Response to Comments

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Appendix E – Response to Comments Results of the Comment Period The comment period for the environmental assessment resulted in the receipt of 525 comment letters, including 40 unique letters and 453 form letters, and 32 form letters that included additional information (“form-plus letters”). Comments were identified in these letters regarding issues and concerns raised by the author that are directly related to proposed project activities. These comments were then categorized according to the primary topics of their content. Within these topics areas, comments were grouped together and summarized along with similar comments. The interdisciplinary team then responded to these summary statements to address the issue or concern identified, or clarify where more information was requested. As you will see below, each topic area begins with this summary “concern statement,” followed by the Forest Service’s response, and then a table of the quoted comments as they appeared in submitted letters. If a comment was unique in its subject from any other comments, it was addressed individually. Any comments that provided substantive new information were considered and necessary revisions made to the environmental assessment and supporting documents or addressed in the draft decision notice. Literature provided in support of a comment that was not previously considered was reviewed by resource specialists and considered in their final analyses where applicable to the Seiad-Horse Risk Reduction Project. A table is included below which lists the names of commenters who submitted letters with a unique identifying number assigned to each commenter. Form letters are included once in this list with one identifying number, although form plus letters are uniquely numbered. All letters submitted during the EA comment period are available for review in the public reading room on the project website: https://www.fs.usda.gov/project/?project=52933 Quoted comments included in this response document are identified by unique comment number which is first the number of the letter submitted, and second a unique identifying number for the comment itself. Should commenters seek to find responses to their own specific comments, this letter number identifier can be used to search for where the Forest responded to their comments in this document. Finally, a table of comment topics is provided to allow for navigation to topics a reviewer may be interested in reading. Regarding the comment response topic numbers themselves, they are not intended to provide any prioritization for the topics discussed (the topics are randomly ordered) and are not continuous (some numbers are missing). These numbers were generated by the database used to process and analyze comments and do not represent any intention of the responders. Missing numbers do not mean that responses or comments are missing or not included. The environmental assessment (EA) referenced in this response to comments is the EA that was available at the time of its release for the public review and comment period unless it is identified specifically as the updated EA.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Commenters by Name, Organizational Affiliation (if provided), Letter Number and Letter Type Letter Name Organization Letter Type # Michelle Bienick 1 Unique Vickie Simmons Seiad Resident 2 Unique Debbie Taylor Seiad Resident 3 Unique Dustin Kuykendall 4 Unique Courtlandt Jennings 5 Master Form Andrew Schwarz Ridgeline Meadows Farms 6 Form Plus Patrick Ayres Seiad Fire Safe Council 7 Unique Sandra Baker 8 Unique Anon Anderson 9 Master Form Hannal Cate 12 Form Plus Cindy Cordova 15 Form Plus Jeff Davies 16 Form Plus Anon Ellis 18 Form Plus Kelley Harding 21 Form Plus Mark Harlings 22 Form Plus Patricia Hine 24 Form Plus Anonymous 25 Form Plus Anonymous 26 Form Plus Anonymous 30 Form Plus Andrea Anon 31 Form Plus Anonymous 32 Form Plus Michelle Lute 35 Form Plus Anon Meyer 37 Form Plus Ann Millhollen 38 Form Plus Lynda Pries 41 Form Plus Hallie Roberts 44 Form Plus Max Ha Sierra Pacific Industries 46 Unique 49 to 51 George Sexton KS Wild Unique and 69 Ian Nelson PCTA 52 Unique 53 Klamath Forest Alliance Luke Ruediger and Unique (Siskiyou Field Office) 56 Dominick DellaSala, Ph.D Geo Institute 54 Unique Luke Breit 57 Form Plus Gary Rainey Horse Creek Resident 58 Unique Kimberly Baker Klamath Forest Alliance 59 Unique

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Letter Name Organization Letter Type # Christopher Lish 60 Unique 62 to Tom Wheeler EPIC Unique 65 Greeley Wells 66 Unique Gail Battaglia 67 Unique Casey Slezak 68 Unique Park Walker 70 Unique Georgina Wright 71 Unique Wendy Lawrence 111 Form Plus Doug Heiken 148 Unique Charlene Woodcock 176 Form Plus Bill Gardner 203 Form Plus John Livingston 213 Form Plus Nancy Schimmel 231 Unique Nuri Pierce 238 Form Plus Bojan Ingle 264 Form Plus John Rogerson 288 Unique Carolyn Ayres 316 Unique Bonnie MacRaith 368 Form Plus Tanya Marseille 435 Unique Lawrence Jimenez 437 Form Plus Tena Scruggs 453 Unique Jared Laiti 475 Unique N.D. Fenton 554 Unique Siskiyou Chapter Native Suzie Savoie 572 Unique Plant Society of Oregon Klamath-Siskiyou Native Suzie Savoie 573 Unique Seeds Roarke Ball 574 Unique Christie Nelson 575 Form Plus Mike Nelson 577 Form Plus Brodia Minter 578 Unique Skye McKnight 868 Form Plus North Coast Regional Fred Blatt Water Quality Control 1067 Unique Board

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Table of Comment Response Numbers and Topics Comment Response #1: Support for prescribed fire and private property fuels treatment ...... 7 Comment Response #2: Activity Fuels Treatment ...... 8 Comment Response #3: Susceptibility of plantations to fire ...... 12 Comment Response #4: Fish habitat and reproduction ...... 18 Comment Response #7: Tribe, community, and stakeholder involvement ...... 20 Comment Response #8: Abney Fire suppression activities ...... 21 Comment Response #9: Water Board Waiver and Permits Required ...... 25 Comment Response #10: Legacy Sediment Site Treatment Effects ...... 27 Comment Response #11: Fire Regime Characterization ...... 29 Comment Response #12: Natural Recovery ...... 32 Comment Response #13: Fuel Break Effectiveness and Feasibility ...... 42 Comment Response #14: Large versus small diameter fuel removal effects ...... 42 Comment Response #15: Use of RAVG data for post-fire assessments ...... 45 Comment Response #16: Treat more area and in a timely manner ...... 46 Comment Response #19: Effects to Soil Stability ...... 47 Comment Response #22: Soil Effects Analysis...... 49 Comment Response #23: Implementation Costs versus Benefits ...... 50 Comment Response #25: Effects to Soil Compaction ...... 51 Comment Response #26: Application of the Watershed Analysis ...... 53 Comment Response #27: Visual impacts of salvage near the Pacific Crest Trail (PCT) ...... 55 Comment Response #30: Support for artificial reforestation ...... 60 Comment Response #31: Hazard tree removal near the Pacific Crest Trail...... 60 Comment Response #33: Large Woody Debris Removal ...... 61 Comment Response #34: Bee Camp Road (47N80) should be closed ...... 62 Comment Response #35: Support for roadside hazard tree removal ...... 64 Comment Response #36: Hazard Tree Removal in Riparian Reserves ...... 64 Comment Response #37: Application of Hazard Tree Guidelines ...... 66 Comment Response #40: Too Much Large Woody Debris ...... 67 Comment Response #41: Sale Administration Marking ...... 67 Comment Response #43: Temporary Road Locations ...... 68 Comment Response #44: Roadside Hazards in Cook and Green SIA...... 69

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #45: Green Tree Harvest ...... 70 Comment Response #46: Salvage Harvest near Inventoried Roadless Area ...... 72 Comment Response #47: Salvage in the Late Successional Reserve ...... 72 Comment Response #48: Focus on Fuels, Hazards, and Burning, not Salvage ...... 77 Comment Response #49: Project Design Features Inadequate to Protect Rare Plants ...... 78 Comment Response #51: Bee Camp Road Hazard Tree Removal ...... 79 Comment Response #52: Opposed to Salvage ...... 82 Comment Response #54: Salvage along the Siskiyou Crest ...... 83 Comment Response #55: Snag and Coarse Woody Debris Retention ...... 84 Comment Response #56: Risk of Non-native Invasive Species Spread ...... 87 Comment Response #57: Clearcutting...... 91 Comment Response #60: General Project Support ...... 92 Comment Response #62: Effects to Late Successional Reserve Characteristics ...... 93 Comment Response #67: Alternative 2 Support ...... 97 Comment Response #71: Environmental Impact Statement is Necessary ...... 97 Comment Response #72: Opposing Views and Scientific Controversy ...... 102 Comment Response #73: Consideration of Relevant Issues from Scoping ...... 104 Comment Response #74: Salvage in Riparian Reserves ...... 106 Comment Response #75: Aquatic Conservation Strategy Compliance ...... 107 Comment Response #76: Sedimentation and Water Quality ...... 109 Comment Response #77: Watershed Effects Analysis ...... 119 Comment Response #78: Siskiyou Crest as a Regional Connectivity Corridor ...... 121 Comment Response #81: Wildlife Effects Analysis ...... 132 Comment Response #82: Effects to Northern Spotted Owl ...... 135 Comment Response #83: Northern Spotted Owl Recovery Plan ...... 137 Comment Response #85: Ecological Benefits of Snags and Course Woody Debris ...... 144 Comment Response #86: Salvage Harvest is Economically Motivated ...... 148 Comment Response #88: Cool, Moist Habitat Post-Fire ...... 149 Comment Response #90: Inconsistent with the Forest Plan ...... 153 Comment Response #91: Reforestation Strategy not disclosed ...... 153 Comment Response #92: Fish Habitat Improvement ...... 155 Comment Response #93: Project Design Features and Best Management Practices are Insufficient ...... 156

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #96: Cumulative Effects Analysis ...... 157 Comment Response #97: Sensitive Plant Viability Post-Fire ...... 161 Comment Response #100: Range of Alternatives ...... 162 Comment Response #101: Karuk and Beschta Alternatives ...... 165 Comment Response #104: Prescribed Fire Implementation ...... 166 Comment Response #105: Small Brush Re-sprout ...... 167 Comment Response #106: Effects of Temporary Roads and Landings ...... 167 Comment Response #107: General Project Opposition...... 168 Comment Response #108: Activities Proposed in the Inventoried Roadless Areas ...... 169 Comment Response #112: Botany Retention Areas ...... 170 Comment Response #113: Wildlife Species not included in Analysis ...... 171 Comment Response #114: Wildlife Use of Burned Areas ...... 173 Comment Response #115: Spatial Extent of Wildlife Analysis ...... 175 Comment Response #116: Use of VQO standards near the Pacific Crest Trail ...... 177 Comment Response #117: Reopening Decommissioned Roads ...... 178 Comment Response #118: Recommendations of the Late Successional Reserve Assessment not Addressed ...... 178 Comment Response #119: Baker Cypress ...... 180 Comment Response #121: Water Board Suggestion for Project Design Feature ...... 180 Literature Provided during the Comment Period ...... 182

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #1: Support for prescribed fire and private property fuels treatment Concern statement: There is support for the prescribed fire activities and fuels reduction activities adjacent to private property. Commenters are supportive of these activities because they may reduce the risk of future wildfire, contribute toward fire resiliency, and aid in the development of a fire adapted forest. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. Associated Comments: Comment # Comments As a home owner in Seiad Valley I have been negatively impacted by several forest fires since 2012. I believe that it is time to do something about the causes. This risk reduction 2-1 project proposes to reduce fuels near private property so that will be a good start. I support this project. Implement prescribed fire treatments to reduce fuel loading and protect nearby 5-8 communities from wildland fire. The proposed fuel reduction adjacent to private land and underburning prescriptions are generally supported by our organizations. These portions are consistent with a "risk 53-12 reduction" project, meet the purpose and need for the project and will encourage fire resilience. We support the responsible use of prescribed fire in the Seiad Horse Planning Area. The 53-278 application of prescribed fire 10-15 years following the Abney Fire could have very positive results for fire resilience and stand development if implemented correctly. Our organizations support private land fuel reduction treatments as proposed in the Seiad Horse Risk Reduction Project. These treatments should be designed to protect private residential inholdings, create defensible fuel profiles in which fire crews can work and 53-282 maintain important ecological values. Providing a buffer around private land with responsible fuel reduction treatments should be a priority if the project is to live up to its name as a risk reduction project. This should specifically apply to private residential land within the planning area.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments We support the use of prescribed fire to maintain fire regimes and protect nearby communities. If the Seiad Horse Risk Reduction Project is to live up to its name and provide fire risk reduction to Seiad Valley and Horse Creek, the use of prescribed fire is required. Prescribed fire will create more healthy, fire adapted conditions than any manual treatment. It will also create far more effective fuel breaks by treating all fuel types from live standing vegetation to duff layers and downed wood. Only prescribed fire and 53-289 wildland fire management have the potential to create highly effective fuel breaks in the form of fire footprints. Community fire resilience requires the judicious use of prescribed fire and the maintenance of recent fire footprints adjacent to rural communities like Seiad Valley and Horse Creek. Wildfire will continue burning in the backcountry of the Klamath River, communities must adapt, evolve and learn to burn in the Wildland Urban Interface and on private land closest to rural residences and infrastructure. Additionally, just as the Abney Fire reduced fuels and made the forests around my home more fire resilient in the future, the residents of Seiad Valley are also well fortified, as they 573-7 have many fire footprints around the valley to lessen fire severity in the near future. Maintenance of these fire areas with prescribed fire is all that is needed to keep homes safe going forward.

Comment Response #2: Activity Fuels Treatment Concern statement: There is a concern that as a result of salvage treatments in the project, a large quantity of activity fuels (surface fuels, or slash) would be generated and, if untreated, increase the risk of future wildfire with high severity burning in the treatment units. Comments claim that the EA did not disclose or analyze the amount of logging slash produced nor the duration that it would remain on the landscape prior to being treated according the Forest's capacity and funding to implement. Forest Service Response: The EA demonstrates that all of the analyzed action alternatives substantially reduce the potential for extreme fire behavior and associated potential for severe burn effects in the future (Table 13, page 53; Tables 20 through 23, pages 60, 61, and 62EA). Studies have shown that a pulse of fuel loading (limbs, tops, and other unmerchantable material) from post-salvage harvesting can occur and increase fire behavior. However, the fuels treatment design for the action alternatives was designed to reduce the amount of fuel post-salvage harvest through a variety of follow-up fuels treatments. The amount of estimated fuel loading for each alternative is disclosed in tables 17 and 20. The results for action alternatives show that "As a result of reduced fuel loading, there would be a decrease in overall flame length potential for the project area…." EA, page 61. The Seiad-Horse Risk Reduction Project includes treatment of activity fuels and therefore findings from studies with respect to increased fuel loading post-salvage logging without activity fuels treatments do not appear to be relevant. Post-logging fuels treatments, such as pile and burning or broadcast burning (jackpot burning), as proposed in the action alternatives, can rapidly reduce total amounts and spatial continuity of surface woody fuels, and may allow logged stands to serve as fuel breaks in a landscape level fuel management strategy (Peterson

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

and Harrod, 2010). For further information, see EA pages 51 through 67 and the response to concern statement #14. While the agency remains confident here that the necessary funding will be acquired when needed for those activities to be implemented, there is no requirement that the receipts from the salvage harvest proposed here or funds from any other sources cover the costs of those future activities. Under current management priorities, national forest timber sales are generally designed to accomplish management or ecological objectives that may have multiple benefits; their primary purpose is not revenue generation. Other actions, such as post-fire slash treatments, are likely to come from a variety of funding sources, including congressional appropriations, grants and agreements, and to a lesser extent timber sale receipts. Forest Service appropriations are authorized by Congress on an annual basis. Because of this, the agency cannot obligate congressionally-appropriated funds for actions to be carried out in future years. We believe the Seiad-Horse Project is likely to receive the funding it requires for full implementation over the course of the project, and the agency is committed to using whatever funds it has available to accomplish the project's post-sale restoration goals. Associated Comments: Comment # Comments Salvage logging would create an immediate source of highly flammable fuel. The forthcoming NEPA document must disclose how many tons of slash would remain per acre and how its presence might influence the multitude of lightning strikes that occur in the watershed regularly....This issue is highly significant because other federal land agencies have acknowledged in NEPA documents that fine woody material up to three inches in 49-49 diameter, such as the tops of trees, has the greatest influence on the rate of spread and flame length of a fire, which has direct impacts on fire suppression efforts (e.g., USDI 2002, USDA 1994). "Salvage logging could increase fuel loadings by 10 tons to the acre or more. With this immediate change in the project area's fuel model, higher rates of fire spread and greater flame lengths would occur." (Rothermel 1991). Direct attack of a fire would be limited under some weather conditions so indirect measures would become necessary. This, in turn, would increase the size and cost of a 49-50 wildfire. Slash created by logging operations, if not treated, would also increase the duration and intensity of a ground fire. The same will be true in the Seiad Horse Risk Reduction Project. The goal is to "get the cut 53-178 out", not reduce activity slash in a timely manner. The Seiad Horse EA failed to disclose or analyze the true extent of activity slash that will be 53-179 created by post-fire logging projects or the duration it will persist on the landscape. The agency must conduct analysis based on the actual capacity of the KNF to implement proposed slash removal activities given the demands of other projects, limited available 53-181 funding, and increasingly numerous post-fire logging units across the KNF that are currently in need of treatment. It is clear to most all fire scientists and firefighting personnel that "heavy logging slash" Fuel Model 13, is the most problematic fuel, with the highest potential fire line intensity. Yet, treating this slash in the post-fire landscape has become increasingly difficult due to 53-183 the sheer number of acres involved. It has also been shown that treating post fire logging slash can affect plant succession and thus forest regeneration. (Strittholt, 2004 P. 19) Likewise, treating logging slash in recently burned areas can increase erosion.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The EA failed to disclose the actual timeframe under which slash removal will be conducted and quantify the increased fuel hazards associated with this logging slash. If slash removal will take 5, 10 or 20 years, this must be disclosed and the increased fire risk 53-189 to nearby communities quantified in fire/fuel analysis. • The EA failed to disclose and analyze the mechanism through which slash removal will be conducted. If slash removal is to be paid for with funding generated from timber receipts, the price of recently harvested timber in the Westside Fire Recovery Project should be used in the economic analysis. The EA failed to disclose and analyze an increase in activity slash within post fire logging units. The EA also failed to quantify tons per acre of activity slash and identify the 53-193 projected duration of time necessary to remove activity slash in post-fire logging units. This increase in small diameter fuel loading after commercial harvest will increase fire risks within the planning area for an undisclosed number of years. The vast majority of slash removal on the Westside Project and the Horse Creek Community Protection and Restoration Project has not been implemented, drastically increasing fuel risks in affected stands. Given the current backlog of thousands of acres, it is likely that the same outcome will affect the post-fire logging proposed in the Seiad Horse Risk Reduction Project. Project acres should be scaled back to reflect the actual 53-194 funds available for activity slash removal. If funding is not available to cleanup all activity slash within three years of implementation, fuel reduction benefits analyzed in the EA will not be realized. All units that cannot be cleanup in three years should be canceled. Units further from the community of Seiad Valley and Horse Creek should be dropped first, including those on the Siskiyou Crest. No logging should take place unless slash can be removed in a timely manner. The EIS must identify projected flame lengths at 3,5,10, 15 and 30 years in treatment unit following implementation of post-fire logging. Flame length modeling should consider tons 53-196 per acre of logging slash and the actual timeframe under which these activity fuels can be removed. The EA failed to disclose and analyze the estimated tons per acre of activity slash created 53-198 in the Seiad Horse Risk Reduction Project. The analysis should be undertaken on the stand level to inform fire risk analysis. • Current fire/fuel analysis in the EA is inadequate The analysis of fuel reduction benefits is always predicated on slash removal. If slash cannot be removed in three years, the EA should analyze the fuel reduction and fire risk reduction benefits to reflect the increased fuel risk every year that slash remains in post fire logging units. The scale of slash buildup in affected stands will drastically increase fire 53-291 risks and the potential for a severe re-burn. If the flush of fine fuel/activity slash generated during logging operations cannot be cleaned-up immediately following the sale due to fiscal constraints, then the sale should be scaled back to compensate. To do otherwise is irresponsible and will put the community of Seiad Valley and Horse Creek at elevated risk in future fires. The EA failed to disclose the most realistic timeframe under which activity slash removal will take place in post-fire logging and site prep and plant units. Analysis must disclose the 53-293 increased fire risk each year slash is not cleaned up. Current analysis does not consider additional fire risks associated with untimely slash removal. Post-fire logging creates enormous quantities of highly flammable activity-created fuel 62-25 ("slash"). Duncan (2002) reported that woody fuels on the ground surface increased 1.2 to

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments 5.3 tons per acre after post-fire logging. Donato and others (2006) compared fire hazard in the Siskiyou National Forest of Oregon burned by wildfires in 1987 and 2002, and concluded that post-fire logging significantly increased the likelihood of high-severity "reburn" compared to sites that were left to naturally recover without management due to the density and volume of fine woody fuels created by post-fire logging activities. Thompson and others (2007) reported similar results. The project will significantly increase fine fuel load on the forest floor by relocating unburned biomass (i.e., tree tops, limbs, needles) from the forest canopy to the ground surface. As discussed above, post-logging fuel treatments must follow salvage logging activities where the objective of logging is to minimize "reburn" hazard (Donato 2006, Dunn and Bailey 2015). Harvesting of trees are planned utilizing ground based, cable and helicopter logging. It is anticipated that there will be a delay between harvesting activities and associated fuel reduction activities, such as has occurred in the adjacent Westside Project. During this time frame, greater accumulation of surface fuels due to logging activities would be anticipated especially within cable and helicopter units where whole tree yarding is not typically practiced. The short term effect of logging is an elevated surface fuel loading from broken tops and branch wood. The greatest fuel loadings post-harvest is expected to occur within helicopter units, followed by cable and ground based units. However, post logging activity breaks the structure and composition of the fuel bed. Upon completion of fuel reduction activities, ground based units would be expected to reduce the greatest amounts of surface fuels due to the ease of facilitating piling and other fuels reduction activities on gentler slopes. Steeper slopes (greater than 40 percent) would be anticipated to require hand piling and or broadcast burning to achieve desired surface fuel loadings of less than 10 tons/acre. Compared to ground-based and cable units, within helicopter units or those areas on steep slopes, larger diameter (greater than 3" diameter) fuels may have increased loads as these fuels can be difficult to pile by hand. Slash fuel concentrations are likely to occur on steep slopes where post-logging pile-and-burn fuel treatments present the greatest logistical difficulty. The area to be logged by helicopter systems indicates the degree to which fire hazard will increase as a result of salvage logging with little or no post-activity fuel treatment. Multiples lines of research positively correlate post-fire logging activity with increased fire hazard and severity due to accumulations of untreated slash fuel. (Donato et al. 2006; Odion et al., 2004; Thompson et al., 2007; Weatherspoon and Skinner, 1995). According to Donato and others (2006), Postfire logging alone was notably incongruent with fuel reduction goals. Fuel reduction treatments (prescribed burning or mechanical removal) are frequently intended following postfire logging [… but resources are often not allocated to complete them. Our study underscores that, after logging, mitigation of short- term fire risk is not possible without subsequent fuel reduction treatments. However, implementing these treatments is also problematic. Mechanical removal is generally precluded by its expense, leaving prescribed burning as the most feasible method. This will result in additional seedling mortality and potentially severe soil impacts due to long duration combustion of logging- generated fuel loads. Therefore, the lowest fire risk strategy may be to leave dead trees standing as long as possible (where they are less available to surface flames), allowing for aerial decay and slow, episodic input to surface fuel loads over decades. Logging-created fuels will render direct attack of a wildfire impossible under weather conditions that commonly prevail in fire season. As a common fire suppression practice, direct attack is not to be attempted

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments when flame lengths exceed four-feet (48-inches) in height. Lost opportunity for direct attack of unplanned ignitions will, in turn, increase the size and cost of the next wildfire in the project area. It also will increase the likelihood of severe soil heating with corresponding losses of productivity. Moreover, logging-created fuels threaten fire worker safety by making wildfires more erratic and difficult to control. That risk is enhanced by the fact that the project area contains scores of road miles that may increase where the likelihood of unplanned ignition from human activity is greatest. (DellaSala and Frost 2001). The Forest Service is required to study and disclose potentially significant effects of post-fire logging on public health and safety, including foreseeable wildland fire control efforts. It should disclose post-logging fuel load and fire hazard in the project area at a unit-scale. The Forest Service should disclose how much slash would remain on the ground after logging is completed, based on site-specific analysis of available canopy fuels that would be relocated to the ground, and the likelihood of post-logging fuel treatment on steep slopes.

Comment Response #3: Susceptibility of plantations to fire Concern statement: There is a concern that the salvage harvest with site preparation and planting treatment will establish a plantation forest structure in units treated. This is a concern for commenters as research and previous fires on the Klamath National Forest have demonstrated that plantation stands, including those created as part of salvage harvest, burn and reburn at a high severity which is uncharacteristic of the project area. Forest Service Response: There is no disagreement that over time, trees will become reestablished within most severely burned areas; however, in some places this may take many decades to centuries. The Seiad- Horse Risk Reduction Project is located within Late Successional Reserves. Guidelines for risk- reduction salvage in Late Successional Reserves were provided in the Forest Plan and recommendations for management were provided in the Forest's Late-Successional Reserve Assessment. The Project as proposed is consistent with both the recommendations of the Late- Successional Reserve Assessment and the guidelines of the Forest Plan. Because Late Successional Reserves have been established to provide high quality habitat for species associated with late-successional forest conditions, management following a stand-replacing event should be designed to accelerate or not impede the development of those conditions (Forest Plan MA 5-30 (incorporated from guidelines on page C-14 of the Northwest Forest Plan ROD); Late-Successional Reserve Assessment 1-24). Research has shown that the quickest way to reestablish a coniferous forest after stand replacement fire is by active reforestation (Zhang et al. 2008). Research has also shown that traditional plantations established in areas with high slash loadings burned severely as noted by the commenters if slash has not been adequately treated (EA page 115). Research has also shown that plantations where residual slash had been adequately treated burned with much less severity and intensity or not at all (Thompson, Spies and Ganio, 2007; Weatherspoon and Skinner, 1995; Omi and Kalabokidis 1991).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Stand density in plantations can also affect stand mortality during fires (Thompson et al. 2007). In the decades from 1960 to 1990, the Forest Service typically planted several hundred trees per acre, creating dense, continuous fuel beds that burned easily, and with high intensity and severity. Much of the research on this topic considered plantations that had these dense, continuous stand conditions since those were the populations available to sample. It is not our intent to create those conditions in replanting efforts in the Seiad-Horse project area. Planting prescriptions will have variable density with relatively fewer trees on upper slopes and overall lower stocking levels than were historically used by the Forest Service. The combination of treating activity and residual fuels prior to planting, and planting trees with variable spacing and density is expected to produce a discontinuous fuel bed that is more resilient to the inevitable future fire than a continuous, densely planted stand (EA page 53). Distance from seed sources will significantly influence the amount of time for trees to become established. There are several patches that are well in excess of 1,000 acres in the project area where reestablishment of trees may take decades to centuries. Given the fire frequency in the Klamath Province it is probable that areas where fuels are not treated will go through several cycles of stand replacement fire until surface fuels created by the 2017 Abney Fire have been reduced to the point that a low to moderate fire severity regime has been reestablished. This fire cycle would maintain areas where fuels have not been reduced in semi-permanent brush fields for decades rather than accelerating the development of late-successional stand conditions. The planted trees in areas where fuels have been successfully reduced are expected to increase the likelihood that conifer forests will persist compared to stands that burned with moderate or high severity where post-fire fuels remain untreated (EA page 70).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments Cancel all post-fire tree planting, including site prep and plant units, to avoid unnatural 5-9 fuel loads, stand conditions, and regeneration. "Plantations are extremely flammable because of high crown to trunk ratio and because crowns are very close to the ground." -Upper South Fork Trinity River Happy Camp Creek Watershed Analysis, Shasta-Trinity National Forest at page 21. "One particular area of concern for potential wildfire effects in this LSR are acres in plantations. Past harvesting and fire salvage have created plantations throughout the [Johnny O' Neil] LSR." - Forestwide LSR Assessment, Johnny O' Neil Section, Page 2-76. Klamath NF. 1999. Our organizations are extremely concerned that the proposed establishment of artificial plantations may increase future fire hazard in the planning area. The agency's proposal to increase fire hazard through plantation establishment necessitates completion of an EIS for this project. The practice of planting young tree plantations significantly increases fire hazard in the mid- to long-term. "Tree plantations are more susceptible to intense fire behavior and severe fire effects than unlogged mature forests, including burned forests" (DellaSala et al. 1995, Odion et al. 2004). The increased susceptibility of plantations to severe fire is due to: 1. "Structural characteristics, such as fine and interlocking branch structures situated low to the ground, which facilitate high heat energy output by fire and rapid fire spread" (Sapsis and Brandow 1997). 2. "Warm, windy and dry microclimates 49-47 compared to what would exist in an unlogged burned forest that possessed more structural diversity, ground shading and barriers to lateral wind movement" (Countryman 1955, van Wagtendonk 1996). 3. "Accumulations of large volumes of fine logging slash on the ground surface" (Weatherspoon and Skinner 1995). In addition to these direct and indirect effects on the fire environment, the cumulative effects of plantation establishment include the creation of more highly flammable evenaged stands on a landscape already vulnerable to uncharacteristically large and severe fires. The number and distribution of even-age tree plantations resulting from industrial 19 timber management has altered fire behavior and effects at both stand and landscape scales in the Klamath National Forest. Please note that the artificial plantations established by the Forest Service following the Hog Fire Salvage in the Salmon River Watershed tended to burn at stand replacing intensity in the 2013 fire event....In summary, post-fire logging to facilitate plantation establishment will reinforce a growing tendency toward high severity fire at a landscape scale. The EA failed to acknowledge peer-reviewed findings indicating that post-fire logging and plantation establishment irreversibly hinder the natural low- and mixed-severity fire regime. Lastly, we bring to your attention the newly published 2018 study by Zald and Dunn which clearly indicates that "intensive plantation forestry characterized by young forests and spatially homogenized fuels, rather than pre-fire biomass, were significant drivers of 49-136 wildfire severity." These findings directly undercut the assumptions in the Seiad-Horse LSR clearcutting EA regarding future fire hazard from fuel removal and the creation of young tree plantations.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Fifth, the ecological importance of biological legacies and of uncommon, structurally complex early-successional stands argues against actions to achieve rapid and complete 49-145 reforestation. Re-establishing fully stocked stands on sites characterized by low severity fire may actually increase the severity of fire because of fuel loadings outside the historical range of variability. The Seiad Horse Risk Reduction Project will increase fire risks in the surrounding area and 53-8 threaten nearby communities by creating more plantation stands and increasing fuel loads. Many of the plantations created after the 1987 Fort Copper Fire closely resembled the 53-38 most likely outcome of the Seiad Horse Risk Reduction Project. That outcome is unnaturally stocked, even-aged stands and explosive fuel loads. The Seiad Horse Project proposes to re-create these plantations and make many more on 53-41 the south face of Copper Butte, increasing future fire risks with unnaturally "stocked" stands. The EA failed to disclose and analyze the impact of replanting on future fire severity. • The 53-163 EA failed to disclose the impact plantations played on fire severity in the Abney Fire. Fuel and fire risk analysis in the Seiad Horse EA did not incorporate the best available science regarding even-aged forest structure. Monitoring data from the KNF has demonstrated a correlation between increased fire severity and plantation-like stands. This finding was evident on the KNF portions of the Abney Fire where post-fire logging units and plantation-like stands burned at high severity....Many studies have also shown post-fire logging and reforestation (e.g. planting) is associated with increased fire severity 53-173 and fuel loading. The EA failed to incorporate a growing body of science regarding fire and fuel risks in plantation-like stands and following post-fire logging operations. The structural conditions encouraged by post-fire logging and artificial reforestation strongly resemble plantation structure and fuel loading. These activities are proposed on over 2,000 acres in the Seiad Horse Project, 54 significantly increasing fire and fuel risks in the Horse Creek and Seiad Creek watersheds. The KNF also failed to incorporate the recommendations and findings in its own planning documents such as the Forest-Wide LSR Assessment, the Seiad Watershed Analysis and the Forest Plan in the Seiad Horse EA. These documents repeatedly identify the risk 53-174 plantations pose to future fire severity and proper ecosystem function. Plantation stands are the most likely locations on the landscape to be affected by uncharacteristic levels of high severity fire. Numerous studies have shown that the density and configuration of regenerating vegetation has more influence on future fire severity than any other factor, including downed, fire-killed trees. A significant body of science exists to demonstrate that 53-176 plantations are highly flammable and management actions proposed in the Seiad Horse Risk Reduction Project will create very similar structural conditions, on thousands of acres in the planning area. The post-fire logging proposed in the Seiad Horse Risk Reduction Project will only create more plantation-like stands throughout the forest and specifically on the southern face of 53-185 Copper Butte. These plantation-like stands will increase fuel hazards and future fire severity, just as they did in the Abney Fire.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments In the KNF, research into the 1987 fires showed that "plantations were uniformly destroyed with few exceptions…the vast majority suffered complete mortality." (USDA FS, 1994) This quote is taken from the FEIS of the KNF LRMP, created to inform and define 53-186 management direction for the KNF. This finding is unfortunately being ignored by KNF land managers who are proposing to create 2,000 acres of plantation-like stands following the Abney Fire. Examination of the spatial pattern created by the 1987 KNF fires showed that tree plantations had twice as much crown fire as unmanaged stands. (Odion 2004) To further support these findings, analysis of the 1994 Dillion Fire on the KNF found plantations burned with more severity than unlogged stands. Plantations also created conditions that encouraged adjacent unlogged stands to burn with high severity and possibly encourage fire spread into areas that may not have otherwise burned (Key, 2000). This finding was evident on the south face of Copper Butte in the Abney Fire. Other authors agree that "reforestation goals should avoid establishing dense, uncharacteristic, "fully stocked" forests, thereby perpetuating the potential for uncharacteristic fire." (Franklin and , 2009 53-187 P.68) Weatherspoon and Skinner came to similar conclusions in their study of the 1987 Hayfork Fires (Weatherspoon and Skinner, 1996). 58 These scientific studies were conducted in ecosystems similar to the proposed project area. Their combined findings prove that post-fire logging generally leads to increased fire and fuel risks, creating higher fire severity in future fire events. Post-fire logging tends to increase fine fuels through the creation of activity slash, by altering forest succession, and hindering natural recovery. Tree planting creates simplified plantation stands with excessive fuel loads and fuel connectivity. The practice encourages high severity fire effects. To claim post-fire logging will reduce future fuel risks and wildfire severity in the project area is unsubstantiated, unfounded, and contrary to the best available science. The EA failed to disclose the estimated tons per acre of logging slash that will be generated in each unit and across the project area. Further analysis should show the potential increase in fire severity associated with this level of slash production and duration it persists on the landscape. • The EA failed to analyze the impact of the proposed action on 53-190 fuel and fire risk at 5, 15 & 30 years in the future. This analysis should be conducted with actual proposed timeframe for slash removal in mind. • The EA failed to produce analysis showing the current predicted flame length within the Abney Fire Area. Further analysis should predict flame lengths at 5, 15 and 30 years, both with and without treatment. The EA failed to utilize the best available science regarding post-fire logging, artificial 53-191 reforestation and future fire severity. The EA failed to disclose the role existing plantations played in increasing fire severity in the Abney Fire. 59 • The EA failed to disclose significant scientific findings on the KNF that demonstrate a connection between plantation-like stands and increased fire severity. • The EA failed to demonstrate the difference between proposed artificial reforestation and 53-192 plantation stand structure. • The EA failed to disclose information regarding the spacing, configuration, species planted and trees per acre planted in reforestation units in the Seiad Horse Risk Reduction Project. This lack of information renders EA fire/fuel analysis invalid and inaccurate.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments We would like to point out that if reducing high severity occurrence is the main concern of the project need, then Horse-Seiad project activities may actually increase uncharacteristic 54-44 levels of high severity fire. Notably, several studies have shown high levels of high severity on lands with intensive management similar to what is being proposed (Odion et al. 2004, Bradley et al. 2016, Zald and Dunn 2018). Post-fire logging and replanting creates flammable landscapes, the reason for much of the 57-2 high-severity burn conditions in the Abney Fire. Consider and remember what happened in these same watersheds thirty years ago. Please don't make the same mistakes! Post-fire logging and replanting has been shown to increase fire intensity and does nothing to reduce future fire potential. Allowing the forest to recover naturally will provide a 70-2 robust, diverse and fire-resistent habitat, eliminate the need to create any new roads and maintain the ecological and scenic values of the area. Post-fire logging and replanting creates flammable landscapes, the reason for much of the 71-2 high-severity burn conditions in the Abney Fire. Consider and remember what happened in these same watersheds thirty years ago. Please don't make the same mistakes! Post-fire logging and replanting creates flammable landscapes, the reason for much of the 148-4 high-severity burn conditions in the Abney Fire. Consider and remember what happened in these same watersheds thirty years ago. Please don't make the same mistakes! Post-fire logging and replanting creates flammable landscapes, the very reason for much 198-2 of the high-severity burn conditions in the Abney Fire. Remember what happened in these same watersheds thirty years ago? Given the characteristic burn patterns and beneficial fire effects, the post-fire logging, road building, and unnatural reforestation proposed in the Seiad Horse Risk Reduction Project is concerning to our organization. According to the Siead Horse EA, proposed actions include 572-1 1,269 acres of post-fire logging and 955 acres of site prep and plant prescriptions. Combined, the two prescriptions will clear 2,200 acres, mostly on the southern slope of Copper Butte on the Siskiyou Crest. The reforestation prescriptions will constitute a "type conversion" from natural, fire-affected forest to plantation-like stands of planted conifers.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments On Page 65 and 66 of the Seiad Horse EA the claim is made that if the Abney Fire is replanted within the Seiad Horse Project that Late Successional Forest will be achieved in 70 years. This is a blatantly false assumption with absolutely no science to back it up. Living near the project area where I look at both green tree and post-- fire clearcuts created in the 1980s, some 40 years ago, it is clear that the Seiad Horse area does not grow trees quickly. The clearcuts created in the 1980s were still small statured, spindly trees with no late successional characteristics whatsoever, and with no hope, in the foreseeable future, to have those characteristics. There is no way that in 30 years clearcuts created in the area would turn into late successional forest. Are there ANY 70 year--old 573-8 replanted clearcuts that are now classified as late successional forest? I would guess not. I would guess that in the harsh, rocky soils of the Siskiyou Mountains, that no 70 year--old clearcuts are currently meeting the criteria of late successional forest. The EA is erroneously making this claim and has no science or long--term monitoring data to back it up. If you clearcut and replant yet again in the Seaid Horse Project area you will simply create more highly flammable tree plantation stands that could help contribute to high-- severity fire that could move quickly with wind to burn my own house down just a few miles away as the crow flies. You will be creating a ticking time bomb of fuel hazards. Whereas, if you were to let the fire recover naturally, you will have a more natural forest recovery that is less likely to contribute to large, stand-- replacing, high--severity fire. Plantation areas have been shown to burn hotter and more fiercely than natural forests, in 575-1 addition to impacting diversity and other natural forest values.

Comment Response #4: Fish habitat and reproduction Concern statement: There is a concern regarding the effects of post-fire salvage logging on fish habitat and reproduction, specifically Coho salmon. Of particular concern is that recent and proposed instream fish habitat restoration projects will be impacted by recent post-fire private land and Forest Service salvage projects. Commenters also claim that these instream restoration projects have become mitigation measures for our salvage projects. Forest Service Response: The EA (and Aquatic Resources Report by reference) discloses that project-related increases in watershed disturbance will occur but will be minor compared to current levels of watershed disturbance from past wildfires, logging, and road or landing construction. The EA acknowledges that minor project-related increase in watershed disturbance is likely to increase adverse effects on fish habitat and populations in the short-term in watersheds that currently are near, at or exceed the threshold of concern for adverse watershed effects and that are vulnerable to further disturbance due the 2017 Abney Fire. However, the EA (and Aquatic Resources Report by reference) determined that the project is expected to benefit fish habitat and populations in the long-term by: (1) reducing risk of future largescale high severity fire that could increase sedimentation and the incidence debris flows that could alter stream channels and remove riparian vegetation shading streams, (2) reducing road-related sedimentation over current condition and post-project implementation condition, and (3) improving fish habitat through the placement of large woody debris. Minor short-term project-related increase in watershed disturbance will slightly increase the risk that existing and planned fisheries restoration projects

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest will be impacted by peak flows and/or excessive sediment transport, however, the minor short- term increase in cumulative risk does not negate the need to attempt fisheries restoration. The need to augment large woody debris in mainstem Horse Creek (and in other Klamath River tributaries) was identified as a priority fisheries restoration action by the Forest Service and the National Marine Fisheries Service long before the 2017 Abney Fire and before the development of the Seiad-Horse Risk Reduction Project. The Seiad-Horse Risk Reduction Project merely provided the opportunity and vehicle to complete environmental analysis and provide a source of logs for large wood loading into the section of mainstem Horse Creek which is within the burned-area and project-area boundary. Large wood loading into mainstem Horse Creek was not included as mitigation for the Seiad-Horse Risk Reduction Project but will help to ameliorate adverse watershed effects on fish habitat by storing sediment and slowing water velocity. This large wood loading will help improve fish habitat by sorting sediment (including creation of quality spawning gravels) and providing refugia by dissipating high water velocity during peak flows. Associated Comments: Comment # Comments Both Forest Service logging alternatives are Likely to Adversely Affect salmon critical 49-118 habitat and essential fish habitat. (EA page 94.) Recently watershed restoration projects have been implemented on Seiad Creek to benefit coho habitat. Tailing piles were re-contoured to reduce channelization, blackberries removed, off-channel habitat enhancement ponds developed, large wood structures installed and trees planted on Seiad Creek. Similar projects are being planned on Horse Creek near the confluence of Fish Creek. Both projects are being spearheaded by the Mid- Klamath Watershed Council. The Seiad Horse Project also proposes to place 27 large wood structures in a 1.4 mile reach in the mainstem of Horse Creek following logging operations. These restoration efforts will be overwhelmed by excessive sediment loads associated 53-246 with historic impacts, private land logging, recent wildfires, the Horse Creek Community Protection and Restoration Project and Seiad Horse Risk Reduction Project. The vast logged off areas, new road construction, landing construction and proposed riparian reserve logging on federal land will significantly impact important salmon habitats by disrupting instream wood recruitment, reducing water holding capacity, increasing stream temperatures, decreasing water quality, increasing peak flows and degrading riparian function. Again, rather than reduce watershed impacts, restoration projects have become mitigation measures to justify significant new impacts to aquatic habitats. EPIC is particularly concerned that beneficial uses associated with the salmon of the Mid- 62-7 Klamath—namely Rare, threatened, or endangered species and Spawning, reproduction, early development—are currently not being maintained.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #7: Tribe, community, and stakeholder involvement Concern statement: There is a concern that stakeholders, local communities, tribes, and conservationists should be consulted for the project so that it will be focused on restoration of a healthy forest. Forest Service Response: The Klamath National Forest agrees that public involvement is extremely important to identify values and issues that are important to local communities, tribes, our recreating public, and citizens across the country who are actively interested in the management of federally managed public lands. Throughout development of the Seiad-Horse Risk Reduction Project, we have reached out to our interested and affected public through the scoping process, meetings, and the public review of the environmental assessment (EA). We have consulted with the Karuk Tribe and discussed the project with the Seiad Fire Safe Council, Pacific Crest Trail Association (PCTA), and Klamath Siskiyou Wildland Center (KS Wild). Throughout the planning process, we have coordinated with our professional colleagues in the U.S. Fish and Wildlife Service, National Marine Fisheries Service, and the North Coast Regional Water Quality Control Board. Eleven formal meetings were held between mid-November of 2017 and early May 2018. The issues raised and comments received have assisted the Forest in developing alternatives that effectively respond to the concerns brought forward. For a full description of public involvement, please see the Public Involvement Section of the EA. Associated Comments: Comment # Comments Work alongside an educated conservationist to get another opinion on HEALTHY forest 1-2 management Our organizations are hopeful that the ecological impacts of salvage logging, the science regarding salvage logging, and the content of these comments may influence the direction 49-4 of this project - but we are concerned that the decision to authorize salvage logging on steep slopes of the Siskiyou Crest in the Late Successional Reserve (LSR) land use allocation may be preordained and inevitable. Please encourage the Klamath Forest leadership to work with local communities, tribal 60-4 interests and stakeholders to restore, rather than clearcut, backcountry, post-fire, Late- Successional Reserve forests in the Seiad-Horse Project Area.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #8: Abney Fire suppression activities Concern statement: There is a concern regarding the effects of suppression activities conducted during the Abney Fire. Part of this concern is that the project should include activities that mitigate the impacts of the fire suppression activities. There is also concern that the EA did not adequately address the post-fire existing condition or properly analyze fire suppression activities from the Abney Fire or of future fires, such as backfiring, dozerline construction, and snagging, as part of cumulative effects or connected action analysis. Forest Service Response: Post-fire remediation of suppression activities lines in severely burned areas are a routine part of fire suppression rehabilitation which is intended to minimize negative impacts caused by suppression activities. While there may be disagreement on this point, from our perspective, the concern for mitigation of fire suppression impacts was addressed by fire suppression rehabilitation. Actions that are part of the Burned Area Emergency Response (BAER) are intended to mitigate the effects of the wildfire. While the Abney Fire was still smoking, a BAER team was at work identifying actions that are needed to protect infrastructure, life and property such as installing water bars on firelines. The effects of the Abney Fire and its associated suppression activities are included in the analysis of effects of the Project as part of the existing condition in the project area as described in the affected environment section for Fire and Fuels, pages 37 to 44 in the EA. This is in accordance with the Council on Environmental Quality (CEQ) Guidance Memorandum on Consideration of Past Actions in Cumulative Effects Analysis dated June 24, 2005 that directs the way cumulative effects analysis should be conducted: "With respect to past actions, during the scoping process and subsequent preparation of the analysis, the agency must determine what information regarding past actions is useful and relevant to the required analysis of cumulative effects. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list and analyze all individual past actions." Mitigations for impacts from suppression activities were conducted as part of the fire suppression operations and are part of the existing condition of the project area and outside the scope of Project actions. Future fire suppression activities should not be considered in a cumulative effects analysis as this is not a reasonably foreseeable action, nor is it a connected action. The CEQ 40 questions document gives this guidance: "The agency has the responsibility to make an informed judgment, and to estimate future impacts on that basis, especially if trends are ascertainable or potential purchasers have made themselves known. The agency cannot ignore these uncertain, but probable, effects of its decision." "Reasonably foreseeable future actions" are defined in 36 CFR 220.3 and in the Forest Service Handbook at 1909.15 as "Those Federal or non-Federal activities not yet undertaken, for which there are existing decisions, funding, or identified proposals. Identified proposals for Forest Service actions are described in 220.4(a)(1)." We consider unscheduled future fire suppression activities as emergency response to an unplanned event, not as reasonably foreseeable actions that can or should be included in cumulative effects analysis. Furthermore, the commenter is correct that a connected action which should be included in a cumulative effects analysis is defined in the Forest Service Handbook as actions

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

that "cannot or will not proceed unless other actions are taken previously or simultaneously" (FSH 1909.15, zero code, section 5). While this project is designed to reduce fuels and thereby reduce future fire severity and intensity, in our judgment, project activities will not determine whether a wildfire can or will occur in the project area, nor does a future wildfire control whether the proposed project can or will occur. Fire suppression activities are an emergency response to an unplanned event and not a proposed action which is subject to Forest Service control and responsibility. Reasonably foreseeable future actions are included in our cumulative effects analysis, as shown in Appendix B of the EA. Associated Comments: Comment # Comments Focus "fire recovery" actions on mitigating impacts associated with discretionary fire 5-14 suppression activities, such as fireline rehabilitation, the removal of activity slash along firelines, and the permanent closure of firelines to discourage OHV use. During the Abney Fire, I was saddened at news that Oregon Forestry allowed their fire to 7-1 enter our district. Further, I was greatly disappointed in learning that backfiring resulted in some areas of the upper watershed being NUKED. The EA (page 53) makes the contention that "reducing these fuel loads [through clearcut logging] minimizes the intensity and severity of future fires, thus improving the likelihood 49-76 of firefighting success." Hence future fire suppression is a connected and cumulative impact with this project. Yet the agency refused to analyze or disclose this connected impact. The Abney fire drew a heavy suppression response that included tree felling, road use, burnout and use of chemical retardants over broad areas. Backer and others (2004) described numerous potentially significant adverse effects on the environment resulting from the suppression of fire including: • Direct soil damage resulting from emergency road, fire line, and helispot construction. • Hydrological impacts caused by fire lines, which 49-77 route overland water flow and disrupt soil infiltration. • Chemical pollution of water and soil from aerial flame retardant drops. 31 • Destruction of snags and other ecologically significant large woody debris. • Spread of highly flammable exotic plants. KNF timber planners elected to analyze and disclose none of the connected impacts above despite timely requests during the scoping period. The EA failed to disclose or analyze the cumulative impact of discretionary fire suppression 53-24 activities implemented during the Abney Fire. As described in the introduction, KNF fire suppression crews lit numerous discretionary backburns while suppressing the Abney Fire. These backburns significantly influenced fire severity and generated more pronounced stand replacing fire effects. These intentionally lit backburns, were approved by KNF administrators and Incident Commanders and 53-25 constitute discretionary actions that must be analyzed in the cumulative impact analysis. Other significant impacts associated with fire suppression activities include dozerlines built in the Condrey Mountain Inventoried Roadless Area and designated Back-Country Area and extensive snagging conducted on the West Fork of Horse Creek.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The cumulative impact of discretionary fire suppression actions implemented during the Abney Fire must be disclosed and analyzed in an EIS. The following specific discretionary fire suppression activities must also be disclosed and analyzed as part of the cumulative impact in the Seiad Horse Risk Reduction EIS. The environmental impacts associated with 53-27 discretionary fire suppression actions were significant in the Abney Fire and can no longer be ignored. Failing to analyze these impacts is irresponsible and constitutes a failure to adequately analyze cumulative effects from recent and foreseeable federal land management actions. The KNF portions of the Abney Fire sustained nearly three times more moderate and high severity fire than the adjacent RR-SNF portions of the fire, some of this increase in fire 53-28 severity is directly related to backburning operations and must be considered a part of the cumulative impact. The EA failed to identify discretionary backburning in the cumulative effects analysis. Backburning operations were discretionary activities approved by KNF land managers and thus should be included as a "recent of foreseeable future action." The effects of discretionary backburning are a part of the existing condition and were implemented knowingly by KNF staff and other fire professionals. • The EA failed to analyze KNF 53-31 backburning operations during the Abney Fire, including the connection between KNF backburning operations and high severity fire effects in the Abney Fire. Analysis should include the location, timing, fire weather conditions and actual outcome of backburning or tactical firing operations conducted between August 31 and September 5, 2017 on the Abney Fire. • The EA failed to disclose or analyze the impacts of backburning as part of the cumulative effects analysis. The EA failed to analyze the impact of KNF backburning on LSR forest values. • The EA failed to analyze the correlation between backburning operations, high severity fire effects and proposed post-fire logging units. The proposed logging units were burned by fire 53-32 suppression crews at the discretion of land managers. This constitutes a connected action. Post-fire logging may not have taken place if KNF had not conducted high severity burnout operations. Discretionary Fire Suppression Snagging

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments According to the September 18, 2017 Inciweb report for the Abney-Eclipse Fire, crews were falling snags "across Horse Creek all day yesterday." Riparian snagging to prepare fireline can have severe impacts to aquatic resources such as water quality, fisheries habitat, instream wood and pool structure and pool frequency. Often large snags are felled and instream wood is removed from the stream. The KNF must disclose the scope and scale of snagging that was conducted along Horse Creek. The KNF must also disclose the removal of instream wood by fire crews. The impact to riparian and fisheries values is significant and will impact long-term recruitment of snags and instream wood for hundreds of years. These impacts were not analyzed in the Seiad Horse EA or considered in the cumulative effects analysis. Snagging along Horse Creek was not an act of god, but rather a discretionary fire suppression activity approved by KNF officials, it must be analyzed as such. The impact of snagging is especially pronounced due to inadequate levels of large instream wood in Horse Creek. The impact of snagging was not considered when analyzing instream wood and LWD in the West Fork of Horse Creek, thus the current analysis is inadequate. The snagging conducted in Horse Creek must be considered in cumulative effects analysis for the Seiad Horse Risk Reduction Project. The following information was included in public comment, but not adequately disclosed and analyzed in the Seiad Horse Risk Reduction EA: • The EA failed to identify discretionary fire 53-33 suppression snagging in the cumulative effects analysis. Snagging operations were discretionary activities approved by KNF land managers and thus should be included as a "recent of foreseeable future action." The effects of discretionary snagging are a part of the existing condition and were implemented knowingly by KNF staff and other fire professionals. • The EA failed to analyze the impact of riparian snagging and instream wood removal by fire suppression crews to riparian values, fisheries habitats, pool structure and frequency, stream bank stability, instream wood recruitment, large wood density and snag recruitment provided by Riparian Reserves in the West Fork of Horse Creek. • The EA failed to analyze the impact of riparian snagging to late successional habitat connectivity in the West Fork of Horse Creek. The role of Riparian Reserves is partially to provide connectivity and late successional habitat within the stream corridor. • The EA failed to analyze the consistency of riparian snagging and instream wood removal with the Aquatic Conservation Strategy. The analysis of ACS Attainment must include the recent impacts of riparian snagging as part of the current condition. Removal of large diameter snags in the Riparian Reserve is inconsistent with ACS Guidelines. • The EA failed to analyze the impact of riparian snagging and instream wood removal on water quality, stream turbidity and pool ratios....The EA failed to identify the impact of instream wood and snag removal to coho salmon habitat in the Horse Creek watershed. The failure to implement MIST led to major unnecessary impacts to the Backcountry 53-35 values in the area. These impacts must be analyzed as part of the cumulative impact to roadless and designated backcountry values.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The following information was included in public comment for the Seiad Horse Project and identified as a relevant issue, yet was not disclosed or analyzed in the Seiad Horse Risk Reduction EA. Failure to disclose these impacts constitutes inadequate NEPA analysis: • The EA failed to identify discretionary fireline construction in the cumulative effects analysis. Fireline construction, including dozer operations were discretionary activities approved by KNF land managers and thus should be included as a "recent of foreseeable future action." The effects of discretionary fireline creation are a part of the existing condition and were implemented knowingly by KNF staff and other fire professionals. • The EA failed to analyze the impact of bulldozer line built in the Condrey Mountain Designated Backcountry Area including cumulative effects, impacts to botanical values, soils, recreational resources, scenic values and Designated Backcountry Area values. • The 53-36 EA failed to analyze the destruction of the Johnson Trail, in the Condrey Mountain Designated Backcountry Area, an area where the KNF Forest Plan mandates the maintenance of non-motorized trails. The decision to bulldoze this trail was made by fire managers and KNF staff, it must be analyzed as such. It is a permenant loss to an important public land resource. • The EA failed to analyze the potential for noxious weed introduction through both fire suppression activities, including dozerline creation and post-fire logging. The 14 level of disturbance associated with wildfire, dozerline creation, increase human use in the form of suppression crews, increased vehicle traffic and soil disturbance from post-fire logging operations will significantly increase the potential for noxious weed spread across the planning area including high elevation meadow systems. • The EA failed to disclose the number of miles of dozerline built during the Abney Fire, as part of the cumulative effects analysis for sedimentation, water quality and erosion rates. Meanwhile, the RR-SNF portion of the Cook and Green Pass Botanical Area were backburned at high severity by KNF crews during hot, dry conditions and gusty winds. The result was to burn large, pure stands of Brewer's spruce, one of the region's most striking 53-294 botanical features. These impacts went entirely unaddressed in the Seaid Horse Project EA. They are part of the cumulative impact. Cook and Green Pass is geographic center of the Siskiyou Crest region.

Comment Response #9: Water Board Waiver and Permits Required Concern statement: There is a concern that the project comply with Regional Water Board consultation process and that the both a waiver and 404 permit application be prepared. There is additional concern that a legacy sediment site treatment plan is prepared and that BMP Roads-6 regarding watercourse crossing on maintenance level 1 roads is addressed. Forest Service Response: The Forest Service will submit an application for coverage under the Waiver from the Regional Water Board prior to commencing project activities. A legacy sediment site plan to meet the conditions of the Waiver will be submitted to the Regional Water Board as part of the application for coverage under Category B of the Waiver. In addition to a Regional Water Board Waiver the Forest will obtain a 401/404 permit prior to commencement of the large wood placement portion of the project.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

The risk of increased floods and debris flows from burned areas on the road system was evaluated in the Burned Area Emergency Response report for the Abney Fire. All maintenance- level 1 roads will be treated to meet National Best Management Practices BMP Roads-6. BMP Roads-6 states that "Level 1 roads receive basic custodial maintenance focusing on maintaining drainage facilities and runoff patterns to avoid or minimize damage to adjacent resources and to perpetuate the road for future use. The integrity of the roadway is retained to the extent practicable and measures are implemented to reduce sediment delivery from the road surface and fills and reduce the risk of crossing failure and stream diversion" (USDA Forest Service 2012). All maintenance level 1 roads within the project area have been surveyed by Forest hydrology staff for legacy sediment sites. Sites found within the Horse Creek drainage will be treated as part of the Seiad-Horse Project and the sites in the Seiad drainage will be covered under the Forest Service watershed program, the watershed condition framework, as it is a priority watershed. Treatment of legacy sediment sites on maintenance level 1 roads will be determined by Forest staff, and may include: dips, outsloping, culvert upgrades, installation of rocked fords, and even culvert removal. Associated Comments: Comment # Comments The agency must also demonstrate that a water quality waiver from the California Water 53-248 Control Board will be issued for this project. The Draft EA lacks a proposed legacy sediment site treatment plan. An acceptable legacy 1067-1 sediment site treatment plan, including a schedule for treatment, must be submitted and approved by the Executive Officer before Waiver coverage will be granted. The Project area experienced moderate to high severity fire across a large area. Existing watercourse crossings on Maintenance Level 1 roads may be at risk from elevated water flow and potential for debris flows from burned areas. If any Maintenance Level 1 road used in the Project area currently contains culverted watercourse crossings, KNF should 1067-5 address in the final EA how BMP Roads-6 will be implemented. If watercourse crossings will remain on Maintenance Level 1 roads after the conclusion of Project activities, KNF should identify in the final EA and/or the Waiver application how they plan to inspect and maintain those crossings into the future. Table 29 on page 73 of the Draft EA contains the following passage: Outputs for Alternative 2 from the Equivalent Roaded Area (ERA) model, threshold of concern was calculated based on channel sensitivity, beneficial uses, soil erodibility, hydrologic 1067-6 responses, and slope stability (USFS, 2004). We were unable to determine whether analysis of legacy sediment site treatments were incorporated into ERA modelling completed for the Project. Please identify in the final EA whether the effects of legacy sediment site treatments are incorporated into ERA modelling for the Project. Page 11 of the Draft EA contains the following passage: With the modified proposed action, large woody debris would be placed in a 1.4 mile long, low-gradient, unconstrained reach of mainstem Horse Creek at up to 27 placement sites using a helicopter. Anyone proposing to conduct activities that require a federal permit or involves dredge or fill 1067-7 activities that may result in a discharge to waters of the United States and/or waters of the state are required to obtain a Clean Water Act (CWA) section 401 water quality certification and/or waste discharge requirements from the Regional Water Board verifying that the project activities will comply with state water quality standards. The

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments most common federal permit for dredge and fill activities is a CWA section 404 permit issued by the U.S. Army Corps of Engineers (Army Corps). The Waiver does not include water quality certification for activities requiring a CWA section 404 permit. Regional Water Board staff recommend that KNF contact the Army Corps and determine whether a CWA section 404 permit is required for activities associated with placing rootwads into Horse Creek, and provide the Army Corps' determination with the Category B Waiver Application. The Army Corps' determination will allow Regional Water Board staff to determine the type of authorization (water quality certification or waste discharge requirements) required for the proposed placement of hazard tree rootwads into Horse Creek.

Comment Response #10: Legacy Sediment Site Treatment Effects Concern statement: There is a concern that the EA did not properly analyze legacy site treatments in regards to their temporal context and that they are being used to mitigate water quality impacts caused by the proposed actions. Commenters claim that most legacy site treatments proposed by the project would be from potential sediment savings by replacing undersized culverts that are unlikely to fail in the short-term under no action, unlike chronic short-term sedimentation or creation of new legacy sites that is likely to occur from project activities. Potential sediment savings from culvert replacements should not be used to mitigate chronic sediment impacts from project activities that may not meet the Aquatic Conservation Strategy (ACS) or the Clean Water Act (CWA). Commenters also believe that legacy site treatments should be analyzed under the no-action alternative and point out that unlike the EA the Aquatic Resources report did analyze legacy sites under the no action alternative. Forest Service Response: The California Porter-Cologne Water Quality Control Act assigns responsibility for protection of water quality to the Regional Water Board. The North Coast Regional Water Board adopted a Waiver Waste Discharge Requirements (order No. R1-2015-0021) as a means for Forest Service projects to comply with State water quality regulations and the Federal Clean Water Act. The Seiad-Horse Risk Reduction Project is expected to be enrolled under category B of the Waiver. Category B projects require a legacy site treatment plan and Regional Water Board review and evaluation for compliance with the Waiver (Waiver, page 24). Since the potential increase in sediment to the watershed is more than minor ("moderate" as defined in the Waiver) Category B waiver for a 303(d)-listed stream is required. Pre-project consultations with Regional Water Board staff indicated that the legacy site treatments described in the EA meet the conditions for coverage under category B of the Waiver. The legacy site plan includes a schedule to treat all of the sites within 8 to 10 years which is the project's estimated lifetime. The Waiver requires that legacy sediment sites be treated either as a part of the project or through a Watershed Restoration Action Plan (WRAP) (Waiver Finding #34). If a new Category B project is within a sixth field subwatershed that contains an active WRAP that is treating legacy sediment sites, the Category B project is exempt from treating legacy additional sediment sites (Category B Condition #1). The Forest Service has an active WRAP in the Seiad Creek Watershed and is currently implementing legacy site treatments through the Seiad Creek Road Rehabilitation Phase 1 and 2

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest projects. The portion of legacy sites in the Seiad-Horse Risk Reduction Project that are located within the Seiad Creek Watershed are already scheduled for treatment and are therefore exempt from any further requirements under the Waiver. These sites are included in the no action alternative. The Forest Service does not have an active WRAP in the Horse Creek Watershed so the Seiad-Horse Risk Reduction Project will be required to the treat legacy sites in Horse Creek as a condition for enrollment under category B of the Waiver. These sites are not included in the no action alternative but are included in all action alternatives in order to meet the conditions of the Waiver and assure compliance with state water quality regulations. Associated Comments: Comment # Comments The KNF's reliance upon legacy site treatment projects that are independent of this timber sale do not serve exempt this timber sale from the NW Forest Plan or the CWA. Further, hypothetic future "sediment savings" from unrelated projects that may (or may not) occur should there be a 100-year food event in the planning timeframe in no way offset certain and immediate increases in sediment loading from this timber sale project. The contention and assumption on page 79 of the EA that legacy site treatments will not occur under the 49-58 No Action Alternative for this project is incorrect and flawed. Note that at page 42 of the Aquatic Resources Report legacy road site treatments are analyzed as part of the No Action Alternative because they will occur independently of and separately from the proposed LSR clearcut logging in the so-called Seiad-Horse Risk Reduction (Clearcut Logging Timber Sale) Project. As stated on page 79 of the EA, due to proposed logging activities "sedimentation to streams could be increased by approximately 2,000 cubic yards…" The ACS and CWA do not permit this result. The agency's NEPA shell-game regarding legacy site treatments and sediment production is simply shameful. As acknowledged on page 14 of the EA, treatment of legacy sites "is ongoing" and is completely independent of the decision document for this project. Yet throughout the EA (see page 78) the Forest Service claims that "potential" (hypothetical) sediment "savings" from culvert replacement legacy site treatments that are unrelated to this logging proposal somehow offset the certain and immediate sediment production from this project. The contention on page 80 of the EA that the logging project will reduce 49-87 stream sedimentation by 34,000 cubic yards is false. The potential and hypothetical sediment reductions should there be a 100 year flood event are entirely from legacy site treatments that have nothing to do with this logging project. What this logging project will in fact do is to immediately and certainly increase sediment production to water quality limited streams. Similarly, the contention on page 79 of the EA that there would be no legacy site sediment treatments under the No Action Alternative is simply false. The decision documents and BAER legacy site treatments are fully and completely independent of the agency proposal to build roads and clearcut the LSRs in this logging project. These impacts will contribute to watershed degradation and have the potential to create chronic "legacy" sediment sites. Currently, the KNF has failed to implement restoration treatments on "legacy sites" in response to the Water Quality Waiver provided in the Westside Fire Recovery Project. The KNF created the additional water quality impacts 53-241 associated with commercial logging, but has failed to implement the "legacy" treatments. The combined affect is an increase in sedimentation and water quality impacts, not a reduction. The cumulative impact of creating more chronic "legacy" sediment sites before cleaning up previous sites is unacceptable.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments It should also be noted that Water Quality Waivers are not intended to mitigate and justify 53-242 additional watershed impacts. The analysis on pages 79-80 of the EA depict a mitigation program rather than a water quality restoration program. The EA failed to disclose that Water Quality Waivers were not intend to mitigate or justify 53-244 additional watershed impacts as is outlined in pages 79-80 of the EA. Water Quality & Fisheries In numerous places, the EA wrongly treats legacy site treatment as part of the project, using the legacy site treatment to mitigate or offset against project impacts. (See EA at 78). As made clear from the EA, legacy site treatment is not being pursued as part of the project. (EA at 115). Some legacy site treatment was approved and work started before the 2017 Abney Fire (such as the Seiad Creek Road Rehabilitation Phase 1 and 2 and the Horse Creek Roadbed Rehabilitation Decision Memo). (EA at 14). Some legacy site treatment was triggered by the fire itself, such as the burned area emergency response (BAER) treatments. (EA at 14). But there are not any sediment site treatments triggered by the proposed post-fire logging.1 1 To the extent that some legacy site treatment is connected to the project, the Forest Service has an obligation to include the treatment 62-24 within the project and its environmental documents. See 40 C.F.R. § 1508.25. Legacy site treatment should be included in the "no action" alternative, which forms, in part, the background conditions against which the project would be judged. The Forest Service's use of sediment site treatment as a project mitigation feature therefore violates the law. To the extent that the Forest Service is independently pursuing restoration activities in the project area, bully for them. But that doesn't change NEPA. The beneficial effect of the legacy sediment site treatment is likewise speculative. Many of the legacy site treatments include upgrading culverts to survive a 100 year flow. EA at 14, 113. Thus, the sediment "savings" for these projects would only occur in the event of that flow. Again, creating a fixed sediment savings and applying it against the project is inappropriate. (See EA at 78).

Comment Response #11: Fire Regime Characterization Concern statement: There is a concern that the EA inadequately or erroneously characterized fire or disturbance regimes on the Klamath National Forest. Commenters state that large high severity burn patches were not uncommon, especially in the true fir zone at higher elevations. Forest Service Response: We agree that it is more likely to have high fire severity in higher elevations (white fir zone) within this project area. We also agree that these upper slope positions, especially on south facing slopes, have a higher likelihood of high severity fire. The true fir zone (Figure 12 in the EA) makes up a very small proportion of the total project area and an even smaller proportion of the treatment area. Most the stands affected by the Abney fire were mixed conifer, pine, and Douglas-fir, which are common on lower to middle elevations in the Klamath Mountains. Under a mixed severity fire regime, some patches of high severity will occur, especially in these stands. The EA provides rationale and has supporting nearby/local research that suggests the area was characterized by a low to mixed severity fire regime (EA, pages 37 to 44). Further explanation of the fire regime relevant to the Seiad-Horse Risk Reduction Project can be found within the Westside Fire Recovery discussion on historic fire regimes which had similar landscape

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

characteristics to the Seiad-Horse project area. This documentation and cited literature suggest that the fire regime was characterized by low to mixed fire severity and that patch sizes and extreme fire behavior from the 2017 Abney Fire was uncharacteristic for the area. A century of fire control has resulted in increased fuel continuity and density when compared to historic norms; temperature and moisture regimes of northern California may have been altered by climate change, further exacerbating the effects of fuel accumulation from fire suppression. Associated Comments: Comment # Comments Attachment 2 is a peer-reviewed study conducted by Odion et al. entitled Fire Severity in Conifer Forests in the Sierra Nevada, California published in Ecosystems, 2006, 9, 1177- 1189. 7 The abstract states: "Natural disturbances are an important source of environmental heterogeneity that have been linked to species diversity in ecosystems. However, spatial and temporal patterns of disturbances are often evaluated separately. Consequently, rates and scales of existing disturbance processes and their effects on biodiversity are often uncertain. We have studied both spatial and temporal patterns of contemporary fires in the Sierra Nevada Mountains, California, USA. Patterns of fire severity were analyzed for conifer forests in the three largest fires since 1999. These fires account for most cumulative area that has burned in recent years. They burned relatively remote areas where there was little timber management. To better characterize high- severity fire, we analyzed its effect on the survival of pines. We evaluated temporal 49-26 patterns of fire since 1950 in the larger landscapes in which the three fires occurred. Finally, we evaluated the utility of a metric for the effects of fire suppression. Known as Condition Class it is now being used throughout the United States to predict where fire will be uncharacteristically severe. Contrary to the assumptions of fire management, we found that high-severity fire was uncommon. Moreover, pines were remarkably tolerant of it. The wildfires helped to restore landscape structure and heterogeneity, as well as producing fire effects associated with natural diversity. However, even with large recent fires, rates of burning are relatively low due to modern fire management. Condition Class was not able to predict patterns of high-severity fire. Our findings underscore the need to conduct more comprehensive assessments of existing disturbance regimes and to determine whether natural disturbances are occurring at rates and scales compatible with the maintenance of biodiversity." The EA failed to identify an accurate description of historic/reference habitat conditions and fire regimes. Many higher elevations communities and habitats on more exposed 53-96 slope positions appear to contain evidence of historic high severity fire effects. This evidence is based on pre-fire age class distributions, early landscape descriptions and historic photographs. The site-specific evidence described above contradicts many of the findings and assumptions in the EA. The EA claims the region's fire regime is dominated by "low to moderate severity fire; and is not stand replacing" (USDA. 2018a p.38). The EA also 53-258 assumes that fire effects in the Abney Fire were outside the range of variability due to the size of mortality patches and high severity effects. Landscape descriptions from the 1860's and historic photos from the 1930's contradict these claims.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The EA failed to disclose that current post-fire conditions in the Abney Fire are well within the range of variability for the Seiad and Horse Creek watersheds. • The EA failed to disclose that early landscape descriptions and photographs demonstrate a highly variable 53-259 landscape with a patchwork of high severity fire effects. • The EA failed to disclose that natural regeneration will likely reproduce conditions that are well within the range of variability. The EA includes a section on historic fire regimes for the project area based on a very narrow citation base (mainly from Skinner and Taylor). Nonetheless, Taylor and Skinner (1998) show substantial variability in high severity occurrence based on slope position, aspect, elevation, and fire weather in the Klamath Mountains and thus the EA falsely displays high severity proportions without addressing this variability and uncertainties in estimating high severity occurrence and patch size. In doing so, the project area is 54-34 assumed to have a fire regime that is low to moderate mixed severity and that large patches of high severity are rare (which contradicts historical estimates from Odion et al. 2014 as mentioned below). The description of fire regimes is the foundation for project treatments based on the assumption that conifer establishment will be limited in high severity burn patches that are the result of "uncharacteristic fires." This is not based on best available science nor have you demonstrated that natural conifer regeneration is less than that required by NFMA five-year post-fire (mentioned above). First, fire regimes in the Klamath-Siskiyou ecoregion are highly variable and include large patches of high severity fire (Donato et al. 2009a,b, Perry et al. 2011, Halofsky et al. 2011, 54-35 Odion et al. 2014 see online supplemental - attached). Large high severity patches occurred historically in the project area, including patch sizes roughly equivalent to those produced by the Abney fire (see Odion et al. 2014 Supplemental). Third, prior fire regime studies by Taylor and Skinner were based on fire scar mapping, which also underestimates high severity occurrence given dead trees do not leave scars 54-37 and there are inherent sampling bias using fire scar mapping over small areas (Odion et al. 2014). Regarding reoccurring burn severity, Gabrinski et al. (2017) found high severity burns 54-43 reoccurred when successive fire intervals were long (=19 yr) for the Klamath-Siskiyou region, and not on shorter intervals (<15 years) as reported in the EA.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #12: Natural Recovery Concern statement: There is a concern that proposed actions will be counterproductive in restoring coniferous forests and the EA did not consider the use of natural regeneration to meet the purpose and need. Commenters also were concerned that disturbance from salvage activities would retard natural regeneration that would otherwise meet our purpose and need to recover LSR characteristics and that we did not adequately analyze these impacts. Forest Service Response: See response to concern #3. The effects to forest regeneration of doing no salvage harvest with site preparation and planning were considered as part of the no action alternative analysis for the impacts related to the project need for fire-resilient coniferous forest in severely burned areas to meet the desired conditions (EA, pages 63 to 65). Ultimately taking no action was found not to meet this aspect of the purpose and need of the project. In larger patches where the majority of the trees were killed by the fire, reestablishment of forest cover would rely on natural regeneration and may take multiple decades or longer. For the larger, contiguous areas of high severity burn, distance from seed sources may further delay natural regeneration because of long distances to trees capable of producing seeds. Damage to natural regeneration as a result of salvage harvest increases with the amount of delay between the fire and the salvage activities. Additionally, the area proposed for salvage harvest is a relatively small percentage of the total area burned in the Abney Fire, leaving considerable acreage on the landscape that will regenerate naturally and likely be early seral habitat for some time (EA, page 66). By treating the proposed salvage units and implementing post-harvest site preparation and planting, regeneration either natural or planted that occurs will be better suited for long term survival because of the reduced fuel loading and fire risk within these areas. Following salvage harvest natural regeneration may still occur in areas near patches of green trees which will remain on the landscape. Associated Comments: Comment # Comments In many places there is a mix of dead and live trees. Much of the forest will come back 5-5 easily over the next 20 years and 16-1 Leave the habitat alone! 30-1 Post-fire environment is vital to the ecosystem and regrowing. Let the earth heal itself. 35-1 Wild, untamed forest are important for ecosystems and people. Attachment 1 is a peer-reviewed study by Donato et al. entitled Post-Wildfire Logging Hinders Regeneration and Increases Fire Risk published in Science express, January 5, 2006. The paper concludes: "Our data show that postfire logging, by removing naturally 49-25 seeded conifers and increasing surface fuel loads, can be counterproductive to goals of forest regeneration and fuel reduction. In addition, forest regeneration is not necessarily in crises across all burned forest landscapes. The results presented here suggest that post- fire logging may conflict with ecosystem recovery goals."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Attachment 13 consists of an April 2006 open letter to Congress from an extremely long and impressive list of scientists contending that: "[N]o substantive evidence supports the idea that fire-adapted forests might be improved by logging after a fire. In fact, many 49-37 carefully conducted studies have concluded just the opposite. Most plants and animals in these forests are adapted to periodic fires and other natural 13 disturbances. They have a remarkable way of recovering literally rising from the ashes because they have evolved with and even depend upon fire."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Attachment 16 consists of a September 2006 post-disturbance literature review by Dr. Dominick A. DellaSala, Ph.D. for the National Center for Conservation Science & Policy. The executive summary for the review states: "Post-disturbance recovery, much like fire itself, has been the subject of intense debate and widespread misunderstanding regarding how and whether to treat regenerating landscapes following large disturbance events. As HR4200 - the Forest Emergency Recovery and Research Act - heads to the Senate for debate, it is important that lawmakers and land managers consider the latest science in making informed decisions about the management of public lands following natural disturbances. Numerous scientific studies have demonstrated that natural disturbances, even very large ones such as volcanic eruptions, wildfires, and severe wind storms, are critical to the health of terrestrial and aquatic ecosystems as they are characterized by unique biological communities and generate important structural elements that forests depend on for decades to centuries. The standing dead, dying, and downed trees (especially large ones) and surviving green and scorched ones transfer their critical functions from the predisturbed forest to the regenerating one. When post-disturbance "salvage logging" removes these important forest elements, it sets back recovery triggering ecosystem damages that may exceed the impact of the initial disturbance itself. Based on a review of approximately 38 scientific studies on post-fire logging and additional government reports published to date, not a single study indicated that logging benefits ecosystems regenerating after natural disturbance. In fact, post-fire logging impedes regeneration when it compacts soils, removes "biological legacies" (e.g., large dead standing and downed trees), introduces or spreads invasive species, causes soil erosion when logs are dragged across steep slopes, and delivers sediment to streams from logging 49-40 roads. With post-disturbance logging these impacts 15 occur when forest recovery is most vulnerable to the effects of additional, especially anthropogenic disturbances, creating cumulative effects that exceed logging of undisturbed forests. Such effects can extend for a century or more, because of the removal of long persisting and functioning wood legacies. These findings are especially relevant to public lands policy and management as post disturbance logging currently generates ~40 percent of the timber volume on Forest Service lands nation-wide (USFS Washington Office, timber volume spread sheets - Timber Management Staff, 2005 statistics). Therefore, the following conclusions were provided to assist decision makers regarding post-disturbance management decisions: (1) post- disturbance landscapes should be allowed to regenerate naturally as evidence from several locations (Biscuit fire (SW Oregon), Storrie and Starr fires (California Sierra's), Yellowstone 1988 fires, Mt. St. Helens eruption, New England hurricanes and insect infestations) indicates recovery can be surprisingly swift and many species that colonize disturbed areas are adapted to them, contributing to recovery in unique ways; (2) road building (even temporary roads) damages regenerative processes in terrestrial and aquatic ecosystems and should be avoided; (3) natural disturbances are characterized by unique biological legacies (large dead and dying trees) essential to regenerative processes - recovery is not possible in their absence; and (4) if salvage logging is to take place for economic reasons, large trees should be retained to protect their biological legacy functions and "no harvest zones" established on steep slopes with fragile soils, including areas of conservation and public health concern such as late-successional and old-growth forests, riparian areas, aquatic watersheds essential to drinking water municipalities, and roadless areas."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The Forest Service is proposing activities to facilitate the artificial planting of trees, and associated elimination of shrubs around planted sites, on hundreds of acres in the fire 49-65 area, implying that natural conifer regeneration would not effectively or adequately occur in the absence of such artificial planting. On August 1, 2006, a letter from nearly 600 American scientists opposed post-fire snag removal and subsequent artificial replanting, finding that such activities do not represent the current state of scientific knowledge and "would actually slow the natural recovery of 49-67 forests and of streams and the creatures within them…" The scientists concluded that "no substantive evidence supports the idea that fire-adapted forests might be improved by logging after a fire." We included this letter in our scoping comments. KNF project planners elected to ignore it.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Patches of higher-intensity fire, wherein most or all trees are killed, do not "remove" the stand of trees, and do not put the area to a nonforest use. On the contrary, higher intensity fire patches create one of the most ecologically important and biodiverse forest habitat types in western U.S. conifer forests: "snag forest habitat". The Forest Service's apparent assumption that higher-intensity fire areas will not naturally regenerate with conifers effectively is not supported by any citation to scientific literature, and is directly contradicted by Forest Service data regarding natural post-fire conifer regeneration in large high-intensity fire patches (Collins et al. 2010). Specifically, the Forest Service found vigorous natural post-fire forest regeneration, dominated mostly by pines and oaks for trees over 1 centimeter in diameter at breast height (Collins et al. 2010, Table 5), and hundreds of trees per acre overall, within several years to about a decade after high- intensity fire, even where native shrub cover was 90- 100% (Collins et al. 2010, Tables 5 and 6). This is consistent with findings from other studies (Shatford et al. 2007). And, while a more recent report from Collins et al. (Plumas Lassen Study 2011 Annual Report) claims to find little natural conifer regeneration in many high-severity fire areas this is misleading in light of the fact that nearly half of the area surveyed had been subjected to intensive post-fire logging, which damages soils and removes or destroys natural seed sources—and many of the areas that were not post-fire salvage logged were pre-fire clearcut. Further, the results of Collins et al. (2010 [Table 5]), who found and reported substantial natural conifer regeneration—especially ponderosa pine and sugar pine—in highintensity fire patches, excluded salvage logged areas, unlike Collins et al. (2011). Collins et al. (2010) state that "some areas within each of these fires experienced post-fire management, ranging from post fire salvage logging, tree release and weed management. These areas 49-68 were removed from analysis." (emphasis added). Specifically, Collins et al. (2010 [Table 5]) found 158 ponderosa pine and sugar pine conifers per acre regenerating in high-intensity fire patches in the Storrie fire—68% of the total natural conifer regeneration by species. Moreover, the plots in Collins et al. (2011 [see map]) within the Storrie fire area were concentrated at the edge of the fire in the areas subjected to extensive salvage logging and roadside hazard tree logging, which removes conifer (including pine) seed sources and tramples natural conifer regeneration with groundbased machinery (thus, even the plots that technically had not been post-fire logged were often adjacent to logged areas). Extensive natural conifer regeneration surveys deeper into the Storrie fire, at seven years post-fire, revealed abundant natural conifer regeneration, especially pine (Hanson 2007b [Tables 1 through 4, and Appendix A]). In 26 addition, over 95% of the conifer regeneration in Collins et al. (2010, 2011) was under 0.1 cm in diameter at breast height (Collins et al. 2010); the plots used to determine the density of conifers of this size covered only 9 square meters of area per plot, and many high-intensity fire patches in the study only had 3-5 plots for an entire high-intensity fire patch (Collins et al. 2011). This means that, even if 200-300 naturally-regenerating conifers per hectare actually existed in a given high- intensity fire patch, the methods used by Collins et al. would be very unlikely to detect conifers, as a matter of basic math and probability. Siegel et al. (2011) concluded that native fire-following shrubs are vitally important to biodiversity in complex early seral forest (CESF) created by high-intensity fire: "Many more species occur at high burn severity sites starting several years post-fire, however, and these include the majority of ground and shrub nesters as well as many cavity nesters. Secondary cavity nesters, such as swallows, bluebirds, and wrens, are particularly associated with severe burns, but only after nest cavities have been created, presumably by the pioneering cavity-excavating

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments species such as the Black-backed Woodpecker. Consequently, fires that create preferred conditions for Black-backed Woodpeckers in the early post-fire years will likely result in increased nesting sites for secondary cavity nesters in successive years." Similarly, Burnett et al. have found that shrub dominated landscapes are critically important wildlife habitat: "while some snag associated species (e.g. black-backed woodpecker) decline five or six years after a fire [and move on to find more recent fire areas], [species] associated with understory plant communities take [the woodpeckers'] place resulting in similar avian diversity three and eleven years after fire (e.g. Moonlight and Storrie)." (Burnett et al. 2012). Burnett et al. (2012) also noted that 'there is a five year lag before dense shrub habitats form that maximize densities of species such as Fox Sparrow, Dusky Flycatcher, and MacGillivray's Warbler. These species have shown substantial increases in abundance in the Moonlight fire each year since 2009 but shrub nesting species are still more abundant in the eleven year post-burn Storrie fire. This suggests early successional shrub habitats in burned areas provide high quality habitat for shrub dependent species well beyond a decade after fire.'" (Burnett et al. 2012). The Rogue-River Siskiyou National Forest Chetco Bar Salvage Project Environmental Assessment acknowledges the importance of post-fire natural regeneration, on page 2-4 it states "[f]ollowing salvage harvest, the same 4,090 acres would be surveyed for natural regeneration. The intent is to rely on natural regeneration wherever possible. If natural regeneration is determined not to be adequate to comply with NFMA 5 year regeneration requirement to achieve stocking levels consistent with management objectives, site-specific appropriate tree species mix would be planted by hand."(Emphasis added). Further, on page 3-5 of the Chetco Bar Salvage Logging Environmental Assessment the Forest Service states "[it is well recognized that management activities, such as post disturbance logging and dense tree planting, can reduce the richness within and 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)." The ecological differences between biologically rich stands that result from natural disturbance and stands that are subject to logging and yarding are well-known and established: "Early-successional forest ecosystems that develop after stand-replacing or partial disturbances are diverse in species, processes, and structure. Post-disturbance ecosystems are also often rich in biological legacies, including surviving organisms and organically derived structures such as woody debris. These legacies and post-disturbance plant communities provide resources that attract and sustain high species diversity, including numerous early-successional obligates, such as certain woodpeckers and arthropods. Early succession is the only period when tree canopies do not dominate the 49-104 forest site, and so this stage can be characterized by high productivity of plant species (including herbs and shrubs), complex food webs, large nutrient fluxes, and high structural and spatial complexity. Different disturbances contrast markedly in terms of biological legacies, and this will influence the resultant physical and biological conditions, thus affecting successional pathways. Management activities, such as post-disturbance logging and dense tree planting, can reduce the richness within and the duration of early- successional ecosystems. Where maintenance of biodiversity is an objective, the importance and value of these natural early-successional ecosystems are underappreciated." Swanson et al, The Forgotten Stage of Forest Succession: Early- Successional Ecosystems on Forest Sites. 2010. Frontiers in Ecology and the Environment.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Attachment 25a of our scoping comments consisted of the Swanson et al paper quoted 49-105 above. KNF timber planners simply ignored this information in the pre-determined rush to log the LSRs. The KNF relies heavily on the Zhang 2008 study while ignoring findings from the Klamath Mountains regarding post-fire natural regeneration. KNF timber planners often contend that "literature does not become Best Available Science until it is related to the analysis and where the findings are interpreted or adopted to site specific conditions." We agree with this statement. Which makes it odd that KNF salvage logging proponents largely ignore post-fire regeneration studies from the Klamath Mountains while repeatedly relying 49-126 upon a single study from the Cascade Mountains in which private industrial timber companies clearcut post-fire stands, apply chemical application and then re-plant with an industrial timber crop. Such an approach is not related to the proposals or analysis in the EA and is not site-specific to the Klamath mountain range. Further, KNF timber planners ignore the substantial natural regeneration that can be easily viewed by simply visiting the proposed LSR salvage logging units. We also urge Forest planners to recognize the extraordinary biological and botanical 49-139 values of Forest Service lands in the LSRs on the Siskiyou Crest. Please emphasize natural recovery of these areas as opposed to salvage logging and plantation establishment. "Our key findings on post-fire management are as follows. First, post-burn landscapes have substantial capacity for natural recovery. Re-establishment of forest following stand replacement fire occurs at widely varying rates; this allows ecologically critical, early successional habitat to persist for various periods of time. Second, post-fire (salvage) logging does not contribute to ecological recovery; rather, it negatively affects recovery 49-141 processes, with the intensity of impacts depending upon the nature of the logging activity (Lindenmayer et al. 2004). Post-fire logging in naturally disturbed forest landscapes generally has no direct ecological benefits and many potential negative impacts (Beschta et al. 2004; Donato et al. 2006; Lindenmayer and Noss 2006). Trees that survive fire for even a short time are critical as seed sources and as habitat that sustains biodiversity both above- and belowground. These habitats will naturally regenerate into complex early-seral habitats, with significant biological legacies....Post-fire conditions will provide standing snags for wildlife habitat, 53-5 downed wood recruitment, slope stability, moisture retention and microclimates to aid regeneration....Native plant communities will respond with vigorous growth, abundant nectar for pollinators and forage for local ungulates. Post-fire logging and the removal of biological legacies will drastically reduce the potential for regeneration of species requiring cool, moist conditions. Yarding and logging activities 53-75 will also impact naturally occurring regeneration, including unique populations of montane species preferring cool, moist habitats.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Natural regeneration is also far more likely to produce a wide diversity of structure and composition than reforested stands planted to commercially valuable species. The loss of structural complexity has the potential to impact natural regeneration patterns and reduce the potential for cool, moist habitats to persist in the post-fire environment. 29 The 53-83 potential for cool, moist species to regenerate from natural fire recovery is high yet, the impact of post fire logging on microclimates, soils, natural regeneration and habitat complexity will reduce and degrade cool, moist habitat conditions on the site and landscape scale. Climate refugia will be more effectively retained if post-fire logging does not occur on the Siskiyou Crest. Much of the forest burned and proposed for post-fire logging is Douglas fir, ponderosa or 53-168 sugar pine habitat at relatively low elevations and should be allowed to recover naturally. The EA also failed to disclose and analyze the effect these properties have on forest 53-170 regeneration and structure. The EA failed to disclose and analyze the impact post-fire logging, yarding, and tree 53-171 planting will have on natural tree, shrub and vegetation regeneration in the project area. Unit 38 should be canceled to protect connectivity and climate refugia. The plant 53-274 community is adapted to high severity fire and post-fire logging will impact natural regeneration. Fourth, the EA provides no data in claiming a lack of conifer establishment in high severity patches. In fact, this is directly contrary to several nearby studies (see below) for large high severity patches. For instance, Donato et al. (2006) found that natural conifer regeneration in high severity patches exceeded tree planting densities of the USFS in the Biscuit fire. Several studies have found abundant conifer establishment in large high severity patches. Donato et al. (2009b) also found abundant conifer regen in short-interval (<15 years) high severity overlapping fires in the Klamath Mountains (i.e., "Conifer regeneration densities were high in both the SI [short interval] and LI [long interval] burns (range = 298-6086 and 406-2349 trees ha-1, respectively), reflecting similar availability of seed source and 54-38 germination substrates"). "Synthesis. SI [short interval] severe fires are typically expected to be deleterious to forest flora and development; however, these results indicate that in systems characterized by highly variable natural disturbances (e.g. mixed-severity fire regime), native biota possess functional traits lending resilience to recurrent severe fire. Compound disturbance resulted in a distinct early seral assemblage (i.e. interval dependent fire effects), thus contributing to the landscape heterogeneity inherent to mixed-severity fire regimes. Process-oriented ecosystem management incorporating variable natural disturbances, including 'extreme' events such as SI severe fires, would likely perpetuate a diversity of habitats and successional pathways on the landscape."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Further, a USFS report (emphasis added) by Brown (2008) noted abundant post-fire conifer establishment for the Klamath-Siskiyou following severe fires: "…. researchers found that the mixed-severity fire regime of the region, which includes patches of repeated severe fire, supports abundant, natural postfire conifer regeneration and regionally significant biodiversity. Salvage logging aimed at reducing risk of severe reburn appeared to make little difference in reducing surface fuels or potential fire behavior. Allowing the postfire early seral shrub phase to run its natural course has the potential to bolster the success and efficiency of several diverse management goals." Brown (2008) further notes (emphasis - this is a USFS publication): • "There was no reduction in surface fuels or re-burn potential from salvage logging. Managed and unmanaged stands exhibited the same surface fuel loads 17-18 years after fire, when reburn potential is high. • The potential for severe re-burn was driven by the inherent structure of young vegetation, and much less by residual woody material from the previous fire. • Natural conifer regeneration typically exceeded prescribed densities without additional planting or intervention in areas within 400 yards of live forest edges. • Extended periods of early 54-40 seral shrub dominance and short interval, high-severity fires appear to be important for conservation of avian biodiversity. • Short-term fire effects on small mammal communities were more significant than those of postfire salvage logging." Brown (2008) also states: "By mapping and measuring the distance from live tree seed sources, managers can confidently eliminate the need for artificial conifer regeneration in highly burned patches less than 0.25 miles from a seed source—even after the most extreme fire events." Based on the above and below citations of abundant post-fire conifer regen, we request that you map the location of seed trees/sources within high severity burn patches to determine if there are sufficient seed sources nearby (see Brown 2008) before you claim a lack of conifer regeneration. Shatford et al. (2007) (cited in the EA but ignored in the conifer assumptions) also report abundant post-fire conifer establishment in severe burn patches - In contrast to expectations, generally, we found natural conifer regeneration abundant across a variety of settings. Management plans can benefit greatly from using natural conifer regeneration but managers must face the challenge of long regeneration periods and be able to accommodate high levels of variation across the landscape of a fire. All logging areas are likely to suffer impacts to natural regeneration, with effects from groundbased harvest likely more severe than skyline, and with skyline more severe than 62-18 helicopter, as a result of decreased ground disturbance. (See Donato et al., 2006; Keyser et al., 2009).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments There is significant new information on the value of dead trees and complex early seral habitat. In October 2013, 250 scientists signed a letter urging greater attention to the conservation of complex early seral forests and natural recovery after fire. These scientists conclude that the "current state of scientific knowledge, indicates that [salvage logging] would seriously undermine the ecological integrity of forest ecosystems on federal lands. … This post-fire habitat, known as 'complex early seral forest,' is quite simply some of the best wildlife habitat in forests and is an essential stage of natural forest processes. Moreover, it is the least protected of all forest habitat types and is often as rare, or rarer, than old-growth forest, due to damaging forest practices encouraged by post-fire logging policies. While there remains much to be discovered about fire in our forests, the scientific evidence indicates that complex early seral forest is a natural part of historical fire regimes in nearly every conifer forest type in the western U.S. (including ponderosa pine and 148-3 mixed-conifer forests) … Numerous studies also document the cumulative impacts of post- fire logging on natural ecosystems, including the elimination of bird species that are most dependent on such conditions, compaction of soils, elimination of biological legacies (snags and downed logs) that are essential in supporting new forest growth, spread of invasive species, accumulation of logging slash that can add to future fire risks, increased mortality of conifer seedlings and other important re-establishing vegetation (from logs dragged uphill in logging operations), and increased chronic sedimentation in streams due to the extensive road network and runoff from logging operations." Della Sala, D. et al (2013) Open Letter to Members of Congress from 250 Scientists Concerned about Post-fire Logging. October 30, 2013. http://geosinstitute.org/images/stories/pdfs/Publications/Fire/Scientist_Letter_Postfire_2 013.pdf or http://www.scribd.com/doc/181401520/Open-Letter-to-Members-of- Congress-from-250-Scientists-Concerned-about-Post-fire-Logging-October-30-2013 We value our wild places highly and want them protected, not exploited for profits. Fire is a natural phenomenon that has been misunderstood by forest managers. That fact should not be used to justify continued exploitation and damage to our forests. The beauty and 176-1 rich diversity of the Siskiyou Crest, including the fire-affected watersheds, must be protected from further misguided "management" and allowed to return to balance without more human intervention. Letting this area recover naturally is the best and most sound environmental decision for 213-1 this fire area. We have learned over 100 years of forest management that fire damaged areas must remain undisturbed to reseed and recover if a natural forest is to exist there again. We 435-1 have learned that clear cutting causes erosion and landslides. We have learned that increased debris and sedimentation in creeks and rivers disturbs fish populations and interferes with fish reproduction. Please do not go forward with the clear cut logging plan prescribed. The Miller Complex was a healthy fire and left a lot of live trees. Fire is an important part of the life of a forest. 574-1 Let it do what it was supposed to do. DO NOT allow a post fire harvest of this forest. The headwaters is of huge importance to all life downstream. It needs to be left alone. Do not let the greed of the timber companies override the science that we know is right.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #13: Fuel Break Effectiveness and Feasibility Concern statement: There is a concern about the effectiveness and feasibility of maintenance of constructed fuel breaks. Of particular concern is firefighter safety on constructed fuel breaks. Forest Service Response: The Fuels Management Zone in this project is not designed to stop extreme fire behavior by itself. Additional adjacent actions of salvage harvest with site preparation, and extensive planned underburning, are designed to produce a relatively open, locally strategic ridgeline with reduced fuels and inherently less potential flame lengths and intensity that will make it safer for fire managers to consider a wider range of management options. (EA, pages 10 and 11) These strategic ridges are often used to suppress wildland fires and will likely be used as holding features during prescribed fire (EA proposed actions section). Ridgetops held the Abney Fire perimeter in many locations as well as other fires in the Klamath Mountains in the past. The fuel break coupled with adjacent treatments, including prescribed burning, would make the fuel break a safer working environment compared to no action and would increase the likelihood of the fuel break to stop any unwanted fires in the future. Associated Comments: Comment # Comments The EA unequivocally assumes fuel breaks will make it "safer" for firefighters. Rarely is this 54-48 assumption tested because it is too risky for firefighters, especially making a stand in fuel breaks against oncoming head fires We have included a fuel break assessment paper by former firefighter Dr. Timothy Ingalsbee (2005) who argues that fuel breaks are practical for starting fires (e.g. prescribed understory prescribed burning and/or facilitate wildland fire use opportunities) but impractical and unsafe for stopping fires (i.e. wildfire suppression). A fuel break needed to 54-49 start fires under the right conditions can be as minimal as a brushed-out hiking trail, but a fuel break needed to stop fires under the wrong conditions (extreme fire weather) is qualitatively more expansive and impactful, and it may never really work given spotfire potential. For examples, fires have been known to jump across 8 lane freeways in southern California; last summer, the Eagle Creek fire crossed the Columbia River Gorge!

Comment Response #14: Large versus small diameter fuel removal effects Concern statement: There a disagreement regarding the effects of project activities on fire severity, fire suppression tactics, and fire fighter safety. Commenters state that removing large diameter fuels does not contribute to reducing fire severity. Forest Service Response: Some research suggests that fire severity and the risk of future wildfires increases as a result of salvage harvest (e.g. Dellasala et al. 2006, Donato et al. 2006, and Thompson et al. 2007). Donato et al. (2006) suggest that post-fire salvage logging can result in a pulse of fine fuels that can increase fire intensity and severity in the short term; however, the paper does not explain the

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

results in a scenario where post-logging slash is treated in all harvested areas. Post-harvest treatment of slash is proposed in all action alternatives, and the predicted effect of this post- harvest treatment is a significant reduction in both fine and coarse woody debris. This type of treatment for post-salvage fuels is recommended by Donato et al. (2006) when they state "Our study underscores that, after logging, the mitigation of short-term fire risk is not possible without subsequent fuel reduction treatments." The Seiad-Horse Risk Reduction Project will treat activity fuels so the findings of Donato et al. 2006 with respect to increased fuels from logging do not appear to be relevant. McIver and Starr (2000) are also frequently cited; however, this literature review is now 17 years old and does not incorporate more recent studies on this topic. Many of these studies did not have post-salvage treatments similar to those proposed in the Seiad-Horse Project. The EA states that the project design "would have reduced snag densities and surface fuel loading in strategic fuels locations. Within these strategic fuels locations, the Project would have beneficial effects by reducing flame lengths, fireline intensity, and resistance to control." (EA, page 60). The EA discloses that follow-up treatments following salvage harvest would occur. These treatments are aimed at reducing surface fuel loading (in all fuel size categories) from activity fuels generated by the salvage harvest, breaking up continuous fuel beds and reducing fuel bed depth. Post-logging fuel treatments, such as piling and burning or broadcast burning (jackpot burning), can rapidly reduce total amounts and spatial continuity of surface woody fuels and may allow logged stands to serve as fuel-breaks in a landscape-level fire management strategy (Peterson and Harrod 2010). In addition, Peterson, Dodson, and Harrod (2014) found that post-fire logging altered post-fire fuel succession by (1) greatly accelerating the deposition of surface woody fuels from logged snags, (2) reducing peak loading of large diameter woody fuels, and (3) initiating the woody fuel decay earlier. Ritchie, Knapp and Skinner (2012) evaluated salvaged units following the Cone Fire on the Lassen National Forest. They found that after four years higher levels of surface fuel accumulations occurred in lower intensity salvage plots. The highest surface fuel accumulations occurred in un-salvaged plots four to either years after the fire. Furthermore, the highest surface fuel accumulations were associated with un-salvaged areas. Ritchie et al. (2012) observed that areas that were salvaged to remove heavy fuels had lower fuel loading after eight years than areas that were un-salvaged. Activity fuel treatment following salvage harvest would reduce fuel loading even further within salvage units. Dunn and Bailey (2014) also found that salvage logging significantly reduces coarse woody fuel loadings after approximately seven years, which likely reduces re-burn hazard for several decades depending on available 1000-hour fuel loadings (Dunn and Bailey, page 107). This is consistent with site-specific fuel modeling and with other literature considered in the EA, notably Peterson et al. (2015). We agree that logging can increase slash loads and hence fire risk if those activity fuels are not treated. In the Seiad-Horse Risk Reduction Project, activity generated slash will be treated to reduce surface fuels to levels consistent with low fire hazard (EA, pages 5 and 37 to 44). As a result, the projects would have beneficial effects by reducing flame lengths, fireline intensity, resistance to control, and firefighter safety (EA, pages 37 to 44).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments The Forest Service must use the best available science regarding the effects of fire or the proposed logging on fire and fuels, and document those conclusions in an EIS. Salvage logging will increase fire hazard "Upon completion of project activities [via Alternative 2], fire behavior would in the short term be greater than under Alternative 1 due to the small diameter material on site...[the] predicted rate of fire spread by year 20 is actually higher than under no action." -Panther Salvage Environmental Assessment, Klamath National Forest, at page 55. "In the project area, where post-fire fuel loading is currently low, logging without timely slash treatment is likely to be the single most important factor that will contribute to an increase in potential wildfire severity." (Weatherspoon 1996). There is no scientific, empirical evidence to prove that the presence of large-diameter standing or 49-48 downed fuels translates into high fire hazard. Besechta et al. (1995) stated, "We are aware of no evidence supporting the contention that leaving large dead woody material significantly increases the probability of reburn" (p. 11). The Besechta Report prompted responses by agency scientists. These included Everett (1995): "There is no support in the scientific literature that the probability of reburn is greater in post-fire tree retention areas than in salvage logged sites…The authors are correct that the intense reburn concept is not reported in the literature" (p. 4). The Forest Service's Pacific Northwest Research Station reviewed the scientific literature and concurred that, "Following Besechta and others (1995) and Everett (1995), we found no studies documenting a reduction in fire intensity in a stand that had previously burned and then been logged" (McIver and Starr 2000). The Seiad Horse Risk Reduction Project, falsely claim that similar post-fire logging and replanting projects will reduce future fire severity. These claims are not supported by 53-39 science, by KNF planning documents or by the fire mosaic on-the-ground in the Mid- Klamath region. The Seiad Horse Risk Reduction Project EA provides false, misleading and erroneous 53-40 information regarding the impact of proposed post-fire logging and replanting activities on future fire severity. The KNF salvage proposal in the Abney Fire is focused on logging trees 18" and larger. 53-182 These large trees are fuels that do not significantly contribute to the spread or intensity of a fire. The EA falsely claims that large dead trees will contribute to subsequent severe fires. 54-56 However, for large trees to pose a major deterrent to firefighters dead trees would have to fall at the same rate (highly unlikely). Notably, numerous studies of beetle-killed forests have shown that when wildfires reoccur in snag forests, they occur at lower severities given that most of the living biomass was already consumed by the prior disturbance (e.g., see comprehensive analyses from multiple regions by Bond et al. 2009, Black et al. 2013, Donato et al. 2013, Hart et al. 2015, 54-57 Meigs et al. 2016). Additionally, large trees do not simply re-combust in a subsequent fire but rather smolder given that the living biomass was already consumed in the prior fire. Large-coarse woody debris also does not contribute to fire spread, a major concern of firefighters, which logging slash does.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Campbell et al. 2016 noted: "The proportion of whole trees having fallen after 10 years was 20 times greater for small diameter trees (<20 cm DBH) than for larger trees……Across species, size class, and location, 57% of the trees killed in the Biscuit Fire are still standing 10 years after their death and have on average lost only 26% of their post combustion necromass...." 17 "In reality, necromass decay over time is expected to exhibit some initial 54-58 lag (as substrates await decomposer colonization or fragmentation) and a decreasing proportional loss over time (as mixed substrates are reduced to their more recalcitrant fractions)." Thus, if the main concern is reburn, then large trees are not a problem given most of their biomass was consumed in the initial disturbance and large trees do not all fall at once. Recognizing that small fuels are the most hazardous and large fuels are the least hazardous, the best way to summarize the effects of salvage logging is to say that it increase fuel loads and fire hazard for several years, followed by a 40 year shortage of large woody habitat. Peterson, David W.; Dodson, Erich K.; Harrod, Richy J. 2015. Post-fire logging reduces surface woody fuels up to four decades following wildfire. Forest Ecology and Management. 338: 84-91. http://www.treesearch.fs.fed.us/pubs/48822 ("Relative to unlogged stands, post-fire logging initially increased surface woody fuel loads, increasing small diameter fuel loads by up to 2.1 Mg/ha during the first 5 years after fire and 148-5 increasing medium diameter fuel loads by up to 5.8 Mg/ha during the first 7 years after fire. Logging subsequently reduced surface woody fuel loads, reducing large diameter fuel loads by up to 53 Mg/ha between 6 and 39 years after wildfire, reducing medium diameter fuel loads by up to 2.4 Mg/ha between 12 and 23 years after wildfire, and reducing small diameter fuel loads by up to 1.4 Mg/ha between 10 and 28 years after wildfire. Logging also reduced rotten, large diameter fuel loads by up to 24 Mg/ha between 20 and 39 years after wildfire.") The significant and long-term reduction of large woody habitat seems much more significant than the minor, short-term changes in small fuels.

Comment Response #15: Use of RAVG data for post-fire assessments Concern statement: There is a concern about the EA not properly discussing the limitations of RAVG data and possibly misrepresenting actual fire severity. Forest Service Response: The Rapid Assessment of Vegetation Condition after Wildfire (RAVG) and the Monitoring Trends in Burn Severity (MTBS) are similar products. MTBS is a multi-year program designed to consistently map the burn severity and burned area boundaries of fires across all lands; MTBS is typically available only from one year post-fire and it is useful for monitoring results of fires into the future but not for portraying the difference in conditions in an area before and immediately after a fire. RAVG uses a relative difference between pre-fire and post-fire conditions, and uses plot data to calibrate the model so it is useful in comparing conditions before and immediately after a fire. Miller et al. (2009), which used plots within the Klamath National Forest as a basis of its research, found the RAVG model to have good accuracy, especially in areas with high canopy cover such as the majority of the Seiad-Horse project area before the Abney fire. Field observation also found the RAVG model results to be accurate. Because of these findings, we found the RAVG model results to be adequately accurate for use

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest in this Project. RAVG also allows for layers, including percentage of change in basal area, canopy cover, and composite burn index that can be valuable for analysis. Since RAVG is the only one of the models that is currently available for the project area, and because it has been found to be relatively accurate, this model is used for analysis of the Project. Associated Comments: Comment # Comments 54-36 Second, while the proportion of high severity fire was reported as high for the Abney fire, this was based on the use of RAVG, which is notorious for overestimating high severity fire occurrence (i.e., misses post-fire conifer needle flushing). We appended below an example of high severity overestimations from using RAVG compared to MTBS for the nearby 2012 Flat Fire in California. Note the substantial difference in high severity estimated by RAVG vs. MTBS. We are also appended below another example for the Sierra region that also showed substantial overestimation using RAVG (see appended Rim fire RAVG vs MTBS from DellaSala 2015: Figure 11.14).

Comment Response #16: Treat more area and in a timely manner Concern statement: There is a concern that the project does not treat enough fire-affected areas in a timely and economic fashion. Forest Service Response: After the Abney Fire, the Forest looked at the burned areas and the standards and guidelines provided by the Forest Plan for their management to develop our proposed action. In areas where the Abney fire burned at low intensity there is no need to take action to salvage fire-killed trees. Also, in many of those areas, trying to pick up scattered dead trees is just not economically feasible. It is also a reality that other resource concerns for water quality and wildlife habitat limit how much of an area can be salvage harvested. On national forest lands, there are about 5,500 acres of moderate or high severity burn where more than 50 percent of the trees were killed. There are salvage operations proposed on 25 percent of those acres. In addition, there are about 7,500 acres of underburn, 39 miles of roadside hazard reduction, 139 acres of fuels reduction adjacent to private property, 955 acres of site preparation (which includes fuel reduction), and 87 acres of fuels management zone (see comparison of alternatives table in the EA, page 13). All of these actions occur in, and are driven by the Abney Fire and direction in the Klamath Forest Plan. While there is more that could be done, we believe the action alternatives are balanced responses to the conditions created by the Abney Fire. Finally, the Forest is diligently working on completing this project in a timely manner, while ensuring compliance with all laws, regulations, and policies, as we recognize that as trees continue to deteriorate, they lose the economic value by which this project is feasible to implement (EA, page 50).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments With the large acres of the Klamath National Forest that have been adversely affected by the catastrophic wildfires over the last few years, it is imperative that as many acres be 46-3 restored to a healthy resilient state as quickly as possible, all while keeping the project economical. As always post fire, time is of extreme importance. The faster the project can be 46-5 implemented the better for economic viability.

Comment Response #19: Effects to Soil Stability Concern statement: There is a concern about the effects of salvage logging on soil stability in the project area. Commenters stated that loss of ground cover as well as tree roots will decrease soil stability, causing more erosion in areas that have been logged compared to areas that have not been logged. Forest Service Response: Loss of ground cover and the eventual decay of tree roots will have a short term decrease in slope stability; however, the removal of fire-killed trees and the re-establishment of conifers will ultimately improve slope stability, and decrease the overall time that a given slope will have a reduced stability. Conifers have the root depth and network to add considerable improvement to slope stability by acting as an anchor in the ground, removing ground water preventing oversaturation, as well as the benefit of the tree itself by intercepting rainfall and protecting against surface erosion. Furthermore, the project is designed so that no ground based activities (other than planting) will not occur on unstable lands (active landslides, toe zones of dormant landslides, granitic slopes greater than 65 percent, and inner gorges), or areas identified to be sensitive to landslides because of the recent fire. The locations of landings, temporary roads, and skid trails have been field reviewed and adjusted to protect unstable lands and control erosion. Ground based treatment is limited to flat and shallow slopes with designs to limit soil disturbance, and control erosion, Skyline and helicopter treatments will be on moderate and steeper slopes which will limit the loss of ground cover, soil disturbance, and overall slope stability and erosion. Associated Comments: Comment # Comments The tree roots prove more stable soil and the clearcutting will have an impact the 15-1 ecosystem. 27-1 Tree roots support soil and protect it from erosion. Cutting trees means mudslides. The EA failed to disclose and analyze the impact to soils and recovering vegetation when 53-197 activity slash is disposed of by slash burning. The EA fails to disclose or analyze the fact that the majority of post-fire logging units, new roads and landings will be constructed in this eastern portion of the project area. Soil 53-226 impacts associated with the Seiad Horse Risk Reduction Project will be concentrated in the most erosive soils in the planning area, and in a currently impaired watershed, that

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments supports important habitat for the coho salmon. For instance, the EA predicts a 10% increase in sediment yield in the West Fork of Horse Creek if the proposed action is implemented (USDA. 2018a p.74). The West Fork of Horse Creek drains into productive coho habitat, has the largest concentration of commercial logging units and the most erosive soils in the area. The impact of concentrating activities in these sensitive soils and watersheds will be severe and was unanalyzed in the EA. The EA failed to disclose or adequately analyze the impact of proposed management activities on soil resources, historic landslides, earthflow and geologic riparian reserves. • 53-234 The EA failed to compare the erosion rates between treated and untreated units in the project area. Harvesting can cause an increase in disturbance of the forest floor that in turn can increase erosive processes, both direct (e.g. mechanical mixing) and indirect (e.g. splash erosion). The magnitude of disturbance is influenced by the method of felling and yarding as well as the mitigation measures imposed, with groundbased extraction (feller-buncher felling, tractor skidding, and partial-suspension skyline yarding) causing greater levels of disturbance relatively to helicopter and full-suspension skyline yarding. Klock (1975) examined disturbance from various logging methods in a post-fire forest. Tractor skidding produced a mean percent disturbance of 36% (although only 10% when over snow), 32% for skyline yarding without full suspicion, 2.8% for skyline yarding with full suspension, and less than 1% for helicopter logging. (See Klock, 1975.) Chou et al. (1994), which examined percent ground disturbance after salvage logging on the Stanislaus National Forest, found that the mean disturbance for tractor logging was 35% and 18% for cable-logged. (See also Chase, 2006; Slesak et al., 2015). Harvesting is also associated with soil compaction. Increased soil compaction influences other processes, including increased runoff from reduced micro and macro soil porosity (Wagenbrenner et al., (2016). Soil compaction and ground disturbance are also associated with impacts to returning vegetation. Post-fire logging has been shown to damage natural regeneration, (Donato et al., 2006; Keyser et al., 2009). Vegetation, particularly increasing root strength, has been shown to reduce 62-14 landsliding risk. Soil compaction has potentially long-lasting effects on plant development, potentially decades. (Wert and Thomas, 1981; Vora, 1988). Logging has also been shown to reduce the amount of soil cover, both in litter and vegetative cover, compared to unburned areas, increasing the amount of bare soil susceptible to splash erosion (Wagenbrenner et al., 2016; Morgan et al., 2014; Chase, 2006). A loss of surface cover also will increase surface flow velocities, resulting in more sheer stress for soil detachment and helping to creating rilling and gullying (Shakesby and Doerr, 2006; Robichaud et al., 2010; Wagenbrenner et al., 2015). Skid trails, feller-buncher trails, cable rows, and other similar disturbances also influence sediment production. Such disturbances, when oriented perpendicular to the slope, can act as sediment traps; however, when parallel to the slope, these trails and tracks can help to concentrate surface flows, promoting rill initiation and sediment production (Wilson, 1999; Ares et al., 2005; Chase, 2006). Skyline or cable yarding generally requires trees be pulled uphill, creating a pattern of cable rows nearly parallel to the slope, which has been shown to create rills and increase sediment production (Chase, 2006; Smith et al., 2011). Tractor logging created both parallel and perpendicular disturbances, in some cases helping to trap sediment, and in others acting to concentrate flows and increase sediment production. Alternatively, soil disturbance could mitigate fire effects as it can break apart bydrophobic soil layers, although this

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments potential benefit is greatest immediately after a fire. (See McDonald and Huffman, 2004). Furthermore, Wagenbreener et al. (2015) found that whatever positive effect this has is negated by soil compaction associated with logging. Similarly, all units are likely to suffer a loss of surface cover as a result of logging (Wagenbrenner et al., 2016; Morgan et al., 2014; Chase, 2006), increasing surface flow 62-19 velocity, scouring and rilling (Shakesby and Doerr, 2006; Robichaud et al., 2010; McGuire et al., 2013; Wagenbrenner et al., 2014).

Comment Response #22: Soil Effects Analysis Concern statement: There is a concern that the EA does not properly disclose impacts to soil resources. Commenters also claim that the Forest did not conduct adequate field review/mapping of soils or provide maps of such review in the NEPA document. Forest Service Response: While we agree that high severity fire can impact soils, as can post-fire salvage and fuel reduction operations, we do not believe the intensive and exhaustive soils analysis requested in the comment is necessary to support those actions being proposed. The regulations for the National Environmental Policy Act (NEPA) state that “NEPA documents must concentrate on the issues that are truly significant to the action in question rather than amassing needless detail” (40 CFR 1500.1(b). Forest Service regulations for preparing environmental assessments note that “The EA (i) Shall briefly provide sufficient evidence and analysis, including the environmental impacts of the proposed action and alternative(s), to determine whether to prepare either an EIS or a FONSI (40 CFR 1508.9) (36 CFR 220.7(b)(3)(i)). The Forest Service reviewed soil conditions on-the-ground during project planning. A portion of the units had complete soil transects using the Forest Soil Disturbance Protocol. This provided the baseline to ensure that visual assessments on the remaining units were accurate. The journey-level soils specialist who conducted field reviews determined that the published soil survey for the Klamath National Forest provided adequate information for project planning, and that project design features and best management practices in place were adequate to ensure that proposed action and alternatives would meet the soil protection requirements of the Klamath Forest Plan Forest Plan consistency checklist). The field surveys and analysis performed by the Forest Service are adequate to inform the decision to be made. Associated Comments: Comment # Comments Total organic matter remaining after the fire and after salvage is the key indicator for the issue of site productivity. The EA fails to address soil chemistry, productivity, hydrology, 49-51 and biological integrity on a site-specific (i.e., unit-by-unit) basis. The KNF did not map soil types and composites using field reconnaissance data and include the maps in the NEPA document

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #23: Implementation Costs versus Benefits Concern statement: There is a concern that the EA did not disclose the costs of all treatments within the Project. Commenters suggest we should prepare an EIS to compare the costs of treatments versus perceived benefits. Forest Service Response: While the agency remains confident that the necessary funding will be acquired when needed for activities to be implemented, there is no requirement that the receipts from the salvage harvest proposed here or funds from any other sources cover the costs of those future activities, nor is there a requirement to compare the economic costs of the activity to its ecological benefits. These considerations, however, are one of the many factors the responsible official must weigh in making the decision to undertake a project or not. Under current management priorities, national forest timber sales are generally designed to accomplish management or ecological objectives that have multiple benefits; their primary purpose is not revenue generation. In this Project, salvage harvest units have been primarily designed to reduce the risk of high severity fire within the Late Successional Reserve and to promote the development of a fire-resilient coniferous forest to meet the desired conditions for this management area, not solely to generate revenue. Salvage harvest achieves important fuel reduction goals because it removes heavy fuels that contribute to future fire severity and resistance to control. In other words, the dead trees that are harvested reduce fuel loads and pay their own way out of the woods. Regardless of the value of timber sale receipts, salvage harvest projects can be highly ecologically valuable, and can provide one of the only economically feasible means of removing the heavy fuels. Salvage logging also reduces the cost of other subsequent fuel treatments such as hazard reduction. We believe the Seiad-Horse Project is likely to receive the funding it requires for full implementation over the course of the project, and the agency is committed to using whatever funds it has available to accomplish the project's post-sale restoration goals. Associated Comments: Comment # Comments The EA fails to disclose the costs of mechanical and related treatments for the entire project area and instead focuses only on presumed benefits. We request that you disclose 54-15 project costs related to temporary road building and decommissioning, road maintenance, heli-logging, fuel treatments, replanting, etc. and compare those costs to presumed project benefits in an EIS.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #25: Effects to Soil Compaction Concern statement: There is a concern that the effects of logging operations on soil compaction has not been properly analyzed in the NEPA document. Logging operations include tractor logging, cable logging, skidding, and temporary road use and construction. Commenters cited peer-reviewed literature, the Klamath National Forest FY12 Monitoring and Evaluation Report and a Bureau of Land Management EA. Project design feature (PDF) Watershed #4 was of particular concern. Forest Service Response: The current conditions were found to be compliant with the Forest Plan and best management practices (BMPs). The effects of logging on the soils in the area cannot be assessed until the post logging soil monitoring. Project design feature Watershed 3 was implemented following the 2012 monitoring report. Watershed 2 makes sure Watershed 4 is not used to the point that it detrimentally affects the soil resource. Associated Comments: Comment # Comments Attachment 15 is a peer-reviewed by that appeared in November 2004 / Vol.54 No.11 issue of BioScience entitled "The Effects of Postfire Salvage Logging on Aquatic Ecosystems in the American West" by Karr et. al. The authors found that: 1. "Postfire salvage logging generally damages soils by compacting them, by removing vital organic material, and by increasing the amount and duration of topsoil erosion and runoff (Kattleman 1996), which in turn harms aquatic ecosystems. 2. Postfire salvage logging has numerous ecological ramifications. The removal of burned trees that provide shade may hamper tree regeneration, especially on high-elevation or dry sites (Perry et al.1989). The loss of 14 future soil organic matter is likely to translate into soils that are less able to hold moisture (Jenny 1980), with implications for soil biota, plant growth (Rose et al.2001, Brown et al. 49-39 2003),, and stream flow (Waring and Schlesinger 1985). Logging and associated roads carry a high risk of spreading nonindigenous, weedy species (CWWR 1996, Beschta et al. 2004). 3. Increased runoff and erosion alter river hydrology by increasing the frequency and magnitude of erosive high flows and raising sediment loads. These changes alter the character of river channels and harm aquatic species ranging from invertebrates to fishes (Waters 1995). 4. Construction and reconstruction of landings (sites to which trees are brought, stacked, and loaded onto trucks) often accompany postfire salvage logging. These activities damage soils, destroy or alter vegetation, and accelerate the runoff and erosion harmful to aquatic systems. 5. By altering the character and condition of forest vegetation, salvage logging after a fire changes forest fuels and can increase the severity of subsequent fires (CWWR 1996, Odion et al. 2004)." Please note that the KNF FY12 Monitoring and Evaluation Report (page 8 and 9) discusses impacts of post-fire tractor yarding in the Panther Salvage timber and states: "The majority of areas that did not meet desired [post project] conditions were located on primary skid 49-52 trails and landings. Due to a lack of protective duff mat on the soil surface, and increased amount of disturbance was noted on secondary skid trails compared to green timber sales. Recommended changes to planning tractor yarding for salvage timbers sales is to reduce the extent of soil displacement and compaction by limiting slope steepness where skidding

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments can occur or limiting the total area in the unit in primary and secondary skid trails. Alternatively, planners can reduce soil disturbance in fire 21 salvage units by changing logging systems from tractor yarding to cable or helicopter yarding." We asked KNF timber planners to please address the following conclusions from page 44 of the Doubleday Fire Salvage Environmental Assessment. March 2009. BLM-ORMO50- 0015-EA. Butte Falls Resource Area. Medford District BLM: http://www.blm.gov/or/districts/medford/plans/files/DoubledayFireSalvage.pdf "Tractor yarding causes soil compaction and displacement. Soil compaction is an increase in bulk density with a corresponding decrease in soil porosity. Compaction reduces soil productivity through a reduction in root growth, tree height, and timber volume (Greacen and Sands 19801; Froehlich and McNabb 19842) and may be produced by a single pass of logging equipment across a site (Wronski 19843). Productivity losses have been documented for whole sites (West and Thomas 19814) 1 Greacen, EL and R Sands. 1980. 1980 Compaction of forest soils. A review. Australian Journal of Soil Research. 18(2):163- 189. 2 Froehlich, HA, and DH McNabb. 1984. Minimizing soil compaction in Pacific Northwest forests. In EL Stone (editor) Forest Soils and Treatment Impacts. Proceedings of 6th North American Soils Conference, June 1983, University of Tennessee, Department of Forestry, Wildlife and Fisheries, Knoxville, TN. P 159- 192. 3 Wronski, EB. 1984. Impacts of tractor thinning operations on the soils and tree roots in a Karri forest, Western Australia. Australian Forestry Research 14:319-332/ 4 West, S and BR Thomas. 1981. Effects of skid roads on diameter, height, and volume growth in Douglasfir. Soil Science Society of America Journal 45:629-632. 24 and for individual trees (Froehlich 19795, Helms and Hipkin 19866). Decreases in important microbial populations have also been observed in compacted soils (Amaranthus et al. 1996.)7 Soil compaction may also increase surface 49-63 runoff because of reducing infiltration (Graecen and Sands 1980.)8 Soil displacement from tractor yarding occurs when the tracked equipment turns on its skids pushing the soil into small piles, or berms, along the skid trails. This displacement of the topsoil removes the organic litter layer and exposes mineral soil. Removal of the loose, organic surface materials promotes surface sealing and crusting that decreases infiltration capacity and may increase erosion (Child et. Al. 1989.)9 Soil displacement also results in a loss of important soil biota, such as mycorrhizal fungi, which facilitates nutrient uptake by plants." (Amaranthus et al. 1989 and 1996.)10 Predictably, our request for the agency to consider the information above was ignored and rejected in the KNF's rush to push out a salvage logging clearcutting project as quickly as possible without sufficient environmental analysis....5 Froehlich, HA. 1979. Soil compaction from logging equipment: effects on growth of young ponderosa pine. Journal of Soil and Water Conservation 34:276-278. 6 Helms, JA, and C Hipkin. 1986. Effects of soil compaction on tree volume in California ponderosa pine plantation. Western Journal of Applied Forestry. 1:121-124. 7 Amaranthus, MP, and DA Perry. 1989. Rapid root tip and mycorrhizal formation and increased survival of Douglas-fir seedlings after soil transfer. New Forests 3:77-82. 8 Greacen, EL and R Sands. 1980. 1980 Compaction of forest soils. A review. Australian Journal of Soil Research. 18(2):163-189. 9 Childs, SW, SP Shade, DW Miles, E Shepard, HA Froehlich. 1989. Management of soil physical properties limiting forest productivity. In: DA Perry et al. (eds.) Maintaining the long-term productivity of Pacific Northwest forest ecosystems. Timber Press, Portland, OR. 10 Amaranthus, MP, and DA Perry. 1989. Rapid root tip and

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments mycorrhizal formation and increased survival of Douglas-fir seedlings after soil transfer. New Forests 3:77-82. 25 KNF timber planners make no attempt to distinguish or disclose that soils which are severely burned are likely to respond to ground-based yarding much differently than soils that are moderately burned despite scoping comments requesting such analysis. Indeed, 49-71 the EA simply ignores site-specific soil impacts from yarding activities while indicating that the location of skid trails, log landings and new roads is largely unknown and will not be disclosed to the public the ID Team or the decision maker prior to project implementation. Both action alternatives would allow for ground-based tractor yarding on post-fire soils on 49-113 slopes up to 45%. (EA page 26.) Our organizations oppose tractor yarding on sensitive schist soils throughout the planning area. We are also concerned by skyline yarding on steep slopes. When trees are yarded up steep slopes, one end of the log drags, creating soil compaction, soil erosion and cup trenches that impact hydrology. This process is especially evident at the upper end of the slope and near the landing. The soil disturbance and compaction can lead to rill and gully erosion in highly erosive schist soils. Temporary road construction and the development of 53-223 new landings will also create potentially chronic sources of sediment in important coho watersheds. Both Seiad and Horse Creek are listed as impaired for turbidity and temperature, both of which are affected by high sediment loads. Water quality impacts are affecting aquatic habitats and listed species. Logging, yarding, hauling, new road and new landing construction will all increase soil erosion and water turbidity. Damage to sensitive schist soils throughout the planning area is of concern, especially in the relatively undisturbed areas at the headwaters of Seiad and Horse Creek. The potential impact to soils in this project are extreme, especially in ground based logging 53-224 units. Post-fire logging and road building will compound soil impacts associated with road 53-237 construction, hydrologic alterations and logging impacts. The heavy equipment involved with logging would cause long-term damage to fragile soils, 203-1 decreasing the chances of regeneration of a diverse ecosystem.

Comment Response #26: Application of the Watershed Analysis Concern statement: There is a concern that the EA did not incorporate recommendations made by the watershed analysis regarding past timber harvest and road building impacts to watershed and habitat conditions. Forest Service Response: Recommendations from the two watershed analysis that include the Project area that are pertinent to the purpose and need of this Project were considered when developing action alternatives. Effects of past timber harvest and road building are considered as part of the existing condition. Travel Management Analysis, including road decommissioning, are not part of the purpose and need of the project. Alternative 1, the no action alternative, analyses the effects of no additional temporary roads.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Temporary roads are proposed in Alternatives 2 and 3 to meet the management objectives of the project. Best management practices and Project Design Features (PDFs) will be implemented with any project action alternative to direct placement of and aid in successful closure and rehabilitation of temporary roads (See the EA, PDF Geology 1 and 4, Watershed 11 and 21, and Appendix D - Best Management Practices). Effects to resources as a result of including temporary road construction and reconstruction (new and existing roadbeds) is detailed in the analysis provided in the Affects to Hydrology section, specifically in the Cumulative Watershed Effects (CWE) model discussion. The EA also states that "All temporary road (new or existing) intersections with the National Forest System roads will be obliterated or blocked at project completion to avoid unauthorized use. All temporary roads would be hydrologically stabilized following use, including out-sloping of road surfaces and proper construction of water bars. Erosion and sedimentation control structures (water bars) would be maintained and repaired according to the guidance in the Forest Service Handbook 2409.15 Region 5 Supplement (USDA 2012b). No new roads would be constructed within riparian reserves. The only existing road in hydrologic riparian reserves that would be used is an existing non-system road that accesses a water drafting site. This existing non-system road has no legacy sediment sites and no stream crossings." (EA, page 14). Effects of temporary road use and construction are disclosed in the EA, and were modeled as part of the CWE analysis, and are included in the project record available on the project website and will be considered by the Responsible Official in arriving at a decision. Associated Comments: Comment # Comments Please note that many of the logging roads in the project area are duplicative "triple stacked" spur roads that serve limited management or recreational purposes. Timber 49-83 planners must disclose the need to log along such roads when weighed against the recommendations of the Watershed Analysis to reduce road density in this planning area Please also note that the B-10 of the Northwest Forest Plan states that: "The intent is to ensure that a decision maker must find that the proposed management activity is consistent with the Aquatic Conservation Strategy objectives. The decision maker will use the results of the watershed analysis to support the finding." The Klamath National Forest 49-92 simply ignores many references in the WA that speak directly to the adverse impacts of road construction, road density, and ground-based yarding practices in these fragile watersheds. The findings of the WA regarding the loss of late-successional habitat through management activities is also not well-reflected in the scoping notice. Additionally, the findings of the Horse Creek Watershed Analysis regarding the impacts of road density (which will be exacerbated by road construction, landing establishment and yarding activities) on the ecological resiliency of the Seiad-Horse planning area are quite clear: "Human activities, including past forest management and road building have fragmented habitat in LSRs and across the analysis area." Horse Creek WA 2-4 38 "The 49-149 amount, distribution and condition of late-successional forest in the landscape has been identified as an issue due to fire suppression effect and loss of older forests through timber harvest, road building and wildfire." Horse Creek WA 3-23 "Timber harvest and road building have accounted for most of the management that has impacted vegetation and influenced the amount of late successional habitat found today." Horse Creek WA 3- 23 "Roading contributes to increased fragmentation of vegetation by dividing patches into

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments smaller fragments. The location of roads on the landscape has a significant effect on landscape continuity and connectivity." Horse Creek WA 3-27 "Road construction removes and fragments habitat, affects wildlife distribution and movements and increases the potential for outside disturbance factors." Horse Creek WA 3-28 "Average total road density within the entire Johnny O'Neil LSR is 3.1 miles of road per square mile….Habitat models in the forest Plan suggest that habitat capability for marten and fisher is reduced to low when open road densities exceed 3 miles per square mile." Horse Creek WA 3-28 Given the findings of the WAs that are quoted above, we contend that the Seiad-Horse timber sale planning process has ignored the requirement at B-10 of the Northwest Forest Plan requiring that: The information from the watershed analyses will contribute to decision making at all levels. Project-specific NEPA planning will use information developed from watershed analysis. For example, if watershed analysis shows that restoring certain resources within a watershed could contribute to achieving landscape or ecosystem management objectives, then subsequent decisions will need to address that information. Impaired watersheds such as Horse and Seiad Creek should not be subjected to further degradation. Road density is directed in Watershed Assessments for reduction rather than 53-238 expansion. No new roads (temporary or permanent) should not be built in the Seiad Horse Risk Reduction Project. The ecological cost is simply too high.

Comment Response #27: Visual impacts of salvage near the Pacific Crest Trail (PCT) Concern statement: There is a concern that the EA did not adequately address viewshed concerns for the PCT, Condrey Mountain Special Interest Area (SIA), Roadless Areas, and historical recreation sites. Commenters opposed the salvage harvest units visible from and close to the PCT, specifically units within a half mile of the PCT, units within one mile of the PCT, units within two miles of the PCT, all units within a Visual Quality Objective (VQO) management area, and all units visible from the PCT. Commenters were particularly concerned about viewsheds from Lily Pad lake to Slaughterhouse Flat. Forest Service Response: As a result of scoping comments, this concern was identified as a relevant issue, and analyzed in detail in the EA. Alternative 3 was developed to respond to this issue by removing all risk reduction salvage harvest treatment within one mile of the northern project boundary, which the PCT follows. Alternative B was also developed to avoid salvage harvest in units near to and within the foreground views of the PCT, but was eliminated from detailed study for reasons documented in the EA. The Forest Plan was used, as mandated, for direction in the scenic resource analysis and for the standards and guidelines that apply to the retention and partial retention visual quality objective management areas within the project area. The Forest Plan lists Cook and Green Pass along the PCT as the designated viewpoint from which to measure effects to scenic resources. As a response to public comment, twelve additional viewpoints were considered along the PCT within the project area, and geographic information analysis disclosed the seen acres or acres that may be seen of proposed alternative treatments from selected viewpoints that include six of the

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest twelve. Appropriate project design features respond to the variety of proposed management activities, to balance minimizing potential direct and indirect visual effects within a shorter timeframe as seen from the viewpoints, as well as ensuring aesthetic and ecological restoration can occur in the project area within a longer timeframe. The following project design features were used to minimize the potential direct and indirect effects of the proposed alternatives as seen from viewpoints along the PCT: Recreation and Scenic Resources 1 through 4, and 8 through 9. Additionally, the following project design features minimize recreational impacts of proposed project alternatives: Recreation and Scenic Resources 5 through 7. All aforementioned design features can be found in the Project Design Feature section of the EA. Associated Comments: Comment # Comments Protect the scenic and recreational qualities of the Pacific Crest Trail (PCT) by canceling all 5-11 post-fire logging units within a mile of the PCT. Protect the viewshed of the PCT by canceling all post-fire logging units visible from the PCT 5-12 between Cook and Green Pass and Slaughterhouse Flat. With that in mind, we are writing today to ask that the Forest utilize appropriate visual 52-1 mitigation measures to minimize the inevitable impacts to the PCT viewshed as it passes along the northern boundary of the project area. 52-2 Whenever possible, avoid salvage harvest units within ½ mile of the Pacific Crest Trail. I appreciate that the project design feature recreation and scenic resources #3 addresses visual impacts of salvage harvest units in that; "Where practical, avoid overall non-natural 52-5 shapes (rectangles, squares, etc.) between salvage harvest and site preparation and planting unit boundaries and non-treatment areas" To expand on that somewhat, please avoid non-natural shapes by striving to match the contour, form, and line of landscape. 53-57 We are concerned that viewsheds for the PCT will be gravely impacted. Canceling all units within two miles of the Siskiyou Crest would also protect the PCT viewshed and maintain the quality of experience currently expected and offered in the region. An estimated 26 units are located within two miles of the Siskiyou Crest in the 53-60 West Fork of Horse Creek and the East Fork of Seiad Creek in sections 10,11, 13, 14, 15 & 16. 23 Units within two miles from the summit of the Siskiyou Crest including: 1,4,8, 26, 27, 28, 35, 36, 37, 38, 39, 41, 42, 44, 45, 46, 47, 48, 49, 50, 51, 52, 86, 87, 92 & 93 should be canceled to protect connectivity on the Siskiyou Crest. The Seiad Horse Risk Reduction Project EA failed to adequately consider significant impacts to the scenic and recreational resources of the Pacific Crest Trail (PCT). The viewshed is the PCT's biggest asset and it will be significantly degraded by the scars of post-fire logging if the Seiad Horse Project is approved. Currently naturally appearing landscapes will be 53-202 altered to include abrupt, linear openings, stump concentrations, denuded slopes, new roads, landings, and generally diminished viewsheds. According to the EA, post-fire logging treatments will be conducted between 211' and 1850' from the trail. Obviously, the units closest to the trail will have the largest cumulative impacts, but viewsheds from the PCT extend across the planning area.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The PCT runs directly above the areas targeting for post-fire logging in both Seiad and Horse Creek. The entire roughly 13 mile stretch of trail from Lily Pad Lake to A view south 53-204 from the Pacific Crest Trail. Unit 35 is located in the green trees directly below, while nearly the entire ridge below will be subjected to post-fire logging in the Seiad Horse Risk Reduction Project. Slaughterhouse Flat would be impacted by degraded viewsheds from post-fire logging. The Seiad Horse Alternative 2 Viewpoints & Viewshed Map accompanying the EA validates these findings by showing distinct viewshed impacts across the PCT roughly 13 miles from the Horse Camp Trail intersection to Slaughterhouse Flat. This viewshed analysis demonstrates that essentially all post-fire logging units will impact the viewshed of the PCT and the cumulative impact will significantly degrade the viewshed and recreational experience. The entire viewshed from Red Butte to Black Mountain will be significantly impacted by proposed management activities. The same analysis shows that substantial viewshed impacts will occur near Slaughterhouse Flat at Viewpoint #12, where over 600 acres of post-fire logging units would be seen. The current viewshed is largely unimpaired and after post-fire logging will consist of vast clearcuts and large impaired viewsheds. Many miles of the PCT will suffer from the creation of unnatural openings with abrupt, linear boundaries, stump concentrations, denuded slopes, new roads, and generally diminished scenic and recreational values. These impacts are directly related to post-fire 53-205 logging, new road and new landing construction proposed in the Seiad Horse Project. Further west, viewshed impacts would be less pronounced, but even at Viewpoint #5 west of Cook and Green Pass 276-acres of post-fire logging would be visible. Although not analyzed, the impact would be similar at the Red Buttes Wilderness boundary near Lily Pad Lake with more than 200 acres of post-fire logging units visible. The long term impacts to the PCT are undeniable Given the international acclaim of the PCT and the continuing popularity of the trail, it would be unwise to degrade the spectacular viewsheds or log so close to the trail. The impacts associated with the Seiad Horse Project will impact thousands of trail users every year. Maintaining a healthy, intact ecosystem along the PCT corridor is consistent with the current and expected future recreational use of the area. Unit 35 near Copper Butte is located roughly 211' from the PCT. Unit 36 will also be visually prominent. Unit 35 and the adjacent units in upper Horse Creek will significantly impact scenic and recreational resources. Unit 35 will be highly visible in the foreground with a vast expanse of contiguous post-fire logging units extending south into Horse Creek. Many of the proposed units in upper Horse Creek would log adjacent to the Condrey 53-206 Mountain IRA and Designated Backcountry Area, in uninventoried roadless areas. These areas are disproportionally important from a viewshed and recreational stand point.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The EA failed to take a "hard look" at the impact of the Seiad Horse Risk Reduction Project on the PCT experience. The agency must adequately analyze the impact of degrading the PCT and its viewshed in an EIS. This analysis must include analysis of both the recreational experience and the economic benefits the PCT provides. It is simple, the less attractive our local section of trail is, the less folks will travel to our area to experience its beauty. 65 Logging treatments would be visible from the PCT and will impact the recreational 53-207 experience of trail users. Protecting the remaining intact forest adjacent to the trail is necessary to protect the internationally renowned values of the PCT. Impacts to the PCT and the immediate environment surrounding the PCT should be minimized by canceling all units adjacent to the Siskiyou Crest and visible from the PCT. A minimum two-mile buffer should extend from the summit of the Siskiyou Crest south. This will protect the PCT viewshed and will also protect the largely intact, two-mile corridor at the headwaters of Horse Creek. The EA failed to adequately consider the extreme viewshed impacts associated with post- fire logging adjacent to the PCT. • The EA failed to adequately disclose and analyze the 53-208 impact of post-fire logging to the recreational experience on the PCT. • The EA failed to disclose and analyze the economic impacts of the PCT to surrounding communities. The EA must analyze and disclose the impact of post-fire logging in visual retention areas Our organizations oppose post-fire logging in Visual Retention Areas on the Siskiyou Crest. 53-209 Protecting these viewsheds and designated Visual Retention Areas will protect the recreational value of the PCT, the Condrey Mountain Inventoried Roadless Area and the Condrey Mountain Designated Backcountry Area. Numerous units are located within a Visual Retention VQO Area on the Siskiyou Crest. 53-210 These units should be canceled. The forests targeted for post-fire logging on Seiad and Horse Creek are particularly 53-211 important, as they are directly adjacent to or below the PCT. Project implementation will significantly impact the important PCT viewshed. Logging these stands will only further degrade VDQ standards in some of our most important viewsheds. The views are currently mostly unimpaired by human development 53-212 and impacts, the foreground, (defined in the EA as up to 1 mile) contains naturally appearing landscapes and will be heavily degraded by post fire logging. The post-fire logging units proposed in the project would degrade important visual resources. Proposed treatments would not provide "attractive scenery" or "naturally appearing conditions". According to Visual Retention VSO "visual considerations" should take precedence over aggressive timber harvest. Post-fire logging proposed in the project 53-213 will drastically alter visual characteristics adjacent to the PCT and the Siskiyou Crest. Historic camping and recreation areas such as the PCT, Condrey Mountain Inventoried Roadless Area and Condrey Mountain Backcountry Area will sustain long lasting impacts from post-fire logging.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Viewshed analysis mapping associated with the EA, demonstrates that many miles of the PCT will be impacted with degraded viewsheds and increased signs of human development. The impacts will extend from Lily Pad Lake to Slaughterhouse Flat with nearly all proposed units in the viewshed of the PCT. At any given location, up to 600 acres 53-214 of new post-fire logging units would be visible. These units would appear as denuded slopes with high stump concentrations, new roads, abrupt, linear boundaries and unnatural regeneration patterns. They do not reflect the desired condition for the planning area, the PCT viewshed and will diminish the backcountry experience the area is known for. The EA failed to disclose the location of all Visual Retention VQD Areas. • The EA failed disclose the impact of post-fire logging on Visual Retention VQD Areas. • The EA failed to 53-215 demonstrate that all proposed treatments will comply with Visual Retention VQD standards. These same units also have the largest impact on recreational values in the Seiad Horse Risk Reduction Project on the PCT and in the Condrey Mountain IRA and Backcountry Area. Unit 35 The highest elevation unit (unit 35) is located just below Copper Butte roughly an 1/8 of a mile from the PCT and about ¼ mile from the summit of the Siskiyou Crest. The 53-263 landing at the top of the unit is the Copper Butte Trailhead and the beginning of the Copper Butte Trail, which provides the only connector trail accessing the PCT from the south (at least now that the KNF bulldozed the Johnson Trail to the west). Unit 35 and the surrounding post-fire logging units will have the largest impact to recreation in the Seiad Horse Project Area. The location of the unit at roughly 5,600' in the Siskiyou Crest Connectivity Corridor is 53-264 troubling and the impacts to the PCT and backcountry recreation are severe. Unit 35 should be canceled to maintain a naturally variable fire mosaic, landscape 53-267 connectivity, roadless values, recreational values and the scenic beauty of the PCT. Unit 36 should be canceled to protect habitat connectivity, maintain high quality 53-268 recreational experiences on the PCT, Condrey Mountain IRA, and Designated Backcountry Area. • The EA failed to analyze the impact to wildland habitats and backcountry recreation in 53-286 the Condrey Mountain IRA, Condrey Mountain Designated Backcountry Area, Kangaroo IRA, and Kangaroo Designated Backcountry Area. It would also have a negative impact on the Pacific Crest Trail. Keep the Trail area as 453-3 natural as possible.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #30: Support for artificial reforestation Concern statement: There is support for artificial reforestation inside the project area. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. Associated Comments: Comment # Comments 7-4 Replanting all areas that can be improved through this process. 46-4 Salvage logging followed with replanting is the right step to ensuring this happens.

Comment Response #31: Hazard tree removal near the Pacific Crest Trail Concern statement: There is a concern that hazard tree removal near the Pacific Crest Trail will impact the character of the trail and that further protections should be implemented. Forest Service Response: As a result of scoping comments, this concern was identified as a relevant issue, and analyzed in detail in the EA. The Forest Plan was used, as mandated, for direction in the scenic resource analysis and for the standards and guidelines that apply to the retention and partial retention visual quality objective management areas within the project area. Six of the 12 additional viewpoints (considered based on scoping comments) were used for the analysis, and geographic information analysis disclosed the miles of roadside hazard that may be seen, as well as the viewing distance to these areas from the viewpoints. Project design feature Recreation and Scenic Resources 2 was included to minimize the short term visual effects of hazard tree removal. However, a no treatment buffer around the trail is not feasible as trees which are hazards to the road, and potentially to the trail as well, need to be abated to meet the purpose and need of the project for safe public access. There are no anticipated trail crossings needed for implementation of project activities and therefore a project design feature to avoid this action is unnecessary. Furthermore, project design features Recreation and Scenic Resources 4 and 9 minimize potential effects to the trail from roadside hazard removal activities.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments Any trees removed, particularly in the stand just west of Cook and Green Pass, could have 52-7 a significant impact on the character of the PCT in this area. I ask that the Forest consider removing as few trees as possible and I stand ready and 52-8 willing to join Forest staff in the field to identify measures to protect the PCT. I appreciate the project design features included in the EA that address hazard tree cutting along the PCT. However, I ask the Forest consider amending them somewhat to further protect the PCT and the experience of the trail user. * • Recreation and Scenic Resources #4 states to "Avoid vegetation removal work within 20 feet of Pacific Crest National Scenic Trail (#2000) corridor, at the Cook and Green Pass area. If hazard tree removal is necessary, work with the silviculturist, the recreation specialist, and the landscape architect (or representatives) for individual tree identification." I understand there may be 52-9 a need for some hazard tree cutting in this area and appreciate that individual trees will be identified by the aforementioned team. However, I would ask that Forest consider avoid removing trees within 50 feet of the PCT. * • Recreation and Scenic Resources #9 states "Protect the Pacific Crest National Scenic Trail from damage during the implementation of roadside hazard tree activities." Furthermore, please consider limiting and designating crossings of the PCT. * • To minimize soil displacement, avoid turning equipment within 50 feet of the PCT.

Comment Response #33: Large Woody Debris Removal Concern statement: There is a concern that the Environmental Assessment has not fully analyzed the effects of large woody debris removal, or how removal of such materials is consistent with the Aquatic Conservation Strategy or the Forest Plan standards. Forest Service Response: Compliance of the project with Aquatic Conservation Strategy objectives was analyzed and the compliance report is included in the EA as Appendix C. The effects of the project on large woody debris within riparian reserves and stream channels was assessed in the compliance analyses of Aquatic Conservation Strategy Objectives 1, 2 and 8. The Aquatic Conservation Strategy analysis determined that the project will not retard or prevent attainment of the Aquatic Conservation Strategy objectives of maintaining and restoring adequate large woody debris in streams and adequate course woody debris in hydrologic riparian reserves. The project is consistent with Forest Plan standards by maintaining large woody debris in streams and course woody debris in hydrologic riparian reserves where safe and feasible to do so.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments The EA provided no specific analysis of CWD levels and the impact of logging trees under 53-218 24" DBH from riparian reserves. The EA failed to disclose and analyze the consistency of proposed riparian reserve logging with the Aquatic Conservation Strategy as directed in MA-54 of the KNF Forest Plan. • The EA failed to disclose and analyze the consistency of proposed riparian reserve logging with 53-221 CWD standards identified in the KNF Forest Plan and Aquatic Conservation Strategy. • The EA failed to disclose that not a single stream reach in Horse Creek meets the 20 pieces per mile requirement for instream wood. The EA must analyze the effect of post-fire logging on instream wood requirements.

Comment Response #34: Bee Camp Road (47N80) should be closed Concern statement: Commenters suggest that roads, especially the Bee Camp road, should be closed. Suggestions include downgrading the road to ML1, decommissioning the road, rehabilitating and revegetating the road, and letting the road to regenerate naturally. Commenters further stated that hazard tree removal on the road is inconsistent with Forest Plan standard and guideline MA9-6 which states that "Existing roads within the management area should be closed, placed in a self- maintaining condition and revegetated" (page 4-104). Forest Service Response: This is outside the scope of the proposed action, and is not related to the decision to be made. Travel analysis is not included in this project, and no new system roads are proposed for construction or decommissioning. Temporary roads are proposed to meet the management objectives. Best management practices and project design features will be used to address effects of temporary roads. Also proposed is the removal of hazard trees from alongside system roads to provide safe access on roads for the public, forest workers, and firefighters. As a commenter mentions, there is a Forest Plan standard and guide for the Backcountry management area that states "Existing roads within the management area should be closed, placed in a self-maintaining condition and revegetated" (Forest Plan, page 4-104). As suggested, roadside hazard tree removal along forest road 47N80 in the Backcountry management area may not be an activity that provides a "self-maintaining condition" for the road. However, this standard and guide continues to say "Roads used for trailhead access should be maintained to accommodate recreation users" (Forest Plan, page 4-104). The 47N80 road is regularly used by recreation users for access two designated dispersed campgrounds at its terminus, and also provides access to the Pacific Crest Trail and the West Fork Seiad Creek Trail. To accommodate recreation user access to these sites, roadside hazard removal is appropriate on the 47N80 road as it meets the purpose and intent of this Forest Plan standard and guideline. Forest Plan interpretation is the responsibility of the Forest Supervisor who concurs that this treatment meeting the purpose of MA9-6.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments Road 47N80, the road to Bee Camp, should be closed and the Kangaroo Roadless Area 5-17 allowed to regenerate naturally after the Abney Fire. Further, the 47N80 "Bee Camp" road should be downgraded to an ML1 road. It serves no 49-13 recreational or management purpose and is a frequent starting point for illegal motorized travel into the Red Buttes Wilderness Area. Decommission roads and restore their hydrologic function, particularly in or near Riparian Reserves, on steep slopes, and where roads are not needed to support fire management 49-88 or private access. Many federal logging roads within the project area should be decommissioned. It is our position that road 47N80 should be closed to all motor vehicle use and all 53-113 proposed roadside hazard logging be canceled. Closure of road 47N80 and cancelation of proposed Roadside Hazard Logging would more 53-115 effectively meet the stated management goals. This Standard and Guide (MA9-6), should be applied to 47N80 and the road should be closed and "placed in self-maintaining condition", hazard tree removal is inconsistent with 53-116 self-maintaining condition and continued inclusion of road 47N80 in the Forest Transportation System is a violation of MA9-6. Road 47N80 should be rehabilitated as described in the MA 9-6, allowed to revegetated 53-117 and made into a non-motorized loop trail from Cook and Green Pass to Bee Camp and back on the PCT. Road 47N80 should be closed to motorized traffic at Cook and Green Pass and all hazard 53-118 tree logging should be canceled. Cancel any new road construction and roadside logging on the Bee Camp Road inside the 57-4 Kangaroo Roadless Area and remove it from the system. Cancel any new road construction and roadside logging on the Bee Camp Road inside the 71-6 Kangaroo Roadless Area and remove it from the system. Cancel any new road construction and roadside logging on the Bee Camp Road inside the 148-8 Kangaroo Roadless Area and remove it from the system. We request that you cancel roadside hazard logging on Bee Camp Road (Road 47N80) and close the road to motorized use to protect the Kangaroo Roadless Area. The SCNPSO frequently hears from our members that the PCT and Bee Camp Road are heavily utilized 572-23 for botanizing due to the amazing botanical diversity and rare plants in the area. Many of our members support the closure of Bee Camp Road in order to protect the roadless and botanical values in the area. Roadside logging is not appropriate in this hotspot for biodiversity. Of special concern to me is that the KNF stay out of the Cook and Green Botanical Area 573-2 and that no roadside logging occur on the Bee Camp Road. Bee Camp Road should be closed and decommissioned to protect Roadless qualities in the Kangaroo Roadless Area.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #35: Support for roadside hazard tree removal Concern statement: There was support for proposed roadside hazard tree removal as this treatment would provide for safe public and firefighter access. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. Associated Comments: Comment # Comments 7-3 Removal of hazard trees along the miles of access roads. 7-5 I'd like to see any roads be kept open for future firefighting access. Making sure that the existing roads remain open is extremely important for public access 46-2 and future fire suppression efforts. The 41 miles of proposed roadside hazard tree removal is a good way to make sure that neither of these is jeopardized.

Comment Response #36: Hazard Tree Removal in Riparian Reserves Concern statement: There was a concern with proposed activities which would remove hazard trees from riparian reserves due to soil and bank disturbance these activities would cause, safety concerns, and the removal of potential large woody debris. Forest Service Response: The project does not include salvage harvest activities within riparian reserves. Riparian reserves were all designated as snag retention areas and will not be salvage harvested. However, where hazard trees occur along roadways within riparian reserves, these hazards must be abated to meet the purpose and need of the project to provide for safe access along forest roads. All trees, fire- killed or green, that are not identified as a hazard will be left standing. Timber operators are required by federal and state law to follow standard occupational health and safety practices to minimize unnecessary risk to forest workers. To minimize the effects of removing these hazards within riparian reserves, the design of the proposed action included leaving felled hazard trees on site which may contribute large woody debris. The description of Alternative 2 in the EA includes the following: "Within stream course riparian reserves, roadside hazard trees equal to or greater than 24 inches diameter at breast height would be felled and left on site according to the following criteria: 1) The faller can safely fell the hazard tree away from the road and the fallen tree would not present a direct hazard to the road; and 2) Once fallen, the tree would not disrupt flow through a drainage structure. Hazard trees in stream course riparian reserves where these criteria are not met, or that are less than 24 inches in diameter at breast height, would be felled and removed" (EA, page 7).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Merchantable hazard trees less than 24 inches in diameter at breast height will be removed as one of the "multiple types of activities proposed in Alternative 2 [that] reduce snag densities and surface fuel loading when compared to no action" (EA, page 60). Furthermore, these small trees are not considered sufficiently large enough to provide for large woody debris in the stream. This is supported by the Forest Plan Final EIS where in criteria for the coarse woody debris (or large woody debris) parameter of fisheries habitat it states "Manage for an average of 20 pieces of large wood per 1,000 lineal feet (100/mile) or to achieve site potential in perennial and fish- bearing streams. Westside minimum length 50 feet and diameter 24 inches" (Forest Plan FEIS, page 3-68). This parallels the Forest Plan standard and guideline MA10-56 which states "Maintain 20 pieces of large wood (40 cubic feet or larger) per 1,000 linear feet within 3rd to 5th order channels, or as identified in the ecosystem management process at the watershed level." Additionally, where large wood requirements are provided for, removal of roadside hazard trees and trees in riparian reserves that pose a safety risk is supported by standard and guidelines MA10-53 and MA10-58, respectively. Hazard trees which are large, greater than 24 inches in diameter at breast height, will be felled and left on site to contribute large wood to the stream. Furthermore, project design features were developed to minimize impacts of removing hazard trees to stream channels, banks, and near stream soils as follows, including Watershed 16, requiring full suspension for yarding over streams and within 30 feet of the stream bank, Watershed 22, prohibiting mechanized heavy equipment used in riparian reserves except on existing system roads, existing landings, or existing non-system roadbeds, and Watershed 24, providing for the use of directional felling to protect stream banks where hazard trees need to be mitigated for public or employee safety. Associated Comments: Comment # Comments The EA fails to analyze and disclose how the yarding (as opposed to felling) of large diameter trees below a road (in "reserve" land use allocations) contributes to human health and safety. We contend that the yarding process may actually increase the 49-82 likelihood of injury. Please note that in reserve land use allocations S&G C-15 of the NFP requires that "[i]n other areas, such as along roads, leaving material on site should be considered." Indeed, the Forest Service simply refused to develop or consider reasonable action 49-84 alternatives that retain, rather than remove, large snags and live trees near roads in the Reserve land use allocation. The agency offers no compelling reason or rational for the proposal (at EA page 7) to yard 49-85 and remove snags up to 24" DBH from supposedly protected Riparian Reserves outside of logging units that it is also counting as "leave tree areas." (See EA page 8). Both action alternatives would allow for yarding through riparian reserves and streams. 49-114 (EA page 30). Our organizations oppose all forms of commercial logging in riparian reserves including commercial hazard tree felling. All trees felled should be left within the riparian reserve as 53-216 coarse woody debris and for bank stability. Tree yarding will cause significant impacts to riparian areas and increase turbidity by disturbing soils.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Roadside hazard prescriptions should leave all trees cut within the riparian reserve or felled into the riparian reserve as coarse woody debris and retained on site rather than 53-217 being yarded out and risk causing undue amounts of damage to the riparian area or causing sedimentation downstream.

Comment Response #37: Application of Hazard Tree Guidelines Concern statement: There is concern that the EA does not fully disclose which hazard tree guidelines the Forest will use in marking trees for removal. Commenters further suggest there are multiple options available to reduce hazard tree potential, including target removal, topping, pruning, or bracing, beyond the removal proposed by this project. Forest Service Response: The EA has been updated to disclose that probability of mortality was assessed using a multi- factor hazard rating score, including: crown injury (percent of crown length killed or percent crown volume killed depending on species), cambium injury (primarily using Bark Charring) and red turpentine beetle activity. Target removal, which includes recommendations such as indefinite road closure (downgrading to maintenance level one) or road decommissioning, is outside the scope of this project and not related to the decision to be made as travel analysis is not included in this project. Topping, pruning, or bracing may be possible when the number of hazard trees requiring mitigation is limited in scope, such as in small campgrounds or administrative sites. However, topping, pruning, or bracing thousands of hazard trees along 39 miles of the national forest transportation system roads would be economically infeasible and cost prohibitive. Associated Comments: Comment # Comments The EA bases roadside hazard tree removal on the probability of tree mortality (PM) using Marking Guidelines for Fire Injured Trees in California and determining size classes to 54-52 remove based on PM values and land use categories (e.g., Riparian Reserve, NSO habitat). However, the EA does not disclose whether PM rates were based on multi-factor hazard rating scores or a single marking factor, resulting in uncertainties in estimating mortality. For instance, the most 16 reliable method assesses three factor ratings: crown injury, cambium injury, and red turpentine beetle (RTB). Leaving anyone of these out can result in 54-53 over or underestimating PM values (see marking guidelines). This needs to be fully disclosed instead of vaguely referencing that you are following the California marking guidelines as managers have flexibility in choosing which guidelines to follow. Moreover, hazard tree management includes much more than just removal of trees with moderate to high PM values. In fact, according to the PSW guidelines for hazard trees, five types of actions are available to managers to reduce tree hazard potential: • Target 54-54 removal (i.e., remove that target area such as picnic tables) • Tree removal (the only one the EA considers) • Topping • Pruning • Specialized Actions (e.g. brace the tree) The EA therefore inappropriately choses a single action - tree removal - when five actions are actually available based on the hazard tree guidelines.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #40: Too Much Large Woody Debris Concern statement: There is a concern that too much wood will be placed in the creek and will cause destruction down channel to infrastructure and private property. Forest Service Response: Hazard tree felling and large wood placement for maintaining and improving fish habitat will increase the amount of in-channel large woody debris that could be mobilized in a large flood; however, (1) projected quantity of in-channel large woody debris will not exceed Forest Plan standards, (2) wood placement will utilize large logs and/or logs with rootwads that are less likely to be mobilized in a flood event, and (3) large wood placement will occur within the low- gradient wide-valley reach of Horse Creek where stream power is lowest. Associated Comments: Comment # Comments He isn't against the placing of the logs into the creek, just cautions the Forest Service to 58-3 not put too much that in a major flood event they dam up down creek and cause issues to roads, bridges, private property, etc.

Comment Response #41: Sale Administration Marking Concern statement: There is a concern for how timber is designated or marked for cutting in timber sale contracts and how the Forest will ensure that the purchasers only cut designated trees. Forest Service Response: The implementation of contracts is beyond the scope of National Environmental Policy Act analysis. Forest Service employees monitor timber marking of harvest units to ensure that prescriptions and marking guides are being followed. Forest Service sale administrators monitor the harvest to assure that Forest Plan standards and guidelines, best management practices, and project design features are being implemented. Associated Comments: Comment # Comments The contention at page 36 of the EA that the KNF will merely "monitor" marking of the LSR clearcut logging units and roadside hazard trees is unlawful. NFMA states that the "designation, marking when necessary, and supervision of harvesting of trees, portions of trees, or forest products shall be conducted by persons employed by the Secretary of Agriculture. Such persons shall have no personal interest in the purchase or harvest of 49-125 such products and shall not be directly or indirectly in the employment of the purchaser thereof." 16 U.S.C. § 472a(g). The courts have interpreted this mandate to require the Forest Service, not the purchaser of the timber sale, to mark each tree - not the ground around a tree - proposed for cutting. West Virginia Div. of Izaak Walton League v. Butz, 522 F.2d 945, 949 (4th Cir. 1975). The courts have also held that timber sale contract language, similar to the promised "pre-work meetings," is insufficient to ensure that the Forest

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Service has complied with 16 U.S.C. § 472a(g). Siskiyou Reg'l Educ. Project v. Goodman, 2004 U.S. Dist. LEXIS 15575, *38 - *39 (D. Or. 2004). In Goodman, the court held that under nearly identical facts (i.e., discussions with purchasers and contract language[1] provisions), The scheme appears to require the purchaser to identify leave trees in areas where not all trees will be cut, albeit according to guidelines and apparently subject to subsequent designation by the Service, although the contract language is somewhat unclear on this point. If the Service designates trees identified as leave trees by the purchaser (as opposed to designating trees identified by Service employees) the Service cannot ensure compliance with the snag retention scheme, and it might be said that the purchaser had a hand in designating leave trees. Goodman, 2004 U.S. Dist. LEXIS 15575, at *39 (D. Or. 2004). The court subsequently enjoined the timber sales at issue in that case, pending the Forest Service's marking of the trees to be logged and demonstration of compliance with 16 U.S.C. § 472a(g), concluding: The court is sympathetic to the difficult task facing the Service in designating and marking timber where necessary, and this ruling does not prevent the Service from attempting additional written designations, although the legislative history casts doubt on whether such a description can be sufficiently specific to permit the Service to verify that the purchaser does not cut the wrong trees. Of course the statute would unquestionably be satisfied if Department of Agriculture employees, lacking interest in the sale or harvest and not in the employ of the purchaser, and without assistance of any such persons, were to conduct all designation and necessary marking…. Goodman, 2004 U.S. Dist. LEXIS 15575, at *39 - *40 (D. Or. 2004).

Comment Response #43: Temporary Road Locations Concern statement: There is a concern that the EA does not adequately disclose the location of the temporary roads and therefore cannot conduct a proper effects analysis. Forest Service Response: The interdisciplinary team has reviewed potential locations of temporary roads in units where they are required to implement proposed harvest activities. They have identified any areas of concern and developed project design features to minimize negative effects to resources. While these locations may be adjusted during implementation due to layout considerations, adjustments would be made with a Forest Service sale administrator and resource specialists will be consulted on the adjusted locations. The analysis of effects of project activities, including temporary roads, related to hydrology and fisheries included consideration of the use of existing temporary roads and the construction of new temporary roads which is reflected in the cumulative watershed effects model results. Construction of temporary roads will follow Best Management Practices and Project Design Features included in Table 7 of the EA, specifically Geology 1 and 4, Non-Native Invasive Species 4, Watershed 7, 11, 21, and 24, and Fisheries 2, and in Appendix D. All temporary roads would be hydrologically stabilized following use, including out-sloping of road surfaces and proper construction of water bars. Erosion and sedimentation control structures (water bars) would be maintained and repaired according to the guidance in the Forest Service Handbook 2409.15 Region 5 Supplement (USDA 2012b).

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments The Forest Service cannot adequately disclose or analyze the impacts of the proposed 8 new logging roads on soil and aquatic resources in the project area because the agency 49-89 has not bothered to determine the location where proposed road construction will in fact occur. Indeed, all that is disclosed in the EA is that the agency intends to build new logging roads. Project maps contain no information regarding new road construction. The soils, watershed and wildlife analysis contain no information regarding the site-specific impacts associated with road construction. As stated on page 31 of the EA the KNF intends to allow unanalyzed "modification to the temporary road alignments during the 49-90 implementation phase of the project" based on the desires of the timber purchaser and the sale administrator. Hence the public and the decision maker cannot know where road 35 construction will occur or what the site specific impacts of road construction will consist of.

Comment Response #44: Roadside Hazards in Cook and Green SIA Concern statement: There is a concern that roadside hazard tree removal will have negative impacts on native plant species in the Cook and Green Special Interest Area, particularly Brewer's spruce. Forest Service Response: Thank you for your concern for the Cook and Green Botanical Area. The Forest acknowledges the unique characteristics of this area, particularly the botanical diversity and noteworthy geologic features. The Forest Plan states: "MA7-18 Salvage of burned or pest-killed trees may be allowed to promote the management goals and objectives of the SIA. This also may be allowed for the control of insects or disease, removal of safety hazards to visitors, for new construction or maintenance of improvements. Reforestation of these areas to meet SIA objectives shall be a high priority" (Forest Plan, page 4-99). As it is mapped, a small portion (roughly 12 acres) of the Cook and Green SIA will be treated for roadside hazard tree removal. Project Design Features are included in the proposed action that will avoid or minimize impacts to special interest species and rare conifers from these activities, see PDF Botany 1 through 4, and 8. Project design features for hazard tree removal would also ensure that adequate coarse woody debris and large wood is retained on the landscape to maintain or promote plant diversity. The area would be surveyed and monitored for rare and invasive plant species, and would receive very high priority for treatment of any invasive treatments due to its unique botanical characteristics.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments The Cook and Green Pass Botanical Area would be impacted by commercial roadside 53-44 hazard logging on the KNF. The Cook and Green Botanical Area is "the largest single aggregation of native plant species known to occur in one limited area in California." (Roof 1975) The SCNPSO regularly botanizes in the Cook and Green Botanical Area. We love to observe, 572-6 photograph, document, and even research rare, unique or endemic plants in the Cook and Green Botanical Area. Cook and Green Pass and the Botanical Area are destination spots for botanists across the West Coast and beyond. This unique place deserves the highest amount of protection.

Comment Response #45: Green Tree Harvest Concern statement: There is a concern that live trees will be harvested as a result of the application of mortality guidelines and the use of yarding corridors, temporary roads, and landings. Commenters state that these activities do not comply with the Forest Plan standard and guideline 5-30(2) (page 4- 87). Forest Service Response: As described in under the Roadside Hazard Tree Removal section in the EA, a "green" tree is defined as any tree with less than a 70 percent chance of mortality using criteria in Report #RO- 11-01 "Marking Guidelines for Fire-Injured Trees in California" (Smith and Cluck 2011). Only trees with greater than a 70 percent chance of mortality within three to five years using these criteria would be cut in roadside hazard units and salvage units. All "green" trees (those trees with less than a 70 percent chance of dying as a result of damage from the Abney Fire) that meet this criteria will be retained within roadside hazard and logging operations. The only exceptions are green trees that pose a hazard to roadways as described in the hazard tree treatment section or the occasional green tree that needs to be removed for cable harvesting or landings (EA, page 6). The citation from the Forest Plan standard and guideline MA5-30(2) regarding all standing live trees should be retained leaves out the concluding sentence which states "...including those injured (for example, scorched) but likely to survive." The project is consistent with this standard and guideline and conservative in this regard as fire-affected trees that have at least a 30 percent chance of survival will be retained. Further, all fire-affected roadside hazard trees equal to or greater than 45 inches diameter at breast height would be retained if they have at least a 10 percent chance of survival. Finally, regarding trees that may be removed for operational needs, the Forest Plan clearly allows for this activity in standard and guideline MA5-30(11) which states "Some deviation from these general guidelines [such as to retain all live trees] may be allowed to provide reasonable access to salvage sites and feasible logging operations. Such deviation should occur on as small a portion of the area as possible and should not result in violation of the basic intent that late- successional forest habitat or the development of such habitat in the future should not be impaired throughout the area. While exceptions to the guidelines may be allowed to provide

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest access and operability, some salvage opportunities will undoubtedly be foregone because of access, feasibility and safety concerns" (Forest Plan, page 4-88). Associated Comments: Comment # Comments It appears that KNF timber planners intend to ignore the guidance of their Forest Plan at MA5-30 directing that when conducting post-fire management in LSRs "all standing live trees should be retained…" Instead, the KNF intends to log live trees in proposed LSR 49-22 salvage units "with a 70 percent or greater chance of dying within the next three to five 6 years." - Seiad-Horse Salvage Scoping Notice, page 9. Further, the agency is targeting green live old-growth trees for roadside logging. The EA fails to disclose how many green (living) trees will be logged to facilitate yarding 49-123 activities. KNF timber planners refuse to analyze or disclose how many green (living) trees will be logged under the assumption that they will die in the future. The remaining patches of forest targeted for post-fire logging, are remnants of cool, moist habitat conditions. The existing canopy will be significantly reduced due to the Mortality Guidelines used in the Seiad Horse Risk Reduction Project. Many live "green" trees with significant living canopy will be logged due to assumptions they will die in the preceding years. They will also be felled if they are within cable yarding corridors or represent safety 53-77 hazards to felling crews, yarding crews and helicopter yarding operations. Based on monitoring of the Salmon Salvage Project, the Westside Project, Panther Salvage and other sales, many green trees are removed in post-fire logging units on the KNF. It these trees are removed in the Abney Fire, the last remnants of cool, moist habitat hanging on after the burn will be lost. The Seiad Horse Project proposes to alter this fire mosaic by removing live trees that the agency predicts will die in five years' time. Live trees will also be removed from yarding 53-84 corridors and adjacent to roads. Logging off standing snags and live trees will hinder natural recovery and the retention of "cool, moist" habitat conditions. The Standards and Guidelines for LSR Forest identified in the KNF Forest Plan also discourage the removal of green trees within LSRs, stating that "Surviving trees will provide a significant residual of larger trees in the developing stand. In addition, defects caused by fire in residual trees may accelerate development of structural characteristics suitable for associated species. Also, those damaged trees that eventually die will provide 53-152 additional snags. Consequently, all standing live trees should be retained" during postfire logging operations. Retaining "all standing trees" is functionally very different than logging green trees the agency suspects may die within five years. The LSR specifically acknowledges the benefit of green trees that may die at a later date and recommends that they be retained throughout the LSR. The KNF has failed to disclose or analyze with these recommendations in mind. Logging both large diameter snags and living, green trees is proposed in the Seiad Horse 53-157 Project, yet will significantly impact LSR values and ecological process.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #46: Salvage Harvest near Inventoried Roadless Area Concern statement: There is a concern with the salvage harvest that is proposed near the Condrey Mountain Inventoried Roadless Area which states that these adjacent lands contribute to the roadless character of the IRA and should not be converted into plantations. Forest Service Response: The areas where salvage harvest is proposed in the Seiad-Horse Project are not within an inventoried roadless area. As with all other management areas (for example, wilderness), the laws, regulations, and policies for designated areas apply to the areas designated as such and not to adjacent lands. The Forest Plan and the Roadless Rule require that management actions taken on lands within the inventoried roadless area maintain roadless characteristics but do not determine the actions allowable on adjacent lands designated as other management areas. All of the salvage harvest units are proposed in areas that are roaded and that have a history of timber management. Changing the regulation or boundaries of the inventoried roadless area is outside the scope of the Seiad-Horse Project. Associated Comments: Comment # Comments In addition to proposing commercial roadside logging from the 47N80 road into the adjacent the Inventoried Roadless Area, the EA calls for logging a large number of units that consist of unroaded forests in which a road does not exist between the forest stands 49-132 and an inventoried roadless area. Forest stands in logging units 43, 44, 45, 46, 47, 48, 50, 52, 87, 88, 90 and 92 contribute to the roadless character of the adjacent IRA. The EA fails to acknowledge or analyze the significant impacts of the agency's desire to covert these wildlands into tree plantations.

Comment Response #47: Salvage in the Late Successional Reserve Concern statement: There is a concern that risk reduction salvage and reforestations actions proposed in Late Successional Reserve will not meet the Forest Plan goals or standards and guidelines related to a variety of topics including, large tree removal, green tree harvest, snag habitat retention, habitat connectivity, spotted owl habitat, coarse woody debris, and natural regeneration. Forest Service Response: The purpose of salvage harvest in the LSR is to reduce the risk of future high severity fire by removing heavy fuels and to accelerate the development fire-resilient coniferous forests by replanting, as described and analyzed in the EA. The Draft EA and Final EA (pages 56-63) disclose the effects of the proposed action and its alternatives on the LSR land allocation. Discussions of effects to natural resources such as late successional forest structure, ecological processes etc. occur within the appropriate resource section of the FEIS. For example, discussions of late successional forest habitat and connectivity occur throughout the wildlife reports. The question of LSR salvage as a "significant issue" is addressed by the design of the alternatives and the limited harvest planned in the LSR land

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest allocation. Salvage harvest in the LSR is being done to reduce risk of future high severity fire, not recover volume. Nearly all of the proposed salvage harvest in the LSR is intended to create fuel breaks and reduce fuels to reduce the risk of future high severity fire. The vast majority of the fire killed trees in the LSR will remain unharvested. Standards and guidelines for the late successional reserve land allocation regulate or prohibit activities that would prevent LSR management objectives from being achieved. All of the proposed LSR salvage harvest in the Seiad-Horse project is intended to reduce the potential for severe fire effects associated with future fire events that may occur within LSR in the project area. The Forest Plan of the Klamath National Forest anticipated that risk reduction salvage may be necessary in the late successional reserve land allocation, and provided project guidelines (Forest Plan page 4-86; MA5-27 to 29) to ensure that the objectives of the Forest Plan were achieved. The Forest Plan also provides general guidelines for salvage in late successional reserves when it is not specific to risk reduction (MA5-30-1 to MA5-30-11). These general salvage guidelines were considered in project design, however, the Forest Plan allows for some salvage operations that do not meet guidelines MA5-30 1 through 4 when the salvage is essential to reduce the risk of future risk of fire (MA5-30-5), as is the case in the Horse Creek Project. The project is fully consistent with the Klamath Forest Plan as required by the National Forest Management Act (See the Forest Plan Consistency Checklist on the project website at: http://www.fs.usda.gov/main/klamath/landmanagement/planning) Project effects to the LSR land allocation and associated resources are disclosed in the FEIS as required by the regulations for the National Environmental Policy Act (NEPA) (40 CFR 1500) and the Forest Service NEPA regulations (36 CFR 220). Associated Comments: Comment # Comments The Seiad-Horse Creek logging proposal indicates that proposed unit salvage logging by the Klamath National Forest is located entirely within the Late Successional Reserve (LSR) land 49-16 use allocation. Such logging will inhibit the objectives of the LSR management, decrease ecosystem recovery and resiliency, and increase the controversy surrounding the agency's salvage logging proposal. As will be (one again) established in these comments, salvage logging decreases ecosystem sustainability by inhibiting natural conifer regeneration, removing structural complexity, 49-19 decreasing nutrient cycling, and (especially when combined with plantation establishment) increasing future fire hazard. These are not appropriate project results for the LSR land use allocation. Attached to these comments regarding the Seiad-Horse LSR Clearcutting Environmental Assessment are three additional peer-reviewed studies relevant to project planning. Thorn et. al. 2017, Impacts of Salvage Logging on Biodiversity. This meta-analysis in the Journal of 49-134 Applied Ecology suggests that "salvage logging is not consistent with the management objectives of protected areas." Please note that all of the proposed Seiad- Horse salvage logging units are in the LSR land use allocation. These treatments do not meet the Purpose and Need for the project or the Standards and 53-10 Guidelines for LSR habitat as outlined in the KNF Forest Plan. The proposal to conduct widespread post-fire logging and artificial reforestation will set 53-143 back late successional habitat, preclude a diverse natural pattern of regeneration, eliminating structural complexity and biological legacies across vast acreages. These

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments actions will significantly impact LSR values and are inconsistent with LSR management directives. It is our contention that post-fire logging within these areas is counterproductive and fails to meet the goals to "protect and enhance conditions of late-successional and old growth 53-144 forest ecosystems." Post-fire logging provides no ecological benefit and includes significant impact to late seral habitat conditions. The KNF is now proposing post-fire logging in the remnant habitats that were underburned in 1987. They are also proposing to recreate the same conditions that led to high severity fire effects in the Abney Fire and were identified as a concern in the 1999 planning 53-146 document. These proposals include post-fire logging and replanting efforts....According to the KNF Forest Wide LSR Assessment post-fire or "salvage" logging should only take place if the effect of logging on LSR values provide long-term benefits to late-successional habitats. The KNF Forest Plan also directs silvicultural risk reduction activities in LSR forest to focus on younger stands (USDA, 1994 p. 4-86, MA5-28). The Seiad Horse Risk Reduction is focused on post-fire logging in older stands and the removal of centuries old trees, in the form of dead standing snags. The Forest Plan recommends that "the scale of salvage and other treatments should not generally result in degeneration of currently suitable owl 53-149 habitat or other late-successional conditions. (USDA, 1994 4-86, MA 5- 28)."The Seiad Horse Project fails to meet this standard by removing large amounts of post-fire foraging habitat and hindering the development of future late seral stand conditions. It also has the potential to sever the east-west connectivity of the Siskiyou Crest by eliminating large swaths of foraging habitat and converting them to non-habitat in the form of young, even aged plantations. Clearly the scope, scale and intensity of logging proposed in the Seiad Horse Risk Reduction Project would be inconsistent with pre-disturbance management goals or Standards and Guidelines in the area's LSR forest, northern spotted owl habitat and in areas designated as for visual "retention" such as along the Siskiyou Crest. Large tree and 53-155 canopy cover retention targets and perhaps upper diameter limits would also have likely been implemented as pre-disturbance management goals. The types of treatments and the types of trees being removed in the Seiad Horse Risk Reduction Project are very different than those were 49 envisioned in the Forest Plan. The EA failed to disclose or analyze how post-fire logging will actually benefit LSR values and late successional forest habitats. The agency must provide both credible science and monitoring data from the KNF to support their claims. • The EA failed to disclose how post- fire logging in the Seiad Horse Risk Reduction Project will meet LSR Standards and Guidelines for snag retention, coarse wood retention and green tree retention in post-fire logging units identified as MA 5-30 in the Forest Plan. • The EA failed to disclose how the 53-162 proposed project will adequately retain snags that will persist until late successional conditions are developed in new stands. • The EA failed to disclose or analyze how the proposed action is consistent the KNF Forest Wide LSR Assessment including approving only actions that will provide "long term positive effect on late-successional habitat and should not diminish suitability [for northern spotted owl] now or in the future...Management following a stand-replacing event should be designed to accelerate or not impede the development of late-successional characteristics." • The EA failed

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments disclose and analyze the fact that according to the Watershed Analysis Seiad Creek has already been heavily impacted by salvage logging and LSR values have been diminished due to post-fire logging. • The EA failed to disclose and analyze a 28% loss of late successional habitat in the Seiad LSR and 64% loss in the Johnny O'Neil LSR associated with industrial logging and post-fire logging. The EA did not quantify late successional forest loss following post-fire logging treatments. • The EA failed to disclose and analyze the impact of proposed actions on the connectivity provided by the Johnny O'Neil and Seiad LSR. The EA failed to disclose how proposed actions are consistent with MA 5-28 in the Forest Plan. MA-28 directs that "the scale of salvage and other treatments should not generally 53-165 result in degeneration of currently suitable owl habitat or other late-successional conditions" in LSR habitat (USDA, 1994 4-86, MA 5-28). Unit 9 should be canceled to protect habitat connectivity on the Siskiyou Crest, in the Seiad LSR and between two large Inventoried Roadless Areas. The unit should also be canceled because the proposed post-fire logging is inconsistent with the Standards & 53-276 Guidelines and the intent of LSR designation. Removing important biological legacies in this unit will impact late successional values, habitat complexity, slope stability and stand development. The EA does not disclose the fact that the nearby Rogue Siskiyou National Forest has chosen a project alternative for the Chetco Bar area (see www.fs.usda.gov/project/?project=53150) that prohibits post-fire logging within Late- Successional Reserves (LSRs) because it is ecologically inappropriate, and they have chosen to only replant if natural conifer regeneration is determined to be inadequate to comply with the National Forest Management Act five-year regeneration requirement to achieve 54-9 stocking densities consistent with management objectives (125-150 trees per acre). BLM (2015 Volume1, p. 50) in its Western Oregon RMPs also has chosen to avoid post-fire logging due to controversy and lack of science support: "Within the Late-Successional Reserve, the BLM would not conduct timber salvage after disturbance, except when necessary to protect public health and safety, or to keep roads and other infrastructure clear of debris." (i.e., meaning roadside hazard). USFWS (2011a, p. 27) also states "LSRs are to be managed to protect and enhance old- growth forest conditions (defined in the Revised Recovery Plan as forests that have accumulated specific characteristics related to tree size, canopy structure, snags, and woody debris and plant associations)." They further state, "According to the NWFP 54-25 Standards and Guidelines (USDA and USDI 1994), no programmed timber harvest is allowed inside the reserves. However, thinning or other silvicultural treatments inside these reserves may occur in younger stands (emphasis added) if the treatments are beneficial to the creation and maintenance of late-successional forest conditions" (USFWS 2011a, p. 27). The EA is therefore inconsistent with LSR management as noted. I am extremely concerned that the Klamath National Forest continues to exploit wildfires as an excuse to clearcut post-fire forests in the Late-Successional Reserve land use 60-1 allocation. It is not appropriate to slick-off old-growth reserves after mixed severity wildfires; the wildlife and watersheds of the Klamath deserve better from the Forest Service.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The Klamath National Forest stands alone in wanting to exploit wildfires in order to 60-3 clearcut backcountry Late Successional Reserves. In the "Guidelines for Salvage," the Klamath National Forest's Land and Resource Management Plan (LRMP) finds: Snags provide a variety of habitat benefits for a variety of wildlife species associated with late-successional forests. Accordingly, following stand- replacing disturbances, management should focus on retaining snags that are likely to persist until late-successional conditions have developed and the new stand is again producing large snags. Late-successional conditions are no associated with stands less than 80 years old. While the project contains a dbh retention requirement for roadside hazard trees, the project does not contain a similar retention requirement for "salvage" units. This violates the Klamath National Forest's LRMP. The EA lacks a discussion of snag fall rates, likely because the best available science indicates that the snags that are most valuable for timber—the largest left standing—are also those that are likely to persist on the landscape the longest. Forest Service research states that larger stems of fire-killed ponderosa pine and Douglas-fir may remain standing for up to 80 years (Harrod et al. 1998). Russell and others (2006) studied temporal dynamics of woody fuel after wildfire affected mixed conifer forest with a significant component of Douglas fir, similar to conditions in the project area. They distinguished longevity of Douglas fir snags from ponderosa pine snags, and reported that stems of the former species remained standing longer due to relative 62-26 heartwood density and rate of decay. More than 80 percent of Douglas fir snags stood 10 years after wildfire compared to approximately 30 percent of ponderosa pine snags (Russell et al. 2006: 183 - Fig. 1). Similar to in Chambers and Mast (2005), large snags (>20- inches diameter) and snags occurring in high densities persisted much longer than smaller snags and others that were not clumped (Russell et al. 2006: 184). Post-fire logging increased the rate of snag fall and shortened the period in which snags provided habitat for cavity-nesting bird species (Russell et al. 2006: 186). Citing this information, we commented that the project is likely to accelerate snag loss and recruitment of large woody fuels compared to a scenario in which no logging occurs. The EA discloses that there are very large snags in many of the units. (See, e.g., EA at 49, Figure 13 (showing trees up to 70" dbh)). Because of the market dynamics of a post-fire timber sale, these are the trees that are most likely to be removed from the project. In this sense, this post-fire timber sale runs counter to the logic contained in the LRMP: Instead of preserving the largest category of snags—those that are most likely to persist on the landscape until the development of late-successional conditions—the project is most likely to remove these trees, while leaving the smallest diameter trees—those least likely to persist—because those are the least merchantable. Without a hard and fast diameter limit, the project is woefully flawed and in violation of the law. The objective of LSR forest "is to protect and enhance conditions of late-successional and "old growth" forest ecosystems, which serve as habitat for late- successional and "old growth" related species including the northern spotted owl. These reserves are designed 572-12 to maintain a functional, interacting, late-successional and "old growth" forest ecosystem (USDA, 1994, 4-83)." It is our contention that post-fire logging within these areas is counterproductive and fails to meet the goals to "protect and enhance conditions of late- successional and old growth forest ecosystems."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #48: Focus on Fuels, Hazards, and Burning, not Salvage Concern statement: Commenters suggest that the project should focus on roadside hazard tree removal, small diameter tree thinning, fuels reduction, and prescribed burning near private property instead of salvage logging. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. This suggested was provided during the scoping comment period and Alternative C was developed in response to those comments. Alternative C proposed limiting the Project to these activities 1) roadside hazard tree removal; 2) underburning; and 3) fuels reduction around private properties. This alternative was eliminated from detailed study because it would not meet the Project's purpose and need for safety of the public and adjacent private landowners to reduce fuels and the risk of future large-scale high severity fire losses of late successional habitat would not be met. For more information please refer to the Alternatives Considered by Eliminated from Detailed Study section of the EA (page 15). Associated Comments: Comment # Comments Cancel all post-fire logging units and focus the Seiad Horse Project on community fire 5-7 protection rather than back country logging. Prescribed fire alone will provide adequate fire protection and would maintain a more natural mosaic of snags, regenerating forests, older stands, chaparral and woodlands. 53-290 Post-fire logging and artificial replanting will only increase fuel loads and complicate the use of prescribed fire. Prescribed fire alone can maintain a healthy fire regime and encourage a natural regenerative process. Please cancel all logging units and focus on community protection, small diameter fuel 57-3 treatments and prescribed burning. Many of the national forests in northern California and southern Oregon have experienced significant wildfire events over the last several fire seasons. Yet planners on the Shasta- 60-2 Trinity National Forest, the Six Rivers National Forest and the Rogue River-Siskiyou National Forest are all focused on roadside hazard treatments and fuels work in the Wildland Urban Interface. NFS post-fire management efforts should focus on hazard removal in residential areas, 70-4 restoring the environmental damage done in fire-fighting and protecting animal habitat connectivity and the watershed. Please cancel all logging units and focus on community protection, small diameter fuel 71-5 treatments and prescribed burning.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Please cancel all logging units and focus on community protection, small diameter fuel 148-7 treatments and prescribed burning.

Comment Response #49: Project Design Features Inadequate to Protect Rare Plants Concern statement: There is a concern that project design features are not adequate for the protection of certain rare plant and fungi species in the area, including Cyprepedium montanum, Phaeocollybia olivacea, and Cyprepedium fasciculatum. Commenters made suggestions that units should be completely canceled if a sensitive plant in located in it. Forest Service Response: Thank you for your comment regarding protections for rare sensitive plant and fungi species in the project area. All known populations of sensitive or “survey and manage” botanical species that occur in areas still supporting viable habitat will be monitored and flagged for avoidance prior to implementation of project work in the vicinity. Buffer zones appropriate for the species of concern will be flagged around each population to ensure microhabitat characteristics are maintained. See Botany PDFs 1, 2, and 6 (EA, Table 7). Areas supporting suitable habitat for botanical species will be surveyed prior to project implementation and any newly discovered populations will be protected as known sites by implementing the appropriate buffer zone for the species as described in the botany PDFs. Cancelling entire units rather than implementing buffer zones that protect the microhabitat of the site may not, in many cases provide the best protection to botanical species of concern in the long term. Achieving project goals that make the area more defensible to future high severity wildfires would benefit the remaining suitable habitat within the project area in the long term. Areas supporting suitable habitat for sensitive fungi species will be protected through project design features that minimize damage to soils, retain organic material and promote the recovery of mycorrhizae and soil microbe networks which sensitive and survey and manage fungi rely on. See the Watershed Project Design Features (EA, Table 7) for details. Additionally, the project includes botanical retention zones that were created to protect highly suitable habitat for survey and manage fungi species. The botanical resource report for this project acknowledges that these measures will not provide complete protection to fungal species and that some short-term direct and indirect effects may occur but will be minimal (Botany Resource report). Associated Comments: Comment # Comments The unit also contains a population of Cyprepedium montanum, the rare orchid is currently 53-266 buffered from treatment, but would be better protected by canceling the unit. According to the Seiad Horse EA Draft Botanical Resources and Non-native Invasive Plant Report, four populations of the Sensitive ectomycorrhizal fungi, Phaeocollybia olivacea, 572-7 are known to occur in sections 26 and 27 of the project area. There is highly suitable habitat for Phaeocollybia olivacea in the southeast portion of the project area, namely in

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Horse Creek. The Seiad Horse EA says that there will not be flagging or avoidance of this Sensitive and important species of fungi. Without flagging and avoidance there is strong potential for logging of trees that contain Phaeocollybia olivacea without adequate protection measures in place. Simply using "project design features" will not actually capture existing populations of Phaeocollybia olivace. Project design features are not enough to safeguard this sensitive species. "Indirect effects may result in a short term decline in habitat condition or population viability where the species is present." (Seiad Horse EA Draft Botanical Resources and Non-native Invasive Plant Report Page, 20) One map in the Seiad Horse Project EA shows one population of Cyprepedium fasciculatum in a logging unit that will not have proper flagging or buffers. This unique and beautiful species has been listed as Sensitive because it is just that — clustered lady's slipper needs 572-9 protection to help stabilize its population for long-term survival and population stability. The SCNPSO requests full flagging of and buffers for clustered lady slipper populations within the Seiad Horse Project area.

Comment Response #51: Bee Camp Road Hazard Tree Removal Concern statement: There is a concern with the roadside hazard tree removal and cost along the Bee Camp Road, which is located within the IRA, backcountry, Cook and Green Botanical area, Baker Cypress habitat, and is near the Pacific Crest Trail. Forest Service Response: The Bee Camp Road is maintenance level 2 road and is open to public use. The proposed Seiad- Horse Project includes hazard tree removal along 2 miles of road 48N20 within the Kangaroo IRA. The Roadless Rule allows the cutting, sale, or removal of timber when it is "is incidental to the implementation of a management activity not otherwise prohibited" by the rule (36CFR 294.13(b)(2)). Region Office reviewed the project and determined 1) It is consistent with the 2001 Roadless Area Conservation Rule, 2) A Washington Office briefing is not necessary, and 3) It will protect roadless area characteristics (Gyant, 2018, project record) PDF's were developed to meet visual requirements for the PCT - PDF Recreation and Scenic Resources 4 - "Avoid vegetation removal work within 20 feet of Pacific Crest National Scenic Trail (#2000) corridor, at the Cook and Green Pass area. If hazard tree removal is necessary, work with the silviculturist, the recreation specialist, and the landscape architect (or representatives) for individual tree identification and PDF Recreation and Scenic Resources 9 - Protect the Pacific Crest National Scenic Trail from damage during the implementation of roadside tree activities. Brewer's Spruce if identified as a hazard will be fell and left on site, PDF Botany 8 - Forest Botanists will flag for avoidance individuals or populations of special interest conifer species; Brewer's spruce, Baker's cypress, and subalpine fir if and where they are found. If a special interest conifer tree is also considered a hazard it will be felled and left on site. Within the Cook and Green SIA PDF Botany 3 - Hazard trees adjacent to flagged populations of Threatened and Endangered, Survey and Manage, and Forest Service Sensitive special interest species will be directionally felled away from the flagged area to avoid disturbing the population. Directionally felled trees may only be removed if it causes no ground disturbance within the flagged area. Yellow and black striped flagging will be used to delineate population boundaries. Alternative 3 considered and

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest analyzed the reduction of miles treated on the Bee Camp Road, treating only the first 1/2 mile. Also see responses to 34 and 108. Associated Comments: Comment # Comments 5-16 Cancel roadside hazard logging on road 47N80 in the Kangaroo Inventoried Roadless Area. This road fragments LSR and IRA values while significantly diminishing recreational and terrestrial forest values. Exacerbating the effects of this highly controversial road by 49-14 further diminishing recreational and forest values through roadside logging is misguided. Yet the EA fails to analyze or disclose the acreage of proposed IRA logging, the number of live and dead trees to be removed, or the impacts of yarding and haul on IRA forest values. Both action alternatives call for logging in the IRA off of the 47N80 Road. The agency refused to develop or consider a reasonable action alternative that avoided this significant impact. Please note that page 12 of the EA indicates that Alternative 3 would reduce the 49-15 roadside logging from 47N80 by "2 miles" while the project maps and Table 3 indicate that Alternative 3 would only reduce the logging by 1.5 miles while still conducted an unquantified and unanalyzed amount of logging associated with 0.5 miles of road 47N80. Both action alternatives call for logging Cook and Green Pass, including the Botanical Area 49-112 and the Inventoried Roadless Areas from the 47N80 road. (EA page 12.) The EA fails to analyze or disclose the number of trees (living and dead) to be removed from the IRA adjacent to 47N80. It appears that the KNF is poised to remove significant numbers of old-growth trees from the IRA and the Cook and Green Botanical Area in order to facilitate its preference for unlimited motorized use along the "unmaintained" Bee Camp Road to nowhere that parallels the Pacific Crest Trail. Please note that The January 12, 2001 Federal Register Notice regarding Rules and Regulations pursuant to the Roadless Rule indicates that: The cutting, sale, or removal of trees must be clearly shown through project level analysis to contribute to the ecological objectives described in§ 294.13(b)(1), 49-133 or under the circumstances described in paragraphs(b)(2) through (b)(4). Such management activities are expected to be rare and to focus on small diameter trees. Thinning of small diameter trees, for example, that became established as the result of missed fire return intervals due to fire suppression and 57 the condition of which greatly increases the likelihood of uncharacteristic wildfire effects would be permissible. Here the KNF is specifically targeting (an unspecified number of) larger trees for commercial removal from the IRA while leaving smaller diameter trees on site. The exact opposite of the direction provided in the Roadless Rule. 52-6 It is imperative that any hazard tree cutting along the road be done very thoughtfully. The Seiad Horse Risk Reduction Project EA proposes roughly two miles of roadside hazard tree removal on road 47N80 (also known as Bee Camp Road). The road is a cherry stem road leading into the Kangaroo Inventoried Roadless Area (IRA) and Kangaroo Designated Backcountry Area. Road 47N80 is also inaccessible to most vehicles, due to the rocky nature of the roadbed. The maintenance of the road as open, to motor vehicles is 53-109 inconsistent with the KNF LRMP and impacts far more forest visitors, than it benefits. The road and the vehicle access it provides disturbs the wilderness-like setting of the Kangaroo IRA and Backcountry Area. Road 47N80 runs parallel to the Pacific Crest Trail badly damaging the backcountry setting and recreational experience the Kangaroo Backcountry Area and IRA were meant to protect. The current motorized access impacts vegetation,

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments wildlife, damages potential backcountry camps around Bee Camp, creates significant noise disturbance and degrades the backcountry experience envisioned in the Final Roadless Conservation Rule and the KNF LRMP. Roadside hazard tree logging should be canceled and the road closed at Cook and Green 53-110 Pass. Road 47N80 also extends through a large area of Baker's cypress habitat, a significant population exists along the road in section 8, above Seiad Creek. Stand replacing fire effects are associated with Baker's cypress regeneration and create conditions conducive to population growth and vigor. The population on West Fork Seiad Creek, include road 53-112 47N80 is the most fire-adapted and healthy population in the Siskiyou Mountains. Given the results of the Abney Fire through this area, a natural fire recovery will encourage health, vigor and population growth in this important population. Roadside hazard logging has the potential to impact many young trees and fire triggered regeneration. The proposed roadside hazard logging violates the Roadless Conservation Rule by proposing the removal of large trees. The Kangaroo IRA was protected under the Final Roadless Conservation Rule and its unique roadless characteristics must be adequately protected. The Seiad Horse Risk Reduction Project fails to do so. The Roadless Conservation Rule allows the removal of hazard trees for human safety, but limits tree removal to small trees (USDA Forest Service 36 CFR Part 294 Special Areas: Roadless Conservation Final Rule). The removal of trees and vegetation along 47N80 and inside the Kangaroo IRA, should meet the standards of 36 CFR Part 294 and limit tree removal to small trees. This would include removing For instance, Part 294.11 requires that "cutting, 53-114 sale, or removal of small diameter timber will be consistent with maintaining or improving one or more of the roadless area characteristics." All references to tree removal in the Final Roadless Conservation Rule and the FEIS are limited to "small diameter trees." The Seiad Horse Risk Reduction EA failed to disclose the number of large diameter trees proposed for removal along two miles of 47N80 and within the Kangaroo IRA. The removal of large diameter trees will impact roadless values, recreational values, botanical and scenic values in the Kangaroo IRA and along the PCT. The EA failed to adequately analyze impacts associated with hazard tree removal on road 47N80 and its impact on its consistency with the Roadless Conservation Rule and KNF LRMP. The EA failed to disclose the requirements of Designated Backcountry Areas in the KNF LRMP to close roads entering this management area, including road 47N80 in the 53-121 Kangaroo Designated Backcountry Area. • The EA failed to analyze the proposed roadside hazard logging for consistency with the Designated Backcountry Area and Roadless Conservation Rule. Conducting post-fire logging of large legacy trees along Forest Service Road 47N80 54-3 bisecting the Kangaroo Roadless Area; Additionally, the Roadless Conservation Rule (DEIS:3-106) provides costing on mechanical treatments: 5 "The current national average cost to mechanically treat and burn areas with heavy fuels is $176 to $276 per acre (Laverty and Williams 2000). To give an example 54-14 of how these costs might increase: if pre-treatment were limited to thinning with chainsaws or the construction of fuel breaks, then the average fuel treatment costs could rise as much as 50% (USDA 1999a)."

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #52: Opposed to Salvage Concern statement: There is general opposition to proposed salvage harvest activities due to their effects to resources. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. An analysis of the effects of project activities, including salvage harvest, is presented in the EA. Associated Comments: Comment # Comments 5-15 Cancel all post-fire logging units in the East Fork of Seiad Creek. Please do not use wildfire as an excuse for yet another controversial "salvage" timber grab 9-2 in remote wildlands. Instead, the KNF should focus post-fire management efforts on restoring communities, 9-3 and protecting our watersheds. We urge the Forest Service to familiarize itself with the growing body of literature 49-138 indicating that the post-fire ecosystems have more to offer than simply an opportunity for salvage logging and plantation forestry. Finally, species dependent on habitat conditions created by high severity fire, with 49-146 abundant standing dead trees, require substantial areas to be protected from post-fire logging (Hutto 1995)." Many of the habitats proposed for post-fire logging are highly functional and resilient 53-4 landscapes. We are also concerned that the Cook and Green Pass/ Condrey Mountain region currently 53-56 known for its intact plant communities, natural landscape mosaic, high value recreation, and incredible biodiversity will be impacted by post-fire logging. Post-fire logging will also introduce stressors to currently intact habitats such as noxious weeds, soil compaction, sedimentation, new road construction and other impacts 53-61 associated with heavy industrial logging. These impacts will reduce connectivity for a variety of species and reduce habitat quality for others. The loss of currently intact forest legacies will be permanent and irreplaceable. Obviously, post-fire logging, through the removal of the snag patches and especially the removal of large diameter snags is detrimental to forest diversity, succession, and recovery 53-167 and should be avoided, especially in LSR forest, complex old stands and landscapes adapted to mixed or high severity fire. Post-fire logging and replanting provides no benefit to the many important resource values 53-283 present in the planning area. In fact, the proposed action will significantly damage many of the important ecological and social values in the area.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments So-cslled "sslvage" logging leaves a degraded, scarred landscape with high probability of increased sedimentation of streams, increased stream water temperatures, loss of habitat 203-3 for many wildlife species, and the high probability of a diverse landscape being replaced with a monoculture ecosytem. All of these negatives, plus the fact that the roadless areas involved would lose the possibility of being upageraded to wilderness areas. 453-5 Please don't log this area

Comment Response #54: Salvage along the Siskiyou Crest Concern statement: There is general opposition to the risk reduction salvage harvest proposed along the Siskiyou Crest, including within 2 miles of the crest, because it is a special place containing habitat, old growth trees, and sensitive scenic areas. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. Similar comments were provided during the scoping comment period for the Project and as a result the interdisciplinary team developed Alternatives 3, A, and B. Please refer to the Issues and Proposed Action and Alternatives sections of the EA for more information on these alternatives. Several commenters also expressed concerns about the appropriateness of salvage harvest along the Siskiyou Crest or within 2 miles of the Siskiyou Crest. All proposed treatments are within management areas that allow for salvage harvest according to standards and guidelines provided by the Forest Plan, such as for the purpose of risk reduction in the Late Successional Reserves (MA5-30). Effects of project activities to habitat connectivity was considered in the EA using the change in fisher, marten and wolverine habitat as an analysis indicator. Land allocations and standards and guidelines in the Klamath Forest Plan and similar designations on the Rogue River National Forest are intended to maintain habitat connectivity. Note that no salvage harvest is planned in any alternative in Riparian Reserves, the land allocation that provides connectivity between larger reserves. Associated Comments: Comment # Comments Please do not do any post fire large scale logging along the Siskiyou Crest. There is major 5-2 habitat to protect there and some of the trees are old growth and older trees that have survived the fire. Protect the connectivity, biodiversity and other biological values of the Siskiyou Crest by 5-10 canceling all units within two miles of the ridgeline. All post-fire logging and replanting proposed in the Seiad Horse Risk Reduction Project 53-9 should be canceled, especially in Late Successional Reserve (LSR) forest and within two miles of the Siskiyou Crest.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments Our organizations strongly oppose any form of post-fire logging or reforestation on the 53-58 Siskiyou Crest. We support the cancelation of all post-fire logging units within two miles of the Siskiyou 53-59 Crest. Finally, a precedent was set and admission made in 2017 when the KNF canceled 18 post- fire logging units in the Horse Creek Community Protection and Restoration Project. These 53-65 units were canceled due to their proximity to the Siskiyou Crest and the potential impacts these units would have on connectivity. The KNF should again acknowledge these important biological values and cancel all units within two miles of the Siskiyou Crest. All units in sections 10 and 15 should be canceled to protect the connectivity of the 53-261 Siskiyou Crest, maintain recreational values, encourage complex, early seral habitat, and promote biodiversity. I oppose all logging within two miles of the Siskiyou ridge, all logging within one mile identified sensitive and scenic areas such as the PCT, Cooke and Green Botanical Area, Red 70-3 Buttes Wilderness and Jonny O'Neil LSR, Kangaroo Inventoried Roadless Area and all clearcut logging within the national forest. I urge the Klamath National Forest to drastically scale back the Seiad Horse Project to keep the project within two miles of the Siskiyou Crest habitat connectivity corridor. Only a major scale back will satisfy the needs of the environment and fire protection for local 573-9 communities, including my own home nearby the Project area. If you don't scale the project back then it should just be cancelled all together. The Siskiyou Crest is a special place and deserves better than the Seiad Horse Project and its clearcut, post--fire logging.

Comment Response #55: Snag and Coarse Woody Debris Retention Concern statement: There is a concern that snag and coarse woody debris retention was not properly disclosed in the EA and is not sufficient to meet Klamath Forest Plan and Northwest Forest Plan standards and guidelines. Forest Service Response: Since the Northwest Forest Plan was adopted first, applicable direction from it was incorporated into the Klamath Forest Plan, which provides direction for management activities on the Forest. In stream course riparian reserves, all hazard trees would be felled according to the hazard tree evaluations described above; the difference is in what happens to a hazard tree once it has been felled. Within stream course riparian reserves, roadside hazard trees equal to or greater than 24 inches diameter at breast height would be felled and left on site according to the following criteria: 1) The faller can safely fell the hazard tree away from the road and the fallen tree would not present a direct hazard to the road; and 2) Once fallen, the tree would not disrupt flow through a drainage structure. Hazard trees in stream course riparian reserves where these criteria are not met, or that are less than 24 inches in diameter at breast height, would be felled and removed. This is consistent with the Forest Plan standards and guideline for Riparian Reserves (RRs) which states "Fell trees in RR when they pose a safety risk. Keep felled trees on-site when needed to meet CWD requirements" (MA 10-58) Coarse woody debris standards will be met by

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

retaining any coarse woody debris now on-site, all cull trees, snags in snag retention areas and riparian reserves, and green trees that are in units. See the snag and coarse wood analysis in the appendix to the Management Indicator Species Report for a complete discussion. Although the project will reduce the number of snags as a result of implementing the project, the Seiad-Horse Project will still retain enough snags to exceed the snag levels and coarse woody debris described in the Forest Plan (MIS Appendix). This comment asserts that the Northwest Forest Plan Standards and Guidelines at C-42 requires the Forest Service to retain a specific number of snags in each salvage harvest unit. This represents an overly narrow and incorrect reading of the Klamath Forest Plan. The comment quotes a single provision from the Northwest Forest Plan, but fails to consider all the applicable supplemental management direction in the Forest Plan for the Klamath National Forest and the multiple objectives of the project. The Forest Plan was signed after the Northwest Forest Plan and incorporated the applicable elements of the Northwest Forest Plan but the Klamath Forest Plan provides direction specific to the Klamath Province and the Klamath National Forest, including snag metrics. It is the Forest Plan that provides management direction for the Klamath National Forest, not the Northwest Forest Plan. The cited language on page C-42 of the Northwest Forest Plan does not appear in the Klamath Forest Plan. Standard and Guidelines 8-22 and 8-25 on page 4-30 of the Klamath Forest Plan provide snag metrics to be used in project planning on the Klamath National Forest. The Forest Plan direction does not require that these snag metrics be met on every acre or in every cutting unit; the Forest Plan requires that within any 100-acre landscape, the appropriate number of snags be retained. This allows Project design to mimic the natural snag distribution described by Skinner (2002) and Taylor and Skinner (1996) with concentration of snags in time and space, and intervening areas where snags would be relatively sparse or would not occur. To accomplish this, we retain all the snags in riparian reserves (except in roadside hazard areas), all of the non-merchantable cull trees and any very large trees with high value to wildlife. In addition, we designate snag retention areas within units where we need additional snags to complement habitat connectivity. Leaving snags in clumps as described in Klamath Forest Plan guideline 8-24 (page 4-30), is more effective than single isolated trees because snags in clumps are more resistant to blowdown. We also reduce the probability that these areas where snags are retained within units will be consumed by inevitable future fires by removing the adjacent heavy fuels with salvage sales and burning the activity fuels when salvage is completed. Also see the analysis in Appendix C of the EA for the aquatic conservation strategy objective review which describe consistency with the Forest Plan. Associated Comments: Comment # Comments Please note that MA5-30 of the KNF Resource Management Plan indicates that in LSRs "following stand-replacing disturbance, management should focus on retaining snags that are likely to persist until late-successional conditions have developed and the new stand is 49-20 again producing large snags." Based on repeated past experience, we believe that KNF timber planners will ignore this Forest Plan standard and guideline and will instead target snags that are likely to persist in the LSR until late-successional conditions develop for

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments extensive unit salvage logging. Indeed, the agency is only targeting snags >14" in diameter for commercial removal. The EA failed to analyze and disclose the ability of the timber sale units to provide the required habitat for snag-dependent species. Timber planners made no attempt to disclose snag retention requirements on an acre-by-acre basis rather than "masked" by relying on snags outside of harvest units to alter the post-harvest per-acre snag numbers or by double-counting riparian reserves as leave trees for LSR unit salvage logging. The NFP at C-42 clearly states: "As a minimum, snags are to be retained within the harvest unit at 49-81 levels sufficient to support species of cavity -nesting birds at 40 percent of potential population levels based on published guidelines and models." C-42 above applies to "harvest unit" scale and the KNF cannot avoid implementation of this substantive snag retention requirement by drawing units larger on maps (and not logging adjacent Riparian Reserves) and averaging snag retention outside of actual logging areas in order to avoid providing habitat for snag associated MIS species. The KNF Forest Wide LSR Assessment and the LSR Standards and Guidelines prioritizes snag retention stating, "Following stand replacing disturbance, management 48 should focus on retaining snags that are likely to persist until late successional conditions have developed and the new stand is again producing large snags ( USDA, 1999, p 4-22 & USDA, 1994 4-87). " The proposed action will not satisfy this requirement because the only snags 53-153 capable of bridging the divide and persisting on the landscape until a new stand emerges are the big, old snags most likely to be targeted in post-fire logging operations. The current Seiad Horse Risk Reduction Project proposal does not address this issue by putting all snags that are determined to persist for 150 years or more and pose no safety risk to logging or yarding crews, on reserve from harvest. The number of trees actually retained will be far too low to meet snag requirements. The Standards and Guidelines also include the recommendation to retain Coarse Woody Debris stating "Following a stand-replacing disturbance, management should retain adequate CWD quantities in the new stand so that in the future it will still contain amounts 53-154 similar to naturally regenerated stands. The analysis that determines the amount of CWD to leave must account for the full period of time before the new stand begins to contribute CWD." (USDA, 1994 4-87). The KNF must demonstrate they are following these Standards and Guidelines for LSR management in the Seiad Horse Risk Reduction Project. The EA failed to disclose the level of retention proposed for existing late successional 53-164 habitat features within the LSR. This should include quantitative figures for snags, coarse wood and living trees retained in each unit following logging operations. Notably, according to Franklin (2000), biological legacies include organisms, organic materials, and organically generated environmental patterns that persist through a disturbance and are incorporated into the recovering ecosystem. These are perennating parts (some roots, rhizomes, and hyphae), propagules (seeds, spores, eggs), organically derived structures (snags, logs and other coarse wood), large soil aggregates, 54-22 physical/chemical/microbial soil properties, root pits and mound, and understory communities. Large dead and dying trees are legacies (Lindenmayer et al. 2008). The EA fails to disclose or define legacy trees for owls and late-seral development and at what densities they will be required to maintain owl cores, LSR development, critical owl habitat, and NRF habitat generally.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments It is clear that large standing snags and coarse woody debris are characteristic of old- growth forest habitats. It is also clear that by logging off these biological legacies forest complexity will be impacted for hundreds of years. The KNF Forest Plan directs the Forest 572-14 Service to maintain large diameter snags in LSR forest subjected to high-severity fire. The goal is to maintain important habitat structures that can persist until a new stand of late successional forest is reproduced. The removal of large diameter, commercially valuable standing snags will remove the very habitat structures the agency is directed to maintain.

Comment Response #56: Risk of Non-native Invasive Species Spread Concern statement: There is a concern that there is an elevated risk of introduction and rapid spread of certain non- native invasive plant species as a result of project activities and that this risk needs to be mitigated. There is particular concern regarding the risk of spread of dyer's woad from the Klamath National Forest into Southern Oregon. Forest Service Response: Thank you for your comment regarding the risk of introduction and spread of non-native invasive species in the project area. The high risk of introduction and spread of non-native invasive species due to the Abney fire, suppression activities, and the proposed project have been acknowledged in the botany and invasive species resource report. Project design features to mitigate that risk have been included in Table 7 (page 17, Project Design Features) of the EA. Post-project non-native invasive species survey and treatments will prioritize areas near the Siskiyou Crest and around the Cook and Green and Baker's Cypress SIAs. Where possible, invasive plant populations will be treated prior to project implementation, then monitored and treated over subsequent years after Project implementation in order to prevent or minimize any invasive plant spread as a result of the project. In addition, Burned Area Emergency Response surveys and early detection rapid response treatments are being conducted and will help document introduction and spread into the project area from Abney fire suppression activities. The California Department of Food and Agriculture (CDFA), and the Siskiyou County Department of Agriculture manage non-native invasive species (NNIS) by use of the same list and risk rating criteria. The Klamath National Forest Noxious Weed and Non-native Invasive Plant List includes 45 species from the State and County lists that are known or expected to occur on the Klamath National Forest. Based on inventories and current understanding of species ranges, a total of 30 high priority NNIS are on the list. In addition, there are 15 species of moderate and low priorities also included on the list. Low and moderate priority species are only managed discretionally based on infestation location and feasibility of control. Due to its wide ecological distribution across the western United States, cheatgrass (Bromus tectorum) is a low priority species on the Klamath National Forest and is not even listed by CDFA. Given its low ranking and wide distribution this species is often not addressed in planning documents. Fuel breaks can act as corridors for invasion by invasive species due to reductions in canopy cover and competing vegetation. Fuel breaks construction methods that leave some overstory canopy and minimize exposure of bare ground may be less likely promote invasion by non-

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest natives species when compared with other methods. This project proposes construction of a 600foot shaded fuel break. Live trees over 12 inches in diameter at breast height (DBH) will be retained and the lower 7 feet pruned to reduce the risk of crown fire initiation. In order to retain overstory canopy elements, construction will use both manual and mechanical thinning techniques to remove dead vegetation, understory vegetation and trees less than 12 inches DBH. As mentioned in the cited article (Merriam et al. 2006), this method of fuel break construction was found to be associated with a decrease in non-native abundance when compared to all other construction methods. Associated Comments: Comment # Comments The EA fails to adequately disclose and analyze the potential for proposed USFS activities 49-79 to increase and hasten the spread of noxious weeds in the planning area. For instance, the Butte Falls Resource Area of the Medford BLM plainly acknowledged that noxious weeds are a serious issue for post-fire logging when it wrote the Timbered Rock Salvage Logging DEIS (Butte Falls RA). That DEIS recognized that "[P]rojects in these [action] alternatives could spread noxious weeds at a higher rate than the No Action 49-80 Alternative, due to a higher level of ground-disturbing activities." (DEIS 3-150). The Timbered Rock DEIS further acknowledged that the higher the burn severity the more vulnerable to noxious weed invasion and that subsequent loss of native vegetation "may be irretrievable." (DEIS 3-151) Such an analysis has not been completed for the Seiad- Horse salvage logging proposal. Thousands of acres have been converted from forested habitats to cheat grass dominated grasslands through a combination of heavy industrial logging, wildfire and post-fire logging. A similar result is occurring on private timberlands in the Middle, Buckhorn and Horse Creek watersheds in the Gap Fire footprint. These areas have been burned, clearcut, disturbed by yarding and hauling operations and subjected to sudden type conversions from native species to non-native or invasive species, namely cheat grass. Federal land management activities proposed in the Seiad Horse Risk Reduction Project will create very similar results due to the size and contiguous nature of units proposed for treatment. The 53-252 expansion of cheat grass by thousands of acres in a few short years is a significant impact with lasting cumulative effects. This type conversion is a fact, in the Dogget, Beaver and Kohl Creek watersheds. This expansion was either created or facilitated by post-fire logging practices very similar to those proposed in the Seiad Horse Project. Federal lands could easily sustain significant infestations of cheat grass and other nonnative species due to post-fire logging....A similar impact is likely on federal lands subjected to post-fire logging in the Abney Fire, only the implications to Botanical Areas, Inventoried Roadless Areas, Designated Backcountry and generally intact plant communities are far greater on the Siskiyou Crest than on private timber land Continued post-fire logging in the Abney Fire will continue facilitating weed spread with 53-253 units located adjacent to the Siskiyou Crest and in close proximity to the Cook and Green Pass Botanical Area. The EA failed to disclose and analyze the current expansion of cheat grass and other non- native or noxious weeds on private land subjected to post-fire logging in the Gap Fire and 53-256 Beaver Fire Area. • The EA failed to disclose and analyze the extent of Dyer's woad invasion in the Westside Fire Recovery Area. A map depicting the location of infestations in

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments relation to post-fire logging units should be prepared in the EIS. • The EA failed to adequately disclose the impact of post-fire logging, tree yarding, log hauling, road maintenance, and log hauling in the Seiad Horse Risk Reduction Project on noxious weed spread. • The EA failed to adequately disclose the impact of noxious weed spread associated with proposed management activities on the botanical values of the Siskiyou Crest, the Cook and Green Pass Botanical Area, and sensitive plant species in the project area. We are also very concerned that noxious weed populations established during post fire logging operations may be spread through prescribed fire treatments. Currently Dyer's Woad has infested much of the Westside Fire Recovery Project and prescribed fire would 53-279 only disturb more soils and spread the infestation further throughout the affected watersheds. Noxious weed populations must be fully treated before wide spread prescribed fire is applied in the Seiad Horse Risk Reduction Project. Additionally, these two papers provide best science examples on fuel breaks, including strategic location and limitations, and invasive species concerns: FACTORS AFFECTING FUEL BREAK EFFECTIVENESS IN THE CONTROL OF LARGE FIRES ON THE LOS PADRES NATIONAL FOREST, CALIFORNIA Syphard, A.D, J.E. Keeley, and T.J Brennan (International Journal of Wildland Fire 2011, 20, 764-775) Abstract: As wildfires have increased in frequency and extent, so have the number of homes developed in the wildland- urban interface. In California, the predominant approach to mitigating fire risk is construction of fuel breaks, but there has been little empirical study of their role in controlling large fires. We constructed a spatial database of fuel breaks on the Los Padres National Forest in southern California to better understand characteristics of fuel breaks that affect the behavior of large fires and to map where 15 fires and fuel breaks most commonly intersect. We evaluated whether fires stopped or crossed over fuel breaks over a 28-year period and compared the outcomes with physical characteristics of the sites, weather and firefighting activities during the fire event. Many fuel breaks never intersected fires, but others intersected several, primarily in historically fire-prone areas. Fires stopped at fuel breaks 46% of the time, almost invariably owing to fire suppression activities. Firefighter 54-50 access to treatments, smaller fires and longer fuel breaks were significant direct influences, and younger vegetation and fuel break maintenance indirectly improved the outcome by facilitating firefighter access. This study illustrates the importance of strategic location of fuel breaks because they have been most effective where they provided access for firefighting activities. FUEL BREAKS AFFECT NONNATIVE SPECIES ABUNDANCE IN CALIFORNIAN PLANT COMMUNITIES Merriam K.E., J.E. Keeley, and J.L. Beyers (Ecological Applications, 16(2), 2006, pp. 515-527) Abstract. We evaluated the abundance of nonnative plants on fuel breaks and in adjacent untreated areas to determine if fuel treatments promote the invasion of nonnative plant species. Understanding the relationship between fuel treatments and nonnative plants is becoming increasingly important as federal and state agencies are currently implementing large fuel treatment programs throughout the United States to reduce the threat of wildland fire. Our study included 24 fuel breaks located across the State of California. We found that nonnative plant abundance was over 200% higher on fuel breaks than in adjacent wildland areas. Relative nonnative cover was greater on fuel breaks constructed by bulldozers (28%) than on fuel breaks constructed by other methods (7%). Canopy cover, litter cover, and duff depth also were significantly lower on fuel breaks constructed by bulldozers, and these

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments fuelbreaks had significantly more exposed bare ground than other types of fuel breaks. There was a significant decline in relative nonnative cover with increasing distance from the fuel break, particularly in areas that had experienced more numerous fires during the past 50 years, and in areas that had been grazed. These data suggest that fuel breaks could provide establishment sites for nonnative plants, and that nonnatives may invade surrounding areas, especially after disturbances such as fire or grazing. Fuel break construction and maintenance methods that leave some overstory canopy and minimize exposure of bare ground may be less likely to promote nonnative plants. Notably, while the EA purports to monitor invasive species, given the expansive use of fuel beaks, mitigation appears grossly inadequate. We request that you include a literature review on problems and limitations of fuel breaks, and more substantial invasive species containment measures. This is of particular concern as fuel breaks will require periodic 54-51 maintenance (adding to undisclosed project costs), could become de facto roads for ORVs and cattle that act as vectors of invasive species spread along with uncharacteristic fire ignitions. In particular, if fuel breaks are colonized by grasses (especially cheatgrass), they will contribute to fire spread and dangerous conditions for firefighters. Thousands of acres of private timberlands have been subjected to post-fire logging in the 2014 Beaver Fire and 2016 Gap Fire footprints. Thousands of acres of forest, in the Beaver Creek, Kohl Creek and Dogget Creek watersheds have been converted from forest habitats to vast contiguous areas of cheat grass, mullein, bull thistle, star thistle and other non- native or invasive species. Thousands of acres have been converted from forested habitats to cheat grass-dominated grasslands. A similar result is occurring on private timberlands in the Middle, Buckhorn, and Horse Creek watersheds in the Gap Fire footprint. These areas were burned in the fire and then disturbed with clear-cut yarding and hauling operations, and subjected to a sudden type conversion from native species to non-native or invasive species, namely cheat grass. Federal land management activities proposed in the Seiad Horse Risk Reduction Project will create very similar results due to the size and contiguous nature of units proposed for treatment and/or logging. The expansion of cheat grass by thousands of acres in a few short years is a significant impact with lasting cumulative effects. This expansion was either created or facilitated by post-fire logging practices very 572-16 similar to those proposed in the Seiad Horse Project EA. Federal lands could easily sustain significant infestations of cheat grass and other non- native species due to post-fire logging. A similar impact from non-native species spread is likely on federal lands subjected to post-fire logging in the Abney Fire. In fact, a 2016 Monitoring Report published by the Klamath National Forest indicates that Dyer's woad (Isatis tinctoria) has spread throughout the Westside Fire Recovery Project Area (USDA, 2017d). It will also likely spread into the post-fire logging projects sold in the Gap Fire footprint in Horse Creek. Continued post-fire logging in the Abney Fire footprint, as proposed in the Seiad Horse Project EA, will continue facilitating weed spread with units located adjacent to the Siskiyou Crest and in close proximity to the Cook and Green Pass designated Botanical Area. Just as Dyer's woad is making its way from the Klamath River over Siskiyou Summit on I-5, if spread throughout the Abney Fire area due to post-fire logging, it could easily spread into the Applegate Valley via Cook and Green Pass. Siskiyou Summit is located at about the same elevation as Cook and Green Pass. The Seiad Horse EA Draft Botanical Resources and Non-native Invasive Plant Report 572-19 discloses that there is one known population of dyer's woad within the Seaid Horse Project

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments area (p. 40). The potential for dyer's woad infestation due to the Seiad Horse Project has not been adequately addressed in the EA. One population of dyer's woad can explode into a massive infestation due to ground disturbance associated with logging and road construction. Given that there are known populations of invasive or non-native plant populations within the Seiad Horse Project, but the infestations are not that extensive at this point, it is highly irresponsible to introduce massive ground disturbance from post-fire logging that has the likelihood of spreading non-native or invasive species into the nearby Botanical Areas and the Siskiyou Crest, possibly even into the Applegate Valley just over Cook and Green Pass. The vector of Cook and Green Pass road has a high potential to spread invasive plant species from the Seiad Horse Project area, and this was not addressed at all in the project's EA. The species that are known to occur in the project area and that have a high potential to spread into nearby botanical areas and over Cook and Green Pass include the following: * Scotch broom * Diffuse knapweed * Spotted knapweed * Star thistle * Dyer's woad

Comment Response #57: Clearcutting Concern statement: There is a concern that clearcut logging practices will be used in the project and stated opposition to this practice. Forest Service Response: As a point of clarification, Clearcutting is a silvicultural system used in green, as opposed to fire- killed, stands of trees. Salvage harvesting dead and dying trees is not "clearcutting”. We are proposing salvage harvest of dead and dying trees, with follow-up site preparation and reforestation. In the Seiad-Horse Project, we are assessing individual trees, on a case-by-case basis, for their ability to survive the effects of the Abney Fire, and salvage harvesting those trees that are dead or determined to have a 70 percent or greater probability of mortality in the next 5 years. Associated Comments: Comment # Comments I understand this is to be a clearcut/plantation planting project. Clearcutting and 8-1 plantation planting have been proven to increase fire danger. I am opposed to this project. I am writing about the Seiad-Horse post-fire timber sale that the Klamath Forest is proposing on the Siskiyou Creek near the Cooke and Green Botanical Area, and the Red 9-1 Buttes Wilderness. I oppose backcountry post-fire clearcutting in this special part of the Siskiyou Crest. The KNF's clearcutting agenda increases fire hazard through tree-farm establishment. 9-4 Please do not clearcut recovering "late successional" forests on steep slopes in the backcountry. The forest will come back strong from coastal management. Clear cut lead directly to 22-1 erosion. 38-1 The forest and its wildlife will recover better if there is not any clearcutting. 39-1 Stop the clear cut! No industrial farming.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments The ideological attachment of the KNF's Supervisor's Office to post-fire clearcutting of LSRs necessitates documentation in an EIS. Consideration and implementation of reasonable 49-24 alternatives that retain, rather than clearcut, snag habitat likely to persist until the next late-successional forest establishes itself are being implemented by the surrounding National Forests. Clearcut logging is clearly inappropriate in LSR forest, yet the KNF has proposed to 53-156 implement clearcut, post-fire logging in both the Johnny O'Neil and Seiad LSR. We have conducted extensive on-the-ground monitoring of timber sale units and have 66-1 documented numerous intact habitats proposed for clearcut logging. Therefore I am very opposed to this clear cutting of a beautiful area. After extensive on-the-ground monitoring of these timber sale units, there are numerous documented intact habitats proposed for clearcut logging. Clearcut logging is not the answer. Science DOES NOT support this practice. Fire is a natural and healthy part of forest 67-1 health. These proposed logging sites are vital headwaters to the rivers and streams they support. Please DO NOT go forward with this proposed harvest. It is not in the best interest of healthy forests. I strongly oppose the clearcut logging proposed by this project. It does not represent the best ecological practices for a very diverse and sensitive ecosystem along the Siskiyou 68-1 Crest. This area should be allowed to regenerate from the fires naturally and for the long term health of the forest rather than exploited for a short term monetary gain that does not benefit any of the local constituents that use this area. On-the-ground surveys of the proposed timber sale units have documented numerous 70-1 intact habitats proposed for clearcut logging. I strongly protest this unnecessary action and object to your classification of these actions as salvage logging. Please do not approve this "salvage" logging project. Normal clear-cutting projects are simply bad logging practices, "salvage" logging clear-cuts are even worse. And why is a full 203-2 environmental impact statement not being required? Does the Forest Service not feel that "salvage" logging has an environmental impact? That's just irrational

Comment Response #60: General Project Support Concern statement: There was general support from commenters for project activities as they would provide needed maintenance in the forest and access along forest roads, as well as rehabilitate forest stands. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments I thank Lisa Bousfield and her team for their hard work, professionalism and efficiency in 3-1 bringing this project together. I am confident that the plan is the best for this area of the forest. I am 100% for this proposed project. It NEEDS to be done! Our forests need to be 4-1 maintained! With regard to the Seiad Horse Risk Reduction Project, I am in full favor of removal of dead 7-2 and dying trees. After reviewing the project I agree with your purpose and need to treat the referenced 46-1 area. Roadside hazard, salvage logging and replanting are all essential to make sure that the forest roads remain open and the forest stands are rehabbed as quickly as possible. 46-6 We support your efforts in keeping the roads open and rehabilitating the forest.

Comment Response #62: Effects to Late Successional Reserve Characteristics Concern statement: There is a disagreement that salvage harvest with site preparation and planting would contribute towards the accelerated recovery of late-successional characteristics in treated stands. Commenters state that salvage harvest would inhibit the development of late-successional characteristics and is inappropriate in late successional reserve. Forest Service Response: Salvage harvest in combination with site preparation (e.g. fuels reduction) and planting of trees as proposed in the Seiad Horse Project Environmental Assessment is designed to accelerate the development of forested habitat. Retention of fire killed trees would result in fuel loads that are in excess of that which is characteristic of the Klamath Province and would create a substantial risk of future high severity fire which would frustrate the purposes for which the Late Successional Reserves were established. This would conflict with the forest wide goals (which includes LSRs) of the Forest Plan for fire management (4-8). Generally, the largest trees occur within hydrologic Riparian Reserves, which are retained. By varying retention according to slope position and aspect, we expect to more closely approximate the landscape patterns of snags and down wood described by Taylor and Skinner (1998), Skinner (2002) and Taylor and Skinner (2003) where snags and down wood are concentrated in time and space, with intervening large areas and periods of time where snags and down wood are sparse. Salvage harvest with the subsequent fuels reduction (e.g. site preparation) adjacent to snag retention areas and Riparian Reserves will reduce surface fuels and fuel continuity, therefore reducing the risk of future large scale, high severity fire affecting late successional forests (including large snags and down wood). We agree that a long regeneration period can benefit certain species including spotted owls and that uniform tree planting over large areas is counterproductive to recovery objectives of the LSR

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

in the high fire frequency environment of the Klamath National Forest. We do not agree, however, that tree planting as proposed in the Seiad-Horse Project is counterproductive to recovery objectives. Reforestation is expected to provide a measure of vegetative diversity that would not otherwise be present on the landscape. These planted stands have a much higher probability of achieving the desired late successional stand condition for the LSR than unplanted areas. As described in the Franklin et al. (2000) report, that in northwestern California, the highest habitat fitness for NSO is found in landscapes that are a mixture of mature and old forest with open vegetation types, such as brush fields and young forest, and not in landscapes dominated by old forests. The fact that an early successional species - the dusky-footed woodrat - is the primary prey for NSO in this region may be part of the reason that owls prefer a mixed landscape. In any case, the fact that habitat fitness for the owl is favored by a heterogeneous landscape mosaic should be factored into decisions regarding establishment of conifer plantations, both within and outside of LSRs. Approximately 1,269 acres, or 23 percent, of the area affected by moderate and high fire severity within the O’Neil LSR is proposed for salvage. All forested high and moderate severity burn patches less than 10 acres in size and all areas where less than 40 percent of the live canopy cover has been reduced by the fire would not be salvage harvested. Approximately 955 acres of existing plantations or proposed salvage units have the potential to be site-prepped and planted; this represents about 17 percent of the estimated 5,553 acres of the O’Neil LSR impacted by moderate to high severity fire. Thus, approximately 4,598, or 83 percent, of the remaining area affected by moderate and high severity fire in this LSR would not be planted and would go unimpeded through the long early seral plant succession cycle described by the commenter. This maintains the complex fire mosaic pattern created by the Abney fire and heterogeneity that benefits NSOs described by Franklin (2000). Areas that would not be planted also include large patches of several hundred acres, in addition to smaller patches, of fire-killed older trees in the Inventoried Roadless Areas. Thus all patch sizes from very small to very large are represented in areas where no salvage harvest or site preparation and planting would occur. Site preparation and planting is intended to increase the likelihood and speed by which burned forested areas are restored to coniferous forest and late successional habitat. The Forest Plan and LSR Assessment both identify coniferous forests with large trees as the desired condition for the LSR (Forest Plan 4-83; LSR Assessment Chapter 3). Forest Vegetation Simulation modeling done for the nearby, recent Westside Fire Recovery Project showed that reforestation established forested conditions more rapidly by treating surface fuels and planting trees than by natural succession (Westside FEIS Chapter 3, Vegetation, Appendix E, Figure FVS-1). If surface fuels are treated and the continuity of fuels are reduced, the size and severity of future fires may also be reduced (Thompson et al. 2007). In the future, as snags fall and become surface fuels in areas that are not site prepped and planted, it is probable that many of these areas will re-burn multiple times because of high surface fuel loads and fuel continuity. As a result, large areas that are not site prepped and planted may remain in an early seral plant community dominated by brush fields for multiple decades. The probability of reestablishing late successional coniferous forests on these landscapes will remain low until surface fuels created by the 2017 fires have been reduced in amount and continuity by subsequent re-burns.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Associated Comments: Comment # Comments As the quotations by the author of the NW Forest Plan above indicate, and as will be 49-1 discussed in these EA comments, post-fire salvage logging does not contribute to the recovery of late-successional forest ecosystems. Rather, the significant impacts of commercial salvage logging inhibit forest recovery and 49-2 increase future fire hazard. It is incontrovertible that a strong consensus exists among fire ecologists that post-fire 49-3 salvage logging impedes and delays forest recovery and is inappropriate in the Late Successional Reserve (LSR) land use allocation. Again, in his recent comments to the Klamath National Forest please note that the author of the Northwest Forest Plan system of LSRs contends that: "Salvage logging of large snags and down boles does not contribute to recovery of late successional forest habitat; in fact, the only activity more antithetical to the recovery process would be removal of surviving 49-17 green trees from burned sites. Large snags and logs of decay resistant species, such as Douglas-fir and cedars, are critical as early and late successional wildlife habitat as well as for sustaining key ecological processes associated with nutrient, hydrologic, and energy cycles." -Dr. Jerry Franklin, 4/6/15. 5 The EA fails to acknowledge or respond to this comment despite it being raised repeated in project scoping. The KNF has recently implemented the Westside Fire Recovery Project and Horse Creek Community Protection and Restoration Projects. Despite the benign sounding names, both 53-135 projects significantly reduced late successional habitat and will starve many young fire affected stands of late successional characteristics for hundreds of years. The Seiad Horse Risk Reduction Project will lead to the same unfortunate outcome. The KNF cannot continue claiming to restore northern spotted owl habitat and building habitat complexity in LSR forests, while denuding slopes of snags, live trees, and downed woody debris in massive post-fire logging projects. The constituent habitat elements for the NSO are being systematically removed, across vast swaths of land effected by postfire 53-136 logging. Snags, and live trees, especially large commercially valuable snags and trees are the very structures that encourage habitat complexity and will become the foundation of any future forest. These large, commercially valuable logs are being targeted for commercial logging throughout the Seiad Horse Risk Reduction Project The EA failed to disclose and analyze the cumulative impact of post-fire logging on LSR connectivity. • The EA failed disclose, analyze and compare the timeframe under which postfire logging units will regenerate into "complex, late successional habitat." This 53-140 analysis must include a comparison of the timeframe required to restore complex, late successional habitat including large diameter snags and downed wood in post-fire logging units and unlogged, but heavily burned areas. Although the KNF has claimed in the Seiad Horse Risk Reduction EA, that post fire logging and artificial reforestation will accelerate the development of late successional forest habitats. The KNF has proposed to remove nearly all remnants of late-successional habitat 53-158 from affected stands. This includes logging large diameter snags and trees that take hundreds of years to reproduce. By removing large diameter snags, the development of late-successional characteristic will be heavily impeded, starving the affected stands of habitat complexity for hundreds of years. The decadence including large diameter snags

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment # Comments and downed wood found in snag forest habitats is the foundation for future late successional characteristics. The Seiad Horse EA failed to credibly demonstrate how the proposed activities will benefit LSR values and the development of late-successional characteristics. The currently 53-160 proposed actions fail to meet this standard and will create long-lasting negative impacts to late-seral conditions within both the Johnny O'Neil and Seiad LSRs. Impairing development of late-seral conditions within the Johnny O'Neil Late- Successional Reserve (LSR) by logging large legacy trees and destroying natural conifer regeneration in 54-4 the process, which is inconsistent with the Northwest Forest Plan (NWFP), owl recovery actions, and critical habitat protections; Project Activities Will Impair Development of Late-Seral Conditions within the Johnny O'Neil LSR and is Inconsistent with NSO Recovery Actions and Critical Habitat Project 54-16 activities will impair development of late-seral development on 1,814 acres of the LSR and is inconsistent with the intent of the NWFP and therefore requires a full EIS. However, the EA refers to similar LSR post-fire logging activities in the Westside salvage project by claiming late-seral conditions can be accelerated/enhanced by logging and tree planting, citing back to Zhang et al. (2008). This citation is inappropriate for 3 reasons: 1) Zhang et al. (2008) was conducted in a different region (Fountain Fire east of Shasta in the Southern Cascades), which was already slated for commercial timber operations on private (not public) lands. Clearly, both the objectives of private lands logging and forest assemblages in the Southern Cascades are not comparable to the project area. 2) Logging 54-20 the very features needed for late-seral development - large live and dead legacy trees- will retard development of late-seral conditions that require legacy trees as numerous studies have shown (e.g., Lindenmayer et al. 2008, Swanson et al. 2011, Donato et al. 2012, DellaSala et al. 2014). 3) Importantly, Donato et al. (2006) documented that similar post- fire logging within LSRs on the Biscuit destroyed natural conifer regeneration, which was greater than conifer stocking densities in unlogged areas on the Rogue-Siskiyou National Forest. The Seiad and Johnny O'Neil LSR were designated to protect connectivity for late-seral species. The 1999 Forest Wide LSR Assessment states, "Salvage should have a long term positive effect on late-successional habitat and should not diminish suitability [for northern spotted owl] now or in the future...Management following a stand-replacing 572-15 event should be designed to accelerate or not impede the development of late- successional characteristics. (USDA, 1999 p 4-22)." Post-fire logging, road building and reforestation will degrade LSR values and diminish habitat connectivity. Removing large snags from the fire area is antithetical to LSR forest values and management and will impede rather than accelerate late successional characteristics.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comment Response #67: Alternative 2 Support Concern statement: There was general support for alternative two of the project. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. Associated Comments: Comment # Comments 58-1 Mr. Rainey is in full support of Alternative 2.

Comment Response #71: Environmental Impact Statement is Necessary Concern statement: There is a disagreement regarding the use of an environmental analysis (EA) instead of the environmental impact statement (EIS) for the Project. There is concern that because the direct, indirect, and cumulative effects of the project on the watershed, wildlife, aquatic organisms, and other resources amount to significance, the project should be considered in an EIS. There is further concern that an EIS should be prepared because of the scale of the project, its controversial nature, the proposed removal of large trees, and determination that the project is likely to adversely affect northern spotted owl. Forest Service Response: The Forest Service has elected to prepare an EA for the Seiad-Horse Project. If, after the EA has been completed, the Forest Service is unable to make a finding of no significant impact, an EIS will be prepared or the no action alternative will be selected. The Forest Service will use relevant science to analyze effects of the action and no action alternatives. Associated Comments: Comme Comments nt # We are very concerned about the direct, indirect, and cumulative environmental impacts on wildlife, watersheds and other resources in the area and we are certain that these impacts 49-5 reach the level of "significance" necessitating completion of an Environmental Impact Statement (EIS) rather than an Environmental Assessment (EA) for this timber sale. Of particular concern is the Forest Service proposal to log old-growth forests within the Kangaroo Inventoried Roadless Area adjacent to the 47N80 road 4 immediately below the 49-12 Pacific Crest trail in mixed severity stands providing late successional habitat. Such logging necessitates the completion of an EIS rather than an EA. The cumulative impacts of significant post-fire logging of Late Successional Reserves that 49-21 provide post-fire foraging in critical habitat for northern spotted owl populations must be

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comme Comments nt # analyzed and disclose in an Environmental Impact Statement rather than an EA. Please note that as acknowledged on page 95 of the EA the project is likely to adversely affect Northern spotted owls and result in their "take." While the amount of "take" is not disclosed or analyzed in the EA, the KNF does indicate that "management actions cannot avoid NSO activity centers or their core use areas" because of the agency's insistence on logging along every possible road within the planning area. (EA page 95). Instead, KNF timber planners intend to construct new logging roads, conduct clearcut logging operations, and authorized yarding activities that will immediately and certainly increase 49-56 sediment loading and cumulative aquatic impacts. Such proposals involve significant impacts to at-risk aquatic values and necessitate the completion of an EIS for this project. As discussed in the Ninth Circuit's ruling of July 24, 2007, NEPA requires disclose of the cumulative impacts of multiple actions: 30 "One of the specific requirements under NEPA is that an agency must consider the effects of the proposed action in the context of all relevant circumstances, such that where "several actions have a cumulative…environmental effect, this consequence must be considered in an EIS." Neighbors of Cutty Mountain,137 F3d 1372, 1378 (9th Cir. 1998) quoting City of Tenakee Springs v. Clough, 915 F.2d 1308, 1312 (9th Cir. 1990)). A cumulative effect is "the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable actions regardless of what agency (Federal or non- Federal) or persons undertakes such other actions." 40 CFR § 1508.7. Our cases firmly establish that a cumulative effects analysis "must be more than perfunctory; it must provide a useful analysis of the cumulative impacts of past, present, and future projects." Klamath Siskiyou Wildlands Center v. BLM, 387, F.3d 989, 993 49-74 (9th Cir. 2004). To this end, we have recently noted two critical features of a cumulative effects analysis. First, it must not only describe related projects but also enumerate the environmental effects of those projects. See Lands Council v. Powell, 395 F.3d 1019, 1028 (9th Cir. 2005) (holding a cumulative effects analysis violated NEPA because it failed to provide adequate data of the time, place, and scale" and did not explain in detail "how different project plans and harvest methods affects the environment"). Second, it must consider the interaction of multiple activities and cannot focus exclusively on the environmental impacts of an individual project. See Klamath Siskiyou Wildlands Center, 387 F 3d at 996 (finding a cumulative effects analysis inadequate when "it only considers the effects of the very project at issue" and does not "take into account the combined effects that can be expected as a result of undertaking" multiple projects). -Oregon Natural Resources Council et al. v. Brong, 9th Circuit, July 24, 2007. The decision to log within an Inventoried Roadless Area and a Botanical Area along Bee Camp Road is unwise and necessitates the completion of an EIS for this project. Please note that page 12 of the EA indicates that the proposed roadside logging is reduced by 2 miles under 49-94 Alternative 3. This statement is incorrect. As disclosed on Table 3 in the EA both Forest Service Action Alternatives involve at least 0.5 miles of logging within the IRA and within the Botanical Area near the Pacific Crest Trail at Cook and Green Pass. The No Action Alternative "will retain all the remaining habitat and important legacy structures (e.g. large trees/snags and woody debries) to aid in the development of NSO 49-97 habitat by providing physical structure as the stand regenerates. Since NSO and their prey base are associated with large trees/snags and logs, alternative 1 will maintain all large trees/snags and large woody debris." The Forest Service failed to avoid removing key

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comme Comments nt # elements of spotted owl habitat such as large snags and future sources of down wood in its action alternatives. Indeed, page 95 of the EA indicates that the proposed logging is "Likely to Adversely Affect" spotted owls and their habitat and will result in "take." Further, page 95 indicate that the Forest Service intends to log occupied core use areas in spotted owl activity centers. These controversial and significant actions necessitate completion of an EIS, rather than an EA, for this project. Please note that Bond 2009 (which were attached to our scoping comments) recommends forgoing salvage logging activities within 1.5 km of NSO nest sites. Yet the Klamath National Forest refuses to develop action alternatives that reflect the findings of peer-reviewed science that conflicts with its post-fire logging agenda. Please note that page 4 of the Northern Spotted Owl Report indicates that "[r]ecent research has argued the value of fire affected nesting, roosting, and foraging habitat in NSO activity centers. The research indicates variability and a high level of uncertainty in the degree to 49-98 which spotted owls use post-fire landscapes…" Nevertheless the KNF intends to log post-fire NSO habitat in LSRs serving as critical habitat. Please note that controversy and uncertainty over project outcomes is a factor necessitating completion of an EIS rather than an EA. An EIS is required to provide meaningful, site specific analysis for Seiad Horse Risk Reduction Project. The scope, scale, and potential cumulative effects of the proposed project require a full EIS. The Seiad Horse Risk Reduction Project is a large post-fire logging project with significant potential impacts to landscape connectivity, biologic diversity, forest regeneration, fuel loading, recreation and scenic resources. Projects of similar size, scale and intensity have 53-15 routinely required an EIS on the Klamath National Forest, including the post-fire logging projects such as the Westside Fire Recovery Project, the Horse Creek Community Protection and Restoration Project, Salmon Salvage, and Panther Fire Salvage. Like these projects, the Seiad Horse Project is highly controversial, is based on disputed science and should require a full EIS analysis. The scale of the project is large and significant, with over 1,200 acres of commercial post-fire unit logging, 39 miles of roadside hazard logging, almost 955 acres of site, prep and planting prescriptions, 4,508 acres of underburning, over 2 miles of new road construction, 139 acres 53-19 of fuel reduction, and between 87 and 179 acres of fuel brake construction and maintenance. The current EA analysis fails to take a hard look at important social, cultural and biologic issues raised by the public. The potential cumulative impacts of these extensive activities requires a full EIS. The location of the proposed logging and vegetation management prescriptions is also 53-20 concerning and should require full EIS analysis. Habitat modification on the scale proposed along with social, cultural, and ecological impacts 53-23 should require preparation of an EIS. Current EA analysis is superficial, inadequate and does not constitute the "hard look" required in the NEPA process. The presence of wolves, a species protected under the Endangered Species Act was not 53-142 disclosed in the Seiad Horse Risk Reduction EA. This failure to disclose and analyze should be considered in a full EIS analysis for the Seiad Horse Risk Reduction Project. If the KNF intends to log the Johnny O'Neil and Seiad LSR they must identify how salvage activities that remove late-seral characteristics will benefit late successional habitats or 53-150 encourage their development. The assertions must also be validated by relevant science and thoroughly analyzed in an EIS. Current analysis in the Seaid Horse EA is insufficient.

Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Comme Comments nt # A full EIS must disclose the controversy and concerns regarding specific units on a unitby- unit basis. The site-specific information provided below must be included in EIS analysis. The units 53-260 themselves should be treated as relevant issues for analysis due to their controversial nature and significant environmental impacts. Given the substantial public and scientific controversy, at a minimum, we are requesting a full 54-2 Environmental Impact Statement (EIS) pursuant to NEPA. While monitoring and "best management practices" are proposed in the EA, they are insufficient in avoiding incidental take to NSO (nesting, roosting, foraging, dispersal habitat and demographic support), are inconsistent with LSR management as directed by the NWFP and attainment of the ACS, inconsistent with the intent of the Roadless Area Conservation Rule (USDA Forest Service 2000), and are based on faulty assumptions and incomplete 54-11 citations about fire regimes, fuel structures, fuel breaks, and application of roadside hazard tree removal guidelines. Thus, we are requesting that, at a minimum, you conduct an EIS with a range of alternatives that complies with the Roadless Conservation Rule, LSR management, the NSO recovery plan, ACS standards and guidelines of the NWFP, hazard tree removal guidelines (more options, see below), and a more comprehensive literature review showing the substantial controversy related to proposed project activities. While the Roadless Conservation Rule allows for removal of hazard trees for human safety (USDA Forest Service 2000), in all cases the Roadless Rule specifies that tree removal is limited to small trees (USDA Forest Service 36 CFR Part 294 Special Areas; Roadless Area Conservation; Final Rule; emphasis added). Thus, we request that you apply the Roadless Rule emphasis on small trees to Forest Service road 47N80 bisecting the Kangaroo roadless area as follows: §? "… hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary. Vegetative management would focus on removing generally small diameter trees while leaving the overstory trees intact." §? "The cutting, sale, or removal of trees must be clearly shown through project level analysis to contribute to the ecological objectives described (emphasis 54-12 added) in § 294.13(b)(1), or under the circumstances described in paragraphs (b)(2) through (b)(4). Such management activities are expected to be rare and to focus on small diameter trees. Thinning of small diameter trees, for example, that became established as the result of missed fire return intervals due to fire suppression and the condition of which greatly increases the likelihood of uncharacteristic wildfire effects would be permissible." §? "In all cases, the cutting, sale, or removal of small diameter timber will be consistent with maintaining or improving one or more of the roadless area characteristics (emphasis added) as defined in § 294.11" (emphasis added). Thus, because the Seiad-Horse post-fire logging activities involve removal of an undisclosed number of large diameter trees along 2 miles of 47N80 that bisects the Kangaroo Roadless Area, an EIS is warranted to comply with the Roadless Rule. The EA proposes substantial removal of large trees >20 in dbh using much larger diameter thresholds 7 for site retention based on whether such trees are in NSO cores, Riparian 54-24 Reserves, LSRs, or have a moderate to high probability of mortality (see below). The scale of removal of large trees (e.g., numbers removed vs. retained) therefore requires further disclosure and analysis afforded by an EIS.

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Comme Comments nt # The cumulative effects analysis, for all issues, particularly for wildlife is woefully 59-1 underestimated, reiterating the need for an EIS. Franklin's bumblebee (Bombus franklini) was historically found only in a small area in southern OR and northern CA. Neither the Horse Creek or Seiad-Horse projects analyzed effects to the Franklin's Bumblebee. The Westside project contained habitat and past known locations for the bee, however, no surveys or consideration were given to this imperiled bee species. Franklin's bumblebee has the most restricted range of any bumblebee in the world. 59-16 Its entire distribution can be covered by an oval of about 190 miles north to south and 70 miles east to west. Populations were readily found throughout 8 its range throughout the 1990s but have declined precipitously since 1998; subsequent yearly surveys have suggested this bee is in imminent danger of extinction. This reiterates the need for an EIS and the consideration of this extremely rare bee species. In conclusion, the agency must complete an EIS and broaden the range for cumulative effects 59-20 on wildlife species. In short, EPIC believes that the EA—together with other evidence referenced herein— demonstrate that the project is likely to result in direct, indirect, and cumulative environmental impacts on wildlife, watersheds and other resources in the area that rise to the 62-1 level of "significance" necessitating completion of an Environmental Impact Statement (EIS) rather than an Environmental Assessment (EA). Accordingly, our organizations expect that the Forest Service will prepare the required EIS. The Forest Service must produce an EIS as the project will result in significant cumulative watershed effects. As the proceeding evidence will show: (A) Current conditions for watersheds within the project area are significantly degraded, to the extent that beneficial 62-3 uses are not being attainted; (B) The best available evidence shows that actions like the proposed project are known to cause significant sediment production; (C) The Forest Service's own modeling shows that the project will cause significant cumulative impacts; The mid Klamath watersheds are critical for threatened species and wild salmon yet you 71-1 continue to degrade and harm them. This project would add significant adverse impacts that should be considered in a full environmental impact statement. An EIS is needed because: (1) Salvage logging is controversial. "Treatment of areas following occurrence of major disturbances is a complex and controversial topic. Complexities include the trade-offs among various resource management goals, such as between management of fuels and provision of wildlife habitat in the case of wildfires. Conflicts often exist between economic and ecological objectives as timber salvage is generally about recovering economic 148-1 values rather than enhancing ecological recovery. A further complication is that science of post-disturbance management activities has only recently begun to receive serious attention." Johnson & Franklin 2009. Report: Restoration of Federal Forests in the Pacific Northwest http://www.forestry.oregonstate.edu/cof/fs/PDFs/RestorationOfFederalForestsInThePacificN orthwest.pdf. 148-2 The agency's salvage logging program has never been considered in the programmatic EIS. The Seiad-Horse project would add significant adverse impacts that should be considered IN A 198-1 FULL ENVIRONMENTAL IMPACT STATEMENT.

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Comme Comments nt # A full Environmental Impact Statement (EIS) is warranted for this large project with potentially 572-24 substantial impacts on the ecosystem. The SCNPSO requests that the Seiad Horse Project require a full EIS.

Comment Response #72: Opposing Views and Scientific Controversy Concern statement: There is a concern that the Forest didn't take a hard look at the literature provided to us from the commenters. Commenters suggested that their literature should've been used over some of the literature the Forest used. Forest Service Response: As described in 40 CFR 1501.7, "there shall be an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to a proposed action." The purpose of the scoping period is for the discovery of alternatives to a proposal or significant impacts that may have been overlooked. The literature provided during the scoping period was considered by the specialists of the interdisciplinary team. Scientific papers provide information but they are rarely site and project specific, nor is there a requirement in law or regulation to follow the recommendations of a journal article. Journal articles do not provide management direction to the Forest Service. That comes from the Forest Plan. Project design is based on the difference between site-specific existing conditions and the desired condition in the Forest Plan. Analysis is based on site-specific data where it exists, and where it does not, the agency must use the best information otherwise available. In its analysis, the Forest Service must consider the available information, and make that information available to all. There is however no requirement of the Forest Service to conduct an exhaustive literature review of every possible journal article for every proposed project. In its review, the Forest Service must acknowledge scientific controversy concerning the effects of an activity. When a decision is made, the Forest Service must show a rational connection between the evidence presented, the facts found and decision made. We believe the record for the Seiad-Horse Project shows these standards have been met. The "best available science" is addressed in the Code of Federal Regulations (40 CFR 1502.24) "Agencies shall insure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements. They shall identify any methodologies used and shall make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the statement. An agency may place discussion of methodology in an appendix." Literature that has been provided by commenters that supports a concern regarding a project level effect or methodology has been reviewed by the interdisciplinary and discussion of this literature can be found throughout this response to comments document. The interdisciplinary team used the best available science in preparing the project design and analysis for this project and the professional and scientific integrity of this best available science is documented in the Draft EA and Final EA and supporting resource reports and appendices. Literature does not become "best available science" until it is related to the analysis and when the findings are interpreted or adapted to site specific conditions.

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Associated Comments: Comment # Comments As stated on page 92 of the EA, "[r]easonable opposing views regarding salvage harvest exist…" but the KNF makes no mention of what these opposing views are or why the agency rejects scientific findings that do not support its LSR salvage logging agenda. Attached to our project scoping comments (attachment 26) was a 2013 letter to congress 49-107 signed by 250 scientists asking that decision makers "consider what the science is telling us: that post-fire habitats created by fire, including patches of severe fire, are ecological treasures rather than ecological catastrophes, and that post-fire logging does far more harm than good to the nations public lands." Klamath timber planners refused this request. During project scoping, Geos Institute submitted a substantial number of citations and pdfs on the widespread impacts of post-fire logging and related project activities that do not support the conclusion reached by the Klamath National Forest regarding no scientific controversies or no controversy at all within the proposed project. Therefore, we are resubmitting portions of scoping comments and pdfs along with additional comments below pertaining to the unresolved and grossly underestimated conflicts surrounding post- 54-7 fire logging proposed for the Seiad-Horse 2 project and the failure of the EA to consider best available science. At a minimum, we request that you analyze a broad range of alternatives that comply with the Roadless Conservation Rule, Northern Spotted Owl Critical Habitat and Recovery Actions, the Northwest Forest Plan management of Late- Successional Reserves and Riparian Reserves, and considers other options for hazard tree removal as described herein. Instead, the Seiad-Horse EA makes unsupported assertions regarding a lack of scientific controversy (p. 90; "Although opposing views were raised during public scoping and were considered, public and internal scoping identified no scientific controversy (emphasis added) over the impacts of this project), nor do you report on federal agencies that have chosen a different approach. Below we have appended 4 letters from hundreds of scientists objecting to post-fire logging activities like those proposed in the Seiad-Horse EA, testimony to the House Natural Resources Committee by Dr. Jerry Franklin (one of the architects of the Northwest Forest Plan), and a newspaper article from a February 2006 congressional hearing in Medford, Oregon involving the substantial controversy surrounding post-fire logging activities in the nearby Biscuit area. "Salvage logging 54-10 generally cannot be justified on the basis that it contributes to the recovery of forest ecosystems following catastrophic disturbances. There is essentially no scientific support for the view that salvage logging can contribute direct positive benefits to ecological recovery; there is abundant scientific evidence that salvage logging can have diverse and significant negative impacts of salvage logging on ecological recovery (e.g., Lindenmayer et al. 2004)." Jerry Franklin, attached testimony. Moreover, our scoping comments included dozens of pdfs and a book citation (Lindenmayer et al. 2008) of post-fire logging impacts to aquatics and water quality, spread of invasive, increased mortality of natural conifer regeneration, increased fine fuel loads, impacts to spotted owls, carbon emissions, and increased future burn severity. These pdfs were not even cited in the EA, which instead inappropriately concludes that there is no scientific controversy. Halofsky et al. (2011) note "both conifer and hardwood regeneration were also abundant 54-39 in riparian areas four years after the Biscuit Fire; mean tree seedling density was 1600/ha

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Comment # Comments and mean sprout density was 8200/ha." Thus, the project EA is based on false assertions of lack of conifer establishment particularly in riparian areas. Figure 5 from Shatford et al. 2007. Dominant conifer abundance by year of establishment. (A) Establishment after fires of 1992-1996 on low-elevation sites; (B) establishment after 54-41 fires of 1987 on low elevation sites (Douglas-fir and Douglas-fir/tanoak series); (C) establishment after fires of 1987 on high-elevation sites (white fir series) in the Klamath- Siskiyou region. In no way can it be concluded that this project has no scientific controversy given the 54-62 extensive literature provided in our comments and the hundreds of scientists that have objected to post-fire logging and related actions like those proposed in the EA.

Comment Response #73: Consideration of Relevant Issues from Scoping Concern statement: There is a concern that the Forest didn't use the commenter’s suggestions of relevant issues. Forest Service Response: The Forest Service received 491 comments in 1,033 letters (719 were form letters) submitted during the public scoping period. The letters and attachments were logged in and electronically filed in the project record. Individual comments from within each letter submitted were identified and highlighted. Issues and concerns were placed into a subject category based on the topic and reviewed by the interdisciplinary team. The analysis presented here, and in supporting documents, responds to and considers the impacts of proposed actions for which commenters expressed concern. Also see the Issues section of the EA. Associated Comments: Comment # Comments The following comment provides valid science, brings forward relevant issues that were inadequately analyzed, provides new information and substantive comment to inform the Decision Record. A valid NEPA analysis requires addressing the relevant issues identified in our comment with adequate analysis and mitigation measures that could include dropping 53-13 units or canceling the sale. All issues must be given a "hard look" and analyzed in sufficient detail. This disclosure of impacts, cumulative effects and environmental consequences has not been adequately addressed in the Seiad Horse Risk Reduction Project Environmental Assessment (EA). The following information was included in public comment for the Seiad Horse Project and 53-30 identified as a relevant issue, yet was not disclosed or analyzed in the Seiad Horse Risk Reduction EA. Failure to disclose these impacts constitutes inadequate NEPA analysis: The following information was included in public comment for the Seiad Horse Project and identified as a relevant issue, yet was not disclosed or analyzed in the Seiad Horse Risk Reduction EA. Failure to disclose these impacts constitutes inadequate NEPA analysis: • 53-42 The EA failed to analyze the contribution of plantation structure to high severity fire effects in the Abney Fire. The EA also failed to analyze the contribution of plantation structure on future fuel loading and fire severity. • The EA failed to analyze the percentage of former plantation stands that suffered high severity fire effects in the Abney Fire. • The

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Comment # Comments EA failed to provide a map, spatially depicting plantation stands within the planning area before the Abney Fire and overlaid with fire severity ratings in the Abney Fire. • The EA failed to provide a map; spatially depicting plantation stands within the planning area before the Abney Fire and proposed post fire logging and site prep and plant units in the Seiad Horse Risk Reduction Project. • The EA failed to disclose and analyze the connection between plantation stands and increased fire severity on the Klamath National Forest. Significant scientific literature and numerous agency documents attest to this fact. • The EA failed to analyze the fuel continuity and structure conditions created by proposed reforestation units and the effect such planting will have on future fire severity. • The EA failed to disclose the spacing, configuration, species planted and number of trees per acre planted in each post-fire and site prep and plant unit. Currently only vague descriptions of treatments have been made. No concrete information regarding trees per acre or the configuration/spacing of plantings has been provided. This basic lack of information precludes realistic analysis of the impacts to forest regeneration, wildlife habitat, biodiversity and fuel loading. Analysis in the EA in inaccurate, incomplete and misleading. • The EA failed to adequately analyze or disclose the significant, highly accessible body of science/academic literature regarding plantation stands, even-aged forest management and fire severity. The failure to utilize or analyze the best available 17 science or address well known scientific consensus, controversy, or uncertainty is arbitrary and capricious. The following information was included in public comment for the Seiad Horse Project and identified as a relevant issue, yet was not disclosed or analyzed in the Seiad Horse Risk Reduction EA. Failure to disclose these impacts constitutes inadequate NEPA analysis: • The EA failed to adequately analyze or disclose the impact of project activities on the intact botanical values and biodiversity of the Cook and Green Pass region. • The EA failed to adequately analyze or disclose the impact of project activities on the globally significant biodiversity of the Siskiyou Crest region. • The EA failed to disclose or analyze the unique and irreplaceable role the Siskiyou Crest plays in regional connectivity and biodiversity. • The EA failed take a hard look at the unique values of the Siskiyou Crest including connectivity, species diversity, climate refugia, and recreation. • The EA failed to disclose and analyze the role of the Siskiyou Crest in facilitating species migration in response to 53-48 climate change. • The EA failed to address the cumulative impact of fire suppression backburns and commercial post-fire logging to botanical resources in the Cook and Green Pass Botanical Area. 5. The EA failed to adequately disclose or analyze all adverse effects associated with post-fire logging in the Siskiyou Crest Connectivity Corridor As described above, the Siskiyou Crest is a unique, irreplaceable and disproportionally important landscape from the stand point of connectivity and biodiversity. As the climax of biodiversity on the West Coast and the conduit for genetic dispersal, the conservation values of the Siskiyou Crest are immense. The Siskiyou Crest represents one of the most important connectivity corridors and climate refugia in western North America. The biodiversity of the Siskiyou Crest and the connectivity it provides is of regional significance and global importance (Stritholt et al., 1999).

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Comment Response #74: Salvage in Riparian Reserves Concern statement: There is a concern that proposed salvage logging in riparian reserves has not been properly analyzed. Commenters stated that salvage logging should be cancelled in riparian reserves and that no credible science supports post fire logging in riparian reserves. Commenters also asked for clarification regarding timber harvest activities in riparian reserves. Forest Service Response: The project proposes only to remove roadside hazard trees and maintain a fuel management zone in Riparian Reserve. Riparian Reserve areas are not proposed for risk reduction salvage harvest. In Riparian Reserve, felled trees qualifying as potential in-stream large woody debris (those 24 inches in diameter or greater) will not be removed (except as described below), and will contribute large woody debris to the stream channel and the associated Riparian Reserve area. Felled trees greater than 24 inches diameter will only be removed if a felled tree would threaten the function of a drainage structure or cause stream diversion, if the faller cannot safely fell the hazard tree away from the road, or if the fallen tree would present a direct hazard to the road. There are also less than two acres of Riparian Reserve planned for treatment for the proposed fuel management zone. These acres are at the top end of the hydrologic riparian reserve and more than one-half site potential tree height distance away from intermittent channels. The treatment proposed on the small portion of riparian reserve includes only the removal of dead and live understory vegetation and live conifer trees less than 12 inches in diameter at breast height, as described in the Proposed Action and Alternative section of the EA. The project is consistent with the Forest Plan standards and guidelines for Riparian Reserves and Aquatic Conservation Strategy goals and objectives as demonstrated in the Forest Plan Consistency Checklist and Appendix C of the EA. Forest Plan standards and guidelines for Riparian Reserves do not limit the Forest from removing hazard trees, and state "Fell trees in RR when they pose a safety risk. Keep felled trees on-site when needed to meet CWD requirements" (MA 10-58). Associated Comments: Comment # Comments 53-219 No credible science supports post-fire logging in Riparian Reserves All post fire logging proposed in Riparian Reserves should be canceled, especially given the 53-220 deficiency in large in stream wood throughout the entire Horse Creek watershed. The EA failed to disclose and analyze sediment yield for Horse and Seiad Creek due to post- 53-222 fire logging in riparian reserves. Table 5 on page 13 of the Draft EA identifies that Alternative 2 proposes 1,814 acres of Risk Reduction Salvage with Site Prep and Plant. Table 2 of the Draft EA summarizes the proposed treatment acreage as shown below. Table 2 is unclear with respect to whether 1067-2 any timber harvest activity is proposed within Riparian Reserves. Please clarify in the final EA whether any timber harvest activities are proposed within Riparian Reserves and specify the type of activity and amount proposed.

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Comment Response #75: Aquatic Conservation Strategy Compliance Concern statement: There is a concern that effects of proposed project activities to stream sedimentation, watershed function, channel morphology, terrestrial connectivity, stream flow conditions, and riparian dependent species are inconsistent with the Aquatic Conservation Strategy objectives of the Northwest Forest Plan and the Clean Water Act. Forest Service Response: Concerns about consistency with the Clean Water Act are addressed in the response to concern statement #9. In regards to concerns about compliance with the Aquatic Conservation Strategy, the Aquatic Conservation Strategy has four components: 1) Key Watershed, 2) Watershed or Ecosystem Analysis (Forest Plan, page 4-25), 3) Watershed Restoration, and 4) Riparian Reserves (Forest Plan, page 4-25). There are no key watersheds within the Seiad-Horse Project. Ecosystem analyses provide recommendations, not management direction, to be considered in project-level planning. Applicable ecosystem analyses were considered in these documents, and we found that the project is largely consistent with the recommendations of the Horse Creek and Thompson/Seiad/Grider Ecosystem Analyses, with one exception of road decommissioning which is outside the scope of the project. Watershed restoration activities within the project include large wood placement, prescribed burning to decrease potential for watershed degradation caused by future high severity fire, legacy site treatments, and hydrologically restoring temporary roads used during the project. Within riparian reserves, standards that prohibit and regulate activities that retard or prevent attainment of Aquatic Conservation Strategy objectives (Forest Plan, page 4-106) will be met. The aquatic conservation strategy analysis found that proposed actions would not retard or prevent attainment of Aquatic Conservation Strategy objectives to maintain and restore (Forest Plan, page 4-106). The decrease in risk of future high-severity fire due to fuel reduction treatments would help to maintain and restore watershed processes identified in the aquatic conservation strategy objectives in the long term. Therefore, the project is consistent with the Aquatic Conservation Strategy and Forest Plan.

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Associated Comments: Comment # Comments As stated on page 50 of the EA, all streams in the project area are currently 303(d) listed under the CWA for sediment and turbidity. Further, page 72 of the EA acknowledges that "most watersheds in Horse Creek have Equivalent Roaded Area ERA values [that] exceed the threshold of the concern." Yet page 74 of the EA calls for increasing ERA throughout the project area and anticipates increases to ERA and landslide potential due to project activities. "The USLE model shows that Alternative 2 would increase sediment in West Fork 49-57 Horse Creek by about 10%" (EA page 74) despite the watershed already being over threshold. Sediment in Salt Gulch and East Fork Seiad Creek would be increased as well. (EA page 74.) The significance of the proposed sediment increases is incontrovertible given that "[a]dditive increases in sedimentation, however slight, in watersheds that are over the 22 threshold of concern are likely to further exacerbate adverse effects to aquatic and riparian habitats." (EA page 77). Neither the ACS nor the CWA permit this outcome. The Forest Service hopes to implement destructive actions such that "[p]roject element related disturbance in the East Fork Seiad Creek 7th field watershed, which is well over threshold in the ERA model, would likely increase adverse effects to aquatic and riparian 49-59 habitats…" (EA page 80). The ACS and CWA do not permit this outcome. As stated on page 80 of the EA "ground disturbing project elements that would increase sediment delivery to streams would be adversely cumulative with current high cumulative effects and sedimentation in the Horse Creek Watershed." Hence an EIS is required for this project. This is not the first timber sale (with associated road construction and ground-based yarding) proposed by the Klamath National Forest in lands designated as impaired watersheds in the LRMP. We urge the Klamath National Forest planners to review the holding contained in Klamath Siskiyou Wildlands Center et. al. v. United States Forest Service, Eastern District Court of California, (2004) regarding the Beaver timber sale in the Beaver Creek AWWC. The court held: (1) that listing CWE mitigation measures without analytical data did not pass NEPA muster; and (2) that the ACS analysis was flawed for failing to disclose the natural range of variability. Further note, the Eastern District Court 49-60 also recently held that the Klamath National Forest violated the law in the Meteor AWWC timber sale Klamath Siskiyou Wildland Center et. al. v. United States Forest Service, Eastern District Court of California, (2006). The court specifically held that the agency's EIS for logging and road construction in this impaired watershed was illegal due to the Forest Service's failure to ensure that the North Coast Regional Control Board's CWA Basin Plan was met because the agency had failed to conduct the monitoring necessary to know the background level of turbidity. Please note that the Seiad-Horse project also threatens violation of the Basin Plan and further cumulative watershed effects within this impaired watershed. Page 12 of the Geology Report indicates that in "Alternative 2, the model predicts that temporary roads and landings would produce about 1,255 cubic yards of landslide 49-62 sediment compared to about 1,172 for Alternative 3." The ACS of the NW Forest Plan and the CWA do not permit this result. The following findings are relevant to the Administrative Record for this salvage timber sale and speak directly to Forest Service policy and guidance documents: Please note that 49-91 at E-20, The Northwest Forest Plan requires that: "[The Watershed Analysis] will serve as the basis for developing project-specific proposals, and determining monitoring and

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Comment # Comments restoration needs for a watershed. Some analysis of issues or resources may be included in broader scale analyses because of their scope. The information from the watershed analyses will contribute to decision making at all levels. Project-specific NEPA planning will use information developed from watershed analysis. For example, if watershed analysis shows that restoring certain resources within a watershed could contribute to achieving landscape or ecosystem management objectives, then subsequent decisions will need to address that information." Degrading Riparian Reserves by removing large legacy trees inconsistent with the Aquatic 54-5 Conservation Strategy (ACS) of the NWFP; (D) The modeling relied upon by the Forest Service is likely an underestimate due to flaws 62-4 in the model's design; and (E) The Forest Service is wrongfully considering non-connected activities as mitigation measures for the project.

Comment Response #76: Sedimentation and Water Quality Concern statement: There is a concern that proposed project activities will increase sedimentation and affect water quality. Consider not doing treatments on steep slopes where sediment can be released. Forest Service Response: While the EA discloses that an increase in sediment production is predicted due to project activities, it also states that it will be at the site scale and will recover quickly (EA, pages 72, 74, 77). The USLE model shows that Alternative 2 would increase sediment in West Fork Horse by about ten percent. Salt Gulch would increase by about four percent and East Fork Seiad by about one percent. All three seventh field watersheds were over threshold prior to project effects modeling. Sedimentation is likely to occur at the site scale, but should recover quickly. At the seventh field watershed scale the only substantial increase in sedimentation according to the model is West Fork Horse. The increased sedimentation from the Abney Fire is much more evident in Horse Creek than the impacts of Alternative 2. The GEO model predicts sediment inputs through landslide delivery. The model for Alternative 2 predicts only Salt Gulch and East Fork Seiad Creek will be over threshold, both of which were over threshold prior to modeling the Project. The increase will be three percent in Salt Gulch and one percent in East Fork Seiad Creek. This increase is relatively small and is much less than the planned treatment of up to 23,000 cubic yards of sediment by legacy sediment site treatments. Associated Comments: Comment # Comments After acknowledging that proposed logging will increase sediment production, equivalent roaded area and landslide potential, the EA (page 75) concludes that "the differences 49-116 between Alternatives 2 and 3 in terms of all analysis indicators are inconsequential for hydrology." Please note that there is almost universal agreement that salvage logging does not leave 49-137 watersheds and forests in a healthier, more resilient state, and that the timber volume gained via salvage is neither predictable nor sustainable.

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Comment # Comments Third, in forests subjected to severe fire and post-fire logging, streams and other aquatic ecosystems will take longer to return to historical conditions or may switch to a different 49-143 (and often less desirable) state altogether (Karr et al. 2004). Following a severe fire, the biggest impacts on aquatic ecosystems are often excessive sedimentation, caused by runoff from roads, which may continue for years. Given these statistics and the admission that fire salvage has "heavily impacted" the Seiad Creek watershed the agency cannot claim ecosystem benefit by further impacting sensitive 53-145 watersheds in LSR forest. By implementing essentially, the same post-fire logging operations that "heavily impacted" the watershed, the same watershed and forest impact will again occur, compounding previous impacts on the site and landscape scale. The Aquatic Resources Report concludes that, "The 2016 Gap Fire and the 2017 Abney Fire is expected to further increase already excessive sedimentation, as is extensive salvage logging on private lands that has occurred and is on-going subsequent to the Gap Fire"(USDA. 2018c p. 27). Yet at this point, the agencies logic breaks down when they claim nearby private land logging combined with natural fire effects will increase already 53-227 excessive sediment loads, yet somehow roadside hazard logging in riparian reserves, post- fire logging, the development of 25 new landings, 8 new roads and widespread soil disturbance and compaction from yarding operations on federal land will not substantially increase sediment delivery. How can this be? Many of the same sediment generating activities are proposed on federal land, in currently mostly undisturbed headwater streams. They will create similar impacts to private land post-fire logging. In streams already suffering from excessive sedimentation and compounding cumulative effects, the increase from federal post-fire logging represents the final straw. In fact, Cumulative Watershed Effects (CWE) analysis in the Aquatic Resources Report finds that every 7th field watershed in the planning area "is being adversely impacted by high levels 53-228 of watershed disturbance" and is either" nearly over the threshold of concern" or "highly elevated" over the threshold of concern in numerous CWE models. (USDA. 2018c p. 29). The proposed Seiad Horse Project will create further cumulative effects including an estimated 2,000 cubic yards of sediment for a minimum of two to ten years (USDA. 2018a p.79-80). According to the Seiad Horse Risk Reduction EA, previous significant impacts to soils are associated with "current road density, previous timber harvests, and wildfires within the project area" (cite, Geology Report p. 12). The proposed action will harvest timber and build new roads in the post-fire environment, creating the same detrimental impacts. 53-230 Although the EA claims the previous impacts "overshadow the relatively small changes in predicted sediment production from the proposed alternatives" (USDA. 2018a p. 12), given the current listing of impairment for sediment and temperature, no additional impacts should be approved. New road construction, even temporary road construction, will increase sediment loads 53-235 and soil compaction in these impaired watersheds, 72 compounding existing effects and water quality concerns. New landings and the use of old landings will increase soil erosion and hydrological 53-240 impacts in impaired watersheds including Lower Horse and Upper Seiad Creek, both support important anadromous fisheries.

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Comment # Comments Although the EA claims to "have the direct effect of (1) improving fish habitat along a 1.4 mile reach of mainstem Horse Creek by placing large woody debris at up to 27 sites and (2) reducing fill volume in the stream channels at some legacy sites" (EA, p.79-80). The EA continues by estimating a two to ten-year increase of approximately 2,000 cubic yards of sediment. This level of increased sedimentation in an already impaired stream is then spun into a positive, by masking its impact, by combining the estimated sediment load produced from project implementation with those that will supposedly be reduced in legacy site 53-250 treatments and restoration activities approved in numerous other projects. Although the numbers look promising, they do not negate the additional impact of increased sedimentation for two to ten years. According to the EA, "In the short term (two to ten years), ground disturbing project elements that would increase sediment delivery to streams would be adversely cumulative with current high cumulative watershed effects and excessive sedimentation in the Horse Creek watershed." ( USDA. 2018a p. 80). These impacts are additional, cumulative and cross significant thresholds of concern for Cumulative Watershed Effects. The Seiad Project EA and accompanying documents presents a stark and disturbing picture of current conditions of watersheds within the project area. All of the areas are sediment 62-5 impaired, thereby threatening salmon habitat and other beneficial uses. These degraded conditions matter because the project will further degrade the watersheds and make attainment of water quality objectives more difficult. As the EA provides, this entire area has been designated as "impaired" under section 303(d) of the clean water act, indicating that current conditions do not meet water quality 62-6 standards and streams are not supporting their beneficial uses, with sediment and stream temperature identified as the pollutants causing impairment. (EA at 50). EPIC is particularly concerned that the Seiad Project is likely to result in substantially increased sediment delivery, relative to post-fire baseline, to Seiad and Horse Creeks and 62-11 the Klamath River. This increased sediment pollution will further degrade the already impacted watersheds within the project. In total, the results of the proposed logging will result in significant environmental impacts, necessitating the preparation of an EIS Fires cause four fundamental ecosystem state changes that impact sediment pollution: reduction in plant canopy; increase in soil water repellency; loss of surface cover; and (4) consumption of soil organic matter. Salvage logging adds additional variables that increase 62-12 or decrease erosion rate, such that in a post-fire logging site, sediment production is a multivariate function. The EA fails to take a hard look at the science, so we must. Here, EPIC presents evidence that the various disturbances associated with post-fire logging likely increase sediment pollution. It is generally acknowledged that post-fire logging can result in additional stream sediment production, as the timing of these land management activities typically occurs when forests are most vulnerable to additional impacts or disturbances. In a review of the existing literature, Karr et al. (2004) lists that post-fire logging can have a multiplying effect 62-13 on the disturbance caused by a fire:...? Postfire salvage logging generally damages soils by compacting them, by removing vital organic material, and by increasing the amount and duration of topsoil erosion and runoff, which in turn harms aquatic ecosystems. The potential for damage to soil and water resources is especially severe when ground-based machinery is used. ? Postfire salvage logging has numerous ecological ramifications. The

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Comment # Comments removal of burned trees that provide shade may hamper tree regeneration, especially on high-elevation or dry sites. The loss of future soil organic matter is likely to translate into soils that are less able to hold moisture, with implications for soil biota, plant growth, and stream flow. Logging and associated roads carry a high risk of spreading nonindigenous, weedy species. ? Increased runoff and erosion alter river hydrology by increasing the frequency and magnitude of erosive high flows and raising sediment loads. These changes alter the character of river channels and harm aquatic species ranging from invertebrates to fishes. ? Construction and reconstruction of roads and landings (sites to which trees are brought, stacked, and loaded onto trucks) often accompany postfire salvage logging. These activities damage soils, destroy or alter vegetation, and accelerate the runoff and erosion harmful to aquatic systems. ? By altering the character and condition of forest vegetation, salvage logging after a fire changes forest fuels and can increase the severity of subsequent fires. ? Postfire salvage logging undermines the effectiveness of other costly postfire rehabilitation efforts, most of which are aimed at reducing soil erosion and runoff. Turning to case studies, the preponderance of case studies have found that post-fire logging significantly increases sediment production and/or causes disturbances associated with sediment production. While a small number of studies have not found significant...Wilson (1999) used rainfall simulators to examine sediment production in a simulated 10-year rainfall event. Sediment production from logged and burned plots produced considerable more sediment than unlogged and burned control sites (1.1 Mg ha- 1 as compared to .05 Mg ha-1). Chase (2006) examined sediment production from groundbased, skyline, and helicopter logging on the Eldorado National Forest in California. Generally, Chase found logging increased the amount of bare soil, mostly attributable to the loss of litter on logged sites. Various logging methods produced differing effects on bare soil, with helicopter yarded sites containing significantly less bare ground than tractor logged sites. Silins et al. (2008) and Silins et al. (2009) examined the 2003 Lost Creek fire in the Oldman River basin, Alberta, Canada. Both studies monited even watersheds, with varying degrees of natural and man-made land disturbance (burned, post-fire salvage logged, unburned) for three (2008) and four (2009) years to assess sediment 62-15 concentrations and production. Silins et al. (2008) found that sediment production increased in burned and logged areas, relative to unlogged control sites, and that the rate was strongly mediated by site-specific factors as well as hydro-climatic controls. Silin et al. (2008) further found that sedimentation was exacerbated by two factors. First, the loss of bank vegetation resulted in the loss of bank stability thereby altering the morphology of watersheds. Second, skid trails and other down-slope trails and roads "served as conduits for overland flow and sediment transport" resulting in "increased availability and down slope movement of sediment in burned and salvage logged watersheds" as well as "accelerated sediment transfer and storage in adjacent streams." Silins et al. (2009) further found notable changes in hydrology and the sediment regime of headwater watersheds were associated with wildfire and post-fire salvage logging. The mean annual total suspended sediment concentrations and yields were respectively eight- and nine- times higher than in unburned watersheds. The practice of post-fire logging created more effective sediment transport networks to stream channels and produced more sediment than burned watersheds that were not salvage logged. The increased availability and downslope movement of sediment in burned and salvage-logged watersheds also

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Comment # Comments contributed to sediment transfer acceleration and storage in streams. Smith et al. (2011) reported that sediment exports following post-fire logging in were 71-320 times greater than in burnt and unharvested eucalypt catchments. Smith et al. found that "runoff modelling indicated that the log drag-lines acted as an extension to the drainage network and increased peak flows at the harvested catchment outlet by 48% for a high intensity summer storm event." Further, soil water repellency was more extensive in the burnt and harvested pine plantation than burnt but unlogged control catchments. Wagenbrenner et al. (2015) looked at groundbased extraction (feller-buncher and skidder) in four different post-fire forests in the interior western United States: Tripod, Washington, Red Eagle, Montana, Kraft Springs, Montana, and Hayman, Colorado. Salvage logging occurred in the Red Eagle, Hayman, and Kraft Springs sites a year after burning. These three study areas included burned control and salvage logged sites. Tripod was logged two years after post- fire monitoring, which allowed before and after logging comparisons. Wagenbrenner et al. found that, although sediment production varied widely between plots and years, "Sedimentation production rates from the skidder plots were typically at least two orders of magnitude higher than the values from the control plots. Sediment production from the feller-buncher plots were usually intermediate between the skidder and control plots." Among the various factors influencing sediment production Wagenbrenner et al. found that, "but for a given location and rainfall intensity the key concerns are the amount of soil compaction and the amount of surface cover." The study found slash placed on the skid trails reduced sediment yields. The passage of heavy logging equipment increased bulk densities at depths to 10 cm, which increased soil strength. This increase in density is a potential problem, because larger soil densities may result in increased surface runoff and therefore more sediment. Slesak et al. (2015), which examined skyline logging in southern Oregon three and four years after a fire, found that mean hillslope erosion was significantly greater in logged areas compared to the control. Some additional factors likely contributed to this result. Slesak et al. compared sedimentation rates from non-logged federal lands to logged private lands, which followed harvest with herbicide "site preparation" to remove vegetation that would compete with regenerating conifers. Wagenbrenner et al (2016) examined numerous sites that burned at high severity in northern Montana, eastern Washington, and southern British Columbia. Wagenbrenner and others found that "Across the three sites, rill sediment fluxes were 5-1900% greater in logged plots than the controls in the year of logging." The study concluded that "Our results indicate that salvage logging increases the risk of sedimentation regardless of equipment type and amount of traffic…" Malvar et al. (2017) performed a salvage logging study in a eucalypt forest plantation in north-central Portugal. The objective of this study was to assess the combined effect of wildfire and salvage logging on soil erosion and runoff and the role of key topsoil properties and ground cover characteristics. Three levels of logging disturbance were compared: no disturbance, skid trails by a wheeled forwarder tractor, and skid trails by the same tractor followed by a tracked feller-buncher. Bulk soil density increased with soil disturbance and tended to increase with depth though not significantly. Although logging was performed when the soil was dry, yet soil compaction was observed at least until 10 cm depth. Mean sediment production rates increased with increasing soil disturbance. The sediment rate for the wheeled forwarder tractor disturbance level was 1.5 times higher than the control, and the sediment rate for the feller-buncher disturbance level was three times higher than the control. Garcia-Orenes et

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Comment # Comments al. (2017), which examined groundbased logging in Spain, found that salvage logging resulted in "significant soil degradation," including loss of soil organic matter, likely to do higher erosion rates than the unlogged burned control. Among studies that found logging had a minimal role in sediment production, mitigation measures and site-specific conditions (e.g. slope and precipitation) appeared to be significant. McIver and McNeil (2006), which studied groundbased extraction of fire-killed timber from the Malhuer National Forest in Oregon, found relatively low amounts of sediment movement, however their results were likely influenced by site conditions (relatively erosion resistant soils, low- to moderate- slopes, natural regeneration, favorable weather conditions) and project mitigation measures (logging over snow or dry slopes). In sum, the great preponderance of studies have found that logging-related disturbances 62-16 increase sedimentation relative to the burned but not logged background. Turning to a site-specific examination of the project, multiple project component cause concern. First, post-fire logging is likely to create ground disturbance, compaction, loss of soil cover, and impaired natural regeneration—all factors identified in previous studies as impacting sedimentation rates. The project includes both groundbased tractor logging systems and partially suspended cable systems, two types of logging identified by the scientific literature as more impactful than other forms, such as fully suspended cable and helicopter yarding. (See Klock, 1975; Chou et al., 1994; Chase, 2006)....The project includes 355 acres of ground-based "tractor" based logging systems. EA at 8). Trees will be felled by a feller-bunchers and logs will be skidded by a rubberwheeled skidder tractor. Both require heavy machinery that will compact and disrupt the ground. Wagenbrenner et al. (2015) found that skidders plots produced sediment at two orders of magnitude higher than controls while feller-buncher plots produced sediment at a rate in between skidder and control plots. The difference between skidder and feller-buncher sediment rates is likely because skidders generally work perpendicular to the slope, dragging logs to landings, while feller-bunchers will create tracks both perpendicular and parallel to the slope. Malvar et al. (2017) found similar results, as discussed above. As Chase (2006) and Silins et 62-17 al. (2008) found, skid trails and other disturbances that run with the slope will help to channelize waterflow, both increasing sediment through rill creation and accelerating the delivery of sediment. Skyline logging will total some 495 acres. (EA at 8). These areas are to be felled by hand and yarded by partial-suspension cable skylines. (EA at 30). In partial- suspension yarding, one end of a tree (or trees) touches the ground while the other end is in the air. Klock (1975) found the disturbance levels between skyline and tractor skidding to be fairly similar, however skyline units will not also be impacted by feller-buncher tracks. Although Klock (1975) did not examine sediment production, Slesack (2015) found higher levels of sediment coming from skyline units than control. The remainder of units, 479 acres, are to be helicopter logged. (EA at 8). Helicopter logging should produce the least ground disturbance. Additionally, the project proposes 39 miles of roadside hazard tree removal. The total acreage of roadside hazard tree removal is not provided. Roadside hazard tree removal will utilize both ground-based and skyline methods. Although the EA doesn't state it, it is also conceivable that timber operators may use winching to drag trees, particularly in steep areas, to the roadside. Winching is likely to produce similar disturbance to skyline yarding as winched trees will drag on at least part of the ground. Logging will further require the creation of new landings 8 new landings. Landing require

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Comment # Comments extensive soil disturbance as heavy machinery is used to create a relatively flat log deck to stack felled trees. After logging, all logging units will undergo "site preparation." Site preparation will include both treatment of logging slash as well as the removal of returning vegetation. In Slesak 62-20 (2015), site preparation was thought to be a major contributing factor in increased sedimentation rates. As shown above, the background conditions are significantly degraded from the fire and from previous land management decisions and that post-fire logging is likely to further degrade these conditions by adding an additional significant disturbance. In their CWE modeling, the Forest Service admits that logging will increase sediment pollution in areas already above the "threshold of concern."...For each of the three models utilized by the Forest Service, the Seiad Project will place a 7th-field watershed above the "threshold of concern," indicating concern that the project will adversely impact beneficial uses in a watershed....In the ERA model, which provides an estimate on the scale of a disturbance by comparing the disturbance to "equivalent roaded acres," all three 7th-field watersheds affected by the project within the 6th-field Horse Creek watershed exceed their threshold of concern. In West Fork Horse Creek, the project is modeled to increase ERA by 22 acres, which in relation to the percent of the total drainage of the watershed is ~.6%, raising the total cumulative percent of the drainage as to 9.8% while the "threshold of concern" for the watershed was only 6.0%. (EA at 73). In Middle Horse Creek, the project is modeled to increase ERA by 27 acres, which in relation to the percent of the total drainage of the watershed is .8%, raising the total cumulative percent of the drainage as to 9.2% while the "threshold of concern" for the watershed was only 7.0%. (EA at 73). Salt Gulch shows the most extreme increase: the project is modeled to increase ERA by 31 acres, which in relation to the percent of the total drainage of the watershed is 1.3%, raising the total cumulative percent of the drainage as to 9.8% while the "threshold of concern" for the 62-22 watershed was 8.5%. (EA at 73). In the GEO model, which predicts landslide sediment, in Salt Creek, the project is anticipated to increase landslide cubic volume by 2.5%. In doing so, the post-project cumulative landslide volume will be increased 233% over background levels—33% over the stated threshold of concern. (EA at 73). Although neither West Fork Creek or Middle Fork Creek is projected to be over the threshold of concern, both are near it as a result of the project, as West Fork Horse Creek will have an increase of 190% over the background and Middle Horse will experience a 176% increase over background. (EA at 73). Finally, turning to the USLE model, despite the flaws identified in subsection I(D) below that would cause the model to underestimate sediment production, the model still shows that both West Fork Horse Creek and Salt Gulch will exceed the threshold of concern. As a result of the project, in West Fork Horse Creek sediment is expected to increase 9.7% over the background, bringing the total sediment loss 83% above the threshold of concern. (EA at 74). In Salt Gulch, the project is expected to increase sediment production by 3.8% over background, bringing the total sediment loss 130% over background. (EA at 74). Cumulatively, the Forest Service anticipates that the project would result "[i]n the short-term (2 to 10 years) sedimentation to streams could be increased by approximately 2,000 cubic yards…" (EA at 79). The "special status aquatic species in the Horse Creek watershed would be adversely affected by indirect effects of the Project…" (EA at 80). In light of the changes to the watershed, the Forest Service concludes: "In the short-term (2 to 10 years), ground disturbing project elements that would increase

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Comment # Comments sediment delivery to streams would be adversely cumulative with current high cumulative watershed effects and excessive sedimentation in the Horse Creek Watershed." (EA at 80)....Like in Horse Creek, for each of the three CWE models utilized by the Forest Service, the Seiad Project will place a 7th-field watershed within the 6th-field Seiad Creek watershed above the "threshold of concern," indicating concern that the project will adversely impact beneficial uses in a watershed. In the ERA model, East Fork Seiad Creek is anticipated to be almost two times above the threshold of concern. The model projects that the project will result in 13 equivalent roaded acres, which in relation to the percent of the total drainage of the watershed is .5%, raising the total cumulative percent of the drainage as to 12.8% while the "threshold of concern" for the watershed was only 6.5%. (EA at 73). In the GEO model, which predicts landslide sediment, in East Forest Seiad Creek, the project is anticipated to increase landslide cubic volume by .9%. In doing so, the post-project cumulative landslide volume will be increased 204% over background levels— 33% over the stated threshold of concern. (EA at 73). Again, despite the flaws identified in subsection I(D) below that would cause the model to underestimate sediment production, the USLE model still shows that East Fork Seiad Creek is expected to increase 1% over the background, bringing the total sediment loss 51% above the threshold of concern. (EA at 74). In light of all the project impacts, the EA concludes: Project element related disturbance in the East Fork Seiad Creek 7th-field watershed, which is well over threshold in the ERA model, would likely increase adverse effects to aquatic and riparian habitats in this sub-watershed in the short-term. Therefore, special status aquatic species which occur in this watershed could be adversely affected by indirect effects in the short-term… (EA at 80). The Forest Service estimates sediment pollution from surface runoff through the Universal Soil Loss Equation (USLE). Although the model found large increases in sediment production in some areas, particularly in West Fork Horse Creek (an increase of ~9.7%), EPIC questions whether the USLE model has been calibrated for use in post-fire logging project. As the discussion of post-fire logging case studies makes clear, the sediment production associated with post-fire logging is often multiple times greater than fire alone. (See Wagenbrenner et al., 2015 ("Sedimentation production rates from the skidder plots were typically at least two orders of magnitude higher than the values from the control plots. Sediment production from the feller-buncher plots were usually intermediate between the skidder and control plots."). The accuracy of any model depends on (a) the ability of the model to account for effects of the physical phenomena causing the output 62-23 and (b) the accuracy to which the parameters have been determined. As one recent article found, the USLE model is "the most widely used, and misused, soil loss estimation equation in the world" (Kinnell, 2010). The USLE model was initially developed using agricultural soil loss data first gathered during the Great Depression and was originally used to predict soil loss from agriculture. It has since been expanded to various other applications. The model has been refined throughout the years, including the creation of the Klamath Universal Soil Loss Equation (KUSLE), described in Elder and Reichert (2004), and is presumably the model used in the Draft Hydrology Report. Bell (2012) reports the KUSLE model works as such: Sediment Delivered (yrd3/ac/yr) = [(0.7)*??*??S*??*??*??] x A A = Area (acres) of polygon; 0.7 = conversion factor (tons to yd3); R = Rainfall/runoff factor (what is a 2 year rain event); D = Delivery factor (what % of sediment will be delivered); C = Cover factor (related to disturbance class); LS = Slope-length/slope

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Comment # Comments steepness factor; K = Soil erodibility factor (related to Soil Map Unit). Bell (2012) notes that many project activities pertinent to our analysis of the Seiad Project are typically captured by the model, including but not limited to: "New road construction—'temporary' or otherwise"; "New or enlarged landing construction"; "Other fuel treatments associated with timber sales"; and "Wildfire - 'high' and 'moderate' burn intensities." However, many activities specific to this project that are likely to generate sediment pollution are not typically modeled, including but not limited to: "Re-opening existing roads"; "Skid trails"; and "Re-opening existing landings." It is particularly alarming that the model fails to capture impacts from skid trails (and presumably feller-buncher trails), as multiple studies have found that skid trails and other similar disturbances are likely responsible for significant increases in post-logging sediment production and delivery, as these disturbances help to channelize waterflow, both increasing sediment through rill creation and accelerating the delivery of sediment. (Wagenbrenner et al., 2015; Malvar et al., 2017; Chase, 2006; Silins et al., 2008). In sum, the USLE model gives reason for pause and concern. Even in its flawed state, it suggests that numerous 7th field watersheds are near, at, or above their thresholds of concern. Furthermore the project is likely to add to this latent background risk, although the model likely fails to capture the increased risk from the project. In addition to fine size surveys, the Forest Service estimates future conditions and project effects through three cumulative watershed effects (CWE) models: the Equivalent Roaded Acres (ERA) model is used to evaluate watershed disturbance; the Universal Soil Loss Equation model (USLE) is used to evaluate soil erosion; and the Geology model (GEO) is 62-27 used to evaluate the potential for mass wasting. The project drains to two 6th field watersheds, Seiad Creek and Horse Creek. Both sediment assessments and CWE modeling suggest that the project area is severely degraded and is likely impacting salmonids and other aquatic species. The EA admits that Horse Creek is adversely impaired and its likely not properly functioning. On Horse Creek, the EA states, "[b]ased on high degree of hillslope and inner gorge disturbance from roads and past and stand-replacement fires and forestry it is assumed that current sediment production and delivery to streams is much greater than pre-European settlement rate. (Aquatic Resources Report at 27, internal citation omitted). Recent fires and post-fire logging have worsened the watershed's condition: The 2016 Gap Fire and the 2017 Abney Fire is expected to further increase already excessive sedimentation, as is extensive salvage logging on private lands that has occurred and is ongoing subsequent to the Gap Fire. Based on past experiences with large storm events on large burned areas it is reasonable to expect an increase in the rate of mass wasting during 62-28 future wet weather events. (Aquatic Resources Report at 27, internal citation omitted). Thus, as a result of previous disturbances, including fire and post-fire logging, mainstem Horse Creek is significantly impaired: Results of 2010, 2013, and 2017 assessments of sediment quantity and quality in mainstem Horse Creek are shown in Table 8 below. Substrate quality impairment was evaluated in mainstem Horse Creek by comparing four sediment indicators in mainstem Horse Creek (a managed watershed) to the 85th percentile value for reference streams that have minor to negligible management-related watershed disturbance. Managed watersheds exceeding the 85% percentile of reference streams may have impaired watershed function. In 2010 and 2013 field assessments, three of the four sediment indices in lower mainstem Horse Creek exceeded reference values as

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Comment # Comments shown in Table 8. In the 2017 field assessment, two of the four indices exceeded reference values. (Aquatic Resources Report 28)....EPIC assumes that the sediment assessment was completed before the 2017 Abney Fire and therefore does not capture sediment inputs attributable to the changed watershed conditions caused by the fire. Even so, the sediment conditions are alarming. Fine sediment (< .85 mm) exceeds 13%, the number found by McHenry et al. (1994) and Barnard (1992) as resulting in almost complete egg mortality and the 10% found by Jensen et al. (2009). In 2010 and 2013, pool filling values likewise exceed the V star values associated with "not properly functioning" habitat, as described by the Forest Service in their Aquatic Resources Report. Similarly, Middle Creek showed alarming sediment levels when last surveyed: (Aquatic Resources Report at 29). Again, fine sediment (<0.85) greatly exceed values associated with significant mortality. Here too, the pool filling (V star) exceeded values the Forest Service associated with "not properly functioning habitat." The project area includes are three 7th field watersheds that are part of the 6th field Horse Creek watershed: West Fork Creek, Middle Horse Creek, and Salt Gulch. Again, the EA discloses that these watersheds are likewise impaired: Cumulative watershed effects modeling results suggest that watershed function is being adversely impacted by high levels of watershed disturbance. Cumulative watershed effects model risk ratios greater than 1.00 indicate an elevated risk ("yellow flag" warning) of adverse impacts to watershed function including altered flow and sediment regimes. Results of cumulative watershed effects (CWE) analysis for Horse Creek show that: (1) the Middle Creek 7th-field watershed is over the threshold of concern in one of the CWE models and highly elevated in the other two CWE models, (2) the Salt Gulch 7th-field watershed is at the threshold of concern in one CWE model and over the threshold of concern in the other two CWE models, and (3) the entire Horse Creek 6th-field watershed is over the threshold of concern in two of the CWE models and near threshold in the third CWE model. (Aquatic Resources Report at 29, emphasis added, internal citations omitted). The evidence presented above all confirms that all three 7th-field watersheds within the project area are not meeting their beneficial uses. Further, mainstem Horse Creek is likely not meeting its beneficial uses. Project impacts would further move the watershed away from attaining its beneficial uses. Seiad Creek "The Seiad Creek 6th-field true watershed provides habitat for SONCC Coho salmon, UKTR Chinook salmon, KMP steelhead, resident rainbow trout, lamprey and other native fish, reptile, amphibian, mammal, and bird species." (Aquatic Resources Report at 33). The Seiad Creek watershed is likely sediment impaired as well. The EA provides: Based on high degree of hillslope and inner gorge disturbance from roads and past and stand-replacement forestry it is assumed that current sediment production and delivery to streams is greater than pre-European settlement rate. The 2017 Abney Fire is expected to further increase sedimentation. (Aquatic Resources Report at 33). Like Horse Creek, surveyed sediment levels in Seiad Creek were elevated: Fine sediment levels (<.85mm) were above 13% should cause considerable alarm. The entire Seiad Creek 6th field watershed is over the threshold of concern for the equivalent roaded acres (ERA) model. (EA at 69; Aquatic Resources Report at 29). Three of Seiad Creek's 7th field watersheds, East Fork Seiad Creek, West Fork Seiad Creek, and Middle Seiad Creek, are within the project boundary. Turning to the CWE modeling, East Fork Seiad Creek is over the threshold of concern in all three CWE models. (Aquatic Resources Report at 29). The evidence presented above all confirms that, at a minimum, East Fork Seiad Creek, is currently experiencing significant environmental impacts. It is

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Comment # Comments likely that, after impacts from the 2017 Abney Fire, mainstem Seiad Creek and other tributaries to Seiad Creek are likewise not meeting beneficial uses. Project impacts would further move the watershed away from attaining its beneficial uses and are therefore "significant" for the purposes of NEPA. The Seiad-Horse project threatens the ecological, recreational and scenic values of this 71-3 remarkable region. Water quality, wild salmon, wildlife and wild places like the Johnny O'Neil LSR deserve 71-4 better. Please reconsider your plan to conduct post-fire logging in the Siskiyou Crest area. The 111-1 Seiad-Horse project has been poorly planned and does not fully take into consideration the true impact to the watersheds involved. The Seiad-Horse project threatens the ecological, recreational and scenic values of this 148-6 remarkable region. Water quality, wild salmon, wildlife and wild places like the Johnny O'Neil LSR deserve better. Logging the fire-affected watersheds the of Siskiyou Crest will dislodge more silt into the tributaries of the Klamath, which is already more silted than is good for the salmon. And of 231-1 course that silt comes from the washing away of good topsoil which takes hundreds of years to replace. I have lived in this area since 1972 and I have to say that the logging that has been done in northern California has ruined wildlife habitat, streams, rivers, the salmon and all manner 368-1 of watersheds. Do not log this steep hillside, it would cause huge amounts of sediment to flow into the several creeks.

Comment Response #77: Watershed Effects Analysis Concern statement: There are concerns that landing building, temporary road building, unit location and road density were not analyzed for sedimentation and watershed concerns. Commenters would like to see all actions on unstable lands be canceled. Forest Service Response: All of the activities of concern listed were analyzed as part of the CWE model runs, and are discussed at length in the Geology Report, Aquatic Conservation Strategy analysis (EA, Appendix C), and the Effects Related to Hydrology portion of the EA (pages 67 to 77). Ground- based equipment is restricted from unstable lands, except where existing landings are located near Seiad Creek where designs are in place to control erosion (the cable corridor over active features issue is no longer relevant as unit became a helicopter unit). Removal of large fire-killed trees via hand fellers, and helicopter yarding followed by replanting conifers, are the only treatments permitted on unstable lands. Otherwise natural tree fall would result in tree throw (the disturbance caused by roots being pulled from the earth) which allows for water infiltration at the site, and the loosening of soil as the tree roots were pulled out. By removing dead trees before they fall, and replanting of conifers, the duration that a slope will be unstable as a result of fire will be greatly reduced. The low ground disturbance caused by hand felling and helicopter yarding is negligible when compared to the net disturbance and sediment delivery that would be accrued over a longer duration of the absence of conifers and the accompanying slope instability.

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Associated Comments: Comment # Comments Please note that page 20 (Geology PDF 1) of the EA indicates that the agency intends to conduct road construction in potentially "unstable land riparian reserves." Page 21 of the EA (Geology PDF 4) allows a Forest Service Geologist to override unstable land riparian reserve protections at his or her discretion. Page 30 of the EA (Watershed PDF 20) allows 49-54 the Forest Service Geologist to authorize cable corridors through unstable lands. Yet the reader, the timber sale ID Team, and the decision maker cannot know if, where or when such actions might occur. Further, the impacts of such actions are not discussed or analyzed in the EA. Both action alternatives allow the Forest Service Geologist to authorize cable yarding 49-115 corridors through unstable lands. (EA page 30). Post-fire logging units on schist soils and on historic landslides or earthflows should be 53-225 canceled. The Thompson/Seiad/Grider Environmental Assessment provides a map depicting "Post Analysis Riparian Reserve Components" this map shows active landslides, toe zone of 70 dormant landslide, inner gorge developed in unconsolidated deposits, etc. Many of these 53-229 features are found within treatment areas (USDA 1999b. figure 5-2). The Horse Creek Watershed Assessment also displays these features within proposed post-fire logging units All of these features should be buffered from post-fire logging (USDA, 2002. figure 3-3). The agency failed to adequately analyze or disclose the risk of debris flows and sedimentation associated with post-fire logging, road construction and landing construction on steep landslide prone slopes, schist soils, and geologically unstable areas. 53-233 Both streams are listed for turbidity and temperature. The impacts to soils will contribute significantly to issues of turbidity and temperature in the Horse Creek and Seiad Creek watersheds. This will in turn, effect the coho salmon habitat downstream. The EA failed to disclose and analyze the current road density and its impact on sedimentation in the Horse and Seiad Creek watersheds • The EA failed to disclose and analyze the recommendations in Watershed Assessments to reduce road density in LSR to less than two miles per square mile. The proposed action will increase road related impacts. • The EA failed to disclose and analyze the elevated level of risk to mass wasting 53-239 and surface erosion posed by post-fire logging, new road and landing construction. • The EA failed to disclose and analyze the cumulative impact of proposed post-fire logging, road building, discretionary fire suppression activities, past timber harvest, current timber harvest on soil resources, erosion rates, surface erosion rates, mass wasting and water quality. 23. The EA failed to disclose and analyze the development of new landings and logging infrastructure on soil resources, water quality and other environmental concerns. The EA failed to adequately analyze the impact of new road and landing construction landings in the planning area on water quality and surface erosion. • The EA failed to 53-243 disclose and analyze the elevated level of risk to mass wasting and surface erosion in affected watersheds. In fact, unit 37 may contain the largest, most concentrated network of riparian reserves of any proposed logging unit. In many places, the distance between riparian reserves is 53-271 relatively minor, forcing the unit into a narrow strip of land between headwater streams. The impact of logging these narrow strips on water quality could be quite severe given the highly erosive schist soils.

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Comment # Comments am very concerned that you want to log steep slopes which will contribute to destabilizing 453-1 these area plus impact a number of creeks and the Klamath River.

Comment Response #78: Siskiyou Crest as a Regional Connectivity Corridor Concern statement: There is a concern about the effects the proposed actions may have on the biological diversity, ecological function, and connectivity provided by the Siskiyou Crest. This concern commenters share is that the Siskiyou Crest is a unique area providing a regionally important habitat connectivity corridor for species which contributes to the area's high level of biodiversity. Commenters stated that the scale, location, and configuration of proposed salvage units will create large, structurally simplified openings lacking biological legacies that will impede the migration and movement of management indicator species, late-successional associated species, and snag associated species including Pacific fisher, northern spotted owl, wolverine, and marten. There is disagreement regarding the sufficiency of the analysis presented regarding connectivity and biodiversity, including the contention that using a focal species for analysis has significant limitations. Commenters further state that these activities are inconsistent with the Forest Plan standards and guidelines and watershed assessment guidance for maintaining and restoring connectivity. Forest Service Response: Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. These public comments in addition to the public comments received during scoping expressed concern about habitat connectivity among other concerns. In response to those concerns about habitat connectivity along the Siskiyou Crest, Alternative 3 was developed to reduce project actions near the ridge along the northern portion of the Seiad Horse project area. Alternative 3 eliminates salvage harvest within one mile of the ridgeline, Further, to more specifically address the concern about habitat connectivity, an analysis indicator called “Habitat Connectivity” was developed to measure the effects of salvage harvest along with the other project actions on habitat connectivity for species that rely on vegetation cover to move across their home-ranges (Biological Evaluation, page 15). Analysis scale is an important component that is often dependent on the purpose of the analysis. The Habitat Connectivity analysis section of the Biological Evaluation discusses the use of the California Essential Habitat Connectivity Project relative to the Seiad Horse project (Biological Evaluation, page 4). The California Essential Habitat Connectivity Project was developed by the California Department of Fish and Wildlife and the California Department of Transportation for large-scale (regional) habitat connectivity planning and is subject to additional analysis if used at a smaller scale (e.g. project scale). Although the larger scale analysis provides a coarse scale assessment that is useful for regional or statewide scale planning, this large scale does not necessarily reflect the spatial scale used by individuals of a particular species (e.g. home-range) or the resulting effects to habitat connectivity as a result of project. For the fisher, marten, and wolverine that are analyzed in the Wildlife Biological Evaluation, the 7th field watershed scale was used for the analysis because it is a biologically relevant scale for individuals of those

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species to move across their home-ranges. Vegetation cover that provides the basis for habitat connectivity is identified at the project scale. Consequently, habitat connectivity was estimated for all the 7th field watersheds that contain proposed project actions and the analysis was designed to measure the smaller scale effects of the project on habitat connectivity. Habitat is defined by biotic and abiotic features that are used by a particular species to meet the needs for survival and reproduction. Fire can create dramatic changes in the habitat by altering the vegetation composition in a particular area and consequently, the fire may result in some areas becoming inhospitable as determined by the species of interest. Like fire, salvage harvest can further change the vegetation structure, but without context of particular species, it is incorrect to identify salvage harvest or any other project action as creating inhospitable conditions. For fisher and marten, fire can remove important habitat components that can affect habitat connectivity like live tree canopy cover which is described in the Wildlife Biological Evaluation (pages 12 to 14). Salvage harvest is proposed in various unit sizes and configurations. As described in the Wildlife Biological Evaluation, the size of the “openings” and the amount of residual woody debris, snags, or live vegetation can influence the potential movements of fisher and marten. Prayer and Harrison (2000) studied the effects of land management on marten in Maine. The authors examined the difference in marten use of forest experiencing spruce budworm that defoliates the trees and land management that removed all the trees (i.e. clearcut). The authors found that marten avoid clearcuts but marten were found in stands affected budworm. Stands affected by budworm had more snags, downed logs, and root masses and included taller trees when compared to clearcut stands which suggests that these structures are important. This physical vegetation structure is likely an important component for fisher and marten use because trees/snags can provide vertical structure while woody debris can provide cover along the ground. The Seiad Horse Project added snag retention areas in the salvage harvest units that will retain more snags and coarse woody debris in the units to reduce the potential effects to fisher and marten. Further, the Seiad Horse Project will retain patches of snags in Riparian Reserves. The acres of Riparian Reserves in salvage units are only being counted once in the analysis for habitat connectivity in the Wildlife Biological Evaluation. Additional snags may be retained due to implementation constraints as well that may increase the number of snags within a given area beyond the planned snag retention areas and Riparian Reserves. The culmination of the various tree/snag retention results in reducing the size of openings. The habitat connectivity analysis in the Biological Evaluation is a measure of opening size created within the existing vegetation that provides enough cover for fisher, marten, and wolverine to move across their home range (page 17). Although habitat connectivity is more accurately described in a spectrum of “more” or “less”, habitat connectivity is described in the analysis using three levels of habitat connectivity: “high”, “moderate”, and “low” habitat connectivity (Biological Evaluation, page 17). These levels of habitat connectivity are intended to measure the relative change in the size of openings in a watershed. Using the basic principle that a watershed with large openings would create conditions that likely are more challenging than a watershed with small openings for a fisher, marten, or wolverine to move across their home range. Therefore, watersheds with low habitat connectivity contain larger openings on average and individuals in those watersheds will likely have more difficulty moving across their home range when compared to watersheds with a high level of habitat connectivity (small openings).

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There are other species beyond just fisher, marten, and wolverine that benefit from Riparian Reserve and other snag retention areas including survey and manage species and Forest Service sensitive species. Habitat connectivity analysis was not specifically completed for every species considered in the environmental assessment (EA) and Wildlife Biological Evaluation, as this was judged to be not only unnecessary but also impracticable due to the wide variety of species and the scale at which each species would need to be analyzed. For example, a connectivity analysis for a mollusk species would be conducted using a small scale of square feet of habitat affected as compared to the scale needed for fisher of hundreds of acres or square miles. Thus a connectivity analysis at the larger scales used by fisher, marten and wolverine was conducted in order to capture a meaningful measure of habitat use that could be extrapolated to species with smaller scale habitat needs. Therefore, the connectivity analysis for fisher, marten, and wolverine and the logic behind the assumptions in the Wildlife Biological Evaluation provide estimated effects to many more species that could occur in the analysis area. Given the activities proposed and the limitation that openings between patches of habitat pose to fisher, marten and wolverine (to a much lesser degree for wolverine) to move through the landscape, habitat connectivity for the fisher, marten, and wolverine can still provide an estimate of connectivity for many other species. Therefore, the habitat connectivity analysis done for fisher, marten and wolverine represents a reasonable estimate for the level of habitat connectivity for many other species that rely on vegetation cover to move across the landscape. Associated Comments: Comment # Comments The habitat is vital and part of forest management plan to connect upper Applegate 5-4 watershed with Klamath watershed. 25-1 This significant ecological values, particularly connectivity for wildlife. Of special concern to our organizations is the proposal to implement unit salvage logging units on the Siskiyou Crest in the Late Successional land use allocation. The Siskiyou Crest is crucially important for wildlife connectivity and due to the checkerboard land ownership 49-6 pattern on the Klamath National Forest. The Siskiyou Crest serves as a regionally important genetic and migratory link between the Cascade and Siskiyou Mountains at the ecosystem/landscape sale. In our scoping comments of January 4, 2018 we requested that project planners please address the unique regional wildlife connectivity values provided by the Siskiyou Crest in project planning. In particular, we asked the Forest Service to disclose the impacts of 49-8 proposed high-elevation snag removal in the LSR on the ability of Management Indicator Species, Late-Successional Associate Species, and Snag Associated Species to move and traverse through the landscape. The Seiad-Horse Salvage Logging EA largely failed to conduct the requested analysis. Both Forest Service logging alternatives increase the size of openings in the West Fork 49-117 Horse Creek Watershed and "change the habitat connectivity level from moderate to low in the short-term." (EA pages 85-86.) As acknowledged on page 3 of the Wildlife Biological Evaluation, "[t]he primary goal of 49-127 forest management is to avoid or minimize impacts to species whose viability has been identified as a concern." Yet in this LSR timber sale, the KNF is removing post-fire habitat

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Comment # Comments that it knows to be use to a variety of FS Sensitive Species, with the LSR land use allocation. Page 4 of the Wildlife BE indicates that "[w]ithout connectivity, wildlife movements can be inhibited possibly affecting individual's movement or possibly isolate a population." Yet pages 84-86 of the EA state that the project "contains portions of the identified Essential Habitat Connectivity area" and that both logging alternatives "increase the size of openings in West Fork Horse Creek Watershed" and "change the habitat connectivity level from moderate to low in the short-term." Hence the "primary goal of forest management" is not achieved by the agencies logging proposal. The Klamath National Forest Resource Management Plan states that: (5-8): Monitoring will address rare and declining species - classified as ... FS sensitive species ... monitoring for the type, number, size and condition of special habitats over time will provide a good indication of the potential health of special habitat-dependent species. Although all special habitat areas do not support rare species, there is overwhelming evidence that special habitat types are closely related to the continued existence of certain rare species. Since many rare species are associated with riparian habitats, the RR system offers potential protection. ... It is also important to recognize that many species' habitat requirements vary considerably with age or side of the individual, and with the season. The area is also a regionally important connectivity corridor allowing genetic diversity to flow through the Siskiyou Mountains to the Coast Range, Cascade Mountains, Oregon 53-7 Interior Valley habitats, the Great Basin and the California Floristic Province. This important connectivity corridor will be significantly impacted by post-fire logging, the removal of biological legacies and plantation development on the Siskiyou Crest. The Siskiyou Crest and the specific region proposed for logging by the KNF also provides highly important connectivity habitat. This habitat is becoming increasingly important for species dispersal and migration associated with climate change. The connectivity of the 53-22 Siskiyou Crest is important on a national and regional scale, meaning impacts to habitat connectivity associated with the Seiad Horse Project will have disproportional impacts throughout the Pacific Northwest and California. The EA failed to adequately disclose or analyze the unique biological diversity, habitat 53-43 connectivity and ecological function of the Siskiyou Crest. We submit Olson et al 2012 to support our contention that connectivity and complexity 53-46 should be maintained on the Siskiyou Crest by canceling all post-fire logging units in upper Horse and Seiad Creek. The Seiad Horse Risk Reduction Project proposes to impact the globally significant 53-47 biodiversity of the Siskiyou Crest and the Cook and Green Pass region. The biological values in the area are particularly high and the Seiad Horse Project threatens to sever this unique and important hub off connectivity found in upper Horse 53-49 and Seiad Creek. The impact to regional and localized connectivity was not adequately analyze in the Seiad Horse Risk Reduction Project EA. Connectivity for late successional forest associates such as the Pacific fisher, northern spotted owl, wolverine and marten could be severed by large, interconnected post-fire 53-50 logging units that render habitat unsuitable. This large, swath of structurally simplified openings created by post-fire logging has the potential to disrupt the east-west flow of connectivity across the Siskiyou Crest. It also has the potential to disrupt important habitat

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Comment # Comments linkages between the eastern Siskiyou Crest, the Red Buttes Wilderness, Siskiyou Wilderness, Marble Mountains Wilderness and the Trinity Alps. Units have been proposed that extend north to south across this east-west corridor, cutting the corridor in two near Copper Butte. These units would reduce the already 53-51 significant bottleneck in connectivity at the headwaters of Horse Creek from two miles wide to less than ¼ mile wide. According to the Seiad Horse EA, structurally simplified clearings greater than 160' wide will be avoided by the Pacific fisher, marten and wolverine. Clearings this wide and much wider will be created by the KNF north to south across the east-west, Siskiyou Crest Connectivity Corridor disrupting wildlife movement and habitat connectivity. Proposed post-fire logging units are located in uninventoried roadless areas surrounding the Condrey Mountain IRA. These intact habitats contribute to connectivity by providing complexity and intact biological legacies. The forests targeted for post-fire logging, contain 53-52 some of the last, complex structural conditions in the West Fork of Horse Creek and the East Fork of Seiad Creek. Although they burned at mostly moderate and high severity, these snag forests currently contribute to landscape connectivity, habitat complexity and forest regeneration by providing large diameter snags and downed wood. These biological legacies have been largely eliminated from much of Horse Creek and the East Fork of Seiad Creek, due to historic and ongoing logging, wildfire and post-fire logging. Logging these last biological legacies will fragment the remaining corridor of intact habitat on the southern face of the Siskiyou Crest. All units with two miles of the summit of the Siskiyou Crest should be canceled to reduce 53-53 impacts to connectivity. New research by Theobald (2012) suggests that analysis of connectivity using focal species 53-55 (as was done in the Seiad Horse EA) has significant limitations. Post-fire logging in this important connectivity corridor will degrade habitat conditions and impede connectivity through the Siskiyou Crest region. The Seiad Horse Risk Reduction Project EA fails to demonstrate how the proposed post-fire logging activities will "maintain or restore migration routes and the connectivity of the landscape to allow for species dispersal." NEPA analysis must address the unique regional connectivity values provided 53-63 by the Siskiyou Crest and the impact of high elevation post-fire logging on the important ecological attributes of the Siskiyou Crest, the climate refugia it provides and the cumulative impact of the Seiad Horse Risk Reduction Project to the region's many important biological values. Analysis in the Seiad Horse EA is insufficient and inadequate. The actual values at risk were not disclosed and the actual impacts were not analyzed using the best available science. The EA failed to adequately disclose or analyze the impact of the proposed project on the Siskiyou Crest Connectivity Corridor. • The EA failed to disclose or analyze the current bottleneck for connectivity on the Siskiyou Crest in the Horse Creek area due to clearcut 53-66 logging, road building and post-fire logging on industrial timberlands. The impact of logging and reforestation in this bottleneck must also be disclosed and analyzed with a full EIS analysis. The EA failed to adequately disclose and analyze the impact of post fire logging on habitat 53-67 linkages between the Condrey Mountain IRA, the Kangaroo IRA and the Red Buttes Wilderness Area.

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Comment # Comments The EA failed to adequately analyze or disclose the impact of post fire logging on habitat linkages for late successional forest associates between northern California and southern 53-68 Oregon. Critical Habitat Units and two Late Successional Reserves were designated to protect these habitat linkages and the viability of late 25 successional forest associates may depend on the connectivity within the planning area. The EA failed to demonstrate compliance with Klamath National Forest Plan Standard and Guideline 6-14 page 4-23 by maintaining or restoring connectivity. • The EA failed to adequately disclose or analyze the limitations of connectivity analysis using focal species rather than "ecological integrity or "naturalness." • The EA failed to adequately disclose or analyze the impact of post-fire logging and the creation of large, structurally deficient openings on habitat linkages connecting large intact landscapes or Natural Landscape 53-69 Blocks. • The EA failed to disclose or analyze the potential barrier to east-west connectivity across the Siskiyou Crest posed by the Seiad Horse Project. Unit configuration, density and size contribute to this potential impact and were not adequately analyzed in the EA. 6. The EA failed to disclose or analyze the role the Siskiyou Crest plays in species dispersal in light of climate change. The EA also failed to disclose and analyze the impact of post-fire logging on climate refugia on the Siskiyou Crest. Species requiring "cool, moist" habitats will utilize high elevation corridors such as the Siskiyou Crest for dispersal to new habitats. Species requiring isolation from human 26 impacts such as the wolverine, marten, Pacific fisher, wolf, and Roosevelt elk will also disproportionally utilize the Siskiyou Crest for dispersal and migration. The Siskiyou Crest is one of the only geographic features in the region that allows species to migrate from 53-70 mountain range to mountain range without encountering large low elevation barriers to species dispersal. It is also one of the only locations that species can migrate in relatively undisturbed habitat from east to west or vice versa. These important features could be significantly impacted by the Seiad Horse Risk Reduction Project and were not adequately address in the Seiad Horse EA. Olson etal 2012 identifies "non-climate" related stressors as potential impacts to connectivity. These stressors include logging and road building. The study is highly relevant 53-71 to analysis in the Seiad Horse Risk Reduction Project where high elevation postfire logging is proposed within a major connectivity corridor. Post-fire logging will also create a barrier for connectivity in high elevation and cool, moist habitat types and microclimates. The opening of forest stands and the reduction of complexity associated with post-fire logging will impact connectivity on the Siskiyou Crest near the Condrey Mountain IRA and Kangaroo IRA. The Seiad Horse EA demonstrates that openings over 160' wide, with little structural complexity will hinder the movement of 53-78 species like the Pacific fisher, wolverine and marten. By restricting the movement of species and disrupt dispersal, these simplified openings will impact large patterns of connectivity across the landscape. Post-fire logging will reduce the quality 28 and quantity of available habitat for cool, moist habitat associates, it will also impact their dispersal or connectivity habitat across the Siskiyou Crest. Units 35-39 should be canceled to maintain landscape connectivity, retain cool, moist 53-90 microclimates and facilitate habitat conditions conducive to the regeneration of montane species adapted to cool, moist climatic patterns.

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Comment # Comments The EA failed to disclose or analyze the role of the Siskiyou Crest in facilitating 31 species 53-91 migration in response to climate change. The EA failed to provide spatially explicit connectivity corridors across the Siskiyou Crest including corridors or islands of montane habitat and cool, moist conditions. Analysis of 53-93 connectivity and climate refugia is inadequate and incomplete without the identification of specific connectivity corridors in the planning area. The EA failed to adequately consider the findings of Olson etal. 2012 when analyzing connectivity, climate change, and the retention of "cool, moist" habitat conditions. • The 53-95 EA failed to consider the findings of Theobald (2012). • The EA failed to consider the findings of the California Essential Habitat Connectivity Report and did not adequately analyze the potential impacts to the connectivity corridors on the Siskiyou Crest. The EA failed to disclose or analyze the significant bottleneck or "pinch point" in 53-97 connectivity on the Siskiyou Crest in the Horse Creek/Seiad Creek area. The Seiad Horse Project proposes post-fire logging in the Siskiyou Crest Connectivity Corridor. The exact location of the proposed Siskiyou Crest units is troubling. The units are located 53-98 in the most significant bottle neck or "pinch point" for connectivity on the entire Siskiyou Crest. The Seiad Horse Risk Reduction Project proposes to heavily log/clearcut these areas and replant with plantation-like stands. Degrading this habitat through post-fire logging will 53-99 challenge late successional species associates by further decreasing connectivity in this vital, shrinking, habitat linkage. The bottleneck or "pinch point" for connectivity in the Beaver Creek and Horse Creek watersheds must be addressed with EIS analysis. The Seiad Horse EA entirely failed to disclose or analyze this bottleneck in connectivity or the proposed projects impact to it. 53-100 The potential outcome on the remaining portions of the Siskiyou Crest Connectivity Corridor is severe, disproportionate and unjustified. Failure to analyze this important issue is arbitrary and capricious and constitutes inadequate NEPA Analysis. The Seiad Horse Project fails to "maintain or restore migration routes and the connectivity 53-101 of the landscape to allow for species dispersal" as is required in the KNF LRMP. In fact, the project actually reduces and degrade existing migration and connectivity on the landscape by reducing snag habitat, habitat complexity and the lands 34 regenerative capacity by damaging soils and impacting water retention....The EA completely failed to 53-102 address the specific connectivity values, concerns and limitations within the planning area and across the broader region. No site-specific analysis was conducted in the EA to evaluate the bottleneck in habitat connectivity in the Horse Creek watershed. The EA failed to disclose and analyze the significant bottleneck or pinch point in connectivity in the Horse Creek drainage. • The EA failed to disclose that significant logging to the east and south has reduced habitat complexity and connectivity in the area. • The EA failed to quantify, describe or consider the specific impact of post-fire logging within this narrow bottleneck for connectivity. • The EA failed disclose the potential impact of 53-103 further reducing this connectivity bottleneck by implementing post-fire logging and site prep/planting on nearly 2,000 contiguous acres running north to south across this important east to west corridor. • The EA failed to demonstrate compliance with the KNF LRMP 6-14, page 4-23 in regards to maintaining and restoring both "migration routes and connectivity of the landscape to allow for species dispersal."

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Comment # Comments The EA failed to disclose or analyze the impact of the proposed project on connectivity 53-104 between large Inventoried Roadless Areas. The massive post-fire logging proposed in the Seiad Horse Risk Reduction Project will only 53-105 further compromise and perhaps sever the connectivity between wildlands and across the Siskiyou Crest. The EA failed to analyze or disclose the impact of post-fire logging and artificial reforestation on connectivity between two large inventoried roadless areas. • The EA 53-107 failed to analyze the impact of degrading connectivity and habitat complexity in Natural Landscape Blocks and Essential Habitat Connectivity in the California Essential Habitat Connectivity Program. These linkages between potential populations were not analyzed in the Seiad Horse EA and post-fire logging units could significantly impact landscape connectivity and 53-125 permeability for the wolverine by creating large structurally simplified openings within a vital connectivity corridor. The KNF has proposed to create over 2,000 acres of structurally simplified openings in the form of post-fire logging units and site prep and plant units. The location and configuration of these units could create a nearly complete barrier to east-west movement, isolation populations from the south and west, as well as impact the potential for dispersal into the eastern Siskiyou. Currently proposed post-fire logging units would reduce the corridor from over 2 miles wide to a thin ¼ mile wide strip near the summit of Copper Butte. If this proposal was implemented, much of the remaining habitat within that ¼ mile corridor 53-126 would also consist of montane chaparral and early successional forest. The late successional characteristics extending from the West Fork of Horse Creek to Copper Butte would be largely removed. The impact of post-fire logging to wolverine habitat and habitat connectivity is severe and long lasting given the time it takes to grow large trees, forests, snags and downed wood and provide additional structural complexity. If the even-aged plantations created in the Seiad Horse Project become subject to self-re-enforcing high severity fire, the impact may be almost permanent. This could represent a total loss to landscape connectivity east of Cook and Green Pass for the wolverine. Although considered in the EA and the Wildlife Biological Evaluation for the Seiad Horse Risk Reduction Project, analysis was inadequate and did not consider the cumulative impact of project activities on this specific connectivity and dispersal corridor. Post-fire 53-127 logging proposed in the Seiad Horse Project would render this corridor useless to the wolverine and all units within two miles of the Siskiyou Crest should be canceled to maintain this vital dispersal corridor. The EA failed to disclose or analyze the complete barrier to connectivity the post fire 53-130 logging units could create due to the location, configuration and scale of logging proposed. According to the Seiad Horse Risk Reduction EA, structurally simplified openings between 160' and 600' wide create dispersal barriers for both the Pacific fisher and Marten. The Seiad Horse Risk Reduction Project will create a nearly contiguous 2,000- acre opening, 53-131 created by post-fire logging prescriptions. This massive opening will extend north to south across the east-west Siskiyou Crest Connectivity Corridor, reducing connectivity across the southern slope of the Siskiyou Crest. The configuration and scale of proposed units will block species dispersal by creating vast blocks of structurally simplified openings. The

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Comment # Comments Siskiyou Crest Connectivity Corridor will be reduced to ¼ mile near Copper Butte due to extensive post-fire logging and the creation of large, structurally simplified openings. The specific location of proposed post-fire logging units could also impact connectivity 53-132 between Pacific fisher populations in the West Fork of Horse Creek by blocking dispersal pathways between the northern California and southern Oregon populations. The EA failed to adequately analyze or disclose impacts to connectivity for the Pacific fisher and Marten, east to west across the Siskiyou Crest and north to south from northern California and southern Oregon. • The EA failed to adequately disclose and analyze the 53-134 impact of creating large structurally simplified openings through post-fire logging. The loss of structural complexity will impact Pacific fisher and Marten habitat quality and habitat connectivity for hundreds of years. The loss of habitat should be analyzed as semi- permanent. These units likely have the largest impact in the Seiad Horse Risk Reduction Project, on the connectivity of the Siskiyou Crest. The size and location of the units could create a barrier to connectivity for late successional species dispersing across the Siskiyou Crest. The 53-262 barrier created by these units could severe the east to west Siskiyou Crest Connectivity Corridor by creating a vast contiguous barrier of simplified, early seral 80 habitat and plantation-like stands lacking snag habitat, downed wood and habitat complexity. The specific location of the unit will have a significant impact on connectivity in the area 53-265 and across the Siskiyou Crest. Given the contiguous nature of these units and sheer size of unit 37, impacts from postfire logging will be heavily concentrated in the upper West Fork Horse Creek. These impacts 53-269 will include a major impact to connectivity given the size and configuration of units in the area. Unit 37 should be canceled to protect the connectivity of the Siskiyou Crest and the stands many important biological values. The size, scale and configuration of post-fire logging 53-273 units in unit 37 and the surrounding units will create an east west barrier to species dispersal for the marten, fisher and wolverine. The units will also likely interrupt dispersal up the Horse Creek drainage from high to low elevations. Unit 39 is very similar to unit 37 in its composition, fire history and current condition. The impacts described above would also apply to post-fire logging in unit 39. Unit 39 is an isolated complex, early seral habitat at the headwaters of Salt Gulch and surrounded by 53-275 burned off plantations stands. Unit 39 provides some structural diversity in a heavily managed and homogenized watershed, dominated by simplified, early seral habitat conditions. Unit 39 should be canceled. Units 1 and 8 should be canceled to promote connectivity and maintain complex, habitat values in the Seiad LSR. The unit contains important biological legacies that cannot be easily reproduced and provide invaluable ecological continuity between the historic stand and the early successional stands developing in its place. The post fire environment includes many important large diameter snags. The retention of these snags will provide 53-277 habitat, recruit large downed wood and create structural diversity that cannot be replace for hundreds of years. The logging prescriptions proposed in the Seiad Horse Risk Reduction Project are inconsistent with LSR Standards & Guidelines. Post-fire logging will degrade late successional habitat values in the long and short term. Logging the important biological legacies in units 1 & 8 will dramatically impact habitat connectivity on the

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Comment # Comments Siskiyou Crest, in the Seiad LSR and as between two large Inventoried Roadless Areas. Units 1&8 should be canceled to protect connectivity, LSR values and important post-fire habitat. • The EA failed to disclose or analyze the percentage of land within the corridor between 53-285 Inventoried Roadless Areas that will be impacted by the Seiad Horse Risk Reduction Project. • The EA failed to adequately disclose or analyze specific role the Siskiyou Crest plays in dispersal and connectivity between potentially distinct wolverine populations in the Klamath, Siskiyou, Cascade and even Sierra Nevada Mountains. The Siskiyou Crest is the 53-288 most likely connectivity corridor to provide dispersal between these potential populations. • The EA failed to disclose or analyze the impact of post-fire logging on east to west connectivity for wolverine on the Siskiyou Crest. We are greatly concerned that proposed project activities would substantially degrade the region's only high-elevation land bridge joining the globally significant Siskiyou Mountains 54-1 (DellaSala et al. 1999) to the Coast Range in an east-west corridor (Figure 1 below) recognized by scientists as potential climate refugia (Olson et al. 2012). The Seiad-Horse project is located within the Siskiyou Crest, a regionally recognized land- bridge and potential climate refugia. Project actions will substantially impact the ability of 54-59 the Crest to function in this fashion and will have significant impacts to NSO cores and owl habitat, NSO critical habitat, LSRs, Riparian Reserves and aquatics (chronic disturbance), invasive species spread, and future fire risks (logging slash, human-related fire ignitions). I deeply value the spectacular beauty and diversity of the Siskiyou Crest, including the fire- affected watersheds. High severity burn areas provide complex habitat and generate pulses of biological legacies that are essential to healthy ecosystems. The mid Klamath 57-1 watersheds are critical for threatened species and wild salmon yet you 1 continue to degrade and harm them. This project would add significant adverse impacts that should be considered in a full environmental impact statement. "Roading contributes to increased fragmentation of vegetation by dividing patches into smaller fragments. The location of roads on the landscape has a significant effect on landscape continuity and connectivity." Horse Creek WA 3-27 "Habitat patterns are critical to species movements and appropriate management of the landscape must consider how changing habitats will affect the ability of species to operate in ways necessary for their survival." Horse Creek WA 3-28 "Road construction removes and fragments habitat, affects wildlife distribution and movements and increases the potential for outside disturbance factors." Horse Creek WA 3-28 "Desired Conditions- Connectivity for late-seral wildlife is 59-18 maintained…there is reduced habitat disturbance from management activities." Horse Creek WA 5-16 "Connectivity of late-successional forest within the Horse Creek portion of the Johnny O'Neil LSR is lacking." Horse Creek WA 5-30 "Maintenance and/or improvement of existing connectivity between large reserves will be achieved through project planning that protects remaining old-growth patches, maintains more than 50% dispersal habitat in the watershed, through road decommissioning in areas with high road density, through maintenance of Riparian reserves and 100 acre LSRs and through management of plantations and burned areas to promote growth of mature trees." Horse Creek WA 5-30 The agency must consider these pertinent statements from the Horse

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Comment # Comments Creek WA and maintain and restore habitat connectivity. The project as proposed fails to do so. We believe the Seiad Horse Risk Reduction Project will degrade the habitat connectivity and unique biological values of the Siskiyou Crest. Units proposed for logging are located within 1/8 of a mile from the Siskiyou Crest near Copper Butte, within two Late 572-2 Successional Reserves and three Critical Habitat Units for the Northern Spotted Owl (NSO). We oppose the post-fire logging, road building and replanting proposed in the Seiad Horse Risk Reduction Project. Instead, this important landscape should be managed to facilitate natural regeneration, connectivity and biodiversity. The Siskiyou Crest is one of the most ecologically and biologically important areas in the Klamath-Siskiyou Ecoregion. The minimal level of impact on the Siskiyou Crest has allowed connectivity and basic functionality to continue in the area, benefiting the entire region. 572-3 The Siskiyou Crest is in need of protection and restoration to ensure proper function and region-wide connectivity. The Seiad Horse Risk Reduction Project does not contribute to these goals, and could, in fact, harm the outstanding ecological value of the Siskiyou Crest. The exact location of the Siskiyou Crest logging units proposed in the Seiad Horse project is within the most significant bottleneck or "pinch point" for connectivity on the entire Siskiyou Crest. Private land logging, especially recent post-fire logging on the south-facing slopes above the Klamath River watershed, have created a significant barrier to connectivity, reducing habitat complexity and forest structure across thousands of acres. The remnant late-seral native forest habitats and complex early-seral plant communities in 572-4 upper Horse Creek are the last remaining late-seral habitats in the Horse Creek watershed, they are also the corridor through which diversity still flows on the Siskiyou Crest. Degrading this habitat through post-fire logging will challenge species by further decreasing connectivity in this vital, shrinking, habitat linkage. The bottleneck or "pinch point" for connectivity was not addressed in the Seiad Horse Project EA. Failure to analyze this important issue constitutes inadequate NEPA analysis. The Siskiyou Crest will play an increasingly important role as a climate refuge and a corridor through which dispersal and migration can occur. Today with the threat of climate change and climate upheaval beginning to affect terrestrial and aquatic habitats across the region, the quality of habitat on the Siskiyou Crest and the connection between intact 572-5 habitats will either benefit or hinder species dispersal. Habitats with a wide range of intact native ecosystems, like the complex burn mosaic of snag forests, old-growth, high elevation forest, young regenerating forests, wet meadows, dry meadows and montane chaparral at the headwaters of West Fork Horse Creek and Seiad Creek, provide opportunities for many species of both plants and animals to disperse and persist. The forests targeted for post-fire logging in the Seiad Horse Project, contain some of the last, old forest structure in the West Fork of Horse Creek and the East Fork of Seiad Creek. Although they burned at mostly moderate and high severity, the snag forests contribute to landscape connectivity and provide abundant biological legacies, such as large diameter 572-11 snags, downed wood, etc. These biological legacies have been largely eliminated from much of Horse Creek and the East Fork of Seiad Creek due to historic and ongoing logging and post-fire logging. Logging these last biological legacies will fragment the remaining corridor of intact habitat on the southern face of the Siskiyou Crest.

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Comment # Comments I feel the Seiad Horse EA has not fully analyzed the unique biodiversity of the Seiad Horse 573-1 Project area, and did not adequately disclose that the area has been proposed for Wilderness or Monument status. The burned forests slated for post--fire logging in the proposed Seiad Horse project also harbor many sensitive indicator species — both wildlife and botanical species. These 573-6 important ecological attributes must be retained and protected on the landscape in order to protect the habitat connectivity of the Siskiyou Crest, an area renowned for its high levels of biodiversity.

Comment Response #81: Wildlife Effects Analysis Concern statement: There is a concern for the sufficiency of the effects analysis for wildlife due to the reliance on risk level assessments and project mitigations and the lack of supporting field data and surveys. Forest Service Response: There is no requirement to conduct surveys for all Forest Service Sensitive species in order to evaluate the effects of a project. Where field data is available, it is used to inform the analysis. When field data is unavailable and suitable habitat is present, we assume presence and analyze the effects of the project actions based on this assumption. As per the Standards and Guidelines within the Forest Plan, northern goshawks are surveyed for prior to implementation and the data gathered from these surveys informs the analysis of effects and the project minimization measures, such as the use of Limited Operating Periods during the sensitive reproductive period for areas with known nests. Project design features are intended minimize or eliminate potential negative effects to species that may occur in the project area. Including these design features in the analysis of effects provides a more accurate estimate of the potential effects to sensitive species than an analysis that does not consider the intentional measures taken to avoid impacts to a given species. The effect of removing fisher habitat including habitat affected by fire is analyzed in depth in the Wildlife Biological Evaluation (BE). The effect of the project on fisher habitat is an estimate, due to the limited scientific information that evaluates the fisher’s specific use of post fire habitat and the subsequent effects of removing a portion fire affected habitat from a much larger fire affected landscape. There is no evidence that fisher “rely” on burned habitat for any aspect of their life history. The BE states that it is possible that fisher may use burned areas to forage, once the understory has grown to a point where it may provide some level of cover; the removal of fire-killed trees from within burned areas is not considered to be removal of habitat that fisher rely upon. For Management Indicator Species (MIS), there is no requirement that they be analyzed at the population-level, but are analyzed at the landscape and project-level according to the requirements stated within the Forest Plan. For MIS listed in the Forest Plan Page 4-38 to 4-41, project-level MIS effects analyses are informed by project- and landscape-scale habitat analyses. Project-level effects on MIS are analyzed and disclosed as part of environmental analysis under the National Environmental Policy Act. This involves examining the impacts of the proposed project alternatives on MIS habitat by discussing how direct, indirect, and cumulative effects will

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change the quantity and/or quality of habitat in the landscape and project area (Forest Plan page 4-39). The Forest Plan analysis requirements for MIS in the Project are summarized in Part I of the MIS Report. Adequately analyzing project effects to MIS, involves the following steps: • Identifying which MIS have habitat that would be either directly or indirectly affected by the project alternatives; (Forest Plan Standards and Guidelines (S&G) 8-21 through and including 8-34). This information is documented in Part I of the MIS Report. • Identifying the Forest Plan forest-level monitoring requirements for this subset of forest MIS (Forest Plan Ch. 5, Table 5-1). • Analyzing landscape- and project-level effects on habitats for which the MIS was selected to indicate in the Forest Plan. Associated Comments: Comment # Comments Page 12 of the BE indicates that "forest stand complexity and physical structure post-fire can provide cover that is likely important for fisher in fire affected forests." Yet the Forest Service logging proposal specifically targets post-fire PFF habitat for snag removal reducing forest stand complexity by removal all fire-affected trees within proposed logging units. The decision to remove LSR habitat relied upon by Pacific Fisher necessitates completion of an EIS and may contribute to the need to list the species. The assumption on page 16 of the EA that "moderate" fire-affected habitat "typically [has] little no tree canopy cover" is simply incorrect and hence the KNF Fisher analysis relies upon a faulty assumption. Page 18 of the BE indicates that the Forest Service lacks any actual data or meaningful information about Fisher locations and populations in the Project Area such that "each fisher home range is estimated for this analysis and…not based on actual fisher home ranges." The conclusions reached in the EA and BE are independent of any data, surveys or field information. The impacts from green (live) tree logging associated with roadside 49-128 hazard trees, landing establishment and yarding corridors is simply ignored by Forest Service timber planners. At page 38 of the BE the Forest Service relies upon the hypothetical potential of high severity fire to undermine consideration of foregoing LSR clearcutting (via the No Action Alternative) while the analysis document contains no such dire prognostications for increase future fire hazard in the timber plantations that the agency hopes to establish throughout these public lands. The significant negative effects of the proposed LSR clearcutting on Fisher are undeniable. "Alternative 2 would result in creating openings in Middle Horse Creek and Salt Gulch to the point that the habitat connectivity would be reduced from a low habitat connectivity level to a very low habitat connectivity level. West Forest Horse Creek habitat connectivity would be reduced from a moderate habitat connectivity to a low habitat connectivity level." FOREST SERVICE SENSTIVE BAT SPECIES It does not appear that the Forest Service analysis regarding sensitive at-risk bat species in the project is informed by any actual surveys or data. Page 2 of the Management Indicator Species Report (MIS Report) contends that the "Monitoring requirements in Chapter 5 of the Forest Plan do not require population 49-130 monitoring on any MIS." This statement is incorrect. The KNF may wish to re-familiarize itself with the holding in KS Wild v. USFS, Eastern District of California 2004, (which is binding precedent for this project) in which the federal district court held that the Klamath

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Comment # Comments National Forest violated its LRMP, and NFMA, by failing to monitor and survey for snag associated MIS species. The role of management indicator species in National Forest planning is described in the 1982 implementing regulations for the National Forest Management Act (NFMA) of 1976: "In order to estimate the effects of each [Forest Plan] alternative on fish and wildlife populations, certain vertebrate and/or invertebrate species present in the area shall be identified and selected as management indicator species and the reasons for their selection will be stated. These species shall be selected because their population changes are believed to indicate the effects of management activities. In the selection of management indicator species, the following categories shall be represented where appropriate: Endangered and Threatened plant and animal species identified on State and Federal lists for the planning area; species with special habitat needs that may be influenced significantly by planned management programs; species commonly hunted, fished or trapped; non-game species of special interest; and additional plant or animal species selected because their population changes are believed to indicate the effects of management activities on other species of selected major biological communities or on water quality [36 CFR 219.19 (a)(1)]." (emphasis added) The agency must provide information describing population numbers, locations, and trends for key wildlife species, nor monitoring data to determine that the proposed action would maintain numbers and distribution of these species sufficient to ensure long-term viability. We know from the WA that forest fragmentation in these watersheds is a serious problem for many MIS species and that late mature and old-growth forest types are in severe deficit in the project area. Hence we believe it is necessary for the EIS to disclose information and analysis regarding MIS population trends in these watersheds. KNF timber planner have ignored these portions of the Klamath Land Resource Management Plan: 56 LMP - 5-3: Population trends of management indicator species will be monitored and relationships to habitat changes determined. This monitoring will be done in cooperation with State fish and wildlife agencies, to the extent practicable (219.19(a)(6)). Monitoring determines 1. Whether existing and merging public issues and management concerns are adequately addressed, and 2. Whether opportunities are realized. LRMP Pg. 5-12, Table 5-1: Monitoring Plan by Resource: Fisheries Management: Fisheries Management for FS Sensitive Species (Summer steelhead and spring Chinook 49-131 Salmon) - Objective: determine population trends and habitat conditions (I). Monitoring Technique: direct observations, mask and snorkel counts. Cooperation with CDFG. Continued for Fisheries Management for MIS species: // Monitoring Objective: determine population trends and relationship to habitat changes (I). Monitoring Technique habitat condition inventory, 10% of habitat per year. Ecosystem classification Coordination with CDFG on fish surveys. Monitoring Frequency: Annually, Reporting Frequency Annually, Standard: Region 5 Methodology Forest Plan S&Gs, Variation from standard requiring further action - 30% deviation from S&Gs (riparian criteria). Additionally, because spotted owls forage in high severity burn patches where owl prey species are abundant (Bond 2016), project activities will impact owl foraging sites and prey species, which was not disclosed in the EA. NSO impacts also not discussed in the EA: §? 54-26 Will shrubs be reduced by logging within LSRs and owl cores, and if so how will this affect owl prey? §? Will post-fire logging exacerbate interspecific competition with Barred Owls, especially given that spotted owls are more vulnerable to territory extinction events in low-quality spotted owl habitat (Dugger et al. 2016)?

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Comment # Comments The project proposes treatment within 0.25 miles of the nest sites of both goshawk territories. This is contrary to the Klamath Forest Plan, which restricts habitat-modifying activities between March 1 and August 31 within Primary Nest Zone (0.5 mile radius). Surveys for goshawks should be completed prior to project planning, so that the results 59-7 may inform the public, decision maker, project layout and treatments as goshawks may be outside of "management zones". Further, surveys have not provided sufficient data to assess the distribution of this species nor have they validated the assumption that this species is adequately provided for by large unmanaged reserves as required by the Klamath Forest Plan. The Seiad-Horse project analysis is very similar to the recent Horse Creek project. Page 12 of the Horse Creek project BE also indicated that "forest stand complexity and physical structure post-fire can provide cover that is likely important for fisher in fire affected forests." Yet the Forest Service logging proposal specifically targets post-fire habitat for snag removal reducing forest stand complexity by removal all fire-affected trees within proposed logging units. The decision to remove LSR habitat relied upon by fishers and martens necessitates completion of an EIS and may contribute to the need to list the 59-11 species. Page 18 of the Horse Creek BE indicated that the Forest Service lacks any actual 6 data or meaningful information about fisher locations and populations in the project area such that "each fisher home range is estimated for this analysis and…not based on actual fisher home ranges." The conclusions reached in KNF's project analysis are independent of any real data, site-specific surveys or adequate field information. The cumulative impacts from snag and green (live) tree logging associated with "salvage" logging, roadside hazard trees, landing establishment and yarding corridors is simply ignored by Forest Service timber planners. "Great gray owls have been heard during surveys that have occurred along the Siskiyou Crest." Forest Wide LSRA 2-78 "Few surveys have been conducted for great gray owls in the analysis area, it is expected that additional surveys will reveal owl nest sites in the area." Horse Creek WA 5-33 The Seiad-Horse Wildlife BE is again woefully inadequate and 59-12 uses flawed methodology, similar to the NSO. For instance, the assumption that moderate severity burn areas no longer provide nesting habitat. Within five to ten years forest canopies would fill in and could again provide suitable habitat. Further the EA and BE do not contain any actual data on species presence and fail to maintain and restore habitat.

Comment Response #82: Effects to Northern Spotted Owl Concern statement: There is a concern for the effects of proposed project activities on the northern spotted owl, its habitat, and the potential for take of the species. These concerns specifically regard potential effects to habitat complexity and structures, activity centers, survival and reproduction, nesting and core sites, and long term impacts to the owls. Forest Service Response: Effects from post fire logging on northern spotted owls and on the structural complexity within suitable NSO habitat, including the effects to individual activity centers, are analyzed and disclosed within the BA. There is no dispute that the project may have adverse effects to northern spotted owls; this is fully disclosed within the BA. The determination for the Seiad-

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Horse risk reduction project is “may affect, likely to adversely affect” northern spotted owls and critical habitat. The assignment of take is not the purview of the Forest Service; take will be assigned by the US Fish and Wildlife Service following their review of the BA and the issuance of a Biological Opinion. The analysis for a jeopardy determination is also under the jurisdiction of the US Fish and Wildlife Service and therefore not included in the BA. The commenter refers us to the Hanson et al 2018 paper. While we have reviewed this paper as published in the Bulgarian open-access journal Nature Conservation, (Pensoft Publishers; not affiliated with Nature Publishing Group or the Nature family of journals), we have also reviewed the rebuttal of this article by the authors of the research paper (Jones et al. 2016) whose findings the Hanson et al 2018 paper attempts to refute. The Hanson et al. 2018 article reaches the conclusion that post-fire salvage logging, and not severe wildfire, caused a reduction in the spotted owl site occupancy following the King fire in the El Dorado demographic study area. However, the rebuttal by Jones et al. demonstrates that the Hanson et al. 2018 article contains clear factual errors and omissions of data that render the argument against Jones et al. 2018 invalid. As described within the Jones et al. 2018 rebuttal, aspects of the Hanson et al. 2018 paper such as “the broader analytical approach (e.g., use of naïve occupancy rather than a formal modeling framework) used by Hanson et al., and what appears to be selective literature citation (e.g., failing to cite new, emerging literature suggesting severe fire can have negative population consequences for spotted owls – Rockweit et al. 2017, Ecology)” bring uncertainty to the findings within the Hanson et al. 2018 paper. The facts and discussion of the Jones et al. 2016 research paper and the Hanson et al. 2018 article were considered in the NSO analysis within the BA and the NSO Report. Effects from post fire logging and the use of post-fire habitat by NSO are analyzed and discussed at length within the BA. Associated Comments: Comment # Comments It is our understanding that when implementing the recent Westside salvage logging clearcuts the Klamath National Forest did not systematically retain legacy snags as was required by Project Design Features (PDFs) included in the NEPA document. It is also our understanding that the Forest Service logged newly occupied core habitat areas for owls 49-99 that relocated as a result of the effects of fire and logging activities. This pattern of logging habitat essential for NSO survival and reproduction is likely to be repeated in the Seiad- Horse LSR timber sale given that "[s]ome activity centers may shift the territory a short distance to better habitat…" such that the KNF is unlikey to know the exact location of owl nesting sites prior to authorizing clearcut logging in the LSR and CHU. Indeed, it is our understanding that such a home range shit and expansion occurred during implementation of the Westside LSR salvage logging clearcutting on the Klamath National 49-101 Forest and that despite assurances contained in the EIS and BA, post-fire stands serving as new NSO core sites were logged. Both Forest Service logging alternatives are Likely to Adversely Affect Northern Spotted 49-119 Owls and result in "take." We also bring to your attention the peer-reviewed 2018 study by Hanson, Bond and Lee 49-135 entitled Effects of post-fire logging on California spotted owl occupancy. The results of the study indicate that "it is post-fire logging, not large fires themselves, that poses a

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Comment # Comments conservation threat to this imperiled species." Indeed, the KNF's recent Westside LSR salvage logging plan involved the "take" of over 100 spotted owls, and the Seiad-Horse timber sale will "take" owls as well. 53-18 Both the threatened NSO and the coho salmon will be heavily impacted. Likewise, the foundation of Northern Spotted Owl (NSO) habitat is complexity. Structural complexity is often associated with decadence (e.g standing snags and downed wood) and 53-148 natural disturbance such as wildfire. The Seiad Horse Project proposes to eliminate these foundational structures and disrupt the natural process that creates the heterogeneity and structural complexity indicative of quality NSO and LSR habitat. 54-6 Degrading Northern Spotted Owl (NSO) critical habitat, activity centers, and core areas. The Johnny O'Neil LSR is important to owl demography, particularly maintenance of NSO survival and reproduction, and it may function as an owl population "source" area given the substantial incidental take from the Westside salvage project and logging on private 54-17 lands in the surroundings has degraded owl habitat over a much larger landscape cumulatively. Therefore, this LSR has regional significance to recovery of the NSO already facing multiple threats (cumulative effects). Notably, project logging activities proposed within the Johnny O'Neil LSR and those resulting in incidental take in the project area are inconsistent with the body of post-fire logging effects on 6 NSO (e.g., Clark et al. 2011, 2013, Bond 2016, Hanson et al. 2018). 54-19 Additionally, because juvenile dispersal habitat is identical to NRF habitat (Sovern et al. 2015), young owls may be dispersing into the project area in response to nearby fires and post-fire logging (cumulative effects). The NWFP "salvage" guidelines also state that, "the scale of salvage and other treatments should not generally result in degeneration of currently suitable owl habitat or other late- 54-21 successional conditions" (see NWFP salvage guideline C-13). Thus, by removing large legacy trees, the EA project activities will degrade owl habitat and LSR conditions, including destroying occupied and unoccupied (historical) nest sites and core areas. Project impacts also cannot be dismissed as insignificant or non-controversial, impacting 54-61 an area important to NSO demography, the Kangaroo Roadless Area, and leading to additional incidental take of owls (on top of the Westside salvage). Post-fire logging would have a negative impact on our wildlife already suffering from the 453-2 fire, especially the endangered Northern Spotted Owl. Threatened species and wild salmon don't need more added harmful impacts.

Comment Response #83: Northern Spotted Owl Recovery Plan Concern statement: There is disagreement regarding the consistency of the project with the Northern Spotted Owl Recovery Plan. Forest Service Response: Recovery Actions within the 2011 NSO Revised Recovery Plan (RRP) have been incorporated into the project design. The 2011 RRP identifies three main threats to NSO (past habitat loss, current habitat loss, and competition with barred owls) and describes a Recovery Strategy which

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Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest includes habitat conservation and active forest management as a means by which to address these threats. As a result, the RRP identified a series of Recovery Actions to guide activities that would contribute to recovery objectives. For the project analysis, Recovery Actions 10, 12, and 32 are most applicable and are described in the table below. Recovery plans are not regulatory documents and are not required to be addressed as part of Section 7 consultation under the ESA. However, in order to provide decision makers and the USFWS, with relevant information, and to address the general compliance requirements as listed under 7(a)(1) of Endangered Species Act, we have provided information regarding project consistency with the Recovery Plan (see table below

Recovery Description Applicable Recommendations Action Intent of this recovery action is to protect, enhance, and develop 10 Conserve spotted owl sites habitat in the quantity and distribution necessary to provide for the and high value spotted owl long-term recovery of spotted owls. habitat to provide • The project was designed to maintain key habitat features additional demographic such as large snags and large coarse woody debris. Many of support to the spotted owl the proposed treatments were designed to minimize effects to population existing habitat and promote stand development. • Prescribed fire provides for long term improvement to the habitat by removing fuels and consequently reducing the potential of high severity fire to move across the treatment areas and into existing NSO habitat. • Treatments were modified in order to reduce the estimated effects from the proposed activities across the entire project area where practicable. • NSO activity centers with recent survey coverage have been analyzed for their potential to contribute to the demographic support of the NSO population in the area. However, much of the Oak project area has not been surveyed, so an assessment of RA10 for most of the sites within this area was limited to the sites that had relatively recent survey information.. • In the Seiad-Horse project area, most of the activity centers had been surveyed at some point prior to the Abney fire, thus providing more current information regarding which sites have been reproductively active. The activity centers that were identified as RA10 sites have additional site specific design criteria and protective measures.

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Recovery Description Applicable Recommendations Action Intent of this recovery action is to focus silvicultural activities on 12 In lands where conserving and restoring habitat elements that take a long time to management is focused on develop such as legacy components, large trees and snags, and large development of spotted owl downed wood for the benefit of future stand development. habitat, post-fire • The treatments were designed to retain high value trees and silvicultural activities snags that are important habitat components in a developing should concentrate on stand of future suitable habitat. Post-fire projects would conserving and restoring achieve this by excluding treatment from within portions of habitat elements that take salvage harvest units and retaining high valued snags within a long time to develop the salvage harvest units. (e.g., large trees, medium • and large snags, downed In roadside hazard treatments, where hazardous trees/snags wood) over 40 inches DBH (Horse Creek-Robinson) or 45 inches DBH (Seiad-Horse and Oak) and trees that exhibit high quality habitat characteristics (i.e. signs of decay and defect, cavities, broken or multiple tops, very large lateral branches and flattened canopy) must be abated, they would not be removed from the site but would be left on site and whole as future downed logs. Maintaining forests with high-quality habitat will provide additional 32 Federal and non-federal support for reducing key threats faced by NSO; protecting these landowners should work forests should provide NSO high-quality refugia habitat from with the Service to negative competitive interactions with barred owls that are likely maintain and restore older occurring where the two species’ home ranges overlap. and more structurally complex multi-layered • Salvage treatments will avoid stands that currently provide conifer forests …allowing RA-32 characteristics. Fuels treatments are designed to for other threats, such as reduce the likelihood of negative effects to habitat from fire and insects to be stand replacing fire. Fuels treatments will contribute to the addressed by restoration overall reduction of stand replacing fire within areas of high management actions. quality habitat through the strategic placement of fuel breaks.

Associated Comments: Comment # Comments The US Fish and Wildlife Service (FWS) completed the Revised Recovery Plan for the Northern Spotted Owl (NSO Recovery Plan) in 2011. According to FWS, "'Recovery Actions' are near-term recommendations to guide the activities needed to accomplish the recovery objectives and achieve the recovery criteria," such that a species may be delisted from ESA protection. Recovery Action 10 directs federal agencies to: "Conserve spotted owl sites and high value spotted owl habitat to provide additional demographic support to the spotted owl 44 population. The intent of this recovery action is to protect, enhance and 49-100 develop habitat in the quantity and distribution necessary to provide for the long-term recovery of spotted owls." The NSO Recovery Plan states "this recommendation includes currently occupied as well as historically occupied sites (collectively "spotted owl sites," see Appendix G: Glossary of Terms)." The NSO Recovery Plan defines "spotted owl sites" as "an occupied spotted owl site or a spotted owl site where spotted owls were documented to be present in the past," and "conserve" as "to preserve to use, or manage wisely." NSO Recovery Plan Recovery Action 12 directs: "In lands where management is focused on development of spotted owl habitat, post-fire silvicultural activities should concentrate on

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Comment # Comments conserving and restoring habitat elements that take a long time to develop (e.g., large trees, medium and large snags, downed wood)." (emphasis added). Post-fire logging particularly targets medium and large fire-killed trees (snags) for removal. According to FWS, the best available information suggests that even with loss of forest canopy cover and other key habitat components typically found in NRF habitat, burned areas can provide some habitat function for spotted owls depending on fire severity. For example, areas that burned at low severity in some cases still provided spotted owl nesting, roosting, and foraging function. Areas that were burned at moderate and high severity may provide some limited nesting and foraging depending on burn patch size, edge type, and proximity to known sites (Bond et al. 2002, Bond et al. 2009, Clark 2007, Clark et al. 2011, and Clark et al. 2013 plus other authors per Appendix C). -Douglas Complex Biological Opinion. Moreover, "studies of spotted owls in post-fire landscapes indicate that spotted owls use forest stands that have been burned, but generally do not use stands that have been burned and logged." While spotted owls prefer late-successional habitat when it is available, they have been observed foraging in areas burned by fires of all intensity categories. The research indicates that low- to moderate-severity fires that retain adequate canopy can function for nesting or roosting and thus allow the continued use of spotted owl activity centers, while territories that burned at high-severity no longer supported nesting spotted owls. It is expected that within mixed severity burns, spotted owls will select the best available post-fire suitable habitat and Activity Centers at these locations may persist into the future. However, results of these and other studies are confounded because of post-fire logging that occurred within the study areas. "While the role of this burned habitat is unclear in overall spotted owl population maintenance, available information suggests that in the short-term this habitat, in particular when it is salvage logged, likely contributes to reductions in spotted owl survival and occupancy." 45 The NSO Recovery Plan states that "based on the best available scientific information, competition from the barred owl (S. varia) poses a significant and complex threat to the spotted owl." Spotted owls are somewhat unique as a species in that they are relatively easy to locate in the field by using a series of bird calls that mimic spotted owl hoots and whistles, to which the spotted owl will respond with its own call or fly in to the surveyor to investigate the source of the calls. Surveyor calls, in conjunction with offering a mouse to an incoming bird, are used in FWS-approved protocol surveys to determine whether a forested stand or known spotted owl site is occupied by a spotted owl pair or individual. However, Monitoring and management of northern spotted owls has become more complicated due to their possible reduced detectability when barred owls are present (Kelly et al. 2003, pp. 51-52; Courtney et al. 2004, p. 7-16; Olson et al. 2005, p. 929; Crozier et al. 2006, p.766-767). Evidence that northern spotted owls were responding less frequently during surveys led the Service and its many research partners to update the northern spotted owl survey protocol (USDI FWS 2012b). The best available science suggests that surveyors' efforts to identify spotted owl sites in the field using spotted owl calls are confounded by the presence of barred owls: research indicates that spotted owls are increasingly not responding to survey calls, even though present in the forested stand, due to the presence of barred owls. The FWS has explained that Evidence suggests that barred owls are exacerbating the spotted owl population decline, particularly in Washington, portions of Oregon, and the northern coast of California (Gutiérrez et al. 2004, pp. 739-740; Olson et al. 2005, pp. 930-931). There is no evidence that the

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Comment # Comments increasing trend in barred owls has stabilized in any portion of the spotted owl's range in the western United States, and "there are no grounds for optimistic views suggesting that barred owl impacts on northern spotted owls have been already fully realized" (Gutiérrez et al. 2004, pp. 7-38). In Oregon, Dugger et al. (2011, p. 2466) reported that some northern spotted owl pairs retained their territories and continued to survive and successfully reproduce during their study even when barred owls were present, but that the effects of reduced old growth forest in the core habitat areas were compounded when barred owls were present. Douglas Complex Biological Opinion. Davis et al. 2014 explain that: Bailey et al. (2009) and Crozier et al. (2006) determined that the presence of barred owls negatively affected the detection probabilities of spotted owls. Olson et al. (2005) determined that barred owl presence positively affected local extinction probabilities or negatively affected colonization probabilities of spotted owls. They concluded that a further decline in the proportion of sites occupied by spotted owls is expected. The steady decline in the number of pairs and the number of non-juveniles on the KSA since 2002 (Appendix A, B) seems to indicate that the KSA population may be experiencing these effects... 46 Because spotted owls are increasingly often nonresponsive to surveyors in habitat that is also occupied by barred owls, surveys for spotted owls that result in a "no occupancy" determination in fact may not accurately indicate the presence or absence of a spotted owl at that location. Barred owls are not the only threat to the spotted owl that is magnified post-fire: the best available scientific information also indicates that spotted owls expand their core areas and home ranges in post-fire environments in order to satisfy life cycle needs including roosting and foraging. According to FWS, Evaluations of spotted owl habitat are usually conducted at two spatial scales; the home range and core areas. The home range is the "area traversed by the individual in its normal activities of food gathering, mating, and caring for young" (Burt 1943:351, cited in USDI FWS 2009). Within home ranges, areas receiving concentrated use, typically surrounding the nest site and favored foraging areas, are called core areas. Douglas Complex Biological Opinion. In unburned forests, the best available science indicates that retaining at least 40% of the estimated home range, and 50% percent of the estimated core area, as suitable (NRF) habitat provides the best chance for spotted owl fitness or viability. In contrast, Where spotted owl activity centers are affected by fire (any range of severities) but sufficient habitat remains in the home range and immediately adjacent area, site fidelity may cause spotted owls to increase the size of their home ranges or shift locations to encompass the best available habitats rather than vacate the burned site (King et al. 1998, Clark 2007, Clark et al. 2011, 2013). Thus, a shift by spotted owls may occur under conditions where the burned area is presumably still functional in terms of extant spotted owl habitat and the affected area is considered to be occupied. This shift is likely to occur within the pre-fire home range of the affected spotted owl(s). Douglas Complex Biological Opinion. Indeed, "Clark (2007) found that in high severity burned landscapes, and landscapes with salvage harvest, spotted owls are likely to increase their home ranges to compensate for the loss of suitable habitat and this will likely impact spotted owl habitat-fitness." Clark and others concluded that "spotted owls may shift their habitat use patterns and/or increase their home range size to encompass the best available suitable habitat post-fire rather than vacate the affected site, unless very poor habitat conditions exist over much of their home range (King et al. 1998, Clark 2007)."

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Comment # Comments Spotted owls that shift and/or expand their home ranges in response to wildfire take advantage of unoccupied habitat that may be necessary for the species to persist in a postfire environment. The NSO Recovery Plan states that it is not uncommon for an occupied spotted owl site to be unoccupied in subsequent years, only to be re-occupied by the same or different spotted owls two, three or even more years later (Dugger et al. 2009). While temporarily unoccupied, these sites provide conservation value to the species by providing habitat that can be used by spotted owls on nearby sites while also providing viable locations on which future pairs or territorial singles can establish territories. Unoccupied owl habitat is important post-fire because it represents vacant territory that may be recolonized by shifting or dispersing owls. In a heavily fragmented and checker boarded landscape like the Project planning area, these "vacant" sites may represent the best remaining suitable habitat. FWS' NSO Recovery Plan includes specific recovery actions that represent the "best available scientific and commercial data available" that FWS is required to utilize during the consultation process. 16 U.S.C. § 1536(a)(2). In 2011, with the spotted owl declining across its range, FWS concluded that 49-102 Recovery Actions 10 and 12 were necessary to reverse the downward trend. Recovery Action 10. In the 2011 NSO Recovery Plan, FWS concluded that conserving currently and historically occupied owl sites was necessary to provide additional demographic support for the spotted owl. Specifically, FWS observed that: The three main threats to the spotted owl are competition from barred owls, past habitat loss, and current habitat loss (USFWS 2008b). Despite the habitat protections of the NWFP, the most recent demographic analysis (Forsman et al. 2011) indicates that spotted owl populations are declining on 7 of the 11 active demographic study areas at about 3 percent annually range-wide. Scientific peer reviewers and Forsman et al. (2011) recommended that we address this downward demographic trend by protecting known spotted owl sites in addition to the retention of structurally-complex forest habitat. Consequently, the best available science embodied in Recovery Action 10 directs agencies to: "Conserve spotted owl sites and high value spotted owl habitat to provide additional demographic support to the spotted owl population," id. at 341, and "this recommendation includes currently occupied as well as historically occupied sites (collectively "spotted owl sites," see Appendix G: Glossary of Terms)." Now, in 2018, rather than heed its own Recovery Plan and advice to recover the spotted 49-103 owl by protecting all occupied owl sites, the KNF and FWS are poised to "take" spotted owls as part of the Seiad-Horse logging project. Excerpted from the USFWS Final 2012 Critical Habitat Rule KLE-6. The KLE-6 subunit consists of approximately 167,849 ac (67,926 ha) in Jackson County, Oregon, and Siskiyou County, California, all of which are Federal lands managed by the BLM and USFS per the NWFP (USDA and USDI 1994, entire). Special management considerations or protection are required in this subunit to address threats to the essential physical or biological features from current and past timber harvest, losses due to wildfire and the effects on 54-18 vegetation from fire exclusion, and competition with barred owls. This subunit is expected to function primarily for north-south connectivity between subunits, but also for demographic support (emphasis added). Our evaluation of sites known to be occupied at the time of listing indicates that approximately 97 percent of the area of KLE-6 was covered by verified northern spotted owl home ranges at the time of listing. When combined with likely occupancy of suitable habitat and occupancy by nonterritorial owls and dispersing subadults, we consider this subunit to have been largely occupied at the

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Comment # Comments time of listing. In addition, there may be some smaller areas of younger forest within the habitat mosaic of this subunit that were unoccupied at the time of listing. We have determined that all of the unoccupied and likely occupied areas in this subunit are essential for the conservation of the species to meet the recovery criterion that calls for the continued maintenance and recruitment of northern spotted owl habitat (USFWS 2011, p. ix). The increase and enhancement of northern spotted owl habitat is necessary to provide for viable populations of northern spotted owls over the long term by providing for population growth, successful dispersal, and buffering from competition with the barred owl. In addition, we request that you analyze project-related impacts to large (>20 in dbh) trees, live or dead, and other biological legacies based on their importance to spotted owls, complex early seral forests (Swanson et al. 2011, DellaSala et al. 2014), and late- successional development (Donato et al. 2012). This will need to involve project level 54-27 inventories of large trees present on site compared to what is being removed (percent removed) by size classes >20 in dbh. Critical Habitat and Additional Impacts Inconsistent with Recovery Actions - As mentioned, project activities violate the conservation intent of KLE-6 critical habitat unit (see above). We also repeat our estimate of critical habitat impacted as described in scoping: 8 Total Acres NSO Critical Habitat Acres (%) Project Area 10,074.2 4,855.5 Ground logging 415.3 199.5 (4.1) Heli-logging 591.9 213.0 (4.4) Skyline logging 716.2 433.8 (8.9) Total logging (%) 1,651.4 (16.4) 846.3 (17.4) The NSO Critical Habitat Rule (USFWS 2011b) does NOT recommend active management in quality owl habitat (which includes foraging habitat) or occupied sites and instead states, "We encourage management actions that will maintain and restore ecological function where appropriate." USFWS (2011b) also recommends that within NSO Designated Critical Habitat (to avoid incidental take), managers should: §? "Focus active management in younger forest (emphasis added), lower quality owl habitat, 54-28 or where ecological conditions are most departed from the natural or desired range of variability; §? Focus on areas outside (emphasis added) of late-successional reserves (LSRs) (i.e., matrix), in moist forests, and follow the Northwest Forest Plan (NWFP) guidelines as informed by the Revised Recovery Plan; §? Follow NWFP guidelines and focus on lands in or outside of reserves most "at risk" of experiencing uncharacteristic disturbance in dry forests and where the landscape management goal is to restore more natural or resilient forest ecosystems; §? Avoid or minimize activities in active NSO territories or high-quality habitat within territories; and §? Ensure transparency of process so the public can see what is being done, where it is done, what the goal of the action is, and how well the action leads to the desired goal." We are also resubmitting our EA scoping comments of December 20, 2017 related to post- fire logging impacts that are clearly inconsistent with NSO recovery actions as supplemented herein: …. post-fire logging is incompatible with Recovery Action 12, provisions of the NW Forest Plan (LSRs), and new information (e.g., Hanson et al. 2018) 54-29 that adds to a growing list of post-fire logging impacts to owls and ecosystems. Thus, the proposed project, especially when added to nearby post-fire logging (e.g., Westside salvage and private lands) will cumulatively degrade owl habitat that over the larger area (Westside included) may trigger a jeopardy decision in Section 7 consultation.

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Comment # Comments Recovery Action 12: In lands where management is focused on development of spotted owl habitat, post-fire silvicultural activities should concentrate on conserving and restoring 54-30 habitat elements that take a long time to develop (e.g., large trees, medium and large snags, downed wood). Also - see discussion of owl prey habitat and fire importance in III- 49 Based on Recovery Action 10 (below), the EA does not contribute to restoring habitat elements that take a long time to develop (e.g., large live and dead trees). Instead, these structural elements are removed in large numbers throughout the project area with the false claim (linked to an inappropriate study outside the region, Zhang et al. 2008) that logging and tree planting will speed up their attainment. It should be noted that this similar claim made at the time by the Rogue Siskiyou National Forest was highly controversial and litigated during the Biscuit controversy. The Rogue Siskiyou National Forest, fortunately, has chosen a different approach this time around by avoiding post-fire logging and planting in LSRs. Recovery Action 10 - conserve spotted owl sites and high 54-31 value spotted owl habitat to provide demographic support (emphasis added) to the spotted owl population. Recovery Action 30 - manage to reduce the negative effects of Barred Owls on spotted owls….. Recovery Action 32 - land managers should work with the Service as described below to maintain and restore such habitat [structurally complex] while allowing other threats, such as fire and insects, to be addressed by restoration management actions. These high-quality spotted owl habitat stands are characterized as having large diameter trees, high amounts of canopy cover, and decadence components such as broken-topped live trees, mistletoe, cavities, large snags, and fallen trees (emphasis added). In sum, project activities within NSO cores, the LSR, and KLE-6 are clearly inconsistent with 54-32 spotted owl recovery and would degrade critical habitat and NSO habitat in general throughout the project area.

Comment Response #85: Ecological Benefits of Snags and Course Woody Debris Concern statement: There is concern for the ecological benefits of snag and coarse woody debris retention, including their ability to provide habitat, hold moisture and moderate temperature, build and maintain soil, and regenerate cool, moist plant associations. Forest Service Response: It is acknowledged that snags serve as important habitat for many species of wildlife. They play a role has a habitat components as well as contribute to habitat connectivity. The Seiad-Horse Project will retain snag levels at or above those levels described in the Forest Plan standard and guidelines 8-25. (Management Indicator Species Report, Snag Analysis, Appendix 1). The Project will meet or exceed 5 snags per acre on average over 100 acres with varying decay and size class, which is defined in the Forest Plan as providing “good” habitat to support snag associated species (Environmental Assessment page 103).

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For the Seiad Horse Project, post-implementation retention of high-valued snags are managed by: • Snag retention areas • Individually retained wildlife tree/snags (Legacy Trees as per Recovery Action 12) • Riparian reserves/inner gorges • Coarse woody debris (Project Design Feature Watershed 1) • Survey and Manage known or possibly occupied sites retention areas (Project Design Feature Wildlife 7) • CWD retention S&Gs (Project Design Feature Wildlife 8) • Trees retained because of exhibiting low probability of mortality within salvage units • Botanical sensitive area buffers Snag retention areas. Snags for wildlife will be retained based on 100-acre landscape areas according to numerical and diameter standards in the Forest Plan (p. 4-26). Harvest units will retain snags in riparian reserves (stream, active landslides and inner gorges) and in clumps in designated snag retention areas. (Environmental Assessment pages 8-9). Individually retained snags. Individual snags within harvest units will be retained if they provide high quality habitat characteristics such as signs of decay and defect, cavities, broken or multiple tops, or very large lateral branches and flattened canopy. In order to contribute to Recovery Action 12 (USFWS 2011), very large snags that have these characteristics and are likely to persist until the next stand is capable of producing large snags should be retained wherever they occur, provided they do not pose a safety risk to forest workers. If a wildlife snag must be felled for safety reasons, the entire tree would be left in place and shall not be bucked into smaller logs (Environmental Assessment pages 8-9). High quality habitat characteristics. The Seiad Horse Project is designed to retain high value trees (Legacy Trees as per Recovery Action 12) and snags that are important habitat components in a developing stand of future suitable habitat. This will be met by the exclusion of treatments within portions of harvest units and retaining high valued snags within the salvage harvest units. In roadside hazard treatments, where hazardous trees/snags over 45 inches DBH and trees that exhibit high quality habitat characteristics (i.e. signs of decay and defect, cavities, broken or multiple tops, very large lateral branches and flattened canopy) must be abated, they would not be removed from the site but would be left on site and whole as future downed logs. (Environmental Assessment page 6). Habitat Connectivity. Habitat connectivity was identified as analysis indicator for a relative measure dispersal habitat for fisher, marten, and wolverine. Habitat connectivity was analyzed at the 7th field watershed scale because it likely represents the scale at which individuals use the landscape. Assumption is made that snags contribute to habitat connectivity. These species are more likely to disperse thru openings greater 160 feet across when structures such as snags where present (Environmental Assessment pages 87 to 88). Summary of Snag Habitat Effects. Generally, for species associated with snags, the project would reduce the number of snags in the short-term, while the species associated with older

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Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest conifer forest may benefit from fuels reduction and tree planting over the long-term. The Seiad- Horse Risk Reduction Project would result in minor to moderate short-term impacts for a few species, but would not result in significant cumulative impacts. (Environmental Assessment page 97). Associated Comments: Comment # Comments 1-1 Do not cut dead standing tress as they serve as habitat Dead wood, including large snags and logs, rivals live trees in ecological importance. Removal of structural legacies, both living and dead, is inconsistent with scientific 49-142 understanding of natural disturbance regimes and short- and long-term regeneration processes. Standing, fire-killed snags provide a very important role in moderating temperature extremes and holding moisture by providing shade while standing and building soil, holding moisture and holding water. Downed trees are essential in holding water high on the landscape and maintaining healthy soil conditions. Deficiencies in coarse wood, 53-79 microclimate and water holding capacity, associated with post-fire logging will reduce habitat connectivity for flora and fauna responding to climate change, the deficiencies will directly reduce moisture retention and disproportionally affecting the regeneration of cool, moist species. The removal of complex biological legacies in this stand will dry and desiccate the site by exposing it to increased solar radiation, drying winds and higher ambient temperatures. 53-86 The removal of standing snags will also starve the ecosystem of downed wood which serves to hold water and retain soil moisture late into the summer months. By removing large snags and downed wood recruitment, microclimate conditions will be 53-88 impacted and the regeneration of cool, moist plant associations will be minimized. The removal of large diameter snags will also impact habitat for the Pacific fisher and Marten who forage in downed wood and den in large cavities found in large diameter trees and snags. These structural components will be removed in large, interconnected post-fire logging units. Nearly 2,000 acres will be affected, essentially removing this habitat 53-133 characteristic in a large contiguous area at the headwaters of Horse and Seiad Creek. The impact will be long lasting due to the time required to grow and replace large diameter trees, snags and downed material. These important habitat features will be deficient for perhaps hundreds of years. The snags targeted for removal will also act as denning structures for the pacific fisher and 53-137 many other species of wildlife. The EA failed to disclose and analyze the water retention capacity, nutrient cycling, soil 53-169 building and microclimate associated with coarse woody debris following a large wildfire. The EA failed to disclose and analyze the difference between complex, early-seral habitat with abundant biological legacies and simplified early seral habitat. The conditions created 53-172 by post-fire logging will starve the stand of snags and coarse wood....The EA failed to disclose and analyze the impact of the proposed project on the biodiversity and structural complexity of regenerating forests.

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Comment # Comments Trees over 200 years old were killed in the Abney Fire in unit 37 and are now proposed for 53-270 post-fire logging. The logging of large, old trees will reduce habitat complexity and starve future stands of large wood and snag habitat. Importantly, Baker (2015) and Franklin et al. (2000) identified habitat components of NSO in dry forests of Oregon's eastern Cascades and the Klamath province to include large older firs (>20 in dbh) in high densities (also see Buchanan et al. 1995). Forest stands used by spotted owls in southwest Oregon tend to have mature and old trees, diverse structural 54-23 composition, large amounts of down woody debris and abundant snags (Clark et al. 2013). Trees >20 in dbh are generally in short supply in dry forests of the Oregon and Washington Cascades (Henjum et al. 1994, Buchanan et al. 1995, Spies et al. 2006) and therefore large trees (>20 in dbh) when killed by intense fire are biological legacies important to owls and to late-seral development. Notably, Dr. Jerry Franklin noted in his 2005 testimony to the House Natural Resources Committee the importance of pulse disturbances for legacy tree maintenance. That is - reoccurring high severity burns provide the legacy tree component an entire area may receive for decades. High severity fires are on long-rotation intervals (note - rotation 54-60 interval is based on an area estimate rather than a point estimate as in fire return intervals). High severity rotation intervals for this region are ~140 years (Odion et al. 2014 Supplemental) meaning that these pulse disturbances are infrequent events at the landscape scale. Cavity-nesting species are prime beneficiaries of fires, 62 species of birds and mammals use snags, broken-topped, diseased or otherwise "defective" trees for roosting, denning, foraging, or other life functions. The White-headed Woodpecker, Pygmy nuthatch and Flammulated owl all have habitat ranges within the project area....The KNF forest plan requires that the largest snags be retained as they last longer make the best wildlife habitat....Forests that burn at high severity burn, snag forests, are often incorrectly assumed to be damaged. Ecologically, this is strongly contradicted by the scientific evidence. Peak biodiversity levels of higher plants and vertebrates are found in patches of 59-17 snag forest habitat—areas where most or all of the trees are killed by fire, consistent with the principle that pyrodiversity enhances biodiversity, especially where mixed-severity fire effects occur. As a result, avian species richness and diversity increases in heavily burned patches occurring within a mix of low and moderate severity effects. Scientists recommend that forest managers ensure the maintenance of moderate and high severity fire patches to maintain populations of numerous native bird species positively associated with fire. At the landscape level, high severity habitat (unlogged) is among the most underrepresented and rare forest habitat types. The removal of biological legacies (e.g. snags) will reduce habitat complexity and starve affected stands of coarse woody debris and snag habitat. Large diameter snags are extremely important for wildlife, especially species associated with cavity habitat. When 572-13 they fall to the forest floor, large diameter snags also build soil, hold moisture, harbor mycorrhiza, provide habitat complexity and cool, moist microclimates that encourage effective regeneration

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Comment Response #86: Salvage Harvest is Economically Motivated Concern statement: There is a concern that salvage harvest in late successional reserve (LSR) is motivated by the recovery of economic value and not the ecological objectives of the land use allocation. Forest Service Response: The purpose of salvage harvest in the LSR is to reduce the risk of future high severity fire by removing heavy fuels and to accelerate the development fire-resilient coniferous forests by replanting, as described by the Purpose and Need section of the EA. Nowhere in the EA is it stated that economic recovery is the objective of salvage harvest in the LSR. The courts have held that the Forest Service may consider economics when considering salvage in LSR. In a legal challenge of salvage in LSRs, the 9th Circuit Court of Appeals determined that, "the Forest Service may consider economic interests in choosing how it will conduct LSR salvage operations; that it may do so is not only a matter of common sense, but it is also something explicitly contemplated by the Northwest Forest Plan (ONRC v. Brong No. 05-35063; D.C. No.CV-04-00693-AA). The EA section on Effects of the Proposed Action and Alternatives discloses the effects of the proposed action and its alternatives on the LSR land allocation, including an analysis of how activities would meet the need for the project for fire risk reduction and coniferous forest development. Salvage harvest in the LSR is being done to reduce risk of future high severity fire, not recover volume. Nearly all of the proposed salvage harvest in the LSR is intended to create fuel breaks and reduce fuels to reduce the risk of future high severity fire. The vast majority of the fire killed trees in the LSR will remain unharvested. Standards and guidelines for the late successional reserve land allocation regulate or prohibit activities that would prevent LSR management objectives from being achieved. All of the proposed LSR salvage harvest in the Seiad-Horse project is intended to reduce the potential for severe fire effects associated with future fire events that may occur within LSR in the project area. The Forest Plan of the Klamath National Forest anticipated that risk reduction salvage may be necessary in the late successional reserve land allocation, and provided project guidelines (Forest Plan page 4-86; MA5-27 to 29) to ensure that the objectives of the Forest Plan were achieved. The Forest Plan also provides general guidelines for salvage in late successional reserves when it is not specific to risk reduction (MA5-30-1 to MA5-30-11). These general salvage guidelines were considered in project design, however, the Forest Plan allows for some salvage operations that do not meet guidelines MA5-30 1 through 4 when the salvage is essential to reduce the risk of future risk of fire (MA5-30-5), as is the case in the Seiad-Horse Project. The project is fully consistent with the Klamath Forest Plan as required by the National Forest Management Act (See the Forest Plan Consistency Checklist). Associated Comments: Comment # Comments Similar to last years' even more egregiously titled Horse Creek Community Protection and Restoration Project, the Klamath National Forest (KNF) continues to sell clear-cut, post-fire 53-1 logging as "restoration," "recovery" or "risk reduction" when in fact, the goal of the project is actually to extract commercially valuable timber from intact areas with important biological values.

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Comment # Comments The post-fire logging and re-planting projects proposed in the Seiad Horse Risk Reduction 53-3 Project provide no restorative benefit and are purely economic and ideological driven. The KNF must also produce scientific evidence to support the claim that proposed activities will "not impede the development of late-successional characteristics." A significant body of science contradicts this position. This body of science although widely 53-151 known, was largely ignored in KNF analysis for the Seiad Horse Project. The current KNF position is not scientifically based and is instead ideologically and economically driven. It is thus inappropriate in LSR forest, where logging for strictly economic purposes is forbidden. As a botanist I know full well that forests need to be protected and are more than just timber. These areas are needed for forest recovery and maintenance. The Forest Service must be more responsive to the needs of the forest and less to special interests of the 238-1 logging companies that as usual put exorbitant profits before our well-being and the reason they are so detrimental. It is not only using wood, is ignoring the needs of the forest to make sure they are a sustainable resource.

Comment Response #88: Cool, Moist Habitat Post-Fire Concern statement: There is a disagreement over the ability of areas within the project to function as "cool, moist" habitat and microclimates which are adapted to fire disturbance. There is a concern that project activities will disproportionally impact this habitat type which functions as a micro-climate that contributes to connectivity, climate refugia, and habitat complexity and these effects need to be analyzed. Forest Service Response: Cool, moist habitat conditions are important for several wildlife species. For example, the Siskiyou Mountains salamander is commonly found in talus shaded by a dense tree canopy which provides cooler, moister conditions that are needed by the salamanders as described in the Biological Evaluation (pages 26 to 27). For other species, like the Tehama chaparral snail, dense tree canopy cover along with woody debris provides cooler, moister conditions needed by this species as described in the Biological Evaluation (pages 28 to 29). The Biological Evaluation describes how wildfire can change the needed site conditions for these species (pages 26, 27, 29, and 30). The loss of tree canopy cover by wildfire typically results in hotter, dryer site conditions until a tree canopy is re-established. In salvage harvest units where trees are dead or dying, there is little to no tree canopy cover as these units were affected by moderate or high fire severity. In these units, live trees with dense canopy cover that occurred before the fire are now dead or dying and without a live tree canopy, these units are likely to experience hotter, drier conditions. Areas with existing live trees that are more likely to provide cool, moist conditions are not proposed for salvage harvest.

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Although the salvage harvest units do not contain the desired cool, moist habitat conditions, the project was designed to retain features to aid in future habitat that will provide cool, moist habitat conditions. More specifically, the Seiad Horse project Environmental Assessment and Wildlife Biological Assessment displays this project design by: • It is recognized in the Environmental Assessment that retention of snags and some standing dead vegetation, as well as retention of CWD to meet Forest Plan standards would provide habitat structure and some shade which would aid in the recruitment or regeneration of shade-tolerant riparian vegetation and trees (Environmental Assessment, page 129). • Project Design Feature – Wildlife 8, specifically addresses the retention of down woody debris (logs) greater 30 inches at diameter breast height in all treatment units. (Environmental Assessment, page 36). These features will be retained with disturbance from cutting, moving, and slash burning avoided as practicable. • In the Project Biological Assessment guidelines to meet Recover Action #12 for NSO identify that large high value trees and snags be retained in salvage harvest units. In addition, trees/snags greater 45 inches diameter at breast height, if abated will not be removed from the site. These downed logs will contribute to site diversity and microclimates (Biological Assessment, page 17). • Retention patches, riparian reserves, and individual trees help to provide cover for NSO. These retention areas are intended to result in; a reduction in the overall size of openings and an increase in the connectivity between remaining suitable habitat; foraging options within post-fire habitat for NSO; and increased levels of snags and large downed logs for future stand development. (Biological Assessment, page 83). • Large snags and large down logs are considered biological legacies in the post-fire environment and play an important role in the long term growth of the future. Large snags and large down logs are also essential attributes for the development of the old forest ecosystem and associated species such as the NSO. Once snags are recruited into coarse woody debris on the ground, they serve as an important element in owl habitat as part of many aspects in the life cycles of NSO prey. Thus, decaying wood serves different functional roles overtime, first providing cover for spotted owl prey in the complex early seral stage of the forest, and ultimately decaying and playing a critical role in soil development of older forests. Downed logs can enhance biodiversity by providing resources for a variety of taxonomic groups, but particularly for saproxylic species important to the development of NSO habitat. Conducting salvage harvest in only portions of a wildfire, while retaining areas of burned forest for sources of snags and downed logs provides a benefit to the overall diversity of species in burned areas, particularly saproxylic invertebrates and fungi dependent on dead and downed wood and crucial to the restoration of older forest conditions and NSO habitat (Biological Assessment, PG 85-86).

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The importance of snags and woody debris is recognized in playing an important role in post-fire landscapes by providing cover, microclimates and habitat for many species. Through implementation of Forest Plan Standards and Guidelines and Recovery Action 12, these components will be retained in the stands after treatment at or above Forest Standard levels. Further, in response to the concerns expressed in comments received during the scoping period, Alternative 3 was developed for the Seiad Horse project to reduce the amount of salvage harvest at the higher elevations. Alternative 3 eliminates salvage harvest within one mile from the northern Seiad Horse project boundary which includes the higher elevation portion of the project. For example, salvage harvest unit 35, in Alternative 3, would not be salvage harvested and those dead trees would be retained to exist in its natural cycle. Associated Comments: Comment # Comments In the response to comments for the Horse Creek Community Protection and Restoration Project, the KNF tried to discredit this study and question its relevance. The KNF falsely claimed that our organizations did not adequately identify the impacts of post-fire logging to climate refugia, stating "most of the region's biodiversity, endemic species, and species vulnerable to climate change are invertebrates, non-vascular plants, and fungi that are 53-72 largely restricted to persistently cool and moist late-successional forests. It is unlikely that severely burned stands where salvage units are located and for which commenters are concerned, are "persistently cool and moist late- successional forests." (USDA. 2017b. P. 36). The KNF also claims that the cited paper does not apply "to the conditions of high severity burns." (USDA, 2017b. P. 39). Both claims are false, misleading and do not apply to the Seiad Horse Risk Reduction Project The assumption that units adjacent to the Siskiyou Crest do not maintain "cool, moist" habitat conditions for climate refugia is absolutely false. For much of the year (at least 6 53-73 months), even south-facing slopes above 4,500' hold snow and sustain cool, moist habitat conditions, creating important micro-climates that contribute to connectivity, climate refugia and habitat complexity. It is also true that the impact of post-fire logging on south-facing slopes will disproportionally impact "cool, moist" microclimates by creating large, structurally simplified openings subjected to hot sun and stand desiccation. In many cases cool, moist 53-74 habitat conditions are patchy and discontinuous, existing in specific microclimates and topographical features. By subjecting these habitats to postfire logging, the shade provided by standing snags and the capacity to retain moisture associated with large downed trees will be lost. The loss of cool, moist habitats within the stands proposed for post-fire logging will be semi-permanent. Given the long-time periods required to produce large trees, large snags, large downed wood and a closed canopy forest conditions, these biological features 53-80 should be retained on the landscape. Large trees, large snags and large downed wood currently found on site will take hundreds of years to generate after logging treatment are conducted. The KNF is also assuming that the Olson 2012 paper does not apply to high severity burn areas. This assumption is false and ignores the natural history, fire history and natural 53-81 stand development patterns of high elevation forest throughout the West. Most high elevation forests adapted to cool, moist habitat conditions, are also adapted to infrequent,

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Comment # Comments high severity fire effects. In fact, most montane species capable of filing cool, moist habitat niches have evolved with mixed severity fire and many are adapted to significant high severity mortality patches (Agee, 1993). To claim otherwise is scientifically unsubstantiated. Snag forests and complex, early seral habitat conditions are a natural response of high elevation forest adapted to mixed severity fire. These natural habitats can far more 53-82 effectively create cool, moist microclimate conditions than cleared and replanted stands resulting from post-fire logging and reforestation. A small section of new road is also proposed to be built through this surviving stand of white fir, further fragmenting the canopy, increasing edge effect, impacting interior forest values and reducing cool, moist habitat conditions. The stand is located at 5,600' and acts 53-85 as refugia habitat. The unit is also less than a quarter mile from the summit of Copper Butte on the Siskiyou Crest. The impacts to these refugia habitats will have disproportional impacts on connectivity and the retention of "cool, moist" habitats on the Siskiyou Crest. They are clearly cool, moist, montane habitats that should be protected to ensure 53-87 adequate connectivity across the Siskiyou Crest Connectivity Corridor. At the top of unit 35 is the underburned white fir stand identified above. This stand maintains "cool, moist" habitat conditions that will be heavily impacted by yarding operations, tree removal, damage to residual trees, the loss of canopy cover and the 53-89 fragmentation of this isolated "cool, moist" habitat, detrimentally impacting interior habitat conditions and creating excessive levels of edge effect that will transition this currently "cool, moist" forest association into a dry, overly simplified, non-functional habitat. The EA failed to disclose the presence of cool, moist habitats at high elevations, on east- facing slopes and in residual stands of living trees, even after relatively high severity fire effects in the Abney Fire. • The EA failed to spatially identify existing montane habitats containing cool, moist habitat conditions. These habitats disproportionally impact the 53-92 potential for connectivity and climate change induced species dispersal. • The EA failed to spatially identify slope exposures, aspects, topographical features and microclimates that support cool, moist habitats both before and after the Abney Fire. These locations contain the highest likelihood of regenerating montane species and sustaining persistent cool, moist habitats. The EA failed to adequately disclose or analyze the role of snags and downed wood in maintaining cool, moist habitat conditions, retaining soil moisture and encouraging 53-94 regeneration. Analysis of snag removal and its impact on moisture retention and regeneration is lacking in the EA. This applies to all species, but especially to cool, moist, montane associates. The location of the unit at the headwaters of Horse Creek in the Siskiyou Crest Connectivity Corridor creates a significant impact to connectivity across the Siskiyou Crest. The connectivity between watersheds in northern California and southern Oregon will also be significantly impacted by aggressive post-fire logging in this extremely sensitive habitat. 53-272 The concentration of riparian areas and biological legacies is important for the connectivity of late successional associates such as the pacific fisher and northern spotted. Disperal from low elevations to higher elevations often requires intact riparian corridors, which are disproportionally utilized for dispersal. The high density of riparian areas, the white fir

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Comment # Comments dominance and the diversified age class distribution provide clear evidence of "cool, moist" habitat conditions that are important for habitat connectivity and act as climate refugia. The stand is east-facing and contains significant cool, moist habitat necessary for continuing connectivity in the face of climate change.

Comment Response #90: Inconsistent with the Forest Plan Concern statement: There is a concern that the Seiad-Horse project is inconsistent with the Klamath Forest Plan. Forest Service Response: As stated in the National Forest Management Act compliance section of the EA, this project is consistent with the Forest Plan and in compliance with the Act as demonstrated by the Forest Plan Consistency Checklist provided as part of the project record; available on the project website under supporting documents. Associated Comments: Comment # Comments Klamath National Forest Plan Standard and Guideline 6-14 page 4-23. The Seiad Horse 53-62 Project fails to meet these standards and guidelines. The post-fire logging proposed is inconsistent with the KNF Forest Plan and is not 53-161 scientifically justified.

Comment Response #91: Reforestation Strategy not disclosed Concern statement: There was a concern that the EA did not disclose spacing, configuration, and species composition of artificial reforestation proposed and how the prescription would differ from even- aged plantation management. Commenters claim that this lack of information renders analysis of project effects to future fire severity inaccurate as plantation establishment would increase severity. Forest Service Response: The EA provides the following details regarding reforestation: "Reforestation would be accomplished by directly planting nursery-grown seedlings or by allowing natural regeneration. Tree species and spacing would depend on a variety of environmental factors, including considerations of climate change, elevation, slope steepness, slope position, aspect, and soil productivity. Reforestation would avoid creation of densely stocked plantations that would prevent the reintroduction of low intensity prescribed fire at a later date. Seedling survival rates and competition from brush species would create a natural mosaic of species and stocking densities. Hardwoods would be considered when determining whether desired stocking objectives have been met" (EA, page 10). Prior to the Klamath Forest Plan (that incorporates direction from the Northwest Forest Plan), plantations were established by a sequence of intensive management actions that go well beyond the scope of this project decision. The following comparison of past and present management

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strategies from a review of stand record cards on the Happy Camp/Oak Knoll Ranger District where plantations were established under the growth and yield management direction of the past and prior to our current Forest Plan direction was used in developing this project. Similar to current management, the first actions in the past were site preparation by broadcast burning on steeper slopes or mechanical piling and burning on gentler slopes. However, the second action of tree planting was much different than now. In the past about a 50/50 mix Douglas-fir and ponderosa pine was planted at an 8 foot by 8 foot spacing equal to 680 trees per acre. This is about 65% denser than our current planting densities of an average of 250 tree per acre. Currently we also plan to plant sugar pine, incense cedar, and white fir in addition to Douglas-fir and ponderosa pine. The third action included one or two re-plantings if needed to keep high stocking levels. We continue to practice this replanting when survival is very poor, though at a reduced stocking level. The fourth action would have included vegetation and animal control using manual methods, herbicide and rodenticides. Historically chemical treatments were repeated several times to retard vegetation competition and reduce animal damage. These chemical treatments are not proposed by this project. The fifth action that would typically occur up to ten years later was called "crop tree release." Under this former practice only the most desirable species and faster growing stock were left and all other trees cut down or may have been treated by fire. This practice is not proposed by this project and rarely implemented under current management direction. The sixth action would have been a pre-commercial thin by year 20 with possibly another pre-commercial thin at year 30 in preparation for a commercial harvest at year 40 or 50. Sometimes pre-commercially thinned materials would be piled and burned but not always. Through all these practices, fires would be excluded from this environment due to the high density of plantation stock. Thinning and harvesting activities such as this are not proposed by this project, are outside the scope of this project, and may not be appropriate according to the standards and guidelines for these management areas under the current Forest Plan. The bottom line is that this project will not develop the highly stocked plantations seen in the growth and yield days of the past and prior to our current Forest Plan. This project also does not preclude the re-introduction of prescribed fire, as planting densities will be much lower, and as the proposed action includes underburning all salvage harvest and site preparation and plant units. Associated Comments: Comment # Comments Reforestation efforts will not account for drastic microclimate conditions and atypical regeneration patterns. The planting of commercially valuable trees species will 53-76 homogenize post-fire reproduction, crowd out natural regeneration, and flood local genetics with typical timber species such as Douglas fir and Ponderosa pine. By removing large old snags and replanting stands with commercially viable conifer species, the habitat quality and complexity will be significantly diminished for many, many years to come. This is of special concern because unit layout in the Seiad Horse Risk 53-106 Reduction Project will create a nearly 2,000 acre area, denuded of vegetation and revegetated in plantation-like stands. This large area includes post-fire logging and site prep and replant units. In this vast area, essentially all habitat complexity will be removed. The Forest Wide LSR Assessment was created to inform LSR management on the KNF. 53-147 Throughout the document plantation stands (similar to those proposed for creation in the Seiad Horse Project) and post-fire logging are identified as significant impacts and fire risks

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Comment # Comments to LSR values. To now claim that these practices provide benefit to late-seral species is contradictory and unsupported by science. Artificial reforestation will also disrupt natural forest recovery, replacing complex early seral habitats with simplified, plantation-like stands; void of biological legacies. These habitats will be significantly set back by post-fire logging. Instead of growing large diameter trees and to a certain extent relying on the post-disturbance landscape to 53-159 provide decadence and complexity, these logged off and replanted stands must produce both large diameter trees, decadence and complexity, essentially from scratch. The additional biological inputs will take hundreds of years to replace and will impact habitat quality and connectivity for long periods of time. By 52 removing existing dead standing vegetation and replanting with commercial conifer 53-166 species, the Seiad Horse Project will, in fact, create roughly 2,000 acres of new clearcuts in both unmanaged and previously logged stands. The EA failed to provide information regarding the spacing, configuration, species planted and trees per acre planted in replanting units in the Seiad Horse Risk Reduction Project. 53-175 Although the EA states that only productive sites will be planted, no empirical data was presented regarding spacing, density and planting configuration. This lack of information renders the fire/fuel analysis in the EA inaccurate and invalid. Although the EA failed to demonstrate how the proposed artificial reforestation differs from even-aged, plantation management, the KNF has drawn conclusions contrary to the 53-177 best available science regarding the outcome of these actions. The proposed actions will certainly increase future fire severity and the relevant science supports these claims.

Comment Response #92: Fish Habitat Improvement Concern statement: There is a concern that the EA is stating there is a net improvement to fisheries habitat due to the project implementation. Forest Service Response: The fisheries analysis in the EA (pages 79-80) and the Aquatic Resources Report (by reference) acknowledges that minor project-related increase in watershed disturbance is likely to increase adverse effects on fish habitat and populations in the short-term in watersheds that currently are near, at or exceed the threshold of concern for adverse watershed effects and that are vulnerable to further disturbance due the 2017 Abney Fire. However, the fisheries analysis in the EA and the Aquatic Resources Report determined that the project is expected to benefit fish habitat and populations in the long-term over current condition and post-project implementation condition by: (1) reducing risk of future largescale high severity fire that could increase sedimentation and the incidence debris flows that could alter stream channels and remove riparian vegetation shading streams, (2) reducing road-related sedimentation over current condition and post-project implementation condition, and (3) improving fish habitat through the placement of large woody debris.

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Associated Comments: Comment # Comments Current analysis in the EA erroneously suggests a net improvement to fisheries habitat due to project implementation. These claims are arbitrary, capricious and lack scientific rigor. 53-249 They also ignore the real impacts associated with post-fire logging, road construction and landing construction on steep, unstable slopes.

Comment Response #93: Project Design Features and Best Management Practices are Insufficient Concern statement: There is a concern that project design features and Best Management Practices are insufficient to provide adequate resource protection, specifically in regards to weed spread, tractor logging on steep slopes, and surface erosion. Forest Service Response: The Forest has included project design features (EA, Table 7) and best management practices (EA, Appendix D) as part of the project design to address overall project objectives, minimize resource impacts, and the ensure Forest Plan compliance. These project design features and Best Management Practices have proved effective in meeting desired conditions and minimizing impacts to resources in past projects. Forest Service project actions are implemented and monitored by Forest Service personnel as demonstrated in Forest Plan directed annual monitoring and the annual publication of the Klamath National Forest Monitoring and Evaluation Report and referenced in the EA, pages 36-37). Associated Comments: Comment # Comments The Project Design Features (PDFs) for the timber sale indicate that the agency intends to authorize tractor yarding on slopes up to 45% in logging units 7, 31, 89 and 91. (Watershed 49-64 PDF 3). While PDF Watershed 4 allows tractors on post-fire soils on pitches greater than 35% in all proposed logging units. Yet the location, acreage and impacts of this authorized steep-slope ground-based yarding is neither disclosed nor analyzed in the NEPA document. Project PDFs will not reduce the risk of weed spread, just as they failed to do so in the 53-254 Westside Fire Recovery Project.

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Comment # Comments The project does contain best management practices and mitigation measures, which could lower the risk. That said, many of the mitigation measures are insufficient or contain significant caveats. Mitigation measures to reduce impacts from road construction allows language allowing for potential abuse. Project Design Feature "Geology 1 allows for road construction in potentially "unstable land riparian reserves" associated with units 6, 25, 31, 35, 38 and 47. EA at 20. Geology 4 allows the Forest Geologist to override unstable 62-21 land riparian reserve protections vis-a-vis road construction and steep slopes. EA at 21. Similarly, mitigation measures for surface erosion contain large and important carveouts. Watershed 3 allows for ground-based skidding on slopes up to 45% in units 7, 31, 89 and 91. (EA at 26). Watershed 16 allows for skyline cable corridors and yarding through riparian reserves and streams (that is neither disclose nor analyzed in the EA). (EA at 30). Watershed 20 allows the Forest Service Geologist to authorize cable corridors through unstable lands. (EA at 30). Project Design Features will not reduce the risk of weed spread, just as they failed to do so in the Westside Fire Recovery Project. In the planning area and throughout the Klamath 572-17 National Forest, noxious weed spread and cheat grass type conversion is clearly correlated with heavy industrial logging and widespread soil disturbance from yarding practices.

Comment Response #96: Cumulative Effects Analysis Concern statement: There is a concern that the project did not sufficiently address cumulative effects of past and reasonably foreseeable future activities. Forest Service Response: The cumulative effects analysis for the Seiad-Horse project has been updated since the EA was released for public review to include the assumption that all private land in the project area will be harvested regardless of burn severity. As described in Appendix B of the EA, the Horse Creek Community Protection and Forest Restoration Project and other federal projects were considered as ongoing actions and included in the analysis of cumulative effects. The cumulative effects of these activities and others described in Appendix B were addressed in EA. An analysis was provided in the EA and in supporting documents of the cumulative effects of the project on the northern spotted owl and wildlife habitat including its connectivity, please see the EA section on Impacts Related to Relevant Issue 2 and supporting wildlife biological evaluations and reports for this analysis. For information about cumulative effects to aquatic resources and fish, please refer to the Aquatic Resources report. For information about cumulative effects to water quality and watershed condition, refer to the Analysis of Effects Related to Hydrology section of the EA. For information about cumulative effects to future fire severity, refer to the EA section on Impacts Related to the Project Need regarding Reduced Risk of Future Large-Scale, High Severity Fire Losses of Late Successional Habitat.

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Associated Comments: Comment # Comments The Forest Service failed to analyze and disclose the cumulative impacts of the fire, fire suppression activities, and post fire logging on slope stability, landslides and sediment 49-53 production via an EIS. This is particularly important in a planning area that includes well- traveled public roads and salmon-bearing streams. Page 29 of the Aquatic Resources Report indicates that "[c]umulative watershed effects modeling results suggest that watershed function is being adversely impacted by high levels of watershed disturbance." Yet the KNF intends to dramatically increase watershed 49-61 disturbance via new road construction, landing establishment, yarding activities and clearcut post-fire logging. Hence an EIS must be completed for this project. The decision to likely adversely affect Coho Salmon and their Essential Fish Habitat necessitates completion of an EIS. The EA failed to disclose and analyze the cumulative impacts of the proposed fire salvage in conjunction with prior and foreseeable management activities and the extensive clearcutting of private pre and post-fire forestlands. The EA failed to address the 49-72 cumulative impacts on future fire behavior, snag retention, soil health, hydrology and wildlife. Please disclose the connected and cumulative impacts of the fires themselves and fire suppression activities. Please note that a proper consideration of the cumulative impacts of a project requires "some quantified or detailed information; [g]eneral statements about some possible effects and some risk do not constitute a hard look absent a justification regarding why 49-73 more definitive information could not be provided." Neighbors of Cuddy Mountain v. United States Forest Serv., 137 F3d 1372, 1379-80 (9th Cir. 1998)). The analysis "must be more than perfunctory; it must provide a useful analysis of the cumulative impacts of past, present and future projects." Id. Given the impacts of past Forest Service logging and road activities on the hydrological and 49-75 terrestrial health of the project area, it is vital that the agency analyze and disclose the cumulative impacts of past activities and its future plans.

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Comment # Comments The public and the decision maker must be able to discern whether these factors resulted in significant impacts when considered cumulatively with the proposed action. Consideration and disclosure of cumulative impacts should include, but not be limited to, the following issues: 1. All past "shelterwood" cuts and clear-cuts, including their impacts on overall canopy cover, old growth quality and extent, and habitat suitability for canopy dependent species including sensitive and indicator species. 2. All past crown fires, including their impacts on overall canopy cover, old growth quality, quantity and extent, and habitat suitability for canopy dependent species including sensitive and indicator species. 3. Past changes in forest structure, including those resulting from the fire, and their impacts on wildlife habitat and populations. 4. Invasive plant populations occurring in past timber sales, along roads and in past fire perimeters, and the potential for the proposed action and/or spatially or temporally concurrent management to introduce and 49-78 increase invasive plant populations within the project area. This analysis should also evaluate invasive plant population responses to climate, seasonality, soil, slope, aspect, land uses, management activities, timing and interactions therein. 5. Overall fire management goals for the planning area, especially the Forest Service's ability to employ Wildland Fire Use as a management tool. The Forest Service should specifically frame the proposed action in terms of fire management goals, and it should demonstrate in the context of cumulative effects analysis—using maps, GIS and a Fire Management Plan— how the proposed restoration activities serve as a corrective step that facilitate managing natural fires both within and beyond the project area in the future. 6. Location of the project area and proposed management activities, including roads and skid trails, in relationship to the location of important wildlife habitat, both formally protected habitats and other important habitat, such as wildlife movement corridors. None of these impacts were analyzed in the Seiad Horse Risk Reduction Project EA, thus 53-26 the analysis of current conditions and cumulative impacts is inadequate, incomplete and misleading. 53-29 These cumulative impacts were not addressed in the Seiad Horse Project EA. The EA failed to disclose or analyze the levels of fire severity in the Abney Fire and their connection to past forest management practices. The EA also failed to disclose that 53-37 previous post-fire logging and reforestation units burned at mostly high severity in the Abney Fire. Obvious site-specific analysis and scientific/academic literature identified through substantive comment was ignored by KNF planners. The EA failed to provide specific consideration regarding the cumulative impact associated 53-120 with road 47N80 including impacts to hydrology, recreation, scenic qualities, botanical qualities, Baker's cypress habitat, roadless values and OHV trespass. The cumulative impact of this increase in logging slash was not analyzed in the Seiad Horse 53-180 EA.

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Comment # Comments The EA failed to disclose and analyze of the intensity of cumulative impacts associated with the Seiad Horse Risk Reduction Project and other recent and nearby impacts. Analysis of the Seiad Horse Risk Reduction Project did not include detailed analysis of cumulative impacts in the Seiad Creek, Horse Creek and Mid-Klamath River watersheds. The cumulative impacts should also be analyzed in regards to the connectivity of the Siskiyou Crest. Cumulative impacts affecting the project area include discretionary fire suppression activities, post-fire logging on private land in the Beaver Fire and Gap Fire footprint, post- 53-199 fire logging on federal land in the Westside Project and Horse Creek Community Protection and Restoration Project, legacy sediment sites, new road and landing construction and other anthropogenic impacts. The effect of these cumulative impacts has severe consequences to stream habitats, water quality, endangered fisheries, water temperatures, peak flows, late seral forest habitat, forest complexity, future fire severity, connectivity of habitat, connectivity between LSR forests, and connectivity on the Siskiyou Crest. All postfire logging units proposed in the project should be canceled due to extreme 53-200 cumulative effects to fisheries and water quality. The EA failed to disclose and analyze the cumulative impact of private and federal land logging in the Horse Creek, Seiad Creek and the Mid-Klamath River watershed. • The EA failed to adequately analyze the cumulative impact to fisheries, water quality, water temperature and other measures of stream health in the Horse Creek Watershed. • The EA 53-201 failed to disclose and analyze the cumulative impact of discretionary fire suppression activities in the Abney Fire and in the nearby Gap Fire. • The EA failed to disclose or adequately analyze the cumulative impact to habitat values, connectivity, wildlife, fisheries, fuel loads, etc. from private and federal land logging. The impact of management activities proposed in the Seiad Horse Risk Reduction Project on coho salmon and other fisheries must be analyze along with the cumulative impact of 53-247 private and federal land post-fire logging, natural fire related effects, cattle grazing, fire suppression activities (including many miles of dozerline and contingency line built in the Gap Fire, Beaver Fire and Abney Fire), road related impacts and legacy sediment 75 sites. The EA failed to adequately disclose and analyze the impact of proposed management activities on coho salmon and other fisheries. • The EA failed to adequately disclose and analyze the cumulative impact of proposed management activities on water quality and fisheries, along with the impact of fire suppression impacts, private and federal land 53-251 logging, fire related effects, cattle grazing, road related impacts and legacy sediment sites. • EA analysis of cumulative impacts to water quality and fisheries is arbitrary, capricious and lacks scientific rigor. Placing large wood in a section of stream does not negate the additional impact of post-fire logging, new road building and new landing construction. The cumulative impact of noxious weed spread associated with post-fire logging on the 53-255 Klamath National Forest was not adequately analyzed in the EA. To begin, just because a project activity has been proposed elsewhere (as claimed in the EA) does not mean it is not controversial or not a significant impact to the environment, 54-8 particularly in the context of cumulative impacts from surrounding logging. Thus, the project EA grossly underestimates cumulative impacts as stated herein and will lead to loss of forest integrity via compounded disturbances (Paine et al. 1999).

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Comment # Comments In order to look at the viability of species populations the agency must consider the impacts from the recent and widespread logging throughout this region, to include all 59-2 private and public land projects and should include changes in habitat conditions from recent fire events as well. The cumulative impact of noxious weed spread associated with post-fire logging on the Klamath National Forest was not adequately analyzed in the Seiad Horse EA. The SCNPSO 572-18 is very concerned with the spread of noxious weeds throughout areas subjected to post- fire logging.

Comment Response #97: Sensitive Plant Viability Post-Fire Concern statement: There is a disagreement with the analysis assumption for sensitive plant species, including Pedicularis howellii (Howell's lousewort), that plant populations within moderate or high severity burned areas are no longer viable due to the effects of the fire. The commenter states that these species are fire-adapted and may have responded positively to the fire; their presence should be field-verified. Forest Service Response: Thank you for your comment regarding the assumptions about survival of known sensitive plant populations. Extirpated populations are assumed to be in areas where vegetation and duff layers have been entirely killed or consumed by fire activity. This assumption is used in order to establish a baseline reference for determining the significance of further potential project effects on remaining populations. Some assumption is necessary in this analysis as comprehensive field surveys and or visits were not feasible for all Forest Service Sensitive species during the analysis period. However, prior to project implementation, all sites known to exist before the 2017 Abney Fire will be monitored and flagged for avoidance as appropriate. Additionally, as modeled and discussed in the botany resource report, areas considered to contain suitable habitat will also be surveyed. In regards to Pedicularis howellii, this species is cannot survive without root attachments to its host plants. In areas where all vegetative plant material has been killed, it is highly unlikely that existing populations of Pediculosis howellii were able to survive without their host plants. However, as stated above, all populations known to occur in the project area prior to the Abney fire will be monitored and flagged as appropriate. Associated Comments: Comment # Comments Analysis of sensitive plant species in the Draft Botanical and Resource and Non-native Invasive Plant Report assumes that sensitive species in moderate to high burn severity based on RAVG data are assumed either extirpated or are no longer expected to maintain 53-257 viable populations (USDA. 2018d p.9). This assumption is inaccurate and taints all analysis of impacts. Many species in the Klamath-Siskiyou Mountains, especially herbaceous understory or herbaceous species can survive even severe wildfires. In fact, some species

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Comment # Comments respond very positively to wildfire, even if moderate or high severity effects occur....In particular, one population of Pedicularis howellii is currently considered extirpated (USDA. 2018d). , this assumption is likely in error. Howell's lousewort only grows in a small area in northern California and southern Oregon. According to the Seiad Horse EA there are two known populations of Howell's lousewort found within the Seiad Horse Project area, specifically in an area proposed for prescribed fire. The EA erroneously assumes, without field monitoring or on-the-ground evidence, that one of the populations of Howell's lousewort has been extirpated due to fire severity, however, due to the rocky location that it usually lives in, soil burn severity is likely to have 572-8 been low or patchy, and it is feasible that the population still exists. The EA's assumption that high-severity fire kills off fire-adapted species such as Howell's lousewort, without verification, is of concern and should be followed up with field verification. Logging in the Seiad Horse Project will likely impact Howell's lousewort dispersal habitat, as suitable habitat exists in numerous locations within the project area; however, if Howell's lousewort's dispersal habitat is logged and degraded the Seiad Horse Project may have adverse impacts on the long-term survival and dispersal of Howell's lousewort.

Comment Response #100: Range of Alternatives Concern statement: There is a concern that the EA did not analyze a reasonable range of alternatives as the outcomes of the alternatives considered were largely similar. Commenters also suggested additional alternatives be considered that do not consider the following activities: salvage harvesting in Late Successional Reserves, in KLE-6 and owl core areas, or anywhere in the project area, conducting site preparation and planting in the project area, constructing any new temporary roads, removing hazard trees from the Bee Camp road, or removing any trees. They also recommended we consider retaining all trees that are greater than 20 inches in diameter at breast height, spreading native grass seed on high severity burned area, or include prescribed fire. Forest Service Response: Thank you for the recommendations for alternative actions the Forest Service may consider. The requirements for what must be considered in an EA are defined in 36 CFR 220.7(b)(2), where it states that an EA must include "Proposed action and alternative(s). The EA shall briefly describe the proposed action and alternative(s) that meet the need for action. No specific number of alternatives is required or prescribed." This is further clarified by 36 CFR 220.7(b)(2)(i) and (ii) which state "when there are no unresolved conflicts concerning alternative uses of available resources (NEPA, section 102(2)(E)), the EA need only analyze the proposed action and proceed without consideration of additional alternatives. The EA may document consideration of a no- action alternative through the effects analysis by contrasting the impacts of the proposed action and any alternative(s) with the current condition and expected future condition if the proposed action were not implemented." The scoping comment period is the provided opportunity to suggest alternatives or share relevant issues for the consideration of alternative development. As such, during the scoping comment period many of these same suggestions were made. The EA at the time of its release for the public review and comment period demonstrates the consideration of a range of six alternatives.

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These alternatives address many of the suggestions provided by commenters here. Please refer to this section of the EA to see how these alternatives were considered. The EA has also been updated since its release for public review to include Alternative D. Alternatives A through D, and the no action alternative address these suggestions and demonstrate they would not meet the purpose and need of the project. As these comments do not provide any new unresolved conflicts that have not already been considered, these newly proposed alternatives provided outside the scoping period will not be considered further. Associated Comments: Comment # Comments Our scoping comments requested that the agency please consider developing and implementing an action alternative in which reserve land use allocations are not subject to unit salvage logging. This the Forest Service refused to do. The decision to clearcut LSRs 49-18 was preordained and inevitable and this NEPA process is designed to support a decision that has already been made to convert the LSR forests into fiber producing timber plantations for the benefit of the timber industry. Please note that your colleagues in the Rogue River-Siskiyou National Forest are not proposing LSR unit salvage logging in high severity post-fire stands associated with the Abney fire, the same fire that burned the forests that the KNF hopes to clearcut. Please further note that in December 17, 2017 your colleagues in the Shasta-Trinity National Forest signed a Record of Decision for the Trinity Post Fire Hazard Reduction and Salvage 49-23 Project that avoided unit salvage logging entirely, including within the LSR land use allocation. Line officers in those two National Forests are wisely focusing post-fire management actions on roadside hazard removal rather than controversial back-country clearcutting of reserve land use allocations. The development and consideration of such action alternatives is clearly reasonable as evidenced by other post-fire Forest Service plans throughout the region. Instead, the Klamath National Forest developed two action alternatives that maximize logging in the Late Successional Reserve land use allocation which would produce substantively identical outcomes depriving the decision maker of a reasonable range of 49-111 action alternatives necessary to weigh trade-offs and arrive at an informed decision. Both action alternatives would construct exactly 8 new logging roads at undisclosed locations. (EA pages 8 and 13.) The Comparison of Alternatives provided on page 51 of the BE indicates that the agencies 49-121 logging alternatives have identical effects determinations for each and every Forest Service Sensitive Species. The project planning process has precluded the ability of the public and the decision 49-122 maker to compare reasonable alternatives, weigh trade-offs, and arrive at an informed decision. The creation of slash should simply be avoided by choosing a non-salvage alternative and 53-184 utilizing prescribed fire around the community of Horse Creek and Seiad Valley when sufficient fuel is available. All post-fire logging, road building, and replanting units should be canceled. Roadside hazard logging should proceed except within riparian reserves, in NSO nesting cores and 53-284 home ranges, in portions of the LSR that are lacking CWD, and on Bee Camp Road (48N70). Prescribed fire treatments (implemented in the fall) should be used to reduce fuel loads in

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Comment # Comments post-fire, regenerating forest habitats. Fuel loads will require at least 10 years to create conditions conducive to prescribed fire use. Proposed private land fuel reduction buffers should also proceed. Finally, Bee Camp Road (48N70) should be permanently closed to vehicle traffic at Cook and Green Pass Road. All substantive issues and site/unit specific concerns must be addressed in a full Environmental Impact Statement (EIS) to allow for adequate analysis and consideration of relevant issues. The impacts of the currently proposed project and the importance of the landscape in question are simply too great to be adequately addressed in an EA. A full EIS must be prepared and relevant issues addressed in the action alternative. One action alternative should be prepared that follows the criteria described above. We also request that you analyze an alternative that does not include hazard tree removal 54-13 along this road bisecting the roadless area and instead using other options as noted below in discussion of the guidelines. We request you analyze an alternative that precludes logging in the KLE-6, LSRs, and owl 54-33 core areas using different hazard tree marking guidelines as noted below. We request that you issue an EIS that evaluates non-tree removal actions to minimize 54-55 impacts to NSO, Riparian Reserves, and the LSR. We request a full EIS including a range of alternatives that minimize impacts by: • Prohibiting logging along the two miles of Forest Service Road 47N80 bisecting the Kangaroo Roadless Area; • Retaining large (>20 in dbh) trees in NSO habitat, LSRs, and Riparian Reserves; • Including actions other than tree removal in reserves, owl cores, and owl habitat as provided by the PSW hazard tree marking guidelines (this could include road closure for safety reasons); • Narrowing the project scope to within the road prism along 54-63 high use roads, thereby substantially reducing miles of hazard tree removals; • Adhering to the NSO recovery plan and critical habitat determination on post-fire logging; • Addressing limitations of fuel breaks, and need for ongoing maintenance, especially invasive species containment and problems with human-caused wildfire ignitions posed by increased access along fuel breaks; and • Working with private landowners to reduce their contributions to uncharacteristically severe wildfires from their intensive logging and road building operations. He would like to see native grass seed spread out over some of the high severity burned 58-2 areas. We urge the agency to— retain all large trees in the project area, drop the units on West Fork Horse Creek, follow recommendations of the NSO Recovery Plan and Horse Creek 59-21 WA, maintain and restore species populations, protect habitat connectivity and to concentrate treatments along roads and private property boundaries. I suggest that post--fire logging be canceled and the Seiad Horse project turned into a 573-4 post--fire study that helps biologists and fire managers better understand the ecological role of fire in the Klamath National Forest on the Siskiyou Crest. The Seiad Horse EA did not adequately analyze the No Action Alternative, which would 573-5 allow for long--term scientific study of the Abney Fire on the Klamath National Forest.

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Comment Response #101: Karuk and Beschta Alternatives Concern statement: There is a concern that no alternative was developed based on the Karuk scoping comments or suggestions from commenters during scoping to apply the methods suggested by Beschta's (1995) research. Forest Service Response: The commenter is correct that a specific alternative proposing actions based on recommendations from the 1995 Beschta et al. paper entitled "Recommendations for Ecologically Sound Post-Fire Treatments on Federal Lands" was not included in the EA at the time of its release for public review. The EA has been updated to include these recommendations as an alternative considered but eliminated in detailed study because the alternative would not meet the purpose and need of the project. The Karuk Tribe submitted a letter about the project on February 2, 2018 with their consultation comments, which was after the public scoping comment period and prior to the public comment period. In their letter, the Karuk expressed comments of the projects which they were supportive of and those they were not supportive of. Although the Karuk Tribe did not suggest an alternative, the Forest considered those component preferences. After consideration, it was determined that the variation on the components being suggested were already addressed through other alternatives. Since the other alternatives considered are already responsive to the Karuk Tribe comments, developing another alternative would be duplicative and would not further contribute to the range of alternatives. The EA has been updated to describe how the suggestions from the Karuk Tribe were considered (see EA, Alternatives Considered but Eliminated from Detailed Study, Alternative E). Associated Comments: Comment # Comments KNF timber planners refused to develop or consider a reasonable action alternative (such as the Karuk or Beschta alternatives that were suggested during the scoping period) that 49-55 would implement the direction of the Aquatic Conservation Strategy (ACS) and the Clean Water Act (CWA), to improve, rather than further degrade, aquatic resources in the project area. During the scoping period for the Seiad-Horse logging project our organizations propose that the Forest Service include analysis of an alternative based upon all of the post-fire 49-108 management recommendations contained in the peer-reviewed 1995 Bestcha paper provided as an attachment to our scoping comments and that retains (rather than logs) high elevation LSR snag habitat on the Siskiyou Crest. This the Forest Service refused to do. The Klamath National Forest also refused to develop and consider an Action Alternative 49-109 that mirrored the proposals outlined by the Karuk Department of Natural Resources in their scoping letter. Please note that the timely Karuk scoping comments specifically requested that KNF timber planners develop and analyze an action alternative in which "salvage activities 49-110 concentrate in plantations to reduce overall conifer density." In a parallel post-fire management NEPA planning process, your colleagues in the Rogue River Siskiyou National

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Comment # Comments Forest (RRSNF) have developed an action alternative, like the one suggested by the Karuk, in which post-fire logging is limited to existing plantations, as opposed to converting native post-fire forests into additional fiber plantations. Please also note that RRSNF timber planners determined that it would be inappropriate under the NW Forest Plan to target the LSR land use allocation for post-fire clearcutting. Hence such alternatives are reasonable for the KNF to consider in order to allow for informed decision making 50 regarding project impacts and trade-offs. For the details of the RRSNF salvage logging proposal and range of alternatives see: https://www.fs.usda.gov/project/?project=53150

Comment Response #104: Prescribed Fire Implementation Concern statement: There is a concern on the timing, use, and placement of the underburning the Forest is proposing. The Pacific Crest Trail (PCT), Inventoried Roadless Areas (IRAs), Botanical Special Interest Areas (SIAs) and Late Successional Reserve (LSR) are especially a concern and would like to see Minimal Impact Suppression Tactics (MIST) used during the burning. Forest Service Response: We agree that informing the PCT Association would be a good idea if any known impacts to the PCT will occur. Tactics that meet the Forest Plan and Project Design Features will occur. Prescribed burn plans will be prepared to meet the need of the Seiad-Horse Risk Reduction Project. This will include any necessary limiting operating periods and other measures to reduce the impacts to wildlife and aquatic species. Many of the burns will likely take place in the fall and maintaining adequate amounts of coarse woody debris is built into design of the project. Roads, ridgelines, and natural features will be used whenever possible as fire lines for the prescribed burning. Associated Comments: Comment # Comments Lastly, in regards to the proposed underburn that would effect a section of the PCT. We understand that planning for and scheduling prescribed burns are subject to suitable 52-10 conditions. Please inform PCTA as soon as possible once an underburn is planned so that we can work with local Forest staff to ensure that PCT users are informed of current conditions and they can plan accordingly.

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Comment # Comments We also believe prescribed fire treatments should be conducted as fall burns to reduce impacts to wildlife and plant communities. Care should be taken to protect roadless values and create low to moderate severity fire effects. MIST tactics should be implemented in prescribed fires located in Inventoried Roadless Areas, Botanical Areas, LSR forest, and adjacent to the PCT. Roads and major ridges should be utilized for fireline whenever possible and dozers should not be utilized to either create fireline or Old-growth snags 53-280 proposed for post-fire logging in LSR forest will not benefit LSR forest values. 91 reopen old firelines. All fireline should utilize existing roads, natural features and/or be built by hand. The agency should prepare prescribed fire prescriptions designed to take advantage of fall conditions, create patchy, mixed severity fire effects and maintain adequate levels of coarse woody debris. The agency should also consider night burning to achieve more low/moderate severity results.

Comment Response #105: Small Brush Re-sprout Concern statement: There is a concern that cutting all live hardwoods under 6 inches will create a significant re- sprout potential and increase brush response making for an even more flammable landscape. Forest Service Response: Even as one of the goals is to reduce the density of understory vegetation and resulting fire behavior, not every hardwood under 6 inches will be cut. Spacing requirements will be met with smaller trees if no larger trees are present which would limit the amount continuous re-sprout or brush response. Every treatment has a period of effectiveness. The fuels treatments proposed will be effective for 7 to 10 years when maintenance will be necessary for re-sprout and new growth of ladder fuels. Associated Comments: Comment # Comments We are concerned that cutting all live hardwoods under 6" would create significant resprout potential and increase in brush response that would result in an even more 59-19 flammable landscape condition in combination with other treatments and plantation creation. Please reconsider not cutting hardwoods or only pruning.

Comment Response #106: Effects of Temporary Roads and Landings Concern statement: There is a concern with the effects of building new temporary roads and using existing temporary roads considering the current road density in the project areas and the long term nature of their effects. Forest Service Response: No new system roads are proposed for construction in the project. Temporary roads are proposed according to the operational needs of the activities proposed in Alternatives 2 and 3 and to meet the management objectives of the project. Best management practices and project design features will be implemented with any project action alternative to direct placement of and aid in

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successful closure and rehabilitation of temporary roads (see Table 7 of the EA, PDF Geology 1, 4, Non-Native Invasive Species 4, Watershed 7, 11, 21, 24, and Fisheries 2, Appendix C - Aquatic Conservation Strategy, and Appendix D - Best Management Practices). All temporary roads will be hydrologically stabilized following use, including out-sloping of road surfaces and proper construction of water bars. Erosion and sedimentation control structures (water bars) would be maintained and repaired according to the guidance in the Forest Service Handbook 2409.15 Region 5 Supplement (USDA 2012b). The effects of temporary roads are included in the analysis of project effects presented in the EA and its supporting documents. Associated Comments: Comment # Comments Build no new logging roads, either "temporary" or "permanent" roads, in the planning 5-13 area. The response of KNF timber planners to the information on page 28-29 quoted above is to 49-86 propose more road construction, log landing establishment and ground-based yarding in the watershed. Simply calling a road "temporary" does not make it so. Many of the impacts are long term, especially if the road is built on contour across steep slopes and full bench cuts. Often "temporary" roads are not recontoured, thus the long-term potential for sedimentation, 53-232 soil erosion, soil compaction, increased noxious or non-native weed spread, unauthorized OHV use, and future use in timber sales or fire suppression activities is elevated above the natural condition. The impacts are in fact, long-term despite the "temporary" euphemism. Current road density in the Seiad LSR is 1.9 miles per square mile, meaning no more roads 53-236 should be constructed. The Seiad Horse Project EA proposes eight new "temporary" road segments. Even temporary roads have long-lasting ecological impacts, in particular on native plant 572-22 populations that are bulldozed during "temporary" road construction. The SCNPSO opposes all new road construction, even so-called "temporary" road construction in the Seiad Horse Project.

Comment Response #107: General Project Opposition Concern statement: There is general opposition to the project because of its effects to recreation, water quality, fisheries, wildland resources, scenic vistas, native plants, wildlife habitat, and other social and ecological values. Commenters also believe that the project will not effectively achieve the goals set out by purpose and need of the project. Forest Service Response: Thank you for your comments on the Seiad-Horse Project. Comments that state a position for or against a specific action are appreciated as this gives the Responsible Official a sense of views and beliefs about a proposed course of action. While such information can be used by the decision maker in arriving at a decision, it cannot be used to improve the environmental analysis or documentation. An analysis of the effects to the resources about which commenters are concerned, and how project activities will meet the project's purpose and need, are presented in the EA and its supporting documents.

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Associated Comments: Comment # Comments 12-1 Protect our forest for the sake of biological diversity and future citizens! Far from restorative, the Seiad Horse Risk Reduction Project will degrade important 53-2 biological values, increase fuel loading, inhibit natural regeneration and heavily impact aquatic habitats. The project will not encourage late successional habitat values, 2 regenerate complex, 53-11 young forest in high severity burn areas, or address fuel/fire risks in the planning area. The impacts to human communities and values will be significant including recreation, water quality, fisheries, etc. Many individuals around the region will be harmed by 53-16 implementation of this project. Implementation of the project will degrade their use of and experience on public lands. The project will also create significant ecological impacts including the disruption of 53-17 natural regeneration, an increase in fuel loads, loss of important biological legacies, impacts to wildlife habitat, biodiversity and water quality. The project also includes logging old-growth trees and snags, roadside hazard logging, fuel reduction, underburning and/or road construction adjacent to the Condrey Mountain Inventoried Roadless Area, Cook and Green Botanical Area, Seiad Baker's Cypress Botanical 53-21 Area, Condrey Mountain Designated Back Country Area, Kangaroo Designated Back Country Area and the Pacific Crest Trail, all of which include highly important social and ecological values. The Seiad Horse EA Project degrades, rather than protects or restores complex habitat 53-54 conditions. The greatest good for the greatest number of people would entail managing the Cook and Green Pass and PCT area for its wildland resources, scenic vistas, intact native plant communities, and wildlife connectivity. The Seiad Horse Project fails to maintain these 53-203 resources and will instead degrade them. This net loss in the resources, experiences and recreational opportunities expected by the public in the Cook and Green Pass and PCT area, constitutes a failure by the KNF to responsibly manage public trust resources.

Comment Response #108: Activities Proposed in the Inventoried Roadless Areas Concern statement: There is a concern that roads will be built in inventoried roadless areas and that large diameter trees will be removed. Forest Service Response: There are no roads being built or salvage harvest units planned in inventoried roadless areas. Tree removal in inventoried roadless areas is limited to roadside hazard tree removal along about 2 miles of forest road 47N80 (Bee Camp Road) in Alternative 2 and 1.5 miles in Alternative 3; this road is a management level 2 road which is open to public use. For large diameter trees, which are equal to or greater than 45 inches in diameter, we would identify any fire-injured trees that have a 90 percent probability of dying in the next three to five years using the criteria in Report #RO-11-01 "Marking Guidelines for Fire-Injured Trees in California." These fire-injured

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trees, which have a 10 percent or less probability of surviving, would be considered potential hazards, a safety concern for users of this road, and would be marked for cutting. The Roadless Rule allows the cutting, sale, or removal of timber when it is "is incidental to the implementation of a management activity not otherwise prohibited" by the rule (36CFR 294.13(b)(2)). The Deputy Regional Forester reviewed the project and determined: 1) the Project is consistent with the 2001 Roadless Area Conservation Rule, 2) a briefing of the national headquarters staff (Washington Office) is not necessary, and 3) the Project will protect roadless area characteristics. The approval letter documenting this decision is included in the project record; on the project website under supporting documents. Associated Comments: Comment # Comments There is actually a large designated area, much of which is planning to be logged and have 5-6 roads built in another wise roadless and wild region. The EA failed to adequately disclose and analyze the mandates of the Final Roadless 53-119 Conservation Rule, limiting tree removal to "small diameter trees." 453-4 Please don't build roads inside Roadless Areas.

Comment Response #112: Botany Retention Areas Concern statement: There is a question regarding clarification of Botany retention areas displayed on the Modified Proposed Action map. The commenter would like to know what species the botany retention areas are for. Forest Service Response: Botany retention areas were determined based on modeling of areas that are thought to contain low to unburned late-seral or old-growth forest conditions. Model parameters largely focused on tree species, community type, canopy closure, and average tree diameter at breast height, as well as RAVG data for areas that received little to no burn severity. Areas selected were modeled as containing suitable habitat for Category B Survey and Manage Fungi species, and the activities proposed in them were not exempt from survey needs under the Northwest Forest Plan or the Pechman Exemptions (see the survey and manage section of the "Botanical Resources and Non- Native Invasive Plant Report"). Therefore, in order to ensure compliance with Survey and Manage Guidelines, these areas were excluded from treatment as botany retention areas. Associated Comments: Comment # Comments Can you please clarify what the two designated "Botany Retention" areas are on the Alternative 2-Modified Proposed Action Map for Range of Coho Salmon, Chinook Salmon, Steelhead trout, and Rainbow trout. In total the map depicts 13 acres of total "Botany 572-10 Retention" area without any further explanation. What species are these "Botany Retention" areas for? The Seiad Horse EA does not fully develop the information regarding proposed "Botany Retention" areas.

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Comment Response #113: Wildlife Species not included in Analysis Concern statement: There is a concern that the wildlife analysis did not sufficiently consider project effects on several species, including: Great grey owls, wolves, pacific fisher, marten, wolverine (recently seen in the vicinity), Siskiyou mountain salamander, NSO prey species (such as dusky footed woodrat), pollinators, butterflies, and sensitive bat species. Forest Service Response: The Forest Service is required to analyze project impacts to specific species identified in policies and regulations. The effects to these species and those listed by the commenter were analyzed and disclosed within either the project Biological Evaluation (for Forest Service Sensitive species: fisher, marten, wolverine, goshawk, sensitive bat species, Siskiyou mountain salamander, great gray owls, and a pollinator the western bumble bee), Northern Spotted Owl Report, or the Wildlife Survey and Manage Report (for Forest Service Survey and Manage species: Siskiyou mountain salamander, great gray owl). The EA references these reports but does not include details of the analyses. Information on species specific effects are described within each report. The EA also references the Biological Assessment (for federally listed species: wolf, northern spotted owl and its prey), that will be available to the public once it is accepted by the U.S Fish and Wildlife Service. Associated Comments: Comment # Comments Our scoping comments also asked the agency to please disclose and analyze potential site specific and cumulative impacts to Siskiyou Crest species such as Great Grey Owls, Pacific 49-11 Fishers and sensitive bat species. Again, this requested analysis and disclosure did not occur. Page 26 of the BE indicates that: "The loss of canopy cover from high severity fire may not necessarily affect micro-site conditions equally across sites thus other factors may need to be considered to determine whether a site may persist after a disturbance event." Yet the timber sale analysis documents are unclear as to how and whether Siskiyou Mountain Salamander habitat will be surveyed or buffered from ground-disturbing 55 activities. Data regarding Salamander locations and populations in the project area is not provided in the 49-129 NEPA analysis. Yet "treatment is proposed in areas [consisting of known SMS sites] that burned at high severity ad have lost most or all the canopy cover." Page 38 of the BE indicates that "[d]espite the changes in vegetation resulting from the fire, these sites are likely to by occupied." Page 49 of the BE reveals that known occupied SMS sites will in fact be logged, rather than buffered in both roadside and unit logging prescriptions. This violates both NFMA, the Survey and Manage program of the NW Forest Plan and the Klamath National Forest LRMP. The EA failed to adequately disclose and analyze the impact of post-fire logging on 53-123 sensitive wildlife species such as the Pacific fisher, marten and wolverine. The Seiad Horse Risk Reduction EA failed to disclose this documented wolverine siting 53-124 despite its proximity to the planning area.

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Comment # Comments Currently, the KNF has no credible information documenting a lack of wolverine occupancy 53-128 and the Siskiyou Crest is the most credible connectivity corridor for dispersal between mountain ranges. The EA failed disclose all NSO habitat designations (NRF, dispersal, nonhabitat) within the planning area. A map depicting NSO habitat designations should accompany the EA. • The 53-139 EA failed to disclose and analyze the use of high severity fire areas for foraging and dispersal of both NSO and pacific fisher. The EA failed disclose and analyze the impact of the Abney Fire on the abundance of NSO 53-141 prey species, including the dusky footed woodrat. • The EA failed to disclose the previously documented wolverine sighting at Alex Hole, on a 53-287 few miles east of the planning area. The size of a pollinator often correlates to the size and shape of a flower, as well as the lifecycle correlating to the bloom time of the plant they have evolved to use for food and/or as a larval host plant. One could write a thesis on this subject and the SCNPSO encourages the Klamath National Forest to fully address the needs of pollinators' lifecycles in the analysis of the Seiad Horse Project. Even Douglas fir trees are important larval host plants for particular species such as the Deceptive sallow moth (Feralia deceptiva). This moth can be locally rare and sporadic and was not accounted for in the Seiad Horse Risk Reduction Project EA. A selected list of native butterflies that most likely occur in the Seiad Horse Project area and their larval host plant(s) is as follows: Butterflies: * Purple hairstreak (Atlides halesus) uses oak mistletoe (Phoradendron spp.) * American painted lady (Vanessa virginiensis) uses pearly everlasting (Anaphalis margaritacea) or pussytoes (Antennaria spp.) * Painted lady (Vanessa cardui) uses native thistles (Cirsium spp.), lupines (Lupinus spp.) and fiddleneck (Amsinckia menziesii) * Western tiger swallowtail (Papilio rutulus) uses cottonwood (Populus trichocarpa), aspen (Populus tremuloides), willows (Salix spp.), wild cherry (Prunus spp.), and ash (Fraxinus latifolia) * Two-tailed swallowtail (Papilio multicaudata) uses ash (Fraxinus latifolia) and chokecherry (Prunus 572-20 virginiana) * Pale tiger swallowtail (Papilio eurymedon) uses Ceanothus species * Anise swallowtail (Papilio zelicaon) uses plants in the Apiacea family, including: (Lomatium spp.), (Heracleum maximum), (Angelica arguta), (Ligusticum spp.), (Osmorhiza spp.), (Perideridea spp.), (Sanicula spp.). * California tortoiseshell (Nymphalis californica) uses deerbrush and other Ceanothus species * Clodius parnassian (Parnassius clodius) uses bleeding heart (Dicentra formosa) * Red admiral (Vanessa atalanta) use stinging nettle (Urtica dioica) * Snowberry checkerspot (Euphydryas colon) uses snowberry (Symphoricarpos albus) * Mylitta crescent (Phyciodes mylitta) uses native thistles (Cirsium spp. such as C. occidentalis) * Lupine/Boisduval's blue (Plebejus icarioides) uses Lupines (Lupinus spp.) and buckwheats (Eriogonum spp.) * Acmon blue (Plebejus acmon) uses buckwheats (Eriogonum spp.) etc. * Buckwheat blue (Plebejus lupini) uses buckwheats (Eriogonum spp.) * Zephyr anglewing (Polygonia gracilis) uses currants and gooseberries (Ribes spp.) * Sara's orangetip (Anthocharis sara) uses plants in the Brassicacea family, especially rockcresses (Arabis spp.) * Satyr anglewing (Polygonia satyrus) uses stinging nettle (Urtica dioica) * Ediths' checkerspot (Euphydryas editha) uses: paintbrush (Castilleja spp.), (Penstemon spp.), lousewort (Pedicularis spp.), owl's clover (Orthocarpus spp.), and Chinese houses (Collinsia spp.)

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Comment # Comments * Additionally, many butterfly species use native grasses as larval host plants, so it is important that native grass communities are protected from management impacts (e.g. timber yarding, timber felling, temporary road construction, etc.). The following butterflies 572-21 that likely occur in the planning area use native grasses for larval host plants: * California ringlet (Coenonympha tullia california) * Sylvan/Great Basin wood nymph (Cercyonis sthenele silvestris) * Juba skipper (Hesperia juba) * Rural skipper (Ochlodes agricola) * Woodland skipper (Ochlodes sylvanoides) * Great arctic (Oeneis nevadensis) Due to the recent documentation of gray wolf OR-44 on a game camera on a ranch in Scott Valley, there is now current and up-to-date evidence and documentation that wolves have returned to the Klamath-Siskiyou Mountains. According to a recent article in the Siskiyou Daily News, the California Department of Fish and Wildlife recently met with the Siskiyou County Board of Supervisors to discuss the new gray wolf in Siskiyou County. Within the 572-25 same article the California Department of Fish and Wildlife admitted that there are likely uncollared wolves in the Klamath-Siskiyou region, including credible accounts of gray wolf sightings in the area near Seiad Valley and Happy Camp. Given this new information, and given that the Seiad Horse EA doesn't even mention gray wolves at all, the EA is not complete and needs to account for this emerging news and changed circumstance. The Seaid Horse EA did not adequately address the presence of Siskiyou Mountains salamanders within the Seaid Horse Project area. The absence of adequate analysis for this 573-10 species demonstrates the need for a full EIS analysis that will address the needs of Siskiyou Mountains salamanders.

Comment Response #114: Wildlife Use of Burned Areas Concern statement: There is a concern for the sufficiency of the wildlife analysis because it does not properly consider how wildlife such as the pacific fisher, northern spotted owl, and goshawk may use burned areas as habitat for foraging, nesting/roosting, and denning. Forest Service Response: The use of burned areas by northern spotted owls is analyzed and discussed at length within the BA. There is no dispute that the project may have adverse effects to northern spotted owls; this is fully disclosed within the BA. The determination for the Seiad-Horse risk reduction project is “may affect, likely to adversely affect” northern spotted owls and critical habitat. The assignment of take is not the purview of the Forest Service; take will be assigned by the US Fish and Wildlife Service following their review of the BA and the issuance of a Biological Opinion. The analysis for a jeopardy determination is also under the jurisdiction of the US Fish and Wildlife Service and therefore not included in the EA or BA. The analysis for goshawk and fisher focus on key habitat elements that are most likely to be impacted by project activities. The key elements are those most commonly used by the species and supported by literature.

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Associated Comments: Comment # Comments 9-5 Post-fire forest are crucial habitat for special plants, animals. 31-1 Please remember lots of animals rely on post-burned areas to survive. Even late successional associates such as the Pacific fisher and NSO will utilize high and 53-6 moderate severity areas for foraging if biological legacies are left in place. The EA and NSO Report (Report) fail to provide adequate analysis or information, further reiterating the need for an EIS....First, moderate severity burn areas are assumed to be post-fire foraging (PFF). According to the Horse Creek Watershed Analysis (WA), nearly the entire West Fork Horse Creek consists of late seral vegetation and nesting/roosting (N/R) habitat (see Figure 3-9 & 3-11 of WA, attached). The NSO habitat EVEG layer used in the analysis confirms this (attached). In ten years, the short-term temporal scale, canopy would fill in and areas that were moderately burned may provide suitable nesting/roosting habitat. Therefore, in the short-term moderately burned areas would likely meet the described habitat characteristics in the 2011 NSO Recovery Plan, 2012 NSO Revised Critical Habitat Rule, or many other research documents. To assume that moderately burned areas are all foraging habitat or PPF is not based facts or data. The Report, page 10, even concludes that, "The majority of the activity centers are within the moderate risk level which represents the activity centers that will likely be challenged to find enough resources to support reproduction given the lower level of habitat, these activity centers likely need all the remaining habitat to find enough resources." Thus leaving all biological 59-4 legacies (aka large trees) and forest structure that takes a long time to develop is prudent in the entire project area. Second, the spatial scale for the analysis only considers NSO Activity Centers (ACs) within the project area. Please see the Seaid-Horse Project May Put Northern Spotted Owl (NSO) in Jeopardy section of these comments. Recovery Action 10 further reiterates this—conserve spotted owl sites and high value spotted owl habitat to provide demographic support (emphasis added) to the spotted owl population. 3 Third, the Report at page 4 assumes that high severity areas contain minimal amounts of structure or cover. While cover may be immediately gone the large dead trees continue to provide critical forest structure. Fourth, the Report at page 5 anticipates that NSO would be less likely to use PFF when compared to suitable habitat. "Even though the value of fire- affected habitat to spotted owls is unclear when compared to foraging habitat, the research shows PFF may be used for foraging. Therefore, PFF may contribute some level of foraging opportunity, but likely of lesser value than foraging habitat." Please see the first point above that explains the importance of moderately burned areas and why these areas in the short term may provide N/R habitat. If reproduction is one of the primary elements of a species existence—then what are the other primary elements that would be affected by the project? Page 13 of the Report states, "Overall, alternative 3 would retain more acres of snags in areas that burned at 59-5 moderate or high fire severity when compared to alternative 2, but very few of these acres of snags are PFF." How could that be, if the assumption in the analysis is that all moderate and high severity burn areas are considered PFF? One assumption that the methodology assumes is that high severity burn areas do not 59-8 contain foraging habitat. This assumption is incorrect. Goshawks are known to forage in recently burned areas.

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Comment # Comments The Wildlife BE does acknowledge that fisher will use high severity burn areas and 59-9 references Hanson 2013 and 2015. The BE failed to acknowledge that female fisher actually prefer high severity burn areas for denning (Hanson 2015).

Comment Response #115: Spatial Extent of Wildlife Analysis Concern statement: There is a concern that the wildlife analysis is insufficient because it did not consider a broad enough spatial scale generally, and specifically for the analysis of northern spotted owl, goshawk, pacific fisher, Siskiyou mountain salamander, and western bumble bee. Forest Service Response: Large, landscape level spatial scale analyses can be useful for larger planning purposes, but in order to inform the analysis of project level effects, a smaller, finer spatial scale is needed. Without a smaller spatial scale, the level of effect can be diluted to the point where impacts from proposed actions are not evident. The spatial scales used within the BE analysis were developed to be biologically relevant and commensurate with the habitat use patterns of the species being analyzed. A broader spatial scale was used for the analysis of large, landscape level land designations such as NSO Critical Habitat. The NSO Critical Habitat analysis within the BA uses a spatial scale commensurate with the size of the Critical Habitat subunit and the area affected by proposed treatment. Associated Comments: Comment # Comments The Oregon and California Klamath Provinces have long been recognized as providing an important contribution to NSO conservation. The Westside project, within the California Klamath Physiographic Province and Critical Habitat Unit 9 (Klamath West) subunits KLW7 and KLW8, and Unit 10 (Klamath East) subunits KLE6 and KLE7, also has a "Likely to Adversely Affect" determination. Westside allowed the take of up to 100 owls. The directly adjacent Horse Creek post-fire logging project which overlaps a portion of the KLE 6 and 7, 59-3 has a "May Affect, Likely to Adversely Affect" determination. KLE6 and KLE7 are intended to enhance or protect existing essential biological or physical features and the primary function for these subunits is to support the survival, reproduction, and dispersal. The Seiad-Horse Risk Reduction Project also overlaps a portion of the Klamath East 6 critical habitat subunit. Effects to this threatened species and their Critical Habitat must be considered at a broader range—given the multiple and recent nearby projects on public and private lands that have significantly impacted this source population. The spatial analysis is entirely inadequate and must be considered at a broader range, especially because of the cumulative effects this species has endured on the Klamath National Forest. The Wildlife Biological Evaluation (BE) looks at a spatial bound of 0.25 59-6 miles around known nest sites. To examine the viability of species the agency must consider the impacts to goshawks from the multiple recent timber sales and timber harvest plans in the last decade including Mt. Ashland LSR, Thom Seider LSR, Johnny O'Neil LSR, Westside and Horse Creek projects and current projects including Lover's Canyon and

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Comment # Comments Craggy Veg. For instance, the Horse Creek post-fire timber sale was determined to downgrade or remove habitat in all of its seven goshawk territories. The Westside project contained at least 11goshawk nest sites, removing habitat within 4 nest sites and causing a high level of risk to reproduction. Again, the spatial analysis area for determining population viability is too small as the EA only considers 7th field watersheds within the project area and the methodology is flawed in determining suitable habitat for fishers. Given the multiple timber sales and timber harvest plans in the region the analysis must look at a broader scale....The significant negative effects to these weasel species from this project in combination with the extensive THP private land logging, Westside and Horse Creek project, on Fisher is undeniable. The Westside project diminished connectivity in 14 sub-watersheds and 59-10 removed connectivity in three others including, Cougar Creek-Elk Creek, Lower West Fork Beaver Creek, and Tom Martin Creek-Klamath River. The loss of several home ranges can result in large effects to the overall population. The Horse Creek project was determined to result in creating openings in Middle Horse Creek and Salt Gulch to the point that the habitat connectivity would be reduced from a low level to a very low habitat connectivity level. West Fork Horse Creek habitat connectivity would be reduced from a moderate to a low habitat connectivity level. The Siskiyou Mountains Salamander (Plethodon stormi) is endemic to 420 square miles of known habitat in northern Siskiyou County, CA and southern Jackson Country, OR. The range of Siskiyou Mountains salamander is centered generally around Seiad Valley and 59-13 that the Seiad-Grider area and is considered a range of contact between the Siskiyou Mountain and Del Norte salamanders. The Happy Camp Fire area affected about 25% of its range and the Gap Fire and Miller Complex Fires possibly affected another 40%. The KNF must look at the entire range to adequately assess impacts to this rare species. The Seiad-Horse project contains seven known sites, one of which experienced high severity fire. The BE does contend that it is likely that these sites are still occupied, as 59-14 salamanders have evolved with fire and because surveys have shown 7 that salamanders use early seral habitat, such as natural recovery areas post-fire. Again, the cumulative effects must consider a larger scale. For the Seiad-Horse project, there are four drainages in the project area with potential bumblebee habitat. Two of the four drainages with potential habitat, Middle Seiad Creek 59-15 and Salt Gulch, showed a low level of disturbance for analysis indicator 1. However, as all other wildlife analysis, the cumulative effects must look at a broader range.

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Comment Response #116: Use of VQO standards near the Pacific Crest Trail Concern statement: Commenters requested the project use retention visual quality objectives (VQOs) for all units within a half-mile of the Pacific Crest Trail, and partial retention VQOs for units within one-half to four miles of the PCT. Forest Service Response: The Forest Plan directs that an inventory of Visual Quality Objectives (VQO) and designated viewpoints be maintained. These areas have been previously mapped using geographic information software and field analysis. Per the visual resource analysis for this project (using the existing mapped inventory), some of the proposed roadside hazard tree removal and underburning exists in retention VQO, and the remainder of salvage harvest, site preparation and planting, and fuels treatments will occur in partial retention VQO. An analysis of the effects of these activities to visual quality is provided in the EA as a response to a relevant issue. Furthermore, while the Forest Plan, under most circumstances, provides a three-year timeframe to meet retention and partial retention VQOs, standard and guideline 11-7 allows for an extension of that timeline where it states, "In the case of recovery activities after extreme catastrophic events such as intense wildland fires, time periods to achieve the VQOs stated in Forest-wide and Management Area Standards and Guidelines may be extended. This would be necessary where previously unnoticed scenery alterations are exposed to view due to loss of vegetative screening, or during timber salvage activities where recovery of forest vegetation is determined to be of greater importance than achievement of VQOs within the time periods established" (page 4-36). As a result, the following project design features were used to minimize to the greatest extent possible the potential direct and indirect effects of the proposed alternatives as seen from viewpoints along the PCT: Recreation and Scenic Resources 1-4, and 8-9. All aforementioned design features can be found on pages 24-26 of the EA. These project design features respond to the proposed management activities within their respective VQOs, considering that a timeframe longer than three years is necessary for the activities proposed in the EA. However, the standards and guidelines that direct management activities for a management area apply only to the areas designated as such and not to adjacent lands. Therefore, the standards and guidelines for retention and partial retention visual quality objective management areas do not apply to all lands within one half or 4 miles of the Pacific Crest Trail, respectively. Changing the boundaries of management areas designated by the Forest Plan is outside the scope of the Seiad- Horse Project. Associated Comments: Comment # Comments As the planning process moves forward, we ask that the Forest strive for a visual quality 52-3 objective of Retention for the northern harvest units that may fall within a half-mile of the PCT as it traverses the Siskiyou Crest. For the harvest units one-half to 4 miles from the PCT, we ask that the Forest strive for a 52-4 VQO of Partial Retention.

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Comment Response #117: Reopening Decommissioned Roads Concern statement: There is a concern that decommissioned roads will be reopened and that this should be addressed in the EA. Forest Service Response: No decommissioned roads are being reopened. No new system roads are proposed for construction or decommissioning. The project design feature in the EA has been updated to remove this reference as it does not apply. Temporary roads are proposed to meet the management objectives and best management practices and project design features will be used to address effects of temporary roads. Associated Comments: Comment # Comments On page 31 of the Draft EA, PDF Watershed-21 contains the following passage (emphasis added): Achieve 80% soil cover on hydrologically connected temporary roads and reopened decommissioned roads within riparian reserves at the end of season of use. We could not find any mention of proposed re-opening of decommissioned roads in the Draft EA. Please identify in the final EA if decommissioned roads, especially roads within riparian 1067-4 reserves, are proposed to be re-opened. If decommissioned roads are proposed for use, please identify in the final EA or the Waiver application if those roads were assessed for the presence of legacy sediment sites, provide the total length of decommissioned road to be re-opened, and describe the measures to protect water quality after use of decommissioned roads.

Comment Response #118: Recommendations of the Late Successional Reserve Assessment not Addressed Concern statement: Concern that a variety of findings and recommendations from the Late Successional Reserve Assessment were not incorporated into the planning process, including: road density, snags and down logs, prescribed fire, late seral habitat, etc. Forest Service Response: Findings and recommendations from within the Forest-wide Late Successional Assessment (LSRA) were incorporated in the project design. For example, no new permanent roads will be constructed for the proposed project. Only temporary roads will be constructed and will be closed following implementation. It is estimated that approximately eight new temporary roads (1.75 miles) and six existing temporary roads that use existing roadbeds (0.75 miles) will be needed for project implementation. Access for this project would be mainly accomplished through the use of roads on the National Forest Transportation System. Temporary roads are estimated at this time and will be finalized to comply with Standards and Guidelines as designated within the Forest Plan. Both new and existing temporary roads will be hydrologically stabilized at the end of the project.

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In addition, snag and downed logs were considered as part of the project design; snag retention patches and wildlife tree retention are incorporated in the design in order to provide habitat elements that take a long time to develop in order to benefit the regenerating stands. Also, prescribed fire is part of the proposed action, as recommended within the Forest-wide LSRA. Associated Comments: Comment # Comments The following findings and recommendations from the Late Successional Reserve Assessment were not incorporated into KNF's post-fire LSR clearcut project planning and the decision making process: "Great gray owls have been heard during surveys that have occurred along the Siskiyou Crest." Forest Wide LSRA 2-78. "The most pervasive human impact to the health and connectivity of aquatic systems within the LSRs is the construction and maintenance of roads." LSRA 2-17. "Roads can affect ecosystems in several ways. Road construction removes and fragments habitat, increases sedimentation in streams, impedes stream flow, affects wildlife distribution and movements, and increases the potential for outside disturbance factors." LSRA 2-31. 39 "[O]pen road densities above 2 miles per square mile may be a threshold for concern, in that human use could negatively impact use of adjacent habitats." LSRA 2-31. "The desired condition within LSRs is to provide late-successional and old-growth forest in which structure and composition is consistent with site conditions and ecological processes. Important structural attributes include live old growth trees, standing dead trees, fallen trees or logs on the forest floor, and logs in streams. Additional important elements typically include 49-148 multiple canopy layers, smaller understory trees, canopy gaps, and patchy understory. These conditions typically begin to appear when forest stands are between 80 and 140 years in age, depending on site conditions, species composition, and site history." LSRA 3- 2. "The introduction of prescribed fire to the LSRs will help encourage the processes and attributes that define late-successional and old-growth ecosystems. It is expected and even desirable to have low to moderate intensity fires burn in LSRs." LSRA 3-2. "It is desired to have scattered individual snags and down logs as well as larger aggregations." LSRA 3-3. "It is desirable to minimize the negative effects of roading within the LSRs, including a reduction in the amount of road related sediment within the watershed." LSRA 1-7. "Road densities within the LSRs should be assessed on the seventh field watershed scale. Generally, road densities below two miles per square mile are considered acceptable levels of risk. Two miles per square mile is a target to reduce toward, and does not imply increased road construction is acceptable in areas currently below that density." LSRA 1-8. "Reducing road densities on unstable lands within LSRs is likely to provide the greatest benefit to aquatic resources and is the highest priority." LSRA 1-22

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Comment Response #119: Baker Cypress Concern statement: There is a concern that project activities will negatively affect the population of Baker cypress in the area. Forest Service Response: Thank you for your comment regarding the Seiad Baker Cypress SIA. Effects to Baker's cypress and the Seiad Baker Cypress SIA are discussed in the Botany Resource Report. Proposed underburning activities do overlap approximately six acres of the Seiad Baker Cypress SIA. However, underburning will not take place in this portion of the SIA for at least fifteen years (PDF Botany 9), in order to allow the new cohort of Baker cypress (stimulated by the Abney Fire) to reach cone-producing maturity. The proposed action would not damage the unique characteristics for which this SIA was established, and is likely to promote the health of remaining Baker cypress stands by stimulating germination and eliminating competing vegetation. Roadside hazard tree logging is proposed along road 47N80 which is near the northern border of the Seiad Baker Cypress SIA. Currently, no hazard trees have been identified near any known individuals of either Baker cypress or Brewers spruce in this area. In the case that hazards are identified in this area, Project Design Features Botany 8 and 9 were developed to protect Special Interest species, including Baker cypress, from negative impacts. Associated Comments: Comment # Comments The EA failed to disclose a significant population of Baker's cypress within the proposed 53-122 roadside hazard logging area on road 47N80. The EA also failed to disclose or analyze the impact of roadside hazard logging on that population.

Comment Response #121: Water Board Suggestion for Project Design Feature Concern statement: The Water Board suggests that we add a project design feature (PDF) that was used in the Horse Creek Community Protection project as follows: "Where logs cannot be adequately suspended for yarding, gouging in corridors will be waterbarred and covered with at least 50 percent logging slash where available and as needed to mitigate erosion and concentration of surface runoff." Forest Service Response: A similar PDF (Watershed 8) was developed for this project as follows: "Slash or water bars will be applied to cable corridors where necessary to minimize the concentration of surface runoff and to keep ground cover at least 50 percent where enough material is available. This will be done after use and prior to the end of the normal operating season." We believe this PDF provides equal protection, provides more clear direction to implementers, and removes the interpretation of what constitutes gouging. This PDF also provides more

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Seiad-Horse Risk Reduction Project Happy Camp/Oak Knoll Ranger District, Klamath National Forest flexibility to use either slash or waterbars to minimize erosion, as both waterbarring and slash placement may not be necessary to contain erosion in all circumstances. Finally this PDF provides additional language on when it would be implemented. Associated Comments: Comment # Comments Project Design Feature (PDF) Watershed-17 from the 2017 Horse Creek Community Protection and Forest Restoration Project states: Where logs cannot be adequately suspended for yarding, gouging in corridors will be waterbarred and covered with at least 1067-3 50 percent logging slash where available and as needed to mitigate erosion and concentration of surface runoff. This PDF is not included in the Draft EA. Skyline yarding is proposed in some harvest units and the quoted PDF appears to be applicable to the Project. Please include this PDF in the final EA.

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Literature Provided during the Comment Period The following literature was provided by commenters during the comment period. It was reviewed by specialists for its relevance to the Seiad-Horse Project as demonstrated below.

Literature Provided Regarding Silviculture Comment #49-27: “Attachment 3 is a peer-reviewed study conducted by Beschta et al. entitled Postfire Management on Forested Public Land of the Western United States published in Conservation Biology, Volume 18, No. 4 August 2004 pages 957- 967. The abstract states: "Forest ecosystems in the western United States evolved over many millennia in response to disturbances such as wildfires. Land use and management practices have altered these ecosystems, however, including fire regimes in some areas. Forest ecosystems are especially vulnerable to post-fire management practices because such practices may influence forest dynamics and aquatic systems for decades to centuries. Thus, there is an increasing need to evaluate the effect of post-fire treatments from the perspective of ecosystem recovery. We examined, via the published literature and our collective experience, the ecological effects of some common post-fire treatments. Based on this examination, promising post-fire restoration measures include retention of large trees, rehabilitation of firelines and roads, and, in some cases, planting of native species. The following practices are generally inconsistent with efforts to restore ecosystem functions after fire: seeding exotic species, livestock grazing, placement of physical structures in and near stream channels, ground-based post-fire logging, removal of large trees, and road construction. Practices that adversely affect soil integrity, persistence or recovery of native species, riparian functions, or water quality generally impede ecological recovery after fire. Although research provides a basis for evaluating the efficacy of post-fire treatments, there is a continuing need to increase our understanding of the effects of such treatments within the context of societal and ecological goals for forested public lands of the western United States." Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes Beschta et al. 2004 presents a list of recommendations to avoid damage from salvage logging. However, for this Project the fish, earth, and water scientists conducted field work in this specific area and used standardized analytical procedures to determine the effects of taking no action at this time (Alternative 1) and two action alternatives in this specific landscape that has been changed by the 2017 wildfires. The results of their site-specific field work and modeling based on Klamath National Forest conditions and processes provide the best information available. Their work shaped the proposed action such that significant old or large trees are retained on slopes and in Riparian Reserves, soils are protected by limiting ground-based skidding and implementing extensive soil and water Best Management Practices, and ecologically sensitive areas such as Riparian Reserves are protected. No new system roads will be constructed for the project and temporary roads needed for the project will be hydrological stabilized and closed after Project implementation. In addition, stream monitoring sites have been established to monitor potential fire and project effects. Instream habitat restoration structure work has been ongoing in lower stream reaches of the Project watersheds that is supported by conservation groups, watershed councils and the Karuk Tribe. When implemented according to project design

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features and best management practices, salvage logging can lessen the time for ecosystems to recover by getting needed burned overstory onto the ground to provide soil cover, increase soil roughness to reduce erosion and break up water repellant layers, return of nutrients to the soil, and replant burned trees. In this Project, following project design features and best management practices will insure erosion levels are low and within Forest Plan thresholds. Comment #49-28: “Attachment 4 is a peer-reviewed study by researchers from the Corvallis Forestry Sciences Lab who found that "mixed-conifer and mixed evergreen-hardwood forests that were salvage logged (and planted) following the 1987 Silver Fire in the Siskiyou National Forest experienced higher severity reburn in the 2002 Biscuit Fire than did stands in the Silver Fire (subsequently burned in the Biscuit Fire) that were not subject to salvage logging and artificial plantation establishment." Thompson, JR, TA Spies, LM Ganio, 2007. Reburn Severity in Managed and Unmanaged Vegetation in a Large Wildfire. Proceedings of the National Academy of Sciences. The abstract states: "Debate over the influence of post wildfire management on future fire severity is occurring in the absence of empirical studies. We used satellite data, government agency records, and aerial photography to examine a forest landscape in southwest Oregon that burned in 1987 and then was subject, in part, to salvage-logging and conifer planting before it reburned during the 2002 Biscuit Fire. Areas that burned severely in 1987 tended to reburn at high severity in 2002, after controlling for the influence of several topographical and biophysical covariates. Areas unaffected by the initial fire tended to burn at the lowest severities in 2002. Areas that were salvage-logged and planted after the initial fire burned more severely than comparable unmanaged areas, suggesting that fuel conditions in conifer plantations can increase fire severity despite removal of large woody fuels."” Forest Response: Was the reference provided or is it accessible? Not provided but accessible online Does the literature provided support comments specifically about the project? Yes We agree that, without follow-up activity fuel treatment, salvage logging would increase fire risk and intensity because it would convert smaller diameter limbs and tops to surface fuels that readily carry fire (Thompson et al. 2007). However, in this Project activity fuels would be treated in any of the action alternatives. In an often cited study of reburns in the Biscuit Fire in southwest Oregon, Thompson et al. (2007) concluded that: “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.” That is the objective of the salvage units in the Project, and the reason that leaving all of the dead wood now present on the landscape would not meet the Project objectives. Reforestation objectives of the Project are not a totally closed canopy forest. We agree that extensive uniform planting would not create the heterogeneity that we seek to reestablish on the landscape; trees will not be planted uniformly. Stand density would vary with slope position and aspect with lower stocking on upper slopes and south and west aspects and higher stocking on north and east aspects that would form a relatively closed canopy on lower slopes. Hardwoods would be included in the target stocking levels so the number of conifers would be less where hardwoods occur. We also anticipate there would be losses from future fires that would further reduce stand density. Our long-term objective is canopy closure of forty percent or greater and 15 or more trees per acre greater than twenty inches in diameter at breast height. The pre-existing snags, downed woody debris, the largest

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diameter fire-killed trees and trees with multiple wildlife characteristics are being retained wherever they occur, as are green trees (with less than a 70% probability of mortality). Comment #49-36: “Attachment 12 is a peer-reviewed paper entitled Salvage Logging, Ecosystem Process, and Biodiversity Conservation by Lindenmayer and Noss that appeared in Conservation Biology Volume 20, No. 4, 949- 958. 2006. The abstract for this paper states: "We summarize the documented and potential impacts of salvage logging—a form of logging that removes trees and other biological material from sites after natural disturbance. Such operations may reduce or eliminate biological legacies, modify rare post disturbance habitats, influence populations, alter community composition, impair natural vegetation recovery, facilitate the colonization of invasive species, alter soil properties and nutrient levels, increase erosion, modify hydrological regimes and aquatic ecosystems, and alter patterns of landscape heterogeneity. These impacts can be assigned to three broad and interrelated effects: (1) altered stand structural complexity; (2) altered ecosystem processes and functions; and (3) altered populations of species and community composition. Some impacts may be different from or additional to the effects of traditional logging that is not preceded by a large natural disturbance because the conditions before, during, and after salvage logging may differ from those that characterize traditional timber harvesting. The potential impacts of salvage logging often have been overlooked, partly because the processes of ecosystem recovery after natural disturbance are still poorly understood and partly because potential cumulative effects of natural and human disturbance have not been well documented. Ecologically informed policies regarding salvage logging are needed prior to major natural disturbances so that when they occur ad hoc and crisis-mode decision making can be avoided. These policies should lead to salvage-exemption zones and limits on the amounts of disturbance-derived biological legacies (e.g., burned trees, logs) that are removed where salvage logging takes place. Finally, we believe new terminology is needed. The word salvage implies that something is being saved or recovered, whereas from an ecological perspective this is rarely the case." Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes This paper provides general discussions of potential impacts of post-fire salvage; however, it is not specific to the fire regime of the Klamath Province or the objectives of the Project. The purpose and need for this Project includes public and worker safety and restoration of fire resilient ecosystems. This paper is a general literature review of a complicated topic that does not consider much of the recent literature relevant and specific to the Klamath Province concerning fuels and fuel accumulation. We agree that removing mature living trees and structural legacies has a negative impact on recovery processes. The Project does not propose to remove mature living trees or structural legacies, living or dead. The Project seeks to protect and enhance late- successional forest habitats by reducing the probability of future stand replacement fire by reducing fuels and accelerating the development late-successional stand conditions by reforesting burned areas. Retention of all of the trees killed by the Abney Fire would create fuel loading that would increase the risk of future high severity fire that would consume snags and down logs and delay development of late-successional stand conditions.

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Comment #49-38: Attachment 14 is a February 24, 2006 peer-reviewed paper presented to the Society for Conservation Biology by Reed Noss, Jerry Franklin and William Baker entitled "Ecology and Management of Fire-prone Forests of the Western United States." Key Findings of this paper include the following: 1. "Research by both ecologists and foresters provides evidence that areas affected by large-scale natural disturbances often recover naturally. 2. Post-fire logging does not contribute to ecological recovery; rather it negatively impacts recovery processes, with the intensity of such impacts depending upon the nature of the logging activity. 3. Post-fire logging destroys much of whatever natural tree regeneration is occurring on a burned site. 4. Evidence from empirical studies is that post-fire logging typically generates significant short- to mid-term increases in fine and medium fuels. 5. There is no scientific or operational linkage between reforestation and post-fire logging; potential ecological impacts of reforestation are varied and may be either positive or negative depending upon the specifics of activity, site conditions, and management objectives. On the other hand, ecological impacts of post-fir logging appear to be consistently negative." Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes This paper provides general discussions of potential impacts of post-fire salvage; however, it is not specific to the objectives of the Project. The purpose and need for this project includes public and worker safety and restoration of fire resilient ecosystems. See response to literature cited in comments #49-27, 49-28, and 49-36. Comment #49-69: “(Attachment 22) Conifer Regeneration After Forest Fire in the Klamath Siskiyous: How Much, How Soon? Shatford, J.P.A.; Hibbs, D.E.; Puettmann, K.J. Journal of Forestry. Volume 105, Number 3, April/May 2007, pp. 139- 146(8). The abstract of this paper states: "The increasing frequency and extent of forest fires in the western United States has raised concerns over postfire management actions on publically owned forests. Information on ecosystem recovery after disturbance is lacking and has led to heated debate and speculation regarding the return of forest vegetation after disturbance and the need for management actions. One critical question emerges, will these ecosystems recover on their own, and if so, over what time frame. We report on one aspect of recovery, the spatial and temporal variation of natural conifer regeneration evident 9-19 years after forest fires in California and Oregon. In contrast to expectations, generally, we found natural conifer regeneration abundant across a variety of settings. Management plans can benefit greatly from using natural conifer regeneration but managers must face the challenge of long regeneration periods and be able to accommodate high levels of variation across the landscape of a fire." KNF timber planners chose to ignore this study.” Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes Shatford et al. 2007 was considered in the EA under Effects of the Proposed Action and Alternatives, Impacts Related to the Project Need, Fire-Resilient Coniferous Forest in Severely Burned Areas to Meet the Desired Conditions for Late Successional Reserves and Provide for Future Habitat, Analysis Assumptions (page 63):

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“Forest Vegetation Simulator modeling scenarios assume that a wildfire will burn through the project area every thirty years and that natural regeneration will be established within 5 years following each fire cycle at densities observed in a study on the Forest (Shatford, Hibbs, and Puettmann, 2007).” Also in the same section under Alternative 1 – No Action, Direct and Indirect Effects (page 64): “Where natural regeneration is successful it would be highly variable depending on site- conditions (Shatford et al. 2007, Tepley et al. 2017).” Comment #49-70: “Attachment 23 to our comments was a paper entitled Vegetation Response to a Short Interval Between High-Severity Wildfires in a Mixed-Evergreen Forest by Donato et al in the Journal of Ecology. 2009, Volume 97. 142-154. Summary: "1. Variations in disturbance regime strongly influence ecosystem structure and function. A prominent form of such variation is when multiple high-severity wildfires occur in rapid succession (i.e. short-interval (SI) severe fires, or 're-burns'). These events have been proposed as key mechanisms altering successional rates and pathways. 28 2. We utilized a natural experiment afforded by two overlapping wildfires occurring within a 15- year interval in forests of the Klamath- Siskiyou Mountains, Oregon (USA). We tested for unique effects of a SI fire (15-year interval before 2002 fire) by comparing vegetation communities 2 years post-fire to those following a long-interval (LI) fire (> 100-year interval before 2002 fire) and in mature/old-growth (M/OG) stands (no high-severity fire in > 100- year). 3. Nearly all species found in M/OG stands were present at similar relative abundance in both the LI and SI burns, indicating high community persistence through multiple high-severity fires. However, the SI burn had the highest species richness and total plant cover with additions of disturbance-associated forbs and low shrubs, likely due to a propagule bank of early seral species that developed between fires. Persistence of flora was driven by vegetative sprouting, on-site seed banks, and dispersal from off-site seed sources. Several broadly generalizable plant functional traits (e.g. rapid maturation, long-lived seed banks) were strongly associated with the SI burn. 4. Sprouting capacity of hardwoods and shrubs was unaltered by recurrent fire, but hardwood/ shrub biomass was lower in the SI burn because individuals were smaller before the second fire. Conifer regeneration densities were high in both the SI and LI burns (range = 298-6086 and 406-2349 trees ha., respectively), reflecting similar availability of seed source and germination substrates. 5. Synthesis. SI severe fires are typically expected to be deleterious to forest flora and development; however, these results indicate that in systems characterized by highly variable natural disturbances (e.g. mixed-severity fire regime), native biota possess functional traits lending resilience to recurrent severe fire. Compound disturbance resulted in a distinct early seral assemblage (i.e. interval-dependent fire effects), thus contributing to the landscape heterogeneity inherent to mixed-severity fire regimes. Process-oriented ecosystem management incorporating variable natural disturbances, including 'extreme' events such as SI severe fires, would likely perpetuate a diversity of habitats and successional pathways on the landscape." The great majority of areas that burn at high severity naturally regenerate conifers vigorously--starting shortly after the fire. See Shatford et al. (2007) in Journal of Forestry on this.” Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes Unlike previous literature cited in a study led by Donato that included fire salvage, this study sampled post-fire regeneration in un-managed stands that had been re-burned within a 15-year period. The time period between wildfires in the Seiad-Horse project area was no shorter than 30

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years, where the Abney Fire overlapped the 1987 Copper Fire, up to 100 years or more outside of the 1987 fire footprint. This paper supports the Seiad-Horse Project since 60 percent of the project area burned by moderate to high severity fire will be left to naturally regenerate and be maintained by prescribed or natural fire (EA, page 66). Comment #49-106: “Attachment 25b of our scoping comments was the document "Restoration Framework for Federal Forests in the Pacific Northwest by Jerry F. Franklin and K. Norman Johnson which supports Swanson et al 2011 need for unmanaged early succession forests. Franklin and Johnson (2012) state on p. 431: "Theoretically, disturbances of either natural (e.g., wildfire) or human (e.g., timber harvest) origin are capable of generating this stage. Large natural disturbances often produce high-quality early seral ecosystems provided they are not intensively salvaged and replanted (Swanson et al. 2011), but such disturbances are poorly distributed in time and space. For example, less than 1% of suitable NSO habitat (complex forest) was transformed by wildfire into early successional habitat between 1996 and 2006 in 49 MF-dominated provinces of the Northwest Forest Plan (NWFP; USDI Fish and Wildlife Service 2011). Areas devoted to intensive timber production generally provide little high quality early seral habitat for several reasons. First, few or no structures from the preharvest stand (e.g., live trees, snags, and logs) are retained on intensively managed sites but are abundant after severe natural disturbances (Swanson et al. 2011). Additionally, intensive site preparation and reforestation efforts limit both the diversity and the duration of early seral organisms, which may also be actively eliminated by use of herbicides or other treatments (Swanson et al. 2011). Consequently, many MF landscapes currently lack sufficient representation of high-quality early seral ecosystems because of harvest, reforestation, and fire suppression policies on both private and public lands." (Spies et al. 2007, Swanson et al. 2011) Again, KNF timber planners largely ignored these findings.” Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes The excerpt from Franklin and Johnson (2012) refers to “areas devoted to intensive timber production” and “intensive site preparation and reforestation efforts” including the use of herbicides. The project area was designated as Late Successional Reserve in the Forest Plan of 1995; although this study may depict past-management practices, it is not relevant to current management strategies on the Forest, especially in Late Successional Reserves. Where salvage harvest is proposed, this Project leaves all “live” trees with less than 70% probability of mortality, pre-Abney fire snags and downed woody debris, and fire-killed very large trees that possess high quality wildlife characteristics. Also, snag retention areas have been identified and deferred from salvage (except for roadside hazard) in mixed severity stands with average live canopy closure greater than 40% and in riparian reserves. Site preparation activities will primarily be accomplished by hand and prescribed fire. No herbicides will be used. We agree that extensive uniform planting would not create the heterogeneity that we seek to reestablish on the landscape; in this Project, trees will not be planted uniformly. Stand density would vary with slope position and aspect with lower stocking on upper slopes and south and west aspects and higher stocking on north and east aspects that would form a relatively closed canopy on lower slopes. Hardwoods would be included in the target stocking levels so the number of conifers would be less where hardwoods occur. As mentioned in response to literature cited in comment #49-70, 60 percent of the moderate to high

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severity burn in the project area will be left to naturally regenerate and maintained by prescribed or natural fire (EA, page 66). Comment #54-42: “Hibbs and Ruth (2011) in a USGS (government report) stated: "The availability of a natural seed source is critical when relying on natural regeneration for tree establishment instead of planting. In the Klamath-Siskiyou Ecoregion, a natural seed source is available in most instances even after a severe fire. Within the boundaries of the Biscuit Fire, for example, many locations experienced fire of sufficient severity to kill all the trees present. Yet, often a living conifer tree that could act as a seed source was present within 400 meters of these severely burned areas (emphasis added). Conifer seeds can disperse this distance, which allows for natural regeneration. In fact, natural conifer regeneration generally was profuse except in the middle of large, severely burned patches and on southern, low-altitude sites." Forest Response: Was the reference provided or is it accessible? Yes, accessible online. Does the literature provided support comments specifically about the project? Yes Although Hibbs and Ruth (2011) is not cited in the EA, dispersal distances of natural seed sources are discussed under Effects of the Proposed Action and Alternatives, Impacts Related to the Project Need, Fire-Resilient Coniferous Forest in Severely Burned Areas to Meet the Desired Conditions for Late Successional Reserves and Provide for Future Habitat, Alternative 1 – No Action, Direct and Indirect Effects (EA, pages 63 – 65). Comment #54-46: “From Zald and Dunn 2018 Abstract. Many studies have examined how fuels, topography, climate, and fire weather influence fire severity. Less is known about how different forest management practices influence fire severity in multi-owner landscapes, despite costly and controversial suppression of wildfires that do not acknowledge ownership boundaries. In 2013, the Douglas Complex burned over 19,000 ha of Oregon & California Railroad (O&C) lands in Southwestern Oregon, USA. O&C lands are composed of a checkerboard of private industrial and federal forestland (Bureau of Land Management, BLM) with contrasting management objectives, providing a unique experimental landscape to understand how different management practices influence wildfire severity. Leveraging Landsat based estimates of fire severity (Relative differenced Normalized Burn Ratio, RdNBR) and geospatial data on fire progression, weather, topography, pre-fire forest conditions, and land ownership, we asked (1) what is the relative importance of different variables driving fire severity, and (2) is intensive plantation forestry associated with higher fire severity? Using Random Forest ensemble machine learning, we found daily fire weather was the most important predictor of fire severity, followed by stand age and ownership, followed by topographic features. Estimates of pre-fire forest biomass were not an important predictor of fire severity. Adjusting for all other predictor variables in a general least squares model incorporating spatial autocorrelation, mean predicted RdNBR was higher on private industrial forests (RdNBR 521.85 _ 18.67 [mean _ SE]) vs. BLM forests (398.87 _ 18.23) with a much greater proportion of older forests. Our findings suggest intensive plantation forestry characterized by young forests and spatially homogenized fuels, rather than pre-fire biomass, were significant drivers of wildfire severity. This has implications for perceptions of wildfire risk, shared fire management responsibilities, and 14 developing fire resilience for multiple objectives in multi-owner landscapes.”

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Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes What is done on lands not managed by the Forest is outside the scope of the project. See response to literature cited in comment #49-106 regarding the assumption that we will be doing the same intensive salvage and plantation establishment practices of the past or like adjacent industrial timber landowners.

Literature Provided Regarding Wildlife Comment #49-9: “(Please see the Rogue River-Siskiyou National Forest Mt. Ashland LSR Assessment).” Forest Response: Was the reference provided or is it accessible? Document was not provided and is not currently accessible Does the literature provided support comments specifically about the project? No The Seiad-Horse project area is outside both the Rogue River-Siskiyou and the Klamath National Forest’s Mt. Ashland Late Successional Reserve; information provided in an assessment for those areas is not directly relevant to this Project. Comment #49-10: “In our scoping comments we requested that that Seiad-Horse salvage logging NEPA analysis address the locally and regionally significant issues regarding management of this unique resource. Please see: Stritholt J.R., R. F. Noss, P. A Frost, K. Van-Borland, C. Caroll, G. Heilman, Jr. 1999. A Conservation Assessment and Science Based Plan For The Klamath-Siskiyou. Rogue River National Forest, Klamath National Forest. 1996. Late-Successional Reserve Assessment; Mt. Ashland Late Successional Reserve Assessment (#RO-284). The EA failed to conduct this requested analysis.” Forest Response: Was the reference provided or is it accessible? Rogue-Siskiyou document was not provided and is not currently accessible. Klamath National Forest document was not provided but is accessible. Does the literature provided support comments specifically about the project? No The cited document, A science-based conservation assessment for the Klamath-Siskiyou Ecoregion (1999), analyzes a large area (16,643 sq. miles) to identify areas for conservation reserves that expand upon the Northwest Forest Plan. This document does not provide findings that are relevant to the Project. The Klamath National Forest Plan discusses the forest-wide conservation concerns and has already established land allocations at the Forest scale. Relevant information from the Klamath National Forest Forest-wide Late Successional Reserve Assessment (1999) was used in developing the Seiad-Horse Project. Spatial boundaries for analysis of the effects of the Project are provided in the EA and wildlife reports. See the response to #49-9 in relation to the Mt. Ashland Late Successional Reserve Assessment.

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Comment #49-29: “Attachment 5 is Hutto, R.L. 1995. Composition of bird communities following stand-replacement fires in northern Rocky Mountain (U.S.A.) conifer forests. Conservation Biology 9: 1041-1058. The abstract states: "During the two breeding seasons immediately following the numerous and widespread fires of 1988, I estimated bird community composition in each of 34 burned-forest sites in western Montana and northern Wyoming. I detected an average of 45 species per site and a total of 87 species in the sites combined. A compilation of these data with bird-count data from more than 200 additional studies conducted across 15 major vegetation cover types in the northern Rocky Mountain region showed that 15 bird species are generally more abundant in early post-fire communities than in any other major cover type occurring in the northern Rockies. One bird species (Black-backed Woodpecker, Picoides arcticus) seems to be nearly restricted in its habitat distribution to standing dead forests created by stand-replacement fires. Bird communities in recently burned forests are different in composition from those that characterize other Rocky Mountain cover types (including early-successional clearcuts) primarily because members of three feeding guilds are especially abundant therein: woodpeckers, flycatchers, and seedeaters. Standing, fire-killed trees provided nest sites for nearly two-thirds of 31 species that were found nesting in the burned sites. Broken-top snags and standing dead aspens were used as nest sites for cavity-nesting species significantly more often than expected on the basis of their relative abundance. Moreover, because nearly all of the broken-top snags that were used were present before the fire, forest conditions prior to a fire (especially the presence of snags) may be important in determining the suitability of a site to cavity-nesting birds after a fire. For bird species that were relatively abundant in or 9 relatively restricted to burned forests, stand-replacement fires may be necessary for long-term maintenance of their populations. Unfortunately, the current fire policy of public land management agencies does not encourage maintenance of stand-replacement fire regimes, which may be necessary for the creation of conditions needed by the most fire-dependent bird species. In addition, salvage cutting may reduce the suitability of burned-forest habitat for birds by removing the most important element--standing, fire-killed trees-needed for feeding, nesting, or both by the majority of bird species that used burned forest." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No Although the referenced literature provides important information pertaining to the referenced species, the effects of the Seiad-Horse Project (salvage harvest and other proposed actions) on bird species identified in the Forest Plan as Management Indicator Species or by the Regional Forester as Forest Sensitive Species are addressed in the EA (pages 99-101), Management Indicator Species report and Biological Evaluation. Comment #49-31: “Attachment 7 is Kotliar, N.B., S.J. Hejl, R.L. Hutto, V. Saab, C.P. Melcher, and M.E. McFadzen. 2002. Effects of fire and post-fire salvage logging on avian communities in conifer-dominated forests of the western United States. In: George, T.L. and D.S. Dobkin. Effects of habitat fragmentation on birds in western landscapes: contrasts with paradigms from the eastern United States. Studies in Avian Biology No. 25. Camarillo, CA: Cooper Ornithological Society. p. 49-64. The abstract states: 10 "Historically, fire was one of the most widespread natural disturbances in the western United States. More recently, however, significant anthropogenic activities, especially fire suppression and silvicultural practices, have altered fire regimes; as a result, landscapes and associated communities have changed as well. Herein,

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we review current knowledge of how fire and postfire salvaging practices affect avian communities in (1) burned vs. unburned forests, and (2) unsalvaged vs. salvage-logged burns. We also examine how variation in burn characteristics (e.g. severity, age, size) and salvage logging can alter avian communities in burns. Of the 41 avian species observed in three or more studies comparing early post-fire and adjacent unburned forests, 22% are consistently more abundant in burned forests, 34% are usually more abundant in unburned forests, and 44% are equally abundant in burned and unburned forests or have varied responses. In general, woodpeckers and aerial foragers are more abundant in burned forests, whereas most foliage-gleaning species are more abundant in unburned forests. Bird species that are frequently observed in stand-replacement burns are less common in understory burns; similarly, species commonly observed in unburned forests often decrease in abundance with increasing burn severity. Granivores and species common in open canopy forests exhibit less consistency among studies. For all species, responses to fire may be influenced by a number of factors including burn severity, fire size and shape, proximity to unburned forests, pre- and post- fire cover types, and time since fire. In addition, post-fire management can alter species' responses to burns. Most cavity-nesting species do not use severely salvaged burns, whereas some cavity-nesters persist in partially salvaged burns. Early post-fire specialists, in particular, appear to prefer unsalvaged burns. We discuss several alternatives to severe salvage-logging that will help provide habitat for cavity nesters."” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No See response to literature cited in comment #49-29. Comment #49-32: “Attachment 8 is Kotliar et al. 2002. Fire on the Mountain: Birds and Burns in the Rocky Mountains. USDA Forest Service Gen. Tech. Rep. PSW-GTR- 191. 2005. A version of this paper was presented at the Third International Partners in Flight Conference, March 20-24, 2002, Asilomar Conference Grounds, California. No abstract is available for this paper.” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No Although this general technical report (2002) provides important information for birds and their habitat in the Rocky Mountains, the Project analysis used relevant research findings that are available for habitat types that occur in the Seiad-Horse project area. Comment #49-33: “Attachment 9 is an October 6, 2006 letter that appeared in Science volume 314 from a number of scientists concluding that: "The effects of post-disturbance logging require careful consideration of whether to log at all, and if so, how to conduct such logging to minimize negative consequences. If we must conduct post-disturbance logging for timber production, stringent ecological safeguards must be in place to minimize impacts to terrestrial and aquatic ecosystems. When viewed through an ecological lens, a recently disturbed landscape is not just a collection of dead trees, but a unique and biologically rich environment that also contains many of the building blocks for the rich forest that will follow the disturbance."

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Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No Although the letter from scientists is not considered relevant scientific information, the general notion of a biologically rich environment is part of the purpose and need of the Project. The analysis for the Project does not make the argument that treatments are designed to improve the forest by logging; logging is a tool for meeting the purpose and need for the Project. Treatments are designed to mitigate fuel loading in an area that has not burned in a substantial period of time by a human-caused fire. By removing these fuels in strategic areas, fire effects would be moderated in later fires, improving the likelihood that a fire burning in this area in the future may not be stand replacing over such a large, contiguous area and creating more of a mosaic across this landscape. Within these constraints, fire is accepted as an important driver of forest health and biodiversity in the Klamath Mountains. Comment #49-34: “Attachment 10 is Smucker et. all, 2005. Changes in Bird Abundance After Wildfire: Importance of Fire Severity and Time Since Fire. Ecological Applications, 15(5), 2005, pp. 1535-1549 q 2005 by the Ecological Society of America. 11 The abstract states: "Fire can cause profound changes in the composition and abundance of plant and animal species, but logistics, unpredictability of weather, and inherent danger make it nearly impossible to study high-severity fire effects experimentally. We took advantage of a unique opportunity to use a before-after/control-impact (BACI) approach to analyze changes in bird assemblages after the severe fires of 2000 in the Bitterroot Valley, Montana. Observers surveyed birds using 10-minute point counts and collected vegetation data from 13 burned and 13 unburned transects for five years before fire and three years after fire. We compared changes in vegetation variables and relative bird abundance from before to after fire between the set of points that burned and the set of points that did not burn. The magnitude of change in vegetation variables from before to after fire increased with fire severity. The relative abundances of nine bird species showed significantly greater changes from before to after fire at burned points compared with unburned points. Moreover, when burned points were separated by whether they burned at low, moderate, or high severity, an additional 10 species showed significant changes in relative abundance from before to after fire at one or more severities. Overall, almost twice as many bird species increased as decreased significantly in response to fire. We also found changes in abundance between one year after and two years after fire for most species that responded to fire. Thus, species that have been termed ''mixed responders'' in the literature appear to be responding differently to different fire severities or different time periods since fire, rather than responding variably to the same fire conditions. These findings underscore the importance of fire severity and time since fire and imply that both factors must be considered to understand the complexities of fire effects on biological communities. Because different bird species responded positively to different fire severities, our results suggest a need to manage public lands for the maintenance of all kinds of fires, not just the low-severity, understory burns that dominate most discussions revolving around the use of fire in forest restoration."

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Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No There is available research that is geographically closer to the project than Montana. The Seiad- Horse Project analysis does not dispute the importance of burned forest for a multitude of bird species; however, the Forest Plan clearly outlines the particular bird species to be evaluated during project planning. These are addressed in the EA (pages 99-101), Management Indicator Species report and Biological Evaluation as noted in the response to literature cited by comment #49-31. Comment #49-35: “Attachment 11 is Kotliar et al, 2007. Avifaunal Responses To Fire in Southwestern Montane Forests Along a Burn Severity Gradient. Ecological Applications, 17(2), 2007, pp. 491-507 by the Ecological Society of America The abstract states: "The effects of burn severity on avian communities are poorly understood, yet this information is crucial to fire management programs. To quantify avian response patterns along a burn severity gradient, we sampled 49 random plots (2001-2002) at the 17 351-ha Cerro Grande Fire (2000) in New Mexico, USA. Additionally, pre-fire avian surveys (1986- 1988, 1990) created a unique opportunity to quantify avifaunal changes in 13 pre-fire transects (resampled in 2002) and to compare two designs for analyzing the effects of unplanned disturbances: after-only analysis and before-after comparisons. Distance analysis was used to calculate densities. We analyzed after only densities for 21 species using gradient analysis, which detected a broad range of responses to increasing burn severity: (I) large significant declines, (II) weak, but significant declines, (III) no significant density changes, (IV) peak densities in low- or moderate-severity patches, (V) weak, but significant increases, and (VI) large significant increases. Overall, 71% of the species included in the after-only gradient analysis exhibited either positive or neutral density responses to fire effects across all or portions of the severity gradient (responses III-VI). We used pre/post pairs analysis to quantify density changes for 15 species using before-after comparisons; 12 spatiotemporal variation in densities was large and confounded fire effects for most species. Only four species demonstrated significant effects of burn severity, and their densities were all higher in burned compared to unburned forests. Pre- and post-fire community similarity was high except in high-severity areas. Species richness was similar pre- and post- fire across all burn severities. Thus, ecosystem restoration programs based on the assumption that recent severe fires in Southwestern ponderosa pine forests have overriding negative ecological effects are not supported by our study of post-fire avian communities. This study illustrates the importance of quantifying burn severity and controlling confounding sources of spatiotemporal variation in studies of fire effects. After-only gradient analysis can be an efficient tool for quantifying fire effects. This analysis can also augment historical data sets that have small samples sizes coupled with high non-process variation, which limits the power of before-after comparisons."” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No There is available research that is geographically closer to the project than New Mexico. See response to literature cited in comments #49-31 and #49-34.

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Comment #49-41: “Attachment 17a consists of Darren Clark's 2007 Master's Thesis in Wildlife Science entitled Demography and Habitat Selection of Northern Spotted Owls in Post-Fire Landscapes of Southwestern Oregon. This 2007 study found that: "Nesting, roosting and foraging habitat with low, moderate, or high severity burn was selected [as habitat] by spotted owls in post-fire landscapes. Furthermore, roosting and foraging habitat with a moderate severity burn was also selected. These habitats were used in a similar manner to early seral forests including: roosting and foraging habitat with low or high severity burn and salvage logged areas. Non-habitat was the only habitat that was avoided." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes The Seiad-Horse northern spotted owl report (summarized in the EA on page 95) uses the findings of Clark 2007. Comment #49-42: “Attachment 17b is a 2013 published paper in the Journal of Wildlife Management. Relationship Between Wildfire, Salvage Logging, and Occupancy of Nesting Territories by Northern Spotted Owls Darren A. Clark, Robert G. Anthony and Lawrence S. Andrews. The abstract states: "Furthermore, Timbered Rock had a 64% reduction in site occupancy following wildfire (2003-2006) in contrast to a 25% reduction in site occupancy at South Cascades during the same time period. This suggested that the combined effects of habitat disturbances due to wildfire and subsequent salvage logging on private lands negatively affected site occupancy by spotted owls. In our second analysis, we investigated the relationship between wildfire, salvage logging, and occupancy of spotted owl territories at the Biscuit, Quartz, and Timbered Rock burns from 2003 to 2006. Extinction probabilities increased as the combined area of early seral 16 forests, high severity burn, and salvage logging increased within the core nesting areas (^b ¼ 1:88, 95% CI ¼ 0.10-3.66). We were unable to identify any relationships between initial occupancy or colonization probabilities and the habitat covariates that we considered in our analysis where the b coefficient did not overlap zero. We concluded that site occupancy of spotted owl nesting territories declined in the short term following wildfire, and habitat modification and loss due to past timber harvest, high severity fire, and salvage logging jointly contributed to declines in site occupancy."” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes The Seiad-Horse northern spotted owl report (summarized in the EA on page 95) uses the findings of Clark 2013. Comment #49-43: “Attachment 18 is a study that was published in the Wildlife Society Bulletin in 2002 by Bond et. al. entitled Short-Term Effects of Wildfires on Spotted Owl Survival, Site Fidelity, Mate Fidelity, and Reproductive Success. The abstract for this study states: "The effects of wildfire on wildlife are important considerations for resource managers because of recent interest in the role of fire in shaping forested landscapes in the western United States. This is particularly true of wildfire effects on spotted owls because of the uncertainty of impacts of controlled burning within spotted owl habitat. Therefore,

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we documented minimum survival, site fidelity, mate fidelity, and reproductive success for 21 spotted owls after large (>540 ha) wildfires occurred within 11 owl territories in California, Arizona, and New Mexico. In each territory, fire burned through the nest and primary roost sites. Eighteen owls (86%) were know to be alive at least 1 year after the fires, which was similar to reported annual adult survival probabilities for the species. Of 7 pairs, of which both members were later resighted, all were located together on the same territories during the breeding season following fires, and 4 pairs produced a total of 7 fledglings. No pair separations were observed after fire. On 8 territories where fire severities were mapped, 50% experienced predominately low- to moderate- severity fires while 50% experienced high severity fires that burned large (>30%) area of the territories. We hypothesize that wildfires may have little short-term impact on survival, site fidelity, mate fidelity, and reproductive success of spotted owls." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes The Seiad-Horse northern spotted owl report (summarized in the EA on page 95) uses the findings of Bond et al. 2002. Comment #49-45: “Attachment 20 is a 2009 peer-reviewed article by Bond et al that appeared in the The Journal of Wildlife Management, 73(7): 1116-1124; 2009, entitled Habitat Use and Selection by California Spotted Owls in a Post-fire Landscape. The abstract for this article states: "Forest fire is often considered a primary threat to California spotted owls (Strix occidentalis occidentalis) because fire has the potential to rapidly alter owl habitat. We examined effects of fire on 7 radiomarked California spotted owls from 4 territories by quantifying use of habitat for nesting, roosting, and foraging according to severity of burn in and near a 610-km2 fire in the southern Sierra Nevada, California, USA, 4 years after fire. Three nests were located in mixed-conifer forests, 2 in areas of moderate-severity burn, and one in an area of low- severity burn, and one nest was located in an unburned area of mixed-conifer-hardwood forest. For roosting during the breeding season, spotted owls selected low-severity burned forest and avoided moderate- and high-severity burned areas; unburned forest was used in proportion with availability. Within 1 km of the center of their foraging areas, spotted owls selected all severities of burned forest and avoided unburned forest. Beyond 1.5 km, there were no discernable differences in use patterns among burn severities. Most owls foraged in highseverity burned forest more than in all other burn categories; high-severity burned forests had greater basal area of snags and higher shrub and herbaceous cover, parameters thought to be associated with increased abundance or accessibility of prey. We recommend that burned forests within 1.5 km of nests or roosts of California spotted owls not be salvage-logged until long-term effects of fire on spotted owls and their prey are understood more fully." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes The Seiad-Horse northern spotted owl report (summarized in the EA on page 95) uses the findings of Bond et al. 2009.

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Comment #49-46: “Attachment 21 consists of a peer-reviewed study by Saab et al that appeared in Forest Ecology and Management (2009) entitled Nest-site selection by cavitynesting birds in relation to salvage logging. The abstract reads as follows: "Large wildfire events in coniferous forests of the western United States are often followed by postfire timber harvest. The long-term impacts of postfire timber harvest on fire- associated cavity-nesting bird species are not well documented. We studied nest-site selection by cavitynesting birds over a 10-year period (1994-2003), representing 1-11 years after fire, on two burns created by mixed severity wildfires in western Idaho, USA. One burn was partially salvaged logged (the Foothills burn), the other was primarily unlogged (the Star Gulch burn). We monitored 1367 nests of six species (Lewis's Woodpecker Melanerpes lewis, Hairy Woodpecker Picoides villosus, Black-backed Woodpecker P. arcticus, Northern Flicker Colaptes auratus, Western Bluebird Sialia mexicana, and Mountain Bluebird S. currucoides). Habitat data at nest and non-nest random locations were characterized at fine (field collected) and coarse (remotely sensed) spatial scales. Nest-site selection for most species was consistently associated with higher snag densities and larger snag diameters, whereas wildfire location (Foothills versus Star Gulch) was secondarily important. All woodpecker species used nest sites with larger diameter snags that were surrounded by higher densities of snags than at non-nest locations. Nests of Hairy Woodpecker and Mountain Bluebird were primarily associated with the unlogged wildfire, whereas nests of Lewis's Woodpecker and Western 18 Bluebird were associated with the partially logged burn in the early years after fire. Nests of wood-probing species (Hairy and Black- backed Woodpeckers) were also located in larger forest patch areas than patches measured at non-nest locations. Our results confirm previous findings that maintaining clumps of large snags in postfire landscapes is necessary for maintaining breeding habitat of cavity-nesting birds. Additionally, appropriately managed salvage logging can create habitat for some species of cavity-nesting birds that prefer more open environments. Our findings can be used by land managers to develop design criteria for postfire salvage logging that will reserve breeding habitat for cavity-nesting birds." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No There is available research that is geographically closer to the project than Idaho. The Seiad- Horse Project analysis does not dispute the importance of burned forest for a multitude of bird species; however, the Forest Plan clearly outlines the particular bird species to be evaluated during project planning. These are addressed in the EA (pages 99-101), Management Indicator Species report and Biological Evaluation as noted in the response to literature cited by comment #49-31. That said, the Saab et al. 2009 study and other similar studies on cavity nesting birds were considered for the Seiad-Horse Project. Aspects of their findings regarding snag retention patches were incorporated into the project design. Comment #49-95: “Scientists have continually recommended that forest managers should ensure the maintenance of moderate and high severity fire patches to maintain populations of numerous native bird species positively associated with fire (Hutto 1995, Hutto 2006, Kotliar et al. 2002, Noss et al. 2006, Smucker et al. 2005). At the landscape level, high severity habitat (unlogged) is among the most underrepresented, and rarest, of forest habitat types (Noss et al. 2006). Indeed, the current annual spatial extent of

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wildland fire in California's forests is about one tenth of what it was prior to fire suppression (Medler 2006). Forests experiencing high severity burns, or "snag forests", are often incorrectly assumed by land managers to be "damaged" (USDA 2004). Ecologically, this is strongly contradicted by the scientific evidence. Peak biodiversity levels of higher plants and vertebrates are found in patches of snag forest habitat—areas where most or all of the trees are killed by fire (Noss et al. 2006), consistent with the principle that pyrodiversity enhances biodiversity, where mixed-severity fire effects occur (Chang 1996). Fireinduced heterogeneity, including a mix of low, moderate, and high severity patches, leads to higher post-fire understory plant species richness compared to homogeneous low severity fire effects (Chang 1996, Rocca 2004). Mixed-severity fire, meaning a heterogeneous mix of high, moderate, and low severity effects, facilitates reproduction of numerous native herbaceous and shrub species (Chang 1996, Rocca 2004), the germination of many of which is triggered by fire-induced heat, charate, or smoke (Biswell 1974, Chang 1996). These flowering plants, in turn, increase biodiversity of flying insects, including hymenopterans (bees, wasps, flying ants). And, fire-mediated conifer mortality attracts bark beetles and wood-boring beetles, some species of which have evolved infrared receptors capable of detecting burned forests from over 161 km away (Altman and Sallabanks 2000, Hutto 1995). Other insect species are attracted by the smoke from fires (Smith 2000). As a result, avian species richness and diversity increases in heavily burned patches occurring within a mix of low and moderate severity effects. Woodpeckers excavate nest cavities in snags and feed upon bark beetle and wood-boring beetle larvae in dead trees; Mountain Bluebirds (Sialia currucoides) and other secondary cavity-nesting species use nest holes created the previous year by woodpeckers; granivores such as the Red Crossbill (Loxia curvirostra) feed upon seed release from cones following fire; shrubdwelling species like the Blue Grouse (Dendragapus obscurus) nest and forage within shrub growth scattered throughout high severity patches; while aerial insectivores such as the Olive-sided Flycatcher (Contopus cooperi) prey upon the bark beetles that are abundant in snag patches (Altman and Sallabanks 2000, Hutto 1995). The Olive- sided Flycatcher is listed by the U.S. Forest Service as a Species at Risk, meaning that there is significant concern about the viability of its populations due to habitat scarcity and loss (USFS 2001). Populations of small mammals experience overall increases shortly after high severity fire, and amphibians are positively associated with the large woody material that gradually accumulates in the decades following such fire effects (Smith 2000). As 41 well, ungulates forage upon post-fire flora, and large predators frequently seek their prey in burned patches (Smith 2000). Studies have detected higher overall avian species richness in severely burned versus unburned forest in the western United States (Bock and Lynch 1970, Hutto 1995, Raphael and White 1984, Siegel and Wilkerson 2005). In one snag forest area resulting from the Manter Fire of 2000 in the southern Sierra Nevada, a total of 111 bird species were observed (Siegel and Wilkerson 2005). Following the 60,000 ha McNally Fire of 2002 in Sequoia National Forest, Olive-sided Flycatchers were found in the burn area (Siegel and Wilkerson 2005). This species had previously been considered to be extirpated from Sequoia National Forest, possibly since 1930 (Altman and Sallabanks 2000). Research has also indicated that numerous avian species, including several woodpecker species, exhibit a preference for burned conifer forest habitat (Bock and Lynch 1970, Dixon and Saab 2000, Murphy and Lehnhausen 1998, Granholm 1982, Hutto 1995, Saab et al. 2002, Saab et al. 2004). Fire-killed trees provide nesting and foraging habitat for numerous woodpecker species (Hutto 1995, Dixon and Saab 2000). Post-fire logging has been described as a threat to such species (Dixon and Saab 2000, Kotliar et al. 2002, Lindenmayer et al. 2004, Murphy and Lehnhausen 1998, Saab et al 2004). To conserve populations of species which prefer heavily burned forest patches in the eastern Cascades, Altman (2000) recommended that: "at least 2% of the forested landscape be maintained in early post-fire habitat; at least 40-50% of such burned stands be retained in an unlogged state; and, where salvage logging does occur, all snags (firekilled trees) > 51 cm (20 inches) dbh and half of all snags 30-51 cm (12-20 inches) dbh should be retained." There is perhaps no vertebrate species more strongly representative of the snag forest habitat type than the Black-backed Woodpecker

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(Picoides arcticus) (Hanson 2007, Hutto 1995). This species is a designated Management Indicator Species, acting as a bellwether for the viability of dozens of other species associated with snag forests (USDA 2004). One of only two woodpecker species globally with three toes instead of four, the Blackbacked Woodpecker is able to deliver exceptionally hard blows due to added heel mobility resulting from the lack of a fourth toe and, as a consequence, it can reach beetle larvae that other woodpecker species cannot (Dixon and Saab 2000). One bird eats an astounding 13,500 beetle larvae per year (Hutto, unpublished data). From behind, the allblack coloring of this species confers excellent camouflage against the charred bark of a fire-killed tree. Though Black-backed Woodpeckers are occasionally, but rarely, seen outside of stand-replacement burns, forests outside of snag forest habitat are believed to be "sink" habitats which do not support them (Hutto 1995, Dixon and Saab 2000). Heterogeneous fires are very important ecologically, since a number of species depend not only upon burned forest habitat in general, but also specifically upon particular levels of severity, with some requiring low or moderate severity burn patches and some 42 requiring only patches of high severity burned forest (Smucker et al. 2005, Kotliar et al. 2007). Indeed, a recent scientific study of the northern Sierra Nevada and southern Cascades by the Forest Service scientists concluded that: "…it is clear from the scientific data that burned forest, including stand replacing burns [high severity fire patches], provide important bird habitat. The abundance and diversity of woodpecker species generally reaches a peak in recently burned forest. The Black-backed Woodpecker, a rare resident of the northern Sierra forest, predominantly occurs in recently burned forest. Olive-sided Flycatcher, a species declining throughout the Sierra Nevada, has been shown to be strongly associated with burned forest as well. Thus we promote the view that burned forest is important wildlife habitat." (USFS 2006) It is the diversity of fire effects that facilitates and maximizes native biodiversity (Connell 1978, Noss et al. 2006). It is, in fact, the unlogged high severity patches that are most in deficit in west coast forests, probably more than any other single forest habitat type.” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No The Seiad-Horse Project analysis does not dispute the importance of burned forest for a multitude of bird species; however, the Forest Plan clearly outlines the particular bird species to be evaluated during project planning. These are addressed in the EA (pages 99-101), Management Indicator Species report and Biological Evaluation as noted in the response to literature cited by comment #49-31. Comment #49-96: “Attachment 24 to our scoping comments was a peer-reviewed study conducted by Lee et al for the Institute for Bird Population published in The Condor 114(4): 792-802, The Cooper Ornithological Society 2012. Its abstract concludes: "Understanding how habitat disturbances such as forest fire affect local extinction and probability of colonization—the processes that determine site occupancy—is critical for developing forest management appropriate to conserving the California Spotted Owl (Strix occidentalis occidentalis), a subspecies of management concern. We used 11 years of breeding season survey data from 41 California Spotted Owl sites burned in six forest fires and 145 sites in unburned areas throughout the Sierra Nevada, California, to compare probabilities of local extinction and colonization at burned and unburned sites while accounting for annual and site specific variation in detectability. We found no significant effects of fire on these probabilities, suggesting that fire, even fire that burns on average 32% of suitable habitat at high severity within a California Spotted Owl site, does not threaten the persistence of the subspecies on the landscape. We used simulations to examine how different

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allocations of survey effort over 3 years affect estimability and bias of parameters and power to detect differences in colonization and local extinction between groups of sites. Simulations suggest that to determine whether and how habitat disturbance affects California Spotted Owl occupancy within 3 years, managers should strive to annually survey =200 affected and =200 unaffected historical owl sites throughout the Sierra Nevada 5 times per year. Given the low probability of detection in one year, we recommend more than one year of surveys be used to determine site occupancy before management that could be detrimental to the Spotted Owl is undertaken in potentially occupied habitat." Klamath National Forest timber planners elected not to consider or respond to these findings.” Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? Yes The Seiad-Horse northern spotted owl report (summarized in the EA on page 95) uses the findings of Lee et al. 2012. Comment #49-140: “Attachment 6 is Hutto, R.L. 2006. Toward Meaningful Snag-Management Guidelines for Post-Fire Salvage Logging in North American Conifer Forests. Conservation Biology 20: 984-993. The abstracts states: "The bird species in western North America that are most restricted to, and therefore most dependent on, severely burned conifer forests during the first years following a fire event depend heavily on the abundant standing snags for perch sites, nest sites, and food resources. Thus, it is critical to develop and apply appropriate snag-management guidelines to implement post-fire timber harvest operations in the same locations. Unfortunately, existing guidelines designed for green-tree forests cannot be applied to post-fire salvage sales because the snag needs of snag-dependent species in burned forests are not at all similar to the snag needs of snag-dependent species in green-tree forests. Birds in burned forests have very different snag retention needs from those cavity-nesting bird species that have served as the focus for the development of existing snag-management guidelines. Specifically, many post-fire specialists use standing dead trees not only for nesting purposes but for feeding purposes as well. Woodpeckers, in particular, specialize on wood-boring beetle larvae that are superabundant in fire-killed trees for several years following severe fire. Species such as the Black- backed Woodpecker (Picoides arcticus) are nearly restricted in their habitat distribution to severely burned forests. Moreover, existing post-fire salvage-logging studies reveal that most post-fire specialist species are completely absent from burned forests that have been (even partially) salvage logged. I call for the long-overdue development and use of more meaningful snag retention guidelines for post-fire specialists, and I note that the biology of the most fire-dependent bird species suggests that even a cursory attempt to meet their snag needs would preclude post-fire salvage logging in those severely burned conifer forests wherein the maintenance of biological diversity is deemed important." Forest Response: Was the reference provided or is it accessible? Yes Does the literature provided support comments specifically about the project? No See response to literature cited by comment #49-95.

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