Frequently Asked Questions and Answers: SET 1

Compiled July 1997

Outline of Topics

Public Involvement
Coordination, Collaboration
Preferred Alternative
EIS Documents - General Questions
Activity Levels
Reconciling Northwest Forest Plan and ICBEMP
Reconciling Conflicting Management Emphases
Broad-scale vs. Local
Overcoming Gridlock
Implementation Prior to Land-use Plan Revisions
Future Revisions and Monitoring
Desired Ranges of Future Conditions (DRFCs)
Reviews and Analyses
Air Quality
Rangelands, Noxious Weeds
Terrestrial Species
Water, Aquatic Species
Below-Cost Sales
Economic Resiliency
Commodity Jobs, Outputs (Timber Volume, AUMs)
Changes Between Draft and Final

Frequently Asked Questions and Answers: SET 1


What is this project, and what are you producing?

The Interior Columbia Basin Ecosystem Management Project (ICBEMP) was started in 1993 by the U.S. Department of Agriculture, Forest Service, and the U.S. Department of Interior, Bureau of Land Management. It began at the direction of President Clinton. Chapter 1 and Appendix A (UCRB)/1-1 (Eastside) of the Draft EIS provide more detailed background information.

The project goal is to produce a science-based management strategy that addresses the big-picture issues affecting Federal lands--issues like forest health, rangeland health, and protection of bull trout. These are issues that cut across a large area, affecting numerous National Forests and BLM Districts.

The entire project area is 144 million acres. Within that, we are making decisions on about 72 million acres of Federal land administered by the Forest Service or the BLM. These decisions will update 74 Federal land-use plans for 45 National Forests and BLM Districts. These are listed in Appendix A(UCRB)/1-1(Eastside). No decisions are being made for private, State, tribal, or other lands.

To date the EIS Team has produced two draft environmental impact statements, or EISs, which were released in May 1997. One Draft EIS (Eastside) covers the BLM- or Forest Service-administered lands in eastern Oregon and Washington. The other (Upper Columbia River Basin [UCRB]) covers portions of Idaho, western Montana, northern Nevada, and small parts of Wyoming and Utah that are tributary to the Columbia River. (See maps 1-1 and 1-2 in Chapter 1 of the Draft EISs.)

The EISs are based on the efforts of the interagency Science Integration Team, which conducted an unprecedented examination of ecological, economic, and social systems in the project area. They looked at current as well as historical conditions, and produced a number of peer-reviewed scientific documents that were used by the EIS Team in preparing the Draft EISs. These are described briefly in Chapter 1 and more fully in Appendix A(UCRB)/1-1(Eastside) of the EISs. The Science Team also produced an evaluation of the ecosystem-based management alternatives developed in the Draft EISs.

Final EISs will be developed based on public comments received during the comment period. Record(s) of Decision will be issued following and based on the Final EISs.


Who is running this project?

The project is overseen by a group of 11 Federal executives. There are three Forest Service Regional Foresters; three BLM State Directors; one participant each from the National Marine Fisheries Service, the U.S. Fish and Wildlife Service, and the U.S. Environmental Protection Agency; and two Forest Service Research Station Directors. This group constitutes the project ICBEMP Steering Committee, which oversees the project with offices in Boise, Idaho, and Walla Walla, Washington.

The Regional Foresters and the BLM State Directors are the decision makers on the land management strategy resulting from this project and will sign the record of decision (ROD). The Station Directors provide the scientific support and foundation for the studies the project has undertaken. The role of the Federal regulatory agencies is to ensure compliance with Federal environmental laws such as the Endangered Species Act, the Clean Air Act, and the Clean Water Act.

Project Manager is Susan Giannettino of the Forest Service, located in Boise; Deputy Project Manager is Geoff Middaugh of the BLM, located in Walla Walla. They replace former co-Project Managers Steve Mealey and Jeff Blackwood. The names and affiliations of Steering Committee members, project management, and others involved in this project are provided in Chapter 5 of the EISs.


What is the goal of the project?

The overall goals are best stated in the "purpose and need": support people and communities, and restore ecosystem health. The purpose and need are discussed in great detail in Chapters 1 and 2.

In Chapter 3 the goals are spelled out in more detail. There are five specific goals for the project: (1) Sustain and where necessary restore the health of forest, rangeland, aquatic, and riparian ecosystems. (2) Provide a predictable, sustained flow of economic benefits within the capability of the ecosystem. (3) Provide diverse recreational and educational opportunities within the capability of the ecosystem. (4) Contribute to recovery and delisting of threatened and endangered species. (5) Manage natural resources consistent with treaty and trust responsibilities to American Indian tribes.


Why are you doing this project?

New information has surfaced indicating serious declines in or threats to forest, rangeland, and aquatic health and related social-economic systems in many places in the interior Columbia Basin and portions of the Klamath and Great basins. Ecological relationships have also become better understood. Federal managers are required to deal with significant new information and to incorporate it into natural resource management. This broad-scale, interagency approach with a sound scientific basis was called for because the issues are broad and cross many boundaries. The ecosystem-management approach also will allow us to be more cost-effective and consistent in our decision-making. The reasons for conducting the project are discussed in greater detail in Chapters 1 and 2 of the Draft EISs.

Who gave you authority to do this ecosystem management plan?

Chapter 1 (pages 8-9) of the Draft EISs describes a number of directives, commitments made through interim direction, court orders, and consultation requirements with regulatory agencies that provide requirements or authority for permanent, ecosystem-based management direction. A number of current laws governing management of Federal lands--including the Federal Land Policy Management Act, National Forest Management Act, and the Endangered Species Act--support an ecosystem-based management approach.

The science analysis covers such a broad area. How accurate can it be at the local level?

In some cases the broad-scale data may not match the fine scale or conditions on a particular piece of ground. The broad-scale assessments reveal trends and provide the bigger picture within which to place local information. Part of the subbasin review process is to validate the science information, as part of the next phase.

The economic assessments, particularly, are over-generalized and appear to gloss over or miss significant impacts at the community level. Do we reliably know what the local economic and ecological impacts of this project may be?

The project examined the characteristics and conditions of nearly 400 small rural communities, nearly half of these in detail. This information is summarized in the Draft EISs. Determining specific community-level economic impacts is limited because of the broad nature of the proposed strategies. The proposed levels of activities are for a geographic level of groups of geographically large subbasins. The intent is to maintain more flexibility in local decision-making. We are continuing to work with interested groups to address this concern.

The broad-scale analyses in the Draft EISs is sufficient to project actual environmental and economic impacts on the cluster level. As individual Forest Service or BLM land-use plans are amended or revised in the future, the environmental and economic impacts of the proposed management strategy will be disclosed for more specific geographic areas.


Why have the project managers allowed "inadequately and poorly reviewed, inconsistently and poorly supported material, and controversial methodology," to be included in such an important document as the Draft EIS? This is especially true of the social-economic studies and recreation and roadless area values.

All of the science documents coming from the project were subjected to a "double blind" peer review. The methodology used for translating recreation use levels into economic impacts was subject to peer review and is the best available. Disagreement among scientists does not always mean that the findings are inappropriate. Existence values for unroaded areas were not used in the Draft EISs, although they are presented in the science documents. The methodology for determining the existence value of unroaded areas is the best available and was subject to peer review. The use of contingent valuation and willingness-to-pay methods is a recognized and legitimate approach in the field of economics in estimating non-market values.

Currently there are plans to meet with groups concerned about the socio-economic studies and how they were used in the Draft EISs, to further define the concerns and work to find acceptable ways of addressing them in the Final EIS.


If this project makes no decisions for private, State, tribal, or other lands, why were these included in the Scientific Assessment?

The extent of the information gathered helps us understand the relationships among activities on private lands and public lands, and helps us understand the big picture. We need to understand these relationships so that reasoned decisions can be made on federally managed lands. We also needed to gather this information to meet the requirements of the National Environmental Policy Act (NEPA). This Act directs us to address a cumulative effects analysis, which looks at how Federal and non-Federal lands affect and are affected by each other's activities.

What if the science information is wrong? How do we fix it? For example, the historical range for bull trout doesn't seem right; how did they come up with it? Will the scientific documents be revised as new data and better science become available?

There are no plans to revise the broad-scale scientific assessment. However, some elements will be able to be corrected in the EISs for the Final. Also, the effects of our actions during implementation of this plan will be monitored and evaluated as discussed in the objectives and standards relative to monitoring in table 3-5 of the Draft EISs (AM-O2, AM-S3 through S7) and in the Implementation Framework appendix. This new information will validate and refine the scientific information.

For the bull trout range as for other topics, the science team used literature, historical accounts, and modeling. In some cases, what appear to be differences may be due to comparing broad-scale science information against fine-scale conditions. The science group is encouraging the validaton of the scientific information. The validated information would be used in monitoring and future management decisions.


What decisions are you making with this project?

The Forest Service and the BLM will decide on overall goals and objectives for managing lands in the project area administered by these two agencies. A desired range of future conditions (DRFC) will be part of the decision, along with the objectives to be used in measuring progress toward attainment of the management goals. We also will decide on required actions (standards) to meet the objectives. The decisions will update our land-use plans to respond to the major issues of forest, rangeland, and aquatic health and to meet social and economic needs. The Record(s) of Decision (RODs) will be based on the information presented in the Final EIS.

How will future management decisions be made?

We will use a collaborative approach to emphasize more local involvement in the decision process and to emphasize active participation of tribes, Federal regulatory agencies, and other levels of government and the public. It may be somewhat more time-consuming and expensive in the short term, but it likely will lower costs in the long term.

Before the ROD is signed, if there is a conflict between existing direction and the expected direction from the ICBEMP decision, do the Forests and BLM Districts continue to use existing direction and existing interpretations?

Until an ICBEMP Record of Decision (ROD) is signed, all Forest Service and BLM units would be required to be in compliance with their existing plans and direction. Following the ICBEMP ROD, management direction and land allocations in existing plans not directly superseded by the ROD would remain in effect. (This would include predominantly site-specific direction.)

What would be the likely consequences for Federal land management in the basin if the ICBEMP ended today without Final EISs or RODs? Would there be any barriers to implementing the features of the preferred alternative under current or revised plans?

Management of BLM- or Forest Service-administered lands would be vulnerable to legal injunctions. Interim strategies (such as PACFISH, INFISH, and Eastside Screens) would be vulnerable to lawsuits since they are supposed to be replaced by this project. Without the interim strategies, Endangered Species consultations on Land and Resource Management Plans for Snake River sockeye and spring/summer and fall chinook salmon would be moot, and the agency would be exposed to the same vulnerability to wide-ranging injunctions as were experienced in 1994 and 1995. Resolution of these injunctions would likely be difficult because of the lack of a consistent strategy for species protection across the range.

The project EISs represent the approach chosen by the agencies to incorporate the new scientific information from the Scientific Assessment into current land-use plans, which is required by law. Without these efforts, there could be an immediate need to incorporate the new information into existing plans by amendment, which would have a high impact on agency time and money.

Both the Forest Service and the BLM would face significant barriers in trying to implement the ecosystem-based features of the preferred alternative under 74 current land-use plans, or in trying to incorporate these features into plan revisions. Agency staffing levels and expertise are inadequate to develop new EISs outside a coordinated process such as this.


Will there be an extended public comment period?

At the present time the public comment period is scheduled to close on October 6, 1997. The ICBEMP's Executive Steering Committee will decide whether or not to extend the comment period.

Why was a teleconference used to initiate the public comment period?

The interior Columbia Basin project area is a very large area. We felt that the best way to reach a great many people and have broad participation was to hold a teleconference. It was not a substitute for having public meetings and open houses across the basin, which are scheduled for July and August. We believe it was best to start the process by delivering the same, consistent message to everyone at the same time. This kind of process enables all members of an audience to hear the information without disruption or distraction. We also wanted to introduce the decision makers to as many people as possible.

How can the Forest Service and BLM assure coordination when other groups have their own agendas, timelines, and priorities? How can you assure that coordination will happen when you don't control other agency budgets, missions, and operating procedures?

We are developing a Memorandum of Understanding that would help partners create a better understanding of what to expect from each other and identify where all partners can do a better job of coordination than in the past. The MOU may also address various agency timelines and how they can mesh better.

With respect specifically to tribal partners, for example, one expectation is that consultation will start early. They will be involved and informed early enough in any planning process that they can truly participate, not just react to proposals. That's one way we can be accountable for effective coordination.


What will be the role of regulatory agencies in Forest Service/BLM management decisions? Will collaborating Federal agencies such as EPA, NMFS, and USFWS have, in essence, equal or greater authority to the Forest Service and BLM in managing Forest Service- and BLM-administered lands? Will they have veto power over the Forest Service and BLM?

Agencies such as National Marine Fisheries Service (NMFS) and the Fish and Wildlife Service (USFWS) consult with the Forest Service and BLM on proposed projects and plans. The intent of interagency collaborative efforts is that they will result in: (1) increased understanding by regulatory agencies of Forest Service and BLM project plans and needs; (2) better understanding of available information and the major issues that should be considered by project managers; and (3) increased understanding of what we need to know to determine effects on sensitive, candidate, proposed, and listed species and the habitats they depend on. In turn, this effort should result in a net increase in timely and efficient project design and implementation, as well as increased conservation of fish, wildlife, and plant species.

These consultation efforts do not change or diminish the authority of Forest Service and BLM managers.


What will be the role of counties and other FACA-exempt groups in developing the ICBEMP Final EIS and future Forest Service/BLM land-use plans? Will they still be consulted during the earliest development of a plan?

It is expected that the counties, States, tribes, and advisory councils will play an important role in implementing the final strategy. As with developing the Draft EISs, they will be involved early and often in this and future efforts. This intent is addressed in objectives HU-O1, HU-O2, and EM-O2, and standards HU-S1 and EM-S3 in ch. 3 of the Draft EISs.

What methods and incentives are being planned to encourage the private sector to participate in and collaborate on ecosystem restoration programs?

The Draft EISs do not specifically address such incentives for ecosystem restoration programs, but objective HU-O6 was intended to encourage scheduling of implementation activities in areas of economic vulnerability that in turn would provide local jobs. We anticipate that most of the thinning, prescribed burning, and other restoration work will be accomplished by contracting with the private sector.

Will the process of coordination be spelled out in the Implementation Plan? At what levels (ERU, subbasin?) We have several task teams working on a process for implementation, which will include suggestions for effective coordination at various levels.

What does the "preferred" alternative mean? Are your minds already made up?

The preferred alternative, Alternative 4, is a starting point for discussion. We are looking for the best way to achieve the purpose and need, which is described in Chapter 1 of the Draft EISs. The final, selected, alternative will undoubtedly be different from this draft, preferred, alternative, based in part on the comments we receive from the public during the comment period.

How and when was the preferred alternative selected? To what extent were FACA-exempt advisory groups involved in the final selection of the preferred alternative?

The preferred alternative was chosen by the ICBEMP Executive Steering Committee, after numerous meetings with FACA-exempt groups including 22 Indian tribes, governor's offices from four States, a coalition of county governments, and a number of BLM and Forest Service advisory committees. We want a management strategy that will ensure affected people have a say in what happens on the landscapes in which they live.
EIS DOCUMENTS - General Questions

What are readers going to find in the EISs, and what are they not going to find?

They will see a strong emphasis on boundaries formed by watersheds, both large and small. The larger ones we call subbasins, which average about 800,000 acres. There are 164 of them in the project area. We group these subbasins with similar conditions into what we call "clusters." When the reader looks for the consequences of the alternatives, which is in Chapter 4, they will find the impacts reported for each EIS area. These are large areas, so there are several National Forests and BLM Districts aggregated together.

Since the EISs are at a broad geographic level, readers will NOT likely find much if anything about their favorite local areas. We summarized information for each EIS area. Readers will not find timber harvest levels for each National Forest. They will not find wildlife habitat impacts or impacts to fish at less than the whole EIS area. This kind of information will come at a more local level, from individual land-use plans on National Forests and BLM Districts.


What are "management activities"? Are they based on theme, objectives, standards, and are they an estimate of activities or something else? How were they derived for each alternative (how were the percentages arrived at)? Will they be adjusted between draft and final EIS?

Management activities, such as riparian restoration, timber harvest, and prescribed burning, reflect expected levels of activity by alternative. They are presented in tables 3-6 and 3-7 of the EIS, which were developed to reflect assumptions of how alternatives would be implemented.

The activities were identified following an initial process that assigned a management emphasis to each cluster by alternative, based on the conditions of the forest and range clusters and the themes of the alternatives; this included the priorities of conserve (C), restore (R), or produce (P), or some combination of these. The management emphases are summarized in table 3-10.

The activity tables were derived by taking the acres in each cluster and multiplying them by the percent of those lands where activities were expected to occur as described in the High (H), Medium (M), or Low (L) ranking in the ruleset (described in the EIS Appendix L (UCRB)/3-3 (Eastside)). Then ranges of activities for affected clusters were aggregated. The midpoint on these ranges were identified, and for analysis purposes, a variance of +/-15% from the midpoint was assumed.

Activity tables were developed to aid analysis, not to assign or allocate specific actions. Various mixes of Conserve, Restore, Produce are applied for each alternative, resulting in objectives and standards being applied differently depending on which emphasis is assigned to the alternative.

We may need to correct data in these tables for the Final EIS, but no numbers will be assigned to specific forests or areas. Decisions on specific project activities will be left to local BLM/Forest Service managers.


One of the reasons past projects have been blocked is the inability to satisfy cumulative impact assessment requirements. Do you believe the Scientific Assessment and Draft EISs provide the background information needed to conduct successful cumulative effects analyses on future projects? Because of the geographic and temporal scope of the EISs, they represent the functional equivalent of the cumulative impact analysis needed for wide-ranging species such as bull trout. The Final EISs will provide the cumulative impact analysis for the broad scale for on-the-ground projects implemented under this strategy, when activity level planning is tiered to and consistent with the overall plan. This will allow managers to focus their analysis at the watershed or project level.

Different disciplines (and agencies) define "roads" differently. What is your definition of a road? How will a common definition of a "road" be achieved?

The Draft EIS glossary provides this definition: BLM: A route open normally to highway vehicles (such as trucks and automobiles); the route may be improved, is maintained by mechanical means, and receives regular and continuous use; the route must have the purpose and intent to be maintained when necessary. Forest Service: Arterial roads are roads usually developed and operated for long-term land and resource management purposes and constant service; collector roads are those that collect traffic from Forest local roads, usually connecting to a Forest arterial road or public highway, operated for either constant or intermittent service depending on land-use and resource management objectives; local roads are roads that are constructed and maintained for a given resource use but also used for other purposes, with locations and standards usually determined by the requirements of a specific resource activity rather than by travel efficiency.

The definition will be clarified for the Final EIS.


What is a HUC? Is it the same as a subbasin?

A Hydrologic Unit Code (HUC) is part of a coding system developed by the U.S. Geological Service to map geographic boundaries of watersheds of various sizes. (See Chapter 2, UCRB page 2-4, Eastside page 2-6.) The HUCs are called (from larger to smaller) first-, second-, third-, and fourth-field HUCs; smaller HUCs are nested within larger ones. A subbasin represents a fourth-field HUC, or a unit of approximately 800,000 to a million acres. The ICBEMP also identified two smaller sizes of HUCs, fifth- ("watersheds") and sixth-field ("subwatersheds") HUCs, to aid in analysis and description. For an illustration of the hierarchical or nested nature of HUCs, see figure 2-1 in the Eastside Draft EIS, figure 2-2 UCRB. For sizes and examples of the various levels, see table 2-3 Eastside, 2-13 UCRB.

What are "timber and livestock priority areas"? Does this mean you are going to "give" some areas to ranchers and loggers? Riparian areas are great for cattle forage production, but fishing is good there, too. Why not call them "fishing priority areas"?

"Priority areas" were identified only for Alternative 5 as areas that are best able to produce products, goods, or services within the ecological capability of an area. Five resource priorities were considered: timber, livestock, aquatic resources, wildlife, and recreation. The assumption used in building Alternative 5 was that each forest and range cluster has a primary management priority and some have a secondary priority (presented in a table on page 3-43 of the Eastside Draft EIS, page 3-35 UCRB; and on maps 3-14 and 3-15). Other uses are likely to occur but any conflicts would be resolved in favor of the priority uses. Appendix 3-3 in the Eastside Draft EIS provides more background on the development of priority areas.

Where timber and/or livestock production are the primary priority, natural large-scale disturbances would be reduced to protect high resource values. In these areas, the aquatic strategy is to conserve remaining fish strongholds and high quality habitat and water, while producing high levels of timber and forage. Habitat is designed in these areas, and activities mitigated, to maintain minimum habitat components for species viability. Where wildlife is a secondary priority, habitat components may be maintained above those necessary for minimum viable populations.


The term "health"--forest, rangeland, ecosystem health--is used repeatedly. What exactly do you mean? This concept is valid only when applied to an individual organism, such as a person. It does not seem to apply to a system such as an ecosystem or a landscape. You have to be able to ask, "healthy for what?" How can the Draft EIS claim to be "science based" when many scientists have rejected the concept of health as applied to ecosystems? The science team dealt with the health issue from the standpoint of "integrity," which is defined in the EIS glossary. The EIS team used the science interpretation to discuss the concept in terms of the purpose and need. Our audience includes many who are not scientists. The public understands the concept of health, and in Chapter 2 (page 2-6 UCRB, page 2-9 Eastside) we provide a full page discussion of how the project used the terms "ecological integrity" and "ecosystem health". That discussion explains that we "used the term 'health' to refer to the capacity of forest, rangeland, and aquatic ecosystems to persist and perform as expected or desired [emphasis added] in a particular area." We may need a better definition and will look into ways to clarify this further.
Activity Levels

Activity tables 3-6 and 3-7 are arranged by cluster. One Forest or District may span several clusters. How does an individual unit figure out what level of activity it can do, and how its activities are going to mesh with choices of other units? Is there a strategy for allocating activities to various Forests or Districts, or for tracking the activity once the ROD is signed? The activity tables are not targets or allocations for individual Forest Service or BLM administrative units. We gave ranges of activities to indicate, "This is what we think is needed to get on top of the problem," but individual units will need to coordinate with others both to implement and to track the activities. The intent of the activity tables is to suggest what may be needed in the first decade to move toward achieving the objectives across the project area. The numbers themselves are not cast in stone.

On tables 3-6 and 3-7, are "harvest" acres distinct and separate from "thinning" acres and/or from "prescribed fire" acres? It makes a big difference in the level of activity to be implemented if the acres for thinning, harvest, and burning are the same acres or different acres. Sometimes prescribed burning, thinning, and timber harvest overlap; sometimes they are separate. We didn't specify beyond the cluster level.


Acres in table 3-6 include all forested acres. You haven't adjusted the table rates to account for riparian areas or wilderness or other areas, so the effective area for implementing the activities may be much different from what is shown. Are you going to provide better, more reliable figures in the Final EIS? We looked at total forest health concerns overall, regardless of administrative boundaries or designations. It may be true that actual acres where activities can occur may be slightly lower in some cases but we don't think the differences will be large. We will be reviewing these acres before the Final EIS is published, and we will modify acres as necessary.
Reconciling Northwest Forest Plan and ICBEMP

How will the implementation requirements of the Northwest Forest Plan (NWFP) be reconciled with the requirements of the Eastside EIS? For example, the NWFP is a reserve strategy; the ICBEMP is a restoration strategy. Some stands that are not "natural" do have spotted owls; the NWFP would say, "preserve this," the ICBEMP would say, "restore this to another condition," which may or may not be good for owls. Is it going to be up to each individual Forest or District to interpret how to choose when these two plans conflict? If there is truly a conflict, the Northwest Forest Plan (NWFP) takes precedence. However, we don't think that in general the two plans conflict; rather, the ICBEMP Draft EISs have been crafted to be complementary to and compatible with the NWFP as much as possible. The overall management emphases described in the Draft EISs do not require that each acre of ground will necessarily be managed with only one emphasis. Overall in the cluster the stated emphasis would prevail, but it is not incompatible that particular areas within a cluster may call for a different approach if needed for owls or other reasons. Collaborative efforts may help resolve problems that do arise.

We intend to look more closely for the Final EIS at specific areas where the NWFP and the ICBEMP plans overlap.

Reconciling Conflicting Management Emphases

How will these management emphases be implemented? For example, if a "Restore" (R) emphasis coincides with a place where an individual Forest Plan identified for timber production, how will the difference be reconciled? Can timber also be produced in an area marked as "Restore"? Does this change individual plan allocations if they conflict the new management emphasis? If in a "Restore" cluster a particular piece of land is not screaming for restoration but has the potential to produce, will timber still be able to be harvested? The new emphases would override old ones in general but the ICBEMP broad-scale emphases do not change individual plan allocations. The "Restore" emphasis does not preclude "Produce;" it just means a different kind of production. When we identify a general emphasis we aren't saying that this is the only thing that goes on every acre of the cluster; it's just the overall emphasis when you look at the whole picture. "Restore" can mean selling some timber or other products if the area stays within the desired range of future conditions. Sidebars in Chapter 3 of the EISs, beginning on page 3-6, explain more fully what we mean by Restore, Produce, and Conserve.


This project is a long-term forest health initiative, but to see any benefits in the near future, and to offer any hope to communities that rely on Federal lands for socio-economic benefits, there must be assurances that money will be appropriated in future Federal budgets that can adequately fund the plan. What assurances do we have that enough money will be appropriated to begin the planning process in the near future, and to implement the plan over time? What happens if full funding does not occur? What are the risks of not achieving the budget objectives?

The Federal agencies are preparing a coordinated budget request for implementation of the strategy for the Administration to present to Congress. Future funding is expected to become more balanced over time. If full funding does not occur, the rate of implementation will be decreased appropriately and proportionately.

Receiving less than full funding will make it harder to achieve the Desired Range of Future Conditions (DRFC) in 100 years. There will be a higher risk of more severe wildfires. We can help reduce this risk by carefully setting priorities for where activities occur, to provide the biggest return on every investment. Reduced funding also will mean reduced activity levels and a reduced number of restoration associated jobs. Reduced funding will affect the predictability of goods and services, which is one of the purposes of the plan.

We are currently putting together a Memorandum of Understanding, which will address in part what happens if one or more partner agencies does not receive the necessary funds from Congress.


What were the assumptions used for estimating the implementation cost of the preferred alternative? Were mitigation costs included? Do the budget estimates account for increased resource management agency costs for interagency, intergovernmental, and public consultation and involvement? Were costs of subbasin reviews, ecosystem analysis at the watershed scale, and monitoring at multiple scales taken into account? Implementation costs were projected for the various management activities shown in tables 3-6 and 3-7 of the Draft EISs. Average unit costs for these activities were based on information on file in the Regional/State offices and from published reports. Mitigation costs were not included in the implementation costs; they are more appropriately identified during specific project planning. Cost estimates were included for interagency, intergovernmental, public consultation, public involvement, subbasin reviews, ecosystem analysis at the watershed scale, and monitoring at multiple scales. See Table 4-65 in the Draft EISs.
Broad-scale vs Local

How will this broad-scale strategy work at the local level? The data and information contained in the strategy is extremely coarse and inappropriate for use at the Forest and District levels. Yet people on the ground will have to operate on a site-specific, per-acre basis. How will individual units take the broad-scale intent of the objectives and apply the fine-scale standards (such as requirements for snags and coarse woody debris)? Must these standard requirements be retained on every acre at all times?

Within the Draft EISs there are processes for bridging broad-scale information to fine-scale application. For example, Subbasin Review will assist Forests and BLM Districts to translate the broad-scale information into local priorities. (See table 3-5, EM-O3, EM-S1 through -S3, and their rationale statements for more details.) Ecosystem Analysis at the Watershed Scale provides a mechanism to adjust standards to meet local conditions, when followed by a NEPA analysis and decision (as described in EM-S13). These in turn will be used in designing on-the-ground projects, having taken into account the broad- and mid-scale information.

In general, standards are not meant to be interpreted as something we want to ensure on every acre. For the Final EIS we will be looking at snag, wildlife, and coarse woody debris requirements to figure them on a broad scale, not per acre. We may need to define other units of measure instead of per-acre, to show how a Forest or District can measure whether it is achieving the standard at the different scales.


How will you make sure that each Forest or District can go about its individual business, and still aggregate up to make sure that objectives are being met at the landscape scale, that units are consistent with each other?

This is the new way of doing business. A unit will not be able to find its own piece of an objective or standard and just go do it. People will need to look forward and back in time, and in all directions in space, to coordinate with others and understand the big picture. It will have to be a coordinated approach. There will certainly be reasons why one place will be different from another, but people will have to be talking to each other and know what others are doing. Objectives HU-O1, HU-O2, HU-O8, and TI-O1, and standards HU-S1 and TI-S1, in table 3-5, contain direction and guidance for accomplishing effective collaboration and coordination.

Adoption of the broad-scale plan may amount to revision of harvest levels for individual Forests prior to a true evaluation of the timber harvest estimates and land allocations specified in each Forest Plan, which may be several years away. What is the risk that implementing this broad-scale plan at the local level will be legally inconsistent with NFMA?

We feel the adoption of this broad-scale management strategy is consistent with the National Forest Management Act (NFMA), as was shown with the Northwest Forest Plan. Our intent with this broad strategy is to provide the framework for forests to revise their land management plans without having to reopen these broad-scale issues that are difficult and inefficient to address by individual units.

We recognize that this broad-scale strategy is going to affect future timber harvest levels. Adjustments or changes to land allocations and outputs will be made by individual forests through the amendment or revision process. It is our intent that this project will help reduce the time and energy needed to make those changes by focusing the forests on more localized issues.


How does this new direction fit with current land-use plans and other efforts such as State Resource Advisory Council (RAC) standards and guidelines?

When ICBEMP and other Forest Service or BLM plans in the project area talk about similar subjects, this plan will automatically amend existing Forest Service or BLM land-use plans. This is addressed in Chapter 1 (UCRB pages 14-19, Eastside pages 19-26). How exactly this will work is being addressed by the Implementation Team.

When land-use plans undergo revision, the intent is for revisions to incorporate the decisions we've made through this process. Forest Service and BLM land-use plans will need to tier to this plan, which says what needs to be done; how things are done will be left to the local level.

We are studying the standards and guidelines being developed by RACs in various States to see whether there are conflicting elements and to determine how comprehensively they will be incorporated into the Final EIS.

The relationship between this and other planning efforts at the Federal, State, tribal, and local levels is discussed in Chapter 1 (UCRB page 16, Eastside page 23).

Overcoming Gridlock

How will the requirements of new studies, shared management responsibilities, and increased accountability for compliance with more than 90 new objectives and standards remove or even reduce the current gridlock in public land management? By using the best available scientific information and working closely with States, tribes, counties, advisory councils, and interested individuals, we will avoid the gridlock that gripped the westside of the Cascade Mtns. for nearly a decade. By proactively approaching important management issues before listings of species under the Endangered Species Act are warranted and lawsuits are filed, we hope to keep these decisions with resource managers and out of the courts.
Implementation Prior to Land-Use Plan Revisions

What provisions are being made for the implementation phase of the selected strategy, which would be in effect following the ROD(s) but before BLM/Forest Service land-use plans are revised? During that period, projects and programs would be modified and budgets would be affected, but outputs and land allocations would not be changed. What potential difficulties does this pose for compliance with land management legislations?

We are working on several strategies that will help provide for the consistent and coordinated application of the decisions made in the ROD across the 45 affected BLM and Forest Service administrative units. These include: developing a process for incorporating and displaying new decisions in existing plans; developing a monitoring strategy that goes across administrative boundaries for the purpose of determining if management actions are being implemented as anticipated and having the desired basin wide effects; developing a plan for coordination among administrative units and among Federal agencies; and developing a strategy for continuing collaboration with States, tribes, counties, and advisory councils during implementation.

We anticipate that some inconsistencies between new basin wide decisions and existing local land allocations may be come apparent as implementation proceeds. As these inconsistencies appear, individual National Forests and BLM Districts will assess the need to amend plans to conform land allocations as needed to meet basin wide goals and objectives.

Future Revisions and Monitoring

What processes are being built into land management programs to revise plans and standards on the basis of new data and monitoring feedback?

The effects of our actions during implementation of this plan will be monitored and evaluated as discussed in the objectives and standards relative to monitoring in table 3-5 (AM-O2, AM-S3 through S7) of the Draft EISs and in the Implementation Framework appendix. This new information will validate and refine the scientific information.

Adaptability has been built into these Draft EISs. Adaptive Management objective AM-O1 and its accompanying standards call for making appropriate adjustments in management strategies as new information, technology, and social desires are identified. See the rationale statement for AM-O1 for more discussion. A process also is in place to allow certain prescriptive standards--such as snags and coarse woody debris levels, Riparian Conservation Area (RCA) zones, and the like--to be adjusted to be appropriate for local conditions (see EM-S13 in table 3-5). The different alternatives describe different processes for adjusting such standards.


Will there be a specific monitoring plan developed before the Final EIS?

The Implementation Team is working on a framework or basic strategy to be ready before the Record of Decision. Then additional teams will work on protocols and measurement schemes. The Implementation Team may develop some specific structure and components of a monitoring plan, but these would be at a larger scale than individual Forests or Districts.

What do you mean by "Desired Range of Future Conditions"? Some of the conditions you describe do not seem very desirable. Shouldn't you have consulted with the public to see what it is we all desire for the future?

The Desired Range of Future Conditions (DRFC) as described in Chapter 3 is a portrayal of the land, resource, social, and economic conditions that are expected to result in 50-100 years if the objectives of an alternative are achieved. Each alternative has a different DRFC, based on the theme, standards, objectives, and activity levels of the alternative. Sometimes the expected conditions are not what everyone would consider ideal. However, when the decision-makers choose an alternative they will be making a conscious decision to accept that these are the likely conditions that will be seen in the long term. The construction of the alternative components, including the DRFCs, reflects input from the public to date. Comments from the public on the Draft EIS, including the DRFCs, will be considered in the preparation of the Final EIS.

What is the scale for the DRFC?

Project area-wide. There will be much variation at the local level, and not every acre is expected to look like the DRFC at every moment.

What happens when the desired range of future conditions (DRFC) is different from the historical range of variability (HRV)? These two concepts seem to be mixed up in the documents, equating one to the other. Can you give an example of where HRV is NOT the same as the DRFC?

The DRFC is meant to reflect a vision of the long-term condition of the land, a portrayal of the land, resource, or social and economic conditions that are expected to result in 50-100 years if objectives are achieved. The DRFC may be the same as, or outside of, the historical range of variability, which refers to the range of conditions and processes that are likely to have occurred prior to the mid-1800s. These historical conditions were discussed in the EISs only as a reference point, to help us compare to current conditions and understand possible trends. See Chapter 2, UCRB page 2-2, Eastside page 2-4, for more discussion of HRV. DRFCs are discussed in Chapter 3.

One example of a situation where the HRV would not be the same as the DRFC is miles of roads in the project area. Historically there were no roads, and we're obviously not going back to that condition.


You single out land-use changes, such as grasslands converted to agriculture, as to blame for current conditions. Why do you present this kind of change as negative for wildlife without consideration of the benefits to society of such changes?

Recognition of the relationships between current conditions and past management or land-use practices is not blaming but is helpful to understand the nature and scope of present conditions and to evaluate possible future courses of action. Clearly, certain changes on the landscape such as conversion of grasslands to agriculture, were made through conscious decisions to benefit society. Knowing that some changes are permanent helps us determine what options are available to address the effects of those changes on wildlife and other resources.

When will we begin to see the changes take place? How long will it take to fully restore Federal forests if the preferred alternative were to be implemented?

The alternatives, including the preferred, look 50-100 years into the future in describing desired forest, rangeland, aquatic, and social-economic conditions. The alternatives prescribe actions for the next 10 years to begin moving toward these desired conditions. So you will be able to see some site-specific changes immediately, as activities are implemented during the first decade. Even with full funding of the preferred alternative, we expect it will take many decades to reach the desired conditions.

What is the role of subbasin review? How is it different from watershed analysis, ecosystem analysis? Where is this outlined in the document?

Subbasin review is intended to pinpoint priority areas (High [H], Medium [M], Low [L]) for restoration, in an integrated review process. It's also intended as a crosswalk, to validate broad-scale science information at the mid-scale. Subbasin review is more general, more of a characterization rather than a full analysis. The rationale statements that accompany EM-O3, -S1, -S2, -S3, -O4, -S5, and -S8 in table 3-5 provide explanations for what subbasin reviews and watershed analyses are intended to accomplish.

Will the ICBEMP Implementation Team conduct subbasin reviews? No. Individual units will conduct subbasin reviews.


What happens if the subbasin review does NOT validate the scientific information? What if the science does not fit what we have on the ground?

We don't expect that the broad-scale science information will always match fine-scale conditions on the ground. It's not appropriate to try to substitute local information for the broad-scale. Broad-scale information won't necessarily be wrong; fine-scale variation within larger land units is to be expected and was considered. Validating the broad-scale information will mean looking at the big picture, to see if the pattern generally fits a particular area.

There may be situations where the baseline data used to build the scientific information needs some correcting. This will be done where necessary (see response to question 1-10). But the kind of validation we will be looking for with subbasin review is broader than that.


When standards call for subbasin review, doesn't this make the review a kind of decision? When a standard is changed during watershed analysis, does it have to be signed by a line officer? Doesn't this make it a decision?

Subbasin reviews (described in table 3-5, EM-O3, EM-S1 through S4) and ecosystem analyses (EM-O4, EM-S5 through S14) are not decision documents. They need to be followed by site-specific NEPA analyses and decision documents if they indicate that a standard should be changed. A standard cannot be changed during watershed analysis, but a standard also cannot be changed through a NEPA process unless watershed analysis has been conducted first. This is discussed in EM-S13.

If a National Forest or BLM District has already done or is in the process of doing an ecosystem/watershed analysis under the Northwest Forest Plan, does that mean the work already done is not good enough and subbasin reviews will still have to be done? If the idea of subbasin review is to identify those areas that need watershed analysis, is the subbasin review really needed in these cases? Subbasin review is different from ecosystem analysis, so it's correct that subbasin review would still need to be done. Subbasin review is more general, more of a characterization rather than a full analysis. Another reason for the subbasin review is to validate the science and look at the bigger picture to make sure that conditions really are the way we say they are. So it's still important to conduct them to get the broader picture. If watershed analysis is already underway or completed, the subbasin review will be quicker to accomplish. See the rationale statement for EM-O3 in table 3-5 for more discussion.

How can a forest afford to stop activities while subbasin review is being done, especially after many have spent a lot of money already doing watershed analyses?

The subbasin reviews are intended to take only 2-3 weeks. Also, not all lands have to be done at the same time. An average of one third per year is called for, and the other two thirds can have activity continue while the subbasin review on the other third is conducted. See EM-S1 and its rationale in table 3-5 for more discussion.

Are current completed watershed analyses going to be adequate, or will they have to be redone?

Watershed analyses already conducted should be adequate, but we need to have both broad- and mid-scale. There's no need to redo work already done, but there may be a need to take a look at the analysis to be sure it's gone as far as it should. The intent is to use existing information where possible, then build on it. This may mean updating periodically but not necessarily starting over. See the rationale to objective EM-O4 in table 3-5 for more discussion.

There seems to be a significant underestimation of acreage requiring Ecosystem Analysis at the Watershed Scale. The acres shown on the map are based on presence of threatened and endangered fish. But many areas will have terrestrial threatened and endangered species, which also would trigger EAWS. Doesn't this mean EAWS has to be done everywhere? Standard EM-S8 in table 3-5 requires Ecosystem Analysis at the Watershed Scale (EAWS) if an Environmental Analysis (EA) or Environmental Impact Statement (EIS) is needed where federally listed threatened, endangered, proposed, or candidate species (both aquatic and terrestrial) may be affected. Map 3-11 was limited to fish and may slightly underestimate the acreage where EAWS would be triggered. But some areas are exempted (if no EA or EIS is required), so there wouldn't be a need to conduct EAWS everywhere.

The many levels of review and analysis are confusing. It seems like almost ALL activities feed into a loop that always goes back to requiring Ecosystem Analysis at the Watershed Scale. Just how many "triggers" are there that require a manager to do EAWS? Only a few certain situations absolutely require EAWS to be conducted. Table 3-5, standards EM-S7 through S10 summarize the triggers. The intent is that eventually EAWS would be done everyplace where management actions could have a watershed-scale effect. This is to ensure that potential actions are evaluated with an overall understanding of the capabilities and limitations of specific watersheds. But it's only required in certain places and circumstances.

What are the impacts in terms of cost, staff, time, project delays to Forest Service and BLM operations that will result from subbasin reviews and all the other layers of analysis and review? How long will it take to complete analysis requirements for watersheds with listed or proposed species before actual restoration work can begin?

Subbasin review is a brief review and validation of broad-scale science data that is intended to take no more than 3 weeks (see table 3-5, EM-O3). We do not expect this review to significantly delay on-the-ground projects. Ecosystem Analysis at the Watershed Scale is a more intensive process that could take 1-4 months to complete depending on the numbers and kinds of issues (see EM-O4). However, we expect that the analyses will support numerous projects within the watershed that would have required individual analyses otherwise.

There are watersheds without listed or proposed species where restoration work can begin immediately upon completion of the individual project plans and accompanying NEPA documents. However, in those watersheds with listed or proposed species it will take longer to begin restoration activities.

We are examining ways to streamline the processes and still meet their intent. Between Draft and Final EIS we will be working with field offices to test subbasin review and develop a guide that will be in place by the time decisions are made. We also are exploring the possibility of exempting a number of subbasins from subbasin review if BLM- or Forest Service-administered lands constitute a minor proportion (e.g., less than 10 percent) of that subbasin.


When standards and objectives talk about "maintaining" soil: does this refer to maintaining at the current level, or returning to and maintaining at historical levels? "Maintain" is intended to mean something different from "restore"; PE-S1 in table 3-5 refers to both. Table A in PE-S1 describes 2 levels of coarse woody debris: the restoration level is higher than the maintenance level.

Will air quality standards be met for prescribed burns under the preferred alternative?

The Draft EISs provide a relative assessment of the impacts from wildfire and prescribed fire on air quality. See Eastside pages 4-23 through 4-28, UCRB pages 4-22 through 4-27. The air quality modeling suggests that prescribed burning particulate emissions considered alone may not cause widespread, regional-scale exceedances of the national Ambient Air Quality Standards (NAAQS). The modeling analyses were not capable of assessing the possibility for localized exceedances of the NAAQS caused by prescribed burning. The models are described in Chapter 4, UCRB pages 4-18 through 4-22, and Eastside pages 4-19 through 4-23.

What direction does the Draft EIS provide for old-growth timber/habitat retention?

The term "old growth" was not used as an ecological descriptor, and the Draft EIS does not state objectives for "old growth." The Draft uses "mature" and "old" multi-story and mature and old single story structural stages to refer to mature and old forest conditions. These are illustrated in the UCRB Draft EIS, table 2-6 and figure 2-4; Eastside table 2-9 and figure 2-7. Current and historical amounts of these structural stages are shown in figures 2-5 through 2-7, UCRB, and figure 2-8, Eastside. These structural stages may or may not contain the various characteristics sometimes identified with "old growth." Therefore, there is not, nor was there intended to be, a direct correlation between the two in this Draft EIS.

Will Rangeland Reform/Healthy Rangelands be folded into the Final EIS?

Yes. We intend to incorporate standards and guidelines into the final EISs to be consistent with Healthy Rangelands and to fit standards and objectives of the project. The BLM will implement Rangeland Standards and Guidelines now, by amending their resource management plans (RMPs). When the ICBEMP Record of Decision is signed, that will again amend the RMPs (and Forest Plans), which will overrule the Rangeland Standards and Guidelines. We will keep abreast of the Standards and Guidelines so we can address potential conflicts immediately.

What changes will be made between Draft and Final EIS regarding wildlife and viability standards? Work on terrestrial species is not yet complete, but at this point no additional standards have been created. We will take what the terrestrial species group develops and incorporate it into the Final.

What are tribal water quality standards? Are these identified somewhere?

Tribal standards are those developed by the tribes and approved by the U.S. Environmental Protection Agency (EPA). They don't include ceded lands or areas of interest; they are for waters inside, not outside, reservations. The document doesn't identify which waters they are, but the AQ-S56 rationale statement explains what they are.

How will this project affect water rights?

Chapter 1 of the Draft EISs contains a discussion of the relationship of these EISs to water rights and adjudications (UCRB page 1-24, Eastside page 1-17). In general, water rights and allocation fall under the jurisdiction of State governments and were not considered in the EIS.

Are activities limited in strongholds?

There is no automatic trigger. Areas of strongholds would be treated the same as other areas: actions that may adversely affect threatened and endangered species would be a trigger for ecosystem analysis at the watershed scale (EAWS).
Below-Cost Sales

Timber is now to be a by-product of restoration activities, meaning smaller, less commercially desirable trees will need to be removed. Has the question of below-cost timber sales been factored into this? How will forest restoration programs be able to pay for themselves?

At this scale and with the many variables that influence costs and revenues, it is difficult to determine if the restoration program will be financially self-supporting. We recognize that not all restoration work will be revenue generating, such as pre-commercial thinning, watershed improvements, and prescribed fire. However, our goal is to take advantage of those restoration activities that are revenue generating to make the restoration program as self supporting as possible while still meeting objectives and standards. Table 3-5, Objective HU-O4 includes direction to deliver goods and services efficiently, providing the most benefits at the least cost. Ultimately, the issue of below-cost timber sales and subsidies for programs that cannot pay for themselves is outside the scope of this EIS and more appropriately addressed by Congress.

Table 4-57 gives a false impression that the number of recreation jobs would offset the loss of wood products, restoration, and ranching jobs. This minimizes the importance of these jobs on Federal lands. An Oregon Employment Dept. study identified far fewer recreation jobs generated by Forest Service and BLM activities than you indicate. Do the number of recreation jobs in table 4-57 account for the majority of jobs in this chart? Table 4-57 accurately displays the number of recreation jobs as calculated by project scientists, who used different methods to calculate employment effects to support broad-scale land management decisions than did the narrower Oregon study. Chapter 4 of the Draft EIS addresses the importance of jobs generated from Federal lands, including a recognition that the importance of different types of jobs varies by locality and is best considered in this context.


Recreation jobs have been shown to pay far less than wood industry jobs. Did the studies supporting the Draft EIS consider the average annual pay per job when calculating economic effects?

Yes. The project's Scientific Assessment and the Evaluation of Alternatives did consider average annual pay per job when calculating economic effects. In addition, it included the issue of economic well-being across the project area, rather than focus exclusively on jobs information. There is a discussion in Chapter 2 of the Draft EIS about salary differentials for those job sectors that are affected by land management activities.

This concern will continue to be addressed between Draft and Final EIS.


AQ-S26 and AQ-S43 seem to conflict: one says, take recreation facilities out if they don't meet Riparian Management Objectives (RMOs), the other stays, it's ok to leave them in. One seems to say that old facilities have to come out but new ones can be put in. Eliminating recreation developments or dispersed activities could have a big impact. Are recreation facilities going to be closed or not? Some of these standards refer to recreation activities while others are more directed at facilities. We will take a closer look at these to make sure they don't conflict. The kinds of decisions that could result in closing or moving specific facilities or activities are left to local National Forest and BLM managers.

Economic Resiliency

How was economic resiliency factored into the Draft EIS?

Objective HU-O6 in table 3-5 recognizes the special needs of "areas of economic vulnerability" by emphasizing customary economic uses in these areas. The intent is to help sustain these areas through the transition to a less dependent (more resilient) condition. At a minimum, those communities identified as "isolated timber-dependent communities" in Chapter 4 (table 4-58) are targeted.

In addition, Chapter 2 of the Draft EISs describes how economic resiliency was determined, and the current economic resiliency conditions. Chapter 4 describes how economic resiliency will be affected by the alternative management strategies and the methodology used to determine resilience. For specific information see UCRB pages 2-195, 3-195, and 4-211; Eastside pages 2-201, 3-203, 4-177.


Will thinning contracts, prescribed burning contracts, or other special considerations be given to those communities who are in danger of losing, or have lost, their jobs? How will you offset the economic impacts of reduced Payments in Lieu of Taxes?

Objective HU-O6 is intended to encourage scheduling of implementation activities in areas of economic vulnerability that would in turn provide jobs. Also, we are projecting an increase in timber harvest levels with the preferred alternative compared to the past three years (see figure 4-53). However, we recognize that the mix of forest products will change and that these harvest levels are below the 10-year average and projects within current land-use plans. We have identified those counties within the project area that have in the past received payments in excess of Payment in Lieu of Taxes that would be most affected (see map 4-2).
Commodity Jobs, Outputs (Timber Volume, AUMs)

At this time it appears that future timber harvest from Federal lands will be about half that provided by existing land-use plans. However, the specific projections are still unsure because the assessment and Draft EISs are at such a broad scale. When will we be able to determine the actual environmental and economic impacts of the proposed strategy?

While both existing and future timber harvest levels may be less than projected in existing land-use plans, the projected harvest levels for the preferred alternative are compatible with long-term protection of fish and wildlife at a broad scale. Fish and wildlife outcomes under existing land-use plans as implemented (Alt.1) were not as positive as for the preferred alternative (Alt.4), and therefore the projected harvest levels under current management are less predictable than the preferred alternative.

The broad-scale analyses in the Draft EISs is sufficient to project harvest levels for clusters in the EIS areas. The actual environmental and economic impacts of the proposed management strategy are reported at this level. As individual land-use plans are amended or revised in the future, the environmental and economic impacts of the proposed management strategy will be disclosed for more specific geographic areas.


Have you determined how many mills will close if you implement your alternatives?

The trend in timber offered is expected to be higher for the preferred alternative over the next 10 years than current levels, but below levels in current land-use plans. It would be reasonable to expect that some time will be necessary to increase the volume of timber offered for sale in order to achieve the 10-year average. Whether over this period of time there would be mill closures is unknown.

Timber supply is not the sole determinant of the number of mills and their operations. A number of factors such as business cycles and interest rates affect demand and income. In addition, the relationship between capital and labor (such as automation), changing consumer preferences, and international demand also affect mill closures.


How can AUMs be the same under all alternatives? Aren't there going to be any changes in the way livestock are managed?

Scientists were not able to accurately predict at the broad scale how AUMs would vary by alternative. The alternatives do differ with respect to livestock management, a category that includes such elements as number of livestock, grazing systems, season of use (length and timing), and the like. (The assumptions regarding livestock management are presented on table 3-12; the levels of livestock management for each alternative can be seen on table 3-11.) Changes in livestock grazing management that would be required to achieve objectives and standards will not necessarily require changes in AUMs. Furthermore, the number of AUMs a permittee might choose to use can be affected by other factors, such as economic feasibility. Therefore, implementation of the objectives and standards does not present a clear picture of how AUMs might change by alternative.

How can you call for closing roads when roads are needed for access for firefighting, restoration work, recreation, access to private inholdings, and other transportation needs?

Roads will not be closed without weighing the risks of leaving the open versus closing them. Reducing effects from roads is what we are primarily interested in (see table 3-5, RM-O2, RM-S1 through S7, and their rationale statements for more discussion). We may keep some roads open but improve their management, recognizing we still need access for recreation, commodities, and restoration. Various access considerations are addressed in HU-O11, HU-O16, HU-S8, and RM-S9 in table 3-5. We think we can close a lot of unneeded roads and not reduce access. But we're leaving the exact "where" of road closures and construction to local decisions. As a point of clarification, most roads that would be targeted for closure are native surface (dirt) roads.

We may need to address the issue of providing access to private inholdings where there are public roads leading to them in low-road-density watersheds.


Just closing roads does not resolve sedimentation and interruption of water flow, and doesn't stop people from using them. Why are you planning so many road closures?

There are many reasons to close roads: water quality concerns, interruption of wildlife corridors, and to limit the spread of noxious weeds, to name a few. Depending on the reason, roads may be closed to remedy the concern. In the case of water quality concerns, it may mean removing drainage structures and re-sloping roads, which would limit future access. For wildlife and noxious weed concerns, it might mean gating or constructing a berm which could allow seasonal or emergency access.

Restoration activities don't always result in decreased road densities; sometimes the density actually increases. How can you justify increasing road densities?

The intent is not to increase or decrease road densities per se but to reduce the adverse effects from roads. There are many ways to do this in addition to road closures, such as better maintenance, seasonal closures, road improvement, and the like. This is discussed in table 3-5, RM-O2, RM-S1, and their rationale statements. Objective RM-O3 and standards RM-S8 and S9 emphasize reduction of roads in areas of high and extreme road density; RM-S15 minimizes increases in road density in high quality subwatersheds where road densities are currently "none" or "very low." Road risk inventories as described in RM-S3 and S4 should help identify where the highest risks are. However, we leave it to local managers to decide how and where to reduce road-related effects when supported by appropriate analysis. In some places this may result in an increase in road densities, but overall throughout the project area it is expected that road densities will be reduced.

Will new road construction be allowed in currently roadless areas?

The intent is to minimize road-related effects, especially in areas currently classified as having road densities of "none" or "low" (see table 3-5, RM-S15). If Forest Service or BLM units have such an "unroaded" area where they want to do some restoration work that calls for more than the recommended road densities, the standard can be changed to allow some new roads in these areas if EAWS is conducted, if it can be shown that no adverse effects will result, and if the NEPA process is completed, as described in EM-S13.

What changes are already being planned before the Final EIS? How will these changes be shared for public review?

Among the changes already being worked on are these: (1) Errors in Appendix 3-4 (Eastside)/G (URCB) on Figure 1 will be corrected. (2) Revised information on terrestrial species viability will be incorporated into Chapters 2, 3, and 4. (3) We will validate achievability of activity levels, and refine them. (4) Socio-economic sections will be revised. (5) Conflicts in coarse woody debris and snag requirements will be reconciled with fire, wildlife, soils, and other needs. (6) The executives will decide whether there will be one or two Final EISs. (7) Chapters will be revised based on public comments.

We don't anticipate that the revised information on terrestrial species viability or other topics will be substantial, but this and other new information will be made available to the public as soon as it becomes available.