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SFL Et Al. Objection to the Inyo Revised Forest Plan (10/3/18) Fran Hunt Eastern Sierra Organizer Sierra Club

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SFL Et Al. Objection to the Inyo Revised Forest Plan (10/3/18) Fran Hunt Eastern Sierra Organizer Sierra Club October 3, 2018 Barnie Gyant Objection Reviewing Officer Pacific Southwest Region USDA Forest Service 1323 Club Drive Vallejo, CA 94592 Submitted via: [email protected] Re: Objections to the Inyo National Forest Plan Revision and Species of Conservation Concern Dear Mr. Gyant: Pursuant to 36 CFR Part 219 Subpart B, Sierra Forest Legacy, California Wilderness Coalition, The Wilderness Society, Friends of the Inyo, California Native Plant Society, Mono Lake Committee, Western Watersheds Project, Defenders of Wildlife, Sierra Club, Center for Sierra Nevada Conservation, Lassen Forest Preservation Group, and Forest Issues Group are objecting to portions of the Draft Record of Decision, Final Forest Plan, and Final Environmental Impact Statement for the Inyo National Forest. The responsible official for the Inyo plan revision is Tammy Randall-Parker, Forest Supervisor, Inyo National Forest. We are also objecting to the list of Species of Conservation Concern adopted by Regional Forester Randy Moore. Collectively, the objecting organizations have provided substantive formal comments throughout the forest planning process for the Inyo National Forest on the objection issues we raise below. We are deeply invested in securing a forest plan for the Inyo National Forest that protects important natural resources and provides for people. This objection covers a variety of issues related to resources affected by the revised forest plan and offers recommendations on how objection issues could be resolved. We appreciate the opportunity for review and possible resolution of issues contained in this objection prior to the approval of the final plan. We look forward to an opportunity to discuss our concerns with you. Sincerely, Susan Britting Lead Objector Sierra Forest Legacy [email protected] PO Box 377, Coloma, CA 95613 SFL et al. Objection to the Inyo Revised Forest Plan (10/3/18) Fran Hunt Eastern Sierra Organizer Sierra Club Malcolm Clark Range of Light Group, Toiyabe Chapter Sierra Club Karen Schambach Executive Director Center for Sierra Nevada Conservation Steve Evans California Wilderness Coalition (CalWild) Laura Cunningham California Director Western Watersheds Project Jora Fogg Policy Director Friends of the Inyo Pamela Flick Senior California Representative Defenders of Wildlife Greg Suba Conservation Director California Native Plant Society Lisa Cutting Eastern Sierra Policy Director Mono Lake Committee Mike Anderson Senior Policy Analyst The Wilderness Society Don Rivenes Executive Director Forest Issues Group Trish Puterbaugh Lassen Forest Preservation Group SFL et al. Objection to the Inyo Revised Forest Plan (10/3/18) Contents I. Wilderness Recommendations .........................................................................................4 II. Inventoried Roadless Areas ........................................................................................... 24 III. Winter Recreational Opportunity Spectrum ................................................................... 26 IV. Northern Goshawk Should be A Species of Conservation Concern ................................ 33 V. At-Risk Wildlife Species ............................................................................................... 38 VI. Eligibility Determinations for Wild and Scenic Rivers ................................................... 53 VII. Meadows and Fens ........................................................................................................ 60 VIII. Complex Early Seral Forests .......................................................................................... 64 IX. At-Risk Plant Species .................................................................................................... 66 X. Restoring Fire As A Beneficial Ecological Disturbance ................................................. 68 XI. References ..................................................................................................................... 69 Attachment A: Evaluation of Underrepresented Ecosystem Types ............................................ 72 Attachment B: Habitat Conditions for California Spotted Owl .................................................. 75 SFL et al. Objection to the Inyo Revised Forest Plan (10/3/18) Objection Issues and Recommended Resolutions I. Wilderness Recommendations Introduction The opportunity to recommend wilderness designations is an integral component of the forest planning process and presents a rare opportunity to provide administrative protection to some of the most spectacular and ecologically important undeveloped lands on our national forests. These areas provide our drinking water, habitat for imperiled wildlife, physical, mental, and spiritual renewal for millions of Americans, and a buffer to the impacts of climate change. Thus, we are disappointed that only four additions to existing wilderness areas on the Inyo National Forest are recommended for wilderness designation in the Final Plan and Draft Record of Decision. While highly deserving of wilderness recommendation, those 37,039 acres represent only about 6 % of the final 614,516-acre inventory of wilderness-quality lands on the Inyo. By contrast, Alternative C would recommend 325,352 acres (about 53% of the final inventory), including many of the most deserving areas. For the reasons described below, the Record of Decision for the final plan should adopt Alternative C’s recommended wilderness to promote the forest’s ecological health and integrity, opportunities for sustainable recreation, and protection of imperiled species, among other social and ecological benefits. Prior Comments on Recommended Wilderness Issues We have previously raised the Recommended Wilderness issues contained in this objection in our extensive comments on the Draft Plan and DEIS1, which included an exhibit containing numerous other comment letters and input previously submitted during the wilderness inventory and evaluation process on the Inyo (and on the Sierra and Sequoia National Forests, at earlier stages of the process).2 In some instances, however, the Draft Record of Decision, Final Plan, and FEIS have presented new information and rationales relating to Recommended Wilderness, which has required us to newly address the issues in this objection. Summary of Objection Points in this Section: A. Many areas deserving wilderness protection are not recommended due to a flawed evaluation and analysis process that illegally biased the outcome. 1 Sierra Forest Legacy, et al., Comments on Draft Plan and DEIS, (August 25, 2016). 2 The Wilderness Society, et al., Comments on Ch. 70 wilderness evaluation process (Oct. 30, 2014) (identifying numerous deficiencies with the “Wilderness Evaluation Narrative Outline”) (Exhibit IX.1); The Wilderness Society, et al., Comments on Ch. 70 wilderness evaluation (June 3, 2015) (identifying process and range of alternatives deficiencies) (Exhibit IX.2); The Wilderness Society, et al., Comments on Ch. 70 wilderness evaluation (Aug. 28, 2015) (identifying numerous deficiencies with the wilderness evaluation process paper) (Exhibit IX.3); The Wilderness Society, et al., Comments on wilderness evaluation process (Dec. 1, 2015) (reiterating our process and range of alternatives concerns) (Exhibit IX.4); California Wilderness Coalition, Comments on early adopter forests wilderness evaluation process (Dec. 1, 2015) (providing site-specific comments on the evaluation of specific areas) (Exhibit IX.5); The Wilderness Society, et al., Comments on wilderness evaluation process and areas identified for DEIS analysis (Feb. 1, 2016) (identifying deficiencies in application of wilderness evaluation criteria, identification of areas to carry forward for analysis, and range of alternatives) (Exhibit IX.6). SFL et al. Objection to the Inyo Revised Forest Plan (10/3/18) 1. The Draft ROD misreads the Wilderness Act’s definition of wilderness 2. Consideration of ecological representation is misrepresented 3. The Draft ROD relies on the inaccurate assumption that at-risk species restoration cannot occur in Recommended Wilderness. 4. Wilderness analysis process lacks consistency and scientific credibility. 5. Wilderness suitability is not properly considered, resulting in tainted analysis and wilderness recommendations. 6. The FEIS and Draft ROD fail to take a hard look at the ecological benefits of recommended wilderness in violation of the National Environmental Policy Act. 7. The FEIS and Draft ROD fail to use the best available scientific information regarding wilderness benefits, in violation of the 2012 Planning Rule. 36 C.F.R. 219.3. 8. The Forest Service should adopt a strengthened Alternative C for recommended wilderness. B: Management of Recommended Wilderness C: The FEIS fails to analyze a reasonable range of alternatives for Recommended Wilderness Areas. A. Many areas deserving wilderness protection are not recommended due to a flawed evaluation and analysis process that illegally biased the outcome. The Draft Record of Decision recommends four areas totaling 37,029 acres for inclusion in the NWPS: South Sierra Addition (17,622 acres), Piper Mountain Addition 1 (11,840 acres), White Mountains Addition West (5,062 acres), and White Mountains Addition East (2,505 acres). The areas recommended in the preferred alternative (B-modified) are all adjacent to existing wilderness managed by the Inyo National Forest or the Bureau of Land Management. The four recommended areas represent only 6% of
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