Chapter 4—Environmental Consequences Giant Sequoia National Monument, Final Environmental Impact Statement Volume 1 377 Chapter 4—Environmental Consequences Volume 1 Giant Sequoia National Monument, Final Environmental Impact Statement 378 Chapter 4—Environmental Consequences Chapter 4 includes the environmental effects analysis. ● Activities would only be conducted after It is organized by resource area, in the same manner appropriate project-level NEPA analysis, if as Chapter 3. Effects are displayed for separate required. resource areas in terms of the ongoing, indirect, and ● Reasonably foreseeable actions do not follow cumulative effects associated with the six alternatives the management direction proposed in the action considered in detail. Effects can be neutral, alternatives. beneficial, or adverse. This chapter also discusses the unavoidable adverse effects, the relationship The following types of actions should be considered between short-term uses and long-term productivity, (depending on resource area): and any irreversible and irretrievable commitments of resources. Environmental consequences form the ● Annual maintenance activities in the scientific and analytical basis for comparison of the Monument, such as roads, trails, special use alternatives. permits, and administrative and recreation sites. These are the activities necessary to maintain basic compliance with regulation and annual operating Types of Effects plans. The Giant Sequoia National Monument Plan is a ● Fuels management in the Monument, such as programmatic plan that defines and describes the prescribed fire and managed wildfire, pile burning, management direction for the Monument for the next maintenance of WUIs (including mechanical 10 to 15 years. Programmatic plans are consistent treatments), and additional fuels reduction with national direction and are, by nature, strategic activities as a result of other vegetation or site and make no site-specific project decisions. There maintenance work (e.g., hazard tree abatement in are effects associated with those decisions and campgrounds). those effects are described and disclosed in this ● Construction or reconstruction of FEIS consistent with the requirements of NEPA. administrative or developed recreation sites Specifically, a description of the environmental effects in the Monument, such as proposals for site associated with this analysis of all of the potential maintenance or deferred maintenance that are effects (ongoing, indirect, and cumulative effects) is listed in existing site management strategies. included in this chapter. ● Grazing allotment management inside and Reasonably Foreseeable outside of the Monument, such as cattle grazing, maintenance activities (including fence repair or Actions construction), and water source maintenance. A reasonably foreseeable action is defined as any ● Road decommissioning inside and outside of project or activity for which the effects overlap in the Monument, such as decommissioning roads time and location with the effects of the project or portions of roads that are part of the designated under consideration (i.e., this EIS). There are a road system for the Sequoia National Forest. number of reasonably foreseeable actions that will, or are likely to, occur which may affect resources ● Tree removal on state, federal, tribal, or private in the Monument. A list of anticipated reasonably lands adjacent to or outside of the Monument, foreseeable actions was developed for resource including portions of enjoined timber sales in the specialists to use during their effects analyses. This Sequoia National Forest outside of the Monument, list is based on these key assumptions: and tree removal for wood production on state, federal, tribal, or private lands. ● Each resource area may be affected in different ways and intensities by these potential activities. ● Reforestation and plantation maintenance activities adjacent to or outside of the ● The timeframe is within the next 3-10 years, Monument, such as site preparation, planting, depending on the resource area. releasing planted trees from competing vegetation, and gopher baiting. Giant Sequoia National Monument, Final Environmental Impact Statement Volume 1 379 Chapter 4—Environmental Consequences ● Annual maintenance activities on state, federal, past actions on an individual basis would not be useful or tribal lands adjacent to the Monument, to predict the cumulative effects of the proposed such as those for roads, trails, special use permits, action or alternatives. In fact, focusing on individual administrative and recreation sites. These are the actions would be less accurate than looking at existing activities necessary to maintain basic compliance conditions, because information is limited on the with regulations and annual operating plans. environmental effects of individual past actions, and one cannot reasonably identify each and every action ● Fuels management on state, federal, or over the last century that has contributed to current tribal lands adjacent to the Monument, such conditions. Also, focusing on the effects of past as prescribed burns and managed wildfires, human actions risks ignoring the important residual pile burning, maintenance of WUIs, and fuels effects of past natural events, which may contribute to reduction activities as a result of other vegetation cumulative effects just as much as human actions. By or site maintenance work (e.g., hazard tree looking at current conditions, the residual effects of abatement in campgrounds). past human actions and natural events, regardless of ● Construction and maintenance activities on which particular action or event contributed to those private lands adjacent to or surrounded by effects, are captured. the Monument, such as home construction, fuels reduction, and ranch or other private business Finally, the Council on Environmental Quality operations. issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states, ● Increasing public pressure (proportional to “agencies can conduct an adequate cumulative increasing general population) for recreation on effects analysis by focusing on the current aggregate and commodities from state, federal, and local effects of past actions without delving into the agency lands (including the Monument and historical details of individual past actions.” The other ownerships in the vicinity), such as clean cumulative effects analysis in this EIS is consistent water, places to recreate, and special products. with the National Environmental Policy Act (NEPA) Regulations (36 CFR 220.4 (f)) (July 24, 2008), Cumulative Effects which state, in part: Analysis Criteria CEQ regulations do not require the consideration In order to understand the contribution of past actions of the individual effects of all past actions to to the effects of the proposed action and alternatives, determine the present effects of past actions. Once this analysis relies on current environmental the agency has identified those present effects of conditions that are a result, in part, of past actions. past actions that warrant consideration, the agency Existing conditions reflect the combined effect of assesses the extent that the effects of the proposal all prior human actions and natural events that have for agency action or its alternatives will add to, affected the environment and might contribute to modify, or mitigate those effects. The final analysis cumulative effects. documents an agency assessment of the cumulative effects of the actions considered (including past, The cumulative effects analyses in this chapter do present, and reasonable foreseeable future actions) not attempt to quantify the effects of past human on the affected environment. With respect to past actions by adding up all prior actions on an action- actions, during the scoping process and subsequent by-action basis. Several reasons exist for not taking preparation of the analysis, the agency must this approach. First, a catalog and analysis of all determine what information regarding past actions past actions would be impractical to compile and is useful and relevant to the required analysis of unduly costly to obtain. Current conditions have been cumulative effects. Cataloging past actions and affected by innumerable actions over the last century specific information about the direct and indirect (and beyond), and trying to isolate the individual effects of their design and implementation could in actions that continue to have residual effects would some contexts be useful to predict the cumulative be nearly impossible. Second, providing the details of effects of the proposal. The CEQ regulations, Volume 1 Giant Sequoia National Monument, Final Environmental Impact Statement 380 Chapter 4—Environmental Consequences however, do not require agencies to catalogue and context for maintaining or restoring ecological or exhaustively list and analyze all individual conditions that provide the desired levels of resources, past actions. Simply because information about such as clean water, clean air, plant and animal past actions may be available or obtained with community diversity, and species viability, consistent reasonable effort does not mean that it is relevant with regulatory requirements and ongoing policies” and necessary to inform decisionmaking (40 CFR (2001 SNFPA, Appendix T, p. T-1). 1508.7). Ecosystem analysis provides opportunities to perform For these reasons, the analysis of past actions in this assessments that