SNFPA Final Supplemental Environmental Impact Statement
January 2004
Response to Public Comments
2. Alternatives
Alternatives, General
2.1. Public Concern: The Forest Service should write the Final SEIS in plain, clear language.
Response: Comments regarding the readability of the document were considered when drafting the final SEIS to improve readability and clarity.
2.2. Public Concern: The Final SEIS should clarify that there is one preferred alternative.
Response: The Draft SEIS identifies only one preferred alternative (S2). The Final SEIS also makes this clear. The Draft SEIS provides a detailed analysis for two alternatives and summarizes the detailed analysis of the Alternatives F2 through F8 from the SNFPA FEIS. The environmental consequences for the original SNFPA alternatives are described in detail in the SNFPA FEIS and are not repeated in the SEIS. Alternative S1 would continue management under the existing SNFPA Record of Decision (ROD, January 2001). Alternative S2 proposes changes to specific elements of the existing ROD as described in Chapter 2 of the SEIS.
2.3. Public Concern: The Final SEIS should improve the analysis to distinguish between the various alternatives. The Draft SEIS analysis of alternatives F2 through F8 is conducted through reference to the FEIS and does not appear to include an updated analysis based on the purpose and need and new information which triggered the review. These procedural problems hinder the document's ability to support a decision under NEPA.
Response: SNFPA alternative development included extensive collaboration and feedback from non-governmental organizations, interest groups, other government agencies, and participants in public meetings to ensure a full range of alternatives (See FEIS Chapters 1 and 2.). For the SEIS, the purpose was not to reconsider broad changes in overall program direction. The SEIS was initiated to incorporate new information and adjust the management direction in the existing SNFPA ROD to better achieve the goals of the SNFPA. This new information has resulted in some minor adjustments to assumptions about how work can be completed on the ground as well as the effects of implementing prevailing management direction. The SEIS relies very heavily upon the analysis presented in the FEIS and incorporates that information rather than repeating it. The analysis of effects for Alternatives F2 through F8 and Modified F8 can be found in the SNFPA FEIS and ROD.
The environmental consequences for the Alternatives F2 through F8 and Modified F8 were described in detail in the FEIS (Volumes 2 and 3, Chapter 3). The SEIS compares the environmental consequences associated with modifications (Alternative S2) to existing management (Alternative S1). Chapter 4 of the FSEIS provides more specific information for resources that could be sensitive to differences between alternatives. The Final SEIS provides comparative data for each alternative, based on the best available information for each affected resource.
2.4. Public Concern: The Final SEIS should include a comparative analysis of the alternatives' implementation costs and social and economic impacts to the public.
Response: An extensive assessment of the social and economic effects of the alternatives is provided in Chapter 3, Part 6 of the FEIS (Volume 2, pages 534-567). Forest Service budget projections were addressed for the programs in the FEIS analysis in Section 6.4 (Volume 2, pages 3-549 to 3-551). Cost efficiency associated with implementing fuels treatments is a reflection, in part, of the types of treatments, the number of acres treated, the cost per acre of the treatments, and any revenues generated by the treatments. The Final SEIS includes an expanded comparative analysis of cost efficiency associated with fuel treatments under Alternatives S1 and S2.
Projections indicate that neither Alternative S1 nor S2 is expected to generate sufficient revenue to fully cover the costs associated with fuel treatments. It is difficult to predict actual funding in future years as this is a decision made by Congress for each fiscal year. The Forest Service uses the program cost projections to request funds from Congress. Funding for each fiscal year will vary as Congress considers current issues and balances Forest Service requests with other national priorities. If full funding for implementation and monitoring is not available, Forest Service officials develop priorities for funding. It is the intent of the Forest Service to develop these priorities in a collaborative environment with the public and other government agencies. In the development of the Final SEIS, the issue of funding has been considered in more detail. Cost estimates have been refined and reflected in Forest Service budget projections. The monitoring and adaptive management plan has been evaluated to develop less costly ways to achieve desired monitoring results and to focus monitoring efforts. The interdisciplinary team has worked to make the alternatives feasible to implement through refinements in the standards and guidelines.
2.5. Public Concern: The SEIS should include a broader range of alternatives.
Response: Each action alternative in the SNFPA FEIS was designed around a theme for managing old forest ecosystems; aquatic, riparian, and meadow ecosystems; fire and fuels; noxious weeds; and hardwood forest ecosystems, and to respond to one or more of the significant issues. Alternative formulation by the Interdisciplinary Team included extensive collaboration with and feedback from non-governmental organizations, interest groups, other government agencies, and participants in public meetings to ensure a range of alternatives. This process is described in the FEIS Chapters 1 and 2, especially pages 4 through 7 and 12 through 16 in Chapter 1 and pages 2 through 17 in Chapter 2.
Under the National Environmental Policy Act, environmental analyses must consider a range of alternatives that address the significant issues and meet the need for the proposed action. The alternatives in the SNFPA FEIS represent a range of alternatives. The SEIS supplements the FEIS, bringing the action alternatives from the FEIS forward as alternatives considered in detail (DSEIS, page 38). The SEIS compares two additional alternatives (Alternatives S1 and S2) in light of the purpose and need to consider adjustments to the existing SNFPA Record of Decision to improve the likelihood of meeting existing goals and objectives.
2.6. Public Concern: The timber volumes associated with the alternatives in the Draft SEIS are not the same as those in the SNFPA FEIS. Total timber harvests for both Alternatives S1 and S2 in the Draft SEIS are somewhat less, and sawtimber harvests are slightly more. The Final SEIS should resolve these discrepancies.
Response: Differences in projected timber harvest outputs between the FEIS and Draft SEIS are due several reasons:
The analysis of Alternative S1 in the Draft SEIS was designed to be consistent with management direction for Modified Alternative 8 as implemented through the SNFPA ROD. The ROD included constraints that were not analyzed for Modified Alternative 8 in the FEIS, for example leaving 10 to 25 percent of the acres projected for mechanical treatments in an untreated condition (SNFPA ROD, pages A-26, A-41, A-44, A-46, and A-47). Adding in these constraints reduced timber outputs for Alternative S1 compared to Modified Alternative 8 as analyzed in the FEIS.
Since the time that the SNFPA ROD was signed in January 2001, significant discoveries were made regarding fuel treatments. Two large landscape analyses based on management direction in the SNFPA ROD revealed that fuels treatment units should be strategically located across broad landscapes to effectively interrupt fire spread. Hence, the SEIS analyzes strategically placed treatment areas across landscapes to resemble a herringbone or tread pattern which more closely matches the pattern based on Dr. Mark Finney's work as described in Appendix J of the FEIS (SEIS, Appendix B). The analysis in the FEIS located strategically placed area treatments nearly exclusively on the upper two-thirds of south- and west-facing slopes. This means different mixes of stands are being treated under both Alternatives S1 and S2 compared to alternatives that adopted a SPLAT strategy in the FEIS (Alternatives 3, 4, 5, 6, 7, 8, and Modified 8), even when the total acres treated are very similar. In addition, since the ROD was signed, managers on each national forest have remapped and adjusted their wildland urban intermix zones (defense and threat zones), based on SNFPA ROD direction for locally determining the locations and boundaries of this land allocations. The analysis in the SEIS is based on these locally determined defense and threat zones, which were not available for the analysis in the FEIS.
The model considers timber production as a by-product of the management program. Therefore, timber production is not a consideration when the model selects among multiple prescriptions that are permissive on a given land allocation. Objectives other than timber output are driving the analysis. Therefore, since there are a multiple ways of doing a fuels treatment, individual model runs often produce slightly different outputs for the same management program.
The Final SEIS modeling appendix (B) describes the assumptions linked to timber harvest outputs in greater detail.
2.7. Public Concern: The Forest Service should consider the practicality of the standards and guidelines when selecting an alternative.
Response: Implementation issues associated with standards and guidelines in the existing SNFPA ROD were addressed during the SNFPA review. Management recommendations for changes to the existing direction for Sierra Nevada national forests considered the feasibility and ease of implementing modified and new standards and guidelines. The ability to implement standards and guidelines is of the utmost importance to the Forest Service.
2.8. Public Concern: The Forest Service should develop management prescriptions on a case by case basis for each different ecosystem.
Response: The Sierra Nevada Forest Plan Amendment is not intended to be a "one size fits all" policy. The SNFPA was designed to provide consistency in managing for sustaining desired environmental, economic, and social conditions across the Sierra Nevada. Actual implementation of management actions based on SNFPA direction would be designed using techniques that fit local conditions and would be based on input from local governments, landowners, businesses as well as other interested individuals and agencies. The proposed changes to the existing SNFPA ROD described in the SEIS were developed to provide additional flexibility for adjusting management practices to respond to different site conditions and local knowledge. Project-level planning would be conducted for each proposed action, and would include public involvement and detailed, site-specific environmental analysis.
2.9 Public Concern: The Forest Service should formalize the Middle Fork Cosumnes analysis process as an alternative focused on developing locally appropriate management prescriptions.
Response: The description of Alternative S2 (the preferred alternative) in Final SEIS includes management direction for conducting an analysis process similar to that developed for the Middle Fork Cosumnes during the SNFPA Review to strategically locate fuels treatments and develop locally appropriate management prescriptions. In addition, project-level planning would be conducted for each proposed action, and would include public involvement and detailed, site-specific environmental analysis.
2.10. Public Concern: The Forest Service should adopt the alternative that pursues an aggressive fuels treatment program. The Forest Service should adopt the alternative that provides fuel treatments to the greatest number of acres.
Response: The SEIS preferred alternative (Alternative S2) is based on the SNFPA Review Team's recommendations in response to direction from the Chief and Regional Forester to "identify opportunities to pursue more aggressive fuels treatments while protecting old forest conditions and species at risk." Yet, the agency must plan for programs that are within anticipated budgets provided by Congress. Alternative S2 in the SEIS was developed to provide opportunities to reduce hazardous fuels over more acres by using the revenues from the harvest of some larger trees to help cover the costs.
2.11. Public Concern: The SEIS should detail how each alternative will accomplish fuel reductions to reach condition class one.
Response: The SEIS describes how Alternatives S1 and S2 share overarching goals for fire and fuels management that includes meeting ecological goals for re-introducing fire. Strategically placed area treatments are first designed to change landscape wildland fire behavior; over time the goal of the treatments shifts toward restoring fire regimes and condition class across the landscape. The Final SEIS includes an analysis of the effectiveness of treatments in modifying fire behavior across landscapes which then facilitates the re-establishment of fire as a process. The use of fire as the follow-up/maintenance treatment is intended to provide for the process restoration in treated areas.
2.12. Public Concern: The Final SEIS should include stand and landscape level analyses to illustrate fire suppression efficiency differences for Alternatives S1 and S2.
Response: The SNFPA FEIS (Volume 2, Chapter 3, part 3.5) discloses the long-range effects of fire suppression combined with limited fuel treatments on fire effects and fire intensity. It also describes various fuels treatment methodologies and the costs of fire suppression. The "Environmental Consequences" section displays reductions in projected acres burned under each alternative, and it also discusses the effectiveness of treating surface, ladder, and crown fuels. The SEIS displays projected wildfire acres burned and severity of effects under Alternatives S1 and S2. The Final SEIS l includes a discussion of treatment effectiveness.
2.13. Public Concern: Without explanation or supporting evidence, the analysis in the Draft SEIS assigns greater risk to mechanical treatments than no treatment or prescribed fire. This is inconsistent with the assigned risk of wildfire, which has the greatest degree of uncertainty. Alternatives with the highest risk of wildfire rank lowest in the Draft SEIS's assessment of risk. This runs contrary to the purpose of the Draft SEIS. The Final SEIS risk assessment should include an assessment of risk based on the estimated acres disturbed by wildfire.
Response: The Draft SEIS does address potential risks associated with projected wildfire acres burned and the severity of wildfire effects. (See wildfire effects for Old Forest Ecosystems on page 149 of the Draft SEIS, Forest and Vegetation Health on pages 156 and 158, Aquatic, Riparian, and Meadow Ecosystems on pages 159 and 160, Fire and Fuels on pages 161 through 164, Noxious Weeds on page 166, Fisher on page 175, Marten on page 180, and California spotted owl on pages 191 and 192.) The Draft SEIS analysis indicates that differences in projected wildland fire acres between Alternatives S1 and S2 vary over time, with the greatest differences projected to occur 50 to 80 years into the future (DSEIS, pages 162 and 163). Under Alternative S2, habitat projections for California spotted owls benefit from reductions in wildfire acres burned and severity of effects by the fifth decade (DSEIS, page 194). Much of the change in fire effects is not projected to show until after the 20-year analysis horizon, and there is greater uncertainty in the outcome of longer-term effects. The Final SEIS includes refinements to discussions of risks associated with projected wildland fires on old forest ecosystems, aquatic, riparian, and meadow ecosystems, and species associated with these ecosystems.
2.14. Public Concern: The Forest Service should adopt the favorable elements from other alternatives that would provide the greatest decline in wildfire acres, greatest increase in old forest conditions, and the greatest economic benefit.
Response: The alternatives in the SNFPA FEIS represent a range of alternatives to meet the stated purpose and need (FEIS, Volume 1, Chapter 1, pages 4 through 7). The FEIS describes the process used to develop the alternatives (FEIS, Volume 1, Chapter 2, pages 5 through 17). The SEIS supplements the FEIS, bringing the action alternatives from the FEIS forward as alternatives considered in detail. The SEIS compares two additional alternatives (Alternatives S1 and S2) in light of the purpose and need to consider adjustments to the existing Record of Decision to improve the likelihood of meeting the goals and objectives of the Sierra Nevada Forest Plan Amendment. The Responsible Official will consider projected effects, risks, costs, and uncertainties associated with each of these alternatives in formulating a decision that addresses the need to reduce the buildup of excessive forest fuels and the need to conserve key habitats for at-risk species associated with old forest ecosystems
2.15. Public Concern: The Final SEIS should include road construction, reconstruction, and maintenance cost estimates for each of the alternatives.
Response: Road construction costs associated with Alternatives S1 and S2 have been added to the Final SEIS.
2.16. Public Concern: The Forest Service should only consider alternatives that adhere to the Chief's direction to refine, not re-write, the Framework.
Response: The Pacific Southwest Region of the Forest Service has met the intent of the Chief's appeal decision and work plan. The Forest Service received more than 200 appeals of the ROD. The Chief affirmed the ROD but directed the Regional Forester of the Pacific Southwest Region (Regional Forester) to review certain elements of the decision. The Regional Forester and SEIS interdisciplinary team have worked closely with the Chief and his staff to assure consistency with the intent of the appeal decision.
On December 26, 2001, the Undersecretary of Agriculture for Natural Resources and Environment (Undersecretary) returned the SNFPA decision to the Forest Service, electing not to conduct a discretionary review. The Undersecretary expressed confidence that the Regional Forester would develop an aggressive plan to respond to the Chief's appeal decision with an open, public review of SNFPA. On December 31, 2001 the Regional Forester chartered the SNFPA Review Team (Team) to evaluate the SNFPA ROD and recommend any needed changes in six specific areas.
- pursue more aggressive fuels treatments while still protecting old-forest conditions and species at risk,
- improve compatibility with the National Fire Plan to ensure that goals of community protection and forest health are accomplished,
- implement the Herger-Feinstein Quincy Library Group Pilot Project to the fullest extent possible,
- reduce unintended and adverse impacts on grazing permit holders,
- reduce unintended and adverse impacts on recreation users and permit holders, and
- reduce unintended and adverse impacts on local communities.
The Team reviewed the appeals record and the Chief's appeal decision. The Team reviewed the SNFPA ROD and FEIS and supporting documents and gathered information concerning each of the above areas. The Team gathered input from national forests currently implementing SNFPA and former members of the SNFPA interdisciplinary team, held meetings with interest groups, sponsored field trips, and reviewed work products generated by the Regional Office SNFPA Implementation Team.
The findings of the year-long review are acknowledged in the SEIS. The review is documented in Sierra Nevada Forest Plan Amendment, Management Review and Recommendations (USDA Forest Service Pacific Southwest Region 2003).
2.17. Public Concern: The Forest Service should consider alternatives submitted by outside parties.
Response: All alternatives, including those proposed by the public, collaborators, and internal Forest Service staff, were given consideration. The process for developing the alternatives is described in the FEIS, Volume 1, Chapter 2, pages 2 through 17. Several of the alternatives in the FEIS are based on material submitted by outside parties during scoping, but they are Forest Service alternatives. Similarly, Alternatives S2 and S3 were developed by the Forest Service, after seeking input for many external sources. Alternative S3 was eliminated from detailed analysis in the Final SEIS because it does not differ significantly from Alternative S1.
2.18. Public Concern: The Forest Service should develop a range of alternatives designed to overcome fuel management funding shortfalls.
Response: It is difficult to predict actual funding in future years as this is a decision made by Congress for each fiscal year. The Forest Service uses the program cost projections to request funds from Congress. Funding for each fiscal year will vary as Congress considers current issues and balances Forest Service requests with other national priorities. If full funding for implementation and monitoring is not available, Forest Service officials develop priorities for funding. It is the intent of the Forest Service to develop these priorities in a collaborative environment with the public and other government agencies. In the development of the Final SEIS, the issue of funding has been considered in more detail. Cost estimates have been refined and reflected in Forest Service budget projections. The monitoring and adaptive management plan has been evaluated to develop less costly ways to achieve desired monitoring results and to focus monitoring efforts. The interdisciplinary team has worked to make the alternatives feasible to implement through refinements in the standards and guidelines.
The agency must plan for programs that are within anticipated budgets provided by Congress. Alternative S2 in the DSEIS was developed to provide opportunities to reduce hazardous fuels over more acres by using the revenues from the harvest of some larger trees to help cover the costs of fuels treatments.
2.19. Public Concern: The SEIS should include stronger protection measures for amphibians in each of the alternatives.
Response: Sierra Nevada Forest Plan Amendment Project goals include protecting and restoring desired conditions of aquatic, riparian, and meadow ecosystems in Sierra Nevada national forests and providing for the viability of species associated with these ecosystems (DSEIS, page 29). The 10 alternatives considered in detail in the SEIS represent different approaches for achieving these goals. All of the alternatives provide various protection measures for amphibians, ranging from alternatives with high degrees of local flexibility to develop protection measures based on local conditions to alternatives with less local flexibility, which rely on protection measures developed at the bioregional scale. Most alternatives use a mix of these approaches.
Alternatives S1 and S2 share similar protection measures, with a key difference being that, under Alternative S2, local managers have the option of developing a site-specific management plan to minimize impacts to the Yosemite toad and its habitat by managing the movement of livestock around wet areas. In addition, the Final SEIS description of Alternative S2's adaptive management and monitoring strategy includes provisions for adaptive management studies in four to six grazing allotments most heavily impacted by Yosemite toad grazing exclusion standards. Appendix A in the Draft SEIS presents standards and guidelines for aquatic habitats and amphibians for Alternative S1 and S2; Appendix D in the FEIS presents standards and guidelines for the other alternatives.
2.20. Public Concern: The Forest Service should develop an alternative that prioritizes watershed management.
Response: Alternatives S1 and S2 include Aquatic Management Strategy (AMS) goals and riparian conservation objectives. The fundamental principle of the AMS is to retain, restore, and protect processes and landforms that provide habitat for aquatic and riparian-dependent organisms, and provide and deliver high-quality waters for which the national forests were established (SNFPA ROD, page A-5). The Forest Service works with the CALFED program and is active in seeking Proposition 50 funding with local and State agencies as well as local watershed groups and non governmental organizations. Collaborative stewardship is an important Forest Service goal in managing the Sierra Nevada forests, and the Forest Service welcomes the participation of State and Federal agencies in working together to enhance and improve watersheds.
2.21. Public Concern: The Forest Service should replace five of the existing alternatives with new alternatives that promote timber harvest and benefits to local economies.
Response: The purpose of the SNFPA FEIS and the SEIS is to address the management of five identified problem areas: old forest ecosystems and their associated species; aquatic, riparian and meadow ecosystems; fire and fuels management; noxious weeds; and lower westside hardwood ecosystems. The purpose of the amendment is not to promote logging or other commercial activities, per se. The Sierra Nevada Review Team did recognize the production of wood by-products of mechanical thinning as an economic opportunity for local communities (DSEIS page 30).
2.22. Public Concern: The Forest Service should fully develop and consider Alternative 2.2.6 "Make Minor Changes to Individual Standards and Guidelines." The Forest Service could use the Middle Fork Cosumnes analysis effort as an example as to how standards and guidelines could be modified.
Response: Comments regarding the utility of the Middle Fork Cosumnes analysis effort are appreciated. The Middle Fork Cosumnes analysis helped the SNFPA Review Team identify implementation problems with certain SNFPA ROD standards and guidelines; however, the Review Team was directed to look for opportunities to improve a broader scope of management direction, for example, consequences to recreation users, recreation permit holders, and grazing permit holders as well as fire and wildlife interactions. Alternative 2.2.6 did not address the fundamental problems of the prescriptive nature of the existing management direction (economic inefficiencies, complications with implementation, questionable effectiveness of fuels treatments, and inability to treat enough acreage with available funds to effectively modify fire behavior or be responsive to the goals of the National Fire Plan). Moreover, the suggested alternative would not provide local managers with the flexibility needed to choose from an array of tools and techniques to better address site-specific conditions.
2.23. Public Concern: The Forest Service should select an alternative that: restores Sierra Nevada forests to pre-settlement conditions; improves short-term fire protections with strategic fuel reduction; simultaneously with fuel reduction, restructures forest to meets restoration goals; makes use of all available tools, including vigorous, well-regulated commercial timber harvest; and prioritizes cost-effectiveness.
Response: While forest and ecosystem health can be ambiguous terms, the intent for Alternative S2 is to restore conditions that would provide greater resilience to drought, climate change and related potential for severe insect/pathogen mortality events (DSEIS, page 45). Treatments to improve forest and ecosystem health and increase resilience to drought and other stressors will likely mimic pre-settlement conditions. In addition, desired conditions for old forest emphasis areas and general forest are aimed at developing forest structures and functions resembling pre-settlement conditions. This is described in greater detail in the Final SEIS.
Protecting life and property from wildfire is a priority of the National Fire Plan and the SNFPA, including the SEIS. To protect lives and property most effectively in the short-term, during the first 5 years of implementation of Alternative S2, 75 percent of fuels treatments would be conducted in the Wildland Urban Intermix (WUI) (DSEIS, page 46).
Concerning the comment on the need for a well-regulated timber program: Alternative S2 recognizes that all managerial tools, including commercial timber sales, are needed for effective fuels management. Alternative S2 provides mechanisms that allow fuels and forest health treatments to generate revenues through commercial forest products to increase the number of acres that can be treated with the available appropriated funds (DSEIS, page 47).