September 29, 2014 Land Management Plan Revision USDA Forest Service Ecosystem Planning Staff 1323 Club Drive Vallejo, CA 94592 Submitted via Region 5 website Re: Comments on Notice of Intent and Detailed Proposed Action for the Forest Plan Revisions on the Inyo, Sequoia and Sierra National Forests To the Forest Plan Revision Team: These comments are provided on behalf of Sierra Forest Legacy and the above conservation organizations. We have reviewed the Notice of Intent (NOI), detailed Proposed Action (PA), and supporting materials posted on the Region 5 planning website and offer the following comments on these documents. We have submitted numerous comment letters since the forest plan revision process was initiated for the Inyo, Sequoia, and Sierra national forests. Specifically, we submitted comment letters on the forest assessments for each national forest (Sierra Forest Legacy et al. 2013a, Sierra Forest Legacy et al. 2013b, Sierra Forest Legacy et al. 2013c), comments on two need for change documents (Sierra Forest Legacy et al. 2014a, Sierra Forest Legacy et al. 2014b) and comments on detailed desired conditions (Sierra Forest Legacy et al. 2014c). We incorporate these comments by reference and attach the letters to these scoping comments. We have included these letters in our scoping comments because significant issues that we raised in these comments have not yet been addressed in the NOI, or the detailed PA creates significant conflict with resource areas on which we commented. Organization of Comments The following comments address first the content of the NOI, including the purpose and need for action, issues not addressed in the scoping notice, and regulatory compliance of the PA as written. Following this, we provide detailed comments on the PA with some recommendations on changes to those plan components to bring them into compliance with regulations and meet the direction SFL et al. comments on Notice of Intent and Detailed Proposed Action 9-29-14 1 in the planning rule. This section also includes recommendations for new wilderness areas and the evaluation and management of Wild and Scenic Rivers. In the last section, we present information and plan components that we ask you to address and incorporate in the development of alternatives. To improve readability, we have provided the following table of contents. Table of Contents I. Purpose and Need for Action 4 A. Defining an Economically-Viable Forest Products Industry 4 B. Carbon Storage 4 C. Declining Trends and Poor Habitat conditions for At-Risk Species 4 D. Aquatic/Riparian Ecosystems 5 E. Wild and Scenic Rivers (WSRs) 6 F. Designated Areas: Wilderness 7 II. Issues Not Identified in Scoping Notice 10 A. Fire as an Ecological Process and Its Positive Benefits 10 B. Conflicts between Logging Practices and Maintaining Habitat Quality 10 C. Analyzing Roadless Areas and Impacts to Roadless Areas in the DEIS 11 D. Road System as a Major issue that Must be Addressed in the Revision 14 E. Condition of Sierra Nevada Meadows 22 F. Fire Prevention Program to Address Human-caused Ignitions 23 III. Adequacy of Proposed Action to Meet Regulatory Requirements 23 A. Poorly Defined or Missing Plan Components 23 B. Ecological Integrity and At-risk Species 24 C. Ecological Integrity and the Integration of Plan Components 28 D. WSR Inventory and Evaluation 29 E. Climate Change 32 IV. Specific Comments on Resource Areas in the Proposed Action 33 A. Management and Geographic Areas 33 B. Forest-wide Vegetation 35 C. Westside Vegetation (Sequoia and Sierra National Forests) 48 D. At-Risk Species 53 E. Timber 82 F. Fire Management 85 G. Air 89 H. Aquatic/Riparian Ecosystems and Streams 89 I. Recreation 91 SFL et al. comments on Notice of Intent and Detailed Proposed Action 9-29-14 2 J. Wilderness 94 K. Wild and Scenic Rivers 114 L. Pacific Crest National Scenic Trail Corridor 120 V. Alternatives to consider in DEIS 121 VI. Conclusion 123 References 125 Appendices 140 Appendix A: Ecosystem Representation in Designated Wilderness Areas in Sierra, Sequoia, and Inyo National Forests Appendix B: Transportation Infrastructure and Access on National Forests and Grasslands: A Literature Review Appendix C: A Primer on Impacts of Forest Roads on Water Quality and Quantity in California Appendix D: Viability Evaluation for California Spotted Owl Appendix E: Aquatic Refuge Areas on the Sequoia, Sierra, and Inyo National Forests Appendix F: Britting et al. 2012, National Forests in the Sierra Nevada: A Conservation Strategy. Appendix G: Comment letters submitted on forest assessments, need for change and desired conditions. SFL et al. comments on Notice of Intent and Detailed Proposed Action 9-29-14 3 I. Purpose and Need for Action To a large extent, we agree with many of the purposes and needs for action. As a matter of policy, it is worth noting that the purpose and need for revision should be to alter existing plan components based on information provided in the assessment. Here we comment on specific purposes and needs that we believe should be clarified and reframed in the draft environmental impact statement (DEIS). We also provide additional purposes and needs for action that were not addressed in the NOI. A. Defining an Economically-Viable Forest Products Industry The NOI (p. 3) states a need, “to modify plan components to maintain levels of forest product and biomass production that support an economically-viable forest products industry, and to encourage local hiring.” We did not find a definition in the NOI or PA that describes an “economically-viable forest products industry.” A clear definition is needed because there are cases where the needs of the forest products industry, i.e., the demand for commercial timber, have been a stressor on ecosystems and in conflict with attaining ecological integrity. Examples of these conflicts include the removal of commercial timber from sensitive spotted owl habitat and salvage logging in areas recently burned by wildfire, e.g., American Fire, Aspen Fire and Rim Fire. It is important to emphasize here that there is a legal requirement for species viability, but not for economic viability. While the 2012 Planning Rule does require plan components for multiple uses, including timber, 219.10 is quite clear that those components must be compatible with sustainability and diversity requirements in 219.8 and 219.9. In addition to defining the term, the DEIS must evaluate the effects of plan components proposed for forest products industry viability on other plan components. B. Carbon Storage The NOI states “There is a need to modify plan direction for terrestrial ecosystems and fire, as described above, to increase the ability of forests to store and sequester carbon.”(NOI, p. 4). As stated here, it is not clear if the purpose is to increase the storage and sequestration of carbon regardless of ecological capacity or instead to sustain the landscapes’ ecological capability to sequester and store carbon. The desired condition provided in the PA (p. 4) provides an appropriate ecological context for carbon storage. Without this context, one could believe that the overriding goal was to increase stored carbon even at the expense of ecological sustainability. We ask that you clarify, consistent with the framing of the desired condition, that the focus is on supporting sequestration and storage of carbon that is ecologically appropriate. As an ecosystem service governed by 219.10, plan components for carbon storage must be evaluated against sustainability and diversity requirements to ensure compatibility. C. Declining Trends and Poor Habitat conditions for At-Risk Species The supplemental need for change document produced in June 2014 indicated that trends for population status and habitat condition were declining for a number of at-risk species. This situation should be identified as a purpose and need in changing the revised forest plans. Species in decline and with poor trend include those from terrestrial, riparian and aquatic ecosystems. SFL et al. comments on Notice of Intent and Detailed Proposed Action 9-29-14 4 Developing a plan that seeks to reverse declines and trends needs to be clearly stated as a purpose and need. D. Aquatic/Riparian Ecosystems The NOI focuses on a need to change the forest plans to allow for more prescribed fire in riparian areas and to integrate desired conditions to improve management outcomes. We agree that these are areas that should be improved, but we find that additional aspects of the existing aquatic management strategy (AMS) should be revised to better address resource conservation and protection. There are very few standards in the existing AMS for each forest plan. The current AMS is essentially an objective based strategy that allows activities to proceed near to these sensitive resources when they are consistent with a suite of goals and objectives. Currently, there are five elements to the AMS: 1) desired conditions; 2) land use allocations (RCAs and CARs); 3) a discrete salmon strategy for salmon-bearing areas of the Lassen NF; 4) adaptive management strategy focused on Yosemite toad and willow flycatcher; and 5) landscape analysis focused on restoration. Our concern with this approach, in large measure, is that the wording for some objectives allows management actions to slow or impede the rate of recovery in areas in poor condition and allows management actions that would limit the transition of a site from good to excellent condition. In addition, the plans provide for no accountability or requirement to take action in areas presently in poor condition, e.g., a poorly functioning road. These limitations jeopardize the ecosystem function and integrity of these sensitive resources. We recommend the AMS be amended to address these problems and specifically address the following: • Roads and trails can have negative impacts on meadow and stream condition (e.g., erosion, altering drainage patterns).