Conservation/ Preservation] Comment #6008-43 - The SDEIS states that Alternative C would be more costly than the other alternatives and the monitoring “would not be improved to a degree commensurate with the increased costs due to the diminishing returns of increased data collection” (SDEIS at pg. 293). Recognizing these concerns, we suggest below several measures that could be incorporated into a revised Alternative B and increase the efficacy of the monitoring alternative with minimal additional staff time or expense. D. Revised Alternative B Alternative B as detailed in the SDEIS is an improvement over the no action alternative, however ,the monitoring scenarios of Alternative B still will not provide the essential information and thorough analyses on which judicious land management decisions are required to be based. We suggest that at minimum the following measures should be incorporated into Alternative B. This would result in a new Revised Alternative B which would increase the strength and efficacy of the monitoring with minimal additional staff time and expense. [Environmental Conservation/ Preservation] Comment #6008-45 - We propose that that “Goals” and “Monitoring Questions” from Alternative B – Part 1 be retained with the following changes: • Goal 1.1 – Monitoring Action – Add: calculate the number of acres of watershed treated in WUI and compare with baseline acres from the 2006 Southern California Land Management Plans; Include the approach as discussed above for Alternative C - Monitoring Questions for Goal 1.2. [Environmental Conservation/ Preservation] Response: No changes have been made to Monitoring Alternative B. While some of the suggested additional monitoring involves GIS analysis that would be relatively simple to perform, it would still require additional time on the part of GIS staff. Alternative B is fully compliant with the 1982 planning regulations under which the LMP was prepared. Based on the comments, it is not clear to us how 38

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

additional GIS analysis would increase the efficacy of Alternative B. Alternative B uses a Forest Service program called Watershed Condition Assessment (WCA) to monitor Goal 5.1, Improve Watershed Conditions. WCA is updated on an ongoing basis, and can reflect short term adverse effects of fuels treatments on specific watersheds. WCA also accounts for wildfires, and the benefits of fuels treatments in preventing wildfires from becoming larger or more severe. It uses a national standard to assess the components of overall watershed health, and is sufficient to address the commenter's concern without requiring additional analysis, however simple that analysis may be. Cumulative effects analysis at the project level also can assess impacts of fuels treatments on a watershed basis, and in some cases may be more appropriate. Other suggested additions to Alternative B would simply report baseline conditions. The nature of many of the suggested monitoring actions does not make them useful for tracking trends, especially when weighed against the costs. For many of them, data is not available, and where it is, it may not be accurate enough for the intended purpose. As an example, many permitted facilities such as organizational camps and recreational residences are not mapped as polygon footprints, but are represented as point features. To create or convert this data would be costly and time consuming, involving either manual interpretation of aerial photography, or on the ground boundary data collection. Utility and transportation corridors are relatively static, and have not changed since 2006, which is why they were dropped as an indicator in Alternative B. The Forest Service has no direct control over new wilderness designations, 303(d) listings, or endangered species actions. Information on some suggested indicators such as miles of decommissioned road, baseline of unauthorized roads, acres of habitat mitigation, or authorized mining plans will be included as Part 2 or 3 monitoring. Monitoring of implementation and compliance with documents tied to specific projects, such as Biological Opinions, and cultural resource stipulations from SHPO, is more appropriate as Part 3 monitoring, and is included there in Alternatives B and C. Protection of cultural resources is already required by several laws and regulations, and monitoring the implementation of cultural resource protections is now included in both Alternatives B and C. Monitoring summaries have and will continue to use program implementation numbers from Part 2 monitoring to address indicators in Part 1 monitoring, to the extent applicable. The benefits of restoring more natural fire regimes as well as the threat of altered ones are well documented in scientific literature and continue to be observed on the landscape. Goals 1.1 and 1.2 adequately address both community protection and forest health. Making all the suggested additions to Alternative B, Part 1 monitoring would increase the costs, and the comments do not make it clear how the suggested changes would increase efficacy of the program. Part 2 monitoring is designed to track trends in accomplishments, or outputs of goods and services. Reporting the miles of road maintained to the proper levels, or

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

decommissioned, on an annual basis, monitors how budgets and outputs increase or decrease over time. The Part 1 monitoring for unauthorized roads is used as an indicator to show if the forests are making progress toward the goal of balancing a need for new infrastructure with restoration opportunities, and is reported every 5 years. That goal, 7.1 in the LMP, is the overall management objective, not any specific outcome of road or trail maintenance or unauthorized route decommissioning. The monitoring of outputs under Part 2 and tracking of indicators to measure progress toward desired conditions are related but are not redundant. Concern #40 Concern: The Forest Service should require consistent monitoring questions across monitoring alternatives. Sample Comment #6008-38 - Appendix 3 of the SDEIS lays out only three alternatives Statements: for monitoring resources in the forests – the no action (Alternative A), the preferred monitoring alternative (Alternative B) and the extensive monitoring alternative (Alternative C). However, the monitoring questions asked by the different monitoring alternatives are not consistent and confuse the data that is already being collected with what should be collected to answer important environmental questions. Based on the fact that Goals of the Forest Plans are the same independent of the monitoring alternative, we believe that well-crafted questions should be consistent between the alternatives, with the differences in the alternatives residing in the actual monitoring actions. Instead, the three monitoring alternatives in the SDEIS each for the most part ask different questions making comparison more difficult.. Alternatives A (no action) and B (Proposed Action) share a number of monitoring questions while Alternative C (Extensive Monitoring) shares few questions, but similar topics or categories, to the other two alternatives.. [Environmental Conservation/ Preservation] Response: The Monitoring Alternatives do not have consistent monitoring questions because the purpose of the alternatives is to show different ways of monitoring, and consider the different impacts each alternative may have. This allows the decision maker to select the alternative that is best for resources and people. To make all the monitoring questions consistent would not allow for this comparison, which is the heart of the NEPA process. The Settlement Agreement directed that the forests analyze alternative monitoring protocols, therefore the differences in monitoring questions are appropriate. Concern #41 Concern: The Forest Service should more clearly link conservation goals with monitoring questions. Sample Comment #8223-1 - The DSEIS-SCNFLMPA states in the introduction to the Statements: section on Natural Resources Environment, Biological Resources: “The four forests lie within a bioregion considered by Conservation International to be one of the world’s 25 biodiversity “hotspots”. These are defined as areas where exceptional concentrations of endemic species are undergoing exceptional loss

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

of habitat (Myers et al. 2000). High vegetation diversity, unique ecological communities found nowhere else, and exceptionally high numbers of endemic plant species characterize this area (USDA Forest Service 2006). The four forests play an important regional role in maintaining large blocks of wildlife and plant habitat. They also contain areas that are the only remaining habitat refugia for species imperiled by the loss of degradation of habitat off-forest. Combined with a mix of local, state, federal and private lands, they form a regional system of open space and habitat preserves within one of the most highly urbanized landscapes in the United States. The 37 Inventoried Roadless Areas (IRA) in this analysis play an important role in this regional system by providing habitat for a diversity of species such as wide-ranging carnivores, localized species and threatened, endangered and sensitive wildlife and plant species. Whether managed alone or in combination with Critical Biological Zones and/or special designations such as Wilderness, Research Natural Areas and Special Interest Areas, these IRAs provide biological strongholds that have typically not been exposed to the same levels of habitat degradation and loss that has occurred across other more utilized areas of the national forests. Native plant and animal communities are generally more intact in these IRAs than in roaded areas of similar size resulting in the presence and abundance of species more likely to be affected by human disturbances. Across the four forests, these IRAs play a key role in maintaining native species and biodiversity because they provide conditions suitable for survival that are declining elsewhere.” How, then, do you reconcile the “important regional role” the four forests play in maintaining large blocks of wildlife and plant habitat with Table 57. Part 1 Monitoring Summary? [Environmental Conservation/ Preservation] Response: The quoted section about biodiversity is provided as background information on the biological resources present on the national forests, and their importance in a regional, national, and international context. While this section serves to highlight the importance of biodiversity, biological resources are just one of many resources and values that National Forests are managed for in accordance with law, regulation and policy. Table 56 is a summary of the monitoring questions and indicators used in the current LMP Monitoring Strategy, also used as a No Action monitoring alternative in Appendix 3. The conservation goals for the LMP are not changing in this LMP Amendment. They remain the same as described in LMP Part 1, the "Vision" for the southern California national forests, and each conservation goal is directly linked to a monitoring question. Several of them set goals directly related to conserving and protecting biodiversity. These two pieces of information are used in different contexts in the SEIS, and there is no need or requirement to reconcile them further.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #42 Concern: The Forest Service should reduce monitoring requirements for inventoried roadless areas. Sample Comment #8814-5 - The monitoring guideline alternatives for the Inventoried Statements: Roadless Areas commit too much emphases and resources on these areas that can be monitored by simply not constructing any transportation level roads within them. Are we just trying to show political importance to IRAs by mandating unnecessary and redundant monitoring? [Individual] Response: The Settlement Agreement required the national forests to analyze alternative monitoring strategies, but did not specify it be done only for the IRAs. The monitoring alternatives considered are therefore applicable to the entire national forests, not just the IRAs. The SEIS has been edited to make this clarification. IRAs do contain all the resources found on non-IRA National Forest System lands, therefore it would not be appropriate to develop separate monitoring strategies for IRAs. Concern #43 Concern: The Forest Service should focus monitoring efforts on native shrublands. Sample Comment #8813-4 - Recognition of the Dominant Vegetation Type Although Statements: the Forest Service has made significant strides in recognizing the fact that the majority of the land within the four National Forests in southern California are not covered by forests, but in fact native shrubands, there continues to be a pervasive emphasis on conifers. For example, the primary focus of monitoring Goal 1.2 (Restoring Forest Health) is on trees. We strongly urge the Forest Service to change this emphasis to better reflect the majority of the resource it manages, native shrublands. [Environmental Conservation/ Preservation] Comment #8813-3 - We also urge the Forest Service to develop a baseline regarding current native shrubland health as part of its monitoring program that would include: - a reliable estimate of how many acres have been type converted historically - the impact fuel treatments, development, increased fire frequency, and climate change may have on existing shrublands - identification of remaining mature chaparral stands (50 to 75 years old) and old growth stands (in excess of 75 years old). [Environmental Conservation/ Preservation] Comment #8813-2 - Monitoring Again we complement the Forest Service for incorporating the fact that shrubland plant communities, the dominant type of vegetation in the four National Forests in southern California, are characterized by Fire Regime Class IV and that “acres in departure categories 2 and 3 are due to excessively frequent fires.” However, there appears to be continued resistance in recognizing that chaparral, in addition to coastal sage scrub, is threatened with type conversion due to increased fire frequencies, especially at lower elevations. We urge the Forest Service to change its Goal 1.2.2 to reflect this fact. [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The land management plan goals for each forest are the same, and described in Part 1 of the three part land management plan. Goal 1.2, restoration of forest health, includes consideration of the fire frequency of chaparral and coastal sage scrub in subgoal 1.2.2. Changing the goals is outside the scope of the projects purpose and need, but the monitoring strategy does describe how these goals will be evaluated. The requested baseline study of shrublands, including the historical analysis, is not required to monitor the trends in reducing excessively frequent fires while improving defensible space. Alternatives B and C outline alternative approaches to answering that question. Alternatives B and C both monitor the trends associated with a variety of vegetation types without placing a primary focus on any one area. Concern #44 Concern: The Forest Service should make recommended changes to the monitoring program under all monitoring alternatives. Sample Comment #8832-6 - The monitoring program should include baseline Statements: measurements and regular monitoring of management activities. The actions in Alternative B is insufficient to identify problems and correct them before there is degradation of the Forests. It was not changed significantly following previous comments. Alternative C is much better than B, but it could be improved according to other comments I have read. [Individual] Comment #8878-31 - any monitoring program should be consistent with the Council on Environmental Quality’s recent memorandum on mitigation and monitoring. [Environmental Conservation/ Preservation] Comment #8878-29 - we would like to see the following items included in any monitoring program: • Monitoring for compliance with terms and conditions of Biological Opinions • Regular monitoring of oil development activities in the Sespe Oil Field • Monitoring of populations of Management Indicator Species, especially mountain lion, mule deer, and blue oaks, given the lack of any current monitoring data. [Environmental Conservation/ Preservation] Comment #8878-30 - the monitoring program should specify a date by which the annual reports will be prepared each year. The annual reports should contain citations to references in the report, and make those references along with all supporting documentation available to the public without requiring submittal of a formal public records request. [Environmental Conservation/ Preservation] Response: All monitoring alternatives include baseline measurements and regular monitoring of management activities. See Appendix 3, Table 5 for the specific management activities for which outputs will be reported annually and Table 4 for descriptions of various baselines used in indicators. Other monitoring also occurs at the level of specific projects, where the same adaptive management model described in Appendix 3 is used. This project level monitoring is outside the scope of this LMP Amendment. Project level

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

monitoring becomes LMP monitoring through Part 3 of the monitoring strategy, but monitoring is an integral part of project implementation whether the information is selected for inclusion in LMP level monitoring or not. LMP Monitoring includes compliance with Biological Opinions in both Alternatives B and C. Activities in the Sespe Oil Field would be monitored under Goal 4.1a. Management Indicator Species are monitored at a habitat level, although forests have the option to include population data, and habitat conditions for these species are the primary indicator for Goal 6.2. The LMP only requires that monitoring reports be produced annually, there is no specified date, which gives forests flexibility to fit LMP monitoring into the overall annual workload. The Settlement Agreement specified that monitoring reports be available by October 31 of each year. All reports, including references, are made publicly available on each forest's websites. The primary guidance for development of LMP monitoring strategies is the National Forest Planning regulations, 36 CFR 219. The CEQ's memorandum on mitigation and monitoring is specific to NEPA, and the monitoring alternatives analyzed are consistent with it for a programmatic, LMP level EIS. Concern #45 Concern: The Forest Service should provide additional guidance on the use of adaptive management and metrics to assess progress toward goals and objectives. Sample Comment #7043-5 - Issue 3: Adaptive Management CA4WDC is encouraged Statements: to see the agency implement “Adaptive Management” principles within the monitoring program. Adaptive management provides for a timely response and adjustment to changing conditions frequently found in management of ecosystems. However, the addition of additional criteria for monitoring within the preferred alternative are unnecessary and not directly linked to other forest management directives. Adaptive management is used where decisions can be made and actions modified during the project duration and a level of experimentation can be applied to achieve the desired goal. You begin with a clear goal and an uncertain means to accomplish that goal. You “adapt” your work steps as conditions change to complete your goal. While adaptive management provides flexibility to change the active steps, it is highly dependent on monitoring, accuracy of data, and analysis of data. Traditional management requires time-consuming and costly studies and analysis to determine a series of actions to achieve the desired goal. It is difficult to predict success in this type of work environment when work conditions are uncertain. Adaptive management is a systematic process for improving management policies and practices to ensure that the organization is prepared for the unexpected and geared for change. Adaptive management is based on learning and changing strategies as you learn. In other words, you begin with a goal and work to achieve that goal. In an adaptive management environment, you

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

constantly monitor your progress towards achieving the goal and adjust your actions based on what you learn from monitoring your progress. Resource management is hampered with uncertainty. While the final goal may be clear, how to achieve that goal involves many uncertain actions and responses to actions. The use of adaptive management allows the resource manager to changes activities when it is determined those activities will not achieve the desired goal. Adaptive management is gaining popularity among resource management agencies and seeks to find a balance between gaining knowledge to improve the future while achieving the best short-term outcome based on current knowledge. It is a tool to change management practices while learning how those practices will affect the desired goal. Adaptive management relies on data, statistical analysis, computer models, and consensus to evaluate strategic objectives. This open management process seeks to include past, present, and future stakeholders. It is both a scientific process and a social process. Adaptive management employs a a series of steps commonly referred to as the Plan-Do- Check-Act cycle. You “Plan” an action to achieve a goal. You “Do” what you planned. You “Check” (monitor) the results of your action. You evaluate your action and “Act” through changing your action as necessary. This cycle is repeated to ensure the goal is accomplished. Adaptive management is based on learning and is either passive or active. Passive adaptive management values learning as it improves decision outcomes as measured by specified metrics. In contrast, active adaptive management explicitly incorporates learning (constant monitoring) as part of the objective function, and hence, decisions which improve learning are valued over those which do not. Active adaptive management is more complex and costly to implement due to its high dependence on constant monitoring. In either situation, careful definition of the metrics is required and establishment of a robust monitoring program is required. Metrics (measurement criteria) must provide direct correlation to the identified goals and objectives. [Recreational (incl. permittees)] Response: The Forest Service recognizes the value of adaptive management and it was adopted as part of the monitoring strategy when the forest plans were revised in 2006. The monitoring alternatives provide a framework for adaptive management that does select metrics that have a direct correlation to the identified goals and will show how the forests are doing over time in meeting those goals. The Alternative B monitoring strategy itself represents adaptive management in action, as it makes several changes based on newly available sources of information, as well as experience with the existing set of goals and indicators Section 5. Comments on the effects analysis. Concern #46 Concern: The Forest Service should analyze cumulative and significant, adverse impacts in the supplemental environmental impact statement, particularly as they relate to the impacts of specific activities.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Sample Comment #9189-2 - In multiple places, the Draft EIS states that it is not Statements: considering or disclosing the environmental effects of foreseeable future specific actions or activities because it is a programmatic document. See, e.g., Draft EIS at 127. However, a failure to address site-specific impacts that could be known at the time a programmatic EIS is prepared has repeatedly been held as a basis for finding a programmatic EIS inadequate. See, e.g., Idaho Conservation League v. Mumma, 956 F.2d 1508 (9th Cir. 1992); Salmon River Concerned Citizens v. Robertson, 798 F. Supp. 1434 (E.D. Cal. 1992). A programmatic EIS must include site-specific analyses of impacts and alternatives when a critical decision has been made that, in practice, constitutes an "irreversible and irretrievable commitment of the availability of resources" to a project on a particular site. California v. Block, 690 F.2d 753, 761-62 (9th Cir. 1982). Accordingly, in order to be legally compliant, the Draft EIS must be revised to include this more detailed, site-specific analysis. [Other] Comment #9189-20 - Watermaster is concerned that the Draft SEIS does not take a "hard look" at certain significant adverse impacts, identified below, as required by NEPA and thus that the SEIS is deficient as a matter of law. [Other] Comment #9189-7 - Even if an action considered alone would have insignificant impacts, the impacts of a proposed action in conjunction with the impacts of all past, present, and reasonably foreseeable future actions may result in significant impacts, and these cumulative impacts must be analyzed under NEPA. 40 C.F.R. § 1508.7. A programmatic EIS must analyze cumulative impacts in the same way as a project-specific EIS. 40 C.F.R. § 1508.25. A number of past, present, and reasonably foreseeable future actions are and have been taking place over recent years that have had the effect of regularly, if not permanently, reducing Californians' access to water supplies for a variety of reasons, including endangered species concerns in the Sacramento-San Joaquin Delta and the Santa Ana River, out-of-state rights to Colorado River water, and overdraft of groundwater in several parts of the State, as well as global climate change and ever-increasing population pressures. The Draft EIS dismisses the significant cumulative impacts that could result from yet another action reducing access to local water supplies by merely stating that the proposed action "would not change the watershed trends for watersheds that are outside of the planning area or outside of the national forest boundaries." Draft EIS at 274. This is the incorrect standard for assessing cumulative impacts under NEPA. Instead, the cumulative impacts section should list other existing, potential, and proposed actions with their impacts quantitatively or qualitatively described, then the impacts of the Proposed Action (and alternatives) are described and added. Here, there is no disclosure of other relevant projects, much less disclosure of those impacts plus the impacts of the Proposed Action (and alternatives). Accordingly, the cumulative impacts section is insufficient under NEPA as it relates to impacts to water and water supply and must be substantially revised. [Other] Comment #8876-37 - The chapter on environmental consequences is

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

excessively general. It is simply insufficient for the DEIS to state over and over again that “There would be more of activity X under Alternative 1, less of activity X under Alternative 2 and even less of activity X under Alternative 3.” The DEIS should fully discuss and describe the impacts of “activity X” on all key ecological and social issues so that the public can understand what it actually means if less or more of “activity X” occurs. For example, in discussing the impact of Alternative 3 on vegetation and tree management indicator species (MIS) the DEIS simply states that: This alternative significantly decreases human disturbance by prohibiting public motorized access and the use of mechanized tools/equipment for fuels reductions and fuelbreak construction. Primitive types of recreation are permitted. As in Alternative 2, effects common to vegetation and tree MIS include elimination of vegetation removal resulting from road construction for access and motorized recreation. This passage and the similar entries for Alternative 1 and 2 on impacts to vegetation and tree MIS beg the following questions: • What impacts occur as a result of vegetation removal for roads, trails and fuelbreaks? • What benefits to air, water, wildlife, recreation and other values occur when vegetation is not removed for roads, trails and fuelbreaks? • What are the impacts of road construction, maintenance and use on all key ecological and social concerns? • What are the benefits to air, water, wildlife, recreation and other values of not building roads? • What are the short and longterm impacts to wildlife, plant communities, scenery, recreation, water quality, etc. of modifying stand structure and species composition during hazardous fuels reduction projects? • What are the impacts of maintaining existing stand structure and species composition? • What are the impacts, both positive and negative, of fire suppression activities? • More specifically, how are vegetation and tree MIS impacted by road, trail and fuelbreak construction? • How is vegetation and tree MIS affected by being placed in protective zones such as RW? [...]It is not enough to make “conclusory” or “perfunctory references” to cumulative impacts or to continue to use the same boilerplate language throughout the EIS. Natural Resources Defense Council v. Hodel, 865 F.2d 288, 298-99 (D.C. Cir. 1988). Cumulative effects analysis requires “some quantified or detailed information. . .” Neighbors of Cuddy Mountain v. U.S.F.S., 137 F.3d 1372, 1379 (9th Cir. 1998). “General statements about ‘possible’ effects and ‘some risk’ do not constitute a ‘hard look’ absent a justification regarding why more definitive information could not be provided.” Id. at 1380. It would obviously be unrealistic for the public to expect a site- specific discussion of the impacts of particular activities such as fuel reduction, fire suppression, roads, fuelbreaks and trails on vegetation, tree MIS, water quality, wildlife or any other topic in the DEIS. However, we ask that the final EIS (FEIS) include a discussion of the known general impacts of various activities. Some portions of the wildlife section of the DEIS includes a much better description of the generic impacts of various activities. For example, in discussing the impact of Alternative 3 on southern steelhead on page 157, the document states that: Decreased access to spawning sites should improve habitat conditions, as well as allow more individuals to reproduce successfully.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Alternative 3 should also result in decreased soil compaction, soil erosion along stream banks and improved water quality. Although people may still be able to access streams/rivers where trout occur, only the least invasive activities are permitted, thus minimizing disturbance to individuals and spawning habitats. The discussion of general impacts to the southwestern willow flycatcher also provides a good model for how the rest of the DEIS should have been written: Effects of reduced road use/access would be beneficial. There would be less physical disturbance and noise disturbance to birds. Even though there is an increase in BCNM in Alternative 2, this is more restrictive use than Alternative 1. Non-motorized use of riparian areas is less disturbing than motorized use as it is less noisy. The reduction in noise would be beneficial to birds during the breeding season as they communicate with sound. Noise reduction would also reduce the likelihood of birds being flushed from nests. Reduced vehicular access should also reduce habitat fragmentation, increase water quality and reduce erosion and sediment into riparian habitats. There should be fewer opportunities to introduce non-native species such as salt cedar and giant reed (i.e. Tamarisk and Arrundo spp.) that reduce habitat quality for birds. The list of watershed condition class indicators on pages 203-204 also provides a good, general description of potential impacts from various activities. On the other hand, on page 151 in discussing the arroyo toad the DEIS states that “Alternative 1 effects to ARTO are the same as the existing condition. Toads should continue to be impacted in the same manner as they currently are now.” The document never explains what this means. How is the species being impacted by relevant management and recreation activities now? This vague statement is repeated for many other species. [Environmental Conservation/ Preservation] Response: The changes that are being evaluated as part of the proposed forest plan amendments are programmatic in nature, and are focused on the suitability of an area for certain activities. The plan amendments won't approve any specific activity, nor will plan decisions amend any permits, close any roads, or change any forest orders. Because the plan decisions are programmatic, and do not evaluate a specific activity or action, it is impossible to describe the impacts of a specific activity in a meaningful way. For example, roads can have several different impacts on the environment, including removal of vegetation, introduction of sediment to streams, and visual scarring of the land. Roads also provide benefits, including access for recreation, fire suppression, and law enforcement. The degree to which a road would have impacts and benefits depends on where the road is located, how the road is designed, and what it connects. Federal law, Forest Service policy, and plan standards all influence decisions about road location and design. At the plan level, we can describe whether road construction is suitable or not for a given land use zone, and we can describe if more or less road construction is likely in the future based in part on the change in land suitability. What we can't do at the plan level is analyze the impacts of road construction, because the plan amendment does not approve any specific road projects.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

The analysis considers past, present and reasonably foreseeable actions. For example, the analysis recognizes the utility infrastructure within and adjacent to the IRAs being studied. The analysis also recognizes those future actions when they are known, such as the continued use of the sediment placement site in the Westfork IRA. The analysis does not analyze speculative actions that have not been formally proposed for consideration by the Forest Service, such as future sediment placement sites. The analysis would not include an analysis of far reaching and unrelated topics such as endangered species concerns in the California Delta and water rights in the Colorado River basin. There has to be a reasonable nexus to the action at hand, and the amendments being considered will have no effect on the water use issues facing California. Section 6. Comments about resource and infrastructure management. Concern #47 Concern: The Forest Service should assess air quality and require burn permits from the affected area and consider air quality impacts from quarry projects. Sample Comment #53-5 - Burn permits should issue from area impacted i.e. San Statements: Joaquin Air District not coastal counties. [Individual] Comment #8895-2 - Please consider the impact that the blasting in Fish Canyon, Azusa by Vulcan will have on air quality in the West Fork of the San Gabriel. [Individual] Response: Chapter 3 describes the air basins and the Air Pollution Control Districts (APCDs) that have jurisdiction within the planning area. The location of the burn project would control which APCD has jurisdiction over the project. The SEIS does not deal with the issuance of burn permits which are done separately as part of project implementation and as part of site specific NEPA for hazardous fuels reduction projects. The Azusa rock quarry expansion proposal is outside of the boundary for the Angeles National Forest and therefore outside of Forest Service jurisdiction. The City of Azusa was the lead agency for the project, which also operates under a permit issued by the South Coast Air Quality Management District (AQMD). The requirements imposed by the City and the South Coast AQMD are intended to mitigate any potential air quality impacts. Concern #48 Concern: The Forest Service should ensure access to, and appropriate land designation of, water developments in the supplemental environmental impact statement. Sample Comment #8833-1 - The first element we would like to see addressed and Statements: emphasized whenever possible, is in the area of access for the maintenance, servicing and retention of developed water sources. Currently, these activities are covered under a “special use permit” from the individual forests. In order to ensure these critical wildlife elements are fully functional and continue to

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

operate in the best manner possible, long-term access needs to be assessed under any planning exercise. Climate change, forest practices and in some cases invasive or feral species of plants and animals have changed the hydrology in certain areas to the detriment of native wildlife. [Other] Comment #8864-2 - We respectfully request the following designations for the areas adjacent to Cogswell Reservoir and the existing Cogswell Sediment Placement Site: a. The designation of “Developed Area Interface (DAI)” for the area marked as “E” on the enclosed map should appropriately reflect the current permitted use of the area as a Sediment Placement Site. The Forest Service issued a 30-year Special Use Permit in 1991 for the Sediment Placement Site. This area is defined roughly by the Cogswell Reservoir to the north, the old boundary line of Arroyo Seco and Mt. Baldy Ranger Districts to the east, Red Box Road to the west, and the ridge line extending from Red Box Road and connecting to the old boundary line of Arroyo Seco and Mt. Baldy Ranger Districts to the south. b. The designation of “DAI” for the area marked as “R” on the enclosed map to appropriately reflect the existing permitted use of the area, which is operation and maintenance of the Cogswell Reservoir. Public Works conducts cleanout operations within this area to restore the storage capacity of the reservoir and therefore the designation must support the use of heavy equipment and trucks to remove sediment from the reservoir and transport sediment to a deposition site. c. The designation of “DAI” for the area marked as “N” on the enclosed map, which is determined to be the site of a potential new Sediment Placement Site. This area was determined to have approximately 100 years of sediment capacity for cleanout operations of the Cogswell Reservoir. This area is roughly defined by the Cogswell Reservoir to the north, Area “E” to the east, Red Box Road to the south, and the ridgeline connecting Red Box Road and the Cogswell Reservoir to the west. [County Government Agency /Elected Official] Response: The SEIS is not changing the current status of any Forest Service system road or trail and is not proposing the closing of any existing Forest Service system road or trail, therefore access via open roads or trails to areas would still be allowed regardless of land use zone designation. Although the analysis does not address every use individually, access to developed water sources using existing system motorized road and trails would not change under the SEIS. Administrative access for cooperators working with the Forest Service to maintain wildlife water developments would also continue. The maintenance, servicing and retention of wildlife water developments would still continue under the EIS. Table 5, (p. 27) Item: Wildlife structures: Alt 1 = Wildlife improvements can be maintained in all areas subject to RACR restrictions. Alts 2, 2a, and 3 = No change in ability to maintain wildlife improvements. This is also stated again in Chapter 4 under the Wildlife Analysis: (p. 152): Management of wildlife enhancement (i.e., wildlife improvements such as water sources) and recovery actions (including the removal of non-native species) would also continue in all areas where it is appropriate to do so, consistent with law and regulation.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Recovery actions in BCNM could use temporary roads and other mechanized equipment, while recovery actions in RW would focus on actions compatible with wilderness management objectives. Table 67, page 169, displays the difference between LUZ designations as to the relative use between the alternatives on motorized verses non-motorized access to maintain a structure that may not be adjacent to a road, given the different allowable BCNM or RW designation. The use of motorized means to access the structure not adjacent to a road or trail may be restricted by LUZ designation, however, access via non- motorized means would still occur, and the maintenance of the structure would still be allowed regardless of LUZ designation. The land use zone alternatives have been corrected to reflect the long term permit issued for the sediment placement site associated with the Cogswell Reservoir. The land use zone proposed for this area is Back County Motorized Use Restricted (BCMUR). BCMUR zoning allows authorized motorized use, and when conducted under an existing permit that use is consistent with the RACR. The DAI zoning is not consistent with the RACR. This issue was also addressed in the response to concern # 28. Concern #49 Concern: The Forest Service should address water resource and water rights issues in the supplemental environmental impact statement, particularly as they relate to the San Gabriel River and Cogswell Dam. Sample Comment #9189-3 - The diversion, collection, conservation, and recharge of Statements: local water supplies depends heavily on the ability to maintain, enhance, and expand the associated water facilities. Because the San Gabriel River watershed is fully adjudicated and already oversubscribed, activities, such as the Proposed Action and Alternative 3, that will impair the diversion, collection, conservation, recharge, or delivery of that water could significantly impact water users. This fact and the potential resulting environmental impacts must be disclosed and analyzed in the Draft EIS. [Other] Comment #9189-5 - The potential loss of water supplies to the Main Basin is of special concern as California has adopted a policy to promote development of regional water supplies to reduce the State's dependence on water exports from the Sacramento-San Joaquin estuary and the Colorado River, largely to protect endangered species in those areas. The State Water Resources Control Board (State Board) adopted the "Recycled Water Policy" in February 2009 and declared one of its goals was to " .. .increase the use of storm water ... by at least 500,000 acre-feet per year by 2020 and at least one million acre-feet per year by 2030 .... " The inability to access and maintain Cogswell Dam and Reservoir may result in the loss of stormwater recharge of up to 12,000 acre- feet per year, which appears to be in conflict with the State Board's Recycled Water Policy. This policy is not disclosed nor analyzed in the Draft SEIS, either in the sections discussing inconsistencies with approved state or local plans (pp. 255-267) or elsewhere. Federal actions should not be taken that would conflict with such fundamentally important state policies or significantly decrease or

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

impair existing water rights, water supply facilities, or drinking water supplies. [Other] Response: Cogswell Dam and Reservoir are operated under special use permit on the Angeles National Forest. Although they are adjacent to the Westfork and West Fork IRAs, they are not within an IRA, and the land use zones assigned to them are not changing. The dam and reservoir themselves are not directly affected by this LMP Amendment. A separate permit exists for a sediment disposal site, and under Alternatives 2, 2A, and 3, the zoning for the permit area was changed for the Final SEIS to Backcountry Motorized use Restricted (BCMUR) to ensure that the zoning within the existing sediment disposal permit area is consistent with the continued use of the area. Under all the alternatives, use of and access to the dam, the reservoir, and the existing sediment disposal site is maintained. Under the prohibitions on road construction in the RACR, the IRAs would not be suitable for future use as sediment disposal sites under any of the alternatives. Because the zoning proposed in the Final SEIS would not impact the sediment disposal area, and there is no change proposed for the reservoir itself, the plan amendment would not impair the diversion, collection, conservation, recharge, or delivery of water in a way that could significantly impact water users. Concern #50 Concern: The Forest Service should expand the analysis of mineral resources and clarify exceptions for mineral development in back-country, non-motorized zones. Sample Comment #9409-2 - According to the Draft SEIS, certain commercial activities Statements: or uses – including oil and gas exploration and development, minerals resources exploration and development, and renewable energy development – may be allowed within BCNM areas by exception,1 but are not allowed in RW areas (table 62). Such activities can have substantial impacts. We recommend that the Final SEIS identify the criteria or guidelines and decision-making process used in granting such exceptions, the likelihood of such exceptions being granted in the future, and the potential extent or cumulative impact to the forests. [Federal Agency/Elected Official] Comment #2224-1 - The draft Land Use Plan (DLUP) did not include an adequate mineral potential analysis. The mineral potential analysis should have been made by the US Geological Survey (USGS). At the very least, the DLUP should have used publically available USGS data for mine locations in its development. The DLUP does not have a description of a reasonable foreseeable development scenario for oil and gas or for hard rock (locatable, salable, solid leasable) mineral resources. Hence the Preferred Alternative in the DLUP is arbitrary and capricious. No objective standard was created for the minerals analysis. Maps of mines and mineral collecting localities in the management area are provided in Maps 1 to 11. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #2224-15 - The DLUP also underestimates the economic contribution of mining and mineral collecting, and oil exploration/development. There are hundreds of mineral collecting clubs and mining companies in California. There are thousands of claims. Mineral collectors and mining claimants spend money when they collect or maintain claims. Almost every weekend, there are miners working their claims in the management area. Sometimes they stay for several days. All this activity has economic impacts on rural communities. These impacts are not addressed in the DLUP. Also the potentially huge impacts to communities in the Monterey/Temblor fracing oil and gas development areas is overlooked in the DLUP. [Individual] Response: The LMP does not define unique criteria for approval of projects that would be allowed “by exception”, but the plan does outline the decision process and criteria for all projects. Project decisions are based on a specific proposal that is analyzed through site specific NEPA analysis. Each project is subject to the design criteria and other direction described in Part 3. Although the Final SEIS cannot speculate on individual projects, the general effects and likelihood of projects being proposed is discussed in Chapter 4. The likelihood of "by exception" activities being considered in the roadless areas is generally very low, because any development would have to be conducted without roads to be consistent with the RACR, and most of the "by exception" activities require extensive road support. Chapter 4 has a more detailed discussion on the likelihood of "by exception" projects. The plan amendment would not change the regulations governing minerals management. Development of Oil and Gas Leases on the Los Padres National Forest is governed by a previous decision. Oil and gas development on the Angeles National Forest and other potential locations is governed by Forest Service and Bureau of Land Management regulations. Hard rock mining is governed by Forest Service regulations at 36 CFR 228 Subpart A. The minerals analysis was based on existing, active claims, and active plans of operations. The maps provided with the comment letter (and filed in the public reading room) reflect historic mines and access roads that are largely abandoned. Regulations governing minerals management would not change as a result of the decision, therefore active mines would continue to remain active as specified by the approved notices of intent and plans of operations. The decision would not alter activities at these locations. Concern #51 Concern: The Forest Service should modify the preferred alternative to allow no "hard" permanent abandoned mine lands closures. Sample Comment #2224-10 - DLUP description of management of abandoned mine Statements: lands (AML) allows for total closure (“hard closure) of some mine features (shafts, adits, drifts, declines). These hard closures make it impossible to miners, mineral collectors, geologists, and other researchers access to the underground mine workings. For geophysicists, mine workings are important features for studying rocks because they are often not as weathered as surface

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

exposures of rock units. In almost all cases, these hard closures are not necessary. The working can be made safe for humans in other ways, such as installing grates over shafts, and at the same time allow access for mineral collecting or research activities. The DLUP Preferred Alternative should be modified to allow no “hard” permanent AML closures. [Individual] Response: The proposed action does not make site-specific decisions, nor does it set policy to limit the applicable alternatives considered during site specific analysis. When an abandoned mine is analyzed for closure, multiple alternatives are looked at from a public safety and protection of resources point of view. These actions are listed on the Forest Schedule of Proposed Actions (SOPA) to support public interaction and input during the decision making process. Concern #52 Concern: The Forest Service should analyze the effect of land use restrictions on mining activity. Sample Comment #2224-4 - The cumulative effects of non-mineral management Statements: prescriptions (wildlife, archaeology, recreation, visual resource management, etc.) have resulted in a depression of mining activity and mineral collecting activity in the management area. There are 975 mines and mineral collecting sites in the management area. Of these, 104 known mines and mineral collecting sites in the management area have already been closed due to wilderness. (Data Tables 1 and 2). Additional non-congressional (administrative) restrictions have been implemented in some LUZ’s by past planning efforts. The preferred alternative adds another 21 sites to places that will be restricted or closed to mineral collected and commercial mining [Individual] Comment #2224-9 - Access route restrictions in the DLUP make it more difficult to miners, mineral collectors, geologists and researchers to get to 975 mining and mineral collecting sites. Each of these mines had a road going to it at one time. Regardless of the new land use classification, these designated Land Use Zones should not include the mines/mineral collecting sites in them, or the roads. The road and mine sites should be “cherry stemmed” from the LUZ classifications. The current condition of these old roads may be poor. But miners and mineral collectors should be allowed to propose temporary road improvements and surface disturbance to get to the mines in order to conduct exploration or development under mining notices or plans or through special use permit applications. The proposed alternative is to close many of the LUV’s to any type of road access and many to casual use collecting. The mine/mineral collecting sites in many cases are miles from roads that are in the DLUP. By restricting vehicular access, USFS is effectively closing them. This closure is not needed to protect non-mineral values. Those competing resources can be protected on a case-by-case basis, as proposals to explore and develop minerals are proposed by miners and mineral collectors. It is poor management to simply close off all activity in the LUZ’s. Mineral users should have the opportunity to propose mineral activities in these areas, and in their proposals show how

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

mineral exploration or development can occur without damaging non-mineral resources. [Individual] Response: The 975 mines and mineral collecting sites in the management area is based on a database of all the sites that at one time were used or explored. Not all claims were developed. Of those sites that were developed, many were worked and then abandoned. The cumulative effects discussion indicates there could be an increase in establishing mining claims based on prior rights before Congress designates a wilderness area. The proposed action does not close sites to mineral collection. The inventoried roadless area classification is the overriding regulation. Notices of Intent and Plans of Operations submitted under the mining regulations can request/propose access within the limits of land designations. Only those roads that are on the Forest Service Motor-vehicle use map (MVUM), those actively accessing a special use permitted area, or those authorized under an approved Plan of Operation are "cherry-stemmed" or maintained. The Forest Service is not closing mineral location areas. Lack of vehicular access did not preclude many of these sites from being developed in the last century. Proposed actions for hardrock minerals development are governed by Forest Service regulations at 36 CFR 228 Subpart A. An assessment of the provided maps and "blue-lined" roads were made across the management area analyzed for this project. On the each of the four Forests, only those roads that lead to an existing active mine, those roads that access a special use permit area, or those that are on the Forest Motor-vehicle Use Map (MVUM) would be maintained. Many of the blue colored lines on the attached maps are in the footprint of old access roads that went to historic mines. The Preferred Alternative does not close any road that is currently authorized. The decision will not change, nor amend, the Mining Act of 1872. The 1955 Multiple Use Mining Act (30 U.S.C. 612) restricts mining operators to using reasonable methods of surface disturbance that are appropriate to their stage of operation (United States v. Richardson, 599 F. 2d 290 (1979); cert. denied, 444 U.S. 1014 (1980)). This legal principle is reinforced by the Forest Service in 36 CFR part 228, which provide procedures for authorizing operations on the National Forests which are reasonably incidental to mining, but requires that such operations be conducted so as to minimize adverse environmental impacts. It is outside the scope of this project to speak to oil and gas discoveries as this project is focused on Inventoried Roadless Areas and land use designations. Generally, oil and gas exploration is the purview of private businesses. In regards to the decline of gold mines on National Forest System lands, the production of locatable minerals is governed by various laws and regulations (e.g. Mining Aact of 1872, Multiple Use Mining Act of 1955, 36 CFR 228 Subpart A). The proposed action does not change any of these laws or regulations. Cumulative effects of the various alternatives include the possibility of increased mining claims in recommended wilderness areas to establish rights prior to a Congressional designation and Presidential signature. The proposed

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

action and the alternatives do not change any of the governing minerals and leasing laws and regulations. Therefore, the proposed action does not analyze the level of mining activity if laws and regulations were changed. It is not relevant to the decision as to what might happen if any number of laws and regulations were changed in some manner. Concern #53 Concern: The Forest Service should document the need for mineral withdrawals in the supplemental environmental impact statement. Sample Comment #2224-3 - Withdrawal proposals for several of the Land Use Zones Statements: (LUZ) are inconsistent with Bureau of Land Management (BLM) and US Forest Service policy. These policies and directives state that withdrawals were only appropriate in areas of high mineral development potential where there is also another resource that can’t be protected any other way than by closing an area to the Mining Law or other mineral entry. Several of the proposed mineral withdrawals are in areas that USFS itself classified as not having potential. The need for mineral closures is not documented. There have never been any citations or problems with miners exploring or developing minerals in the LUZ’s proposed for closure. Management conflicts between mineral collecting and other land uses can be mitigated through the USFS mining and recreational regulations, specifically through issuance of special use permits or through NEPA analysis of mining plans of operation. [Individual] Response: The proposed action and alternatives do not propose any mining withdrawals. A recommended wilderness land use designation does not cause a withdrawal. The action does not change any of the governing minerals laws or regulations. Proposed projects are required to be analyzed through the NEPA process. Site- specific multiple-use management and potential conflicts are analyzed in the process and recommendations and mitigations are specified during this process. Concern #55 Concern: The Forest Service should address the impacts of mining and other industries to water use and ecological and human health. Sample Comment #8890-1 - West Fork and Westfork - Mining by the Vulcan Materials Statements: Corp. (Azusa Rock Quarry) should not be allowed adjacent to ANF. Mining will disrupt the new (1998) Fish Canyon Trail which runs through both the ANF and Vulcan Materials property. Mining next to ANF will have negative impacts on the chapparal ecosystem in the national forests. The ecological"edge effect" impacts will be harmful to plant and animal species within the ANF. Visual impacts from the Fish Canyon Trail will be severe. Forest Service land (ANF) next to the rock quarry should be classified as CB in addition to BCNM. [Environmental Conservation/ Preservation] Comment #7490-1 - IF YOU ALLOW MINING, THEN THE WATER SHOULD BE, HIGHLY, LIMITED. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #8807-1 - Allowing industry into these areas will be a tragic blow to California ecological balance, which WILL affect everyone here on the west coast adversely. Financial ruin will accompany any tampering by the "businessmen" to make the area more financially 'viable'; they have NO idea what havoc they will bring down upon ALL our heads by their interference; they have no inkling as to how badly their 'improvements' will cause problems with this very essential bio-region. It IS necessary to PROTECT this area, it is especially important NOW, when there are so many problems facing quality of water and air. DO NOT SELL IT SHORT! THINK of the legacy YOU will be leaving those who come after you, your children and grandchildren, by letting unsympathetic businesses in to areas which need to be nurtured. [Individual] Response: The proposed action or alternatives would not change any mining policies or regulations and any proposed mining projects on the national forests are required to be analyzed through the NEPA process. Site-specific multiple-use management and potential conflicts are analyzed in the process and recommendations and mitigations are specified during this process. Water (quantity and quality) and air quality are just two resources that are analyzed during the NEPA process and during implementation. Limitations occur on a site-specific basis. Air quality problems can be reported to regulatory agencies and mitigations or limitations can be required to protect public health and safety. The Roadless Area Conservation Rule governs one aspect of development. The Azusa Rock Quarry is located outside of the congressionally designated boundary of the Angeles National Forest, and therefore management of the project is not subject to Forest Service jurisdiction. Concern #56 Concern: The Forest Service should identify paleontological sites in the supplemental environmental impact statement. Sample Comment #2224-11 - There is no paleontological collecting sites identified in Statements: the DLUP. [Individual] Response: Paleontological sites are noted in the Appendix 2 IRA evaluations for the Quatal and Sawmill-Badlands units. There are no designated collecting sites. More information on Forest Service management of paleontological resources can be found at: http://www.fs.fed.us/geology/fossils.html Concern #57 Concern: The Forest Service should address land designation impacts to lands available for energy development. Sample Comment #8781-4[Sample Statement] ANF Plan Amendments: While neither Statements: action alternative would have a direct impact on the existing transmission line corridors, the Plan would decrease the suitable area available for possible energy development, and is especially true of Alternative 3. [Municipal/City Government Agency /Elected Official]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The EIS discusses energy development impact in the Non-Recreation Special Uses section of Chapter 4. Lands available for energy development would be reduced under any of the action alternatives. Concern #58 Concern: The Forest Service should ensure that all actions comply with local fire and fuels management code and ordinance requirements. Sample Comment #8880-1-- 1. Any development proposed within the County of Los Statements: Angeles Fire Department's jurisdiction must comply with all applicable codes and ordinances which may be subject to water systems requirements for fire protection purposes and fire apparatus access. 2. This area described in the project scope is located within the area described by the County of Los Angeles Forester and Fire Warden as Very High Fire Hazard Severity Zone (VHFHSZ). All applicable fire code and ordinance requirements for brush clearance and fuel modification plans are subject to compliance if any development is proposed. 3. Specific fire and life safety requirements for any development will be addressed during the Fire Department review of any construction plans prior to building permit issuance. [County Government Agency /Elected Official] Response: Nothing in the LMP changes the jurisdiction of county or local governments. If the county or local agencies have jurisdiction by law, than those local or county requirements will apply. Concern #59 Concern: The Forest Service should discuss fire prescription impacts to natural resources, invasive species, and defensible space protection. Sample Comment #7916-10 - On p. 114, the Draft SEIS states that: “Recent studies by Statements: the Southern California Wildfire Risk Scenario Project have shown that factors that improve the outcome of fuel breaks are firefighter access, fire size, and fuel break condition (Syphard et al 2011)6,7. Firefighter access is the most influential variable. ... Firefighter access is the one variable that is affected by the proposed changes in Land Use Zones, ...” If, as Syphard et al found, fuel breaks really only work for suppression when firefighters are on them, why is it then assumed in the rest of the discussion that existing fuel breaks must be maintained, especially those that are not connected to roads? What is the likelihood that they are in the right place for future fires? Increased BCNM and RW zoning under Alternate 3 means that bulldozers cannot be used to cut control lines and to get truckloads of firefighters onto the non-road-connected fuel breaks quickly. We suggest that those fuel breaks should be revegetated instead of kept open--and susceptible to invasion by non-natives. [Environmental Conservation/ Preservation] Comment #8645-8 - Fire Analysis. Based on CNPS policy on native plants and fire safety [9], we are concerned that the Wildland Urban Interface "Threat Zone" is considered to be a minimum of 1.25 miles (p. 113), and that within it, "an additional 'strip' (sic) of vegetation

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

[is] modified to reduce flame heights and radiant heat." This appears to be a counterproductive approach. The simple fact is that ignitability is as big a problem as heat and flame height. Flashy fuels are more immediately dangerous than poorly-ignitable ones, no matter how much fuel is poorly-ignitable has accumulated. The 1.25 mile-wide area (not a strip) would be managed by removing woody plants to reduce the fuel load. Typically, such wholesale clearing results in replacement of native communities by non-native invasives, which, while containing less fuel, are more ignitable (since they are basically entirely flashy fuel). Grass and weed fires spread faster, and are more dangerous to the firefighters and to nearby buildings and people. Such clearances also denude slopes, opening the way for later erosion and landslides. [10] Certainly, the Service should work in concert with nearby structure owners to create defensible space, but wholesale clearing will only increase the fire danger to those people and structures, along with danger from landslides and floods, at the cost of increased land for invasive weeds. [Environmental Conservation/ Preservation] Comment #7916-9 - On Invasive Non-Native Species and Fuels Management: These issues are intertwined and must be analyzed together, which we do for the following sections of the Draft SEIS: • CNPS agrees with the Draft SEIS statements on invasive species found at pp. 61-62, 273-274, and elsewhere, and note that, according to Table 21, so few treatment programs are planned or are occurring for the invasives known to be in the IRAs. Lack of funding for invasives control is discussed on pp. 273-274. Controlling non-natives will control their ignitability, hence better protect communities from fire risk as well as aid resilience of the native vegetation. It would be a better investment of time, effort and public resources (e.g., taxpayers’ money) to work on controlling invasives, rather than on constructing buffer zones and fuel breaks in native vegetation. On pp. 273-274, it is stated that a chief stressor leading to non-native plant invasion is vegetation clearing and ground disturbances. Despite that, clearing and disturbance for fuel reduction (e.g. 100-foot to 1.25- mile buffer zones) and fuel break construction are assumed as part of fuels management even under Alternative 3 (p. 140). This is counterproductive. The buffers and fuel breaks will provide “highways” of disturbed land into and throughout the Forests. These ‘highways” are all too susceptible to invasion by annual non-natives, that quickly turn into flashy fuels, that will increase the very fire danger that the buffers and fuel breaks are supposed to ameliorate. The increase in invasives and the short-period fire regime they foster also reduces the resilience of the native vegetation--the natural ecosystems--that Forests are supposed to protect. [Environmental Conservation/ Preservation] Comment #7916-11 - On p. 113-114 it is stated that: “All fires are aggressively suppressed on the [Four Forests]. ... fuel breaks, roads, and past burns have been an effective combination in helping limit wildland fire size.” This contradicts the statements on p. 111: “... 24 wildfires over ten acres have occurred since 2006 within the [Four Forests], including the Day (162,700 acres, 2006), Porter Ranch (58,401 acres, 2007), Witch (197,990 acres, 2007),

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Zaca (240,207 acres, 2007), La Brea (90,000 acres, 2009), and Station (160,577 acres, 2009) fires.” (Acreages and dates added.) Much recent research has shown that under the Santa Ana wind conditions that occur several times each fall over much of the Four Forests area, most fires are not even slowed down by “fuel breaks, roads, and past burns8, 9, 10, 11. So we wonder why fuel breaks continue to be constructed and maintained at much effort and (taxpayers’) expense and to the detriment of the natural habitat. Throughout the DEIS there is an underlying theme that vegetation equals "fuel," e.g., an unfortunate example is the term “chaparral fuels” on p. 14. At the same time, the importance of fire to the proper functioning of Southern California’s natural ecosystems is discussed in many places, as are the increasing problems resulting from the too-successful fire prevention done during the last century. Thus the Draft SEIS expresses a dichotomy of values that we wish to highlight as the Amendment process moves forward: • Fire causes loss of value (economic as well as habitat) and is to be guarded against and suppressed as much as possible, and • Fire has much value (even if not easily quantifiable) because it is essential to the health of the ecosystems the Forests were set up to protect, and must be allowed to burn safely. [Environmental Conservation/ Preservation] Comment #8645-9 - Will the Amendment explicitly compare the issues surrounding non-native management, erosion management, and fire? These three issues are intimately intertwined and cannot be analyzed in isolation. Massive clearing for fire will exacerbate problems with erosion and non-native invasive species, while controlling non-natives will increase fuel loads while decreasing ignitability. [Environmental Conservation/ Preservation] Response: The SEIS addresses the changes in LUZ designation and the effects on the management of invasive species in Chapter 4 of the Draft and Final SEIS. The analysis for invasive species, as well as the wildfire and community protection analysis, assumes that individual fuels reduction projects, prescriptions, and fuel break management activities and their effects on invasive species or erosion control management, are evaluated during separate site specific NEPA analysis and therefore are outside the scope of this analysis, as are fire suppression management activities and their effects. The suppression effectiveness and fire fighter access analysis in Chapter 3 points out that road access is one variable related to fuel break effectiveness, and the variable that could be changed by a change in land use zones. Even when there is road access to a fuel break, the other variables can outweigh the access, and the fuelbreak will not be effective. The analysis has been clarified to reflect that suppression is not always successful because of this, leading to large scale fires as reported in the fire history section of the analysis. The analysis does not assume that any particular fuelbreak or access point will be maintained, but since the forest plan fire strategy does rely in part on fuelbreaks (Fire 5 - Fuelbreaks and Indirect Community Protection), it is important to disclose how the changes in LUZ could affect the system of existing fuelbreaks.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

The effects analysis in Chapter 4 has been clarified to further explain how the changes in land use zone will not change the fire management strategy outlined in the plan. Individual fuels reduction projects prescriptions and fuel break management activities and their effects on invasive species or erosion control management, are conducted as separate site specific NEPA documents and therefore are outside the scope of this analysis, as are fire suppression management activities and their effects. Concern #60 Concern: The IRA analysis should more thoroughly discuss the benefits of RW designations to California condors as well as the impacts to condors of activities allowed by exception. Sample Comment #8878-5 - The IRA Analysis for each IRA should assess the benefits Statements: of RW zone allocation on the integrity of historic or current roosting sites, nesting sites, and foraging grounds, and should also consider the impacts of allowing certain types of development and land use activities – such as mining, oil drilling, land disposal, target shooting, authorized motorized use, renewable energy, communication sites, harvesting of wood and other forest products, and fuelbreak construction. In our scoping comments, we suggested that the IRA analyses be modified so that they offer consistent summaries of the benefits of wilderness designation, as well as the threats posed by development activities and land uses. The language used in these evaluations with respect to condors remains substantially unchanged, so we will repeat many of our scoping comments here. Wilderness designation provides a suite of additional wildlife habitat and ecosystem protections beyond any other land use zone. The benefits of wilderness designation were even highlighted in the LMP EIS, which acknowledged that “the level of protection for some species and habitats was increased by additional wilderness designations” during the previous planning period, and that wilderness “provides relatively large, undisturbed habitat for wildlife, including a number of threatened, endangered or sensitive species.” The draft LMP EIS went into even further detail: For a long time, wilderness was viewed primarily as an area to meet primitive recreation needs. However, it is now also being recognized as critical refuge for biodiversity, ecosystems, threatened plants and wildlife and airshed and watershed values in a rapidly growing part of the country. Environmental education and scientific research values are important as well. 8 … National Forest wilderness in southern California provides an important open-space reservoir of biodiversity for many species of wildlife and plants. Wilderness management focuses on allowing natural conditions to prevail, usually by eliminating or limiting human intervention. Therefore, the overall effect of wilderness designation is to provide additional protection and maintenance of natural biological diversity. Populations of federally listed threatened and endangered species located within any designated wilderness would be protected from potential disturbance or development.” U.S. Forest Service, 2004. Draft Environmental Impact Statement for Revised Land Management Plans: Angeles National Forest, Cleveland National Forest, Los Padres National Forest, and San Bernardino

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National Forest. Pages 3-173, 3-175. The reasons for deleting this language from the Final EIS are unknown, but these considerations should be evaluated in the SEIS and the IRA Analysis. We recommend that this language be restored in the SEIS. Several IRA analyses seem to discount the benefits that a wilderness designation would provide to condor survival and recovery. For example, the following language occurs in several IRA analyses: Current and projected human uses and developments on National Forest System lands in the Sawmill-Badlands roadless area are not substantially affecting the habitat of this species. Condors require large tracts of land in order to maintain viable populations. Currently, this endangered species occupies areas that are part roadless and part roaded. Current monitoring data does not indicate that the presence of roaded areas is precluding the use of these areas by these birds nor does the data show that California condors use designated wilderness areas more frequently than non-wilderness areas. The recovery plan for the condor does not recommend the designation of additional wilderness areas as a means of promoting the recovery of the species. IRA Analysis at 139 (Antimony), 155 (Cuyama), 181 (Fox Mountain), 211 (Madulce-Buckhorn), 227 (Sawmill- Badlands), and 240-41 (Sespe-Frazier). The analysis for the Diablo IRA states, “Condors have shown an ability to inhabit areas with much human development. But they, like most other wildlife, are more adapted to unaltered habitats.” IRA Analysis at 164. It is important for the IRA Analysis to be based on a full and accurate review of current information, and this language falls short of that imperative and is based on incomplete and sometimes inaccurate information. While these areas do include “historic roost sites,” they are also currently used by condors. The statement that “monitoring data does not indicate that the presence of roaded areas is precluding or reducing the use of these areas by these animals” contains no citation or incorporation by reference (as required by NEPA), and is not based on 9 the volume of scientific literature and on-the-ground data showing a variety of impacts to condors from human activity along roads. In fact, the Forest Service has known for forty years that “Vehicular travel has been shown…to be a major cause of disturbance to condors. No nests have been found closer than 1.2 miles of a moderately used dirt road.”3 More recently, the Forest Service stated 3 U.S. Forest Service, 1971. Habitat Management Plan for the California Condor, page 31. 4 According to FWS, “Designated wilderness areas encompass large areas of the LPNF, providing broad protection to habitat of the California condor.” U.S. Fish and Wildlife Service. 2001. Biological and conference opinions on the continued implementation of land and resource management plans for the four southern California National Forests, as modified by new interim management direction and conservation measures (1-6-00-F-773.2). Page 88. 5 U.S. Fish & Wildlife Service, 2005. Biological and Conference Opinions on the Revised Land and Resource Management Plans for the Four Southern California National Forests (1-6-05-F-773.9). Page 104. Potential threats to California condors from resource management activities on National Forest System lands include modification or loss of habitat or habitat components (primarily large trees) and behavioral disturbance to nesting condors caused by vegetation

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treatment activities. Also, facilities maintenance (including roads), recreation, or other associated activities within occupied habitat could prevent or inhibit nesting or lead to nest failure (USDA Forest Service 2001)…. Designated wilderness areas encompass large areas of the Los Padres National Forest, providing broad protection of habitat for the California condor (U.S. Fish and Wildlife Service 2001).4 Furthermore, FWS states that “[r]oosting sites must be isolated from human disturbance or intrusion.”5 The implication that a RW zone allocation is unnecessary because the California Condor Recovery Plan “does not recommend the designation of additional wilderness areas as a means of promoting the recovery of the species” is equally as troublesome. Granted, the Recovery Plan does not specifically refer to wilderness designation, but one of the five actions it calls for is to “[m]aintain habitat for condor recovery.” And under the section titled Conservation Measures, the recovery plan highlights land acquisitions to preserve condor habitat, and public entry in these areas has been prohibited since acquisition (and even stricter mandate than what is required by a RW designation). The plan also notes that in March 1995, the FWS recommended that a captive release program be initiated in the Ventana Wilderness of the Los Padres National Forest, evidencing a preference for large, intact areas with limited development. The plan recognizes that “[r]oosting sites and nesting sites are susceptible to similar disturbance threats, and their preservation requires isolation from human intrusion.” It also states that “[p]rotection should be provided by management plans on public lands,” meaning that the LMP Amendment is an excellent opportunity to secure strong protections for 10 IRAs that provide important condor habitat, such as Antimony. The plan also calls to “[p]reserve key foraging areas near nests and roosts,” including the San Emigdio Mountains and portions of the Antimony IRA. Wilderness is our nation’s most powerful tool to preserve habitats and landscapes. It is also a tool that can be used to fulfill the Forest Service’s duties under Section 7(a)(1) of the Endangered Species Act, which requires all agencies to “utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conservation of endangered species and threatened species.” One of these authorities is the recommendation of certain habitats for designation as wilderness. If the IRA Analysis retains the reference to monitoring data, then the SEIS should summarize the data gathered and the monitoring protocol used, consistent with the incorporation-by-reference requirements of NEPA. The data should be made available to the public for review. The IRA Analysis should also include a consistent evaluation of the benefits that a RW zone allocation will provide to condors. For example, the analysis for the Antimony IRA states: Wilderness designation could preclude wind energy development and potential impacts to condors. IRA Analysis at 141. And the analysis for the Fox Mountain IRA states: The landforms in this unit provide uplifting winds which attract condors to fly along it, particularly in their north to south migrations. There are also historic roost/nest sites in Lion Canyon. The same winds that attract the condors make the ridgeline suitable for wind energy development, which can cause fatal collisions between soaring condors and the wind generators. To the extent that wilderness recommendation

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would minimize wind energy development in this unit beyond existing measures, such a recommendation could benefit the condor. IRA Analysis at 184. This protection against potential wind energy development is not mentioned in any of the other IRAs where condors occur, nor is this evaluated as a potential impact in the DSEIS. Wind energy development is allowed in all other zone allocations except for RW, again demonstrating how wilderness is the best tool to protect condor habitat. In the Machesna Mountain IRA Analysis, the Forest Service states that a RW land use zone would “not substantially enhance condor recovery efforts as the unit is not used by condors, there is no indication of a future threat to the condors that could emanate from this unit and there is already a half mile to one mile of wilderness around the historic nesting and roosting areas.” IRA Analysis at 206. However, the same IRA analysis also discloses that condors “still occasionally soar over this unit and may once again nest at the nearby historic Beartrap or Castle Crags cliff sites” and “Condors still occasionally soar over this area.” Id. at 201-02. As described above, if a RW zoning designation is not selected for this IRA, then it will be open to a variety of development activities, including mining. The IRA acknowledges “evidence of historic 11 mining activities within the unit” suggesting that the area may be vulnerable to resumption of mining activities at some time in the future. IRA Analysis at 201, 05. Several IRAs erroneously state that condors are adapted to development and human activity. For example, the Sawmill-Badlands IRA analysis claims that condors “have the ability to survive in less than primitive surroundings.” IRA Analysis at 232. The White Ledge IRA analysis claims that condors are “adaptable to most human development.” Id. at 280. These statements are inconsistent with a long line of studies showing that condors require areas free of human disturbance for nesting and roosting,6 and as such, should be removed from the IRA Analysis. 6 The Forest Service’s species account for condors states: “Viability is a definite concern due to the extremely small population and vulnerability to many factors on National Forest System lands and other lands. Greatest among these are shooting, lead contamination, collision with overhead transmission lines and towers, trash, and general human disturbance.” Moreover, in 2005, the U.S. General Accounting Office (the research arm of Congress) concluded that “the endangered California condor is particularly susceptible to disturbances from human activities. Condors have been observed landing on oil pads on the refuge, which poses a safety risk to the birds and reduces their fear of humans.” GAO 2005, p. 22. As condors become more accustomed to human presence, they are more likely to interact with oil drilling activities. This, in turn, results in an increased likelihood that condors will ingest trash and experience other impacts from other activities on or near the national forest. More recently, the risks of condors becoming habituated to human presence was summarized as follows: “Early releases of captive-bred condors identified unanticipated problems related to the acclimatization of condors to human activities. Condors were observed raiding picnic coolers, perching on houses and aerials, and, in one instance, breaking into a summer cabin and ransacking the interior (Grantham, pers. comm. 2008). Acclimatization potentially draws condors to

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areas in which human activities could inadvertently harm individual birds and can modify the species behavior in the wild. California condors demonstrating habituation behavior must be chased away from dwellings and are at further risk of injury at that time…. USFWS has determined that California condors that become attracted to human activity and that are not deterred from previous aversion training received while in captivity, and that are not discouraged by deterrence efforts after becoming habituated to human structures or activities, must be captured and relocated, undergo additional aversion training, and be re- released, or be permanently removed from the wild.” Dudek 2012. Draft Tehachapi Upland Multiple Species Habitat Conservation Plan, page 4-53. Finally, the IRA Analysis suggests that a RW zoning allocation is inconsistent with wildlife management, particularly California condors. For example, the analyses for several IRAs state that wilderness designation could impede condor management efforts because of restrictions on the use of motorized vehicles. See IRA Analysis at 181 (Fox Mountain), 220 (Quatal), 231 (Sawmill-Badlands), and Sespe-Frazier (242). Please recall that the Wilderness Act – as well as the Forest Service’s own Wilderness Management Handbook – allows wildlife management activities to continue if necessary to preserve an area’s wilderness character. See U.S. Forest Service, 2007. Wilderness Management Manual, Chapter 2323.33 - Wildlife Management, and Chapter 2324.4 - Research in Wilderness. See also Association of Fish & Wildlife Agencies, U.S. Forest Service, and U.S. Bureau of Land Management. 2006. Policies and Guidelines for Fish and Wildlife Management in National Forest and Bureau of Land Management Wilderness. If wildlife management is used to disqualify an area from consideration as RW, then the IRA Analysis should discuss use of specific roads for these purposes in each IRA (including whether those roads are system roads or non-system roads) and should describe the use of motorized vehicles for wildlife management. We encourage the Forest Service to consult with the U.S. Fish 12 & Wildlife Service’s Condor Recovery Program to identify any key access routes that would be affected by a RW designation. We are unaware of any recent efforts to transport and release condors in the IRAs. [Environmental Conservation/ Preservation] Response: The Draft SEIS did include a general discussion of the effects of the alternatives on California condors, and this discussion will be updated in the Final SEIS as described in the response to concern #61.It is not possible to evaluate the site specific impacts of future projects allowed by exception until a project is proposed. This issue was addressed in the response to concern #92. The Final EIS does have a general discussion of projects effects in the context of the suitability of projects under the various land use zones. As described in the Draft and Final SEIS, changing to more restrictive land use zones such as BCNM or RW would benefit most wildlife species and their habitat by reducing future disturbance. The U.S. Fish and Wildlife Service completed the Biological Opinion for the revised LMPs on September 30, 2013, which evaluated the effects of the current LMPs and associated ongoing activities on endangered species.

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Specific to condors, the Biological Opinion concluded: “In summary, we have considered the impacts to California condor from the individual and aggregate ongoing uses. The Forest Service will implement standards that should minimize both the site-specific and overall impacts to this species and its habitat. With these measures, the low level impacts anticipated will not result in an appreciable reduction in the reproduction, numbers, or distribution of the California condor on Forest Service lands or rangewide.” Concern #61 Concern: The Forest Service should analyze project impacts to condors. Sample Comment #8878-35 - The DSEIS figures are limited to formally-designated Statements: critical habitat, and no figures are provided that compare the amount of other suitable and/or occupied condor habitat acres protected under various land use zones. Critical habitat for condors was designated in 1976 and 1977, and does not necessarily reflect all of the areas currently being used by condors. Moreover, the Forest Service’s species account emphasizes protecting high-use condor flyways throughout the forest: Because ‘flyways’ are an important habitat component for California condors and are where the risk of death is high due to collisions with man-made objects, recent conservation work has focused on gathering information regarding the location and use of these flyways. These ‘high use flyways’ are being determined based on historic observations of frequent use (ocular, radio and aircraft tracking from the wild population of the 1980s), recent observations of release birds, and through radio and satellite telemetry. Satellite tracking allows for both real time and elapsed time movement monitoring that can be used to locate birds, and to identify areas being used by the birds for nesting, roosting, and foraging. At a minimum, the SEIS should include a map showing the location of these high-use condor flyways in and near the IRAs. The SEIS must evaluate the impacts to condors and condor habitat outside of the formally-designated critical habitat boundaries. Only then can the SEIS accurately compare the effects of various alternatives. [Environmental Conservation/ Preservation] Comment #8878-33 - Table 11 (Summary of Threatened, Endangered, Proposed, and Candidate Species within IRAs) states that condors occur in only 6 of the 16 IRAs being evaluated in the Los Padres National Forest. See DSEIS at 45. This table should be corrected to include additional IRAs where condors are known to occur. The table omits the following IRAs from the list of roadless areas with occurrences of California condors: • White Ledge (the IRA Evaluation states that condors “frequent” this area) • Spoor Canyon (the IRA Evaluation states that condors may soar along the Sierra Madre Ridge in this unit) • Juncal (the IRA Evaluation states that condor foraging habitat is found in this area) • Quatal (the IRA Evaluation states that condors have been reintroduced “in and adjacent to” this area) • Black Mountain (the IRA Evaluation states that condors fly over this area) • Garcia Mountain (the IRA Evaluation states that condors are “present” in this unit). [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #8878-32 - In our scoping comments, we recommended that the SEIS evaluate the direct, indirect, and cumulative impacts of the Proposed Action and alternative land use designations, and should also evaluate monitoring protocol specifically tailored to condors. The draft SEIS includes a one-page evaluation of the benefits to condors afforded under the various alternatives, but does not evaluate any of the potential adverse impacts to condors from the various development activities allowed under a BCNM land use designation. Activities like oil drilling, mining, temporary road construction, construction of communication towers and facilities, wind and geothermal energy development, sale/disposal of forest lands, harvest of forest products, and type conversion – all of which are allowed in the BCNM land use zone, and prohibited in the RW land use zone – may have significant individual and cumulative impacts to condors. These impacts must be disclosed and evaluated in the SEIS. [Environmental Conservation/ Preservation] Response: As shown in the Final SEIS Table 11, 11 IRAs are known to have California Condor occurrences. These IRAs include: Antimony, Cuyama, Diablo, Dry Lakes, Fish Canyon, Fox Mountain, Salt Creek, Malduce Buckhorn, Sespe- Frazier, Machesna Mountain, and Sawmill-Badlands. This table will be modified to include the White Ledge, Spoor Canyon, Juncal, Quatal, Black Mountain and Garcia Mountain IRAs. California condors are a wide ranging species, and may have been seen sighted in other IRAs not listed in Table 11. The species has been known to travel the entire length of the Los Padres National Forest within one day. For analysis consistency across all four national forests, animals are considered to be "occurring within an IRA" if public data from US Fish and Wildlife Service’s corporate GIS database, California Fish and Wildlife and Forest Service’s Natural Resource Manager – NRIS Wildlife databases indicated that occurrence information was available. Animals were considered for analysis only if their occurrence information overlapped the GIS boundary of the IRA. They were not considered for analysis if they were adjacent to, but outside of the IRA boundary. Some species information is considered sensitive and therefore not displayed for public use. Figures in the Biological Assessment (supporting documentation to the SEIS, available in the project record) provide maps of federally designated critical habitat and known occurrence information. Due to the sensitivity of the management of this species, detailed occurrence information is not displayed in the SEIS or the BA. California condor flyways are generally shown as "occurrence". Condors can shift their use of flyways on a regular basis. Birds can be seen in any of the IRAs and can easily fly between the IRAs in any given day, which could indicate that the entire Los Padres National Forest is suitable for the species. Individuals could also occur on the Angeles or San Bernardino Forests as well. However, for consistency, only occurrence information and critical habitat information was used as part of the analysis. Table 7 of the BA compares the acres of federally designated critical habitat under the various land use zones for the different alternatives. The Forest

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Service Biological Assessment only analyzes the effects of the different alternatives on federally designated critical habitats and known occurrence information per ESA regulation (50 CFR 402.12– Section 7(a)(2)). The Biological Assessment (supporting documentation to the SEIS, available in the project record) analyzes the effect of the different alternatives on federally designated critical habitat and known occurrence information. The different alternatives do not authorize on-the-ground activities. The alternatives merely change the designation of the land use zones to be consistent with the 2001 Roadless Rule. All management activities on the national forest are subject to site-specific NEPA analysis, including consultation with US Fish and Wildlife Service, if needed. Finally, all management activities in inventoried roadless areas must be consistent with the 2001 Roadless Rule and what is allowed in roadless areas. Refer to the species specific on-going activities Biological Assessments for the LPNF (Cooper, 2012). This document analyzes the direct, indirect and cumulative effects of various land management actions on the California condor. Concern #62 Concern: The Forest Service should recommend more wilderness in Alternative 2 to protect critical habitat for steelhead. Sample Comment #9430-1 - To further minimize impacts to steelhead and designated Statements: critical habitat, NMFS recommends the Forests develop Alternative 2 so that IRAs containing or bordering critical habitat are designated as recommended wilderness (R W). Furthermore, there is ecological value in protecting tributaries to designated critical habitat streams on Forest lands, thus NMFS recommends that the Forests designate IRAs that contain tributaries to critical habitat streams, as R W (displayed in the enclosure). [Federal Agency/Elected Official] Comment #9430-3 - The BCNM land-use designation does limit future activities, such as roads, developed recreation, special uses, and energy developments that can impair the function and quality of essential habitats on which the life hi story and ontogeny of endangered steelhead depend. However, based on NMFS' understanding of the current LMP, oil development, energy development, communication facilities, mining, and disposal of national forest lands are all allowed "by exception" in the BCNM land-use zone. [Federal Agency/Elected Official] Response: Alternatives 2 and 2a allocate the areas associated with steelhead critical habitat as Back Country Non-Motorized, and Alternative 3 allocates those areas to Recommended Wilderness. As noted in the analysis, Alternative 3 would have the greatest benefit to both steelhead and water quality. Activities allowed "by exception" are activities that are not generally compatible with the land use zone but may be appropriate under certain circumstances. Those circumstances would be evaluated at the project level, but as discussed in the Final SEIS in the assumptions section of Chapter 4, the likelihood of certain activities such as oil and gas drilling, new communication 68

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sites, and wind energy development in the IRAs is low for a number of reasons. The primary reason is that any activity would need to be conducted without new or reconstructed roads, and road are typically necessary to support those activities. Any mineral leases would be issued with "no surface occupancy" stipulations, which would eliminate the potential for oil or gas drilling on National Forest System lands. In addition to the project level analysis of "by exception" circumstances, project specific impacts to endangered species or habitat are evaluated during project level analysis. Project design features and project mitigation measures are typically adopted to protect endangered species and their habitat, and the effect of the actions on endangered species is disclosed as part of the analysis and decision. Concern #64 Concern: The Forest Service should provide more up-to-date information sources and inventories of sensitive plant species in the supplemental environmental impact statement. Sample Comment #1449-4 - I do not agree that the sources referenced for rare plant Statements: occurrence information are the ‘most accurate readily available at the time this document was prepared.’ One resource mentioned, the California Natural Diversity Database (CNDDB), is a valuable source of information, however, it is not always completely up to date (unprocessed data), nor does it include all known occurrences of rare plants. A search of the online CNDDB Quickviewer tool for the Lockwood Valley USGS 7.5’ quadrangle, which is wholly within the LPNF, returns a list of seven special status plants. A search of the California Native Plant Society’s (CNPS) online Inventory based solely on the Lockwood Valley quadrangle returns a list of 14 special status plants, including the federally listed Threatened Eriogonum kennedyi var. austromontanum. Expanding that same CNPS search to cover nine quadrangles centered on the Lockwood Valley quadrangle returns a list of 31 special status plants, including the federally listed Endangered Eremalche parryi subsp. kernensis. Only the 6th Edition of the CNPS Inventory of Rare and Endangered Plants was referenced in this report. This edition of the Inventory, published in the year 2000, is completely out of date. The Inventory is currently in its 8th Edition and can be publically and easily accessed online at http://www.cnps.org/cnps/rareplants/inventory/. [Individual] Comment #1449-5 - The Botanical Assessment does not indicate what areas were considered in the review of the literature and databases mentioned. A literature review must be broad enough in scope in order to gather adequate information about the distribution of rare plants relative to a specific area. The California Department of Fish and Wildlife provides Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (2009), which includes the following recommendations (in part) for preparing for botanical surveys: Before field surveys are conducted, compile relevant botanical information in the general project area to provide a

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regional context for the investigators. Consult the CNDDB and BIOS for known occurrences of special status plants and natural communities in the project area prior to field surveys. Generally, identify vegetation and habitat types potentially occurring in the project area based on biological and physical properties of the site and surrounding ecoregion, unless a larger assessment area is appropriate. Then, develop a list of special status plants with the potential to occur within these vegetation types. It is standard practice to search a minimum of nine quadrangles when developing a list of rare plants that may occur in a specific area. Both CNPS and CNDDB offer the option to search nine quadrangles on their respective online websites. [Individual] Comment #1449-8 - The Botanical Assessment refers the reader to the species accounts, many of which are out of date and contain inaccurate information. For example, the species account for Eriogonum kennedyi var. austromontanum states on the first page that ‘there is no critical habitat designated or proposed for this species’ when in fact critical habitat was designated for this species in December of 2007 (see 73092 Federal Register / Vol. 72, No. 246 / Wednesday, December 26, 2007). Another example is the species account for the federally listed Threatened Brodiaea filifolia. The species account for this taxon states that ‘A final rule to designate CH for Brodiaea filifolia has not been made.’ This statement is also not accurate. Critical Habitat was established for this taxon in February 2011 (see 6848 Federal Register Vol. 76, No. 26 / Tuesday, February 8, 2011). The species account for Brodiaea filifolia also states that the management status for California is ‘None’; in fact, this plant was listed as State Endangered in 1982 (see California Department of Fish and Wildlife List of State and Federally Listed Endangered, Threatened, and Rare Plants of California, April 2013, available online at http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/TEPlants.pdf.) No species account for Eremalche parryi subsp. kernensis is included in this document. I did not review all of the species accounts for accuracy, however, the fact that very important information is either misstated or missing from the accounts mentioned above (or species accounts are entirely missing) is an indication that these species accounts in general, and the Botanical Assessment which refers to them, are unreliable. Both the Botanical Assessment and the analysis of Inventoried Roadless Areas, which is based on the Botanical Assessment, are therefore inadequate as the Botanical Assessment does not include the most current scientific information available and completely missed two federally listed plant species that occur on the Los Padres National Forest. The Forest Service failed to adequately identify all of the rare plants that may occur in these IRAs, and subsequently, these plants were dismissed from further review in both the Botanical Assessment and the DEIS; thus there is no analysis of potential impacts to these plants. [Individual] Response: Information on occurrences of plant species and critical habitat contained in the IRAs were derived from the Forest Service's Natural Resources Manager - NRM-TESP which includes threatened, endangered and sensitive species locations in the Forest Service's GIS information system. Location information

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from forest botanists that had been referenced in the IRA Evaluations was also used. The effects analysis for this project was programmatic and included only those species known to occur within the IRAs. We acknowledged in the Biological Evaluation and Assessments and the Draft and Final SEIS that additional rare plants and invasive plants may be present within the IRAs. If additional species were to occur they would be subject to the same beneficial effects as described in the Biological Evaluation and Assessment as plants known to occur. In the future, if specific projects are proposed within the IRAs, additional sources of botanical information such as CNNDB and the Consortium of California Herbaria could be utilized for the site-specific assessments. Land use zoning of IRAs was based on certain forest objectives not just the presence of species. Please see response to concern #106 for more detailed information. The Forest Service updated the Botanical Evaluation and Assessment and the Final SEIS regarding threatened, endangered, and sensitive plant species in response to comments. Specifically, in the Final Botany Biological Assessment’s threatened and endangered species and designated critical habitat table, Eremalche parryi ssp. kernensis and Eriogonum kennedyi var. austromontanum were changed from potential to occur to known to occur on the Los Padres National Forest. Eryngium aristulatum var. parishii was also added to the table as known to occur on the Cleveland National Forest. In addition, Eremalche parryi ssp. kernensis and Eryngium aristulatum var. parishii were confirmed to occur within IRAs. Both species were included in the effects analysis in the Final Biological Assessment and carried through the Final SEIS. Species accounts for Eremalche parryi ssp. kernensis and Eryngium aristulatum var. parishii were added to the project record, along with many other updated sensitive species accounts. Symphyotrichum defoliatum was also confirmed to occur within an IRA on the Cleveland National Forest. This species was included in the effects analysis in the Addendum to the Biological Evaluation and carried through the Final SEIS. The presence of these 3 species was also added to the appropriate Wilderness Evaluations. In the Botany Biological Evaluation and Assessment and the Draft and Final SEIS we used the most up to date data obtained from the U.S. Fish and Wildlife Service (Ventura office) and also from their website (http://criticalhabitat.fsw.gov/) even though it may have not been updated in the species accounts. Concern #65 Concern: The Forest Service should clarify the methodology used for vegetation classification and provide vegetation maps. Sample Comment #7916-5 - On the Vegetation Classification Analysis: On pp. 38-42, Statements: Vegetation Conditions are analyzed using the Wildlife Habitat Relationship (WHR) system. The WHR system does not comply with the National Vegetation Classification Standards (NVCS)3, which should be the basis for vegetation classification, rather than the WHR, for the Four Forests. The

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Manual of California Vegetation, 2nd Edition (MCV2)4 is in compliance with the NVCS and is the most detailed description of California vegetation available in 2013. It is based on modern field surveys done over a large portion of California, thus is the most accurate vegetation dataset available. The DEIS contains extensive information portraying the Four Forests’ vegetation using WHR, TWINSPAN, and tree MIS. However, these tools are not able to resolve the finer vegetation classifications defined by the National Vegetation Classification System (NVCS, referenced above), including delineating locations of rare plant communities from more common types. As a result, the prioritization of management decisions and actions to avoid and minimize impacts to rarer communities is not possible. Vegetation maps keyed to the NVCS that presents tables of vegetation types and acreages would fully comply with both the national standards and the 2000 MOU noted above, and most importantly, such maps would improve the decision making process for this and future Forest management planning. [Environmental Conservation/ Preservation] Comment #7916-6 - The US Forest Service Pacific Southwest Region is one of 11 agencies and organizations who are signatories to the Memorandum of Understanding for Cooperative Vegetation and Habitat Mapping and Classification5, finalized by the California Biodiversity Council in 2000. The MOU’s goals are “... to establish and maintain statewide vegetation and habitat data layers of known accuracy in compliance with the National Vegetation Classification System (NVCS).” We strongly urge the Forest Service, and in this case Pacific Southwest Region staff, to implement the intent of the May 2000 vegetation mapping MOU by developing and including vegetation maps based on the NVCS in the Final EIS, and in subsequent Forest management planning documents. [Environmental Conservation/ Preservation] Comment #8645-3 - Why was the Wildlife Habitat Relationships (WHR) system used? There is a National Vegetation Classification Standard [2], and the WHR does not comply with it. Additionally, in 2000, Brad Powell, the Pacific Southwest Regional Forester, signed a non-binding Memorandum of Understanding For Cooperative Vegetation and Habitat Mapping and Classification [3], whose stated goals were "to establish and maintain statewide vegetation and habitat data layers of known accuracy in compliance with the National Vegetation Classification System." This MOU was also signed by CNPS and many other agencies and organizations. Given the importance of this Amendment and DSEIS, what was the rationale for the decision made to use the non-compliant and obsolete WHR system instead? The MCV2 [4] system is compliant with current standards, and presents a wealth of additional information on history, rarity of component species, crosswalks among different classification systems, even fire history. The increased accuracy and information would have followed NEPA's guidance to "foster excellent action." [5] Why was the MCV2 not

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

used? [Environmental Conservation/ Preservation] Response: A MCV2 vegetation map would have been useful for the analysis. However, in southern California, it is available for only a portion of the San Jacinto District of the San Bernardino National Forest and therefore this tool could not be used for the entire analysis area. The most detailed Forest Service vegetation map available for the SEIS was the USFS Calveg map. However, the correspondence between MCV2 alliances and Calveg types is uneven at best. The Calveg map was developed using remote sensing in combination with gradient modeling but had limited field verification. As a result, its accuracy is questionable for small-scale analyses. In contrast, MCV2 alliance mapping combines field vegetation plots with photo interpretation to create detailed, more accurate maps. Given the size of the national forests and limited funding for vegetation mapping, this labor-intensive approach is unlikely to be employed any time soon. Region 5 currently is updating the southern California vegetation maps using more sophisticated species modeling but these maps were not available for the SEIS. In any case, it is unlikely that they will map MCV2 alliances, especially fine-scale shrub alliances. WHR vegetation types were chosen because they provided the best balance between accuracy and type descriptions. Furthermore, because the vegetation is being re-classified into LUZs less likely to cause negative impacts to the vegetation, the use of a vegetation map more detailed than WHR seemed unnecessary. The IRAs are scattered across four national forests. The Two-way Indicator Species Analysis (TWINSPAN) was only used to group IRAs having similar types of vegetation so they could be viewed in the broader landscapes presented in the Southern California Mountains and Foothills Assessment (SCMFA). Many clustering techniques could have been used to group IRAs instead of TWINSPAN. TWINSPAN was chosen because it is flexible and produced four recognizable groups that fit well into the SCMFA. Concern #66 Concern: The Forest Service should require surveying of sensitive plant species as part of monitoring efforts. Sample Comment #7916-8 - On Threatened, Endangered Plant, and Sensitive Plant Statements: Species and Critical Habitat: It is stated on p. 53 that “Out of 29 federally-listed threatened and endangered (T&E) plants that occur on the four forests, only two species ... are known to occur or have designated Critical Habitat in the IRAs.” We agree that “Most of the IRAs have not been completely surveyed for botanical resources. It is possible that undetected occurrences of T&E plants occur in the IRAs,” (p. 53) and request that such surveys be done as part of the Monitoring Alternatives. Furthermore, we agree that “[b]ecause focused surveys have not been conducted in all parts of every IRA, it is possible that other sensitive plant occurrences are present but undetected/unmapped in the IRAs.” (p. 55) In Tables 18 and 19, many species have been documented within 73

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

more easily accessible Land Use Zones, i.e., Back Country Motorized Use Restricted, Developed Area Interface. It is likely that focused surveys, off-road and off-trail, would discover a number of additional occurrences of both listed T&E and Sensitive species. In order to assess fully the management needs of these plants, such surveys must be done as part of monitoring associated with any approved Alternative. [Environmental Conservation/ Preservation] Response: Management indicator species (MIS) are specifically selected because they are the most indicative of overall ecosystem health. Sensitive species may be, but are not necessarily, indicative of an ecosystem. Several of the MIS in the LMP are also considered Sensitive. Sensitive species surveys are more appropriate at a project level, and are routinely required for projects with potential to impact individual species. Results of sensitive species surveys are tracked on an ongoing basis through the Natural Resource Information System, a Forest Service Corporate database. Threatened, Endangered and Sensitive (TES) plant species monitoring was considered as part of the monitoring associated with Management Indicator Species (MIS) monitoring efforts under Monitoring Goal 6.2, Table 57: Goal 6.2/Question: Are trends in resource conditions indicating that habitat conditions for fish, wildlife, and rare plants are in a stable or upward trend? Indicator: Management Indicator Species. Action: Use baseline MIS habitat condition from the 2005 Southern California Land Management Plans analysis and compare the existing MIS habitat condition on the southern California National Forests. Update every 5 years. The Forest Service conducts focus surveys only in conjunction with site specific project analysis that may occur within a given Land Use Zone. Information and data from these surveys are incorporated every 5 years into updates to the baseline information via the NRIS GIS database. In addition, some ongoing management activities and site specific projects have specific monitoring requirements for TES plants as requirements of ESA Section 7 consultation with the US Fish and Wildlife Service, regardless of LUZ designation. Concern #67 Concern: The Forest Service should focus on the protection of native plant species in their land management plan. Sample Comment #7916-4 - CNPS suggests that, by emphasizing preservation and Statements: protection of the native-plant resource, the Forests will better provide the ecosystem services that they have long provided, such as protecting their watersheds from erosion and for water production, as well as the newly important service of carbon sequestration2. [Environmental Conservation/ Preservation] Response: Management of native plant resources has been fully discussed within the 2006 FEIS and in the 2013 SEIS. The LMP includes several Forest Goals that relate to plants, including goals 1.2 (Restoration of Forest Health), 2.1 (Management

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

of Invasive Species), 5.1 (Improve watershed condition), and 6.2 (Provide ecological conditions to sustain viable populations of native and desired nonnative species). LMP Part 3 describes design criteria that apply to all projects, including measures to protect native plants. The Supplemental EIS evaluated several issues related to native plants, and analyzed the effects of the zoning alternatives on those related resources. The general conclusion for most resources was that increasing the area allocated to more restrictive LUZs could improve species habitat. Refer to the Final SEIS Chapter 4 biological resource sections for more detail. Concern #68 Concern: The Forest Service should re-evaluate their analysis of invasive species in the supplemental environmental impact statement. Sample Comment #8658-8 - On Invasive Non-Native Species: It is good to see that the Statements: invasion of Centaurea melitensis in the Ladd IRA is among those that have treatments planned or occurring, according to Table 21. It is a bit surprising that there are no other known invasives’ populations in the Trabuco District’s IRAs, according to the Table. OCCNPS concurs with the state CNPS office’s comments on the DEIS’ discussion of invasive species in the Four Forests and on Table 21. [Environmental Conservation/ Preservation] Response: The analysis is based on the current information available. The invasive species analysis concludes that the ability to detect, control, and eradicate non- native invasive species would remain the same under all alternatives. Concern #69 Concern: The Forest Service should restrict cattle access to Southern California National Forest lands. Sample Comment #8874-9 - Range cattle: The lands included in this LMP have Statements: wandering cattle that don't seem to have a home or owner. Since there are no Cattle leases or allowances in this LMP, protect the lands in question and do something about the wandering cows. The cattle are very destructive to lands mentioned in these comments. [Individual] Response: Livestock grazing is managed under grazing permits or special use authorization as described in the livestock grazing sections of Chapters 3 and 4. Each allotment is analyzed under a separate NEPA process. Grazing is a suitable activity in the RW land use zone, and allowed in designated wilderness as provided by the Wilderness Act. Title 36, Code of Federal Regulation, part 261, subpart A, General Prohibitions 261.7 prohibits placing or allowing unauthorized livestock to enter or be in the National Forest System or other lands under Forest Service control without authorization. Unauthorized range cattle should be reported to the nearest Forest Service Office.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #72 Concern: The Forest Service should not restrict access to, or use of, grazing permits and allotments in the supplemental environmental impact statement. Sample Comment #9366-7 - In your finalized Land Management Plan and maps we ask Statements: that you identify the existing permit roads to indicate that they will be designated for overland motorized travel for the operation of our grazing permit. We ask that you exempt us from any modification in LUZ designation that would prohibit motorized overland travel and/or restrict the use of our Forest Service livestock grazing permit on the Los Padres National Forest, and ask that you choose Alternative 1, No-Action Alternative. [Individual] Comment #9267-1 - The Kern County Cattlemen's Association has a membership of over 120 individuals and/or business entities, a number of whom hold cattle grazing permits in the Los Padres National Forest. These ranchers and businesses will be adversely impacted by implementation of the Proposed Action that is under consideration in this LMP Amendment. Our Association requests that you choose Alternative 1- No Action as your management plan for the Los Padres National Forest. The Proposed Action, Alternative 2, would change the land use zoning on members' permits from Back Country or Back Country Motorized Use Restricted to Back Country Non-Motorized (BCNM) land use designation. In essence, this Land Use Zone (LUZ) allocation allows the USFS to restrictively manage the area more like a wilderness area without the potential statutory designation. Our Association opposes any zoning that further restricts access and use of a USFS grazing permit by our member ranchers. Continuing to allow motorized access to permits is essential for ranchers who utilize the roads and trails to maintain waters, monitor the rangeland and monitor and move cattle. Motorized access correspondingly allows emergency responses for fire-fighting, search and rescue operations and access for law enforcement authorities to apprehend illegal marijuana growing operators. [Grazing, Domestic Livestock (incl. permittees)] Response: Grazing allotment access was included in Alternatives 2, and 2a along authorized routes. As shown in Chapter 4, Table 101, about 12 miles of permitted roads are currently within the BCNM land use zone. In response to these comments on the Draft SEIS, access to the Santiago allotment has been added to all alternatives under the Back Country Motorized Use Restricted LUZ for existing routes. The area adjacent to these existing routes will be zoned as Back Country Non-Motorized, however overland motorized travel may be approved on a case by case basis by the Forest Officer in charge of administering the specific permit.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #73 Concern: The Forest Service should ensure that the plan amendments will provide continued access to existing and future communication, electrical, generational, and other utility infrastructure. Sample Comment #8781-1 - LADWP operations require continuous and uninterrupted Statements: access to the LADWP's property and/or easement around the Aqueduct. The Plan should not negatively affect the ability of LADWP personnel to gain access for maintenance and operation of the Aqueduct. [Municipal/City Government Agency /Elected Official] Comment #9405-1 - The proposed Ladd IRA shown on the Cleveland National Forest Maps – Overview Map North has a portion designated "Back Country" which may impact Metropolitan's communication site known as Pleasants Peak, as well as access to the site. This proposed designation should not impose any restrictions on Metropolitan's ability to access, operate, or maintain these critical communications facilities. Since these comments are being submitted within the comment period established by the Forest Service under the National Environmental Policy Act (NEPA), Metropolitan looks forward to reviewing the Forest Service's responses and reviewing an amended SEIS that addresses our concerns.' Enclosed for your information is a copy of an exhibit which illustrates Metropolitan's impacted facility which is proposed to be located within the "Back Country" designation zone. [Other] Comment #7917-3 - SDG&E requests that all of its existing facilities, as well as the facilities included in the pending MSUP application, continue to be managed according to their current land use zone designations. SDG&E essential transmission and distribution assets and associated access roads should be excluded from the proposed land use zone redesignation and treated similarly to designated utility corridors within the USFS. The proposed land use redesignation could preclude SDG&E from maintaining the system in a safe manner, conducting necessary maintenance and inspections and from fire- hardening the existing electric distribution and transmission grid. Motorized and mechanized access is necessary along pole lines for emergencies as well as routine operation and maintenance. [Utility Group (water, electrical, gas)] Comment #8781-3 - • The LADWP maintains a system of access and patrol roads by prescriptive rights and/or are under special use permits for its daily use in maintenance and operation of the electrical transmission system. In order to maintain transmission infrastructures and maintain system reliability, it is necessary that these roads are available for use. • An area within 100 feet on all sides of each tower, measured horizontally, must remain open and unobstructed for maintenance and emergencies, including periodic washing of insulators by high-pressure water spray. • The location of access and patrol roads used by the LADWP for facilities maintenance within the ANF and SBNF should be excluded from Plan redesignation in order to maintain accessibility within these Forests. [Municipal/City Government Agency /Elected Official]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #9297-3 - San Bernardino National Forest DWR operates and maintains seismic equipment within a vault in the San Bernardino National Forest. The vault is along Cleghorn Trail off Highway 138. The Trail is a designated Off-Road Vehicle Trail maintained by a local Off-Road Vehicle group. DWR also has a pipeline that crosses through the forest land. Although the vault does not appear to be within an area that may face access restrictions, portions of the pipeline may. DWR would like assurance that we will continue to have access to our vault if needed and to our pipeline to perform inspections and maintenance as needed. [State Government Agency /Elected Official] Response: The Forest Service has evaluated the effect of the proposed amendments on the various authorized improvements for all utilities and their associated access roads in the area, and where alternatives would impact those facilities it is noted in the Non-recreation Special Uses section of the Final SEIS. Some minor corrections have been made to Alternatives 2, 2a, and 3 to adjust the land use zone boundaries to avoid conflicts when appropriate. The plan amendment does not make any project related decisions related to current authorizations, and would not change access or activities authorized under the current permits. For example, if an existing permit authorizes road or helicopter access to permitted facilities, that access would not change as a result of the amendment. By the same token, the proposed amendments would not grant or ensure any access to a holder that does not already exist under a valid authorization. Permit holders can check with the local authorized officer if there are questions about activities authorized by their current permits. It should be noted that prescriptive rights cannot be established across federal land. The Los Angeles Department of Water and Power operates and maintains facilities that are authorized by statute, and any forest plan direction would not modify the statutory authorization. If the amendment would change the future status of the permitted use by changing the land use zone, such as the potential effects of RW allocation on the SDG&E powerline in the Cedar Creek undeveloped area, that effect is noted in the analysis. While the analysis considers the potential effects related to designated utility corridors, the proposed amendments do not make decisions regarding potential new facilities. Any new facilities would need to be proposed by an applicant, accepted for consideration if the proposal meets the screening criteria, and analyzed in an environmental document before a decision would be made. The proposed amendment would affect the suitability of areas allocated to BCNM and RW for developed special uses, and that effect is disclosed in the Non- recreation Special Uses section of Chapter 4.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Concern #74 Concern: The Forest Service should remove or relocate powerlines and access roads in the Cedar Creek, Boulder Creek, and Cuyamaca Peak areas to protect land locked steelhead and other resources. Sample Comment #8874-3 - Removal or relocation of a second powerline and Statements: supporting road up the westside of Cuyamaca peak is also very important. This powerline is a public safety issue(fire risk) and is the only man made intrusion on the west fact of cuyamaca peak. The current powerline road mess up the west side of Cuyamaca peak is visible 20 miles away in the community of Lakeside when the sun is at the right angle. The removal of this powerline restores the west face of Cuyamaca to unspoiled wilderness that is visible all the way to the Pacific Ocean. Removal of this powerline also helps protect the Cuyamaca Cypress located in this area. The Cuyamaca Cypress trees need to be included in this LMP and protected. Removal of the powerline road network would also limit the illegal offroad activity that takes place in this area. [Individual] Comment #8874-2 - Electrical powerlines and their supporting network of roads in the proposed areas interfere with the wild character of the area. Remove or implement an underground re-route of TL-626 and distribution line 79 (Powerlines) through the plan area under Boulder Creek Road. TL-626 and 79 along with the supporting powerline roads run North-South through the Descanso and Palomar district LMP area. TL-626 in the main man-made intrusion to this area and its removal or relocation would greatly improve the wilderness character of the area and improve public safety. TL-626 has caused fires in the past and will likely in the future. A powerline(TL-626) with a current wind speed rating of 38 mph located in multiple foot high chaparral with documented wind speed gusts of 92 mph is a recipe for disaster. When you think of the scenic integrity of this area, the current powerlines are an eyesore. Boulder Creek is a major tributary to the San Diego River which flows through the LMP area. Boulder Creek is home to a controversial strain of trout that are self sustaining. These trout are known as native Steelhead by some biologists and their existence is denied by other government agencies. The fact is, Boulder Creek contains fish that are reproducing naturally and live in the creek. The Boulder Creek fish have the look, smell, and DNA of a steelhead like fish. Modern lake stocked trout as released in Lake Cuyamaca cannot survive and reproduce in the warm waters of Boulder Creek. The fish in Boulder creek are something special and deserve study and protection. Option 3 and removal of TL626 would protect this watershed and these fish from erosion and harm. Western Pond turtles also inhabit the creeks in the LMP area and face a similar status. Sunrise powerlink biologist denied their existence, I submitted photo proof to the PUC of their existence. Please put these powerlines under Boulder Creek Road or remove them from the plan area to further protect the area in question. [Individual]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The Southern Steelhead Biological Assessment (supporting documentation to the SEIS, available in project records) analyzes the effects of the different alternatives on designated critical habitats and known occurrence information. Pages 24-27 describe the distribution of southern steelhead on the Los Padres and Cleveland National Forest. Figures 6 and 7 also show the distribution of southern steelhead and their overlap with the IRAs. The Biological Assessment only analyzes the effects of the different alternatives on designated critical habitats and known occurrences that overlap with the analysis IRAs. The fish in Boulder Creek are not considered southern steelhead due to lack of access to the Pacific Ocean caused by several dams. This population is not currently recognized by NOAA Fisheries. Boulder Creek has been stocked by the Department of Fish and Wildlife in the recent past, which makes the fish population here more likely the progeny of stocked rainbow trout (Personal communication with Kirsten Winter, Cleveland National Forest Biologist). As noted in response to concern #73, the proposed amendments would not change the existing status of authorized facilities because the plan amendments do not make project decisions. The future of these facilities could be affected if the land use zone were to change to RW as proposed in Alternatives 2a and 3. Under a RW land use zone, those powerlines would not be a suitable use and issuing a new permit would require a project specific plan amendment. The Non-recreation Special Uses section of Chapter 4 discloses the effect of a RW land use zone on those powerlines. The transmission line (TL-626) referenced in the comment is being analyzed as part of a project specific EIS for the renewal of the master permit for San Diego Gas & Electric (Forest Service Project # 310). That project level analysis will support the decision associated with the master permit, and will document the project specific analysis for the effects of the powerline on the Boulder Creek area.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Section 7. Comments about transportation systems and recreation management. Concern #75 Concern: The Forest Service should analyze methods and criteria for keeping roads open for public access. Sample Comment #61-1 - One suggestion is to keep open the jeep roads that the Statements: environmentalists want to shut off, but keep them rough -- e.g., limited maintenance like Santa Ysabel Truck Trail (12S07) which ought to keep those intent on mayhem away. Then, access is limited to those serious enough, and with the right vehicle, to enjoy a true jeep road. Another option is to regulate access, via a gate with an access code that is given out to those with vehicles who get a day pass. , It seems to me as if the primary goal of environmentalists is to keep motorized vehicles out of the wilderness. A better objective might be to control access. [Other] Comment #8833-2 - The second area of concern relates to “historic access”. We vigorously support the general guideline of: if an area has had a particular access for at least 50 years that route is to be retained. We believe, for the most part, this is reasonable with the exception of access for developed water sources mentioned above. We also support the guideline which designates access to be no more than three miles apart. We believe travel of this distance is reasonable in most cases, with the exception that terrain may dictate a closer spacing. We would hope these two existing guidelines taken in tandem would help dictate current and future planning efforts as they relate to public access. [Other] Comment #9037-6 - There is another troubling trend in the CNF that has a significant impact on public access. Several locked gates have been erected recently, presumably due to Border Patrol and SDG&E (Sunrise Powerlink) activities. These gates have been erected on roads that have historically been open for public access to the Forest. A long-term plan for the use and eventual removal of these gates should be included in the new Land Management Plan. Otherwise, it will be several years before this issue can be addressed in the next LMP, and thus this negative impact on public access would persist for several more years. [Environmental Conservation/ Preservation] Response: Decisions about road management criteria and methods of access are made during the travel management process as directed by the Travel Management rule. Each forest has published Motor Vehicle Use Maps that show which roads are open to the public for motor vehicle travel. This issue was raised during scoping, and was determined to be outside the scope of the analysis (see Chapter 1, issues not considered in the analysis). There are roads constructed and maintained by permit, including the SDG&E access roads mentioned in comment letter 9037. Those roads are not maintained for public access, and the project level decisions that authorize those roads typically set the requirements that the permit holder will follow. In the case of the Sunrise Powerlink, gates were required on most of the SDG&E roads used for the project.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

While the LMP does not make travel management decisions, the land use zones do establish the suitability criteria for motorized travel in an area. The Roads and Trails analysis in Chapter 4 of the SEIS discusses how the land use zones would change for the roads and trails in the planning area. Alternatives 2 and 2a do not change the land use zones for any open public road. Concern #76 Concern: The Forest Service should update their road inventory. Sample Comment #2224-2 - These maps also show existing access routes in the USFS Statements: road inventory, and also historic roads not included in the USFS road inventory. The USFS road inventory is inaccurate and incomplete. [Individual] Response: The inventory of National Forest System roads and trails is complete, and available on line for each forest at http://www.fs.usda.gov/detail/r5/landmanagement/gis/?cid=STELPRDB532784 0. Like any inventory of an actively managed system, the data is updated as conditions change on the ground. The Draft SEIS used the most current version of the inventory at the time of publication. The Final SEIS will also use the most current version of the inventory to support the analysis. This is the best data available for the analysis. The inventory of unauthorized routes was compiled from sources of information, including field inventories, that were gathered over the last 10 years. It is updated as funding allows, and may not capture all of the user- created unauthorized routes that have developed since the last survey. It may also show roads that have become impassable through natural processes. Since these unauthorized roads are not part of the Forest Service transportation system, and not open to the public for motorized travel, the accuracy of this information is sufficient for this planning level analysis. The Roads and Trails analysis discloses the length of unauthorized routes in the various land use zones by alternative, and discusses the effects of those changes on the priority for decommissioning. As discussed throughout the Draft and Final SEIS, and in response to several comments, the plan amendments would not make any project level decisions, and any decommissioning proposals would undergo site specific analysis. Concern #77 Concern: The Forest Service should encourage a flexible buffer approach for forest roads and trails to accommodate site-specific needs. Sample Comment #2232-7 - Route Specific comments – Mt Pinos Ranger District The Statements: draft SEIS recognizes that the proposed 100 foot buffer for roads and trails will complicate road and trail maintenance. In some cases this corridor may be adequate while in others maintaining the existing Forest transportation system may require a wider corridor. This may be necessary to accommodate trail reroutes and relocations to reduce the grade of existing routes so that they may

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

better approximate current design standards. Although the draft SEIS includes no site specific analysis of the roads and trails there is an Inventoried Roadless Area Road and Trail Analysis that was developed as part of the Settlement Agreement. This analysis included a Route Scoring Model that assigned resource scores to Forest System roads and trails in the planning area and ranked them for potential resource impact. Many of the highest recreational value motorized trails on the Mt. Pinos Ranger District of the Los Padres ( Sespe Fraiser IRA) were reported as having high resource scores indicating a high potential for resource impacts. These routes included 19W04 Snowy, 20W24 Yellowjacket, 20W09 Cottonwood, and 20W06 Lockwood Creek. In addition several sections of trail in this IRA were reported to have a gradient greater than 0.5 indicating a steep grade. Rerouting these trails to reduce gradient could require a corridor wider than 200 feet. On this basis we feel that a corridor width of 300 feet is necessary for sections of the following trails that received a gradient score greater than 0.5. [Recreational (incl. permittees)] Comment #54-3 - I would like to see more flexibility proposed as part of this plan as well. IE; 500 ft corridors around existing motorized trails if they are to be "cherry stemmed" into RW areas. ( a 300 ft corridor may not have been enough to repair the Toad springs connector trail due to the size of the landslide) [Individual] Comment #8870-4 - Page 14, 4a: In areas with known geologic disruption and in consideration of future unforeseen acts of nature (e .g. erosion, earthquake, fire, flood, land-slide, etc.), the Department requests that ANF consider utilizing a variable width buffer in these areas, as deemed appropriate for existing authorized motorized roads and trails. [County Government Agency /Elected Official] Response: The issue of road buffers, allowances for relocation, and potential for future motorized trails was considered during scoping. In response to the scoping comments, Alternative 2, the Proposed Action, was modified to maintain the existing land use zones for several of the suggested future opportunities. Alternatives 2 and 3 applied fixed width buffers (100' on both sides of a road or trail) to Forest Service roads and motorized trails, and in some cases custom buffers of variable width were adopted to accommodate specific issues. Wider buffers were considered as an alternative but eliminated from detailed consideration as explained in Chapter 2. The specific areas identified in the comments on the Draft SEIS were reviewed, and as described in Chapter 2 the land use zone boundaries around the Quail Trail were adjusted to keep the current land use zone in the area for Alternative 2a. The request for wider buffers was reviewed but the approach taken in the Draft SEIS was not changed. There isn't sufficient justification for wider buffers absent some specific information about future opportunities. This same rationale would apply to the consideration of new forest plan standards that would waive the need for plan amendments if roads or trails were relocated in

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

areas where motorized or mechanized use was not suitable. The best approach in our view is to work through any site specific issues, relocation proposals, or other new opportunities through the normal project level planning and analysis process. Any project would need to be consistent with the Roadless Area Conservation Rule (RACR), which does allow relocation of roads for resource protection under conditions outlined in the RACR (see 36 CFR 294.12). Road, trails, and associated corridors incorporated into designated wilderness are subject to the language in the public law that designated the area as wilderness. The Toad Springs trail in the Chumash Wilderness is certainly an example of a trail that is constrained by adjacent wilderness. It is also a good example of a road corridor where the designating language provided direction about the future of that route. Alternative 2 and 2a propose a forest specific standard to address the intent of the "Los Padres Condor Range and River Protection Act of 1992" (see the Chapter 2 descriptions of Alternatives 2 and 2a). Concern #78 Concern: The Forest Service should address general road management-related requests and issues. Sample Comment #3602-1 - I would ask that any pavement be permeable. I would be Statements: happy to specify some affordably permeable materials. [Individual] Comment #88-2 - It is also advisable to provide management review and adequate administrative resources to effectively monitor and manage access on Cedar Creek Road. [Environmental Conservation/ Preservation] Response: As described in Chapter 1 of the Draft SEIS, issues related to travel management, road management, and staffing are outside the scope of this planning effort. Concern #79 Concern: The Forest Service should clarify which county roads could be closed as a result of plan implementation and permit county consultation. Sample Comment #8750-1 - Table 45 on Page 99 of the DSEIS indicates that there Statements: are2.9 miles of County roads in the Los Padres National Forest that could be affected (potentially closed) by the proposed action. It is not clear whether these roads are in the County of Ventura; therefore we would offer the following comment: If the proposed action will have an impact on Ventura County roads, in particular, but not limited to, Boy Scout Camp Road, Camino Cielo, Rice Road, Lockwood Valley Road, Piru Canyon Road, and/or Matilija Road, then the Transportation Department would like to review and comment on the proposed action. Our review is limited to the impacts this project may have on the County's Regional Road Network. [County Government Agency /Elected Official]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #8814-3 - Alternative 4(?) calls for the closing of Eagle Peak Road. Eagle Peak Road is not owned by the Forest Service and is in fact owned by the County of San Diego. This is not some type of RS2477 route. The FS grant deed to this area specifically omits Eagle Peak Rd. and other roads in the area. [Individual] Comment #8864-4 - According to the DSEIS, there are only 0.3 miles of County road in the Planning Area of the Angeles National Forest (refer to table 99 on page 238, table 102 on page 239, and table 105 on page 241). Additionally, pages 99, 237, and 243 of the document suggests there might be closures of County roads as a result of this amendment, however it does not specifically indicate which roads would be closed or affected. The Supplemental Impact Statement should specify what County roads are scheduled for closure or are being restricted in some manner so that the potential impacts to facility operations and maintenance can be evaluated. [County Government Agency /Elected Official] Response: As explained in the Draft SEIS, decisions about roads are not made during the amendment process. Future decisions about roads would be guided by plan direction, but no changes would occur until a project specific decision was made through the travel management process. The roads and trails analysis has been expanded in Chapters 3 and 4 of the Final SEIS to describe the county roads that are adjacent to the IRAs. Most of the roads are intended to be outside the IRA boundaries and the overlap is more of a mapping issue than an intent to manage the area as roadless. The IRA maps are maintained by the Forest Service Washington Office, and once the agency develops a process to submit corrections to the maps, this analysis may be used as a basis to identify needed corrections. The only county road that is intended to be within a changed LUZ is the Eagle Peak road in San Diego County. As described in the SEIS, this road is included in an RW land use zone proposed as part of Alternative 3. There are no changes proposed for the Lockwood Valley road in Ventura County, the Cerro Nores road in Kern County, the Pozo Arroyo road in San Luis Obispo County, or the S7 and Boulder Creek roads in San Diego County. Concern #80 Concern: The Forest Service should prepare a mountain bike plan, develop more trails in the Southern California National Forests, and track visitor use. Sample Comment #18-3 - While it is not included in the current DSEIS, I stongly Statements: support the need for a comprehensive mountain bike plan as part of a holistic approach to the use of our public lands. [Individual] Comment #9277-2 - With respect to the proposed Recommended Wilderness, we would like to know if the Forest Service conducted trail user counts on the existing and historical trails to determine the type and volume of traffic the trails currently support. We know that some of our members currently use some of these trails and such a study would seem appropriate before 40,000 acres of 85

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

land so near to the Santa Clarita and Antelope Valley communities is forever shut down to cyclists. [Multiple Use or Land Rights Organization] Comment #9277-7 - due to the shortage of mountain biking trails in this area, we would request that the Forest Service conduct a study to determine where new multi-use trails could be implemented in this area. [Multiple Use or Land Rights Organization] Response: Forest visitor use, participation and satisfaction are measured by the National Visitor Use Monitoring (NVUM) system. Analysis of the most recent data is summarized in the SEIS project records. The complete reports for the southern California national forests may be viewed and downloaded (individually or combined) from the NVUM web site. The southern California national forests use this NVUM information, along with other sources, needs, opportunities and public input, to make strategic and project-level decisions regarding development of new trails as well as management of existing trails. Development of new trails is outside of the scope of the SEIS. Concern #81 Concern: The Forest Service should eliminate the multi-use corridor in Land Use Zone Alternative 2 or require additional public input. Sample Comment #6007-2 - I had reviewed the maps of the alternatives, but it wasn't Statements: until I attended the public meeting at the Santa Clara/Mojave Rivers District office in Acton on March 28, 2013 that I was aware of the meaning of the thin, almost invisible yellow lines marking historic hiking and riding trails within the proposed wilderness around Fish Canyon as being designated for multiuse. Even though I have been involved with trails issues and have met with various public agencies (ANF, BLM, state, county and city parks) regarding trails over the last 15 years, neither I nor any other equestrian representative were contacted to participate in the scoping meetings. The scoping process is therefore incomplete and this project should return to scoping so that ALL interested stakeholders have a say in the subsequent proposed alternatives. [Multiple Use or Land Rights Organization] Comment #8059-8 - The rationale for creating the wilderness exclusion corridors contemplated in Alternative 2 is to allow for mechanical transport on trails that are entirely surrounded by the Salt Creek and Fish Canyon Recommended Wilderness. DEIS p. 240: "Narrow BCNM corridors were included along designated trails within the Fish Canyon IRA to accommodate mountain bike use." Excluding the trail system within a wilderness from the wilderness itself to allow for activities otherwise prohibited in wilderness clearly violates the intent of the Wilderness Act. The trail corridors proposed in Alternative 2 are an attempt by the Forest Service to find a way around the Wilderness Act. This is not an acceptable approach, and it potentially undermines the integrity of the Wilderness Act. [Environmental Conservation/ Preservation] Comment #8914-1 - Regarding Alt. 2, the idea of designating a 50' multi-use

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

corridor through a wilderness is novel and ill-conceived. 1 - the expectation of wilderness users will be the experience the area without mechanized vehicles 2 - Mechanized vehicles will degrade the wilderness area and is not compatible with the goals of protecting sensitive areas. [Multiple Use or Land Rights Organization] Response: The Forest Service has reviewed the narrow BCNM corridors included in the Draft SEIS along designated trails within the Fish Canyon and Salt Creek IRAs of the Angeles National Forest that would accommodate mountain bike use. Further analysis has led to the elimination of all (approximately 20 miles) of these BCNM corridors in Alternative 2a, making the entire Fish Canyon and Salt Creek area a RW land use zone in that alternative. This was done to provide a greater range of analysis and because it is more consistent with the Wilderness Act, more manageable, and there is no evidence of significant mountain bike use in this area. There are other higher-quality mountain biking opportunities outside of this area. Concern #82 Concern: The Forest Service should redesignate identified trails to non-motorized status or avoid "cherry-stemming" trails in potential wilderness areas. Sample Comment #8810-1 - We support the White Ledge/Juncal/Diablo Wilderness Statements: proposal with the caveat that the OCEAN VIEW TRAIL (Forest Route 5N12.1) area (included within the proposal boundaries) MUST be returned to NON- MOTORIZED status. The Historic Ocean View Trail section in question, see appendix 1 map, is one of the most vulnerable and sacred areas of the greater Matilija and Chumash cultural traditions, and is currently the subject of illegal off-road vehicle, gun/shooting, and environmental/watershed destruction/violations. We agree with our Ojai District Ranger Sue Exline who explains that it is physically and procedurally impossible for the Forest Service to police and control this remote wilderness section of the Los Padres Forest, which is the subject of the devastation and desecration. We therefore request that the entire dirt road section of the Ocean View Trail be closed to motorized traffic, in consideration of the illegal off-road vehicle violations, and in consideration of the fire season and 2nd year of drought -- closed for environmental and watershed restoration until such time in the future as the restoration is complete, and the Wilderness Area approved/enacted, and abridgements of the road be fully in place. If the closure of the full OHV Road / Ocean View Trail to motorized traffic is politically impossible at this time, then we request immediate closure of the short section from Noon Peak eastward, within the proposed boundaries of the White Ledge Wilderness. "The Ocean View Trail is a historical route that has been cut, dozed, and altered over the last century as to barely resemble the route described in a 1910 guidebook as 'one of the most beautiful of all' the Santa Barbara trails. Many of the changes are due to fire lines cut along the ridgelines east of the Romero Saddle, as well as some expansions as OHV routes (the Divide Peak OHV road now constitutes a large portion of the former Ocean View Trail.) The portion that remains a foot

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

trail is still a nice stretch with magnificent views." Craig R. Carey, Hiking and Backpacking Santa Barbara and Ventura. The Ocean View Trail from Santa Barbara in the West, continues eastward along the highest elevations of the Matilija Mountain Range (Eastern Santa Ynez Mountain Range) to become the El Camino Cielo Trail which continues all the way eastward to the current Kennedy Canyon and Rancho El Nido preserve along the Matilija/Ventura River. [Academic/Professional Society] Comment #9353-14 - While we are very pleased and grateful that the Angeles National Forest (AN F) is recommending the IRA for wilderness designation under two alternatives, we strongly oppose the exclusion of All of the IRA's trails from the proposed wilderness in Alt. 2. These trails are currently NOT used by mountain bikers, and on the ground evidence suggests that mountain bikers have not used these trails for 15+ years. In fact, some of the trails pass extensively through sensitive habitats such as streams where such use is inappropriate. None of the 19 miles of trails within the potential wilderness are actually used by the mountain bikers currently. None of these trails should be cherry stemmed out. The mountain bikers use Lower Fish/Gillette to Warm Springs, which is outside the potential wilderness. They also use the mountain bike user created trail called the Golden Eagle Trail, which is their primary 27 mile trail in the area. Areas that drop into creeks should be protected from mountain bikes and other abuse.[...]Trails: Upper Fish Canyon-In bad condition, portions of trail missing, 3 huge downed trees, 20' of trail missing, numerous HUGE landslides, and it dumps into the Fish Canyon river bed. There are also numerous slide areas along the trail making it difficult/impossible to pass. Without stream bed alteration and major overhaul, this could not be a feasible mountain biking trail. The steep trail is more than 15 degrees, which does not even adhere to IMBA standards. Gillette Mine Trail- The beginning of this trail is in passable condition except for 3 downed trees. The trail then deteriorates, and crosses a Native Burial Ground. Lower Gillette Mine Trail exists for a short time, but was washed completely out in 2005 and the connection no longer exists. Without reroute for the Native American burial ground, and a reroute over crumbling granite (about 1/2 of the existing trail), and resurrection of the lower portion of the trail, this could not be a sustainable trail for mountain bikers. Also, Mountain bikers are currently accessing an ANF OHV closure along 7N23 to the saddle of this trail by utilizing 2.5 miles of PCT including a cut they have made from 7N23 to join up with the PCT. This area closure needs to be reinforced (and trespassing on the PCT needs to be enforced) to keep them out, and to keep them from damaging the area. The steep trail is more than 15 degrees, which again, does not even adhere to IMBA standards. Burnt Peak-This trail is in very poor condition. There are 4 areas that were initially reinforced with wooden retaining walls. These walls have been shattered by landslides. There are steep drop-offs on the lower side of each of these, and landslides above. These would be areas of constant repair/upkeep, difficult and extremely expensive to maintain. There is nowhere else to reroute the trail at these points due to the landslides. The trail dumps into the creek, and there are 1.5 miles of strictly riparian habitat before it meets the Upper Fish

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Canyon trail. The steep trail is more than 15 degrees, which does not adhere to IMBA standards. [Civic or Place-Based Groups (Kiwanis, Elks, Community Council, Planning Cooperative)] Response: The Ocean View trail is outside of the IRAs analyzed and any changes to the use of that road would be made as part of the forest travel management process. Alternative 2 did not change the current LUZ for the Forest Service trails within the proposed Salt Creek and Fish Canyon RW areas. Mountain bike use is suitable under the BCNM land use zone. Alternative 3 included the trails in the RW land use zone, and mountain bike use is not suitable under the RW land use zone. Alternative 2 responds to the issues raised by the mountain bike user groups as a result of scoping. In response to the comments on the Draft SEIS, the Forest Service reviewed the resource conditions associated with the trails, and determined that the preferred desired condition for the area is recommended wilderness. Alternative 2a allocates those trails to RW, without changing Alternative 2 or 3. Concern #83 Concern: The Forest Service should incorporate trail maintenance needs into their assessment of recommended wilderness areas. Sample Comment #3408-5 - Both existing and more wilderness deserve trail Statements: maintenance somehow built in to the actual designations. This should be an integral consideration of new LPNF lands to be considered for wilderness. [Individual] Comment #8818-1 - Rancho Cucamonga Engineering Services Department - The National Forest Service should consider repairing the portions of Cucamonga Truck Trail 1N34 that were washed out, to improve emergency access for fire suppression and rescue purposes. Improved public access to Cucamonga Canyon could also reduce the necessity for rescue since hiking will likely continue whether or not the routes are safe. [Municipal/City Government Agency /Elected Official] Response: Specific road or trail maintenance activities are outside the scope of this analysis. Those actions are analyzed as site specific projects and would have to be consistent with the requirements of the Roadless Area Conservation Rule. This analysis does consider the zoning associated with roads and trails, and in the case of the Cucamonga Truck Trail (1N34) the land use zones evaluated in all three action alternatives are compatible with continued use of the road. Concern #84 Concern: The Forest Service should analyze the effect of more restrictive land designations on trail systems and dispersed recreation opportunities. Sample Comment #9277-3[Sample Statement] Banning cyclists from specific trails and Statements: areas has would likely cause greater congestion on nearby trails that remain multi-use. Fewer trails for mountain bikers in the growing SCV and AV areas

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

could increase the instance of user conflict in those regions. [Multiple Use or Land Rights Organization] Comment #8736-2 - The Wilderness Act does not allow any form of mechanical transportation and specifically prohibits bicycles. This prohibition will be in direct conflict with the existing alignments of the California Riding and Hiking Trail (Caliente Inventoried Roadless Area), proposed alignments of the San Diego River Trail and the Trans County Trail (Eagle Peak, No Name & Sill Hill Inventoried Roadless Areas with Cedar Creek & Upper San Diego River Publicly Proposed Undeveloped Areas). Existing sections of these three regional trails currently allow all three user groups. The proposed Wilderness Designation may require the rerouting of existing or proposed trail alignments in order to accommodate mountain biking. When rerouting is not possible, mountain bikers may experience disconnects in the trail systems or be forced to turn around and not continue on the trail through the designated wilderness areas. The County of San Diego Department of Parks and Recreation would appreciate the opportunity to work with the Southern California National Forests Land Managers to explore the County's regional trail routes that would be adversely affected by the new wilderness designations. At the time of the public review of the trails program and proposed regional trail alignments, there were no major concerns over trail locations and/or users. The regional trails are incorporated into the County's General Plan and any major deviations may result in an amendment to the General Plan. [County Government Agency /Elected Official] Comment #7043-3 - Issue 1: Disbursed Recreation Draft Supplemental Environmental Impact Statement for the Southern California National Forests Land Management Plan Amendment, Summary, Page ii, states: “The effects analysis concludes that allocating more of the study area to restrictive land use zones would benefit resources such as watershed, wildlife, and dispersed recreation by limiting future activities. The suitable area available for development of roads, developed recreation, special uses, and energy developments would decrease. No change is expected for grazing. Management for the reduction of hazardous fuels would likely shift from mechanized treatments to less intensive treatments, particularly in recommended wilderness areas. When this statement is closely analyzed for content, it raises the question of how “...disbursed recreation...” can benefit when restrictive land use zones are increased. As noted in other portions of the DSEIS, an overall reduction in land available for recreation will result with the implementation of the preferred alternative. Indeed, the statement acknowledges that recreation and special uses would decrease. Additionally, shifting management for the reduction of hazardous fuels from mechanized to a less intensive treatment does not coincide with agency direction concerning public safety and management prescriptions within Inventoried Roadless Areas. [Recreational (incl. permittees)] Response: Dispersed recreation occurs where there are few or no developed facilities present. As noted in the SEIS, many of the southern California national forest inventoried roadless areas already have relatively less dispersed recreation than

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

other areas due to their remote backcountry locations, steep slopes, few trails and heavy, often impenetrable chaparral at low to mid-elevations. The SEIS analyzed the effects of dispersed recreation for the alternatives in Section 4, Environmental Consequences. In general, it was determined that there would be minimal impacts to visitors who wanted to participate in dispersed recreation within inventoried roadless areas recommended as wilderness other than a slight decrease in motorized and mechanized access in some locations. There would not be a reduction of land available for public recreation but some of the recreation use in these locations would change. More of the non-motorized trail system would be included within BCNM or RW land use zones in the selected alternative. Mountain bike use of these trails in BCNM would not be affected; mountain bike use of the few trails within RW would become a non-conforming activity. The road and trail analysis in Chapter 4 was updated to discuss the effects of the alternatives on the regional trails proposed in San Diego and Los Angeles counties. Concern #85 Concern: The Forest Service should analyze motorized recreation in the supplemental environmental impact statement. Sample Comment #2232-4[Sample Statement] Motorized recreation should be Statements: discussed in Chapter 3, Recreation. We would like to comment on Recreation Section, draft SEIS, page 84. We note that this section includes no discussion of motorized recreation. This is surprising given the significant number of Forest visitors that participate in this activity. The 2009 Los Padres NVUM Visitor Activity Participation Survey indicates visitors participated in Motorized Trail Activity (5.9%) and OHV Use (4.8%), greater than other activities that are discussed in this section such as hunting (3.4%,) and primitive camping (3.4%). Hang gliding is discussed even though it is not reported in the NVUM Survey. With 924,000 visits to the Los Padres over 50,000 visitors have participated in Motorized Trail Activity, a significant number particularly given the limited mileage of the trail system. Although motorized trails are addressed in the section on Facility Operation and Maintenance there is little mention of OHV use as a form of recreation. We consider this an oversight and feel that a discussion of OHV recreation should be included. [Recreational (incl. permittees)] Response: As noted in the 2006 FEIS prepared in support of the 2006 LMP, the Forest Service's role as a provider of OHV recreation opportunities is unique in California. Motorized recreation (including OHV management) is extensively discussed and analyzed in detail and with specific data in the 'Motorized Trails' portion of the 'Facilities Operations and Maintenance' section in the FEIS. That discussion begins on page 283 of the 'Affected Environment' on page 283 (for five pages) and continues on page 545 of the 'Environmental Consequences' (for 11 pages).

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

The SEIS tiers to and incorporates all of that discussion and analysis and adds additional detail about relevant Los Padres National Forest inventoried roadless area motorized recreation in the 'Motorized Trails' section of 'Facilities Operations and Maintenance' of Chapters 3 and 4. Concern #87 Concern: The Forest Service should modify wilderness boundaries to exclude motorized and mountain bike trails. Sample Comment #2173-2 - In the Ojai area, the trails you should leave open to Statements: mountain biking include: Chorro Grande, Lion, White Ledge, Ortega and Thorn Meadows. In Santa Barbara, Buckhorn and Alamar/Mono. [Individual] Comment #2232-6 - Route specific comment BCNM boundary of the Black Mountain IRA to accommodate a planned trail reroute. We would like to call your attention to Attachment 1 which provides details of a proposed trail reroute we recently flagged in for the Pozo La Panza area of the Santa Lucia Ranger District of the Los Padres National Forest. This attachment shows that a proposed trail reroute of 15E10 Quail Trail would not be possible without a Forest Plan amendment under the Preferred Alternative/Proposed Action. The goal of this trail flagging project, conducted by Trails Unlimited, an Enterprise Unit of the Forest Service, is to reduce the grade and to improve the sustainability of existing motorized routes on the Santa Lucia Ranger District. This approach is necessary to help our trails meet current Forest Service design standards. This reroute would provide an “Easiest” route to help keep traffic off 29S02 Navajo Road and reduce traffic on 16E22 Mc Ginnis Creek Trail. This would reduce impacts to adjacent Mc Ginnis Creek and address safety concerns caused by unauthorized use of Navajo road by non-highway licensed vehicles. By making a BCNM boundary adjustment in the preferred alternative this trail connector could be completed following NEPA analysis but without requiring a Forest Plan amendment. [Recreational (incl. permittees)] Comment #147-2 - I would also like to request that the Forest Service ensure that the Golden Eagle Trail is entirely excluded from any Recommended Wilderness. [Individual] Response: Motorized and mechanized access routes near and through inventoried roadless areas were analyzed during the SEIS process. Where practical and environmentally appropriate, boundaries of BCNM and RW land use zones were adjusted to exclude existing roads and trails that are used by vehicles and mountain bikes. Some of the specific areas of public concern identified included locations in the Los Padres National Forest and the Angeles National Forest as follows: Santa Barbara Ranger District Buckhorn Trail (Malduce Buckhorn IRA): Much of the trail is overgrown with brush but it does receive some mountain bike use, particularly off the Buckhorn Road. Under Alternatives 1, 2, and 2a the trail would be within a BCNM land use zone and mountain bike use could continue. In Alternative 3 this route would lie within a RW land use zone where

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

mountain bikes would become a non-conforming use. Alamar/Mono: This trail is outside the SEIS project area (between the Malduce Buckhorn IRA and the Diablo IRA). A large portion of the trail is within the Mono IRA, already classified as RW in the 2006 Forest Plan where mountain bikes are a non-conforming use. Ojai Ranger District Chorro Grande Trail (Approximately half within the Sespe-Frazier IRA): This trail originates off State Highway 33, traverses north to Reyes Peak Road and receives low to moderate mountain bike use. Under Alternatives 1, 2, and 2a this portion of the trail would be within a BCNM land use zone. In Alternative 3 the trail would lie within a RW land use zone where mountain bikes are a non-conforming use. Lion Canyon Trail (mostly, if not all, within the Sespe – Frazier IRA in the Rose Valley area adjacent to the Sespe Wilderness boundary): The trail receives low to moderate mountain bike use. Under Alternatives 1, 2, and 2a the trail would be within the BCNM land use zone. In Alternative 3 it would lie within the RW land use zone where mountain bikes are a non-conforming use. White Ledge Trail: There is no White Ledge Trail within the Ojai Ranger District. There are a number of trails within the White Ledge IRA. However, all of these trails originate from or require access through non-National Forest System lands that are at present not accessible to the public. Alternatively, there is a Sisar Canyon/Red Reef Trail that provides access to the White Ledge primitive camp and the Sespe Wilderness. While the majority of this trail is within the existing Sespe Wilderness, the southern extent is located both within and adjacent to the Sespe – Frazier IRA. The non-wilderness portion of the trail receives mountain bike use. A segment of the route is on the Sisar Road and outside the IRA. The IRA segment of the trail begins where it intersects Sisar Road and ends where it reaches the Sespe Wilderness boundary. This trail segment is within the BCNM land use zone in all SEIS alternatives. Ortega Trail (Mostly within the Dry Lakes IRA): This trail (23W08) is a motorized route which is open to motorcycles. Access to and use of this route would remain under all SEIS alternatives. The trail corridor would be within the BC land use zone under Alternatives 1, 2, 2a, and 3. Mt. Pinos Ranger District Thorn Meadows Trail: This is officially named the Thorn Point Trail. It originates at Thorn Meadow Camp and ends at Thorn Point on the Mt. Pinos Ranger District. The trail is within the existing Sespe Wilderness and therefore has not been suitable for mountain bike use. Another concern was in regards to the possible accommodation of a trail reroute near the BCNM boundary of the Black Mountain IRA. The BCNM land use zone boundary was changed within the Black Mountain IRA to accommodate a potential segment reroute of the Navajo Bypass Trail (16E23) and connection to the Quail Trail (15E10). The area identified for the re-route is classified as BC, which allows public motorized trail use. This adjustment is reflected in Alternative 2a. In Alternative 3, the RW boundary was similarly adjusted and the potential re-route area was classified as BC.

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

On the Angeles National Forest, the Golden Eagle route is not recognized as a Forest system trail. Standard S35 in Part 3 of the LMP restricts non-motorized vehicle travel (including bicycles) to system roads, trails and limited areas. The Forest has not implemented a closure order that would make this prohibition enforceable. However, land use zone boundaries in all alternatives have been adjusted to exclude this route corridor from RW to allow future travel management planning that may consider making a Golden Eagle Trail part of the Forest trail system. This is a very minor change affecting less than one acre and approximately 150 feet of potential system trail. Concern #88 Concern: The Forest Service should justify the statement that "mountain biking opportunities would be forgone" for the Cucamonga wilderness. Sample Comment #6008-12 - The Sierra Club would like to challenge the statement Statements: made on page 296 of Appendix 2 that “Some mountain biking opportunities would also be foregone with wilderness.” We know of no known existing roads or trails that will be closed for this dispersed recreation use. We have long been opposed to the expansion of Mt. Baldy ski lifts into this IRA and have supported the Forest Service in their decision to preserve this wild area as wilderness and not a ski facility. [Environmental Conservation/ Preservation] Comment #6008-24 - On page 303 of Appendix 2, the false statement is made: “Some mountain biking opportunities would also be foregone with wilderness recommendation.” Certainly, the now washed out Cucamonga Truck Trail 1N34 is still open to mountain bikes and the Sierra Club knows of any Forest Service system roads or trails that would be closed by recommended this IRA as wilderness. [Environmental Conservation/ Preservation] Response: SEIS Appendix 2, Inventoried Roadless Area Analysis, includes documentation for the San Bernardino National Forest Cucamonga B and Cucamonga C units. Cucamonga B includes 2.7 miles of Forest system road and 1.0 miles of Forest system non-motorized trail (including 0.25 miles of Trail Class 3 and 0.75 miles of Class 2). Some mountain bike use could occur on these routes, possibly 1N34 (San Sevaine Road), and it would be foregone if included within a RW land use zone. Cucamonga C has 0.6 miles of Forest system road and 3.85 miles of Forest system non-motorized (Trail Class 2) trail. Some mountain bike use could occur on these routes, possibly 7W05 (West Fork Trail), and it would be foregone if included within a RW land use zone. Concern #89 Concern: The Forest Service should consider land designation effects to ultra running. Sample Comment #3952-1 - I am part of what is called the Ultra Running community Statements: which designates long distance running over 50 km or 31 miles. Among this community are those like me who only run races that take place in mountain trail areas. I am concerned that the designation of some of the land areas in the

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

proposed amendments would prevent ultra races from happening in those areas even though trail running represents minimal impact to wilderness areas. Would those are involved in this amendment process consider including some language to allow organized ultra trail races through the designated areas? [Individual] Comment #3407-2 - In reviewing the Draft Supplemental Environmental Impact Statement, Southern California National Forests, Land Management Plan Amendment for Angeles National Forest, Cleveland National Forest, Los Padres National Forest, San Bernardino National Forest areas, I noticed that the thousands of trail runners were not mentioned. Mountain bikers were mentioned. There was a vague reference in the Recreation section, Recreation Special Use Authorizations, pg 224, “The competitive recreation events held in the Trabuco IRA would not be suitable activities under the RW LUZ proposed by Alternative 3”. Alternative 3 Wilderness designation would shut down organized trail running events and therefore shut out this whole user community for events that have existed for years.[...]Please consider us in your decision as trail runners also provide volunteer time to perform trail maintenance and for an increasing number of events this has become mandatory for entry. [Individual] Response: Competitive events (including ultra-trail running) that require a special use permit are discussed in the SEIS as well as in specific inventoried roadless areas in Appendix 2, including the Trabuco IRA. The Forest Service Wilderness Handbook 2323.13h - Competitive Events states: "Do not permit competitive events, including competition involving physical or mental endurance of a person or animal, foot races, canoe or boat races, competitive trail rides, survival exercises (including military), or other activities of this nature in wilderness." This direction would also apply to RW land use zones but not to BCNM land use zones. Alternate locations for ultra-trail running events would have to be found if some roadless areas were to be designated as RW. Personal ultra-trail running (not as part of a competitive event) has been and would continue to be allowed in designated wilderness and RW land use zones. Discussion and analysis of ultra-trail running has been clarified in the SEIS Affected Environment and Environmental Consequences sections. Concern #90 Concern: The Forest Service should disclose and analyze impacts to existing ski areas in the supplemental environmental impact statement. Sample Comment #8986-2 - The MSSL has extensively reviews the DSEIS and has Statements: focused comments under this section to provide a fatal flaw in the document. Under the of the Affected Environment, sub-section Social and Economic Environment, entitled “Recreation” starting at page 84, the DSEIS provides the following: (a) Developed Recreation Developed recreation facilities have been constructed to offer recreation experiences, protect resources or otherwise manage visitor activities. There is one facility within the inventoried roadless

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

areas addressed in this SEIS. This entire sub-section fails to disclose under “Developed Recreation” (page 85) the existence of the MBSL as a permitted developed recreation area. Further, under this same “Recreation” section, the DSEIS provides: (b) Recreation Special Use Authorizations There are no changes to the few recreation opportunities offered in partnership with commercial and non-commercial entities through special use authorizations within the southern California national forests inventoried roadless areas addressed in this SEIS. Winter Sports Winter sports opportunities by special use authorization within the southern California national forests include downhill skiing and snowboarding, Nordic skiing, and snow play. There are none within the southern California national forests inventoried roadless areas identified in this SEIS. The two statements (above) lack adequate foundation and indeed are completely false. As cited in the Background section of the comments provided by the MBSL, the existing permit provided in 2001 includes the area known as Stockton Flats for future development. [Recreational (incl. permittees)] Comment #8986-7 - The MBSL asserts that the SDEIS has failed to take required “Hard Look Doctrine” established by the Court. The SDEIS is woefully deficient in that it does not disclose anywhere in the entire document the existing permit the MBSL holds from 2001 to allow for future development of the Ski Area. As such, the reviewer is lead to believe that there would not be a significant impact on a viable permitted business venture that has existed for well over three decades. The loss of this future development may cause great financial harm and distress to the MBSA as the year’s progress. (a) The "Hard Look" Doctrine - A Lay Explanation The National Environmental Policy Act (NEPA) states that all Federal agencies "to the fullest extent possible" must provide a detailed environmental impact statement (EIS) (42 U.S.C. 4332). Neither Congress nor the courts have indicated precisely how much detail an EIS must contain. However, courts consistently have held that, at a minimum, NEPA imposes a duty on Federal agencies to take a "hard look at environmental consequences" (Natural Resources Defense Council v. Morton, 458 F.2d 827, 838 (D.C. Cir., 1972). Hence, courts have carefully checked EIS's for completeness of information and detail, soundness of analysis, thorough discussion of alternatives, and disclosure of sources. Some court decisions have ordered agencies to prepare new statements if these criteria are not met. The courts' interpretation is that the agency has the "requirement of a substantial, good faith effort at studying, analyzing, and expressing the environmental issues in the EIS and the decisionmaking process, and a recognition that a rule of reason must prevail because an EIS which fully explores every relevant environmental detail could never be drafted" (Natural Resources Defense Council v. Morton, 458 F.2d 827, 838 (D.C. Cir., 1972)). If the EIS provides good faith analysis and sufficient information to allow a firm basis for weighing the risks and benefits of a proposed action, the court will find the EIS to be sufficient (County of Suffolk v. Secretary of the Interior, 562 F.2d 1368 (2nd Cir. 1977), cert. denied, 434 U.S. 1064 (1978)). [Recreational

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(incl. permittees)] Comment #8986-3 - The DSEIS also fails to disclose the existence of the 2001 permit that is held by the MBSL in the Environmental Consequences section. (a) Recreation Special Use Authorizations There are few changes to the few recreation opportunities offered in partnership with commercial and non- commercial entities through special use authorizations within the analysis roadless areas. The competitive recreation events held in the Trabuco IRA would not be suitable activities under the RW LUZ proposed by Alternative 3. (b) Winter Sports Downhill skiing, snowboarding and Nordic skiing opportunities do not vary by alternative as there are no existing winter sports special use authorizations in the analysis roadless areas. Some very small amount of individual use may occur but it would not be affected by any alternative. Most roadless areas in this analysis are in lower elevations. [Emph. Added] Both statements above are patently false. The MBSL, as provided numerous times above, has an existing permit demonstrating the existence close to the area known as Stockton Flat within the boundary of the permitted area. Moreover, the aforementioned permit provides an avenue for future development of the existing Ski Area in the same area now being proposed as recommended Wilderness. Even the maps provided in the DSEIS demonstrate that the recommended Wilderness proposed by the planning effort would cut- off the access to the ski area’s access road to Lytle Creek as the boundary drawn on in the Preferred Alternative demonstrates a conflict with the Wilderness boundary and the existing access road near Devil’s Backbone. [Recreational (incl. permittees)] Response: Discussion and analysis of winter sports recreation, including ski areas, has been clarified in the Affected Environment and Environmental Consequences sections of the SEIS as well as in the Cucamonga B inventoried roadless area documentation in Appendix 2 to reflect an accurate description of the Mt. Baldy Ski Lifts. The SEIS contains no discussion, analysis or proposal regarding the Stockton Flats area of the Sheep Mountain Undeveloped Area in the San Bernardino National Forest. That unit is outside of the scope of the SEIS. However, it was included in the FEIS and subsequent Washington Office appeal decision. No winter sports of any type were included in the Developed Recreation sections of the FEIS or the SEIS. Rather, winter sports was discussed and analyzed in separate sections of those documents. Concern #92 Concern: The Forest Service should analyze and monitor public access for hunting opportunities in the supplemental environmental impact statement. Sample Comment #9037-5 - the Forest Service should specifically monitor trends in Statements: hunting throughout the Forest, and in particular in IRA's and RW's. This would allow them evaluate trends in hunting participation, as called for in EO 13443. [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment #6580-2 - The DSEIS does not seem to adequately address any planning in the proposed Land Management Plan Amendment (LMPA) for enhanced public access for all legal recreational activities, particularly hunting opportunities. NOTE: There is a widely held consensus within the outdoor recreation community that any update to a Land Management Plan should serve as an opportunity to be exploited by the FS to implement the purpose/intent of EO 13443, which is described in part as a means to direct Federal agencies within the Department of the Interior and Department of Agriculture that have a measurable effect on public land management, outdoor recreation, and wildlife management -- to facilitate the expansion and enhancement of hunting opportunities and the management of game species and their habitat. [Individual] Comment #9037-3 - The major thrust of the DSEIS was to assess plans to convert existing Inventoried Roadless Areas to Recommended Wilderness areas (RW's). This conversion would allow the opportunity to enhance public and hunting access by opening roads that are within the boundaries of the Wilderness Areas but have an "easement" that is outside the Wilderness Area. This would prohibit the use of vehicles within the Wilderness Area, but still allow the public to drive on roads to the interior of the Wilderness for hiking, hunting, equestrian use, etc. Public access could also be enhanced by developing parking areas at the ends of roads that terminate at the WA's and on roads that provide access to the interior of WA's. When we pointed out that the Wilderness Area designations would make it impractical to walk into large portions of those areas, it was suggested that we could use horses. While this makes sense for the Bob Marshall Wilderness Area, where outfitters pack in hunters for multi-day hunts, this is totally impractical in Southern California. The primary species we hunt in the National Forests are turkey, quail and deer. Deer hunters typically do one day hunts, and turkey and quail hunters typically do half day hunts. (Note that the average duration of a CNF visit by a hunter is 5 hours according to the usage data compiled by USFS.) There are no outfitters now, nor is it likely there ever will be, who would establish an outfitting business in Southern California to hunt deer, turkey and quail. If the Forest Service did monitor hunting activity as called for in EO 13443, they would find that horses are seldom used for hunting in the Cleveland National Forest. The DSEIS alludes to a "model" that was used to assess IRA's suitable for conversion to RWA's. The criteria do not include "enhancement of hunting opportunities" in their model. This was a missed opportunity to respond to the spirit and intent of EO 13443. We believe that to respond to the EO in good faith, the Forest Service needs to perform another serious analysis of the roads that could specifically have a right-of-way outside the proposed Wilderness Areas and that would provide access to the interior of these WA's. This effort should also include an assessment of parking areas that should be included in the LMP A to enhance access for all public recreational activities. [Environmental Conservation/ Preservation]

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The Forest Service recognized hunting participation as an issue in the SEIS and incorporated the direction of Executive Order (EO) 13443 and companion Federal Lands Hunting, Fishing, and Shooting Sports Roundtable Memorandum of Agreement (MOA). Miles of system roads and trails were used as an assessment indicator. Hunting is regulated by the California Department of Fish and Wildlife. Wilderness and recommended wilderness land use zones would remain open to hunting (as would most areas on the national forests) unless an area is subject to a forest closure. Mechanized and motorized access to hunting opportunities in the inventoried roadless areas analyzed would change in the selected alternative as described in the SEIS. Most existing motorized access (roads and trails) was maintained by road and trail corridors within the roadless areas. Foot and equestrian access would remain unchanged in all alternatives. The quality of the fishing and hunting experience may eventually become higher in the selected alternative because of a potential decrease in relative crowding, harvest, harassment and poaching. Forest visitor use, participation and satisfaction (including that of hunting) are measured by the National Visitor Use Monitoring (NVUM) system. Analysis of the most recent data is summarized in the SEIS project records. The complete reports for the southern California national forests may be viewed and downloaded (individually or combined) from the NVUM web site. The Summary of Issues Considered in the Analysis (Table 2), includes hunting as one of the issues for analysis in the SEIS. The SEIS is not changing the current status of any open road or trail and is not proposing the closing of any existing roads or trails, therefore access via open road or trail to areas would still be open regardless of land use zone designation. This means that all existing roads and trails open to the public that occur within the various land use zones would remain open to the use currently authorized on them. Access for hunting would still be available to the public. Table 3 - Summary of Issues not Considered in the Analysis (SEIS p. 10) further states: The Wilderness Act and designating legislation controls what uses are allowed within designated wilderness. Wilderness is open to hunting (as are most areas on the National Forests) unless the area is subject to a general closure. Table 5 - Comparison of the Land Use Zone alternatives based on the issues (SEIS p 27) shows a comparison of the alternative effects on the issue of hunting: Alt 1 = No change in current use or level of access. Alts 2 and 2a = No change in current use or level of motorized access. Use of mechanized equipment prohibited in RW areas. Alt 3 = Minor change in current level of motorized access. Use of mechanized equipment prohibited in RW areas. The SEIS further analyzes hunting (and fishing) on page 96:There are no changes to hunting or fishing opportunities (which are permitted and regulated by the California Department of Fish and Game) within the southern California

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

national forest inventoried roadless areas addressed in this SEIS. However, hunting is discouraged within the King Creek Research Natural Area located in the Sill Hill Inventoried Roadless Area of the Cleveland National Forest. Recent estimates of these activity participation ranges are shown in the NVUM reports. On SEIS page 137: “A network of low standard Back Country roads provides access for a wide variety of non-motorized dispersed recreation opportunities including camping, hiking, biking, hunting and fishing”. And finally (on SEIS page 233) under Visitor Use, Access, Participation, Satisfaction and Tourism “Visitor use has grown tremendously in the past fifty years and it is projected to continue to grow over time in the southern California national forests. Intense use will continue at many existing sites and areas, and new and additional use will occur at those sites and areas that are now only lightly being used or not used at all. As popular sites and areas fill to their capacity levels more use will shift from the heavier summer season to spring, fall and winter. Use may also shift to off-Forest locations. Visitors will become more diverse and have changing expectations of recreation opportunities. It is expected that currently popular southern California short- term day-use recreation activities, including driving for pleasure, picnicking, hiking, nature viewing and water play, would continue to increase more than traditional backcountry extended-duration activities such as backpacking, dispersed camping and hunting. Motorized back road and off-highway vehicle use as well as (mechanized) mountain biking are projected to remain popular. Visitor participation is expected to vary by alternative depending upon the type of land use zone access and restrictions but total use is not expected to change.” Concern #93 Concern: The Forest Service should provide more facilities and signage on forest lands. Sample Comment #3753-1 - Please consider placing signage around the San Gabriels, Statements: especially at high-impact areas such as Chantry Flat, behind JPL, and at the West Fork in multiple languages, including Mandarin, Vietnamese and Spanish. Anglers don't realize that these areas are no stocked and the fishing has gone from good to zero. See my blog, www.lariverflyfishing.com for reporting. [Individual] Comment #9400-1 - I think they should have more restrooms, and more signs to know where to go. I have an awesome time everytime I go to the mountains I personally think that the nature needs more restroom for other families. [Individual] Response: National Forest facility and signage development and management are addressed at a local forest or ranger district level and are outside the scope of the SEIS.

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Section 8. Comments about wilderness and wild and scenic rivers. Concern #94 Concern: The Forest Service should analyze the effects of placing a roadless area in a land use zone that allows for development. Sample Comment #8876-36 - The DEIS on page 127 states that, “Since planning Statements: decisions do not authorize any ground disturbing activities, the decisions do not have a direct effect on the environment.” This defies common sense. In order for a roadless area to be developed, the US Forest Service (USFS) must first place a roadless area in a land-use zone (LUZ) where development is allowed and then the agency must approve a ground-disturbing activity in that zone. The latter action cannot occur without the former. The impacts of placing a roadless area in a LUZ where development is allowed must therefore be thoroughly studied in all appropriate planning documents. The DEIS offers a more accurate and logical view on page 141 where it states that “…the type of activities that are either prohibited or permitted on national forest system lands as a result of land use zoning do have direct and indirect effects on wildlife and their habitats.” The possibility of subsequent NEPA documents fails to address the impacts of placing IRAs in zones where development and other activities are allowed. The FS must comply with NEPA “at the earliest possible time to insure that planning and decisions reflect environmental values.” 40 C.F.R. § 1501.2. A project-by-project NEPA analysis will not and cannot address the combined and cumulative regional and local environmental impacts of allowing such development to occur in the first place. [Environmental Conservation/ Preservation] Comment #8876-38 - We request that the LMPA discuss and describe the consequences that RW zoning and nonwilderness management will have on the affected IRAs. Specifically, we request that the LMPA examine the direct effects, indirect effects, and cumulative impacts of placing all or part of an IRA in land management zones that allow for types of recreation or land management activities that could result in the roadless area losing its wilderness character over the life of the southern California LMPs. Some of the issues that should be studied, described and discussed for each alternative in the LMPA include: • The risks of reducing water quality in IRAs. • Consequences of and for fire and fuels management in IRAs. • Impacts of insects and disease in IRAs. • Impacts to the size of roadless areas given that there is a positive relationship between size of an area protected from human disturbance and maintenance of biodiversity. • Impacts to IRAs of development at various elevation distributions. • Impacts to terrestrial animal habitat in IRAs, including fragmentation and connectivity, edge effects, habitat suitability and effectiveness, early successional habitat, game species and late-successional habitat. • Impacts to aquatic animal habitat and species in IRAs, including fragmentation and connectivity, water hydrology and stream channel morphology, habitat complexity, water quality, pools, riparian vegetation, introduction of nonnative species and diseases and over-harvest and illegal

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introduction. • Impacts to terrestrial and aquatic plant species in IRAs, including non-native invasives and habitat fragmentation. • Impacts to threatened, endangered, proposed and sensitive species in IRAs. • Impacts to research, monitoring and reference landscapes in IRAs. • Consequences for non-mechanized, mechanized and motorized recreation in IRAs. • Impacts to scenic quality in IRAs. • Consequences to heritage resources in IRAs. • Impacts from IRA development on existing wilderness and the possibility of future wilderness designation. • The impacts every alternative will have on the natural integrity, apparent naturalness, remoteness, solitude, special features, manageability, logical boundaries, and special places or values in roadless areas. [Environmental Conservation/ Preservation] Response: The CEQ regulations at 40 CFR 1508.8 describe the types of “effects” to include: (a) Direct effects, which are caused by the action and occur at the same time and place.(b) Indirect effects, which are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems. Land management plans are programmatic documents. The four plans evaluated in the Draft SEIS provide a framework for integrated resource management while guiding project and activity decision making on the four national forests. Specifically, the land management plan decisions considered in this plan amendment do not require any actions to occur, do not approve any site specific actions, do not change any permits or contracts, do not close any roads, or do not create legal rights or obligations. There are no effects that occur at the same time and place as the plan amendment. Within the context of the CEQ regulations, the plan amendment would not have any direct effects. In contrast, the decisions considered in this plan amendment are designed to change the pattern of land use over time, and therefore could have related effects on air and water and other natural systems. Within the context of the CEQ regulations, any effects associated with the decisions evaluated in the proposed plan amendment would be indirect. The site specific analysis of future developments would occur during project analysis. It is not possible to conduct a site specific analysis of the effects of unknown future projects at the programmatic level. Many of the questions raised in comment 8876-38 can only be answered with site specific analysis that takes into account the design features of a specific proposal, implementation of LMP standards, and other project specific mitigation measures. The analysis at the plan level can consider the general effects of various activities that are allowed by exception, and the Final SEIS has been updated to do that.

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Concern #95 Concern: The Forest Service should consider the effects of allowing development "by exception". Sample Comment 8811-1 - As representatives of the major environmental and land and Statements: water conservation organizations in Santa Barbara, Ventura, San Luis Obispo, and Kern counties, we urge you to select the highest level of protection for many of these areas by zoning them as Recommended Wilderness (“RW”). We share a common concern that the Forest Service’s Preferred Alternative (Alternative 2) does not recommend any new areas as RW, leaving these lands, watersheds, and rare plant and wildlife habitats vulnerable to development. While the Forest Service’s Preferred Alternative (Alternative 2) does increase protections in these areas by zoning them as Back Country Non-Motorized (“BCNM”), the BCNM zoning designation still allows for a significant level of development and resource extraction. According to Tables 60-63 in the Draft Supplemental Environmental Impact Statement (“DSEIS”), the following activities are allowed in areas zoned as BCNM: • Oil and gas development and exploration • Disposal/sale of National Forest System lands • Construction and maintenance of “temporary” roads • Construction of communication towers and facilities • Mining exploration and development • Wind & geothermal energy development • Commercial harvesting of wood & other forest products • Fuelbreak construction using type-conversion with invasive species These development activities are allowed “by exception” in areas zoned as BCNM, but they are expressly prohibited in areas zoned as RW. The DSEIS loosely defines this exception as “Conditions which are not generally compatible with the land use zone but may be appropriate under certain circumstances.” This open-ended definition provides unlimited discretion to approve a host of environmentally harmful activities in these IRAs. These exceptions do not apply to areas zoned RW, and because of this, we believe that the best way to fully protect many of these areas is through a RW zoning designation. More than twenty years have passed since Congress has protected any wilderness lands in the southern Los Padres National Forest. Today, the Forest Service has an opportunity to significantly expand and connect the network of wilderness lands in the forest. A wilderness recommendation is the best tool to preserve wildlife habitat and safeguard watersheds that provide sources of clean water for our farms and communities. Permanently protected open spaces enhance our quality of life, and promote outdoor recreation opportunities that boost local businesses and tourism revenues. Our organizations – along with our more than 10,000 members from throughout the Central Coast – are committed to protecting our region’s watersheds, wildlife habitat, outdoor recreation opportunities, clean air and water, coastline, and open spaces. To this end, we urge the U.S. Forest Service to select the highest level of protection for many of the 16 IRAs in the southern Los Padres National Forest by zoning them as Recommended Wilderness (“RW”). [Environmental Conservation/ Preservation]

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Response: The LMP allows certain activities to occur in the various land use zones "by exception". As noted in comment 8811-1, the LMP defines "by exception" as conditions which are not generally compatible with the land use zone but may be appropriate under certain circumstances. Those circumstances would be evaluated on a case-by-case basis during project level analysis. Until that project level analysis is complete, a "by exception" project is not authorized. The discretion allowed by this approach to zoning is not unlimited. Any project proposed, including a project considered "by exception", has to meet the statutory and regulatory requirements in effect at the time of the decision. For example, any project proposed in an IRA would need to meet the requirements of the Roadless Area Conservation Rule. The prohibition on new road construction or road reconstruction would limit many of the activities listed "by exception" in the Back County Non-Motorized (BCNM) zone because they would not be able to be implemented without roads. Renewable energy projects such as windmills rely heavily on roads for development, and would be infeasible without road access. Any project would also be subject to the requirements of the Endangered Species Act and Clean Water Act, and would be subject to the standards adopted in Parts 2 and 3 of the revised LMPs. Oil and gas development projects are constrained by the stipulations in their lease. The portions of the IRAs that were included in the 2005 Oil and Gas Leasing decision included "no surface occupancy" stipulations in any future leases. While oil and gas development may be suitable in BCNM zones "by exception", no surface occupancy would be allowed within any of the study IRAs. The Final SEIS has been revised to clarify the nature of "by exception" projects. Concern #96 Concern: The Forest Service should identify and analyze new areas for recommended wilderness designation in the supplemental environmental impact statement. Sample Comment #6008-25 - Here's how it can be managed as a viable recommended Statements: wilderness: All 4,102 acres of Cucamonga C IRA should be added to the 6,260 acres recommended in Cucamonga B. There is no reason why Cucamonga Canyon wash should not receive wilderness protection. This would do much to protect the south side of the Cucamonga Wilderness. There is no reason why the Wilderness boundaries should be section lines here. This will also do much to protect sensitive Nelson Bighorn Sheep habitat. As stated on page 304 of Appendix 2, “San Gabriel bighorn sheep are affected by development. There is a need to provide a sanctuary for certain biotic species, including the San Gabriel bighorn sheep.” [Environmental Conservation/ Preservation] Comment #123-1 - I am very disappointed that the Forest Service did not zone any new areas in the Los Padres National Forest as "Recommended Wilderness" in the proposed Forest Plan amendment. This zoning would provide interim protection until the lands are formally designated as wilderness under the 1964 Wilderness Act. As Forest Supervisor you have an obligation to

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protect our wilderness areas. These areas give us open space, clean water, scenic vistas, and outdoor recreation opportunities that preserve the natural environment and enhance our quality of life. Wilderness is our most powerful land conservation tool, and I believe it is vital that we permanently preserve as much of the wilderness remaining in the Los Padres National Forest as possible. Therefore I urge you to recommend new areas for wilderness designation in the Los Padres National Forest. [Individual] Comment #240-1 - Portions of the Upper Kelly Gorge should be included in the plan, for the protection of the old, large oak trees in the riparian area and the amphibians that live there. [Environmental Conservation/ Preservation] Comment #8059-2 - Areas not yet recommend by the Forest Service, such as Red Mountain and Tule, have many of the same virtues as Fish Canyon and Salt Creek, although the Forest Service evaluations of the areas do not reflect this. Tule and Red Mountain very much deserve the agency's reconsideration and recommendation. Westfork --which encompasses the steep, majestic slopes north of 2N24 and south of 2N25 --anchors the viewshed from San Gabriel Wilderness southern peaks and trails. Westfork as Recommend Wilderness would protect the scenic backdrop to fishers, mountain bikers and hikers on 2N25. Westfork deserves the agency's recommendation. [Environmental Conservation/ Preservation] Comment #8059-21 - We ask that the spectacular Condor Peak roadless area be added to the scope of the Plan Amendment, that a new evaluation of the area be conducted, and that the area be recommended as wilderness. [Environmental Conservation/ Preservation] Response: The SEIS considered recommend wilderness zoning in Alternative 3 for all the areas studied, including those areas on the Los Padres and Angeles National Forests mentioned in the comments. The analysis also considered areas outside of the study IRAs such as Condor Peak but eliminated those areas from detailed study as explained in Chapter 2. The Forest Service agrees that Cucamonga C IRA does contain habitat for Region 5 sensitive San Gabriel bighorn sheep (Ovis canadensis nelsoni). The alternatives are consistent with Forest Service Manual direction (FSM 2670.22) which covers the management of sensitive and proposed sensitive species for all funded, executed, or permitted programs and activities. Land use zones regardless of level of designation must still comply with direction (FSM 2670.22) and policy (FSM 2670.32) which states:1. Assist states in achieving their goals for conservation of endemic species.2. Review programs and activities as part of the National Environmental Policy Act of 1969 process through a biological evaluation, to determine their potential effect on sensitive species.3. Avoid or minimize impacts to species whose viability has been identified as a concern.4. Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole. (The line officer, with project approval authority, makes the decision to allow or disallow impact, but the

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decision must not result in loss of species viability or create significant trends toward federal listing.)5. Establish management objectives in cooperation with the states when projects on National Forest System lands may have a significant effect on sensitive species population numbers or distributions. Establish objectives for federal candidate species, in cooperation with the FWS or NOAA Fisheries and the states. While Alternative 3 for Cucamonga C does provide for more RW than Alternative 2 (BCNM), it is important to emphasize that the management of wildlife must still comply with FSM manual regardless of LUZ designation. If or when new projects within the Cucamonga C IRA are proposed, these projects must adhere to this direction and policy, at which time a site-specific NEPA analysis and supporting documentation will be prepared. This Final SEIS does not authorize ground-disturbing activities to occur that would have any effects on San Gabriel bighorn sheep. Concern #97 Concern: The Forest Service should not designate areas as recommended wilderness in the supplemental environmental impact statement because of public health and safety concerns related to law enforcement, criminal activity, and border security. Sample Comment #8550-12 - Hindering Law Enforcement Expansion of Designated Statements: Wilderness limits the ability of law enforcement to patrol lands and stop illegal activities because of restrictions on use of motorized vehicles. Several large marijuana plantations have been documented in Cuyamaca State Park in the past few years, right next door to the Sill Hill IRA. If these areas are added as Recommended Wilderness it will only make it more difficult to law enforcement to access and patrol the areas. Other common issues include poaching, vandalism, rowdy partying (Cedar Creek Falls), and illegal or irresponsible use of motorized vehicles. It is well documented in many cases that criminal activity can increase in areas where public access is hindered. [Individual] Comment #8550-13 - Legal Use as a Deterrent to Illegal Use Fiscal restraint and significant budget cuts facing state and Federal government agencies are limiting the numbers of law enforcement available to patrol our public lands. This makes the role of the law-abiding public as the “eyes and ears” of law enforcement critical in monitoring the well-being of our natural areas. The very presence of the public discourages illegal activities. Restrictions on access that accompany a Wilderness Designation will keep out many law-abiding citizens. However, those intent on criminal activities will pay no mind to Wilderness boundaries. Therefore, expansion of designated Wilderness will make it more difficult to control illegal activities. [Individual] Comment #8550-14 - Securing our Borders In Southern San Diego County, many of the Proposed Recommended Wilderness are in close proximity to the USA/Mexico border. These areas are well within the area which US Border

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Patrol is active in carrying out its responsibilities. The ability of US Border Patrol to conduct its operations would also be hindered by expansion of Designated Wilderness, which has serious implications to National Security. The prevalence of illegal immigration and drug smuggling north-bound, and illegal smuggling of drug profits and weapons to Mexico would only be aided by expanding Wilderness and the resulting hindrance on operations of the US Border Patrol. [Individual] Response: The Draft and Final SEIS describe the current Law Enforcement situation in Chapter 3 and evaluate the effects of the alternatives on law enforcement and border security in Chapter 4. As noted in the comments, the remote and rugged terrain is difficult to patrol, and roads play a key role in patrol efforts. Alternatives 2 and 2a maintain the existing road system in land use zones where roads are suitable. Alternative 3 would affect access on the Cedar Creek and Eagle Peak roads, as noted in the Law Enforcement analysis section of Chapter 4, this would have an impact on law enforcement in the Eagle Peak area. Concern #98 Concern: The Forest Service should not designate areas as recommended wilderness in the supplemental environmental impact statement because of socioeconomic impacts. Sample Comment #8550-15 - Economic Effects of Wilderness By limiting people’s Statements: access to back-country areas by designating additional Wilderness, there will be repercussions to the Southern California economy. We have some special natural places here, which many people would no longer be able to use. As a result, they would spend their vacation dollars elsewhere. This would impact all sorts of businesses such as restaurants, hospitality, gas stations, repair shops, bike shops, and outdoor gear stores. Less spending, fewer jobs, and less tax revenue for all levels of government would result. A mountain biker typically spends $2,000 to $4,000 on a bike, and many buy a new bike every year or every second year, along with a constant supply of replacement parts, tires, and riding clothing. Limiting our access to riding areas with expanded Wilderness would mean we either ride less, or ride elsewhere, and spend our money elsewhere. I have read comments that Wilderness Designation would draw in more visitors; however, I have hiked in many Wilderness areas, and unless you are in the Sierras most of them do not see a lot of use. Hikers and horses can access them now without Wilderness designation than they could as Designated Wilderness, so I do not see any economic benefit to Wilderness aside from having to print new maps. [Individual] Comment #8550-20 - How do you justify the economic effect of additions to Wilderness when only a small number of current users will have access to newly designated Wilderness? Those who no longer have access take their vacations elsewhere, and will spend money on gear and equipment for their hobbies elsewhere. [Individual]

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Comment #8626-5 - There will be a large cost for managing more wilderness and/or Backcountry non-motorized land [Recreational (incl. permittees)] Response: The beneficial economic impact of motorized recreation was one of the issues raised during scoping. The analysis does not predict any economic impacts from recommended wilderness designations because motorized users will continue to have access to the existing road system. With no change in motorized access, the level of use of the national forests would remain at current levels, and users will continue to enjoy the areas open to motorized use. There will be some impact to mountain bike users under RW zoning, however, Alternatives 2 and 2a maintain mountain bike access in the areas that support mountain bike use. Concern #99 Concern: The Forest Service should not designate areas as recommended wilderness in the supplemental environmental impact statement because of increased fire risk. Sample Comment #8550-11 - We have had several significant fires in the San Diego Statements: back country in the last decade. The Proposed Recommended Wilderness in the San Diego Country IRA’s will significantly increase the risk of catastrophic fires occurring which can char vast areas of wild lands and have the potential to reach far into urban areas. The main issue here is that a Wilderness Designation would limit the ability of USFS to mitigate fire risk using mechanical equipment to reduce brush, build fire breaks, create and maintain a network of fire access roads, and to monitor its lands. The ability to mitigate fire danger is even more important with the Sunrise Powerlink being built by SDGE through the San Diego backcountry. This is of huge concern to everyone in Southern California, and will concern will only become greater should extended periods of drought persist. [Individual] Comment #9366-4 - In the mid-1980's and again in 2006, lightning-caused wildfires spread from USFS land on Blue Ridge onto our private property. The Kern County Fire Department used bulldozers, helicopter water air drops and hand crews from the county and Forest Service to attempt to suppress the fire. The established road on our permit that also traverses our property and that we maintain, successfully helped to stop the progression of these fires, confining the wildfires to grassland fires before they became major forest fires. The road as a firebreak saved us and other taxpayers from further financial loss and eliminated the risk to firefighters' safety. To enable firefighters to effectively suppress a wildfire Whenever a wildfire has occurred in the permit area, Kern County and USFS firefighters have extensively used the established roads, our private roads and the Forest Service roads, for bulldozers and transporting the hand crews to the location. This capability to quickly and efficiently access the fire line is essential to stop major disaster. Roadless/ motorless designations restrict wide-scale fire suppression activities and diminish the likelihood of an aggressive response from fire fighters when a wildfire occurs, a situation that is alarming to neighbors. [Individual]

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Response: The forest plans address fire management using five strategies (Fire 1 through 5) which include approaches for fire prevention, direct community protection, fire suppression, firefighter and public safety, and indirect community protection. The proposed changes in land use zones do not change the overall approach for fire management. Alternatives 2 and 2a maintain the Developed Area Interface (DAI) areas in the roadless areas around communities and adjacent to proposed RW areas. Alternatives 2 and 2a maintain access along all existing open Forest Service roads, and only one to three miles of permitted road would be included in RW (Tables 104 and 107 in the Final SEIS). Although 10 miles of fuelbreaks are included in RW, the forest plan does allow fuel break maintenance in RW by exception (Table 62).Given the lack of change to the fire management situation, the Wildfire and Community Protection analysis in Chapter 4 of the FEIS does not conclude that the risk of large catastrophic fires would increase with RW land use zone designations. The analysis does recognize that there is a substantial risk for large scale fires throughout southern California, and that large fires are going to occur in the future. The plan strategy to focus on direct and indirect community protection is designed to mitigate that overall risk. Concern #100 Concern: The Forest Service should eliminate specific areas from recommended wilderness designation in the supplemental environmental impact statement. Sample Comment #129-2 - I don't believe the West Fork of the San Gabriel River Statements: should be designated as wilderness. There is already development there. [Individual] Response: The West Fork IRA is not proposed for RW in Alternatives 2 or 2a, but is proposed for RW in Alternative 3. This range of alternatives and associated analysis provides the decision maker the information needed to make an informed decision. Concern #101 Concern: The Forest Service should clarify how inventoried roadless areas were evaluated and land use zone allocations were determined in the supplemental environmental impact statement. Sample Comment #8878-19 - On a general note, it is difficult for the public to Statements: determine why certain land use zones were selected for certain areas of IRAs in each alternative. Why, for example, is there a second corridor zoned BCNM near the crest of Cuyama Peak in the Cuyama IRA? Why are certain areas on the perimeter of the Fox Mountain IRA zoned BC? The IRA Analysis should contain brief explanations for any portions of IRAs that receive different land use zone allocations than the predominant land use zone, so that the public can gain a better understanding of the Forest Service’s justification for selecting certain land use zones. [Environmental Conservation/ Preservation]

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Comment #1467-4 - Why is area 2 held differently from area 1 and 16? 2 was a runway at one time but if 1 and 16 are being called roaded restricted but 2 is unroaded this is really backward. 2 should be part of the recommended wilderness areas as it is totally connected with the other areas. [Environmental Conservation/ Preservation] Comment #8878-20 - we recommend that the IRA Analysis contain a scoring system so that the public can gain a better understanding of how the wilderness capability, suitability, and need criteria are weighed to guide the agency’s decision on whether to recommend an area for wilderness protection. While the IRA Analysis contains a fairly comprehensive evaluation of each IRA’s wilderness criteria, it is difficult to determine how the Forest Service weighs all of the various items mentioned in a given IRA’s evaluation. Perhaps some sort of scoring system would enable the agency, decision-makers, and the public to better understand how the IRA Analysis is applied in the decision-making process. [Environmental Conservation/ Preservation] Response: The southern California national forests applied standard agency guidance as described in Forest Service Handbook (FSH) 1909.12, Chapter 70 - Wilderness Evaluation for the inventoried roadless areas in the SEIS. This included a review and evaluation of capability, availability and need as documented in Appendix 2. Summaries of the inventoried roadless area rationale will be included in the Draft ROD when it is released. Additional documentation, including various scoring systems, was not developed as they were not thought to be useful or appropriate for this analysis. The alternative design is explained in Chapter 2 in the description of the alternatives. The existing zoning was maintained in areas with roads, fuel breaks, or other improvements that are not compatible with BCNM or RW zoning. For example, all the alternatives maintained a BC corridor along the road to the Cuyama Peak fire lookout in the Los Padres National Forest. The nationally designated IRA boundary attempted to exclude this area from the IRA, but unfortunately the mapping missed the actual road location. The Final EIS [for the revised LMP] included a scoring system in the Wilderness Evaluations, and the IDT considered a more detailed scoring matrix early in this SEIS process. While scoring systems can be useful, they are often criticized for being subjective. The Responsible Official will use the updated IRA evaluations and the effects analysis in the Final SEIS to support any recommended wilderness decisions (see Chapter 70 of FSH 1909.12). Concern #102 Concern: The Forest Service should revise their evaluation of inventoried roadless areas to more fully consider scientific, educational, and wilderness values or unique landscape characteristics. Sample Comment #8878-16 - The IRA Analysis focuses primarily on tangible Statements: wilderness values, such as views, a sense of solitude, recreation opportunities, and natural resource protection. In revising the analysis and preparing the SEIS,

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the Forest Service should also consider that wilderness carries “significant intangible values that are difficult to quantify, including values for an appreciation of open spaces and natural beauty; for nature’s healing to the human imagination and spirit; for solitude, serenity, and spiritual renewal; and simply for the knowledge that wild places are wild and will remain that way forever.” U.S. Forest Service, 2005 at 510. [Environmental Conservation/ Preservation] Comment #6008-6 - The area’s capability is rated as low for four reasons: (1) Sights and sounds issues as described above; (2) No unique scientific or education values are found there; (3) It offers moderate to low opportunities for challenge and adventure, and (4) “there are some improvements within the unit.” The statement that there is no known scientific or education values is quite false. Deep Canyon is the primary stream (1.56 miles) in this unit. We agree with your statement on page 287: “While the location of Pan-ox-su remains uncertain, Yellow Body (a figure in Cahuilla mythology) and his travels remain an important part of Cahuilla history and Deep Canyon is connected to his story. Numerous archaeological sites have been recorded in this canyon. The narrative also states under “Special Features” that “Other prehistoric properties located in the area represent unique classes of sites which merit further investigations.” [Environmental Conservation/ Preservation] Comment #6008-15[Sample Statement] I would like to also challenge the statement on page 298 of Appendix 2: “Much of the Front Country Ranger District non-wilderness land encompasses similar landscapes and opportunities.” The Cucamonga B IRA is one of the most outstanding wildlands in Southern California. As one traveled once up the North Fork of Lytle Creek to explore the Cold Creek area, I could have sworn that I was hundreds of miles from civilization. Wildlife abounded the further I traveled from the Lytle Creek community. [Environmental Conservation/ Preservation] Response: The Forest Service fully considered inventoried roadless area scientific, educational and intangible wilderness values as well as unique landscapes. All comments received from the public that included identification of factual errors have been reviewed and addressed through specific edits (if any) to the inventoried roadless areas in the SEIS Appendix 2. None of those edits resulted in changes to the affected environment of environmental consequence in the SEIS itself. Many other comments reflected opinions and philosophical differences with Forest Service discussion, analysis and recommendation. Concern #103 Concern: The Forest Service should revise their evaluation of inventoried roadless areas to more fully consider their fire suppression value and ability to limit noxious weeds. Sample Comment #8878-13 - The analyses for several IRAs frown upon wilderness Statements: designation because it “could limit the ability to treat noxious weed infestations that are an ever increasing threat, particularly from 20 fire suppression and

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recreational vehicles, but also from other vectors such as wildlife and wind movement.” IRA Analysis at 140. The Forest Service should clarify whether these infestations are in disturbed areas along roads and near developed areas, which would generally not be included in any reasonable RW zone allocation. Typically, the areas most suitable for RW zone allocations – remote areas far from roads and development – have low risk of noxious weed infestations. If there are particular areas of concern for noxious weeds, the SEIS should identify these locations and consider boundary adjustments as appropriate. However, also note that the Wilderness Act and the Forest Service’s Wilderness Management Handbook allow for (and even promote) efforts to eradicate noxious weeds from wilderness areas. [Environmental Conservation/ Preservation] Comment #6008-35 - Here's why your arguments against the area in the forest plan were wrong: The IRA’s availability is rated as low and moderate in part because “…fast, aggressive initial attacks on wildfires in this area…will be more difficult if the unit is designated as wilderness.” This flies in the face of Forest Service policy and history. Over the years the Forest Service has done a truly outstanding job of both protecting communities and wilderness resources while managing wildfires. This fundamental truth is ironically states emphatically in the FEIS in Vol. 2 (Appendices), page 595: “The notion that wilderness designation makes fire suppression more difficult and restrictive is not based on fact. All roadless areas (including designated wilderness) are difficult to suppress fires within because of our inability to drive there to put the fire out with fire engines. The current protocol to obtain permission to use mechanized equipment to suppress wilderness fires is not a time consuming process or significant barrier to fire suppression efficiency. The encumbrances firefighters encounter in fighting wilderness fires are the same logistical challenges they face in any firefighting situation without road access.” It is not enough to make general, completely unsupported statements in the EIS. This does not constitute the “hard look” at issues required by NEPA. The area’s availability rating would have been higher had it been given a fair and proper assessment. [Environmental Conservation/ Preservation] Response: The Forest Service fully considered inventoried roadless area fire suppression values. All comments received from the public that included identification of factual errors have been reviewed and addressed through specific edits (if any) to the inventoried roadless areas in the SEIS Appendix 2. None of those edits resulted in changes to the affected environment of environmental consequence in the SEIS itself. Many other comments reflected opinions and philosophical differences with Forest Service discussion, analysis and recommendation. Wilderness evaluation of the roadless inventory of the Forests, as well as of other undeveloped area proposed by the public, is based on a number of different criteria, including capability, availability, and need. Capability: The capability of potential wilderness is the degree to which it contains the basic characteristics that qualify it for wilderness designation. Factors examined include environment and special features, challenge, outdoor

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recreation opportunities, and manageability. Availability: An area's availability is determined by comparing wilderness values in that location to the value of and need for other resource uses and production from the same land area. Need: The need for designation of new wilderness is based on comparing the value of a potential area to existing wilderness in nearby locations as well as to the National Wilderness Preservation System as a whole. This analysis considers demand for additional wilderness recreation opportunities on the forest. It also looks at the need to give certain vegetation types the protection that wilderness designation would afford. The wilderness evaluation assessment is not solely based on the management of invasive species. The management of invasive species falls under the factor of environment as part of the Capability criteria. The SEIS addresses the changes in LUZ designation and the effects on the management of invasive species is discussed starting on page 210 and summarized in Table 79. The two issues related to non-native species management are related directly to how changes in Land Use Zones could influence the introduction and spread of non-native species and whether the available control methods would vary by LUZs. SEIS Table 78 summarizes the mapped known occurrences of invasive species by LUZ for each alternative. SEIS Table 79 summarizes the potential effects in terms of introduction, establishment, spread, and management of non-native plants and animals for each Alternative. The risk for the potential introduction, establishment and spread of non-native plants and animals may be highest under Alternative 1 (No Action). This risk is due to the greatest amount of motorized and mechanized access, and the least potential to prioritize, decommission and restore the 188 miles of unauthorized routes within the IRAs. There is also higher risk that some nonnative animals would be attracted to the edge effect along these routes and that potential disturbance from other suitable uses could promote conditions for nonnative plant and animals to persist. This risk is highest in this alternative due to the types and acreages of suitable uses that would be allowed within the current land use zones. The risks may be lower in Alternatives 2/2a due to the potential for a slightly lower number of roads/trails available for mechanical (i.e., mountain bikes) and motorized vehicles and reduced acreage for suitable uses within land use zones and recommended wilderness. Risks would be lowest in Alternative 3 due the highest acres of RW having the fewest miles available for mountain biking and the fewest acres available for suitable uses. Risk would also be reduced in Alternatives 2, 2a, and 3 as more priority is placed on the decommissioning and restoration of unauthorized roads within BCNM LUZ and RW respectively.

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Concern #104 Concern: The Forest Service should revise their evaluation of inventoried roadless areas to more fully consider watershed condition, water infrastructure, and availability for timber production. Sample Comment #8878-14 - The IRA Analysis recognizes the high-quality streams Statements: and washes found in roadless areas, but then implies that it is useless to offer these areas any sort of additional protection because water quality downstream – outside of the IRA, and in some cases, even outside of the forest – is diminished by neighboring land uses. For example, the Fox Mountain analysis states: The headwaters of the watersheds within this unit are in good functioning condition and water quality is subsequently good from Forest Service lands. The lower parts of the watersheds are private lands that are heavily grazed with subsequent impacts to water quality. Streams from a series of canyons are intermittent and flow to the Cuyama River which eventually confluences with the Santa Maria River and provides municipal water to several communities. There would be little likelihood of improving water quality by restricting access to this unit and would only serve to limit management options in event of fire. IRA Analysis at 179. Even if water quality is degraded in downstream segments located outside of the IRA, there are still overall benefits to the watershed by preserving the upper headwaters as wilderness – namely, the reduction in cumulative impacts. The SEIS should consider a recent study by The Wilderness Society showing a relationship between healthy watersheds and protected lands in the National Forest System. The authors of this report used GIS technology to study the overlap between three categories of watershed conditions (properly functioning, at risk, and impaired) and three types of national forest land designations (Wilderness, Roadless, and all other national forest lands). The results at a national scale show a striking association between watershed health and land protection (i.e. “water loves wilderness”).7 7 The full report is available at http://wilderness.org/files/Watershed-Health-in- Wilderness.pdf The Forest Service also attempts to claim that wilderness designation would preclude vehicular access into IRAs to manage water quality: 21 As a whole, these watersheds show poor flow characteristics due to channel disturbance. The overall rating for Cuyama is Class 2, functioning at risk. The potential for water quality improvement through channel improvements is good in this unit although access into the area to manage water quality would be influenced by the ultimate zoning designation. IRA Analysis at 152. Please explain why motorized access is necessary to manage water quality. Also, the cause of the “channel disturbance” is unclear and should be clarified as well. [Environmental Conservation/ Preservation] Comment #8878-17 - Many of the IRAs contain water developments such as springs, pipelines and accompanying access roads. The IRA Analysis should acknowledge that these are acceptable uses in wilderness in accordance with the Forest Service’s Wilderness Management Handbook § 2323.43(d). [Environmental Conservation/ Preservation]

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Comment #8878-18 - For each IRA, the IRA Analysis determines the availability of the area for timber production and forest products. This information is then used to help determine whether an area is available for wilderness designation. Unfortunately, the IRA Analysis is inconsistent (and at times even nonsensical) in how it evaluates an area’s availability for timber production. For example, the analysis for Fox Mountain states that “[n]o timber products are available within this unit.” IRA Analysis at 182. However, for the Juncal IRA, the IRA Analysis contains an elaborate discussion on the area’s potential for producing timber and other forest products, even though the area in fact has little potential to produce such products. Specifically, the evaluation for the Juncal IRA states: Timber products, such as firewood or mulch, may be created by thinning activities designed to improve the health of the vegetation. Downed logs and snags provide diversity of wildlife habitat. These products and services are needed to enhance the forested environment and move it towards the condition where it has the capacity for renewal and recovery from a wide range of disturbances. 23 IRA Analysis at 197. Similar language is used in the IRA Analysis for Black Mountain (148), Cuyama (156), Diablo (165), Dry Lakes (173), Garcia (190), Madulce-Buckhorn (214), Quatal (221), Sespe- Frazier (255), Tequepis (271), White Ledge (279) – but for no other IRAs outside of the Los Padres National Forest. The only timber in this area is inaccessible and has little or no commercial value. If this statement is retained in the IRA Analysis, the Forest Service should explain whether specific thinning activities are proposed in this area (or whether these thinning activities purely speculative, in which case they should not be included in this evaluation). Furthermore, the Forest Service should share any data it has showing that the “forested environment” in this area needs to be enhanced, and why it does not currently have the capacity for “renewal and recovery from a wide range of disturbances.” Id. More accurately, these IRA evaluations should contain the same language as the Fox Mountain IRA described above: “No timber products are available in this unit.” [Environmental Conservation/ Preservation] Response: The SEIS states that changing land use zoning classification to RW would generally improve watershed condition, which is a broader measure than water quality. The watershed assessment of effects is based on the Watershed Condition Classification, which relies on an understanding that only certain indicators are affected by land use designations. They are Aquatic Habitat (habitat fragmentation, large woody debris, channel shape and function), Riparian Vegetation, Roads and Trails (Open Road Density, Road Maintenance, Proximity of Routes to Water), and Soil Erosion. One of the reasons that IRAs and RW have better watershed condition is that road density can affect fragmentation, proximity to water, channel shape, and road maintenance; thus reduced road density positively affects watershed condition. As part of the assessment, each indicator is rated as either GOOD (the watershed is functioning properly [between 75-100% of undisturbed, depending on indicator] with respect to that attribute), FAIR (the watershed is functioning

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at risk [between 25-90% of undisturbed, depending on indicator] with respect to that attribute), or POOR (the watershed is impaired or functioning at unacceptable risk [from <25% to <90% of natural, depending on indicator] with respect to that attribute). The large range encompassing a FAIR rating generally indicates that moving to a GOOD condition will take a substantial change in land management and restoration activities. For example, the Cuyama IRA crosses four HUC 6 watersheds, two of which are Condition Class 1 (Burges Canyon-Cuyama River and Rancho Nuevo Creek) and two of which are in Condition Class 2 (Santa Barbara Canyon and Deer Park Canyon-Cuyama River). The two watersheds currently in Condition Class 2 have been assessed to move to Condition Class 1 if this area is classified as an RW land use zone in Alternative 3. Some IRAs contain existing water development infrastructure, including springs and pipelines, that are authorized under special use permit or right for range, wildlife and watershed purposes. The Forest Service recognizes the existence of these water developments as well as their need for maintenance and repair if an IRA is classified as an RW land use zone. FSM 2323.43(d) provides guidance and direction for servicing water development features in wilderness including the use of motorized equipment and mechanized transportation if appropriate. The Forest Supervisor can authorize routine maintenance. SEIS inventoried roadless area evaluations have been reviewed and the Timber discussion in the Availability section has been revised to clarify forest management intent and to make it consistent across the four southern California national forests. Concern #105 Concern: The Forest Service should revise their evaluation of inventoried roadless areas to include an assessment of cross-county and future recreation needs and opportunities. Sample Comment #6008-7 - As for issue number three, we fail to see why one cannot Statements: find opportunities for challenge and adventure in a 3,101 acre and 4.8 square mile area of roadless land adjacent to a large designated wilderness. The FS fails to offer any real evidence to the contrary. It is not enough to make general, completely unsupported statements in an EIS. This does not constitute the “hard look” at issues required by NEPA. The capability rating for this area would have been higher had it been given a fair and appropriate evaluation. Neither the public, nor the Regional Forester can make informed decisions about roadless areas based on an incomplete analysis. The FEIS and ROD thus fail to meet the standards set forth in the NEPA, 40 CFR Part 1500.2 (3) and Part 1500.1 (b) which require the federal government to ensure “that environmental information is available to public officials and citizens before decisions are made and before actions are taken,” and that the information provided to public officials and citizens “must be of high quality.” [Environmental Conservation/ Preservation]

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Comment #8878-12 - The narrative for several IRAs overlooks opportunities for cross-country adventure, claiming that areas are too steep, or vegetation is too dense. However, nearly every IRA contains a variety of steep and gentle slopes, and a wide variety of vegetation that includes not only dense chaparral but also open grasslands and sagebrush, as well as oak woodlands and savannahs that are easily traversed. In lieu of blanket statements, the SEIS should take a hard look at each area’s potential to offer cross-country recreation opportunities. [Environmental Conservation/ Preservation] Response: The Forest Service fully considered inventoried roadless area cross-country and future recreation needs. All comments received from the public that included identification of factual errors have been reviewed and addressed through specific edits (if any) to the inventoried roadless areas in the SEIS Appendix 2. None of those edits resulted in changes to the affected environment of environmental consequence in the SEIS itself. Many other comments reflected opinions and philosophical differences with Forest Service discussion, analysis and recommendation. Concern #106 Concern: The Forest Service should revise their evaluation of inventoried roadless areas based on a complete listing and assessment of special-status and migratory bird species. Sample Comment #8878-9 - Allocating RW land use zones through the LMP Statements: amendment process can serve as an important tool to promote the conservation of global bird species. As such, the IRA Analysis should evaluate the importance of each IRA on the Los Padres National Forest for bird conservation, and identify any special-status bird species that may occur in each area. Special-status bird species are those listed as California Bird Species of Special Concern by the California Department of Fish & Game, as Birds of Conservation Concern by FWS, as Birds of Management Concern by FWS, and those species that appear on the United States WatchList, a joint project between American Bird Conservancy and the National Audubon Society. Including bird conservation in this analysis will help the Forest Service prepare a complete and fully-informed SEIS, and will also help the agency achieve compliance with the Memorandum of Understanding (“MOU”) Between the U.S. Department of Agriculture, Forest Service and the U.S. Fish & Wildlife Service to Promote the Conservation of Migratory Birds. That MOU requires the Forest Service, in part, to: Address the conservation of migratory bird habitat and populations when developing, amending, or revising management plans for national forests and grasslands, consistent with NFMA, ESA, and other authorities listed above. When developing the list of species to be considered in the planning process, consult the current FWS Birds of Conservation Concern (updated 2002 and available at www.fws.gov/migratorybirds/reports/BCC2002.pdf), State lists, and comprehensive planning efforts for migratory birds (see Definitions for a list of comprehensive plans). Evaluate and consider management objectives and

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recommendations from conservation planning efforts for migratory birds. Acknowledge special designations that may apply to all or part of the planning area, such as Globally Important Bird Areas in the United States, and acknowledge such designations in the appropriate plan documents. MOU at 6. [Environmental Conservation/ Preservation] Comment #8878-10 - The DSEIS and IRA Analysis identify certain endangered, threatened, sensitive, and other special-status plant and animal species that are known to occur in that particular area. The presence of these species weighs in favor of an area’s suitability for wilderness designation. Therefore, it is important for the IRA Analysis and the SEIS to contain a full and complete listing of all special-status species for each IRA. However, many (if not most) of the IRA evaluations contain incomplete special-status species listings. Species that are known or likely to occur in a 18 particular IRA are not listed in the area’s wilderness evaluation, meaning that the evaluation is not taking all of the potential wilderness values of a particular area into account. Special-status species may be overlooked in IRA evaluations because the areas have not been thoroughly surveyed. However, the IRA Analysis should not assume that a species is absent just because it was not detected in whatever limited surveys have been done in a particular area. Rather, the IRA Analysis should evaluate whether suitable habitat is or may be present in a particular IRA, and should assume occupancy in suitable habitat until surveys are conducted to protocol. The IRA Analysis and SEIS should also examine sources like the California Natural Diversity Database (CNDDB), the Consortium of California Herbaria, and the species lists from neighboring land reserves. Specifically, the Wind Wolves Preserve and the Bitter Creek National Wildlife Refuge both have fairly extensive lists of special-status plant and animal species that occur within their respective boundaries. Certain species that occur in these areas may also be presumed to occur in similar habitats in neighboring IRAs. [Environmental Conservation/ Preservation] Comment #1449-11 - The Inventoried Roadless Area Analysis for the Antimony IRA contains the following statement: One sensitive plant to have been found in this unit is a small population of Imperata [sic] Layia heterotricha (pale-yellow layia). There are no threatened or endangered plant species or their habitats within Antimony. A population of Allium howellii var. clokeyi, a Forest Service Sensitive plant species, occurs in this unit on Trail 118. I reported the presence of this population to the Forest Service in 2012; photographs showing diagnostic taxonomic features were also provided. At least two other rare plants have been observed on the Wind Wolves Preserve, which is immediately adjacent to this IRA (Eriophyllum lanatum var. hallii and Mimulus pictus). There is abundant suitable habitat for these, and possibly other rare taxa to occur in this IRA. The extent of focused surveys conducted in this IRA, if any, is unknown. The discussion for the Antimony IRA does not contain any mention of a vernal pool that occurs within this IRA along Cerro Noroeste Road. Many voucher specimens of Downingia bella, a plant that is an indicator species of vernal pools, have been collected from this pool. Although

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no rare plants have been documented in this pool, to my knowledge no focused surveys have been conducted here, either for rare plants or for rare invertebrates that may also be present. The Antimony IRA also provides an important link between Bitter Creek National Wildlife Refuge, the Wind Wolves Preserve, and other areas of the Los Padres National Forest. For this reason, and because there is a high potential for rare plants to occur that may be threatened by various activities, this IRA should be considered as a recommended wilderness area. [Individual] Comment #6008-9 - The narrative offers a series of “not applicable” statements regarding plants and animals, including the southwestern willow flycatcher that occurs in the area. The narrative failed to explain how plants and animals will be affected by the fact that 3,108 acres are in BCNM zones (where communication site construction, commercial logging, fuelbreak construction, “temporary” road construction, energy development, mechanized vehicle use are allowed.) The use of short, generic, and utterly unsupported reassurances about the future wellbeing of plants and animals in the face of the severe development threat posed by the zoning schemes described above does not under any circumstances constitute a complete and fair analysis. The need rating for the area would have been higher had it been given a fair and appropriate evaluation. Neither the public, nor the Regional Forester can make informed decisions regarding roadless areas when the FEIS and ROD fail to meet the standards set for in NEPA. [Environmental Conservation/ Preservation] Response: Management of special-status species is part of the evaluation of inventoried roadless areas for wilderness recommendation. Wildlife and plant species and their habitats are considered as part of the special features criteria under Capability criteria. SEIS Table 2 for TESP species states: "The IRAs provide habitat to a wide range of Threatened, Endangered, Proposed, Candidate, Sensitive (TEPCS or TES) plant and animal species. LMP standards and consultation with the Fish and Wildlife Service and the National Marine Fisheries Service protect these species and habitat when projects are implemented. Changes in LUZ allocations influence the types and intensity of projects that may occur in the future. Increasing the area allocated to more restrictive LUZs could improve species habitat." Listing of special-status and migratory bird species does not directly influence the wilderness evaluation. But the recommendation of wilderness does provide more restriction on the types of use that may occur and thus more indirect protection for these species and habitats. The LMP FEIS still provides the standards and guidelines for the protection of wildlife and plant species, regardless of LUZ. In addition, the lists for special-status species (including Forest Service Sensitive Species) may change from year to year depending on new information on population or habitat trends. For example, in the last decade the bald eagle was de-listed under the Endangered Species Act and is now considered as Forest Service Sensitive Species.

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Concern #107 Concern: The Forest Service should not make recommended wilderness determinations based on sight and sound criteria. Sample Comment #6008-5 - Here's why your arguments against the area in the forest Statements: plan were wrong. 1) One of the reasons given for the area’s low capability rating is that “View of, and sounds from Highway 74 are evident at times and from certain vantage points (page 283, IRA Analysis).” Not only is this criticism inappropriate, but it is important to note that some portions of the roadless area are over 2.5 miles away from these features. The capability rating for this area would have been higher had it been given a fair and appropriate evaluation. Neither the public, nor the Regional Forester can make informed decisions regarding roadless areas when the FEIS and ROD fail to meet the standards set forth in NEPA, 40 CFR Part 1500.2 (e) and Part 1500.1 (b) which require the federal government to ensure “that environmental information is available to public officials and citizens before decisions are made and before actions are taken,” and that the information provided to public officials and citizens “must be of high quality.” [Environmental Conservation/ Preservation] Comment #8059-20 - One of the oddities of the Forest Service Inventoried Roadless evaluation is its claims that "the presence of man is strongly evidenced by transmission lines and electronic sites on the boundary perimeter." The Condor Peak proposed wilderness area is actually remarkable for its lack of trammeling or human influence given its relative proximity to foothill communities. None of the "trammeling" mentioned in the analysis is actually in the proposed Condor Peak wilderness area except for the historic Tom Lucas Trail Camp which can correctly be seen as a wilderness amenity that featured, pre-Station Fire, the welcome shade of oak trees, a stream and picnic tables. The Forest Service's negative conclusion about the wilderness character of the Condor Peak area relied on features outside the area itself, features not visible in most of the proposed wilderness area, and upon "sights and sounds" criteria rather than an area's actual undeveloped character. In so doing the Forest Service acted contrary to long-standing direction from Congress to avoid using sights, sounds and other external influences to judge an area' s wilderness quality .The eastern boundary of the proposed wilderness area is JN27 and the 500kV transmission line that runs along it. The transmission line is not visible from most of the trails within the proposed wilderness area due to the area' s topography. The power lines are visible in the distance from an easterly section of the Condor Peak Trail --if you look down a thousand feet rather than out at scenic Josephine Peak. The power lines in no way detract from the beauty and tranquility of the Condor Peak area itself. [Environmental Conservation/ Preservation] Comment #8878-15 - In evaluating an area’s wilderness capability and availability, the IRA Analysis largely relies upon external “sights and sounds” criteria, rather than an IRA’s internal undeveloped character, to decide whether or not IRAs should be recommended for wilderness designation. This is

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contrary to long-standing direction from Congress to avoid using sights, sounds and other external influences to judge an area’s wilderness quality. During Subcommittee Hearings for the 1978 Endangered American Wilderness Act, Congress found that: many areas…received lower wilderness quality ratings because the Forest Service implemented a “sights and sounds” doctrine which subtracted points in areas where the sights and sounds of nearby cities (often many miles away) could be perceived from anywhere within the area. This eliminated many areas near population centers and has denied a potential nearby high quality wilderness experience to many metropolitan residents, and is inconsistent with Congress’ goal of creating parks and locating wilderness areas in close proximity to population centers. The committee is therefore in emphatic support of the Administration’s decision to immediately discontinue this “sights and sounds” doctrine.8 8 House Report 95-540, 95th Congress, July 27, 1977, page 5. 9 Subcommittee on Parks and Recreation of the Committee on Energy and Natural Resources, United States Senate on S. 1180, September 19 & 20, 1977, Publication No. 95-88, Committee on Energy and Natural Resources, page 41. During Senate hearings on the Endangered American Wilderness Act, Dr. M. Rupert Cutler, the Assistant Secretary of Agriculture, assured Senator Pete Domenici (R-NM) that “…there is no reference in the Wilderness Act to criteria for wilderness that includes such things as the sights, sounds, and smells of civilization which is a set of criteria which has been misapplied to wilderness areas.”9 If Congress adopted what seems to be the Forest Service’s criterion, nearly all of the designated wilderness areas in southern California would never have been formally protected as 22 wilderness in the first place. Indeed, some of the jewels of the National Wilderness Preservation System in the southern Sierra and elsewhere have “sights and sounds” issues yet still contain strong wilderness characteristics. [Environmental Conservation/ Preservation] Response: The Forest Service fully considered inventoried roadless area sight and sound issues. Minor intrusions of sight and sound quality did not automatically rule a roadless area out of consideration as a recommended wilderness. All comments received from the public that included identification of factual errors have been reviewed and addressed through specific edits (if any) to the inventoried roadless areas in the SEIS Appendix 2. None of those edits resulted in changes to the affected environment or environmental consequence in the SEIS itself. Many other comments reflected opinions and philosophical differences with Forest Service discussion, analysis and recommendation. Only those roadless areas identified in the Settlement Agreement were analyzed for potential recommended wilderness land use zoning. Other roadless areas, including Condor Peak in the Angeles National Forest, are therefore outside of the scope of the SEIS. Identification and analysis of new areas for possible recommendation as wilderness would be a future forest-level decision.

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Concern #109 Concern: The Forest Service should justify recommended wilderness boundaries and respond to suggested boundary revisions. Sample Comment #6008-17 - On page 295 of Appendix 2, the statement is made: Statements: “Portions of the Cucamonga B unit are relatively close to the community of Lytle Creek. In the past, motorized equipment and mechanical transport have been used as part of initial attacks on wildfires in the Lytle Creek Wash. Potential impacts might be minimized by placing the recommended wilderness boundary at the toe of the slope rather than in Lytle Creek itself. The Sierra Club agrees with this boundary recommendation except for the exclusion of Stonehouse Crossing Campgound. [Environmental Conservation/ Preservation] Comment #6008-26 - Pyramid Peak A IRA: We support Alternative 2’s recommended wilderness boundaries for this IRA with the exception that we would like you to include both the Pacific Crest Trail and Live Oak Canyon Trail within the proposed wilderness boundaries. General Description: Pyramid Peak A IRA has 15,824 acres of which 7,358 acres was recommended as wilderness and 8,466 acres was recommended as non-wilderness. The recommended wilderness IRA is a suitable addition to the San Jacinto Wilderness created by the 1964 Wilderness Act and with acreage added by the California Wilderness Act of 1984. [Environmental Conservation/ Preservation] Comment #8626-13 - ANF – North Maps/Fish Canyon, Red Mt., Salt Creek and Tule IRAs – Routes 7N05 & 7N01 a. Boundary RW does not provide adequate buffer to allow for accommodating potential re-routes of roads due to natural occurring weather conditions. b. RW boundary crosses and overlaps Lake Hughes Rd which is a paved road and managed by the county. c. South end corridor between Tule RW & Red Mountain RW does not provide an adequate buffer. [Recreational (incl. permittees)] Comment #8876-3 - No explanations are given for the boundaries of the RW zones in either Alternative 2 or 3, nor did the DEIS respond to any of the site- specific comments or questions we posed in scoping. We request that the FEIS explain the reasons for the proposed boundaries under Alternatives 2 and 3. [Environmental Conservation/ Preservation] Response: The boundaries of the recommended wilderness land use zones were drawn to include suitable areas, exclude conflicting uses, and to buffer roads. While there are many possible areas where boundaries can be established, the focus of the analysis at the plan level is the effects of the land use zone at the forest scale. If the recommended wilderness areas are incorporated into wilderness legislation, the general boundaries established in the law are followed by detailed boundary mapping conducted by the agency.

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Concern #110 Concern: The Forest Service should recommend additional wild and scenic river designations for the supplemental environmental impact statement. Sample Comment #3953-2 - I also ask the Forest Service to complete its studies and Statements: recommendations of 200 miles of creeks and rivers that may be considered for National Wild and Scenic River protection in the Angeles, Cleveland and San Bernardino forests. [Individual] Response: This issue was raised during scoping and as described in the Draft SEIS in Chapter 1, determined to be outside the scope of the analysis. Refer to Chapter 1 of the Final SEIS, Table 3 for more details. Section 9. Comments on economic and social considerations. Concern #111 Concern: The Forest Service should recognize and protect social and cultural resources in the Southern California National Forests. Sample Comment #8123-1 - Red Mountain is scared ground to me. My Father's ashes Statements: were scattered there. He loved Red Mountain. His name was Clyde Bolster, Kickapoo of Oklahoma. His Kickapoo name was Hutke-Lotti-Este-Jotti. Died of lung cancer in 1996. Please protect his final resting place. [Individual] Comment #8112-7 - Cultural, art, and heritage sites, and Native American sites in the forests need to be celebrated and preserved. USFS should conduct a thorough survey of relevant places within and adjacent to the forests that celebrate diversity, democracy and freedom. Interpretive and educational programming and monument status should recognize the vital contributions that people of color, women and Native Americans have made to the region. USFS should develop culturally and linguistically appropriate facilities, signage that relies on icons rather than words, and programming to serve diverse people. [Civic or Place-Based Groups (Kiwanis, Elks, Community Council, Planning Cooperative)] Response: In compliance with the National Historic Preservation Act, it is the policy of the Forest Service to ensure that land use decisions and management practices do not have an inadvertent adverse effect on the characteristics that qualify cultural resources for listing on the National Register. For all proposed Forest Service undertakings, the agency analyzes effects on National Register listed or eligible properties and takes those effects into account in land use decisions. The agency consults with the SHPO, Indian tribes, Advisory Council, and the interested public about proposed land use decisions and their potential effects on cultural resources, in accordance with 36 CFR part 800 or under national, regional, or State programmatic agreements that are applicable to the undertaking proposed. In the Forest Land Management Plan, Part 2, stewardship of the irreplaceable cultural and tribal resources under the national forest's control is addressed by Strategic Program Emphasis and Objectives

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Tribal 1: Traditional and Contemporary Uses, Her 1: Heritage Resource Protection, Her 2: Public Involvement Program, and Her 3: Heritage Research. As part of the agency protection and stewardship responsibilities, we have developed and regularly implement preservation-related programs to recognize, enhance, restore, interpret, and use National Register eligible or listed properties. The Forest Service has also established partnerships with the public and private sector to achieve stewardship goals and enhance capacity to meet public education and outreach goals, including through our national Passport in Time program. We agree that the public needs to become more aware of California's cultural diversity and its tangible manifestations on the land. The Region in the past has sponsored Heritage Resource Interpretation for Cultural Diversity training with Five Views - An Ethnic Historic Site Survey for California used as a textbook. Cultural diversity has been a criterion (enhancement of public awareness of cultural diversity as reflected in our cultural heritage) for Heritage Resource enhancement grants, and heritage interpretation projects focusing on cultural diversity that are present on the four southern California national forests. The second tactic under Program Strategy Her 2: Public Involvement Program (found in Part 2 of the Forest Land Management Plan) provides the focus to continue to foster the connection between the public and their tie to the diverse cultural heritage of the land. Management direction in the forest plan speaks to the Forest Service’s intent for equitable outreach and providing of services. In Part 1 of the forest plan, Strategic Goal 3.1, Managed Recreation in a Natural Setting, the desired condition states that: "Proactive efforts reach both traditional and non- traditional users and lead to a greater citizen understanding, appreciation, advocacy, and participation in forest stewardship and ecosystem conservation." The desired condition is also that "People connect to the land and to each other through expanded public information, interpretive services, and environmental education." This direction is further amplified in Part 2 of the forest plan in the Desired Condition and Program Emphasis sections for each Place. In support of moving towards these goals, various outreach and participation strategies are identified in Part 2 of the forest plan. Scattering of ashes without that specific permission of the landowner is a violation of California Health and Safety Code. Moreover, in areas where historical or archaeological sites may be located, the introduction of modern human remains into pre-existing cultural deposits may constitute an adverse effect to historic properties under Section 106 of the National Historic Preservation Act (36 CFR 800.5(a)(2)). It should also be noted that any proposed use of National Forest System Lands must first undergo a screening process (36 CFR 251.54(e)(1)(i)-(ix)) that includes several stipulations, including: (i) The proposed use is consistent with the laws, regulations, orders, and policies establishing or governing National Forest System lands, with other applicable Federal law, and with applicable State and local health and sanitation laws.(iv) The proposed use will not create an exclusive or perpetual right of use or occupancy.(v) The proposed use will not unreasonably conflict or interfere with administrative use by the Forest

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Service, other scheduled or authorized existing uses of the National Forest System, or use of adjacent non-National Forest System lands. The Forest Service does not authorize the scattering or interment of cremated human remains (nor the erection of plaques, memorials, monuments, etc.) on National Forest System lands, for the very reason that it has the effect of de facto encumbering those lands in perpetuity. This is avoided to prevent anyone assuming an implied right to impact future management activities, in the belief that the activity will somehow conflict with an area where a loved one's remains had been spread. For the current action, no specific project-level activities are being proposed (see Introduction portion of Chapter 4). As new projects within these zones are proposed, they will be individually analyzed for impacts. Concern #112 Concern: The Forest Service should assess environmental justice concerns in the supplemental environmental impact statement. Sample Comment #9189-9 - Many of the people that will be impacted by these Statements: enormous increases in water costs, and/or the decrease in amount of local water available, are from low income households and reside within disadvantaged communities. Under Executive Order 11,988, every federal agency is to make "achieving environmental justice part of its mission" by identifying and addressing disproportionately "high and adverse human health or environmental effects of its programs, policies, and activities on minority and low-income populations." 42 Fed. Reg. 26951 (1977). Unfortunately, in violation of Executive Order 11,988, there is no acknowledgment or analysis in the Draft SEIS of these Environmental Justice concerns. The Draft SEIS must be revised to analyze these impacts, and attention should be focused on alternatives and mitigation strategies that can ameliorate these impacts. See Environmental Justice: Guidance Under the National Environmental Policy Act (1997), available at http://www.epa.gov/compliance/resources/policies/ej/ej_guidance_neap_caq_1 297.pdf. The additional alternative proposed below would significantly reduce or eliminate these impacts. [Other] Comment #8112-3 - USFS must ensure compliance – including in the revised land management plan for these four forests – with equal justice laws and principles that guarantee equal access to public resources, including the President’s 1994 Executive Order 12898 on Environmental Justice, and Title VI of the Civil Rights Act of 1964 and its regulations. The President’s Order on Environmental Justice, Executive Order 12898, requires agencies to “make achieving environmental justice 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.” Executive Order 12898 § 1-101 (Feb. 11, 1994); see also id., §§ 1-102, 6-604. Other federal civil rights laws and principles also apply here. Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000d - 2000d-4a, ensures equal access to public

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resources by prohibiting recipients of federal financial assistance (such as state, regional, or local park agencies and environmental organizations) from discriminating on the basis of race, color, or national origin in their programs or activities.1 The Department of Agriculture, like other federal agencies, has enacted regulations to implement Title VI. See 7 C.F.R. §§ 15.1 et seq. Title VI and its regulations prohibit both intentional discrimination, as well as unjustified discriminatory impacts for which there are less discriminatory alternatives, regardless of intent. Title VI applies to all of the programs and activities of a recipient agency if any part of the agency receives federal funds. See 68 Fed. Reg. 51334 (Aug. 26, 2003) (definition of “program” subject to Title VI); 7 C.F.R. § 15.2(k). Green Access Disparities As the National Park Service has recently highlighted, “Los Angeles County is one of the most disadvantaged counties in terms of access to parks and open space for children of color and people of color.” Draft San Gabriel Watershed and Mountains Special Resource Study & Environmental Assessment (Newsletter #5, Nov. 2011) p. 219. Extensive research studies by The City Project and others support this conclusion. See generally Robert García and Seth Strongin, Healthy Parks, Schools and Communities: Green Access and Equity for Southern California Policy Report (The City Project 2011), available at www.mapsportal.org/thecityproject/socalmap/ComprehensiveSocalReport.html . Visitation data for the Angeles National Forest show low visitation rates by people of color. USFS data from 2000 show that more than 47% of the population of Los Angeles County is Latino, but only 11% of visitors to the Angeles Forest are Latinos. Nearly 10% of the residents are black, yet only 1% of the visitors to the forest and 0% of visitors to the forest’s wilderness areas are black. Asians account for an estimated 25% of the total population of the San Gabriel Valley, yet only 4.5% of visitors to the Angeles are Asian.2 A more recent but limited survey of 270 Angeles Forest visitors in the San Antonio and San Gabriel Canyons found that 65% of day use visitors were Latino.3 Nationally, USFS reports that over 90% of visitors to all national forests are non-Hispanic white, while less than 5% are Latino, less than 2% are Asian, and only 1% are African American.4 These data mirror broader park visitation patterns. The results of a study of visitation patterns at the Golden Gate National Recreation Area corroborate over four decades of research on park constraints.5 Traditionally absent groups are expressing a desire to enjoy the benefits associated with outdoor recreation in public lands, including National Forests. While identifying physical, mental, and spiritual benefits of access to nature, many participants expressed frustration with limited physical access, subtle racism, and general exclusion from the culture of parks as reasons why they avoid these public spaces. Green Access and Human Health Disparities The City Project has extensively analyzed the environmental justice and Title VI implications of green access and health disparities, most recently in its 2011 policy report Healthy Parks, Schools and Communities: Green Access and Equity in Southern California. The report is a case study of nine counties that includes GIS mapping and demographic analyses, evidence based social science research, and participatory community based research. As

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documented in the report in ways that are relevant here: • Children of color living in poverty with no access to a car have the worst access to places for physical activity in parks and other green space. They suffer disproportionately from higher levels of obesity and diseases related to the lack of physical activity. Id. at 9-12, 26- 111. One’s health is determined by where one lives, the color of one’s skin, and the amount of money one has, more than the amount spent on health care or individual choices. • Park disparities are not an accident of unplanned growth, an efficient market in land, or rational choices maximizing personal utilities. Disparities reflect a legacy and pattern of discriminatory land use, housing, education and economic policies dating back to the New Deal and beyond. Id. at 112-21. • Park and health disparities in Southern California are consistent with broader patterns across the nation. Id. at 9-12. • The report analyzes the myriad values at stake in equal access to park and health resources. Id. at 19-25. • The report analyzes park and health disparities under civil rights laws and principles, including Title VI and the President’s Order on Environmental Justice. Id. at 122-23. • The report presents recommendations for change that are generally applicable to USFS. Id. at 125- 26. We respectfully refer USFS to the cited sections of this report, which is available on the web at www.cityprojectca.org/greenjustice. There is no good way to reach the forests and mountains in the Los Angeles region using transit, as documented in a study by USC students.6 Transit to Trails -- to take inner city youth and their families and friends on fun, educational and healthy hiking, biking and camping trips to mountains, rivers, and other natural green spaces for no or low cost -- will help. The Southern California Association of Governments (SCAG) calls for public transportation to improve access for all to parks throughout Southern California in its 2008 Regional Transportation Plan (RTP) Environmental Justice Report. “Public parks serve all residents. . . . However, not all neighborhoods and people have equal access to these public resources,” including National Forests. “[A] multi-agency effort must be undertaken in order to further address and remedy the issue of inequity of park access.” See SCAG RTP Environmental Justice Report 11-14, 24 (2008), available at www.cityprojectca.org/blog/archives/880. Access to green space, and to the health, economic, environmental and other benefits that green space can provide, are environmental justice and civil rights issues. These concerns can be addressed through “recommended wilderness” and “back country non- motorized” designations in the revised land management plan for the four forests that reflect the importance of access to green space and healthy recreation. They can also be addressed through programs such as Transit to Trails. [Civic or Place-Based Groups (Kiwanis, Elks, Community Council, Planning Cooperative)] Response: The Final SEIS includes a discussion on environmental justice in Chapter 4 to address this concern.

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Concern #113 Concern: General agency concurrence letters, no response needed Sample Comment #9409-1 - Based on our review of the Draft SEIS, we have rated the Statements: document as Lack of Objections (LO). (See enclosed EPA Rating Definitions). EPA supports the Forest Service's plan to reclassify land use zone allocations in the Angeles, Cleveland, Los Padres, and San Bernardino National Forests. Allocating greater amounts of the study area to more restrictive land use zones, as proposed, should benefit sensitive resources by limiting future activities. [Federal Agency/Elected Official] Response: No response is needed to address this concern.

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Concern #114 Concern: The Forest Service should annex the Simi Hills area and manage it as recommended wilderness. Sample Comment #511-1 - Contained within the proposed development area of the Statements: Simi Hills lies Burro Flats, an ancient Native American holy site (formerly used by both the Tongva and the Chumash). While Burro Flats is presently under the control of a military contractor (I believe it's still Rockwell), which is obligated to protect the site and its pictographs, I am not at all confident that this protection will remain adequate if the area is developed. While there are other reasons for prohibiting development, the protection of Burro Flats is the one I am emphasizing. I am a novelist and an avocational historian, and a white man at that. Burro Flats must be saved.... [Individual] Response: The Simi Hills area, including the Chatsworth Preserve and Santa Susanna Mountains are located west of the Angeles National Forest and South of the Los Padres National Forest, in the vicinity of the Simi Valley. Simi Peak and a portion of the Simi Hills are within the boundary of the Santa Monica Mountains National Recreation Area. More information about the management of the National Recreation Area can be found at http://www.nps.gov/samo/parkmgmt/index.htm The Simi Hills and Santa Susanna Mountains area is outside of the Congressionally designated boundaries of either forest. Consideration of this area is outside the scope of this analysis because forest planning only applies to designated units of the National Forest System. Section 10. Specific comments on the IRA Evaluations Cleveland National Forest – All IRAs Comment: Comment #8645-7 - Table 1. Sensitive species found within or adjacent to the Project area but not considered in the DSEIS Table 1. Sensitive species found within or adjacent to the Project acre but not considered in the DSEIS Scientific Name Status Barker Cedar Cold- No Sill Trabuco Upper CNPS Valley Creek water Name Hil SD List l River Arctostaphylos otayensis 1B.2 X Asplenium vespertinum 4.2 X X Chorizanthe leptotheca 4.2 X X Deinandra paniculata 4.2 x Dudleya cymosa var. 1B.2 X ovatifolia Eriastrum luteum 1B.2 X Eryngium aristulatum FE/ X var. parishii 1B.2 Grindelia hirsutula var. 1B.2 X hallii Mimulus clevelandii 4.2 X Mimulus diffusus 4.3 X Pickeringia Montana 4.3 X

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var. tomentosa Quercus engelmannii 4.2 X X X X X Romneya coulteri 4.2 X Rupertia rigida 4.3 X Symphyotrichum 1B.2 X defoliatum Xanthisma junceum 4.3 X

Response: Two of the 16 species, Eryngium aristulatum var. parryi, a federally endangered species and Symphyotrichum defoliatum, a USFS Sensitive species were confirmed to occur within IRAs in the analysis area. E. aristulatum var. parryi occurs within the Cedar Creek, Eagle Peak, No Name, Sill Hill, Upper San Diego River New (adjacent) Area and was analyzed in the Final SEIS Botanical Assessment (USDA FS 2013c). S. defoliatum occurs within the Upper San Diego River IRA and was addressed in the Final SEIS Biological Evaluation (USDA FS 2013b). Wording indicating E. aristulatum var. parryi is present in the “Cedar Creek, Eagle Peak, No Name, Sill Hill, Upper San Diego River New (adjacent) Area was added to the Cedar Creek IRA Evaluation as its location was bordering this analysis area. Symphyotrichum defoliatum was added as present in the Upper San Diego River IRA Evaluation. In addition to confirming the two species mentioned above, the Cleveland National Forest biologist provided information on the following four species listed in Table 1: Arctostaphylos otayensis – This location from CCH (California Consortium of Herbaria is not in/near an IRA. It is a mile or two from Trabuco IRA. This location is far from the known range of A. otayensis so the Forest is not too confident that this is a correct identification. There is a specimen so the Forest could ask Rancho Santa Ana to look at it. On 7/30/13, the Forest Botanist asked Fred Roberts (expert botanist, author/co-author of ‘Floras of Orange and Riverside Counties’) to look at the specimen. He replied that he would investigate but that it was most certainly incorrect due to location data being mixed up or misidentification, as A. otayensis can be fairly tricky to separate from A. glandulosa. Therefore, until further confirmation, the Forest Service assumes that this plant is not present on the Cleveland National Forest nor is it near an IRA. It was not added to the Coldwater IRA Evaluation. Dudleya cymosa ssp. ovatifolia - This species has a very specific habitat preference for talus slopes. Per the USFWS five-year review and expert opinion of Fred Roberts, the Modjeska Peak population – which was near, not in, Coldwater IRA - has been assigned to a different taxon. That leaves only a population in Modjeska Canyon on or adjacent to Forest that is about five miles from any of the IRAs. This species is not present in the Coldwater IRA and was not added to the IRA Evaluation. Eriastrum luteum – This species is not Forest Service Sensitive for the Cleveland National Forest so it was not considered. Jepson shows this only in San Luis Obispo area. The Forest Service is not sure what has been done with the (very old) collections from Riverside County but it appears that they have 130

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been assigned to a different taxon. Collections by Munz date from 1923 or so, but even he does not include this taxon in his later floras and Jepson 1 and 2 show it only for San Luis Obispo County area. This species is not known to occur on the CNF and was not added to the IRA Evaluations. The other 10 species were not Forest Service Sensitive species; therefore, they were not included in the analysis for sensitive or federally listed species. None of the alternatives are expected to interfere with the long term viability of any rare or common species if they were present. These species were not added to the IRA Evaluations. Quercus engelmannii - This species is also not a Forest Service Sensitive species. It was analyzed in the MIS analysis for this project. In the Biological Evaluations (USDA FS 2013a, 2013b) the Forest Service acknowledged the obligation to maintain viability off all native species and have determined that none of the alternatives are expected to interfere with the long term viability of any rare or common species. This species was not added to the IRA Evaluations. Regarding the presence of additional invasive species, the Forest Service states in the Draft and Final SEIS Botanical reports (USDA FS 2013a, 2013b) and IRA Evaluations that “it is likely that some undetected non-native plants occur in one or more of the IRAs.” Additional invasive plant species were not added to the Wilderness Evaluations for the Final SEIS. Cleveland National Forest - Coldwater and Trabuco IRAs Comment: Comment #8658-7 - Table 18 does not include the CPRP species below, which were found by searching on “County” and “CNPS Inventory” in the Consortium of California Herbaria (CCH) website. The CCH’s mapping places some of them in sites that appear to be near the IRA’s boundaries. If their collection sites are not actually within the IRA’s it is likely that there are more of the plants nearby within the boundaries.

Scientific Name CRPR Trabuco District IRA Dudleya cymosa ssp. ovatifolia 1B.2 Coldwater Eriastum luteum 1B. 2 Coldwater Mimulus clevelandii 4.2 Coldwater, Trabuco Mimulus diffusus 4.3 Coldwater Pickeringia Montana var. tomentosa 4.3 Trabuco Romneya coulteri 4.2 Coldwater

Response: Information on Dudleya cymosa spp. ovatifolia and Eriastrum luteum below was provided by the Cleveland National Forest Biologist (Winter, pers. comm. 2013). Dudleya cymosa ssp. ovatifolia - This species has a very specific habitat preference for talus slopes. Per the USFWS five-year review and expert opinion of Fred Roberts, the Modjeska Peak population – which was near, not in,

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Coldwater IRA - has been assigned to a different taxon. That leaves only a population in Modjeska Canyon on or adjacent to Forest, that is about five miles from any of the IRAs. This species is not present in the Coldwater IRA and was not added to the IRA Evaluation. Eriastrum luteum - This is not a Forest Service Sensitive species for the Cleveland National Forest so it was not considered. Jepson shows this only in San Luis Obispo area. The Forest is not sure what has been done with the (very old) collections from Riverside County but it appears they have been assigned to a different taxon. There are collections by Munz from 1923 or so but even he does not include this taxon in his later floras and Jepson 1 and 2 show it only for San Luis Obispo county area. This species is not known to occur on the Cleveland National Forest and it was not added to the IRA Evaluations. The remaining 4 species in the table above are CRPR list 4 species (not USFS sensitive species) thus were not individually analyzed in the Final SEIS Biological Evaluation (USDA FS 2013b). None of the alternatives are expected to interfere with the long term viability of these species if they are present. They were not added to the IRA Evaluations. Los Padres National Forest – All IRAs Comment: Comment #8878-7 - The DSEIS contains an incomplete inventory of sensitive plants that occur in the IRAs. For example, only 4 of the 16 IRAs in the Los Padres National Forest (and 6 of the 88 sensitive plant species) are listed in Table 18 which displays the acreage of known sensitive plant occurrences by IRA. DSEIS at 55-58. While we do not expect the Forest Service to conduct floristic surveys across all 400,000+ acres within the IRAS, the DSEIS could at a minimum contain acreage breakdowns for suitable habitat, or even a breakdown of sensitive plant species they may occur in an IRA because they are known to occur in similar habitats nearby. Response: For the analysis, data on plant species contained in the IRAs were derived from the Forest Service's Natural Resources Manager - NRM-TESP, which includes threatened, endangered and sensitive species locations in the Forest Service's GIS information system. Also used was location information from forest botanists that had been referenced in the IRA Evaluations. The SEIS Effects Analysis for this project was programmatic and included only those species known to occur within the IRAs. The Forest Service acknowledged in the Biological Evaluations/Assessments and in the Draft and Final SEIS that additional rare or invasive plants may be present within the IRAs because surveys may not have been conducted. If additional species were to occur they would be subject to the same beneficial effects described in the Biological Evaluation and Assessment as those plants known to occur. In the future, if specific projects are proposed within the IRAs, additional sources of botanical information such as CNNDB and the Consortium of California Herbaria could be utilized for the site-specific assessments. The Botanical Evaluation and Botanical Assessment were combined as one document in the Draft SEIS. For the Final SEIS, a separate Biological

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Assessment was created. In the Biological Assessment, the Forest Service addressed two additional plants (Eryngium aristulatum var. parishii and Eremalche parryi subsp. kernensis) brought to our attention through public comment (USDA FS 2013c). The threatened/endangered species/designated critical habitat table was updated to: 1) change Eremalche parry subsp. kernensis and Eriogonum kennedyi var. austromontanum from potential to known to occur on the Los Padres National Forest and 2) add Eryngium aristulatum var. parishii as occurring on the Cleveland National Forest. New species accounts were created for Eremalche and Eryngium and added to the project record. In the addendum to the Biological Evaluation (USDA FS 2013 b) the Forest Service verified and analyzed effects to one additional sensitive species in response to public comment (Symphyotrichum defoliatum on the Cleveland National Forest). The additional species addressed in the Biological Evaluation and Assessments were also added to the IRA Evaluations along with the following statement “Floristic surveys have not been conducted throughout the entire IRA, therefore additional occurrences and/or species may be present, especially after wildfire.” Comment: Comment #8878-8 - The Forest Service should disclose whether suitable habitat may occur in the IRA. If suitable habitat does occur, then the species should be assumed present. Response: This comment was referring to plants. The Forest Service did not assess suitable habitat in the Draft or Final SEIS. Due to the programmatic nature of the analysis, effects to known occurrences were analyzed. In the future if site- specific projects are proposed within an IRA, suitable habitat may be assessed and analyzed if appropriate to do so. Comment: Comment #8878-9 - Allocating RW land use zones through the LMP amendment process can serve as an important tool to promote the conservation of global bird species. As such, the IRA Analysis should evaluate the importance of each IRA on the Los Padres National Forest for bird conservation, and identify any special-status bird species that may occur in each area. Response: Los Padres National Forest IRAs are evaluated as per FSH 1909.12, Chapter 70. Several IRAs have been edited to add bird conservation information. Bird conservation information is included as appropriate in other IRAs. Comment: Comment #8878-10 - The DSEIS and the IRA Analysis identify certain endangered, threatened, sensitive and other special-status plant and animal species that are known to occur in that particular area. The presence of these species weighs in favor of an area’s suitability for wilderness designation. Therefore, it is important for the IRA Analysis and the SEIS to contain a full and complete listing of all special-status species for each IRA. However, many (if not most) of the IRA evaluations contain incomplete special status species listings. Species that are known or likely to occur in a particular IRA are not listed in the areas wilderness evaluation, meaning that the evaluation is not

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taking all of the potential wilderness values of a particular area into account. Special-status species may be overlooked in IRA evaluations because the areas have not been thoroughly surveyed. However the IRA Analysis should not assume that a species is absent just because it was not detected in whatever limited surveys have been done in a particular area. Rather, the IRA Analysis should evaluate whether suitable habitat is or may be present in a particular IRA, and should assume occupancy whether suitable habitat is or may be present in a particular IRA and should assume occupancy in suitable habitat until surveys are conducted to protocol. The IRA Analysis and SEIS should also examine sources like the California Natural Diversity Database (CNDDB), the Consortium of California Herbaria, and the species lists from neighboring land reserves. Specifically, the Wind Wolves Preserve and the Bitter Creek National Wildlife Refuge both have fairly extensive lists of special-status plant and animal species that occur within their respective boundaries. Certain species that occur in these areas may also be presumed to occur in similar habitats in neighboring IRAs. Response: The IRA Evaluations were edited prior to release of the Draft SEIS and again for the Final SEIS. Every effort was made to ensure species that were known to occur within an IRA were included in the text of each IRA Evaluation. As stated in a prior comment response, due to the programmatic nature of the analysis, the Forest Service analyzed effects to known occurrences. In the future, if site-specific projects are proposed within an IRA, suitable habitat may be assessed and analyzed if appropriate to do so. Comment: Comment #8878-11 - The IRA Analysis downplays any need to designate more wilderness areas to accommodate future anticipated increases in visitation to these areas. For example, the analysis for many IRAs contains the following statement: Present visitor use on all wildernesses on the District and Forest is relatively low. There are a few popular spots that receive extra visitor pressure but no restrictions on use have been necessary to maintain wilderness characteristics or preserve the sustainability of the wilderness setting. The designation of this area as wilderness would not have any influence on visitor use of other wilderness areas. However, in other areas – and often in the same breath – the analyses also admit that “[p]opulation growth and urbanization are increasing rapidly on the Interstate 5 corridor and wilderness use is expected to increase. IRA Analysis at 140. In addition, the IRA Analysis frequently rejects the need for more wilderness in the Los Padres National Forest by referring to other proposed and existing wilderness areas within a 20-mile radius. For example, for Madulce-Buckhorn, the IRA Analysis states: Within a 20 mile radius of Madulce Buckhorn are the San Rafael Wilderness (197,380 acres), Dick Smith Wilderness (67,800 acres), Chumash Wilderness

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(38,150 acres), Matilija Wilderness (29,243 acres) and Sespe Wilderness (219,700 acres). This unit is also near the Diablo roadless area (19,608 acres) and the Madulce Buckhorn recommended wilderness addition (5,360 acres) to the Dick Smith Wilderness. This unit is within 10 miles of the Mono recommended wilderness addition (27,012 acres) to the Dick Smith Wilderness (71,350 acres) and the Matilija recommended wilderness addition (2,700 acres) to the Matilija Wilderness (29,243 acres). All of these existing wilderness areas and recommended additions are of similar landscape character and contain strong wilderness characteristics. This analysis begs a few questions. Why was a 20-mile radius selected instead of 50 or 100 or even 200 miles? By selecting a relatively narrow radius of 10 or 20 miles, the Forest Service is giving the impression that there is an abundance of wilderness in our area, resulting in low “need” ranking for particular IRAs. The selection of 10 or 20 miles ignores the fact that the next-closest wilderness areas are hundreds of miles away, and that even wilderness areas that are 10 or 20 miles away from each other may sometimes require several hours on remote roads to travel from one to another by vehicle. Response: The IRA Evaluations did not downplay recommended wilderness land use zone classification based on future use but rather examined each IRA on a site- specific basis. Additional recommended land use zone classification was not rejected on the Los Padres National Forest by only referring to other wilderness in the general vicinity. Multiple criteria were examined. Guidance from the Forest Service Handbook was used for IRA Evaluation wilderness radius. A required distance is not specified by the Handbook. The IRA Evaluations did not include a standard, blanket 20 mile radius but rather examined each IRA on a site-specific basis. FSH 1909.12, Chapter 70, 72.31, 72.31 – Factors, “In determining whether there is a need to recommend a potential wilderness area for wilderness study or designation, at a minimum consider the following factors: 1. The location, size, and type of other wildernesses in the general vicinity and their distance from the proposed area. Consider accessibility of areas to population centers and user groups. Public demand for wilderness may increase with proximity to growing population centers.” Los Padres National Forest – Fox Mountain IRA Comment: Comment #8878-19 - Why are certain areas on the perimeter of the Fox Mountain IRA zoned BC? Response: A land use zone buffer consisting of Back Country (BC) and Back Country Motorized Use Restricted (BCMUR) land use zones was allocated within the Fox Mountain IRA and adjacent to the Sierra Madre Road for an established fuel break.

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Comment: Comment #8878-22 - We dispute the argument in this IRA Analysis that the designation of wilderness adjacent to private property “will probably create future conflicts as the private property continues to be developed along the Forest boundary.” See IRA Analysis at 180. Given the remoteness of this area, and the current land uses on private parcels adjacent to this area, there is a low likelihood that private property would be developed much beyond what it is today. If the Forest Service is going to use this as a reason to disqualify an area from RW zone allocation, then please provide specific examples of development proposals that may affect the area’s wilderness characteristics. In addition, we again note that activities outside of an IRA should not be used to disqualify an area from a RW zone allocation. Response: Chapter 70 of Forest Service Handbook 1909.12 directs the Forest Service to evaluate “how boundaries affect manageability of an area.” Section 72.1(5) further states “boundary locations avoid conflict with important existing or potential public uses outside the boundary that might result in demands to allow nonconforming structures and activities in wilderness,” and “boundaries, where possible, conform with terrain or other features that constitute a barrier to prohibited uses.” Comment: Comment #8878-22 - Please include additional scenic landmarks in this analysis, including views of the Caliente Mountains, the Carrizo Plain National Monument, and the southern Sierra Nevada range. And given the dominant rock outcrops in Lion Canyon, we believe that the IRA Analysis should provide further detail about this particularly unique and striking landform, as well as the red rock formations that are found in Santa Barbara Canyon. Response: The IRA Evaluation has been edited in response to this comment. Comment: Comment #8878-22 - We disagree that “water sources are very scarce in the area.” IRA Analysis at 179. While many of the streams in the area are ephemeral, the area does contain dozens of natural springs that provide reliable, continuous water sources for wildlife, livestock, pack stock, and visitors to the area. Response: Many of the streams in the area are ephemeral and there are springs that provide a source for water. However, the available water from springs tends to be very localized, and thus limited. At certain times of the year, and particular during dry years, some springs in the Forest go dry. Comment: Comment #8878-22 - The IRA Analysis identifies the Sierra Madre Special Interest Area (“SIA”) and the Eastern Sierra Madre Ridge Archaeological District as the only “special features and values” of this area. IRA Analysis at 180. While these areas certainly are some of the top features and values of this area, there are plenty of others to complement them. The IRA Analysis should evaluate these additional special features and values: o Presence of many other Native American sacred sites located outside of the SIA, but in the IRA; o Unique red rock formations in and around Santa Barbara 136

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Canyon; o The remnants of petrified forests and other paleontological resources in the lower elevations; and o Unique grassy potreros and scattered rock formations, including substantial rock outcrops in Lion Canyon. Response: The IRA Evaluation has been edited in response to this comment. Comment: Comment #8878-22 - These landforms are not considered in the section of the analysis that addresses the area’s “identifiable landform types,” which concludes that the area has no “unique features.” IRA Analysis at 182. We disagree, for all of the reasons outlined previously – unique potreros, rock outcrops, red rock formations, and the dramatic rock assemblages in Lion Canyon all contribute to the unique features of the Fox Mountain IRA. Response: The IRA Evaluation has been edited in response to this comment. Comment: Comment #8878-22 - The following sensitive plant species are identified in the IRA Analysis as occurring in this IRA: Blakeley's spineflower (Chorizanthe blakleyi), umbrella larkspur (Delphinium umbraculorum), Fort Tejon woolly sunflower (Eriophyllum lanatum var. hallii),pale-yellow layia (Layia heterotricha), and Parish's checkerbloom (Sidalcea hickmanii ssp. parishii). IRA Analysis at 180. According to the California Natural Diversity Database, the following additional special-status plant species may also occur in this IRA, and should be referenced in the IRA Analysis: o Fort Tejon woolly sunflower (Eriophyllum lanatum var. hallii) (CNPS List 1B.1) o Lemmon's jewel-flower (Caulanthus lemmonii) (CNPS List 1B.2) o Round-leaved filaree (California macrophylla) (CNPS List 1B.1) o San Luis Obispo mariposa lily (Calochortus simulans) (CNPS List 1B.3) Moreover, Kern mallow (Eremalche kernensis), San Joaquin wooly-threads (Monolopia congdonii), and California jewelflower (Caulanthus californicus) are all known to occur in areas within close proximity of this IRA, and are therefore likely to occur within this IRA. These species should be referenced in the IRA Analysis as well, along with any special-status animals that may occur in the area. Response: Fort Tejon Woolly sunflower (Eriophyllum lanatum var. hallii) is known to occur in the Fox Mountain IRA and was addressed in the DSEIS botanical evaluation (USDA FS 2013a). This species was stated as known to occur in the Draft SEIS Fox Mountain IRA Wilderness Evaluation. This information has been retained in the Final SEIS Fox Mountain IRA Evaluation. The Los Padres National Forest Botanist was contacted regarding the potential for Lemmon’s jewelflower (Caulanthus lemmonii), Round-leaved Filaree

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(California macrophylla), and San Luis Obispo mariposa lily (Caulanthus simulans) to occur in the IRAS. He stated all of these species are likely to occur close to but not necessarily within the Fox Mountain IRA. There is certainly a possibility that they are there, but that would depend on the accuracy of the GPS polygons (Simpson, pers. comm. 2013). Round-leaved filaree is not a Forest Service sensitive species. If it were to occur, none of the alternatives are expected to interfere with the long term viability of any rare or common species. The federally endangered Kern mallow (Eremalche kernensis), was confirmed to occur in the Sawmill-Badlands IRA. Effects to this species were analyzed in the Final Botanical Biological Assessment (USDA FS 2013c) for the FSEIS. Presence of this species was added to the Sawmill-Badlands IRA Evaluation. The two other federally endangered species mentioned, San Joaquin wooly- threads (Monolopia congdonii) and California jewelflower (Caulanthus californicus), are not known to occur within the Los Padres National Forest. Comment: Comment #8878-22 - The section on water availability and use, while mentioning that the headwaters within this unit may generally be in good functioning condition, should also note that some springs and riparian areas suffer from adverse impacts caused by concentrated livestock use associated with the three grazing allotments in this area. Response: The Forest has no known spring and riparian issues within the grazing allotments in this IRA. Comment: Comment #8878-22 - The private inholding in Cox Canyon has been acquired by the Forest Service, though it is still shown as private land on the DSEIS maps. Please update the maps and apply the appropriate zoning designation to the parcel. Response: The private in-holding in Cox Canyon was acquired by the Forest Service. The Agency closed on the parcel on September 30, 2011. The Forest is awaiting the official title report and the land status GIS database has not been updated to reflect this acquisition. Los Padres National Forest – Antimony IRA Comment: Comment #1449-11 - A population of Allium howellii var. clokeyi, a Forest Service Sensitive plant species, occurs in this unit on Trail 118. I reported this presence of this population to the Forest Service in 2012; photographs showing diagnostic taxonomic features were also provided. At least two other rare plants have been observed on the Wind Wolves Preserve, which is immediately adjacent to this IRA (Eriophyllum lanatum var. hallii and Mimulus pictus). There is abundant suitable habitat for these, and possibly other rare taxa to occur in this IRA. The extent of focused conducted in this IRA, if any, is unknown. Response: The Los Padres Forest Botanist was contacted regarding this statement (L. Simpson, pers. comm. 2013). He stated “The trail is in the Sespe-Frasier IRA south of the Ranger Station, not in Antimony.” He was unaware of any

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Lockwood Valley Clay, the preferred substrate of Allium howellii var. clokeyi, occurring within the Antimony IRA. The Botanical Biological Evaluation for sensitive plant species completed for the Draft and Final SEIS acknowledges presence of Allium howellii var. clokeyi in the Sespe-Frasier IRA. It was determined Alternatives 2, 2a and 3 will not negatively affect this species and may be beneficial (USDA FS 2013a, 2013b). Comment: Comment #1449-11 - The discussion for the Antimony IRA does not contain any mention of a vernal pool that occurs within the IRA along Cerro Noroeste Road. Many vouchers of Downingia bella, a plant that is an indicator of vernal pools, have been collected from this pool. Although no rare plants have been documented in this pool, to my knowledge no focused surveys have been conducted here, either for rare plants or for rare invertebrates that may also be present. Response: The Los Padres Forest Botanist was contacted regarding this statement (L. Simpson, pers. comm. 2013). He stated to the best of his knowledge, the vernal pool is on private land. The vernal pool information was not added to the IRA Evaluation. Comment Comment #8878-21 Also in our scoping comments, we suggested that the IRA Analysis evaluate the presence of the San Emigdio Mountains Globally Important Bird Area (204,344 acres), which encompasses a portion of the Antimony IRA. The revised IRA Evaluation does not acknowledge the Globally Important Bird Area, even though it possesses the following features that could be protected and enhanced through a RW land use designation: Response The IRA Evaluation has been edited to acknowledge the San Emigdio Mountains Globally Important Bird Area. Comment: Comment #8878-21 - The IRA Evaluation for Antimony IRA states that “A strip of private land along San Emigdio Canyon bisects the area.” DSEIS Appendix 2 at 134. This private land is part of the Windwolves Preserve – at more than 95,000 acres, the west coast’s largest non-profit land preserve. This extension of private conservation land into this IRA should not detract from its wilderness character – indeed, it complements it. The Wildlands Conservancy – the nonprofit conservancy that owns the Windwolves Preserve – manages these lands as if they were wilderness. Therefore, a RW designation of the lands adjacent to, and surrounding, the Windwolves Preserve would complement both public and private land conservation initiatives. Response: The IRA Evaluation has been edited to remove the ‘private land intrusion’ language under the Description of Size and Shape section. The IRA Evaluation has also been edited to acknowledge the Wind Wolves Preserve in San Emigdio Canyon.

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Comment: Comment #8878-21 - To further reduce the impacts of existing roads and motorized trails on the wilderness landscape, we suggest that Alternative 3 be modified with mechanisms to control unauthorized trespass into the neighboring Wind Wolves Preserve. For example, the segment of Road 9N53 north of Salt Creek Campground could be included in the RW zoning classification to reduce fragmentation. Currently, this road is gated at the boundary with Wind Wolves Preserve, inviting trespass. A non-motorized buffer would appropriately protect the preserve from future incursions, and would enhance the wilderness characteristics of the Antimony IRA. The same modification could be made for Road 9N19A – zoning for a non-motorized buffer north of Pleito Creek Campground that would allow for continued motorized access to the campground, with a non-motorized buffer north of the campground that would prevent trespass and benefit wilderness values. Finally, the zoning allocation applied to the final segment of Road 9N52 between Marian Campground and Brush Mountain could also be modified to provide a non- motorized buffer around the known condor roosting sites on Brush Mountain. This would eliminate a third road intrusion into the Antimony IRA. These three roads are all in the existing IRA, and detract from the area’s wilderness character while providing limited access and recreation opportunities. Response: The SEIS has already been updated to reflect the recommendation for Roads 9N53 and 9N19A provided in this comment. Under Alternative 2 and 3 roads 9N53 and 9N19A are buffered as backcountry which allows public access to the campgrounds located along these roads. However, this land use designation stops short of the Forest Boundary with the Wind Wolves Preserve, thereby creating a non-motorized public use buffer. The IRA analysis was updated to remove the word “often” and replace it with the word “occasional.” As a roost site, Brush Mountain receives occasional use by condors. The presence of people and OHVs along road 9N52 (trail 22W12) has not been an issue. Comment: Comment 8878-21 - Citing the area’s “linear shape,” its proximity to roads and development, external sights and sounds, and developed roads and trails, the IRA Analysis concludes that opportunities for wilderness challenge are limited and that “management as a wilderness would be difficult.” IRA Analysis at 137-138. However, the Wilderness Act does not specify any particular shape that an area must be before it qualifies for wilderness designation; rather, the law only requires that an area be 5,000 acres or larger. Several existing wilderness areas on the Los Padres National Forest – particularly those in San Luis Obispo County – are equally as narrow, or even narrower in some cases, than is Antimony. With respect to external sights and sounds, that is not an adequate basis to evaluate an area’s wilderness suitability or capability for the reasons outlined in Part One above. Response: Chapter 70 of FSH 1909.12 directs the Forest Service to evaluate the manageability of an area when determining the capability of a potential wilderness. Section 72.1(5) states to “consider such factors as size, shape, and

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juxtaposition to external influences.” The Wilderness Act sec. (C) (3) does state an area be at least 5,000 acres. However, an area may be less than 5,000 acres if it is of “sufficient size as to make practicable its preservation and use in an unimpaired condition.” FSH 1909.12 Chapter 70 sec. 71.1 provides additional detail. For ‘sight and sound’ concern see Response to Concern # 107. Comment: Comment #8878-21 - The IRA Analysis for Antimony contains three factual errors. First, it states that the streams originating in Antimony “eventually reach[] the Santa Maria River” by way of the Cuyama River. IRA Analysis at 139. Please note that these streams empty into the San Joaquin Valley, not the Cuyama River watershed. Second, it states that the Johnson Canyon allotment is active, when in fact it is vacant and has not been grazed in several years. And third, the analysis references habitat connectivity with Hopper Mountain National Wildlife Refuge. The correct reference is to the Bitter Creek National Wildlife Refuge that is located immediately adjacent to Antimony, not Hopper Mountain, which is located many miles to the south. The IRA Evaluation has been edited to replace Hopper Mountain with Bitter Creek. Response: The vast majority of the streams originating in the Antimony IRA flow to the San Joaquin Valley. However, very small portions of the southwest border of the IRA are within the Quatal Canyon Watershed which is part of the Cuyama basin and flows into the Santa Maria River. The IRA Evaluation has been edited accordingly. The Johnson Canyon allotment is vacant. The IRA Evaluation has been updated to reflect that. The IRA Evaluation has been edited to replace Hopper Mountain with Bitter Creek. Comment: Comment #8878-21 - The IRA Analysis states that there are “40 acres of reforestation within the area that requires maintenance” and that there is “considerable concern for potential dwarf mistletoe and bark beetle infestation in the coniferous species.” IRA at 140-41. Where is this reforestation area located? What type of maintenance does it require? Does it involve motorized access or mechanized equipment, and can it be accomplished without either? Is the concern over infestations limited to the area of reforestation, or does it apply to all forested areas in Antimony? What is the basis of the agency’s concern over the potential infestations, and how likely is the potential? It is unclear how this information was applied to the evaluation of the area’s availability for wilderness designation. Response: The IRA Evaluation has been edited to provide more detail in response to this comment. The 40 acre reforestation area is located along Tecuya Ridge near Frazier Park and was burned in the 2006 Scott Fire. Reforestation efforts have been undertaken in the past, and if funding allows, subsequent planting will continue. The area is accessed by the existing road and OHV trail network.

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The Antimony IRA includes infestations of dwarf mistletoe and bark beetle as identified by Forest Service’s Forest Health Protection. The infestations have led to higher incidences of tree mortality in some areas of the IRA than in others. The continued impact of the infestations on tree stand health and the potential for spread is of concern to the forest. Comment: Comment #8878-21 - The IRA Analysis also identifies a “shaded fuelbreak across Tecuya Ridge [that] is in the conceptual design phase.” Id. The Forest Service cannot use speculative future development proposals to reduce an area’s suitability or availability for wilderness designation. It is important to note that the Forest Plan does allow for community protection activities and fuelbreak construction in RW zones “by exception.” If the IRA Analysis is going to rely on this speculative future development proposal, then it should describe the location and nature of the project, its intended completion date, and whether or not it is compatible with a RW zone allocation, given the exception for fuelbreak construction. Response: Tecuya Ridge is near the community of Frazier Park. The fuel break project described is in the planning stages, and it is appropriate to describe the potential future use when determining availability of lands for recommended wilderness as per Forest Service Handbook 1909.12, Chapter 70, Section 72.2. Los Padres National Forest – Black Mountain Comment: Comment #8878-6 - In the previous version of the IRAA on page 144, the USFS stated that “The overall appearance of the area is of rounded landforms covered with dull green chaparral. The landscape is lacking in variety and distinctive landforms, vegetation or water forms, which make it minimally attractive.” In the latest version of the IRAA, again on page 144, the sentence has been changed to read: The overall appearance of the area is of rounded landforms covered with chaparral. All of Black Mountain illustrates scenic attractiveness characteristics that are typical or common (Scenic Attractiveness Class B). These are landscapes where landform, vegetation patterns, water characteristics and cultural features combine to provide typical or common scenery. They generally have positive yet common attributes of variety, unity, vividness, mystery, intactness, order, harmony, uniqueness, pattern and balance. The final 10 words of the description are quite Zen-like. While we are not sure what they mean, they sound much better than “dull” and “minimally attractive.” Response: Although the description may be quite Zen-like, the attributes are used to describe scenic attractiveness and landscape character. A more complete use of the terms in the context of landscapes can be found in the glossary of Part 3 of the LMP.

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Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Los Padres National Forest – Cuyama IRA Comment: Comment #8878-25 - We support a RW zoning allocation for this IRA. Please describe the nature of the cherry-stem in the IRA boundary on the southern flank of Cuyama Peak, as show below: Response: The IRA maps are maintained by the Forest Service Washington Office and the Agency has not yet developed a process for making changes to the IRA boundaries. We think the original IRA map tried to cherry stem the road to the lookout, but incorrectly mapped the location (See the response to Concern #101). Los Padres National Forest – Quatal IRA Comment: Comment #1449-9 - The Inventoried Roadless Area Analysis for the Quatal Canyon IRA includes the following statement: Pale yellow layia (Layia heterotirca) [sic] is the only sensitive plant that occurs in the unit. There are no threatened or endangered plant species or their habitats within Quatal. The federally listed Endangered Eremalche parryi subsp. kernensis has been documented (vouchered) in Ballinger Canyon, which is immediately adjacent to this IRA. The Quatal Canyon IRA contains abundant suitable habitat for this taxon; it is likely to occur in Quatal Canyon, however no surveys for this plant have been conducted in this IRA. According to the CNPS, this taxon is “seriously threatened by agriculture, grazing, and oil development,’ therefore this IRA should be considered as recommended wilderness area. Response: Based on this comment letter, the geographical coordinates of the Eremalche parryi subsp. kernensis specimens in the California Consortium of Herbaria were mapped to determine if this taxon was present within the Quatal IRA. The Forest Service GIS analysis indicated that there are no known occurrences within the Quatal IRA. However, a presence was confirmed within the Sawmill Badlands IRA to the south. Additional information regarding this occurrence is provided below in this document. The Quatal Wilderness Evaluation was updated to correct the spelling of Layia heterotricha and to modify wording in two sentences as follows: “There is one known location of the Forest Service sensitive plant species pale yellow layia (Layia heterotricha).” “Pale yellow layia (Layia heterotricha), a Forest sensitive plant species is known to occur. No threatened or endangered plant species are known to occur within Quatal. Floristic surveys have not been conducted throughout the entire IRA, therefore additional occurrences and/or species may be present, especially after wildfire.” See also the Response to Concern # 106. It explains that the IRA land use zoning was based on certain forest objectives, not just the presence of species. Los Padres National Forest – Sawmill-Badlands IRA Comment: Comment #8878-8 - Kern mallow (Eremalche parryi subsp. kernensis) – Known populations of Kern mallow occur in the Ballinger Canyon area, which is immediately adjacent to several IRAs, including Quatal, and Sawmill-

143

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Badlands, and in close proximity to Cuyama, Antimony and Fox Mountain as well. All contain suitable habitat for Kern mallow, and the plant should be assumed to occur there. An Environmental Assessment prepared by the U.S. Forest Service states that Kern mallow is known to occur in the Sawmill- Badlands IRA. Response: Eremalche parryi subsp. kernensis (Kern mallow) was confirmed to occur in the Sawmill-Badlands IRA of the Los Padres National Forest. It was analyzed in the final Biological Assessment (USDA FS 2013c) and added to the Final SEIS and to the Sawmill–Badlands IRA Evaluation. Comment: Comment #8878-8 - Southern mountain buckwheat (Eriogonum kennedyi var. austromontanum) – The federally-threatened southern mountain buckwheat is known to occur throughout the Mt. Pinos Ranger District. Suitable habitat may occur in Antimony, Quatal, Sespe-Frasier, and Sawmill- Badlands IRAs. Response: Southern mountain buckwheat is not known to occur within any of the SEIS IRAs. The location on the Los Padres National Forest where it is known to occur is surrounded by existing wilderness (Simpson, pers. comm. 2013). This species was added as occurring on the Los Padres National Forest in the Biological Assessment and made a “no effect” determination based on no known occurrences within an IRA (USDA FS 2013c (FSEIS BA, page 46, table 11). This species was not added to the IRA Evaluations. Comment: Comment #8878-41 - We appreciate that the Forest Service is proposing to rezone all three areas from Back Country (current) to Back Country Non- Motorized (Preferred Alternative 2). We agree that this more protective zoning allocation will benefit this IRA and reduce environmental impacts in this area. However, we are concerned that Alternative 2 includes a narrow corridor in Long Canyon (Section 3) that is zoned Back Country Motorized Use Restricted. This is concerning, given the types of development activities that are allowed in this less-protective zoning allocation. The DSEIS should evaluate the environmental impacts from this development potential, and the IRA Analysis should disclose the justification for excluding this area from the surrounding BCNM zoning allocation. Response: The narrow corridor of BCMUR is for an established road within the Apache Range Allotment. Comment: Comment #8878-44 - The IRA Analysis seems to reject a RW land use allocation for this area based on the presence of “numerous private parcels along the western boundary” that “limit[] the possibilities for vegetation management activities and the establishment and management of fuel breaks adjacent to this growing urban interface.” IRA Analysis at 228. The private rural lands along the western boundary do not constitute a “growing urban interface” and should have no bearing on the area’s suitability for wilderness designation. Moreover, speculative “vegetation management activities” are not a permissible consideration, and should be stricken from the IRA Analysis.

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Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The IRA Evaluation has been edited to remove ‘growing’ and replace it with ‘wildland’. Portions of the area are within Wildland Urban Interface (WUI) threat zones and some of these areas have been allocated a developed area interface (DAI) land use zone. The IRA Evaluation does not suggest that none of the IRA should be zoned RW; rather, that an RW allocation adjacent to the identified communities would limit the possibilities for vegetation management in the urban interface zone. Chapter 70 of Forest Service Handbook 1909.12 directs the Forest Service to evaluate “how boundaries affect manageability of an area.” Section 72.1(5) further states “boundary locations avoid conflict with important existing or potential public uses outside the boundary that might result in demands to allow nonconforming structures and activities in wilderness.” White Ledge Comment: Comment #8878-24 - The IRA Analysis states, “Public access along the southern flank is not possible because private lands preclude access.” IRA Analysis at 274. The Ojai Valley Land Conservancy recently acquired the Ventura River Preserve along the southern boundary of this IRA, and the Kennedy Ridge Trail provides public access into the IRA through this preserve. This trail connects with the historic Ocean View Trail, providing public access through the middle of this IRA. Response: Technically, the OVLC Ventura River Preserve is east of the IRA and does not share a boundary with the IRA. The IRA analysis is correct that private land precludes access along the southern flank. There is a trail on the Ventura River Preserve that leads to the Forest Service boundary. However, there is no official trail on the National Forest System lands in that area that ultimately leads to the White Ledge IRA. Several years ago the Ojai Ranger District was in the initial planning stages of a project to construct the Kennedy Ridge Trail. However, those planning efforts have been place on hold for the time being. Comment: Comment #8878-24 - A portion of this IRA was threatened by uranium mining in the 1970s. The IRA and SEIS should disclose that this area may be vulnerable to future mining claims. The DSEIS incorrectly states that this IRA has “no evidence of historic mining activities.” DSEIS at 254. A Recommended Wilderness designation would prohibit, without exception, any mining in this area. The DSEIS does disclose that this area has a “high potential” for oil and gas. DSEIS at 254. This threat should be evaluated in the IRA Analysis. While the area is not currently open for oil and gas development under the 2005 leasing plan, that plan could be revised in the future. Protecting the IRA through a wilderness recommendation and eventual designation would preclude future oil and gas exploration and development in this area. Response: Mining claims were filed in 1977 and subsequently closed by 1982. The majority of these claims and most of the claim areas were located in sections 10 and 11, T4N, R24W S.B.B.M., outside and south of the IRA. Directly adjacent to this location, some of the claims were located slightly within the IRA in the southern ½ of sections 2 and 3, T4N, R24W. The claims are centered on the 145

Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

uranium mining claim site identified on the Matilija topographic map, located outside the IRA. There are no remnant mining developments in the area, and there is no evidence that historic mining activities took place in this location outside or inside the IRA. The IRA analysis and SEIS information correctly state “there is no evidence of historic mining activities.” The SEIS discusses the impacts of the alternatives, including the RW land use zone allocation in Alternative 3, on future lease applications. San Bernardino National Forest – Cactus Springs Comment: Comment #6008-4 - One of the reasons given for the area’s low capability rating is that “View of, and sounds from Highway 74 are evident at times and from certain vantage points (page 283, IRA Analysis).” Not only is this criticism inappropriate, but it is important to note that some portions of the roadless area are over 2.5 miles away from these features. Response: The full text from the IRA Evaluation states “Views of and sounds from State Highway 74 are evident at times and from certain vantage points although not highly pervasive or intrusive. Roads surround the unit on all four sides.” Comment: Comment #6008-6 - The statement that there is no known scientific or education values is quite false. Response: The IRA evaluation states “There may be some unique or specific scientific or educational opportunities. See the ‘Cultural Resources’ discussion below.” Comment: Comment #6008-6 and 7- Deep Canyon is the primary stream (1.56 miles) in this unit. We agree with your statement on page 287: “While the location of Pan-ox-su remains uncertain, Yellow Body (a figure in Cahuilla mythology) and his travels remain an important part of Cahuilla history and Deep Canyon is connected to his story. Numerous archaeological sites have been recorded in this canyon. The narrative also states under “Special Features” that “Other prehistoric properties located in the area represent unique classes of sites which merit further investigations.” (page 287, IRA Analysis) As for issue number three, we fail to see why one cannot find opportunities for challenge and adventure in a 3,101 acre and 4.8 square mile area of roadless land adjacent to a large designated wilderness.. Response: The IRA evaluation states “Similarly, physical and mental challenge, a spirit of adventure and awareness, and a sense of self-reliance and inspiration are moderate. Although Cactus Springs B is relatively remote for southern California the area offers somewhat limited isolation and thus moderate adventure, excitement, challenge, initiative, and self-reliance. These feelings intensify, however, as one considers the connection to the much larger existing Santa Rosa Wilderness.” Comment: Comment #6008-64 - The IRA’s availability is rated as low because “Cactus Springs B is relatively remote for southern California the area offers limited isolation and thus low to moderate adventure, excitement, challenge, initiative, and self-reliance.

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Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Response: The IRA evaluation states “Although Cactus Springs B is relatively remote for southern California the area offers somewhat limited isolation and thus moderate adventure, excitement, challenge, initiative, and self-reliance. These feelings intensify, however, as one considers the connection to the much larger existing Santa Rosa Wilderness.” Comment: Comment #6008-65 - Secondly, the area’s availability is rated as low because “…the condition found on the majority of the project area has been characterized as a forest where the probability of a catastrophic wildfire occurring is moderate to high.” (page 288, IRA Analysis) This flies in the face of Forest Service policy and history. Response: The IRA evaluation states “Vegetative mortality has occurred in this area due to the recent drought and insects/disease. The northern boundary of this area borders the community of Pinyon Pines. The Santa Rosa Fuels Reduction Project is in the planning stages. It would reduce vegetative fuels and wildfire hazards on National Forest lands south of Highway 74 near Spring Crest, Ribbonwood Equestrian Camp, and the Santa Rosa Indian Reservation on approximately 7,116 acres. That includes a large portion of the Cactus Springs B Inventoried Roadless Area. Under the National Fire Plan and the Healthy Forest Initiative, emphasis is placed on reducing the risk of wildfire within the wild land-urban interface around communities at risk. The condition found on the majority of the project area has been characterized as a forest where the probability of a catastrophic wildfire occurring is moderate to high. See this link…” San Bernardino National Forest – Cucamonga B and C IRAs Comment: Comment #6008-12 - The Sierra Club would like to challenge the statement made on page 296 of Appendix 2 that “Some mountain biking opportunities would also be foregone with wilderness.” We know of no known existing roads or trails that will be closed for this dispersed recreation use. Response: The area includes 1.0 mile of Forest system non-motorized trail (including 0.25 miles of Trail Class 3 and 0.75 miles of Class 2). Comment: Comment #6008-15 - I would like to also challenge the statement on page 298 of Appendix 2: “Much of the Front Country Ranger District non-wilderness land encompasses similar landscapes and opportunities.” The Cucamonga B IRA is one of the most outstanding wildlands in Southern California. As one traveled once up the North Fork of Lytle Creek to explore the Cold Creek area, I could have sworn that I was hundreds of miles from civilization. Wildlife abounded the further I traveled from the Lytle Creek community. Response: The IRA evaluation states “Much of the Front Country Ranger District non- wilderness land encompasses similar landscapes. However, much of the Cucamonga B area is more distinct and unique and thus provides more opportunities for quality wilderness recreation experiences.”

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Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Comment: 6008-24 - On page 303 of Appendix 2, the false statement is made: “Some mountain biking opportunities would also be foregone with wilderness recommendation.” Certainly, the now washed out Cucamonga Truck Trail 1N34 is still open to mountain bikes and the Sierra Club knows of any Forest Service system roads or trails that would be closed by recommended this IRA as wilderness. Response: The IRA Evaluation state that “Portions of the Cucamonga Truck Trail 1N34, which is the southern boundary of much of this unit, washed out following the 2003 Grand Prix Fire. It has not been rebuilt and is closed to use public motorized use from the Forest boundary at Cucamonga Canyon to just west of Joe Elliott dispersed camping area on the east. There are 0.6 miles of Forest system road. There are 3.85 miles of Forest system non-motorized (Trail Class 2) trail. San Bernardino National Forest - Pyramid Peak Comment: Comment #6008-30 - There is one error found on page 43 of the Four Forests Plan Amendment SDEIS: (peninsular bighorn sheep). Response: The text has been corrected. San Bernardino National Forest – Raywood Flat Comment: Comment #6008-35 - The IRA’s availability is rated as low and moderate in part because “…fast, aggressive initial attacks on wildfires in this area…will be more difficult if the unit is designated as wilderness.” Response: We can’t find this text in the Raywood Flat narrative. The SEIS evaluated the effect of the various zoning alternatives and concluded that fire suppression effectiveness would not be impacted by RW zoning.

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Southern California National Forests Final Supplemental Appendix 4 Land Management Plan Amendment Environmental Impact Statement

Attachment 2 – Agency and Elected Official Letters

149

UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration

NATIONAL MARINE FISf I C I~ I [S SERVIC[ Southwest Reg1on 501 West Ocean Boulevard. SUite 4200 Long Beach Cahforn1a 90802-4213

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William Metz Forest Supervisor Cleveland National Forest I 0845 Rancho Bernardo Road, Suite 200 San Diego, California 92127-2107

Dear Mr. Metz:

NOAA's National Marine Fisheries Service (NMFS) reviewed the Draft Supplemental Environmental impact Statement (DSEIS) for the proposed Southern California Land Management Plan (LMP) Amendment (for Angeles, Cleveland, Los Padres, and San Bernardino National Forests, hereinafter termed the "Forests"). The proposed action is to amend LMP land-use zone allocations for select Inventoried Roadless Areas (IRAs) and to amend LMP monitoring and evaluation protocols . The scope of the proposed action is within the range of the endangered Southern California Distinct Population Segment (DPS) of steel head (Oncorhynchus mykiss), the threatened South-Centra l California DPS of steel head, and designated critical habitat for both species. Accordingly, the following comments on the DSEIS are provided to assist the Forests' ongoing development of land-use zones that are commensurate with the life history and habitat requirements of steel head. The comments contained herein supplement and extend NMFS' November 27, 2012, comments on the October 29, 2012, administrative DSEIS.

NMFS recognizes the Forests' Alternative 2 includes restrictive land-use zones (e.g., Back Country Non-Motorized, BCNM). This provides some level of habitat protection and remains central for improving and restoring natural watershed function and values on Forest land, which contain the majority of historicai spawning and rearing habitats for steel head. The BCNM land-use designation does limit future activities, such as roads, developed recreation, special uses, and energy developments that can impair the function and quality of essential habitats on which the life hi story and ontogeny of endangered steelhead depend. However, based on NMFS' understanding ofthe current LMP, oil development, energy development, communication facilities, mining, and disposal of national forest lands are all all owed "by exception" in the BCNM land-use zone. To further minimize impacts to steelhead and designated critical habitat, NMFS recommends the Forests develop Alternative 2 so that IRAs containing or bordering critical habitat are designated as recommended wilderness (R W). Furthermore, there is ecological value in protecting tributaries to designated critical habitat streams on Forest lands, thus NMFS recommends that the Forests designate IRAs that contain tributaries to critical habitat streams, as R W (displayed in the enclosure). 2

Specifical ly, NMFS recommends that portions of the following specific zones be designated as RW: Tequepis, White Ledge, Dry Lakes, and Sespe-Frazier (see enclosure)'.

NMFS appreciates this opportunity to review the publi caffy released DSEIS for the proposed action. Please contact Brittany Struck at 562-432-3905, or via emai I at [email protected] if you have a question concerning this letter, or if you require additional information.

Sincerely,

Penn etas Southern California Area Office Supervisor : for Protected Resources

Enclosure

cc: Alice Berg, NMFS, Sacramento Michael Kellett, USFS, Yellejo Kirsten Winter, USFS, Cleveland Kevin Cooper, USFS, Los Padres Administrative File: 151422SWR2011PR00328

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This rating system was developed as a means to summarize the U.S. Environmental Protection Agency’s (EPA) level of concern with a proposed action. The ratings are a combination of alphabetical categories for evaluation of the environmental impacts of the proposal and numerical categories for evaluation of the adequacy of the Environmental Impact Statenient (EIS).

ENVIRONMENTAL IMPACT OF THE ACTION

LO” (Lack of Objections) The EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal.

“EC” (Environmental Concerns) The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would like to work with the lead agency to reduce these impacts. “EO” (Environmental Objections.) The EPA review has identified significant environmental impacts that should be avoided in order to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.

“EU” (Environmentally Unsatisfactory) The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce these impacts. If the potentially unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be recommended for referral to the Council on Environmental Quality (CEQ).

ADEOUACY OF THE IMPACT STATEMENT

“Category 1” (Adequate) EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying language or information.

“Category 2” (Insufficient Information) The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analysed in the draft EIS. which could reduce the environmental impacts of the action. The identified additional information, data, analyses, or discussion should be included in the final EIS. “Category 3” (Inadequate) EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analysed in the draft EIS, which should he analysed in order to reduce the potentially significant environmental impacts. EPA believes that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft E1S. On the basis of the potential significant impacts involved, this proposal could be a candidate for referral to the CEQ.

*From EPA Manual 1640, Policy and Procedures for the Review of Federal Actions Impacting the Environment.

United States Department of the Interior OFFICE OF THE SECRETARY Office of Environmental Policy and Compliance Pacific Southwest Region 333 Bush Street, Suite 515 San Francisco, CA 94104

IN REPLY REFER TO: (ER 13/0091)

Filed Electronically

17 May 2013

Robert Hawkins Natural Resource Planner, Team Leader U.S. Forest Service 10845 Rancho Bernardo Road Suite 200 San Diego, CA 92127

Subject: Draft Environmental Impact Statement for the Southern California National Forests Land Management Plan, Amendment, CA

Dear Mr. Hawkins:

The Department of the Interior has received and reviewed the subject document and has no comments to offer.

Thank you for the opportunity to review this project.

Sincerely,

Patricia Sanderson Port Regional Environmental Officer cc: Director, OEPC OEPC Staff Contact: Lisa Treichel

May 16, 2013

Mr. William Metz, Forest Supervisor Cleveland National Forest Service 10845 Rancho Bernardo Road, Suite 200 San Diego, CA 92127-2107

Dear Mr. Metz:

DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT SOUTHERN CALIFORNIA NATIONAL FORESTS LAND MANAGEMENT PLAN AMENDMENT LOS ANGELES COUNTY DEPARTMENT OF PUBLIC WORKS COMMENTS

Thank you for the opportunity to review the Draft Supplemental Environmental Impact Statement (DSEIS) for the Southern California National Forests Land Management Plan Amendment. The four southern California national forests (Angeles, Cleveland, Los Padres, and San Bernadino) propose to amend the Land Management Plans (LMP’s) as they relate to the management and monitoring procedures of Inventoried Roadless Areas (IRA’s) within the forests’ boundaries and the DSEIS analyzes the proposed alternatives.

The following comments from the Los Angeles County Department of Public Works are for your consideration and relate to the environmental document only, specifically the areas contained within the Angeles National Forest:

Water Resources:

1. Due to the potential adverse impacts on Public Works’ facilities, we respectfully object to the following proposals included in the DSEIR in regards to the areas adjacent to Cogswell Reservoir and the existing Cogswell Sediment Placement Site:

a. Alternative 2 (Proposed Action) which proposes to change the land use zone in the West Fork of the San Gabriel River from “Back Country, Motorized Use Restricted (BCMUR) to Back Country, Non-Motorized (BCNM).”

William Metz May 16, 2013 Page 2

b. Alternative 3 (Recommended Wilderness Emphasis) which proposes to change the land use zone in the West Fork of the San Gabriel River from “Back Country (BC),” “BCMUR,” and “BCNM” to “Recommended Wilderness (RW).”

2. We respectfully request the following designations for the areas adjacent to Cogswell Reservoir and the existing Cogswell Sediment Placement Site:

a. The designation of “Developed Area Interface (DAI)” for the area marked as “E” on the enclosed map should appropriately reflect the current permitted use of the area as a Sediment Placement Site. The Forest Service issued a 30- year Special Use Permit in 1991 for the Sediment Placement Site. This area is defined roughly by the Cogswell Reservoir to the north, the old boundary line of Arroyo Seco and Mt. Baldy Ranger Districts to the east, Red Box Road to the west, and the ridge line extending from Red Box Road and connecting to the old boundary line of Arroyo Seco and Mt. Baldy Ranger Districts to the south.

b. The designation of “DAI” for the area marked as “R” on the enclosed map to appropriately reflect the existing permitted use of the area, which is operation and maintenance of the Cogswell Reservoir. Public Works conducts cleanout operations within this area to restore the storage capacity of the reservoir and therefore the designation must support the use of heavy equipment and trucks to remove sediment from the reservoir and transport sediment to a deposition site.

c. The designation of “DAI” for the area marked as “N” on the enclosed map, which is determined to be the site of a potential new Sediment Placement Site. This area was determined to have approximately 100 years of sediment capacity for cleanout operations of the Cogswell Reservoir. This area is roughly defined by the Cogswell Reservoir to the north, Area “E” to the east, Red Box Road to the south, and the ridgeline connecting Red Box Road and the Cogswell Reservoir to the west.

3. Alternatives 2 and 3 as proposed in the DSEIS may have adverse impacts on the long-term operation and maintenance of the Cogswell Dam and Reservoir, which provides vital regional flood protection, sediment management, regional water supply, and habitat preservation as well as recreational benefits. The following sub-sections describe these potential impacts.

William Metz May 16, 2013 Page 3

3.1 Impacts to Regional Flood Protection:

a. Existing roads and trails in the areas of the San Gabriel River West Fork River downstream of the Cogswell Dam must continue to allow motorized access by Public Works. Any proposal to change the land use zone to a more restrictive designation may interfere with the access and therefore the operation and maintenance of the Cogswell Dam and Reservoir.

b. Cogswell Dam and Reservoir are vital components of the San Gabriel Canyon regional flood protection system. The capacity of Cogswell Reservoir is nearly 12,000 acre-feet. Along with the San Gabriel and Morris Dams and Reservoirs, the dams and reservoirs in San Gabriel Canyon need to provide a minimum of 50,000 acre-feet of water storage for flood attenuation to meet the Los Angeles County Drainage Area (LACDA) requirements enforced by the United States Army Corps of Engineers (Corps).

If the operation of Cogswell Dam and/or the ability to clean out Cogswell Reservoir is impacted by a restrictive designation, meeting the LACDA requirements would be completely dependent on San Gabriel and Morris Reservoirs. If operation or maintenance problems or restrictions develop at either of the remaining two facilities, the LACDA requirements will not be met. This is a very real concern, as restrictions to protect the Santa Ana Sucker at San Gabriel Reservoir already impact the amount of time available for storage capacity restoration at the Reservoir.

Therefore, the loss of Cogswell Reservoir and potential noncompliance with the LACDA flood attenuation requirements could severely impact flood protection along the San Gabriel River (including the Corps’ Santa Fe Dam and Whittier Narrows Dam), the lower Rio Hondo River and the Lower Los Angeles River.

In addition, communities that have previously been removed from the mandatory flood insurance zones by the $212 million LACDA Project, completed in 2002, may have to be reevaluated for inclusion in the mandatory insurance zones, which would result in millions of dollars in additional insurance premiums to residents within these areas. The LACDA Project was designed to prevent an estimated $2.3 billion in William Metz May 16, 2013 Page 4

flood damages, affecting 14 communities and over 500,000 people, living within the 100-year floodplain.

3.2 Impacts to Sediment Management:

a. Significant volumes of sediment and debris, particularly after wildfires, accumulate in Cogswell Reservoir and diminish its flood control and water conservation capacity. Periodically this sediment must be removed. Due to the 2009 Station Fire, the sediment accumulated in Cogswell Reservoir has resulted in the need for a cleanout that is anticipated to fill the capacity of the existing Cogswell Sediment Placement Site covered under the 1991 Special Use Permit.

Given the remote location of Cogswell Dam and Reservoir and the difficulty of access, trucking sediment would be costly and require heavy truck traffic through the forest. The Forest Service has expressed concerns about trucking’s potential impacts to recreation and aesthetics along established recreational roads and trails. There have also been significant stakeholder and regulatory objections to removing sediment by means of sluicing down the West Fork. There have also been concerns expressed by the Forest Service about potential impacts from placing a sediment slurry pipeline down the West Fork. Therefore additional sediment placement sites along the south slopes of Cogswell Reservoir will need to be eventually developed in order to continue to operate and maintain the reservoir over the long term.

b. If the reservoir fills up with sediment and land use zoning restrictions on potential sediment placement and transport effectively precludes Public Works from cleaning it out, the California Division of Safety of Dams will likely require Public Works to decommission the dam to comply with the State’s seismic stability requirements. Beyond the loss of the flood protection and water conservation benefits, decommissioning is costly. The cost for a similar decommissioning action at Big Tujunga Dam was estimated several years ago to be approximately $40 million.

c. In 1991 the Forest Service issued a 30-year Special Use Permit for the present Cogswell Sediment Placement Site because it was determined in the Forest Service’s Environmental Assessment that the sediment placement site is the least environmentally damaging alternative for sediment management at the Cogswell Dam and Reservoir. The William Metz May 16, 2013 Page 5

Forest Service’s July 23, 1990 Decision Notice/Finding of No Significant Impact (DS/FONSI) made the following points in justifying the use of a sediment placement site adjacent to Cogswell Reservoir:

i. Objectives of recreation use, wildlife habitat, and fish habitat, will be maintained, as identified in the [1987] Angeles National Forest Land and Resources Management Plan.

ii. It is important for the safety of downstream areas in the community areas for this reservoir to be fully functional as a flood control reservoir.

iii. Clean out of the reservoir will allow flexibility for operations in the event an earthquake damages one of the other dams in the system, or their valves.

iv. Better control of water during major storms, which might threaten overtopping of Morris Reservoir.

v. Enhanced water quality in the West Fork below the dam by controlled release of clean water.

vi. By keeping the activity confined to the watershed of Cogswell Reservoir, any unforeseen events that might affect sediment site will be confined to the existing reservoir.

vii. Impacts on recreational use of the West Fork area will be minimized. I [the USFS Arroyo Seco District Ranger] did not want to have either a [sediment slurry] pipeline, nor major truck traffic be associated with the National Bicycle Trail, which is the road to the reservoir.

The factors cited by the USFS’s 1990 DN/FONSI for sediment management at Cogswell were re-affirmed in the Corps’ 1997 Record of Decision for the San Gabriel Canyon Sediment Management Plan.

d. Public Works acknowledges that changes in the land use zone designations will not in itself allow immediate use of additional areas upstream of Cogswell Dam and Reservoir for sediment disposal. We understand that compliance with National Environmental Policy Act and William Metz May 16, 2013 Page 6

California Environmental Quality Act as well as acquisition of several Federal and State permits will be required.

3.3 Impacts to Regional Water Supply:

a. Cogswell Dam and Reservoir are vital components of the water supply system in the San Gabriel River watershed. Water from Cogswell Reservoir is used to supply millions of residents and businesses in the San Gabriel Valley and the coastal plain down to Long Beach. These inhabitants receive the water in the form of surface diversions or pumping from the groundwater basins that are fed by the San Gabriel River (Upper and Lower San Gabriel Canyon Basins, Main San Gabriel Basin, Central Basin, and West Coast Basin).

Given the environmental restrictions imposed at the sources of imported water during even the best of water years, the region may not be able to import enough water to compensate for the loss of storage at Cogswell Dam and Reservoir in the event the facility cannot be maintained or operated as needed to provide the water to the water rights holders and residents of the service area.

3.4 Impacts to Habitat Preservation and Recreational Benefits:

a. Cogswell Dam and Reservoir are vital to maintaining the biological and recreation values the Forest Service and the parties suing the agency intend to protect.

b. Restrictions on flood control releases and/or reservoir cleanouts as a result of designating a more restrictive land use zone may increase the potential for uncontrolled spillway flows at the Cogswell Dam. Uncontrolled flows will likely cause washouts of the West Fork Road and adversely impact dam operations, water conservation releases, aquatic habitat, and recreational access in the West Fork. West Fork Road is open to recreational bicyclists. Increasing the frequency of washouts will lead to increased maintenance costs to Public Works and the Forest Service, assuming funding is available and restrictions do not prevent road repairs.

c. Restrictions on dam operations and sediment removal, transport, and disposal may also reduce and possibly eliminate the water storage capacity needed to implement the instream flow recommendations of William Metz May 16, 2013 Page 7

the West Fork Long Term Management Plan (West Fork Plan). Since 1989, Public Works has operated Cogswell Dam in accordance with the West Fork Plan, a cooperative agreement among several entities that, along with us, comprise of the West Fork Working Group, including the Forest Service, the Main San Gabriel Basin Watermaster and other local water users, and the California Department of Fish and Wildlife and California Trout. The West Fork Plan includes instream flow recommendations for the health and benefit of the biological resources in the West Fork, among which are the Santa Ana sucker, arroyo chub, Santa Ana speckled dace, rainbow trout, and the southwestern pond turtle.

d. The West Fork Plan and its signatories acknowledged the Cogswell Dam and Reservoir need to be maintained and periodically cleaned out for the purpose of flood protection and water supply to Los Angeles County residents as well as accommodating the West Fork Plan’s instream flow recommendations. It should be noted that natural inflows into the Cogswell Reservoir often do not meet the West Fork Plan’s flow recommendations. Inflow and rainfall data from the 1930s through the 1990s indicate that the inflow into Cogswell Reservoir met the West Fork Plan’s instream flow recommendations in only 6 years out of the 60-year period. Natural inflows into Cogswell Reservoir have been observed to drop down to zero during the increasingly frequent dry summers.

For questions regarding the Water Resources comments, please contact Jolene Guerrero of Watershed Management Division at (626) 458-4364 or [email protected].

Transportation:

1. According to the DSEIS, there are only 0.3 miles of County road in the Planning Area of the Angeles National Forest (refer to table 99 on page 238, table 102 on page 239, and table 105 on page 241). Additionally, pages 99, 237, and 243 of the document suggests there might be closures of County roads as a result of this amendment, however it does not specifically indicate which roads would be closed or affected. The Supplemental Impact Statement should specify what County roads are scheduled for closure or are being restricted in some manner so that the potential impacts to facility operations and maintenance can be evaluated. William Metz May 16, 2013 Page 8

2. The County currently maintains and inspects existing bridges located on Lake Hughes Road and West Fork Road and therefore these roads shall be excluded from any closures or restrictions that would prohibit access to said bridges so that these activities can occur. Figure 4 on page 34 shows an overview map of the Angeles National Forest however it could not be determined from looking at this map or any other information within the DSEIS (the Angeles National Forest - North Maps could not be downloaded from http://www.fs.fed.us/nepa/fs-usda- pop.php?project=35130) if Lake Hughes Road and West Fork Road are located within an IRA. Regardless, Lake Hughes Road shall be excluded from the Fish Canyon, Tule, and Red Mountain IRA’s and West Fork Road shall be excluded from the West Fork and the Westfork IRA’s.

3. Page 14 of the DSEIS, states, “Motorized access on existing authorized roads and trails was maintained, with 100 foot buffers applied along county and forest roads, and 300 foot buffers applied along state highways.” Lake Hughes Road and San Francisquito Canyon Road appear to have a buffer of 100 feet applied, which keeps the entire right-of-way out of Back Country Non-Motorized or Wilderness designations. Both of these roadways have sections of easement or special use permitted with the USFS for maintenance of the roads at a 100 foot width. The SEIS should disclose/verify that the 100 foot buffer proposed is for 100 feet on either side of the road so the 100-foot width of current USFS permitted use for both roadways will be covered in the Developed Area Interface (DAI) zones.

For questions regarding Transportation comments No. 1 and 3, please contact Ron Castaneda of Road Maintenance Division at (661) 947-7173 or [email protected].

For questions regarding Transportation comments No. 2, please contact David Sharkey of Road Maintenance Division at (562) 622-5813 or [email protected].

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105 East Anapamu Street, Room 406 Chandra L. Wallar Santa Barbara, California 93101 County Executive Officer 805-568-3400 • Fax 805-568-3414 www.countyofsb.org

Executive Office

May 16, 2013

Mr. William Metz, Forest Supervisor Cleveland National Forest Service 10845 Rancho Bernardo Road, Suite 200 San Diego, CA 92127-2107

E-mail: [email protected]

RE: Draft Supplemental Environmental Impact Statement Southern California National Forests Land Management Plan Amendment

Dear Mr. Metz:

Thank you for the opportunity to comment on the Draft Supplement Environmental Impact State Southern California National Forests Land Management Plan Amendment. At this time, the County submits comments from the Planning and Development Department.

The County looks forward to future analysis and outcomes for this project. If you should have further questions, please do not hesitate to contact my office directly or Glenn Russell, Director, Planning and Development Department, at 805-568-2085.

Sincerely,

Chandra L. Wallar County Executive Officer

Cc: Glenn Russell, Director, Planning and Development Department

Encl: Planning and Development Department letter, May 14, 2013

Renée E. Bahl Terri Maus-Nisich Dennis Bozanich Assistant County Executive Officer Assistant County Executive Officer Assistant to the County Executive Officer [email protected] [email protected] [email protected]

RESOURCE MANAGEMENT AGENCY Planning Division Kimberly L. Prillhart county of ventura Director

May 16,2013

Cleveland National Forest Attn.: LMP Amendment 10845 Rancho Bernardo Road, Ste. 200 San Diego, CA 92127-2107

E-mail : socal_nf_lmp_amend [email protected]. us

Subject: Comments on the DSEIS, Southern California National Forests Land Management Plan (LMP) Amendment

To Whom lt May Concern:

Thank you for the opportunity to review and comment on the subject document. Attached are the comments that we have received resulting from intra-county review of the subject document. Additional comments may have been sent directly to you by other County agencies.

Your proposed responses to these comments should be sent directly to the commenter, with a copy to Laura Hocking, Ventura County Planning Division, L#1740, 800 S. Victoria Avenue, Ventura, C 93009. lf you have any questions regarding any of the comments, please contact the appropriate respondent. Overall questions may be directed to Laura Hocking at (805) 654-2443.

Sincerely,

þa, T Maier, Manager Planning Programs^4 Section

Attachments

County RMA Reference Number 13-008

800 South Victoria Avenue, L# 1740, Ventura, CA 93009 (805) 654-2481 Fax (805) 654-2509 @ Pilnted on Recycled Paper PUBLIC WORKS AGENCY TRANSPORTATION DEPARTMENT Traffic, Advance Planning & Permits Division MEMORANDUM

DATE: March 7,2013 TO RMA - Planning Division Attention: Laura Hocking

FROM: Transportation Department

SUBJECT: REVIEW OF DOCUMENT 13-008 Draft Supplemental Environmental lmpact Statement (DSEIS) Project: Southern California National Forests Land Management Plan (LMP) Amendment Lead Agency: USDA, Forest Seruice Proposed amendment to revise Land Use Zone (LUZ) allocations for select lnventoried Roadless Areas (lRAs) within four national forests in Southern California.

Pursuant to your request, the Public Works Agency - Transportation Department has completed the review of the above subject document.

This project is a proposed amendment to Land Management Plans (LMPs) in four Southern California National Forests (the Angeles, Cleveland, Los Padres, and San Bernardino National Forests). The LMPs were adopted in 2006 and allocated lands within lnventoried Roadless Areas (lRAs) to various Land Use Zones (LUZs) based on wilderness evaluations. There was a lawsuit overthe revised LMPs. This amendment is a result of the Settlement Agreement (SA) approved in January 2011.

There are three alternatives considered in the DSEIS. Alternative #1 is the "No Action" alternative. Alternative #2 is the "Proposed Action" that resulted from the SA. This alternative would rezone a majority of the LUZs within the lRAs to Back County Non- Motorized (BCNM) and/or Recommended Wilderness (RW). Alternative #3, if chosen, would rezone more lRAs to the RW designation. According to Tables 119 and 120 on Pages 280 and 281 of the DSEIS, the totalfederalwilderness acreage in Ventura County would increase lrom 278,166 acres to 402,804 acres or 48o/o to 70o/o of 574,420 acres in federal lands (Bureau of Land Management, Forest Service, Fish and Wildlife Service, and National Park Service).

Table 45 on Page 99 of the DSEIS indicates that there are2.9 miles of County roads in the Los Padres National Forest that could be affected (potentially closed) by the proposed action. lt is not clearwhetherthese roads are in the County of Ventura; therefore we would offer the following comment: lf the proposed action will have an impact on Ventura County roads, in particular, but not limited to, Boy Scout Camp Road, Camino Cielo, Rice Road, Lockwood Valley Road, Piru Canyon Road, and/or Matilija Road, then the Transportation Department would like to review and comment on the proposed action.

Our review is limited to the impacts this project may have on the County's Regional Road Network.

F:\transpor\LanDev\Non_County\1 3-008 (USDA),doc

Hello, Mr. Bob Hawkins, Project Manager:

The City has reviewed the above-noted document. The following statement from the Rancho Cucamonga Engineering Department and the attached document from the Rancho Cucamonga Fire Protection District are the Cityâ€™s comments relating to that document.

Rancho Cucamonga Engineering Services Department - The National Forest Service should consider repairing the portions of Cucamonga Truck Trail 1N34 that were washed out, to improve emergency access for fire suppression and rescue purposes. Improved public access to Cucamonga Canyon could also reduce the necessity for rescue since hiking will likely continue whether or not the routes are safe.

If you have any questions, please contact me. Thanks.

Mike Smith

Associate Planner

City of Rancho Cucamonga

10500 Civic Center Drive

Rancho Cucamonga, CA 91730

(909) 477-2750 ext. 4317

[email protected]

file:///C|/AMSET_Projects/CNF_socal_IRA/DSEIS_response_to_comments/gov_ltrs/8818_rc_city.txt[9/20/2013 8:21:06 AM]

RANCHO CUCAMONGA

F IRE PROTECTION DISTRICT PREVENTION BUREAU

May 16, 2013

Mr. William Metz, Forest Supervisor Cleveland National Forest Service 10845 Rancho Bernardo Road, Suite 200 San Diego, CA 92127-2107

Re: Draft Supplemental Environmental Impact Statement Southern California National Forests Land Management Plan Amendment

Mr. Metz,

The Rancho Cucamonga Fire Protection District has had the opportunity to review the Draft Supplemental Environmental Impact Statement Southern California National Forests Land Management Plan Amendment (SEIS). Of particular interest to the Fire District are the alternatives under consideration for the areas designated as Cucamonga B and Cucamonga C.

The Fire District supports Alternative 3, which is the Recommended Wilderness Emphasis for the Cucamonga B and Cucamonga C areas.

The Cucamonga Canyon watershed and Cucamonga Creek are important and valuable water resources for the City of Rancho Cucamonga and nearby communities. The canyon in recent years has seen increased use as a recreational area due, in large part, to social media making a wider percentage of the southern California population aware of an area in the canyon that has come to be known as Sapphire Falls. This recreational use is noted in Appendix 2 of the SEIS.

In the past 12 months, the Fire District has responded 22 times to Cucamonga Canyon to rescue people who have become trapped in the canyon. In the recent past, two visitors to the canyon have fallen to their deaths. The rescues and the deaths resulted from unrestricted and ill-advised access to dangerous areas of the canyon.

OVER

10500 Civic Center Drive • Rancho Cucamonga, CA 91730 • 909-477-2770

In addition to the health and life safety concerns that exist in Cucamonga Canyon, the environmental damage being done to the canyon and the adverse impact to the water resources are a concern to the Fire District. The canyon walls are a favorite target of spray paint graffiti. Trash and other debris regularly find their way into Cucamonga Creek. The Fire District has a vested interest in protecting the canyon’s vital water supply to the community and is a supporter of a healthy community and environment.

As mentioned in the Wilderness Section on page 228 of the SEIS, a Wilderness designation for Cucamonga C will “generally allow natural processes to occur with few restrictions or restraints. When management actions are taken, the most common type of wilderness management is the control of visitation and recreation.” Such management would greatly benefit Cucamonga Canyon, its environment, and the watershed and would provide a higher level of public safety for an area with a history of injury and death to those who are unfamiliar with the area and its terrain.

For these reasons, the Rancho Cucamonga Fire Protection District supports Alternative 3 of the SEIS for areas Cucamonga B and Cucamonga C.

Respectfully submitted,

Mike Bell Fire Chief

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