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CHAPTER 4
RESPONSE TO COMMENTS

Introduction

Chapter 4 describes the process used to analyze, consider, and respond to public comments on the Draft Environmental Impact Statement for the Herger-Feinstein Quincy Library Group Forest Recovery Act (DEIS). Included is a summary of public involvement activities and efforts made to solicit public input, a description of the content analysis and response to comment processes, and the actual comments and responses. Each section of response is preceded by a brief narrative summary expressing public concerns regarding specific topic areas. Public concern statements that represent both general and specific themes in public comment follow this description of the range of concerns. A detailed description of public comment with sample quotes from respondents' letters can be found in the Content Analysis Summary Report in the project file.

Summary of Public Participation Activities
The process of identifying issues, concerns, and opportunities that were analyzed and used to guide development of alternatives in the FEIS are discussed in Chapters 1 and 2 of the FEIS.

On December 21, 1998, the Forest Service published in the Federal Register a Notice of Intent (NOI) to prepare an environmental impact statement to disclose the impacts of a pilot project as described in the Act. In December 1998 and January 1999, potentially interested parties including individual members of the public; interest groups; and Federal, State and local government agencies were contacted and offered opportunities to provide input and comment on the proposal.

By the close of the NOI comment period on January 19, 1999, 185 letters had been received. These letters expressed a range of public concerns and suggestions that were reviewed and analyzed by the Interdisciplinary Team and the Content Analysis Enterprise Team.

News releases announcing the NOI and upcoming public meetings were sent to news agencies throughout northern California, individuals on the Lassen, Plumas, and Tahoe National Forest’s mailing lists, and individuals on mailing lists comprising names and addresses submitted by the public in December 1998. Meetings were held with the Quincy Library Group, local governments, Federal and State agencies, environmental groups, and tribal representatives between January and April 1999. Public information meetings were hosted by the Lassen, Plumas, and Tahoe National Forests at Loyalton, Blairsden, Quincy, Greenville, Oroville, Chico, Burney, and Chester, California between January 4 and 16, 1999. Two scoping workshops were also held in Susanville and Quincy, California on January 16, 1999. Open houses were held in Chico, Susanville, and Quincy, California on February 24 and 25, and May 12, 1999, to review preliminary alternative design for the DEIS. Additionally, several project updates were mailed to participants in March and April.

Workshops and public meeting with interested groups continued throughout the FEIS development process. Following the release of the DEIS, copies of the document were mailed to 650 people. Public information meetings on the DEIS were hosted by the Lassen, Plumas, and Tahoe National Forests at Loyalton, Blairsden, Quincy, Susanville, Greenville, Chico, Burney, Chester, Nevada City, and Sacramento, California between June 23 and July 12, 1999. Two public roundtables were also held in Vallejo and Quincy, California on July 7 and 8, 1999.

Consultations between the Interdisciplinary Team and groups such as the Quincy Library Group, the Sierra Nevada Forest Protection Campaign, and the Plumas Forest Project were held throughout the period leading up to the issuance of an FEIS. Information and guidance meetings were also held during this period with a Steering Committee consisting of representatives from the Pacific Southwest Research Station, the Pacific Southwest Regional Office, and the Forest Supervisors of the Lassen, Plumas, and Tahoe National Forests. Information sharing meetings were also held with the Sierra Nevada Forest Plan Amendment (Sierra Nevada Framework Project) interdisciplinary team.

Summary of Comment Received
The Project Team Leader received over 10,000 letters, telefaxes, and electronic mail messages about the DEIS. The majority of this public comment was comprised of responses resulting from form letter campaigns initiated by several non-governmental organizations and reflective of many divergent views. The remaining public comment largely consisted of detailed responses to technical and other information in the DEIS and attached appendices. The majority of the latter type of response was received from the public within the service area of the Lassen, Plumas, and Tahoe National Forests.

The use of public comments should not be construed as a vote-counting process. The National Environmental Policy Act requires Federal agencies to consider all public input. The content of each response is evaluated relative to legal and technical guidance offered in relevant environmental law and regulation, and with regard to the interdisciplinary team's professional judgment.

As described in the Council on Environmental Quality’s implementing regulations for the National Environmental Policy Act at 40 Code of Federal Regulations (CFR) 1503 through 1504, public input about the DEIS was treated in the following ways:

Content Analysis Process
Public comments on the DEIS were documented and analyzed using a process called "content analysis." Content analysis is a systematic method of compiling, categorizing, and capturing the full range of public viewpoints and concerns about the DEIS. Information from public and employee meetings, letters, electronic mail messages, telefaxes, and other sources are included in this analysis. Content analysis is intended to help the Responsible Officials and the Interdisciplinary Team clarify, adjust, or make use of technical information submitted by the public.

Through the content analysis process, each piece of correspondence was given a unique identifier number to allow analysts to link specific comments to original letters. All respondents’ names and addresses were entered into a database program enabling creation of a complete mailing list of all respondents. This database was also used to track pertinent demographic information such as special interest group input and Federal, State, County, and local government responses.

All input was considered and reviewed, in most cases by two analysts. Each comment was read by an analyst, sorted into concerns and themes, and then entered verbatim into the database. In preparing the final summary analysis, public statements were reviewed again using database printouts. These reports track input and allow analysts to identify a wide range of public concerns and analyze the relationships between them. The final product includes a narrative description of public comment by topic, a list of public concerns and supporting sample quotes. Public concerns identified during content analysis are used as a starting point in organizing and developing the response to comment.

This process and the resulting summary are not intended to replace comments in their original form. Rather, they provide a map to the letters and other input on file at the Plumas National Forest Supervisor's Office in Quincy, California. The Interdisciplinary Team and some members of the public were encouraged to and did review actual letters firsthand.

It is important for the public and Interdisciplinary Team members to understand that the content analysis process does not attempt to treat comments as votes. In no way do the results of content analysis attempt to sway decision makers towards the will of any identifiable majority. There are many reasons for this, the primary one being a desire to revise the proposal in a way that protects the land and serves all people -- not just some. Content analysis ensures that every comment is considered at some point in the decision process.

Purpose and Need
Ecosystem protection and restoration are goals most respondents believe the selected alternative in the Record of Decision should achieve. Where people disagree is on relative levels of protection and restoration, as balanced against extractive uses of Federal lands and the role these lands play in the economies and quality of local communities.

Those who favor ecosystem protection and restoration with an emphasis on limited resource extraction and a generally passive approach to management cite several desired outcomes: (a) viable wildlife habitat, (b) water quality protection, (c) improved forest health, and (d) benefits for future generations. Alternately, proponents of a strong role for resource extraction activities and more active management of ecosystem conditions believe timber harvest can be used to improve the condition of the land and meet the needs of local communities. In light of this, one respondent asks the Forest Service to consider the compatibility of the Act with the Forest Service mission, suggesting that it will be difficult for the Forest Service to implement an alternative that meets both the intent of the Act and guidance set forth in the agency mission.

The ability of the Forest Service to produce a viable alternative within the constraints presented by the Act and environmental laws, such as the Endangered Species Act and the National Forest Management Act, is a source of conflict for many. While many people urge the Forest Service to implement Alternative 2 as the only course of action they believe will allow compliance with the Act, many others assert that only Alternative 5 will allow the agency to implement any of the objectives of the Act and remain in compliance with environmental laws.

Public Concern: The purpose and need statement for the pilot project should specify the underlying purpose and need for action.

The purpose and need statement for the pilot project was rewritten for the FEIS. It was decided that only a basic statement of the requirements specifically prescribed by the Act would be included. The "underlying issues" were not specifically addressed, but can be inferred by the statement made.

Public Concern: The DEIS should be withdrawn and amended to meet the requirements of the environmental laws which take precedence over it.

Existing laws, regulations, and policies were considered carefully in each of the Alternatives. The Act specifically states that activities generated from the analysis will comply with existing statutes. If there are conflicts, they will be fully disclosed in the Record of Decision.

Public Concern: The Forest Service should make ecosystem protection and restoration the highest priority on National Forest System lands.

Public Concern: The Forest Service should continue to allow multiple uses of National Forest System lands.

The Forest Service draws its authority for land management from several Congressional Acts including the Organic Act, the Multiple Use Sustained Yield Act, and the National Forest Management Act. In each of these statutes, the Forest Service is constrained or directed to provide opportunities for multiple uses and multiple benefits for the American people from the national forests. This concept is central to the agency's mission and continues to guide our management of these lands.

Public Concern: The Forest Service should address the compatibility of the Act with the Forest Service mission.

The Forest Service mission serves as a guide for all of the agency's actions. The Act expresses the will of the legislative branch of the Government. As mandated, the Forest Service will carry out the intent of the Act; however, this mandate in no way relieves the Forest Service from its objective of "Caring for the Land and Serving the People." The FEIS and Record of Decision will reflect the agency's best effort to meet the intent of law within the parameters of our mission.

Public Concern: To demonstrate that ecosystem health can be compatible with public use, the Forest Service should implement the pilot project as mandated.

The objectives of the Act are clear and the Forest Service must implement these objectives as mandated. The FEIS represents the first step in that process. The Act requires the Forest Service to monitor the effects of implementation on the health of ecosystems and local communities. Inasmuch as this relationship between ecosystem health and public use can be meaningfully measured, the Forest Service will gather appropriate information as identified in the FEIS. The general agency view, as expressed in our mission statement, as well as the legal framework that guides our management, is that ecosystem health can and is compatible with public use. The FEIS represents the Forest Service's best effort to meet the intent of the Act within the parameters of our mission. It includes analysis of varying levels of resource outputs contrasted against the level of protection of natural amenities and ecosystem health provided by each alternative.

Proposed Action
It is extremely important that this pilot project prove that ecosystem health can be compatible with human use, asserts one respondent. Several people believe that the pilot project presents a unique opportunity to create a "new method of forest management" -- a method sensitive to both the environment and local economic concerns. These supporters of the pilot project maintain that management should be implemented as proposed in the Act.

Many other respondents, while recognizing the inevitable implementation of the pilot project, offer a range of suggestions for improving approaches to protect ecosystem health. They believe management approaches in the preferred alternatives, especially the proposed level of timber harvest increase, will threaten the ecological integrity of the affected forests. One conservation group urges the Forest Service to implement the pilot project slowly and carefully, "with an eye toward protecting the habitat of this area."

Confusion about the binding nature of the statute appears to influence several people, who encourage the Forest Service to reject the Act altogether. Most of these people are opposed to a plan, which they believe, sacrifices the health of the forests and the interests all the other stakeholders in our national forests, to timber interests.

Many respondents offer specific guidance and suggestions regarding what kinds of action should comprise the proposal, and how and what science should be used to guide implementation. These topics are covered in more detail in later sections.

Public Concern: The Forest Service should implement the pilot project in a way that prioritizes ecosystem health over resource extraction.

Maintaining ecosystem health, a concern identified in the Act, will receive substantial deference in any decisions resulting from the FEIS. The proposed action and alternatives give priority to ecosystem health. Resource extraction is a by-product of the proposed action.

Public Concern: The pilot project should be modified to comply with all environmental laws.

Development of the FEIS for the pilot project was complicated by the fact that the Act requires that compliance with environmental laws. All relevant laws were considered as the FEIS progressed. The Interdisciplinary Team consulted extensively with attorneys from the Department of Agriculture, Office of the General Counsel to ensure compliance was appropriate. The FEIS analyzed alternatives to the proposed action. The selected alternative complies with environmental laws. Therefore, the Forest Service disagrees that the FEIS needs modification to comply with this aspect of the Act.

Public Concern: The Forest Service should not implement the pilot project.

On October 21, 1998, the President of the United States signed the Department of the Interior and Related Agencies Appropriations Act, including Section 401, "The Herger-Feinstein Quincy Library Group Forest Recovery Act." The Act states that the Secretary of Agriculture, acting through the Forest Service and after completion of an environmental impact statement, shall conduct a pilot project on Federal lands within the Lassen and Plumas National Forests and the Sierraville Ranger District of the Tahoe National Forest to demonstrate the effectiveness of specific resource management activities, including a strategic system of fuelbreaks, group selection, and individual tree selection, and avoidance or protection of specified areas. Additionally, the Forest Service is to develop a program for riparian restoration.

The Act states that the environmental impact statement and associated Record of Decision are to be completed by in 300 days (ending August 17, 1999). The Act also states that the pilot project will be conducted for a period not to exceed 5 years or until an amendment or revision of the of the Land and Resource Management Plans for the Lassen, Plumas, and Tahoe National Forests (Forest Plans) is completed, and that such amendment or revision will include analysis of an alternative that generally models the pilot project area and resource management activities. The Act states that the California Spotted Owl Sierran Provence Interim Guidelines will be used until other guidelines are subsequently issued.

Public Concern: Implementation of the pilot project should specify the maximum treatment area and distribute this area fairly among national forests and counties.

The selected alternative will identify the strategy and extent to which management activities will be implemented. Other factors, such as annual budgets and site-specific conditions will influence how much resource management activity is implemented in a given year.

Public Concern: The FEIS should specify acreage impacted by alternatives according to land classifications.

Under all alternatives, projects would occur on lands available under the current Forest Plan allocations. None of the alternatives include amendments that change Forest Plan land allocations or reclassify lands as specifically identified for vegetative management activities such as timber harvest or fuel reduction. This information is readily available in the Forest Plans. Numerous sections of the FEIS discuss the number of acres estimated for treatment under the proposed action and each of the alternatives.

Public Concern: The FEIS should describe the location, character, and extent of land disturbing activities planned under each alternative.

The FEIS represents a programmatic (strategic), rather than a site-specific analysis. It does not describe specific locations, character, or extent of resource management activities. The Act specifies certain management activities – construction of fuelbreaks, timber harvest using the uneven-age silvicultural systems known as group selection and individual tree harvest selection, and the establishment of a riparian restoration program. The defensible fuel profile zone and area fuel treatments were strategically located on the landbase, but the specific locations and characters of features will be described in future site-specific analyses. Group selection and individual tree selection harvest treatment areas will be located based on site-specific needs and conditions. The fuelbreaks are the basis for determining site-specific work locations, with other resource management activities often being connected actions to fuel reduction work.

Public Concern: Alternatives in the FEIS should defer resource management activities in spotted owl habitat areas, protected activity centers, and deferred and offbase areas as specified by Congress.

The Congressional Record includes Congressional discussions and Committee language regarding the drafting of the Act. Committee language indicates that resource management activities are excluded from specific areas. This intent is specified in the Act. The proposed action, Alternative 2, also reflects Congressional intent by excluding resource management activities to areas outside protected activity centers, spotted owl habitat areas, and deferred, and offbase areas. Alternative 2 also excludes resource management activities from late successional old growth (ranks 4 and 5) as specified in the Act. Regional Forester direction to Forest Supervisors regarding California spotted owl protection in a May 1, 1998, is included as part of Alternative 2. These exclusions affect the analysis and comparison of alternatives because they limit the area available where resource management activities may take place.

Public Concern: The FEIS should recognize that the proposed action is a significant amendment of the Lassen, Plumas, and Tahoe Forest plans.

The determination of amendment significance, under the National Forest Management Act, is made in the Record of Decision. The significance determination is based on four factors, as described in the Forest Service Handbook 1909.12, 5.32. The four factors are: (a) timing, (b) location and size, (c) goals, objectives, and outputs, and (d) management prescription. The Record of Decision will contain a discussion of each of these factors and a determination of amendment significance.

Public Concern: The Forest Service should use the best available science in implementing the Pilot Project.

The Interdisciplinary Team used the best available, peer-reviewed science in preparing the FEIS. The bibliography for documents their reference base for making professional judgments. In addition, there was much communication and coordination with team members of the ongoing Sierra Forest Framework for Conservation and Coordination as well as members of the Research Branch of the Forest Service.

Public Concern: The Forest Service should incorporate the findings of the Sierra Nevada Ecosystem Project Report into the pilot project.

Many parts of the Sierra Nevada Ecosystem Project Report contained information relevant to the decision being made in this FEIS. They were used, cited, and referenced in the body of the FEIS.

Public Concern: The FEIS should include analysis of a no action alternative in keeping with the letter and intent of the National Environmental Policy Act and the Council on Environmental Quality regulations, and the Forest Service's Environmental Policy and Procedures Handbook.

Alternative 1 is the no action alternative required by the National Environmental Policy Act and its implementing regulations at 40 CFR 1501 through 1508. Alternative 1 reflects ongoing management that has already undergone decision making and disclosure in accordance with the processes and procedures required by the National Forest Management Act and National Environmental Policy Act.

Public Involvement and Collaboration
Although many people commenting on the DEIS are concerned that pending site-specific decisions will be unduly influenced by special interest groups, they do not agree about which groups present the greatest threat to fair process. "Please do not bow to the vocal extremists of the Sierra Club," exhorts one respondent. Many people fear the efforts of the environmental interests to "prohibit the removal of any trees from our national forests" will thwart local community efforts to plan for ecological and social needs. In contrast, others perceive any local planning effort in itself as problematic and biased. Voicing a shared opinion, one person states, "The national forests should not be controlled by local collaborators. They belong to everyone in the nation." The result of favoring local planning over broad-scale decision making, asserts one respondent, will be a lack of attention to ecosystem management principles and a "detrimental mosaic of management practices." The timber industry, the third special interest group to draw public ire, has also exerted undue influence over the process, some believe. These people question the integrity of the pilot project and believe it is the result of closed-door politics favoring industry interests.

Moving beyond polarized positions, several people suggest constructive measures for broadening the effectiveness of the public involvement process. The Forest Service should make a good faith effort to collaborate with the Quincy Library Group on project design and implementation, some respondents advise. One person asserts that such collaboration will lead to decisions that respect the land’s holding capacity and meet local needs. Public participation efforts should also draw in people who live outside the planning area, some say, because "taxpayers from across the country will be paying for implementation of the pilot project, and yet the vast majority of the populace receive no benefits compared to citizens living in local communities." Consequently, the FEIS process should expand its outreach, information, and participation processes to include the broader regional and national publics, this person maintains. Other respondents suggest strategies for integrating people with technical expertise into the planning process; they think professional foresters and field staff should be involved on both the decision making and the implementation levels.

The comment period for the DEIS was too short, many people say. An extension of 30 to 60 days, they assert, would facilitate full participation by people outside the planning area, especially those who had no input into the passage of the Act. For a few, this extension is a required element if the FEIS is to remain in compliance with National Environmental Policy Act process. They argue that the alternatives presented in the DEIS constitute significant amendments of Lassen, Plumas, and Tahoe Forest Plans. As such, they assert, a longer time for public comment is required. In contrast, some people believe that waiting to implement a management plan will compound problems and increase fire safety risks. The comment period should not be extended, they assert.

Public Concern: The Forest Service should not allow project decisions to be swayed by special interest groups.

The Forest Supervisors of the Lassen, Plumas, and Tahoe National Forests will select an alternative or combination of alternatives based on analysis in the FEIS. The decision will reflect and balance the objectives of the Act, guidance from the Forest Plans, and concerns from the public.

Public Concern: The Forest Service should collaborate with the Quincy Library Group and other public groups on project design, priority, and implementation.

As required by the National Environmental Policy Act, the Forest Service will seek public response and comment on site-specific analyses and decisions derived from the Record of Decision for this FEIS, including site-specific design, resource management activity priority, and location. This FEIS represents the first step in implementing the Act. While it establishes a programmatic (strategic) framework for implementation, it does not provide sufficient detail from which to meet the intent of the National Environmental Policy Act requirements for site-specificity in review of direct, indirect, or cumulative effects. Site-specific decisions that derive from the Record of Decision for this FEIS will be subject to additional public participation and review. As required by the National Environmental Policy Act, the Quincy Library Group, other interest groups, and the public will receive opportunities to participate in site-specific analysis and implementation.

Public Concern: Local communities should have input in Federal land management.

The National Environmental Policy Act ensures that citizens nationwide have an opportunity to participate in decision making for public resources, including the lands and resources administered by the Forest Service. Local, regional, and national concerns were used to shape alternatives in the FEIS. Federal land managers, by law, are responsible for making decisions about the management of public lands and are held accountable to do so. Balancing ecological and social needs will continue to be the most challenging land management dilemma on public lands.

Public Concern: The Interdisciplinary Team should seek public input from people residing outside the project area.

Public notification included the Federal Register, many regional media outlets, an Internet website, and a mailing list of nearly 7,000. Members of the Interdisciplinary Team and the Project Manager responded to requests for meetings, including several held throughout the region. Over 10,000 comments were received from individuals and organizations from across the country. Refer to the planning file for a list of names and addresses of contributors to this process.

Public Concern: The Forest Service should involve field staff and professional foresters in the FEIS design process.

Chapter 7 – List of Preparers, contains biographical sketches, including education and experience, for the resource professional who developed this FEIS. Professionals resource managers and field staff, including many natural and social science disciplines, representing the Lassen, Plumas, and Tahoe National Forests, and other Forest Service organizations, were members of the Core Interdisciplinary Team and extended the Interdisciplinary Teams.

Public Concern: The Forest Service should extend the comment period for the DEIS.

The National Environmental Policy Act directs that agency officials allow a minimum of 45 days for comments on an environmental impact statement prepared by Federal agencies that have a formally established appeal processes, unless a different time period is required by law or regulation (40 CFR 1506.10). The review period for this document complies with this requirement.

Public Concern: The National Environmental Policy Act process and the Record of Decision date should be extended.

The Act mandates that the environmental analysis and Record of Decision be completed in 300 days. The 300 days ends on August 17, 1999. It is not within the purview of the Forest Service or the Secretary of Agriculture to exceed the time limit imposed by the Congress through the Act.

Public Concern: The Forest Service should ensure that public concerns are adequately addressed and summarized in the FEIS.

In addition to this summary, the planning file contains a full analysis of public concerns.

Other National Environmental Policy Act Analyses and Processes that Influence the Scope of FEIS
"I don’t see how this ‘recovery act’ proposal can be melded with the existing planning being done with the Sierra Nevada framework study. Which is the tail? Which is the dog?" These questions from one respondent represent a general public concern with the nature of the relationship between the pilot project and the Sierra Nevada Forest Plan Amendment process. Many people would like to see the Forest Service delay implementation of the pilot project until a Sierra Nevada rangewide forest planning process is complete. They believe any other action would disregard the importance of the Sierra Nevada Framework Project process and ultimately result in poor decision making. "It makes no sense to have two parallel processes for Sierra Nevada forests under way simultaneously without careful coordination between them," one respondent asserts. Many people believe that any proposal should incorporate pending Sierra Nevada Framework Project findings which identify methods to assure viability of various forest types and wildlife species.

Extending their concerns to the implementation phase, several people contend that the pilot project should defer to the Sierra Nevada Framework Project process at all levels, with the FEIS serving as a supplement to the upcoming regional amendment.

Espousing a conflicting opinion, other respondents claim direction contained in the Sierra Nevada Conservation Framework Project environmental analysis for the Lassen, Plumas, and Tahoe National Forests should defer to this FEIS. Another respondent insists the Sierra Nevada Framework Project environmental analysis and resulting amendments must not be allowed to diminish or interfere with the intended benefits or term of the pilot project. The pilot project and Sierra Nevada Framework Project should be analyzed in separate environmental analysis documents, these people recommend, to maintain the distinction between the two processes.

Public Concern: The Forest Service should assess how the pilot project will relate to the Sierra Nevada Framework Project forest plan amendment process.

The Act states that the Secretary of Agriculture, acting through the Forest Service and after completion of an environmental impact statement, shall conduct a pilot project on Federal lands within the Lassen, Plumas, and Sierraville District of the Tahoe National Forests to demonstrate the effectiveness of specific resource management activities including strategic system of fuelbreaks, group selection, and individual tree selection, and avoidance or protection of specified areas. Additionally, the Forest Service is to develop a program for riparian restoration.

The Act states that the environmental impact statement and Record of Decision are to be completed in 300 days (ending August 17, 1999). The Act also states that the pilot project will be conducted for 5 years or until an amendment or revision of the of the land and resource management plans for the Lassen, Plumas, and Tahoe National Forests is completed. Plan amendment processes will include analysis of an alternative that generally models pilot project area and resource management activities.

The Responsible Officials for the FEIS are the three Forest Supervisors for the Lassen, Plumas, and the Tahoe National Forests. The Pacific Southwest Regional Forester is the Responsible Official for the Sierra Nevada Framework Project. Because the Responsible Officials for the two environmental analyses differ, they must be analyzed separately.

Public Concern: The Record of Decision should apply the Aquatic Conservation Strategy approved in the Sierra Nevada Framework Project amendment Record of Decision to the pilot project area for the pilot period.

The Sierra Nevada Framework Project has not yet published a Draft Environmental Impact Statement. No Record of Decision for that environmental analysis exists, therefore, this FEIS is unable to fulfill this request.

Public Concern: The FEIS should include a description of alternatives developed for the Sierra Nevada Framework Project forest plan amendment environmental impact statement.

The Sierra Nevada Framework Project has received wide exposure in communities throughout northern California. In addition, the project has received national media exposure and provides public information through an extensive Internet site. Chapter 1of the FEIS briefly describes the relationship between these two environmental analyses, but conforms to direction in the National Environmental Policy Act regulations at 40 CFR 1502.1 to keep environmental impact statements concise, not encyclopedic.

Relationship to Other Environmental and Resource Protection Laws and Executive Orders
Public comment concerning pilot project compliance with Federal environmental legislation suggests that compliance with the Act may preclude compliance with other relevant policies. Respondents cite the National Forest Management Act and the National Environmental Protection Act as two laws, among others, which they believe, would be violated by implementation of the Act. One respondent claims the pilot project violates the National Environmental Policy Act specifically because it prescribes increased timber harvest levels.

Several respondents believe the Forest Service should honor Congressional intent in passing the Act by choosing an alternative that mirrors the management practices outlined in the legislation. While Congress may have passed the legislation, others assert, the Act is the result of a flawed process. These people appear to be asking the Forest Service to right the wrongs created by a system, which they believe, allows controversial legislation to become law without appropriate public comment or debate. A few people oppose pilot project implementation on the grounds that it will instigate costly, time-consuming litigation without providing any benefits to communities and forests.

Public Concern: The Forest Service should follow national environmental protection laws in implementing the pilot project.

The Act requires the Forest Service to conduct the pilot project in conformance with environmental laws. The FEIS provides a brief discussion of the most important laws and regulations guiding this FEIS.

Public Concern: The FEIS should include a civil rights impact analysis.

A Civil Rights Impact Analysis is discussed in Chapter 3 and disclosed in the Appendix O of the FEIS.

Public Concern: The Forest Service should choose an alternative that meets the intent of Congress for the Act.

The Record of Decision for this FEIS will include the rationale for the selected alternative and the reasons that for not selecting the other alternatives.

Public Concern: The FEIS should disclose road decommissioning commitments under Action Item #20 of the Clean Water Action Plan.

The effect of the Clean Water Action Plan on road decommissioning has been added to Chapter 3 of the FEIS in the "Affected Environment" section under "Roads." The Clean Water Action Plan is also discussed briefly under the "Water Quality" portion of that same section. Only current year targets are known, while out-year targets are still to be determined (personal communication with John Rector, USFS Regional Watershed Resource Management, July 19, 1999).

Alternatives Including the Proposed Action
Alternative 2, many people believe represents a viable new approach to forest management and is the most desirable alternative presented in the DEIS. Some call for immediate adoption of Alternative 2 to meet the obligations of the Congressionally mandated Act. This alternative, described by some as "utilitarian," best serves the needs of communities and the environment. Respondents cite several projected benefits under implementation of Alternative 2: fire prevention and safety, job creation, school funding, economic stability, improved water quality, recreational access, and, wildlife habitat restoration. "The selection of any other alternative would fracture the consensus that has developed the Quincy Library Group Plan, and that was embraced by Congress as an appropriate action to encourage local participation with the management of our national resources," comments one individual.

While several people offer qualified support for Alternative 4, the second preferred alternative, many other respondents are dissatisfied with both Alternatives 2 and 4. One person feels that the Forest Service is asking the public to ``choose between the lesser of two evils.'' The preferred alternatives are incompatible with the Forest Service mission and inconsistent with good forest management practices, people assert. Several respondents criticize the preferred alternatives for failing to include recent scientific findings and, ultimately, for failing to provide adequate environmental protection. Acknowledging a need to balance economic and social interests with forest and ecosystem protection, some maintain the preferred alternatives inappropriately favor natural resource extraction.

Many who feel that the preferred alternatives will not provide adequate environmental protection enthusiastically endorse Alternative 5. "Alternative 5 is the only plan that implements the new direction for the Forest Service charted by its Chief, Mike Dombeck," proclaims one individual. Alternative 5 pleases many other people because it incorporates science recommendations based on Sierra Nevada Ecosystem Project research -- content that many feel is not a part of the other alternatives. Some respondents go beyond Alternative 5 endorsement to ask that the Forest Service strengthen Alternative 5 by reducing allowable timber harvest levels, increasing wildlife and riparian area protection, and preserving old growth forests and roadless areas. Implementation of Alternative 5 should also mandate impact analysis in relation to the Sierra Nevada Framework forest plan amendment process, one person suggests.

"The Forest Service has an affirmative obligation to fully consider alternatives to the proposed action advanced in the Quincy pilot project legislation, and furthermore to select the alternative which best meets project purpose and need and furthers the goals and policies of the National Environmental Policy Act,'' claims the Environmental Protection Agency. Many other people concur with this opinion and hold that the Forest Service should broaden the range of alternatives to incorporate accurate scientific information, include viable citizen alternatives, and comply with environmental legislation.

Several respondents offer specific proposals for new alternatives addressed in responses below and in later sections.

Public Concern: The Forest Service should select the most appropriate alternative.

The Act requires that the Forest Service complete an environmental impact statement evaluating the effects of implementing the resource management activities specified in the Act. The Act also requires that the Forest Service follow all environmental laws, including the National Environmental Policy Act. The decision makers will select an alternative based on the analysis in the FEIS. The decision will meet environmental laws and reflect and balance the objectives of the Act, guidance from the Forest Plans, and the concerns of the public.

Public Concern: The Forest Service should fully consider the range of alternatives and select the alternative which best meets the project's purpose and need, is based on existing science, and complies with environmental laws.

The Forest Service has considered and analyzed a range of alternatives including three that were either developed in response to public concerns or developed by citizens themselves. The decision reflects and balances the objectives of the Act, guidance from the Forest Plans, the concerns of the public, and environmental laws.

Public Concern: The FEIS should include an alternative which fully implements the Scientific Assessment Team guidelines for riparian protection, as well as considering an alternative based on the Sierra Nevada Ecosystem Project) approach to riparian protection.

Alternative 5 incorporates Sierra Nevada Ecosystem Project guidelines for riparian management. Alternatives 2 through 4 incorporate the riparian buffer system required by the Act, and described in Appendix K of the "Viability Assessments and Management Considerations for Species Associated with Late-Successional and Old-Growth Forests of the Pacific Northwest," a Forest Service research document dated March 1993 and co-authored by the Scientific Analysis Team.

The FEIS considered a "Level I" (Scientific Analysis Team guidelines) watershed analysis for the project area. A more intensive "Level II" analysis would be conducted at the site-specific level (Alternative 2 through 4). Alternative 5 would require a more comprehensive watershed analysis before management activities would occur inside the riparian buffer area.

The only evaluation in the FEIS of Sierra Nevada Ecosystem Project and Scientific Analysis Team aquatic/riparian strategies is to compare them against the current strategy in the Forest Plans, known as streamside management zones. To this end, we have subjectively determined that both are an improvement. No analysis or determination of their worthiness relative to each other or to the protection they are supposed to be provide is made. Further, the Act specifically says that the Forest Service is to apply Scientific Analysis Team guidelines to those management activities specifically mentioned in the Act in the area of the pilot project only for the term of the project. In the remainder of the planning area, Forest Plan streamside management zone requirements will remain in effect.

Public Concern: The FEIS should include an alternative that incorporates map-based emphasis areas and standards and guidelines discussed in the Sierra Nevada Framework forest plan amendment process(Alternatives 5 and 6).

A full array of alternatives was developed for this FEIS. Alternative 5 analyzes a conservation strategy. The major issues were considered and addressed through one or more of the alternatives developed for this FEIS.

Public Concern: The FEIS should incorporate the Plumas Forest Project’s preferred alternative cutting prescription.

Vegetation prescription language pertaining to desired stand structure for defensible fuel profile zones and the balance of the pilot project area have been incorporated into Chapter 2 of the FEIS. Alternatives differ in the type of cutting prescriptions that are allowed. For example, alternatives 1, 2, and 5 call for adherence to interim California spotted owl guidelines when conducting vegetation management in California spotted owl vegetation types. Alternatives 3 and 4, contain vegetation prescription language for suitable California spotted owl habitat that is more restrictive than the interim direction and may resemble the alternative cutting prescription used by Plumas Forest Project. Vegetation types that are not specifically addressed by the interim direction for protection of the California spotted owl or language contained in Alternatives 3 and 4, are subject to the standards of guidelines of the Forest Plans.

The Forest Plans allow for a full range of silvicultural practices to meet management objectives. These practices must be consistent with the interim direction for protection of California spotted owls and with the Record of Decision for this FEIS. The actual prescription selected depends on the site-specific analysis that considers various resource needs such as wildfire hazard, wildlife habitat, and forest health.

Public Concern: The FEIS should identify an alternative that implements adaptive management.

Alternatives 2 through 5 include a monitoring strategy that over time should result in information that can be used to improve and refine management. Programmatic (strategic) management direction, such as the direction provided by this FEIS, is often modified by research or site-specific needs. Currently a number of monitoring efforts are ongoing which may influence future management decisions.

Public Concern: The Forest Service should include citizen alternatives in the FEIS.

Alternative 5 in the FEIS was submitted by a citizen coalition.

Public Concern: The FEIS should include evaluation of alternatives with respect to their relative effectiveness in suppressing fire.

Effectiveness of fire suppression was analyzed by fire management personnel from the Lassen, Plumas, and Tahoe National Forests based on their past experience on fires within the planning area and elsewhere. The conclusions are documented in Chapter 3.

Funding for Implementation
New management strategies are only effective, some people warn, if there is available funding for their implementation and maintenance. If these new management prescriptions are implemented, some question whether current project funding will be jeopardized. Some respondents caution decision makers to look at long-term funding forecasts and have alternative strategies if the proposed levels of funding are not appropriated for the project. Building on this sentiment, others add that planning models should be developed to assess how project goals, strategies, and guidelines will perform with varying funding amounts. Some individuals responding to the draft also ask for an analysis of funding programs to see where opportunities lie to better finance the plan so that goals of the project and environmental compliance are achieved.

Public Concern: The Forest Service should address how proposed activities in the FEIS and the affected communities will be funded.

This public concern is beyond the scope of the FEIS. Funding is addressed in the Act. The Act discusses funding sources which are Congressional appropriations, either specifically for projects developed from this FEIS (known as earmarks) or other appropriated funds (Forest Service baseline or carryover). The Act does not authorize any appropriations to implement the Act’s requirements. Congressional Resources Committee language recognizes that implementation of the pilot project would be contingent on additional appropriations. Chapter 3 of the FEIS, displays the anticipated costs and revenues associated with the vegetation management activities for each alternative, and the total costs and resulting economic activities for implementing the full range of activities for each alternative.

Public Concern: The FEIS should adequately consider the costs associated with each of the alternatives.

Chapter 3 of the FEIS, displays the anticipated costs and revenues associated with the vegetation management activities for each alternative, and the total costs and resulting economic activities for implementing the full range of activities for each alternative. Supplemental funding would likely be needed to fully implement the selected alternative as described in the Record of Decision

Public Concern: The Forest Service should evaluate how implementing the pilot project would be affected by the current budget and a range of future potential budget allocations.

Implementation of the alternatives was modeled at full funding levels to facilitate a comparison of effects between alternatives. For any given year, the Forest Service will submit budget requests to implement the full pilot project program. Congressional appropriations during the pilot period may or may not meet the budget requirements for the pilot project. In these situations, the Forest Supervisors will change proposed programs to reflect differences between submitted budgets and actual appropriations.

Affected Environment and Environmental Consequences

Climate
Forest management decisions must be made in the context of a changing global climate, several individuals believe. Rather than simply focusing on pre-settlement forest conditions as a management guide, one person suggests the FEIS should address the role of current climatic conditions in forest management practices. Others assert forest restoration is desperately needed to help offset what they describe as "global warming." Restoring forest ecosystems, one person contends, "will help curtail some of the global warming which has been taking place over the last several decades."

Public Concern: The FEIS should account for current climatic conditions.

This is a topic of great interest to all those who manage large land areas. It affects soil, vegetation, water, wildlife, and the processes that drive them; including floods, droughts, and wildfires. The latest science dealing with climatic changes and changed weather patterns is used as much as possible, but climatic shifts are slow, usually on a minimum 30-year time scale, well beyond the scope of this FEIS.

Public Concern: The Forest Service should restore areas damaged by extractive industries to help slow global warming.

This public concern is beyond the scope of this FEIS. Restoration of the ecosystems over large landscapes may influence local weather patterns, but on the smaller watershed scale, ecosystem restoration is likely to have only localized effects. Ecosystem restoration will take decades or centuries to show effects over large scales, as well as on some elements of the smaller, site-specific ecosystem scales, such as soils.

Physical Environment

Watershed
Although people generally agree that watershed protection is a laudable goal, they offer varying prescriptions for its realization. Citing that the Sierra Nevada forests supply 60 percent of the State of California's water, many believe methods should be employed to maintain forest health resulting in improved moisture retention. Some people contend that Alternative 2 in the DEIS will provide improved water quality, while others assert that Alternative 5 is a better choice for watershed protection because they believe it is less focused on timber production.

Many respondents want the Forest Service to recognize the important ecological role of forests in watershed protection. Specifically, one person reasons that the water holding capacity of mature trees necessitates their protection. Retaining trees, especially old growth, this individual contends, is the best flood protection and insurance we have for healthy forests in the future. The value of water and forests’ role in maintaining water quality should not only be considered in planning, but also quantified in an economic sense, according to one respondent. Claiming that the commodity value of water exceeds that of timber, this person believes forest recovery budgets should reflect this economic water value. Others are concerned with the construction of dams on national forest waterways and ask that waterways and riparian environments be protected from this form of disturbance.

Public Concern: The Forest Service should ensure that the pilot project will protect water quality.

Water quality is of primary concern to the Forest Service and must be dealt with in all projects. Best Management Practices for the Management of Water Quality on National Forests in California is an outgrowth of the Clean Water Act and the interaction of the Forest Service with the California Water Quality Control Board. We must not only apply these practices on each project, we must monitor their use and effectiveness and then report our findings annually to the State. This FEIS deals with the subject in the "Affected Environment" section under the "Water Quality" section, and throughout the "Environmental Consequences" section when discussing impacts to soil, water, and the aquatic/riparian ecosystems. It is also discussed as an issue with roads. Specific water quality issues and mitigation will be dealt with at the site-specific project level.

Public Concern: The FEIS should adequately assess the cumulative effects of alternatives on watershed condition.

The specific prescription for each alternative was modeled using a multi-scale and hierarchical approach, similar to the modeling used for the Sierra Nevada Framework Project. Inputs and assumptions were applied to the model to derive projected outputs, such as timber outputs and costs. A cumulative effects analysis is included, where past and projected amounts and intensities of management activities are used to develop watershed effects in terms of equivalent roaded acres. The equivalent roaded acres impact outputs of each alternative are weighed with their respective positive benefits against Alternative 1, the reference condition, in Chapter 3 under the "Environmental Consequences" section for soil and water.

Public Concern: The FEIS should identify and protect key watersheds and riparian areas.

The only watersheds that have been designated and meet the definition for "key watersheds" are those on the Lassen National Forest where an anadromous fishery exists. Key watersheds are a set of watersheds thought to be important for aquatic species, primarily fish. The network of key watersheds has already been established in the area affected by the Scientific Analysis Team guidelines and by FEMAT for areas affected by the northern spotted owl. It should be noted that the Act specifically designated lands to be offbase or deferred for the term of the pilot project. These offbase and deferred lands include the designated key watersheds and other lands thought to be important for preserving late successional old growth areas and important riparian corridors, such as along the Middle Fork Feather River. Also included are all California spotted owl habitat areas and protected activity centers (Committee Report, November 4, 1997, Calendar No. 257, Quincy Library Group forest Recovery and Economic Stability Act of 1997, Report 105-138, page 8). Much of this offbase and deferred land forms a contiguous network of interconnecting areas perceived as important wildlife migration corridors and aquatic preservation areas.

Public Concern: The FEIS should include a description of and rationale for the new methodology used to assess watershed sensitivity to land disturbance.

The methodology used to analyze watershed sensitivity follows the Pacific Southwest Region requirements described in Forest Service Handbook 2509.22 Soil and Water Conservation Handbook Chapter 20 Cumulative Off-site Watershed Effects Analysis. Known information was compiled and evaluated and significant factors identified. Numerical ratings were applied. Further, the information was not intended to be used to evaluate the differences among the alternatives, but rather to aid in the development of the alternatives. A separate analysis was employed whereby equivalent roaded Acres were used to weigh the differences among the alternatives (EIS Chapter 3, Affected Environment and Environmental Consequences). In addition, a cumulative watershed effects analysis will be conducted during site-specific planning, as required by the National Environmental Policy Act, for all projects except for a few watersheds on the Lassen National Forest not prone to cumulative effects of the physical environment due to their geology and topographic setting.

This type of analysis was specifically designed to meet the needs of the FEIS and its objectives.

The Watershed Sensitivity and Condition Analysis for the Herger-Feinstein Quincy Library Group Forest Recovery Act Project Area, dated April 9, 1999, and displayed in Appendix N, was initially developed to provide input into an optimization model where both positive and negative outputs of implementing the Act could be analyzed into an optimum set of alternative outputs. (See Sessions, J., K.N. Johnson, and D. Sapsis, 1996, Addendum to the Sierra Nevada Ecosystem Project Report, pages 115-174, for a discussion of the application of this type of analysis). The "Tolerable Equivalent Roaded Acre Increase" developed from this analysis was to be used to help set limits on the optimization model outputs during its modeling runs. Outputs from the watershed sensitivity and condition analysis are further used in the development of a riparian restoration strategy and to help guide strategically placed fuelbreaks, both at the site-specific analysis level.

As stated in Forest Service Handbook 2509.22, section 22.11, "Indicators of cumulative watershed effects vary, depending upon watershed characteristics, climatic regime and water-related values of concern." The parameters described and evaluated in the sensitivity and condition analysis for this FEIS were chosen and evaluated by all of the hydrologists and soil scientists who work on the Lassen, Plumas, and Tahoe National Forests. Biologists from the Forests were included in reviews of the methodology and results.

A complete copy of the analysis, the factor ratings, and the scoring (using computer-generated sorting) is in the planning file. Results of the final analysis were reviewed and adjusted by resource specialists on each Forest familiar with the watersheds in their area of responsibility. Most of these people have worked in the field on the Forests for over 15 years and bring a knowledge of watershed sensitivity, condition, and processes most important to each watershed that is not available in any database.

Public Concern: The FEIS should require comprehensive watershed assessments and stream surveys to ensure accurate watershed monitoring.

Alternative 5 addresses this issue through the requirement for a watershed level analysis before site-specific level planning. The FEIS is considered a "Level I" (Scientific Analysis Team guidelines) watershed analysis for the pilot project area, and a more intensive analysis, similar to a "Level II" analysis would be conducted at the site-specific level (Alternative 2 through 4). Alternative 5 would require a more comprehensive watershed analysis before management activities would occur inside the riparian buffer area.

Public Concern: The Forest Service should consider the beneficial role that mature trees play in flood prevention.

The beneficial role of mature trees in preventing flood flows is not considered specifically, but is a part of maintaining soil health, the primary ecosystem element that determines how water flows off the land. The timing of flows, which includes both low flows and flood flows, is reviewed in the "Affected Environment" section under "Physical Environment" under the heading "Amount and Timing of Water Runoff." It is diversely dealt with under "Roads" in this same section, and then throughout the "Environmental Consequences" section as potential changes to surface runoff from soil compaction and roading.

Public Concern: The FEIS should quantify the commodity value of water in land management decisions.

The commodity value of water to downstream users is very important and is being dealt with by analyzing the potential increases in water yields. The Act specifically requires that we report on the changes to water yields. The changes in water yield that might occur as a result of implementing the alternatives has been determined to be non-measurable. Water yields are dealt with in the "Affected Environment" under "Amount and Timing of Water Runoff," and again in the "Environmental Consequences" section under the discussion of each alternative. In addition, the Act attempts to improve forest health, decrease the extent of high-intensity wildfires, and stimulate the local economy through this work.

Public Concern: The Forest Service should prevent the construction of dams on National Forest System waterways.

Even though dams and diversions are mentioned as one of the primary concerns throughout the Sierra Nevada Range in the "Affected Environment" section under "Aquatic, Riparian, and Meadow Ecosystems," it is not carried into the analysis because it is outside the scope of this FEIS. This FEIS is specific to construction of fuelbreaks, small group harvesting, and restoration projects, amending the Forest Plans for these resource management activities only. Dams and diversions are dealt with more specifically in each Forest Plan in the sections dealing with standards and guidelines.

Soils
The effects of logging practices on forest soils are the primary concern for those who offered comments on soils management. Citing adverse impacts of logging ranging from increased erosion to decreased soil productivity, these people strongly believe the FEIS must analyze a variety of potential effects of logging on soils.

Public Concern: The FEIS should consider the impacts of overstory removal on soil conditions and seedling survivorship.

Site-specific analysis will be used to aid in determination of the site-specific location and size of overstory removal areas. During the interdisciplinary team process, the soil scientist and silviculturist evaluate site-specific areas for treatment. Soil conditions such as manageability, plant available moisture, soil depth, and success of regeneration are usually primary concerns at this programmatic (strategic) level of planning and are thoroughly analyzed.

Public Concern: The FEIS should analyze the effects of logging on forest soils.

This analysis evaluates the effects of logging on forest soils. It is dealt with by analyzing equivalent roaded acres as the risk of affecting soil productivity, both directly and cumulatively. The elements of soil productivity include soil erosion, soil cover, soil compaction, soil organic matter and surface organic matter, soil moisture, soil hydrologic function, and soil buffering capacity. Soil and surface organic matter deal with wildfire risk, nutrient cycling, and accelerated erosion. Each alternative in the "Environmental Consequences" section is evaluated against both the positive and negative effects to soil productivity.

Aquatic, Riparian and Wet Meadow Ecosystems
Most respondents who commented on aquatic, riparian, and wet meadow ecosystems are concerned with how these areas should be protected and the scientific basis on which protection measures should be founded. While many agree that riparian protection requirements should be based on the most current scientific recommendations, they differ in which management guidelines should be followed for the pilot project area. Management guidance offered in the California Resources Agency and the US Department of Commerce, National Marine Fisheries Service Report, the Scientific Analysis Team report, and the Sierra Nevada Ecosystem Project report are all referenced by respondents who want them considered by the Interdisciplinary Team. Specifically, some want the Forest Service to evaluate the appropriateness of the Scientific Analysis Team riparian standards for the pilot project area. Wary that the management approach detailed in the DEIS is inconsistent with the Scientific Analysis Team approach, one conservation organization believes the Forest Service should follow the Scientific Analysis Team guidelines and complete a watershed analysis before planning resource management activities. However, others warn that prohibiting management activities while waiting for a watershed analysis will hinder the success of proposed the fuel management activities. Some people recommend following the riparian ecosystem buffering strategy detailed in the Sierra Nevada Ecosystem Project report while implementing the pilot project.

Many people also offer specific management prescriptions for protecting riparian areas. As a starting point for impact analysis in the FEIS, some cite the need for a detailed inventory and evaluation of streams and current riparian area conditions. In cases where watersheds are currently above the threshold of concern, the California Regional Water Quality Control Board suggests the FEIS specify practices and mitigation measures to prevent further degradation of these marginal areas. As an additional protection measure, logging activities should be prohibited within several miles of any water source regardless of land ownership, writes one respondent.

Another source of concern for some people is protection of ephemeral streams. Although several people believe the Interdisciplinary Team should carefully consider the impacts of the pilot project on ephemeral streams and advocate selection of Alternative 5 for its water quality protection emphasis, others question whether interference with these streams truly poses a threat to forest ecological integrity.

Regardless of which specific riparian protection strategies are selected for the pilot project area, several respondents urge the Forest Service to coordinate watershed projects with local watershed authorities and adhere to existing management plans.

Public Concern: The Forest Service should coordinate watershed projects with local watershed authorities and existing management plans.

The Chief of the Forest Service strongly encourages the Forest Service to be involved with partnerships wherever possible. The recently released Clean Water Action Plan that will be in effect during the term of the pilot project is a watershed-based strategy that is most effective where partnerships have been developed. The Forest Service is a very active member of the Feather River and Pine Creek Coordinated Resource Management groups, organizations whose goal is watershed restoration.

Public Concern: Watershed projects proposed in the FEIS should comply with the Lahontan Basin Plan.

The Forest Service agrees with this concern. The basin plans set the standards that are used to compare results of water quality monitoring established to determine the effects of Forest Service projects. These monitoring efforts are a part of the Best Management Practices Evaluation Program to determine how well Forest Service projects meet water quality objectives established by the regional board in which the project was implemented. The Best Management Practices Evaluation Program is a part of each Forest Plan and is included in the monitoring strategy, Chapter 6 of this FEIS.

Public Concern: The Forest Service should follow Scientific Analysis Team guidelines regarding watershed analysis completion prior to resource management activity planning including consideration for activities within riparian buffers prior to completion of watershed analysis.

The Act requires use of the Scientific Analysis Team guidelines. While it is true that the Scientific Analysis Team Report requires that ". . . management activities are essentially prohibited unless the watershed analysis indicates such activity is necessary to accelerate meeting desired ecological conditions" (U.S. Forest Service. "Viability Assessments and Management Considerations for Species Associated with Late-Successional and Old-Growth Forests of the Pacific Northwest, The Report of the Scientific Analysis Team." March 1993, page 281). The intent of the Act was to use the interim widths prescribed in the Report for areas where watershed analyses have not been conducted, and to follow the specific riparian management objectives and standards and guidelines listed in the Report that apply to the management activities required by the Act.

Public Concern: The Forest Service should not prohibit management activity in riparian zones while awaiting watershed analysis.

Alternatives 2, 3, and 4 either meet the Act specifically or the intent of the Act by employing the Scientific Analysis Team guidelines. Alternative 5 employs the riparian management strategies identified in the Sierra Nevada Ecosystem Project report. A subjective evaluation of the level of riparian protection provided under each alternative is made in the "Environmental Consequences" section. All action alternatives allow activity within the riparian buffer zone. A site-specific analysis determines that riparian management objectives would be met.

The adequacy and effectiveness of any riparian protection and management strategy has yet to be scientifically tested. Most are a product of general observations and experience combined with specific research findings, such as that conducted for large woody debris, and logical analysis applying scientific principles. The latest science in much of the Sierra Nevada Ecosystem Project Report is of this type. Monitoring the effectiveness of the different strategies will also help answer some of these questions. The monitoring strategy included as Chapter 6 of this FEIS will help provide some of that information.

Public Concern: The FEIS riparian protection requirements should be based upon the most current scientific recommendations.

The alternatives represent a wide range of riparian protection measures. The Scientific Analysis Team guidelines are a requirement of the Act. The effects are analyzed in Chapter 3 and the appropriate appendices. The FEIS also considered more recent guidelines that were outlined in Sierra Nevada Ecosystem Project. These are included in Alternative 5 of the FEIS.

Public Concern: The FEIS riparian protection requirements should match those proposed by the Scientific Review Panel convened by the California Resources Agency and the National Marine Fisheries Service.

The comment that the findings from the Scientific Review Panel Report appear to address the concerns of the Endangered Species Act salmonid species, and therefore, are sufficient as protection measures on Federal lands can be addressed in a number of ways. First, it is true that the proposed Federal riparian protection standards from the Scientific Analysis Team differ from those recommended by the Scientific Review Panel. The Scientific Review Panel was convened to provide a comprehensive review of the California Forest Practice Rules, with regard to their adequacy for the protection of (certain) salmonid species. As noted in the Report, however, these recommendations apply to a specific geographic area and are not necessarily applicable to other areas.

Second, it has not been determined that the recommendations for riparian protection are sufficient for listed anadromous fish under the Endangered Species Act (communications with V. Campbell, National Marine Fisheries Service). According to the National Marine Fisheries Service, the Scientific Review Panel did not review the California rules from an Endangered Species Act standpoint and National Marine Fisheries Service is just now in the process of doing so (in coordination with the State).

Third, Federal agencies are required to more fully implement their regulations to conserve species, so rules for private land (for Endangered Species Act species) are not apt to apply in the same way to Federal lands because of different standards.

The Forest Service has considered the potential effects of the programmatic pilot projects legislative mandate to analyze the effects of the Scientific Analysis Team riparian protection widths.

Public Concern: The Forest Service should consider a range of riparian buffer zone management techniques.

This public concern was addressed through the development of a range of alternatives. Alternative 1, which represents current direction, analyzed the effects of streamside management zone buffers that provide the least protection. Scientific Analysis Team guidelines as required by the Act were considered for Alternatives 2 through 4. The maximum protection was offered under Alternative 5, which uses the riparian buffer width recommendations from the Sierra Nevada Ecosystem Project.

Public Concern: The Forest Service should not allow logging within a several-mile boundary of any water source, regardless of land ownership.

The Act requires use of the Scientific Analysis Team guidelines. While it is true that the Scientific Analysis Team Report states, ". . . management activities are essentially prohibited unless the watershed analysis indicates such activity is necessary to accelerate meeting desired ecological conditions" (Forest Service. "Viability Assessments and Management Considerations for Species Associated with Late-Successional and Old-Growth Forests of the Pacific Northwest, The Report of the Scientific Analysis Team." March 1993, page 281), the intent of the Act is to use the interim widths prescribed in the Report for areas where watershed analyses have not been conducted, and to follow the specific riparian management objectives and standards and guidelines listed in the Report that apply to the management activities required by the Act.

Public Concern: The Forest Service should evaluate where and when the Scientific Analysis Team riparian standards should apply to the pilot project.

This public concern is outside the scope of this FEIS in that the Act specifically requires ". . . wide protection zones . . . consistent with riparian protection guidelines in . . . the document entitled Viability Assessments and Management Considerations for Species Associated with Late-Successional and Old-Growth Forests of the Pacific Northwest," known as the Scientific Analysis Team guidelines. The actual determination of the appropriateness of the Scientific Analysis Team standards is a research question and beyond the scope of this FEIS. The level of riparian protection given to aquatic/riparian ecosystems is evaluated subjectively under the discussion of each alternative in the "Environmental Consequences" section. In addition, a statement has been added to the description of those alternatives where the Scientific Analysis Team guidelines are to be implemented that clarifies where and when the guidelines are to be used.

Public Concern: The FEIS should use an appropriate characterization of the Sierra Nevada Ecosystem Project riparian buffer system.

The aquatic/riparian protection and management widths evaluated in the DEIS and FEIS for Alternative 5 were modeled after those developed in the Sierra Nevada Ecosystem Report (Kondolf et al. 1996). All riparian protection strategies (streamside management zones, Scientific Analysis Team guidelines, and Sierra Nevada Ecosystem Project guidelines) call for variable widths. This is discussed in the description of the alternatives in Chapter 2 and displayed in a table and further discussed in Appendix R. For purposes of evaluating the differences among the alternatives for the level of riparian protection provided, an average width was developed and modeled. This evaluation was initially used to evaluate the differences between the alternatives and was later discarded in favor of a more subjective evaluation of the level of riparian protection ascribed to each alternative (Chapter 3, Environmental Consequences).

Public Concern: The Forest Service should employ the riparian management strategies identified in the Sierra Nevada Ecosystem Report while implementing the pilot project.

Alternatives 2 through 4 meet the Act specifically or the intent of the Act by employing the Scientific Analysis Team guidelines. The Act states that for the term of this pilot project, riparian protection will the Scientific Analysis Team guidelines. Alternative 5 employs the riparian management strategies identified in the Sierra Nevada Ecosystem Report and Alternative 1 employs the streamside management zone strategy. A subjective evaluation of the level of riparian protection provided under each alternative is made in the Environmental Consequences section.

The adequacy and effectiveness of any riparian protection and management strategy has yet to be scientifically tested. Most strategies are a product of general observations and experience combined with specific research findings, such as that conducted for large woody debris, and logical analysis applying scientific principles. The latest science in much of the Sierra Nevada Ecosystem Report is of this type. Monitoring the effectiveness of the different strategies will also help answer some of these questions. The monitoring strategy (Chapter 6 of the FEIS) will help provide some of that information.

Public Concern: The FEIS should provide an alternative that couples Scientific Analysis Team and Sierra Nevada Ecosystem Project buffers for riparian and aquatic ecosystems.

The two strategies for aquatic/riparian protection and management appear similar. In fact, "the main components of FEMAT [very similar to the Scientific Analysis Team guidelines] and the Sierra Nevada Ecosystem Project approaches to aquatic and riparian management are similar, they differ mainly in the details, including terminology" (Forest Service. 1998, page 102). The riparian habitat conservation area is very similar in its width determination and management requirements as the community/energy zone prescribed in the Sierra Nevada Ecosystem Project Report (Kondolf et al. 1996, Volume II, pages 1022 through 1025). The Sierra Nevada Ecosystem Project goes a step further in prescribing a land use buffer that includes lands upslope and upstream of the community/energy zone. This concept of a zone and buffer system is provided in Alternative 5 and described in the Chapter 2 alternative descriptions and again in Chapter 3, under Environmental Consequences, and for Alternative 5, Level of Aquatic and Riparian Protection. A brief description and comparison is given in Appendix R.

The National Environmental Policy Act requires that each alternative be compared to the reference condition, in this case Alternative 1. The Environmental Consequences section comparison of each alternative does just that.

Public Concern: The FEIS should contain a detailed evaluation of current riparian area conditions.

Site-specific planning and inventory work will include an analysis of current and potential impacts to riparian and aquatic ecosystems in the project watershed. For this programmatic analysis, a watershed analysis was conducted. The procedures used and the results of the analysis are in Appendix N. Through the use of geographical information system modeling, most streams and riparian areas were located as were sensitive soils and very steep slopes. The percent of each watershed with "response channels" (those channels formed in alluvial material) and their general conditions were also recorded. This information was used to evaluate each watershed as to its sensitivity and condition with a final determination of its cumulative watershed effects potential.

Aquatic diversity area delineation is beyond the scope of this FEIS, but would be generally provided for in the offbase and deferred lands identified by the Act.

Public Concern: The FEIS should address the impacts of proposed management activities on ephemeral streams.

The analysis specifically evaluates the protection provided headwater channels under each alternative in the Environmental Consequences section, under Level of Aquatic and Riparian Protection.

Public Concern: The Forest Service should not add protection for ephemeral streams.

Ephemeral streams have been shown through many studies to be not only hydraulically linked to downstream intermittent and perennial channels, but also to sources of sediment and nutrients, affecting downstream aquatic and riparian areas. Those channels upstream of ephemerals that do not show evidence of annual scour and deposition are also hydraulically linked to downstream channels, but not by surface flow, rather by subsurface flow. These channels are not included specifically in the definition of ephemeral stream types. All alternatives as analyzed in the FEIS provide for ephemeral stream protection.

Public Concern: The effectiveness of Best Management Practices in protecting aquatic resources should be disclosed in the FEIS.

A description of the results of monitoring Best Management Practices was displayed in the Environmental Consequences section of Chapter 3, page 17 ,under "Alternative 1: Indirect and Cumulative Effects." Streamside management zone implementation and effectiveness was specifically mentioned as being generally effective for protecting soil and water resources when implemented properly. The monitoring program has detected a weakness with delineation of streamside management zones on the ground because not every ephemeral channel type was identified during site-specific planning. Because these channels were not identified, they were not protected. Additionally, the monitoring strategy, Chapter 6 of the FEIS, contains a strategy that will continue to monitor the implementation and effectiveness of riparian protection zone and management, adjusting the protection and management where weaknesses arise.

Public Concern: The FEIS should disclose those streams within the pilot project that are water quality limited.

A list of the impaired watersheds and a brief discussion of the Clean Water Action Plan to accelerate the goals of the Clean Water Act is included in the Affected Environment" section of Chapter 3 under Water Quality and mentioned under Roads in the same section. Appendix N, gives a more detailed analysis of the condition of all watersheds in the planning area. This is a relatively more detailed analysis of the condition of the water quality and problems than that conducted by the State of California in their California Unified Watershed Assessment of October 1, 1998.

Public Concern: The FEIS should specify practices and mitigation measures to limit degradation in areas currently above the threshold of concern.

The threshold of concern does not represent the exact point at which cumulative watershed effects will occur. Rather, it serves as a yellow flag indicator of increasing susceptibility for significant adverse cumulative effects occurring in a watershed. At the site-specific level, mitigation measures would be prescribed that consider the effectiveness of the measures in reducing the susceptibility of adverse cumulative watershed effects.

A cumulative watershed effects analysis will be conducted as a part of each site-specific plan and design to determine the amount of watershed disturbance, including recovery that has occurred. Cause-and-effect relationships are determined and mitigation measures prescribed. Restoration opportunities are also identified and applied.

Roads
Road access and related ecological impacts are primary concerns for many who commented on road construction and decommissioning for the pilot project. Citing various needs ranging from recreation to fire suppression, some respondents strongly believe the Forest Service must maintain or enhance road access in national forests. Others call for an end to new road construction. Existing Forest Service road systems, these people argue, often create water quality problems through increased soil erosion, destroy spawning grounds for many fish and aquatic species, fragment wildlife habitat, and increase introduction and spread of non-native plant species. These adverse environmental effects, they further assert, must be addressed in the FEIS.

Many respondents offer ideas and suggestions for mitigating or preventing the often cited impacts of roads on natural systems. Moving away from high grade road construction to softer road construction, one person contends, should be a Forest Service requirement for lessening the impacts of construction and allowing a faster return to natural conditions after use. Although the adverse ecological effects of roads are most commonly mentioned by respondents, some people believe other values must be considered when addressing road impacts in a given area. In fact, these people suggest that the Forest Service prepare a road inventory to identify roads that should be closed for not only ecological but also aesthetic or cultural purposes.

Several people are also concerned with specific implementation details regarding the Act. The Forest Service, one individual asserts, must re-establish the infrastructure within the pilot project area if logging companies are going to be able to properly and safely transport specialized equipment to these areas. The DEIS also fails to address the costs associated with road construction for the pilot project, according to one member of the wood products industry. The FEIS, this person believes, should include analysis of the costs per mile and the total costs for road construction and reconstruction.

Public Concern: The FEIS should address the cumulative impacts of permanent roads on the environment.

Roads are addressed within the FEIS in the Physical, Aquatic, and Riparian section, in the Wildlife section and in the Fire section. Roads are a part of the cumulative impacts of these resource areas.

Public Concern: The FEIS should disclose the effects of temporary roads on the environment.

Temporary roads are addressed in the FEIS in the Physical, Aquatic, and Riparian section. This is a programmatic (strategic) FEIS and is not the appropriate place to determine temporary road construction needs at the site-specific scale. Temporary road construction needs are evaluated during the implementation phase as site-specific decisions. Any potential effects of temporary road construction will be assessed during implementation, as appropriate, and each decision will be subject to the site-specific analysis including opportunities for further public participation. Temporary roads are required to be decommissioned following use by timber sale contractors.

Public Concern: The Forest Service should analyze the impacts of roads on the Sierran ecosystem.

The FEIS, Chapter 3, includes analysis of the impacts of roads on the ecosystems of the planning area. This analysis drew in part on broader scale studies from Sierra Nevada-wide efforts. Analysis of the impacts of the roads on the entire Sierran System is most appropriate at a higher planning level. The Sierra Nevada Framework Project forest plan amendment environmental analysis will deal in part with the resolution of concerns at a range-wide scale.

Public Concern: The FEIS should separate road decommissioning from logging in its analysis of road miles per alternative.

The FEIS shows the miles of new road construction and decommissioning. Project planning will be the vehicle for analysis of road decommissioning needs. Timber sale purchasers have decommissioned roads and the Forest Service will continue to relocate, reconstruct, and decommission roads through the use of timber sale contracts.

Public Concern: The Forest Service should not build new roads in national forests.

National Forest System lands are managed under a multiple-use concept, which provides a wide range of amenities to the public, including recreation and commodities such as minerals and wood products. Roads are necessary to meet the direction given by Congress. Currently each national forest is assessing its road inventory and determining which roads are necessary to meet the multiple-use direction. This has resulted in closing a number of roads; however, recreation, timber harvest, general administration, and other uses require roads to access National Forest System lands. This type of decision is outside the scope of this document.

Public Concern: The FEIS should use consistent criteria to designate lands offbase to road building.

This concern was addressed by a correction in the FEIS, Chapter 3.

Public Concern: The FEIS should analyze the costs per mile and the total costs for road construction and reconstruction.

The requested analysis is included in SPECTRUM modeling and the "Miles of Road Work by Alternative" spreadsheet located in the planning file. The total costs for road construction and reconstruction are included in Social and Economic Analysis found in Chapter 3 and the appendices.

Public Concern: The Forest Service should require construction of softer roads for timber harvesting and reduce high grade road construction.

The Forest Service already does this. This FEIS requires an analysis of the road system needed for each area entered (Appendix R - Riparian Management Plan, Riparian Improvement Strategy and Scientific Analysis Team standards and guidelines RF-3 and RF-4). However, this is a programmatic FEIS and is not the appropriate place to determine road construction standards at the site-specific scale. The Forest Service will follow Forest Plan direction and Best Management Practices at the site-specific level. Road construction standards and road management objectives are evaluated during the implementation phase as site-specific decisions. Any potential effects of road construction will be assessed during implementation, as appropriate and each decision will be subject to the a site-specific analysis process including opportunities for further public participation.

Public Concern: The Forest Service should improve the forest infrastructure needed to implement the pilot project.

This will be done at the site-specific planning level where resource needs can be better and more accurately considered. The FEIS recognizes there will be a need for infrastructure improvements including road reconstruction. There are also opportunities to remove roads that no longer are needed or are a detriment to other resources.

Public Concern: The Forest Service should provide road access for recreation and fire suppression.

Each national forest is assessing its road inventory and determining which roads are necessary to meet the multiple-use direction set by Congress. The determination of road access for recreation and fire is better made at the site-specific level, where local concerns can determine need. A number of factors in maintaining the current road systems are considered including the effects to resources, as well as current and future needs for recreation and fire suppression.

Public Concern: The FEIS should prepare a road inventory and identify roads suitable for closure, and should clearly specify what roads will be decommissioned and make this information available to the public..

This is currently taking place as part of the Travel Management Plan. The FEIS requires an analysis of the road system needed for each area entered (Riparian Management Plan, Riparian Improvement Strategy and Scientific Analysis Team standard and guidelines RF-3 and RF-4) This analysis is programmatic (strategic) FEIS and is not the appropriate place to determine roads suitable for closure. Road analysis dealing with road closure occurs during the implementation phase as site-specific decisions. Any potential suitable road closures will be assessed during implementation and each decision will be subject to the site-specific analysis process including opportunities for further public participation.

Roadless/Unroaded Areas
Whether they believe the Forest Service should protect roadless areas greater than 5,000 acres or 160 acres in size, many respondents agree that protection of these areas is vital. Noting that the Act directs the Forest Service to defer logging in some roadless areas, some ask that the FEIS defer logging and road building in all roadless areas. Others fear that road construction necessary to implement the Act will increase access for recreational users including off-highway vehicle enthusiasts. Because they see increased recreational use as detrimental to sensitive wildlife species, they call for permanent protection of roadless areas even if they are less than 5,000 acres. One conservation organization points out that the DEIS failed to consider and protect the Bald Mountain and Castle Peak roadless areas on the Sierraville Ranger District.

Public Concern: The FEIS should offer more protection for roadless areas.

Alternatives 2 through 5 include protection for 146,820 acres of deferred, 319,613 acres of offbase, and 153,750 acres of late successional old growth habitat. In addition, Alternatives 4 and 5 include protection of 397,434 acres of areas of late successional emphasis habitat and Alternative 5 evaluates an additional 97,400 acres of unroaded areas for protection. The number of acres affected by the February 1999 interim rule placing a temporary (18 month) moratorium on road construction are determined on a site-specific basis. The moratorium restricts road construction and reconstruction but does not restrict other resource management activities.

Public Concern: The FEIS should consider more Wilderness designations.

This public concern is outside the scope of the FEIS. The Forest Service does not have authority to make Wilderness designations. The Forest Service merely recommends Wilderness designation to Congress, when appropriate. Wilderness designations are reserved to Congress. Forest Service Wilderness recommendations are part of the forest planning requirements completed to fulfill National Forest Management Act obligations.

Public Concern: The FEIS should be consistent in the number of roadless areas it specifies will be affected by alternatives.

Alternatives 2 through 5 include protection for 146,820 acres of deferred, 319,613 acres of offbase, and 153,750 acres of late successional old growth habitat. In addition, Alternatives 4 and 5 include protection of 397,434 acres of areas of late successional emphasis habitat and Alternative 5 evaluates an additional 97,400 acres of unroaded areas for protection. In Alternatives 1 through 4, a temporary moratorium on road building in unroaded areas greater than 1,000 acres adjacent to Wilderness, wild areas of Wild and Scenic Rivers and RARE II areas is in place. The number of acres effected by the February 1999 temporary moratorium on road construction are determined on a site-specific basis. This moratorium restricts road construction and reconstruction but does not restrict other resource management activities.

Public Concern: The FEIS should disclose the effects of alternatives on roadless areas less than 5,000 acres in size.

Alternative 5 evaluates an additional 97,400 acres of unroaded areas for protection. This alternative protects all roadless areas 1,000 acres and larger. Each resource area evaluates the effect of this protection. In Alternatives 1 through 4, a temporary moratorium on road building in unroaded areas greater than 1,000 acres adjacent to Wilderness, wild areas of Wild and Scenic Rivers and RARE II areas is in place.

Public Concern: The Forest Service should not increase de facto wilderness by deferring management activities.

The FEIS documents the management activities associated with each alternative, including deferring timber harvest and road construction. Management activities would be deferred for the period of the pilot project only.

Air Quality
The effects of prescribed fire on air quality concerns some people who responded to the DEIS. In particular, the Nevada Division of Environmental Protection wants to see that "cumulative impacts, interstate transport, smoke mitigation measures, and alternatives to burning are addressed in the development of the FEIS." Consideration of air quality impacts, however, is only one important part of a fuels management strategy, according to one individual. A public education effort, this person contends, is also needed to increase awareness of the history and benefits of prescribed burns in the Sierra Nevada region.

Public Concern: The FEIS should analyze the potential air quality impacts resulting from prescribed fires.

Particulate emissions generated from prescribed burns were calculated for each alternative as shown in Table 13.1 in Appendix X. Alternatives to prescribed burning will be addressed at the site-specific level. The NFSPUFF model was used to predict cumulative particulate concentrations under a worst-case scenario. The predicted concentrations were below national and state standards.

Public Concern: The Forest Service should better educate the public about smoke as a by-product of prescribed burns.

The Pacific Southwest Region signed a Memorandum of Understanding with the California Air Resources Board on July 13, 1999, concerning prescribed burns. The Memorandum of Understanding requires agencies to coordinate efforts to educate the public about prescribed burns.

Public Concern: The FEIS should address how the Forest Service will comply with the Environmental Protection Agency’s Interim Air Quality Policy on Wildland and Prescribed Fires.

The Pacific Southwest Region is committed to following guidance and direction pertinent to smoke management and air quality protection as provided in the Interim Air Quality Policy on Wildland and Prescribed Fires announced by the Environmental Protection Agency in 1998, and in the Smoke Management Guidelines under Title 17, currently being revised by the California Air Resources Board. The Forest Service will work together with the California Air Resources Board and local air pollution control districts for implementation of prescribed burn activities.

Visual Resources
In response to the visual resources section of the DEIS, one individual claims that this section does not address the aesthetic value of the westside canyon country of the Lassen and Plumas National Forests, including the Pacific Crest Trail, Middle Fork Feather Wild and Scenic River, and the Feather Falls Scenic Area. Another respondent is concerned that the analysis may have overlooked consideration of the visual impacts of defensible fuel profile zones.

Public Concern: The FEIS should consider the visual impact of defensible fuel profile zones.

The visual impacts of defensible fuel profile zones are best addressed at the site-specific planning level. Any effects on the visual resource occurring, as a result of implementing site-specific projects derived from this FEIS will be addressed in site-specific analyses. These implementation phase decisions will be made in accordance Forest Plan goals, objectives, standards, and guidelines and National Environmental Policy Act processes for environmental analysis, including opportunities for further public participation.

Public Concern: The DEIS fails to address the aesthetic value of the westside canyon country of the Lassen and Plumas National Forests.

Aesthetic values associated with westside canyons are best addressed at the site-specific planning level. Any affects on aesthetic values will be addressed before implementation. These implementation phase decisions will be made in accordance Forest Plan goals, objectives, standards, and guidelines and National Environmental Policy Act processes for environmental analysis, including opportunities for further public participation.

Biological Environment

Vegetation Resources
Although most people who commented on vegetation management direction are concerned with timber management practices, a few question how implementation of the FEIS may affect other vegetation types. Several people believe the FEIS must address the potential effects on wildlife that depend on early successional vegetation from conversion of forests to older age classes. "What will happen," one individual asks, "to the vast majority of wildlife which require early successional stages to survive?"

Others are wary of the FEIS because they believe the effects of fuelbreaks on forest structure, such as soil disturbance and shade reduction, will create opportunities for the introduction and spread of non-native plant species. Preventing the spread of non-native plant species, they assert, must be a priority in implementing and funding the pilot project. Worried that funding for the pilot project will dry up before any noxious weed management strategies are implemented, one person asserts that the affected forest environment will be "permanently and progressively degraded." According to this individual, Alternative 5 presents the least significant threat of non-native plant invasion. Another respondent suggests that the Forest Service adopt the California Native Plant Society's proposed protected area guidelines in an effort to prevent the introduction and spread of non-native plant species.

Public Concern: The FEIS should address how the early successional vegetation communities and associated species will be affected by the pilot project.

Alternatives in the FEIS include the implementation of Forest Plan standards and guidelines (Tahoe Forest Plan page 28, Lassen Forest Plan 4-30, Plumas Forest 4-30) defining succession of vegetation communities and the quantity of vegetation in specific seral stages for a given management area. Such analysis provides information for assessments for site-specific projects derived from the FEIS. In addition, identification of associated species and how they are affected will be made by an interdisciplinary team during site-specific environmental analyses.

Public Concern: Long-term management should be visualized as management of a mosaic of different age classes that meet all wildlife and other needs.

Alternatives in the FEIS include the implementation of Forest Plan standards and guidelines (Tahoe Forest Plan page 28, Lassen Forest Plan 4-30, Plumas Forest 4-30) for succession of vegetation communities and the quantity of seral stages are required by management area. Long-term management of a mosaic of groups of different age classes can best be assessed through landscape or watershed analyses. These analyses, in turn, provide information for the site-specific environmental analyses. To facilitate the ability to manage a mosaic of different age classes across the landscape, the FEIS includes monitoring protocols for biodiversity for which seral stage status is an integral part.

Public Concern: The FEIS should include an analysis of effects of alternatives on snag recruitment.

All alternatives require compliance with California spotted owl interim direction, including required snag densities. Concern exists that the required snag densities may pose a safety hazard to woods workers. Since the adoption of the interim rule, managers have analyzed snag densities with respect to safety of woods workers. On a site-specific basis, and as described in Chapter 3, snag location of can be accomplished in a way that avoids many safety hazards and still meets requirements. There may be situations where snag recruitment measures are necessary. This will be determined on a site-specific basis.

Lower Westside Hardwood Forest Ecosystems
Adequate analysis of existing conditions and potential effects of the FEIS on lower westside hardwood forest ecosystems and the habitat they provide for deer is a concern for many respondents. They ask the Forest Service to review and analyze protection measures included in the FEIS.

Public Concern: The Forest Service should review the adequacy of the protection measures included in the FEIS for the lower westside hardwood zone.

Oak retention standards were developed as described in Chapter 3. Where oak is present, an average 25 to 35 square feet basal area per acre of oaks over 15 inches diameter at breast height (DH) will be retained. Site-specific planning will determine the feasibility of meeting these retention standards. Smaller oaks may be left if determined to be needed for future recruitment. Following this direction will provide for wildlife and vegetative diversity.

Old Forest Ecosystems
Protection of all remaining old growth forests is a concern for many who responded, whether or not these forests are identified specifically in the Sierra Nevada Ecosystem Project Report or elsewhere. Those who compare the percentage of old growth remaining in Sierran national forests to that persisting in national parks believe too much has already disappeared, and all that is left must be preserved. Old forests are not only important as habitat for wildlife, some say; they are also important for their wild value and as a legacy for future generations.

Several people offer different estimates of the old forest acreage, ranging from 60,000 to 160,000 acres, they believe should be protected under the pilot project. The Forest Service should protect all forests identified as areas of late successional emphasis in the Sierra Nevada Ecosystem Project Report, they recommend. According to some respondents, the FEIS alternatives fall short in the area of old growth protection. Both of the preferred alternatives fail to provide adequate protection, writes one person, while another individual encourages the Forest Service to reject all alternatives.

The fate of unprotected old forests in the planning area is a concern for some. Senator Dianne Feinstein asks that the Forest Service avoid logging and road building in late successional old growth areas, even if they are not deemed offbase or deferred. Similarly, a conservation organization asks for an analysis of pilot project effects on unprotected old forests, including stands near the South Fork of the Feather River. A physician worries that as old forest disappears, the possibility of potentially helpful biological discoveries from these areas diminishes. Another person is concerned about the fragmentation of habitat and requests that wildlife corridors through old forests be protected.

Several people offer direction for managing old growth areas. Old forests identified in the Sierra Nevada Ecosystem Project Report should be managed as areas of late successional emphasis, according to some. Other old growth not identified in the Report, they say, should be managed for the protection of ecological systems and retention of old growth forest. In contrast, some people believe that active management activities should not be excluded from old forests. For several people, selective logging in old growth forests is a viable option. Fire hazard reduction activities should also be permitted in areas of late successional emphasis, according to others. In contrast, many believe old growth areas should be entirely off limit to logging.

The need for a clear definition of late successional old growth is a key concern for people. At least three different definitions have been used in the Sierra Nevada in the 1990’s, one person writes, and the Forest Service should end the confusion by selecting a scientifically-defensible, credible definition.

Public Concern: The selected alternative should protect old growth forests.

Protection of old forest values is one of the significant issues identified through both internal and external public and other agency comments during scoping. As required, alternatives were developed to respond to this issue. Each alternative developed responds to this issue, but varies in the amount of protection afforded to old forest values. All alternatives comply with the large tree retention direction in the California spotted owl interim direction. Alternative 1 incorporates Forest Plan direction for providing at least 5 percent of each seral stage represented in a given planning area, as well as providing for old forest habitat conditions in other land allocations, including wildlife habitat management areas, Wilderness, and Wild and Scenic River Corridors. Alternatives 2 through 5 include Forest Plan direction and additionally provide for protection of highly ranked late successional old growth (rank 4 and 5) stands reported in the Sierra Nevada Ecosystem Project. Alternatives 4 and 5 provide for additional conservation of old forest values by protecting areas of late successional emphasis.

Public Concern: The Forest Service should avoid scheduling timber harvest and road construction activities in late successional old growth stands, even if they are not designated offbase or deferred.

The FEIS responded to this public concern by including in Alternatives 2 through 5 the protection of highly ranked late successional old growth (ranks 4 and 5) reported in the Sierra Nevada Ecosystem Project by deferring timber harvest and road building. Alternatives 4 and 5 provide for additional conservation of old forest values by protecting areas of late successional emphasis.

Public Concern: The selected alternative should make old growth forests off limit to logging.

Protection of old forest values is one of the significant issues identified through both internal and external public and other agency comments during scoping. As required, alternatives were developed to respond to this issue. Alternatives in the FEIS vary the protection afforded to old forest values. This concern is evaluated and compared in the Environmental Consequences section of the FEIS.

Public Concern: The FEIS should analyze the impacts of the pilot project on areas of unprotected old growth.

Chapters 2 and 3 of the FEIS describe proposed treatments and potential consequences and effects of the proposed treatments to late successional old growth (ranks 4 and 5) and areas of late successional emphasis, as identified and described in the Sierra Nevada Ecosystem Project.

Public Concern: The Forest Service should protect wildlife corridors for species dependent on old growth.

Habitat connectivity specific to species that use old growth was addressed and described in the Biological Assessment/Biological Evaluation, and summarized in Chapter 3 of the FEIS, for California spotted owl, American marten, and Pacific fisher. Impacts to the forest carnivore habitat network across the pilot project area were addressed and described in the Biological Assessment/Biological Evaluation, and summarized in Chapter 3 of the FEIS, for American marten and Pacific fisher. Under Alternatives 3 and 4, suitable California spotted owl habitat will be retained, enhancing habitat attributes for wildlife corridors. These public concerns were considerations during the review of effects of each alternative on wildlife.

Public Concern: The Forest Service should manage old growth as areas of late successional emphasis.

Old forest is a significant issue in the FEIS. Areas of late successional emphasis are an important part of the old forest issue. Alternatives were designed to include different levels of management regarding old forest and areas of late successional emphasis. The environmental analysis examines the effects of the different alternatives on the areas of late successional emphasis. As described in Chapter 2, Alternatives 1, 2, and 3 do not recognize the areas of late successional emphasis strategy in their design. Alternatives 4 and 5 include the areas of late successional emphasis strategy in their design.

Public Concern: The alternatives should not exclude management activities in old forest areas.

Alternative 1, is the no action alternative. It follows Forest Plan direction for activities allowed or excluded from areas with old forest values. Protection of old forest values was provided for in varying degrees by protecting Sierra Nevada Ecosystem Project late successional old growth ( ranks 4 and 5) in Alternatives 2 through 5, and, in the case of Alternatives 4 and 5, areas of late successional emphasis as described in the Sierra Nevada Ecosystem Project. Timber harvest and road building are not permitted in late successional old growth (ranks 4 and 5); however, light activities, such as underburning and brushing are allowed to enhance fire resiliency. Areas of late successional emphasis are deferred from mechanical treatment or fuels management.

Public Concern: The selected alternative should allow selective logging in old growth.

The consequences of timber harvest in late successional old growth and areas of late successional emphasis are outlined in the Environmental Consequences section of the FEIS. Each alternative developed to respond to this issue varies in the protection afforded to old forest values. All alternatives comply with the large tree retention guidelines in the interim direction for the protection of California spotted owls. The areas of late successional emphasis strategy allows for some management activity. The Sierra Nevada Ecosystem Project Report, Volume 1, Chapter 6 states: "Management of areas of late successional emphasis would emphasize treatments to maintain, enhance, and protect high quality late successional conditions. Active management within areas of late successional emphasis is anticipated in at least some areas, with prescribed fire being the primary tool. Mechanical fuel treatment (timber harvest) could be allowed, if limited in intensity and extent, so as to maintain conditions as near natural as possible."

Public Concern: The pilot project should include reduction of fire hazard in areas of late successional emphasis.

Vegetation management treatments allowed in areas of late successional emphasis vary under each alternative. Alternatives 1 through 3 permit vegetative management activities using current Forest Plan direction in areas which have been identified as areas of late successional emphasis. Although the interim direction for the protection of California spotted owl guidelines (1992) will be followed in all alternatives, some harvest of larger trees in unsuitable habitat would take place under Alternatives 1 through 3. In Alternatives 4 and 5, areas of late successional emphasis are deferred from vegetative management, mechanical treatments, or fuels management.

Public Concern: Analysis for the FEIS should use a clear, scientifically credible and defensible definition of late successional old growth forest.

The FEIS uses the definitions provided in the Sierra Nevada Ecosystem Project as mapped identifying late successional old growth forests. The work done for Sierra Nevada Ecosystem Project considered a number of factors, including attributes that occur under natural conditions. Because plant communities are rarely alike, it is very difficult to provide a definition that fits every site. However, there are some common components based on the specific vegetational community.

Public Concern: The FEIS should clarify if areas of late successional emphasis and late successional old growth (ranks 4 and 5) north of Highway 299 will be protected.

Alternative maps in the FEIS, show that the lands north of Highway 299 are not included in the pilot project area, and will not be managed in accordance with the Act.

Public Concern: The FEIS should include accurately mapped acreage of old growth occupied by owls and goshawks.

The Wildlife Report (Chapter 3 and Appendix AA) displays habitat as defined by suitability. This includes providing strata labels used to define the different types of suitable habitat. The ability to show the amount of old growth used by these species is very limited and is better accomplished at the site-specific analysis level where experience and site-specific information can be included.

Public Concern: The FEIS should analyze the impact of the pilot project on old growth stand structure and configuration, rather than limiting evaluations to tree size and canopy closure.

During the scoping process, many people expressed concern regarding the protection of highly ranked late successional old growth and areas of late successional emphasis mapped areas. These comments were used as an index to evaluate the alternatives.

Under the Fish and Wildlife Resources section of Chapter 3, the effects of the alternatives on snag and large woody debris (down logs) is addressed. Current vegetation databases rely heavily on crown closure and tree size. Horizontal and vertical structure desired characteristics are difficult to define and are not presently designed into vegetation labels that comprise the current database. Large tree dominated vegetation is easily analyzed and served as a proxy for old forest.

In the FEIS, new prescription language (see Chapter 2) was developed for Alternatives 3 and 4 to promote vertical diversity. This language pertains to all lands identified as either "select" or "other" strata in the interim California spotted owl direction. These strata comprise 47 percent of the pilot project area.

Public Concern: The FEIS should establish large, spatially-explicit late successional old growth reserves.

Alternatives 2 through 5 have late successional old growth (ranks 4 and 5) identified. In these areas, road building and timber harvest is deferred. Alternatives 4 and 5 have areas of late successional emphasis networks, as described in Sierra Nevada Ecosystem Project, also identified for deferral of road building and timber harvest. In addition, Alternative 5 includes old forest emphasis areas. The intent of these areas is to establish large, spatially-explicit reserves of old forest which encompass both late successional old growth (ranks 4 and 5), as well as areas of late successional emphasis mapped areas. Old forest emphasis areas are intended to provide for large contiguous areas of land across the landscape.

Public Concern: The selected alternative should protect areas of late successional emphasis as identified in the Sierra Nevada Ecosystem Project.

Alternatives 4 and 5 allow for deferral of timber harvest and road building activities within areas of late successional emphasis. Alternative 1 is described in the Environmental Consequences section as having a moderate effect, and Alternatives 2 and 3 as having minor effects on areas of late successional emphasis.

Public Concern: The selected alternative for old growth forests should be Alternative 5

Alternative 5 is one of the alternatives discussed in detail in the FEIS. Each alternative will be considered and a decision made based on their individual merit. The Act directs the Forest Service to complete an environmental impact statement by August 17, 1999. The Interdisciplinary Team believes a reasonable range of alternative old growth protection options was provided to the Responsible Officials for addressing this significant issues identified during scoping.

Public Concern: The FEIS should analyze and disclose how long abandoned defensible fuel profile zones may take to recover to old growth structural characteristics.

Chapter 3 of the FEIS discusses the effects of the alternatives on a number of old forest indices. These include late successional old growth and areas of late successional emphasis, as well as acreage of large tree vegetation types. Alternatives 2 through 5 protect late successional old growth (ranks 4 and 5), Alternatives 4 and 5 protect areas of late successional emphasis, and Alternative 5 establishes extensive old forest emphasis areas and protects all patches of late successional old growth (ranks 4 and 5). All alternatives show a dramatic increase in large tree dominated vegetation over the next 5 decades.

Within defensible fuel profile zones, snags are allowed. Through time, residual trees in defensible fuel profile zones will attain larger size. There is latitude for developing vertical diversity. Included in the FEIS (Chapter 2) for Alternatives 3 and 4 is new prescription language that does not allow for the degradation of California spotted owl nesting habitat to foraging habitat. The new prescription language does not allow for degrading California spotted owl foraging habitat to unsuitable. Included in Alternatives 3 and 4 are prescription language for promoting vertical diversity. Tree growth over time was simulated and is provided in Appendix D.

Public Concern: The FEIS should include a cumulative effects analysis on old forests.

The FEIS, Chapter 3, contains language describing the cumulative effects on late successional old growth, areas of late successional emphasis, and large tree vegetation.
 
 

Timber Harvest Management
Whether supportive of or in opposition to logging on national forests, those who comment on timber management generally offer prescriptions for future management practices. Claiming that forests are a useful renewable resource, many people believe the logging industry must retain its ability to extract timber from national forests. According to one individual, all forests should be harvested, including old growth and other forest types identified in the Sierra Nevada Ecosystem Project Report.

Conversely, others suggest the Forest Service focus on minimizing the negative effects of intensive logging practices on forest health. Citing adverse effects such as sedimentation of streams and habitat fragmentation, these people argue the evidence of destruction caused by logging activities is well documented. For some people, minimizing these effects requires a sustainable approach to harvesting trees. Although many respondents use the term "sustainable" in defining future forest management goals, their interpretation of sustainable harvests appear to be synonymous with non-commercial, selective harvests for some and fuel thinning for others. Whatever specific timber management technique is used, several people believe the technique must be consistent with managing the planning area as a mosaic of different age classes and for biodiversity.

In order to address the negative impacts associated with existing timber harvest techniques, many want the Forest Service to explore a broad range of timber management practices that seek to minimize or prevent impacts. Commercial logging, some people suggest, should be eliminated on national forests for a variety of reasons, ranging from the need to end taxpayer subsidies for logging companies, to the need to prioritize growing recreational interests. Other prescriptions for harvest techniques include minimizing group selection harvests and requiring pilot project harvest levels not exceed current levels of extraction. One person offers helicopter logging as an alternative to traditional logging practices to minimize the adverse effects of road building and erosion often associated with timber removal via logging trucks. Another alternative to intensive logging activities, one respondent notes involves designation of specific national forest areas for logging, while excluding the remainder. Mixing sawlog trees with chip trees when extracting timber concerns one Forest Service employee who urges the Forest Service to end this inefficient practice. In contrast to those who offer suggestions for harvest techniques that proactively minimize adverse effects, one individual believes a logging company's responsibility extends beyond the term of the harvest phase of a logging operation. The Forest Service, this person asserts, should require timber companies to replant areas after harvest.

Clear criteria for single or group tree selection in the FEIS is another primary concern for many who respond on the topic of harvest prescription methods. They want the FEIS to provide detailed guidance on many aspects of harvest methods, including logging techniques and tree selection criteria. Doubting that the proposed single and group harvest methods will mimic the natural fire regime in the Sierra Nevada region, one individual believes the FEIS should analyze the relationship between proposed harvest methods and the pattern of mortality resulting from natural fire.

Many representatives from the wood products industry express concern regarding how the Act will ensure they have adequate harvest opportunities. Specifically, one member of this industry wants the FEIS to specify that a percentage of the timber cutting projects be designated for Small Salvage Timber Sales. Incorporation of Small Salvage Timber sales in pilot project activities, this respondents asserts, will allow small operators the "opportunity to purchase and merchandise a portion of these projects." Another representative from the wood products industry believes restricting logging operations to dry or hard frozen conditions, as detailed in the DEIS, will compromise the success of the pilot project by reducing the number of allowable working days. The Forest Service, this person requests, should adopt a provision for winter logging operations similar to that found in the California Forest Practice Rules.

Public Concern: The Forest Service should consider potential risks to public safety from increased log truck traffic resulting from implementation of the Act.

The Forest Service is concerned about public safety. For this reason, timber sale contracts require adherence to State traffic laws. Contractors are required to provide traffic warning signs in accordance with the Manual of Uniform Traffic Control Devices. Harvest levels under Alternatives 2 through 5 are lower than planned harvest levels in the original Forest Plans. It is important to note that these original harvest levels were reduced in recent years by the Forest Plan amendments providing interim direction for the protection of the California spotted owl. This lower harvest level does not increase the safety hazard from logging traffic.

Public Concern: The Forest Service should allow logging on national forests.

The Forest Service manages lands under a multiple-use concept that places production of timber products on equal footing with management of other resources. The Forest Service is mandated by Congress under several statutes to produce goods and services from National Forest System lands and resources (Organic Act, Multiple-Use, Sustained-Yield Act, the Renewable Resources Planning Act as amended by the National Forest Management Act as a few examples), including the production of timber. The establishment Acts for National Forest System lands set priority on the production of sustained yields of timber and high quality water. This direction from Congress remains in effect; however, the emphasis is changing and currently timber harvest is used to meet a number of resource needs (including fuel reduction and wildlife habitat) in addition to strictly providing commodities.

Public Concern: The selected alternative should designate a forest area only for logging.

Of the 2,422,163 acres in the pilot project area, 31 percent are currently not available for harvest. Of these, 466,000 acres are identified as off base or deferred, 100,844 are in designated Wilderness Areas, and 192,388 are in spotted owl habitat areas or protected activity centers. These values do not reflect riparian areas restricted from harvest. Alternative 3 eliminates an additional 59,000 acres (2.4%, for a total of 33.4%) of late successional old growth (ranks 4 and 5) from harvest consideration. Alternative 4 includes 172,000 acres (7.1%, for 40.5%) of areas of late successional emphasis as unavailable for logging. Alternative 5 essentially eliminates scheduled timber harvest. Acres to be harvested annually varies among the alternatives. The

Forest Plans for the Lassen, Plumas, and Tahoe National Forests, as well as the alternatives, include land allocations and management guidelines that designate areas where harvest is permissible or restricted.

Public Concern: The FEIS should address a broad range of timber management practices.

Removal of forest products through timber sales is part of the Forest Service's multiple-use mandate from Congress as promulgated in the following legislation:

In general, timber harvest is designed to optimize economic efficiency, while minimizing detrimental environmental effects. As an example, small diameter biomass material is typically included in timber sales to meet the objective of fuel reduction in a timely fashion with fewer harvest entries, despite the fact that this material has a low or negative value, as long as the sale as a whole has a positive value. Separating the removal of chips and sawlogs into two sales increases the number of entries and consequent disturbance, delays meeting ecological objectives, and increases the risk of loss to fire or insects during the delay.

Public Concern: The FEIS should consider the potential advantages of group selection silviculture.

Appendix E provides a feasibility analysis for the use of the uneven-age silviculture system known as group selection. The intent was not to display the positive or negative aspects of group selection, but to determine if the accomplishment expectations as described in the Act were feasible.

The Final Environmental Impact Statements for the Land and Resource Management Plans for the Lassen, Plumas, and Tahoe National Forests contain an appendix titled "Major Silvicultural Systems and Their Application." This appendix provides a complete discussion on the beneficial and adverse effects of group selection. The FEIS alternatives designed different strategies for group selection harvest. Three of the alternatives have high levels of group selection accomplishment, while the other two have low levels. The effects of the alternatives with the different group selection harvest strategies are described in Chapter 3.

Public Concern: The FEIS should include clear criteria for single or group tree selection harvest.

Chapter 2 of the FEIS explains the priorities for group selection and individual tree selection harvests. Analysis and assessment of specific stand information will occur during site-specific environmental analysis.

Public Concern: The FEIS should analyze the relationship between the proposed harvesting methods and the pattern of mortality resulting from natural fire.

Chapter 3 of the FEIS describes the effects and consequences of the proposed treatments in the alternatives. Stocking reduction in timber stands, similar the reductions designed for the FEIS, has proven beneficial for reducing fire impacts in forested stands. For example, many of the thinned stands in the planning area have been underburned successfully after thinning.

Public Concern: The Forest Service should consider and minimize the negative effects of intensive logging practices on forests.

The FEIS incorporates recommended mitigation measures to avoid, reduce, or eliminate effects to resources, including effects to threatened, endangered, and sensitive plants; heritage resources; water; wildlife; air quality; and roads. Measures include site survey or inventory, avoidance or prevention techniques, and monitoring during site-specific implementation.

Public Concern: The selected alternative should minimize acres of group selection.

Alternatives 1 through 5 provide a range of acres treated by group selection harvest. Alternative 1 is patterned after current practices (less than 500 acres per year). Alternatives 2, 3, and 4 have over 7,000 acres of group selection harvest. Alternative 5 has no specific targets for group selection harvest, but levels will be below that of Alternative 1. As shown in Chapter 2 annual harvest levels range across the alternatives from less than 15 million board feet (Alternative 5) to nearly 300 million board feet (Alternative 2). Current management (Alternative 1) harvests approximately 124 million board feet.

Public Concern: The Forest Service should develop a sustainable approach to harvesting trees.

Current direction for the pilot project area is contained in the Lassen, Plumas, and Tahoe Forest Plans. Sustainable harvest levels are established based on predicted growth and other resource objectives. Currently, the rate of tree growth in the pilot area exceeds planned harvest levels in the Forest Plans, as well as all alternatives analyzed in the FEIS. Harvest levels as described in Chapter 2 and 3, represent by-product outputs resulting from meeting the design objectives of each alternative. Alternatives were designed around treatment of the landscape. Harvest levels vary depending on alternative design and how aggressively the landscape is treated over the pilot project period.

Public Concern: The FEIS should specify that some of the timber cutting projects be Small Salvage Timber Sales.

Determination of whether a timber sale is warranted, and what size of timber or timber value is completed at the site-specific planning level. The Lassen, Plumas, and Tahoe National Forests use the Small Salvage Timber Sale program as opportunities arise. Forests Supervisors and District Rangers make every effort to balance and distribute a range (size and value) of timber sales between small and large businesses. The program of Small Salvage Timber Sale activity on the Lassen and Plumas National Forests is described in Chapter 3 of the FEIS.

Public Concern: The Forest Service should adopt a provision for winter logging operations resembling that found in California Forest Practice Rules.

Neither the Act nor this FEIS prohibits winter logging operations. Soil quality standards identified in the Environmental Consequences section of the FEIS allow winter logging operations where they will help meet or exceed standards. The use of winter logging is determined on a site-specific basis.

Public Concern: The FEIS should consider using helicopter logging.

Aerial logging, including helicopter logging methods, is an acceptable practice in the pilot project area. The need to use aerial logging is determined by site-specific analysis. Helicopter logging is a biologically feasible harvest method in many parts of the pilot project area; however, it is generally expensive (more than $1,500 per acre), averaging 4 or 5 times the cost of ground logging methods. The FEIS indicates that much of the timber to be removed from the pilot project area has low value. For all alternatives, use of helicopter logging has the potential to substantially increase the cost of harvest. Shortfalls would be paid for with appropriated funds. Site-specific analysis will be used to determine if helicopter logging is economically feasible.

Public Concern: The FEIS should consider the probability of eliminating leave trees.

Experience has shown that windthrow, although more prevalent in shelterwood harvests, is generally dependent on local conditions. For example, in 1995 the Swain Mountain Experimental Forest suffered severe damage due to high winds. While some of the damage may have been due to recent openings in the stand (around 1988) that area is known to receive heavy winds. Other areas treated similarly did not receive damage or were only slightly damaged. The potential for windthrow is considered by the silviculturist when developing a harvest prescription. Probability of windthrow is assessed in a risk assessment and requires knowledge of the exact area to be treated; therefore, this type of assessment is best done as part of a site-specific analysis so local conditions can be adequately considered. Risk of windthrow is difficult to assess at the programmatic level of this FEIS.

The treatments associated with installation of defensible fuel profile zones and individual tree selection will leave many more trees than are found in the Swains Mountain Experimental Forest sites. The reduced number of trees lowers the potential for windthrow. Silviculturists consider windthrow when prescribing vegetative management for site-specific projects.

Many of the group selection harvest areas will have residual trees following harvest to comply with interim direction for the protection of California spotted owl. Group selection treatment areas will be 2 acres or less in size and will receive some wind protection from adjacent stands. Site-specific analysis will determine appropriate location and size for group selection treatment areas to reduce windthrow risk. Windfall in harvest and fuel treatments is not considered to be a major problem, thus the FEIS does not address this concern.

Public Concern: The Forest Service should address the potential loss of future medicinal discoveries if old growth trees in national forests are logged.

The medicinal values of old growth trees is outside the scope of this FEIS. Old growth retention is addressed in a variety of ways by the alternatives. Each of the alternatives provides for some level of retention for old growth areas and associated resources. All alternatives comply with the interim direction for protection of California spotted owl by retaining green trees over 30 inches diameter at breast height (DBH) in suitable California spotted owl habitat.

Public Concern: The FEIS should provide specific criteria to define hazard trees and when they will be removed.

Such determinations and analysis are most appropriately made at the site-specific level. The definition of criteria for the identification of hazard trees is beyond the scope of this FEIS. The Pacific Southwest Region recently issued direction regarding hazard tree identification and removal.

Public Concern: The FEIS should analyze and account for effects of salvage sales already under contract on implementation of the pilot project in eastside forests.

The pilot project term is 5 years. During the first years, planning and implementation be coordinated around existing projects. Site-specific planning will examine many variables before implementation including: (1) location of defensible fuel profile zones, (2) location of group selections, and (3) the location of areas where stocking reduction is needed. Recently thinned areas would be low priority for additional treatment, unless the additional treatment was needed to meet management objectives. Site-specific environmental analysis by an interdisciplinary team will determine needs.

Public Concern: The FEIS should include an alternative in Rangeland Renewable Resource Planning Act and National Forest Management Act growth requirements are applied to harvest prescriptions.

The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the National Forest Management Act of 1976 contains direction pertaining to forest planning, offering timber sales, and other topics. No specific mention is made of growth requirements for individual stands with respect to thinning. The Forest Plans allow use of a full range of silvicultural practices to meet management objectives. Local managers have discretion to implement management practices for individual projects, which are more restrictive than Forest Plan direction. No specific standards and guidelines regarding this matter have been included in the FEIS.

Public Concern: The Forest Service should require that timber companies replant harvested areas.

Funds are collected under the authority of the Knutson-Vanderberg Act of 1930 requiring purchasers of national forest timber make deposits to finance reforestation and other sale area improvements. The Forest Service uses these funds to accomplish reforestation planting (often through service contracts). When the need for reforestation is created by timber harvest other than salvage, the Knutsen-Vandenberg collection is considered essential and the sale value must support the cost of reforestation. When the need for reforestation results from a natural phenomena, such as fire or insect epidemic, the salvage sale value does not have to support the cost of reforestation. Congressionally appropriated funds may then be requested to finance reforestation needs including planting.
 
 

Special Interest and Resource Natural Areas
A few respondents, believing that protection of botanical Special Interest Areas was overlooked in the DEIS, ask that it be addressed in the final EIS.

Public Concern: Alternatives in the FEIS should protect botanical Special Interest Areas and Research Natural Areas.

Common to all alternatives analyzed in the FEIS is the exclusion of the eleven Special Interest Areas and Research Natural Areas already designated in the Forest Plans for the Lassen, Plumas, and Tahoe National Forests. In addition, all proposed Special Interest Areas on the Plumas National Forest, 12 new areas and 2 expansions, are excluded from the resource management activities described in Alternatives 1 through 5.

Noxious Weeds
The primary concern expressed about noxious weeds is a request made by some respondents to tier the FEIS decision to the range-wide noxious weed strategy being developed for the Sierra Nevada Ecosystem Project.

Public Concern: The Record of Decision should tier defensible fuel profile zone construction activities to the range-wide noxious weeds strategy approved as part of the Sierra Nevada Conservation Framework Record of Decision (ROD).

The Responsible Officials and the Interdisciplinary Team have coordinated with the Sierra Nevada Conservation Framework on noxious weed strategies, and believe that the proposed standards and guidelines for noxious weeds in the FEIS are consistent with the Sierra Nevada Conservation Framework proposal. The Sierra Nevada Conservation Framework is still in the environmental analysis phase. No Record of Decision has been completed for that analysis. The National Environmental Policy Act provisions for adoption, incorporation by reference, and tiering, are not applicable until such time as a Record of Decision exists for the Sierra Nevada Conservation Framework proposal.

Public Concern: The FEIS should address the introduction and spread of non-native plant species and allocate funding for noxious weed control.

We agree that noxious weed and non-native invasive plant species are a concern in the pilot project area, and that these species would likely increase because of soil disturbance from mechanical entry and other resource management activities. The Noxious Weed section of the Environmental Consequences in the FEIS and Appendix G discuss potential effects.

Amendments to establish standards and guidelines for noxious weed prevention and control are included for Alternatives 2 through 5. These new standards and guidelines will be implemented in addition to any mitigation measures determined necessary during site-specific analysis. Funding for specific pilot project area inventory, noxious weed treatment, and monitoring are included in the cost analysis. Funding for noxious weed work not associated with specific project implementation is beyond the scope of this analysis.

Wildlife Resources
Protection of wildlife and habitat are issues for many people who submitted comments on the DEIS. Many indicate they understand the Forest Service’s mandate to implement the Act and ask that the Forest Service to implement the Act in a way that will protect wildlife and the environment. Declining wildlife populations are a signal that management practices must be reviewed, one person writes, and several others remind the Forest Service of its responsibility to ensure the viability of all species living in the forests. Some people are concerned about preserving biodiversity. The Forest Service should choose an alternative based on the Sierra Nevada Ecosystem Project Report, one writes, to protect not only aesthetic values but also species diversity in the forests.

Although most comments regarding wildlife are general, a few ask the Forest Service to consider the needs of specific animals. Several people are concerned about declining deer populations and would like Forest Service management activities under the FEIS to benefit deer and their habitat in early successional vegetation communities. Conducting controlled burns, protecting riparian areas, and eliminating herbicide spraying would all benefit deer, they believe. One respondent is concerned about the western pond turtle and asks the Forest Service to consider its special habitat needs. Because the turtle nests up to ¼ mile away from water, this person writes, even the 540-foot riparian buffers in Alternative 5 provide inadequate habitat protection.

Some people think an important step in protecting wildlife species is conducting assessments and surveys to learn more about them. The Forest Service should complete a comprehensive wildlife survey and update it regularly, writes one respondent. Another person calls for the collection of more specific data on "biodiversity, critical species, habitat integrity, ecological complexity . . . and monitoring." Perhaps rare species are not really rare, an individual suggests; maybe they are just never seen because too few biologists are in the field. "Closer relationships with people who live and work in the forest would probably reveal more sightings," this person writes.

Although many people express concern regarding impacts from Alternative 2'on wildlife and habitat, many also say they believe Alternative 2 will benefit wildlife. Some think Alternative 2 will ensure better water quality, and as a result, healthier salmon populations.

Public Concern: The Forest Service should consider the effects to wildlife species resulting from the pilot project and implement the pilot project in a manner that protects wildlife and its habitats. Of special concern are species viability, biodiversity, and potential effects on deer, and the northwestern pond turtle. The analysis should also recognize any benefits to wildlife of implementing the project.

The potential effects, both positive and negative, to species such as deer, bear, and other management indicator species is discussed in Chapter 3. The potential effects to threatened, endangered, and sensitive species, including the northwestern pond turtle, are considered in the Biological Assessment/Biological Evaluation and are summarized in Chapter 3. Each alternative was evaluated as to the risks associated with high severity fire, with those alternatives that provided more protection being considered more beneficial to threatened, endangered, and sensitive species, as described for each in the Biological Assessment/Biological Evaluation located in the planning files.

Public Concern: The Forest Service should conduct comprehensive wildlife surveys and assessments.

The need for wildlife surveys is assessed at the site-specific level. When needed, these surveys are conducted using established protocols. Wildlife surveys are documented in a site-specific Biological Assessment/Biological Evaluation. The placement of defensible fuel profile zones and other activities will be determined at the site-specific level, where a more in-depth analysis of effects on all species, including forest carnivores, will be completed and documented in a site-specific biological evaluation. This analysis, in turn, will be subject to environmental analysis and will receive further public participation.

Public Concern: The Forest Service should contact people who live and work in the forest for information on wildlife sightings.

Many of the wildlife sightings in the Lassen, Plumas, and Tahoe National Forest databases are from interested members of the public. These sightings may be significant during implementation of the proposal as information with particular relevance to site-specific decisions. However, they are site-specific and are more useful during site-specific analysis than at the programmatic-level of this FEIS.

Neotropical Migratory Birds
Compliance with the Migratory Bird Treaty Act and disclosure of potential effects of increasing cowbird populations on neotropical migrants and other birds were topics of concern for a few respondents. They argue the DEIS did not adequately account for potential effects on neotropical migrants.

Public Concern: The FEIS should analyze the effects of the pilot project on neotropical migratory birds.

The overall effects to neotropical migrants are discussed within Chapter 3. The analysis recognized that some neotropical migrants, or land birds, prefer more open habitats and others require denser stands. Appendix I contains an analysis generated from the Wildlife Habitat Relationships Program. Changes in species habitat suitability values for implementation of defensible fuel profile zones and group selection harvests are displayed. Within the Appendix I analysis is list of the neotropical migrant species that occur in the pilot project area. Analysis for neotropical migrants is best accomplished at a level where site-specific factors can be considered. The monitoring section of the FEIS includes monitoring of land birds (including neotropical migrants), to determine bird responses to the proposed resource management activities.

Public Concern: The FEIS should address the pilot project's compliance with the Migratory Bird Treaty Act.

The Migratory Bird Treaty Act was established to address the issue of poaching migratory birds. Under the Migratory Bird Treaty Act, except as permitted by regulation, it is unlawful at any time, by any means, or in any manner to pursue, export, import, transport, or carry any migratory bird. The Forest Service will not be engaging in any of these activities. The Migratory Bird Treaty Act was also intended to apply to individuals; the Forest Service is an entity, not a person. Implementing resource management activities during the avian breeding season was identified in the FEIS as a potential adverse impact to nesting birds.

Public Concern: The FEIS should disclose potential increases in and impacts from brown-headed cowbird populations because of the proposed action.

The resource management activities were analyzed as to potential impacts on brown-headed cowbird populations in the context of impacts to willow flycatchers. This information is documented in the Biological Assessment/Biological Evaluation. An additional analysis, using the Wildlife Habitat Relationship Program, indicated a slight increase in brown-headed cowbird habitat values (from low to moderate) as a result of thinning and opening up stands consistent with defensible fuel profile zone implementation. This increase in habitat value could potentially increase brown-headed cowbirds, and subsequent nest parasitism, within the pilot project area.

Public Concern: The Forest Service should consider the impacts of declines in habitat and opening forest canopies on warblers under the FEIS.

The overall effects to neotropical migrants is discussed within Chapter 3. The analysis recognized that some neotropical migrants, or land birds, prefer more open habitats and others require denser stands. Shrub cover is another important component that must be considered. However, as the Sierra Nevada Ecosystem Project also points out, Stellar's jay populations are declining as well; therefore, effects to these predatory species are also a concern. Such analysis is better accomplished at the level where site-specific factors can be considered. Appendix I of the FEIS contains an analysis generated from the Wildlife Habitat Relationships Program. Changes in species habitat suitability values for implementation of defensible fuel profile zones and group selection harvests are displayed. The analysis indicates that warbler species that occur in the pilot project area. Creation of defensible fuel profile zones results in no change in habitat values for the warblers mentioned, except for a minor increase in value for the Nashville warbler. Creation of group selection harvest openings results in declines in habitat suitability for Macgillivrays and Hermit warblers, and neutral effects for the other species.

Threatened and Endangered Species
Most comments regarding rare species refer to sensitive species people fear may become endangered, rather than species already designated as endangered or threatened. This section contains the few comments referring specifically to endangered or threatened species. The Forest Service must protect these species from road building, logging, and habitat loss, some people believe. One respondent asserts that the agency, "even if implementing poorly thought-out legislation such as this," must still comply with the Endangered Species Act. Forest Service actions show a disregard for endangered wildlife and their habitats, according to another, and will cause the listing of even more species. Some would like the FEIS to include an analysis of the effect of increased timber harvest on endangered species.

Public Concern: The Forest Service should protect endangered species. The FEIS should analyze the effects of increased logging on endangered species.

The Endangered Species Act requires the Forest Service protect endangered species and their critical habitat. The assessment of effects to endangered species by resource management activities described in the FEIS is documented in the Biological Assessment/Biological Evaluation. This assessment resulted in a determination of not likely to adversely affect endangered species for any of the alternatives, as documented in the Biological Assessment/ Biological Evaluation and Chapter 3 of the FEIS.

Public Concern: The Forest Service should protect endangered plant species. The FEIS should analyze the effects of increased logging on endangered plant species.

The Biological Assessment for Threatened and Endangered Plants, located in the planning file, addresses the impacts of the pilot project on known threatened and endangered plant species. This assessment includes analysis of potential effects on plants resulting from. Forest Plan direction for the Lassen, Plumas, and Tahoe National Forests is to maintain the viability of threatened and endangered plant species. Before site-specific projects are implemented, surveys will occur and management direction for protection will be applied. By protecting the locations of threatened and endangered plant occurrences, species viability will be maintained. In addition, the FEIS monitoring plan identifies post-project evaluation, including monitoring of the effectiveness of protection measures. Monitoring includes sampling rare plant occurrences for condition and trend of both the population and habitat before and after treatment. When monitoring identifies concerns, adaptive management modifications will be recommended.

Public Concern: The FEIS should identify when surveys for rare plants will be conducted under each of the alternatives.

The need for plant surveys is determined at the site-specific level where habitat can be assessed and a determination made with respect to plant surveys. If suitable habitat is identified for any threatened, endangered, or sensitive plants assessment of the need for surveys based on the plant species and recent surveys in the area will be completed. The FEIS is a programmatic document and does not identify implementation locations; therefore, an accurate assessment of survey needs cannot be provided at this strategic analysis level. The Rare Plant Biological Assessment and Biological Evaluation discusses the risk to these species according to habitat type.

Public Concern: The Forest Service should avoid altering the habitat of recently delisted species.

The Forest Service is required by law to protect endangered species and their critical habitat. The assessment of the effects to endangered species by resource management activities described in the FEIS are documented in the Biological Assessment/Biological Evaluation. This assessment resulted in a determination of not likely to adversely affect endangered species for any of the alternatives, as documented in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. Specific to the bald eagle and the peregrine falcon, these species are still listed species, thus they are still subject to the Endangered Species Act and consultation with the USDI Fish and Wildlife Service for any resource management activity that could affect habitat. Consultation with the US Fish and Wildlife Service regarding the pilot project has been ongoing and is documented within the Biological Assessment/Biological Evaluation and the FEIS. It is expected that delisting will occur within one year. Management of these species would then be subject to new guidelines that may come forward after delisting.

Sensitive Species
Sensitive species, especially those that appeared in the June 10, 1998, Pacific Southwest Region list, are the primary concern of people who submitted comments on wildlife. These people want the FEIS to include a full viability assessment for sensitive species in the pilot project area. This assessment, some assert, should include an analysis of existing habitat and species habitat needs. In addition, a conservation organization writes, the FEIS must also analyze cumulative impacts of the pilot project in conjunction with other past, current, and reasonably foreseeable future actions. One person recommends that all available scientific information, including the Sierra Nevada Ecosystem Project Report, be compiled to form a single management strategy to protect the Sierran sensitive species.

Many people are concerned with potential habitat fragmentation resulting from implementation of the pilot project and specifically, the construction of defensible fuel profile zones that they believe will reduce habitat connectivity and endanger the survival of sensitive wildlife species, and their effects may violate legal mandates regarding species survival. Any reduction in suitable habitat for these species is unacceptable, asserts one person who believes these habitats should be kept intact. In contrast, another believes habitats should not be set aside for protection based on questionable scientific information.

Between the two preferred alternatives, one person states, Alternative 4 is superior because it provides more habitat protection. Others believe the Forest Service should delay any implementation of the pilot project until the USDI Fish and Wildlife Service determines whether to list Pacific fisher, American marten, California spotted owl, or other sensitive species as endangered or threatened.

Public Concern: Analysis for the FEIS should include a full viability assessment and habitat analysis for sensitive species.

A habitat analysis for sensitive species has been conducted and is described in the Biological Assessment/Biological Evaluation. Managers rarely have all the information needed to conduct a fully quantitative population viability analysis. This is true for all the sensitive species present in the pilot project area. As a substitute for this missing information, a practical alternative is to use inventories of species distribution and suitable habitat (quality and quantity) in assessing potential impacts to habitat. This allows for a review of the potential affects to individuals and those activities that might result in a potential decline in species numbers and distribution that increases the risk for a loss of viability. The Biological Assessment/Biological Evaluation describes the potential effects of the resource management activities on the suitable habitat for each sensitive species that could be present in the pilot project area. Based on the various analyses, the determinations indicate that species viability would be maintained for all sensitive species with the exception of the California spotted owl if Alternatives 1 or 2 are implemented.

Public Concern: The Forest Service should adopt a single management strategy to support and enhance populations of sensitive wildlife species in the Sierra.

This public concern is beyond the scope of the project. Adoption of such a management strategy appropriately occurs at the Regional or National levels of the Forest Service. The concurrent Sierra Nevada Framework environmental analysis is partially addressing this concern with specific reference to California spotted owl, furbearers, riparian-dependent species, and sensitive species. Strategies for enhancing sensitive species populations identified by the Sierra Nevada Framework environmental analysis may affect site-specific decisions made during the implementation of the pilot project.

Public Concern: The Forest Service should recognize that implementation of Act will result in fragmentation of sensitive species habitat.

Fragmentation of sensitive species habitat and habitat connectivity was addressed and described in the Biological Assessment/Biological Evaluation and is summarized in Chapter 3 of the FEIS for California spotted owl, American marten, and Pacific fisher.

Public Concern: The Forest Service should protect suitable habitat for sensitive wildlife species by selecting an alternative that provides more habitat protection for them.

The Forest Service agrees that protection of habitat important to sensitive species needs to be carefully considered. The effects to habitat were considered in the Biological Assessment/

Biological Evaluation and are summarized in Chapter 3. Alternatives 3, 4, and 5, provide additional habitat protection for sensitive species.

Public Concern: Lands should be set aside for wildlife species only when based on solid data and documentation.

Currently when lands are set aside or otherwise protected for wildlife, such actions are based on solid data and documentation. These set-aside areas may be considered based on nest sites, species presence, and known habitat requirements (as for protected activity centers and spotted owl habitat areas) nest territories, eagle winter roosts, forest carnivore habitat networks, or other reasons. Protected activity centers described in Alternative 5 are based on data and documentation or information gathered during site-specific surveys.

Public Concern: The Forest Service should protect suitable habitat for sensitive plant species, and select an alternative that provides more habitat protection for them.

Information about management of sensitive plants in the pilot project area is found in the Sensitive Plant Biological Evaluation/Biological Assessment. In summary, current management direction for sensitive plant species is to maintain species viability throughout their geographic ranges. (Refer to the Forest Plan direction for sensitive plants.) Little is known about many sensitive plant species. When ecological requirements for sensitive plants are not known, maintaining species viability is best accomplished by buffering occurrences from direct or indirect impacts. As ecological requirements are better understood, conservation strategies for a sensitive plant or group of plants are developed to outline management prescriptions for those plants. These conservation strategies include plans for maintaining these plants across the landscape and provide strategies for protection of suitable habitat and overall species viability. Each conservation strategy is based on best available data and documentation and requires a signed decision document. Conservation strategies are not available for many of the sensitive plants known or suspected to occur on in the pilot project area.

Public Concern: Lands should be set aside for plant species only when based on solid data and documentation. Analysis for the FEIS should include a full viability assessment and habitat analysis for sensitive plant species.

It is recognized that past and current activities have altered sensitive plant occurrences and their habitats in the pilot project area. It is also recognized that implementation of timber harvest, fuels management, and restoration activities could cumulatively add to these impacts. Current management direction is designed to eliminate or reduce negative cumulative impacts.

A critical step in cumulative effect analysis is to compare the current condition of the resource to projected changes resulting from management activities and natural variability. This is difficult for sensitive plants because long-term data are often lacking, and many sensitive plant habitats have a long history of disturbance (an undisturbed reference is often lacking). Minimizing onsite changes to sensitive plants is an effective way of reducing cumulative impacts, including viability concerns. If adverse effects are minimized or reduced at the local scale, it follows that there will be a greatly reduced potential for larger-scale effects.

Alternatives 2 through 5 include direction to survey for sensitive plants and follow current management direction for plants as they are found. An effects analysis is a part of the biological evaluation process and is required in cases where sensitive plants are found in or near site-specific treatment areas. As stated in the Biological Assessment/Biological Evaluation, the pilot project area has known occurrences of sensitive plants and unsurveyed potential habitat. Effects to sensitive plants will be evaluated site-specifically and management direction will be followed. In summary, implementation of Alternatives 2 through 5 requires that direct, indirect or cumulative impacts to sensitive plants that could cause reduced viability across the landscape must be site-specifically avoided.

Public Concern: The Forest Service should delay implementing the FEIS until the USDI Fish and Wildlife Service determines whether to list Pacific fisher, American marten, and California spotted owl as threatened or endangered species.

A determination of threatened or endangered status for any plant or animal species that occurs with the planning area covered will affect the decision, regardless of whether it is received before or after implementation begins. The Forest Service considered potential for listing in during this analysis and will modify the decision as needed to comply with the protection of listed species as afforded under the Endangered Species Act. A listing could result in a direct modification of the decision, the overlay of a regional or national forest level recovery strategy, and modification of site-specific decisions. At the very least, a listing would result in thorough analysis and consideration of the potential effects of a decision on the relevant species.

Public Concern: The absence of a population viability analysis for California spotted owl, Pacific fisher, and American marten should be remedied. Without it, the FEIS is fatally flawed.

A viability assessment could be forthcoming from the Sierra Nevada forest plan amendment environmental analysis, also known as the Sierra Nevada Framework Project. This assessment will include the potential effects on habitat by the proposed resource management activities of the pilot project. The timelines are such that the Congressionally mandated completion date for this FEIS (August 17, 1999), will occur before a viability assessment will be completed by the Framework environmental analysis. A habitat analysis for California spotted owl, Pacific fisher and American marten has been conducted and is described in the Biological Assessment/ Biological Evaluation.

Managers rarely have all information needed to conduct a fully quantitative population viability analysis. This is true for the California spotted owl, Pacific fisher and American marten. As a substitute for this missing information, a practical alternative is to use inventories of species distribution and inventories of the quality and quantity of suitable habitat, and then assess the potential impacts to habitat. This allows for a review of the potential effects to individuals and those activities that might result in a potential decline in numbers and distribution, which increases the risk for a loss of viability. The Biological Assessment/Biological Evaluation describes the potential effects of resource management activities on suitable habitat for California spotted owl, Pacific fisher, and American marten. Based on the analyses, the determinations indicate that species viability would be maintained for all sensitive species; the exception being the California spotted owl if Alternatives 1 or 2 are implemented.

Public Concern: The FEIS should analyze the effects of defensible fuel profile zone construction on sensitive ridgetop plant communities.

The effects to rare plant communities were assessed in the Plant Biological Assessment/ Biological Evaluation available in the planning file. These documents looked at the different communities that support rare plants and the effects that may occur due to the implementation of the resource management activities described in each alternative.

Public Concern: The pilot project should initiate formal Endangered Species Act consultation before implementation.

The Forest Service has worked closely with the staff of the USDI Fish and Wildlife Service throughout the development of the DEIS and FEIS. On June 14, 1999 a copy of the Biological Assessment/Biological Evaluation, and the DEIS were delivered to the USDI Fish and Wildlife Service. On June 15, 1999, the Forest Service requested informal consultation on the proposed pilot project. On August 3, 1999, the USDI Fish and Wildlife Service provided a written response that discussed specific issue areas and concerns identified in the DEIS, and also provided management recommendations regarding Federally listed species, and non-listed species of concern identified as at risk in the Sierra Nevada. The USDI Fish and Wildlife Service provided this letter and recommendations to meet the timelines for the completion date of August 17, 1999, mandated by the Act. The USDI Fish and Wildlife Service will complete the formal consultation process by October 27, 1999, with the completion of its Biological Opinion.

For anadromous fish species, consultation with the Department of Commerce National Marine Fisheries Service has been ongoing since enactment of the Act. On June 11, 1999, a letter was sent to the Department of Commerce National Marine Fisheries Service to initiate consultation and request concurrence on the consultation process for the pilot project. Based on preliminary discussions with the Department of Commerce National Marine Fisheries Service, it was concluded that Endangered Species Act obligations for consultation at the programmatic level for the pilot project were met under Forest Plan level consultation completed previously. To meet Endangered Species Act obligations at the site-specific level; however, site-specific assessments will be conducted and consulted on as individual projects are evaluated.

California Spotted Owl
California spotted owl populations are already declining, according to some people, and they believe the proposed action will only make the situation worse. Several conservation organizations believe listing under the Endangered Species Act may be imminent. In this light, many ask the Forest Service to delay releasing the FEIS until a viability assessment for the California spotted owl is complete. One respondent insists that anything else constitutes "an unacceptable disregard for the need to proceed with utmost caution in light of the owl’s precarious status." Some believe the Forest Service should be strengthening protection for the California spotted owl and its habitat, not reducing it; even the California Spotted Owl Environmental Assessment doesn’t do enough, they say. They think the Forest Service should select Alternative 5 because it produces the least habitat fragmentation and provides the greatest protection of snags and California spotted owl designated protected activity centers and spotted owl habitat areas.

New scientific information, the adequacy of existing information, and the analysis of data on the California spotted owl are all topics many people feel should be assessed or re-assessed for the FEIS. These respondents do not believe the DEIS provides enough information on the status of the California spotted owl, its habitat needs, and the effect of implementation on California spotted owl population trends. The level of activity proposed in some alternatives leads them to question whether adequate nesting, foraging, and dispersal habitat can be maintained to ensure a viable California spotted owl population.

Public Concern: The FEIS should address recent evidence of declining California spotted owl populations in the Sierra Nevada.

The four demographic studies conducted for California spotted owl in the Sierra Nevada were considered in the analysis of alternatives and documented in the Biological Assessment/ Biological Evaluation. Results are summarized in Chapter 3 of the EIS.

Public Concern: The FEIS should analyze the effects of increased logging on the California spotted owl.

The effects of all resource management activities proposed by the Act on California spotted owls were analyzed and documented in the Biological Assessment/Biological Evaluation and summarized in Chapter 3 of the EIS.

Public Concern: The Forest Service should delay release of the FEIS until a viability assessment is completed for the California spotted owl.

It is assumed this public concern refers to a viability assessment that might be forthcoming from the Sierra Nevada forest plan amendment environmental analysis currently ongoing. The timelines are such that the mandated completion date of August 17, 1999, will occur before a viability assessment will be completed by the Framework environmental analysis. A habitat analysis for California spotted owl has been conducted and is described in the Biological Assessment/Biological Evaluation.

Managers rarely have all information needed to conduct a fully quantitative population viability analysis. This is true for the California spotted owl. As a substitute for this missing information, a practical alternative is to use inventories of California spotted owl distribution and the quality and quantity of suitable California spotted owl habitat, and then assess the potential impacts to habitat. This allows for a review of the potential affects to individuals and those activities that might result in a potential decline in California spotted owl numbers and distribution, which increases the risk for a loss of viability. The Biological Assessment/Biological Evaluation describes the potential effects of the resource management activities on suitable California spotted owl habitat. Based on the various analyses, the determinations indicate that species viability would be maintained for all sensitive species, except the California spotted owl if Alternatives 1 or 2 are implemented.

Public Concern: The Forest Service should strengthen protection for the California spotted owl and its habitat.

The alternatives provide a range of habitat protection for California spotted owl. They were analyzed for their effects on California spotted owl habitat. Alternatives 1 and 2 implement interim direction for the protection the California spotted owl. Alternatives 3 and 4 implement the interim direction and were designed to maximize retention of suitable California spotted owl habitat over the pilot project period, while providing for resource management activities designed to reduce the threat of high severity fire. Alternative 5 was designed to maintain at least 50 percent of each California spotted owl home range in suitable habitat.

Public Concern: The Forest Service should implement an alternative that protects California spotted owl habitat by reducing the risk of stand destroying wildfire.

The Forest Service agrees with this public concern. All alternatives are analyzed as to their effect on reducing the risk of stand destroying fire, and effectiveness of each alternative in protecting California spotted owl habitat. This is documented in the Biological Assessment/ Biological Evaluation and Chapter 3 of the FEIS.

Public Concern: The Forest Service should implement Alternative 5 to protect the habitat needs of spotted owl populations.

The alternatives were analyzed for their effects on California spotted owl habitat. The effects of each alternative, in terms of direct impacts and protection of California spotted owl habitat, are documented in the Biological Assessment/Biological Evaluation and summarized in Chapter 3 of the EIS.

Public Concern: The Forest Service should consider new scientific findings on California spotted owls when preparing the FEIS.

The four demographic studies conducted for California spotted owls in the Sierra Nevada were considered in the analysis of the alternatives, and documented in the Biological Assessment/ Biological Evaluation. Results are summarized in Chapter 3 of the FEIS. The findings from these studies, including the demographic study conducted on the Lassen National Forest, were used as a basis for the analysis, and subsequent alternative development (Alternatives 3 and 4) and ultimately the determination of effects.

Public Concern: The pilot project should not adversely affect California spotted owl or its habitat, thereby failing to ensure viability and contributing to a trend towards listing.

The Biological Assessment/Biological Evaluation analyzed the potential effects to California spotted owl habitat associated with each of the alternatives considered. The Biological Assessment/Biological Evaluation made a determination for each alternative and provides the reason for the finding, as documented in Chapter 3 of the FEIS. Alternatives 3, 4, and 5 do not warrant a finding of causing a trend towards listing.

Managers rarely have all the information needed to conduct a fully quantitative population viability analysis. This is true for all the sensitive species present in the project area. As a substitute for this missing information, a practical alternative is to use inventories of species distribution and suitable habitat (quality and quantity) in assessing the potential impacts to habitat. This allows for a review of potential effects to individuals and those activities that might result in a potential decline in species numbers and distribution, which increases the risk for a loss of viability. The Biological Assessment/Biological Evaluation describes the potential effects of the resource management activities on the suitable habitat for California spotted owls in the pilot project area. Based on the various analyses, the determinations indicate that species viability would be maintained for all sensitive species, the exception being the California spotted owl if Alternatives 1 or 2 are implemented. Alternatives 1 and 2 were considered to have sufficient adverse affects to warrant a trend towards Federal listing for the California spotted owl.

Public Concern: The quantity and quality of nesting and foraging habitat for California spotted owls should not be reduced by projects carried out under the FEIS; the quality of dispersal habitat for juvenile California spotted owls should not be reduced by projects carried out by the FEIS.

The anticipated effects to nesting and foraging habitat were analyzed in the Biological Assessment/Biological Evaluation and summarized in Chapter 3 of the FEIS. Each alternative has a different effect on the amount and quality of these habitats and the effects are displayed in the Biological Assessment/Biological Evaluation and Chapter 3. Alternatives 3 , 4 and 5 were developed by the Interdisciplinary Team to maintain the existing quantity of California spotted owl nesting and foraging habitat. Site-specific analysis will be needed to describe the effects in terms of tree size and a more accurate assessment of changes in canopy closure. Site-specific analysis will also provide a more accurate assessment of the changes in the quality of nesting and foraging habitat.

Public Concern: Projects carried out under the FEIS that accelerate population declines should not result in a reduction of suitable habitat in California spotted owl home ranges.

The Biological Assessment/Biological Evaluation and the FEIS include an analysis that shows the impacts of each alternative on the amount of suitable habitat found in California spotted owl home ranges. The Bart study was used as the basis for this analysis. Alternatives 1 and 2 show decreases in the amount of home ranges supporting more than 50 percent suitable habitat. Alternatives 3, 4, and 5 maintain the current number of home ranges that support more than 50 percent suitable habitat. Alternative 5 was designed to maintain home ranges in at least 50 percent suitable habitat (if currently present).

Public Concern: The FEIS should not increase logging and fragmentation in California spotted owl areas of concern.

Fragmentation of sensitive species habitat and habitat connectivity were addressed and described in the Biological Assessment/Biological Evaluation and summarized in the FEIS for California spotted owl, American marten, and Pacific fisher. Fragmentation of habitat within the areas of concern identified by the California Spotted Owl Technical Report were also addressed in both documents. Increased fragmentation of habitat due to site-specific project implementation was identified as a potential problem for area of concern 1 and 3.

Public Concern: The FEIS should not result in an increase in nearest neighbor distance for protected activity centers and spotted owl habitat areas.

Impacts to nearest neighbor distance between protected activity centers and spotted owl habitat areas were discussed in the Biological Assessment/Biological Evaluation. Because protected activity centers and spotted owl habitat areas are not directly affected by resource management activities from the pilot project, there should be no change in this distance between with any alternative. A reduction in habitat quality and quantity between protected activity centers and spotted owl habitat areas, including habitat in home ranges associated with each protected activity center and spotted owl habitat area, could reduce California spotted owl densities, limiting successful mate finding, dispersal, and increasing nearest neighbor distance. Alternatives 1 and 2 will decrease the quantity of suitable habitat between protected activity centers and spotted owl habitat areas, possibly increasing the nearest neighbor distances. Maintaining existing suitable California spotted owl habitat with Alternatives 3, 4, and 5 should not increase the mean nearest neighbor distance between California spotted owl pairs.

Public Concern: The California Spotted Owl interim Guidelines are inadequate to ensure California spotted owl viability and should not be used.

The Forest Service agree that this interim direction is not intended to ensure long-term California spotted owl viability. The Biological Assessment/Biological Evaluation discloses this fact. The Act contains direction to comply with "the standards and guidelines for the conservation of the California spotted owl as set forth in the California Spotted Owl Sierran Province Interim Guidelines ,or the subsequently issued guidelines, whichever are in effect." For this reason, the interim direction guidelines were used in the analysis. The analysis of effects to California spotted owl were not limited to compliance with the interim direction, because several habitat factors, including impacts to the quantity and quality of suitable California spotted owl habitat across the project area and in individual home ranges was analyzed.

Public Concern: The FEIS should not rely on protected activity centers and spotted owl habitat areas as adequate management strategies for the California spotted owl.

The Act contains direction to comply with "the standards and guidelines for the conservation of the California spotted owl as set forth in the California Spotted Owl Sierran Province Interim Guidelines, or the subsequently issued guidelines, whichever are in effect." Protected activity centers and spotted owl habitat areas form the foundation for managing California spotted owl habitat in the Sierra Nevada. It is beyond the scope of this FEIS to develop new California spotted owl strategies that replace the interim direction guidelines. The FEIS considered new information, along with the interim direction guidelines, and developed Alternatives 3 and 4 to provide for the retention of suitable habitat that exceeds the interim direction guidelines in terms of habitat protection.

Public Concern: The pilot project fails to comply with interim direction for the protection of California spotted owls and will not ensure California spotted owl viability.

The Forest Service disagrees. All alternatives comply with the interim direction guidelines. A statement of compliance with can be found in the FEIS. The Forest Service agrees that the California spotted owl interim guidelines are not intended to ensure long-term owl viability. The Biological Assessment/Biological Evaluation discloses this.

Public Concern: The FEIS should address compliance with California Spotted Owl Interim Guidelines.

The FEIS states that all alternatives comply with the direction in the California Spotted Owl Interim Guidelines. The effects of meeting the guidelines are summarized in the Appendix AA and the Biological Assessment/Biological Evaluation located in the planning file.

Public Concern: The FEIS should include adequate disclosure of impacts on California spotted owl habitat (impacts to 20 to 30 inch trees, impacts of incremental reductions in habitat quality, and failure to account for all nesting habitat).

Impacts to California spotted owl habitat, including potential reductions in the quality and quantity of suitable nesting and foraging habitat across the pilot project area, and in home ranges, was analyzed and disclosed in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. Impacts to habitat components most important for California spotted owls, such as large trees, large snags, down woody material, and canopy cover, were also analyzed and documented within the Biological Assessment/Biological Evaluation and Chapter 3. In addition, habitat connectivity and fragmentation were discussed.

For all resource management activities, impacts to 20 to 30 inch trees were discussed in terms of compliance with the interim direction guidelines for basal area retention in the largest trees for "selected" and "other" strata. The trees to be retained will be determined through site-specific data collection, such as Forest Inventory Analysis plot information and the development of basal area curves. The actual impacts to trees in this size class will depend on the treatment prescription, including any upper limit diameter calculations (to meet interim direction guidelines).

The interim direction guidelines define "selected" strata as strata preferentially selected for nesting by owls. "Other" strata is used by owls, but not preferred for nesting. All "selected" timber strata are considered to be suitable for nesting. California spotted owls also nest in "other" strata (M3N/M3G) in aggregations of "selected" strata that are too small for individual mapping. It is recognized these large tree clumps in foraging habitat provide habitat attributes preferred by California spotted owls, but at the scale used for the FEIS, such areas cannot be clearly displayed. Such areas can be displayed at the site-specific level where silvicultural inventories provide better site-specific data. The analysis of the impacts by the alternatives on suitable nesting and foraging habitat was based on California Wildlife Habitat Relationship types. The M3N/M3G strata types fall in the size class of California Wildlife Habitat Relationship 4N/4G. The figures used to estimate the acres of suitable nesting and foraging are considered sufficiently accurate to predict effects for purposes of this analysis. Site-specific analysis is still required where actual strata will be defined and the impacts analyzed and documented in a site-specific biological evaluation.

This programmatic FEIS considers the cumulative (incremental) loss of habitat as an overall effect of the action. Incremental reductions in habitat would be analyzed as part of the cumulative effects analysis at the site-specific level to provide a more accurate assessment of the effects of incremental reductions in habitat.

Public Concern: The FEIS should reconcile or account for differences in California spotted owl and pilot project habitat type projection.

Table 3.19 in the DEIS was revised. In Chapter 3 of the FEIS, new figures were included. All numbers were generated from SPECTRUM, a linear program model that models, among other items, vegetation changes through time. The management prescriptions and objectives were coded in for each alternative. The alternatives designed for this FEIS are unique.

Alternative 5 still shows (for most decades) less California Wildlife Habitat Relationship size 5 than the other alternatives. The difference is much less than originally displayed in the DEIS. Alternative 5 has the least amount of mechanical treatment acres. Growth into larger tree and stand sizes for acres mechanically treated will be more rapid.

Alternative 5 and size 6 stands are a different matter. Size 6 stands are characterized as multi-layered. Under the different alternatives, the effects on this stand structure differ as the revised data shows. For example, in decade 3, the revised data shows Alternative 5 to have the most size 6 acres.

Northern Goshawk
Believing analysis of the effects of alternatives on goshawks is not adequate in the DEIS, several respondents ask for the completion of a viability assessment before a Record of Decision. Protection of nesting areas, effects of the proposal on prey species and their habitat, and cumulative effects of actions are all concerns for these respondents. They cite new management considerations on the Tahoe National Forest, and what they believe is a lack of disclosure for critical assumptions used in the analysis of impacts as evidence of a need to reassess potential effects on goshawks.

Public Concern: The FEIS should provide an adequate analysis of effects on goshawk habitat under each of the alternatives. This should include effects on nesting and foraging habitat.

Following publication of the DEIS, the Biological Assessment/Biological Evaluation and the FEIS were improved to disclose the impacts to goshawk nesting and foraging habitat. Group selection harvest cannot be assessed site-specifically at the programmatic scale of this FEIS. At the time of implementation, a site-specific analysis will be conducted, including an assessment of mitigation needed to reduce impacts to goshawk nesting territories and results will be incorporated in site-specific project layout and design.

Public Concern: The FEIS should better account for the effects of alternatives on goshawk prey species and their habitat.

Chapter 3 and Appendix I provide an analysis of effects of the resource management activities on the changes to habitat values that could occur for a variety of wildlife species. In addition, this analysis was used to determine potential impacts to prey species of certain sensitive species, including goshawks. The Biological Assessment/Biological Evaluation discusses the common goshawk prey species, their preferred habitat, and describes attributes of constitute quality foraging habitat as discussed in Reynolds (1992). These attributes include stand structure diversity in moderately open stands of various age classes. The conclusions in the Biological Assessment/Biological Evaluation are supported in work done by Block et al. (1993). Beier and Drennan (1995) found that goshawks will hunt in open areas where there may be fewer prey individuals, but hunting success is higher.

The Biological Assessment/Biological Evaluation also addressed disturbance and the potential for more human-goshawk interaction. Studies indicate noise does not effect goshawk nesting or most raptors. A number of active goshawk nests reviewed in 1999 on the Almanor Ranger District of the Lassen National Forest were within 150 feet of active roads (Williams, personal communication). Site-specific analysis will address impacts, including noise, if it is identified as a potential affect.

Public Concern: The Forest Service should consider Alternative 5 for protection of goshawk habitat.

The alternatives were analyzed for their effects on goshawk habitat, including Alternative 5. The effects of each alternative, in terms of direct impacts and protection of goshawk habitat are documented in the Biological Assessment/Biological Evaluation and in Chapter 3 of the FEIS and will be considered by the Responsible Officials.

Public concern: New Tahoe National Forest management considerations for goshawk should be addressed in the FEIS.

The new Tahoe National Forest management considerations were identified in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. These management considerations are applicable only for the Sierraville Ranger District portion of the pilot project area.

Public Concern: The FEIS and Biological Assessment/Biological Evaluation should reveal the critical assumption underlying analyses and conclusion: (Definition of a territory, what constitutes prey base, what constitutes medium and high importance habitats, eastside versus westside effects).

For the purposes of this analysis, territories are assumed to be those areas that are managed in accordance with each Forest Plan’s management direction (standards and guidelines) for goshawks (Chapter 3 and Biological Assessment/Biological Evaluation). Each territory is mapped based on site-specific habitat and landscape features.

The most common prey species were identified and impacts addressed in the Biological Assessment/Biological Evaluation. High habitat suitability is provided by those habitat types and stages that provide all requisites for breeding, feeding, and resting, and each was assigned a value in the range of 0.66 to 1.0 in a California Wildlife Habitat Relationships analysis. Moderate habitat suitability provides lesser quality habitat for breeding, feeding, and resting, and receives a value in the range of 0.33 to 0.66 in the California Wildlife Habitat Relationships analysis. These habitat values are further explained in Appendix I.

The analysis of impacts on goshawk habitat, westside (including transition zone) versus eastside was analyzed and displayed within the Biological Assessment/Biological Evaluation and Chapter 3. This was re-displayed following publication of the DEIS.

Public Concern: The Biological Assessment/Biological Evaluation should adequately describe cumulative impacts to goshawk under each alternative.

Cumulative effects require an analysis of the past, present, and reasonably foreseeable future management actions. Due to the programmatic level of this FEIS, a general description of these activities was identified in the Biological Assessment/Biological Evaluation, particularly in terms of impacts from timber harvest, road construction, and fuels treatment on adjacent private lands. The cumulative effects described in the Biological Assessment/Biological Evaluation are common to all alternatives; however, their effects must be considered site-specific level to be adequately displayed in the appropriate context.

American Marten and Pacific Fisher
The needs of Pacific fisher and American marten are combined in the minds of some respondents. Others vehemently oppose any analysis that treats the habitat needs of both animals as one in the same. They ask that analysis of effects of alternatives on Pacific fisher and American marten be conducted separately. Protection for these animals is a concern for many people, and they believe the Forest Service should consider the species needs when locating defensible fuel profile zones. The Forest Service should mitigate defensible fuel profile zone effects on these animals, one suggests, by limiting canopy openings in fuelbreaks that traverse forest carnivore habitat.

Completion of a viability analysis for Pacific fisher and American marten before a Record of Decision, many feel, is vital to ensuring adequate protection and necessary if the agency wants to avoid a trend towards listing. Analysis of the effects of canopy closure, adequacy of denning and foraging habitat, habitat connectivity, and adverse impacts of selective logging are all areas of the DEIS people feel should be improved in the FEIS. Several respondents feel these analyses are critical because, they assert, relying on interim direction for the protection of California spotted owl or Forest Plan direction is inadequate to protect American marten and Pacific fisher.

Public Concern: The FEIS should address the impacts of the pilot project on Pacific fisher and American marten separately.

The habitat requirements for each species were considered separately in the Biological Assessment/Biological Evaluation and summarized in Chapter 3. Habitat overlap, in terms of late-seral attributes (large trees, canopy cover, snags, down woody material), are needs common to both species. Management strategies for both species on the Lassen, Plumas, and Tahoe National Forests at the site-specific level essentially tie the two species together. The forest carnivore networks are designed to provide suitable forest carnivore habitat links across the landscape, protect legacy structural elements of large diameter live trees, snags, and down logs, and provide management guidelines for specific habitat attributes. The Tahoe and Plumas National Forests do not associate specific species with their carnivore networks.

Individual habitat needs for the Pacific fisher and American marten were identified and considered in the Biological Assessment/Biological Evaluation developed for this analysis. At the programmatic level of this FEIS, where specific treatment areas have not been identified, the site-specific effects to habitat cannot be evaluated and are more appropriately considered in a site-specific biological evaluation. For purposes of this analysis, effects to the habitat network were used as a means to predict the effects on forest carnivores. General effects to habitat were considered in terms of the potential loss of snags, down logs, and canopy closures.

Public Concern: The Forest Service should consider the needs of forest carnivores when placing defensible fuel profile zones..

Impacts of resource management activities, including defensible fuel profile zones, on forest carnivore habitat, including habitat networks, were analyzed and documented in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. The site-specific placement of defensible fuel profile zones will be determined at the site-specific level where a more indepth analysis of effects on all species, including forest carnivores, will be completed and documented in a site-specific biological evaluation. Such analyses are subject to public review.

Public Concern: The FEIS should contain a more thorough analysis of the effects of the proposed activities on forest carnivores.

At the programmatic level, an analysis of effects of implementing each alternative on forest carnivores was conducted, displayed in the Biological Assessment/Biological Evaluation, and summarized in the FEIS. The analysis displays direct impacts to habitat in the forest carnivore network, and direct and indirect impacts to habitat across the pilot project area. A map of the forest carnivore network was created and is available in the planning file. Further analysis will be conducted at the site-specific level and documentation of effects will be disclosed in site-specific Biological Assessment/Biological Evaluations.

Public Concern: Alternatives in the FEIS should provide canopy closures adequate to assist in Pacific fisher and American marten recovery.

The alternatives were analyzed as to their effects Pacific fisher and American marten habitat. The FEIS analyzed the effects of silvicultural treatment options that implement a variety of fuel management strategies. Each alternative affects Pacific fisher and American marten habitat differently, in terms of acres treated, impact to habitat quality, connectivity, and distribution. Stand canopy closure, as it relates to meeting the habitat requirements of these species, was one of the parameters analyzed and disclosed in the Biological Assessment/Biological Evaluation and FEIS. Alternatives 3, 4, and 5 provide better options for providing Pacific fisher and American marten habitat for future management strategies.

Public Concern: The pilot project should not exacerbate the problem of inadequate denning and foraging habitat for Pacific fisher. It should consider the effects of defensible fuel profile zones on Pacific fisher and not degrade habitat. The analysis should show how alternatives other than Alternative 5 will adequately protect Pacific fisher.

An analysis of effects on fisher denning and foraging habitat from resource management activities proposed in the pilot project area, including defensible fuel profile zones, for all alternatives, is displayed in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. Adequacy of Pacific fisher habitat protection and maintenance is displayed for each alternative in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS.

Public concern: The FEIS should not rely on interim direction for the protection of California spotted owl to provide or maintain Pacific fisher habitat.

Habitat requirements and management guidelines for American marten and Pacific fisher were displayed in the Biological Assessment/Biological Evaluation and summarized in Chapter 3 of the FEIS. The effects of the various alternatives were disclosed in the Biological Assessment/Biological Evaluation and Chapter 3 of the FEIS. Although the habitat attributes identified for California spotted owl overlap, to some degree, with Pacific fisher and American marten habitat attributes (large trees, snags, down logs, canopy cover), the Biological Assessment/Biological Evaluation and FEIS do not use the interim direction for protection of California spotted owl as a surrogate for maintaining suitable Pacific fisher and American marten habitat. Effects to these species were based on the impacts of the alternatives on the amount, connectivity, and distribution of suitable habitat.

Public Concern: The FEIS should account for the inadequacy of forest carnivore networks.

The Forest Service disagrees. This public comment reflects a common misinterpretation that mistakenly implies forest carnivore areas are set aside. Forest carnivore networks were established on the Lassen Forest Plan. These habitat management areas have standards and guidelines that govern management activities occurring in their boundaries. Management activities in the network should meet the standards and guidelines for providing forest carnivore habitat or habitat attributes.

The Tahoe and Plumas National Forests developed their forest carnivore networks outside of Forest Plan management direction in response to a May 1, 1998, clarification letter from the Regional Forester. These networks were developed based on habitat and forest carnivore sighting records. Management intent in these networks is to maintain habitat options for American marten and Pacific fisher by:

The adequacy of the forest carnivore networks has not been tested regionwide. Additional management direction for these networks, or some replacement strategy, is expected from the Sierra Nevada Framework effort.

Public Concern: The FEIS should examine the potential adverse impacts to the Pacific fisher from group selection logging.

Following publication of the DEIS, both the Biological Assessment/Biological Evaluation and the FEIS were revised to improve disclosure of impacts to American marten and Pacific fisher habitat. Group selection harvest activities cannot be assessed site-specifically at the programmatic scale of this analysis. A site-specific analysis will be conducted , including determination of necessary mitigation to reduce impacts to habitat, that will assess design and project layout. Impacts to denning and foraging habitat will be further analyzed in site-specific biological evaluations.

Public Concern: The FEIS should include a spatially explicit analysis of impacts on Pacific fisher habitat.

The programmatic nature of this FEIS allowed only limited spatial analysis. Defensible fuel profile zone locations and area fuel treatment locations were placed across the pilot project area in a strategic manner that could be effective in reducing the threat of catastrophic fire. Potential impacts to Pacific fisher habitat were based on the assumed (modeled) location of these defensible fuel profile zones and area fuel treatments. Whenever defensible fuel profile zones and area fuel treatments entered suitable habitat, across the landscape and in forest carnivore habitat networks, impacts to suitable habitat were assessed. Spatially explicit analysis will be available following site-specific analysis utilizing the geographic information system layers developed for the defensible fuel profile zones and area fuel treatments, but modified for site-specific needs. Group selection areas were not available at the programmatic level because placement is developed under silvicultural prescriptions completed during project development. Potential effects are difficult to assess at the programmatic level of this analysis because placement, size, and vegetative conditions are too varied. The effects of group selection harvests are also varied and can have adverse effects to Pacific fisher, while at the same time, having positive effects for its prey. Due to this variability the analysis of effects of implementing group selection harvests, based on spatial analysis, is much more effective at the site-specific level.

Amphibian and Fisheries Resources
The protection of amphibian species is a concern for many people who responded to the DEIS. The Forest Service should coordinate with the California Department of Fish and Game to end fish stocking in areas with sensitive amphibian species, one individual wrote. Others ask that all amphibian breeding areas be protected from logging and grazing.

Protection of salmon in westside rivers and streams is also a concern for many respondents. Some ask that the pilot project implement Sierra Nevada Ecosystem Project water quality recommendations. They believe these guides offer the best means of protecting salmon and other native fish.

Public Concern: The FEIS should address the effects of fish stocking on sensitive amphibian species.

The issue of fish stocking is outside the scope of this FEIS. The practice of fish stocking is the responsibility of the California Department of Fish and Game. The Forest Service and the California Department of Fish and Game share mutual interest and responsibility in the protection of amphibians. To this end, these Federal and State agencies are working at the regional and local levels (but outside the narrow scope of this analysis) to address the potential impacts of fish stocking on sensitive amphibian species.

Public Concern: The Forest Service should protect amphibian breeding areas from management activities.

The Forest Service agrees that amphibian breeding areas need protection. There are a number of ways these areas will be directly or indirectly protected (programmatically and site-specifically). First, all water bodies will receive, at a minimum, protection through the designation of buffers based on the Scientific Analysis Team guidelines, Sierran Nevada Ecosystem Project guidelines, streamside management zone (Forest Plan direction), or PACFISH riparian habitat conservation areas; and application of management direction (standards and guidelines) that regulate the type and extent of activities that may occur in these areas. Although the specific habitat requirements for amphibians are not fully known, the Scientific Analysis Team and PACFISH buffers were developed with the underlying principle of maintaining and restoring aquatic and riparian ecosystem health and function, which will promote conservation of aquatic communities.

Second, in some watersheds (Deer Creek, Mill Creek, and Antelope Creek), further protection to amphibians (including breeding sites) are provided for under more limited management prescriptions contained in the Forest Plans. Examples include proposed or designated Wild and Scenic River and Wilderness prescriptions.

Third, resource management activities under the pilot project are excluded in offbase and deferred areas, some of which contain known breeding populations of amphibians.

Finally, at the site-specific level, mitigation needs will be determined where additional protection measures are necessary (as identified through the Endangered Species Act consultations for listed amphibians or development of biological evaluations for sensitive ones).

Public Comment: The Forest Service should follow Sierra Nevada Ecosystem Project water quality recommendations to protect salmon.

The Forest Service is also very concerned about protecting salmon. As noted in the FEIS, one element common to all alternatives is implementation of the aquatic conservation strategy known as PACFISH. This programmatic direction amended the Lassen National Forest Plan in 1995. PACFISH was developed specifically for the protection and restoration of anadromous fish (salmon and steelhead). This direction was developed in coordination and consultation with the Department of Commerce National Marine Fisheries Service, the regulatory agency for listed anadromous fish. In the FEIS, the application of PACFISH direction and a description of the watersheds where the direction applies is discussed in the Affected Environment and Environmental Consequences sections under Fish. The Feather River salmon are important; however, this particular population is restricted to habitat below Lake Oroville, a very large storage reservoir downstream of the pilot project area.

Public Concern: The FEIS should analyze the impact of the pilot project on salmon.

The Forest Service analyzed potential effects of the pilot project on Central Valley steelhead and Central Valley chinook salmon, which included informally consulting with the Department of Commerce National Marine Fisheries Service. The results of this analysis and consultation are found in the FEIS, in Chapter 3. Consultation with the Department of Commerce National Marine Fisheries Service is complete for at the programmatic level of this FEIS. Site-specific assessments for salmon and steelhead will be conducted and consulted on as individual projects are evaluated during site-specific analyses derived from this FEIS.

Insects and Disease
The FEIS should include an analysis of the risks and costs related to insects and disease, according to one respondent. Associated costs could total $30 million, this person estimates, and in their opinion the DEIS fails to detail a plan for preventing or responding to insect infestations. The FEIS should also include a description of how drought affects vulnerability to insects and disease, another individual writes.

Public Concern: The FEIS should directly address the impacts and costs associated with the negative effects of insects and disease.

Aerial surveys conducted annually on National Forest System lands in to detect occurrence of insect and disease problems. Current conditions, as described in the DEIS, are the result of above normal levels of precipitation over the past few years. Bark beetle related mortality is closely correlated with droughts in California and is currently at background levels throughout the analysis area.

Douglas-fir tussock moth activity is disclosed in Appendix W. Currently, Douglas-fir tussock moth populations are at endemic levels. The Lassen, Plumas, and Tahoe National Forests cooperate in an annual western United States Douglas-fir tussock moth trapping survey program to monitor population levels. Information obtained from the traps initiates additional monitoring activities if trap counts exceed specified levels.

Weather events are unpredictable, though drought is likely to be the most important during pilot project period. Due to the variability of natural phenomena (weather and insects included) prediction of costs associated with future insect and disease control is difficult at the programmatic level of this analysis. Site-specific analysis will be needed to address response to insect, disease, and drought should the need arise during the pilot project period. The site-specific analysis will include an economic analysis and cost/benefit information.

Public concern: The FEIS section on insects and diseases should include a discussion of the effects of drought.

The second paragraph under Affected Environment in the insect and disease portion of the FEIS describes the effects the most recent period of drought had on insects and disease. Drought and the associated impacts are disclosed in the Insect and Disease Report located in the planning file. To summarize, whenever an area receives less than 80 percent of normal precipitation, conifer mortality increases above background levels. As severity and length of the drought increase, the potential for high levels of conifer mortality also increases. Based on information from the most recent protracted drought period in the late 1980s and early 1990s, most of the mortality occurred in areas that would normally receive less than 40 inches of annual precipitation (what would typically be considered eastside and transition zones).

Fire and Fuels
Many people favor Alternative 2 because they believe it will most dramatically decrease the risk of large wildfires. This approach will create a more fire-resilient forest, they say, while protecting timber, property, and wildlife habitat. Some respondents support Alternative 5 because it does not require opening the forest canopy. They think this Alternative 5 will not increase wildfire risk if maintenance funding fails to materialize. Some believe the pilot project may not reduce fire danger as claimed. Others do not voice support for or opposition to alternatives; instead, they direct their comments to specific features of the alternatives. These comments are found in following subsections.

Several respondents recommend that the FEIS include an expanded analysis of fire history in the planning area, including incidence on range, forest, and private lands. The FEIS should also, one person suggests, expand its discussion of the historical effects of fire suppression and its analysis of weather effects on fire.

One person asserts that the Forest Service renew its fire suppression program by involving all employees and using committees of experts, rather than computer models, to gauge suppression effectiveness.

Public Concern: The Forest Service should select Alternative 2 because it contributes to fire safety.

The relative contributions of Alternative 2 to fire safety are addressed in Chapter 3, Fire, Environmental Consequences.

Public Concern: The Forest Service should select Alternative 5 because it contributes to fire safety.

The relative contributions of Alternative 5 to fire safety are addressed in Chapter 3, Fire, Environmental Consequences.

Public Concern: The Forest Service should recognize that the pilot project would not reduce fire danger.

Fire danger is comprised of two elements – risk and hazard. Opportunities to manage risk are limited. For example, while we cannot influence the risk of lightning-caused fires, the Forest Service can manage the risk of human-caused fires by educating forest users. The alternatives presented in the FEIS explore a variety of approaches to managing fire hazard.

Public Concern: The FEIS should analyze the fire history of lands in the pilot project area.

Fire history information was reviewed for all lands in the planning area, and this information was used to evaluate how the different alternatives might effect the size and severity of future wildfires. The history of fire on private land or rangeland was not analyzed separately because it is believed all alternatives propose a landscape-level fuel management strategy that would buffer areas of private and public land, and that the criteria developed to prioritize tactical implementation and consider the existing fire hazard of private lands and rangelands.

Public Concern: The FEIS should include an analysis of the historical effects of fire suppression.

An historical perspective was considered in the analysis as a means for relative comparison to existing conditions. The findings are documented in Chapter 3, Fire and Fuels, Affected Environment.

Public Concern: The FEIS should consider the effects of weather on fire patterns.

A discussion of the effects of weather on fire patterns is found in Chapter 3, Fire and Fuels, Affected Environment and Environmental Consequences. Weather effects are important factors in fire and fuel management because of their potential to affect both the risk of a fire occurring and their influence on hazards associated with fire.

Public Concern: The Forest Service should use a committee, not a computer model, to review the effectiveness of fire suppression efforts.

Computer simulations used in development and analysis of the effects of fire suppression under each alternative were reviewed and interpreted by Forest Service fire management specialists. Conclusions and findings are documented in Chapter 3, Environmental Consequences.

Public Concern: The Forest Service should involve all employees in fire suppression activities.

Employee duty assignments are internal management decisions and are beyond the scope of this FEIS. Each year many employees assist in fire suppression activities, in a variety of capacities from direct suppression to support roles. Fire suppression is a priority for a large number of Forest Service employees during the fire season. Fire suppression needs are balanced with other land and resource management needs.

Public Concern: The Forest Service should ensure that computer models used to predict fire hazard are accurate and apply to the planning area.

Several different computer models were used to analyze different aspects of wildfire potential, such as relative risk of a large fire occurring and how fuel treatment patterns influence fire spread and intensity. Model limitations and modeling assumptions were considered in the evaluation of model outputs, as was relevancy of the model results.

Public Concern: The FEIS should not rely on Forest Service fire records alone to show fires before 1900 because they are inaccurate.

The Forest Service agrees that the accuracy of some of early fire history information could be better, but it was the best information available at the time the analysis was preformed. The information in these records provides a reasonable picture of what occurred for use in making a landscape-level assessment. For this analysis, only fires from 1970 through 1996 were used to assess the effects of implementing the alternatives.

Public Concern: Analysis in the FEIS should not assume that frequent low intensity burns were the norm in the northwestern Sierras without strong evidence.

Fire frequency and intensity was examined in the Sierra Nevada Ecosystem Project Report, Chapter 38, Volume II. The summary recognized the lack of specific fire history studies for this area, but concludes there is no reason to believe that the fire return intervals for Ponderosa pine dominated sites in the northern Sierras would be greatly different from those in other parts of its range.

Public Concern: The FEIS should ensure a comprehensive monitoring program will be in place to measure the effects of defensible fuel profile zones on ecological and socioeconomic conditions.

A monitoring strategy, including data gathering, evaluation, and reporting was developed as Chapter 6 of the FEIS.

Public Concern: The FEIS should analyze and consider the role of understory fuels on fires susceptibility in the eastside zone.

The FEIS includes discussion of expected fire behavior, and related consequences of implementing different fuel reduction patterns (defensible fuel profile zones and area fuel treatments) proposed by the alternatives for pilot project areas.

Public Concern: Baseline information for fire modeling parameters in the FEIS should use weather data from weather stations in the pilot project area.

Weather data from stations in the planning area was used for FARSITE and BEHAVE fire modeling. For broader-scale modeling to show relative differences in flame lengths, a weather station from the Stanislaus National Forest was used to allow consistency with modeling completed for the Sierra Nevada Framework forest plan amendment environmental analysis. Mount Elizabeth information was used after analysis of weather data showed that 90th percentile weather variables from the Stanislaus National Forest were in the same range as 90 th percentile weather variables for weather stations in the pilot project area.

Public Concern: Alternatives in the Interdisciplinary Team should work with property owners to reduce the vulnerability to fire of their properties, rather than emphasizing reducing wildland fuel loads.

Personal home flammability, rather than wildland fuels, is the principal cause of property losses during wildland/urban interface fires. Working together with property owners will increase the effectiveness of fuel reduction on public lands and increase fire suppression effectiveness, while reducing wildfire losses. The direct effect these cooperation with private landowners will have on reducing the number of homes and structures lost to wildfire will depend on actions taken by private landowners to reduce the flammability of their property. While the Forest Service provides public education about fire safety and reduction of wildfire hazards to property owners, requiring private landowner compliance with suggested fire safety and flammability reduction programs is outside the jurisdiction of the Forest Service and the scope of this FEIS.

Fuel Treatments
Many people agree that reducing forest fuels is important to forest health and fire safety in the pilot project area. They disagree, however, regarding the best approach for fuel reduction. This subsection focuses on comments regarding a wide variety of fuel treatments including thinning, prescribed fire, and herbicide use.

Because people believe wildfire poses a hazard to life and property in the Sierras, they want urban interface areas to receive the highest priority in fuel reduction efforts. Many think the Forest Service should concentrate on reducing fuels in these areas first. Some respondents believe these fuels should be thinned mechanically, while others believe they should be thinned with the use of prescribed fire. Low-intensity burns in these areas, people suggest, would not only make them safer but also would improve wildlife habitat and foster forest health. Private property adjacent to National Forest System lands should also receive attention, one person recommends. This individual believes the Forest Service should work with private landowners to help coordinate thinning projects large enough to attract timber companies.

Respondents propose a wide variety of fuel treatment methods for the pilot project area, including mechanical thinning, prescribed fire, selective logging, pruning, goat grazing, and fuel break construction. Some people state a clear preference for one method or another, while others recommend using a combination of several methods to reduce fuels. Thinning and prescribed fire should be used to "reduce fire hazard and allow trees room to grow," one person suggests, and the by-products should be used for poles, chips, and paper pulp. A conservation organization calls for a combination of pruning, burning, and thinning without commercial logging or cutting any trees greater than 11 inches in diameter. An individual asks how much chipping can be done without causing a harmful build-up of nitrogen on the forest floor. The Forest Service should not use intensive logging practices to thin the forest, according to one person: "Intensive-logging practices must be minimized. I have seen a photograph of a thinned forest strip. After thinning, what is left is not forest . . ." In addition, this person writes, "data indicates that thinning the forest does not reduce the fire danger."

Several people offer specific guidelines for thinning canopy cover. The FEIS should offer a range of alternatives for crown cover retention, according to a conservation organization, including an alternative that allows 60 to 80 percent of the canopy to remain. An individual writes that although 40 percent canopy cover may be appropriate for areas where the canopy is accessible for high maintenance, this level would encourage the growth of brush and a 60 percent canopy cover would better reduce the chances of the fuelbreak growing "into a new problem."

Prescribed fire should be explored as a viable option for reducing fuels across the pilot project area, in the opinion of some respondents. They believe air quality compliance and coordination with public and private land managers should be addressed in any analysis of prescribed burning. One person specifically requests information on prescribed fire as an alternative to logging in construction of fuelbreaks. Another, who supports the use of prescribed fire, asks that its use be maximized, but "not along established hiking trails!" A member of the wood products industry asks who will bear the liability for property loss in controlled burning situations.

An air quality management district recommends that the FEIS evaluate the economic feasibility of alternatives to prescribed fire, including the production of biomass fuel.

Public Concern: The FEIS should clearly state when, where, and how herbicides may be used.

Maintenance of defensible fuel profile zones may require the use of herbicides, but need is unclear at this time. Many treatment options exist – mechanical, fire, and chemical. In March 1998, the Pacific Southwest Region issued a Final Environmental Impact Statement for Vegetation Management for Reforestation. The Final Environmental Impact Statement for Vegetation Management for Reforestation analyzed a full range of vegetation management tools and directs Forest Supervisors to conduct site-specific analysis before selection of a treatment option.

Public Concern: The FEIS should present more than one alternative that focuses on fuel reduction near human developments.

All alternatives propose fuel reduction around communities using a variety of methods and strategies.

Public Concern: The Forest Service should prioritize fuel thinning efforts in areas adjacent to private property.

Implementation schedules developed for all alternatives consider this element when prioritizing fuel reduction activities. The success these activities have on reducing private property losses to wildfire will be depend action taken by the property owners to reduce the flammability of their property.

Public Concern: The Forest Service should maximize the use of prescribed fire for reducing fuel loads, especially near developed private property.

The identification of locations where prescribed fire will be used is best done during site-specific analysis. The effects of prescribed fire depend on local-scale vegetative conditions, weather, season, and other factors best accounted for in a site-specific analysis. These site-specific decisions are subject to disclosure and public participation.

Public Concern: The Forest Service should coordinate thinning projects with small landowners.

Forest Service standard operating procedure is to notify landowners of projects proposed on adjacent public lands. Where and when thinning projects are allowed, adjacent landowners will be notified before a decision for a site-specific project. Notification ensures that the concerns of landowners who may be affected are assessed and considered.

Public Concern: The Forest Service should use a range of methods for thinning fuels.

Prescribed fire is a useful tool for reducing surface fuels and increasing the distance of live tree crowns from the ground (reducing potential for crown fire initiation and spread). Site-specific analysis will determine how well the use of prescribed fire or other fuel reduction practices meet the objectives of reducing fire hazard.

Public Concern: The FEIS should address nitrogen build-up resulting from chipping of woody debris.

Chips are usually removed from treatment sites and used for energy production. However, if the proposed practice on a specific project is to spread chips in the treated area, the effect of the increase in the carbon/nitrogen ratio on herbaceous and woody growth replacement will be analyzed and disclosed in a site-specific environmental analysis.

Public Concern: The Forest Service should not use intensive logging to thin the forests.

The alternatives examined in the FEIS provide the Responsible Officials with a range of timber harvest levels and harvest prescriptions. Each alternative represents a different set of trade-offs in terms of harvest volume and environmental protection.

Public Concern: The FEIS should include a range of alternatives for crown fuel reductions.

The alternatives presented in the FEIS examine a range of canopy cover densities. Each alternative represents a different set of trade-offs in terms of harvest volume and environmental protection.

Public Concern: The FEIS should disclose who would implement burns and bear the liability for fire loss.

The analysis in the FEIS is a programmatic (strategic) analysis. It does not specify actual locations where fuel reduction treatments will occur. Liability is addressed in the Burn Plan specific to an implementation project. When projects are implemented the Forest Service normally coordinates activities directly or supervises contractors who complete the work.

Public Concern: The Interdisciplinary Team should design alternatives that construct fuelbreaks with prescribed fire instead of commercial logging.

The use of prescribed fire as one method of creating fuelbreaks. Other methods, including mechanical treatment and commercial timber harvest exist. Options will be determined on a site-specific basis when treatments are implemented.

Public Concern: The FEIS should address the coordination of prescribed burning activities with public and private land managers.

Forest Service standard operating procedure is to notify adjacent public and private land mangers when treatments are proposed adjacent to their lands. The Plumas and Lassen Forests, and the Sierraville District of the Tahoe National Forest participate in the Northeastern Air Alliance group. Where and when prescribed burning is allowed, adjacent landowners will be notified before implementation of site-specific projects. Where and when thinning projects are allowed, adjacent landowners will be notified before a decision for a site-specific project. Notification ensures that the concerns of landowners who may be affected are assessed and considered.

Public Concern: The Forest Service should conduct prescribed fire where it does not degrade recreational values.

Potential impacts of prescribed fire on recreational values will be assessed during site-specific planning. The assessment of impacts will take into consideration Forest Plan management direction for recreational opportunities.

Public Concern: The FEIS should evaluate the economic feasibility of alternatives to prescribed fire.

The use of biomass fuel is consistent with the goals of Alternatives 2, 3, and 4. Site-specific evaluation will analyze the need to remove biomass fuels before prescribed burning.

Public Concern: The Forest Service should demonstrate to what degree reductions in fuel loads will reduce fuel hazard.

The FARSITE computer model was used to simulate changes in fire behavior given changes in the fuel profile, stand structure, topography, and weather. Conclusions are documented in Chapter 3, Environmental Consequences. Site-specific analysis will evaluate the degree of fuel reduction needed to reduce fire hazard in a specific area, given hazard, risk, and values to be protected.

Public Concern: The FEIS should disclose criteria for identification of when and where prescribed burns will be used.

The FEIS analyzes the environmental consequences of each alternative at the programmatic scale. On July 30, 1999, the Forest Service presented the Northern Sierra Air Quality Management District with information on acres of prescribed burning (by county) that were modeled for each alternative. This information is located in the planning file. The DEIS also included information on emissions predicted, by county. At the programmatic level, this is the finest scale of information available.

There is not enough information available at this time to provide details on site-specific scheduling of prescribed burning for any of the alternatives. Site-specific evaluation will determine what type of fuel reduction is required and how air quality standards will be met. Site-specific burn plans will be prepared in accordance with the Memorandum of Understanding on Prescribed Burning Between the California Air Resources Board and the Forest Service, Pacific Southwest Region, signed July 13, 1999.

Defensible Fuel Profile Zones and Area Fuel Treatments
The construction of defensible fuel profile zones emerged as the primary concern for most respondents. Some people are convinced the defensible fuel profile zones will harm the environment while failing to provide any reduction in fire hazard, while some remain just as convinced that fuelbreaks will dramatically reduce fire danger, while providing environmental and economic benefits for the community.

People point out a number of analysis needs regarding fuelbreaks and their ability to control wildfire, including their effectiveness at stopping crown fires and providing safety to firefighters. The FEIS should include analysis of wildfire risk before and after treatment, as well as a comparison of defensible fuel profile zone effects versus those of prescribed fire, some suggest. Analysis must include both worst-case and best-case scenarios for project implementation, according to a conservation organization. Another organization doubts that existing roads are adequately maintained for implementing the defensible fuel profile zones in a fire suppression situation.

Respondents believe the FEIS must evaluate the effects of defensible fuel profile zones under a variety of maintenance schedules and construction levels. Similarly, an individual asks for an analysis of the impacts on fire hazard reduction if the Forest Service cannot construct or maintain defensible fuel profile zones to the desired levels. Maintenance is critical to the success of fuelbreaks, many people agree, and the FEIS should analyze and account for necessary maintenance. They are concerned with the cost and labor requirements of future maintenance because they believe that without it, future fire risk will actually increase in defensible fuel profile zones. One person suggests that the Forest Service treat a past fuelbreak project to develop an estimate of maintenance costs. If herbicides are going to be used as a tool in construction and maintenance, a conservation organization writes, the FEIS should clearly disclose the details of their use.

The FEIS should not only analyze the effectiveness of defensible fuel profile zones in reducing wildfire, some people believe; it should also evaluate its impacts on wildlife and habitat. Forest fragmentation is a major concern for many. "Habitat connectivity is a crucial component in preserving the viability of sensitive species,'' one person writes, and "the creation of defensible fuel profile zones will severely degrade connectivity."

People offer several suggestions for locating defensible fuel profile zones. One Fire Safe Council recommends using the 1995 Technical Fuels Report for Lassen, Plumas, and Tahoe National Forests as a resource for determining locations. Another Fire Safe Council recommends considering community defense zones as defensible fuel profile zones and applying the same strategies for these areas. According to a County Board of Supervisors, the Forest Service also should coordinate the location of defensible fuel profile zones with adjacent landowners and communities.

For some, the most important aspect of defensible fuel profile zones is the amount of acreage dedicated to their construction. Many believe the Forest Service should treat the maximum number of acres allowable under the Act to realize maximum environmental and economic benefits. This acreage is too much for some people; one recommends that the Forest Service try a 1,000-acre plot each year for testing. Yet, for others, even the maximum acreage is not enough. Considering the poor condition of the forest, one person writes, the Forest Service should be cutting as much as 500,000 acres a year in the pilot project area. One respondent questions whether enough land exists, after subtracting acreage considered offbase or deferred, to construct an effective system of fuelbreaks.

Respondents also offer comments on desired configuration for defensible fuel profile zones. Defensible fuel profile zones openings should not exceed ½ acre, one person suggests, in order to limit forest fragmentation. Others provide alternative suggestions for the shape of defensible fuel profile zones. Instead of making defensible fuel profile zones rectangles or squares, one individual writes, the Forest Service should design them to follow a "meandering pattern that follows natural features." Special considerations should also be given to ridgelines, asserts another. To protect visual and wildlife values, this person recommends, all large trees should be retained, and the spacing between trees can be smaller. Although some people would like to see fuelbreaks follow different configurations, one-person thinks the FEIS should use the term defensible fuel profile zones consistently to mean linear fuelbreaks.

Several people point out that defensible fuel profile zones cannot stand alone in warding off fire hazard. Fires can jump fuelbreaks through spotting, one person writes, and "the exclusive use of fuelbreaks and theexclusion of fuel treatment is crazy." Another believes the emphasis on defensible fuel profile zones should be accompanied by an improved Forest Service fire suppression organization.

The costs and revenues associated with the construction of defensible fuel profile zones are a concern for some, and they suggest the Forest Service evaluate economic efficiency to get the most for its money.

Public Concern: The Forest Service should not construct defensible fuel profile zones.

The Forest Service is required to consider construction of defensible fuel profile zones by the Act. The actual construction (amount and placement) will be determined at the site-specific level. The FEIS provides an estimate of the number of acres of defensible fuel profile zones that are projected for each alternative.

Public Concern: The FEIS should contain an analysis of the effectiveness of defensible fuel profile zones in controlling fire.

The FEIS does includes an analysis on the effectiveness of defensible fuel profile zones in controlling fire in Chapter 3, Fire, Environmental Consequences.

Public Concern: The FEIS should compare the relative risk of wildfire in areas before and after applying treatment.

Fire danger is comprised of two elements – risk and hazard. Opportunities to manage risk are limited (the Forest Service cannot influence the risk of lightning-caused fires but can manage the risk of human-caused fires by educating forest users). The alternatives explore a variety of ways to manage hazard. The expected outcomes are described in Chapter 3, Environmental Consequences.

Public Concern: The FEIS should address whether enough of a land base exists, following the designation of offbase and deferred lands, to construct an effective system of defensible fuel profile zones.

The effectiveness of the defensible fuel profile zones network developed in lands available during the pilot project time period was analyzed and the conclusions documented in Chapter 3, Environmental Consequences.

Public Concern: Analysis for the FEIS should compare the effects of linear fuelbreaks and prescribed burning on wildfire.

An important facet of the pilot project is to monitor and report the results of implementing the resource management activities. Available information on the relative effectiveness of prescribed burning, fuelbreaks, and area fuel treatment is insufficient to allow for adequate assessment at the programmatic level of this FEIS. One purpose of the pilot project is to provide opportunities to fill this data gap. Monitoring the effects of the selected alternative will play an important role in the implementation phase, regardless of the method of fuel treatment chosen.

Public Concern: Analysis for the FEIS should include effects of fuelbreaks on fire behavior under a variety of maintenance regimes and defensible fuel profile zones construction levels.

The FEIS presents a range of approaches to fuelbreak construction as displayed in Chapter 2, Description of Alternatives, and the Environmental Consequences in Chapter 3.

Public Concern: The FEIS should analyze and disclose crown bulk densities of tree species in defensible fuel profile zones, and their effects on fire spread.

The FEIS discusses measures of crown bulk densities that may offer a means of determining appropriate crown structures for even-aged stands at the site-specific level.

Public Concern: The Forest Service should quantitatively analyze the effects of defensible fuel profile zones construction on forest fragmentation.

The effects of defensible fuel profile zones construction and forest fragmentation have been analyzed and the conclusions are included in Chapter 3, Environmental Consequences.

Public Concern: The FEIS should analyze the impact on fire hazard reduction if the Forest Service can not meet defensible fuel profile zonesgoals or adequately maintain defensible fuel profile zones.

The impact of relative levels of defensible fuel profile zones maintenance is addressed for each alternative in Chapter 3, Environmental Consequences.

Public Concern: The Forest Service should ensure that existing infrastructure is adequate to implement the construction of defensible fuel profile zones.

Although road construction necessary under each alternative is assessed in Chapter 3, Environmental Consequences, transportation system needs specific to the construction of defensible fuel profile zones will be analyzed on a site-specific basis.

Estimations were made about necessary maintenance to maintain the desired condition in defensible fuel profile zones and area fuel treatments, as well as the estimated costs to accomplish maintenance. These estimates are in Chapter 3, Environmental Consequences. The affect of not adequately treating activity-generated fuels is also summarized in the Environmental Consequences.

Public Concern: The Forest Service should reduce the number of acres treated annually for the pilot project.

The alternatives presented in the FEIS examine a range of annual treatment acreage.

Public Concern: The Forest Service should construct the maximum annual acreage of defensible fuel profile zones for the pilot project.

The alternatives examine a range of acres that would be treated.

Public Concern: The FEIS should minimize habitat fragmentation by limiting defensible fuel profile zones to ½ acre openings.

The effects of habitat fragmentation were considered in a number of resource areas, primarily wildlife. The fire and fuels discussion reviewed three strategies in treating stands for fuels and provided a discussion on the effectiveness of each. Habitat fragmentation will also be considered at the local level during site-specific planning.

Public Concern: The FEIS should consider alternate configurations for defensible fuel profile zones.

Alternatives 2 through 5 consider alternate configurations of defensible fuel profile zones for fuel hazard reduction. Configuration of defensible fuel profile zones is influenced on a site-specific basis by topography, vegetation, and Forest Plan management prescriptions. Site-specific alterations in configuration will likely occur during project implementation.

Public Concern: The definition of "defensible fuel profile zone" in the FEIS should remain consistent among alternatives.

The term "defensible fuel profile zone" is defined in the Glossary for this FEIS and is used consistently throughout the document.

Public Concern: The FEIS should include consideration of the costs and revenues associated with fuelbreak construction.

The SPECTRUM model used in the analysis of effects for fuelbreak construction under each alternative provides projections of costs and revenues associated with varying levels of implementation. The results of this modeling are disclosed in Chapter 3, Environmental Consequences.

Public Concern: The Forest Service should consider community defense zones defensible fuel profile zones adjacent to communities.

"Community defense zone" is a term used in the Technical Fuels Report indicating a strategy to increase protection of communities from wildfire and reduce the chance of fire spreading into wildland areas. Even though the term community defense zones is not used in any of the alternatives, fuel treatment strategies focus fuel treatments in the urban interface serving the same purpose as a community defense zone.

Public Concern: The Forest Service should use the 1995 Lassen, Plumas, and Tahoe National Forests Technical Fuels Report as a resource in locating defensible fuel profile zones.

Most defensible fuel profile zones identified in the Technical Fuels Report are included in Alternatives 2, 3, and 4 as possible locations for defensible fuel profile zones establishment, and as additional areas in the western portion of the planning area, although site-specific evaluation will determine exact location of defensible fuel profile zones. The area fuel treatments proposed in Alternatives 3, 4, and 5 are essentially the same as the "fuel reduction zone" strategy recommended in the Technical Fuels Report, and both defensible fuel profile zones and area fuel treatments proposed in all the alternatives would accomplish the same objectives as the community defense zone strategy recommended in the Technical Fuels Report.

Public Concern: The Forest Service should construct defensible fuel profile zones in coordination with adjacent landowners and communities.

As part of site-specific planning a scoping process will be used. Adjacent landowners will be contacted during the scoping phase for projects proposed on adjacent public lands.

Public Concern: Management prescriptions in the FEIS should not rely solely on linear fuelbreaks for fire hazard reduction.

Three of the four action alternatives propose area fuel treatments. The effectiveness of the different alternatives at reducing the acres burned and severity at fire perimeters was analyzed and documented in Chapter 3, Environmental Consequences. The intent of developing a network of defensible fuel profile zones during the pilot project period is to increase suppression efficiency by reducing the potential for crown fire spread and the amount of work required to establish an effective control point. This would not decrease the need for suppression resources to do the work needed to control the fire.

Public Concern: The Forest Service should ensure that existing infrastructure is adequate to implement the construction of defensible fuel profile zones.

Although road construction necessary under each alternative is assessed in Chapter 3, Environmental Consequences, transportation system needs specific to the construction of defensible fuel profile zones will be analyzed on a site-specific basis.

Public Concern: The FEIS should contain a strategy and criteria for the implementation of defensible fuel profile zones around communities.

Alternatives 2, 3, 4, and 5 propose fuel reduction treatments adjacent to communities. The FEIS contains elements to be used to prioritize tactical implementation. Forest Service representatives are currently members of the various Fire Safe Councils in and adjacent to the planning area. Our goal is to have collaborative planning for fuel reduction projects adjacent to communities and private land accomplished through the Fire Safe Councils to enable a finer-scale assessment of fire hazard and development of site-specific.

Public Concern: The FEIS should exclude high elevation areas and red fir stands from defensible fuel profile zone construction.

Any criteria established for developing a tactical implementation schedule for construction of defensible fuel profile zones would take into consideration and establish implementation priorities in red fir forest types. Site-specific analysis will be used determine specific defensible fuel profile zone prescriptions based on historic stand structure, fire regime information, and habitat requirements.

Public Concern: The FEIS should disclose criteria and ranking for prioritization of defensible fuel profile zones construction.

Common criteria have been developed for all alternatives based on hazard, risk, and value. This will allow for the development of a tactical implementation schedule.

Social and Economic Environment

Cultural Heritage Resources
Instead of relying on accidental discovery of cultural sites during ground disturbing activities, several people believe the Forest Service should actively try to locate them. "The agency should conduct an intense archaeological search with survey," one individual writes, "and continue with a program of research and education." The project area contains many historic sites that may provide a useful comparison to current conditions, another suggests. Some people offer recommendations for interpreting and protecting sites once they are located. Signs and interpreters (docents) could be used to help preserve these areas, according to one respondent.

The FEIS should reflect not only Native American history, one person believes, but also include Euro-American history in the planning area. Euro-American history may be "more significant in terms of forest use and misuse," this person states, and many sites could be affected by implementation of the pilot project.

Public Concern: The Forest Service should put more effort into finding and interpreting historic sites.

This request is beyond the scope of this FEIS. Cultural resource surveys and interpretation of heritage resource site occur in conjunction with site-specific implementation.

Public Concern: The FEIS discussion of cultural heritage resources should include European American culture in addition to that of Native Americans.

The Forest Service acknowledges that cultural heritage resources associated with Euro-Americans are important and this is reflected in the FEIS. As noted in the Affected Environment section, heritage resources in the planning area represent some 9,000 years of prehistory and history, documenting a wide array of economic, social, and ideological activities that are crosscut by a diversity of ethnic groups. These include Euro-American cultures, which immigrated to the region within the last 100 to 150 years. Specific Euro-American heritage resources will be identified in site-specific implementation and afforded the same protections as other cultural heritage resources.

Native American Tribes and Communities
Consultation with tribes and assurance of access and use of traditional gathering areas and resources are two concerns expressed with regard to effects of the pilot project on tribes. Acknowledgment of existing agreements and consultation practices is one item some tribal members would like to see in the FEIS.

According to a member of the Pit River Tribal Council, the Forest Service should include Native Americans in the development and implementation of pilot project activities. These activities could potentially affect cultural and archaeological resources and tribal economic and cultural needs. This person is concerned about potential impacts on Native American cultural resources by proposed activities, and recommends that a complete study of cultural and archaeological resources be performed before implementing the pilot project. Current efforts regarding consultation with affected tribal groups have been inadequate, in this individual's opinion. This person also suggests that Native Americans be employed to monitor any ground-penetrating disturbances resulting from pilot project activities.

The Native American Grave Protection and Repatriation Act director for the Mooretown Rancheria recommends that Native Americans be employed in all facets of the pilot project. Additionally, this person believes paid Native American monitors should be employed at identified gathering areas, and these areas should be temporarily cordoned off and excluded from any mechanized equipment use.

The need for an evaluation of economic, demographic, and cultural concerns of tribes in the pilot project area is a common concern for some respondents. This evaluation, they believe, will be helpful in finding ways to build an economic base that includes sustainable forest management practices. Some tribal members believe that because the pilot project area lies partially in the tribe's ancestral territory, the Forest Service should be required to enter into a agreement with the autonomous bands of the Pit River Tribe. In addition, one Pit River Tribe Councilperson asks that the FEIS direct prescribed burning activities to areas of fire-dependent plant species with cultural uses.

Public Concern: The Forest Service should involve Native Americans in the evaluation and implementation of pilot project activities.

As required by laws, regulations, and policy, appropriate consultation for each site-specific undertaking will occur with tribal governments, groups, and knowledgeable resource users to identify cultural properties, species of concern, and specific uses in all areas potentially affected by implementation. For each site-specific undertaking, appropriate consultation will occur with tribal governments, groups, and knowledgeable resource users to identify cultural properties, species of concern, and specific uses in all areas potentially affected by project implementation.

As required by the National Historic Preservation Act and the Native American Graves Protection and Repatriation Act, appropriate consultation will be conducted with Native Americans when any archaeological excavation occurs on Native American sites.

Public Concern: The Forest Service should involve Native Americans in the evaluation and implementation of pilot project activities.

Employment opportunities for Native Americans, women, and other minorities afforded by the implementation of the FEIS are described in the Civil Rights Impact Analysis located in Appendix O.

Public Concern: Analysis for the FEIS should evaluate tribal economic, demographic, and cultural needs in relation to the proposed actions.

Chapter 3 of the FEIS discusses tribal demographics and cultural issues. The Civil Rights Impact Analysis included in the FEIS describes potential economic impacts to Native Americans from the proposed implementation.

Public Concern: The Quincy Library Group and the Forest Service should enter into an agreement with the 11 autonomous bands of the Pit River Tribe.

This request is outside the scope of this FEIS. Such agreements must be developed through a partnership and a memorandum of understanding between all interested parties.

Public Concern: The Forest Service should provide Native Americans with free access to hardwood and softwood trees in national forests.

Use of trees, both hardwoods and softwoods, needed by tribes for traditional cultural purposes can be authorized for Federally recognized tribes. Arrangements can be made with the nearest Forest Service office. Such agreements consider site and time-specific information and are outside the scope of this FEIS.

Public Concern: The Forest Service should allow Native Americans to hunt and fish on National Forest System lands without a license.

Hunting and fishing on National Forest System lands is regulated by the State of California Department of Fish and Game. The Forest Service has no authority to approve non-licensed hunting and fishing on the National Forest System lands.

Public Concern: The Forest Service should identify and exclude gathering areas from use of mechanized equipment for pilot project activities.

For each site-specific undertaking, appropriate consultation will occur with tribal governments, groups, and knowledgeable resource users to identify cultural properties, species of concern, and specific uses in all areas potentially affected by implementation. If needed, mitigation measures will be implemented to protect traditional cultural properties.

Public Concern: The FEIS should direct prescribed burn activities to areas of fire-dependent species with cultural uses.

For each site-specific undertaking, appropriate consultation will occur with tribal governments, groups, and knowledgeable resource users to identify cultural properties, species of concern, and specific uses in all areas potentially affected by implementation. If feasible, species of concern will be enhanced using traditional methods of treatment, including the use of fire. For example, a Plumas National Forest project in the planning phase will stimulate growth and enhance the quality of bear grass blades used by Native American basketweavers by burning the area used for gathering. These types of opportunities will be identified and evaluated during site-specific analysis.

Public Concern: The Forest Service should acknowledge and consider the Maidu Stewardship Project as an important factor in developing the FEIS .

For each site-specific undertaking, appropriate consultation will occur with tribal governments, groups, and knowledgeable resource users to identify cultural properties, species of concern, and specific uses in all areas potentially affected by implementation. Implementation of the FEIS will not preclude agreements or permit activities that are currently in place. Improving communications with tribal governments is a high priority, at both the local and national levels of the Forest Service. To that end, the Forest Service has entered into an agreement with the Maidu Cultural and Development Group to develop protocols in the coming year, as part of the "Using Timber Sales to Achieve Other Vegetative Management Goals."

Public Concern: The Forest Service should consider the potential violations of the Environmental Justice Executive Order related to implementation of the pilot project on lands used by Native Americans.

Environmental Justice Executive Order 12898, signed in 1994, directs Federal agencies to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority and low-income populations. No adverse human health or adverse environmental effects have been identified during analysis of this FEIS. To ensure that implementation activities do not adversely affect the ability of Native Americans to continue to hunt, fish, and gather in the planning area, appropriate consultation will occur with tribal governments, groups, and knowledgeable resource users to identify traditional uses in all areas potentially affected by implementation. Appropriate mitigation measures will be implemented to protect traditional cultural properties.

Socioeconomic Considerations
The best use of the resources available in the Northern Sierras is of great concern to many people, both those who live in and outside the pilot project area. To many, social and cultural concerns are integrally linked with economic concerns that together inform people's discussions of their quality of life. People want stable communities in the Northern Sierras. However, those living in the pilot project area and those who visit the Sierras do not agree on the means to achieve such stability. Concerns range from protection of the natural environment for aesthetic or emotional reasons, to safeguarding tourism seen by many as the future of the Sierran economy, to assuring that resource extractive industry continues to form the base of healthy communities and economies.

The natural beauty of the Sierras is what many people refer to when describing why they live in or visit the mountains. Emotional and spiritual well being is a component of why several individuals report enjoying the Sierras. The aesthetics of the mountains, they feel are an important aspect of history and the current experience of the Sierras. They do not want to lose this to further extractive management.

Exploring the Sierras is a multi-generational activity for many people who grew up sharing the Sierras with grandparents or grandchildren. Several individuals are distressed that the pilot project might allow further timber harvest in an area that they feel is best kept relatively unscarred by human activity. They want to preserve as one person states, "the ancient forests, roadless areas, streams, rivers and clear lakes for future generations to enjoy."

To many people the link is strong between preserving the aesthetic qualities of the Sierras and maintaining community stability. They believe the tourism industry is a growing and increasingly important part of local economies. Protection of forests and watersheds they feel is vital to attracting and holding tourists and the money they bring to local communities. "Who wants to hike in a cut-over forest or fish a silted-in stream?" some people ask. They are afraid that implementation of the preferred alternatives will lead to degradation of the environment that draws people to recreate in the Sierras. While acknowledging the impact of tourist dollars on local economies, some people would like to limit the expansion of motorized recreational opportunities.

Protection of watersheds is of concern to some respondents who point to the money generated by water that flows out of the Sierras. Regional economies benefit, they believe, from ensuring that watersheds continue to function properly. One individual asserts that water accounts for 60 percent of the money generated from commodity and service production in the Sierras.

In contrast, some people believe Alternative 2 will provide the best route to community stability. They believe that timber production has always been the backbone of local economies and should continue to be. By harvesting trees, local industry can continue to support jobs and the forest ecosystems can benefit from thinning and fuel reduction. Timber dollars are an integral part of community structure, some people argue, because they are the source of funding for schools and infrastructure projects. They wonder how counties will fund necessary social programs without timber receipts.

Relying on tourism, some believe, is unwise because tourist dollars fluctuate and are not a secure source of continued community income. "One big fire and all those hikers and anglers won't be coming back," one person points out. The focus of forest management should continue to be multiple-use, they believe, which includes timber management and access to forest lands for a full range of recreationists beyond just hikers and anglers.

The pilot project concerns some individuals who question the sustainability of the preferred alternatives. If community stability is a goal, then local economies they assert, should not be, "dependent on five year spikes in timber sales." One person believes that most losses in timber industry jobs are related to mechanization and foreign markets, not to more restrictive environmental protections. Resource extraction, they argue, is not a stable enough platform for future community growth. Attention should be paid to educating local citizens and on retraining efforts to enable community members to understand changes to the local economy and play an informed and strong role in adjusting to these changes.

The whole discussion of community stability, some respondents believe, should address the role of local communities in the decision making process. They want to ensure that local input is included in resource management decisions that affect their communities.

Public Concern: The Forest Service should protect the forests as a natural heritage for future generations.

The FEIS addresses one of aspect of protection, fire and fuels management. The FEIS contains a range of fuel management strategies designed to provide protection in an array of amounts. The management activities described in the Act are intended to promote forest health and protection while providing economic benefits to local communities including the timber industry. The intent of management activities prescribed by the Act is to lessen the risk of high intensity wildfire destroying large areas, thereby protecting forest ecosystems for future generations.

Public Concern: The Forest Service should place forest stewardship over the concerns of the timber industry.

The management activities described in the Act are intended to promote forest health and protection, while providing economic benefits to local communities including the timber industry.

Public Concern: The FEIS should consider the breadth of economic activity which is dependent on the quality of the environment in the affected region.

Chapter 3, Visual Resources, states that "wildfire could alter the character of the landscape." The intent of the resource management activities in the Act is to lessen the intensity of potential wildfires on the landscape. Large, intense wildfires could definitely have a negative impact on the tourism industry. The vegetation management activities in the Act are designed to avoid negative impacts on the visual quality of the landscape, thereby reducing collateral impacts to tourism. Other requirements of the Act including riparian restoration, road construction, road reconstruction, road decommissioning and additional protection of special areas in the Forests may have positive effects on tourism.

Public Concern: The Forest Service should emphasize the community stability goals of Alternative 2.

Social and economic benefits to communities are described in Chapter 3, Environmental Consequences of the FEIS.

Public Concern: The Forest Service should recognize the economic and social benefits of the pilot project.

Economic and social benefits and costs resulting from the various alternatives are discussed in Chapter 3, Environmental Consequences, of the FEIS.

Public Concern: The Forest Service should consider that commercial logging in Sierra Nevada National Forests is unlikely to foster community stability.

Community well being and economic benefits to communities are discussed in Chapter 3 Environmental Consequences, of the FEIS.

Public Concern: The FEIS should include an analysis of the impacts to communities from technological changes in the wood products industry.

The economic analysis completed for this FEIS shows overall positive social and economic benefits to local communities from implementation of the Act, as described in Chapter 3 Environmental Consequences, of the FEIS. Technological changes in the wood products industry are ongoing and an analysis of their impacts is outside of the scope of this FEIS. The management activities required by the Act include activities requiring various levels of mechanization, from activities designed to use machines to those accomplished through manual labor.

Public Concern: In the FEIS, the Forest Service should more fully discuss and emphasize the economic contributions of non-timber industries.

Appendix S discusses employment and income by economic sector and contributions to the eight-county area of influence. The economic analysis performed to compare economic impacts between alternatives compares differences between the implementation of activities proposed in the alternatives. The analysis is not a comprehensive comparison of all economic aspects in the eight-county area.

Public Concern: The FEIS should support the diversity of local economies, including extractive industries.

The resource management activities described in the Act support the diversity of the local economies by providing commodities and employment opportunities while protecting forest aesthetics and amenities.

Public Concern: The FEIS should develop a baseline socioeconomic description of the pilot project area and establish a monitoring program to determine the effects of management actions.

Appendix S provides baseline socioeconomic data about the planning area and surrounding area of influence. A detailed monitoring plan is also included as Appendix T.

Public Concern: The FEIS should address the Sierra Nevada Ecosystem Project economic analyses and how they differ from analyses presented in the alternatives.

The Sierra Nevada Ecosystem Project analysis was an assessment of existing conditions in the Sierra Nevada. The economic analysis in the FEIS is a comparison of potential impacts on the existing condition of proposed management activities.

Public Concern: The FEIS should consistently apply analysis of economic effects to the same geographic area.

Various economic subregions of the Sierra that set the stage for the baseline socioeconomic description of the planning area are addressed in Appendix S. All tables in Appendix S display information for the eight counties only in the area of influence (each of the counties contain some pilot project land). The IMPLAN analysis conducted for Chapter 3 of the FEIS used the same eight-county area as the basis for analysis.

Public Concern: The FEIS economic analysis should be applied to a timeframe longer than the 5-year period of the pilot project.

The short-term and long-term economic effects of implementing the Act are discussed in Chapter 3, Relationship of Short-term Uses and Long-term Productivity.

Public Concern: The FEIS should consider the breadth of economic activity dependent on the quality of the environment in the affected region.

Chapter 3, Visual Resources, states that "wildfire could alter the character of the landscape." The intent of the resource management activities in the Act is to lessen the intensity of potential wildfires on the landscape. Large, intense wildfires could definitely have a negative impact on the tourism industry. The vegetation management activities in the Act are designed to avoid negative impacts on the visual quality of the landscape, thereby reducing collateral impacts to tourism. Other requirements of the Act including riparian restoration, road construction, road reconstruction, road decommissioning and additional protection of special areas in the Forests may have positive effects on tourism.

Public Concern: The pilot project should emphasize protecting the value of regional watersheds.

The commodity value of water to downstream users is very important and is dealt with by analyzing the potential increases in water yields. The Act specifically requires reporting of changes in water yields. The changes in water yield that might occur as a result of implementing the alternatives were determined to be non-measurable. Water yields are dealt with in the Affected Environment under Amount and Timing of Water Runoff and again in the Environmental Consequences section under the discussion of each alternative. In addition, the Act attempts to improve forest health, decrease the extent of high-intensity wildfires, and stimulate the local economy through this work.

The value of water flowing from the Feather River is especially high, given that it flows through several hydroelectric plants and then into Lake Oroville, the head, and largest reservoir, of the State's water system. The highest value water is that flowing from the basin during the dry season. Little, if any, change is expected to occur as a result of implementing this short-term pilot project.

Public Concern: The Forest Service should work to ensure that the economic benefits of the FEIS would be widely distributed among the local population.

Social and economic benefits to communities are described in the Environmental Consequences Chapter 3 of the EIS. Specific impacts to women and minorities are addressed in the Civil Rights Impact Analysis located in Appendix O.

Public Concern: The FEIS should include alternate funding directions for communities that may lose Forest Reserve Revenues that are used for public road and school financing. This should be disclosed for the alternatives in the FEIS.

Congress is currently debating the setting of Forest Reserve Revenues to counties at a constant level, not dependent upon local harvest levels. This is a matter of Federal law, and is outside the scope of the FEIS.

Public Concern: The pilot project should address the affects of reduced timber production on school funding.

The effects of reduced timber production on school funding is discussed in the Environmental Consequences in Chapter 3 of the FEIS.

Public Concern: The FEIS should consider the effect of timber price on 25 Percent Fund revenue payments.

Appendix S discloses total county budgets for 1989 through 1997 and Forest Reserve Revenue by county for the same period. The price of wood would affect Forest Reserve Revenues, however relative differences between alternatives would remain the same. Great variations in stumpage values are not anticipated in this short-term pilot project.

Public Concern: The FEIS should more fully explain the role of local service contracts.

Appendix T describes service contracts and their role in Forest Service management activities. Table 5 in Appendix IC of Appendix T lists the location of contractors, number of contracts, and sum of service contract values.

Public Concern: The models used in FEIS should not overstate the role of the wood products industry in shaping the economy of the area.

The IMPLAN analysis conducted to compare the economic impacts between alternatives (Chapter 3) takes into account the effects of the FEIS alternatives on economic sectors.

Public Concern: The FEIS should not use models based on economic base theory for planning.

Economic base theory is disparate from input-output models such as IMPLAN. Adequacy of economic models is a topic of ongoing debate among economists. The IMPLAN model has deficiencies, but accurately displays response to activities analyzed in this FEIS. IMPLAN is considered an appropriate model to measure economic impacts of activities.

Public Concern: The FEIS should more fully evaluate the role of private timber industry and supply on the local economy.

A comparison of the roles of the private timberlands and public timberlands in providing timber harvest by county is displayed in Chapter 3, percentage of county timber harvest from public lands. Mill locations are listed in Appendix S. The economic analysis considers only those management activities that would be conducted under the Act, as a way to make comparisons between alternatives. However, the analysis does display impacts of these activities on all sectors of the economy.

Public Concern: Analysis in the FEIS should not overestimate the predicted value of wood produced on national forests.

Stumpage values used in the economic analysis for this FEIS were provided by the California State Board of Equalization and are based on current market transactions.

Public Concern: The Forest Service should address how proposed activities in the FEIS and the affected communities will be funded.

Proposed activities in the FEIS would be funded by Congressionally appropriated dollars. The costs and benefits of timber sale activities and total costs to implement each alternative are displayed in the FEIS.

Public Concern: The FEIS should use a spatially-explicit model to plan the implementation of the pilot project.

Forest Plan standards and guidelines and areas designated as restrictions or constraints by the Act are entered into the SPECTRUM model from geographic information system databases and are spatially-explicit. When a particular class of acres is selected by SPECTRUM for management activity, the precise location of the activity in that acreage class is then through site-specific analysis.

Range Management
The Congressional Record for the Act, some respondents note, suggests that neither Congress, nor the Quincy Library Group, intended to impact grazing activities in the area affected by the proposal. In light of this information, some people, in particular those representing ranching or other grazing interests, ask that the pilot project FEIS not change existing allotment management. Guidance offered in the Lassen, Plumas, and Tahoe Forest Plans is sufficient in their view. Many representatives of ranching or grazing interests want the Forest Service to consider the location of range allotments and the timing of the grazing season when selecting pilot project areas so as to avoid disrupting existing grazing activities whenever possible. If, however, implementation of the pilot project necessitates that changes be made to livestock management requirements, some believe the Forest Service should conduct a site-specific analysis before changes are made.

While most respondents are concerned with the effects of the Act on current livestock operations several people comment on the role of grazing in national forests. Livestock grazing on public lands is viewed as both a management tool, specifically an opportunity to enhance watershed and riparian conditions, and a environmentally degrading practice. Many of those respondents who espouse the latter view advocate prohibiting grazing on all national forests.

Public Concern: The FEIS should not include any management criteria for livestock that differ from existing policy in the Plumas, Lassen and Tahoe Forest Plans.

The Act specifically states (Section 401 )(c)(2)(c) that application of the Scientific Analysis Team guidelines for riparian protection is required where livestock grazing is being conducted in the specific location at which the guidelines are being applied to a specified resource management activity. These activities are construction of defensible fuel profile zones, group selection harvest, individual tree selection harvest and riparian restoration projects. This means that any location where a resource management takes place in a riparian habitat conservation area is an area that management standards specific to grazing in the Scientific Analysis Team Report will be applied. The guidelines direct that "grazing practices be promptly adjusted to eliminate adverse effects of domestic and wild ungulates on riparian resources." It is likely therefore, that some adjustment may be necessary to ensure that the Scientific Analysis Team guidelines, as they apply to riparian area management, are implemented in order to fully comply with the Act.

Public Concern: The Forest Service should inform allotment holders of projects in or near their allotments and include these people in developing grazing guidelines.

Whenever a resource management activity planned for implementation falls inside a grazing allotment, the term grazing permittee(s) for that allotment will be consulted to facilitate planning the activity. This consultation is required by the National Environmental Policy Act and Forest Service policy.

Public Concern: The Interdisciplinary Team should consider the location of range allotments and the timing of grazing season when selecting pilot project areas and conduct a site-specific analysis before changes are made to livestock management requirements.

The location of activities and timing of implementation is influenced by a number of factors. Grazing permittees will be afforded the opportunity to provide to participate in site-specific analysis conflicts with grazing can be addressed and remedied effectively.

Public Concern: The Forest Service should consider grazing as a management tool.

Determination that grazing is an appropriate management tool is outside the scope of this FEIS. Site-specific analysis will provide the opportunity to consider grazing management, along with other management methods, as a tool to achieve desired conditions.

Public Concern: The Forest Service should end grazing in the national forests.

Use of National Forest System lands for livestock grazing is beyond the scope of this FEIS. Rangeland management on National Forest System lands is provided for in law, including the Multiple Use, Sustained Yield Act and the National Forest Management Act. The Forest Service does not have authority to change these laws. Such authority is reserved to Congress.

Public Concern: The FEIS should consider the effects of grazing, particularly on vegetation and fuels management, in the scope of activities affecting implementation of the pilot project.

Implementation of any resource activity described in the alternatives will consider the effects of the activity on the environmental, including vegetation, through site-specific analysis. Livestock grazing is not a resource activity as defined by the Act and will not be subject to analysis, except where it overlaps riparian habitat conservation areas.

Public Concern: The FEIS should include grazing management guidelines that comply with the Recissions Act of 1995.

The DEIS mentioned that livestock permits will be allowed only where site-specific analysis has been completed. This does conflict with direction provided by the Recissions Act of 1995. The statement was not incorporated in the FEIS.

Recreation and Tourism
Roads, campgrounds, trails and other recreational opportunities on the national forests in the pilot project area are important to many people. Respondents ask that alternatives in the FEIS protect recreational resources and opportunities.

Public Concern: The Forest Service should ban vehicles on trails and not construct off-road vehicle routes.

The banning of vehicles on trails and the construction of off-road vehicle routes is beyond the scope of the FEIS.

Public Concern: The implementation of the Act should not be allowed to damage recreational resources in the project area.

Recreation resources will be considered, evaluated, and protected during site-specific implementation.

Public Concern: The FEIS should avoid locating defensible fuel profile zones along the Pacific Crest Trail.

Section 7(a) of the National Trails System Act (Public Law 90-543) provides that the presence of the trail shall not preclude the application of normal management practices on lands it crosses. Page 32 of The Pacific Crest Trail Guide for Location, Design, and Management states, "The existence of the trail, in general, will not dictate the management of the lands it traverses. Rather, the management of the trail will reflect the management of the adjoining land." The location of defensible fuel profile zones is best addressed at the site-specific level. Any affects on the visual resource will be addressed during implementation.

Wilderness and Wild and Scenic Rivers
Those people who mention "wilderness" often use the term to describe a natural or pristine area, rather than an officially designated wilderness area. In this context, they believe, wilderness or wild lands should be preserved and not sacrificed for what some term "short-term financial gain." Rivers should also receive special protection, according to some respondents; they suggest that the Forest Service conduct a survey of all potential Wild and Scenic Rivers and recommend eligible streams for official Wild and Scenic River designation. A few respondents are concerned that limiting activities in certain areas to provide for California spotted owls, American marten and Pacific fisher, or maintain old growth forest conditions will result in de facto wilderness designation.

Public Concern: The FEIS should consider more wilderness designations.

The Act does not directly deal with the designation of more Wilderness. Although the implementation of the FEIS at the site-specific level will require consideration of the roadless character of relevant lands, the authority for a decision to designate Wilderness lies with Congress. Recommendations by the Forest Service for inclusion of specific lands in the National Wilderness System are generally made in Forest Plans.

Public Concern: The Forest Service should preserve wilderness.

Wilderness management objectives, guidelines and standards are identified in Forest Plans of the Lassen, Plumas, and Tahoe National Forest covered by the Act and this FEIS. No modification of current management direction for Wilderness Areas will occur as a result of this FEIS.

Public Concern: The Forest Service should complete a Wild and Scenic River survey and nominate all eligible streams and rivers for designation.

The Wild and Scenic River Program is a part of the Forest Plans process and beyond the scope of this FEIS.

Monitoring Strategy
Monitoring the effects of the pilot project on social and environmental conditions in the pilot project area, respondents point out, plays a central role in the Act. Many are concerned by what they view as a lack of clear direction for carrying out monitoring in the DEIS. They ask that the FEIS include a comprehensive effectiveness monitoring plan.

Public Concern: The Forest Service should address how proposals in the FEIS will be implemented, monitored, and accounted.

An monitoring strategy was designed for the FEIS (Chapter 6). The Act requires an annual status report provided to Congress that includes: (a) an accounting of funds; (b) a description of treatment acres; (c) forest health improvements; (d) fire-risk reductions; (e) water yield increases; and (f) other natural resource-related benefits achieved by implementation. Additionally, the report will include: (a) a description of economic benefits to local communities achieved by implementation; (b) a comparison of revenues generated by, and costs incurred in, implementing the activities described in the Act with the revenue and costs for timber management of such lands before their inclusion in the pilot project; (c) a proposed schedule of management activities for the upcoming year; and (d) a description of any adverse environmental impacts from the pilot project.

Public Concern: The FEIS should include a comprehensive effectiveness monitoring plan.

The FEIS contains a comprehensive monitoring strategy in Chapter 6. It includes implementation and effectiveness monitoring, plus an adaptive management strategy. Reporting requirements of the Act are included for environmental, economic, and fire and fuel impacts, both positive and negative.

Public Concern: The FEIS should specify that monitoring during implementation of the Act use the best available science.

Chapter 6 of the FEIS contains a monitoring strategy to be used during implementation. The strategy was developed with the most accurate information currently available, including the Forest Health Pilot and Best Management Practices monitoring, as well as new information designed to supplement and improve current monitoring efforts.

INCLUDED COMMENTS LIST
The included comment list is an index of the comments included in the FEIS.
 

Federal and State Elected Officials PDF File Link
State of California State Assemblyman, District 2 (Q1666) 153KB
State of California State Senator, First District (Q1769) 341KB
State of Wisconsin, State Representative, 36th Assembly District (Q1514) 72KB
The Honorable Dianne Feinstein, United States Senate (Q13) 337KB
Native American Nations, Tribes, and Bands
Maidu Cultural and Development Group (Q1097) 366KB
Mooretown Rancheria (Q709) 257KB
Pit River Tribal Council, Hammawi Band (Q129) 1,078KB
Pit River Tribe (Q139) 433KB
Federal Agencies
United States Department of Agriculture, Forest Service, Adaptive Management Services (Q838) 121KB
United States Department of the Interior, Fish and Wildlife Service (Q1807) 177KB
United States Environmental Protection Agency, Region IX (Q183) 2,261KB
United States Environmental Protection Agency, Region IX (Q1806) 2,148KB
State Agencies PDF File Link
State of California
Department of Forestry and Fire Protection (Q112) 680KB
Department of Parks and Recreation, Division of Off-Highway Motor Vehicle Recreation (Q1294) 238KB
Department of Transportation (Q194) 171KB
Regional Water Quality Control Board, Lahontan Region (Q22) 636KB
Regional Water Quality Control Board, Lahontan Region (Q1808) 519KB
The Resources Agency, Department of Forestry and Fire Protection (Q95) 381KB
State of Nevada Division of Environmental Protection (Q148) 214KB
City, County, and Local Governments and Agencies
Alpine County Superintendent of Schools (Q586) 217KB
Boise County Board of County Commissioners (Q1467) 406KB
Butte County
Air Quality Management District (Q138) 354KB
Air Quality Management District (Q1591) 222KB
Board of Supervisors (Q843) 712KB
Department of Public Works (Q1321) 184KB
Schools Superintendent (Q332) 136KB
Coos County Board of County Commissioners (Q418) 162KB
Curry County Commissioner (Q417) 185KB
Davis City Councilwoman (Q1765) 203KB
Glenn County Board of Supervisors (Q1630) 609KB
Kane County Superintendent of Schools (Q415) 217KB
Lane County Commissioner (Q398) 220KB
Lassen County PDF File Link
Board of Supervisors (Q193) 189KB
Board of Supervisors (Q1313) 898KB
Office of Education (Q1606) 243KB
Modoc County Board of Supervisors (Q1415) 434KB
Mono County Superintendent of Schools (Q567) 212KB
Northern California County Supervisors Association (Q985) 236KB
Northern Sierra Air Quality Management District (Q140) 460KB
Northern Sierra Air Quality Management District (Q1748) 1,326KB
433KB
3,221KB
3,523KB
259KB
1,330KB
QLG Counties Forester (Q1798) 742KB
Plumas County
Board of Supervisors (Q2900) 417KB
County Supervisor, District 3 (Q328) 185KB
Department of Public Works (Q512) 251KB
Regional Council of Rural Counties (Q530) 255KB
Shasta County
County Supervisor, District 2 (Q1318) 194KB
County Supervisor, District 3 (Q1317) 430KB
County Supervisor, District 4 (Q1640) 433KB
County Supervisor, District 5 (Q1421) 432KB
Sierra County Board of Supervisors (Q146) 466KB
Siskiyou County
Board of Supervisors (Q215) (Q1057) 231KB  239KB
Board of Supervisors, Chair of the Board (Q1037) 200KB
County Supervisor, District 4 (Q703) 139KB
Tehama County Supervisor, District 3 (Q60) 356KB
Tulelake Basin Joint Unified School District (Q585) 183KB
Yuba County Board of Supervisors (Q1871) 545KB

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