Chetco Bar Fire Salvage Project Comment Analysis
Response and Concern Status Report
Generated: 6/22/2018 12:48 PM Project: Chetco Fire Salvage Project (53150)
Comment Period: Other - 30-Day Comment and ESD Comment Period
Period Dates: 4/16/2018 - 5/16/2018 and 5/18/2018 - 6/18/2018
Name Comment Text Response Text
Comment #
ESD Comments Received 5/18/2018 - 6/18/2018
Vaile, Joseph 1-2 An ESD may prove counterproductive to the goals of the agency, if it The Forest Service has been engaging the public in a robust and thorough process since the prevents meaningful mitigation measures to the proposed action. The Chetco Bar fire began. Refer also to the response to comment 1-1 for more information on use of the ESD may prevent the Forest Service from engaging the public design criteria and evaluation for feasibility. in a robust and thorough planning process that could be accomplished through an objection process.
Page 1 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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1-5 Please note that the discussion of the agency's desire for an ESD at page The EA states "An additional consideration is the health and safety of forest visitors and 2-6 of the Chetco Bar Fire Salvage EA makes reference to a concern for nearby private landowners due to numerous dead trees, as well as Forest Service staff and "the health and safety of forest visitors." We wholeheartedly agree that forest industry workers working in the Chetco Bar Fire Salvage project area. Traveling or this is a legitimate concern. Yet, the roadside hazard tree projects working in forests where the majority of trees have been killed by fire is inherently addressing health and safety concerns have already been approved and dangerous. By delaying the sale date until late October of 2018 or later, there would be an are currently being implemented in the fire area. The pending ESD increased risk to forest visitors, nearby private landowners, Forest Service staff, timber request deals specifically with unit salvage logging, not with safe fallers and/or equipment operators in the project area. This is due to the ongoing ingress, or travel in the planning area. deterioration of snags because of increased defect, weathering agents, over-wintering, and other environmental factors. Snags that would be felled in the summer of 2018 for timber harvest would have fewer defects and provide less relative risk to forest workers." Additionally the ESD describes that "high densities of standing snag hazards would pose a safety risk to forest users, nearby private landowners, and fire fighters in the future. Snags can fall at any time, posing a continued threat to people working and recreating in the forest. Hazards to crews working to reforest burned areas and crews conducting future fire suppression are also a concern. While not all dead trees would be salvaged within the proposed units, safety hazards to work crews conducting tree planting and fire suppression would be substantially mitigated by salvage tree removal. Areas not treated along private land boundaries would leave high densities of standing snag hazards which could pose a safety risk to private land owners. Future fire starts may occur in the area and suppression activities would be dictated by the snag loading of the area and safety risks to fire fighters working in the area. Areas not treated along private land boundaries would increase these safety risks and make suppression activities along private land boundaries problematic in the future."
1-4 Specifically, we remain concerned with streamside protection and the The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical need for input from the National Marine Fisheries Service to develop habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the meaningful avoidance and mitigation strategies. Our desire is to ensure action alternatives, then no cumulative effects can occur from the proposed activities. protection for clean water and salmonids. Likewise, we urge the Forest 1-1 We appreciate the Forest Service focusing some of the post fire logging Thank you for your comment, we understand your concerns. We are confident the proposed in this project in previously managed plantations and in areas evaluation for feasibility described in the EA, Chapter 1 and the design criteria described in outside of roadless areas. We also look forward to more management the EA, Appendix A for the project will minimize or avoid potential adverse effects of the in the Chetco watershed that focuses on watershed health and action alternatives.
Page 2 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1-3 With the ESD, we are concerned that the agency will be unable to All substantive comments raised during the scoping period and the 30-day comment period integrate site-specific, substantive concerns raised in the planning on the Draft EA have been addressed appropriately. In fact, the January 2018 scoping letter process into project layout and implementation. We hope that this is described the need to capture timber value in the matrix land allocations that experienced not the case, and stand ready to work with the Forest to address these 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be concerns before a final decision is made. evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources. (EA at 1-1) Additionally, project specific design criteria have been developed to minimize or avoid potential adverse effects of the action alternatives. (EA, Appendix A) All applicable best management practices (BMPs) for watershed and vegetative management would be used to enable the achievement of water quality standards (General Water Quality Best Management Practices, Pacific Northwest Region, USDA Forest Service 2011). (EA at 2-7)
30-Day Comments Received 4/16/2018 - 5/16/2018 Avritt, Carrie 8-4 I understand that some logging may be necessary for safety reasons As of May 25, Oregon Department of Forestry has received notification of operations on such as along roads, but elsewhere the forest should be left alone, 6,421 acres from private land owners. The Draft EA at page 3-3 estimated private land especially in light of the thousands of acres of private lands nearby that salvage on about 9,455 acres for cumulative effects analysis. are already being clearcut.
8-3 If left alone, the post-fire landscape here will provide essential habitat The effects to northern spotted owl and coho salmon are displayed in the EA, Chapter 3 for imperiled wildlife like northern spotted owls and coho salmon -- two Fisheries and Aquatic Biota section. Specifically, the Proposed Action would likely adversely species that are barely hanging on. affect habitat and by disturbance, Alternative 3 would not likely adversely affect habitat but would likely adversely affect by disturbance. Both action alternatives would have no direct, indirect or cumulative effects to coho salmon. Refer to the EA, Chapter 3 Fisheries and Aquatic Biota section for the entire effects analysis.
8-1 I'm writing to urge you to reconsider your plan to log more than 4,000 The No Action alternative addresses your concerns. acres of public lands in the Chetco River region of the Rogue River- Siskiyou National Forest.
Page 3 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Anthony, Hal 45-1 The logging will, as usual, simply create more fire danger in a time of The effects to fuel loads is described in the EA, Chapter 3 Fire, Fuels and Air Quality section. climate temperature change that is already, as you well know, more than devastating communities. Letting in more sunlight so a weensy few people make millions is wrong, and you kinow that.
Fronce, Linnea
91-1 Birds and animals need dead trees for homes. And last time I read The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix about logging the fire ravaged areas in CA they were cutting down live land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 trees as well. Basically clear cutting everything. That doesn't sound like Chetco Bar fire. (EA at 1-4) Additionally, the No Action alternative addresses your concerns. safety measures.
Anderson Kathleen 104-1 This is a treasured wild area. Let the recovery happen naturally. Logging The No Action alternative addresses your concerns. machinery disrupts the soil and recovery of the forest.
Oliveria sheelagh 126-1 Clearcutting in Oregon is archaic and totally irresponsible. Foresters The effects to soils are described in the EA, Chapter 3 Soils section. say, "it comes back". It never comes back. This is pure ignorance. I am a botanist who pays attention. The forests on Mt Hood have at the most 3" of topsoil/duff as compared to 3' deep soils that were here before white people. You are damning your children to an earth without oxygen. perreault herve 147-1 I urge Forest Service decision makers to bring communities and The No action alternative addresses your concerns about " avoiding post-fire clearcut stakeholders together by avoiding post-fire clearcut logging and new logging and new road construction in the Chetco River Watershed ". road construction in the Chetco River Watershed.
147-2 Please do not convert post-fire native forests into second-growth Alternative 3 addresses your concerns about "not convert post-fire native forests into timber plantations. second-growth timber plantations" .
147-3 Please work with the public to focus management near homes and Alternative 3 addresses your concerns about "focus management near homes and communities while protecting remote backcountry forests and communities while protecting remote backcountry forests and tributaries" . tributaries.
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Name Comment Text Response Text
Brown Alex 254-1 We also had this "wild" experience marred by seeing blue paint and Blue paint and flagging does normally indicate a timber sale. Not knowing where you were flagging throughout the forest. Is this the timber sale? The only thing I at makes it hard to determine if it was this project or some other project. The effects of the can imagine that would be worse than someone vandalizing this proposed salvage logging is displayed in the EA, Chapter 3. Additionally, the No Action beautiful forest with spray paint, is for someone to cut all of those alternative addresses your concerns. massive trees down. I don't get it. Why would the Forest Service do so much damage to the forest that is so close to the tourist area of the Chetco River? And why kick the forest while it's down? It doesn't make any sense.
Schwartz Jake 361-1 WE VOTE.....WE PAY OUR TAXES...... AND WE CARE ABOUT AMERICA'S The No Action alternative addresses your concerns. WONDERFUL, VANISHING WILDERNESS. WE ASK YOU TO LOOK TO THE FUTURE, AND FOR YOUR GRANDCHILDREN...... AND OURS...... DO NOT LET THEM LOG THE CHETCO RIVER REGION. THIS WOULD BE ANOTHER GIVEAWAY TO THE LOGGING COMPANIES...... AND CERTAINLY NOT IN THE BEST INTEREST OF THE AMERICAN PEOPLE OF THE WILDLIFE OF OREGON. PLEASE THINK OF AMERICA'S FUTURE! WE THANK YOU FOR YOUR ENLIGHTENED VISION...... AND FOR YOUR POLITICAL COURAGE.
Jason 466-1 Oregonian and avid hiker here, please do not do any clear cutting or The No Action alternative addresses your concerns. salvage logging on any past burned forested area. Not only are standing dead trees beneficial for the ecosystem, but they are better for recreation and scenic values. (Cut stumps, regardless if they are in a burn area, are still less scenic than standing dead snags).
Hemmingsen Jim
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Name Comment Text Response Text
534-1 Please consider limiting any logging to only dead trees, in areas that The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage have been previously logged and roaded. These limitations will allow harvest under the action alternatives. The species being targeted for salvage under the for natural recovery in native stands and in unroaded areas, maintain action alternatives include Douglas fir and incense cedar, therefore they have been included important large snag habitat ans structure, and help protect the values in Table 3. No other species would be targeted for salvage removal. However, any tree, so much of the public holds dear about the Chetco area. regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
Swift Charles 619-2 And it should conduct road maintence activities to facilitate salvage Road maintenance activities are proposed in all action alternatives, refer to the EA, page 2- operations and improve the existing road network. 3.
619-1 Given the size and scope of the Chetco Bar fire, the forest should The EA at 1-1 states "85% of the National Forest System lands burned within the Chetco Bar maximize recovery within the project area and seek additional Fire occurred within lands where management allocations (such as congressionally reserved opportunities for salvage and replanting. areas, late successional reserve (LSR) and riparian reserve) either prohibit post-fire salvage or have requirements to show ecological beneficial effects of treatments to aid in post-fire ecosystem recovery. The remaining 15% of the fire on NFS lands occurred in lands designated as Matrix. Within the approximately 25,386 acres of land designated as matrix, approximately 13,626 acres incurred 50-100 percent basal area loss." The evaluation for feasibility of the 13,626 acres has reduced acres to 4,090 due to removing inventoried roadless areas, removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources.
619-4 Most importantly, the Rogue River-Siskiyou National Forest needs to Accelerating active vegetation management on the Rogue River-Siskiyou National Forest is accelerate its active vegetation management on Forest Service land to outside the scope of this project. reduce the risks of future fires.
619-3 Much of the national forest have an uncharacteristically high level of The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix fuels that exacerbate the intensity of wildfires. It's too late for the land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 forests affected the Chetco Bar fire, but nearby communities deserve a Chetco Bar fire (FEA at 1-4). comprehensive post-fire program that protects public safety, supports local jobs and speeds reforestation.
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Name Comment Text Response Text
Sherwood Mark 680-1 ask that you limit post-fire logging to roadside hazards, avoid steep Alternative 3 addresses your concerns regarding not building new temporary roads. The No terrains, include buffers to minimize damage to streams, and that you Action alternative addresses your concerns regarding limiting post-fire logging to roadside do not build new roads. hazards, avoiding steep terrain and not building new temporary roads. All alternatives include buffers to minimize damage to streams.
680-2 request that you prioritize the long-term productivity of this critical There are no direct or indirect effects identified to aquatic resources from proposed habitat for salmon and steelhead in the Chetco and surrounding activities associated with the Chetco Bar Area Salvage Project. Because there are no effects watersheds. associated with proposed project activities to aquatic resources, there can be no negative cumulative effects. (EA Chapter 3 Fisheries and Aquatic Biota section)
Brand Ronald 734-1 Please reconsider your plan to log more than 4,000 acres of public lands The No Action alternative addresses your concerns. in the Chetco River region of the Rogue River-Siskiyou National Forest. If loging does happen in this region, only selective cutting should be allowed. Never clearcutting. Clearcutting is too disruptive to watersheds, habitats and wildlife. Furthermore, clearcuts are awful to look at and just plain depressing.
Mihal Debbie 753-2 However, if science shows that harvesting wood in severely burnt areas In 2015, scientists from Oregon State University and the Pacific Northwest Research Station of native forest along with replanting with varying species at various completed a literature review concerning the Ecological Effects of Post-fire Salvage Logging times is best, I would support options two and three, as long as less in the Pacific Northwest (Reilly et al. 2015). These scientists found the ecological effects of severely scarred native areas capable of regeneration on their own are post-fire salvage logging vary depending on the treatment, fire severity, and biological left alone. setting (Peterson et al. 2009). These scientists concluded that based on their literature review, in general, little research supports the idea that salvage logging has beneficial ecological effects on terrestrial or aquatic resources (Karr et al. 2004, Beschta et al. 2004, Lindenmayer and Noss 2006). To provide the proper context, they concluded that salvage logging needs to be addressed at landscape scales and in terms of tradeoffs with other ecological and economic objectives. Many of the ecological guidelines they recommend for post-fire management are included in the design of this project. (EA at 3-1)
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753-1 I am writing to request that the lands scarred by the recent Chetco Fire The best available science is considered in preparation of this EA. The concept of "best be salvaged in alignment with best practices as found by scientific study available science" is also a matter of opinion to some degree since scientists can legitimately and experience. disagree about the meaning or impact of individual study results. As a general matter, we show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document. (EA at 3-1)
753-3 I do support assisting local timber industries to recuperate their losses Assisting local timber industries to recuperate their losses from the fire is outside the scope that were not covered their insurance policies. However, I see no of this project. This project occurs on National Forest System lands, not private property. reason to support them above and beyond what their usual and customary responsibilities would be, i.e., fixing their roads when it is they who built them in the first place. Nor do I support them profiting from this fire above and beyond their usual gains averaged over years.
Mancus Philip 835-1 As a taxpayer, I personally do not want to have to bear the brunt of The No Action alternative addresses your concerns. some people making money off of salvage sales. The revenues to the county will be insufficient to make up the long term costs, which will be externalized onto the local citizen when our water supply is threatened and fisheries weaken. The voices seeking salvage cuts come primarily from the outside and seem to not have in mind the long term interests of the Chetco River watershed, wildlife, and the people who live here. In contrast, the experienced professionals who have been involved in wild land fire management for over 30 years have all said the same thing: salvage logging is a bad idea
Condon Elaine
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Name Comment Text Response Text
875-1 The whole area needs to be salvaged. If you leave the dead and dying The EA at 1-1 states "85% of the National Forest System lands burned within the Chetco Bar on the forest floor you will be creating another disaster, just like you, Fire occurred within lands where management allocations (such as congressionally reserved along with the environmentalists, have created in the past. Clean up the areas, late successional reserve (LSR) and riparian reserve) either prohibit post-fire salvage forest, put cattle in there to keep the grass down, repair the roads for or have requirements to show ecological beneficial effects of treatments to aid in post-fire public access. SALVAGE THE WHOLE 300,000 ACRES. ecosystem recovery. The remaining 15% of the fire on NFS lands occurred in lands designated as Matrix. Within the approximately 25,386 acres of land designated as matrix, approximately 13,626 acres incurred 50-100 percent basal area loss." The evaluation for feasibility of the 13,626 acres has reduced acres to 4,090 due to removing inventoried roadless areas, removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources.
Starsinger Jewell 936-1 Trees are the lungs of the earth. They contain the souls of the Thank you for your comment. The No Action alternative addresses your concerns. Grandmothers. They invite the energy of life from Grandfather. They are our bridge to life on earth. Be careful how you Think progress should look. If you like breathing, don't take any more trees.
Harman Johanna 939-2 "so-called "forest restoration" only impoverishes forest ecosystems by The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix removing the dead trees and reducing the likelihood of new mortality." land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 George Wuerthner, "Harvesting Dead Trees is Bad for Forests," Feb 18, Chetco Bar fire. (EA at 1-4) No where in the EA do we purport that this project is for "forest 2018 restoration".
939-5 How can you not understand your job is primarily to protect these This comment outlines the opinion of the commenter, and a Forest Service response is not places, not destroy them. required.
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939-3 I urge Forest Service decision makers to stop prioritizing the timber The Forest Service is proposing to salvage harvest 4,090 acres burned in the 191,197-acre industry over protection of the special biological diversity of this area. Chetco Bar Fire. The Chetco Bar Fire burned 191,197 acres of which 170,321 acres are on National Forest System (NFS) lands. Approximately 85 percent (~144,935 acres) of the NFS lands that burned within the Chetco Bar Fire occurred within lands where management allocations (such as congressionally reserved areas, late successional reserve (LSR) and riparian reserve) either prohibit post-fire salvage or have requirements to show ecological beneficial effects of treatments to aid in post-fire ecosystem recovery. The remaining 15 percent (25,386 acres) of the fire on NFS lands occurred on lands designated as matrix. The January 2018 scoping letter described the need to capture timber value in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources. Additionally, the EA, Appendix A describes project design criteria to minimize or avoid potential adverse effects of the action alternatives.
939-4 Prohibit any new road construction in the Chetco River Watershed None of the alternatives evaluated in this project propose any road reconstruction. About 13.5 miles of temporary roads would be constructed and rehabilitated after use. Temporary roads are not intended to be included as part of the forest road atlas, as they are managed by the projects or activities under which they are authorized and decommissioned at the conclusion of the authorized activity. No new temporary roads would be constructed within riparian reserves. Temporary roads would be closed and restored after salvage and related activities are complete (EA at 2-4).
939-1 Stop ANY old growth grabs. The forest needs that old growth. The Forest Service is proposing to salvage harvest 4,090 acres burned in the 191,197-acre Chetco Bar Fire. The effects to complex early seral habitat are described in the EA, Chapter 3. Thompson Ronald 992-1 please restrict post-fire logging, and instead focus public investment on The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix improved fuels planning and treatment projects --- particularly in land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 plantations and proximate to wildland interface communities. Chetco Bar fire. (EA at 1-4)
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992-2 Regarding post-fire salvage logging, there is no ecological reason for The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix these damaging activities. Salvage logging is a disruption of the natural land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 recovery processes --- and this means that salvage logging is bad for Chetco Bar fire. (EA at 1-4) The effects to resources are described in the EA, Chapter 3. salmon and steelhead and other wildlife species.
Price Lily 998-1 I am an Environmental Science major at Humboldt State University and The No Action alternative addresses your concerns. recently have accepted an internship position with the Forest Service. I am dismayed that the Forest Service is not doing more to protect the lands the agency was established to protect. I do not think this clear- cut proposal will be providing the greatest amount of good to any living being in this lifetime.
Maron-Friend Judith 1048-1 LOGGING IS OUT OF CONTROL IN OUR STATE AND ONCE AGAIN IT The No Action alternative addresses your concerns. APPEARS THAT THE LOBBIES WITH THE MOST MONEY ARE THE ONES WHO GET WHAT THEY WANT!! WE ARE TIRED OF MONEY TAKING PRECEDENT OVER THE GREATER GOOD AND WE EXPECT OUR ELECTED OFFICIALS TO DO THEIR JOBS ON BEHALF OF THE GREATER GOOD!!
Harman Johanna
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1065-1 I urge Forest Service decision makers to respect the Chetco's 44 miles of None of the alternatives evaluated in this project include any actions (except haul routes on Wild and Scenic designation. existing roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined to have no effect to water quality. The rationale for this determination is documented in the Hydrology section. The project incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea- run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section.
Alexander Carol
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Name Comment Text Response Text
1210-1 I know the Chetco River well and understand it's inestimable value None of the alternatives propose salvage harvest in riparian reserves. Additionally, the No as habitat for threatened species. As you know, there is nothing else Action alternative addresses your concerns. like the Chetco left in Oregon and this riparian system really cannot withstand more violent disruption. Fires are one thing; the human intrusion and destruction after fire is a whole other thing. No doubt you are working in good faith to fulfill your mandate under pressure, but please reconsider your plan to log more than 4,000 acres of public lands in the Chetco River region of the Rogue River-Siskiyou National Forest.
Hovis Katherine 1279-1 We need to protect as much forest as we have left with all our might. The No Action alternative addresses your concerns. Please. Don't take the trees and the animals that will surely die with them.
Stapes Lynn 1287-1 Areas that are highly trafficked by tax paying citizens must be allowed a The No Action alternative addresses your concerns. natural restoration. This is part of nature. It maintains the current habitat instead of the removing all aspects of the habitat for single species trees basically obliviating the habitat and it's inhabitanst.
Klein Randy 1312-1 If left alone, the post-fire landscape will recover rapidly and provide The No Action alternative addresses your concerns. essential habitat for imperiled wildlife like northern spotted owls and coho salmon.
1312-2 Post-logging water quality has been shown to increase turbidity ( The proposed project was determined to have no effect to water quality. The rationale for see "Turbidity Responses from Timber Harvesting, Wildfire, and this determination is documented in the Hydrology section. The project incorporates a Post-Fire Logging in the Battle Creek Watershed, Northern system of design features that ensure there can be no mechanism to affect water quality. California", Lewis and others, 2018, Env. Mgt. DOI10. 1007/s00267- Some examples of design features to protect water quality include no-cut riparian buffers 018-1036-3) . Salmon, steelhead and other species will be harmed by on both sides of all streams, conditional restrictions on the haul of salvaged timber, and this. improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. (EA at 1-9)
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1312-3 This area is also one of the most beautiful wild river regions in the The No Action alternative addresses your concerns. west and attracts anglers, hikers, rafters and many others for recreation. We all want to see the land retain its beauty and high water quality, not with eroded hillslopes and degraded water quality that will surely follow clearcut logging.
Murray Margaret 1339-1 I was fortunate to camp in this region three years ago when I drove to The No Action alternative addresses your concerns. Crater Lake from the East Bay. I was so amazed, so inspired and heartened by this beautiful river region. We don't need loggers to destroy it, nor the wood to be harvested, nor the corporations to make money off of our precious land.
Gchesa Elen 1417-1 Only fire damaged trees that are beyond redemption that are dead or Thank you for your comment. Table 2 in the EA Chapter 2 at 2-2 describes the guidelines will die, should be cut. The rest of the forest should be left to used for predicting mortality by species and diameter. regenerate itself.
Brodie Eileen
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Name Comment Text Response Text
1440-1 The cycle of fire and forest renewal is not a call to harvest if we The No Action alternative addresses your concerns. are managing the environment for lasting wildlife and river health. Logging will bring further damage requiring more costs to try and mitigate runoff and landslides-such mitigation often fails. Revenues from timber sales can cloud the real costs of allowing industrial scale logging in public forests. Further loss of habitat and silting of rivers is not wise stewardship.
Epperson Daniel 1483-1 I'm writing to urge you to NOT reconsider your plan to MANAGE more Thank you for your comment. The Proposed Action alternative addresses your concerns. than 4,000 acres of public lands in the Chetco River region of the Rogue River-Siskiyou National Forest.
Gallardo Kathleen 1508-1 I am SO SICK of the way our government agencies are riding rough shod The No Action alternative addresses your concerns. over our lives. Oregon is a precious jewel that must be carefully taken care of. Do YOUR JOB and HEAR US - LEAVE THIS AREA AND OTHERS ALONE POST FIRE. Being in nature is healing - and as a nation, if we ever needed healing it is now.
Richmond John & Susan
1543-1 Just who do you work for, what job do you do? Is America just a The No Action alternative addresses your concerns. corporate giveaway, or are we the land and its people? Please do your job. Protect the forest and the people against all depredations.
Wuerthner George 1593-1 There is a lot of scientific research that calls into question the idea that The effects to snags and wildlife species dependent on snags is addressed in the EA, Chapter any "salvage" logging harms the ecosystem. Dead trees are critical to 3, Wildlife section. many animal species. Indeed, biodiversity is often the second highest in burnt forests and only old growth forests have a greater amount of species. Many scientists have written about the perils of logging. Even the dead trees are major sources of carbon storage. Removal reduces the overall carbon storage in the area. There's simply no rational reason to log here.
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Name Comment Text Response Text
Flanagan Janet 1595-1 I live in the mountains in Northern California surrounded by clear The No Action alternative addresses your concerns. cuts that Sierra Pacific, Red Emerson, has logged! Our 105 acre ranch has become a refuge and island to the wildlife as their once habitats have been leveled to dust forever. Where once there were owls, squirrels, birds, mountain lions, fox,, bear, fischer and so much more there is now nothing, but a dead chemical drenched vast land. Nothing grows and nothing lives! We are stripping our lands of trees, they absorb carbon so we can all breath. This clear cutting method has destroyed all the echo systems for thousands of miles, it is going to destroy all of us if it continues. Please look at a Google map to see what clear cutting has done to the west coast mountains. Its insane and should stop now for the wildlife. But also for us!! Please do not consider clear cutting along the natural Rogue River in the Siskiyou National Forest. Oregon has already done great damage to her own state out of greed. Please no more, protect our forests and wildlife!
Gross Cynthia 1687-1 We are the last corner of the lower 48 states with these precious The No Action alternative addresses your concerns. resources. HOW CAN YOU EVEN CONSIDER ANYTHING BUT A NATURAL RECOVERY FOR THIS WATERSHED?
Chione Andrew 1690-4 Please don't salvage log the Chetco. It will hurt the fish and the wildlife The No Action alternative addresses your concerns. and devastate a place important to me.
1690-1 Post-fire logging is going to increase the sedimentation in the river and The EA states "There are no measurable direct, indirect, or cumulative effects to erosion or cause a loss of post-fire habitat. sedimentation, peak flows, stream temperature, or waterbody condition expected from the Chetco Bar Fire Salvage project" . The EA also states "The Action alternatives would have no direct, indirect or cumulative effects to aquatic biota (aquatic threatened, endangered and sensitive species) . EA Chapter 3 Hydrology section and Fisheries and Aquatic Biota section.
1690-2 Those dead trees will be used by wildlife and then, when they fall into Effects to wildlife species dependent on snags are described in the EA Chapter 3 Wildlife the streams, by fish. section.
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1690-5 When I visit the Chetco river this summer, I hope to see native post-fire There will be 144,000 acres that have no history of timber harvest and would not be succession on our National Forest, not the scars of salvage logging. salvaged (DEA at 3-5) to see "native post-fire succession on our National Forest". Also the No Action alternative addresses your concerns.
1690-3 With all of the salvage logging on private land already affecting the Cumulative effects from salvage logging on private lands is described throughout chapter 3. river, please do not exacerbate the negative affects by clearing the public land as well. Hummel Danielle 1707-1 The ecological impacts of salvage logging are hugely devastating to all The effects to wildlife species are displayed in the EA, chapter 3. types of wildlife, very destructive. Wildfires are natural parts of the ecosystem, and the trees that remain after a fire, including living, dying, decaying, or damaged trees, are all a necessary part for that ecosystem to recover from the fire.
1707-2 To claim that it is necessary to recover the economic value of these The Responsible Official determines the breadth or narrowness of the need for action. trees by logging them, is a manipulative way of gaining access to areas Additionally, the project is only proposed in matrix lands, where logging is allowed and where logging was not previously allowed. encouraged. The No Action alternative addresses your concerns.
Evans Steve 1708-2 Do extensive post fire salvage log . Thank you for your comment. The Proposed Action alternative proposes to salvage harvest and plant on 4,090 acres. 1708-1 Do it right this time. 1) Stop fire at the beginning This comment is outside the scope of this project. The purpose of this project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire.
Wuerthner George 1719-1 The use of "temporary" roads is a distraction. While the roads are in Of the 13.5 miles of proposed temporary roads, about 1.3 miles are new construction. The use, they are creating the same problems as any other road. Spread of remaining are using existing unclassified roads where there is an existing road template. The weeds, disturbance of wildlife, and corridors for human entry (ATVs, effects of temporary roads on the spread of weeds, and disturbance of wildlife are etc. ). addressed in the EA, Chapter 3. Illegal entry by ATV's is a law enforcement issue.
D Bosco 1736-1 I have read about harvesting the burnt trees and I think, that it make Thank you for your support. sense to do so rather than wasting the wood that can be obtained from those trees. So I support the salvage.
Schott David Page 17 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1740-1 It can't be overemphasized how important it is to salvage in a timely We agree, that is why as a part of this project an Emergency Situation Determination (ESD) manner. under 36 CFR 218 was requested for the Chetco Bar Fire Salvage Project.
1740-2 The Forest Service needs to take a hard look at the last two decades of Two decades of non-production and smoke from wildfires are outside the scope of this non-production. What it also needs to do is fully understand the project. implications of smoke on our communities. It's no longer just an economic concern. There's now a huge detrimental health implication that occurs with large fires. Smoke now must become one of the factors the Forest Service considers in the planning and management of this national forest. To keep smoke from becoming such a huge concern, the Forest Service needs to have a policy of immediate and total response to fires, much like the Oregon Department of Forestry does for BLM, State and private timberlands. We can't tolerate any more allowing manageable small fires to become huge catastrophic fires such as the Chetco Bar.
Davies Gwen 1747-1 More than ever this could literally be life and death for humanity. Our The No Action alternative addresses your concerns. Milton Kyle 1753-1 This area is literally the birthplace of many species of trees that The No Action alternative addresses your concerns. Zumeta Benjamin 1761-2 This type of logging has proven to destroy some of the best bird and The No action alternative addresses your concerns. 1761-1 We will vote and write and take direct action until whoever needs to This comment outlines the opinion of the commenter, and a Forest Service response is not lose their job over this does. Who profits from this, foreign required. Johnson Curt 1780-1 Why the reduction in an already pathetic attempt to harvest dead The EA states "The January 2018 scoping letter described the need to capture timber value salvage timber? The cut should be more not less! in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." EA at 1-1
Page 18 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Braun Steve 1789-1 Probably best to not have any press release if it is only going to address This comment outlines the opinion of the commenter, and a Forest Service response is not 2.5% allowable of the amount burned...Inefficiencies at best...... required.
Abell Sandy 1801-1 Everything dead that is left in the forest provides fuel for the next fire. Fuel loading within the treatment units would increase immediately post-harvest. As coarse We need to clear much of this in order to better manage future fires. fuels would be removed during harvest, much of the fuel accumulation would consist of finer fuels, primarily in the form of branches. Fuel loadings after harvest can be considered a hazard as needles dry and turn red. (EA Chapter 3 Fire, Fuels and Air Quality section)
1801-2 Logging/clearing burned and downed trees is the only logical thing to The action alternatives address your concern. do.
Chocktoot Perry 1811-1 Klamath Tribe comment for Draft Chetco EA No response required. Hurley Kim 1812-2 Forest management put the forests in this position now the solution is This comment outlines the opinion of the commenter, and a Forest Service response is not to waste again. Please use the creativity of the greatest educated required. country and fine a proper use of this resource before it is too late. Doing nothing put the forests in this position. Let's fine a solution!
1812-1 Time is of the essence in harvesting this burnt timber. If the timber can The EA at page 2-6 describes the Emergency Situation Determination (ESD) under 36 CFR have any use from the lack of lumber in the hottest building market 218 that was requested for the Chetco Bar Fire Salvage Project. An ESD would expedite the industry why wouldn't we make every attempt to salvage it. Also I time period in which this salvage sale could be offered to the public by allowing personally know that there is opportunity for this burnt timber to be implementation of the project immediately after a decision on the project has been signed chipped and used for many products. and published. This is expected to be in late June 2018.
Shipley Doug 1826-1 I wholeheartedly want the riparian areas protected, but I would also This comment outlines the opinion of the commenter, and a Forest Service response is not support increasing that 4,100 acres of salvage to double that. The forest required. will grow back either way, but I'd like to see a large scale salvage in the area to compare to areas that aren't salvage logged.
Steitz Jim
Page 19 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1828-1 I urge you to remove any new road construction and any logging in Alternative 3 addresses your concerns. primary forests, in the proposal for post-fire 'salvage' logging in lands affected by the 'Chetco Bar' fire.
1828-6 Moreover, the Forest Service can allow the 'Chetco Bar' fire to set a The No Action alternative would provide a " demonstrative model of the capacity for intact demonstrative model of the capacity for intact old-growth forests to old-growth forests to regenerate without intervention " and therefore addresses your regenerate without intervention. This would help the Forest Service to concerns. break the cycle of self-fulfilling prophecy that post-fire forests require logging, which in turn leads to overstocked stands of small-diameter trees, which in turn lead to greater vulnerability of stand-replacing fire.
1828-4 Moreover, this project would damage the fragile soils that must be left The effects of salvaging are displayed in the EA, Chapter 3. Specifically, the effects to soils to regenerate, not subject to mechanical shear and friction from heavy are described in the EA Chapter 3 Soils section. machinery in their naked condition. Without normal vegetative detritus shielding against physical stress, these soils are inevitably left damaged for decades after a 'salvage logging' operation drags its immensely heavy wheels and chains over the ground.
1828-3 Second, this statement ignores the immense value of the remaining The effects of salvaging are displayed in the EA, Chapter 3. Specifically, the effects to 'dead, dying, and/or damaged trees' for the forest's regeneration. complex, early seral habitat are described in the EA at 3-8 through 3-11. Additionally, These 'dead, dying, and/or damaged trees', i.e. 'snags' are extremely Alternative 3 addresses your concerns. valuable as reservoirs for moisture and nutrients. The Forest Service should have learned from a number of studies, including those conducted by its own agency scientists, describing post-fire forest regeneration and the deleterious affects of post-fire 'salvage' logging. In designating them for "salvage" logging, a term that negates these ecological values by "salvaging" monetary value as the only extant one, the Forest Service confuses and undermines the public understanding of forest ecology that it attempts to communicate elsewhere. A scientifically informed management plan would never embrace so ecologically fallacious a construct as post-fire "salvage logging".
Page 20 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1828-5 The Forest Service has made significant and admirable progress away This comment outlines the opinion of the commenter, and a Forest Service response is not from the old, rogue agency of ancient forest liquidation toward an required. agency of legitimate, responsive ecological managers. Sadly, this transition came too late for most of Oregon's public forests, and the Forest Service must complete this transition before any more large trees are logged.
1828-2 The premises and purpose of this project are at variance with the Forest The Responsible Official determines the breadth or narrowness of the need for action. Service's own knowledge of forest ecology, and with its obligations to manage these lands for the greatest cumulative public benefit. The Forest Service press advisory for this project states, "The purpose of the Chetco Bar Fire Area Salvage project is to capture timber value by harvesting dead, dying, and/or damaged trees in a timely manner." This premise is doubly erroneous. First, it implies that all trees are intended or destined to be 'harvested' at some point, and that the Forest Service must 'capture' this value before it is lost to the elements and to decomposers. Such an implication would blatantly contradict the letter and spirit of the Forest Service charter. It also ignores the larger landscape context of the coastal mountains, whose sprawling private plantations already provide immense amounts of timber, including post- fire logging in 2018, requiring no 'salvage' effort by the Forest Service to augment this glut.
Moore Claudette 1832-1 I'm amazed that you will only be salvaging only 4,000 acres of the The EA states "The January 2018 scoping letter described the need to capture timber value 191,000 that burned!!! That is awful!!! in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." EA at 1-1.
Page 21 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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1832-2 The brush will come back and we will have another horrible wild fire The EA states "Just over 48 percent, or 91,118 acres within the fire perimeter are classified season. This is a totally unacceptable plan. We need to salvage as having 50 percent or more basal area loss. Of this, 13,626 acres or 8 percent of this high thousand more acres!! severity area is designated as matrix under the Northwest Forest Plan. Because the patch sizes (treatment units) under consideration are small and within larger patches of high basal area loss, the lack of treatment in these specific patches is unlikely to contribute to success or failure of fire suppression activities. In the longer term, (>20 years) increased shrub continuity and snag decomposition would reduce firefighter effectiveness and pose safety hazards for safe suppression options." EA Chapter 3 Fire, Fuels and Air Qualtiy section.
Merz Gayle 1840-2 Leaving more charred acres will create more fuel for future fires and The EA states "Areas adjacent to treatment units will remain untreated, this will reduce allow more carbon into the atmosphere. continuity in fuels and overall fire danger in the near term, mitigating the potential for fire spread from these treatment units. "Reducing connectivity of surface fuels at landscape scales is likely the only way to decrease the size and severity of reburns until vertical diversification and fire resistance is achieved." (Thompson et al, 2007) From a fire standpoint the changes in fuels continuity on the landscape due to this project is considered negligible in the context of the broader event" (EA Chapter 3 Fire, Fuels and Air Qualtiy section). The EA also states that "Climate change is a global phenomenon because major greenhouse gasses mix well throughout the planet's lower atmosphere (IPCC 2013). Considering emissions of greenhouse gasses in 2010 was estimated at 49 ± 4.5 gigatonnes globally (IPCC 2014) and 6.9 gigatonnes nationally (USEPA 2015), a project of this magnitude makes an infinitesimal contribution to overall emissions. Therefore, at the global and national scales, this proposed action's direct and indirect contribution to greenhouse gasses and climate change would be negligible. In addition, because the direct and indirect effects would be negligible, the proposed action's contribution to cumulative effects on global greenhouse gasses and climate change would also be negligible (EA Chapter 3 Climate Change section)."
Page 22 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1840-1 Salvage the entire 19,426 acres as originally planned. The EA states "The January 2018 scoping letter described the need to capture timber value in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." EA at 1-1.
Barnes Barbara 1852-1 I want to comment as a member of the public with an interest in The No action alternative addresses your concerns. maintaining above all the health of our watersheds and wildlife. In my opinion these considerations are far more important than harvesting the maximum number of board feet.
Anthony Hal 1878-1 The Natural Selection Alternative (NSA), an accepted forestry modality The Proposed Action would salvage 2.4% of the National Forest System lands burned in the in Selma, Oregon, is not only the best model for forests - it is the ONLY Chetco Bar fire. The remaining 97.6% would be left to evolve under similar conditions as model that can work in forest actions by people. Please review this your " Natural Selection Alternative ". Additionally, the No action alternative addresses your plan, which was submitted by Orville Camp and is currently applicable concerns. to 500 acres of exquisitely beautiful, extant forests in that area, including 100 acres of the Camp's own property having the NSA applied to it
Kloor Mike 1881-1 We have to end this destructive practice of clear cutting now and This comment outlines the opinion of the commenter, and a Forest Service response is not forever! required.
Johnson Bonnie 1888-1 Heavy logging is unnecessary and will prevent a healthy recovery of the The No Action alternative addresses your concern. biological diversity we need for the future.
Page 23 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1888-2 Logging on private lands has already harmed the watershed, please be This comment outlines the opinion of the commenter, and a Forest Service response is not enlightened stewards, not abusers of our public forests. They belong to required. all of us, not to the timber industry.
Mohler June 1902-1 Not only would additional roads and logging badly impact fish and There are no direct or indirect effects identified to aquatic resources from proposed water quality, and introduce more invasive weeds and diseases, but it activities associated with the Chetco Bar Area Salvage Project. Because there are no effects would also discourage or eliminate opportunities for fishing, hunting, associated with proposed project activities to aquatic resources, there can be no negative hiking, etc. This would result in a negative economic impact for local cumulative effects. As a result, project activities would have No Effect to SONCC coho businesses and communities that depend on these activities, and it salmon, SONCC coho CH, Pacific eulachon, North American green sturgeon, and Essential would hurt the State of Oregon, because this area is a true state Fish Habitat. Project activities would have No Impact to KMP steelhead, Pacific lamprey, treasure. SONCC Chinook salmon, California floater, Western ridged mussel, highcap lanx, scale lanx, rotund lanx, robust walker, Pacific walker, and Haddock's Rhyacophilan caddisfly because these species are not known to occur, do not have suitable habitat within proximity to any of the proposed activities, or project activities are disconnected from the aquatic system within their range distribution. (EA, Chapter 3, Fisheries and Aquatic Biota) No salvage activities are proposed in the Chetco Wild and Scenic River corridor or in any other areas with retention or preservation VQOs.
Krisa Rama 1904-1 I believe watershed preservation should be given a higher priority than The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix salvaging timber. land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (DEA at 1-4). Additionally, the No action alternative addresses your concerns. Ocean Alisa 1912-1 Studies have been done in Corvallis, that prove areas that have had Thank you we are aware of numerous studies. The effects of the alternatives are described wildfire will recover drastically faster and better when left alone, in the EA, Chapter 3. Additionally, the No Action alternative addresses your concerns. compared with areas where salvage logging took place after a fire.
Ruediger Luke 1917-1 www.thesiskiyoucrest.blogspot.com The majority of this comment outlines the opinion of the commenter, and a Forest Service response is not required. The remaining is addressed in the response to comment 1815.
Betcher Alan
Page 24 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1930-1 We should log the fire devastated area as soon as possible on all This comment outlines the opinion of the commenter, and a Forest Service response is not suitable land without exceptions on our national forest land. The required. However, the January 2018 scoping letter described the need to capture timber salvage of 13,626 acres is a silly number out of 191,197 acres. What are value in the matrix land allocations that experienced 50-100 percent basal area loss, about these people thinking? Do these people have any common sense on 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment the value of this timber and the ramifications to our forests. This and that the treatment acreage would be reduced further, due to a combination of factors. number is poorly thought out. Time is of the essence. * To log for The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to timber for lumber mills * To eliminate fire from leaving the dry dead removing inventoried roadless areas (IRA), removing units lacking economically viable logs * To avoid having a hard wood forest of maples, oaks and products, logging systems operability and accessibility, locating and avoiding unmapped madrone. * To avoid disease and insects * We need to reseed the riparian reserves, and considerations for post-fire wildlife habitat and other resources (EA at burned areas with conifer * We don't need another fire in southern 1-1). Oregon in this area.
Johns David 1931-5 Human machines will only muck it up, damaging soil, removing snags Refer to Chapter 3 for a description of the effects of the project. Additionally, the No Action and other fire remains that are important to a healthy landscape and alternative addresses your concerns. wildlife, degrade water quality, and create other negative effects.
1931-2 It is important wildlife habitat in a world that is increasingly being The effects to wildlife are described in the EA Chapter 3 Wildlife section. gobbled up and otherwise degraded by human myopia, mindlessness and greed. The region is not just important in and of itself; it also forms a critical hub, linking the Oregon Coast Range, Cascades, Sierra Nevada and other areas.
1931-4 It is particularly reprehensible to open up any roadless areas to logging. None of the alternatives evaluated include any actions in the inventoried roadless areas. The effects to undeveloped lands are described in the EA Chapter 3 Undeveloped Lands section. Specifically about 1,433 acres of other undeveloped lands would be salvaged making these areas no longer considered undeveloped.
1931-3 The Klamath Siskiyou region is one of the few left where some Salmon The EA Chapter 3 Fisheries and Aquatic Biota section determined "The Action alternatives runs remain healthy. would have no direct, indirect or cumulative effects to aquatic biota, federally listed threatened or endangered species or Forest Service Sensitive species."
Page 25 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1931-1 The proposal to log 4,000 acres affected by the Chetco Bar Fire is The No Action Alternative addresses your concerns. unacceptable. I have seen first-hand the clumsy destructiveness of industrial logging. Such mechanical dinosaurs do not belong in the woods, with the noise, exhaust, fuel spills and much else. The Chetco fire area and the entire Klamath-Siskiyou region is too valuable to log.
MacGregor Therese 1944-5 By enabling so much fuel to accumulate by lack of salvage, forests are The Proposed Action alternative proposes to reforest 4,090 acres as needed. Additionally, a not being replanted and encouraged to return to a more natural forest future proposed project would reforest additional areas however the exact number of acres like state. is unknown at this time. 1944-3 The timber that isn't harvested on the USFS lands and Wilderness lands The effects to fuel loads are described in the EA, Chapter 3 Fire, Fuels and Air Quality will eventually fall to the forest floor and be more fuel for additional section. fires.
1944-4 The unharvested timber will deteriorate over 20-30 years and the The effects to climate change are described in the EA, Chapter 3 Climate Change section. deterioration process will release approx 3 times more carbon into the atmosphere that what occurred at the time of the fire...... and the amount of carbon release at the time of the fire was estimated to be approx 27 tons of carbon for each and every acre that burned. In this case it was 192,000 acres which equates to an amount of 5.4 million tons of carbon released. That means that an additional 15 million tons of carbon will be released into the atmosphere over the next 20-30 years.
Schwartz Ryan 1945-1 The forest ecosystems that make Oregon great are built on burned The No Action Alternative addresses your concerns. areas. We need to leave fallen trees in their place - as long as they don't endanger people. Please do not allow additional logging to destroy the ecosystems we love.
Meier Courtney
Page 26 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
1946-1 New roads will become a source of sediment and erosion into the The EA states "There are no measurable direct, indirect, or cumulative effects to erosion or waters of the Chetco. Sediment and erosion are enemies of salmon. sedimentation, peak flows, stream temperature, or waterbody condition expected from the Chetco Bar Fire Salvage project because there are no effects to the measures used to predict potential effects." Additionally the fisheries and aquatic biota section states "There are no direct or indirect effects identified to aquatic resources from proposed activities associated with the Chetco Bar Area Salvage Project. Because there are no effects associated with proposed project activities to aquatic resources, there can be no negative cumulative effects."
Kew Michael 1958-3 I live 40 yards from North Bank Chetco River Road and, every weekday, This comment outlines the opinion of the commenter, and a Forest Service response is not all day, since the fire was "out," dozens and dozens of log trucks speed required. past my house. The drivers of these trucks are jerks, generally. Most are on contract and do not live here, so speeding and running local residents off the road is of no concern, especially since the Oregon State Police don't "patrol" (laughable in itself) the road until after 2 p. m. How convenient for the log truckers, since their days end around 3 p. m. Many hills above the Chetco look more like a dusty bombed-out moonscape than the once-green forests they were centuries before industrial logging raped and pillaged. Curry County is mostly a clueless backwater, stuck in the 1950s, desperate for any dollar, thinking that constantly raping the environment is the way to go. I realize the great "green" (ha!) and "liberal" and "ecofriendly" state of Oregon remains puppet-mastered by Big Timber. This does not mean it is right. Or sustainable. Because, as facts show, it is not.
1958-4 Though the acreage was thankfully "cut" (pun intended), this proposal The No Action alternative addresses your concerns. to log more than 4,000 sensitive acres of the forests impacted by the Chetco Bar Fire is of HUGE concern to me and everyone here who doesn't work for South Coast Lumber, a quaint but noisy, pollutive, and destructive relic of the town's glory days. "Wood products" is mostly a farce. It is 2018, not 1948.
Cogdill Catherine
Page 27 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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1968-2 Also, the amount of silt will clog the river and its mouth. The EA states "Both alternatives have no harvest riparian areas with a width of 175 feet or greater that exceeds the buffer width needed to protect streams from sediment delivery form salvage operations." EA Chapter 3 Hydrology section.
1968-3 I urge Forest Service decision makers to bring scientists, communities The No action alternative addresses your concerns about " avoiding post-fire clearcut and stakeholders together by avoiding post-fire clearcut logging and logging and new road construction in the Chetco River Watershed ". new road construction in the Chetco River Watershed.
1968-1 Look at the terrain in person, please, before making a decision. If it is On the ground reconnaissance has been completed on all units. Unstable slopes have been logged, some of the proposed areas will take decades to recover removed from salvage units. because of the steepness of the terrain.
Miller Steve 1971-1 I am writing to urge you to please consider limiting any logging of the Alternative 3 addresses your concerns regarding limiting salvage logging to previously Chetco Bar Fire area to only dead trees, in areas that have been logged and roaded areas. The No Action alternative addresses your remaining concerns. previously logged and roaded. This will allow for natural recovery in native stands and in unroaded areas, maintain important large snag habitat and structure, maintain recovering soils, and help protect the many values so important to much of the public.
Duggan Jack 2006-1 The science on post-fire harvest is clear and shows intensive logging The use of best available science is addressed in the EA, Chapter 3. compounds the problems created by fire.
Williams Kathy 2009-1 Thank you for focusing your proposed post-fire activities along the Alternative 3 was developed to address your concerns. Chetco on existing timber plantations and on addressing roadside hazard trees. This strikes me as a common-sense proposal that can bring people together while avoiding environmental damage to the beloved Chetco Watershed.
Law Mary
Page 28 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2045-1 become more conservative of our joint resources. It is well known There are no measurable direct, indirect, or cumulative effects to erosion or sedimentation, now that forest fires do not kill forests. It is also well known the peak flows, stream temperature, or waterbody condition expected from the Chetco Bar Fire erosion that comes from logging, esp after a fire. Salvage project because there are no effects to the measures used to predict potential effects. (EA Chapter 3 Hydrology section)
Spivak Eric 2049-1 Though I appreciate the economic impact of the logging industry, I Alternative 3 and the No Action alternative addresses your concerns. believe that the decision to log 4,000 + acres in the Chetco Bar burn area is short sighted. As the tourism industry continues to go, leaving pristine areas unlogged will help to grow outdoor recreation tourism and have a longer term and more sustainable impact than logging.
Ash Delbert 2083-2 And it should conduct road maintence activities to facilitate salvage Road maintenance activities are proposed in all action alternatives, refer to the EA, page 2- operations and improve the existing road network so that future fires if 3. any can be accessed.
2083-1 Given the size and scope of the Chetco Bar fire, the forest should The EA at 1-1 states "85% of the National Forest System lands burned within the Chetco Bar maximize recovery within the project area and seek additional Fire occurred within lands where management allocations (such as congressionally reserved opportunities for salvage and replanting. areas, late successional reserve (LSR) and riparian reserve) either prohibit post-fire salvage or have requirements to show ecological beneficial effects of treatments to aid in post-fire ecosystem recovery. The remaining 15% of the fire on NFS lands occurred in lands designated as Matrix. Within the approximately 25,386 acres of land designated as matrix, approximately 13,626 acres incurred 50-100 percent basal area loss." The evaluation for feasibility of the 13,626 acres has reduced acres to 4,090 due to removing inventoried roadless areas, removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources.
Page 29 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2083-3 Much of the national forest have an uncharacteristically high level of This comment is outside the scope of the project. fuels that exacerbate the intensity of wildfires. It's too late for the forests affected by the Chetco Bar fire, but nearby communities deserve a comprehensive post-fire program that protects public safety, supports local jobs and speeds reforestation. Most importantly, the Rogue River-Siskiyou National Forest needs to accelerate its active vegetation management on Forest Service land to reduce the risks of future fires.
Donelson Bruce 2094-1 Post-fire logging slows forest recovery by compacting soils and The effects to soils and regeneration are described in the EA, Chapter 3. disturbing the fragile top soil layer. It also damages new post-fire growth. Many surviving trees are adversely affected or logged, and the presence of downed logs can help to deter erosion.
Robertson- Joan Geisler 2107-2 We need to protect the delicate balance that is already challenged Both Action alternatives consider the short term economic benefits verses the long term along the Chetco and be accountable to present and future generations impact on the area resources. Additionally, the No Action alternative addresses your of Americans. The future challenges to clean water and air and the concerns. balance of the ecosystem depend on the decisions that we make today. I understand the role that the Forest Service has in balancing these interests. This is a role that impacts future generations. I ask you to consider the short term economic interests vs the long term impact on this unique and extremely sensitive area.
Warren Stuart 2115-1 I simply would like to insist that your decisions will impact Chinook The EA Chapter 3 Fisheries and Aquatic Biota section determines "The Action alternatives salmon and winter steelhead in the Chetco and Pistol rivers watershed would have no direct, indirect or cumulative effects to aquatic biota, federally listed and they should be given ample consideration. threatened or endangered species or Forest Service Sensitive species."
Page 30 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2115-4 The Chetco River is famous for its world class chinook and winter The No Action alternative addresses your concerns. steelhead fishing. In order to maintain that I have these requests for you: 1.) Absolutely no clearcutting, 2.) No/few new roads built, 3.) Riparian setbacks should be increased and enforced, 4.) Skidding and dragging on steep slopes prohibited. Utilize helicopters as much as possible.
2115-2 The remaining natural filtration systems that have been unaffected are This comment outlines the opinion of the commenter, and a Forest Service response is not now being removed at rates that are unsustainable from private timber required. harvest. This year alone, South Coast lumber has clearcut nearly 10,000 acres in close proximity to the rivers and tributaries. Not to mention the nearly 200,000 areas negatively effected by fire. My fear is elevated levels of sediment in the rivers and streams and an increased rate of land sliding. At what cost are we willing to subject our salmon and steelhead to this?
2115-3 Will there be consideration for the fishing guides that operate on these The Chetco Bar Area Salvage Project will implement full riparian reserve no cut buffers of streams? Is the Forrest Service prepared to pick winners and losers 175' on non-fish bearing stream and 350' on fish bearing streams. By implementing the through this process? mandatory full buffer widths on all streams as part of the project's design criteria, there would be no increase in fine sediment delivery to any stream or associated increase in turbidity from salvage harvest and yarding activities (EA Chapter 3 Hydrology section). Trees would be removed and harvested by a variety of logging system methods including ground- based logging systems, skyline yarding and helicopter. Ground based logging systems would occur on slopes less than 30%. Skyline and helicopter based logging systems typically occur on slopes greater than 30% (EA at 2-2).
Worthington Brandon 2117-1 I am a fly fishing guide in southern Oregon who looks forward to None of the alternatives include any actions (except haul routes on existing roads) in the showing my clients the beauty of the chetco every winter. We Wild and Scenic Chetco River Corridor, however activities could be seen or potentially seen already see the impacts of logging operations in the watershed. All from the river. The effects to visual quality is described in the EA, Chapter 3 Recreation and I have to do is point, explain, and regardless of my clients previous Visuals section. understandings, they clearly see impacts. And it upsets them! They want wild rivers and Intact watersheds! That's one of the reasons they come to the chetco
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Name Comment Text Response Text covault jonnel 2119-1 Please DO NOT CLEAR CUT! I'm moving to this area soon and hope to The No Action alternative addresses your concerns. paddle board and row on the Chetco without having to look at the ugly and depressing scars of forest degradation.
Steitz Jim 2141-1 I urge you to remove any new road construction and any logging in Alternative 3 addresses your concerns. primary forests, in the proposal for post-fire 'salvage' logging in lands affected by the 'Chetco Bar' fire.
Pouley Cheryl 2167-1 We have no comments to offer at this time. Please keep in mind that Thank you for your comment. our comments are limited to cultural resource concerns - other tribal departments may offer comment.
McPartland Joyce 2219-2 And YES to: Focus on management that protects homes and The Action Alternatives (Alternative 2 and 3) address your concerns about "focus communities from future fires. We can use the best science that tells us management near homes". Refer to the EA, page 3-1 for the use of best available science. how to restore forests, rather than continuing to destroy public lands.
2219-1 NO to: The Forest Service contemplating whether or not to conduct The No Action alternative addresses your concerns. post-fire clearcut "salvage" logging on over 4,000 acres of public lands that would involve punching 13 miles of new logging roads into this amazing watershed. That's on top of the 9,500 acres of private industrial timber lands that have already been logged this year.
Lee Robert
Page 32 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2225-1 We have already seen what logging along the frontiers of the Illinois The No Action alternative addresses your concerns. River have done. In the summertime, the 20-40 foot wide river turns to a trickle and all the fish fry in waters reaching 80+ degrees. For tourism's sake, the river looks like shiiiite and hippies and drug addicts now wander into it and bathe there-it's really quite sickening. The Cehtco is probably the last "wild and free" flowing river in the state. The fact that you might choose to turn what remains of it into a loggers' paradise tells me a lot about your thinking. So just consider this, those of us who own land/pay taxes throughout Curry and Josephine Counties have paid enough to at least be heard as we try to defend what little hasn't already been destroyed! Over the past 26 years, I've watched my neighbors/inheritees log over 8000 acres-including stealing some trees off my own land rather than working for a living. I am sickened to death hearing the excuses people give for destroying everything in their path. STOP. THINK. AND PRESERVE! At least leave us the Chetco. I know of at least one logging company that clear cut almost all of it's Chetco proprties over the last 20+ years. Isn't that enough? Now slides on rainy days are all that remains of a once pristine watershed closer to Brookings,
tom-doolittle Anon I also understand and agree with the value and process of salvage The Responsible Official determines the breadth or narrowness of the need for action. timber following a wildfire. However, all of these salvage operations Please refer to the Best Management Practices (EA Chapter 2) and Design Criteria (EA must very clearly protect and improve the forest, they are NOT JUST A Appendix A) in the EA for examples of how the Forest Service proposes to implement the REVENUE or TIMBER OPERATION. project in ways that minimize or eliminate resource effects.
2232-1 I understand the need for some wood production, some revenue, and Refer to Response to comment 2232-1 most importantly fire reduction but logging must also be very carefully planned, environmentally sustainable, offering permanent protection of the forest, reducing impact of logging roads and erosion. The list of your responsibilities goes on and on. You must only think of this when you plan salvage timber operations. 2232-3
Page 33 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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The criteria that has been proposed of removing 40" trees where 30% The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage of the canopy has been damaged is absurd and wrong especially when harvest under the action alternatives. The species being targeted for salvage under the it requires 85% of the canopy to be damaged before removal of smaller action alternatives include Douglas fir and incense cedar, therefore they have been included diameter trees. This must be reversed- SAVE THE LARGER DOMINANT in Table 3. No other species would be targeted for salvage removal. However, any tree, TREES. Do not remove them. regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
2232-2 Wasbauer Marius 2245-1 I urge you to adopt alternative 3 in your assessment of logging Thank you for your comment. alternatives for the Chetco Bar Fire burrned area.
N Gary 2257-2 Please focus logging in existing plantations only. Alternative 3 addresses your concerns.
2257-1 We believe it is important to avoid logging in native forests, and that all Alternative 3 does not propose to salvage log unmanaged stands. The EA, Table 3 at 2-2 has green trees should be left and not logged. been edited to better reflect the intent of proposed salvage harvest under the action alternatives. The species being targeted for salvage under the action alternatives include Douglas fir and incense cedar, therefore they have been included in Table 3. No other species would be targeted for salvage removal. However, any tree, regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
Gardiner Christine 2265-1 this season, this year. We must not commit the travesty of post-fire The No Action alternative addresses your concerns. clearcut logging and new road construction in the Chetco River Watershed. This watershed must be protected in as intact a condition as we are able to achieve zucker lee
Page 34 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2310-2 We further wish to complain that your process is opaque: Despite The comments database email ([email protected]), receiving notification of the planned salvage and links to the specifics, in which you sent this email, is the link for input. Additionally, the project website ( there is no link for Forest Service input; and the Medford Mail Tribune is https://www.fs.usda.gov/project/?project=53150 ) includes a copy of the legal notice that not received by most Oregonians for determining the comment period: was published in the Medford Mail Tribune. Seems like a strategy to avoid public involvement.
2310-1 Writing on behalf of the 5 voting adults of my Oregon family: We wish Thank you for your comment, the NEPA process is not a voting process. The No Action to go on record as opposed to the salvage logging planned for the alternative addresses your concerns. Chetco Bar fire area.
Rutledge Donna 2363-1 My thoughts are that we need to leave all burned areas to revitalize The No Action alternative addresses your concerns. themselves in natures way. I've seen areas that have been allowed to grow back and in short measure there are many species living in the burned stumps and standing trees. These areas will also begin to produce many species of flora. I've also seen salvaged areas that struggle. My opinion is that timber should be left in all burned areas. No salvage contracts.
Rex Angela 2365-1 Burned over areas are important for ecological health and create The effects of the alternatives on wildlife habitat, soils, erosion, and sedimentation are unique habitat for both bats and woodpeckers. Clear cutting described in the EA, Chapter 3. destabilized soils, increases erosion and sedimentation in streams and rivers where salmon run, and removes habitat and structure from the landscape.
Journet Alan 2376-5 A commonly held misconception, applied partially because it serves the No where in the EA do we suggest that. Refer to the EA, Chapter 3, Climate Change section purpose of those who wish to log our forests ostensibly to protect us for more information. from mythic emissions, is that fires result in substantial carbon emissions, thus compounding the global warming problem. In fact, the data deny this claim.
Page 35 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2376-4 Fire impact is measured in terms of intensity, meaning the energy The EA states "The 2017-Chetco Bar fire burned approximately 191,197 acres. released during the fire, and severity, referring to the ecological Approximately 60,500 acres (32%) burned at high mortality fire that resulted in, for all damage the fire imposes. Fire impact is extremely patchy, with only practical purposes, a stand replacement event." EA at 3-6. very small percentages if total area burned suffering very severe fire damage.
2376-8 Fires do not result in soil compaction and erosion to anywhere near the The effects to soils are described in the EA Chapter 3 Soils section. same extent as logging. While the opening of the canopy might increase precipitation induced soil erosion and drying out, the presence of downed wood will minimize this, and the occurrence of regenerative succession will also reduce the impact. Meanwhile, the downed timber will decay and return nutrients to the soil, while logging will simply haul these away and burn what remains.
2376-11 My conclusion is that our forests will be best served if we simply leave The No Action alternative addresses your concerns. the burned trees, which serve as wildlife habitat and constitute a critical component of the natural recovery process. While I am not opposed to harvesting trees from our forests, I suggest that the best approach to the burned areas is to leave them to allow the forest to recover as it normally does from these critically important fires. Let us not compound the problem by imposing further devastation on the forest through logging.
2376-2 Oregon's forests are reportedly responsible for sequestering about 50% The EA states "The scope and degree of change from the action alternatives is minor. The of the in-boundary emissions of carbon dioxide from the state. This total area proposed for salvage (up to 4,090 acres) is a fraction of the forestland in the means conserving healthy forests can contribute substantially to project planning area and on the RRSNF as a whole. A project of this magnitude would reducing the state's contribution to the global problem climate contribute minimally to regional greenhouse gases. Furthermore, at the global scale, the problem. action alternatives direct and indirect contribution to climate change would be negligible, and therefore the project's cumulative effects on greenhouse gasses and climate change would also be negligible." (EA Chapter 3 Climate Change section)
2376-10 Since fire is a normal occurrence, and the landscape historically would The effects to complex early seral habitat are described in the EA, starting on page 3-8. be a mosaic of areas in various stages of succession from fire, these Specifically, the Proposed Action alternative would reduce about 1.5% of the complex early areas have become critical wildlife habitats. These habitats would be seral habitat in the Chetco Bar fire.
Page 36 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2376-6 The activity in forests that contributes most to carbon emissions is tree Climate change is a global phenomenon because major greenhouse gasses mix well harvest. throughout the planet's lower atmosphere (IPCC 2013). Considering emissions of greenhouse gasses in 2010 was estimated at 49 ± 4.5 gigatonnes globally (IPCC 2014) and 6.9 gigatonnes nationally (USEPA 2015), a project of this magnitude makes an infinitesimal contribution to overall emissions. Therefore, at the global and national scales, this proposed action's direct and indirect contribution to greenhouse gasses and climate change would be negligible. In addition, because the direct and indirect effects would be negligible, the proposed action's contribution to cumulative effects on global greenhouse gasses and climate change would also be negligible. (EA Chapter 3 Climate Change section)
2376-7 The claim that logging simulates fire in its impact is patently false. Nowhere in the EA do we claim that "logging simulates fire".
2376-3 The dry forests of SW Oregon have historically been subjected to The majority of the project area has been determined to be in fire regime 1 - 0-35 year frequent fires, possibly with a median Fire Return Interval before we frequency and low (surface fires most common) to mixed severity (less than 75% of the imposed fire suppression of as few as 8 years. All other things being dominant over story vegetation replaced (EA Chapter 3 Fire, Fuels and Air Quality section). equal (which they never are), this would suggest that 12.5% of the area should burn each year. If we travel back thousands of years, we find that the area burned annually during the last century, and especially recently, is much lower than it was. Indeed, comparing fire trends with climate, the primary driver of fire risk in this area, suggests we are experiencing a substantial fire deficit.
2376-9 There seems little doubt that the argument for salvage logging is not The EA states " The purpose of the Chetco Bar Fire Salvage project is to capture timber value based on a desire for promoting healthy, resilient, or carbon in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting sequestering forests. It is based merely on a desire to take advantage of from the 2017 Chetco Bar fire ." (EA at 1-4) the fire to extract maximal amounts of timber. Furthermore, the logging effort will undoubtedly target the largest trees, exactly those which are needed to support the area through its recovery.
2376-1 What is our objective in managing Federal Forest - our public lands? The EA states " The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire ." (EA at 1-4)
Smith Kimberly
Page 37 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
2381-1 The water is so clear and such a gorgeous color of blue, it looks The No Action alternative addresses your concerns. tropical, but instead of resting off of some island, it serves an ecosystem and habitat that's even closer to my heart: the beautiful Oregon wilderness and our very own Redwoods. I'm so grateful for this river and the watershed as a whole. Being there brings me peace. I swim and kayak in it every year. And it is vital to preserving this very special area and the plants and wildlife that reside there, and this is very important to me. The forests of the Chetco belong to all Americans, and it is our responsibility to restore rather than exploit the world-class values of this special place
Bonner Candace 2391-1 Look at the newest science, and do what is right for Oregon The use of best available science is described in the EA, Chapter 3.
Potter Dave 2394-4 And especially so if the logs are shipped raw to Asia. [That is so wrong, The export of unprocessed timber is restricted from lands managed by the Forest Service, not processing the logs into lumber in the U.S.] U.S. Department of Agriculture, and the Bureau of Land Management, U.S. Department of the Interior, in the West. In addition, the Forest Service and the Bureau of Land Management have implemented regulations to ensure that Federal timber is not substituted for private timber (Hines, Judith A. 1987. Log export restrictions of the Western States and British Columbia. Gen. Tech. Rep. PNW-GTR-208. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station; 13 p).
2394-5 Logging roads cost more than they return. And, long term, they erode No new road construction would occur. Temporary roads would be utilized and closed and soil into waters. They also greatly facilitate people poaching, off restored after salvage and related activities are complete. roading, growing pot and dumping old cars and garbage. No new logging roads, please.
2394-7 Please follow the needs and requests of we the majority. Very much The No Action alternative addresses your concerns. minimize industrial logging of the burn.
2394-2 Please keep clear cutting to minimum for special reasons such as The No Action alternative and Alternative 3 address your concerns. roadsides and other human use areas.
Page 38 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2394-6 Replanting forests often end up with single species or just a few tree The intent is to rely on natural regeneration wherever possible. If natural regeneration is species turning a forest into a form of farm fields. Forest ecosystems determined not to be adequate to comply with the NFMA five-year regeneration are not healthy with farm style tree plantings of one or two species. requirement to achieve stocking levels consistent with management objectives, site-specific Replanting must go to the cost of planting many species of trees and appropriate tree species mix would be planted by hand. shrubs to actually regrow a forest.
2394-1 Research shows that after fire logging is not beneficial to quality forest The EA states "Implementation of salvage logging may reduce the amount of natural regeneration. It is best to leave the forest plants and soils undamaged regeneration, if present, due to ground disturbing activities. This would most likely occur in by machinery - and new logging roads - if a renewed community of the ground based logging system units of the proposed action and alternative three (619 plants and animals is desired. acres and 336 acres). However, proposed artificial regeneration would mitigate this impact by planting site-specific appropriate tree species mix." EA Chapter 3 Vegetation section.
2394-3 We the majority are concerned about long term values such as The effects to resources are displayed in the EA, chapter 3. watershed, hiking, clean creeks and rivers, salmon, other fish species, rafting, fishing, hunting and aethetics. Long term these values are much more valuable than economic returns to some timber companies.
O'Brien Mary 2403-2 The only resources we truly have to weather the impending The EA states "The scope and degree of change from the action alternatives is minor. The radical shifts due to climate change are places such as the Chetco total area proposed for salvage (up to 4,090 acres) is a fraction of the forestland in the River and the forests that protect it. Please consider what we will project planning area and on the RRSNF as a whole. A project of this magnitude would lose here to open these vital forests to the degradation of clearcut contribute minimally to regional greenhouse gases. Furthermore, at the global scale, the forestry and the attendant roads. And conversely, please commit action alternatives direct and indirect contribution to climate change would be negligible, yourselves to the abundant opportunities in species wealth, human and therefore the project's cumulative effects on greenhouse gasses and climate change jobs, recreation, and plain safe drinking water that will flow from clean would also be negligible", EAChapter 3 Climate Change section. and un-industrialized places such as these.
Sanderson-Fox Lisa
2412-1 Protect water quality! Logging on public lands should focus on fire "There are no measurable direct, indirect, or cumulative effects to erosion or resiliency while protecting waterways from sedimentation and sedimentation, peak flows, stream temperature, or waterbody condition expected from the preserving habitat for fish and wildlife! Do not allow salvage Chetco Bar Fire Salvage project" (EA Chapter 3 Hydrology section) . logging to be a pretext to fulfill timber quotas!
Hathaway Kathy
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2417-1 Don't be conservative with our right to log these forests and don't set The EA states "The January 2018 scoping letter described the need to capture timber value us up for more fire and smoke in the years to come. Please consider the in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 citizens of S Oregon instead of just the salmon. acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." EA at 1-1.
2417-2 If I trusted the Forest Service I would have more confidence in how you This comment outlines the opinion of the commenter, and a Forest Service response is not manage and what you have proposed. But your agency hasn't garnered required. much respect lately so I would be more confident of someone else's assessment of logging for this area.
Maynord Barbara 2419-1 Please stop the discussion of destruction of this legacy and prevent ANY The No action alternative addresses your concerns. post-fire clearcut logging and new road construction in the Chetco River Watershed. Save the river and nature, you can make a difference in our country and our culture.
Rider Cynthia 2425-2 We are in favor of any activity which reduces the risk of fire and smoke The EA states "Areas adjacent to treatment units will remain untreated, this will reduce in 2018 and future seasons. continuity in fuels and overall fire danger in the near term, mitigating the potential for fire spread from these treatment units. "Reducing connectivity of surface fuels at landscape scales is likely the only way to decrease the size and severity of reburns until vertical diversification and fire resistance is achieved." (Thompson et al, 2007) From a fire standpoint the changes in fuels continuity on the landscape due to this project is considered negligible in the context of the broader event." EA Chapter 3 Fire, Fuels and Air Quality section
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Name Comment Text Response Text
2425-1 We urge the Forest Service to strongly consider salvaging timber on as The EA states "The January 2018 scoping letter described the need to capture timber value many acres of burned land as possible, to reduce fuel for future fires. in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." EA at 1-1.
Scimeca David 2432-1 Please maximize salvage and restoration efforts. The Proposed Action alternative is the maximum salvage alternative. Hill Roberta 2439-1 Please do not convert post-fire native forests into second-growth The No Action alternative addresses your concerns. timber plantations.
2439-2 We must focus management near homes and communities AND fiercely Alternative 3 addresses your concerns. protect remote backcountry forests and tributaries.
Mead Lucy 2474-1 And please recognize the wisdom upon which OregonWild has built its Thank you for your comment. many productive and reasonable recommendations. Their approach to so many of these issues is measured and so intelligent.
Clemons Carl 2491-1 I suggest that you read his dissertation. Thank you, we have read many studies by Donato. Richie Marina 2609-1 I'm very much against logging in roadless areas--period--our future None of the alternatives evaluated here include any actions in the inventoried roadless wilderness. And that's what I hear is in the proposal to log over 4,000 areas (EA at 1-9). acres of the forests impacted by the Chetco Bar Fire is of concern to me. Koenig John
Page 41 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2721-1 I urge you to not follow suit with public lands. Instead hold them to a The No Action alternative addresses your concerns. higher standard and allow for natural recovery. Standing dead timber provides food and shelter for many forms of wildlife.
Knopf Clay 2751-2 Please consider limiting any logging to a minimum number of dead The No Action alternative addresses your concerns. hazard trees, in areas that have been previously logged and roaded. These limitations will allow for natural recovery in native stands and in unroaded areas, maintain important large snag habitat and structure, including long term recruitment, and help protect the values so much of the public holds dear about the Chetco area.
2751-1 Science clearly shows that road building and logging in fire scarred The best available science is considered in preparation of this EA. The concept of "best ecosystems is destructive to recovery of soils, biotic communities, and available science" is also a matter of opinion to some degree since scientists can legitimately water quality and quantity downstream. Wild Salmon and other disagree about the meaning or impact of individual study results. As a general matter, we threatened wildlife deserve and require as much habitat protection as show consideration of the best available science when we insure the scientific integrity of possible, as mitigation for the damage done by the Chetco Bar Fire. the discussions and analyses in the project NEPA document. (EA at 3-1)
Harris Alexander 2884-1 I request that you leave un-roaded parts of the wild landscape alone! Alternative 3 addresses your concerns.
Stewart Crista 2976-1 The Tribe would like to be immediately notified if an inadvertent If any cultural materials are encountered during the course of the project, then all ground discovery is made during the course of work. disturbing activities in the immediate vicinity of the discovery will cease and a 30 m avoidance buffer will be established. All artifacts and materials will be left in place and protected from further damage. The Contractor will promptly notify the Forest Service Representative (FSR). The FSR must then immediately notify the Forest Archaeologist and District Ranger of the discovery. Work will not resume in that area until the Forest Archaeologist or designated Forest Service professional archaeologist has evaluated the material and provisions regarding inadvertent discoveries in Appendix D of the Programmatic Agreement for the 2017 Chetco Bar are followed to comply with 36 CFR 800.13 (Section 106). (EA Appendix A at A-36)
Cooper Romain
Page 42 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2977-6 Confine post fire logging to Matrix. Avoid logging in LSR, Wild & Scenic The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix River corridors and in "special areas" such as Botanical Areas. land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4). Only matrix land allocations are included in this project.
2977-7 Do not log in Inventoried Roadless Areas. None of the alternatives in this project include any actions in the inventoried roadless areas (EA at 1-9). 2977-5 Follow the Aquatic Conservation Strategy conservatively and strictly in The purpose of this project is to capture timber value in the matrix land allocations by riparian areas. harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4). Only matrix land allocations are included in this project.
2977-8 Leave uncut buffers around Wilderness, Wild & Scenic River corridors, All of these areas will be protected as determined necessary. Inventoried Roadless Areas, Botanical Areas and other "special" areas. This will enhance recreational opportunities and retain biological/ ecological values. 2977-10 Manage conservatively and carefully to prevent the introduction and The effects to invasive plants are described in the EA, Chapter 3 Invasive Plants section. limit the spread of any non-native plants or animals.
2977-11 Manage conservatively and carefully to prevent the spread of Port Salvage logging and other connected actions increase the risk of spreading PL. In compliance Orford Root Disease and Sudden Oak Death disease. with the Record of Decision for the Land and Resource Management Plan Amendment for Management of Port-Orford-cedar in Southwest Oregon, Siskiyou National Forest (USDA Forest Service 2004) a POC risk analysis has been documented using the risk key. The risk key is in the project record and is used to clarify the environmental conditions that require implementation of one or more of the disease controlling management practices listed in the LRMP amendment. Project design criteria described in chapter 2 would minimize or eliminate the risk of spreading PL. Therefore there would be no direct or indirect effects to the spread of PL. (EA Chapter 3 Vegetation section)
2977-3 Restrict post fire logging to roadside logging and managed stands. Alternative 3 addresses your concerns.
2977-4 Retain large numbers of snags on all units. Especially, retain all the very Snags will be retained in all units according to the project design criteria in the EA, Appendix large snags (over say 35" dbh). A. Additionally, the Proposed Action would remove snags on less than 2.5 percent of the National Forest System lands that burned in the fire. The remaining 97.5 percent of the fire would contain snags at various levels.
2977-2 Severely Limit helicopter yarding as the heavy use of fossil fuels adds to The use of helicopters allows for full suspension of logs and therefore less ground negative impacts of climate change. disturbance.
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2977-1 Severely limit new road construction including "temporary" road About 13.5 miles of temporary roads would be constructed and rehabilitated after use. construction. Limit harvest to trees that can be yarded from existing Temporary roads are not intended to be included as part of the forest road atlas, as they are roads managed by the projects or activities under which they are authorized and decommissioned at the conclusion of the authorized activity. No new temporary roads would be constructed within riparian reserves. Temporary roads would be closed and restored after salvage and related activities are complete.
2977-9 Where practical, close roads where vehicle use can or will cause Closing roads is outside the scope of this project. Closed roads opened and used for log haul excessive resource damage. Prohibit any off road vehicle use in the fire will be reclosed with implementation is complete. Erbe Howard 2979-2 (2) From a friend of mine; Doug-fir trees 10"- 40" DBH with up to 30% The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage green canopy will be logged the same as 100% dead, EA:2-2. This is harvest under the action alternatives. The species being targeted for salvage under the pure greed with no redeeming rationale. Always compare this Chetco action alternatives include Douglas fir and incense cedar, therefore they have been included Bar proposal to "Siskiyou National Forest Supervisor Scott Conroy, who in Table 3. No other species would be targeted for salvage removal. However, any tree, wisely prohibited green tree logging with the biscuit ROD". We need to regardless of species, that is determined to be a hazard to operations may be removed for oppose this green tree timber grab vehemently: "NO Green Tree safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as Logging." Everybody including the general public will understand this per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and reasonable request. We do not want to wait till we see green old marking guidelines for more information about the species targeted for salvage harvest and growth trees on log trucks. snag and down wood retention levels.
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2979-5 Keeping the Chetco River running clear and protecting the wild Chetco None of the alternatives evaluated in this project include any actions (except haul routes on fish runs should be the top priority of the U.S. Forest Service. existing roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined to have no effect to water quality. The rationale for this determination is documented in the Hydrology section. The project incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea- run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-9 to 1-10)
2979-4 Please consider limiting logging activities to previously managed stands Alternative 3 addresses your concerns. while retaining unroaded wild-lands.
Page 45 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
2979-3 what are the cumulative effects from the logging that's already been The cumulative effects of private salvage logging has been described in the EA, where done over there, esp. private in the area. I haven't looked too far into it applicable. yet, I'm assuming a lot of this salvage is going to be clear-cut and replant into plantation?
2979-1 You say you are going to honor the ACS in that you state there will be Following the salvage of the fire killed trees from the 1987 Silver Fire on the Siskiyou nothing taken out of Riparian Reserves. I feel the Riparian175' tree National Forest, the effectiveness of riparian buffers were monitored. A summary of the height is on the low end, esp. given BLM Picket West is 190', but I'll take monitoring results found that buffer areas were very effective in maintaining stream bank no cut in Riparian over the alternative. I'm also not totally on board integrity as well as reducing sediment delivery (Kormeier, 1995). The Silver Fire used the with stating that upslope sedimentation will be filtered through the following Siskiyou Forest Plan buffer widths: 150 feet on fish-bearing streams 100 feet on Riparian, esp. in the coastal rain belt. We've always kind have known nonfish-bearing perennial streams 25 feet on intermittent streams Both alternatives have that argument was weak at best anyway! Lastly, I think I saw no harvest riparian areas with a width of 175 feet or greater that exceeds the buffer width somewhere in the EA You have a problem with a road and needed to protect streams from sediment delivery form salvage operations. There were sedimentation (don't quote me here), it's the same old argument ……. reports this winter of elevated turbidity on the lower Chetco River. The source was You know you're doing work in here … Fix it! identified to be active private log haul during winter storm events causing road fines to be delivered to the road ditch and then to the Chetco River. Oregon Department of Forestry notified the company of the situation. As mitigation measures, they placed additional road rock surfacing and put hay bales in the ditches to filter out fine sediment. Forest Service resource specialist's field surveyed Chetco Bar high burn severity areas during winter storm events. The small streams in these areas were running clear with no signs of streambank or channel bottom instability. Larger streams below these areas were also clear. This is consistent with the turbidity monitoring of both the past Silver and Biscuit fires that concluded elevated turbidity from the fires is not a concern. (EA Chapter 3 Hydrology section) Forest roads used for salvage would have road maintenance activities to varying degrees, dependent upon severity of road damage, potential for erosion and sediment production, and designed maintenance level. (EA at 2-3)
christiekuper 2980-2 Please do not convert post-fire native forests into second-growth Alternative 3 addresses your concerns about "not convert post-fire native forests into timber plantations. Please work with the public to focus management second-growth timber plantations" and "focus management near homes and communities near homes and communities while protecting remote backcountry while protecting remote backcountry forests and tributaries" . forests and tributaries.
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2980-1 The Forest Service should focus post-fire logging on existing plantations. Both of the action alternatives include " buffers to minimize damage to streams ". After reviewing your project proposal I support the limiting logging to Alternative 3 addresses your concerns about "limiting logging to plantations only" . The No plantations only, avoids steep terrains, do not build new roads, and Action alternative addresses your concerns about " avoid steep terrains, and do not build include buffers to minimize damage to streams new roads ." reagan peg 2982-1 I urge you to use the lightest touch possible and while I would prefer The Proposed Action alternative proposes to salvage harvest less than 2.5 percent of the that you do nothing I understand you are not seriously considering that. area burned on National Forest System lands. Additionally the No Action alternative addresses your concerns.
Vileisis Ann 2983-3 Avoid cutting live trees We are concerned about your plan to log Smith and Cluck 2011 provide the best available science for identifying trees with a scorched trees. Many trees that appear to be scorched actually have probability of mortality following fire. This guideline has been recommended by the Forest the capacity to revive and will continue to put out seeds, carrying the Health Protection zone entomologist Bill Schaupp, Ph.D. based on 27 years of experience. A genetic legacy of thousands of years of local adaptation to the utterly Rapid Assessment following the fire and other correspondence on the use of Smith and unique conditions of the Chetco watershed. Such adaptation may prove Cluck 2011 for the Southern Oregon region is included in the project record. Additionally, particularly important given predicted risks of climate change. We the entire Region 6 within the Pacific Northwest in Oregon and Washington uses the Field are concerned that the marking guidelines you plan to use to predict Guide for Danger-Tree Identification and Response along Forest Roads and Work Sites in tree mortality (Smith and Cluck, 2011) are based on conditions and Oregon and Washington, 2016. On pages 44-45 of the danger tree identification guide, and forest associations in the Sierra Nevada of California and will result in subsequent training, refer to their methodology for determining mortality in large tracts of too many green trees unnecessarily cut. We urge you to leave more, or fire killed trees. If the diameter of Douglas fir is greater than 40"and there are any green all, live trees. needles, regardless of % scorch, it will be retained. If any large trees or snags are deemed a danger tree, then they can be felled. Legacy trees are not targeted for salvage. See the following excerpts from the project design criteria: Protect live legacies - Maintain a 70-foot (1/2 site potential tree) un-treated buffer around any live legacy trees with potential structure. No live legacy trees would be removed for any reason including roads, landings or yarding corridors. This is for Marbled Murrelet habitat.
2983-2 Avoid logging in "undeveloped," previously unmanaged lands Alternative 3 addresses your concerns.
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2983-16 Beyond this logging project, we urge the Forest Service to follow up Thank you for your comment. This is outside the scope of this project, however we are with a plan that addresses outstanding needs for fire safety, watershed always learning from the past. health, and forest resiliency in the long term.
2983-11 However, on page 3-162, there is a lack of supporting references in the The proximity to Chetco Bar fire of the three naturally-regenerated stands seemed analysis that should be remedied. The EA notes research, Little et al. particularly relevant in the research (Little et al., 1995) reference in the EA. The intent of the 1995, which looked at conifer regeneration following a fire about 100 local reference is to illustrate that Douglas-fir regeneration was delayed and prolonged up years ago, but does not reference more recent, relevant local research, to 40 years later following the 1881 fire. However, additional supporting references have such as: Shatford, et al., 2007, "Conifer regeneration after forest fire been added. This prolonged natural regeneration concept is supported by (Hibbs, 2009) as in the Klamath-Siskiyous: how much, how soon?" Journal of Forestry one of the key findings noted abundant conifers regenerating 10 to 15 years post-fire. The 105: 139-146. Donato, et al., 2009,"Conifer regeneration in stand- paper also noted scarce natural regeneration greater than 400 meters from living trees and replacement portions of a large mixed- severity wildfire in the Klamath- was most limited on drier, lower elevation, south facing slopes. Also another regional study Siskiyou Mountains," Canadian Journal of Forest Research, 39: 823-838. of conifer regeneration 9-19 years after fires in southern Oregon and northern California Hibbs, 2009, "Recovery after Severe Fire in the Klamath-Siskiyou: What noted conifer regeneration to be surprisingly protracted and variable' (Shatford et al., Happens without Planting?" Fire Science Brief, 49:1-6. 2007). Another recent regional paper Disequilibrium of fire-prone forests sets the stage for a rapid decline in conifer dominance during the 21 st century (Diaz et al., 2018) about potential impacts from climate change noted 'current forest extent may not reflect current climatic patterns' and using a landscape simulation model estimated about one third of the Klamath forest landscape (northern California and southwest Oregon) could transition from conifer dominated forest to shrub/hardwood chaparral, triggered by increased fire activity coupled with lower post-fire conifer establishment; 'the area of high severity fire in large patches increased under climate change scenarios hampering a rapid recolonization of new tree recruits (further distances from seed sources)'. Post-fire conifer establishment probability was reduced under climate change due to increased summer drought. Potentially delayed natural regeneration is a concern to meet the NFMA requirement: '(E) insure that timber harvested from National Forest System lands only where - (ii) there is assurance that such lands can be adequately restocked within five years after harvest. The Forest's intent is to rely on natural conifer regeneration wherever possible, however the agency is required under NFMA to restock harvested stands within this five year timeline.
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2983-11 Restocking with conifers is an important component of timber production objectives on continued Matrix land allocations. Current Forest direction for the Chetco Bar fire is to delay artificial regeneration and survey for natural regeneration post-salvage to determine if stocking levels are sufficient to meet the NFMA five-year regeneration requirement. If natural regeneration is determined not to be adequate to achieve stocking levels for Matrix within the NFMA timeline, site-specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre to meet LRMP objectives.
2983-13 In addition, the EA should include recognition that some areas should The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix be allowed to return as meadows. land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4) not to restore meadows, however restoring meadows may be analyzed under separate analysis. The NFMA at Sec. 3 (d)(1) It is the policy of the Congress that all forested lands in the National Forest System be maintained in appropriate forest cover with species of trees, degree of stocking, rate of growth, and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management in accordance with land management plans (EA at 3-160). Additionally, the EA at 2-4 allows " regeneration requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand ." Therefore, it may be appropriate, on a case-by-case basis as determined by a botanist, to plant other species like deciduous oaks.
2983-14 In analyzing the effect of the proposed project on climate change, the Thank you for your comment. That section of the EA has been revised to include more EA refers to research from central Oregon (Meigs, et. al., 2009), an area appropriate research. with a very different forest ecosystem, suggesting that the burned area will likely be a carbon source for decades before carbon sequestration from tree growth will exceed competition. However, there is a more recent and more relevant paper from our Siskiyou region that provides more refined findings and suggests greater potential for variation in emissions: Campbell, et al. "Carbon emissions from decomposition of fire-killed trees following a large wildfire in Oregon, United States," Journal of Geophysical Research: Biogeosciences, (2016), 718-730.
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2983-6 Marbled murrelets have high nest site fidelity, and while the EA stated PDC are included in the EA to protect existing nest trees that may occur within or within 70 that much of this habitat area is burned, there should still be surveys feet of salvage activities (EA, Appendix A at A-5) This protection is a 70-foot no-treat buffer conducted for murrelet activity before cutting in these stands. intended to retain existing screening or protection that large dead or dying trees may be providing a potential nest site. PDC also restrict cutting operations during the critical breeding season to minimize disruption of murrelet nest sites (EA Appendix A at A-5).
2983-5 Northern spotted owl: The series of significant wildfires in the greater Potential occupancy of existing habitat and use of burned habitat was considered in the Kalmiopsis area has left spotted owls and other species that depend on analysis of effects to NSO (EA Chapter 3 Wildlife section). PDC are included to minimize old growth forests with lack of critical habitat. Though the fire has disturbance to NSO during the critical breeding period (EA Appendix A at A-4). Furthermore, damaged viability for known core areas and home ranges, given broad the Forest is conducting NSO surveys in 2018, and plans to conduct NSO surveys in 2019 (EA loss of habitat, any patches of remaining forest may be occupied. Chapter 3 Wildlife section).
2983-9 Please keep track and monitor management activities so that we may Wildlife biologists from the Forest and USFWS will review the layout of a sample of units continue to learn and refine understanding about wildfires and how with the various snag and down wood retention PDCs to ensure compliance. The Forest is post fire logging activities affect forest conditions. required to complete implementation monitoring reports annually to USFWS for projects under consultation. Additionally, post implementation monitoring would occur for most resources as needed. A proposed PNW Study evaluating long term effects of fuel treatments may also occur under a separate analysis.
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2983-12 the EA suggests that there has been debate but not consensus about Thank you for the reference. In addition to Zald and Dunn (2018), an article from Thompson the effects of young plantations on fire severity, but there are no et al, 2007 address both the Silver (1987) and Biscuit (2002) fire from the Siskiyou National supporting references to demonstrate the range of debate and findings. forest. Its focus was on managed and unmanaged vegetation and subsequent management We recommend adding appropriate citations to the EA to provide a following these events. An important input of both Thompson and Zald and Dunn, is that better accounting to the public of research considered. Along those there are no data documenting the density of conifers per acre in either study. It is accepted lines there is one very recent paper to consider: Zald and Dunn, that on private industrial forest lands, densities will be maximized. Similarly, on public land "Severe fire weather and intensive forest management increase fire planted after the Silver and Biscuit it is also recognized that trees per acre would be higher severity in a multi-ownership landscape," Ecological Applications, April and more evenly spaced than one might find in an unmanaged stand. The Douglas fire of 26, 2018. 2014 demonstrated that young intensively managed plantations can burn with high severity, as compared to older adjacent stands (Zald and Dunn 2018). An important observation from Zald and Dunn is the stand age used in the analysis, BLM stands used a stand age of 109 years while private forests used 52 years. This is important as older trees are larger with thicker bark and greater height to live crown. Even a moderate fire in a young forest can have high severity effects as compared to similar conditions in older forest. Ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity (Coppoletta et al 2016) (EA Chapter 3). As Thompson points out, "young forests, whether naturally or artificially regenerated, may be vulnerable to positive feedback cycles of high severity fire." There is a large component of early seral brush species that occupy sites soon after high severity fire. Albini noted a strong shrub response can further add to hazardous surface fuel conditions. In Coppoletta et al 2016, reburn severity was highest in plots that contained more than 60% cover of shrubs. It is expected that in the Chetco Bar area, particularly in the Douglas fir/Tanoak plant association that there will be a strong shrub response. If fire returns to these sites before the stand reaches maturity, high severity fire can return to the site. "Many of the plantations examined in this analysis had lower conifer densities and a larger component of shrubs and hardwoods that would be found in typical intensively managed plantations of the same age."
2983-12 This suggests that whether conifer or shrubs, short return intervals can maintain vegetation continued in a perpetual early seral state. Thompson et al 2007, "Reducing connectivity of surface fuels at landscape scales is likely the only way to decrease the size and severity of reburns until diversification and fire resistance is achieved."
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2983-15 We are aware that in the recent roadside logging sale, there are already The Letter you reference describes situations that are specific to the Roadside Danger Tree reports of trees marked for logging within riparian corridor buffer. Abatement project Categorical Exclusion . All timber sales under the Roadside Danger Tree Richard Nawa (KS Wild) has reported to the Forest Service that Packer Abatement Categorical Exclusion will contain a 100 foot fall and leave, no yarding buffer, RS Salvage timber sale units have been located within Riparian which falls under a separate NEPA decision. The Chetco Bar Fire (CBF) Area Salvage Project , Reserves. How will the Forest Service ensure that marking crews are will exclude all riparian reserves (175 feet (non-fish bearing perennial/intermittent and instructed not to place timber sale units within the 175 ft Riparian ephemeral streams), and 350 feet (fish bearing, perennial)) from harvest activity. Reserves on each side of streams (350 ft. for fish streams)?
2983-8 We are concerned about ground-based logging on severely burned The purpose of this project is to capture timber value in the matrix land allocations by soils. Peer reviewed publications by Bestcha et al. 2004 and Karr et al. harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 2004. recommend against ground-based salvage logging on moderate 1-4). Project design criteria S-1 through S-15 have been developed to mitigate detrimental and severely burned soils. According to the EA, "severely burned soils distrubance to soils. In addition, S-1 and S-2 were developed to prevent further soil are considered to be detrimentally disturbed." We recommend that you degradation, and to ensure units are at or below 15% detrimental soil disturbance per consider helicopter logging on severely-burned soils or dropping the Forest Plan and Regional Standards. The proposed action did consider helicopter logging on severely burned areas from units. severely burned soils on 27 percent of the proposed acres (EA at 2-2), as well as, 15 percent of proposed acres in Alternative 3 (EA at 2-5). The No Action alternative addresses your concerns and eliminates proposed project activities on all burned soils.
2983-7 We are concerned about the proposed salvage activities in the A description of the analysis methods for slope stability in the project area is found in the preferred alternative slated for 902 acres in SRI landscape types 8 and 9 Soils Resource Report at pages 3-4 and EA, Chapter 3 Soils section. Potential effects from that are identified as having "high mass failure potential." The EA Alternative 2 and 3 on slope stability is discussed in the Soil Resource Report at pages 32-33, indicates that project design features will avoid the most problematic including the indicators in the field used to help identify instability, and additional areas during layout and implementation to "reduce the potential for descriptions of instability that have been found in the project area and buffered out of units mass failures." However, having seen how logged over landslides can (page 34) (EA Chapter 3 Soils section). All unstable or potentially unstable areas would be impact streams, we think it would be more prudent to avoid altogether excluded from treatment areas per Project Design Criteria on page 24 (ibid.), therefore no these high-risk areas, or adopt the more-protective Alternative 3 option impacts to slope instabilty are expected from proposed project activities in these landtype in this particular case. units. The No Action Alternative also addresses your concerns by not proposing any management activities.
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2983-4 we remain concerned that the EA presents an overly optimistic The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical evaluation regarding impacts on SONCC coho salmon with its "no habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the effects" determination. Because of the high density of streams, action alternatives, then no cumulative effects can occur from the proposed activities. the presence of many roads in the project area, and cumulative impacts owing to less restrictive logging practices on proximate private land, we are concerned about the high likelihood that soil disturbance will lead to sedimentation despite mitigating project design features. We are also concerned that by planning all the logging projects before completing consultation with NOAA (the BiOp is still not available to the public) that the cart is put before the horse, so to speak. The Chetco SONCC coho run is particularly imperiled and so impacts should not be taken lightly. In particular, we are concerned about cumulative impacts in tributary sub watersheds that will experience heavy logging on private lands, such as Panther Creek. Since SONCC coho spawning occurs in smaller tributary watersheds, we urge you to analyze impacts in that framework in order to determine how to reduce impacts to these ESA threatened fish. We are also more generally concerned about road failures and chronic, road-related sedimentation both during and after the timber sales. We urge vigorous implementation of full riparian buffers and all possible sediment reduction measures on roads to minimize impacts to SONCC coho.
2983-10 We urge the Forest Service to assure that all temporary logging roads Temporary roads are not intended to be included as part of the forest road atlas, as they are are quickly and fully restored to avoid damage from sedimentation and managed by the projects or activities under which they are authorized and decommissioned risks of spreading invasive weeds and pathogens. at the conclusion of the authorized activity. No new temporary roads would be constructed within riparian reserves. Temporary roads would be closed and restored after salvage and related activities are complete. (EA at 2-3)
2983-1 We were very disappointed to see in the draft EA that only 2 out of 19 Thank you for your comment. At least 6 papers were considered in the Final EA. papers were considered and included. carr Janet
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2984-1 Congressman DeFazio made the comment that Oregon has a backlog of Temporary roads would be closed and restored after salvage and related activities are restoration projects totaling approximately five billion dollars. Given complete using monies generated from the salvage sale. that dollar quantity of incomplete projects, there does not appear to be any good reason to add to that deficit with new temporary roads built to access and salvage logs.
2984-3 Please make an evidence-based decision, based on verifiable science The best available science is considered in preparation of this EA. The concept of "best that protects the watershed. available science" is also a matter of opinion to some degree since scientists can legitimately disagree about the meaning or impact of individual study results. As a general matter, we show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document. (EA at 3-1)
2984-2 The proposed EA does not address cumulative impacts and is Cumulative effects are addressed in the EA, Chapter 3. deliberately vague.
Niemi Ernie
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2985-1 A. Failure to Provide an Evidence-Based Estimate of Expected Revenues The project proposes to salvage dead, dying or damaged timber. The current market prices and relatively higher prices paid for raw saw logs has increased in recent years following the 2008 recession. The NEPA process and timber sale preparation requirements are followed to inform the responsible official what is needed to sell timber from the national forest. For this salvage sale proposal, information from the RAT report and field reconnaissance was used to determine financial efficiency. The recommendation to propose salvage logging was based on the stands that were burned over. They contain primarily Douglas-fir, a product valuable to society and to the local economy. Once the financial efficiency has been determined, no other analysis is required past the project initiation. For this salvage proposal, an economic efficiency , as recommended, is used to further inform the decision maker as to the viability of the proposed action, to help refine the actual salvage acreage, and to help design an implementation plan . The effects to other resources are described in the EA, Chapter 3. Refer to FSH 2409.18 - timber sale preparation handbook Chapter 10 - for information on the timber sale process. See FSM 2430 for direction on preparing financial and economic analyses. See FSM 1970, FSH 1909.15, Environmental Policy and Procedures Handbook, FSH 1909.17, Economic and Social Analysis Handbook, and FSH 2409.13, Timber Resource Planning Handbook, for analysis procedures and additional direction. Refer to FSM 1900 - PLANNING CHAPTER 1970 - ECONOMIC AND SOCIAL EVALUATION 1970.6 - The responsible line officer determines the scope, appropriate level, and complexity of economic and social evaluations to meet overall objectives and policy (FSM 1970.2 and 1970.3). The scope and depth of analyses depend on the potential social and economic effects of the plan, project or program under review. In many planning and management situations, applicable laws and regulations or Forest Service policy specify analysis requirements. The cost and availability of social and economic data may be considered when determining scope. Refer also to 1971 - ECONOMIC EVALUATIONS
Ruediger Luke
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2986-68 "Eagle Creek and North Fork and Mineral Hill Fork, has naturally Please see response to comments 2989-15 and 3336-2 for discussion on steep, unstable sediment rich streams. This has been augmented by tractor yarding of slopes. No new system road construction is proposed for the project. See response to large clearcuts and road construction on steep, unstable slopes (USDA comment 2986-33 in regards to temporary roads. Also, refer to the Hydrology Report, 1996, p. 33)." Both these streams are proposed for wide-spread, Direct and Indirect Effects Common to the Action Alternatives subsection and the EA, watershed wide post fire logging and new road construction. Post-fire Chapter 3 Hydrology section for effects discussion on turbidity from log-haul. In addition, logging and new road construction in streams such as Eagle the no action alternative addresses your concerns. Creek/Mineral Hill Fork that already contain elevated levels of stream turbidity should be cancelled.
2986-30 1. Pacific Fisher and Marten According to the Seiad Horse Risk Refer to the response to comment 2986-45. Reduction EA published by the Klamath National Forest, structurally simplified openings created by implementing post-fire logging will created barriers to species dispersal. All units over 160' wide will create barriers to dispersal for late successional habitat associates like the Pacific fisher and marten ( Seiad Horse EA). These impacts can become compounded by unit configuration and surrounding landscape conditions. In some cases, proposed logging units will create nearly complete barriers for dispersal between watersheds. The impact of post-fire logging on Pacific fisher and marten populations could be severe given the relative lack of structural complexity in much of the lower Chetco River watershed. Compared to the rest of the Chetco River watershed, the more productive soils and forest associations in the lower Chetco River contain the highest potential habitat value for the Pacific fisher.
2986-67 1. Post Fire Logging should not be allowed in Riparian Reserves and all None of the Action alternatives in this project propose salvage logging in riparian reserves. activities must comply with the Clean Water Act and Aquatic All activities in this project comply with the Clean Water Act and the Aquatic Conservation Conservation Strategy Strategy. 2986-27 1. Post-fire logging in Post-fire Foraging Habitat for the Northern Alternative 3 addresses your concerns. spotted owl should be canceled. Considerable controversy exists regarding the utilization of post-fire foraging (PFF) habitat for the NSO.
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2986-66 1. The Chetco Bar Fire Salvage Project currently does not include any None of the Action alternatives in this project propose salvage logging in late successional post-fire logging or re-planting in LSR forest or Inventoried Roadless reserves or Inventoried Roadless areas. Areas, under no circumstance should these areas be included.
2986-60 1. The Chetco Bar Fire Salvage Project EA failed to adequately analyze Negative impacts to natural conifer regeneration from salvage logging is not likely to be a the impact of post-fire logging on succession/recovery/productivity long-term problem due to the prolonged period of natural conifer recruitment post-fire that occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon State University researcher found that conifers continue regenerating 10 to 15 years after a fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' research "suggests that early salvage logging may not make much difference to regeneration in the long run because they found that successful and abundant conifer recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetation section. See also the analysis to complex early seral habitat in the EA, Chapter 3 starting at 3-5.
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2986-38 1. The Draft EA failed to adequately disclose or analyze the impact of All proposed salvage activities are within the matrix land allocation and are not within any post fire logging to connectivity and dispersal of late successional inventoried roadless areas. The 1994 NWFP ROD on page B-1 provides a general ecological habitat associates such as the Pacific fisher, marten and Northern basis for forest management describing the intent of the standards and guidelines to spotted owl. Portions of the project area contain important "provide guidance for situations not specifically covered by the standards and guidelines." It connectivity habitat, connecting the Pacific Ocean to the interior further states "[t]he matrix is an integral part of the management direction included in mountains and the Kalmiopsis Wilderness Area. these standards and guidelines. Production of timber and other commodities is an important objective for the matrix. However, forests in the matrix function as connectivity between Late-Successional Reserves and provide habitat for a variety of organisms associated with both late-successional reserves and younger forests. Standards and guidelines for the matrix are designed to provide for important ecological functions such as dispersal of organisms, carryover of some species from one stand to the next, and maintenance of ecologically valuable structural components such as down logs, snags and large trees. The matrix will also add ecological diversity by providing early seral habitat." (NWFP ROD pp B-1 to B-2) Furthermore, the NWFP ROD describe provisions for management following natural disturbances in LSR and matrix. Specifically, "[I]n the matrix, objectives for management after stand-replacing events will generally differ from those for [LSR]. Economic benefits of timber production will receive greater consideration. For example, the commercial salvage of dead trees will be less constrained, and replanting disturbed areas will be a high priority'. (NWFP ROD pp B-8 to B-9) A considerable amount of LSR and administratively withdrawn land allocations provide connectivity between the Kalmiopsis Wilderness and the lower Chetco River and between the Kalmiopsis and the westernmost boundary of the Siskiyou National Forest (SNF) on the Pistol River. The SNF comprises roughly 78 percent of the Chetco River Watershed. LSR, administratively withdrawn and congressionally reserved lands are removed from scheduled timber harvest and provide habitat connectivity on 69 percent of the SNF in the Chetco River watershed.
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2986-38 Matrix lands comprise 9 percent of the Chetco River watershed. Proposed salvage activities continued comprise less than 2 percent of the Chetco River watershed. While proposed salvage units, landings and temporary roads would reduce habitat complexity offered by the existing snags, these units would retain snags and down wood at levels that comply with NWFP and Siskiyou Forest Plan direction for matrix supplemented by best available science in the Siskiyou Supplement and DecAID while also providing early seral habitat (EA Chapter 3 Wildlife section). Furthermore, project design criteria to retain legacy snags within units that were previously NRF habitat for the northern spotted owl minimize effects of proposed harvest to structural elements associated with late successional habitat also used by marten and fisher. The remaining SNF lands outside of proposed salvage activities that comprise 76 percent of the Chetco River watershed would continue to provide habitat connectivity as it exists. The SNF comprises roughly 59 percent of the Pistol River watershed. Matrix lands comprise 27 percent of the Pistol River watershed and the remaining 32 percent of the SNF is lands removed from scheduled timber harvest. Proposed salvage activities comprise 1 percent of the Pistol River watershed. The remaining 58 percent of the SNF would continue to provide habitat connectivity as it exists. Furthermore the Wildlife section of the EA Chapter 3 describes the effects of the action alternatives to undeveloped areas within the connectivity corridors identified by the commenter. As described, proposed activities would affect from 0 to 10 percent of these areas and would retain snags and down wood to meet the standards and guidelines for matrix. The remaining majority of these corridors would continue to provide habitat connectivity as they exist.
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2986-58 A similar conclusion was found by Donato (2006) who determined that Harvest operations are recognized as contributing to increased surface fuel loading and residual dead wood does not influence reburn potential as significantly reduced snag densities within harvest unit boundaries. Surface fuels from harvest as does the structure of regenerating forest. Thus, even salvage logging operations will most likely be the biggest contribution to future fire risk for approximately with slash disposal disturbs natural recovery, creating dense plantation 15 years, at which time decomposition will have reduced the continuity of surface fuels, and stands where fuel connectivity and fire severities are unnaturally high. after live fuels, (both brush and trees) have completely occupied the site. Thompson et al 2007 points out, "young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". It is expected that there will be a strong shrub response that can exacerbate surface fuel conditions. (Albini 1976) Furthermore, ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity (Coppoletta et al 2016). Reforestation in the action alternatives will also increase the continuity of fuels on the site. Appropriate species mix and planting densities will help to ensure that there is sufficient regeneration but only in amounts required to meet reforestation requirements. Current guidelines are to achieve 125-150 trees at 4.5 feet tall per acre. The preferred method is for natural regeneration, artificial reforestation will occur where a natural seed source is not available. Young conifer regeneration will combine with shrub species to occupy the growing space on the site, when full site occupancy is realized, ambient conditions will determine when and if these live fuels are available to burn. It is anticipated that even with natural or artificial regeneration, the continuity of shrub layer will drive future fire events for the near term, overriding the influence of conifer regeneration in activity units. Allowing for unplanted areas, openings and planting at lower densities can serve to break up continuity of fuels and reduce future fires intensity and severity. In all, the effects of this treatment in terms of potential fire behavior are minimal due to the small acreage of treatments relative to the larger areas of high severity in the Chetco Bar footprint (EA Chapter 3 Fire, Fuels and Air Quality section).
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2986-53 A study of post fire logging in Oregon found salvage without slash Fuel loading within the treatment units would increase immediately post-harvest. Project treatment increased fine fuels by 3-13 tons per hectare (Duncan, 2002). design criteria for the Chetco Bar Area salvage require limiting fuel bed depth to an average This is highly significant to this project because it is unlikely that the RR- of 12" after harvest operations. Resource concerns for soils and hydrology require some SNF will dispose of logging slash following logging operations. The EA organic material to be left on site to mitigate the effects of lack of ground cover. Slash fuels claims as much as 10/20 tons per acre could be generated in post-fire remaining on site will be represented by the SB1 and SB2 model as shown below in terms of logging activities (EA 3-121). Significant activity slash is proposed to be the size (diameter and time lag) and depth of the material. Fuel loads will be highly variable left on site, including an average 12" fuel bed of fine, dead, dry activity depending on the type of material harvested, and basal area prior to harvest. Fuel bed slash with high levels of fuel continuity. depth has a greater influence on future fire behavior than overall loadings. Material in excess of meeting resource concerns will be redistributed within the unit or yarded to a landing to be piled and burned. In ground based units activity fuels can be piled and burned throughout the unit (EA Chapter 3 Fire, Fuels and Air Quality section).
2986-63 According to the Chetco River Watershed Analysis "Snags and large The Chetco River Watershed Analysis was written in 1996. The 2017 Chetco Bar fire is the downed wood are at low levels in most managed stands and burned largest fire to burn in the Chetco and Pistol River 5 th field watersheds since the 2002 Biscuit areas of the lower and middle watershed. These components are also Fire. RAVG fire severity mapping estimates approximately 25 percent of the Chetco naturally low in the upper watershed due to fire and ultramafic soil watershed burned with 75-100% basal area mortality and 12 percent with 50-75% mortality. conditions. (USDA,, 1996, p.16)" The lack of snag and large wood Inventory data prior to the fire suggest that the Chetco River watershed was 11 percent habitat before the fire demonstrates a need to recruit both snags and deficient overall in snags per acre than reference conditions, although it had 3.5 times more large downed wood. Both resources will be nearly eliminated in post- area with over 24 snags per acre (15 vs 4 percent). Inventory data for large snags (>20 fire logging units. The result will be to continue the current snag and inches diameter) prior to the fire suggest the Chetco River watershed was 23 percent downed wood deficiency in the lower portions of the watershed. This is deficient in area with large snags than reference conditions (51 vs 28 percent area with no especially important because the lower watershed is the only portion of snags) with deficiencies in all ranges of snag density. After the fire, the watershed now has 2 the watershed capable of creating abundant large instream wood, large percent more area with snags >10 inches diameter than reference, and nearly 10 times snags, and large downed woody material. more area with more than 24 snags per acre than reference condition (39 vs 4 percent). The post-fire distribution of large snags for the Chetco River watershed suggests the watershed is now 12 percent deficient in large snags overall than reference conditions. Note that this deficiency is in area with fewer than 6 snags per acre, whereas the watershed now has nearly 4 times more area with more than 6 snags per acre than reference conditions and potentially providing suitable habitat for bat roosts and cavity-nesting birds (EA Chapter 3 Wildlife section). Additionally, the EA, Appendix A describes design criteria for the retention of snags and downed wood in salvaged units.
Page 61 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-42 All post fire logging units and new road construction in the South Fork Refer to response to comment 2986-38. Connectivity Corridor should be cancelled, including units 113, 114, 117, 119, 120, 121, 122, 123, 125, 127, 128, 129, 130, 131, &132.
2986-65 Although claims that post-fire logging and reforestation will accelerate As stated in the EA, the management allocation for the proposed project is Matrix: conifer establishment and thus late successional habitat development 'Approximately 85 percent (~144,935 acres) of the NFS lands that burned within the Chetco are dubious and unsubstantiated, it is still unclear if that is even Bar Fire occurred within lands where management allocations (such as congressionally desirable. Would accelerating conifer establishment play a positive reserved areas, late successional reserve (LSR) and riparian reserve) either prohibit post-fire influence on stand development, structural diversity or late salvage or have requirements to show ecological beneficial effects of treatments to aid in successional habitat values? Is it appropriate to attempt to manipulate post-fire ecosystem recovery. The remaining 15 percent (25,386 acres) of the fire on NFS successional stages and post-fire vegetation? It is unknown, but lands occurred on lands designated as matrix. The land allocation for the proposed action is scientific evidence does demonstrate that decadence, redundancy, Matrix. The primary emphasis of Matrix is sustainable timber harvest.'. The proposed action structural complexity and age class diversity cannot be created will treat approximately 2.4% of NFS lands leaving most of the fire area to naturally overnight. These habitat elements must be created through ecosystem regenerate. Negative impacts to natural conifer regeneration from salvage logging is not process and can take long period of time to create. Instead of likely to be a long-term problem due to the prolonged period of natural conifer recruitment maintaining biodiversity and promoting natural regeneration, the post-fire that occurs in the Klamath-Siskiyou region. Key findings from a research paper project proposes to create unnatural, novel vegetative conditions and from an Oregon State University researcher found that conifers continue regenerating 10 to promotes overly dense plantation-like stands. These conditions will 15 years after a fire (Hibbs 2009). Some have argued that early salvage logging post-fire can limit or retard the potential of treated stands to develop late damage the chances of successful recovery because the logging itself kills emerging successional characteristics and increase the potential for high severity seedlings. Hibbs' research "suggests that early salvage logging may not make much reburns. Current EA analysis of stand development and regeneration is difference to regeneration in the long run because they found that successful and abundant unrealistic, inadequate and lacks scientific rigor. The claim that post-fire conifer recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetation logging and artificial reforestation will accelerate conifer establishment section) Post-fire vegetation is predominantly tanoak naturally regenerating through and more quickly produce forested habitat is arbitrary, capricious and sprouting and seed across the burned area. Unfortunately, tanoak is the primary host in invalidated by the literature. Oregon of the non-native pathogen, Sudden oak death (SOD), Phytophthora ramorum.
Page 62 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-65 Statewide SOD occurs only in the forests of southwest Curry County (and within the fire continued area), where it is well adapted to mild, wet coastal conditions. Potential Vegetation Type (PVT) mapping for most of the Chetco Bar fire area is Tanoak/ Douglas-fir-moist which reflects site potential of future vegetation development in this drainage. Aggressive management strategies are currently in place to slow the spread of SOD; however, Forest Health protection pathologists anticipate the disease will continue to cause tanoak mortality in moist tanoak forests now and into the future. As tanoak is a prolific sprouter and a fast-growing species, tree planting may be necessary for species other than tanoak to become established and dominate the canopy in the short term. Artificial regeneration (planting) of non-bole hosts may help to slow SOD spread. Breaking up large continuous areas of tanoak in structure and species composition will change disease spread dynamics by slowing initial local disease spread, reducing inoculum levels overall, and reducing the probability of long-distance spread, while still maintaining tanoak on the landscape (Goheen, 2018).
2986-9 Although the agency has proposed over 4,000 acres of post-fire logging The paragraph you refer to is describing the cumulative effects of removing snags across the in matrix lands. According to the EA, "The combined proposed action entire Siskiyou National Forest to the wildlife species who utilize snags. The effects would and danger tree abatement project acres plus a small amount of acres occur on less than 1 percent of the total acres on the Siskiyou National Forest. The for the additional 200 snags per year would affect 15,000 to 20,000 Responsible Official has determined that is not significant. Especially in considering the acres total over the next 2-3 years which is less than 1 percent of total number of snags that was created by the Chetco Bar fire. acres on the Siskiyou National Forest." (EA 3-53). The cumulative impacts associated with logging, yarding and log hauling at this scale must be considered in the EIS.
2986-17 Although the EA claims that both the Chetco River and Pistol River Considering all snags greater than 10 inches in diameter Figure 4 shows that the Chetco watersheds are above reference conditions for snags and downed River watershed currently has 10 percent of its area with 0 snags which is less than the wood (EA 3-26), the same analysis demonstrates that the Chetco River reference condition of 12 percent of the watershed with 0 snags. So overall the Chetco is 12% deficient in large snags over 20" DBH and the Pistol River is 25% watershed is above reference conditions in total snag density greater than 10 inches DBH. deficient. The Pistol River watershed (figure 7) is deficit in all snags greater than 10 inches with 27 percent having 0 snags as compared to 13 percent in the reference condition. The commenter is correct that both watersheds are deficit in snags > 20 inches DBH as shown in Figures 6 and 8.
Page 63 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-57 An unpublished study of the Biscuit Fire found that areas salvage logged A fuel model is a set of information on the fuelbed inputs to be used in specific fire behavior after the 1987 Silver Fire burned with twice as much high severity fire or fire effects models. Anderson (1982) proposed 13 fuel models; Scott and Burgan (2005) than in unsalvaged stands (Harma, 2003 P.82). In his review of the Silver proposed an additional 40 (IFTDSS 2016). The models identified in the EA were chosen due Fire salvage, researchers found areas salvage logged burned 16%-61% to the size (diameter or time lag category) of the material used as inputs. It is expected that higher during the Biscuit Fire than in unsalvaged areas. He concluded resulting fuel as a result of harvest will be highly variable. Limiting fuel bed depth to 12" that "the hypotheses that salvage logging followed by planting reduces provides modeling outputs for flame lengths and rates of spread consistent with successful burn severity is not supported by the data." He found this to be true initial attack. Fire severity is the effect of a fire on ecosystem properties, usually defined by even in stands that were salvage logged and broadcast burned; this is the degree of soil heating or mortality of vegetation. The severity of a fire depends on the due to the vegetative diversity and small gaps found in naturally fire intensity and the degree to which ecosystem properties are fire resistant. For example, recovering forests. (Thompson, 2007). This will certainly be evident in a fire of exactly the same fireline intensity might kill thin-barked trees but have little effect the Chetco Bar Fire Salvage Project were fuel beds up to 12" deep will on thick-barked trees. Therefore, fire severity is, in part, a function of the ecosystem being be allowed to carpet post fire logging units. This level of activity slash burned and is not simply indexed from fireline intensity. If a fire has a long residence time, will significantly increase future fire severity. fire severity will usually increase. (Agee 1993) "Young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". (Thompson et al 2007) Young conifer regeneration will combine with shrub species to occupy the growing space on the site, when full site occupancy is realized, ambient conditions will determine when and if these live fuels are available to burn. Fire weather was shown to have a strong influence on reburn severity. (Coppoletta et al 2016). It is anticipated that even with natural or artificial regeneration, the continuity of shrub layer will drive future fire events for the near term, overriding the influence of conifer regeneration in activity units. Allowing for unplanted areas, openings and planting at lower densities can serve to break up continuity of fuels and reduce future fires intensity and severity. The effects of this treatment in terms of potential fire behavior are minimal due to the small acreage of treatments relative to the larger areas of high severity in the Chetco Bar footprint.
Page 64 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-57 Fine fuels will increase after harvest operations. Current fuel loads are very low due to the continued Chetco Bar fire of 2017. Soil and hydrologic concerns require some material to be left on site after project implementation. Project design criteria aimed at limiting the amount of residual material left after harvest are designed to limit fire behavior to that which can be successfully initial attacked using hand tools. The PDC will require slash in excess of the 12" depth will be yarded to a landing to be piled and burned during wet weather. Fine fuels will decompose more rapidly than coarse fuels, it is expected that these fine fuels will be the primary component of fuel loadings for approximately 15 years at which time live fuels will become the primary source for future fire spread. Personal observations from the Chetco Bar fire indicate that 15 years is a reasonable time frame for live fuels, mainly in the form of brush and small trees, to become the primary driver of future fire severity. Areas burned in the 2002 Biscuit fire that did not receive any form of treatment after again burned during the Chetco Bar fire. The primary driver of this fire spread was in the form of brush. Removal of dead trees reduces risk and hazards for future fire management response. Snags are recognized as a limiting factor in fire management activities, due to their degraded condition and unpredictable time of falling. Until snags can be mitigated, wildfire response can be delayed. Delayed response can reduce decision space for responders and impact final fire size and duration. Once snags become involved with fire, they can become a source for fire spread through spotting. Spotting distance is directly related to the material burning as well as the height of ember production. It is expected that there will be a strong shrub response that can exacerbate surface fuel conditions. (Albini 1976) Furthermore, ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity. (Coppoletta et al 2016)
2986-43 At the center of the connectivity corridor and in undeveloped area Refer to response to comment 2986-38. 2615, the RR-SNF has proposed over 200 acres of post fire logging and new road construction in undeveloped area 2615. The removal of post- fire habitat is expected to remove 84% of the post-fire foraging habitat in undeveloped area 2615. The action would nearly eliminate post-fire foraging habitat and complex, early seral habitat in the upper Pistol River watershed.
Page 65 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-15 Based on the current Forest Service estimation, the number of acres on Specific to the Chetco Bar fire, timber industry lands have ongoing active salvage within the both private and federal land subjected to post-fire logging in the lower Chetco Bar fire. As of May 25, 2018 Oregon Department of Forestry has received Chetco River watershed could be as much as 29,455 acres if the notification of operations on 6,421 acres from private land owners. Within this ownership, roadside hazard and unit logging in the Chetco Bar Fire Recovery the Forest estimates it is reasonably foreseeable that 9,455 acres has been or will be Project is implemented as currently proposed. The EA did not disclose harvested within the near future. Approximately 8,310 acres are within the Chetco River this figure or analyze based on that level of cumulative effects. This watershed and 1,145 are in the Pistol River watershed. The BLM has approximately 170 failure to analyze or disclose full cumulative impacts necessitates acres of foreseeable harvest within the Chetco River watershed and about 5 acres in the disclosure and analysis of logging 29,455 acres in an EIS. Pistol River watershed. All with more than 50% basal area loss. In addition, about 250 miles of roadside danger tree removal in 2018 and 2019 is proposed throughout the fire area for a maximum of 13,540 acres. Not all of these acres have burned. In fact, 34 percent (4,642 acres) currently have less than 25% basal area loss or are unburned. However, the maximum footprint of 250 feet on either side of the road (13,540 acres) was used for wildlife analysis purposes in the danger tree project CE. Of these acres, approximately 12,550 are within the Chetco and Pistol River 5th field watersheds, of which approximately 1,145 acres overlap with salvage units in alternative 2. Approximately 10,166 acres within the Chetco River watershed are in the roadside danger tree treatment area and 2,386 acres are in the Pistol River Watershed. The EA, Table 13 displays the acres for each watershed considered for cumulative effects to snags. It is reasonable to assume the estimates for the Roadside Danger Tree Abatement project are overestimated. Currently, the Packer (280 acres), Mineral (245 acres), and Snaketooth (204 acres) Roadside Danger Tree Abatement units have been identified on-the-ground and total about 729 acres. Additional Roadside Danger Tree Abatement units have not yet been identified. We have over estimated impacts based on the maximum possible extent that project activities could occur and still the effects are not expected to be significant.
Page 66 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-23 Currently Alternative 2 would remove 2,222 acres complex, early seral The EA at 3-8 described the geographic boundary for analyzing effects to early seral habitat habitat in previously unmanaged forest. These stands are located in the as the 146,261 acres of National Forest System (NFS) lands that have no history of timber lower Chetco River, where unmanaged, complex forest habitat of any harvest within the Chetco Bar fire perimeter. For this analysis, private and BLM lands were successional stage is relatively rare. Although abundant in some considered managed stands and therefore not complex early seral habitat. Therefore there portions of the watershed, complex, early seral habitat is lacking in the would be no cumulative effects to complex early seral habitat from salvage logging on lower Chetco River watershed. The EA claims that because large private and BLM lands. This is because the geographic boundary for analyzing effects to portions of the planning area provide abundant complex early seral early seral habitat is on NFS lands only and private and BLM lands were never considered habitat, there will be no cumulative effects. This is fundamentally unmanaged in this analysis. The current Roadside Danger Tree Abatement project would untrue because of the location of the units in the lower Chetco River have cumulative effects to complex early seral habitat and biological legacies and are watershed, the lack of complex habitat and connectivity in the lower described in the EA Chapter 3 Complex Early Seral Habitat section. There are no known Chetco River. Post-fire logging would be responsible for significant future projects in these areas. reduction in habitat quality; downgrading habitat from complex to simplified, early seral.
2986-49 Despite the claims in the EA, no new road will cross streams of any kind, See response to comments 2986-32 and 2986-33. careful inspection of the unit maps, show that numerous stream crossings will occur.
2986-12 Future fire severity will also be significantly increased throughout the Fire severity is the effect of a fire on ecosystem properties, usually defined by the degree of 4,000 acres proposed for logging due to the removal of complex forest soil heating or mortality of vegetation. The severity of a fire depends on the fire intensity structures that facilitate forest regeneration, a significant influx of fine and the degree to which ecosystem properties are fire resistant. For example, a fire of fuels and "re-stocking" requirements that could include due to artificial exactly the same fireline intensity might kill thin-barked trees but have little effect on thick- reforestation. barked trees. Therefore, fire severity is, in part, a function of the ecosystem being burned and is not simply indexed from fireline intensity. If a fire has a long residence time, fire severity will usually increase (Agee 1993). "Young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire" (Thompson et al 2007) (EA Chapter 3 Fire, Fuels and Air Quality section).
Page 67 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-73 Historically, a cycle of repeated fire, both wildfire and indigenous The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix burning, created and maintained Long Ridge Prairie. Today, prescribed land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 fire and managed wildfire could maintain the meadow in a productive Chetco Bar fire. (EA at 1-4) Prescribed fire and managed fire to maintain Long Ridge Prairie condition. These fires would clear back fuel deposited by fire killed are outside the scope of this project. trees, promote herbaceous growth, creating niche habitat for local deer and elk, maintain habitat for grassland species and pollinators, while providing cultural food sources and resources to the local tribal community. Such an approach would provide an opportunity to explore the development and maintenance of coastal prairie habitats from forest to grassland, using natural process and indigenous land management techniques. Going forward, it would allow us to study "prairie restoration" techniques using prescribed fire and prescribed natural fire rather than more intensive, industrial means. In this way, the proposed research many not just inform land management, but it will also expand our understanding of the region's cultural history.
2986-55 In a study conducted in the Biscuit Fire area, researchers found the Yes thank you, we are aware of that study. No where in the EA do we purport that the following key findings: 1) Salvage logging does not reduce reburn project would reduce reburn potential. The purpose of the project is to capture timber potential 2) Severe re-burn is driven by the structure of young value in the matrix land allocations by harvesting dead, dying and/or damaged trees vegetation and regeneration not by residual woody material from resulting from the 2017 Chetco Bar fire. The effects of the proposed activities on fuel levels previous fire ( Donato, 2008). The researcher stated that "if the is described in the EA, Chapter 3 Fire, Fuels and Air Quality section. management objective is to reduce the risk of high severity reburn, post fire management of deadwood may need to focus on non- merchantable material, which makes up a large portion of residual deadwood and is the most available fuel." This is extremely significant because the RR-SNF salvage proposal in the Chetco Bar Fire will be focused on removing large, commercially valuable trees and will leave all trees and snags under 7" DBH (EA 3-152).
Page 68 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-28 In the Seiad Horse Risk Reduction Project EA published recently by the Project design criteria for snag and down wood retention meet or exceed standards and Klamath National Forest It was determined that structurally simplified guidelines for such retention in matrix. Though salvage would reduce these elements in the openings over 160' wide would create barriers for dispersal of late units, they would contain these elements as required, and continue to provide early successional species such as the Pacific fisher, marten and NSO (Seiad successional habitat. These units comprise a small proportion of the diversity of seral stages Horse EA). The Chetco Bar Fire Salvage Project proposes to create many including complex early seral habitat that surrounds them. See also response to comment structurally simplified openings across the lower Chetco River 2986-45. watershed, significantly increasing fragmentation and reducing habitat permeability.
2986-74 Instead, the Forest Service has proposed clearcut, post-fire logging and Refer to the response to Comment 2986-37. reforestation in the area around Packer's Cabin and Long Ridge Prairie. This unfortunate proposal will not mimic natural ecosystem process or promote scenic values important at Packer's Cabin and Long Ridge Prairie. In fact, the ground disturbance and heavy equipment use inherent to commercial, post-fire logging will promote the spread of noxious weeds and impact existing native plant communities, hindering the restoration of native prairie habitat.
2986-2 it seems the Chetco Bar Fire Salvage project is inconsistent with multi- All projects have a specific purpose and need statement. It is at the sole discretion of the use management Responsible Official to establish the scope of the analysis, including the scope of the actions, alternatives, and effects (40 CFR 1508.25). The effects to relevant resources are described in the EA, Chapter 3.
2986-33 Large section of new road proposed to access units 80, 81, 175, 176, & The Soils Resource Report discloses the effects of temporary roads to the soil resource, 177 is a substantial addition to the road network. The agency has also including expected long term impacts (page 29, 31-32) (EA Chapter 3 Soils section). See also proposed large expansions to access units 89, 96, 97, & 99, as well as response to comment 2986-32. units 138, 139, 141, 142 & 143. Significant additional roads are also proposed to access unit 129, as well as, units 130 & 131. Building large expansions onto existing road networks should not be called "temporary", there is nothing temporary about it. When compared to natural conditions, many important resources will be permanently impacted by so-called "temporary road" construction.
Page 69 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-72 Long Ridge is an important connectivity corridor extending from the Refer to response to comment 2986-38. Kalmiopsis Wilderness boundary to the Chetco River Canyon near the river's confluence with the South Fork. The area contains a diverse mixture of plant communities, soil types and successional stages. Near Quail Prairie Mountain serpentine soils influence the plant associations, favoring pine stands, including knobcone pine, lodgepole pine, Jeffery pine, and a few groves of cedar and fir. Hardwood stands, dense chaparral, and rocky serpentine outcrops punctuate the piney canopy. Occassionally, more productive soils grow massive old trees, such as in unit 25 at the northwestern flank of Quail Prairie Mountain.
2986-5 Matrix lands are designated for timber production, but the "standards The Project was designed to meet direction in the Northwest Forest Plan, and the Siskiyou and guidelines for the matrix are designed to provide for important Forest Plan. ecological functions such as dispersal of organisms, carryover of some species from one stand to the next, and maintenance of ecologically valueable structural components such as downed logs, snags and large trees" (EA 1-8). It does not appear that adequate considerations have been made in the Chetco Bar Fire Salvage project to provide for important ecological functions or maintain ecologically valuable structural components including snags, downed trees and large trees in proposed logging units. In fact, treatments proposed in the Chetco Bar Fire Salvage Project would starve affected stands of these very structural components for decades or even centuries until they can be recreated. Reproducing large trees, snags and downed wood will inherently require long periods of time.
Page 70 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-54 NEPA analysis must be conducted with this reality in mind. The agency Treatment units will have greater fuel continuity after harvest, this can increase fire rates of must analyze fire hazards associated with logging treatments based the spread. Reburn severity is often a concern after harvest activities. However, logging slash is following metric. How many tons of logging slash will be produced in only part of the fire risk story, and it may not be the most important after a few years. each post-fire logging unit? How will this logging slash effect highly (Thompson et al, 2007) It is expected that there will be a significant brush response both available fine fuel loading and resistance to control in future fire events. within and outside of harvest units. Adjacent untreated areas will retain lower fuel levels This must be compared to stands that are not subjected to post-fire and high spatial heterogeneity which can aid in slowing fire growth. "many of the logging and the subsequent pulse of highly flammable tops, limbs, and plantations examined in this analysis had lower conifer densities and a larger component of relatively fine woody fuels associated with salvage logging. This analysis shrubs and hardwoods that would be found in typical intensively managed plantations of should be conducted to document fuel loading 5, 10, 15 and 20 years the same age." This suggests that whether conifer or shrubs, short return intervals can following the Chetco Bar Fire. The cumulative impact of this increase in maintain vegetation in a perpetual early seral state. logging slash must be analyzed in the upcoming EIS analysis.
2986-10 Not only will vast acreages be converted or re-converted to plantation- Implementation of salvage logging may reduce the amount of natural regeneration, if like stands through post-fire logging and "reforestation," this process present, due to ground disturbing activities. This would most likely occur in the ground will devastate natural fire regeneration. based logging system units of the proposed action and alternative three (619 acres and 336 acres). However, proposed artificial regeneration would mitigate this impact by planting site- specific appropriate tree species mix. Negative impacts to natural conifer regeneration from salvage logging is not likely to be a long-term problem due to the prolonged period of natural conifer recruitment post-fire that occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon State University researcher found that conifers continue regenerating 10 to 15 years after a fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' research "suggests that early salvage logging may not make much difference to regeneration in the long run because they found that successful and abundant conifer recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetation section) The intent is to rely on natural regeneration wherever possible. If natural regeneration is determined not to be adequate to comply with the NFMA five-year regeneration requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. (EA at 2-4)
Page 71 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-80 Numerous units in the Pistol River watershed are located within The EA at 3-68 states "2615 is a fairly large polygon dissected by managed stands and a undeveloped area 2615. These units appear to be located in large block of private lands, which most likely has or will be salvaged. There are four small unmanaged habitat, contain significant biological legacies and meadows (less than an acre) within the polygon. Forty-two (42) percent of the undeveloped important complex, early seral habitat. This habitat is especially lands in this polygon are NRF, 8% are PFF, and 29% are dispersal habitat for NSO." The EA at important in the Pistol River watershed. The EA documents and deficit 3-71 also states within undeveloped polygon 2615 "Salvage is proposed on 218.3 acres, in early seral habitat in the Pistol River watershed. The Pistol River was some of which occurs on the perimeter of the polygon and near managed stands and roads. documented to be below the natural range of variability for early seral Proposed salvage in four interior harvest units would further dissect this polygon of habitat. Complex, early seral habitat is particularly important and undeveloped lands. However, salvaging would not take the polygon below 2,000 acres. should be maintained, especially in the Pistol River watershed and in There are also 4 proposed temp roads for a total of 0.4 miles within this polygon. None of undeveloped areas or Inventoried Roadless Areas. the four small meadows (less than an acre) would be affected by the project. About 84% of the PFF in this polygon would be salvaged under this project. The effects of salvaging PFF are no different in undeveloped lands as they are for developed areas. Therefore, for a complete description of the effects of salvaging PFF refer to the Wildlife section of this document."
2986-37 Of particular concern is also the impact post-fire logging will have on "Salvage units would be visible in the immediate foreground and middleground from the recreational experience at Packer's Cabin. portions of primary travel routes (FSRs 1107, 1376, 1407, 1909, 1917), Forest Service Trail (FST) 1103, and Packers Cabin Recreation Rental. Visual effects would include machinery, personnel, piles, and exposed soil during active operations, and stumps and slash afterwards. These effects would gradually become less evident, but would likely be visible for 10-15 years or more depending on local understory regeneration. However, adherence to project design criteria (PDCs) would ensure that effects become subordinate to the natural landscape character within the prescribed timeframe to attain the applicable VQOs of partial retention and modification." A simulation of proposed action visual effects as would be seen from Packers Cabin recreation rental is included in the EA. "Project activities would negatively affect the ROS setting of Packers Cabin if it is occupied during active operations. Suspending operations in units adjacent to Packers Cabin for the summer recreation season would avoid this." (EA Chapter 3 Recreation and Visuals section) Project design criterion VR-35 was added to the final EA at Appendix A, page A-35 to address concerns regarding the Packers Cabin recreation experience.
Page 72 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-56 One researcher stated that once unmanaged stands were mixed with a Fire regimes in Douglas Fir/hardwood forests are considered to be one of the most variable. patchwork of plantation stands "the potential exists for a self (Agee 1993) This variability makes generalizations about the fire regime and its effects reinforcing cycle of catastrophic fires." (Perry, 1995 b) difficult. Recent events as well as historical records, combined with vegetation patterns indicate intense stand replacing events have been and will be part of the system. Fire behavior can range from low intensity surface fire, to mixed severity to stand replacement, often times within the same perimeter. Historically, high frequencies of low and medium intensity fire broke up large uniform patches into complex mosaics of age, size and structure. (Wills 1991). Resulting vegetation patterns are a mosaic of patches of differing sizes and multi aged stands. Current fire suppression has allowed homogenization of stand conditions and removed much of this mosaic. The Douglas fire of 2014 demonstrated that young intensively managed plantations can burn with high severity, as compared to older adjacent stands. (Zald and Dunn 2018) The severity of a fire depends on the fire intensity and the degree to which ecosystem properties are fire resistant. For example, a fire of exactly the same fireline intensity might kill thin-barked trees but have little effect on thick- barked trees. Therefore, fire severity is, in part, a function of the ecosystem being burned and is not simply indexed from fireline intensity. If a fire has a long residence time, fire severity will usually increase. (Agee 1993)
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2986-61 Other authors and scientists tend to agree that no scientific study to The best available science is considered in preparation of this EA. The concept of "best date has substantiated claims that post-fire logging and tree planting available science" is also a matter of opinion to some degree since scientists can legitimately encourages a healthy and natural recovery of forest associations. On disagree about the meaning or impact of individual study results. As a general matter, we the contrary, post-fire logging tends to degrade soil, vegetation, and show consideration of the best available science when we insure the scientific integrity of aquatic resources and decrease biodiversity, creating simplified the discussions and analyses in the project NEPA document. Salvage logging is one aspect of plantation stands, not patchy and fire adapted native ecosystems. It post-fire management and may be used to address a variety of issues including worker and does not facilitate forest development or reduce fuels. The practice of public safety issues, risks along roads, and risks to infrastructure such as buildings and post-fire logging followed by reforestation is designed to create recreational facilities. Salvage logging may also be appropriate to recover economic value plantation stands, not structurally complex habitat. and support community resiliency. The ecological consequences of salvage, however, are often considered negative from the perspective of soils, hydrology, and wildlife habitat resources, although wildlife species responses vary. In 2015, scientists from Oregon State University and the Pacific Northwest Research Station completed a literature review concerning the Ecological Effects of Post-fire Salvage Logging in the Pacific Northwest (Reilly et al. 2015). These scientists found the ecological effects of post-fire salvage logging vary depending on the treatment, fire severity, and biological setting (Peterson et al. 2009). These scientists concluded that based on their literature review, in general, little research supports the idea that salvage logging has beneficial ecological effects on terrestrial or aquatic resources (Karr et al. 2004, Beschta et al. 2004, Lindenmayer and Noss 2006). To provide the proper context, they concluded that salvage logging needs to be addressed at landscape scales and in terms of tradeoffs with other ecological and economic objectives. Many of the ecological guidelines they recommend for post-fire management are included in the design of this project. For a complete list of ecological guidelines recommended refer to the EA Alternatives Considered but Eliminated from Detail Analysis documentation in the project record.
2986-61 For purposes of the environmental assessment completed for this project, the Responsible continued Official has determined the appropriate comparison to address the tradeoffs between ecological considerations and economic objectives pertaining to salvage logging as recommended by Karr et al. (2004), Beschta et al. (2004) and Lindenmayer and Noss (2006), while also considering the economic value consistent with the Forest Plan, as amended, will be the comparison of effects disclosed in Chapter 3 between the No Action and the Action alternatives. (EA at 3-1)
Page 74 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-13 Perhaps, most importantly, are the cumulative impacts associated with The Soils Resource Report disclosed the cumulative impacts to soils (page 34-36, EA Chapter soils, surface erosion rates, and water quality in the Chetco River 3 Soils secton). Also refer to the EA, Soils section, Soil Stability and Erosion Hazard Potential watershed. subsection for a discussion on potential erosion. Refer to the EA, Hydrology section for water quality discussions.
2986-59 Plantations also created conditions that encouraged adjacent unlogged It is recognized and accepted that high density plantations can burn at high severity and stands to burn with high severity and possibly encourage fire spread influence adjacent stands. (Zald and Dunn 2018). At issue is not whether there will be a into areas that may not have otherwise burned (Key, 2000). Likewise, young forest, but what species and densities will be present, what age, and most other authors agree that "reforestation goals should avoid establishing importantly ambient conditions when it does reburn. Fire weather had s strong influence on dense, uncharacteristic, "fully stocked" forests, thereby perpetuating reburn severity, followed by shrub cover percentage. (Coppoletta et al 2016) Whether the potential for uncharacteristic fire." (Franklin and , 2009 P.68) artificial regeneration or natural, the forest structure has been impacted. Young trees have Weatherspoon and Skinner came to similar conclusions in their study of thin bark, lower height to live crown and are overall shorter trees. Fire severity is a measure the 1987 Hayfork Fires. (Weatherspoon and Skinner, 1996). of the physical change in an area caused by burning. Fire severity describes the effects of fire on vegetation, litter, or soils. It is most commonly used to describe fire's effects on the primary tree cover. A typical low to moderate severity fire in a young forest can have high severity effects due to these criteria. The same fire in an older forest will have less severity due to the age and size of the trees. Density is an important consideration for young forests. Planting densities on private industrial forests can range from 450-600 trees per acre. The Chetco Bar fire Area Salvage is not proposing densities this high. "young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". (Thompson et al 2007) The proposed action proposes salvage harvest on 4090 acres. Within the Chetco Bar fire perimeter, this amounts to just over 2%. While it is recognized that harvest units will have higher fuel loadings for 15-20 years, the reduced connectivity of harvest units at this scale will help to decrease the connectivity of surface fuels. Reducing connectivity of surface fuels at landscape levels is considered an important strategy for reducing future rates or spread.
Page 75 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-82 Please consider developing a new alternative that focuses post-fire The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix logging on roadside hazards only, with the goal of providing safe public land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 access on open forest roads while producing timber in a timely manner Chetco Bar fire (EA at 1-4). While this alternative would accomplish the need for recovering from Matrix lands. economic value of timber burned in the fire, it would do so at a reduced level and it would not meet the purpose of the project throughout the matrix land allocations. This alternative would only treat matrix land allocations along roads. Additionally, the Danger Tree Removal project has already authorized the removal of danger trees along all roads within the Chetco Bar fire perimeter.
2986-62 Post-fire logging also hinders natural regeneration in many other ways. Negative impacts to natural conifer regeneration from salvage logging is not likely to be a It negatively effects nutrient replenishment by damaging, compacting, long-term problem due to the prolonged period of natural conifer recruitment post-fire that and eroding soil resources during falling and yarding operations. Post- occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon fire logging can also cause "onsite impacts to early successional native State University researcher found that conifers continue regenerating 10 to 15 years after a plant species…where species are nitrogen fixers, (salvage) can fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the significantly affect a major pathway of nutrient replenishment." chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' (Beschta, 2004) research "suggests that early salvage logging may not make much difference to regeneration in the long run because they found that successful and abundant conifer recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetation section) Additionally, post-fire vegetation is predominantly tanoak naturally regenerating through sprouting and seed across the burned area. Unfortunately, tanoak is the primary host in Oregon of the non-native pathogen, Sudden oak death (SOD), Phytophthora ramorum. Statewide SOD occurs only in the forests of southwest Curry County (and within the fire area), where it is well adapted to mild, wet coastal conditions. Potential Vegetation Type (PVT) mapping for most of the Chetco Bar fire area is Tanoak/ Douglas-fir-moist which reflects site potential of future vegetation development in this drainage.
2986-22 Post-fire logging in complex, early successional habitat should be Alternative 3 and the No Action alternative address your concerns. canceled to maintain the most diverse, ecologically complex portions of the Chetco Bar Fire.
2986-21 Post-fire logging in unmanaged and undeveloped lands in the Chetco Alternative 3 and the No Action alternative addresses your concerns. and Pistol River watersheds should be canceled. 2,222 acres or 54% unmanaged, 1433 or 35% undeveloped.
Page 76 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-44 Post-fire logging will have a profoundly negative effect on connectivity Early seral habitat connectivity would remain post-harvest because the project will only within the area by removing biological legacies, eliminating 2,222 acres remove dead and dying trees as defined in the EA Chapter 2. Regrowth of shrubs, forbs and of complex, early seral habitat, logging undeveloped areas, disrupting trees would be disturbed in the short-term, but is expected to continue after harvest. natural regeneration and building new roads. These activities should be Retention of snags and down wood would meet Forest Plan standards for matrix and canceled in all existing connectivity corridors. provide for 30% tolerance levels for species associated with snags and down wood. (EA Chapter 3 Wildlife section) The 2,222 acres salvaged representing 1.5 percent of unmanaged stands in the fire area would not be devoid of vegetation post-treatment and would still provide habitat connectivity with snags and down wood for complexity meeting project design criteria, even though it would not be the same degree of complexity as the 98,000 acres of untreated complex early seral habitat surrounding these units in the fire area. This small proportion of harvest scattered throughout the burned area, may locally reduce habitat complexity and connectivity function of the habitat present in these units, however they are surrounded by thousands of acres of untreated habitat that will continue to provide complex, connectivity habitat. See also response to comment 2986-38.
2986-18 Prescriptions that virtually eliminate snag and coarse wood habitat will Our prescriptions do not virtually eliminate snag and coarse wood habitat. Refer to the EA, have lasting impacts to structural complexity, late successional forest Appendix A for design criteria that that minimize or avoid potential adverse effects of the development, wildlife habitat values, regeneration patterns, nutrient action alternatives. See also the EA, Chapter 3 for a description of the effects to resources. cycling, soil resources, forest productivity, water holding capacity and many other measures of stand development or ecological function.
2986-64 Professor Jerry Franklin seems to agree stating in his comment on the The EA estimates that about 30% or 43,745 acres of unmanaged national forest system Biscuit Fire salvage project that "naturally disturbed habitat that is lands within the Chetco Bar fire are considered early seral habitat. Under the Proposed undergoing slow natural reforestation—without salvage or planting—is Action, approximately 2,222 acres or 1.5% are planned for salvage. That would leave about the rarest of the forest habitat conditions in the Pacific Northwest. Yet 98.5% or 41,523 acres of "naturally disturbed habitat that is undergoing slow natural it is increasingly evident from research such as at Mount St. Helens, that reforestation, without salvage or planting". such large slowly reforesting disturbed areas are important as hot spots for regional biodiversity." (Franklin. 2004).
2986-77 Quail Prairie Creek and its relatively intact habitats provide very Refer to response to comment 2986-38. important connectivity habitat between the Kalmiopsis Wilderness and the lower Chetco River watershed.
Page 77 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-39 The Checto Bar Fire Salvage Project proposes to log in relatively intact Refer to response to comment 2986-38. connectivity corridors on Long Ridge, Quail Prairie Creek, the Pistol River, on the ridge near High Prairie and the South Fork.
2986-70 The Chetco River Watershed Analysis identifies significant cumulative Refer to EA, Hydrology Section, Cumulative Effects subsection. See also response to 2989- effects in the Basin Creek Watershed where over 60% of the watershed 18. was previously harvested (USDA, 1996, p. 31) The area is now targeted for near watershed wide post-fire logging, resulting in likely more than 80%-90% of the watershed harvested. This will impact peak flows, water quality, spawning gravels, etc.
2986-34 The Chetco River Watershed Analysis identifies the following Temporary roads are roads authorized by contract, permit, lease, or other written watersheds as currently containing high road density. No new roads or authorization, or emergency operation not intended to be part of the forest transportation landings should be built in the following watersheds due to system and not necessary for long-term resource management. Temporary roads are not corresponding road density (miles per square mile): Chetco River Elk intended to be included as part of the forest road atlas, as they are managed by the projects Cr. To Eagle Cr. 4.4, Lower Quail Creek 3.6, Basin Creek 3.3 (USDA, or activities under which they are authorized and decommissioned at the conclusion of the 1996, p.31). authorized activity (EA at 2-3). Landings would be decompacted preferably with an excavator, seeded and covered with some residual slash (EA, Appendix A). Temporary roads and landings are intended to be part of the forest transportation system and therefore they would have no impact on road densities.
2986-31 The construction of new road on this scale will create significant There is no proposed system road reconstruction or construction under the action watershed impacts and will increase sedimentation in the Chetco River alternatives (EA at 2-3 to 4). The Soils Resource Report discloses the effects of temporary watershed, threatening its incredible water quality and fisheries roads to the soil resource, including expected long term impacts (page 29, 31-32) (EA habitat. The proposal also identified new landings throughout the Chapter 3). The Hydrology Resource Report discusses effects of temporary roads and water watershed to facilitate yarding activities. quality (page 28-30) (EA Chapter 3). See also response to comment 2990-46 and 2986-32.
Page 78 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-41 The corridor also provides connectivity between the Chetco River Refer to response to comment 2986-38. Canyon, Eagle Creek, the Mineral Hill Fork and the East Fork of the Pistol River. This corridor is extremely important for the diversity of dispersal pathways it facilitates, connecting watersheds and wildlands. The Chetco Canyon Connectivity Corridor is likely the most important corridor of habitat in the lower Chetco River watershed and should be protected. All units proposed and new road construction in the Chetco Canyon Connectivity Corridor should be cancelled.
2986-51 The cumulative impact of discretionary fire suppression activities The EA at 3-2 states " Chetco Bar Fire Suppression Activities - Approximately 58.3 miles of should be analyzed in the Chetco Bar Fire Salvage EA. In particular, dozer lines were constructed or reconstructed in and around the Chetco Bar Fire perimeter watershed impacts associated with increased turbidity and riparian on National Forest System Lands, as well as 51 miles of hand line. Rehabilitation and repair function such as dozerlines, riparian snagging, clearing of drop points, of areas disturbed by suppression included pulling back hand line and dozer line berms and safety zones and helipads, handlines, and backburning should be slash and seeding with native grasses where appropriate, installing water bars on fire lines, analyzed. The EA failed to consider the cumulative impact of and grading road surfaces affected by fire vehicle and equipment use." The cumulative discretionary fire suppression activities on watershed, soil and fishery effects of fire suppression activities were described in the EA, Chapter 3, where applicable. resources.
2986-8 The Draft EA failed to adequately analyze the scale of cumulative The temporal and spatial scale of analysis is variable depending on the resource concern impacts on federal land associated with post-fire logging proposed in being evaluated, particularly when considering the effects of past, present, and reasonably the Chetco Bar Fire Salvage Project. foreseeable actions. During the interdisciplinary process the team followed guidance presented in CEQ's letter dated June 24, 2005 regarding past actions. Using this guidance the following summary of past, present, and reasonably foreseeable actions within and adjacent to the CBF Salvage project area was developed. These projects were considered where relevant, when addressing the cumulative effects for various resources. The effects are disclosed in chapter 3. (EA at 3-2)
Page 79 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-35 The Draft EA failed to adequately consider recreational values and The EA at 1-10 stated "The proposed project was determined to have no effect to recreational impacts associated with post-fire logging in the Chetco Bar recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The Planning Area. The Brookings Area is highly dependent on coastal rationale for this determination is documented in the Recreation and Visual Resources tourism and recreational fishing, swimming and boating on the Chetco section. The project incorporates a system of design features that protect recreation River for economic revenue. The fishery alone is a significant economic settings and opportunities, examples of which include haul restrictions during high-use and quality of life benefit to the community. times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section." Regarding the Chetco River fishery, the EA at 1-10 stated "The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section.
Page 80 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-36 The EA claims that there will be no visual effects within the Wild and The EA at 1-10 stated "The proposed project was determined to have no effect to Scenic River Corridor, but some units will be visible in the middle recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The ground and background from the Chetco River (EA 3-152). The vast rationale for this determination is documented in the Recreation and Visual Resources clearcuts implemented by the private timber industry have already section. The project incorporates a system of design features that protect recreation compromised scenic and recreational values in the lower Chetco River. settings and opportunities, examples of which include haul restrictions during high-use The implementation of over 4,000 acres on adjacent federal land will times, provisions protecting public access to recreation sites and areas, and implementation further impact the viewsheds, scenic and recreational values in the Wild techniques to minimize scenic effects of project activities. For more information refer to the and Scenic River Corridor and the lower Chetco River Watershed. Recreation and Visual Resources section." The EA Chapter 3 Recreation and Visuals Resource section stated "No salvage activities are proposed in the Chetco Wild and Scenic River corridor or in any other areas with retention or preservation VQOs." The EA also stated that "Project design criteria would ensure activities achieve VQOs without affecting the character and setting of the landscape as seen from the Chetco River." The rationale for these determinations are documented in the Recreation and Visuals Resource section. Furthermore, project design criteria VR 1 through 10 found in Appendix A of the EA directly address protection of visual resources, while VR 11-34 directly address concerns related to protection of recreation setting and experience.
2986-7 The EA did not analyze the scale of Roadside Hazard Logging and The EA described the cumulative effects of the Roadside Danger Tree Abatement project consider whether the Purpose and Need to produce "salvage" timber in where it overlaps in time and space with this project. These are two separate projects. a timely manner, from Matrix lands could be met by implementing with Whether the Purpose and Need to produce "salvage" timber in a timely manner, from Roadside Hazard Logging only. It is our position that roadside hazard Matrix lands could be met by implementing only the Danger Tree Removal project outlines logging will adequately and sustainably meet the timber production the opinion of the commenter, and a Forest Service response is not required. goals of Matrix lands, while also protecting natural resource values.
Page 81 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-14 The EA failed to adequately analyze the cumulative impact of private The EA at 3-3 stated "The exact amount of logging and reforestation on nearby private lands land logging. is difficult to ascertain because private companies and individuals are not always willing to share that information. Using GIS analysis, there is about 13,843 acres of private land within the CBF perimeter. Approximately 4,377 acres incurred 0-25 percent basal area loss (RAVG analysis), 1,989 acres incurred 25-50 percent loss, 1,724 acres incurred 50-75 percent loss, and 5,742 acres incurred 75-100 percent loss (see Table 7). Assuming no salvage logging is taking place in areas that incurred 0-25% basal area loss, we can estimate up to 9,455 acres of salvage on nearby private lands has occurred, is occurring, or may occur in the near future." Additionally, as of May 25, 2018 Oregon Department of Forestry has received notification of operations on 6,421 acres from private land owners. Cumulative effects of private land salvaging was described in the EA Chapter 3 where relevant, for various resources.
2986-52 The EA failed to adequately analyze the impact of Post-Fire Logging and It is anticipated that even with natural or artificial regeneration, the continuity of shrub Re-planting on Fuel Loading and Future Fire Severity layer will drive future fire events for the near term, overriding the influence of conifer regeneration in activity units. Allowing for unplanted areas, openings and planting at lower densities can serve to break up continuity of fuels and reduce future fires intensity and severity. The effects of this treatment in terms of potential fire behavior are minimal due to the small acreage of treatments relative to the larger areas of high severity in the Chetco Bar footprint. Young conifer regeneration will combine with shrub species to occupy the growing space on the site, when full site occupancy is realized, ambient conditions will determine when and if these live fuels are available to burn. Fire weather was shown to have a strong influence on reburn severity. (Coppoletta et al 2016). (EA Chapter 3 Fire, Fuels and Air Qualtiy secton)
2986-50 The EA failed to adequately analyze the potential for non-native As mappeded in the recent POC inventory on the Siskiyou National Forest (Nielsen 2013), pathogens to spread throughout the lower Chetco River watershed due there is no host POC present in the lower Chetco River watershed to spread this non-native to proposed project activities. pathogen. The nearest Sudden Oak Death (SOD) infested-site is over ½ mile from proposed timber sale units (silviculture Rx, Appendix A map). There are numerous SOD PDCs derived from quarantine area restriction in Appendix A of the EA to mitigate human-assisted spread of this disease.
Page 82 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-47 The EA failed to analyze the potential spread of POC Root Rot Recent inventory on the Siskiyou National Forest (Nielsen 2013) maps Port-Orford-cedar associated with post-fire logging (POC) at the higher elevations in the northern half of the fire area. Proposed salvage units do not have POC root rot, Phytophthora lateralis-(PL)- infested areas within or adjacent to unit boundaries. (EA Chapter 3 Vegetation section) A POC Risk Key was assembled in compliance with the Record of Decision for the Land and Resource Management Plan Amendment for Management of Port-Orford-cedar in Southwest Oregon, Siskiyou National Forest (USDA Forest Service 2004). The risk key identified Management Practices to mitigate potential spread of PL. Tree planting genetically resistant POC seedlings is recommended to increase landscape resistance to PL infection.
2986-16 The EA fails to identify an adequate diameter limit or "legacy" tree There is no requirement to identify a diameter limit for snags. The EA, Appendix A describes standards for retention within all post-fire logging units. the design criteria for snag retention and it varies by Northern Spotted Owl core or home range, critical habitat, and remaining areas. In some areas, we would retain the largest snags available or legacy features.
2986-40 The Forest Service has proposed hundreds of acres of post-fire logging Refer to response to comment 2986-38. units in the area, including a concentration on Long Ridge that will likely create barriers to connectivity. All units proposed and new road construction in the Long Ridge/Quail Prairie Connectivity Corridor should be canceled.
2986-69 The impact of converting complex, early seral habitat to plantation-like The cumulative effects are described in the EA, Chapter 3. stands in the Chetco Bar Fire Salvage Project will compound existing cumulative impacts in the Eagle Creek and Mineral Hill Forks.
2986-4 The planning area also contains high levels of biodiversity, numerous Yes, and the effects to them are described in the EA, Chapter 3. undeveloped areas and Inventoried Roadless Areas.
Page 83 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-83 The project should also implement a large Coastal Prairie Research and The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix Restoration project on Long Ridge and around Long Ridge Prairie. The land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 proposed coastal prairie restoration, including prescribed fire, native Chetco Bar fire (EA at 1-4). A large coastal prairie research and restoration project on Long seeding, cultural management practices and other non-commercial, Ridge are outside the scope of this project. non-industrial technique could be used to create a strategic fuel brake on Long Ridge. The current emphasis maximizes timber production at the expense of all other resources. We believe the Chetco River watershed and the surrounding human communities deserve a more reasonable approach.
2986-26 The proposal to log complex, early seral habitat should be canceled. All Alternative 3 and the No Action alternative address your concerns. post-fire logging units proposed in undeveloped or unmanaged land should be eliminated from consideration.
2986-1 The Purpose and Need is biased, narrow and does not reflect the actual The Responsible Official has sole discretion to establish the scope of the environmental natural resource and recreational values of the planning area. analysis, including the scope of the actions, alternatives, and effects (40 CFR 1508.25).
2986-11 The regeneration of complex forest ecosystems will also be significantly Within the 4,090 acres of proposed salvage harvest, 1,868 acres occur in managed stands set back. These impacts will be sustained across over 4,000 acres, that cannot be considered intact, unmanaged habitats, in sensitive watersheds with high including intact, unmanaged habitats, in sensitive watersheds with high biological value and important fisheries habitat. The remaining 2,222 acres are within biological value and important fisheries habitat. unmanaged stands. The effects to these areas has been described in the EA, Chapter 3.
Page 84 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-78 The region is coastal in nature and contains a few scattered redwoods, The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage as well as lush forests of Douglas fir. Redwood trees should be buffered harvest under the action alternatives. The species being targeted for salvage under the from logging operations to reduce the potential for mechanical damage action alternatives include Douglas fir and incense cedar, therefore they have been included and impacts associated with yarding operations. in Table 3. No other species would be targeted for salvage removal. However, any tree, regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels. Regarding Redwood Trees: The southern portion of the Chetco Bar fire is located within the northern boundary of the redwood ( Sequoia semperviren ) range. Proposed treatment units are located outside of areas with natural redwood canopy cover, though old district maps show some managed stands planted with redwood (e.g. east of Basin Creek and south of Panther Creek) (Silvicultural Prescription p. 2). Therefore, pockets of naturally occurring redwood exist within the project area but not within the project footprint (where ground disturbing activities are proposed). Several proposed treatment units have had redwood planted as a managed species. Most of these planted redwood trees are exhibiting sprouting, and epicormic branching. Regardless of the amount of green needles remaining, redwood trees would be retained, unless they pose a safety or operational concern as described above.
2986-24 The removal of 2,222 acres of complex forest habitat regardless of the Alternative 3 addresses your concerns. successional stage represents an irreversible loss of important complex, connectivity habitat.
2986-19 The RR-SNF has identified absolutely no guidelines for "legacy" tree Refer to the EA, Appendix A for design criteria specific to snags and downed wood. retention in the majority of the Chetco Bar Fire Salvage Project. This omission is inconsistent with the current best management practices acknowledged by many National Forests. It is also inconsistent with Standards and Guideline for matrix land that require the maintenance of ecological function and species dispersal, as well as the "maintenance of ecologically valuable structural components such as downed logs, snags and large trees" (EA 1-8).
Page 85 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-76 The scenic and recreational qualities of Packer's Cabin will also be badly Refer to the response to Comment 2986-37. degraded if post-fire logging occurs. 2986-45 The Seiad Horse EA published by the Klamath National Forest identifies The assumptions for fisher, marten and wolverine connectivity analysis identified in the simplified openings over 160' wide and created by post-fire logging as Seiad Horse Risk Reduction EA p 85 are: "Large openings (areas with no overhead cover) barriers to Pacific fisher and marten dispersal. EA identifies impacts to between habitat patches reduces habitat connectivity Fisher, marten and wolverine likely denning and resting habitat, does not evaluate impact of large avoid crossing openings without snags and coarse woody debris greater than 600 feet in structurally simplified clearings as Seiad Horse EA does. All structurally width Fisher, marten and wolverine likely avoid crossing openings without physical structure simplified openings larger than 160' are potential barriers to species (e.g. trees, snags, or coarse woody debris) greater than 160 ft in width. Pre-fire dispersal and will be avoided by late successional habitat associates denning/resting and foraging habitat that burned at moderate and high severity (greater such as the Pacific fisher and Marten (cite Seiad Horse EA). The current than 50 percent basal area loss) becomes movement habitat for the purposes of this EA analysis does not adequately consider the potential impact of analysis. Movement habitat that burned at moderate and high severity (greater than 50 creating structurally simplified openings larger that 160' wide and the percent basal area loss) is considered non-habitat." Page 15 of the associated BE for that EA direct barrier that they can create to species dispersal. The Chetco Bar also describes fisher, marten and wolverine habitats as: "Denning/resting: >50 percent Fire Recovery Project proposes to create structurally simplified opening canopy cover, large live and dead trees, large woody debris Foraging: =40-50 percent all across the planning area, exponentially increasing habitat canopy cover, may lack denning trees Movement: =20 percent overhead cover regardless of fragmentation. tree size" The units proposed for salvage in the Chetco Bar fire have had 50 percent or greater basal area loss. Approximately 36 percent of the Chetco River Watershed is mapped with 50 percent or more basal area loss (55,428 acres high mortality with >75% basal area loss, plus 26,000 acres with 50-75% basal area loss, EA p 3-6). Approximately 9 percent of the Pistol River Watershed is mapped with the same basal loss (3,174 with >75% basal area loss plus 2,257 acres with 50-75% basal area loss, EA p 3-6). For the purpose of this analysis these acres are considered to provide some degree of movement habitat. Proposed units would affect 23 percent of this fire-created movement habitat in the Chetco River watershed and 9 percent of this habitat in the Pistol River watershed. Aside from a small proportion of these watersheds lacking cover (grassy areas, rock outcrops), the remaining low severity and unburned acres in these watersheds (64 percent of the Chetco and 91 percent of the Pistol) will continue to provide a mosaic of denning/resting, foraging and movement habitat for these species.
Page 86 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-45 All salvage units would retain snags and downed wood to meet Forest Plan standards for continued matrix supplemented by DecAID recommendations for 30 percent tolerance levels of snag and down wood obligate species (EA Chapter 3 Wildlife section and EA Appendix A). While salvage harvest of the proposed units may reduce the quality and connectivity function of this fire-created movement habitat in the Chetco and Pistol River watersheds, salvage units are spread across the watersheds and situated within a larger mosaic of untreated movement habitat (77 percent of fire-created movement habitat in Chetco and 91 percent of Pistol) that would continue developing and functioning as movement habitat.
2986-25 The size of the planning area was used to mask the impact in EA The temporal and spatial scale of analysis is variable depending on the resource concern analysis. The EA analyzes this impact by considering the entire Chetco being evaluated, particularly when considering the effects of past, present, and reasonably Bar Fire Area, this means that vast acreages in the Kalmiopsis foreseeable actions (EA at 3-2). Whether an area is "off limits" to commercial timber Wilderness Area where no post-fire logging treatments are legally extraction is irrelevant for effects analysis. allowed have skewed the analysis of cumulative impacts. Because large portions of the planning area are off limits to commercial timber extraction, only small portions of the planning area are available for harvest and a much smaller planning area should have been used for analysis.
2986-6 The volume of timber available in roadside hazard logging satisfies the This comment outlines the opinion of the commenter, and a Forest Service response is not need to produce commercial timber from the Matrix land allocation. required.
2986-29 The widespread removal of biological legacies on 15,000 to 20,000 Recovery Action 12 states "In lands where management is focused on development of acres (with roadside hazard and unit logging combined) will significantly spotted owl habitat, post-fire silvicultural activities should concentrate on conserving and diminish NSO habitat values and have significant cumulative short and restoring habitat elements that take a long time to develop (e.g. large trees, medium and long-term impacts. Habitat elements and structural complexity large snags, downed wood). USDI Fish and Wildlife Service, 2011 p. III-49. The Project removed during logging treatments will take hundreds of years to includes design criteria emphasizing retention of medium and large snags and downed reproduce. Recovery Action 12 recommends conserving habitat wood throughout the project units (EA Chapter 3 Wildlife section, Appendix A, A-1 to A-2). elements that take long periods of time to develop such as large snags and downed wood (USDI Fish and Wildlife Service, 2011). These habitat elements are disproportionally found in PFF habitat and will be disproportionally removed in post-fire logging operations.
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2986-3 The Wild and Scenic Chetco River and its Outstanding Resource Values The effects to the Chetco Wild and Scenic River and its outstanding resource values are (ORV) of water quality, recreation and fisheries should be identified as described in the EA. Specifically, the EA at 1-9 states "None of the alternatives evaluated important drivers for the project, even in Matrix allocations here include any actions (except haul routes on existing roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined to have no effect to water quality. The rationale for this determination is documented in the Hydrology section. The project incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no- cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section."
Page 88 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-71 Together the connectivity corridor contains tens of thousands of acres Refer to response to comment 2986-38. of intact connectivity corridor. The corridor also provides connectivity between the Chetco River Canyon, Eagle Creek, the Mineral Hill Fork and the East Fork of the Pistol River. This corridor is extremely important for the diversity of dispersal pathways it facilitates, connecting watersheds and wildlands. Units 138, 139, 140, 141, 142, & 143 are located on a ridgeline that provides connectivity between the Mineral Hill Fork and the mainstem of the Chetco River. Before the fire, much of this area was late successional mixed conifer forest and now contains important, complex early seral habitat. Stand conditions were relatively open structured, with large populations of madrone and tanoak among scattered overstory conifers. The removal of these large biological legacies will significantly degrade habitat values, damage natural regeneration, and impact sensitive post-fire soils.
2986-81 Undeveloped area 2615 provides important connectivity habitat Refer to response to comment 2986-38.
2986-79 Units have been clustered at the lower end of Devil's Backbone, near The effects to complex early seral habitat are described in the EA, Chapter 3. Additionally, road 1909. These units are located in a narrow strip of land between Alternative 3 addresses your concerns and would not reduce the acres of complex early the South Kalmiopsis Intventoried Roadless Area and undeveloped area seral habitat. 4334. These units also contain significant biological legacies and some of the most impressive complex, early seral habitat in the lower Chetco River watershed. The stands are important post-fire foraging habitat for the NSO.
Page 89 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-20 Using a 50% tolerance level, the EA identifies minimum snag density for The EA Chapter 3 displays the 50% tolerance levels for these species and the existing snag population viability of numerous snag and cavity obligates found in the distribution for the current and reference conditions. In DecAID, reference conditions are area. These include the Fringed Myotis bat on the lower end of the based on a snapshot in time of the condition of sample plots within unmanaged stands spectrum that requires an estimated 33.2 snags per acres for representing the relevant habitat type (Southwest Oregon mixed-conifer) for the population viability, while White headed Woodpeckers require 105 unmanaged portion of the watershed to compare with plot conditions in managed stands snags pre acre. The majority of those species analyzed including the Red-representing the managed portion of the watershed. The Chetco River watershed currently breasted nuthatch, Hairy woodpecker, western bluebird and Northern has 35% more acres with greater than 24 snags per acre than reference conditions and the Flicker require between 79.8 snags per acre and 98 snags per acre. Pistol has 11% more than reference (EA Chapter 3 Wildlife section). These stands with the None of the proposed treatment areas will provide adequate habitat highest snag densities are widely distributed through the fire (EA Figure 14) and likely for these snag and cavity obligate species. provide snag densities at the 50 and 80 percent tolerance levels. Watersheds typically do not provide 80 percent tolerance levels at high proportions, DecAID acknowledges that recently burned areas are opportunities to provide higher amounts of 80 percent tolerance levels, and that a mix of 50, 80 and 30 percent tolerance levels would be desired. https://apps.fs.usda.gov/r6_decaid/views/main.html Given standards and guidelines for matrix land allocations, the project aims to retain snags to meet the 30 percent tolerance levels for this habitat type in the proposed units. (EA Chapter 3, and Appendix A, A-3) The units comprise 4 percent of the 39 percent in the Chetco watershed with >24 snags/acre, and 6 percent of the 15 percent in the Pistol watershed with >24 snags/acre. Each watershed would continue to have high snag densities above reference conditions with these reductions (31 percent and 5 percent higher than reference respectively) and meet the desire to have a mix of all tolerance levels in the watersheds. To demonstrate the clear impact of post-fire logging, the EA states, "Biological legacies in this document represent the organic debris, particularly the large organically-derived structures like standing dead trees (snags) and down logs.
2986-20 These structures are increasingly appreciated for their role in ecosystem functioning, such continued as the importance of large woody structures as animal habitat (Franklin 1990). It is well recognized that management activities, such as post-disturbance logging and dense tree planting, can reduce the richness within and the duration of early-successional ecosystems (Swanson et al. 2011 ), and can reduce the diversity and abundance of species dependent upon dead and decaying wood (Thorn et al., 2018)." (EA 3-5).
Page 90 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2986-32 We are especially concerned by the new road proposed in the Eagle See response to comment 2986-31. Use of existing legacy templates that are not part of the Creek watershed to access units 89,96,96, & 99. This particular new Forest transportation system are proposed and analyzed for temporary road use with the road appears to cross three riparian reserves and is likely to create project. The location of new temporary roads would be limited to stable ridge systems and significant watershed impacts. Numerous other new roads appear to would not be within riparian reserves (EA, Appendix A). Existing legacy templates which are cross streams and contour across steep slopes including roads that identified for temporary roads may currently be sources of sediment for streams. The provide access to units, 29, 83, 84, 127, 130, 131, 132, 150, 152, 175, project would improve conditions on these legacy templates by implementing such actions 176 and 177. All proposed new roads crossing seasonal or year-round as recontouring unstable road fills, removing old drainage features, decompacting road streams should be canceled to reduce sedimentation and hydrologic surfaces, placement of available slash, waterbarring, and placement of barriers to prevent alterations. future vehicle use (EA, Appendix A, including S-13 and S-14). Also, the no action alternative addresses your concerns.
2986-48 We are very concerned that new road construction and the potential Recent inventory on the Siskiyou National Forest (Nielsen 2013) maps Port-Orford-cedar that technically "closed" roads will receive OHV trespass will spread (POC) at the higher elevations in the northern half of the fire area. Proposed salvage units POC Root Rot. This could be a significant vector of POC root rot spread do not have POC root rot, Phytophthora lateralis-(PL)- infested areas within or adjacent to in the lower Chetco River watershed. unit boundaries. The nearest infested stream is in a separate drainage in East Fork Pistol River north of Mineral Fork drainage. This drainage is outside the project area and does not have any proposed units or road construction in proximity to this stream. There is a seasonal POC gate on FS 1376 road outside of proposed units that is closed during the wet season (October 1 - May 31) to reduce OHV traffic to mitigate spread of PL. The POC risk key in the silvicultural prescription lists management practices of project scheduling, washing project equipment and utilizing un-infested water that are project design criteria in Appendix A of the EA.
2986-75 Wildlife snags will be removed, impacting song birds, woodpeckers and Effects to migratory birds, woodpeckers and other cavity nesters are addressed in EA, cavity nesting wildlife that are currently extremely active in the burn Chapter 3. In addition PDC in Appendix A at A-3 and A-7 would provide protection of cavity area. nesters. Quinn Joseph 2988-7 "Cancel all units in Quail Prairie Creek, Mineral Hill Fork, Eagle Creek, The No Action alternative addresses your concerns. around Packer's Cabin and Long Ridge, above the Chetco River, near High Prairie above Road 1376, and above Mislatnah Creek.
Page 91 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-20 Again, bearing in mind the environmentally retrograde management Following salvage harvest, the same 4,090 acres would be surveyed for natural practices already evident on the intervening private industrial holdings regeneration. The intent is to rely on natural regeneration wherever possible. If natural within the CBS Fire perimeter, UW wishes to encourage a more regeneration is determined not to be adequate to comply with the NFMA five-year conservative approach to restocking conifers on public lands, in regeneration requirement to achieve stocking levels consistent with management general. Largely monoculture conifer (e.g., Douglas Fir) replanting, we objectives, site-specific appropriate tree species mix would be planted by hand. Trees would believe, would best be avoided. be planted at appropriate densities to achieve 125-150 trees per acre (EA at 2-4).
2988-24 Also, please bear in mind the tremendous ecological value of large old The EA, Chapter 3 Complex Early Seral Habitat and Wildlife sections describes the trees, dead, dying or fully alive. importance of large old trees and the effects to them.
2988-15 As we read that seminal paper, too heavy restocking with conifers See response to comment 2988-18 and 2989-36. appears to result in long term flow depletion, especially in low summer flows.
2988-9 Cancel all units that will impact the view shed for recreational users The effects to visual quality has been addresses in the EA, Chapter 3. Additionally, the No along the Chetco River and its tributaries. Recreation on the Chetco Action alternative addresses your concerns. River helps sustain the economy of southern Oregon's coastal communities. Logging public land will diminish the recreational experience along the Wild and Scenic Chetco River and its tributaries."
Page 92 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-10 Cavity creators and utilizers On page 2 of its CBS scoping comments, The EA considered the effects of the project on the existing snag densities in the project UW stated: "It is also useful to note the value of so called "snag forests" area (EA Chapter 3). See also response to comment 2986-20. to the viability of avian species, such as the Black Backed Woodpecker. Complementary with early seral regrowth of grasses, bushes and trees on these high intensity burned areas, is the retention of numerous snags resulting from fire. Recent studies undertaken by the Pacific Northwest Research Station (see Science Findings, issue #199, August 2017) highlight the need for a sufficient number of these valuable bi- products of high intensity fire to be retained. Surprisingly, researchers determined that many burned snags were just too hard for woodpeckers to penetrate for cavity purposes. They found '…that at- risk species, namely the black-backed and the white-headed woodpeckers, were nesting within burns that contained 86 to 96 percent of trees with unsuitably hard wood."[6] And: "Providing snags that woodpeckers can excavate is important for forest ecosystem health in the Pacific Northwest, where more than 50 wildlife species use woodpecker-excavated cavities for nesting or roosting.' "[7] We wish here to reemphasize that finding of the USFS PNWRS.
2988-8 Conduct activities that provide for public safety, maintain undeveloped The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix habitats, encourage complex, early successional forests, biodiversity, land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 and create more fire resilient habitats adjacent to the community of Chetco Bar fire (EA at 1-4). Additionally, Alternative 3 addresses your concerns. Brookings. Backcountry logging and artificial reforestation provides absolutely no benefit to communities at risk in the Brookings area.
Page 93 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-14 CONIFER RESTOCKING In regard to a possible heavy conifer restocking The proposed action is to treat areas outside of riparian reserves. Units are mostly along on lands that may be offered for area salvage, we feel compelled to ridgeline or mid-slope positions that are that are considerable distances from running water remind the RRSNF of the data-based conclusions arrived at by the Perry- to impact stream flows. The Forest's intent is to rely on natural conifer regeneration Jones 2017 study, conducted by the USFS at paired stream sites on the wherever possible. Current Forest direction for the Chetco Bar fire is to delay artificial H.J. Andrews and South Umpqua Experimental Forest and discussed regeneration and survey for natural regeneration post-treatment to determine if stocking below. levels are sufficient to meet the NFMA requirement: '(E) insure that timber harvested from National Forest System lands only where - (ii) there is assurance that such lands can be adequately restocked within five years after harvest'. If natural regeneration is determined not to be adequate to achieve stocking levels for Matrix within the NFMA timeline, site- specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. This is considerably lower planting density than historic levels within plantations that were tree planted at approximately 436 to 680 trees per acre. Additionally, there is opportunity to break up the continuity of tanoak across the landscape through tree planting to expedite establishment of alternative conifer species to Sudden oak death (SOD), Phytophthora ramorum , and to introduce disease- resistant five-needle pines and Port-Orford-cedar that are adversely affected by two additional non-native pathogens that are present, White pine blister rust, Cronartium ribicola , and Port-Orford-cedar root disease, Phytophthora lateralis to improve future forest health conditions within the fire area (Goheen, 2018).
Page 94 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-16 Despite UW having raised this seminal issue in its scoping comments, See response to comment 2988-18 and 2989-36. we failed to see any consideration of low flow rates in the EA. We note this statement from the EA: "There would be no cumulative effects to hydrology from reforestation."[12] Given the conclusions of Perry- Jones, itself undergirded by some 40 to 60 years of careful USFS paired streamflow data, and the admission by the RRSNF that more than 9,000 acres of adjoining and/or proximate private industrial lands within the CBS footprint will be extensively and completely salvage logged and densely restocked with largely monoculture Douglas Fir seedlings, UW sees this statement as unsupported and potentially specious. This very large amount of area salvage followed by heavy restocking will most definitely impact the hydrology of these watersheds in a harmful and cumulative way.
2988-6 In addition, we strongly urge the RRSNF not to extract still living trees The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage regardless of remaining green canopy, unless they present a clear and harvest under the action alternatives. The species being targeted for salvage under the immediate safety hazard. action alternatives include Douglas fir and incense cedar, therefore they have been included in Table 3. No other species would be targeted for salvage removal. However, any tree, regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
2988-17 In seeming to discount any cumulative impacts from salvage logging, in The loss of trees from fire in riparian areas, upslope and the regrowth of trees overtime can particular to low summer flows, the EA states: "None of the Action potentially change the summer low flow rates. The Wondzell reference refers to timber Alternatives are proposing the salvaging of fire effected trees within the harvest of green trees outside the riparian buffer. This project is upslope salvage of fire riparian area."[15] During the above-mentioned low flow conference, it killed trees. The trees in most riparian areas, where upslope fire salvage is occurring, have was repeatedly pointed out by Steve Wondzell (Research Ecologist, also been killed by fire. Any change in low summer flow from the loss of trees is from the USFS PNW Research Station) that riparian buffers do not and cannot, by fire, not timber harvest of green trees. definition, determine or prevent summer low flow rates, when the catchment outside that buffer has been extracted and replanted to Douglas Fir.
Page 95 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-4 Likewise, we cannot support construction of 13.5 miles of roads, The No Action alternative addresses your concerns. regardless of whether or not they are labeled temporary.
2988-12 Regarding impacts of salvage logging to the conservation and ultimate Proposed salvage would not occur in existing NRF or dispersal habitat for NSO. Proposed recovery of the NSO, UW strongly recommends against area salvage in salvage under alternative 2 would reduce approximately 921 acres of post-fire foraging partially burned stands. This is of particular concern to us in any units habitat which at the stand level have much less than 40% live canopy cover. Small patches listed as critical habitat for the Northern Spotted Owl, and especially of live trees that do not meet the definition of "dead and dying" (EA Chapter 2) may occur in those exhibiting appreciable green tree survival. the units and would be retainted in addition to legacy snags and down wood described in the project design criteria (EA Chapter 3 Wildlife section and Appendix A, A-1 to A-2). PFF habitat proposed for salvage under alternative 2 comprises 5% of the PFF habitat available in the critical habitat subunit, 4% of which is low RHS PFF that has a lower likelihood of use by NSO due to it's position in the landscape (eg. ridgelines) compared to parts of the landscape more likely to be occipied by NSO (eg. drainages). (EA Chapter 3 Wildlife section.)
2988-13 Regarding whether post-fire, unsalvaged habitat is suitable for NSO use, The EA considers the studies by Monica Bond along with other studies of NSO use of post- Monica Bond (2016) reports changing evidence about the effects of fire fire habitat to determine the degree of effects of salvage harvesting PFF. (EA Chapter 3) on the three subspecies of spotted owls. Bond et al. 2016 is specifically referenced in the project Biological Opinion on p. 35.
2988-1 Repeating what we stated in our scoping comments, hoping that the The cumulative effects of salvage logging on private lands has been addressed in the EA, message gets through: as a practical matter, there will be nearly zero Chapter 3 where effects overlap in time and space. As of May 25, 2018 Oregon Department environmental consideration afforded these watersheds by this nearly of Forestry has received notification of operations on 6,421 acres from private land owners. 10,000 acre clear cut area salvage on private industrial timberlands within the Chetco Bar Wildfire footprint.
2988-21 Roads As both UW and the RRSNF know only too well, the Chetco Bar Alternative 3 is a more conservative approach and responds to your concerns regarding new Fire Area, as so much of the forested slopes of Western Oregon, is and legacy roads. already impacted by a seemingly ever-increasing spider web of forest roads. The ecological harms, hydrological and otherwise, imposed upon watersheds by new and legacy forest roads are well known. We suggest that a more conservative approach to salvage logging might lessen the purported necessity for the USFS to construct yet additional miles of new road hereon.
Page 96 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-23 Simply, we ask the RRSNF to please take the accumulation of tree The cumulative effects from private land salvaging, BLM land salvaging, and the Danger Tree removal on this landscape into full and careful consideration when Removal project have all been considered in the EA where applicable, Chapter 3. conducting roadside salvage and when creating fire breaks. Perhaps a less extensive approach to hazard tree removal might work to at least partially reduce this accumulation? Might not careful work along the most heavily used roads be more than sufficient?
2988-3 This inequity must be borne in mind by Federal Forest managers when The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix they propose extractive operations, salvage or green tree, when one of land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 the stated purposes of such extraction is to help fund local Chetco Bar fire (EA at 1-4). OFPHT funds are outside the scope of this project. governments. This juxtaposition between public and private ownerships is every bit as unjust and out of balance as the aforementioned environmental inequities existing between private and public on these watersheds.
2988-11 UW directs the RRSNF's attention to another interesting recent study Approximately 88,757 acres of the Chetco Bar fire burned with 50% or more basal area loss. out of Oregon State University that delivers an encouraging message (EA p 3-6) These areas provide the most opportunity for post-fire insects due to open about post-fire insect life which, admittedly, we had not anticipated. conditions that favor a variety of brush, forbs, grasses that benefit a variety of pollinators. That is, the critical importance of this post-fire habitat to the numbers Proposed salvage may cause direct mortality of insects in the proposed units during and health of native pollinators. operations and short-term reduction of tbis vegetation which comprises about 4.6 percent of the 88,757 acres in the fire area and less than 1 percent of all acres of the Chetco and Pistol River watersheds. (EA Chapter 3 Wildlife section).
2988-2 UW states for the record that in formulating all of its extractive The temporal and spatial scale of analysis is variable depending on the resource concern management plans in general, and in nominating so many acres for being evaluated, particularly when considering the effects of past, present, and reasonably area salvage on Chetco Bar, in particular, managerial probity demands foreseeable actions. During the interdisciplinary process the team followed guidance that the USFS fully consider this historical context. presented in CEQ's letter dated June 24, 2005 regarding past actions. Using this guidance the EA included a summary of past, present, and reasonably foreseeable actions within and adjacent to the CBF Salvage project area. These projects were considered where relevant, when addressing the cumulative effects for various resources. The effects are disclosed in chapter 3 (EA at 3-2).
Page 97 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-18 UW strongly suggests that the RRSNF analyze its area salvage proposals The Perry-Jones study was conducted on paired streams to determine the effects of timber in light of Perry-Jones and the USFS paired stream data that undergirds harvest of green trees. The trees proposed for salvage are fire killed which is outside of the it. We suggested this in our scoping comments so as to preclude scope of the Perry-Jones study. needless duplication of effort. For one reason or another, this suggestion was overlooked or ignored. Mark it well: UW fully intends to pursue this issue.
2988-19 UW wishes to draw the RRSNF's attention to the recent Zald and Dunn The RRSNF has no control over private land holdings, therefore it is inappropriate for the Paper[16] (copy also attached), sponsored by the Humboldt and OSU RRSNF to "object in every way possible, to the threat of conifer over-stocking" on private Schools of Forestry and the Roseburg District of the BLM, whose data lands. The Forest can only speak to the cumulative effects of private land salvage and rich empirical conclusions were obtained on the Douglas Complex Fire reforestation, if they are relevant. The temporal and spatial scale of analysis is variable Area. This seminal study, to a considerable degree, turns the oft- depending on the resource concern being evaluated, particularly when considering the repeated narrative that blames ostensibly overgrown public forestlands effects of past, present, and reasonably foreseeable actions. During the interdisciplinary for the rapid and intense spread of wildfire. On the Douglas Complex, process the team followed guidance presented in CEQ's letter dated June 24, 2005 researchers showed that the intervening private industrial monoculture regarding past actions (EA at 3-2). It is recognized and accepted that high density fiber farm plantations exercised a more significant influence on wildfire plantations can burn at high severity and influence adjacent stands. Conclusions and data spread and intensity than older stands on adjoining and proximate from the Douglas complex analysis from the Zald and Dunn paper are helpful to inform public lands. UW urges the USFS to object, in every way possible, to the current and future management after high severity fire. It is important to note that the threat the kind of conifer over-stocking that so typically occurs on stand age used in Zald and Dunn was a significant driver of fire effects. Federally owned and adjoining and proximate clear cut private holdings, poses to nearby managed stands used in the analysis were 109 years vs the privately managed forests were public forestlands. Naturally, we also ask the RRSNF to carefully 52. In fact after Burn index stand age was the most important factor. "intensively managed consider the inadvisability of adding to this threat by means of its own private industrial forest burned at higher severity than older federal forest" (Zald and Dunn too heavy restocking. With this caveat in mind, we strongly urge the 2018). At issue is not whether there will be a young forest, but what species and densities forest managers to avoid area salvage in the 2022 acres of primary will be present. Thompson et al 2007 points out, "young forests, whether naturally or forest included in Alternative 2. artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". If tree or stand age is a surrogate for overall tree size, it is expected that fire severity would be higher in young forests. It is important to revisit the definition of fire severity. Fire severity describes the immediate effects of fire on vegetation, litter, or soils. It is most commonly used to describe fire's effects on the primary tree cover. When trees are young, they have thinner bark, lower height to live crown and are therefore more susceptible to even moderate fire.
Page 98 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-19 Surface fuels from harvest operations will most likely be the biggest contribution to future continued fire risk for approximately 15 years, at which time decomposition will have reduced the continuity of surface fuels, and after live fuels, (both brush and trees) have completely occupied the site. It is expected that there will be a strong shrub response that can exacerbate surface fuel conditions (Albini 1976). Furthermore, ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity (Coppoletta et al 2016) (EA Chapter 3 Fire, Fuels and Air Quality section).
2988-22 We ask the USFS to please carefully consider the environmental impact The cumulative effects of the Roadside Danger Tree Abatement project are described in the an overly aggressive hazard tree removal action would have on EA, Chapter 3, where applicable. watershed function.
2988-5 we offer at least conditional support for Alternative 3, Thank you for your support.
Page 99 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2988-25 When one considers the carbon release impact associated with road The Forest Service does not have a national policy or guidance for managing carbon, and the building, tree falling, yarding, loading and transporting salvaged stems, tools for estimating carbon and sequestration are not fully developed. Current direction for in addition to the losses in manufacturing and use of wood products, a addressing climate change issues in project planning and the NEPA process is provided in cautious approach to post-fire extraction seems to us to be called for. the document Climate Change Considerations in Project Level NEPA Analysis (USDA Forest Regarding the latter concern, UW offers the following, excerpted from Service 2009). This document outlines the basic considerations for assessing climate change the conclusions section of the paper Wood Products and Carbon in relation to project-level planning. Two types of climate change effects will be considered Storage, written by Ann Ingerson and sponsored by the Wilderness for this analysis: Effect of the proposed project on climate change, specifically effects to Society: "Setting public goals for forests will require weighing the greenhouse gas emissions and carbon cycling. Examples include: pyrogenic emissions advantages of accumulating more carbon in forests versus the caused by prescribed burning, changes in biogenic emissions through thinning and forest advantages of accumulating it in furniture, homes, and landfills or management, avoidance of large pyrogenic emissions associated with wildfire through burning to generate energy. In most cases, boosting forest carbon forest management, and carbon cycle alterations through reforestation and forest stores will create stable, self-sustaining carbon reserves at no fossil-fuel management. Effect of climate change on the proposed project. Examples include: effects emissions cost. Protecting and enhancing forest carbon reserves can of climate change on the seed stock selection for reforestation, potential changes in natural also help maintain undisturbed, late-successional forests that are forest regeneration, and effects of decreased snow fall on recreation or stream flows. (EA currently rare across the landscape. These forests could provide a Chapter 3 Climate Change section) refuge for species stressed by a changing climate and provide valuable lessons about how natural systems adapt to new conditions. In contrast, carbon storage in wood products and landfills depends upon continuing fossil fuel use and requires space for housing and landfills that displace carbon-fixing vegetation".[17] Of course, this is not to say there are no benefits to be had from ecologically sensitive timber harvests. Rather, we feel it speaks to the need for such limited harvests, as all other USFS management activities, to be planned and conducted so as to adequately consider the impacts of forest management on the Earth's climate.
Sexton George 2989-10 Allowing log haul until turbid water is visibly leaving the road surface Thank you for your comment. Language in the EA has been modified to include active is certain to result in fine sediment being delivered to CCH. sentences rather than passive sentence structure. Therefore, statements that will "minimize" sedimentation have been changed to "eliminate" sedimentation.
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2989-34 Alternative 2 would involve significant logging of Post Fire Foraging Please refer to the response to comment 3538-13. (PFF) habitat in 11 NSO home ranges (EA 3-15) and within designated NSO critical habitat unit KLW3 (EA 3-16) such that the project is Likely to Adversely Affect NSO and their habitat and necessitates completion of an EIS due to significant impacts to this listed species. Alternative 2 is Likely to Adversely Affect NSO "due to removal of large snags within PFF habitat that would otherwise contribute to physical and biological features of future suitable habitat for Northern spotted owls." (EA page 3-45).
2989-33 Alternative 3 has a higher economic efficiency ratio of 1.16. This Alternative 3 does have a higher economic efficiency ratio (1.16) compared to the Proposed effectively means the revenue generated by the project exceeds the Action (1.08). However the Proposed Action alternative has a higher Present Net Value costs incurred by the Forest Service to implement the project." (EA 3- ($2,830,596) compared to Alternative 3 ($1,097,172). The Proposed Action alternative also 59). has higher revenue generated ($37,882,466) when compared to Alternative 3 ($7,925,246).The Proposed Action also provides more volume (71,476 MBF) to the local market compared to Alternative 3 (14,953 MBF). EA, Chapter 3 Economics section.
2989-48 As indicated on page 4 of the Draft Silvicultural Prescription Report, In compliance with the Record of Decision for the Land and Resource Management Plan numerous logging units, temporary road locations and timber haul Amendment for Management of Port-Orford-cedar in Southwest Oregon, Siskiyou National routes traverse currently uninfected POC watersheds. The EA largely Forest (USDA Forest Service 2004) a POC risk analysis has been documented using the risk fails to analyze or disclose the potential for irreversible spread of PL key. The risk key is in the project record and is used to clarify the environmental conditions associated with temporary road establishment and timber haul. that require implementation of one or more of the disease controlling management Despite the acknowledgement in the POC "Risk Key" of significant practices listed in the LRMP amendment. Project design criteria described in chapter 2 uninfected POC watersheds/stands, the project fails to implement the would minimize or eliminate the risk of spreading PL. Therefore there would be no direct or recommended POC management strategy of prohibiting wet weather indirect effects to the spread of PL. (EA Chapter 3 Vegetation section) operations. Note that the Risk Key indicates that the proposed action will introduce appreciable additional risk of infection to uninfected areas.
Page 101 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2989-32 As stated on page 3-52 of the EA "Alternative 2 would reduce large All proposed units are within the matrix land allocation. In reference to Figures 6 and 8 of snags that may contribute to future legacy structure associated with the EA, salvage units occur in the >=18 snag/acre category for the Chetco and Pistol River suitable mature and old-growth forest habitats for Northern spotted watersheds. This high snag density is currently higher than reference condition in both owls and marten." Hence the impacts of Alternative 2 may be watersheds. Proposed salvage acres would occur in 1.6 percent of the Chetco and 20" dbh significant to wildlife species of concern. (EA Chapter 3 Wildlife section), the remaining snag density in the salvage units would fall into the 0-2 or 2-4 snag/acre categories in those figures. The high snag density categories would remain higher than reference conditions and the watersheds would still have a lower deficit of snags than they did prior to the Chetco Bar fire. For these reasons, the proposed salvage is not expected to appreciably affect wildlife species that use mature forests with legacy structure because there would still be more legacy snags now than there was prior to the fire to contribute to future habitat.
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2989-38 Black Backed Woodpeckers R. Nawa and others observed rare black- Black-backed woodpeckers are not identified as a federally listed or Forest Service Sensitive backed wookpeckers subsequent to the Biscuit fire. There needs to be Species. Therefore survey and protections are not required for individuals of these species a mitigation to provide for a large snag patch if a nesting BBW is found outside of protection for migratory birds in general from the Migratory Bird Treaty Act. In and verified. BBW require a large snag patch habitat to provide order to meet the intent of the Migratory Bird Treaty Act, the following PDC would be adequate food for young. implemented if an active black-backed woodpecker nest were encountered during project activities: WL -15: Untreated buffers of active bird nests encountered during project activities would be large enough to avoid soliciting a stress response that causes an adult to flush from incubating eggs or nestlings, avoid feeding young or exhibit defensive behavior until young have fledged. Because this buffer distance would be site and species specific, the distance would be determined by a Forest-employed wildlife biologist or appointee. Suitable BBWO habitat exists outside the fire perimeter throughout the western states. Approximately 2% of the fire area and 16% of the matrix lands are proposed for timber harvest with the proposed action. There is not currently known use of black backed woodpeckers in the fire area, however since the majority of the fire area would not be treated by salvage, it is reasonable to expect that if black backed woodpeckers are using the fire area that sufficient habitat would exist even with the implementation of the proposed action. Studies of black-backed woodpecker home range sizes have found that the higher the snag basal area, the smaller the home range (Dudley et al. 2012, Seavy et al. 2012, Siegel et al. 2014, Tingley et al. 2014) BBWO home ranges are highly variable ranging from 59 to751 acres (Siegel et al. 2013 and Tingley et al., 2014). Snag basal area alone best predicts home range size, such that as snag basal area increases, home ranges exponentially decrease in size, strongly suggesting increased habitat quality (Tingley et al., 2014). BBWOs also occupy green forests, and recent occurrence rates were found to be higher in green forests than previously suggested. Green forest occurrences positively correlated with elevation, latitude, northern aspects, number of snags, tree diameter, and lodgepole pine forests, implying that green forests with higher snag densities may provide important secondary habitat. (Fogg et al., 2014).
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2989-38 Dudley et al. 2013 described foraging habitat selected by black-backed woodpeckers as continued "burned forest with high densities of larger diameter trees". This could be equated with post- fire foraging habitat described for northern spotted owls. The project minimized harvest of PFF habitat such that approximately 7 percent of 12,904 acres of PFF in the Chetco and Pistol River watersheds would be affected by the project. With proposed harvest and other activities considered that would reduce high snag densities in these two watersheds, they would still remain above reference conditions for high snag densities that would provide potential foraging habitat for black-backed woodpeckers. (EA Chapter 3 Wildlife section). Additional Literature Citations included above: Dudley, J. G., V.A. Saab, and J.P. Hollenbeck. 2012. Foraging-habitat selection of black-backed woodpeckers in forest burns of southwestern Idaho. The Condor 114: 348-357. Fogg, A. M., L. J. Roberts, and R. D. Burnett. 2014. Occurrence patterns of Black-backed Woodpeckers in green forest of the Sierra Nevada Mountains, California, USA. Avian Conservation and Ecology 9:3. Seavy, N.E., R.D. Burnett, and P.J. Taille. 2012. Black-backed woodpecker nest-tree preference in burned forests of the Sierra Nevada, California. Wildlife Society Bulletin 36:722-728. Siegel, R.B., M.W. Tingley, R.L Wilkerson, M.L Bond, and C.A. Howell. 2013. Assessing home range size and habitat needs of black-backed woodpeckers in California: Report for the 2011 and 2012 field seasons. Report to USFS Pacific Southwest Region. The Institute for Bird Populations, Point Reyes Station, California. Siegel, R.B., M.W. Tingley, and R.L. Wilkerson. 2014. Assessing home-range size and habitat needs of black-backed woodpeckers in California. Report for the 2013 field season. Institute for Bird Populations, Sierra Nevada Bird Observatory, Point Reyes Station, CA. www.birdpop.org Tingley, M.W., R.L. Wilkerson, M.L. Bond, C.A. Howell, and R.B. Siegel. 2014. Variation in home-range size of black-backed woodpeckers. The Condor 116:325-340.
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2989-23 Changed Conditions and The 1996 Chetco Watershed Analysis Comment noted. Our interdisciplinary team of scientists (the Team) will be completing an Analysis in the EA is not based on the best available science because it updated watershed analysis, however it is important to note that the existing conditions relies upon a 1996 Chetco Watershed Analysis that has not been discussed throughout the EA will support the information that will go into updating the updated to reflect effects of the Chetco Bar Fire. watershed analysis. The project's purpose was to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire, and if delayed by a watershed analysis until October 2018 or later timber value would be reduced (EA at 2-6). The effects of the Chetco Bar Fire was reflected within each indicator based on professional judgment and field observations in the appropriate resource specialist reports.
2989-5 Due to substantial deleterious cumulative impacts to the Panther Creek The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical and Basin Creek watersheds providing Critical Coho Habitat, habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the additional impacts to these watersheds should be avoided. action alternatives, then no cumulative effects can occur from the proposed activities.
2989-6 Ground Based Salvage Logging on High Severity Burn Soils See response to comment 2983-8.
2989-25 However, the EA fails to assess the significance of In response to your comment, cumulative effects from dozer and hand lines have been erosion/sedimentation from 58 miles of dozer lines and 51 miles of incorporated into the Soils and Hydrology Reports, and included into the EA under resource hand lines (EA 3-3) as a cumulative effect. We assert in the absence of sections. any effectiveness monitoring for fire line rehabilitation, the EA must report expected erosion/sedimentation from fire lines, which could be significant.
Page 105 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2989-30 Implementation of Alternative 2 will undermine Forest Service policy Fire hazard for any particular forest stand or landscape is the potential magnitude of fire objectives regarding fire hazard and result in significant impacts that behavior and effects as a function of fuel conditions (Peterson et al.. 2005). Fire hazard necessitate completion of an EIS for this project. most commonly refers to the difficulty of controlling potential wildfire. Fire behavior characteristics such as rate-of-spread, intensity, torching, crowning, spotting, fire persistence, or resistance to control are generally used to determine and describe fire hazard. As Brown et al. (2003) indicated, fire severity can be considered an element of fire hazard. The Rogue River Siskiyou land and resource management plan identifies strategies for fuel management. 12-2 The fire hazard presented by natural, activity or prior activity fuels should be reduced to appropriate levels, considering the site specific risk, and utilizing economically efficient treatment methods. The selected treatment methods should meet fuel management objectives which integrate consideration for all resource values. Fuel management objectives as identified in the EA call for limiting fuel bed depth to 12" across treatment units. This was identified as modeling shows moderate spread rates and low flame lengths, which will allow for direct attack with hand tools. 12-4 Proposed activity units (harvest, thinning, conversion, release, etc.) should be designed and coordinated on the ground so that size, shape, location, timing, spatial distribution, and management risk are considered for fire management and other resource requirements and help make the fuel treatment and fire protection of the units as practical and economical as possible. Proposed activity units provide opportunities for future fire management through snag mitigation. Additionally, the location of harvest units does not increase connectivity of surface fuels. Managing fuel loadings and location of harvest activities are within typical vegetation management activities on the Rogue River-Siskiyou National Forest, and therefore do not require an EIS.
2989-3 Implementation of Alternative 3 would result in both higher economic Alternative 3 does have a higher economic efficiency ratio (1.16) compared to the Proposed efficiency and a higher net value to the agency than would Action (1.08). However the Proposed Action alternative has a higher Present Net Value implementation of proposed action (Alternative 2). ($2,830,596) compared to Alternative 3 ($1,097,172). The Proposed Action alternative also has higher revenue generated ($37,882,466) when compared to Alternative 3 ($7,925,246).The Proposed Action also provides more volume (71,476 MBF) to the local market compared to Alternative 3 (14,953 MBF). Please refer to the EA Chapter 3 Economics section.
Page 106 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2989-44 Less than one hundred foot buffers (EA-134) are not proven to be See EA Appendix A (A-37, PDF No. SP-1), "No new roads or landings would be constructed adequate to protect known populations of Sidalcea malviflora, and no slash piling or ground-based equipment would be used within 100 feet of sensitive Ericameria arborescens and Bensionella oregana from effects of clear- plant population boundaries." cut salvage logging. Unit size should to be reduced to provide adequate no cut buffers.
2989-2 Log haul will directly negatively impact federally threatened Southern Part of the design criteria for the Chetco Bar Area Salvage Project is to avoid any additional Oregon/Northern California Coasts Coho Salmon and their critical disturbance in areas directly adjacent to stream channels, therefore no harvest has been habitat such that the Forest Service must conduct consultation with authorized within the Riparian Reserve land use allocation. Field observations are detailed in the National Marine Fisheries Service. chapter 3. Field observations and past monitoring studies (McHugh, 2005) were reviewed in order to predict sediment impacts to streams (EA Chapter 3 Hydrology Section). The Project Design Criteria (EA, Appendix A) list specific actions to control any potential sedimentation to streams. Protective riparian reserve buffers (EA Chapter 3 Hydrology section) around all streams and potentially unstable areas serve to retain sediment. Sediment trap structures would be used where needed (LH-6, Appendix A, page A-16).
2989-46 Page 8 of the Logging and Transportation Report indicates that each Thank you for your comment. Page 8 of the Logging and Transporation Report also helicopter logging unit will involve two landings requiring the clearing indicates: "However, the actual landing size and location can vary widely depending on and leveling of 80 ft by 200 ft of forests including the removal of live terrain, slope, volume flown per acre, and flight direction." (Logging and Transporation green trees. The location, number and impact of these landings on soils, Report, Economic Analysis, Page 8, Crum 2018). An aerial harvest systems analysis was hydrology and wildlife habitat are not analyzed or disclosed in the completed based on the estimated 2 percent disturbance on soils, which includes Chetco Bar Salvage EA. disturbance from landings. Refer to EA Chapter 3 for Aerial (Helicopter) Systems discussion. Also, refer to soils section, Soil and Site Productivity subsection and Table 22. Table 22 identifies total estimated acres of detrimental soil disturbance for aerial harvest system for Alternative 2 (22 acres) and Alternative 3 (6 acres) (EA Chapter 3).
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2989-37 PDF No. VR-4 (A-25) This PDF provides for retaining all living Adherence to all project design criteria is required and is the basis for determinations made vegetation within the following treatment units: 1, 4, 31, 32, 35, 38, in the EA. As such, all will be fully implemented. Project design criterion VR-2 in Appendix A, 40, 110, 111, 125, 140, 176, 177, 33, 64, 65, 66, 9, 11, 12, 13, 15, 16, 18, page A-23 stated "Created openings or clearings, including openings for landings, should 19, 20, 22, 23, 25, 27, 76, 102, 103, 104, 106, 107, 108, 114, 130, 131, mimic size, shape, and character of natural openings found in the surrounding landscape." 141, 142, 143, 17, 26. Is this PDF in fact being implemented in project Mandating a size range for project created openings would be at odds with the stated design and implementation? PDF No. VR-2 "Created openings or objective of criterion VR-2, to "mimic the existing natural forms, lines, colors, opening sizes, clearings, including openings for landings, should mimic size, shape, and and opening shapes in the landscape and to avoid the introduction of artificial patterns or character of natural openings found in the surrounding landscape. uniform appearance." Openings should be irregular and random in shape to prevent visually recognizable artificial patterns in the landscape. Openings should follow contours or natural terrain features and should not have straight edges or angular corners. Edges of openings should be horizontally and vertically feathered with nonmerchantable and small woody understory vegetation." We interpret this to mean that openings created by logging would range from 1- 5 acres for units 1, 4, 31, 32, 35, 38, 40, 110, 111, 125, 140, 176, 177, 33, 64, 65, 66, 9, 11, 12, 13, 15, 16, 18, 19, 20, 22, 23, 25, 27, 76, 102, 103, 104, 106, 107, 108, 114, 130, 131, 141, 142, 143, 17, 26. Is this PDF in fact being implemented in project design and implementation?
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2989-31 Please note that no specific analysis for impacts to soil, water quality, Any special or unique resource values in undeveloped lands that have been identified by air quality; plant and animal communities; habitat for threatened, project resource specialists are described in the EA for each polygon. If special or unique endangered and sensitive species; recreation; noxious weeds; and resources were not identified for a polygon, the effects for resources such as, soils, water cultural resources, etc. have been conducted in regards to proposed quality, vegetation, fuels, air quality; plant and animal communities, habitat for threatened, logging in undeveloped wildlands. No specialist report has been endangered, and sensitive species; noxious weeds, roaded modified and roaded natural prepared to disclose and analyze impacts to the unique and distinct recreation, semi-primitive non-motorized and motorized recreation, scenery, and cultural values provided by undeveloped wildlands. resources are the same as disclosed in previous sections of this chapter and not reiterated here. Several of these polygons represent lands that are adjacent to or encompass the Chetco and Pistol Rivers and/or their tributaries. The Chetco River and Pistol River Watersheds contain ESA-listed Southern Oregon/Northern California Coasts (SONCC) coho salmon and their designated critical habitat, Forest Service Sensitive SONCC Chinook salmon, Pacific lamprey, and Klamath Mountain Province (KMP) steelhead trout. The range of the species described above are all found within polygons 5416, 1622, 3877, and 4334. The other identified undeveloped lands within the project area are all in close proximity to stream channels that contribute to the habitat needs of the species described above. However, there are no anticipated project related effects to any of these species, as is described in the Fisheries section of the Chetco Bar Area Salvage EA, therefore the unique qualities of these species will not be affected in any way from project-related activities. Undeveloped lands within the project footprint were not identified to have special or unique soil resource values. Soils identified within the project footprint are summarized above and fully described in the Soils Resource report in the project record. Effects to the soil resource from proposed project treatment activities would not differ based on the description of land (undeveloped). Management direction and project design criteria are required to ensure compliance and avoid adverse impacts to soils, and would be implemented during operations across all NFS lands.
2989-31 Therefore, the description of effects are not differentiated further in the analysis, and continued include salvage logging activities and the associated connected actions to complete project activities. Approximately, 826 acres (about 20% of the salvage areas proposed) of undeveloped lands are proposed for salvage under Alternative 2, and an estimated 1.5 miles (about 11% of the temporary roads proposed) of existing legacy templates reused for operations as temporary roads. (EA Chapter 3 Undeveloped Lands section)
Page 109 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2989-28 Reconstruction of Road 1407-180 to access unit 99 appears to cross a Thank you for your comment. See response to comment 2989-15 and 2989-27. No road steep headwall in SW1/4 of section 19 (T38S R12W) and associated construction or reconstruction is proposed under this project proposal (EA at 2-4). riparian reserve. This midslope road is on 55% slopes and would have high potential for a debris flow or log haul sediment into Eagle Creek CCH. The EA failed to analyze or disclose erosion potential and landslide potential for this temporary road. KS Wild Chetco Bar Salvage EA Comments 15 A presumably new temporary road accessing unit 176 appears to cross a riparian reserve (EA B- 10 Fig. 32). The action alternatives appear to disregard direction in the Siskiyou National Forest Plan at IV- 57 indicating that "construction of temporary roads should normally be discouraged." (EA 3-69). The EA contains no site-specific (or cumulative) effects analysis regarding the impacts of postfire logging road construction and re-construction.
2989-35 Red Tree Voles It is our understanding from page 3-17 of the EA that Red Tree Voles are addressed in the EA Chapter 3 Wildlife section. Proposed salvage would the Forest Service intends to log post-fire stands with as little as 50% remove dead and dying trees as described in the EA Chapter 2. Furthermore, the Survey mortality (and a substantial green tree canopy component), and live Protocol for the Red Tree Vole Ver. 3.0, 2012 pp. 9-10 provides direction to identify stands green old-growth trees with minimal crown scorch without conducting that provide "suitable habitat that may potentially contribute to a reasonable assurance of required Red Tree Vole surveys. persistence" for which surveys would be required. Such stands in the Mesic Zone for RTV surveys should have at least 18" QMD of trees and conifer or mixed conifer hardwood stands with dominant, codominant and intermediate canopy closure of 60% or more. Furthermore, live Douglas-fir needles are the primary food source for RTV. The stands proposed for salvage do not have canopy closure of 60% or greater. There may be some small patches of trees with live branches in a unit, but as a whole none of the units would provide suitable habitat for RTV, and therefore do not require surveys.
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2989-45 Requirements to manage for sensitive plant species cannot be A pre-field review was completed to determine areas of high probability habitat within the effectively implemented without pre-disturbance surveys. project planning area to survey specific sites for sensitive species. Field checks of potential habitat for sensitive species were completed during Burned Area Emergency Response (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EAChapter 3 Botanical Resources section, and EA Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018).
2989-39 Retaining all green trees in units would fulfill any snag requirements The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage since some of these trees will certainly become snags in the short harvest under the action alternatives. The species being targeted for salvage under the term. Retaining live trees will help maintain KS Wild Chetco Bar action alternatives include Douglas fir and incense cedar, therefore they have been included Salvage EA Comments 19 root strength needed for slope stability for in Table 3. No other species would be targeted for salvage removal. However, any tree, a longer period while continuing to contribute needle cast. Please regardless of species, that is determined to be a hazard to operations may be removed for note that page 3-77 of the EA indicates that "needle cast and leaf litter safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as appeared to have the greatest effect on erosion vs accumulation…" per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and for soil resources. marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels. Effects of harvesting dying and damaged trees is discussed in the effects to soils on slope stability and erosion hazard potential and are included in Chapter 3 of the EA. Impacts to soil stability and erosion hazard potential from harvest of trees with a probability of mortality consistent with Table 3 is not expected to have a significant effect.
2989-40 Retention of live green trees may reduce the significant impacts of Please refer to the response to comment 2989-39. post fire logging on wildlife, soils, conifer regeneration, and aquatic forest values. It may also reduce social controversy and contribute to project buy-in.
Page 111 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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2989-4 Salvage logging of previously unmanaged forest stands will increase fire Harvest units will have increased levels of fine fuels immediately following harvest. These hazard, fine fuels, potential flame lengths and rates of fire spread fuels will be the primary contribution to fire rates of spread and intensity for approximately compared to untreated post-fire forests. 15 years at which time live fuels will have fully occupied the site. Personal observations during the Chetco Bar fire of areas that previously burned in the 2002 Biscuit demonstrate that areas of high severity fire again burned at high severity. After 20 years, research has shown that areas of salvage will have lower fuel loadings as compared to those unmanaged portions. Harvest operations will contribute fine fuels, small diameter twigs and branches and unmerchentable tops, (slash) to the surface. Currently very little surface fuel remains as a result of the Chetco Bar fire. Soils and hydrology concerns require some amount of material to be left on site for resource protection. Project design criteria limit surface fuel accumulations to 12" depth or less throughout harvest units. Limiting fuel bed depth can enhance initial attack capabilities and success rates. Additionally, until live fuels (both brush and trees) occupy the site, fire spread will be limited by the lack of surface fuel continuity. Removing dead trees will also serve to improve access in the event of a future fire event. Previously burned trees (snags) are recognized as a threat to fire fighter safety during fire events. Harvest operations are recognized as contributing to increased surface fuel loading and reduced snag densities within harvest unit boundaries. Surface fuels from harvest operations will most likely be the biggest contribution to future fire risk for approximately 15 years, at which time decomposition will have reduced the continuity of surface fuels, and after live fuels, (both brush and trees) have completely occupied the site. Thompson et al 2007 points out, "young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". It is expected that there will be a strong shrub response that can exacerbate surface fuel conditions. (Albini 1976) Furthermore, ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity. (Coppoletta et al 2016). (EA Chapter 3 Fire, Fuels and Air Quality section)
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2989-19 Significant watershed scale impacts to CCHin 6th field watersheds have The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical been masked by analysis restricted to larger 5th field watersheds. habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the Please further note that there will be significant deleterious cumulative action alternatives, then no cumulative effects can occur from the proposed activities. (EA impacts to the Panther Creek Watershed from proposed extensive Chapter 3 FIsheries and Aquatic Biota section) Forest Service logging and foreseeable private lands (South Coast Lumber) clearcutting with no riparian buffers and associated utilization of unstable road 1407-150.
2989-9 The Chetco Bar Salvage EA (3-115) states that "Road-derived sediment A discussion of erosion and sedimentation, as well as turbidity is discussed in the Hydrology would be directed onto the forest floor through cross drains where it section of the EA Chapter 3. In addition, road maintenance activities would be implemented would be filtered before reaching stream channels." The existing cross in areas where potential for erosion and sediment production is predicted (EA at 2-3). drains are inadequate to disconnect the stream system from all roads Furthermore, the following project design criteria serve to mitigate impacts from "road- subjected to log haul (See Photo 1). Numerous proposed haul roads are derived sediment" including: H-4, LH-10, LH-11, LH-12, and LH-13. See EA, Appendix A for a located only a short distance from streams while vegetation that full list of PDCs. would normally filter out log haul sediment has been removed by the fire (e.g. Roads 1376, 1909). The EA/action alternatives/PDFs do not provide for specific locations for additional cross drains that would substantially disconnect the log haul roads from the stream system (e.g. Panther Creek, Basin Creek, Quail Prairie Creek, Eagle Creek).
2989-18 The Chetco Bar Salvage EA analyzed cumulative effects at relatively The Northwest Forest Plan addresses effects at the 5th field watershed scale. If relevant, large 5th field watersheds which greatly diminished the actual effects smaller scales can be used. No salvage activities are planned within designated Northwest at smaller watershed scales that are relevant to CCH. Forest Plan riparian areas. Under the Aquatic Conservation Strategy, Riparian Reserves maintain and restore aquatic resources. Since no activities are planned within the riparian reserves, addressing effects at a smaller than a 5th field scale is not relevant.
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2989-14 The Chetco Bar Salvage EA failed to discuss and report baseline stream See response to comment 2989-23 in regards to reporting baseline conditions. Also, refer to sediment conditions. Table 8 (p. 17) in the Hydrology Report identifies the EA Hydrology section , Affected Environment, Fire subsection (EA Chapter 3) for a the Chetco River, Eagle Creek, Pistol River and South Fork Chetco as discussion on stream conditions post-fire, and subsequent Environmental Consequences, 303(d) listed for sediment. Data about sediment condition in ESH Turbidity (fine sediment delivery) subsection for observed stream sediment conditions streams are available from Forest Service stream surveys but were not within the project footprint. In addition, project design criteria (EA, Appendix A) maintain a reported in the EA (i.e. available information per NEPA). full Northwest Forest Plan riparian no cut buffer within at least one or two site potential tree heights (175 or 350 feet) on fish bearing and perennial non-fish bearing streams to avoid sedimentation from project activities, and therefore no change in conditions in 303(d) listing is predicted.
2989-26 The EA (3-103) also reports that private land logging/log haul during See response to comment 2989-12. Please also refer to the Hydrology Report, Direct and winter 2018 on Forest Service Road 1376 muddied the Chetco River. Indirect Effects Common to the Action Alternatives subsection (EA, Chapter 3) for effects The EA fails to acknowledge that similar log haul-related turbidity from discussion on turbidity from log-haul. In addition, no private log-haul is expected on FSR federal logging could affect the Chetco with the proposed action. 1407-150. The EA does not discuss "no wet season" log haul restrictions for South Coast Anticipated private log haul on Road 1407- 150 could also increase Lumber because private log haul is authorized under a separate process. turbidity of the Chetco River because the EA provides for no wet season log haul restrictions for South Coast Lumber.
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2989-27 The EA (3-106) states "There is no road reconstruction proposed in this Refer to to the EA Chapter 3, Hydrology section, Temporary Roads and Landings subsection project" but then contradicts this statement by stating "Temporary for clarifying language. There is no reconstruction proposed in this project on system roads, roads would include reconstruction of existing (Unclassified) roads however reconstruction of existing road prisms that are not part of the Forest where there is an existing road template." Reconstruction of Road transportation system is proposed and analyzed for temporary road use with the project. 1407-184 to access unit 89 appears to cross a steep headwall in SW1/4 See comment 2989-15 for discussion on erosion and landslide potential on temporary of section 19 (T38S R12W). See EA B-4 Figure 26 and Bosley Butte roads. The location of new temporary roads would be limited to stable ridge systems and Quadrangle. This midslope road is on 55% slopes and would have high would not be within riparian reserves (EA, Appendix A). Existing legacy templates which are potential for a debris flow or log haul sediment into Eagle Creek CCH. identified for temporary roads are currently a sources of sediment for streams. The project The EA failed to analyze or disclose erosion potential and landslide would improve conditions on these legacy templates by implementing such actions as potential for this temporary road. The EA failed to assess likely recontouring unstable road fills, removing old drainage features, decompacting road erosion/sedimentation of Panther Creek from South Coast Lumber surfaces, placement of available slash, waterbarring, and placement of barriers to prevent reconstruction of washed out Road 1407-150 (cumulative effects). The future vehicle use (EA, Appendix A, including S-13 and S-14). See response to comments EA fails to provide for decommisioning of Road 1407-150 subsequent 2989-12 and 2989-26 in reference to FSR 1407-150. Use of this road would be authorized in to log haul by South Coast Lumber. The EA (3-106 states) that "new a separate nepa document. However the EA found that erosion and sedimentation would temporary roads or landings would not be located within Riparian not increase from proposed action alternatives (EA, Chapter 3), based on PDCs (Refer to EA, Reserves as stated in the project design criteria in Chapter 2", however, Appendix A). Therefore, no cumulative effects would occur from project activities (EA, we found at least two temporary roads that appear to cross riparian Chapter 3 Hydrology section) even if the use of the FSR1407-150 road is authorized. reserves as noted below. Currently the EA fails to demonstrate compliance with RF-2, RF-3, RF-4, RF-5, and RF-7 for these new roads (USDA and USDI 1994 b,c page C-32 and C33).
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2989-15 The EA (3-106) states that "None of the alternatives include activities Refer to the EA, Chapter 3 Soils section, Soil Stability and Erosion Hazard Potential that will alter the natural frequencies of landslides." While it is subsection for actions that could increase risk of landslides and erosion potential of difficult to predict increased frequency of landslides with any temporary roads. To mitigate risk of landslides use of the Slope Stability and Soil Risk certainty (e.g. "will"), the EA fails to analyze actions that may increase Erosion model will aid in identifying unstable and potentially unstable terrain. The areas the risk for landslides. Detrimental soil disturbance would occur on identified as VERY HIGH risk in this analysis are considered unstable or potentially unstable 238 acres in Alternative 2 which may increase the risk for landslides. areas, and as such are included in the Riparian Reserve network. Using this process, areas Green tree logging EA (2-2) would hasten loss of root strength and classified as "VERY HIGH" will be excluded from treatment activities and will be buffered could increase the risk for landslides. Reconstruction of Road 1407- appropriately according to the Riparian Reserve widths identified for the Chetco Fire 184 to access unit 89 appears to cross a steep headwall in SW1/4 of Salvage project. A Hydrologist or Soil Scientist will assist in field validation and identification section 19 (T38S R12W). See EA B-4 Figure 26 and Bosley Butte of additional unstable areas and streams prior to implementation of stand treatments (EA, Quadrangle. This midslope road is on 55% slopes and would have high Appendix A, PDC S-1). No road reconstruction is proposed under this project therefore there potential for a debris flow or log haul sediment into Eagle Creek CCH. is no potential for Road 1407-184 to cause a debris flow or log haul sediment into Eagle The EA failed to analyze erosion potential and landslide potential for Creek CCH from reconstruction activities. See also, response to comment 2989-12 and 2989- this temporary road. The EA fails to discuss potential for road failure 14. for anticipated reconstruction of "washed out" Road 1407-150 by South Coast Lumber.
2989-43 The EA (3-134) identifies 6 sensitive plant species known to occur within The EA Chapter 3 Botanical section, acknowledges that Illiamna latibracteata "is found the Chetco Bar Salvage Project Area. The EA fails to acknowledge that almost exclusively within openings in recently-burned forests dominated by white fir (Abies Illiamna latibracteata is fire-dependent and likely exists in seed banks concolor) or Douglas-fir (Pseudotsuga menziesii)" It is acknowledged that Illiamna in the burned area. latibracteata is fire-dependent and likely exists in seed banks in the burned area. The EA discusses potential effects to Illiamna latibracteata .
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2989-8 The EA (3-71) states: "Post-haul maintenance that would occur on these The only areas where the haul route is directly adjacent to coho salmon critical habitat are roads would restore the road surface (without ruts) that would be (or will be) paved prior to any haul associated with the Chetco Bar Area Salvage Project. The capable of producing less sediment than their rutted counterparts; paved roads are not anticipated to produce any dust that might impact designated coho post-haul water-barring would also correct roadway drainage issues salmon critical habitat. On gravel roads that are close to but not directly adjacent to coho and minimize sedimentation." Post-haul maintenance would not salmon critical habitat, dust abatement activities associated with the project will keep dust reduce sediment delivery to CCH during project implementation. from reaching designated coho salmon critical habitat. Water withdrawals for dust "Minimizing" sediment indicates that some sediment from utilized abatement activities will not occur in coho salmon critical habitat. In addition, the EA haul roads would continue to impact CCH post-project The Chetco Bar Chapter 3 Transportation section has been revised per your comment: "Post-haul Salvage EA fails to disclose that dust from haul roads will increase fine maintenance that would occur on these roads would restore the road surface (without ruts) sediment into CCH despite dust abatement. Dust abatement is not and would correct road drainage issues; post-haul water-barring would also correct shown to be adequate for CCH mitigation. The EA fails to discuss that roadway drainage issues." water removals for dust abatement may reduce summer habitat for salmonids and have adverse effects. The EA fails to identify specific haul route segments that are hydrologically connected to the stream system or require site-specific actions at these locations to prevent road haul sediment from reaching streams (See Photos 1-4).
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2989-36 The EA 3-109 states "There would be no cumulative effects to The action alternatives do not convert mid- and late seral mixed conifer stands to Douglas- hydrology from reforestation." New information reported by Perry fir plantations as the study reported by Jones and Perry 2017 evaluates and then draws and Jones 2017 (attached) finds that replacement of native forests conclusions on potential causes. The Chetco Bar Fire killed the trees in the proposed with planted forests results in significant long-term summer low flow treatment areas and thereby altered the hydrology of the small catchments within affected deficits. The low KS Wild Chetco Bar Salvage EA Comments 18 flow areas. Early seral conditions will occur in most of the high mortality areas across the entire deficits are most apparent in smaller watersheds that have had area of the Chetco Bar fire. The study referenced here (Perry and Jones 2017) does not previous replacement of mature and old growth forests (i.e. compare the effects of fire-killed late seral habitat and the resulting hydrologic differences cumulative effects). Stand age modeling into the long term would between early seral Douglas-fir plantations and early seral tanoak stands, for instance. The likely reveal that Rainbow Creek, Panther Creek, Basin Creek, Quail paper is silent on how Douglas-fir plantations compare to natural early seral regeneration Prairie Creek, Eagle Creek and possibly others can be expected to when tanoak is the primary regnerating species. The paper only compares harvest of late have low flow deficits beginning around 2035 and continuing for 50 seral habitat and converting to early seral Douglas-fir plantations and the resulting effects to years or more. The Forest Service sponsored a one day science hydrology. conference at OSU on low summer flows on April 4, 2018 due to the serious potential adverse impacts from planting Douglas fir plantations on summer low flows. The Chetco Bar EA fails to disclose to the public and decision maker the inevitable adverse impacts to CCH from anticipated plantation establishment.
2989-17 The EA does not contain a systematic evaluation of haul roads and their Please refer to EA, Appendix A for PDCs, which will reduce the likelihood of stream potential for stream diversion at major culverts (See Photos 1, 2, 3). diversions at major culverts. In addition, the Chetco Bar BAER Hydrology and Engineering reports identified (4) large culverts to upsize on FSR 1376, 1909 (2), and 1983 (Chetco Bar Fire BAER Hydrology Report, Callery et. al., 2017 and Chetco Bar Fire Engineering Resource Assessment- Transporatation System, Blankenship III et. al., 2017). These culverts will be replaced during the summer of 2018.
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2989-12 The EA fails to analyze certain sediment impacts from South Coast A special use permit was recently received by South Coast Lumber, and is currently under Lumber reconstructing washed out road 1407-150 in Panther Creek review by the Forest. This is a seperate project and If granted, will be a separate decision. watershed and private log haul with no wet season restrictions. Appropriate project design criteria and mitigation measures would be applied as determined. Washed out road 1407-150 may not be reconstructed. In regards to "no wet season restrictions", private log haul across FS lands is subject to a Forest Service issued Road Use Permits, if the log hauler does not have outstanding rights. Terms and conditions of the permit are dictated by the Forest Service and typically include language to prevent water quality degradation. Road use can be limited to dry season and dry soil moistures only and users are required to suspend operations when indications of rutting or turbid water are observed.
2989-7 The EA fails to disclose that some of the detrimental displacement (i.e. The modeled sediment delivery rates from the BAER reports were based on a 5 year event within unit erosion) would be transported to stream channels and that has a 20 percent likelihood of occurring. In addition, the accuracy of model output is CCH located downslope and downstream from logging units. The EA estimated to be +/50%. Furthermore, model output is in tons per acre on a storm event fails to disclose that many proposed logging units, especially those on basis, so these are not annual estimates. This past winter season no 5 year events were steeper slopes, are hydrologically connected to the stream system. observed to suggest that sediment delivery reached the estimated rates, and field Maximum modeled sediment delivery rate from the BAER report was observations led us to believe the model may have over predicted sediment delivery rates. 98.6 tons per acre (EA 3-77; MacDonald and Ochoa 2017). The EA Additionally, the modelled sedimentation from the BAER Report would most likely be failed to use sediment models from the BAER report (or similar models) expected to occur from areas in close proximity to stream channels, not evenly distributed to estimate sediment delivery to streams from proposed logging units. across the landscape. Part of the design criteria for the Chetco Bar Area Salvage Project is to For example, the Biscuit Fire Recovery Project Final Environmental avoid any additional disturbance in areas directly adjacent to stream channels, therefore no Impact Statement (attached) utilized a sediment model to predict harvest has been authorized within the Riparian Reserve land use allocation. Field sediment impacts to streams based on alternatives with varying observations are detailed in chapter 3. Field observations and past monitoring studies amounts of logging that included full riparian reserve protection (see (McHugh, 2005) were reviewed in order to predict sediment impacts to streams (EA Chapter FEIS III 199-291). 3 Hydrology section). The Project Design Criteria (EA, Appendix A) list specific actions to control any potential sedimentation to streams. Protective riparian reserve buffers (EA Chapter 3 Hydrology section) around all streams and potentially unstable areas serve to retain sediment. Sediment trap structures would be used where needed (LH-6, Appendix A, page A-16).
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2989-16 The EA fails to inform the decision maker that roads damaged by the The EA evaluates potential effects from the proposed action, action alternatives, and no fire will be susceptible to increased failure/increased sediment action that are reasonably certain to occur. None of the road network that is proposed to production due to intensive log haul despite PDFs and BAER repairs. be utilized for timber haul will be in a dilapadated condition when haul occurs and will be This is particularly true because many roads were in "dilapidated" maintained to standards that will ensure life and safety are protected. Catastrophic road condition before the fire. At 3-93 the EA states "Older, dilapidated failure is not reasonably certain to occur due to the activities associated with this project. road networks existing in the watershed exacerbate the occurrence of landslides and sediment delivery." The EA fails to report that road failure is probably the most important threat to CCH.
2989-13 The EA fails to report that this incident of log haul causing elevated The process to authorize private commercial haul under a road use permit is a separate turbidy in the South Fork Chetco and mainstem Chetco was from process from this EA. Additional measures will be implemented under the Danger Tree Forest Service Road 1376 located on private land. The KS Wild Chetco contracts to harden segments of road that are adjacent to CCH. The majority of South Coast Bar Salvage EA Comments 10 EA fails to provide for any restrictions lumber's timber has been extracted from road 1376, 1909, and 1917. Also, see response to for private log haul (e.g. wet season restrictions) on Forest Service comment 2989-12. Roads 1376, 1917, 1909 , 1407 and 1407-150 and fails to disclose past and future sedimentation from wet season log haul by South Coast Lumber.
2989-11 The EA fails to assess the effectiveness of these Project Design A discussion of erosion and sedimentation effects based on the effectiveness of riparian Features as they relate to "minimizing" sediment impacts to CCH. The reserve buffers is detailed in the EA. Refer to Erosion and Sedimentaiton from Salvage EA failed to take a hard look at effectiveness of barriers in preventing Logging. Both alternatives have no harvest riparian areas with a width of 175 feet or greater sedimentation of streams. Forest Service researchers have compiled a that exceeds the buffer width needed to protect streams from sediment delivery form literature review titled: "Effectiveness of Best Management Practices salvage operations (EA Chapter 3 Hydrology section). Additional project design criteria serve that have Application to Forest Roads: A Literature Synthesis" to mitigate impacts (EA, Appendix A, including Log Haul, Soil and Hydrology BMPs). available at https://www.nrs.fs.fed.us/pubs/53428 The
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2989-20 The Forest Service Must Conduct Formal Section 7 Consultation with The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical National Marine Fisheries Service Prior to Issuing a Decision habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the Implementation of Alternative 2 will Likely Adversely Affect (modify) action alternatives, then no cumulative effects can occur from the proposed activities. EA Coho critical habitat through sediment deposition in streams serving Chapter 3 FIsheries and Aquatic Biota section. as critical habitat due to detrimental soil KS Wild Chetco Bar Salvage EA Comments 12 disturbance and sedimentation from log haul, logging and yarding and road and landing construction.
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2989-24 The Hydrology/Fisheries "no effect" determination and "no cumulative Refer to response to comment 2989-7. Cumulative effects in the Soils and Hydrology Report effects" determinations are clearly in error. Maximum modeled has been modified to include Chetco Bar Fire suppression activities. Please refer to the EA, sediment delivery rate from the Chetco Bar BAER report was 98.6 Soils Section, Cumulative Effects from Action Alternatives subsection and Hydrology section, tons per acre (Chetco Bar EA 3-77; MacDonald and Ochoa 2017). The Watershed Cumulative Effects subsection (EA Chapter 3). Biscuit FEIS III 227-285 provides extensive analysis of sediment produced by similar salvage logging. The EA is biased because it lifts passages from the Biscuit FEIS that support the idea of no sediment from salvage logging (FEIS III-230 first paragraph and elsewhere ) while ignoring all analysis in the FEIS that predicts increased sediment from salvage logging. Furthermore the EA fails to cite the Biscuit FEIS from where it copied passages nearly verbatim into the EA. In the Chetco Bar planning effort the Forest Service has failed to conduct the required analysis necessary for unbiased and informed decision making. The EA makes the scientifically unsupportable assertion that logging activities will not increase the modeled sediment delivery rate (i.e. cumulative effects). We have previously provided additional science based analysis indicating probable sediment increases from unit logging and log haul. Please also note that as indicated on page 3-101 of the EA "Soils are particularly susceptible to increased erosion and reduction of productivity after wildland fire." Additionally, as noted on page 3-77 of the EA needle cast and leaf litter (which will be inhibited by logging activities) "appear to have the greatest effect on erosion vs accumulation" at the site level. The EA fails to assess the effectiveness of rehabilitated fire lines with respect to erosion/sedimentation.
2989-22 The proposed action may violate the Endangered Species Act with Please refer to response 2989-20. respect to federally threatened Southern Oregon/Northern California Coasts Coho Salmon. (EA 3-112). The EA fails to report increased sediment impacts to Coho Critical Habitat (CCH) from proposed actions and neglects to conduct cumulative effects analysis at watershed scales relevant to CCH.
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2989-1 The proposed logging of 826 acres of undeveloped forest stands greater An irreversible or irretrievable commitment of resources refers to impacts on or losses to than 1,000 acres in size involves an irretrievable commitment of resources that cannot be recovered or reversed. Examples include permanent conversion of resources that will permanently and significantly alter the character of wetlands and loss of cultural resources, soils, wildlife, agricultural production, or a forest type that many Americans would like to see retained on their socioeconomic conditions. Irreversible is a term that describes the loss of future options. It federal lands. applies primarily to the impacts of use of nonrenewable resources, such as minerals or cultural resources, or to those factors, such as soil productivity, that are renewable only over long periods of time. Irretrievable is a term that applies to the loss of production, harvest, or use of natural resources. For example, if farm land is used for a non-agricultural event, some or all of the agricultural production from an area of farm land is lost irretrievably while the area is temporarily used for another purpose. The production lost is irretrievable, but the action is not irreversible. As stated in 40 CFR § 1502.16 of the Council on Environmental Quality (CEQ) Regulations, agencies must identify, as part of the environmental consequences discussion in an Environmental Impact Statement (EIS), any irreversible or irretrievable commitments of resources which would be involved in the proposed action or reasonable alternative(s), should they be implemented. Discussion of irreversible or irretrievable commitments of resources is not required in an Environmental Assessment (EA).
2989-29 The significant environmental impacts of post-fire logging road Please refer to the response to comment 2990-41. The Siskiyou Land Resource establishment necessitate completion of and EIS since "Temporary Management Plan (SLRMP) soil quality standards require that "The total area of detrimental roads and landings are expected to have an irretrievable reduction in soil conditions should not exceed 15 percent of the total acreage within the activity area, soil productivity since they are bladed (soil is mixed and displaced) including roads and landings." (SLRMP, IV-44). The effects to soils from temporary roads and and compacted." (EA page 3-81). Please note the direction in the landings are analyzed and accounted for in the soils report and are counted towards the 15 Siskiyou National Forest Plan at IV-44 indicating that project planners percent detrimentally disturbed, through a soil disturbance evaluation (EA Chapter 3 Soils must "Ensure land management activities are planned and conducted secton). In addition, project design criteria, best management practices, and mitigation to maintain soil productivity and stability." The existing significant measures have been developed to minimize or eliminate effects to soils to meet the impacts of the NFTS on aquatic forest values is stunning and additional Siskiyou Forest Plan and R6 standards and guidelines for soils (EA, Appendix A). Proposed cumulative impacts to water quality limited streams may violate both actions are designed to maintain ACS objectives and to meet Clean Water Act standards (EA the Aquatic Conservation Strategy and the Clean Water Act. As stated at Appendix A and Project Record, Hydrology Report at Appendix A). on page 3-95 of the EA "A study showed that sedimentation rates from roads within the Pistol River Watershed produced sediment 32 times that of surrounding undisturbed forest lands."
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2989-41 There is scientific uncertainty about the best way to reach a mortality Smith and Cluck has been identified by the local Forest Health Protection entomologist (Bill determination, which should have been discussed in the EA. While Schaupp, Ph.D.) as the best available science for the region including the Chetco Bar fire Smith and Cluck 2011 - the agency's chosen methodology - uses only area salvage. The local entomologist is fluent with the post-fire mortality estimation crown scorch to predict mortality, more recent research indicates that literature, worked directly with Lisa Ganio and Robert Progar during their analysis for crown scorch is a poor predictor of mortality, and should be coupled publication of their research, which was funded in large part by Forest Health Protection, with other indices such as crown volume consumed, the number of and continues to collaborate and share expertise with Daniel Cluck, Sheri Smith and Sharon bole quadrants with dead cambium, and the presence of beetles in Hood. Discussions in Ganio and Progar include that previously published models predicting order to more accurately assess mortality probability. Ganio and Douglas-fir and ponderosa pine tree mortality are most accurate when they contained Progar, Mortality predictions of fire-injured large Douglas-fir and measures of crown volume, cambium damage and the presence of beetles and results ponderosa pine in Oregon and Washington, USA, FOREST ECOLOGY corroborate previous research from other regions where tree crown fire injury and AND MANAGEMENT 390 (2017) 47-67 (collecting and analyzing data cambium injury are consistently useful in the prediction of post-fire tree mortality from the Chetco Bar fire area, among other locations in Region 6). We investigation, which is consistent with the protocols in Smith and Cluck 2011. In addition, encourage the Forest Service to review Ganio and Progar (2017), a copy Ganio and Progar used their dataset to validate the logistic equation from Hood 2008 that is of which has been provided to the Forest Service, and reevaluate the used in Smith and Cluck for Douglas-fir post-fire mortality estimation and it performed very propriety of utilizing Smith and Cluck (2011). well. Validation of predictive models with actual data is a rarely taken important step in determining model accuracy. Smith and Cluck use crown damage as a measurement guideline to identify trees in specific mortality classes, however guidelines from Smith and Cluck are based on established research which is evaluated and discussed in Ganio and Progar 2017 including: Yellow pine (ponderosa and Jeffrey pine), white fir, sugar pine and incense cedar guidelines are based on: Hood, Sharon M.; Smith, Sheri L.; Cluck, Daniel R. 2010. Predicting mortality for five California conifers following wildfire. Forest Ecology and Management. 260: 750-762. Douglas-fir guidelines are based on: Hood, Sharon M. 2008. Delayed Tree Mortality following Fire in Western Conifers . JFSP Final Report 05-2-1-105, US Department of Agriculture, Forest Service, Rocky Mountain Research Station, Missoula, MT. 35 p. Based on this information Ganio and Progar does not provide sufficient differences in the methods selected to warrant changing proposed morality guidelines.
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2989-41 Field estimation using fewer variables than full logistic models is discussed in Smith and continued Cluck in the section "Determining what variables to use when marking trees", as well as in sections of Ganio and Progar and in the recent review article by Wooley et al. (2012 ) and elsewhere. The small increase in predictive accuracy obtained by including the variable cambial injury would be more than offset by the large amount of extra time and effort necessary to acquire such data and was not recommended (see Appendix A in Smith and Cluck for an example) for Chetco Bar salvage tree marking. Measurements of fire effects to tree crowns are the single most effective predictors of post-fire tree mortality regardless of species, region or fire type, or whether they reflect fire behavior or explicit injury to the crown (Wooley et al. 2012). The inclusion of beetle presence is built into Smith and Cluck and described on page 8 in the section "Evidence of significant bark and/or wood boring beetle activity (Any tree meeting this criteria is predicted to die and no further assessment is required)". Woolley, T., D.C. Shaw, L.M. Ganio, and S. Fitzgerald. 2012. A review of logistic regression models used to predict post-fire tree mortality of western North American conifers. International Journal of Wildland Fire 21: 1-35. http://www.publish.csiro.au/nid/114/paper/WF09039.htm
2989-42 We are extremely troubled by the proposal in Table 3 on page 2-2 of The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage the Chetco Bar Salvage EA to target extremely large old-growth pines harvest under the action alternatives. The species being targeted for salvage under the with little crown scorch for logging. Indeed, this causes us to distrust action alternatives include Douglas fir and incense cedar, therefore they have been included the agency's objectives for this project. It is essential for buy-in and in Table 3. No other species would be targeted for salvage removal. However, any tree, public trust that project planners not target living lightly scorched old- regardless of species, that is determined to be a hazard to operations may be removed for growth pines for logging. The remaining living large old-growth pines safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as are disproportionately valuable for wildlife, watershed, and social per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and objectives and should not be logged. marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels. Regarding Pine species: Incidental occurrences of knob cone pine, white pine and possibly ponderosa pine occur within the project footprint but are not species that are targeted for salvage removal under the action alternatives. Regardless of the amount of green needles remaining, all pine species would be retained, unless they pose a safety or operational concern as described above.
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2989-21 We do not dispute the need for riparian reserve protections and log Thank you for your comment. The lower portion of the haul route on road 1376-000 is haul sediment abatement. We do dispute the assertion that the paved and will not generate sediment that might enter the stream network. The 1909-000 proposed mitigation actions will result in no sediment impacts to CCH. road will have haul restrictions that limit haul during wet periods, when sediment might be mobilized to reach stream networks.
2989-47 We urge the Forest Service to avoid the high risk of invasive plant Alternative 3 and the no action alternative address your concerns. spread associated with extensive post-fire logging ground disturbance and road establishment.
2989-49 We would like to be notified weekly via email when you have finished Thank you for your comment. Your request to be notified when field marking to protect field marking specific units to protect riparian reserves. We want to riparian reserves is completed has been forwarded on to the appropriate Forest Service verify the 175 ft. no cut buffers. Attached to these EA comments is a personnel. The Letter you reference describes situations that are specific to the Roadside May 7, 2018 correspondence to the Rogue River - Siskiyou National Danger Tree Abatement project Categorical Exclusion . All timber sales under the Roadside Forest identifying numerous inadequate (less than 175 ft.) riparian Danger Tree Abatement Categorical Exclusion will contain a 100 foot fall and leave, no reserves marked for retention in the Packers RS Salvage logging yarding buffer, which falls under a separate NEPA decision. The Chetco Bar Fire (CBF) Area project associated with the Chetco Bar fire. What is the source of Salvage Project , will exclude all riparian reserves (175 feet (non-fish bearing these errors? How does the Forest Service propose to avoid repeating perennial/intermittent and ephemeral streams), and 350 feet (fish bearing, perennial) from these significant errors in the forthcoming Chetco Bar Salvage logging harvest activity. project? We are extremely concerned that the agency is not in fact implementing full riparian reserves in project layout and implementation, thus undercutting the analysis and assumptions contained in its NEPA documents.
DellaSala Dominick
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2990-2 (1) Replace RAVG estimates with MTBS fire severity estimates that are The Rapid Assessment of Vegetation Condition after Wildfire (RAVG) program produces comparable to other regional studies (as it stands, you cannot data describing post-fire vegetation conditions on National Forest System (NFS) lands which compare RAVG estimates for the project with studies of severity is used to assess and prioritize post-fire vegetation management. RAVG uses the Relative based on MTBS - this is apples to oranges); Differenced Normalized Burn Ratio (RdNBR), which is derived directly from the dNBR, but is considered more sensitive to vegetation mortality than the dNBR. RAVG is considered an initial assessment, which describes initial vegetation mortality (typically 30 days post-fire containment), but does not capture delayed vegetation mortality. Monitoring Trends in Burn Severity (MTBS) is a multi-year project designed to map consistently the burn severity and perimeters of fires across all lands of the United States between 1984 and present. The data generated by MTBS will be used to identify national trends in burn severity, providing information necessary to monitor the effectiveness and effects of the National Fire Plan and Healthy Forests Restoration Act. MTBS maps burn severity using the dNBR; however, the RdNBR is used to adjust burn severity thresholds to better describe post-fire effects to vegetation. MTBS is considered an extended assessment because most fires are mapped using images acquired one-year post-fire (at peak of greenness). This provides the ability to capture delayed vegetation mortality during the mapping process. The results of RAVG were ground verified in all units. MTBS data is not yet available and would not meet the purpose and need of the project because by the time it is available, the burnt timber would have lost most of its value. The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4).
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2990-3 (2) Retain more of the large (>20 in dbh) legacy trees by implementing This is not a hazard or danger tree project. The purpose of this project is to capture timber treatments that do not rely solely on logging (see Pacific Southwest value in the matrix land allocations by harvesting dead, dying and/or damaged trees Hazard Tree Marking Guidelines, below) especially in spotted owl resulting from the 2017 Chetco Bar fire. The EA, Table 3 at 2-2 has been edited to better habitat and Riparian Reserves; reflect the intent of proposed salvage harvest under the action alternatives. The species being targeted for salvage under the action alternatives include Douglas fir and incense cedar, therefore they have been included in Table 3. No other species would be targeted for salvage removal. However, any tree, regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels. Additionally, Alternative 3 addresses your concerns about retaining more large >20 inch diameter at breast height trees.
2990-4 (3) Conduct botanical surveys and provide the public with results of For botanical species: A pre-field review was completed to determine areas of high spotted owl surveys in relation to areas slated for logging; probability habitat within the project planning area to survey specific sites for sensitive species. Field checks of potential habitat for sensitive species were completed during Burned Area Emergency Response (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3, Botanical Resources section and EA, Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018). For spotted owl: Protocol surveys for NSO are underway this season (2018). (EA Chapter 3, Wildlife Section)
2990-5 (4) Exclude steep slopes (>30%), fragile soils (ultramafic, granitics), and The Action alternatives do not propose ground based logging systems on slopes over 30%, hydrological areas containing Darlingtonia fens (no helicopter nor do they propose salvage harvest on fragile soils, ultramafic soils, or areas with logging); Darlingtonia fens. Additionally, the No Action alternative addresses your concerns.
2990-6 (5) Drop undeveloped areas (826 acres,1.5 miles of temporary roads) Alternative 3 addresses your concerns. and unmanaged (2,222 acres) stands from project logging activities, as logging will forever change their character; and
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2990-7 (6) Reduce log hauling distances (e.g., up to ~104 miles) that otherwise Proposed road maintenance would reduce road-derived sediment generated during pose a significant impact to endangered coho salmon by further increased road use over the life of the project. Road-derived sediment would be directed impairing water quality limited streams in the project area (mitigation onto the forest floor through cross drains where it would be filtered before reaching stream is inadequate). channels. No-harvest riparian buffers, intermittent stream status, and proximity to fish bearing streams would be sufficient to prevent any sediment delivery from temporary spur road construction and road maintenance activities to downstream occupied habitat. Road maintenance associated with the project will be required to follow all criteria in the National Best Management Practices for Water Quality Management on National Forest System Lands (USDA, 2012) to mitigate any potential for road related sediment from entering any watercourse or ditch connected to the stream network. (EA, Fisheries and Aquatic Biota section)
2990-8 (7) Redo the cumulative effects section to take into account the The Danger Tree Removal project was described in the EA, Chapter 3 under Past, Present substantial roadside logging and options for maintaining large trees as and Reasonably Foreseeable Actions section. Additionally the cumulative effects were requested in our comments below. described as applicable throughout Chapter 3. The temporal and spatial scale of analysis is variable depending on the resource concern being evaluated, particularly when considering the effects of past, present, and reasonably foreseeable actions. Additionally, for effects to be cumulative they must overlap in time and space.
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2990-24 Additionally, because spotted owls forage in high severity burn patches Effects to NSO prey are disclosed in the EA Chapter 3 Wildlife section. No activities are where owl prey species 13 are abundant (Bond 2016), project proposed within NSO core areas. Effects that may occur in the home ranges beyond the activities will impact owl foraging sites and prey species, in both PFF1 core areas are short-term shrub reduction from cutting, or crushing during operations, but and PFF2 (low and high RHS). We request that you disclose: §? Will they would not be completey removed from the units. Post-fire salvage studies have found shrubs be reduced by logging within owl cores, and if so how will this that effects of salvage logging were less intense to small mammal populations than the affect owl prey species and densities? §? Will post-fire logging effects of the fire. Nonetheless, salvage disturbance will likely reduce habitat for prey exacerbate interspecific competition with Barred Owls, especially species in the short-term, PDC to retain snags and down wood in salvage units would given that spotted owls are more vulnerable to territory extinction provide structure that would also benefit prey species in the long-term. The untreated events in low-quality spotted owl habitat (Dugger et al. 2016)? portion of the landscape is expected to provide a diverse source of prey speices. The project biological opinion (BO) provides consideration for the effects of the project to interspecific competition with barred owls. Barred owls are known to occur in the project area and likely influence habitat use by spotted owls. The project would maintain all existing NRF and dispersal habitat in the project area and minimizes impacts to post-fire foraging habitat most likely to be used by spotted owls, however the BO states that there is "some uncertainty how, or to what degree the treatments may exacerbate the effects on spotted owls in the action area." (BO p. 58) Furthermore, the BO concludes that with consideration of the combined impacts of the proposed action, the fire, impacts to prey and impacts associated with barred owls, that the level of incidental take is estimated to represent 0.1 percent of the NSO population at the provincial level and not likely to result in jeaopardy to the species. (BO p 72)
2990-11 Additionally, Miller and Safford (2012, cited in the EA but not in the The correct article as identified in the EA. Miller, Jay D., et al. "Trends and causes of severity, literature section so I assume you mean this one - "Trends in wildfire size, and number of fires in northwestern California, USA." Ecological Applications 22.1 severity: 1984 to 2010 in the Sierra Nevada, Modoc Plateau, and (2012): 184-203. southern Cascades, California USA") cannot be used to claim the project area is outside historic range of variability since that study was for a different region.
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2990-37 Available scientific evidence is overwhelmingly clear that post-fire Effects to the soil resource from proposed salvage activities in the action alternatives are logging results in numerous significant and adverse impacts on soil discussed in the Soils Resource Report (Project File) and in the EA Chapter 3 Soils section, resources. In order to comply with its legal and statutory and recognize that proposed activities can have negative effects to the soil resource. Project requirements, the Forest Service needs to develop and consider specific design criteria, best management practices, and mitigation measures have been alternative ways to avoid these impacts. developed and incorporated into the action alternatives in order to minimize or eliminate these negative effects to the soil resource to a level that will meet compliance and consistency with legal requirements and Forest Plan Direction for the soil resource (EA, Appendix A). In addition, the No Action Alternative addresses your concerns to avoid these impacts.
2990-38 Based on all of these well recognized and significant impacts, it has Project design criteria, best management practices, and mitigation measures have been been strongly recommended by a large number of forest and natural specificially designed and incorporated into the two action alternatives to minimize, reduce, resource scientists that post-fire logging be prohibited in sensitive or eliminate potential negative effects from proposed activities to the soil resource and areas, including areas such as the Chetco Bar project area, or in any site sensitive areas (EA Appendix A). The purpose of the Chetco Bar Fire Salvage project is to where accelerated erosion is possible (Beschta et al. 2004, 1995). capture timber value in the matrix land allocations within the Chetco Bar Fire (EA at 1-4). More specifically, Karr et al. (2004) and Beschta et al. (1995) advanced Approximately 85 percent of the NFS lands that burned within the Chetco Bar Fire occurred a number of pointed recommendations regarding post-fire forest within land allocations other than matrix which are not a part of the two action alternatives management, including the following: §? Protect soils from further (EA at 1-1) and therefore would experience levels of natural recovery and avoid active damage, especially in ecologically sensitive areas §? No tractors and management soil impacts. In addition, the No Action Alternative addresses your concerns to skidders in burned areas because of the exacerbated soil compaction avoid impacts to soils. and erosion problems they create; §? No road building (including "temporary" roads) or landings in the burned landscape; §? Retain old and large trees; §? Limit reseeding and replanting, and; §? General recommendation to allow natural recovery to occur on its own or intervene only in ways that promote natural recovery.
2990-16 Based on Brown (2008), we request that you map the location of seed A preliminary map has been created for Chetco Bar fire with 200 and 400 meter buffers trees/sources within high severity burn patches to determine if there from live tree edges for the Chetco Bar fire. This map is included in the Project Record. GIS are sufficient seed sources nearby before you conclude a lack of mapped areas greater than 400 meters centered around large high severity burn patches conifer regeneration in these patches. surrounding Panther, Mineral and Basin creeks, much of these areas within the Matrix land allocation. The Forest is planning to develop a post-fire reforestation strategy that will address tree planting needs in the context of ecological, climate change and land allocation management objectives.
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2990-27 Based on Recovery Action 10 (below), the EA does not contribute to Recovery Action 10 states: "Conserve spotted owl sites and high value spotted owl habitat restoring habitat elements that take a long time to develop (e.g., large to provide additional demographic support to the spotted owl population". The proposed live and dead trees). While we appreciate dropping 260 acres of PFF action avoids any salvage harvest in NSO nest patches and core areas. The project will habitat, this seems arbitrary and instead we request that you drop all maintain all exstining NRF and dispersal habitat in the action area including high value NRF. units within PFF habitat in order to contribute to Recovery Action 10, None of the affected home ranges currently meet the "threshold values" of at least 40% 12, 30, and 32. suitable NRF (USDI Fish and Wildlife Service 2011, pp. III-42 to III-43, EA Table 13, Chapter 3 Wildlife section). The project minimized effects to 260 acres of PFF habitat with the highest likelihood to be used by NSO for foraging. PFF habitat does not meet the description of high value habitat detailed by the Forest Level 1 consultation team (canopy cover =60% and =2 canopy layers) for RA-10 or RA-32. Recovery Action 30 states: "Manage to reduce negative effects of barred owls on spotted owls so that Recovery Criterion 1 can be met." The project biological opinion (BO) provides consideration for the effects of the project to interspecific competition with barred owls. Barred owls are known to occur in the project area and likely influence habitat use by spotted owls. The project would maintain all existing NRF and dispersal habitat in the project area and minimizes impacts to post-fire foraging habitat most likely to be used by spotted owls, however the BO states that there is "some uncertainty how, or to what degree the treatments may exacerbate the effects on spotted owls in the action area." (BO p. 58) Furthermore, the BO concludes that with consideration of the combined impacts of the proposed action, the fire, impacts to prey and impacts associated with barred owls, that the level of incidental take is estimated to represent 0.1 percent of the NSO population at the provincial level and not likely to result in jeaopardy to the species. (BO p 72)
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2990-17 Based on the above regionally specific literature, you cannot claim that Negative impacts to natural conifer regeneration from salvage logging is not likely to be a "the longer reforestation is delayed after the fire, the less chance the long-term problem due to the prolonged period of natural conifer recruitment post-fire that trees, either planted or seeded naturally, have of outcompeting the occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon shrub component." This argument is based old-school forestry that has State University researcher found that conifers continue regenerating 10 to 15 years after a very little basis in contemporary ecological sciences. While fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the hardwoods and shrubs undoubtedly compete to some degree with chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' conifer seedlings, accumulating evidence shows that conifers also research "suggests that early salvage logging may not make much difference to benefit - both directly or indirectly - from their association with regeneration in the long run because they found that successful and abundant conifer hardwoods and shrubs in recently burned areas. Because sprouting recruitment continues for years, even after severe fire." The growing space for conifers that hardwood and shrub species recover quickly after fire, they help seed in naturally or are artificially planted post-fire will receive meaningful competition for minimize loss of soil carbon and nutrients that facilitate site resources from tanoak and sprouting vegetation. Tanoak sprouts grow rapidly in good reestablishment of later-arriving plants, maintain critical elements of light and can average two feet per year the first 15 to 20 years often dominating vegetation soil structure, and provide critical habitats for soil organisms that cover following fire (Roy 1957). Conifer trees that become established will grow slowly until depend on plants for their continued survival (Amaranthus & Perry tree height overtops surrounding vegetation or succumbs to competition. Local research on 1989, Borchers & Perry 1990, Perry et al. 1989). the Siskiyou National Forest of three naturally regenerated stands following a large fire in 1881 noted most of the Douglas-fir regeneration established between 1890 and 1920 indicating a delayed and prolonged period of conifer establishment following this wildfire (Little et al. 1995). The study sites were located on Gold Beach Ranger District (Fairview, Panther Lake, Pistol River) and within proximity to the Chetco Bar fire. This prolonged natural regeneration concept is supported by (Hibbs, 2009) as one of the key findings noted abundant conifers regenerating 10 to 15 years post-fire. The paper also noted scarce natural regeneration greater than 400 meters from living trees and was most limited on drier, lower elevation, south facing slopes.
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2990-17 Also another regional study of conifer regeneration 9-19 years after fires in southern continued Oregon and northern California noted conifer regeneration to be surprisingly protracted and variable (Shatford et al., 2007). Another recent regional paper Disequilibrium of fire-prone forests sets the stage for a rapid decline in conifer dominance during the 21st century (Diaz et al., 2018) about potential impacts from climate change noted 'current forest extent may not reflect current climatic patterns' and using a landscape simulation model estimated about one third of the Klamath forest landscape (northern California and southwest Oregon) could transition from conifer dominated forest to shrub/hardwood chaparral, triggered by increased fire activity coupled with lower post-fire conifer establishment; 'the area of high severity fire in large patches increased under climate change scenarios hampering a rapid recolonization of new tree recruits (further distances from seed sources)'. Post-fire conifer establishment probability was reduced under climate change due to increased summer drought. Current Forest direction for the Chetco Bar fire is to delay artificial regeneration and survey for natural regeneration post-salvage to determine if stocking levels are sufficient to meet the NFMA five-year regeneration requirement to stocking levels consistent with management objectives. The Forest is planning to develop a post-fire reforestation strategy that will address tree planting density in the context of susceptibility to future high severity fires, climate change and land allocation management objectives. (EA Chapter 3 Vegetation section)
2990-34 Even for SS species that are not strongly fire-adapted, it cannot be A pre-field review was completed to determine areas of high probability habitat within the assumed -- as the EA erroneously does -- that the Chetco Bar Fire has project planning area to survey specific sites for sensitive species. Field checks of potential eliminated all suitable habitat in the project area. habitat for sensitive species were completed during Burned Area Emergency Response (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3 Botanical Resources section, and EA, Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018).
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2990-40 For example, Forest Service must disclose, for the planning area, the We would like to note that the USDA Forest Service document being referenced in your percentage of existing detrimental soil disturbance from past timber letter in relation to this comment is an over 15-year-old draft document. The Forest is harvest, fire suppression activities, livestock grazing, off-road vehicle required to meet our Siskiyou National Forest Land and Resource Plan for soil productivity. use, firewood cutting, and other human disturbances. It cannot only See also RTC 2990-41. The soils Resource Report discloses the percentages of existing provide percentages of "Severely Burned" conditions in the cutting detrimental soil disturbance from past land mangement activities as well as the units following the fire. The Forest Service then must display, for the methodology used in calculating those areas (page 12-16; EA Chapter 3 Soils section). In planning area, the anticipated percentage of total detrimental soil addition, refer to the Soils section, Soil and Site Productivity subsection (Table 20) for the disturbance that would exist in these same cutting units after salvage total anticpated percentage of detrimental soil disturbance. logging activities.
2990-44 In addition, an undisclosed (but likely significant) amount of existing The Soils Resource Report discloses the effects of road maintenance (page 29, 30-32, EA system roads will receive new maintenance or upgrading -- which may Chapter 3 Soils section). In addition, the effects of temporary roads, including expected long include resurfacing, blading/reshaping, roadside tree removal, term impacts, are disclosed in the soils report and EA (page 31-34, EA Chapter 3 Ea Soils brushing, culvert and ditch cleaning -- "to make them suitable for section). Futhermore, sources indicate development of mitigation measures are effective in treatment access". While acknowledging that some (undisclosed) minimizing effects to the soil resource from project activities (Froehlich and mcNabb 1983; degree of erosion and other soil impacts will likely result from these Luce, 1997; USDA Forest Service, 2018)--see EA, Appendix A. actions, the EA essentially dismisses these impacts by claiming that new roads would be temporary, and "following use, would be returned to the highest degree of productivity reasonably achievable". These statements do not constitute sufficient analysis of this issue and fail to consider available scientific evidence about the numerous insidious and long-term impacts of roads on soils and other important resource values.
2990-25 In addition, we request that you analyze project-related impacts to Project-related impacts to legacy biological features were minimized with PDC that retain large (>20 in dbh) trees, live or dead and other biological legacies these features described in the EA Chapter 3, and Appendix A, A-1 to A-2. Furthermore, the based on their importance to spotted owls, complex early seral extent of impacts to these features are described in the EA in response to this and other forests (Swanson et al. 2011, DellaSala et al. 2014), and late- related comments. See also responses to comments 2989-32 and 2986-20. successional development (Donato et al. 2012).
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2990-26 In general, post-fire logging is incompatible with Recovery Action 12, Salvage harvest is proposed in the matrix land allocaiton. Proposed salvage would be and new information (e.g., Hanson et al. 2018) that adds to a growing additive to cumulative effects resulting in removal of approximately 4 percent of NSO PFF list of post-fire logging impacts to owls and ecosystems. Thus, the habitat in the action area. Approximatley 65 percent of the PFF removed by the project is proposed project, especially when added to nearby post-fire logging the least likely to be used by NSO due to distance from existing NRF and topographic (e.g., Westside salvage and private lands) will cumulatively degrade position compared to that of most known NSO core use areas. Project PDC would retain owl habitat. large snags and downed wood to meet Forest Plan requirements which also meet the intent of Recovery Action 12 considering the managment focus of the matrix land allocation. See also response to comment 2986-29.
2990-18 Large Legacy Tree Removal Is Not Based on Best Available Science Table 3 shows the Smith and Cluck guidelines for marking based on 0.6 probability for Table 3 of the EA presents diameter distributions and scorch standards mortality. The tree sizes and species all have different mortality thresholds based on the used to log legacy trees in the project area. There are several findings presented in Smith and Cluck. This has been identified as best available science for problems with this table. First, there are inconsistencies among this region by the local expert entomologist. The table shows the diameter of Douglas fir species in terms of the relationship between tree size to be removed between 10" - 40". If there are any green needles, regardless of % scorch, on a Douglas-fir based and scorching amounts. greater than 40", it will be retained. If any large trees or snags are deemed a danger tree, then it can be felled. Legacy trees are not targeted for salvage. See the following excerpts from the project design criteria: Protect live legacies - Maintain a 70-foot (1/2 site potential tree) un-treated buffer around any live legacy trees with potential structure. No live legacy trees would be removed for any reason including roads, landings or yarding corridors. This is for Marbled Murrelet habitat. Existing snags and down wood- Leave aggregates and individuals of large legacy snags (See PFF decision tree and affected units above). Avoid and protect existing large down wood ≥10 inches dbh to the greatest extent possible. Use treatment skips to avoid large dead wood (>20 inches dbh) or areas of accumulated dead wood. This is for Post Fire Foraging(PFF) to help with Northern Spotted Owl habitat recovery.
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2990-12 Moreover, the EA does not include any explicit protocol to account Smith and Cluck 2011 specifically addresses protocols for pine flushing. Because pines are for pine flushing of conifers with high amounts of canopy scorch. very rare in this area and would not be targeted for falling or removal in the area salvage, Douglasfir also is capable of epicormic branching post disturbance. Table 3 has been updated in the final EA to be consistent with the actual proposal. Table 8 Thus, at a minimum, Table 8 estimates of vegetation mortality in the describes basal area loss, or mortality of stands within the fire perimeter as determined by EA may be grossly inaccurate especially for the mixed and high RAVG [1] analysis. There is no differentiating between species. Field reconnaissance mortality classes. observations determined in this case the RAVG model under predicted the amount of basal area loss. Regardless of the predictions, the Forest is not targeting pine removal with this proposals. The Pine species seen within the high severity killed stands are primarily knob cone pine. They are a fire adapted species and are not targeted for harvest. Incidental occurrences of white pines are not targeted for harvest, regardless of the amount of green needles remaining. Additionally, the needle less Douglas-fir have not shown any signs of regrowth. Douglas fir and incense cedar trees having green needles remaining will be evaluated for retention as per the Smith and Cluck (2011) guidelines. Trees passing the Smith and Cluck evaluation will be retained. If during the life of the contract, the tree subsequently dies, the snag can then be removed. The forest has designed this project to provide green Douglas-fir for seed generation. [1] Rapid Assessment of Vegetation Condition after Wildfire (RAVG), uses remote sensing, and Landsat data to assess the loss of basal area from wildfire. For detailed information on RAVG analysis, refer to the RAVG program's website: http://www.fs.fed.us/postfirevegcondition.
2990-23 NORTHERN SPOTTED OWLS The NWFP "salvage" guidelines state that, The salvage guidelines on p. C-13 of the NWFP apply to the Late Successional Reserve land "the scale of salvage and other treatments should not generally result allocation. Proposed salvage units are all within Matrix land allocations. The project would in degeneration of currently suitable owl habitat or other late- not degrade existing NRF or dispersal habitat, and minimizes removal of post-fire foraging successional conditions" (see NWFP salvage guideline C-13). Thus, by (PFF) habitat where it is most likely to be used by NSO. No project activities are propsed in removing numerous large legacy trees on 4,091 acres of the matrix, NSO nest sites or core areas. Snag retention would prioritize leaving legacy snags in the EA project activities will degrade owl habitat, including possibly early seral PFF habitats which would provide structure for future suitable spotted owl destroying occupied and unoccupied (historical) nest sites and owl core habitat. (EA Chapter 3 Wildlife section and EA Appendix A, A-1 to A-2) areas.
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2990-28 Owl information is dated, not based on best available science, and NRF habitat is also considered dispersal habitat and is understood to be of higher value for retentions in NRF are arbitrary The reference to juvenile owl dispersal than stands with lower canopy cover (40-60%) (EA, Chapter 3 Wildlife section). dispersal habitat as being the 50:11:40 rule is dated. Sovern et al. The study cited by Sovern et al. (2015) was conducted on the east slope of the Cascades in (2015) documented juvenile owls using dispersal habitat equivalent to Washington State. The forest type of southwest Oregon is very diverse with characteristics NRF habitat. Thus, we request you re-evaluate impacts to juvenile of both moist and dry forests. The 2012 Designation of Revised Critical Habitat for the owls using the latest published study (Sovern et al. 2015) and not the Northern Spotted Owl. Final Rule. p 71904 states that in the Klamath and Northern 50:11:40 rule. Additionally, the retention standards used in the EA California Interior Coast Ranges which includes the Klamath West (KLW) critical habitat unit: that are based on 500-foot distance from existing NRF is arbitrary and "Compared to other zones, additional foraging habitat showed greater divergence from not based on any published studies or data. nesting habitat, with much lower canopy cover and tree size. Low to intermediate slope positions were strongly favored." Regarding the retention design criteria based on distance from NRF, the study by Comfort et. al. 2016 which evaluated the differentiation of edges selected by northern spotted owls after the Timbered Rock fire in southern Oregon, found that at broad spatial extents, NSO diffuse edges had a positive effect on selection of the habitat by foraging owls where hard edges had a negative relationship with owl use. This study evaluated the type of edge by the degree of change in burn severity across a 90 meter distance ( 30m mapping resolution). Hard edges are where high severity was adjacent to low severity and diffuse edges are where there was moderate severity adjacent to low severity. In this EA, we used 500 (approx 150m) to capture the diffuse edge between unburned NRF with high RHS and any burned NRF (PFF). We believe this represents the PFF mostly likely to be selected by owls based on this study and others that have found California spotted owls in the Sierra Nevada to use burned habitat for foraging, particularly in close proximity to unburned habitat (Eyes et al. 2017, Clark 2007, Bond et al. 2009, Bond et al. 2016).
2990-31 Regarding life cycle analysis, the EA provides a very limited and biased Hennigar et al 2008 and Perez-Garcia et al 2005 were added to the references cited section assessment of wood stores and compares stores to concrete (we of the EA. The EA stated "Life cycle analyses of wood, from forest to final product, show could not find the Hennigar et al. 2010 or the Perez- Garcia et al. 2005 that carbon can be stored in wood products for hundreds of years (Hennigar et al. 2008). in the literature cited). A more recent regional analysis by carbon Additionally, the use of wood products for construction rather than fossil fuel intensive experts (Law et al. 2018) questions long-term wood stores in buildings concrete and steel has positive carbon implications (Perez-Garcia et al. 2005). " We did not as being grossly overstated. We request that you use these estimates use any estimates. Also we could not find Law et al 2018. as they are regionally specific and conduct a life cycle analysis of emissions rather than dismiss them as negligible because you are using the wrong analysis scale.
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2990-1 Roadside hazard tree removal is not reported as a cumulative impact The Roadside Danger Tree Abatement project was described in the EA, Chapter 3 at 3-4. even though over 100 miles in the project area will be impacted (a Additionally, where applicable the cumulative effects of the Roadside Danger Tree separate Categorical Exclusion is not sufficient for dismissing Abatement project were described by resource. The temporal and spatial scale of analysis is cumulative impacts). variable depending on the resource concern being evaluated, particularly when considering the effects of past, present, and reasonably foreseeable actions. Effects must overlap in time and space to be considered cumulative.
2990-19 Second, the Forest Service does not indicate how scorch levels were Smith and Cluck 2011 are based on extensive post fire monitoring published in several other assessed but instead vaguely refers to Marking guidelines for fire- peer reviewed literature documents. Additionally, members of the field crew are Region 6 injured trees in California. The EA does not disclose whether PM rates (R6) qualified to identify Danger Trees. The guidelines we use for R6 is "Field Guide for the were based on multi-factor hazard rating scores or a single marking Danger-Tree Identification and response along Forest Roads and Work Sites in Oregon and factor. Washington., USDA, 2016" Contributors were a group of experts from USFS, Oregon Department of Forestry, Washington DNR and Association of Oregon Loggers. The guide provides information on pages 44 and 45 regarding large areas of recently killed trees. There is reference to guidelines that have been published to "determine the survival probability of fire-injured, living conifers in northeastern Oregon and elsewhere with probable applicability to other areas in Oregon and Washington." These references are: Scott, D. W., C. L. Schmitt, and L. H. Spiegel. 2002. Factors affecting survival of fire injured trees: a rating system for determining relative probability of survival of conifers in the Blue and Wallowa Mountains. USDA For. Serv., Health Protection, BMPMSC-03-01, La Grande, OR. 86p. Smith, S.L. and D. R. Cluck. 2011. Marking guidelines for fire-injured trees in California. Report # RO- 11-01, USDA For. Serv., Forest Health Protection, Pacific Southwest Region, Susanville, CA. 15p. Smith and Cluck 2011 has been the guideline recommended by the local entomological specialist for this area as the best available science available at this time for the area of the fire. The salvage proposal would use the guidelines to determine if any living trees within a stand of fire killed snags would be retained as a legacy feature, or removed to salvage the timber resource. Field estimation using fewer variables than full logistic models is discussed in Smith and Cluck in the section "Determining what variables to use when marking trees", as well as in sections of Ganio and Progar and in the recent review article by Wooley et al. (2012 ) and elsewhere.
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2990-19 The small increase in predictive accuracy obtained by including the variable cambial injury continued would be more than offset by the extremely large amount of extra time and effort necessary to acquire such data and was not recommended (see Appendix A in Smith and Cluck for an example) for Chetco Bar salvage tree marking. Measurements of fire effects to tree crowns are the single most effective predictors of post-fire tree mortality regardless of species, region or fire type, or whether they reflect fire behavior or explicit injury to the crown (Wooley et al. 2012). The inclusion of beetle presence is built into Smith and Cluck and described on page 8 in the section "Evidence of significant bark and/or wood boring beetle activity (Any tree meeting this criteria is predicted to die and no further assessment is required)". Woolley, T., D.C. Shaw, L.M. Ganio, and S. Fitzgerald. 2012. A review of logistic regression models used to predict post-fire tree mortality of western North American conifers. International Journal of Wildland Fire 21: 1-35. http://www.publish.csiro.au/nid/114/paper/WF09039.htm
2990-39 The Chetco Bar EA fails to adequately analyze the direct, indirect and The effects to soils are described in response to the purpose of the project and based on cumulative impacts of proposed actions on soils and soil productivity project design criteria. The purpose of the project is not soil restoration, but to capture in the project area. timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. Refer to the Soils Section of the EA in Chapter 3 for direct, indirect, and cumulative impacts to soils, including Appendix A for soil PDCs.
2990-43 The Chetco Bar EA fails to adequately evaluate the adverse impacts to Please refer to EA Chapter 3 for discussion on temporary roads. Approximately 12.2 miles of soils and site productivity associated with construction of temporary temporary road would be constructed on existing legacy templates for Alternative 2 and 9.4 roads and landings. miles for Alternative 3. There would be no additional detrimental disturbance associated with the use of these templates as soils have been compacted and displaced from past use and this is accounted for in the existing condition for soils. Approximately, 1.3 miles of new temporary roads would be constructed, which would result in an estimated 4 acres being detrimentally disturbed through compaction and displacement. Alternative 3 does not propose new temporary roads. Table 22 estimates the potential disturbance from all logging systems (i.e. ground based harvest, skyline harvest, and aerial harvest systems) proposed, which includes disturbances from landings. Project design criteria requires landings and all temporary roads (whether existing template or new) to be rehabilitated to promote the restoration of soil productivity (EA Appendix A at A-12,13).
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2990-42 The Chetco Bar EA's reliance on generic Best Management Practices Project design criteria, best management practices, and mitigation measures for the soil (BMPs) is not scientifically or legally sufficient to demonstrate that resource have been developed at the project scale for the Chetco Bar Fire Salvage project significant adverse impacts to soil resources will be avoided. and are based on local conditions and Siskiyou National Forest Plan direction (Soils Resource Report at pages 1-2, 24-26, 35 in the project file). In addition, the latest findings from the National Best Management Practices (BMPs) Monitoring Summary Report for the Pacific Northwest Region, USDA Forest Service (USDA, 2018) have been added into the Soils Report. The Soils Report (page 24) shows that the implementation and effectiveness of Mechanical Vegetation Management Activity BMPs and design features has been greater than or equal to 80% for the 2015 to 2016 National BMPs Monitoring Summary Report (USDA, 2018). Please refer to the Soils Report, page 24 in the Project Record to read full discussion.
2990-46 The EA also fails to adequately evaluate impacts associated with the See the response to comment 2989-46 and 2990-43. Also, please refer to project design construction of numerous landings throughout the Chetco Bar project criteria S-12 (EA at Appendix A), which states: "No new landings would be allowed within area as part of proposed logging. Even helicopter logging often Riparian Reserve. Avoid locating landings near any type of likely flow or sediment transport creates significant soil damage through extra-large landings needed for conduit during storms, such as ephemeral channels and swales, where practicable." large volumes of logs (Megahan 1987). How many new landings does Therefore, new landings will not be located within riparian reserves. Existing landings, as the Forest Service expect to be construct and of what size and type? described in H-6 (EA, Appendix A), could be reused within 100 feet of streams if needed to How many acres of soil will be adversely impacted, and 36 how will access treatment units, however approval by the soils scientist, hydrologist and/or fisheries these cleared and compacted areas be distributed across the project biologist would need to be acquired. Existing landings would then be rehabilitated to area in relation to streams and other sensitive features? These improve infiltration capacity over pre-treatment conditions (subsoiled to break up impacts have not been estimated or disclosed in the EA, so the agency compaction, etc.). cannot say with any factual basis whether forest plan standards will be met. All proposed soil impacts must be estimated and fully presented so that the public can comment and an adequate cumulative effects analysis can be prepared.
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2990-15 The EA does not include appropriate regional studies of abundant post- The EA does include a local study of three naturally regenerated stands following a large fire fire natural conifer establishment even in large high severity patches in 1881 on the Gold Beach Ranger District. These stands are in proximity to the Chetco Bar nor does it specify when natural conifer seedling sampling will occur fire. Though this paper was not designed to study natural conifer regeneration following fire, the paper did note that most of the Douglas-fir regeneration established between 1890 and 1920 indicating a delayed and prolonged period of conifer establishment following the 1881 wildfire (Little et al. 1995). Additional references were added to the Final EA. This prolonged natural regeneration phase is supported by key findings from another paper about natural regeneration following fire on the Klamath-Siskiyou from an Oregon State University researcher who found abundant conifers regenerating 10 to 15 years after a fire. (Hibbs, 2009). The paper also noted scarce natural regeneration greater than 400 meters from living trees and was most limited on drier, lower elevation, south facing slopes. Another regional study of conifer regeneration 9-19 years after fires in southern Oregon and northern California found conifer regeneration to be surprisingly protracted and variable ' (Shatford et al., 2007). This paper concluded 'Forest managers who use natural regeneration will need to develop planning and decision tools that can accommodate spatial variability and include thresholds for regeneration success with a much longer regeneration phase than commonly accepted in the region'. Another recent regional paper Disequilibrium of fire- prone forests sets the stage for a rapid decline in conifer dominance during the 21 st century (Diaz et al., 2018) about potential impacts from climate change noted 'current forest extent may not reflect current climatic patterns' and using a landscape simulation model estimated about one third of the Klamath forest landscape (northern California and southwest Oregon) could transition from conifer dominated forest to shrub/hardwood chaparral, triggered by increased fire activity coupled with lower post-fire conifer establishment; 'the area of high severity fire in large patches increased under climate change scenarios hampering a rapid recolonization of new tree recruits (further distances from seed sources)'.
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2990-15 Post-fire conifer establishment probability was reduced under climate change due to continued increased summer drought. Current Forest direction for the Chetco Bar fire is to delay artificial regeneration and survey for natural regeneration post-treatment to determine if stocking levels are sufficient to meet the NFMA requirement: '(E) insure that timber harvested from National Forest System lands only where - (ii) there is assurance that such lands can be adequately restocked within five years after harvest;'. The Forest's intent is to rely on natural conifer regeneration wherever possible. The timing of natural regeneration surveys will occur within one to two years post-treatment to allow time to grow tree seedlings if necessary to address the five year restocking requirement. If natural regeneration is determined not to be adequate to achieve stocking levels for Matrix within the NFMA timeline, site-specific appropriate tree species mix would be planted by hand. An appropriate tree mix would be planted at appropriate densities to achieve 125-150 trees per acre.
2990-35 The EA does not present sufficient information to accurately evaluate A pre-field review was completed to determine areas of high probability habitat within the the potential for adverse effects on SS plants project planning area to survey specific sites for sensitive species. Field checks of potential habitat for sensitive species were completed during Burned Area Emergency Response (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3 Botanical section, and EA Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018). Effects to the six sensitive plant species, including Bensoniella oregano , are discussed in the EA Chapter 3 Botanical section.
2990-47 The EA fails to discuss and analyze likely adverse impacts of proposed Please refer to the Soil Section, Forest Mycorrhizal Associations, EA Chapter 3, and actions on the soil biotic community, including soil food webs, which subsequent effects analysis, under Soils and Site Productivity subsection in the EA Chapter are known to strongly influence nutrient dynamics, plant succession, 3. and other important ecosystem processes.
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2990-21 The EA falsely concludes that large dead trees with needles need to be The fuels report mentions material left after harvest (slash, limbs, tops etc…) will increase logged to reduce fine fuels from needle castings fuel loadings within harvest units. As stated in the scoping letter, only dead and dying trees will be harvested. Many of these trees died as a result of crown fire, therefore there are few if any needles remaining. Site visits made throughout the fall, winter and spring confirm that there will be few trees with needles. Trees that died from scorch will retain needles after fire, trees that died as a result of crown fire do not retain needles. Needles and fine fuels are the primary component of fire spread. If there are no needles, this will reduce inputs to fire rates of spread and fireline intensity within these treated areas. It is expected that this lack of needles will reduce flame lengths, and rates of spread as compared to slash resulting from green tree harvest. There is no justification for needing to harvest trees due to needle cast. The areas selected for harvest were identified prior to this analysis.
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2990-9 The EA incorrectly assumes fire regimes in the project area are Fire regimes in Douglas Fir/hardwood forests are considered to be one of the most variable. predominately low mixed severity and therefore claims there is (Agee 1993) This variability makes generalizations about the fire regime and its effects significant departure from historic conditions difficult. Recent events as well as historical records, combined with vegetation patterns indicate intense stand replacing events have been and will be part of the system. Fire behavior can range from low intensity underburns, to mixed severity to stand replacing events, frequently within the same fire perimeter. Historically, high frequencies of low and medium intensity fire broke up large uniform patches into complex mosaics of age, size and structure. (Wills 1991). Resulting vegetation patterns are a mosaic of patches of differing sizes and multi aged stands. Will and Stuart (1994) found mean return intervals in NW California of 13-22 years. Other studies reported median fire return intervals of 10-30 years. (Atzet et al. 1996, Atzet and Martin 1992, Agee 1991, Adams and Sawyer 1980). Intense stand replacing fires still maintain patchiness with some green trees surviving. (Wills and Stuart 1994, Wright and Bailey 1982.) Severely burned areas may account for only 15-20% of the total area burned. (Atzet and Martin, Adams and Sawyer 1980) (EA Chapter 3 Fire, Fuels and Air Quality section) Siskiyou National forest records indicate has managed fires in this area, but all have been kept small. The area identified for harvest activities has missed one or several fire returns due to current fire management. "Recent research suggests that landscapes with unaltered fire regimes are more "self- regulating" than those that have experienced fire-regime shifts; in self-regulating systems, fire size and severity are moderated by the effect of previous fire." (Parks et al. 2013) These fires had they been allowed to burn, would certainly have contributed to the patchiness typically found in Douglas Fir/Hardwood forests. This is the departure from historic conditions referenced in the EA. Areas proposed for harvest were not selected based on fire regime.
2990-29 The EA uses an inappropriate spatial scale from which to assess climate The EA Chapter 3 Climate Change section states " The Forest Service does not have a impacts particularly from logging-related emissions. While logging national policy or guidance for managing carbon, and the tools for estimating carbon and 4,090 acres may not contribute to the overall pool of regional or sequestration are not fully developed. Current direction for addressing climate change global emissions, that's the wrong scale. By inference, that would mean issues in project planning and the NEPA process is provided in the document Climate no single action has any significance to the global climate and Change Considerations in Project Level NEPA Analysis (USDA Forest Service 2009). This therefore why bother? Instead, the Forest Service should examine a document outlines the basic considerations for assessing climate change in relation to range of alternatives and chose the one with the least emissions. project-level planning . "
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2990-41 The Forest Service claims that "soil quality is maintained when erosion, The Objective of FSM 2500 - Watershed and Air Management, R6 Supplement 2500-98-1, in compaction, displacement, rutting, burning, and loss of organic section 2520.2, is "To meet the direction in the National Forest Management Act of 1976 matter are maintained within defined soil quality standards."21 But and other legal mandates. To manage National Forest System lands under ecosystem even if the Forest Service were to meet the 15% standard in all Activity management principles without permanent impairment of land productivity and to Areas, and even if the soil conditions of land outside Activity Areas maintain or improve soil and water productivity." It goes on to state at 2520.2 1 (a) "Soil could reasonably be ignored, the Forest Service still cannot assume quality is maintained when soil compaction, displacement, puddling, burning, erosion, loss that there has been no "significant or permanent impairment of the of organic matter and altered soil moisture regimes are maintained within defined productivity of the land" as NFMA requires. Soil productivity can only standards and guidelines." and goes on to define the Region 6 soil quality standards. In be assumed to be maintained if it turns out that the soil standards addition, the Siskiyou National Forest Land and Resource Management Plan provides forest- work. To determine if they work, the Forest Service would have to specific standards and guidelines for the soil resource. Both are referenced and utilized in undertake objective, scientifically sound measurements of what the the Chetco Bar Fire Salvage Project Soils Resource Report (pages 1-2, 35) to guide proposed soil produces (grows) following management activities. project activities, design criteria, best management practices, and mitigation measures, to meet both the forest and regional standards and guidelines for the soil resource, and therefore meet the direction in the National Forest Management Act of 1976 as per our Forest Service Manual and Forest Plan management direction.
2990-45 The Forest Service essentially claims in the EA that proposed new roads The Soils Resource Report and Soils section in the EA discloses the effects of temporary will have no long-term adverse impacts because they are roads to the soil resource, including expected long term impacts (page 29, 31-32) (EA "temporary", but the agency has presented no scientific evidence in Chapter 3 Soils section). support of this statement.
2990-32 The potential for adverse impacts of proposed action alternatives on A pre-field review was completed to determine areas of high probability habitat within the special status / sensitive plant species are not adequately evaluated project planning area to survey specific sites for sensitive species. Field checks of potential because the Forest Service failed to conduct post-fire botanical habitat for sensitive species were completed during Burned Area Emergency Response surveys. (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3 Botanical Resources section, Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018).
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2990-13 The RRSFN also lumped moderate (50%) with high (>75%) severity fire Areas identified for harvest needed to meet both the high severity and fall within matrix effects ostensibly to increase the area to be logged. This lumping is land allocations. Field visits verified the remote sensed data and Smith and Cluck guidelines inappropriate for two reasons: (1) high severity is mainly were used to determine which trees would be available for harvest. characterized by RdNBR values that correspond to >75% (some authors use >90%) overstory tree mortality (see Odion et al. 2014); and (2) high severity patches are exceptionally diverse and typically do not need planting, which can impair development of complex early seral forests (DellaSala et al. 2014).
2990-14 Therefore, the proportion of high severity fire actually may be much The Rapid Assessment of Vegetation Condition after Wildfire (RAVG) program produces lower than RAVG, meaning you can retain even more large biological data describing post-fire vegetation conditions on National Forest System (NFS) lands which legacies and reduce the overall impact to complex early seral forests, is used to assess and prioritize post-fire vegetation management. RAVG uses the Relative particularly within NSO PFF1 and PFF2 habitat (high and low RHS). Differenced Normalized Burn Ratio (RdNBR), which is derived directly from the dNBR, but is considered more sensitive to vegetation mortality than the dNBR. RAVG is considered an initial assessment, which describes initial vegetation mortality (typically 30 days post-fire containment), but does not capture delayed vegetation mortality. Monitoring Trends in Burn Severity (MTBS) is a multi-year project designed to map consistently the burn severity and perimeters of fires across all lands of the United States between 1984 and present. The data generated by MTBS will be used to identify national trends in burn severity, providing information necessary to monitor the effectiveness and effects of the National Fire Plan and Healthy Forests Restoration Act. MTBS maps burn severity using the dNBR; however, the RdNBR is used to adjust burn severity thresholds to better describe post-fire effects to vegetation. MTBS is considered an extended assessment because most fires are mapped using images acquired one-year post-fire (at peak of greenness). This provides the ability to capture delayed vegetation mortality during the mapping process. The results of RAVG were ground verified in all units.
2990-30 Therefore, we request that you calculate a social cost of carbon as the The Forest Service does not have a national policy or guidance for managing carbon, and the appropriate analysis scale and compare that with the estimated project tools for estimating carbon and sequestration are not fully developed. Current direction for benefits to provide a level economic playing field that considers the addressing climate change issues in project planning and the NEPA process is provided in true costs of logging, rather than discounting those costs by claiming the document Climate Change Considerations in Project Level NEPA Analysis (USDA Forest they are negligible on a global scale. Service 2009). This document outlines the basic considerations for assessing climate change in relation to project-level planning. (EA Chapter 3 Climate Change section)
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2990-20 Third, hazard tree management includes much more than just logging This is not a hazard or danger tree removal project. The purpose of this project is to capture the trees that have moderate to high PM values. In fact, according to timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees the PSW guidelines for hazard trees, five types of actions are available resulting from the 2017 Chetco Bar fire. to managers to reduce tree hazard potential: • Target removal (i.e., remove that target area such as picnic tables) • Tree removal (the only one considered in the EA) • Topping • Pruning • Specialized Actions (e.g. brace the tree) The EA therefore inappropriately choses a single action - logging - when five actions are available based on hazard tree guidelines. Thus, we request that you include non-tree removal 12 actions to minimize impacts to NSO, Riparian Reserves, and other high conservation value areas where hazard trees are a concern.
2990-36 Unfortunately, the Chetco Bar Fire Salvage Project draft EA fails in its A pre-field review was completed to determine areas of high probability habitat within the legal obligations to sustain these outstanding botanical values, by: 1) project planning area to survey specific sites for sensitive species. Field checks of potential not conducting the necessary standard field surveys, 2) erroneously habitat for sensitive species were completed during Burned Area Emergency Response dismissing the potential occurrence of SS plants, including fire- (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been adapted SS species, within the project area, and 3) failing to present completed on roughly 1,020 acres of high probability sensitive plant habitat within the sufficient information to evaluate the full range of potential impacts of project footprint. Surveys will continue to occur through spring of 2018 and if any additional proposed actions on SS plants and fungi. In order to comply with sensitive plant populations are found prior to implementation, mitigations for protection various legal statutes designed to protect botanical resources, the would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, Forest Service must conduct post-fire botanical surveys in areas that SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this will be disturbed by proposed actions, as is the normal standard for project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, projects of this nature, and to share the results of these surveys as part 2018). of a more thorough effects analysis.
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2990-10 We note that there are at least two inappropriate citations used in the The Rapid Assessment of Vegetation Condition after Wildfire (RAVG) program produces EA to back claims not relevant to the study area or for high severity data describing post-fire vegetation conditions on National Forest System (NFS) lands which comparisons using different estimators. For instance, Miller (2012) is used to assess and prioritize post-fire vegetation management. RAVG uses the Relative (cited in the EA) actually used MTBS to estimate high severity fire Differenced Normalized Burn Ratio (RdNBR), which is derived directly from the dNBR, but is effects while the EA uses RAVG that is notorious for over estimating considered more sensitive to vegetation mortality than the dNBR. RAVG is considered an high severity (apples to oranges comparison). initial assessment, which describes initial vegetation mortality (typically 30 days post-fire containment), but does not capture delayed vegetation mortality. Monitoring Trends in Burn Severity (MTBS) is a multi-year project designed to map consistently the burn severity and perimeters of fires across all lands of the United States between 1984 and present. The data generated by MTBS will be used to identify national trends in burn severity, providing information necessary to monitor the effectiveness and effects of the National Fire Plan and Healthy Forests Restoration Act. MTBS maps burn severity using the dNBR; however, the RdNBR is used to adjust burn severity thresholds to better describe post-fire effects to vegetation. MTBS is considered an extended assessment because most fires are mapped using images acquired one-year post-fire (at peak of greenness). This provides the ability to capture delayed vegetation mortality during the mapping process. The results of RAVG were ground verified in all units. MTBS data is not yet available and would not meet the purpose and need of the project. The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. (EA at 1-4)
2990-33 Without any substantiating evidence, the EA falsely claims that the A pre-field review was completed to determine areas of high probability habitat within the project area no longer supports suitable habitat for SS plants. The EA project planning area to survey specific sites for sensitive species. Field checks of potential identifies six SS plant species with known occurrences inside or in very habitat for sensitive species were completed during Burned Area Emergency Response close proximity (i.e., within 100 feet) to the Chetco Bar project area, (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been four of which are known to be disturbanceadapted and therefore completed on roughly 1,020 acres of high probability sensitive plant habitat within the more likely to benefit rather than be extirpated by fire as asserted by project footprint. Surveys will continue to occur through spring of 2018 and if any additional the EA. sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA at 3-133, Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018). Effects to the six sensitive plant species are discussed in the final EA Chapter 3 Botanical Resources section.
Artley Dick
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2993-6 At page 3-159 : "The following is a summary of the Silvicultural See project web page for the complete electronic project record, referenced throughout the Prescription report. The entire report is incorporated by reference and document. https://www.fs.usda.gov/project/?project=53150 can be found in the project file, located at the RRSNF, Gold Beach Ranger District, Gold Beach, Oregon." Incredibly, the IDT members don't know 40 CFR 1502.21 says: "No material may be incorporated by reference unless it is reasonably available for inspection by potentially interested persons within the time allowed for comment." Hiding important information hundreds or thousands of miles from the public also violates: 40 CFR 1500.2(b) because no evidence is presented for environmental effects conclusions. 40 CFR 1501.2(a) because the environmental effects and values are not identified in detail. 40 CFR 1500.1(b) because there is no substantiating evidence for effects conclusions, thus, the public cannot determine if they are accurate and based on best science. 40 CFR 1506.6 (a) because you did not Make diligent efforts to involve the public in preparing and implementing NEPA for this project. 40 CFR 1506.6 (b) because you did not make environmental documents available so as to inform those persons and agencies who may be interested or affected. 40 CFR 1500.2 (d) because you did not encourage and facilitate public involvement in decisions which affect the quality of the human environment.
2993-7 Comment #: Ranger Berner and DFS Russell, when all your IDT members See response to comment 2993-244. disagree with and reject the findings of hundreds scientists does this constitute "scientific consensus?" Please explain why you choose to rely on the knowledge of the IDT members and reject the "best science" recommendations of over 600 Ph.D. biological scientists. Please don't tell the public the scientist's statements aren't applicable because they are not site specific unless you omit all literature in your References section that is not specific to this timber sale.
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2993-5 Comment #: Without exception all post-fire timber sale P&Ns describe See response to comments 2993-234, 2993-236, and 2993-244. the need to "capture" trees before they loose economic value. Elsewhere in these comments I have described the tragic wildlife habitat destruction resulting from any and all post-fire timber sales. I have listed the names of over 600 Ph.D. biological scientists who recommend post-fire landscapes must never be disturbed. You propose rob the organic material that should be returned to the soil. You trade away wildlife habitat with this timber sale. You lie by omission. Your DEIS pre-decisional EA is silent on the benefits of an undisturbed post- fire landscape.
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2993-4 Comment: Attachment #15 contains quotes by Hilda Diaz-Soltero, Dr. See the EA at 3-1 " The best available science is considered in preparation of this EA. The Ann Bartuska, Chief Dale Bosworth, Associate Chief Sally Collins, Chief concept of "best available science" is also a matter of opinion to some degree since Dr. Mike Dombeck, Chief F. Dale Robertson, Agriculture Secretary Dan scientists can legitimately disagree about the meaning or impact of individual study results. Glickman, and USFS Chief Tom Tidwell, who all tell the public the USFS As a general matter, we show consideration of the best available science when we insure depends on "best science" as the basis for it's projects. I have included the scientific integrity of the discussions and analyses in the project NEPA document. attachments to these comments that contain quotes of the research Salvage logging is one aspect of post-fire management and may be used to address a variety conclusions of hundreds of scientists no connected with the USDA that of issues including worker and public safety issues, risks along roads, and risks to describe major short and long term damage to the non-timber infrastructure such as buildings and recreational facilities. Salvage logging may also be resources in the project area resulting from commercial logging and appropriate to recover economic value and support community resiliency. The ecological road construction … especially temporary road construction. This consequences of salvage, however, are often considered negative from the perspective of represents best science. These Opposing Views Attachments are not soils, hydrology, and wildlife habitat resources, although wildlife species responses vary. In contained in the References section of this draft EA. Why? 2015, scientists from Oregon State University and the Pacific Northwest Research Station completed a literature review concerning the Ecological Effects of Post-fire Salvage Logging in the Pacific Northwest (Reilly et al. 2015). These scientists found the ecological effects of post-fire salvage logging vary depending on the treatment, fire severity, and biological setting (Peterson et al. 2009). These scientists concluded that based on their literature review, in general, little research supports the idea that salvage logging has beneficial ecological effects on terrestrial or aquatic resources (Karr et al. 2004, Beschta et al. 2004, Lindenmayer and Noss 2006). To provide the proper context, they concluded that salvage logging needs to be addressed at landscape scales and in terms of tradeoffs with other ecological and economic objectives. Many of the ecological guidelines they recommend for post-fire management are included in the design of this project." See also the EA Chapter 3 References section for a list of included references.
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2993-3 Comment: Ranger Berner and DFS Russell and IDT members, clearly the The No Action Alternative would not harvest in any post fire habitat. Additionally, see conclusions of over 600 independent Ph.D. scientists recommending to response to comment 2993-234 for a discussion of the magnitude of the action alternatives never log a post-fire landscape represent "best science." Opposing in comparison to the overall "post-fire landscape". Your comment states " dead and dying Views Attachment #15 contains the statements by USFS leaders telling trees in a post-fire landscape have significantly more value if left in place to function as the public the USFS grounds all projects in "best science." Here are a Nature intended, than logging them off to provide corporate profit." The Forest Service few examples from Opposing Views Attachment #15: Why do you acknowledges the benefit of dead and dying trees to benefit wildlife extensively in Chapter reject "best science" knowing Chief Bosworth said this: "The American 3, environmental consequences of the action alternatives to wildlife. See the EA Chapter 3 " people have come to expect us to use the best science, and we ought to Effects common to all species Direct and Indirect Effects of Action Alternatives Snag and use the best science." Link to statement: down wood retention per the project PDCs for both action alternatives would lessen the http://www.andruscenter.org/images/transcripts/Sustainable_transcrip loss of these habitat elements that are important to these species and ensure that some of t.pdf Why do you reject "best science" knowing Chief Dombeck this habitat will remain where it is available in harvest units." said this: "The Forest Service must be a leader in using the best science." Link to statement: http://www.waterplanet.ws/transitions/tr9804/ Why do you reject "best science" knowing Chief Dombeck said this: "The responsible policy maker ought to seek out the best science, because ultimately that will yield the best result." Link to statement: http://whyfiles.org/247sci_politics/index.php?g=5.txt Why do you reject "best science" knowing Chief Robertson said this: "Let's keep it up and make sure our decisions reflect the best science." Link to statement: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_053856.p df Why do you reject "best science" knowing Chief Tidwell said this: "We have some of the best science, and we need to make sure we're applying that." Link to statement: http://westinstenv.org/sosf/2009/06/19/tidwell-interviewed-by-the- missoulian/
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2993-2 Comment: Ranger Berner and DFS Russell, you have just read 1) a 2006 See the EA Chapter 3 Wildlife section, environmental consequences to wildlife and those letter to Congress signed by 540 Ph.D. independent biological scientists, species who require snags and downed logs for effects of the project to wildlife, EA Chapter and 2) a letter sent to Congress and President Obama signed by 253 3 Soils section, for soils, and EA Chapter 3 Fire, Fuels and Air Quality section, for fire and Ph.D. independent biological scientists. Each letter includes fuels. See the EA at 1-1 " The Rogue River-Siskiyou National Forest (RRSNF) had undisputable evidence explaining why a post-fire landscape must approximately 14 percent of its 1.8 million acres burn during the summer of 2017. The remain intact and unlogged. Here are short excerpts from each letter: Chetco Bar Fire was the largest fire on the Forest, burning 191,197 acres of which 170,321 Letter #1-"Many scientist-reviewed studies and syntheses (please acres are on National Forest System (NFS) lands. Approximately 85 percent (~144,935 acres) see the selected citations appended to this letter) have recently come of the NFS lands that burned within the Chetco Bar Fire occurred within lands where to this conclusion. For example, no substantive evidence supports the management allocations (such as congressionally reserved areas, late successional reserve idea that fire-adapted forests might be improved by logging after a fire. (LSR) and riparian reserve) either prohibit post-fire salvage or have requirements to show In fact, many carefully conducted studies have concluded just the ecological beneficial effects of treatments to aid in post-fire ecosystem recovery. The opposite. Most plants and animals in these forests are adapted to remaining 15 percent (25,386 acres) of the fire on NFS lands occurred on lands designated periodic fires and other natural disturbances. They have a remarkable as matrix. Given the scale of fire-killed trees in the Chetco Bar fire, prioritization of where to way of recovering - literally rising from the ashes - because they have focus post-fire salvage efforts was crucial for project success. The management objectives evolved with and even depend upon fire." (page 1, paragraph 3) of matrix points to the need of harvesting timber; subsequently, it is important to salvage Letters #2 and #3- "After a fire, the new forest is particularly vulnerable timber and reset the timber production for future harvest opportunities. This timber would to logging disturbances that can set back the forest renewal process for be harvested, capturing the economic value that was intended to be sustainably and evenly decades. Post-fire logging has been shown to eliminate habitat for harvested over time. Areas within matrix were prioritized for addressing the large amounts many bird species that depend on snags, compact soils, remove of smaller diameter fire-killed trees. Within the approximately 25,386 acres of lands biological legacies (snags and downed logs) that are essential in designated by the Northwest Forest Plan as matrix, approximately 13,626 acres incurred 50- supporting new forest growth, and spread invasive species that 100 percent basal area loss (RAVG analysis). Focusing on burned areas with 50-100 percent outcompete native vegetation and, in some cases, increase the basal area loss located on lands designated as matrix helped narrow the scope of the flammability of the new forest." (page 2, paragraph 2)) Most project." As outlined above, the proposed action focuses on areas in matrix land allocations competent, caring USFS line-officers who value healthy non-timber (suitable for timber harvest) (approximately 25,386 matrix acres within the project area) natural resources would allow the recommendations of over 600 Ph.D. and further refined to only those acres which endured approximately 50-100 percent basal independent biological scientists to override several biased timber IDT area loss. members.
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2993-2 Further analysis refined the proposed action acres to 4,090 by " removing units lacking continued economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources." (EA at 1-1) The proposed action could potentially affect about 16% of the matrix lands within the project boundary, and could affect 30% of the matrix lands that fell into the 50-100 percent basal area loss. On a larger scale, the proposed action would affect only 2% within the fire perimeter that overlaps with Forest Service land. Alternative 3 could affect approximately 7% of matrix lands, or approximately 14% of matrix lands in the 50-100 percent basal area loss.
2993-1 Comment: Ranger Berner and DFS Russell, you reject the advice of over See the EA at 1-4 "The purpose of the Chetco Bar Fire Salvage project is to capture timber 600 Ph.D. biological scientists who signed a letter to Congress in 2006 value in the matrix land allocations by harvesting dead, dying and/or damaged trees and a letter to the Senate and President Obama in 2015. Both letters resulting from the 2017 Chetco Bar fire. Timber would be harvested following standards and contained multiple reasons why a post-fire landscape must never be guidelines outlined in the Siskiyou National Forest Plan as amended by the Northwest Forest disturbed. You reject the science contents of both letters and instead Plan. This project would salvage fire-killed or dying trees to provide timber to local mills and accept the recommendations of your timber employees on the IDT economies. Dead or dying trees would be salvaged in areas where operations are whose jobs depend on selling timber sales. Might there be bias? Keep in economically feasible while considering potential impacts to sensitive resources and values. mind USFS leaders have been telling the public agency projects are all The timber value would be prioritized and captured using a salvage prescription as grounded in "best science" since 1993. determined by a certified silviculturist." Additionally, see EA Appendix A for a comprehensive list of project design criteria that minimize or eliminate resource effects of the action. Effects to resources are outlined in the EA Chapter 3. Finally, the No Action Alternative would not "disturb" the post-fire landscape.
2993-A Several attachements were addressed seperately. Refer to the Project File
Hawkins Tom
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2994-9 A minimum 85% slash cover will greatly limit the ability of native Siskiyou NF Forest Plan Management Direction - Forest-wide standards and guidelines for vegetation to reoccupy the site. Reduce the percent slash ground cover soil and water resources, (USDA 1989, pages. IV-44 through IV-48) are: Ensure land and seed with native grass and forbes. management activities are planned and conducted to maintain soil productivity and stability. The S&Gs specific to the Soils resource are listed below: Mineral soil exposure guidance (specific to Chetco Bar Fire project footprint, minimum 85 percent effective ground cover) (S &G 7-4) (EA Chapter 3 Soils section) 85 percent effective ground cover is required post operations and will mitigate potential soil erosion and loss of organic matter and nutrients by increasing the amount of woody debris in the project footprint over existing conditions, and add vegetative debris to the ground surface at a greater rate than what would occur under natural conditions (EA Chapter 3 Soils section).
2994-11 CCPLA supports treatments that improve, maintain and keep existing Thank you for your comment. The Proposed Action alternative improves, maintains and roads and trails open; generate revenue for the county to maintain keeps all existing open roads open, and uses generated monies to maintain roads. roads and trails; and reduce the risk of future catastrophic fires, and improve forest resiliency.
2994-7 Every effort should be made to make logging piles with suitable There are no roads proposed to be closed under this project. All open roads will continue to firewood available to the public before a road is closed. be open after the project is implemented.
2994-10 New landings within 300 feet of an open road suitable for dispersed To reduce the impacts of erosion and subsequent sedimentation on log landings and to camping should be left open. maintain or improve soil infiltatration capacity and reduce compaction, all landings would be decompacted preferably with an excavator and covered with some residual slash (85% EGC). (EA Appendix A)
2994-6 Roads that are identified in the database as closed, which have never Only the closed roads that would be opened for log haul would be re-closed at completion been physically closed, should be left open following treatments. Any of project (EA at 2-4). road closed should leave a portion of road surface suitable for foot travel to facilitate post salvage treatments such as planting and prescribed fire and future fire suppression.
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2994-3 The decision on how much undeveloped land to provide on the Siskiyou Nevertheless, the effects to undeveloped lands must be described in the EA. National Forest to meet multiple-use objectives has been made. The proposed project units are within the 3-4 % of forest matrix land allocation where timber harvest can occur. Salvage of timber within the proposed 1,433 acres of undeveloped lands should occur to meet the stated purpose and need.
2994-1 The decision to limit salvage to matrix and not look at the entire fire It is the Responsible Officials sole discretion to establish the scope of the environmental was made with no public involvement and fails to take a hard look at analysis, including the scope of the actions, alternatives, and effects (40 CFR 1508.25). the whole fire considering protection of Brookings from future fires, the Additionally, the Alternatives Considered but Eliminated from Detail Analysis document economics of providing funding for treatments, and the needs of describes the rationale for not considering in detail 10 other alternatives. restoring late-successional habitat treatments.
2994-2 The EA analysis also does not disclose or consider the amount of At the fire scale, currently about 30% (43,745 acres) of the 146,260 acres of unmanaged NFS untreated complex early seral habitat and biological legacies existing in lands within the Chetco Bar fire are considered early seral habitat, well above the NRV of the remaining 97% of the Chetco Bar Fire not proposed for salvage. 7.9% to 11.6%. Additionally, about 39% (56,910 acres) incurred 25-75% basal area loss, Fifty percent of which is either Wilderness, Wild and Scenic River or which are described as mixed mortality fire that can create patches of complex early seral Inventoried Roadless Area. The amount of early seral habitat and legacy habitat. Under the Proposed Action alternative, approximately 2,222 acres of unmanaged structure occurring on the adjacent Collier Butte and Biscuit Fire were stands (1.5% of the unmanaged NFS lands) are planned for salvaging and potentially also not disclosed. artificial reforestation if natural regeneration is not sufficient (EA at 3-9).
2994-5 The EA does not disclose or identify the location of the 6.3 miles of This information is included in the EA, Appendix B, Alternative Maps. currently closed roads that will be opened and reclosed. EA maps have Basic Custodial Care (closed) in the legend, but only 4 short segments could be found. 2994-8 The value of an opened or new road to future prescribed fire This project does not propose to close any roads. Temporary roads are not intended to be operations and access for fire suppression, planting, etc., should also be part of the forest transportation system and not necessary for long-term resource considered when determining condition to leave a road in following management. This project proposes to implement road maintenance activities that would use. leave the roads in better condition, thus facilitating future fire suppression activities.
2994-4 We again state that we cannot support any actions that rely in any way Thank you for your comment. on the Travel Analysis recommendations for decommissioning roads, because the analysis was arbitrary and capricious, and thus, fundamentally flawed.
Astor Amanda
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2995-27 F-1: This is inconsistent with VR-1. Please indicate if VR-1 is a slash Stump heights will not be measured against the slash depth requirement. Slash depths are disposal zone and the rest of the unit must be below 3ft. or if to be no greater than 12" on average within harvest units. (EA Chapter 3 Fire, Fuels and Air something else is proposed. Quality section)
2995-5 Implementation of Alternative 3 would be inconsistent with the Forest's Alternative 3 addresses concern for effects of salvage logging to early seral habitat with snag and down wood guidelines. The Forest Service has used the biological legacies (snags and down wood) by removing unmanaged stands from proposed DecAid model to predict and advise appropriate levels of snags to meet salvage units (EA at 2-4 thru 2-5). The Forest Plan states "habitat capability for woodpeckers LRMP guidance. Figure 4 on page 3-19 of the EA indicates that the (indicators for cavity-nesting species) should be continually maintained throughout the Chetco River Watershed currently has 3-times as many snags greater Forest at not less than 60 percent of potential population levels" (SNF Plan p IV-33). Table-IV- than 12" based on DecAid and 10-times as many snags greater than 24" 5 in the Forest Plan (p IV-34) indicates that 185 total snags per 100 acres would be based on DecAid. Given this compelling data, how could the Forest minimally required in forested habitat to meet this requirement and Table IV-8 (Forest Plan Service possibly justify selecting an Alternative that exacerbates this p. IV-35) indicates a minimum of 115 snags per 100 acres in shrub/sapling/open pole habitat excessive snag condition even further by leaving additional snags on the would meet the requirement. The DecAID snag information provides current best available landscape? science about wildlife use of snag habitat, and advises that certain wildlife species use much higher densities of snags per acre than what the Forest Plan required (EA figure 4). Therefore, the excess snags not included in Alternative 3 provide more suitable habitat for cavity-nesting species and meets the intent of maintaining this habitat above the minimum requirement (EA Chapter 3 Wildlife section). Given that the watershed currently has more snags than reference condition according to DecAID, the Forest has the opportunity to manage snag levels in parts of the watershed to meet the higher tolerance levels for several snag-related species which is advised by DecAID for post-fire landscapes ( https://apps.fs.usda.gov/r6_decaid/views/main.html table SWOMC_PF). Alternative 3 supports that opportunity.
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2995-3 Issue 1 discusses unmanaged stands, yet on page 3-8 of the Draft EA, The EA at 3-8 stated "Stands harvested and reforested more than 80 years prior to the Environmental Consequences to Complex Early Seral Habitat and Chetco Bar fire could be considered complex early seral habitat however they were not Biological Legacies (Issue 1) talks about the affected environment being included in the analysis because that data is not readily available. To provide a conservative stands harvested and reforested more than 80 years prior to the Chetco analysis, private lands and BLM lands for this analysis were all considered managed stands." Bar fire. The deferred stands in Alternative 3 are considered unmanaged. The USFS recently hosted a symposium, "Ecological, Economic and Social Objectives for managing stands over 80," which focused on the science behind the arbitrary 80-year-old threshold. We encourage you to review the presentations contained here. Due to the nature of this project as a fire salvage, the reserve age guidelines are not relevant.
2995-26 IV-2, IV-4, IV-5, and SIL-3: Please consider combining all these criteria. Thank you for your comment. The project design features mentioned have different They all discuss cleaning equipment purposes and discuss separate mitigations.
2995-18 Please disclose if an owl circle will not be considered if there is more The existing amount of suitable habitat for the core area and home range were considered than 50% of the core burned under high severity and no longer suitable, for determining impact of the project on habitat. If a core or home range has less than 50 or as well as if the home range is no longer 40% suitable. 40 percent of existing suitable NRF habitat, the impact of removing PFF would be a higher degree of negative effect with the assumption that this habitat element is currently providing some function in foraging and structure for future habitat than in core areas or home ranges that have meet thresholds for suitable NRF because there would still be adequate functioning habitat available without the PFF.
2995-17 Please disclose if the level of burn severity is being taken into Project activities requiring snag retention described in the EA Appendix A on page A-1 would consideration within historic core areas and home ranges for the flow occur within areas of moderate or high fire severity as described in the proposed action. The chart on page A-1. EA, Appendix A, flow chart at A-1 is the application of snag retention guidelines with consideration for the likelihood of owls to be using the habitat for foraging based on distance from existing NRF and the relative habitat suitability of the site. (EA Chapter 3 Wildlife section) The flow chart does not consider the amount of NRF habitat currently available in the core area or home range.
2995-20 Please divulge if there will be or has been any owl calling to check for Protocol surveys for NSO are underway this season (2018). (EA Chapter 3 Wildlife secton) occupancy within historic owl circles and areas of high RHS.
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2995-8 Please explain why "Other Undeveloped Areas" is an analysis issue and Undeveloped areas were brought up during the scoping period. Comments described that how it is related to the Purpose and Need of the project. If there is no salvage logging and other connected actions (temporary roads) within areas identified as correlation, then remove this analysis issue. having undeveloped character may make these areas no longer considered undeveloped lands. It does not have to be related to the purpose and need. It is considered an issue because the Proposed Action alternative affects it. Just as the Proposed Action alternative affects fish and wildlife, we must display the impacts of the project.
2995-11 Please explain why PFF2 is considered PFF at all and how far can PFF2 PFF is identified where NRF habitat was burned at moderate to high intensity. Recent really be away from identified suitable habitat. studies indicate that NSO may still use this habitat post-fire (EA Chapter 3 Wildlife section). These studies differ in the amount and severity of habitat that burned and the location of activity centers and post-fire NRF relative to the fires. For this reason, we did not dismiss the potential for NSO to use any of the PFF in the landscape, but evaluated the degree of potential effects to NSO using all impacts to PFF and factors that influence the likelihood of the habitat to be used by NSO based on the distance from existing NRF, historic core use areas, and the position of the habitat in the landscape (RHS). PFF1 is identified within 500 feet of existing NRF which includes the edge habitat between NRF and the burned area shown to be used by NSO in recent studies moreso than the burned area beyond that edge habitat, especially large areas of high severity burn. Therefore, PFF2 is identified beyond the assumed edge habitat and if it is in a topographic position of high relative habitat suitability, then protecting large snags and down wood in this high RHS PFF2 would provide important habitat elements of future NRF. Finally, PFF2 with low RHS has the lowest likelihood of use by NSO in the short term. (EA Chapter 3 Wildlife section).
2995-4 Please explain why stands harvested and reforested more than 80 years The EA at 3-8 stated "Stands harvested and reforested more than 80 years prior to the prior to the Chetco Bar fire are considered unmanaged and where the Chetco Bar fire could be considered complex early seral habitat however they were not importance of the age of 80 comes from. included in the analysis because that data is not readily available." These stands are not considered unmanaged, but could be old enough to have closed canopy characteristics. To provide a conservative analysis of complex early seral habitat, the responsible official decided not to include these stands as complex early seral habitat, as well as private lands and BLM lands.
2995-6 Please explain why the Proposed Action does not meet the intent and The Proposed Action alternative proposed to salvage harvest 2,222 acres of complex early reason for having Alternative 3 seral habitat and 1,433 acres of undeveloped lands, whereas Alternative 3 does not.
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2995-10 Please explain your rationale for protecting known nest patches The 70-acre nest patches around known NSO sites usually coincide with the habitat to be (without current survey data) and areas of dispersed high RHS. retained as 100-acre LSRs per the NWFP and are to be retained even if they become unoccupied by northern spotted owls (NFWP ROD 1994 p. C-11). This is also emphasized in the 2011 Revised Recovery Plan for the Northern Spotted Owl on page III-49, Recovery Action 12 which states: "In lands where management is focused on development of spotted owl habitat, post-fire silvicultural activities should concentrate on conserving and restoring habitat elements that take a long time to develop (e.g. large trees, medium and large snags, downed wood)." Therefore, the known nest patches in the project area are protected as a means to comply with the NWFP ROD and Forest Plan direction to manage habitat for federally threatened and endangered species to achieve objectives of recovery plans. (SNF Forest Plan IV-27).
2995-16 Please identify how monitoring will be completed to ensure objectives Regarding wildlife monitoring, wildlife biologists from the Forest and USFWS will review the are met on the ground. layout of a sample of units with the various snag and down wood retention PDCs to ensure compliance. The Forest is required to complete implementation monitoring reports annually to USFWS for projects under consultation. Other resources would monitor post implementation as required. Additionally, long term fuels monitoring is in the early stages of pre-NEPA.
2995-19 Please identify if you assuming the high RHS has suitable habitat in it or RHS is used in combination with the GNN habitat mapping the Forest uses for NSO habitat. has this been field verified. The GNN habitat map identifies NRF, dispersal and capable habitat and the RHS data is used to refine the habitat primarily based on the topographic position of the habitat, which has been shown to correlate well with where known owl sites occur in the landscape. Furthermore, the RAVG fire severity mapping was used to identify the moderate and severely burned areas for the project and all of these data together were field verified for a large portion of the project area. The findings were that the mapping was reasonably accurate for the purposes of the project analysis. PDC will be implemented based on site specific conditions in the field, but are expected to be reasonably well represented by the data used for the project analysis. (BA p 23)
2995-12 Please identify the size, in acres, the existing NRF (500ft. or more away) Patches of NRF greater than 1 acre within high relative habitat suitability (RHS) was used to must be to consider any given location a PFF1 or PFF 2 identification. determine PFF1 vs PFF2. Most high RHS NRF in the project area is in much larger contiguous patches following drainages. There are few small isolated patches of high RHS NRF in the project area. (Project Biological Assessment Map 3, Project Biological Opinion, Appendix E)
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2995-13 Please include the storage of carbon in wood products from the sale of "The Forest Service does not have a national policy or guidance for managing carbon, and timber into your considerations of net emissions of greenhouse gases. the tools for estimating carbon and sequestration are not fully developed. Current direction for addressing climate change issues in project planning and the NEPA process is provided in the document Climate Change Considerations in Project Level NEPA Analysis (USDA Forest Service 2009). This document outlines the basic considerations for assessing climate change in relation to project-level planning." The scope and degree of change from the action alternatives is minor. The total area proposed for salvage (up to 4,090 acres) is a fraction of the forestland in the project planning area and on the RRSNF as a whole. A project of this magnitude would contribute minimally to regional greenhouse gases. Furthermore, at the global scale, the action alternatives direct and indirect contribution to climate change would be negligible, and therefore the project's cumulative effects on greenhouse gasses and climate change would also be negligible. (EA Chapter 3 Climate Change section)
2995-2 Please list the species that are "complex early-successional" obligates The EA at 3-5 states "This section (Complex Early Seral Habitat and Biological Legacies) within previously burned areas. Please identify if the species also describes the effects to early seral habitat and biological legacies. Additional information on needs large biological legacies, e.g., why cutting the trees in these the effects specific to standing dead trees (snags), and down woody debris and the wildlife stands will degrade the habitat needed for the species. Please list species that depend on these attributes are addressed in the Wildlife section." Alternative 3 the amount of habitat each species needs and how much of this habitat was developed to address the issue of early seral habitat and biological legacies brought up exists on the forest. Please provide a rationale as to why this during the scoping period. habitat is so important that Alternative 3's limited actions are warranted to be seriously considered.
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2995-1 Please provide an expanded rationale as to why the IRAs do not have In supporting documentation: Alternatives Considered but Eliminated from Detailed any actions proposed and were not evaluated. Analysis, Alternative C: An alternative that salvage harvests trees within Inventoried Roadless Areas (IRA) was brought forward during scoping. While this alternative would accomplish the need for recovering economic value of timber burned in the fire, it would not achieve the balance of sustainability between economic returns and ecological values that is an objective in the Siskiyou National Forest Plan. In IRA, the cutting, sale, or removal of generally small diameter timber generally must be needed for one of the following purposes (i) To improve threatened, endangered, proposed, or sensitive species habitat; or (ii) To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects, within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period; and will maintain or improve one or more of the roadless area characteristics as defined in § 294.11. Salvage harvesting in IRA is highly controversial and the proposed Chetco Bar fire salvage project was not designed to maintain or improve roadless area characteristics, nor was it designed to improve threatened, endangered, proposed, or sensitive species habitat. The purpose of the Chetco Bar fire salvage project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. The Deciding Official therefore did not propose salvage harvest with IRA, in fact the scoping letter explicitly stated "No activities or harvesting of trees would occur in any inventoried roadless areas."
2995-21 Please verify all Design Criteria are project specific and have not been Design criteria described in EA Appendix A are all considered to be relevant to the project. duplicated from projects containing only "green" timber management. Whether or not they are duplicated from projects containing only "green" timber management is irrelevant.
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2995-24 R-7: Why does there have to be a separate permit for snow plowing? Project design criteria are developed to ensure that project activities can be conducted The first sentence is not a Design Criteria. The second sentence is and without significant impact to any of the affected resource areas. Adherence to project can be taken care of under the timber sale contract in the Operating design criteria throughout all phases of project implementation is the basis for the Requirements Provision. R-8: Haul being suspended is not a Design assumptions, determinations, and findings in the EA. As such, project design criteria must Criteria. It is a part of the timber sale contract. This criterion should be detailed enough to mitigate specific potential project effects, broad enough to cover removed. R-9: Why does burned bark need to be removed from the foreseeable operational contingencies, and flexible enough to facilitate implementation roadway? Is this realistic for this project area is all locations? R-11: across large and variable project areas. Please define "freeze-thaw" conditions and the parameters for measuring them that the Sale Administrator will use.
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2995-23 S-2: When you say, "Roadside Danger Tree Abatement harvest units Thank you for your comments and recommendations. S-2 was clarified in the EA, Appendix overlapping with area salvage would be a priority area to evaluate," do A; and Soils Report (Ochoa, 2018). Please refer to the EA, chapter 3, Soils Section, for you mean during the operation of the area salvage or after operations discussion on S-4 and citation for SLRMP IV-44, S&G. PDC S-9 allows flexibility for prep and are complete? S-4: Please site (SLRMP IV-44, S&G 7-2). S-5: This layout crews to plan logging systems in accordance with SLRMP IV-44, 7-2 and will remain in exact text is already in the SLRMP as cited and thus is not a project the PDC in EA, Appendix A as written. Your suggestion on PDC S-12, H-2, and H-3, and H-6 specific Design Criteria and does not need to be included in the list. have been incorporated into the PDC list. The objective of S-15 is to minimize consumption Appendix A should only be for project specific Design Criteria, not to of soil organic matter and minimize soil heating; and to minimize soil and site productivity, reiterate the Standards and Guidelines in the SLRMP. S-9: This is therefore burn windows are not limiting soil objectives and will remain as written in PDC. already stated in the SLRMP IV-44, 7-2. It is worded differently but Suggestion for H-1 has been noted. We have incorporated your suggestion for S-5, and as states the same thing. S-10, LH-2, LH-3, LH-4, LH-9, LH-10, LH-12, SIL- the Wildlife PDC meets the Soils LWD Objective, we refer to meeting the WL LWD 1: Thank you for including flexible language about soil, log haul, and requirement to also meet the Soils objective for LWD. We have also incorporated your roads. This allows local weather to drive the allowable equipment suggestions for LH-6 to allow for flexibility in sedimentation management structures. operations instead of arbitrary dates. S-12, H-2 & H-3: Please combine these Design Criteria under H-2. It could say, "No new temporary roads, skid trails, or landings are allowed within Riparian Reserves. Avoid locating temporary roads, skid trails, and landings near any type of likely flow or sediment transport conduit during storms, such as ephemeral channels and swales, where practicable. Existing legacy templates may be used after review and approval by Hydrologist, Soil Scientist, or Fisheries Biologist in Riparian Reserves if rehabilitation occurs post-harvest, which would meet ACS objectives by restoring riparian dependent conditions. See Soils PDCs for effective obliteration measures." S-15: There is hardly any soil organic matter left in the areas proposed for treatment, therefore this resource is already compromised. With limited burn windows as is, do not limit yourself to an even smaller one.
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2995-9 The cost of helicopter logging has been grossly under estimated. The helicopter cost is likely underestimated for this analysis, but is the information we have Helicopter logging cost is closer to $800/MBF. Please change the at this time and serves to demonstrate the differences in alternatives. Helicopter logging helicopter stump to truck cost from $400/MBF to $800/MBF. was proposed in order to mitigate impacts to resources by reducing the miles of temporary roads needed to implement the project. The Responsible Official will evaluate the tradeoffs between ecological and economic objectives. The National Forest Management Act (NFMA) requires that projects and activities be consistent with the governing Forest Plan (16 USC 1604 (i)). The harvesting system to be used is not selected primarily because it will give the greatest dollar return or the greatest unit output of timber (16 USC 1604(g)(3)(E)(iv)); The harvest systems proposed under the selected alternative, Alternative 2 the Proposed Action, was identified as the system that best accomplished the multiple resource objectives associated with accomplishment of the project purpose and need. An environmental assessment is supposed to be a concise public document that serves to briefly provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or finding of no significant impact. The cost of helicopter logging does not change the impacts of the project on resources.
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2995-25 VR-1: These measures do not apply to this project. "a) Cut stumps to 8 Project design criteria are developed to ensure that project activities can be conducted inches or less, contour stump cuts to match the surrounding terrain, without significant impact to any of the affected resource areas. Adherence to project and face cuts away from the road/trail/site to the maximum extent design criteria throughout all phases of project implementation is the basis for the possible." This will be nearly impossible. Stump heights should be 12 assumptions, determinations, and findings in the EA. As such, project design criteria must inches everywhere. "b) Remove timber in a manner that minimizes detailed enough to mitigate specific potential project effects, broad enough to cover disturbance to soil and natural forest duff layers, rehab drag marks to foreseeable operational contingencies, and flexible enough to facilitate implementation natural existing condition." There is no duff left, it has all been burned. across large and variable project areas. "e) Locate temp roads, landings, and piles beyond the immediate foreground to the maximum extent possible." This can be combined with VR-26 & VR-27. Overall, this measure is unrealistic and ridiculous for this project especially because there will be roadside salvage in front of the area salvage units that do not have these criteria. This Design Criteria should just be deleted. VR-2: This Design Criteria is also unrealistic. A landing should be operational and safe. It may be an operational hazard to leave a feathered edge of snags. There is no non- merchantable or small woody understory in most cases due to the high severity of the fire. In general, this criterion is operationally unrealistic for this project and project area and should be deleted. VR-3: This criterion is a reiteration of stump height in contracts. It should be deleted because it adds no project specific information. VR-4: This criterion is a reiteration of prescription language and does not need to be in Appendix A. It does not add any project specific information. In general, this criterion is operationally unrealistic for this project and project area and should be deleted. VR-5: ....
2995-14 We appreciate the Forest Service pursing an Emergency Situation Thank you for your support. Determination to help expedite this implementation.
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2995-7 We are also unsure why Alternative 3 has no effects to "Other Alternative 3 does not propose to salvage in unmanaged stands. Undeveloped lands occur in Undeveloped Lands." unmanaged stands.
2995-29 We are concerned with the prominent level of subjectivity to the snag None of the salvage units are proposed within known core areas. All of the home ranges in retention design criteria in PFF1 and PFF2 on page A-1 of Appendix A. the action area still contain suitable NRF, but none currently meet the 40% threshold (EA First off, does it matter if the core or home range is severely burned Chapter 3 Wildlife section, and Table 13). Much of the remaining NRF is in stream drainages and degraded? Elsewhere, "take" is assessed at the threshold of 50% of with high relative habitat suitability (RHS). In this large of a burned area, it is possible that the core area being suitable and 40% of the home range being suitable. NSO may shift their core use area within their home range to incorporate more existing NRF Secondly, why is RHS being used in PFF2? It is our understanding that and associated edge to improve foraging success. Therefore, legacy snag retention PFF2 is more than 500 ft. away from any suitable NRF. prioritization is based on the likelihood that the PFF is currently contributing to foraging habitat. In the core areas and home ranges, PFF1 (high and low RHS) are emphasized the most, followed by PFF2 with high RHS, and then PFF2 of low RHS. Approximately seventy- eight percent of the salvage unit acreage is "capable" habitat (BA Table 13) where 4 snags/acre greater than 10 inches dbh with two greater than 20 inch dbh would be applied.
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2995-15 We understand that the Forest Service considered standards for snag The following standards and guidelines specific to Matrix management were applied to the retention and other resources during the design of this salvage project. project (NWFP ROD 1994: pg. C-40): A) "Manage to provide a renewable supply of large We would like to remind the Forest Service that the Northwest Forest down logs well distributed across the matrix landscape in a manner that meets the needs of Plan discusses standards & guidelines in the context of the landscape: species and provides for ecological functions. Develop models for groups of plant "manage to provide a renewable supply of large down logs well associations and stand types that can be used as a baseline for developing prescriptions." distributed across the landscape." (NWFP ROD 1994: pg. C-40). The The Siskiyou National Forest Plan Supplement provides these standards, while the Chetco terms "across the landscape" and "throughout the Matrix" are and Pistol River watershed analyses provide DecAID advisor provides current information frequently used in the Northwest Forest Plan when describing based on best available science. All exceed the guidelines described in B) below, and were standards and guidelines. used to develop the Project prescriptions for snags and down wood. B) "Until standards are developed as described above, the following guidelines apply in areas of regeneration harvest. In … western Oregon south of the Willamette National Forest…, a minimum of 120 linear feet of logs per acre greater than or equal to 16 inches in diameter and 16 feet long shall be retained…. In all cases, standards and guidelines from current plans and draft plan preferred alternatives apply if they provide greater amounts". C. "Course woody debris already on the ground should be retained and protected to the greatest extent possible from disturbance during treatment (e.g. slash burning and yarding) which might otherwise destroy the integrity of the substrate." E. "As with all standards and guidelines, these guidelines are meant to provide initial guidance, but further refinement will be required for specific geographic areas. This can be accomplished through planning based on watershed analysis, and the adaptive management process."
2995-28 We would like the Forest Service to develop a logging plan early in the On June 5, 2018, the first of several proposed salvage sales have been identified in the field. planning process so that the retention tree layout can be designed with The Interdisciplinary team will review the sale area and make recommendations to the it in mind in order to balance the need for economical timber sales with retention standards for all resources concerned. Refinement of the logging plan is the the need for retention of key structural elements in salvage harvest objective. Any identification that has occurred prior to the decision notice is draft. We have units. not applied paint or any pre-decisional mitigations. Once a decision is signed, we can complete the sale preparation and have the final design criteria to meet the objective and award the sale in a timely manner.
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2995-22 WL-1: Does it matter if the nest patch is unsuitable habitat now or will WL-1: The nest patches are protected as "known spotted owl activity centers" which are each nest patch be a no cut? WL-4: "[…] unless protocol surveys have included in the 100-acre LSRs described in the 1994 NWFP ROD pp C-10 to C011. Any determined the nest site or habitat not occupied, non-nesting, or failed salvage in nest patches would comply with LSR standards and guidelines. None are in nesting attempt." Does this mean the Forest Service will be calling to proposed for salvage in this project. WL-4 & WL-6: The Forest plans to conduct protocol determine this, or will purchasers be allowed to pay for independent NSO surveys in 2019. However, consideration may be given to independent protocol surveys? WL-6: Will these nest sites be surveyed be surveyed? Does surveys as long as the surveyors meet the Forest's expectations for qualifications and the this mean the Forest Service will be calling to determine this, or will Forest can provide contract inspection. WL-8: Yes. Large snags within one tree-height of a purchasers be allowed to pay for independent surveys in nest sites and nest likely provide some screening from weather conditions and predators. This situation is unserved NRF habitat? WL-8: Does the protection buffer of 70ft. only mostly likely to occur along the edges of certain units that are adjacent to occupied marbled apply to trees with nesting structure and live trees surrounding it? In murrelet habitat or other patches of suitable murrelet habitat where occupancy is other words, are you applying this buffer to live trees with structure unknown. Because the unit boundaries have not all been identified on the ground, this surrounded by snags? buffer would be applied to potential nest trees for marbled murrelets within 70 feet of any unit. The project BA was revised to include consideration for edge effects to Marbled Murrelet after the draft EA was out for public comment. The final EA includes this revision.
Helms Heidi 2998-1 The Chetco River Watershed is home to the Chetco Indian people The forest conducts government to government consultation with eight federally who have lived there since pre-European and colonialism. Chetco recognized tribes that are associated with forest lands under treaties, adjudicated ceded people still use this area for hunting, fishing and gathering much that land claims, and/or use forest lands for traditional and cultural purposes. A consultation will be lost if you open the gates to cutting it. Many people grieved letter that provided details of the proposed action and invited consultation and over the toll that was taken from the burn but much good happened recommendations was sent to all eight tribes on January 5th, 2018: the Coquille Indian with that burn. While some people see it as profits lost, the burn will Tribe, Cow Creek Band of Umpqua Tribe of Indians, Confederated Tribes of Siletz Indians, restore the area naturally, and in that process has wiped out diseases Confederated Tribe of Grand Ronde, Elk Valley Rancheria, the Klamath Tribes, Quartz Valley taking over the land. Cutting is not a solution to the preservation of the Indian Reservation, and the Tolowa Dee-ni' Nation. land and water. The burn will bring back a state of health to the area that cutting never will.
Davies Gwen
Page 170 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3004-1 Oregon has pioneered caring for our environment, forests, and The No Action alternative addresses your concerns. waters!!!! Please uphold those values. I voted for Tom McCall proudly knowing he had supported keeping the Oregon coast open to the public, wanted the Willamette cleaned up, the bottle bill, and many other concerns for Oregon as a special state. Other programs have continued and expanded those values. With the climate changing protecting native forests and water in all places. . . . from source to ocean. . . . . is the most critical issue we have as a species.
Sprague Samuel 3011-1 There is a great opportunity here to use traditional ecological Controlled burning is outside the scope of this project. knowledge and allow fire to be a part of the landscape again. Controlled burning would have prevented the great tragedy that befell the Kalmiopsis wilderness last fire season. This place is still wild and scenic, and should be treated as so.
Young Harvey 3012-1 I perfer minimum logging in the watershed of the chetco river. Yes on The No Action alternative addresses your concerns. hazard trees no on the rest of the landscape.
Prow sharon 3024-2 NO salvage logging in old growth. Alternative 3 addresses your concerns.
3024-1 Stay out of Late Successional Reserves on this area where the Chetco All lands within the project footprint where salvage harvesting would occur are matrix land Bar fire hit and started in the Kalmiopsis Wilderness. allocation. Late successional reserves will not be salvaged with this project.
McLaughlin Michael 3029-1 PLEASE allow ecosystem recovery and maintenance of wild untouched The No Action alternative addresses your concerns. forest and regrowth to such original conditions.
Lish Chris 3034-1 I also urge Forest Service decision makers to bring communities The No action alternative addresses your concerns about " avoiding post-fire clearcut and stakeholders together by avoiding post-fire clearcut logging and logging and new road construction in the Chetco River Watershed ". new road construction in the Chetco River Watershed.
Page 171 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3034-2 Please do not convert post-fire native forests into second-growth Alternative 3 addresses your concerns about "not convert post-fire native forests into timber plantations. second-growth timber plantations" .
3034-3 Please work with the public to focus management near homes and Alternative 3 addresses your concerns about "focus management near homes and communities while protecting remote backcountry forests and communities while protecting remote backcountry forests and tributaries" . tributaries.
Kenner Kate Kenner Despite what some think we need nature -I do for sure. The Chetco The EA states "There are no direct or indirect effects identified to aquatic resources from River brings much to the lives of people and it is home to many animals. proposed activities associated with the Chetco Bar Area Salvage Project. Because there are To destroy their home as well along with the salmon who swim there is no effects associated with proposed project activities to aquatic resources, there can be no wrong. negative cumulative effects."
Moryc David 3044-3 Any alternative should avoid streamside areas and staying off of steep All action alternatives avoid streamside areas, restrict ground based logging systems to slopes prone to soil erosion and landslides that once triggered can slopes less than 30%, avoid slopes prone to soil erosion and landslides, and decommission dump damaging loads of sediment into streams over an extended temporary roads after implementation. The action alternatives propose varying levels of period of years. It is critically important to avoid creating new roads and temporary roads and the No Action alternative proposes no new temporary roads. There decommission any temporary roads that are often the largest are no measurable direct, indirect, or cumulative effects to erosion or sedimentation, peak contributor to harmful amounts of stream sediment. flows, stream temperature, or waterbody condition expected from the Chetco Bar Fire Salvage project because there are no effects to the measures used to predict potential effects.
3044-2 Any EA alternative must meet management requirements within Key All alternatives considered in this project meet management requirements within Key Watersheds and Riparian Buffers, must focus on maintaining aquatic Watersheds and Riparian buffers and maintain aquatic values. Refer to the EA, Chapter 3 for values, and where roads or logging should avoid impacts to water more details. quality and aquatic species
Page 172 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3044-4 Based on peer-reviewed science we have serious concerns about the See response to comments 2989-19 and 2990-37. In addition, please refer to EA at effect of post-fire treatment on soils and erosive slopes and Appendix A, S-1. Sensitive soils, unstable slopes, and potentially unstable areas would be consequently Coho salmon listed under the Endangered Species Act buffered by appropriate widths as described in Table 23 (EA Chapter 3 Soils section). (ESA). Log hauling and road construction in the project area will have Protective no-cut areas and buffers around all streams and potentially unstable areas serve significant negative impacts on listed fish. We are especially concerned to retain sediment and prevent erosion on steep slopes. The mitigations proposed for log about substantial deleterious cumulative impacts to the Panther Creek haul will be closely monitored during implementation and have been shown to effectively and Basin Creek watersheds that provide Critical Coho Habitat. Because mitigate the potential for sedimentation on gravel surfaced roads. The vast majority of the of these effects on listed Coho salmon and the inability to mitigate for haul route that is in proximity to coho salmon critical habitat is the 1376-000 road. The 1376- these impacts NOAA Fisheries should perform a full Section 7 ESA 000 is paved and will not generate road-derived sediment from haul or public use that could consultation on this EA. then be transported to the stream network.
3044-5 We also incorporate by reference the EA comments of KS Wild Thank you for your comment. KS Wild's letter will be responded to as appropriate. submitted on May 14, 2018.
3044-1 We ask that any alternative the U.S Forest Service (USFS) chooses All alternatives considered in this project recognize the productivity and diversity of the recognize the productivity and diversity of the Chetco River's Chetco River's landscapes, including wildfire, and these processes were carefully considered landscapes are a result of natural processes, including wildfire, and and accommodated as part of post-fire management. The natural productivity of the soils these processes must be carefully considered and accommodated as and waters of these public lands would be protected. part of post-fire management. Protecting the natural productivity of the soils and waters of these public lands should be the priority.
t veronika 3079-1 There has been a lot of private logging in the Chetco already after this The No Action alternative addresses your concerns. fire and the trees that remain need to stay to provide biomass and shelter to the wildlife of the area. When strands get logged it creates much more fire danger as tall grasses and weeds take over and create kindling for new fires. Trees are resistant to wildfires and hold water and cast shade on the ground to cool it. Please don't long this precious diverse forest it is vital for the health of our land.
Vaile Joseph
Page 173 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3096-9 Bad science to log burns. The best available science is considered in preparation of this EA. The concept of "best available science" is also a matter of opinion to some degree since scientists can legitimately disagree about the meaning or impact of individual study results. As a general matter, we show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document.
3096-3 Clear cutting is counterproductive, as old growth trees are far more dire The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix resistant than the overgrowth or brush that spring up in clear cut areas. land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. Essentially all trees removed are either dead, dying or damaged to such a degree they are not expected to live.
3096-1 I urge Forest Service decision makers to bring communities and The No action alternative addresses your concerns about " avoiding post-fire clearcut stakeholders together by avoiding excessive post-fire clearcut logging logging and new road construction in the Chetco River Watershed ". and new road construction in the Chetco River Watershed.
3096-4 Logging the area will damage new growth including redwood seedlings The No Action alternative addresses your concerns. which have begun to disperse naturally from a nearby stand. It is crucial for the ecosystem that this area be allowed to recover naturally.
3096-6 Please allow the forest to recover naturally, not become a single-aged The No Action alternative addresses your concerns. monoculture tree plantation like the majority of western Oregon.
3096-2 Please only do logging in plantations Alternative 3 addresses your concerns.
3096-7 Please put the earth and the ecosystems before monetary contracts.. The No Action alternative addresses your concerns.
Page 174 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3096-5 Proposed green tree logging of 30% green doug-fir must be prohibited The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage in the final decision. There are plenty o f 100% dead trees to satisfy harvest under the action alternatives. The species being targeted for salvage under the needs for volume. action alternatives include Douglas fir and incense cedar, therefore they have been included in Table 3. No other species would be targeted for salvage removal. However, any tree, regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
3096-8 PROTECT OUR RIVERS! Salvage logging is not proposed within riparian reserves.
3096-10 This is a horrible idea! Please reconsider this. The No Action alternative addresses your concerns.
Heide Allen 3107-3 I am in favor of Alternative 3, which limits most of the impacts of post- Thank you for your support. fire logging to areas near existing roads.
3107-1 I ask that the U.S Forest Service (USFS) prioritize protection of water Both the Proposed Action alternative and Alternative 3 utilize best management practices as quality, riparian buffers, and habitat function for salmon and steelhead well as project design criteria to minimize or eliminate resource effects. Additionally, all in determining how to conduct post-fire logging operations in the salvage units were evaluated for feasibility and many areas were removed due to logging Chetco Bar Fire project area. systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources.
3107-2 urge the Forest Service to take a science-based approach to identifying The best available science is considered in preparation of this project. The concept of "best areas within the Chetco Bar Fire project area that can be logged available science" is also a matter of opinion to some degree since scientists can legitimately without undue impact on water quality and ecosystem function in the disagree about the meaning or impact of individual study results. As a general matter, we watershed. show consideration of the best available science when we insure the scientific integrity of the discussions and analyses.
Werschkull Grant
Page 175 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3114-2 In summary, we ask that the USFS restrict post-fire logging, and instead The purpose of the project is to capture timber value in the matrix land allocations by focus public investment on improved fuels planning and treatment harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at projects --- particularly in plantations and proximate to wildland 1-4). Alternative 3 addresses your concerns. interface communities.
3114-3 In the alternative, should the USFS insist on conducting post-fire Thank you for your support. logging, we advise choosing Alternative 3, which limits most of the impacts to areas near existing roads, and avoids steep terrain riparian areas. 3114-1 We ask that the U.S Forest Service (USFS) recognize that the Both the Proposed Action alternative and Alternative 3 utilize best management practices as productivity and diversity of the Chetco River's landscapes are a result well as project design criteria to minimize or eliminate resource effects. Additionally, all of natural processes, including wildfire, and these processes must be salvage units were evaluated for feasibility and many areas were removed due to logging carefully considered and accommodated as part of post-fire systems operability and accessibility, locating and avoiding unmapped riparian reserves, and management. In other words, protecting the natural productivity of the considerations for post-fire wildlife habitat and other resources. soils and waters of these public lands should be the priority. covault jonnel 3139-1 The Chetco, Smith, Rogue and Klamath Rivers are now prime The No Action alternative addresses your concerns. recreational areas where people from all over the USA and world come to visit. I recreate on the Smith and Klamath and can't wait to paddleboard and row on the Chetco. More money is to be made in the recreation industry than logging which will help coastal communities. Selectively cut, please. Clearcutting is a visual blight that has so many negative consequences, I can't believe we are still considering this harvest method.
Follette Cameron
Page 176 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3153-1 ORCA is gravely concerned that the action alternatives proposed in the None of the alternatives evaluated here include any actions (except haul routes on existing EA may lead to the degradation of these outstanding values—especially roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined when considered cumulatively with the extensive private land logging to have no effect to water quality. The rationale for this determination is documented in the and with the effects of the Chetco Bar Fire across 68% of the Chetco Hydrology section. The project incorporates a system of design features that ensure there River's watershed. can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-10)
Peterson Brenda 3163-1 Allow the Chetco to recover naturally. Nature doesn't need our help in The No Action alternative addresses your concerns. "recovering" from wildfire. Logging, however, will negatively impact the recovery and devastate many needed habitats.
Page 177 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Greyraven Ruth 3168-1 I urge the USFS to rely on science in its planning for post-fire The best available science is considered in preparation of this EA. The concept of "best management, specifically in regard to the Chetco River watershed. available science" is also a matter of opinion to some degree since scientists can legitimately There is no evidence for an ecological value for "salvage logging". disagree about the meaning or impact of individual study results. As a general matter, we show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document. (EA at 3-1)
3168-2 Post-fire logging is a one-time profit for one industry, with a negative The proposed project was determined to have no effect to aquatic species, including ecological value. Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. (EA at 1-10)
Kolb Brianna 3172-1 The Chetco River is a place where anyone can go to escape reality, for The No Action alternative addresses your concerns. me it's a place I prefer to go when I'm battling some emotional demons. There isn't a soul in this world that could go to any of our river bars located on the Chetco (and there are tons) and not feel like they are at complete peace, the soothing river and poetic wind between the trees are what makes this place our home, the Chetco isn't like any other! We're lucky to say we were raised on the Chetco, so please don't take our home from us.
Burke Mike 3179-1 Hopefully we can learn from past mistakes Thank you for your comment.
Stemsrud Arne
Page 178 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3184-1 Please Prioritize protections for wild salmon and steelhead habitat in The proposed project was determined to have no effect to aquatic species, including the Chetco watershed with Chetco Bar Salvage Project. Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. (EA at 1-10)
3184-2 While the science does not support an ecological basis for post-fire The best available science is considered in preparation of this EA. The concept of "best salvage logging, I do appreciate that this proposal focuses post-fire available science" is also a matter of opinion to some degree since scientists can legitimately activities on the existing matrix lands, and ask that you limit post-fire disagree about the meaning or impact of individual study results. As a general matter, we logging to roadside hazards, avoid steep terrains, include buffers to show consideration of the best available science when we insure the scientific integrity of minimize damage to streams, and that you do not build new roads. the discussions and analyses in the project NEPA document. (EA at 3-1) wilson shannon 3187-1 As far as ecological justification to salvage log any native forests on No where in the EA do we purport that salvage logging benefits the ecosystem. The public lands, there is no such scientific data that asserts that salvaging ecological consequences of salvage, however, are often considered negative from the logging benefits the ecosystem what so ever. In fact, the bulk of perspective of soils, hydrology, and wildlife habitat resources, although wildlife species science on this subject asserts that salvage logging dramatically harms responses vary (EA at 3-1). the ecosystem and natural recovery.
Page 179 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3187-2 We're also concerned that the proposed logging will increase the risk of Treatment units will have greater fuel continuity after harvest, this can increase fire rates of future fire to local communities and to national forest lands that form spread. Reburn severity is often a concern after harvest activities. However, logging slash is the watershed of the Wild and Scenic Chetco River. It is a well only part of the fire risk story, and it may not be the most important after a few years. established fact that early seral tree stands and tree plantations burn (Thompson et al, 2007) Adjacent untreated areas will retain lower fuel levels and high much faster and hotter than areas where down large dead woody spatial heterogeneity which can aid in slowing fire growth. The proposed treatment areas debris and snags remain. account for only 2 percent of the high severity footprint of the Chetco Bar fire, and many of these high severity areas are in the immediate vicinity of treatment, it is expected that these treatments would have little effect on future fire management activities due to this fragmented nature of unit locations. The treatment units are relatively isolated and small in comparison to the larger, adjacent areas of moderate and high severity. This heterogeneity is important in terms of fire spread and improved conditions into the future. The project design criteria will allow for effective fire suppression activities without further treatment. (EA Chapter 3 FIre, Fuels and Air Quality section)
Jungwirth James 3195-1 This kind of logging would be degrading the integrity of the ecosystem The effects of the project are described in the EA, Chapter 3. Specifically the EA states "The at large and negatively impact the quality of the water and the fish CBF Salvage project would not incrementally add to cumulative effects because no populations in the river. measurable effects to sedimentation, water yield, riparian vegetation, or in-stream wood in Riparian Reserves or hydrologically connected areas are predicted. Salvage activities would not impact waterbody condition. The project footprint is 3% of the hydrologic analysis area, and none of these treatments would occur within Riparian Reserves or other potentially hydrologically connected areas. There would be no cumulative effects to water yield and peak flows because no live trees would be harvested, and detrimental soil conditions from ground-based harvesting methods would be minimized through BMPs and PDC. There would be no cumulative effects to instream woody debris because no trees would be removed from Riparian Reserves." The effects to fisheries and aquatic biota are also described in the EA, Chapter 3. Specifically the EA states "There are no direct or indirect effects identified to aquatic resources from proposed activities associated with the Chetco Bar Area Salvage Project. Because there are no effects associated with proposed project activities to aquatic resources, there can be no negative cumulative effects."
bccorelse
Page 180 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3202-3 The EA provides no analysis or assurance that the river's watershed Refer to the EA, Chapter 3, Recreation and Visuals section. condition and its outstanding values will not be degraded by the cumulative activities occurring on private land and proposed on federal public lands.
3202-3 We are very concerned that the action alternatives proposed in the EA None of the alternatives evaluated here include any actions (except haul routes on existing may lead to the degradation of these outstanding values-especially roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined when considered cumulatively with the extensive private land logging to have no effect to water quality. The rationale for this determination is documented in the and with the effects of the Chetco Bar fire across 68% of the Chetco Hydrology section. The project incorporates a system of design features that ensure there River's watershed. can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-10)
Page 181 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3202-3 We're also concerned that the proposed logging may increase the risk Treatment units will have greater fuel continuity after harvest, this can increase fire rates of of future fire to local communities and to national forest lands that spread. Reburn severity is often a concern after harvest activities. However, logging slash is form the watershed of the Wild and Scenic Chetco River. only part of the fire risk story, and it may not be the most important after a few years. (Thompson et al, 2007) Adjacent untreated areas will retain lower fuel levels and high spatial heterogeneity which can aid in slowing fire growth. The proposed treatment areas account for only 2 percent of the high severity footprint of the Chetco Bar fire, and many of these high severity areas are in the immediate vicinity of treatment, it is expected that these treatments would have little effect on future fire management activities due to this fragmented nature of unit locations. The treatment units are relatively isolated and small in comparison to the larger, adjacent areas of moderate and high severity. This heterogeneity is important in terms of fire spread and improved conditions into the future. The project design criteria will allow for effective fire suppression activities without further treatment. (EA Chapter 3 FIre, Fuels and Air Quality section)
3202-3 We're especially concerned that Riparian Reserves, steep slopes, areas Refer to the Design Criteria listed in Appendix A regarding soils and hydrology. Slopes over above inner gorges, areas with the potential for landslides and areas 30% would have cable or helicopter logging. Riparian reserves have been excluded from sensitive to surface erosion and soil loss should not be subject to harvest units. See design criteria S-1 through S-15 and H-1 through H-6. further disturbance
Wahl Mary 3209-1 I urge the Forest Service (FS) to chart a post-fire management course The NEPA process and timber sale preparation requirements are followed to inform the that minimizes logging, to consider economic outcomes beyond solely responsible official. For this salvage sale proposal, information from the RAT report and field timber revenue, and to account for the costs of additional damage to reconnaissance was used to determine financial efficiency. The recommendation to propose water quality, fish and wildlife, and the recreational uses of the Forest salvage logging was based on the stands that were burned over. They contain primarily that would occur if salvage logging is implemented. Douglas-fir, a product valuable to society and to the local economy. Once the financial efficiency has been determined, no other analysis is required past the project initiation. For this salvage proposal, an economic efficiency, as recommended, is used to further inform the decision maker as to the viability of the proposed action, to help refine the actual salvage acreage, and to help design an implementation plan. The effects to other resources, water quality, fish and wildlife, and recreational use are described in the EA, Chapter 3.
Page 182 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3209-2 If the FS decides to do post-fire salvage logging, it should be limited to All Action alternatives are confined to matrix lands, salvage would not occur in late matrix areas, or to protect public safety along forest roads or near successional reserve or riparian reserves. developed areas, and should avoid logging old growth, riparian, Late Successional Reserve, and other non-matrix forest areas.
James Fenner 3211-1 I strongly urge the U. S. Forest Service to prioritize protection for water Refer to the best management practices and design criteria in the EA Chapter 2 and EA quality, riparian buffers, and habitat for salmon and steelhead near the Appendix A. Design criteria provide descriptions of how to implement the proposed action top of the list when determining how to conduct post-fire logging in ways that minimize or eliminate resource effects of the action. Through the project, all operations in the Chetco Bar Fire project area. applicable best management practices (BMPs) for watershed and vegetative management would be used to enable the achievement of water quality standards (General Water Quality Best Management Practices, Pacific Northwest Region, USDA Forest Service 2011). (EA at 2-7) There are no direct or indirect effects identified to aquatic resources from proposed activities associated with the Chetco Bar Area Salvage Project. Because there are no effects associated with proposed project activities to aquatic resources, there can be no negative cumulative effects. (EA Chapter 3 Fisheries and Aquatic Biota section)
3211-2 We therefore urge the Forest Service to take a science-based The best available science is considered in preparation of this project. The concept of "best approach to identifying areas within the Chetco Bar Fire project available science" is also a matter of opinion to some degree since scientists can legitimately area that can be logged without undue impact on water quality, disagree about the meaning or impact of individual study results. As a general matter, we wildlife habitat, and ecosystem function in the watershed. show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document. (EA at 3-1)
Collins Kyle 3233-2 Clearing forest damaged by fire in previous years is an irresponsible The EA at 3-113 states "There are no measurable direct, indirect, or cumulative effects to approach which does not match our current science shows. Fire erosion or sedimentation, peak flows, stream temperature, or waterbody condition damaged areas are subject to severe erosion and this is only heightened expected from the Chetco Bar Fire Salvage project because there are no effects to the via the introduction of heavy machinery and logging equipment. measures used to predict potential effects."
Page 183 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3233-3 The sediment produced by these operations will threaten the integrity Please refer to appendix A, Design Critiera, specifically those design criteria protecting soils of the Chetco's water quality and harm not only wildlife, but the (S-1 through S-15), and hydrology (H-1 though H-6). These design criteria are integrated into communities downstream who rely on this resource as their primary the project in order to mitigate the impacts to those resources (such as soils and hydrology) drinking water. Additionally, there is little evidence that post fire from the project activities. logging will decrease future fire damage and it may actually increase the potential for fire in the future by allowing slash and other materials to accumulate in the wake of timber cutting.
3233-1 We must protect the remaining unspoiled areas we have in a way that Alternative 3 addresses your concerns. is balanced and considers the best available science regarding post fire recovery, wildfire conditions, and conservation science.
Churchill Jack 3237-1 The accumulative impacts on the Chetco watershed of both private The cumulative effects of this project are described in the EA throughout Chapter 3. land and public forest land management decisions must be evaluated in the EA. including the impacts not evaluated in the Categorical Exclusion for miles of roadside logging These impacts include seasonal flow regimes, temperature trend changes particularly late summer flows, sediment production and impact on the fishery and drinking water supplies of Brookings and other domestic water right users
3237-2 The Forest Service is responsible under Oregon Water Quality Plan to The proposed project was determined to have no effect to water quality. The rationale for meet compliance of the water quality standards of the streams in the this determination is documented in the Hydrology section. The project incorporates a watershed it manages. system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. (EA at 1-9)
Bernstein Robert
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3247-1 I strongly favor the Forest Services option # 3..small scale logging with Thank you for your comment. The best available science is considered in preparation of this less road building. Less disruption is best..we should save what we have EA. The concept of "best available science" is also a matter of opinion to some degree since and do as little further damage as possible. We should be science scientists can legitimately disagree about the meaning or impact of individual study results. based. As a general matter, we show consideration of the best available science when we insure the scientific integrity of the discussions and analyses in the project NEPA document. (EA at 3-1)
Western Californians Wilderness 3256-1 The rivers in southwestern Oregon are important for salmon and The proposed project was determined to have no effect to water quality. The rationale for steelhead, along with our northernmost California rivers. It is important this determination is documented in the Hydrology section. The project incorporates a that their ecosystems remain as intact as possible. Recognizing that fire system of design features that ensure there can be no mechanism to affect water quality. is part of that ecosystem militates against salvage logging on a large Some examples of design features to protect water quality include no-cut riparian buffers scale, especially when there are private lands nearby that are subject to on both sides of all streams, conditional restrictions on the haul of salvaged timber, and clearcutting. You must take those effects into account. improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. (EA at 1-9) The Proposed Action alternative would salvage harvest on less than 2.5% of the burned area on National Forest System lands.
knopf clay 3268-1 It is clear that this landscape is likely to experience recurring fires in the The No Action alternative addresses your concerns. Wahl Shirley
Page 185 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3275-1 I am writing to urge the USFS to take great care with post-fire logging in The best available science is considered in preparation of this EA. The concept of "best the Chetco Bar area. The fire created huge impacts to the USFS land, available science" is also a matter of opinion to some degree since scientists can legitimately and neighboring lands and communities; I urge the USFS not to make disagree about the meaning or impact of individual study results. As a general matter, we conditions worse by rushing to log trees that would be far more show consideration of the best available science when we insure the scientific integrity of valuable to the Forest if left standing, or where post-fire logging will the discussions and analyses in the project NEPA document. (EA at 3-1) add to the harmful impacts to the Forest.
3275-3 If you decide to do post-fire salvage logging, it should be limited to All action alternatives limit salvage logging to matrix land allocations only. None of the matrix areas, or to protect public safety along forest roads or near alternatives evaluated in this project include any actions (except haul routes on existing developed areas, and should avoid logging old growth areas, wild and roads) in the Wild and Scenic Chetco River Corridor. The No Action alternative addresses scenic areas, and other non-matrix forest areas. your other concerns.
Page 186 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3275-2 The recreational, fisheries - both commercial and sport --, water quality, None of the alternatives evaluated in this project include any actions (except haul routes on and other values of the forest are important by themselves, and for the existing roads) in the Wild and Scenic Chetco River Corridor. The proposed project was economic uplift they provide. In fact, the economic value of these determined to have no effect to water quality. The rationale for this determination is contributions from the forest is high and must be considered along with documented in the Hydrology section. The project incorporates a system of design features the economic value of logging. that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea- run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-9 to 1-10)
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3275-2 The NEPA process and timber sale preparation requirements are followed to inform the continued responsible decision maker what is needed to sell timber from the national forest. For this salvage sale proposal, information from the RAT report and field reconnaissance was used to determine financial efficiency. Basically, the recommendation to propose salvage logging was based on the stands that were burned over. They contain primarily Douglas-fir, a product valuable to society and to the local economy. Once the financial efficiency has been determined, no other analysis is required past the project initiation. For this salvage proposal, an economic efficiency , as recommended, is used to further inform the decision maker as to the viability of the proposed action, to help refine the actual salvage acreage, and to help design an implementation plan . The effects to recreation, fisheries, water quality and other resources are described in the EA, Chapter 3.
Kehr Rich 3281-3 Describing how this project moves the landscape toward historical Refer to the response to comment 3281-1. and future reference conditions will go a long way toward countering the status-quo argument.
3281-2 How does the current condition for the project area relate to the Please refer to the response to comment 3281-1. The purpose of the Chetco Bar Fire range of these reference conditions? It is likely that this project area is Salvage project is to capture timber value in the matrix land allocations by harvesting dead, departed from reference conditions. This departure from reference dying and/or damaged trees resulting from the 2017 Chetco Bar fire. (EA at 1-4) conditions is a major justification for land management activities such as fire salvage. The design of units and resulting ecosystem services should reflect the dynamics of patch and pattern on the landscape described by historical and future reference conditions. Placing units simply to salvage trees does not help move the landscape toward reference conditions. How will the work proposed in this project move the area toward reference conditions and allow fire to play a more natural role and provide for landscape restoration?
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3281-4 How will the project provide for healthy landscape dynamics, and a Refer to the response to comment 3281-2. sustainable and resilient future ensuring wildlife habitat, water quality, and other important ecosystem services? Please see the research work on landscape and disturbance ecology of Dr. Paul Hessburg and others.
3281-1 I couldn't find discussion in the EA about reference conditions Refer to the Natural Range of Variation (NRV) analysis in the EA at 3-7. (historical and expected future) for the project area and its associated ecosystem sub-region. Reference conditions describing the landscape before fire suppression are important for understanding how the project area has changed, primarily due to human fire suppression.
3281-8 I did not find a transportation analysis report posted on line. Why are The Responsible Official directed the team to only include temporary roads. None of the only temporary roads being used in this project? Long temporary alternatives evaluated here propose any new road construction. (EA at 2-4) roads that are not properly designed can cause considerable erosion and impact to waterways and fish habitat. If there are temporary roads planned longer than about a half a mile, why were these roads not considered for design as permanent roads and proposed for addition to the forest road system? These longer road corridors will likely be used again for forest management in accordance with forest plan direction. Why keep disturbing the ground every 10 to 30 years by keeping them as temporary roads?
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3281-9 My last comment is a general one having to do with the size of the The January 2018 scoping letter described the need to capture timber value in the matrix project. The project seems too small. Using the fire salvage proposal it land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The would seem appropriate to move the landscape patch and pattern letter stated these areas would be evaluated for feasibility of treatment and that the toward reference conditions which would result in improved mix of treatment acreage would be reduced further, due to a combination of factors. The wildlife habitat, fire regimes, and ecosystem services in the long run. evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing Why go with such a small project footprint when the Forest Service inventoried roadless areas (IRA), removing units lacking economically viable products, could use this opportunity for landscape restoration? logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources. (EA at 1-1) Additionally, the purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. (EA at 1-4)
3281-5 The EA speaks to the impact of insects and disease on the forest within Refer to the response to comment 3281-2. the project area and the need to mitigate the impact of these disturbance agents. There is little to no discussion about the pre-fire suppression landscape, and the historical patch and pattern mosaic which existed prior to suppression. With successful fire suppression over the last 100 years the landscape forest pattern has changed. How will this project address moving the project area toward reference conditions for this ecosystem sub-region, mitigating the potential for mega fires and significant loss of ecosystem services and important wildlife habitat? Will the project shift the primary disturbance regimes to those described in reference conditions? Should the project do so?
3281-7 The improving economy has resulted in increasing timber prices. Is Trees would be removed and harvested by a variety of logging system methods including helicopter now a viable logging alternative, and could it be used in ground-based logging systems, skyline yarding and helicopter. (EA at 2-2) place of constructing a portion of the temporary roads?
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3281-6 The visual quality analysis addresses change from the current condition. Refer to the response to comment 3281-2. How will the project move the landscape toward reference conditions for visual quality for the ecosystem subregion? Will the project provide for a more sustainable visual landscape, capable of withstanding historical disturbance patterns without the type of massive changes we are seeing now due to mega fires?
Andreae Chris 3282-1 Just a few points that the Forest Service omitted: 1, A 'managed' The No Action alternative addresses your concerns. forest is a tree farm. 2, 'Thinning' destroys habitat for countless other species. 3, Trees like douglas firs need to grow in stands; they require other doug firs growing with them. The only way to restore a forest is to remove the factor(s) that threaten it. That means Just Leave. Get Out. Leave the last remaining tracts of Cascadia's forest alone. Let our forests rest and recover.
Craft S 3284-1 I implore you to cancel all post fire logging units in the complex. The No Action alternative addresses your concerns. Absolutely cancel all logging in undeveloped areas in the planning area. Cancel new road construction in the Chetco River Watershed. Cancel all units in the Quail Prairie Creek, Minerak Hill Fork, Eagle Creek, and Packer's Cabin and Long Ridge areas. Cancel all units that will impact the view-shed for recreational use along the Chetco River. Our Southern Oregon communities depend on the income from tourism to the Chetco River.
Bourdon Sunny 3292-2 I would also like to urge the USFS to limit logging activites to stands Alternative 3 addresses your concerns. previously managed/logged and to retain un-roaded areas. Roadless areas should be protected for their wilderness values. The proposed logging of 826 acres of undeveloped forest stands greater than 1,000 acres in size would permanently alter the character of roadless public lands that many Americans, and locals, would like to see retained.
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3292-3 Post-fire logging (because calling it "salvage" is truly misleading) of The definition of salvage cutting is the the removal of dead trees or trees damaged or dying previously un-managed stands will increase fire hazard. because of injurious agents other than competition, to recover economic value that would otherwise be lost (The Dictionary of Forestry, 1998). Surface fuel loading in both treated and untreated areas would accumulate post-fire, beginning to decline as early as 20 years post-fire within the activity units (Peterson 2014; Ritchie 2013). Treatment units will have greater fuel continuity after harvest, this can increase fire rates of spread. Reburn severity is often a concern after harvest activities. However, logging slash is only part of the fire risk story, and it may not be the most important after a few years. (Thompson et al, 2007) Adjacent untreated areas will retain lower fuel levels and high spatial heterogeneity which can aid in slowing fire growth. The proposed treatment areas account for only 2 percent of the high severity footprint of the Chetco Bar fire, and many of these high severity areas are in the immediate vicinity of treatment, it is expected that these treatments would have little effect on future fire management activities due to this fragmented nature of unit locations. The treatment units are relatively isolated and small in comparison to the larger, adjacent areas of moderate and high severity. This heterogeneity is important in terms of fire spread and improved conditions into the future. The project design criteria will allow for effective fire suppression activities without further treatment. (EA Chapter 3 Fire, Fuels and Air Quality section)
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3292-1 The USFS should take a watershed-focused approach by avoiding The proposed project was determined to have no effect to water quality. The rationale for building new roads, logging native forests, logging on steep slopes or in this determination is documented in the EA Chapter 3 Hydrology section. The project riparian areas. I am concerned that the plans are to build 13 miles of incorporates a system of design features that ensure there can be no mechanism to affect roads, log native forest stands, and haul logs across the watershed water quality. Some examples of design features to protect water quality include no-cut without enough mitigation. Those activities are known to cause erosion riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged that could harm the river. I would like to urge the U.S. Forest Service to timber, and improving the drainage features of the road system that might be utilized for choose a path forward that restores, rather than degrades, the aquatic haul. For more information refer to the Hydrology section. The proposed project was values of the Chetco Watershed that many hold dear. determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. (EA at 1-9) Additionally, the No Action alternative addresses your concerns.
Collier Zachary
Page 193 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3308-1 After visiting 50 of Oregon's 58 National Wild and Scenic RiversI firmly None of the alternatives evaluated here include any actions (except haul routes on existing believe the Chetco is the crown jewel of the National Wild and Scenic roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined River system. It should be protected and left in it's natural state. to have no effect to water quality. The rationale for this determination is documented in the Hydrology section. The project incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-9)
Wahl Shirley
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Name Comment Text Response Text
3313-1 I urge that the decisions made by the FS incorporate the other values The Forest Service is proposing to salvage harvest 4,090 acres burned in the 191,197-acre and contributions to our economy and well-being, along with the Chetco Bar Fire. That is less than 2.5 percent of the burned area on National Forest System immediate interest in logging. Lands. The January 2018 scoping letter described the need to capture timber value in the matrix land allocations that experienced 50-100 percent basal area loss, about 13,626 acres. The letter stated these areas would be evaluated for feasibility of treatment and that the treatment acreage would be reduced further, due to a combination of factors. The evaluation for feasibility has been ongoing and has reduced acres to 4,090 due to removing inventoried roadless areas (IRA), removing units lacking economically viable products, logging systems operability and accessibility, locating and avoiding unmapped riparian reserves, and considerations for post-fire wildlife habitat and other resources. (EA at 1-1) None of the alternatives evaluated here include any actions (except haul routes on existing roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined to have no effect to water quality. The rationale for this determination is documented in the Hydrology section. The project incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species.
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3313-1 Some examples of design features to protect aquatic species include no-cut riparian buffers continued of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-9)
3313-2 If the decision is to engage in post-fire logging, I urge the FS to consider The best available science is considered in preparation of this EA. The concept of "best results of all the research and experience of the last few decades available science" is also a matter of opinion to some degree since scientists can legitimately showing that logging can and often does add further stress to the disagree about the meaning or impact of individual study results. As a general matter, we already-damaged forests, and that it is often not the case that logging show consideration of the best available science when we insure the scientific integrity of provides the best economic benefits to the area. the discussions and analyses in the project NEPA document. (EA at 3-1)
Harman Johanna 3320-2 Logging is not restoration. No where in the EA do we claim that logging is restoration.
3320-1 Please make sure environmental damage to the beloved Chetco Please refer to the design criteria in the EA, Appendix A. Watershed is lessened. In fact, can you increase the buffer zone? I can see the ugly, bald clearcuts from the Chetco river, quite easily. Please don't allow the timber plantations to creep closer to the Chetco. Any excuse to log.
Ullian Barbara
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3336-4 Comments submitted by Geos found that the EA's reliance on generic Please refer to response to comment 2990-42. Best Management Practices (BMPs) is not scientifically or legally sufficient to demonstrate that significant adverse impacts to soil resources will be avoided. We'd also argue that the sufficiency of the BMPs—which the EA relies on to demonstrate that the outstandingly remarkable water quality and fisheries values of the Chetco will be protected—is not adequate under the anti-degradation standard of the Wild and Scenic Rivers Act.
3336-12 Given these studies and our concerns for the cumulative effects to the The Purpose of this project is to capture timber value in the matrix land allocations by watershed of the Wild and Scenic Chetco River and for the safety of the harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. surrounding communities, the only viable action alternative is Restoration of the watershed function and not increasing future fire risks is not a part of the Alternative 3 and it must be implemented with the goals of restoration purpose of this project (EA at 1-4). The effects of this proposal are described in the EA, of watershed function and not increasing future fire risks to Chapter 3. communities.
3336-13 Our question is - why is the EA basing its analysis on "experience with Thank you for your comment. This section of the EA has been revised to include local other fires in Central Oregon" when there's research conducted research. specifically in the the Biscuit and Silver fire areas, and the Klamath- Siskiyou Region, that addresses shrub and conifer interaction following wildland fire?
3336-6 Overall the watershed cumulative effect section (p. 3-107) does not The EA Chapter 3 Hydrology section discloses the indirect, direct, and cumulative effects seem adequate to address the potential impacts of the extensive from logging on proposed National Forest System lands, private land logging, roadside private land logging, the hazard tree logging, and the logging proposed danger tree abatement, as well as field observations from the fire. In addition, the on national forest land, with the additional effects of the fire itself. Northwest Forest Plan addresses effects at the 5th field watershed scale. No salvage activities are planned within designated Northwest Forest Plan riparian areas. Under the Aquatic Conservation Strategy, Riparian Reserves maintain and restore aquatic resources.
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3336-8 The EA discusses similar findings by Donato et al. 2006 in the climate The findings of Donato et al. 2006 were applied to the project. Refer to the EA, Chapter 3, change section of the EA under the heading "Effect of climate change Climate Change section. on the proposed project." (p. 3-166) However, we can't see how these findings are applied in the EA, especially with regard to the fact that post-fire logging and planting increase fire risk, even if its in the short term.
3336-3 The EA provides no analysis or assurance that the river's watershed Refer to the response to Comment 3336-1. condition and the outstandingly remarkable values dependent on it will not be degraded by the cumulative activities occurring on private land and proposed on federal public lands.
3336-5 The EA states that increased sediment due to human influence has been Please refer to response to comments 2989-7 and 2989-23. observed but that its not been a chronic issue and on p. 3-101 it states that: * In the CBF area the soils have a high infiltration capacity reducing the likelihood of over-land-flow occurring. Because of the high infiltration capacity of the soils, the increase in surface erosion is less following a wildfire than may be found in other areas that have reported high rates of erosion First, this statement does not seem consistent with the Burned Area Emergency Response Soil Resource Assessment for the Chetco Bar fire. Also, p. 112 of the Chetco Watershed Analysis for the Quail Prairie Creek subwatershed revealed concern
3336-11 Therefore, we cannot support the logging of green trees or of larger The No Action alternative addresses your concerns. trees in native stands and it argues that any pos-fire logging should not increase future fire risk.
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3336-10 Thompson also found that the large-diameter fuels removed during Refer to the response to comment 3336-7. post fire logging do not readily carry wildland fire and that logging fire- killed trees may increase available surface fuels by transferring unmerchantable material, such as tops, branches, and broken boles to the ground immediately after harvest. Thompson 2007.
3336-9 We understand, the Rogue River-Siskiyou National Forest is required to Page 73 of the Chetco River Watershed Analysis describes broad opportunities for timber follow its forest plan, but the level of logging proposed at one time is harvest of green stands. It also describes opportunities for salvage but they are limited due beyond what was anticipated the Forest's Chetco Basin Watershed to the lack of large-scale disturbance. This watershed analysis was written in 1996. The Analysis. See for example page 73. Chetco Bar fire (a large-scale disturbance) occurred in 2017. There are now new opportunities for salvage.
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3336-1 We're concerned that the action alternatives proposed in the EA may The EA at 1-9 stated "The proposed project was determined to have no effect to water lead to the degradation of these outstanding values—especially when quality. The rationale for this determination is documented in the Hydrology section. The considered cumulatively with the extensive private land logging, with project incorporates a system of design features that ensure there can be no mechanism to the hazard tree logging on national forest land and with the effects of affect water quality. Some examples of design features to protect water quality include no- the Chetco Bar fire across 68% of the Chetco River's watershed. cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The EA at 1-10 stated "The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section." As regards the Chetco River fishery, the EA at 1-10 stated "The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish- bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section.
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3336-7 We're concerned that the proposed logging on Matrix land, and that The areas of heavy slash fuel loads and large slash piles were referencing private timber managing these lands for timber production, is likely to increase the risk property. There has been little regeneration harvest on public lands in the Chetco of future fires to local communities and to the national forest lands that watershed since the adoption of the NW Forest plan in 1994. This description was from the form the watershed of the Wild and Scenic Chetco River. fire behavior forecast from the Chetco Bar fire 2017. Harvest operations will contribute fine fuels, small diameter twigs and branches and unmerchentable tops, (slash) to the surface. Currently very little surface fuel remains as a result of the Chetco Bar fire. Soils and hydrology concerns require some amount of material to be left on site for resource protection. Project design criteria limit surface fuel accumulations to 12" depth or less throughout harvest units. Limiting fuel bed depth can enhance initial attack capabilities and success rates. Additionally, until live fuels (both brush and trees) occupy the site, fire spread will be limited by the lack of surface fuel continuity. Removing dead trees will also serve to improve access in the event of a future fire event. Previously burned trees (snags) are recognized as a threat to fire fighter safety during fire events. Harvest operations are recognized as contributing to increased surface fuel loading and reduced snag densities within harvest unit boundaries. Surface fuels from harvest operations will most likely be the biggest contribution to future fire risk for approximately 15 years, at which time decomposition will have reduced the continuity of surface fuels, and after live fuels, (both brush and trees) have completely occupied the site. Thompson et al 2007 points out, "young forests, whether naturally or artificially regenerated may be vulnerable to positive feedback cycles of high severity fire". It is expected that there will be a strong shrub response that can exacerbate surface fuel conditions (Albini 1976). Furthermore, ambient conditions, specifically temperature and humidity at the time of reburn followed by shrub cover will have the greatest impact on future fire severity (Coppoletta et al 2016). Reforestation in the action alternatives will also increase the continuity of fuels on the site. Appropriate species mix and planting densities will help to ensure that there is sufficient regeneration but only in amounts required to meet reforestation requirements.
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3336-7 Current guidelines are to achieve 125-150 trees at 4.5 feet tall per acre. The preferred continued method is for natural regeneration, artificial reforestation will occur where a natural seed source is not available. Young conifer regeneration will combine with shrub species to occupy the growing space on the site, when full site occupancy is realized, ambient conditions will determine when and if these live fuels are available to burn. It is anticipated that even with natural or artificial regeneration, the continuity of shrub layer will drive future fire events for the near term, overriding the influence of conifer regeneration in activity units. Allowing for unplanted areas, openings and planting at lower densities can serve to break up continuity of fuels and reduce future fires intensity and severity. In all, the effects of this treatment in terms of potential fire behavior are minimal due to the small acreage of treatments relative to the larger areas of high severity in the Chetco Bar footprint (EA Chapter 3 FIre, Fuels and Air Quality section).
3336-2 We're especially concerned that Riparian Reserves, steep slopes, areas Please refer to project design criteria in EA at Appendix A. These areas have been excluded above inner gorges, areas with the potential for landslides and areas from post fire salvage logging activities, with the exception of existing legacy templates if sensitive to surface erosion and soil loss should not be subject to reviewed and approved by a soil scientist, hydrologist, and/or fish biologist and can be further disturbance of the post-fire landscape until recovery has rehabilitated. Also, refer to response to comments 2989-15, 2990-38, and 3044-4. In sufficiently advanced. addition, the No Action alternative also addresses your concerns.
Brumo Abel 3352-1 I was on the Chetco River and surrounding land this winter, following There were reports this winter of elevated turbidity on the lower Chetco River. The source the fire, and I observed first-hand how devastating the fire was to some was identified to be active private log haul during winter storm events causing road fines to streams. The burned areas that were logged and the associated road be delivered to the road ditch and then to the Chetco River. Oregon Department of Forestry network in those area were horrendous, with huge amounts of notified the company of the situation. As mitigation measures, they placed additional road sediment being flushed into tributaries and the Chetco River. rock surfacing and put hay bales in the ditches to filter out fine sediment. Forest Service Additional road building, heavy equipment use, and removal of trees is resource specialist's field surveyed Chetco Bar high burn severity areas during winter storm not a wise decision or in the public interest events. The small streams in these areas were running clear with no signs of streambank or channel bottom instability. Larger streams below these areas were also clear. (EA Chapter 3 Hydrology section)
Palzer Bob
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3355-1 My name was inadvertently left off of the groups that signed on to the Thank you for your comment. comments submitted earlier today by Dominick DellaSala of the Geos Institute. I fully agree with them and consider me to be added to the groups as submitted.
Ullian Barbara 3361-1 Friends of the Kalmiopsis submitted scoping comments for the Chetco Scoping comments were addresses and used to develop the alternatives to the proposed Bar Salvage Project. I could not see if concerns raised during scoping action as well as project design criteria. were addressed in the EA so for the record, I'm submitting our scoping comments again. grmcmahan 3374-2 For example, Table 14 uses the acronym NLAA under Alternative 3 but Thank you for your comment, Table 14 has been edited to include definitions of the effects LAA under Alternative 2 without defining either term. Citizens would calls. benefit from a clearer summary of the technical basis for any decisions.
3374-3 While I support Alternative 2, and request for quick action, I must note The purpose of the project is to capture timber value in the matrix land allocations by that this entire E/A process IS NOT "serving people" OR "meeting the harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. (EA at needs of present and future generations". The "product" you are 1-4) seeking from these E/A proposals is completion of "the process", not solving the fuel load reduction issue that this E/A ignores and leaves behind for the "present and future generations". Apparently that is of little or no consequence to the Forest Service. Both the Forest Service Mission Statement AND Motto are empty words. Extreme fire risks to the Rogue River Siskiyou National Forest, the citizens and surrounding communities will not be reduced by these alternatives.The 2002 Biscuit Fire Scar was 23 miles from Brookings, the 2017 Chetco Bar Mega Fire scar is now only 5 miles from Brookings. The Forest Service may be content with this fact, I am not.
Page 203 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3374-1 With global climate change predicted to result in more extreme The purpose of this project is to capture timber value in the matrix land allocations by weather events including dryer conditions that can aggravate the harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at spread of fires and the potential for more catastrophic fires, I request 1-4). No where in the EA do we suggest that the proposed action would reduce potential for the US Forest Service (USFS) use this Salvage Project to mitigate to the future fires. In fact, the EA states " Fuel loading within the treatment units would increase greatest extent feasible, this increased risk of catastrophic fire to the immediately post-harvest. " The cumulative effects section of the EA states " Surface fuel Rogue River Siskiyou National Forest, Curry County and the general loading in both treated and untreated areas would accumulate post-fire, beginning to Brookings area. decline as early as 20 years post-fire within the activity units (Peterson 2014; Ritchie 2013). Treatment units will have greater fuel continuity after harvest, this can increase fire rates of spread. Reburn severity is often a concern after harvest activities. However, logging slash is only part of the fire risk story, and it may not be the most important after a few years. (Thompson et al, 2007) Adjacent untreated areas will retain lower fuel levels and high spatial heterogeneity which can aid in slowing fire growth. The proposed treatment areas account for only 2 percent of the high severity footprint of the Chetco Bar fire, and many of these high severity areas are in the immediate vicinity of treatment, it is expected that these treatments would have little effect on future fire management activities due to this fragmented nature of unit locations. The treatment units are relatively isolated and small in comparison to the larger, adjacent areas of moderate and high severity. This heterogeneity is important in terms of fire spread and improved conditions into the future. The project design criteria will allow for effective fire suppression activities without further treatment ."
Martel Kendal 3384-6 During the 2018 field season, we would like the Forest Service to work This comment is outside the scope of this project, however the request for collaboration with the WRCFC to coordinate a field trip to an oak stand in the Biscuit field trips has been forwarded to the appropriate forest service personnel. Fire area that did not undergo salvage. We would also like to see areas that were reburned in the Chetco Bar Fire. As the WRCFC continues to discuss zones of agreement on post fire management, field trips such as these will offer insight to the public and the WRCFC on the difference between where salvage occurred and did not occur on the landscape.
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3384-5 We support and encourage the use of post-harvest regeneration Thank you for your support. If natural regeneration is determined not to be adequate to surveys, site preparation, and tree planting. In addition to the species comply with the NFMA five-year regeneration requirement to achieve stocking levels listed for replanting, the collaborative supports and encourages species consistent with management objectives, site-specific appropriate tree species mix would be diversity in the replanting area, including western hemlock, grand fir, planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees and deciduous oak species as appropriate. per acre (EA at 2-4).
3384-3 We support retaining all trees in riparian reserves. If yarding corridors Thank you for your support. Salvage harvest will not occur in riparian reserves. are used, there should be no trees removed out of the riparian zone.
3384-2 We support road reconstruction and repair on the existing Thank you for your support. None of the alternatives evaluated propose any road transportation network. In addition, we would also like to see an reconstruction (EA at 2-4). Proposed road activities all fall within the road maintenance attempt to disconnect the stream system from the road system where category and are described in the EA at 2-3. applicable and achievable.
3384-1 We support the construction of short temporary roads only when Thank you for your support. No new temporary roads would be constructed within riparian resource values are considered, and impacts are mitigated. We reserves. Temporary roads would be closed and restored after salvage and related activities recommend prioritizing construction of these temporary roads in are complete (EA at 2-3). locations that will not deliver additional sediment to the stream system.
3384-4 We support the mechanisms for fuel reduction and disposal of slash, Thank you for your support. Mechanized equipment would be limited to slopes less than including hand piling, lop and scatter, chipping, mastication, and pile 30%. burning. However, we also recommend using machine piling only on landings due to the impact on already disturbed soils.
Dolle Alex
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3385-1 I do understand there is an economic reason for salvage logging, but Thank you for your comment. The EA states "Surface fuel loading in both treated and that argument should be fought on its own merits, not by exaggerating untreated areas would accumulate post-fire, beginning to decline as early as 20 years post- the degree to which salvage logging will protect other, non-burned fire within the activity units (Peterson 2014; Ritchie 2013). Treatment units will have greater forest. fuel continuity after harvest, this can increase fire rates of spread. Reburn severity is often a concern after harvest activities. However, logging slash is only part of the fire risk story, and it may not be the most important after a few years. (Thompson et al, 2007) Adjacent untreated areas will retain lower fuel levels and high spatial heterogeneity which can aid in slowing fire growth. The proposed treatment areas account for approximately 2 percent of the high severity footprint of the Chetco Bar fire, and many of these high severity areas are in the immediate vicinity of treatment, it is expected that these treatments would have little effect on future fire management activities due to this fragmented nature of unit locations. The treatment units are relatively isolated and small in comparison to the larger, adjacent areas of moderate and high severity. This heterogeneity is important in terms of fire spread and improved conditions into the future. The project design criteria will allow for effective fire suppression activities without further treatment. " (EA Chapter 3 Fire, Fuels and Air Quality section)
Ginther Dan 3386-1 As a third generation Oregonian I am deeply disappointed with the Thank you for your comment. limited efforts regarding the cutting of fire damaged timber. Any fire damaged tree that has potential for usefulness needs to be harvested. Far too long we have been wasting Oregon's natural source of revenue. Waste not, want not ...... need more be said?
Savoie Suzie
Page 206 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3392-9 California globe-mallow (Iliamna latibracteata) there are no currently A pre-field review was completed to determine areas of high probability habitat within the known occurrences of this species within the project area, but it could project planning area to survey specific sites for sensitive species. Field checks of potential move into the post-fire area. According to the CBF Salvage EA, habitat for sensitive species were completed during Burned Area Emergency Response California globe-mallow "prefers open canopied conditions but (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been sometimes is found in partial shade. Iliamna latibracteata is found completed on roughly 1,020 acres of high probability sensitive plant habitat within the almost exclusively within openings in recently-burned forests project footprint. Surveys will continue to occur through spring of 2018 and if any additional dominated by white fire (Abies concolor) or Douglas-fire (Pseudotsuga sensitive plant populations are found prior to implementation, mitigations for protection menziesii)." This species needs fire to reproduce and to keep the area would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, where it grows open and sunny enough to ensure long-term population SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this health. A full botanical survey for this species should be undertaken project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, prior to approval of the CBF Salvage project in order to locate live 2018). Effects to the six sensitive plant species, including Iliamna latibracteata are established plants and germinating seedlings within the project area. discussed in the EA Chapter 3 Botanical Resources section. Because California globe-mallow is fire-dependent, it is likely to thrive in the post-fire environment and perhaps even experience an increase in population and spread throughout the project area as long as salvage logging is not allowed to degrade its likely habitat.
3392-6 Gasquet manzanita (Arctostaphylos hispidula) 10 known occurrences A pre-field review was completed to determine areas of high probability habitat within the Gasquet manzanita, according to the CBF Salvage EA is a "fire project planning area to survey specific sites for sensitive species. Field checks of potential dependent species with refractory seeds (Emerson 2010; Keeley 1991)." habitat for sensitive species were completed during Burned Area Emergency Response This species needs fire to reproduce and to keep the area where it (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been grows open and sunny enough to ensure long-term population health. completed on roughly 1,020 acres of high probability sensitive plant habitat within the A full botanical survey for this species should be undertaken prior to project footprint. Surveys will continue to occur through spring of 2018 and if any additional approval of the CBF Salvage project in order to locate live established sensitive plant populations are found prior to implementation, mitigations for protection plants and germinating seedlings within the project area. Because would be developed EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, Gasquet manzanita is fire-dependent, it is likely to thrive in the post-fire SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this environment and perhaps even experience an increase in population as project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, long as salvage logging is not allowed to degrade its likely habitat. 2018). Effects to the six sensitive plant species, including Arctostaphylos hispidula , are discussed in the EA Chapter 3 Botanical Resources section.
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3392-7 Goldenfleece (Ericameria arborescens) 4 known occurrences A pre-field review was completed to determine areas of high probability habitat within the Goldenfleece, according to the CBF Salvage EA, "is known to occur in project planning area to survey specific sites for sensitive species. Field checks of potential openings of Douglas-fir forest; disturbance and fire are necessary for habitat for sensitive species were completed during Burned Area Emergency Response germination." This species needs fire to reproduce and to keep the area (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been where it grows open and sunny enough to ensure long-term population completed on roughly 1,020 acres of high probability sensitive plant habitat within the health. A full botanical survey for this species should be undertaken project footprint. Surveys will continue to occur through spring of 2018 and if any additional prior to approval of the CBF Salvage project in order to locate live sensitive plant populations are found prior to implementation, mitigations for protection established plants and germinating seedlings within the project area. would be developed (EA at 3-133, Appendix A at A-37, SP-3). Field surveys for sensitive and Because goldenfleece is fire-dependent, it is likely to thrive in the post- invasive plants are occurring simultaneously for this project and the "Danger Tree fire environment and perhaps even experience an increase in Abatement Along Roadsides" project (Categorical Exclusion, 2018). Effects to the six population and spread throughout the project area as long as salvage sensitive plant species, including Ericameria arborescens , are discussed in the EA Chapter 3 logging is not allowed to degrade its likely habitat. Botanical Resources section.
3392-10 Oregon bensonia (Bensoniella oregana) 4 known occurrences A pre-field review was completed to determine areas of high probability habitat within the According to the CBF Salvage project EA, Oregon bensonia prefers to project planning area to survey specific sites for sensitive species. Field checks of potential grow in "Seeps, springs, moist meadows and wet roadside ditches along habitat for sensitive species were completed during Burned Area Emergency Response upper slopes and ridges." Due to its propensity to grow within moist (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been areas it is likely that Oregon bensonia has persisted in the post-fire completed on roughly 1,020 acres of high probability sensitive plant habitat within the environment due to its fire-avoidance strategy of growing in moist project footprint. Surveys will continue to occur through spring of 2018 and if any additional locations. A full botanical survey for this species should be undertaken sensitive plant populations are found prior to implementation, mitigations for protection prior to approval of the CBF Salvage project in order to locate live, would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, established plants and germinating seedlings within the project area. SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this Because Oregon bensonia is a fire-avoider species, it is likely to thrive in project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, the post-fire environment and perhaps even experience an increase in 2018). Effects to the six sensitive plant species, including Bensoniella oregano , are population and spread throughout the project area as long as salvage discussed in the EA Chapter 3 Botanical Resources section. logging is not allowed to degrade its likely habitat.
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3392-8 Siskiyou or Coast checkerbloom (Sidalcea malviflora ssp. patula) 3 A pre-field review was completed to determine areas of high probability habitat within the known occurances According to the CBF Salvage EA, coast project planning area to survey specific sites for sensitive species. Field checks of potential checkerbloom is found in "Open woodlands, openings within mixed habitat for sensitive species were completed during Burned Area Emergency Response forests, meadows, or grassy places." Its preference for these fire (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been adapted habitat types shows that coast checkerbloom is a fire-adapted completed on roughly 1,020 acres of high probability sensitive plant habitat within the species that will most likely rebound and be stimulated by fire. A full project footprint. Surveys will continue to occur through spring of 2018 and if any additional botanical survey for this species should be undertaken prior to approval sensitive plant populations are found prior to implementation, mitigations for protection of the CBF Salvage project in order to locate live established plants and would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, germinating seedlings within the project area. Because coast SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this checkerbloom is fire-dependent, it is likely to thrive in the post-fire project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, environment and perhaps even experience an increase in population 2018). Effects to the six sensitive plant species, including Sidal cea malviflora ssp. patula , and spread throughout the project area as long as salvage logging is not are discussed in the EA Chapter 3 Botanical Resources section. allowed to degrade its likely habitat.
3392-11 Siskiyou trillium (Trillium kurabayashii) According to the CBF Salvage A pre-field review was completed to determine areas of high probability habitat within the project EA, Siskiyou trillium prefers to grow in "Coniferous forest, project planning area to survey specific sites for sensitive species. Field checks of potential woodland, and chaparral at low to mid elevations." Its preference for habitat for sensitive species were completed during Burned Area Emergency Response these fire adapted habitat types shows that Siskiyou trillium is a fire- (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been adapted species that will most likely rebound and possibly even be completed on roughly 1,020 acres of high probability sensitive plant habitat within the stimulated by fire. A full botanical survey for this species should be project footprint. Surveys will continue to occur through spring of 2018 and if any additional undertaken prior to approval of the CBF Salvage project in order to sensitive plant populations are found prior to implementation, mitigations for protection locate live established plants and germinating seedlings within the would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, project area. Because coast checkerbloom is fire-dependent, it is likely SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this to thrive in the post-fire environment and perhaps even experience an project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, increase in population and spread throughout the project area as long 2018). Effects to the six sensitive plant species, including Trillium kurabayashii , are as salvage logging is not allowed to degrade its likely habitat. discussed in the EA Chapter 3 Botanical Resources section.
3392-28 Cancel all logging units in complex, early seral habitat, undeveloped Alternative 3 addresses your concerns. areas, and post-fire foraging habitat for the Northern spotted owl (NSO).
3392-20 Cancel artificial tree regeneration (i.e. tree planting) in order to avoid The intent is to rely on natural regeneration wherever possible. If natural regeneration is the development of plantation stands and the associated increased fuel determined not to be adequate to comply with the NFMA five-year regeneration loads. requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. EA at 2-4.
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3392-18 Cancel the project and consider an approach that is focused on the The purpose of the project is to capture timber value in the matrix land allocations by protection of communities and residences in future fires. harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4). The No Action alternative addresses your concerns.
3392-26 Cancel units in the Mineral Hill Fork, the watershed is steep and highly The No Action alternative addresses your concerns. unstable.
3392-25 Cancel units surround Packers Cabin and on long ridge, on road 1376 The No Action alternative addresses your concerns. near near High Prairie, the complex, early-seral forests in Quail Prairie Creek and along Devils Backbone
3392-4 Cumulative Impacts of Private Land Logging Salvage logging on nearby private lands was described in the EA at 3-3. Additionally, the temporal and spatial scale of analysis is variable depending on the resource concern being evaluated, particularly when considering the effects of past, present, and reasonably foreseeable actions. During the interdisciplinary process the team followed guidance presented in CEQ's letter dated June 24, 2005 regarding past actions. Using this guidance the EA provided summary of past, present, and reasonably foreseeable actions within and adjacent to the CBF Salvage project area . These projects were considered where relevant, when addressing the cumulative effects for various resources.
3392-24 Do not build any new logging roads, either so-called "temporary roads," The No Action alternative addresses your concerns. or permanent roads.
3392-23 Do not log in "geologic" Riparian Reserves or on unstable, highly None of the alternatives propose ground based salvage logging on unstable or highly erodible soils. erodible soils.
3392-22 Do not log in Riparian Reserves. The large wood deposited in streams None of the alternatives propose salvage logging in riparian reserves. from fire-killed snags is very important for long-term stability, water quality, water quantity and habitat values.
Page 210 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3392-12 In order to protect this possible northern migration each and every The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage single redwood tree in Chetco Watershed should be given buffers and harvest under the action alternatives. The species being targeted for salvage under the protection during project implementation. The CBF Salvage project area action alternatives include Douglas fir and incense cedar, therefore they have been included contains numerous populations of redwoods as well as individual in Table 3. No other species would be targeted for salvage removal. However, any tree, random trees. These areas include a significant population on regardless of species, that is determined to be a hazard to operations may be removed for Snaketooth Butte and at least one individual tree on the roadside in the safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as Quail Prairie Creek Watershed adjacent to road 1909; however, per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and redwoods could be hidden and undiscovered in other areas within the marking guidelines for more information about the species targeted for salvage harvest and project area and there was no mention of a detailed botanical survey snag and down wood retention levels. Regarding Redwood Trees: The southern portion of for redwoods within the EA. There should be a specific redwood tree the Chetco Bar fire is located within the northern boundary of the redwood ( Sequoia inventory done by trained botanists within the project area in order to semperviren ) range. Proposed treatment units are located outside of areas with natural capture the true presence of redwoods and to be able to buffer and redwood canopy cover, though old district maps show some managed stands planted with protect these important biological legacies. redwood (e.g. east of Basin Creek and south of Panther Creek) (Silvicultural Prescription p. 2). Therefore, pockets of naturally occurring redwood exist within the project area but not within the project footprint (where ground disturbing activities are proposed). Several proposed treatment units have had redwood planted as a managed species. Most of these planted redwood trees are exhibiting sprouting, and epicormic branching. Regardless of the amount of green needles remaining, redwood trees would be retained, unless they pose a safety or operational concern as described above. If deemed a hazard to operations, they would be felled and left on site.
3392-27 Maintain large patches of unlogged snag forest, even in Matrix lands, All alternatives maintain large patches of unlogged snag forest. The Proposed Action for habitat and stand complexity, and the maintenance and integrity of alternative proposes the most salvage logging and it impacts less than 2.5 percent of the fire native plant communities. on national forest system lands.
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3392-3 Matrix Lands Are Not Sacrifice Zones The impact of post-fire logging None of the alternatives evaluated here include any actions (except haul routes on existing and replanting will degrade water quality in one of the region's clearest, roads) in the Wild and Scenic Chetco River Corridor. The proposed project was determined most pure waterways: the Chetco River. It will also increase fuel loading to have no effect to water quality. The rationale for this determination is documented in the and future fire severity, impact natural forest regeneration, reduce Hydrology section. The project incorporates a system of design features that ensure there habitat complexity, and compromise long-term forest health for short- can be no mechanism to affect water quality. Some examples of design features to protect term timber values. Although the project is located in "matrix" water quality include no-cut riparian buffers on both sides of all streams, conditional lands, allocated for timber production, the impacts to local fisheries, restrictions on the haul of salvaged timber, and improving the drainage features of the road water quality and scenic values will outweigh any potential economic system that might be utilized for haul. For more information refer to the Hydrology section. benefit from selling low-priced salvaged timber. (EA at 1-9) The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea- run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. The proposed project was determined to have no effect to recreation settings or opportunities in the Chetco Wild and Scenic River corridor. The rationale for this determination is documented in the Recreation and Visual Resources section. The project incorporates a system of design features that protect recreation settings and opportunities, examples of which include haul restrictions during high-use times, provisions protecting public access to recreation sites and areas, and implementation techniques to minimize scenic effects of project activities. For more information refer to the Recreation and Visual Resources section. (EA at 1-10)
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3392-16 Non-Native, Noxious, and Invasive Plant Spread is Likely The SCNPSO The EA discusses the seven invasive plant species known to occur within the project is also concerned about the likely spread of noxious and invasive plant footprint that are likely to spread. These include Centaurea solstitialis (Yellow Star-thistle), species due to logging activity. Because the proposal includes over Cirsium vulgare (bull thistle), Cytisus scoparius (Scotch broom), Hedera helix (English Ivy), 4,000 acres of logging, there is a strong possibility that a large portion Rubus armeniacus (Himalayan blackberry), Rubus laciniatus (cutleaf blackberry), and of the Chetco River Watershed will see huge increases in noxious and Senecio jacobaea (tansy ragwort) (EA Table 34). The EA discusses the environmental invasive plant species. Soil disturbance at this scale is surely going to consequences of invasive plant spread due to the proposed action alternatives (EA Chapter result in massive noxious weed spread. The EA did not adequately 3 Invasive Plants section). Project Design Features were designed to limit the spread of disclose what noxious weeds and invasive plants are likely to be an invasive plant species (EA Appendix A, A-37- A38; PDF No. IV-1-8). Project Design Features issue and what the Forest Service will do to limit the spread of non- include washing equipment; avoiding invasive plant infested landings; using only weed free native, noxious, and invasive plant species. Scaling back the project is gravel sources, seed and straw; including an invasive plant locator map in the sale area map the best way to limit likely spread. and project file; and prioritizing monitoring and post-treatment of invasive plant species within the project area for at least 5 years after completion.
3392-1 Post-Fire Logging Has Negative Impacts Authoritative scientific The effects of the alternatives are described in the EA, Chapter 3. evidence from the Klamath-Siskiyou Mountain Ecoregion has consistently shown that post-fire logging and tree plantation development increases fuel loads, impacts forest regeneration, degrades biodiversity, reduces habitat complexity and negatively affects water quality. If the scale of post-fire logging laid out in the Chetco Bar Salvage Proposed Action (Alternative 2) is implemented, the same impacts will take place in the incredible Chetco River Watershed.
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3392-2 Post-Fire Tree Planting Prior studies of the Biscuit Fire area showed Current Forest direction for the Chetco Bar fire is to delay artificial regeneration and survey rapid conifer establishment from natural seed sources that exceeded for natural regeneration post-salvage to determine if stocking levels are sufficient to meet those of planted areas (Donato et al., 2006, Campbell et al. 2010). the NFMA five-year regeneration requirement to stocking levels consistent with Studies of Biscuit Fire salvage logging also showed that post-fire logging management objectives. The Forest is planning to develop a post-fire reforestation strategy killed most of the natural regeneration by removing biological legacies that will address tree planting density in the context of susceptibility to future high severity (Donato et al. 2006). The SCNPSO encourages the Forest Service to let fires, climate change and land allocation management objectives. Negative impacts to the Chetco Bar Fire area recover naturally after the fire without any natural conifer regeneration from salvage logging is not likely to be a long-term problem tree planting due to the prolonged period of natural conifer recruitment post-fire that occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon State University researcher found that conifers continue regenerating 10 to 15 years after a fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' research "suggests that early salvage logging may not make much difference to regeneration in the long run because they found that successful and abundant conifer recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetation section)
3392-29 Redo the cumulative effects section of the EA. Roadside hazard tree The Roadside Danger Tree Abatement CE was included in the cumulative effects section of removal is not reported as a cumulative impact in the EA even though the EA under summary of present actions, EA at 3-3. Additionally, each resource section over 100 miles in the project area will be negatively impacted by described cumulative effects of the Danger Tree removal where effects overlapped in time roadside hazard logging. A separate Categorical Exclusion is not and space. sufficient for dismissing the cumulative impacts of roadside hazard logging within the CBF Salvage project.
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Name Comment Text Response Text
3392-14 Sudden Oak Death and POC Root Rot The CBF Salvage project EA did In compliance with the Record of Decision for the Land and Resource Management Plan not adequately address sudden oak death or Port Orford-cedar (POC) Amendment for Management of Port-Orford-cedar in Southwest Oregon, Siskiyou National root rot. Both Sudden Oak Death and POC Root Rot are present in the Forest (USDA Forest Service 2004) a POC risk analysis has been documented using the risk Chetco and Pistol River Watersheds. key. The risk key is in the project record and is used to clarify the environmental conditions that require implementation of one or more of the disease controlling management practices listed in the LRMP amendment. Project design criteria described in chapter 2 would minimize or eliminate the risk of spreading PL. Therefore there would be no direct or indirect effects to the spread of PL. Salvage logging and other connected actions may increase the risk of spreading SOD. Project design criteria described in chapter 2 would minimize or eliminate the risk of spreading SOD. Therefore there would be no direct or indirect effects to the spread of SOD. (EA Chapter 3 Vegetation section)
3392-5 The EA provides no supporting documentation that can prove or back A pre-field review was completed to determine areas of high probability habitat within the up the EA's claim that burned areas are no longer capable of supporting project planning area to survey specific sites for sensitive species. Field checks of potential populations of sensitive plant species. habitat for sensitive species were completed during Burned Area Emergency Response (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been completed on roughly 1,020 acres of high probability sensitive plant habitat within the project footprint. Surveys will continue to occur through spring of 2018 and if any additional sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018).
3392-15 The impact of the Chetco Bar Fire and the proposed logging activities Salvage logging and other connected actions may increase the risk of spreading SOD. Project could also spread Sudden Oak Death, but little is known about the design criteria described in chapter 2 would minimize or eliminate the risk of spreading SOD. pathogen and its response to the fire and post-fire logging. More Therefore there would be no direct or indirect effects to the spread of SOD. (EA Chapter 3 research and a better understanding of SOD needs to be undertaken Vegetation section) before a project of this scale, with possible massive ecological impacts is undertaken.
Page 215 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3392-21 The project currently does not propose any post-fire logging in LSR None of the alternatives propose salvage logging in late successional reserves or Inventoried forest, Inventoried Roadless Area or Key Watersheds. Please do not Roadless areas. consider any of these land management designations for post-fire logging in the Record of Decision for this project.
3392-19 The project currently proposes to maximize timber production and The effects to fuel loads are described in the EA, Chapter 3 Fire, Fuels and Air Quality create highly flammable tree plantation stands. Fuel loads and fire risks section. will be heightened in the future by this project by encouraging dense, even-aged vegetation.
3392-13 The SCNPSO is concerned about the ability of redwoods to persist and Refer to the response to comment 3392-12. The redwood stand in Little Redwood thrive in the Chetco Bar Fire area due to proposed roadside hazard Campground is not part of this project, therefore it is outside the scope. However, your logging and salvage logging in the area. Even if trees are identified and point is well taken and slash piles should have adequate space to consume the slash while marked, there still needs to be an official policy that outlines project not damaging residual trees. design features that will give redwoods wide buffers during project implementation. Additionally, as of March 2018, many recovering redwood trees at the Forest Service's Little Redwood Campground were in danger of being burned from the very large slash/burn piles created along North Bank road.
Wells Greeley 3395-3 Cancel all artificial reforestation units. The intent is to rely on natural regeneration wherever possible. If natural regeneration is determined not to be adequate to comply with the NFMA five-year regeneration requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. Additionally, the No Action alternative addresses your concerns.
Page 216 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3395-8 Cancel all new road construction to protect aquatic habitats and water No new road construction is proposed under any alternative. There would be a maximum of quality in the Chetco River watershed. 13.5 miles of temporary road constructed under Alternative 2, and 9.4 miles of temporary road constructed under Alternative 3. From the 13.5 miles of temporary road proposed under Alternative 2, 1.3 miles is new construction. The No Action alternative does not propose temporary roads.
3395-1 Cancel all post-fire logging units in complex, early successional habitat Alternative 3 addresses your concerns and does not propose salvage in complex, early seral throughout the planning area. habitat.
3395-7 Cancel all units in Post-Fire Foraging habitat for the Northern spotted Alternative 3 addresses your concerns and does not propose salvage in post-fire foraging owl. habitat for Northern Spotted Owl.
3395-4 Cancel all units in Quail Prairie Creek, Mineral Hill Fork, Eagle Creek, The No Action alternative addresses your concerns. around Packer's Cabin and Long Ridge, above the Chetco River, near High Prairie above Road 1376, and above Mislatnah Creek.
3395-2 Cancel all units in undeveloped areas identified in the planning area. Alternative 3 addresses your concerns and does not propose salvage in undeveloped lands.
3395-6 Cancel all units that will impact the viewshed for recreational users No salvage activities are proposed in the Chetco Wild and Scenic River corridor or in any along the Chetco River and its tributaries. other areas with retention or preservation VQOs. Project design criteria would ensure activities achieve VQOs without affecting the character and setting of the landscape as seen from the Chetco River. Salvage units would be visible in the immediate foreground and middleground from portions of primary travel routes (FSRs 1107, 1376, 1407, 1909, 1917), Forest Service Trail (FST) 1103, and Packers Cabin Recreation Rental. Visual effects would include machinery, personnel, piles, and exposed soil during active operations, and stumps and slash afterwards. These effects would gradually become less evident, but would likely be visible for 10-15 years or more depending on local understory regeneration. However, adherence to project design criteria (PDCs) would ensure that effects become subordinate to the natural landscape character within the prescribed timeframe to attain the applicable VQOs of partial retention and modification. Additionally, the No Action alternative addresses your concerns.
Page 217 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
3395-5 Conduct activities that provide for public safety, maintain undeveloped The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix habitats, encourage complex, early successional forests, biodiversity, land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 and create more fire resilient habitats adjacent to the community of Chetco Bar fire (EA at 1-4). Brookings. Backcountry logging and artificial reforestation provides absolutely no benefit to communities at risk in the Brookings area.
Burke Mike 3396-1 Is it possible to get on the bidder's list for timber sales from this project, Your contact information has been forwarded to the appropriate personnel. including appraisal summaries?
Whitaker Beth 3412-2 I oppose post-fire clearcut logging and new road construction in this The No Action alternative addresses your concerns. Watershed. Please do not convert post-fire native forests into second- growth timber plantations, rather work with the public to focus management near homes and communities while protecting remote backcountry forests and tributaries.
3412-1 I would like to see restoration of the wilderness qualities of this special The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix place. land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire. (EA at 1-4) Mitman June 3449-1 Building roads and increasing any kind of logging in the area will cause No new road construction would occur under any alternative. About 13.5 miles of tremendous, irreversible damage to water quality, fish, wildlife and temporary roads would be constructed and rehabilitated after use. Of these 13.5 miles, plant communities, as has happened throughout Oregon's Coast Range. about 1.3 miles are new, the remaining are existing road templates that will be re-used. The effects of the project are displayed in Chapter 3. Specifically, there would be no impact to water quality or fish. Impacts to wildlife and plant species vary by species and are displayed in the EA, Chapter 3.
3449-2 It opens the area to vandalism, illegal dumping, damage from off road The effects the project would have on invasive species and plant diseases are described in vehicles, more human-caused fires, plant and wildlife poaching, invasive the EA, Chapter 3 Invasive Plants section. Because no new road construction is occurring, species, and plant diseases (to name a few of the problems it will and any temporary roads would be decommissioned and rehabilitated there would be no cause). increase in road miles or densities. Therefore the project is not expected to open the area to vandalism, illegal dumping, damage from off road vehicles, more human-caused fires, and plant and wildlife poaching.
Page 218 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Hanley Laurel 3471-1 A forest fire is NOT an excuse for logging an area. Let it recover The No Action alternative addresses your concerns. naturally, and IT WILL! Please wisely use the power of your management position and be a steward, not an exploiter, of this land.
Rittenhouse- Serena Barry 3498-5 Cancel all artificial reforestation units. Natural tree regeneration The intent is to rely on natural regeneration wherever possible. If natural regeneration is provides adequate reforestation, creates a healthy habitat mosaic, determined not to be adequate to comply with the NFMA five-year regeneration harbors higher levels of biodiversity, and provides more patchy, fire requirement to achieve stocking levels consistent with management objectives, site-specific resilient, early-seral habitats than artificial reforestation. appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. Additionally, the No Action alternative addresses your concerns.
3498-4 Cancel all new road construction to protect aquatic habitats and water No new road construction is proposed under any alternative. There would be a maximum of quality in the Chetco River watershed. 13.5 miles of temporary road constructed under Alternative 2, and 9.4 miles of temporary road constructed under Alternative 3. From the 13.5 miles of temporary road proposed under Alternative 2, 1.3 miles is new construction. The No Action alternative does not propose temporary roads.
3498-1 Cancel all post-fire logging units in complex, early successional habitat Alternative 3 addresses your concerns and does not propose salvage in complex, early seral throughout the planning area habitat.
3498-3 Cancel all units in Post-Fire Foraging habitat for the Northern spotted Alternative 3 addresses your concerns and does not propose salvage in post-fire foraging owl. habitat for Northern Spotted Owl.
3498-6 Cancel all units in Quail Prairie Creek, Mineral Hill Fork, Eagle Creek, The No Action alternative addresses your concerns. around Packer's Cabin and Long Ridge, above the Chetco River, near High Prairie above Road 1376, and above Mislatnah Creek.
3498-2 Cancel all units in undeveloped areas identified in the planning area Alternative 3 addresses your concerns and does not propose salvage in undeveloped lands.
Page 219 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3498-8 Cancel all units that will impact the viewshed for recreational users No salvage activities are proposed in the Chetco Wild and Scenic River corridor or in any along the Chetco River and its tributaries. Recreation on the Chetco other areas with retention or preservation VQOs. Project design criteria would ensure River helps sustain the economy of southern Oregon's coastal activities achieve VQOs without affecting the character and setting of the landscape as seen communities. Logging public land will diminish the recreational from the Chetco River. Salvage units would be visible in the immediate foreground and experience along the Wild and Scenic Chetco River and its tributaries. middleground from portions of primary travel routes (FSRs 1107, 1376, 1407, 1909, 1917), Forest Service Trail (FST) 1103, and Packers Cabin Recreation Rental. Visual effects would include machinery, personnel, piles, and exposed soil during active operations, and stumps and slash afterwards. These effects would gradually become less evident, but would likely be visible for 10-15 years or more depending on local understory regeneration. However, adherence to project design criteria (PDCs) would ensure that effects become subordinate to the natural landscape character within the prescribed timeframe to attain the applicable VQOs of partial retention and modification. Additionally, the No Action alternative addresses your concerns.
3498-7 Conduct activities that provide for public safety, maintain undeveloped The purpose of the Chetco Bar Fire Salvage project is to capture timber value in the matrix habitats, encourage complex, early successional forests, biodiversity, land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 and create more fire resilient habitats adjacent to the community of Chetco Bar fire (EA at 1-4) Brookings. Backcountry logging and artificial reforestation provides absolutely no benefit to communities at risk in the Brookings area.
Johnson Bonnie 3501-1 Help our Chetco River watershed - don't make the horrible mistakes of The effects to soils are described in the EA, Chapter 3 Soils section and vary depending on the past in salvage cutting that makes it impossible for our native the type of harvest method. The effects to reforestation are also described in the EA, forests to recover. Compacting the earth, crushing native seeds, Chapter 3. Additionally, the hydrology section in Chapter 3 states "There are no measurable causing horrible erosion. Please don't do it!! direct, indirect, or cumulative effects to erosion or sedimentation, peak flows, stream temperature, or waterbody condition expected from the Chetco Bar Fire Salvage project because there are no effects to the measures used to predict potential effects."
John Jessica 3509-1 What may be being overlooked in this effort to extract financial gains The Proposed Action alternative would salvage harvest standing dead or dying trees 7 from this fire is the priceless value of trees that were damaged but inches diameter at breast height (DBH) and greater. The Proposed Action alternative would withstood the fires. salvage harvest less than 2.5 percent of the burned area on National Forest System lands. Additionally the No Action alternative addresses your concerns.
Page 220 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text bethmark 3520-1 Given all the information I have read and from what I have witnessed as Thank you for your comment. a concerned southern Oregon resident of 45 years, is that the Chetco River and it's watershed must be protected and only Alternative 3 gets any way near to this task.
Nelson Christie
3523-1 Specifically, Riparian Reserves, steep slopes, areas above inner None of the action alternatives propose salvage logging in riparian reserves, and unstable gorges, areas with the potential for landslides and areas sensitive areas. No ground based logging methods are proposed on slopes greater than 30%. to surface erosion and soil loss should not be subject to further Additionally, the No Action alternative addresses your concerns. disturbance - these areas should be out of bounds for post-fire logging.
Scott Gabriel
Page 221 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-4 Alternative 2 would log 2,222 acres of unmanaged early seral habitat Under the Proposed Action alternative, approximately 2,222 acres of unmanaged stands with biological legacies. It is ridiculous to say that over two thousand (1.5% of the unmanaged NFS lands) are planned for salvaging and potentially artificial acres of these impacts is not significant. reforestation if natural regeneration is not sufficient. It is considered not significant because of the following: The Chetco Bar fire burned 191,197 acres. Of that 89 percent (170,321 acres) are on National Forest System (NFS) lands. Within the 170,321 acres on NFS lands, about 86 percent (146,261 acres) are unmanaged stands. The Proposed Action alternative would affect about 1.5% of unmanaged stands. At the fire scale, currently about 30% (43,745 acres) of the 146,260 acres of unmanaged NFS lands within the Chetco Bar fire are considered early seral habitat, well above the NRV of 7.9% to 11.6% . Additionally, the Proposed Action alternative would affect about 5% of the existing early seral habitat. The 2,222 acres (1.5%) of salvaged and planted unmanaged stands are within matrix allocations where timber harvest and other silvicultural activities should be conducted, according to standards and guidelines. These areas after salvage, will still be considered early seral habitat but are expected to lose their diversity in species, processes, and structure (complexity). Traditional forestry activities (eg clearcutting or post-disturbance logging) reduce the species richness and key ecological processes associated with early-successional ecosystems; other activities, such as tree planting, can limit the duration (eg by plantation establishment) of this important successional stage (Swanson et al. 2011). The 2,222 acres of salvaged and planted unmanaged stands are also expected to become established more rapidly than naturally seeded acres, limiting the duration spent in the early seral stage. (EA at Chapter 3, Comlex Early Seral Habitat section)
3538-12 Cumulatively, the impacts of this project would be significant on aquatic The EA found that the action alternatives evaluated in Chapter 3 had no effect to critical habitat. Increased sedimentation from logging, road building and log habitat for SONCC coho salmon. If no direct or indirect effects are anticipated from the haul; loss of large woody debris; and extensive use of the action alternatives, then no cumulative effects can occur from the proposed activities. transportation system would degrade watershed conditions. In light of the imperiled nature of fish species, and the incredibly high recreational values of the Chetco, these effects ought to be considered significant.
Page 222 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-6 EA p.3-9. Please carefully consider the myriad ways that natural Currently, post-fire vegetation is predominantly tanoak naturally regenerating through regeneration functions, as opposed to clearcutting and planting. There sprouting and seed across the burned area. Unfortunately, tanoak is the primary host in are very real benefits to slower forest re-establishment. There is no Oregon of the non-native pathogen, Sudden oak death (SOD), Phytophthora ramorum. doubt that soils in these areas would be in better condition with natural Statewide SOD occurs only in the forests of southwest Curry County (and within the fire regeneration. area), where it is well adapted to mild, wet coastal conditions. Potential Vegetation Type (PVT) mapping for most of the Chetco Bar fire area is Tanoak/ Douglas-fir-moist which reflects site potential of future vegetation development in this drainage. Aggressive management strategies are currently in place to slow the spread of SOD; however, Forest Health protection pathologists anticipate the disease will continue to cause tanoak mortality in moist tanoak forests now and into the future. As tanoak is a prolific sprouter and a fast-growing species, tree planting may be necessary for species other than tanoak to become established and dominate the canopy in the short term. Artificial regeneration (planting) of non-bole hosts may help to slow SOD spread. Breaking up large continuous areas of tanoak in structure and species composition will change disease spread dynamics by slowing initial local disease spread, reducing inoculum levels overall, and reducing the probability of long-distance spread, while still maintaining tanoak on the landscape (Goheen, 2018). Current Forest direction for the Chetco Bar fire is to delay artificial regeneration and survey for natural regeneration post-treatment to determine if stocking levels are sufficient to meet the NFMA requirement: '(E) insure that timber harvested from National Forest System lands only where - (ii) there is assurance that such lands can be adequately restocked within five years after harvest;'. The Forest's intent is to rely on natural conifer regeneration wherever possible. The Forest Service is proposing to salvage harvest 4,090 acres burned in the 191,197-acre Chetco Bar Fire. There are 170,321 acres on National Forest System Land within the fire area of which 81,344 acres are in the Kalmiopsis Wilderness Area. The proposed action will treat approximately 2.4% of NFS lands leaving most of the fire area to naturally regenerate.
Page 223 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-13 Effects to the spotted owl would be significant. Please consider them in This environmental assessment (EA) was prepared to determine whether implementation of an EIS. CBF project may "significantly" affect the quality of the human environment and thereby require the preparation of an environmental impact statement. Preparation of this EA fulfills agency policy and direction to comply with the National Environmental Policy Act (NEPA). (EA at 1-4) The legal standards for ESA determinations and NEPA findings of significance are different. Although an ESA determination may influence a NEPA finding, it does not determine NEPA "significance." A potential impact on an ESA-listed species or its habitat does not automatically mean "significance" in terms of a NEPA finding, nor does it automatically result in the need for a "higher" level of NEPA documentation (CE vs. EA vs. EIS). The project design minimized impacts of removing PFF habitat by limiting the removal of PFF with the highest likelihood of use by NSO based on current research EA Chapter 3 Wildlife section. The Forest minimized the amount of PFF1 with high RHS that would be affected by the project. Of the PFF that would be affected by the project, approximately 70 percent is PFF with the lowest likelihood of use by NSO because it is beyond 500 ft of existing NRF which is considered to be beyond the burned and unburned edge habitat that is most likely to be used by NSO. This secondary PFF (PFF2) habitat is also in a topographic position with low relative habitat suitability (RHS) that is less likely to be used by nesting owls (e.g. ridgelines). Project design criteria to retain large legacy snags in PFF consider proximity to NRF and RHS and the likelihood of PFF to be used by NSO. (EA Appendix A at A- 1) Of nine NSO home ranges affected by the project, seven would have no change in proportion of PFF1, and two would have 1 percent or less reduction in low RHS PFF1. Seven home ranges would have a reduction in total PFF2; site 142 would have a 1 percent reduction, site 307 would have a 4 percent reduction, and the other 5 sites would have a 2 percent reduction. (EA Table 13) The proposed action would remove approximately 921 acres (BA Table 13) which is 9 percent of PFF habitat in the NSO action area and 5 percent of available PFF habitat within the KLW3 critical habitat subunit.
Page 224 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-13 This also takes into consideration the removal of PFF for the roadside danger tree project. continued This is a small proportion of the PFF habitat now available in the fire, and all existing NRF habitat would remain. The small amount of PFF habitat removed by the proposed project is expected to have a small degree of impact to spotted owls as explained in the project Biological Opinion (BO) that does not result in "significance" under NEPA. The BO for this project reached the conclusion that "the proposed action may adversely affect, but is not likely to jeopardize the continued existence of the spotted owl…and is not likely to adversely modify their critical habitat". (Project BO at 68) Based on consideration for proposed removal of up to 921 acres of previous NRF that burned, the Service concludes a "reasonable likelihood of harm to two known sites and one potential site." Recent spotted owl demographic data indicates the likelihood of occupancy of the three sites would be 19 percent or approximately one owl. For this reason, the impacts of the project are "not expected to affect the overall resiliency of the population of owls at the province or rangewide scales." (Project BO at 69)
3538-10 It is not accurate or responsible to say that "design features …ensure Project design criteria, best management practices, and mitigation measures for the soil there can be no mechanism to affect water quality," aquatic habitat or resource have been developed at the project scale for the Chetco Bar Fire Salvage project recreation. EA 1-9. There is no scientific citation given for that and are based on local conditions and Siskiyou National Forest Plan direction (Soils Resource incredible statement. Its credibility is further undermined by the fact Report at pages 1-2, 24-26, 35 in the project file). In addition, the latest findings from the that none of these specific design features are actually being explained National Best Management Practices (BMPs) Monitoring Summary Report for the Pacific or applied. The public is simply supposed to assume the agency will, at Northwest Region, USDA Forest Service (USDA, 2018) have been added into the Soils some point, come up with and require design features that preclude Report. The Soils Report (page 24) shows that the implementation and effectiveness of negative impacts. But even the best mitigation measures and BMPs do Mechanical Vegetation Management Activity BMPs and design features has been greater not eliminate most impacts. Certainly this is not the case with the than or equal to 80% for the 2015 to 2016 National BMPs Monitoring Summary Report transportation system and streams. Minimizing in-water work, for (USDA, 2018). Please refer to the Soils Report, page 24 in the Project Record to read full example, does not eliminate in-water work. Adopting wet weather discussion requirements, restricting ground-based harvest on steep slopes, and similar logging BMPs similarly are good and wise things to do, but in no case do they eliminate impact.
Page 225 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-2 Please prepare an EIS that encompasses ecological restoration goals The purpose of this project is to capture timber value in the matrix land allocations by harvesting dead, dying and/or damaged trees resulting from the 2017 Chetco Bar fire (EA at 1-4). Ecological restoration is not part of this project. This environmental assessment (EA) was prepared to determine whether implementation of CBF project may "significantly [1] " affect the quality of the human environment and thereby require the preparation of an environmental impact statement. Preparation of this EA fulfills agency policy and direction to comply with the National Environmental Policy Act (NEPA). (EA at 1-4) [1] Significance as defined by context and intensity of an action.
3538-16 Post-fire botanical surveys were not done for this project, "because of A pre-field review was completed to determine areas of high probability habitat within the the low potential for detection [of sensitive plants] due to the severity project planning area to survey specific sites for sensitive species. Field checks of potential of the fire in relation to the quality of the habitat." EA 3-133. However, habitat for sensitive species were completed during Burned Area Emergency Response there appear to be a large number of sensitive botanical species that (BAER) reconnaissance immediately following the fire. Pre-disturbance surveys have been would be expected to occur in fire-disturbed areas. These surveys need completed on roughly 1,020 acres of high probability sensitive plant habitat within the to be done. Without the surveys, impacts to these sensitive species are project footprint. Surveys will continue to occur through spring of 2018 and if any additional highly uncertain and therefore even more significant than otherwise. sensitive plant populations are found prior to implementation, mitigations for protection would be developed (EA Chapter 3 Botanical Resources section, and EA Appendix A at A-37, SP-3). Field surveys for sensitive and invasive plants are occurring simultaneously for this project and the "Danger Tree Abatement Along Roadsides" project (Categorical Exclusion, 2018).
Page 226 of 341 Chetco Bar Fire Salvage Project Comment Analysis
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3538-7 Post-fire logging has major negative impacts on the ability of stands to Negative impacts to natural conifer regeneration from salvage logging is not likely to be a naturally regenerate, and this natural regeneration has a host of long-term problem due to the prolonged period of natural conifer recruitment post-fire that benefits that would be lost under the proposed action. Even high- occurs in the Klamath-Siskiyou region. Key findings from a research paper from an Oregon severity fire patches generally will regenerate naturally. The EA State University researcher found that conifers continue regenerating 10 to 15 years after a incorrectly argues that faster logging and planting would speed fire (Hibbs 2009). Some have argued that early salvage logging post-fire can damage the regeneration because delays in logging would cause hardwoods and chances of successful recovery because the logging itself kills emerging seedlings. Hibbs' shrubs to out-compete conifers. This argument however disregards the research "suggests that early salvage logging may not make much difference to importance of hardwoods and shrubs to overall forest regeneration and regeneration in the long run because they found that successful and abundant conifer resilience. See e.g. (Amaranthus & Perry 1989, Amaranthus et al. 1990; recruitment continues for years, even after severe fire." (EA Chapter 3 Vegetaton section) Borchers & Perry 1990, Perry et al. 1989); (Conrad et al. 1985) Currently, post-fire vegetation is predominantly tanoak naturally regenerating through (Ceanothus enhances associated tree growth); (Horton & Parker 1994). sprouting and seed across the burned area. Unfortunately, tanoak is the primary host in Oregon of the non-native pathogen, Sudden oak death (SOD), Phytophthora ramorum. Statewide SOD occurs only in the forests of southwest Curry County (and within the fire area), where it is well adapted to mild, wet coastal conditions. Potential Vegetation Type (PVT) mapping for most of the Chetco Bar fire area is Tanoak/ Douglas-fir-moist which reflects site potential of future vegetation development in this drainage. Aggressive management strategies are currently in place to slow the spread of SOD; however, Forest Health protection pathologists anticipate the disease will continue to cause tanoak mortality in moist tanoak forests now and into the future. As tanoak is a prolific sprouter and a fast-growing species, tree planting may be necessary for species other than tanoak to become established and dominate the canopy in the short term. Artificial regeneration (planting) of non-bole hosts may help to slow SOD spread. Breaking up large continuous areas of tanoak in structure and species composition will change disease spread dynamics by slowing initial local disease spread, reducing inoculum levels overall, and reducing the probability of long-distance spread, while still maintaining tanoak on the landscape (Goheen, 2018).
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3538-7 Current Forest direction for the Chetco Bar fire is to delay artificial regeneration (planting) continued and survey for natural regeneration post-treatment to determine if stocking levels are sufficient to meet the NFMA requirement: '(E) insure that timber harvested from National Forest System lands only where - (ii) there is assurance that such lands can be adequately restocked within five years after harvest;'. The Forest's intent is to rely on natural conifer regeneration wherever possible however the agency is required by NFMA to restock harvested stands within this timeline. The Forest Service is proposing to salvage harvest 4,090 acres burned in the 191,197-acre Chetco Bar Fire. There are 170,321 acres on National Forest System Land within the fire area of which 81,344 acres are in the Kalmiopsis Wilderness Area. The proposed action will treat approximately 2.4% of NFS lands leaving most of the fire area to naturally regenerate.
3538-15 The cumulative impacts of this project, when combined with the effect The cumulative effects of this project are displayed in the EA, Chapter 3. The effects were of the fire itself, past fires, fire-fighting efforts, extensive salvage on determined to not be significant (Refer to the Decision Notice and Finding of No Significant adjacent lands (about 9,455 acres on nearby private lands, with Impact). effectively no protection for environmental value), roadside hazard tree removal, BLM salvage, and global climate change, are significant and warrant an EIS.
3538-14 The EA says that a request for an ESD was received but there has been Thank you for your comment. By June 2018, the value of fire killed timber in the Chetco Bar no action on it yet. EA 2-6. This is an unfortunate situation. Cascadia Fire Salvage project area is estimated to be minimally reduced. However the reduction in Wildlands does not support an emergency determination here because value would be even greater if the fire killed timber is not harvested until late October of (1) there is no emergency, and (2) the procedural effect of such a 2018 or later; estimated to be reduced by 20-30%. (EA at 2-6) Refer also to the Public determination would greatly increase the controversy and Involvement section of the EA, Chapter 1. contentiousness of this project, by eliminating opportunities for further consultation and collaboration.
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3538-8 The EA works from the unsupported assumption that this area is almost Fire regimes in Douglas Fir/hardwood forests are considered to be one of the most variable. all Fire Regime 1. That assumption is the factual premise from which (Agee 1993) This variability makes generalizations about the fire regime and its effects the entire project springs—the idea being that last summer's fire was difficult. Recent events as well as historical records, combined with vegetation patterns an unnatural aberration. Yet at the same time, the EA says that the high indicate intense stand replacing events have been and will be part of the system. Fire severity fire was within the natural range of variability. We are behavior can range from low intensity underburns, to mixed severity to stand replacing concerned that the agency is using overly-simplistic fire regime events, frequently within the same fire perimeter. Historically, high frequencies of low and classifications out of convenience, that result in critical site-specific medium intensity fire broke up large uniform patches into complex mosaics of age, size and factors being overlooked. structure (Wills 1991). Resulting vegetation patterns are a mosaic of patches of differing sizes and multi aged stands (EA Chapter 3 Fire, Fuels and Air Quality section). Areas identified for harvest were not based on fire regime. Will and Stuart (1994) found mean return intervals in NW California of 13-22 years. Other studies reported median fire return intervals of 10-30 years (Atzet et al. 1996, Atzet and Martin 1992, Agee 1991, Adams and Sawyer 1980). Intense stand replacing fires still maintain patchiness with some green trees surviving (Wills and Stuart 1994, Wright and Bailey 1982). Severely burned areas may account for only 15-20% of the total area burned (Atzet and Martin, Adams and Sawyer 1980) EA Chapter 3 Fire, Fuels and Air Quality section). Siskiyou National forest records indicate the forest has managed fires in this area, but most have been contained during initial attack. The area identified for harvest activities has missed one or several fire returns due to current fire management. "Recent research suggests that landscapes with unaltered fire regimes are more "self- regulating" than those that have experienced fire-regime shifts; in self-regulating systems, fire size and severity are moderated by the effect of previous fire." (Parks et al. 2013) These fires had they been allowed to burn, would certainly have contributed to the patchiness typically found in Douglas Fir/Hardwood forests. This is the departure from historic conditions referenced in the EA.
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3538-11 The Forest Service approach focuses only on the forest canopy, to the Scoping is used to identify issues that relate to the effects of the proposed action. The issues total exclusion of considering fire intensity on the ground or the were separated into three groups for the purpose of this analysis: Key Issues, Analysis Issues condition of soils. As a result, no alternatives are considered to address and Issues Eliminated from Detailed Study. A complete issue identification summary is in the impacts to soils, and the EA only contains an abbreviated analysis of soil project record files, including issues eliminated from detailed study along with the rationale impacts. This is a particular problem because while canopy impacts can for their elimination and this Environmental Assessment hereby incorporates by reference at least partly be understood by looking at satellite images and the like, the EA Issue Statements in the CBF Salvage project file (40 CFR 1502.21) (EA at 1-12). Soils soil condition requires a more intensive on-ground survey and site- was determined to be an analysis issue that is addressed by project design criteria. Please specific knowledge. refer to the Soils Report, Fire subsection, pages 16-23 within the Supporting Project Documents, which considers and discusses the Burned Area Emergency Response Soils Analysis based on the final soil burn severity map (MacDonald and Ochoa 2017) (Link: https://data.ecosystem-management.org/nepaweb/nepa_project_exp.php?project=53150). Alternative 3 and the No Action Alternative also address impacts to soil concerns. Alternative 3 proposes post-fire salvage logging activities on 1,868 acres in comparison to 4,090 acres in Alternative 2, which would eliminate soil disturbance on 2,222 acres. As well as, the No Action Alternative eliminating all post-fire salvage logging activities and connected actions that also avoids soil impacts.
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3538-9 The proposed action involves an increase in fire ignition risk that is Fire risk is defined as the potential and frequency for wildfire ignitions. Fire risk is often significant and warrants a hard look. These risks occur not only from defined as the number of fires per 1,000 acres per decade. Areas that have a fire start every the project activities themselves, but over the long-term as well by one to ten years are considered to have a high fire risk. The majority of fire starts for this creating more and more plantations that require more and more active area are from lightning. The proposed action will not affect future fire risk. Fire hazard for management. This issue is of very keen public interest, perhaps more so any particular forest stand or landscape is the potential magnitude of fire behavior and than any other factor, and is highly controversial from a scientific effects as a function of fuel conditions (Peterson et al. 2005). Fire hazard most commonly perspective. Alternative development could meaningfully address this refers to the difficulty of controlling potential wildfire. Fire behavior characteristics such as factor. Please consider fire risk and fire resiliency effects in a full EIS. rate-of-spread, intensity, torching, crowning, spotting, fire persistence, or resistance to control are generally used to determine and describe fire hazard. As Brown et al. (2003) indicated, fire severity can be considered an element of fire hazard. Suppression resources contain over 95% of fires to less than 10 acres. Those fires that escape initial containment usually are (1) ignitions that occur when fuel moistures and atmospheric conditions allow for extreme fire behavior, (2) fires in areas of high contiguous fuel loads, (3) fires not quickly or easily accessible, (4) fires in areas that don't allow suppression resources to safely work in close proximity to the fire (no escape route and/or safely zone), or (5) a combination of the above. Removing dead trees will allow suppression resources to work safely in close proximity to the fire utilizing direct tactics. Project design criteria limit fuel bed depth to 12". Limiting fuel bed depth can maintain fire behavior characteristics that can be safely engaged using direct tactics. The desired fuel model produces a low rate of spread and low to moderate flame lengths. Additionally, these meet criteria identified in the Siskiyou land and resource management plan (1989); (12-2) The fire hazard presented by natural, activity or prior activity fuels should be reduced to appropriate levels, considering the site specific risk, and utilizing economically efficient treatment methods. The selected treatment methods should meet fuel management objectives which integrate consideration for all resource values. (12-4)
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3538-9 Proposed activity units (harvest, thinning, conversion, release, etc.) should be designed and continued coordinated on the ground so that size, shape, location, timing, spatial distribution, and management risk are considered for fire management and other resource requirements and help make the fuel treatment and fire protection of the units as practical and economical as possible. The proposed treatment areas reflect approximately 1-2% of the overall fire area, and 2-4% percent of the high severity patches within the fire. "Reducing connectivity of surface fuels at landscape scales is likely the only way to decrease the size and severity of reburns until vertical diversification and fire resistance is achieved." (Thompson et al, 2007) From a fire standpoint the changes in fuels continuity on the landscape due to this project is considered negligible in the context of the broader event. Future fire risk will be largely contingent on ambient conditions as well as the live fuel continuity. Fire weather was shown to have a strong influence on reburn severity. (Coppoletta et al 2016). It is anticipated that even with natural or artificial regeneration, the continuity of shrub layer will drive future fire events for the near term, overriding the influence of conifer regeneration in activity units. Allowing for unplanted areas, openings and planting at lower densities can serve to break up continuity of fuels and reduce future fires intensity and severity. The effects of this treatment in terms of potential fire behavior are minimal due to the small acreage of treatments relative to the larger areas of high severity in the Chetco Bar footprint. (EA Chapter 3 FIre, Fuels and Air Quality section)
3538-1 The purpose and need for the project is unduly narrow and biases the The Responsible Official establishes the scope of the environmental analysis, including the decision-making process. scope of the actions, alternatives, and effects (40 CFR 1508.25).
3538-5 We have questions about the "Natural Range of Variation" (NRV) The EA is only trying to display that right now (after the Chetco Fire) within the fire analysis (Kuhn 2018) that was completed for the watersheds that cover perimeter, we are within the natural range of variation for early seral habitat and the area the majority of the fire and that may be impacted by post-fire salvage will still be within the natural range of variation for early seral habitat after any alternative is logging. See EA p.3-7. It is explained that NRV is a measure that only implemented. works over a large land scale and a long period of time. Contradicting that, the EA applies the NRV analysis as a snapshot in time to say that certain watersheds are above or below the natural range of variability. Please take a hard look at the time scale being applied for this analysis.
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3538-3 We object to the EA approach of "incorporating by reference" a vast "Agencies shall incorporate material ... by reference when the effect will be to cut down on trove of un-organized data and analysis. This is not a legitimate means bulk without impeding agency and public review of the action. The incorporated material of accomplishing NEPA's mandate. shall be cited in the statement and its content briefly described." 40 CFR 1502.21
Follansbee Diane 3570-1 Please focus logging in existing plantations only. Alternative 3 addresses your concerns.
3570-2 Please leave all green trees; after a fire, many trees that look scorched The EA, Table 3 at 2-2 has been edited to better reflect the intent of proposed salvage have the capacity to revive and will continue to put out seeds, carrying harvest under the action alternatives. The species being targeted for salvage under the the genetic legacy of thousands of years of adaptation to the utterly action alternatives include Douglas fir and incense cedar, therefore they have been included unique conditions of the Chetco watershed, particularly important in Table 3. No other species would be targeted for salvage removal. However, any tree, given risks of climate change. regardless of species, that is determined to be a hazard to operations may be removed for safety reasons. Additionally, legacy trees, live trees and snags are proposed for retention as per the PDC described in the EA, Appendix A. Please refer to the silviculture prescription and marking guidelines for more information about the species targeted for salvage harvest and snag and down wood retention levels.
Furler Mark 3571-1 And please when the logging is complete I urge you to restore all Temporary roads are not intended to be included as part of the forest road atlas, as they are temporary roads are fully restored. managed by the projects or activities under which they are authorized and decommissioned at the conclusion of the authorized activity. Temporary roads would be closed and restored after salvage and related activities are complete. (EA at 2-3)
Monett David 3572-1 The salvage harvest acreage that you have proposed doing is way to Thank you for your comment. low. You need to salvage as many acres as possible with ground, yarder and helicopter even if you get only enough out of the timber to get the ground cleared and planted. You need large fuel breaks. What you do not treat will be a terrible fire hazard. Will burn again.
Wilberg Ray
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3573-1 All the many intact or lightly damaged acres must be left to recover The No Action alternative addresses your concerns. naturally, as nature has done for millions of years, very successfully. Unmanaged recovery will protect the fisheries, water quality, biodiversity, recreation and scenic values. Leave the undeveloped areas alone and forget the artificial restoration, let mother nature do her best work. NO NEW ROADS! This Wild and Scenic Chetco River and the value to recreation is paramount. Do not log this burn, and protect the Northern Spotted Owl and Stop converting natural forest into fire-prone plantation.s
North Richard 3574-1 Please cut all the salvageable logs for helping to pay off local and state Thank you for your comment. debt. Keep the forest healthy, and eliminate firewood for burning the next year of forest fires.
Mikasi Ayani 3575-5 All artificial reforestation units should be canceled because forests are The intent is to rely on natural regeneration wherever possible. If natural regeneration is healthier if they allowed to naturally recover. determined not to be adequate to comply with the NFMA five-year regeneration requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand. Trees would be planted at appropriate densities to achieve 125-150 trees per acre. (EA at 2-4)
3575-4 All new road construction should be canceled to prevent erosion and None of the alternatives evaluated in this project propose any new road construction. protect streams. Temporary roads would be closed and restored after salvage and related activities are complete. (EA at 2-4)
3575-3 All units in mature forest and Spotted Owl habitat should be canceled Alternative 3 addresses your concerns. to preserve important wildlife habitat.
3575-6 All units near the boundary of the Kalmiopsis wilderness area and in the The No Action alternative addresses your concerns. Quail Prairie Creek area should be canceled. Finally, all units impacting the view seen by recreational users should be canceled.
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3575-2 However, many of these lands have bever been logged before and The No Action alternative addresses your concerns. contain old growth trees that should not be cut. Cutting mature forests and replacing them with young tree plantations increases fire risk because young trees are more likely to burn than older trees. Forests should be allowed to naturally recover instead of being logged and replanted.
3575-1 Logging would cause sediment to be discharged into the river, The proposed project was determined to have no effect to water quality. The rationale for negatively impacting these fish runs. Constructing new roads would also this determination is documented in the EA, Chapter 3 Hydrology section. The project threaten these fish runs. incorporates a system of design features that ensure there can be no mechanism to affect water quality. Some examples of design features to protect water quality include no-cut riparian buffers on both sides of all streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Hydrology section. The proposed project was determined to have no effect to aquatic species, including Klamath Mountain Province (KMP) steelhead trout and Southern Oregon/Northern California Coasts (SONCC) Chinook salmon. The rationale for this determination is documented in the Fisheries and Aquatic Biota section. The range of sea-run cutthroat trout is similar to that of KMP steelhead trout and the potential for effects to steelhead can be assumed to be similar for cutthroat trout. The project incorporates a system of design features that ensure there can be no mechanism to affect aquatic species. Some examples of design features to protect aquatic species include no-cut riparian buffers of 350' on both sides of all fish-bearing streams, conditional restrictions on the haul of salvaged timber, and improving the drainage features of the road system that might be utilized for haul. For more information refer to the Fisheries and Aquatic Biota section. (EA at 1-9)
30-Day Comment Form Letters Received 4/16/2018 - 5/16/2018 Last Name First Name Comment Letter #
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Name Comment Text Response Text
Abernathy Jennifer 687 Able Mary 2607 Abondolo Gianna 1148 Adair Jan 63 Adams Joan 1787 Adams Winn 1665 Adell Valerie 1501 Adell Valerie 2705 Aden Sandi 2034 Aere Honora-Bright 956 Aere Honora-Bright 1791 Aere Honora-Bright 3076 Aerne Jo 2842 Affholter Lloyd 876 Ahlstrom Jennifer 966 Aitken Selene 2176 Ajari Leslie 3073 Alan Glenn 348 Alaux Myriam 2509 Albert Anthony 1633 Albertine Gisele 747 Alderman Mick 1560 Aldridge Michael 825 Aleman Corina 2019 Aleman Corina 3504 Alexander Dara 405 Alexander Gerald 292 Alexander June 461 Alexander Tangren 1674 Alexandra Kathryn 1717 Alexandra Kathryn 3427 Alford Amanda 1882
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Alford Amanda 3403 Allard Elena 1085 Allen Ann 1392 Allen Charles 2421 Allen Cindy 730 Allen Dana 369 Allen Dana 1406 Allen Katherine 516 Allen Susan 609 Allen Sylvia 1942 Allen Vinit 247 Allison Rebecca 137 Alm Erik 1232 Altman Peter 1062 Altshuler John 1619 Altshuler John 2179 Amann Matthew 2010 amant Kurt 3231 Amdersin Joan 3445 amick brenda 2522 Amlin Briana 3249 Ampel Carol 2400 Anderholm Jon 1184 Anders Daggie 2488 Anders Dagmar 1579 Andersen Evette 14 Anderson Christeen 3358 Anderson Christeen 3437 Anderson Helen 359 Anderson John 1407 Anderson Linda 2334 Anderson Virginia 2263
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Anderson Virginia 3557 Andreae Chris 3200 Andreas Leticia 3331 Andrew Tamika 976 Andrews Rev 256 Andrews Terry 2260 Andrews Terry 3323 Angell J 1524 Angell JL 1977 Angus Billy 2467 Annecone Lisa 1252 Anovak Agraff 1475 Anshin Judith 798 Anthes Russell 1916 Anthony Hal 2216 Antonelli Jordan 368 Aquino Manuel 2160 Arancibia Jennifer 831 Araujo Hildalylia 402 Arbuckle Nancy 805 Arellanes-HanLani 1542 Argenal Ana 1420 Arlen Barbara 2826 armijo salme 597 Armstrong Patricia 1372 Arnold Kathryn 1399 Askins Susanna 1310 Askins Susanna 2972 athens marissa 1766 athens marissa 2748 Atkinson Richard 2585 Atkinson Richard 2873
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Auger Sylvie 2720 Auger Sylvie 2830 Augstein Lynn 636 austin amber 2969 Axt Phyllis 1612 Aydelott Steve 1072 Aydelott Steve 2447 Ayres Betsy 1213 B Maureen 396 B. Jill 919 B.Greene Anon 287 Babcock Rachael 3367 Babcock Rachael 3507 Babin Ellen 189 Bach Kimberly 487 Bachhuber Stephen 2459 Backus Rex 557 Baier Chelsea 3411 Bailey Joan 296 Bailey Joan 581 Baker James 2963 Baker Kimberly 770 Baker Rebecca 1124 Baker Rowan 3266 Baker Vickey 1415 Baker Vickey 2274 Baker Vickey 2719 Balderston Jason 3315 Baldwin Fredrick 1409 Baldwin Natylie 1167 Baldwin Paul 1644 Baley Patricia 2364
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Ball Roarke 2299 Ballance Britt 2642 Balog Emery 3182 Baltz Ruhee 2478 Balwinski Monica 1200 Baniqued Jarrod 1571 Bansemer Kenton 3193 Baratashvil Sophia 885 Barbee Carol 2518 Barca Erin 246 Barca Erin 1735 Barca Erin 2605 Barca Erin 3388 Barger John 93 Barger John 2551 Barich Mary 1108 Barker Anne 1368 Barker Richard 2020 Barker Richard 2807 Barnebey Kathleen 1513 Barnes Barbara 1328 Barnett Susan 521 Barrett Charles 2735 Barron Bridget 525 Bartel Kevin 985 Bartl Alan 1350 Bartl Alan 2090 Barton Ann 1741 Barton Ann 3194 Basart Michelle 193 Basart Michelle 591 Basile Emily 3225
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Basye Judith 74 Bates Russell 3129 Battistessa Gerri 641 Batty Vernon 2465 Baudains Barry 2760 Bauer Bruce 1993 Bauer Bruce 3371 Baughman Charles 249 Baum Stephanie 1955 Baum Stephanie 3353 Bauman Natasha 929 Baumann Michelle 1479 BAUR Nancy 906 Baxter Joslyn 744 Bayer Ted 3016 Bazinet Jon 475 Beall Dennis 83 Beam Rick 75 Bean William 1117 beardsley Andrea 3113 Beauchamp Deborah 1895 Beausoleil Claudia 1731 Beausoleil Claudia 2329 Beausoleil Daniel 1681 Beausoleil Daniel 3092 Beavin Kathleen 2628 Bechmann Elisabeth 2755 Beck Kim 2071 Beck Kim 2570 Becker Jacob 3110 Becker Sue 1207 Beckus Nancy 1656
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Beckwith Jane 2441 Beeler Kim 2547 Beeler Meg 1451 Beldin Joan 2859 Beldin Joanie 1240 Belenky Dan 1844 Bell Cathie 316 Bell-Becker Dee 144 Belle Maureen 178 Belloso-Curie Jorge 453 Belloso-Curie Jorge 982 Belz Paul 3018 Bennett David 2109 Bennett Maris 1495 Bennett Virginia 1781 Bennett Virginia 3296 Bensinger Judy 2772 Benson Scott 1733 Bent Chelsea 707 Benton Annette 1364 Benton Patricia 2311 Benton Patricia 3101 Berg H 1671 Bergen Andrea 1461 Berger Elmer 1583 Bergeron Valerie 2514 Bergstedt Charlie 529 Berman Alyson 3036 Bernard Alexa 1746 Bernard Janice 1709 Bernhaut Joseph 507 Bernstein Barbara 2591
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Berry Rebeckah 1400 Bertano Silvia 2759 Bertsch Mary 754 Bescript Linda 2205 Bescript Linda 3479 Best Marilyn 2586 Bettendorf Lisa 2148 Betti Mark 2917 Bevard Michael 1120 Bianco Sally 499 Bidinian Jane 286 biemuller eric 2479 Biggins Henry 706 Biggins Henry 889 Bihler Chris 2805 Billings Lisa 2501 Billings Lisa 2734 Bills Barbara 1129 BILWIN GINA 1058 Binckley Charles 672 Bindas Janet 1586 Binder Joann 107 Bingham Petra 823 Biocca Andrea 1250 Bishop Nancy 159 Bittler Tammy 2891 Bizon Amy 1642 Bjorge Melanie 86 Black Karen 2342 Black Pauline 1954 Blackburn Tara 384 Blackstone LINORE 2461
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Blaise Sharlane 1307 Blake Leigh 3039 Blakeney Penny 386 Blanc Greg 340 Bleckinger Dana 1226 Bleicher Karan 2612 Bliden Michael 3280 Blissett Lesley 2682 Bloom Martin 59 Bloomfield Gary 991 Blount Susan 3513 Blumenthal Harry 1316 BLUNK ELLEN 153 Blythe Frances 1317 Bob Ziller Gloria 1929 Bob Ziller Gloria 3302 Bobe Pablo 1995 Bobe Pablo 2836 Bobe Pablo 3305 Bobrick Melantha 1531 Boccia Linda 688 Bodwell Nancy 1582 Boffey Peter 1855 Bogin Ronald 278 Bogios Constantine 1147 boisgard isabelle 2915 Bol Erwin 3525 Bond Joshua 1348 Bones Taylor 3093 Bones Taylor 3512 Bonner Vallery 1545 Boomhower Deborah 1983
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Boomhower Deborah 1996 Boomhower Deborah 2211 Boomhower Deborah 3468 Boone Foster 673 BoonyarattapAnanya 2967 Borcherding Paul 533 Boschert Michele 142 Boshkov Lynn 857 BOSTIC MARTY 2839 Bothwell Jane 2172 Botts Jessica 815 Boucard Matt 1216 Boucher Justin 3207 Boulton Jenny 1002 Bourdon Richard 3236 Bourque Joseph 685 Bowman Gwyneth 854 bowne jim 2212 bowne jim 3481 Bowron Alice 1742 Boyd Keith 3434 Boylston Sandra 1603 Boynton Lynne 55 Bradfield Susan 838 Bradley Rhonda 1713 Bradley Rhonda 2848 Bradley Rhonda 3560 Bransford Gladys 321 Branson Jack 201 Brant Karen 43 Brasure Trudy 1569 Brauer Staci 1089
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Braun Diana 824 Braun Steve 2254 Brazis Christine 870 Breazeale Joseph 780 Breckenridge Sarah 2124 Breitwater Pamela 1191 Brennan Brien 408 Brennan John 2173 Brennan John 3063 Brennan John 3141 Brenner Sarah 236 Bresky Robert 2477 Breuer Ann 2559 Brevik Katherine 1323 Brewer Anna 1738 Brewer Anna 2519 Brewer Anna 3115 Brewer David 2838 Brewer John 2001 Brewer John 2816 Brewer John 3485 Brewer Roger 2959 Brice Lisa 2948 Bricker John 1677 Bridgewater Paul 2918 Brinckman Tessa 765 Brinkerhoff Aaron 1401 Brinkley John 736 Brinkley John 1346 Brinkley John 2483 Brinkley Mike 2161 Brinkley Mike 3363
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Brinkley Randi 990 Brinkofski Kevin 2097 Brock JoAutumn 76 Broeke Trisha 180 Broms Sharon 1306 bronner karen 3340 Brosh Linda 617 BROU Rachelle 2765 Brown Kevin 2847 Brown Kevin 3446 Brown Louise 111 Brown Margaret 2615 Brown Marilynn 1528 Brown Robert 2850 Brown Tabitha 2150 Brown Tommy 1259 Brown Tommy 1839 Browndog Lila 456 Browne sally 2779 Browne Shannon 2338 Browning Patricia 1863 Browning Patricia 3104 Bruce Edie 496 Bruckert Claudia 3156 Brumitt Ruel 954 bruner cheryl 2125 Bryan Kevin 1817 Bryan Kevin 3130 Bryan Pat 2671 Bryer P 485 Buczek Celine 2035 Budde Sharon 245
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Buell Ashley 1013 Bugni David 2643 Buhowsky Joe 924 Bumstead Bob 3152 Buratovich Ned 89 Burch Robert 911 Burch Robert 2944 Burd Lori 385 Burden Veronica 1176 Burdine Sherry 240 Burger Donold 2429 Burger Stephen 3366 Burgess William 444 Burke Barbara 1646 Burke Laramie 3346 Burke Sarah 1471 Burpo Leslie 739 Burtis David 900 Burton Don 2253 Burton Don 3127 Bush Brad 2710 Buskirk William 3416 Buslot Chantal 2473 Buswell Bev 1919 Butler David 2590 Butler Douglas 2158 Butler Michael 1263 Butler Pamela 979 Butler Tim 3046 Bwye Alexandra 1169 C.Downer Craig 2333 C.Zakoren Anon 1989
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C.Zakoren Anon 3002 Cabot Kimberly 436 Cain Tamara 562 Calascibetta Michelle 2105 Caldwell Dylan 3255 Callaway Larry 2831 Callaway Phillip 2799 Callejo Margarita 3495 Calvillo Juan 3380 Camden Brad 3111 Camhi Gail 1271 Campbell Denise 586 Campbell-TeaTherese 1201 Canarsky Maurine 176 Canja S 1506 Canning Stephen 2292 Cano Yude 57 cappello dan 2685 Cardenas Edgar 2304 Cardenas Edgar 3493 Cardiff Lynn 450 Cardiff Lynn 2757 Carey Deborah 325 Carl Nancy 1299 Carl Samuel 519 Carlson Susan 608 Carlstroem Matthew 2138 Carnall Michelle 2236 Carnes Lance 393 Carnese David 68 Carney-FeldmCatherine 1445 Carothers River 3167
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Carr Gaile 2414 Carraway Kermit 1559 Carrier Byron 2362 Carson Jo 589 Carter Kimm 459 Carter Michelle 40 Carty Lori 1909 carvajal mauricio 2616 carvajal mauricio 2857 carvajal mauricio 2922 Cass Maryjo 1563 Cassianna Frank 2127 Cassianna Frank 2581 Cassidy Kate 212 Castillo Rita 27 Castillo Theresa 1044 Castle-Rey Christina 977 Cate Susan 2416 Catranides Lisa 2182 Catt Shannon 3503 Cattell June 2046 Cattell June 3080 Cavin Ron 1396 Cerny Jayne 1568 Cervera Isabel 1464 CERVERA ISABEL 2573 CERVERA ISABEL 2611 Chaddrton George 868 Chapman Bruce 41 Chariton Laura 190 CHARLEBOIS STACIE 783 Charles Mahin 1382
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Charles Stephanie 1255 Charnes Michael 387 Chatroux Noel 2438 Chavez Bonita 886 Chavez Michele 1251 Check Pamela 547 Chen Allan 2693 Chenoweth Alyissa 509 Chenoweth Alyissa 757 Chenoweth Alyissa 1088 Cherwink Robert 567 Chesler P 1553 Cheung May 3359 Chi Animae 1127 Chi Animae 1275 Chi Animae 2810 Chi Animae 2895 Chianis Antonia 1845 Chianis Antonia 3118 Chieco Eileen 2038 Child Katrina 3021 Childers Judy 441 Childers Judy 2712 Childs Christie 577 Childs Christie 2085 Childs Christie 3458 Childs Lisa 490 Childs Lisa 1074 Childs Nat 527 Chismar Nancy 1706 Chittenden Jerry 635 Chittim Veroune 1457
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Chittim Veroune 2086 Chittim Veroune 3389 Chou Kelly 80 Christensen Rosemary 1352 Christensen Walter 758 Christian David 2000 Christiansen Holly 3322 Christie Sarah 3419 Cifelli Laura 232 Civiletti Jane 2589 Clark Barbara 1976 Clark Crystal 2695 Clark Ejay 1377 Clark Jason 1932 Clark Stephanie 1093 Clark W. 2528 Clark W. 2709 Clark-McKitri Blythe 440 Clarke Cher 2796 Clarkson Ann 1212 Clay Ted 1680 Clayton Julie 965 Cleaves Robyn 3552 Cleese Rose 1084 Cluver Sharon 2070 Clymer Lois 272 co Young h Fishawk 3565 Cochran Robin 2672 Cochrane Linda 1363 coffee william 3103 Coffey Josephine 1277 Cohen Bruce 1338
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Cohen Bruce 2443 Cohen Hayyim 1294 ColafranceschTina 665 Colclazier Erin 1331 Cole Dori 1843 Cole Karen 3000 Collay Daniel 2649 Colley Belinda 1281 Collinet Al 2322 Collinet Al 3550 COLLINS Carol 2952 Collins William 1682 Colvard Philip 1075 Commons Sandy 3005 Comnes Barbara 2298 Comnes Barbara 2954 Conger Regina 544 Conner Kristen 48 Conrad-AntovKristin 2731 Conrad-AntovKristin 3286 Contreras Lucely 625 Contreras Oscar 2128 Cook Gary 947 Cook Liz 729 Cook Nena 2639 Cook Orrin 320 Cooke Harriet 996 Cooke Sam 1798 Cooley Bruce 1877 Cooley Bruce 3382 Cooluris Helen 946 Cooney Tom 1297
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Cooper Dianne 1871 Cooper Donnie 3558 Cooper Justine 1730 Cooper Justine 3091 Cooper Michael 2792 Corey Marilee 392 Cornelisse Tara 865 Cornell Linda 326 Cornez Sandi 972 Coscione Nancy 3459 Costamagna Marilyn 2324 Costamagna Marilyn 2600 Costamagna Marilyn 3144 Costello John 575 Coucy Pascale 1135 Coulson Lynne 794 Council Nina 667 Councilman David 1637 Covert Peggy 1575 Cowan Nancy 198 Cowan Nancy 944 Cowdin Marielle 2696 Cowen Anna 964 Cox James 3055 Coyle Gregory 494 Crabill Phillip 1095 Crabill Phillip 2950 Craig Diane 2684 Craig Kim 1241 Craig Patrick 1433 Crane Donna 3492 Crane Crane Cecelia 978
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Crase Steve 993 Crawford Vern 2388 Cribbins Judy 837 Critser Jackie 420 Crockett Laurel 1537 Crockett Scott 984 Crockett Scott 2800 Croissant Susan 3394 Cronin Christopher 3215 crosby isabel 2736 Crosby Pete 2082 Cross Bonnie 285 Cross Merridy 1860 Crotty John 2841 Crowley Jeanne 1301 Crozier Sandra 1371 Cruz Marian 1330 Cruz Marian 2178 Cruz Marian 2546 Cuddy Sarah 2470 Cuellar Kebrhea 1023 Cuellar Kebrhea 2868 Cullup Allison 2266 Culver Kaleb 1922 Culwell Debra 874 Cummins Peter 2505 Cunningham Casey 2856 Cunningham Linda 1729 Cunningham Linda 3421 Cunningham Nancy 676 Cvitanich Danielle 742 D J 373
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D Bushnell Martha 1679 D Bushnell Martha 3551 D'Adamo Michael 1193 D'amore Oceanah 2081 D.Susman Catherine 2156 Dadgar Lisa 997 Daeschner Doug 1693 Dahlen Beverly 694 Dahlgren Deborah 1810 Dahlgren Deborah 3007 Dale Robert 1390 Daly Paul 2462 Dames William 3425 Danforth Megan 1870 Danforth Megan 3136 Daniel Marinell 643 Daniello Paul 858 Daniels-CurreElizabeth 140 Danson Joshua 3040 Darling Chris 695 David Carla 127 David Carla 1703 David Carla 3529 Davidson Amber 2568 Davies Dorothy 817 Davies Sha 448 Davine Jill 1494 Davis Cheryl 1632 Davis France 2277 Davis Heather 832 Davis Jerry 3413 Davis Laura 2048
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Davis-WarnerFlorence 554 Dawson Adele 1655 Dawson Adele 2516 Dawson Adele 2863 Day Connie 356 day Mark 2343 Dayton David 344 Dean Dave 2096 Dean James 1940 Dean Stacey 511 DeAngelo Vic 1100 Debraal Karen 1408 Debraal Karen 2209 Debraal Karen 3090 Decker Terri 928 Deddy John 1640 Deguzman Genevieve 1049 Dehnert Monty 150 Delagrange Brian 1920 DellaSala Dominick 3478 Dellepiane Silvio 3066 Delles Susan 888 delles susan 2360 delles susan 3188 Delorenzo Teresa 3065 Demoll Christine 930 DeMuth Lupin 2154 Dennis Gudrun 2645 Der Loo Bernadette 1521 Derbyshire Cameron 2902 Derosier Chad 1973 Detweiler Katelyn 2126
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deveuve suzanne 422 Devi Leela 2883 Devine Karla 2323 Devine Karla 3196 Dewitt David 1403 Dexter David 294 Dianich A 2602 Dice Lisa 1538 Dick Tamar 3100 Dick Tamar 3119 Dick Tamar 3158 Dickinson David 3464 Dickson Drew 3376 Diernisse Connie 1509 Dietrich Karol 345 Dietrich Mary 322 DiGiorgio Michael 2267 Dilip Sanand 2776 Diller Susan 1645 Dimand Cynthia 3454 Din Sebastian 3516 Dinelli Luca 2392 Dingell David 96 Dishion Catherine 226 Djelal Juana 334 Dlugonski Melba 425 Dlugonski Melba 1725 Dlugonski Melba 3430 Docherty Rachel 755 Doering David 512 Dogole Ian 151 Dolmage James 1757
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Dolores ScheeRobert 2352 Domanchuk Barbara 961 Dominguez Mari 1837 Dominguez Mari 3562 Donaldson Karen 1526 Donelson Bruce 3248 Donnell Bruce 1441 Donnille Shawn 2926 Donston Kacey 372 Donston Kacey 2925 Doolittle Tom 2180 Dorband Glenn 2484 Dotson Michael 2382 Doty Thea 308 Douglas Dianne 2047 Douglas Dianne 2878 Douglas Dianne 3390 Douglas Dianne 3412 Douglas L 1395 Douglas Virginia 2408 Doumitt Rhett 1324 Dowling Gary 1662 Dowling Holly 725 Drawhorn Robin 2766 Drentlaw Leslie 646 Drew Janet 610 Drumright Chris 1795 Drumright Chris 3343 Dryad Anne 2599 Ducey C 1424 Duclaud Monica 655 Duerr J 1199
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Dufka Tim 604 dumont lynette 2613 Dundom Bill 1670 Dundom Pam 1732 Dunn Juliette 1267 Dunn Matthew 2648 Dyche Danny 784 Dyer Jym 1661 Dyer Ruth 3431 E Holly 33 E.Darby Anon 1548 E.Newman Roberta 631 E.Stoker Wesley 1050 E.Stoker Wesley 1805 E.Stoker Wesley 3125 Earnshaw Shinann 642 Easter Darrel 2307 Easter Darrel 3505 Ebbe Kristin 1924 Ebbe Kristin 3203 Ebbe Kristin 3447 Ebel Kevin 2899 Eberlein Eb 2259 Eckersley April 3116 Eckert Linda 1476 Edelen Jennifer 2198 Edelen Jennifer 2239 Edelen Jennifer 3022 Edell Miriam 1450 Edgar Barrett 2893 Edwards Cathy 1710 Edwards Elizabeth 257
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Edwards Estella 347 Edwards Rob 2811 Eells Victoria 3151 Efimova Valeriya 1885 Egen Gretchen 255 Egen Susan 3561 Eggers Elizabeth 1838 Ehrlich Isaac 1311 Eichenberg Frank 1448 Eicher Annie 19 Eiffert Jen 1197 Eiffert jen 2396 Eiffert jen 3175 Eisman Nancy 1414 Eley Patricia 826 Elias Mary 890 Elkins Carol 251 Ella Jean 2900 Elliott Benton 1320 Elliott Benton 2614 Elliott Susan 161 Ellis Koll 904 Elson Adam 2185 Elston Crystal 2743 Elston Crystal 2846 Elwood Peg 1073 Emerick Craig 1481 Emerson C 599 Emme Linda 1437 Eng Richard 1961 Eng Richard 2592 Engelbrecht Luz 2349
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Englert Mary 1552 Engstrom Kathleen 191 Ensign Dianne 1374 Ensign Dianne 2637 Epstein Manny 431 Erb Cheryl 584 Erceg Mae 955 Erickson David 2227 Erickson Sandy 951 Ericson Mary 304 Ericson Mary 3345 Erland Bud 2056 Erland Bud 3097 Esden-TempsDanika 2750 Esperas Randall 1322 Eugene Schaffer 3289 evans bronwen 2526 Evans Jo 702 Evans Kate 2346 Everett John 338 Everett Rob 2345 Everett Rob 3379 Evers Mary 638 Ewalt Maximilienne 1347 Exo Kaye 156 Exton Jack 1051 F K 682 Fahrner Rita 1228 Faith Heather 1775 Faith-Smith Bonnie 2296 Faith-Smith Bonnie 2579 Falconer Jody 167
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Name Comment Text Response Text
Falk Martin 767 Falkenstein Jeffrey 1939 falkenstein jeffrey 2823 falkenstein jeffrey 3234 Fallandy Yvette 1121 Fanis Elena 2482 Fannon-LamkLynette 1098 Farah Laura 1380 Farin Larry 3126 Farmer Juliet 1217 Farmer Karen 2453 Farrier Morgan 1381 Fast Yvonne 2921 Faurot Jason 1345 Fava Patricia 1625 Fechner Joann 3536 Feder melanie 2968 Feinberg Joanne 2061 Feinberg Joanne 3456 Feissel John 647 Feldman Mark 622 Felts Logan 3455 Feltzin Joya 2943 Ferguson Cindy 1342 Fety Jim 1978 Fety Jim 3490 Fetz Margot 2784 Fiedler Rita 3109 Field Liz 2930 Fields Dylan 3457 Filice Ed 3364 Filice Katherine 3506
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Name Comment Text Response Text
Fillmore Ann 1522 Fillmore Jamie 333 Findlay Kathleen 264 Fineberg Ellen 2290 Fineberg Ellen 2355 Fink Patti 727 Finn Gary 3381 Finnerty Dean 3263 Finney Rory 1921 fiorini Liliana 2715 Fisher Monika 1047 Fisher-Smith Dot 3132 Fister Loreli 1327 Fitzgerald Glennis 1309 Fitzgerald Julia 315 Flake Beth 1068 Flebotte Katharine 25 Flebotte Katharine 1017 Fleming Laura 49 Fletcher Jennifer 1356 Fletcher Jennifer 1427 Fletcher Jennifer 2714 Flittie Richard 398 Flood Laurie 77 Florance Jeannine 2818 Florenzen Cynthia 506 Flowers Bobbie 2689 Fluetsch John 760 Fogarty Dan 563 Foley Kate 2189 Foley Mary 1192 Foley Mary 2072
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Name Comment Text Response Text
Folger Robert 2110 Fontain Shawn 118 Foo Ida 1491 Foot Susie 1470 Forbes Carol 3484 Force Karen 649 Ford Cheryl 1936 Forest John 1076 Forman Fay 2118 Forman Fay 3084 forman janet 2770 Forster Bruce 2701 Forster Wendy 2781 Fort MIchele 2610 Foster Brianne 2067 Foster Brianne 2595 Foster Lorraine 973 Foster Lorraine 2415 Foster Lorraine 3232 Foster Rosemary 656 Foster Rosemary 2829 Foster Susan 1402 foust william 2409 Fowler Elizabeth 3134 Fox Deborah 1980 FOX jane 99 Fox Kathryn 214 Fox Sandy 1274 Fox-Loken Shelley 1514 Franchi Irena 2582 Francis Larry 1326 Francis Larry 1925
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Name Comment Text Response Text
Frankfurter Aryeh 2122 Frankland Winn 1982 Franklin Barbara 2206 Frazer Barbara 1181 Fredricks Joanne 78 Freedman Matt 1611 Freeman Andrea 1026 Freeman Andrea 1094 Freeman Linda 772 Freiberg Harry 1998 Freiberg Harry 2683 Freiberg Harry 3015 Freiberg Harry 3057 Frengle Caroline 1222 Friedman Esther 1466 Friedmann Michael 2958 Frisk Crystal 1195 Fritzsche Valerie 892 Froeschl Doris 2594 Frolova Inga 222 Frost Michael 480 Frost Michael 2023 Fugate Deborah 1351 Fuller Robert 771 Fulwiler Fran 1260 Fung Sara 1527 Funk David 2536 Fusilier Gilda 500 Futrell Sherrill 1011 Futrell Sherrill 1029 G H 148 Gabriel Loren 893
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Name Comment Text Response Text
Gaede Marc 2153 Gaede Marnie 3210 Gaehwiler Catherine 1600 galati Laura 1830 Galli Bill 958 Galvin Peter 1156 Galvin Peter 2378 Gaponoff Sharma 360 Garber Sandra 792 Garcia Christine 3106 Garcia Mary 3201 Garcia Mary 3475 Garcia-Barrio Constance 1182 Garcia-Barrio Constance 2764 Gardener Gardenia 799 Gardiner Dr. 3173 Garitty Michael 474 Garner Shauneen 2287 Garrecht Jamila 987 Garren Sharon 1643 Garrett Steve 1159 Garrett Steve 3181 Garsson Jane 3297 Garvett Esther 2560 Garvey Lydia 1819 Garvey Lydia 3053 Gatzke Robert 3283 Gaughan Jill 842 gavin jen 1751 Geddis Cliff 2385 Gehman Heidi 2289 Gehr Charles 3312
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Name Comment Text Response Text
Geisler Grant 2142 Gendvil Derek 2244 Gendvil Derek 3444 Gentili-Lloyd Mika 1384 George Erin 2718 George Ursula 2199 Germanotta Betsy 1550 Germenis Carol 451 Getty George 1847 Geyer Monica 614 Geyer Monica 2703 Ghosh Sudeshna 1772 Ghosh Sudeshna 2606 Ghosh Sudeshna 3049 Gibb Karen 1318 Gibb Wayne 1243 Gibbons Brian 2053 Gibbons Brian 2379 Gibbons Brian 3185 Gibbs Colleen 1990 Gibbs Stefanie 2812 Gibson Claudia 70 Giesbrecht Guy 352 Gigel Jessica 173 Gigel Steve 139 Gilbert Janet 3216 Gilmore James 917 Gilmore James 3165 Gils Piet 1762 Gingras Brian 1692 Gingras Brian 3133 Ginsberg Barbara 2442
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Name Comment Text Response Text
Ginsburg Wayne 3089 Gladfelter Barbara 488 Glass Andrea 1564 Glatthorn David 3174 Glick Julie 399 Glickfield Adam 513 Glynn Ronald 1926 Godard Jeffrey 2347 Goerke Carol 1994 Goerke Carol 2975 Goertz Wade 3085 Goff Paul 1858 Goff Paul 3278 Gold Carol 793 Gold Vicki 2165 Gold Vicki 3128 Golden Loriel 1078 Goldenberg Thomas 3463 Goldfeld Anne 341 Goldin Martha 263 Goldsmith Ken 3010 GOLICK JAN 1759 GOLICK JAN 2469 Gomez Armando 845 Gonsman James 50 Gonsman James 1984 Gonzalez Gerardo 594 Goodman Greg 401 Goodrich Roxanne 585 Goodrich Roxanne 2870 Goodwin Margaret 1745 Gopinath Gabrielle 1107
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Name Comment Text Response Text
Gorospe Cynthia 2358 Gosenski Michael 2022 Gotch Katherine 1139 Gottesman Judith 429 Graca Connor 1721 Grady Lori 2725 Graham Charlie 572 Graham Charlie 628 Granstrom Pennie 2496 Grant Carmen 238 grant elizabeth 1370 Grantham Stephen 2669 Grassia Frank 968 Grawunder Marc 2576 Gray Brian 1652 Gray David 1529 Gray Sylvia 2912 Graziano Brian 491 Green Aiyana 2386 Green Joyce 1020 Greene Ford 715 Greenwald Green 1428 Greenwood Barbara 1660 Greenwood Holly 907 Greenwood Len 1140 Gregory Nancy 2879 Greider Laurey 434 Greinke Pamylle 2230 Greinke Pamylle 3409 Griffith David 666 Grose Linda 483 Groshong Victoria 88
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Name Comment Text Response Text
Gross Eileen 280 Grunde Benjamin 1823 Grundman Dave 1055 Guinan Valerie 1223 Gunderson Monica 1943 Gustafson Allee 2217 Gustafson Allee 3108 Gustafson Allee 3219 Gustafson Rae 1503 Guthrie Michelle 311 Gynane Kathy 2337 Gynane Kathy 3238 H Vanessa 2569 H. Janet 3 Haak Valerie 943 Haddad Barbara 82 Hadden Marion 1715 Hadden Marion 3356 Haddow Ian 773 Haehlen Heidi 2100 Hafner Nancy 94 Hagarty Brendan 528 Hagelin Christine 1608 Hagen Hayley 2383 Hagen Kay 2008 Hagen Kay 3045 Hagen Valerie 1576 Hagerty Scott 3229 Hailey Diane 1763 Haines John 1547 Haines Kyle 2480 Haines Kyle 2782
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Name Comment Text Response Text
Haiston Nancy 1458 Halbe Denise 806 Halcomb Erin 1783 Hall Jennifer 2889 Hallett Mark 482 Halliday Paul 2556 Halliday Paul 2738 Halloran Michael 1291 Hamilton Carole 390 Hamilton Pamela 1304 Hammel Kirby 2330 Hammer F 579 Hampson James 1606 Handa Sharon 1160 Hanley Lisa 505 Hannagan Brian 2016 Hannagan Brian 2278 Hannagan Brian 3400 Hannah Ian 2534 Hannigan Bob 2042 Hannigan Bob 3019 Hanscom Brad 790 Hansen Julie 2184 Hanson Phil 1082 Hanson Phil 2093 Hanson Phil 2704 Hanson Samara 1057 Hanus Jeffry 1752 Hanus Jeffry 3251 Happyrock Han 2305 Harbert Merriann 64 Harby Susan 467
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Name Comment Text Response Text
Hard Jim 640 Hardison Jeanette 2228 Hardy Kay 1846 Hargraves Mark 122 Harkin Carol 3191 Harper Charesa 442 Harr Silva 1426 Harrington Garth 2372 Harris Alexander 2147 Harris Chris 1237 Harris Donna 571 Harris Freya 2389 Harris Freya 2854 Harris Freya 2960 Harris Gail 2543 Harris Jamie 2550 HARRIS JOHN 1512 Harris Julie 253 Harrison David 181 Harrison Jen 679 Harrison Randy 417 Harrison Randy 2146 Harrison Randy 3566 Harrison Robert 197 Hart Karin 1242 Hartwell Beth 1818 Harvey Kristin 3486 Hasson Ed 1436 Hastings Joanne 2241 Haudebourg Michèle 2927 Hauge Jennifer 1534 Hauge Jennifer 2678
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Name Comment Text Response Text
Hayden Greg 2024 Hayes Jennifer 2159 Hayford George 3189 Hazelton Judith 1918 Healey Kathy 692 Heaps Lynell 1654 Heath Soulin 595 Heath Susan 281 Heath Susan 2508 Heck Zechariah 3122 Heckman Dale 382 Heckman Wayne 1986 Hedgecock Juliette 1967 Heiden Jessica 503 Heinlein Richard 1854 Heintz Penny 1128 heiser Chris 3521 Heisler Robert 225 Heisler Susan 3250 Heitner Arlene 414 Heline Eric 2422 Heline Eric 3435 helm adam 2132 Helm Robert 1021 Helwig Michael 2716 Hemenez Jeffrey 1334 Hemmingsen James 552 Hendrickson Mike 3545 Hendrik HuhnLaura 921 Hendrix Linda 132 henley cheryl 2575 Henry Lynn 2367
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Name Comment Text Response Text
Henry Susan 1549 Hensley Karen 3098 Herbert Annabelle 336 Herboso Leire 502 Hermeyer Dave 1565 Hernandez Richard 2309 Hernandez Richard 3262 Hernday A 449 Herndon James 2017 herron elizabeth 54 Hervert Carla 555 Hesser Yola 129 Heyerman Robert 1820 Hickey Rya 1459 Hiestand Nancy 1105 Higgins Mike 2834 Higinbotham Alan 362 Higson Howard 157 Hildebrand Valerie 1770 Hildebrand Valerie 2923 Hildebrand Valerie 3257 Hilden Bj 216 Hilden Peggy 1280 Hill John 2652 Hill Tonia 2318 Hillard Sandra 1031 Hillson Scott 228 Hillson Scott 2708 Hinchen Carol 1566 Hinds Carolyn 493 Hines John 2197 Hinsberger Wendy 598
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Hipszky Ginger 2452 Hobbins Cynthia 1723 Hobbins Cynthia 3075 Hobbs Susan 208 Hocking Zora 1056 Hodges Suzanne 807 Hoelscher Scott 2261 Hoelscher Scott 3083 Hoffman Rebecca 2511 Hofmann Michelle 1651 Hohler Dave 3428 Holford Sharon 860 Holifield Barbara 1024 Hollis-FranklyCandace 737 Holloway David 478 Holman Pati 2434 Holmes Juliet 1116 Holmgren Jeanette 2406 Holmgren Jeanette 2961 Holmquist Kirsten 2270 Holt Jillian 600 Holt Steven 3429 Holtzhausen Chris 813 Holub Ana 2436 Holzman Wendy 2548 Honkomp Dennis 2426 Honkomp Dennis 3306 Honthaner Deborah 3522 Hood Paula 276 Hood Susan 1175 Hoone Timothy 3222 Horn Karen 1760
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Horn Karen 3253 Horner Jerry 1206 Horton Karen 29 Horvat Sabolch 2753 Horwitz Martin 1266 Hotchkiss George 1431 Hough Kurtis 2885 Houshour Deborah 1727 Houshour Deborah 2463 Howard Celeste 102 Howell Lisa 2820 Howell Marybeth 795 Hoynacki Paul 1045 Hoyt C 962 Hoyt Virginia 913 Hubbard Chris 2175 Huddleston Molly 1254 Hug George 1452 Hug George 2052 Hug George 2690 Hug Janis 1103 Hugh O'Donnell 3277 Hughes Rich 458 HUGHES ROBERT 2938 Humke Ken 592 Hummel KennethJulia 2166 Hummel Valoree 2905 Humrich Aidan 1493 hunt eric 2398 Hunt Myphon 895 Hunter Kari 800 Hurley Gaylene 1827
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Name Comment Text Response Text
Hurst Mark 1518 Huskisson Irene 2656 Huson Kacie 1551 Hyatt Stuart 2539 Hyde David 1578 Hyman Harvey 295 Hyndman Carol 932 Iam J 84 Ibbotson David 2790 III Mariano 561 Inglis john 2752 Irby Drew 432 Irwin Chrstina 31 Ison Matt 2405 Itdown Cut 3235 Ivey Gary 2375 Ivor Charles 1465 J.Angell Anon 3162 J.Golick Anon 3180 J.Loomis Carol 1305 J.Prince Steven 2143 J.Seigel Howard 1641 Jackson Ken 2039 Jacobsen Barbara 79 Jacobson Don 154 Jacobson Don 2655 Jaffe David 957 Jain Paula 455 james bettie 2380 James J 2485 James Kenneth 1321 james r 1515
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james r 2717 Janiak Joe 3539 Janota Linda 1959 Janson-Smith Kim 223 Janssen Robyn 2002 Janssen Robyn 3227 Jasiukiewicz Anna 2604 Jasiukiewicz Anna 2833 Jaubert Frédéric 2564 JEFFROY Annick 2843 Jekabsons Kathleen 3311 Jelen Jonathan 1014 Jenkins Jacqueline 143 Jenkins Phyllis 1975 Jenkins Phyllis 3467 Jennings Jan 2237 jensen jennifer 2014 Jensen Wesley 7 Jergens Jovy 1033 Jerro Bonnie 1367 Jevne Lucretia 654 Jilton Sandra 305 Jitreun S 1711 Jitreun S 2542 John Leland 927 Johnsen Jenet 558 Johnsen Jenet 1749 Johnsen Jenet 1962 Johnson Alice 1468 Johnson Ara 1987 Johnson Carrie 117 johnson cheri 1683
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Johnson Dwight 720 Johnson Elvis 192 Johnson Felicia 1664 Johnson Jacob 2797 Johnson Jdefrancesco 235 Johnson Joyce 696 Johnson Koeby 1876 Johnson Loree 3508 Johnson Tucker 3433 Johnston Philip 2248 Jokelson Daniel 1869 Jokelson Daniel 2210 Jolliff Shirley 596 Jon Gray Carla 1607 jones Annamarie 1218 Jones Bradley 539 Jones Edmund 365 Jones Frank 545 Jones Frank 2243 Jones Frank 3517 Jones Helen 100 Jones Hilary 1188 Jones J. 2004 Jones Jane 131 JONES KENNETH 2427 JONES KENNETH 3330 Jones Linda 141 Jones Linda 2598 Jones Mabel 934 Jones Valentine 1776 Joos Sandra 2970 Jordan James 1144
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Jorgensen Britton 2464 Jorgensen Irene 763 Jorgenson Vicki 959 Joseph Rob 1833 Joseph Rob 3494 Josephine vonPeter 2875 Journet Alan 2249 Jr. L.D. 2455 Juchert Walter 764 Judith Berg David 312 Judith Berg David 2567 Judkins Jack 698 Jurczewski Carol 1970 Jurczewski Carol 2691 Jurczewski Carol 2936 Jurczewski Carol 3524 K Charlie 454 K. Saran 2647 K. Sue 3077 K. Sue 3254 K.Kliban Judith 39 K.L. Anon 6 Kaai Robin 2450 Kacir Doug 1546 Kacskos Sue 224 Kaczmarek Penelope 2939 Kalinowski David 3117 Kalvelage Joan 1816 Kalvelage Joan 3171 Kamendrows Victor 331 Kaminski Robert 2091 Kane Janice 1434
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Kane Jenny 2535 Kane Linda 1289 Kane Linda 1856 Kane Linda 2794 Kane Linda 3159 Kaneko Masayo 2457 Kaplan Lily 1834 Kappel K 658 Karcich Bob 447 Karcich Martha 1034 Karjala Barry 1785 Kastner Mary 1101 Kasunic Dennis 1894 Katayama Kayla 3226 Katsarou Litsa 2749 Katz Richard 2169 Katz Richard 3013 Katz Sara 2078 Kaufman Andrea 1081 kavan philip 210 Kavan Philip 2974 Kavanaugh Michael 822 Kay Joel 377 Kazandjian Helena 2641 Keahon Christopher 2335 Kearns Patric 1264 Keefe Christopher 3006 Keefer Neal 2495 keena steve 897 Keifer Elizabeth 709 Kelley Dorinda 290 Kelley Dorinda 1938
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kelley dorinda 2529 Kelley Dorinda 3415 Kellman Lisa 1015 Kelly Catherine 1797 Kelly Maria 1915 Kelly Maria 3081 Kelly Maria 3147 Kelz Lisa 1964 Kemp Joshua 3347 Kemp Todd 2084 Kenagy David 435 Kendall Trish 2608 Kennedy Claire 2867 Kennedy Jared 2667 Kennedy Scott 691 Kenner Kate 1963 Kenney Michael 517 Kent Donald 203 Kenworthy Jane 1702 Kerr James 182 Kerst Duncan 215 Kerst Duncan 3149 Kessler I 297 Ketcherside Sharon 469 Keys Catherine 1764 Keys Thomas 2754 Kilham Alice 211 Kimball Jess 2531 Kimbauer Elli 523 Kimbauer Elli 1604 Kimbell Henry 1622 King Judy 1060
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King Steven 791 King Susan 887 Kinsley Kay 2804 Kinsman Judy 1341 Kiran Jade 3530 kirchhoff joana 2681 Kirsch Jo 834 Kirschling Karen 950 Kitzler Gesher 252 Kiver Eugene 1556 Kizirian Shari 1394 Klappholz Shelley 2629 Klare Maxwell 3325 Kleiman Christine 357 klein zachary 3186 Knablin Richard 2424 Knablin Richard 2670 Knapp Harry 1202 Knapp Harry 2288 knapp harry 2722 knapp harry 2814 Knapp Harry 3272 Knoll Carolyn 1626 Knowles Cybele 2780 Knox Elena 1136 Koch Joann 1270 Koch Joann 1910 Koch Joann 3310 Kocher Sharon 175 Koehrsen Glenn 723 Koehrsen Glenn 2747 Koenig John 35
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Koenigsdorf Jill 1634 Koessel Karl 1137 Koessel Karl 1849 Koessel Karl 2079 Koessel Karl 3473 Koff Marilyn 2845 Kohler Lisa 768 Koivisto Ellen 65 koritz Raleigh 2858 Korn Meryle 2785 Korpela Jonna 2449 Kowalewski Joyce 821 Kowalewski Joyce 1589 Kowalewski Joyce 1758 Kowalewski Joyce 3138 Kowalewski Joyce 3295 Kowall Betty 931 Kramer-DoddGay 21 KRATINS OJARS 1658 Krause Doug 2059 Krause Doug 3341 Krisa Rama 2242 Krisa Rama 2351 Kriss Evan 827 Kroeber Elise 1233 Krupnick Wendy 1590 Kruse Susan 1173 Krystal Phyllis 1215 Kucharski Stephen 3399 Kuczora Carol 803 Kukulcan Jaguar 2064 Kunz Ethan 2353
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kuppler Bonnie 1807 kuppler bonnie 2687 kuppler George 2707 kuppler George 3373 Kurzweil Lloyd 859 Kush Lynn 1220 Kush Lynn 2011 Kush Lynn 2881 Kush Lynn 3145 Kuticka Sheri 71 L.Carpenter Anon 504 L.Lovely Michael 1018 L.Peffer Robert 2120 L.Yaco Anon 1628 La Cruz Carole 1649 La Cruz Carole 3102 Lackner Lucas 1150 Lacy Sharon 109 Laffey Karen 3087 Lahorgue Frank 1422 Lai A 1588 Laiti Jared 1525 Lake Daphne 220 Lakota Anne 752 Lamb Alexandra 603 Lambart Eric 602 Lambart Eric 2677 Lambert Carol 681 Lambert Mara 846 Lambert Mara 1186 Lambert Mara 2370 Lamberty Janis 1130
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Lamoreau Jessica 3470 Lander Sue 2170 Lane J 248 Lane Marilyn 2533 lane priscilla 270 lane priscilla 497 LANG Dominique 2896 Langford Charles 310 Langford Charles 2819 Langston Zed 2525 Lanz Eugene 648 LaPage Ted 2494 Lapointe Kenneth 2341 Lapointe Kenneth 2768 Lapointe Kenneth 3245 Laporte Mike 804 Larcome Richard 2359 LArison John 3131 Larks Wendy 615 Larson Janet 657 Larson Keith 3404 Lasahn J 1410 Lau Monique 200 Lauer Marcy 470 Lauer Richard 423 Laughery Cynthia 3387 Laurance Lauree 2411 Laurance Lauree 3051 Law Randa 912 lawford rhonda 2745 lawford rhonda 2933 Lawrence Beverley 988
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Lawrence Carol 1413 Lawrence Chris 1695 Lazar Burt 1630 Lazar Magdolna 26 Lazarus Chris 2557 Lazier Steffani 1090 Lazos Lauren 3420 Leblanc Joe 756 Leclair Michael 2220 Ledden Dennis 1587 Lee Jean 678 Lee Jeff 3148 Lee Jonathan 410 Lee Nicholas 1866 Lee Nicholas 2835 Lee Regina 2149 Lee Sherrie 741 Lee Trina 613 Lee Trisha 733 Leech Kathryn 1430 Leech Ruba 16 Leeds Vicki 1375 Lefebvre Lyne 2860 Lefever Kristina 1699 Lefler Jacque 1025 LeGue Mark 2558 Lehr Beverly 1325 Lemley Carol 2865 Lenchner Nicholas 328 Lenk Karen 1726 Lennard Spencer 2089 Lennard Spencer 2393
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Lenstet Kathryn 1555 Lentz Christine 2945 Lenzen-DebadVallie 1393 Leonard Lance 1937 Lescher George 1750 Lesh Carol 3466 Lesmond Michelle 1562 Lester Rebecca 819 Lester Susankay 1189 LeVee Penny 2018 Leverette Adrienne 2887 Levin Beth 115 Levin Beth 1927 Levine Chuck 616 Levine David 1969 Levine David 3548 Levine Ellen 2513 Levy David 1151 Lewis Ashley 12 Lewis Gerald 3307 Lewis Tommy 829 Lewis Wendy 324 Liberge Marcel 438 Liberman Elinor 1008 Light Wendy 1041 Lilla Brian 1269 Linam Stephanie 479 Lind Larry 2029 lindey robert 785 Lindgren Connie 1066 Lindgren Jean 128 Lindh Carrie 477
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Lindner Bill 1504 Lion-Storm Nancy 3360 Lipman Deborah 2761 Lippmann Rebecca 3460 Lips Bev 1314 lips stu 1019 lips stu 1667 Lis Fleming David 1007 Lish Christopher 3069 Little Heather 2957 Little James 1842 Little John 1676 Little Nancy 2949 Livingston John 1315 Livingston John 1722 Livingston John 2825 Livingston John 3061 Lloyd Darvel 120 Lloyd Darvel 428 Lloyd George 1329 Lobel Colleen 2744 Lobel Colleen 2953 Lockhart Jim 1620 Lodeesen David 2965 Loe Steve 3086 Lofgren Carol 363 Loh Nicole 1853 Loh Nicole 2815 Lombard Ruth 103 Lonergan James 1685 Long Dwight 2791 Long Elizabeth 2043
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Long Kit 1143 Long Loretta 726 Longan Lynn 1873 Longan Lynn 2908 Longan Lynn 3397 Loosli Ed 620 Lopez Mary 536 Lord Tracy 2058 Lord Tracy 3316 Loro Karen 51 Louie Denise 1092 Louis Jeanette 2650 Lovato Dominic 1889 Lovato Dominic 3276 Loveland Jim 606 Loveland Jim 626 Lovig Jayne 1621 Lowe Alta 1597 Lowrey Donita 2853 Lowry Marsha 69 Lucas Janie 1378 Luck Diane 1596 Lunn Ardis 2872 Lutje Debra 2774 Lutsuk Alicia 1099 Luursema Eva 2937 Lyda Mary 250 Lyles Nancy 601 Lynch Charles 538 Lynch Topher 3500 Lynn Alice 1115 Lynn Fischer Phil 10
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Lynne Penelope 28 Lyon Jane 1519 Lyons Dustin 1067 Lyons Dustin 1949 Lyons Dustin 3542 Lytle Denise 2448 M Ann 914 M g 2040 M June 2940 M Kira 133 M Kristi 1765 M Kristi 3314 M Sarah 938 M. Keiko 406 M.A.Kruse Anon 1389 M.E.Braun Anon 1802 M.Ohanian Laura 1841 Mac Graham Marcy 2134 Macan Catherine 1296 Macan Edward 1111 MacCollom Alex 1636 MacComb Alan 510 Maceira David 1429 MacGregor Therese 1874 Macias Sherry 1647 MacIntosh Stephne 863 Mack Chris 277 MacKay Ingeborg 486 MacKenzie Susan 639 Mackie Craig 2924 MacKinnon Bonnie 1295 MacKinnon Bonnie 2332
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MacKinnon Bonnie 3154 Mackinnon Jane 409 Mackler Sally 2055 MacLaggan Andrew 56 MacLeod Jimmy 1997 MacRaith Bonnie 2730 Madden Erin 2377 Madden Margaret 1602 Madigan Sally 896 Madson Carolyn 3357 Maertz Ronald 207 Maggied Michael 2060 Maggied Michael 3082 Magnuson Linda 1477 Mahoney Sarah 1248 Mainland Edward 1161 Maish Sally 1574 Maize Dave 1689 Maker Janet 2095 Maker Janet 3221 Malan-ThompKathleen 53 Malone Constance 630 Malone-PershDeja 3140 Maloney Kathleen 2204 Maloney Kathleen 3362 Mamoyac Joy 2456 Mangels Francis 262 Mangiantini Joseph 3252 Mann Sandra 2849 Mannchan Brandt 1691 Mannchan Brandt 3035 Maples Aaron 974
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Maranowski Erica 849 MarcandonatOurania 2131 MarcandonatOurania 3406 Marchel Doug 675 Marchetti Donna 537 Marie Sylvia 1516 Marilyn Reng Lee 2935 Mark Bailey Melinda 662 Marlinghaus Emilie 2756 Maron-FriendJudith 2471 MarquardsonSheree 3217 Marrs Cynthia 1000 Mars Mae 541 Marsh Samuel 1835 Marsh Susan 668 Marsh Susan 2466 Marshal Moser 3339 Marshall Dale 740 Marshall Erin 670 Marshall Raymond 1488 Martin Heidi 2194 Martin Mark 3324 Martin Martha 1285 Martin Michelle 1079 Martin Richard 560 Martin Rosada 3178 Martin Warren 3060 Masek M 351 Massa Alison 149 Massa Joy 508 Materi Sandra 1360 Materi Sandra 2234
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Materi Sandra 2651 Materi Sandra 3050 Mathews Don 350 Matthews Jill 2247 Matticola Sharon 3489 Mauk Carmen 430 Maxfield Randy 105 Maxwell Lawrence 781 May Marylyn 1042 Mayer Joellen 970 Mayer Karen 1557 Mayer Laura 2251 Mayer Oscar 2618 Mayo Alberta 1231 Mazaira Rick 3461 Mazzola Lisa 2627 Mazzola Lisa 2674 McAfee Michelle 125 McAfee Michelle 2291 McAlister Shawn 1106 McCalister Janet 724 McCall Randall 2510 McCarthy Aislinn 1157 McCauley Dion 3205 McClarty Rob 2357 McClarty Rob 3491 McCleary Bob 697 McCleary Tiffany 110 McCloskey Melanie 1530 McClure Doyle 2517 McCollum Daniel 1185 McConnell Kelly 164
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McConnell-PeSarah 1914 McCormick Devin 883 McCormick Mark 2700 McCoy Melinda 213 McCue Karen 761 McDaniel Larry 2460 McDargh Catherine 1768 McDermott Mary 2319 McDermott Mary 3477 McDonald Hilary 1666 McDowell Claire 24 McDowell Kelley 1247 Mcfadden Julia 2112 Mcfadden Julia 2235 McGanty Erin 34 McGaughey Mary 3042 McGee Kristin 2538 McGovern Donlon 816 McGowan Wendy 980 McGowan Wendy 2050 McGowan Wendy 3150 McIntyre Jerrie 108 McKeighen Daniel 1567 McKelvey Don 2739 McKenzie Eileen 809 McKinley Bertha 1496 McKinsey Margaret 2321 McKitrick Marshal 926 McKnight Stephanie 514 McLeod Eileen 963 McMonagle Rick 2497 McMullen Gail 2901
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McMurray Deborah 1362 McSweeney Charles 1533 McSweeney Charles 1653 McSweeney Charles 2075 Mctevia Andrew 2215 McVicker Luann 400 Medina Deborah 72 Meerman Thomas 2 Meier Victoria 2186 Meislin bBarbara 3553 Meister Joanne 1492 Melin Ron 1335 Melius Dan 869 Melman Laura 426 Menanno Susan 884 Menanno Susan 1799 Menanno Susan 3335 Mendez Paul 3164 Mendibles Arlene 1385 Mendoza Destiny 583 Mercer KB 1183 Meredith Donna 1204 Meredith Lauren 62 Merner Mark 204 Merrigan Anita 2177 Merrill Joan 1063 Merriman Joan 866 Merritt Regna 2824 Merryman Lindsay 718 Mertes John 1678 messett Dax 3418 Meurer Chris 2566
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Meyer Bruno 2031 Meyer Colonel 1463 meyer diane 2054 meyer diane 3177 Meyer Janet 1154 Meyer Lara 1386 Mezzapelle Cheri 87 Michaels Melissa 2221 Michaels Melissa 3369 Michalek David 3047 Michelsen Mary-Kay 2544 Mick David 3554 Micketti Joseph 1814 Micketti Joseph 3279 Miesen Janis 37 Mikal Baker 551 Mikasi Ayani 1972 Mikolajczyk Ga 1867 Mikula Richard 2226 miles jeff 2373 Miles Yvonne 699 Miller annika 1145 Miller Arthur 1227 Miller Caroline 1615 Miller Jack 138 Miller James 2773 Miller Jennifer 2742 Miller Ken 2113 Miller Ken 3410 Miller Melissa 1523 Miller Neil 2222 Miller Pam 540
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Miller Pamela 2130 Miller Pamela 2640 Miller Pamela 3020 Miller Pamela 3555 Miller Richard 397 Miller Robert 1778 Miller Robert 3488 Milton Jack 177 Minkus Carol 166 Minnick Margaret 704 Mintkeski Walt 1941 Misner Patricia 652 Mitchell Dave 2540 Mitchell Tamara 2864 Moffatt Alden 1258 Mohr Jon 95 Moissant Helen 553 Moldal David 3273 Molgora Bianca 782 Molinar Angela 2037 Mollo Elizabeth 942 Molnar Daniela 1298 Monahan Gregory 2430 Monroe James 1235 Mont-Eton Jean 66 Montano Brandi 828 Monteith Dawn 145 Monteith Dawn 526 Montgomery Edih 983 Montgomery Edih 1897 Montgomery Edih 3166 Montgomery Maggie 1903
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Moody Cathe 1577 Moon Rick 1027 Moore Amanda 1442 Moore Betty 2617 Moore Malcolm 948 Moore ML 2025 moore Penny 1887 Moose Mary 233 Mooshie Marilyn 2580 Moraiti Vicky 2111 Moraiti Vicky 3223 Morales Marisa 2532 Morgan Evan 1570 Morgan Judy 853 Morgan Kelly 2886 Morgan Linda 375 Moricca Joan 1648 Moritz Jules 2920 Morley Julaine 52 Morningstar Larry 2104 Morningstar Larry 3220 Morningstar Myrica 2181 Morris Zachary 3261 Morrish Ken 1872 Morrison Glenn 550 Morse Bob 1803 Morton Robin 481 Mosqueda Anna 3027 Moszyk John 1162 Moszyk John 2775 Moulard Roger 1822 Moulton Rene 3071
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Mrs. Charles Mr. 1848 Mrs. John KU Mr. 1900 Mueller Christine 155 Mueller Roger 1850 Mueller Thomas 2445 Mueller-BrowJulie 3383 Mugele Kathleen 23 Mulcare James 119 Mulcare James 2302 Mulcare James 2314 Mulcare James 2451 Mulcare James 2572 Mulcare James 3365 Mullaney Bryan 789 Mullaney Bryan 1928 Mullendore Eric 2168 Mulligan Hilary 1110 munson deanna 2554 Murakami Maki 2468 Murakami Maki 2661 Murphy Donna 1268 Murphy Melissa 283 Murphy Teri 703 Murray Cristy 90 Murray Peter 3377 Murray Roy 1627 Musser Richard 1149 Myers Adele 3333 Myers Donna 106 N.C Anon 230 N.Morris Donald 1851 Nacrelli Michael 1890
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Nafziger Nikki 3497 Nagel Lawrence 2041 Nagel Lawrence 3301 Nahigian Kenneth 1261 Nahill Brad 3556 NarbutovskihAnna 355 Nardella Lynn 1113 Narvios Raquel 877 Narvios Tem 465 Nauman April 3155 Nauman Cory 3170 Nazor Craig 2561 Nazzaro Maria 3559 Nazzaro Patricia 2262 Nazzaro Patricia 3452 Neal Charles 1558 Neihart Janet 2074 Neihart Janet 3183 Nelson Deborah 2788 Nelson Ian 376 Nelson Jan 820 Nelson Kimber 2897 Nelson Tammy 2374 Ness Gina 787 Neste Lisa 2506 Neste Lisa 2861 Nettleton John 2361 Nettleton John 3206 Neuenburg Melody 1069 Neus Marleen 1948 Neus Marleen 2964 Neus Marleen 3265
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Name Comment Text Response Text
Newberger Mark 2256 Newcomb Carroll 1720 Newell Nancy 2890 Newlin Cedar 2699 Newton Susan 349 Nichols Alicja 2973 Nichols Guy 1520 Nickle Paige 920 Nicodemus Sharon 1675 Nicodemus Sharon 2549 Nicodemus Sharon 2593 Nicodemus Sharon 3135 Nicoletto Linda 684 Nielsen Sonja 2653 Niemann Barbara 1500 Nirmaier Allison 1158 Nissen Joanie 2188 Nissen Joanie 3337 Nistad Kimberly 1052 nj12hsus@gmAnon 2795 Nkrumah Samuel 574 Noack Michael 1616 Noble Ann 1510 NOBLE Erin 2344 Noel Letitia 2418 Noel Letitia 3161 Noland John 2947 Nordeman Valerie 1337 Norman Gunta 2284 Norman Gunta 2951 Norman Gunta 3269 Norman Julie 1947
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Name Comment Text Response Text
Norman Tim 3030 Norup Paul 2541 Nounnan Jack 1443 Nowicki Maria 289 Nudelman Deb 196 Nuessle Charlotte 2268 Nuessle Charlotte 3499 Nugent Carol 1236 Null Ciry 2327 Nurse Heidi 3327 O Catherine 364 O'Brien Jess 2101 O'Brien Meighan 476 O'Brien Shayne 542 O'Donahue Joni 1418 o'donoghue rosalind 2904 O'Driscoll Maggie 1262 O'Hara Sharon 910 O'Keefe Lauren 1425 O'Melia Megan 1905 O'Neal Maureen 2106 O'Neal Maureen 2631 O'Neal Maureen 3120 O'Neal Maureen 3432 O'Neil Leslie 2732 O'Neil Leslie 3288 O'Neill Maureen 1650 O'Rorke Dennis 307 O. Raychel 2433 Oakes Ashley 1659 Oakley Cliff 1796 Oakley Cliff 3472
Page 304 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Oaks Phoebe 1043 Obrien Kathy 994 Obrien William 1623 Obrien William 2283 Ocean Alisa 2520 Ocean Alisa 3469 ocean chris 2577 Oconnor Siochai 629 Odell Rollin 812 Oder Stephen 701 Oder Stephen 2907 Oehler John 1786 Ogan Sean 379 Ojeda Jr Joe 301 Olafsson Sveinn 1163 olch karen 894 Olenjack Michael 2088 Olivier Larry 2711 Olsen Victoria 381 Olson Allen 2524 Olson Allen 2746 Olson David 1899 Olson David 3214 Olson Leah 1272 Omann Geneva 2312 Onasch Carole 2634 Ong Ning 330 Opgenorth Lucas 2413 Orengo-McFaMichelle 1460 Orf Becky 2269 Orlando Roberta 1146 Orth Marla 404
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Name Comment Text Response Text
Ortiz Robert 1009 Osborne Samantha 2163 osmun Richard 2882 Ostler Rosemarie 2906 Overman Greg 58 OVERMAN KYLE 2003 Overy Linda 1234 Owen James 3052 Owens Cindy 1273 Owens Theresa 1003 ozkan dogan 2444 ozkan dogan 2472 P C 1532 P J 1609 Padgett Beverly 953 Pagsolingan Czora 339 Paige Nieba 1387 Palacky Tami 1249 Palacky Tami 1701 Palacky Tami 2679 Palacky Tami 2817 Palacky Tami 3329 Palaia Constance 2218 Palladino Travis 777 Palzer Bob 3328 Panayi Christopher 1134 Panayi Christopher 2404 Panayi Christopher 2871 Panayi Christopher 3197 Pannell Bonnie 371 Paradise Brian 1952 Paramore Eileen 2276
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Name Comment Text Response Text
Paraszewski Joseph 1054 Paravagna Linda 1131 Parham Mary 271 Pariani Laura 833 Park Wendy 424 Parker Pancho 2136 Parker Robert 101 Parkhurst Christine 160 Parlette Karen 168 Parris Joel 1792 Pasichnyk Richard 801 Pasillas Christina 1498 Pasillas Christina 2844 PASQUA JOHN 2250 PASQUA JOHN 3043 Pass Alanna 2663 Patotzka Lori 1096 patten carolyn 1794 Patten Jasmine 1864 Patten Jasmine 3424 Patterson Katherine 1077 Patterson Kevin 981 Paul Tanya 231 Paulus Audie 1028 Paxton Dia 2350 Paxton Dia 3423 Payette Aaron 244 Payne Dale 1022 Payne Kennett 713 Pearce Mark 3199 Pearl Alita 645 Pearson Sean 3143
Page 307 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Peavy Jerry 1300 Peck Karin 1244 Peffer Robert 3527 Pelfini Allison 329 pelleg josh 2664 Pellicani Andrea 1472 Pellicani Andrea 2077 Pellicani Andrea 3023 Pendergast James 580 Penney Janet 522 Penney Janet 847 Peranio-Paz Giana 2971 Perez Margarita 634 Peril S 267 Pero Mike 3440 Perricelli Claire 1196 Perricelli Claire 1886 Perry Brenda 268 Perry Jim 933 Perry Laurie 20 Perry Laurie 2571 Peters Valerie 3303 Petersen Meghan 661 peterson beth 3293 Peterson Connie 2698 Peterson Davin 1180 Peterson Ed 1728 Peterson Kim 902 Peterson Mary 3398 Peterson Michael 2910 Peterson Terri 1037 Peterson Tyson 418
Page 308 of 341 Chetco Bar Fire Salvage Project Comment Analysis
Name Comment Text Response Text
Petroni John 1 Petrulias Linda 2315 Peyser Victoria 2903 Peyser Victoria 2914 Pfander Ellen 2632 pfeffer gordon 3258 Pfohl Travis 3259 Pfost Leslie 1793 Phelps Tami 73 Philips Jesse 2308 Phillips Debra 1012 Phillips Donna-Lee 999 Phillips Robert 1229 Picchetti Gloria 2103 Picchetti Gloria 2786 Pichardo Morena 559 Pichel Vanna 1490 Picton Rebecca 797 Pincetich Christopher 612 Pinson Luan 2512 Pintagro Thomas 2771 Pisani Maureen 769 Pizzo Carolyn 839 Pizzo J 717 Plitt Kathryn 124 Poggi Pietro 565 Pointe Amber 1857 Polk Nora 1572 Pombo Brian 1208 Pomies Jackie 1187 Pond Christopher 2521 Ponte Alyson 2157
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Name Comment Text Response Text
Pool Joan 1256 Popovic RatkaMira 3058 Porch Delores 2840 Porter Joelle 856 Porterfield Joseph 1614 Poscharscky Debra 664 Powell David 3260 Powell Gary 217 Powell Gary 2300 Powell Jeanne 468 Powell Kathleen 1080 Powers Kara 732 Powers Susan 5 Prandi Linda 3213 Preston Lynne 1071 Price Dan 2928 Price Linda 719 Price Marilyn 745 Price Michael 2545 Priebe Matthew 1293 Prince Steve 302 Prince Steve 2787 Prince Steve 3462 Prince Susan 323 Pringle Mark 3124 Pruett Jim 3348 Puaoi Richard 473 Pugliese Norman 2401 Purvis Virginia 700 Quentin Margaret 165 Quillian Phoebe 1933 Quillian Phoebe 3350
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Name Comment Text Response Text
Quillin Karen 460 Quinn David 3541 Quinn Pat 81 Quintanilla Nancy 1906 R B 2956 R.Griffith Nancy 202 R.Zierikzee Anon 1284 Raborn Gail 412 Radys Karen 318 Raffetto Christine 30 Rahberger Linda 2348 Rahmun Lindsay 548 Raible Annette 967 Rajan Sara 3033 Ramaker Julianne 489 Ramirez Cheryle-May 2174 Ramsey Elizabeth 1332 Ramsey Walter 593 Randall David 1960 Randall Philip 464 Randick Marlys 861 Raney Dennis 2076 Rangeloff Michael 2763 Ranuio Cindy 1373 Ranz Lauren 716 Rappolt Chrissie 2737 Rasler Dr.Michael 97 Rasler Dr.Michael 627 Rasmussen Debie 1419 Ratcliff Philip 389 Ratcliff Philip 898 Ratner Marjorie 2272
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Name Comment Text Response Text
Ratner Ronald 2767 Rauworth Steve 1152 Ray Celeste 2306 Ray Rick 573 Ream Casey 1411 Rebenstorf Barbara 779 Redden Denise 515 Redman Julie 2942 Reed Robert 1221 Reed Tessa 2162 reeson paulo 2454 Reeves Lenore 1253 Reeves Lenore 2339 Reeves Lenore 2537 Reeves Lenore 2673 Reeves Lenore 3190 Rego James 786 Rego Jessa 3294 Rego Maria 728 Rehder Melissa 179 Rehg Charmaine 1911 Rehné Veronica 2966 Reid Gabby 952 Rein Kari 2273 Rein Kari 3176 Reinberg Donald 1444 Reis Maria 710 Reiswig Claire 3094 Remy Casey 1601 Remy Casey 2726 Remy Linda 1540 Rennacker Ann 3321
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Name Comment Text Response Text
Reno Sienna 1473 Rensch Pam 1635 Rettmann Jonathan 3074 Reuter Debra 227 Rex Eli 1594 Reynolds Andrea 872 Reynolds Jim 564 Reynolds Krista 2740 Reynolds Marjorie 2366 Reynolds Rozlyn 3451 Rhee Donna 2121 Rhein Tansy 3351 Ricci Mark 185 Riccio Catherine 1170 Rice Jan 2098 Rice Joseph 1861 rice kyra 3515 Rice Walter 568 Richards Jay 750 Richmond David 2827 Richmond Lonna 1432 Ricker Robin 38 Rickerson Paul 1965 Rickerson Paul 3487 Ridder Lynette 1591 Riddle Donna 184 Riepe Linda 1164 Riha John 2068 Riley Scott 1064 Rinas Juanita 1610 Rinas Juanita 1956 Rinas Juanita 3224
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Name Comment Text Response Text
Ringgaard Line 2151 Ringgaard Line 2458 Ringgaard Line 3246 Rinne Fred 881 Rippey Ray 1684 Risberg Erica 2762 Rischel Lauren 1480 Rischel Lauren 2783 Riser Marianna 3105 Risso Susanne 1112 Rita Grauer James 1668 Rivera Christine 1276 Rivera Javier 2821 Rizer William 2862 Rizza Sam 3095 Roberge Cheryl 3438 Robert Moser 3244 Roberts Brock 530 Roberts Brock 2801 Roberts Harriet 2440 Roberts Jeff 2007 Robertson Arran 2741 robertson mike 2490 Robins Arlin 2620 Robinson Diana 1592 Robinson Dvora 714 Robinson Janet 1988 Robinson Janet 2702 Robinson Janet 3112 Robinson Joyce 2092 Robinson Mary 15 Rochambeau Rod 1714
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Name Comment Text Response Text
roche maureen 421 roche maureen 3378 Rochester Mark 751 Rochford Cyd 275 Rockwell Charles 1624 Roden Vanessa 484 Rodgers John 1061 Rodriguez Lorena 186 Rodriguez Lorena 637 Roether Evelyn 2252 Rogers Mark 3482 Rogers Maureen 1435 Rohn Douglas 3008 Rohr Barbara 986 Rohr Kathy 3540 Rohrbaugh Stacey 749 Roland Raymie 282 Rollison Sheri 1349 Roma Michele 36 Romero Devin 818 Romero Valerie 1171 Romero Valerie 1657 Romine-Man Courtney 1743 Romine-Man Courtney 3534 Romo Roberto 299 Rorick Andrew 766 Rose Becky 1109 Rose Cora 3448 Rose Katie 2894 Rose Tona 1388 Rose-WagnerPatricia 1209 Rosenbaum John 332
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Name Comment Text Response Text
rosenberg Jay 3407 Ross Cory 1257 Ross Paulette 1456 Ross Susan 1405 Ross Wilson 2164 Rossi Greta 2692 Rowe Daniel 1829 Rowe Daniel 3157 Rowe Erin 1365 Rowe Gret 237 Rowe Ren 445 Rowlison Suellen 269 Rozner Tom 113 Rubin Brady 2028 Rubin Brady 3287 Rubin Toni 3569 Rubschlager Matthew 2476 Rudd Valerie 1035 Rudh Nissa 3544 Rudolph John 3031 Ruediger Luke 2387 Rueger Janet 2437 Ruff Bryan 686 Ruiz Kathleen 183 Rust David 1487 Ryan Marie 174 Ryan Wayne 85 Ryder Patricia 808 Ryland Gail 1165 S A 123 S. Ron 1016 S. Ron 2171
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Name Comment Text Response Text
S. Ron 2196 S. Ron 3242 S.Chapek Anon 1265 Sabatini Kathy 535 Sacks Yale 1744 Sadler Darla 1355 Saglietto Eve 2293 Saikevych Irene 1489 Salinas Andrea 1303 Salmon David 3533 Salomon Sherry 1086 Saltzen JoAn 2420 Saltzen JoAn 3026 Salyers helen 411 Sambora Lisa 879 SAMPER SANDRY 2504 sampson Katherine 2486 Samson Steven 3264 Samuelson Georgeanne 171 Samuelson Georgeanne 2633 Sanchez Paul 651 Sanchez Tony 1884 sanders m 205 sanders moya 814 Sanders Robert 2033 Sanders Robert 2686 Sanders Robert 2697 Sanders Robert 3204 Sanders Sandra 1737 Sands Mike 1907 Sandstrom S.Deirdre 1114 Sandstrom S.Deirdre 1485
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Name Comment Text Response Text
Sandvik Richard 1039 Sanford Mallory 1779 SANG sau 2271 Sanguinetti John 457 Santiago Barbara 1880 Santone Deborah 2507 Santoro Michele 864 Saravanja Natasha 3274 Sargent-ReedLeah 1688 Sasaoka Julie 11 Saslow M 1168 Saucy Michael 2997 Saul David 2354 Saul David 2874 Saul David 3496 Saunders Ellen 2601 Savala Elke 380 Savala Elke 774 Savoie Joy 2190 Sawyer Michael 778 Saxe Anne 134 Saxon Diana 901 saxton karen 2435 Saylor Loralei 721 Scarpaci Mark 2065 Scelza Sharon 1992 Schader Kevin 1359 Schaefer Patrick 3025 Schaffer Carol 903 Scher Carol 743 Schiffman Lauren 1046 Schilling Jessy 3054
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Name Comment Text Response Text
Schillo Noah 576 Schimke Whitney 1913 Schipper Dini 2728 Schlegel Lois 2297 Schmeder Nadya 891 Schmidt Irene 2069 Schmidt Lee 2729 Schmidt Ron 1497 Schmidt Susie 2102 Schmitz Heidi 1179 Schmokel Stan 1412 Schondorf Lee 1225 Schonert Jessica 3121 Schoppert Linda 1087 Schrama Tamara 3041 schuemmer sue 2356 Schultz Judith 366 Schumacher Amy 2087 Schwartz Don 433 Schwartz Jake 443 schwartz joyce 2946 Schwarz Andrew 1748 SchwarzschildNomi 319 Schweickart Diana 582 Scott Barbie 1038 Scott Marilynn 899 Seaforth Janet 3332 Sebastian Joseph 288 Sebring Stacy 2021 Segal Sarah 3372 Seiber Suzanne 3474 Seigel Neil 2402
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Name Comment Text Response Text
Seigel Neil 2622 Seigel Neil 3240 Seil Fredrick 2552 Sekander Martha 3267 Selden Scott 1806 Seldom mr 2013 Seltzer Rob 1474 Seltzer Rob 2778 Semple John 2336 Senteney Jason 1979 Serafini Diane 1282 Sergienko Peter 1439 Sergienko Peter 1673 Serna Jessica 532 Serra Dawn 3537 Sesto Holly 2240 Severson Derek 1777 Sévilla Caroline 2499 Sewall Dana 531 Sewall Dana 2659 Sexton Chessley 1716 Sexton George 2317 Sexton George 2978 Sexton George 2981 Sexton George 2987 Sexton George 2991 Sexton George 2992 Sexton George 2996 Sexton George 3526 sexton sara 2668 sexton sara 3309 Shabbott Mary 2665
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Name Comment Text Response Text
Shaffer Kathleen 239 Shanafelt Betsy 1985 Shane Stephen 452 Shanker Gopal 284 Shapira Susan 218 shapiro steven 960 Sharee Donna 1001 Sharnoff Stephen 1950 Sharp Donna 327 Sharp Margaret 836 Shauinger Lynn 1453 Shaw Jonathan 2108 Shaw Joseph 419 Sheehy Steve 2313 Sheehy Steve 2503 Sheehy Steve 3441 Shein Keith 1278 Shelby BC 391 Sheldon Michelle 2855 Shelley Dan 472 Shelley Edward 1809 Shelley Ian 2724 Shelley Jon 260 Shelton-RohdLisa 2144 shenkinl leslie 2662 Shepard Tricia 135 Shepherd Marilyn 1421 Sherman David 274 Sherman Elisabeth 1030 Sherrill Tyler 354 Sherwood Dan 1190 Sherwood Dan 2563
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Name Comment Text Response Text
Shields Katherine 1974 Shirkey Paul 2481 Shirley Rebecca 1482 Shirley NelsonMilton 2584 Shook Anna 343 shore elizabeth 871 Short Samittria 3422 Shortridge Katrina 566 Showerman Linda 2231 Shreve Rick 112 Shultz Lehi 2596 Shunn Shanti 2005 Siegner Sandra 60 Siegner Sandra 2625 Silen Stephan 46 Silkey Ulrike 234 Silvey Katherine 1155 Silvey Kevin 1756 Silvey Kevin 3299 Simmons James 1070 Simon Katy 549 Simon Peter 1541 Simon Peter 2658 Simon Philip 303 Simon Roslyn 1246 Simonson Annette 2340 Simpson Suzanne 1059 Sinclair Christine 922 Sinclair Karen 518 Singer Ellen 2635 Singerline Terrence 3391 Singh Sajan 659
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Name Comment Text Response Text
Sinnott Scott 3300 Sinram Danika 241 Sivesind Torunn 273 Sjogren Karen 2636 Skell Deborah 437 Skinner Michelle 940 Skirvin Katherine 2909 Skye Kat 1383 Slaton Nicole 1174 Slikas Elizabeth 918 Slikas Elizabeth 2828 Smale Maryann 3408 Small Barbara 1404 Small Ricardo 2487 Smiley Karl 471 Smith Candace 1006 smith candice 2325 Smith Christopher 2555 Smith Decker 1286 Smith Donald 2214 Smith Glenn 683 Smith Hillary 1631 Smith Joan 802 Smith Kellie 2399 Smith Kellie 2852 Smith Kristin 162 Smith Linda 989 Smith Linda 2395 Smith Louis 1739 Smith Louis 3476 Smith Mick 317 Smith Mick 2129
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Name Comment Text Response Text
smith mike 1599 Smith Rachel 1535 Smith Sally 1194 Smith Sara 855 Smith Shirley 370 Smith Tammy 759 Smith Tiffany 3442 Snouffer Michael 1813 Snouffer Michael 3531 Snow Opie 1686 Snyder Gail 2733 Snyder Susan 1211 Snyder Todd 1502 Sobolik Dennis 2208 Sobotka Jon 2694 Soderstrom Janet 1245 Soerensen Erika 738 Sojourner Mary 1953 Soldanels Lori 2869 Soltesz Steven 2688 Solway Sean 2331 Sonenshine Scott 1808 Sonenshine Scott 3370 Sophia Ilana 2588 Sorensen Janell 2423 Sorensen Janell 3290 Sorenson Doug 1178 Sorrels Brandess 3349 Soto Angelica 611 Sovola Dr.Shelley 1141 Spence Kathryn 653 Spencer Amy 1133
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Name Comment Text Response Text
Spencer Steph 2238 spencer steph 2837 Spencer Steph 3003 Sperry Sheridan 1486 Spevak Edward 1824 Spevak Edward 1875 Spevak Edward 3137 Spicer Patricia 1123 Spies Ron 3067 Spini Jane 152 Spiritwalker Lila 1784 Spotts Richard 731 Spotts Richard 2066 Spotts Richard 2397 Spotts Richard 3354 Spotts Richard 3568 Spradley Jess 1771 Sprague Lisa 607 Spratley Richard 2803 Sprnger Sarah 1353 Sroa Linda 187 St.Germain Kelly 1462 Stafford Sarah 413 Stannard Danielle 1883 Stansbury Katherine 2793 Stansfield Lesley 862 Stansfield Lesley 1142 Stansfield Lesley 3518 Starr Kimberly 206 Stebbings Barrie 243 Steele Christine 3239 Steele Lisa 1005
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Stefanik Fiona 2660 Steffen Maria 3160 Stein Cynthia 1638 Steinberger Judy 2515 Steinbreche Kathy 873 Steininger Lorenz 722 Steininger Lorenz 2282 Steininger Lorenz 2621 Steininger Lorenz 2675 Steininger Lorenz 3342 Steinwurtzel Matt 3001 Steitz Jim 2062 Steitz Jim 3146 Stephan Stephanie 13 Stephens Chandra 1177 Stephens Margaret 1639 Steponaitis John 1438 Sterling Michele 1288 Stern Kenneth 3453 Stern Matt 2654 Stevens Janet 1862 Stevens Kelly 2644 Stevens Nancy 3212 stevens sarah 22 Stevens-BriodSusan 2431 Stevens-BriodSusan 3009 Stewart Christine 2809 Stewart John 300 Stewart Lesley 3198 Stewart Mary 810 Stice Laura 844 Stiles Sarah 546
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Name Comment Text Response Text
Stillings Lorrie 556 Stillwaggon Daniel 569 Stinchcomb julie 1584 Stirpe D 92 Stoilov Luben 306 Stokes Diana 1344 Stone Gwen 2565 Stone Jan 1125 Stone Jan 2680 Stone Jeffrey 1446 Stone Jeffrey 2200 Stone Jeffrey 2727 Stone Robert 2015 Strailey Faith 1398 Strailey Piers 969 Strasser Jurgen 337 Stratton Anthony 1499 Straus Faye 261 Strickland Karen 1991 Strockis Desiree 3528 Stroup David 3510 Stufflebeam J 2523 STUTHEIT DANIELLE 2822 Suba?? Mesut 2813 Sullivan Edward 1361 Sullivan Jerry 2026 Summers Jan 291 Sumner Jeanne 18 Susman Cathey 2802 Sustaita miaya 623 swan shirley 2706 swan shirley 3291
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Name Comment Text Response Text
Swanson Kristen 712 Swanson Kristen 2583 Sweet-BunneAmanda 1166 Swenning Christine 1447 Swenson Jean 660 Swift Kay 578 Swisher William 1391 Sykes Wally 916 Sylvae Carla 2192 Sylvae Carla 3547 sylvae Lina 3059 Sysamouth Mali 671 T Jessica 446 T Rae 378 T Sara 663 Taft Kathleen 17 Takaro Mark 2285 Takaro Mark 3070 Talbot Michael 693 Tamburello Kristopher 2187 Tamori Carolee 1613 Tanner Karen 1172 Tanzer Elaine 1343 Taroli Garry 2316 Taroli Garry 3532 Tarver Letitia 925 Taudvin Diane 1698 Taudvin Diane 3450 Taylor Andrew 1010 Taylor Andrew 2279 Taylor Anne 1896 Taylor Barbara 1554
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Name Comment Text Response Text
Taylor Cynthia 394 Taylor Holly 633 Taylor J.Holley 388 Taylor Jacqueline 1868 Taylor Jacqueline 3401 Taylor Jamie 3037 taylor michelle 2630 Taylor Nannette 746 Taylor Oakley 708 Taylor Richard 796 Taylor Steph 2553 Taylor Stephanie 1923 Taylor Stephanie 3393 Tays Kimberly 3068 Tedesco-Kerr Terry 2371 Tedesco-Kerr Terry 2646 Tedesco-Kerr Terry 3417 Telep Gerald 587 Tennant Allie 1672 Tenscher Max 1773 Tepoel Karen 1836 Terrell Jo 1754 Terry Susan 221 Tetley Richard 2255 Tetley Richard 3142 Thalmayer Amber 880 Thalmayer Amber 1767 Thalmayer Amber 3443 Thaw John 937 Therry Dennis 1376 Thieke David 1585 Thiemann Eva 2012
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Name Comment Text Response Text
Thiemann Eva 2099 Thieret Jeffrey 1774 Thomas Bob 1004 Thomas Bob 1800 Thomas Bob 3014 Thomas Bob 3567 Thomas Mary 2562 Thomas Mary 2932 Thompson Carol 1449 Thompson Carol 1951 Thompson Carol 2597 Thompson Carol 3334 Thompson Donna 1893 Thompson Donna 3514 Thompson Katherine 1283 Thompson Lauren 298 Thompson Pat 383 Thompson Richard 3426 Thompson Robin 1831 Thompson Ronald 2139 Thompson Ronald 3519 Thompson Sabrina 2492 Thomson Joyce 1423 Thoreen Marlys 905 Thorwaldson Nancy 1467 Tibbot Ann 2036 Tidwell Stephanie 2155 Tiefer Hillary 1505 Tim Scholl Sue 1313 Tinker Caroline 3169 Todd A. 2619 Tom Beene 2123
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Name Comment Text Response Text
Tomblin Maren 1214 Tomczyszyn Michael 136 Tomlinson Barbara 632 Tomlinson David 2328 TONET Monique 2962 Toney Kevin 1539 Toni Canning Stephen 2888 Torelli Cynthia 1198 Toriello Frank 775 Touchstone Lana 975 Townsend Alan 1336 Townsend charles 2789 Townsend Tamara 2624 Trantham Julie 415 Trapp Gene 1416 Trauth Beti 3483 Treacy Carol 1053 Treadwell Elaine 219 Treffinger Katherine 265 Trejo Deborah 2063 Trevethan Evelyn 908 Tribble Michael 830 Tribble Michael 848 Tribble Peggy 416 Triggs Bob 3368 Trosper Cheryl 1219 Troup Scott 3228 Troxell Christopher 3543 Trufan Hal 1036 Trufan Hal 3480 Trumper Karen 2183 TSANG SAU 2866
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Name Comment Text Response Text
Tubbs Ellen 1469 Tucker James 1354 Tuddenham Anne 689 Turner Dena 2475 Turtle Carol 2777 Tvedt David 266 Tvedt David 2498 Twombly Glen 909 Unger Michelle 353 Unger Michelle 1119 Usami Chris 2223 Uyeki Bill 3511 Vaile Joseph 1865 Vaile Joseph 3563 Vaile Sarah 1788 Valastro Cecile 209 Valastro Cecile 2530 Valencia Carmel 2133 Valencia Mandy 2407 Vallejo Maria 1032 Vance Victoria 776 Vardanyan Artur 1859 Vardanyan Artur 3317 Varga John 2275 Vasquez Silvia 42 vayu satya 3439 Vayu Satya 3564 Vazquez Patricia 2929 Vazquez Patricia 2934 Vel Jen 935 Venegas Jeff 314 VERGILIA NADINE 2030
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Name Comment Text Response Text
VERGILIA NADINE 3064 Vest Lori 195 Vida Tímea 2603 Vigil Trisha 2294 Vigil Trisha 3243 Vilbrandt Jody 463 Villalobos Briana 2233 Ville Anna 1091 Vinogradoff Anna 748 Vinson Jean 342 Vinton Janine 1704 Vinton Janine 3032 Vlasiadis Andreas 1333 vlasiadis andreas 2527 Volk-AndersoVirginia 492 Vollmer Alex 1366 Vorachek Mary 114 Vorachek Mary 1981 Voruz Judy 2191 VourosCallah Pamela 2207 VourosCallah Pamela 3319 Voves Deborah 2666 Vu Tung 1292 Vuist-Bruske Martha 941 W.Clark Anon 1238 W.Clark Anon 1669 W.Clark Anon 2384 W.Clark Anon 3078 W.McAlister Kevin 3062 Wacker Heidi 2295 Waichler Colin 462 Wakefield Marie 1397
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Name Comment Text Response Text
Wakefield Marie 1782 Wald-Tuttle Anita 158 Walden James 1040 Waldron Elizabeth 2713 Waldroup Linda 624 Walker Constance 2140 Walker Joan 621 Walker Joan 2280 Walker Joan 3535 Walker Leann 841 Walker Ted 1724 Walker-Dale Heather 358 Walker-Sloss Halorie 194 Wallace Marti 1132 Wallace Melanie 293 Wallace Nathan 3056 Wallace Susan 878 Wallick Richard 1138 Walters Linda 1957 Walters Linda 2999 Walters Nathaniel 1598 Ward Dona 543 Ward Lori 4 Waring Alysa 915 Warner Chris 843 Warriner Elizabeth 590 Wasbauer Marius 2326 Wasgatt Ann 9 Washington Chris 1618 Washington Chris 1769 Washington Chris 2808 Washington Chris 3285
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Waterhouse Dennis 1102 Watkins Warren 374 Watkins Warren 501 Watrous Barbara 2135 Watrous Barbara 2851 Watrous Ellen 2880 Watson Claire 3208 Watson Donna 570 Watson Kathleen 690 Watson Michael 1122 Watson Valerie 172 Watts Elizabeth 2587 Watts Linda 2489 Weaver Geoff 2258 Weaver Kathy 170 Weaver Sylvia 1901 Weaver William 1454 Webb Randall 1083 Weberski John 242 Wechsler Susan 1224 Wecker Tamara 762 Wedell Indira 199 Wei Annie 2638 Wei Annie 2676 Wei Annie 2916 Weidner Naomi 2195 WEIGEL RICHARD 2769 Weiner Joan 3436 Weinstein Diane 1705 Weis Vincent 67 Weiser Charlotte 971 Weissbuch Brian 1663
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Name Comment Text Response Text
Welch Joanna 1573 wells greeley 2080 Wells Janette 163 Wells Lasha 2913 Welsh Hartwell 852 welsh shari 1898 Wendel Tom 1580 Wendla DuncBruce 2502 Wenzell Katherine 3192 Wenzlaff Carla 2911 Wert Katharine 2301 Wert Kirsten 3546 Werthman Julie 520 West Dennis 1358 Wetteland Signe 61 Whaley Richard 650 Whalley Ruby 2213 Wheeler Mark 1536 Wheeler Mark 1718 Wheeler Mark 2493 Wheeler Mark 3048 Wheeler Thomas 1104 Whelan Barbara 2264 Wherley Michael 259 Wherley Michael 1935 Whisenand Gretchen 403 Whitaker Howard 1544 White Ann 735 White Daniel 2574 White Jeffrey 2114 White Karen 439 White Lois 1507
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White Lois 1629 White Maria 427 white paul 1712 White Rebecca 2116 Whiting gm 1308 Whitworth Amy 116 Whyte Richard 2931 Wick Kim 840 Wick Kimberly 188 Wiebenson Sarah 1126 wiegmann mira 2320 Wieland Chuck 98 Wilber Stewart 367 Wilburn Patricia 146 Wilcox Judy 949 Wiley Kimberly 335 Wiley Kimberly 811 Wiley Kimberly 2955 Wiley Mark 2286 Wiley Ralph 2044 Wilfong-Grus Ellen 2303 wilhelm martha 1825 wilhelm martha 3271 Wilkins Jaci 1369 Wilkins Joe 1821 Wilkinson Barbara 1517 Williams David 2798 williams freddie 2027 williams freddie 2073 williams freddie 3298 Williams Glen 395 Williams Jack 3338
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Name Comment Text Response Text
Williams Kathy 1790 Williams Kathy 1892 Williams Kyenne 1484 williams michael 2500 williams mitch 2578 Williams R.Terra 1290 Williams Terrie 1734 Williams Terrie 3218 Williams Zack 3402 Willis Dave 1239 Wilson Elias 3502 Wilson Jim 258 Wilson Katalin 705 Wilson Richard 2390 Winchester Stew 618 Winkle Jenny 2145 Winnett Jason 2246 Winter Edward 2446 Winter Edward 2877 Winter Margery 2368 Winter Margery 3405 Winters Drusilla 711 Wintman Karen 674 Wirt Cara 1697 Wisdom Robin 2203 Wismer Bruce 945 Wissler Aaron 2410 Witbeck-OsboCheryl 169 Witchner Beverly 867 Witt Matt 1908 Wobus Elizabeth 1118 Wolcott Leslie 32
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Name Comment Text Response Text
Wolf David 644 Wolf Janette 669 Wolfe Carol 229 Wolfe Katherine 2281 Wolfe Katherine 3326 Wolfe Michael 1097 Wolff Cam 2898 Wong Bill 1153 Wood Andrew 3088 wood barbara 1891 Wood Pamela 407 Woodall Sandra 1357 Woodall Sandra 2152 Woodall Sandra 2626 Woodall Sandra 2876 Woodall Sandra 3099 Woodard Jud 1478 Woodbury Ross 995 Woodhouse Marily 3230 Woodriff Elaine 851 Woodriff Elaine 2224 Woodriff Elaine 3304 Woods James 130 Woodward Linda 1203 Woodz Stephen 2137 Woolford Ronald 588 Woolley John 1755 Woolley John 2723 Woolley John 3123 Woolley Josh 1999 Woolley Josh 3072 Woolsey Carri 279
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Worden Viki 2941 Workman Elizabeth 2892 Worth Debra 1605 Wortman Jan 3344 Wright Jan 1815 Wright Marcia 313 Wright Sheila 1581 Wu Blake 923 Wyatt Jill 2832 Wyman Jean 1230 Wyman Jean 2657 Wymetalek Pat 2202 Yancey Reuben 1934 Yarbrough Jim 309 Yarbrough Jim 498 Yarbrough Jim 1700 Yarbrough Jim 3017 Yates Pamela 47 Yeager Sky 1340 Yeager Sky 2919 York Dan 3270 Young Karen 677 Young Leda 1302 Young Lily 1617 Zangara Amanda 850 Zauskey Vince 1696 Zawacki Zosia 2428 Zebker David 495 Zeller Rudy 1205 Zellman Rich 3549 zelmanovich silvana 1319 Zenker Rev.Elizabeth 788
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Zern Sam 1455 Zerzan Paula 346 Zilberstein Gene 1511 Zimmerer Sheryl 3241 Zook Suzanne 1694 Zuber Bruce 2057 Zuber Eric 1966 Zuber Marvin 2201 Zucker M.Lee 605 Zucker M.Lee 1804 Zucker M.Lee 3465 zucker marguery 2758 Zufelt Steven 3318 Zukoski Katie 121 Zumeta Ben 2051 Zumeta Ben & Kristen 2229 Zumeta Benjamin 2193 Zumeta Benjamin 3028 Zumeta Kristen 2032 Zumeta Kristen 2623 Zuuk Alan 2806
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