Umatilla Activism &, Rising Tide: a 'pro-Pain' in Charlie Hales Money Train

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KBOO
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Air date: 
Thu, 04/23/2015 - 10:00am to 10:15am
Interviews with Cathy-Sampson-Kruse of the Umatilla Nation and Rising Tide's Lowen Berman

 

 

 


DATE \@ "MMMM d, y 'AM/PMt' h:mm AM/PM" April 7, 2015 at 9:57 AM Mark Teply Cramer Fish Sciences Project Manager 4405 7th Ave SE, Suite 306 Lacey, WA 98503 nfnc_public@fishsciences.net Re: Comments on North Fork Mill Creek A to Z Project Dear Mark, Thank you for providing me the opportunity to comment on the North Fork Mill Creek A to Z Project (NFMC). I also want to thank you for your prompt reply to my request for the Specialist’s Reports. The pre-decisional Environmental Assessment (EA) findings of No Significant Effects for the NFMC Proposed Action, Alternative (Alt) B and Alternative C are not supported by the documentation in the EA and the Specialist’s Reports. The EA finds that several issues are “outside the project scope,” or are dealt with in other documents that should be part of the environmental analysis and fully documented in the EA. GRAZING The EA does not provide any site specific information regarding the grazing impacts to the affected streams in the Project Area (PA). It states that the effect of current grazing allotments on water quality and riparian habitat are addressed in a separate grazing allotment plan. The name of the plan is not mentioned. Page PAGE 9 of NUMPAGES 9 What is the name and date of the plan, and what grazing allotments does it cover? In a seemingly contrary move, the EA finds it necessary to discuss protections from potential adverse effects to the grazing allotment from the proposed timber sale and offers enhancements such as creating up to 200 acres of openings and proposes planting them with native grass to provide more grazing area for the existing range permit. Are these new openings factored in the environmental effects analysis? Does this move the area closer to the Historic Range of Variability as expressed in the purpose and need? Have the cattle had any adverse effect on water quality and riparian habitat in the Project Area? When was the latest monitoring of site specific effects of cattle on the water and riparian resources in the PA? I could not find this information in the EA or the Specialist’s Reports. Alt B proposes to construct an additional 30.8 miles of new temporary road in addition to the already 65 miles of Forest Service (FS) and unauthorized roads in the PA. The project also proposes to increase the amount of openings by conducting shelterwood and commercial thinning in the PA. These actions can make it easier for cattle to access riparian habitat and streams which can result in additional adverse impacts to water quality and the fishery in the PA. The grazing issue is significant and should be fully examined in the EA. What stream segment(s) in the Project Area have a TMDL due to excess coliform bacteria? Are the grazing allotment cattle contributing to the 303(d) status? This information should be provided in the EA. CLIMATE CHANGE Deforestation is linked to climate change. The EA states the impact on climate change from the NFMC Project is insignificant. The idea of cumulative effects is to consider those things that might seen insignificant but when added to other similar actions can have a significant effect. What would the CNF consider a significant amount of logging activities that would contribute to climate change? Given the EA’s way of dealing with this issue, it could excuse all particular logging activities wherever and whenever from being considered as a contributor to climate change. The effects of deforestation on climate change should be fully considered in this EA. A to Z EXPERIMENT The EA avoids discussing the “elephant in the room.” In a precedent setting move, the Forest Service has granted Vaagen Brothers Lumber Company (Vaggen), a for profit timber company, broad and sweeping powers that includes designing the A to Z Projects, doing the environmental analysis, writing the EA, deciding where, how, and how much to log, where Page PAGE 9 of NUMPAGES 9 and how many roads need to be constructed and just about everything else associated with a Forest Service timber sale except make the final decision. The A to Z Projects include the upcoming Middle and South Fork Mill Creek, Onion and Little Twin Projects. While Vaagen Brothers Lumber Company itself does not have the expertise to do everything associated with NFMC Project, they have hired specialists to do what is necessary to implement the Project. It appears that Vaggen’s role is similar to a general contractor who is responsible for the work of the subcontractors. The respective missions of the FS and the for profit Vaagen Lumber Company are different and could influence the outcome of the financial and environmental impacts of the sale. It is doubtful that the FS is going choose the No Action alternative, or significantly alter the Project since Vaagen, a member of the local community and the Northeast Washington Forest Coalition, bid one million dollars to participate in this experiment. By having Vaggen responsible for most of the work associated with timber sale planning and management, it provides the opportunity for the Colville National Forest (CNF) to reach its timber target. The CNF claims it cannot currently do so because of budget and staff reductions. This is a significant action and needs to be disclosed and fully discussed in the EA.The fact that the Proposed Action calls for a very large timber sale with an inordinately large amount of road construction could be consistent with the needs of a for-profit timber corporation. Vaagen needs to have a sale that offers a sufficient volume of timber to cover its bid price, the costs associated with the project, and make a profit. The public can expect large timber sales if this experiment is continued to other timber sales. This is a national forest issue and the public throughout the country needs to know of this experiment and how it can affect the environmental outcome. The financial aspect of this experiment also needs to be fully disclosed. Does the FS expect this to be below cost or profitable project for the agency? WATER QUALITY & FISHERY Critical information, which can be found only in the Specialists Reports, are not and should be presented in the EA. This is one example of many National Environmental Policy Act (NEPA) violations that can found throughout the EA. The hydrology and fish sections of the EA omit information necessary for the public to make an informed decision. What follows are just a couple of examples. One would have to go to the Fishery Specialist’s Report to find out that in 6.5 miles of streams surveyed that are currently classified as fish bearing, only 19 fish were sampled and only one westslope cutthroat trout was found (Fishery Specialist’s Report p.6). The gravity of this situation needs to be presented in the EA. There was no mention of bull Page PAGE 9 of NUMPAGES 9 trout. Is there bull trout habitat in the Project Area? The EA also omits information regarding the fact that the WEPP and WEPP FuME models are within +/- 50% of predicted values. According to the NFMC A to Z Project Hydrology Specialist Report, the WEPP road model and WEPP FuME are used to estimate sediment production. According to the Hydrology Specialist Report, p.17, “The documentation for the WEPP:Road model indicates that sediment delivery estimates are within +/- 50% of predicted values (Elliott et al. 1999). As a result, and like for the WEPP:FuME estimates, model-predicted sediment delivery values are best used to compare relative differences between alternatives and modeling scenarios. Error estimates for the average annual sediment load are not provided by the WFPB watershed analysis manual (WFPB 2011).” These models and their limitations should be, but are not referred to, in the EA. These models are used to predict sediment levels throughout the EA. It is unreasonable to put so much weight on these models given the wide range of confidence levels. The EA places a lot of emphasis on these figures without letting the public know that the figures are within +/- 50% of predicted values. How accurate are the predictions of a increase in sediment of 63% for duration of logging activities, a decrease of 1 percent in the short term, and a 65% decrease in the long term as predicted for Alt. B? The CNF should realize that logging and road construction are not surgical strikes. Do these figures include the sediment increases during Rain on Snow (ROS) events, lack of road maintenance and other site specific sediment producing activities on Forest Service and non-Forest Service managed ground in the project area? The EA at p. 64 states that there is continued erosion from existing roads. When were these roads constructed? The EA relies heavily on models in its effects analysis due to a paucity of on the ground, scientifically credible, site specific quantitative monitoring information. The CNF has not demonstrated that it has an adequate site specific monitoring program and consequently is out of compliance with the Colville National Forest Plan. Failure to follow the monitoring requirements makes it impossible for the CNF to determine the accuracy of its predictions of the environmental impacts of other timber sales. That information can be applied to proposed timber sales. Much is predicated on continued maintenance of new and existing roads after the project is over. Is that realistic given the reduced CNF budget and considering the poor condition of many existing roads and many impaired culverts? What percent of existing roads on CNF receive significant yearly maintenance? How many miles of CNF road received maintenance in FY 2010, 2011, 2012, 2013, 2014, 2015. Page PAGE 9 of NUMPAGES 9 The EA lacks sufficient site specific watershed analysis for each of the affected stream drainages for the public to adequately evaluate the environmental impacts. Is there significant bedload deposition, point and mid-channel bars, and adverse effects from cattle in the affected stream segments? It does mention that the streams fall short of INFISH Riparian Management Objectives (RMO) for width depth ratio, fine sediment, stream bank angle and large woody debris. The EA does not adequately discuss the causes and the significance of not meeting the RMO. How long will the affected streams remain impaired and how will these problems effect the fishery in the short and long term? What are the existing impacts to the fishery in each of the affected streams? The EA states that current sediment levels in project area streams are 23%. What methodology was used to make that assessment? The EA does not describe the composition of the sediment—what type of materials are eroding and accumulating in the streams? The EA does not adequately address the short and long term significance of this amount of sediment deposition. What are the site specific recorded levels of sediment, fine and bedload, for each of the affected streams? What is the significance of these levels? What is the significance of the predicted increases in sediment production in each of the affected streams in the project area? How are the affected streams dealing with accumulated sediment? How long will it take for these streams to recover and meet the RMO’s given the increase in water yield and additional sediment that will be generated by the 30.8 miles of proposed new temporary road construction, logging and cattle intrusion? Road construction results in sediment; decommissioning the temporary roads adds another pulse of sediment. The EA does not describe the elements proposed road decommissioning. Are these applicable to all decommissioned roads? What is involved in decommissioning roads? RAIN ON SNOW (ROS) Much of the logging activity takes place in areas susceptible to ROS. The EA does not use the best available science to determine the frequency, water yield, impacts, duration and other characteristics associated with ROS. Nor does the EA adequately disclose this information. The timber sale proposes to build an additional 30.8 miles of road in addition to the existing 65 miles of road in the project area. The EA proposes 1,741 acres of shelterwood logging (avg. 75% of trees >7 inches dbh will be cut along with many trees under 7 inches) and 2,277 acres of commercial thinning (removing an avg. of 50% of the trees). The proposed logging will change large areas from mature forest canopy to intermediate forest canopy category. The EA fails to reveal what coefficients will be used for site specific areas to evaluate the susceptibility and intensity of a ROS event. Page PAGE 9 of NUMPAGES 9 The EA does not adequately disclose the effects of ROS events on site specific drainages that have varying amounts and types of logging, road density, spacial and other characteristics that influence a ROS event. What is the existing road density and the road density post logging/road construction in the PA? How does the CNF Forest Plan deal with road density? The EA does not compute Equivalent Clearcut Area (ECA). Proposed roads and logging create a large additional amount of openings in the Project Area which could significantly effect water quality, quantity and fish habitat. How many ECAs will be created by the proposed timber sale? What is the total amount of ECAs in the North Fork Mill Creek PA? The Hydrology Specialist’s report, Figure 19, represents the mean daily peak flows for the North Fork Mill Creek. What date is being represented by that graph? One point in time is not an adequate means of evaluation. The use of “mean daily peak flows” is not a fair representation of flow levels. The models used to evaluate the amount of ROS flows and its impacts are no substitute for daily recording of stream flows from instream gauges on the North Fork Mill Creek. There is no longer an instream gauge on the North Fork Mill Creek. The inadequate monitoring of ROS events undercuts the conclusions regarding effects of ROS events. INSECTS AND DISEASE One of the justifications for the A to Z project is to reduce susceptibility to insects and disease in the PA. Are the current levels of insects and disease beyond those found in a normally functioning forest? Are they trending beyond normal levels? Is there data from site specific surveys conducted in the PA to determine the current levels of insects and disease and it trends? What best available science was used to determine that the proposed logging will “improve” the current situation. FIRE A Purpose and Need for the Proposed Action is to “reduce the threat of severe wildfire.” What is the basis for the assumption in the EA that the PA is ripe for a severe wildfire? The EA assumes in Alt A that without this project the chances for a severe wildfire will occur with extreme effects is increased. There are many examples of wildfires that burn in a mosaic fashion leaving a naturally functioning forest without having a significant effect on soils, water quality or wildlife. Fire is an important aspect of a naturally functioning forest. The proposed logging will significantly open up the area and reduce the amount of existing mature forest. These logged areas will more likely be drier, warmer, susceptible to increases in wind and will generate more ground fuels than currently exist. All these characteristics have the potential to increase the risk and severity of a wildfire. The EA Page PAGE 9 of NUMPAGES 9 does not adequately discuss these increased risks. The EA also states that it will leave a lot of fine material on the ground to increase the nutrient level. What will keep the fines from burning up, especially in the areas that will be broadcast burned? The slash generated by the logging, pre commercial thinning and road construction also increases the risk and intensity of wildfire. The proposed action alternatives do not make the PA fireproof. The issue of wildfire is controversial. There are reports by credible scientists who dispute that logging significantly reduces the risk and intensity of wildfire. None of these opposing views are presented in the EA. The EA fails in its obligation to use the best available science in its analysis. The EA needs to factor the possibility of wildfire and its effects in all the action alternatives. CUMULATIVE EFFECTS The EA needs to consider the cumulative effects on Mill Creek since another large timber sale, Middle and South Forks Mill Creek A to Z Project is to be implemented in the foreseeable future. These creeks along with the North Fork Mill Creek drain into Mill Creek and could have significant direct, indirect and cumulative effects on Mill Creek. The EA lacks a sufficient and credible cumulative effects analysis because it does not adequately consider the past, present and site specific future activities on non Forest Service managed land in the project area. These activities need to be more carefully considered in all the cumulative effects analysis discussed in the EA. The EA relies on unreliable models to predict the effects of the proposed project because the CNF has not had a sufficient, scientifically credible quantitative monitoring program to determine the reliability of the EA’s predictions on past timber sales as required in the CNF Forest Plan. Is there an implementation and effects monitoring regime proposed for this project? If so, what are the specific elements of the monitoring plan? It is hard to believe that 30.8 miles of road and 2.2 miles of road realignment plus all the ground skidding, slash piling, etc from previous activities on FS and non-FS land, combined with this proposed timber sale would not exceed soil standards considering, "Much of the surveyed area was logged and roaded, primarily 30 to 50 years ago. Substantial detrimental soil conditions (DSC) was caused by these activities.” (EA p.72) According to the Soil Specialists Report road construction results in a 30 foot width of soil disturbance. Damaged soil takes very long time to recover so existing cumulative effects of soil impacts from previous timber sales and other activities in the PA are minimized in the EA. The leaving of large organic debris (LOD) on ground does not replicate natural conditions. Leaving LOD post logging in the logging units will not replicate the constant feed of various size trees as occurs in natural forest. Page PAGE 9 of NUMPAGES 9 Many of the logging units appear to be located in high and moderate mass wasting areas according to the map in Soil Specialist’s Report (figure 5). This map should be displayed in the EA with unit designations. Since there are no unit designations delineated on the map it is impossible to determine unit and road location in relation to moderate and high mass wasting hazard. EA fails to disclose the possibility and effects of and potential for mass wasting in areas with “moderate” rating. The Forest Service must quantify how much soil has been permanently impaired within the project area and forest wide, to determine if the principle of “sustained yield” is being applied, and to demonstrate consistency with NFMA’s prohibitions on causing permanent impairment of soil productivity. NOXIOUS WEEDS The EA fails to to adequately address the spread of noxious weeds, which have the potential effect of reducing site productivity by replacing natural vegetation and competing with same for soil nutrients, moisture, etc. It fails to adequately discuss the extent of noxious weed infestation in the PA. Who is responsible for the management of the weeds after the contract is over? How many acres have been treated in FYs 2013, 2014? How many races of the Project Area are infested with noxious weeds? The primary method for treating noxious weeds is with herbicides. What effect does herbicide application have on the flora and fauna of the forest? HISTORIC RANGE OF VARIABILITY (HRV) The EA takes an extremely narrow tree centric view of HRV. Trying to move towards the state of the forest as it was at one point in time is contrary to the nature of natural forest which is always changing. The large timber sale and road construction aspect of the Project with its regeneration logging, new “temporary” roads and additional culverts, and creating habitat or noxious weeds will move the PA farther from a natural functioning forest. The streams are laden with sediment, the roads are still contributing sediment, it is below the amended Forest Plan old growth levels, yet it is converting large contiguous areas of mature forest that has the potential to become old growth. It cares little for the elements that degrade the forest. The EA fails to examine the HRV of culverts, roads, noxious weeds and significant soil disturbance. The planting of 564 acres of proposed shelterwood logging will result in the reduction of the genetic diversity of the forest. The genetic structure of each of the tree species differ depending on its location on the landscape. Planting trees with nursery stock does not replicate the diversity that exists within each tree species as does natural regeneration. Page PAGE 9 of NUMPAGES 9 WILDLIFE The EA is in violation of the CNF Forest Plan that requires monitoring of management indicator species populations and their habitat units to ensure the needs and of mature and old growth dependent species are being met. National Forest Management Act (NFMA) requires surveys to insure the viability of management indicator species. With the Eastside Screens Forest Plan Amendment and the specific MIS habitat provisions of the Forest Plan, the CNF has relied exclusively upon project-level habitat designations as its only viability strategy. This is contrary to the Forest Service’s own best available science. The Committee of Scientists (1999) report also stress the importance of monitoring as a necessary step for the Forest Service’s overarching mission of sustainability: “Monitoring is the means to continue to update the baseline information and to determine the degree of success in achieving ecological sustainability.” Yet the CNF has not consistently published a Forest Plan Monitoring and Evaluation Report despite the forest plan requirement that it be issued annually. The EA also does not adhere to Forest Plan wildlife standard 4 which requires: “Give special consideration to management or protection of unique habitat components, not covered by other management indicator species, during evaluation of activities that may effect such habitats and the species that are dependent on them. Evaluate the species status, dependency on the component, and the extent or limitation of the component as factors influencing the viability of populations within the Forest or the range of the species.” The logging and road construction will result in fragmentation. The EA does not adequately discuss the impacts on MIS and other species as a result of the loss of interior forest habitat. What impacts will fragmentation have on the wildlife in the PA? Are there lynx in the Project Area? How has the CNF determined whether or not there are lynx in the Project Area? Are there grizzly bear in the area? How has the CNF made that determination? Thank you for the opportunity to comment. Sincerely yours, Barry Rosenberg cc: Kootenai Environmental Alliance Page PAGE 9 of NUMPAGES 9 Selkirk Conservation Alliance

 

 

 

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