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August 25, 2016 Forest Planner, Forest Plan Revision USDA Forest

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August 25, 2016 Forest Planner, Forest Plan Revision USDA Forest August 25, 2016 Forest Planner, Forest Plan Revision USDA Forest Service, Region 5 Sent via: [email protected] Re: Comments on the Draft Environmental Impact Statement for Revision of the Inyo, Sequoia, and Sierra National Forests Land Management Plans To the Forest Plan Revision Team: These comments on the Draft Forest Plans and Draft Environmental Impact Statement for Revision of the Inyo, Sequoia, and Sierra National Forests Land Management Plans are submitted on behalf of the organizations noted below. Collectively, we have been engaged in the forest plan revision process for these three national forests since initiated in 2012. Many of our organizations also have a long history of engagement in forest planning beginning with the first plans adopted in the late 1980s to early 1990s for national forests in the Sierra Nevada. We have embraced the new Planning Rule and taken seriously its invitation to provide feedback early in the process and throughout the development of the revised plans. We remain committed to working with your agency to develop revised forest plans that protect sensitive resources, provide for ecological integrity, and provide high quality recreational experiences. Our detailed review of the draft plans and DEIS indicate that there are significant gaps in assessment, development of plan components and evaluation of environmental consequences that preclude a meaningful analysis of the effects of the draft plans and alternatives on the environment. We ask that you revise the draft plans and revise or supplement the DEIS and circulate these documents for a 90-day comment period. Please contact Susan Britting (530-295-8210; [email protected]) if you have questions about these comments. Sincerely, Susan Britting, Ph.D. Stan VanVelsor, Ph.D. Executive Director Regional Conservation Representative Sierra Forest Legacy The Wilderness Society Ryan Henson Senior Policy Director CalWild/California Wilderness Coalition Ben Solvesky Wildlife Ecologist Sierra Forest Legacy John Buckley Executive Director Darca Morgan Central Sierra Environmental Resources Consulting Wildlife Biologist Center Sierra Forest Legacy Greg Suba Craig Thomas Conservation Director Conservation Director California Native Plant Society Sierra Forest Legacy Karen Schambach President Center for Sierra Nevada Conservation Peter Nelson Senior Policy Advisor for Federal Lands Defenders of Wildlife Frances A. Hunt Eastern Sierra Organizer Pamela Flick Sierra Club California Representative Defenders of Wildlife Alan Carlton Sierra Nevada Team Leader, Sierra Club Steve Evans Wild & Scenic River Consultant Friends of the River Malcolm Clark Range of Light Group (Toiyabe Chapter) Sierra Club SFL et al. Comments on the DEIS for draft forest plans on the Inyo, Sequoia, and Sierra national forests (August 25, 2016) 2 Trudy L. Tucker National Forest Chair Tehipite Chapter, Sierra Club Jerry Bloom Science Director Forest Issues Group Joe Fontaine Kern-Kaweah Chapter, Sierra Club Lisa Cutting Eastern Sierra Policy Director Mono Lake Committee Michael J. Connor, Ph.D. California Director Jenny Hatch Western Watersheds Project Executive Director Sierra Nevada Alliance Patricia Puterbaugh Don Rivenes Lassen Forest Preservation Group Conservation Director Sierra Foothills Audubon Society SFL et al. Comments on the DEIS for draft forest plans on the Inyo, Sequoia, and Sierra national forests ( August 25, 2016) 3 Table of Contents I. Major Themes and Issues....................................................................................... 7 A. The DEIS is Inadequate and Must be Revised ............................................ 7 B. The Draft Plans are Inadequate and Must be Revised. ................................ 9 C. Recent and Ongoing Tree Mortality ........................................................... 10 D. “Flexible Forest Plans” Lead to Unacceptable Uncertainty ......................... 11 E. Management Areas Not Properly Identified in Draft Plans ......................... 15 F. Documentation and Use of Best Available Science Information ................. 16 II. Terrestrial Ecosystems ........................................................................................... 17 A. Fire: Beneficial Disturbance Process or Threat? ......................................... 18 B. Assumptions in the Analysis Not Clearly Described ................................... 19 C. Assumptions in the DEIS Not Supported By the Draft Plans or 24 Alternatives ................................................................................................ 21 D. Restored Condition Not Consistently or Clearly Defined ............................ 24 E. Claims about the Overabundance of Large Trees Are Not Supported by Data and Are Contrary to Available Data ................................................... 25 F. Method Used to Set Restoration Acreage Not Defined ............................... 27 G. Defining the Spatial Locations of Moist and Dry Mixed Conifer ................ 27 H. Lack of Clarity in Some Plan Components ................................................. 28 I. Old Forests................................................................................................. 29 J. Complex Early Seral Forests ...................................................................... 31 III. Aquatic and Riparian Ecosystems .......................................................................... 44 A. Meadow Ecosystems .................................................................................. 44 B. Critical Aquatic Refuges ............................................................................ 51 C. Water Drafting Standards in the Existing Sierra Forest Plan ....................... 52 D. Priority Watersheds Are Not Identified in the Plan ..................................... 53 E. Range Management, Affected Species, and Affected Water Resources ...... 53 IV. Wildlife, Fish and Plants ........................................................................................ 69 A. Major Themes and Issues ........................................................................... 69 B. Regional Forester Sensitive Species Program and Species of Conservation Concern ..................................................................................................... 79 C. At-risk Species Inappropriately Excluded from Species of Conservation Concern List ......................................................................... 84 D. California Spotted Owl .............................................................................. 98 E. Pacific Fisher ............................................................................................. 116 F. Sierra Marten ............................................................................................. 123 G. Sierra Nevada Bighorn Sheep..................................................................... 127 H. Mule Deer .................................................................................................. 128 SFL et al. Comments on the DEIS for draft forest plans on the Inyo, Sequoia, and Sierra national forests (August 25, 2016) 4 I. California Condor ...................................................................................... 129 J. Willow Flycatcher ...................................................................................... 135 K. Great Gray Owl .......................................................................................... 151 L. At-Risk Sub-Alpine Carnivores: Sierra Nevada Red Fox and Wolverine .... 169 M. Amphibians Affected by Grazing Management and Livestock Impacts ...... 174 N. Yosemite Toad ........................................................................................... 184 O. Bi-State Sage Grouse ................................................................................. 189 P. At-Risk Plants ............................................................................................ 193 V. Soil Quality ........................................................................................................... 203 VI. Fire Management and Air Quality .......................................................................... 204 A. Fire Management ....................................................................................... 204 B. Air Quality ................................................................................................. 219 VII. Sustainable Recreation ........................................................................................... 225 A. Recreation Opportunity Spectrum .............................................................. 226 B. Management of Over-Snow Vehicle Use .................................................... 230 C. Management of Mechanized Uses .............................................................. 239 D. Tree Mortality ............................................................................................ 239 VIII. Wild and Scenic Rivers.......................................................................................... 239 A. Inyo Draft Plan .......................................................................................... 239 B. Sequoia Draft Plan ..................................................................................... 243 C. Sierra Draft Plan ........................................................................................ 246 IX. Wilderness Recommendations ..............................................................................
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