P.O. Box 1749, Quincy CA 95971


David Peters, Project Manager
USDA Forest Service
Herger-Feinstein Quincy Library Group
Forest Recover Act Project EIS
P.O. Bos 11500
Quincy, CA 95971-6025

Dear Dave,

   These comments are provided in accordance with the National Environmental Policy Act, which states that “it is the continuing responsibility of the Federal Government to use all practicable means, consistent with other essential considerations of national policy, to improve and coordinate Federal plans, functions, programs, and resources to the end that the Nation may...(3) attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other desirable and unintended consequences.” Public participation is both required and guaranteed under NEPA (42 USC Sec 4331), which in section 101(c) states, “The Congress recognizes that each person should enjoy a healthy environment and that each person has a responsibility to contribute to the preservation of the environment.”

   In commenting on the Draft Environmental Impact Statement (DEIS), members of the Quincy Library Group would like to acknowledge that most of the members of the Forest Service's interdisciplinary team for this EIS are long-time friends and neighbors as well as Forest Service employees. These individuals are valued and respected as members of our communities and fellow citizens. At the same time, they work for a federal agency with its own bureaucratic goals, policies, and internal rivalries for budget and power that have little to do with the conditions and management of these particular national forests. But we also recognize, and hope that others do, that we must separate the professional from the personal in reviewing and commenting on the DEIS.

   In these comments QLG will call attention to and be critical of whatever errors and deficiencies we believe exist. On the other hand, we wish to make clear at the outset that on balance we believe the DEIS provides a sufficient range of options and adequate information on the essential differences among those options as required by NEPA to support, if interpreted and applied in a reasonable manner, a credible decision on how best to implement the Herger-Feinstein Quincy Library Group Forest Recovery Act in a manner that will satisfy legal requirements of the Act and the intent of Congress.

   The point we will make throughout these comments is simply that the available information, interpreted reasonably and applied in a manner consistent with the Act and other law, fully supports implementation of Alternative 2, and can support no other option except implementation of Alternative 2.

   Our comments are organized as follows:

I. Summary of QLG's recommendation in favor of adopting Alternative 2 and opposed to adopting the other alternatives.

II. Support for QLG's position.

III. Concerns regarding the DEIS treatment of issues not necessarily limited to comparison of alternatives.

IV. More detailed support for QLG's recommendation of Alternative 2 and opposition to the other alternatives.

V. Suggestions to correct editorial errors, improve the DEIS analysis of alternatives and their effects, and to deal more completely with other issues of significance.

   Appendices are attached, with detailed information or expanded comment on selected issues.

I. The Quincy Library Group supports the adoption of Alternative 2 and opposes the adoption of other alternatives because:

II. Summarized Support for QLG's Position in favor of Alternative 2.

Alternative 2 implements the Act, while the other alternatives do not.

   The Act sets specific goals and limits for the resource management activities it requires, and defines which resource management activities are part of the Pilot Project, and by implication which are not. The resource management activities required by subsection (d) of the Act include:

   1. “Construction of a strategic system of defensible fuel profile zones [DFPZs], including shaded fuelbreaks, utilizing thinning, individual tree selection, and other methods of vegetation management consistent with the Quincy Library Group-Community Stability Proposal, on not less than 40,000, but not more than 60,000, acres per year.”

   Alternative 2 implements DFPZs on an acreage that is within the required range of 40 to 60 thousand acres per year, while the other alternatives cut the DFPZ acreage to only a small fraction of the requirement, and/or attempt to substitute non-DFPZ treatments for a large part of the requirement. The DEIS, the Sierra Nevada Ecosystem Project (SNEP) Report, and other sources identified later in our comments indicate that a strategic system of DFPZs is a network of linear fuel treatments. All complete descriptions and all published maps of DFPZs reflect that fact. While the Act recognizes that various methods of vegetation management may be used within a DFPZ, it does not permit the substitution of “area treatments” for DFPZs, as is done in Alternatives 3 and 4, and it does not permit the drastic reduction of DFPZ construction in Alternatives 3 and 4, or the omission of DFPZ construction, as could be done under the terms of Alternative 5.

   2. “Utilization of group selection and individual tree selection uneven-aged forest management prescriptions described in the Quincy Library Group-Community Stability Proposal to achieve a desired future condition of all-age, multistory, fire resilient forests as follows:

“(A) ...Group selection on an average acreage of 0.57 percent of the pilot project area land each year of the pilot project.

“(B) ...Individual tree selection may also be utilized within the pilot project area.”

Alternatives 2, 3, and 4 specify 8,700 acres per year of group selection, which is said to be equivalent to 0.57 percent of the Pilot Project area. Alternative 5 calls for small “forest openings” but fails to require any acreage per year of such treatment, and thus fails to meet the specific requirement of the Act.

   In order to achieve the desired future condition that is specified, QLG believes it would be appropriate to include group selection within or adjacent to DFPZs wherever possible, as well as elsewhere. Failure to give prominent consideration to this possibility is a deficiency in the analysis of the environmental effects of each alternative, because locating small group harvests within DFPZs would: (1) provide better protection of the investment in regeneration represented by these groups; (2) provide a greater variety of stand structures within the DFPZs; (3) offer opportunities for more efficient implementation of both the DFPZs and the group harvests, in planning, constructing, and financing them; (4) increase by as much as 10 percent the length of DFPZs that could be constructed each year, thus putting a more effective DFPZ network in place earlier; and (5) implement the concept that DFPZs are not intended to be permanently different from the desired future condition of the entire forest (except to continue to provide for safe and efficient fire suppression within the central zone of a DFPZ). QLG believes these possibilities should be analyzed and disclosed in the Final EIS, so they will be considered in comparing alternatives, and later won't be ignored or thought not permissible by the project-level planners.

   3. “The Scientific Analysis Team [SAT] guidelines for riparian system protection ... shall apply to all resource management activities ... and timber harvesting activities that occur in the pilot project area during the term of the pilot project.”

   QLG believes that adoption of the SAT guidelines in Alternatives 2, 3, and 4 provides a higher level of protection for riparian areas than is provided by current direction and practice, and a more discriminating protection that would be provided by Alternative 5.

   Alternative 5 would implement what are called “SNEP guidelines” for riparian system protection. The DEIS doesn't give a specific reference to the SNEP source of those guidelines, nor does it provide the formula by which the SNEP buffer widths were calculated. DEIS Table 3.5 (ch 3, pg 15) says the SNEP buffers would average 540 feet on each side of affected streams and wetlands, but no explanation of this calculation is provided. QLG believes that neither of the two formulas provided in SNEP would result in an average buffer width of 540 feet if reasonable assumptions were made, and that in any case the (corrected) SNEP formula that was most likely used in the DEIS computations is arbitrary and not well founded in either science or mathematics. (For a detailed critique of the SNEP buffer widths, please see QLG's letter to the Sierra Nevada Framework Project EIS Team Leader, copy attached as Appendix Q-4.)

   Alternatives 2, 3, and 4 seem to assume identical application of the SAT Guidelines and other riparian management provisions of the Act, but there are differences among these alternatives in the way that riparian management provisions are described. For example, two paragraphs under the heading “Issue: Watershed Effects and Aquatic and Riparian Protection” are identical in Alternatives 3 and 4, but significantly different in Alternative 2. If no difference is actually intended, the descriptions should be identical (or 3 and 4 should simply incorporate the text of 2 by reference).

   The Act calls for “A program of riparian management, including ...riparian restoration projects...” Alternative 2 says that “Riparian management will consist of establishing a system of riparian restoration projects and a system of Riparian Protection Zones as described in [SAT]...,” whereas Alternatives 3 and 4 mention only the SAT restrictions, not the riparian restoration projects.

   The DEIS compares only the management activity allowed and the protection provided in riparian areas (see Table 3.5), it fails to define, consider, or compare the benefit that each alternative would provide by implementing riparian restoration projects. One additional advantage of Alternative 2 is that is would provide more numerous opportunities for efficient riparian protection and restoration, because building DFPZs along existing roads can be coordinated with improving and rebuilding roadways that are often the source of riparian problems.

   4. The Act requires “Status Reports ... Not later than February 28 of each year during the term of the pilot project...” These reports must include information not normally generated by standard Forest Service accounting and reporting processes, but there is no mention in the DEIS of this requirement or of Forest Service plans to fulfill it.

   5. The Act requires a “Final Report ... The Secretary shall establish an independent scientific panel to review and report on whether, and to what extent, implementation of the pilot project ... achieved the goals stated in the Quincy Library Group - Community Stability Proposal...” This report must be based on better and more comprehensive information than has normally been generated by standard Forest Service monitoring, accounting, and reporting processes. The DEIS fails to mention this requirement of the Act, and makes no preparation for gathering and reporting adequate data on which to base the Final Report.

   Well designed processes to monitor and account for the Pilot Project activities and their results must be implemented from the beginning, in order to make possible the Status Reports and the Final Report required by the Act, and to support future management decisions according to proper adaptive management. (Please see the discussion on Monitoring in Section III for an expansion of these points.)

Alternative 2 implements a sound fuels reduction and fire protection strategy at adequate scale and pace, while the other alternatives do not.

   The DEIS says (chapter 3, page 127) that “For the fires over 100 acres during this time period [recent 27 years]: 1 percent of the fires accounted for 98 percent of the acres burned.” This and other published information, such as the comprehensive treatment of fire in SNEP, Volume II, Chapters 37 to 44, and 56, clearly support the conclusion that the highest priority for fuel treatment and fire protection must be to reduce the probability that a wildfire will grow to very large size. That is the focus of the fuelbreak strategy specified by the Act. In order to implement that strategy it is essential to have at least 40,000 acres per year of Defensible Fuel Profile Zone (DFPZ) constructed in the forest and around communities, as required by the Act. DFPZ construction at the 60,000 acre level authorized by the Act would be much preferable, but it is certain that implementation at less than 40,000 acres per year, which is about 2.7 percent of the Pilot Project area and less than 2 percent of the planning area, is not capable of catching up with the fuel buildup and fire protection problem on these national forests, much less getting ahead of it.

   According to information supplied by the Forest Service at “open house” meetings on the Act, Alternative 3 would reduce the rate of DFPZ construction to about 32 percent of the level required by the Act, and substitute “area treatments,” for a total acreage approximately equal to the DFPZ acreage alone that is required by the Act. Alternative 4 would reduce DFPZ construction to about 28 percent of the level required by the Act, and substitute “area treatments,” for a total acreage only about half of that required by the Act. Alternative 5 does not specify any requirement for DFPZ construction or any particular level of fuel reduction.

   The levels of DFPZ construction specified in Alternatives 3 and 4 are not sufficient to make a sound fuel reduction and fire protection strategy, and the substitution of area treatments for all or part of the DFPZ deficit does not cure that problem or meet the requirements of the Act.

   Treating 40,000 acres per year minimum, as required by the Act, is good, and the analysis based on about 44,500 acres per year provided in the DEIS is adequate to support implementation of any amount in the range from 40 to 60 thousand acres per year. However, QLG believes it would be advantageous to analyze the effects of implementing the maximum of 60,000 acres per year, because the beneficial effects of DFPZ construction would be significantly greater and be realized sooner. Later in these comments we discuss more fully the failure of the DEIS to analyze adequately or give credit for the ecological, economic, and fire protection benefits of fuel reduction in general, and DFPZs in particular.

Alternative 2 provides better assurance of long term viability for all plant and animal species, including those thought to be at high risk, and particularly for California Spotted Owls.

   In 1992 the Forest Service California Spotted Owl Technical Assessment Team concluded that “Severe wildfire in Sierran mixed-conifer forests may represent the greatest threat to current owl habitat.” (Verner, et al, “The California Spotted Owl: a Technical Assessment of Its Current Status” [the CASPO Report] USFS, PSW GTR 133, 1992, Ch 12, pg 258). That assessment has only been reinforced in subsequent years by the SNEP report and other descriptions of the increasing risk and growing hazard of very large high intensity wildfires.

   The potential loss of both habitat and habitat connectivity was vividly demonstrated that same year of 1992 by the Fountain Fire, in which over 64,000 acres burned in less than three days at an average rate of 17.4 acres per minute, completely destroying many stands of owl habitat, and creating a major area of unsuitable habitat between the Northern Spotted Owl and the California Spotted Owl sub-species. It is clear that any strategy which fails to reduce the risk of stand-destroying wildfire is not a strategy which is likely to help sustain viable owl populations, and the fire threat to owls is only an indicator of the similar threat to all species of forest plant and animal life.

   Reports from owl demographic studies indicate that the studied populations are declining. However, the reported declines do not correlate with empirical data on either the history of management activity or the actual rates of change within measured owl populations. That is, there is no statistical difference in predicted population trend between study areas which have received significant vegetation management activities and study areas which have not experienced historic vegetation management activities, so there is no basis for concluding that previous or current management activity has affected or is affecting the viability of owl populations. (Please see Appendix Q-1, an analysis of owl viability as it relates to suitable habitat, by Steve Self, wildlife biologist and QLG member, and Appendix Q-2, a very recent review bearing on the viability issue, by Dr. Jared Verner, principal author of the 1992 CASPO Technical Assessment.)

   Despite the absence of scientific foundation for its conclusion, the DEIS assumes that all fuel reduction treatments that thin the forest canopy would have a net adverse effect on spotted owl habitat. QLG examines in detail and refutes this assumption in Section III of these comments and Appendix Q-1 referred to above.

III. Major concerns regarding the DEIS treatment of several issues that are not limited to comparison of alternatives.

Failure to analyze and consider the potential effects of fuel reduction on wildlife habitat, owl viability, human safety, and other positive aspects of forest health and sustainability.

   The DEIS says that

“Implementation of the resource management activities as defined in the Act, including DFPZ construction, is intended to reduce risks of stand-replacing fires. Reducing the threat of stand-destroying fires could result in protecting owl habitat, including known owl PACs and SOHAs. Reducing the threat of stand destroying fires to reduce total acres burned in wildfire events complies with the interim guidelines.” (DEIS ch 2, pg 4)

   This passage is the closest the DEIS gets to considering the central purpose and potential long term advantage of implementing the DFPZ strategy specified in the Act, but it is not mentioned in the summary or initial description of alternatives. In all other places where the effects of management activity are discussed, analyzed, or displayed, the only effects are said to be either neutral or adverse to ecological processes, and particularly adverse to maintaining spotted owl habitat and the viability of spotted owl populations.

   When the DEIS failure to analyze and consider advantages of fuel reduction was raised with members of the HFQLG EIS Team, the crux of the answer seemed to be that there were no good computer models for testing the hypothesis and quantifying the potential benefits of fuel reduction on the habitat of owls and other wildlife. Even assuming that is true, QLG believes that meaningful professional judgments not only can be made but must be made, to establish the relative advantage of doing more fuel reduction instead of less or none, and of doing the initial fuel reductions in a strategic pattern instead of scattered on the landscape. Such professional judgments have been made, and are available in highly regarded publications, but the DEIS paid no attention to them. For example, the quotes below are from SNEP:

“Alternatives 6-10 called for building DFPZs in the first two periods.” [of 10 years each] According to our simulations, the DFPZs reduce the extent of fire by up to 1/3 over fifty years.” (Johnson, Sessions, and Franklin, SNEP Addendum Ch 6, pg 187.)

“Given the possibility that relatively little prescribed fire might occur, we reexamined some alternatives...

“Without the fuel treatments across the landscape provided by prescribed fire, the likelihood of severe fire can be reduced in two ways. Timber harvest with slash treatment can reduce wildfire severity and DFPZs can reduce the extent of wildfire.” (Johnson, Sessions, and Franklin, SNEP Addendum Ch 6, pg 190.)

“Goal 1: Reduce Substantially the Area and Average Size Burned by Large, High-severity Wildfires... We are aware of no other strategy with as great a potential in the short term to progress reasonably rapidly toward achieving Goal 1.” (Weatherspoon and Skinner, SNEP Vol II Ch 56, pg 1480.)

   See also the earlier quote (in Section II above) from the CASPO Report regarding the hazard of high intensity wildfire to California Spotted Owls.

   QLG believes that sound forest planning according to NFMA and the disclosure of all known or reasonably likely environmental effects according to NEPA require that the potential advantages of strategic fuel reduction and other resource management activities required by the Act must be described, analyzed, and evaluated by the best methods that existing science and management art permit. It is a requirement to disclose the positive effects, not just the negative effects, that each alternative can be expected to have.

   Failure to consider positive effects of resource management activities is particularly apparent in the DEIS evaluations of environmental consequences for Spotted Owl and other wildlife viability.

Lack of a comprehensive integrated monitoring plan.

   The DEIS mentions only “business as usual” monitoring, all of it scattered throughout the document as standard boiler-plate that would too easily be ignored as usual. We count 10 short paragraphs headed “monitoring” that are scattered over 7 separate pages of Chapters 2 and 3 of the DEIS, plus one promise to develop a monitoring plan later that would deal with socio-economic effects. All 10 of the “Monitoring” paragraphs are about “implementation” monitoring, which has to do with whether activities were actually implemented as planned, and whether applicable “Standards and Guidelines” and “Best Management Practices” were followed. This is much too narrow a view of the monitoring requirements that should underlie a comprehensive monitoring plan in the Final EIS and Record of Decision.

   The purpose of the Pilot Project, as stated in the Act, is “...to implement and demonstrate the effectiveness of the management activities described...” (emphasis added). To demonstrate the effectiveness of an activity requires effectiveness monitoring, which deals with the question of what effect a management activity has on the landscape and on ecological processes, not just with the question of whether the planned activity was implemented by the rules. The DEIS gives virtually no attention to the need for effectiveness monitoring.

   A comprehensive integrated monitoring plan that deals with both implementation and effectiveness monitoring must be developed and given prominent well-organized display in the Final EIS because: (1) there must not be a “business as usual” interpretation of the monitoring requirements during project planning and implementation; (2) a monitoring plan tailored to this project is essential, both to meet the Act's main purpose, and as a foundation on which to build the reports required by the Act; (3) the success of any “pilot project” rests largely on how well the results of that project are documented and reported; and (4) a significant purpose of this Pilot Project is to learn and adaptively manage into the future, which is not possible without adequate monitoring results to guide the adaptation.

   Furthermore, the Act reinforces the Forest Service requirement to follow all existing laws, and the National Forest Management Act (NFMA) requires monitoring plans. Failure to include a comprehensive monitoring plan, based on a well-designed monitoring strategy intended to support adaptive management, could be interpreted as failure to comply with existing law. A useful guide on fulfilling the NFMA monitoring requirement is included in the Sierra Nevada Framework for Conservation and Collaboration (SNFCC), EIS draft of June 4, 1999, which says in part: "Monitoring in relation to land management is intended to provide information on the implementation of management direction, the condition of resources, the effectiveness of management direction in meeting resource objectives, and the validity of assumptions made about cause and effect relationships during the development of management direction." The SNFCC draft gives particular emphasis to the role of monitoring in adaptive management.

   The HFQLG Final EIS must include a similarly well-founded monitoring plan, based on a sound strategy for actually implementing the general requirements for monitoring found in NFMA, and the specific requirements of the Act for demonstrating and reporting results of the Pilot Project, so as to provide for adaptation of future management.

   The DEIS makes no mention of the Forest Health Pilot Monitoring project developed by the Forest Service with support of the Quincy Library Group in 1997 and implemented in 1998. This plan could well serve as the foundation for the monitoring plan that is required for the HFQLG Pilot Project. However, it is critical that the Forest Health Pilot (FHP) monitoring plan be reviewed to determine what changes and improvements must be made to meet all requirements of the Act, and actually to address the questions of greatest current and long term interest.

   QLG suggests that Version 1.3 of the FHP Monitoring Program Plan be revisited. This version listed the monitoring-related questions recommended by the QLG, as well as other questions that arose during development of that plan. Elements that were dropped from the implemented version of the Forest Health Pilot monitoring plan should be reexamined for the HFQLG Pilot Project (i.e. Wildlife, Administrative and Budget Scale). Please see Apendix Q-13, attached, a copy of Version 1.3 of the FHP monitoring plan.

   QLG recommends that photo point monitoring be employed to the maximum extent possible, particularly for monitoring the condition and performance of DFPZs over time. Photo points are very cost-efficient for many monitoring purposes, and they give perhaps the best picture of forest condition and management progress when made available to the public.

   QLG's continuing concern about monitoring is that it must actually be implemented, not just talked about. A comprehensive, integrated, tightly focused monitoring plan must occupy a prominent place in the Final EIS, because without that prominence there is very little chance that monitoring will actually be given an adequate budget and be implemented with sufficient vigor and continuity to support the evaluations and reports required by the Act and other applicable law.

   Please see Appendix Q-12, which suggests the data required and a format for recording it, to track the planning and implementation of projects.

Inappropriate assumptions regarding wildlife habitat.

   The DEIS analyses of habitat impacts for wildlife species other than just the California spotted owl seem to similarly begin with an assumption that fuel reduction treatments and thinning from below are adverse disturbances. It runs counter to the DEIS description of the affected forest ecosystems in Chapter 3, pages 29 through 34, as having “little resemblance” to pre-1850 conditions:

“The impact of recent human activities on the analysis area can be understood through disturbance regimes. The change in disturbance regimes, from natural fire to fire exclusion and catastrophic fire; from limited grazing to intensive seasonal livestock grazing; from periodic and patch-effect forest pathogen mortality to significant landscape level drought related mortality denotes a sharp divergence from the natural disturbance regimes.” (DEIS Ch.3, p.30)

   The west-side yellow pine type is “greatly changed due to logging, mining, grazing and fire suppression and many stands are dense, young and even-aged dominated by fire intolerant and shade tolerant species.... Forest biodiversity and structural complexity [are] now greatly reduced.” (DEIS Ch.3, p.32)

   The mixed conifer type is described as suffering the adverse consequences of overstocked stand conditions and fire exclusion. (Ibid.)

   True fir forest ecosystems are characterized as having increased densities of both red and white fir, and “[c]learcutting in this forest type has created tremendous openings at a far greater acreage than is normally found from natural causes (fire, windthrow, disease and rock outcropping).” (DEIS Ch.3, p.33)

   Finally, in the eastside pine type, “Considerable acreage has been converted from old growth park-like stands to young, dense, white fir invaded stands.” (DEIS Ch.3, p.34)

   Thus it is ironic at best that the DEIS states, “The need to maintain diverse vegetative seral stages appears to be focused on the preservation of large tracts of undisturbed old forests and riparian areas.” (DEIS Ch.3, p.29)

   Certainly what are left of the undisturbed native forests should be held intact until better scientific understanding is possible; the QLG landbase allocations in the Act and Alternative 2 accomplish that for the life of the Pilot Project. But preservation (including protection from catastrophic wildfire) of what old-growth forest is left does not remedy the loss of biodiversity and forest structural complexity in the overstocked, fire-intolerant stand conditions identified in the preceding paragraphs. The California Wildlife Habitat Relationships (CWHR) modeling that was performed for the DEIS predicted that three out of four wildlife species would be either benefit (142 out of 247) or be unaffected (40 out of 247) from reductions in forest canopy closure. (DEIS Chapter 3, page 64) Likewise, small group selection is estimated by the CWHR model to produce positive results for 136 of 257 species, while 83 of 257 species are expected to suffer negative habitat trends. (Ibid.)

   The Final EIS needs to take the analysis further than the draft has gone so far: if far more species benefit than are harmed by an activity, how should the decisionmaker balance the tradeoffs? It's not as though all the lands targeted for treatment are great habitat now. The CWHR model evaluates relative changes, rather than making objective habitat quality evaluations, but that fact can be forgotten in the running of the model. Also easily forgotten, it seems, is the fact that the CWHR system focuses on tree size and canopy closure. Shrub and herbaceous layers, snags and large downed wood are not used by CWHR as habitat descriptors. (DEIS Ch.3, p.58) Thus attributes that are now recognized as critically important habitat components aren't even part of the analytical tools used for the DEIS.

   Worse still for the validity of the DEIS analysis is the omission of stand-replacing wildfire effects on the quantity and distribution of wildlife habitat types. Long-term species viabilities cannot be realistically assessed while wildfire effects are presumed to be non-existent.

Inadequate analysis and consideration of the potential advantages of group selection silviculture.

   The DEIS Appendix E, page 8, states

"Many stands do not lend themselves to group selection. Much of the mixed conifer belt in the pilot area is comprised of uneven-aged stands which are best managed using an individual tree selection uneven-aged technique. Blind obedience will require younger thriftier age groups be harvested to meet accomplishment expectation. Refer to the attached 'Group Selection Priorities' white paper for more insight."

   The "Group Selection Priorities" white paper, page 11 of Appendix E, says,

"Implementing the group selection system as described in the Act presents logic and strategy dilemmas. These can be categorized by biologic and economic concerns. With these in mind, the Forest Service needs to develop treatment priorities which will allow the best chance for success."

   This section then goes on to list biologic and economic concerns about group selection and on page 5 lists eight dilemmas relative to these concerns.

   In the Conclusion, this section says,

"Implementing the group selection expectation of the Act will be a challenge. Obedience to the accomplishment expectations will involve some compromising of conventional growth and yield thinking. There is room for good decision making and prescription development." (Appendix E, page 13)

   In this section the DEIS completely ignores any positive effects of group selection and surprisingly does not reference either the CASPO or SNEP reports.

   NEPA requires that beneficial effects as well as adverse effects must be disclosed, and that “...the agency shall make every effort to disclose and discuss at appropriate points in the draft statement all major points of view on the environmental impacts of the alternatives including the proposed action.”

   The CASPO Technical Assessment (Verner et al. 1992) Chapter 13, pp 271-272, described some potential long term strategies for timber management in the Sierra. That report addresses group selection silviculture as follows:

"One kind of structure that may have promise for protection and long-term maintenance of owl habitat is multi-aged mosaics of small, even-aged groups or aggregations. Groups would generally range in size from about 2 acres down to a quarter-acre, or probably less. Probably this type of silviculture best approximates pre-settlement stand structures. This warrants serious consideration. Openings would be sufficiently large to permit regeneration of shade-intolerant as well as shade-tolerant species. Multiple size classes in general would be separated horizontally rather than vertically, but in sufficient proximity to satisfy this attribute of owl habitat. Horizontal separation of size class also would confer some degree of resistance to crown fire."

   Group selection silviculture is addressed as follows, in chapter 44 of the Sierra Nevada Ecosystem Project final report to Congress (Weatherspoon 1996):

"The long-term sustainability of any desired forest condition in the Sierra Nevada depends in part on adequate establishment of vegetation at suitable intervals."

   According to Weatherspoon, evidence indicates that the pre-settlement fire regime which dominated most Sierra Nevada forests produced a mosaic of small even-sized groups of trees. The pre-settlement fire regime is described as one in which fire burned relatively frequently at low to moderate severity with many small trees being killed by the fire, but most large trees surviving.

"Scattered individuals and groups of main canopy trees, however, are killed where the fire locally flares up or burns more severely (or groups of trees previously killed by other agents such as bark beetles are consumed to varying degrees by the fire), leaving scattered small openings with a matrix or surviving small trees." (Weatherspoon 1992) He describes this fire regime and stand structure as common during the pre-settlement era in the Ponderosa and mixed confer forests and states: "Silviculturally this kind of stand structure is approximated with the group selection cutting method."

   The SNEP Report's Chapter 15, "Silviculture in the Sierra," written by Helms and Tappeiner (1996), says

"Implementing overly prescriptive policy leads to a reduction in landscape diversity. For example, specifying a diameter limit on cutting, the amount of basal area to be retained, continuous cover, and the number of snags over broad ranges of stand types could benefit certain wildlife species but would drive stand composition to shade-tolerant species and would also likely lead to stand-replacement fires, loss in stand vigor, and increased susceptibility to insects . . . [T]he group selection method should encourage a variable opening size that enables the silviculturist to obtain regeneration of varying levels of shade tolerance, develop 'fuzzy' or more natural irregular boundaries, address fire and fuels issues, and use safe logging practices . . . Given the wide variability in existing stands in Sierran forests, flexibility is needed in prescribing treatments that best meet management and policy objectives." (p. 467)

   Only five sources are listed in the Literature Review, Appendix E, page 14. Other sources which should have been reviewed and cited are as follows:

Holmen, Scott P. and Heald, Robert C. II. 1988. Group Selection Silvicultural Systems, A Planning Example. Blodgett Forest Research Station. Dept. Forestry and Resource Management. University of California Berkeley, Calif. (attached as Appendix Q-9)

McKelvey, Kevin S. and Weatherspoon, C. Phillip. 1992. Projected Trends in Owl Habitat. The California spotted Owl: A Technical Assessment of its Current Status. U.S. Forest Service general technical report PSW-GTR - 133.

Weatherspoon, C. Phillip. 1996. Fire - Silviculture Relationships in Sierra Forests. Volume II Assessments and Scientific Basis for Management Options. Sierra Nevada Ecosystem Project. Final Report to Congress. Wildland Resources Center Report No. 37. Univ. of Calif. Davis.

McDonald, Philip M., Ritchie and Abbott. 1996. Ten-year Diameter and Basal Area Growth of Trees Surrounding Small Group Selection Openings. Northwest Science, Vol. 70, No. 4, 1996.

(attached as Appendix Q-10)

   The DEIS, however, relies primarily on an overly negative critique of group selection silviculture that was written by John Fiske (“Major Silvicultural Systems and Their Application,” Lassen National Forest Plan Appendix O, 1992) which has been rebutted repeatedly by Friends of Plumas Wilderness. The first formal response by FPW was done in 1986, and is included here as Appendix Q-8 because the arguments are still basically the same. A somewhat broader context for the issue is presented Appendix Q-7, “Regeneration Silviculture as Proposed by QLG.”

   Additional information on group selection issues is provided in Appendices Q-9 and Q-10.

Inadequate consideration of potential Forest Service revenue and long term cost reductions that would tend to offset and repay the direct costs of implementation.

   The DEIS comparison of alternatives fails to display the direct Federal costs and revenues in a clear and easily understood manner, and it completely neglects the opportunity, through the choice of one alternative or another, to avoid future costs to the Forest Service, other levels of government, and the public. Forest planning regulations in the National Forest Management Act (NFMA) at 36 CFR 219.12(b), (g) , and (h) all mention considering publicly raised issues, social and economic effects. For example, 219.12(g). “Estimated effects of alternatives. The physical, biological, economic, and social effects of implementing each alternative considered in detail shall be estimated and compared according to NEPA procedures. These effects include those described in NEPA procedures (40CFR 1502.14 and 1502.16) and at least the following:

“...(3) Direct and indirect benefits and costs ... including investment, administrative, and operating costs of the agency and all other public and private costs required to manage the forest up to the point where the outputs are valued and the environmental consequences are realized;

"...(iii) the economic effects of alternatives, including impacts on present net value, total receipts to the Federal Government, direct benefits to users that are not measured in receipts to the Federal Government, receipt shares to State and local governments, income, and employment in affected areas...."

   In addition, “...an environmental impact statement should at least indicate those considerations, including factors not related to environmental quality, which are likely to be relevant and important to a decision.” (40 CFR 1502.23).

   The Final EIS must clearly display the expected budgets and estimates of gross receipts and direct costs for each alternative. It should also provide estimates of all other public and private costs and potential cost avoidance provided by each alternative. Estimates of receipts, costs, and future effects on avoided costs are, of course, subject to variation, due to uncertainty as to which acres would be treated, the volume and value of timber inventory on the acres treated, and other factors. Nevertheless, a comparison of costs and benefits among alternatives would be more reliable than the absolute estimates on which they are based, because fluctuating values and most factors involving uncertainty would apply to every alternative alike.

   QLG believes that long term avoidance of both direct and indirect costs and losses associated with very large catastrophic wildfires is a major factor in the differences among alternatives. QLG believes that Alternative 2 best provides for both a substantial yield of environmental and economic benefits, and for sustaining those benefits by reducing the threat of catastrophic wildfire, improving silvicultural management, and protecting and restoring riparian areas. Alternative 3 does not state or implement any strategy, much less the best strategy for fire protection. Alternative 4 also fails to state a strategy, then greatly reduces the rate at which fuel treatment would be done, whether strategic or not. Alternative 5 could, and probably would, reduce potential benefits in fire protection, improved silviculture, watershed restoration, and community stability to the vanishing point.

   An evaluation of these potential differences among alternatives, not just according to conventional Forest Service measures, but with full consideration of the wider and deeper value system of the larger society, must be reported in the Final EIS in order to meet both the letter and the spirit of NFMA, NEPA, the Act, and the QLG Community Stability Proposal. Please see Appendix Q-11 for additional comment on socio-economic issues.

The DEIS addresses the traditional sorts of socio-economic impacts of Forest Service jobs, contracts, and timber production (including payments to counties from timber sale receipts). But what the DEIS terms "indirect effects" from Forest Service management are not explored in any depth, either qualitatively or quantitatively. In several places in the QLG area (e.g., Lake Almanor, Graeagle and the Mohawk Valley-Whitehawk-Gold Mountain area of eastern Plumas County), the residential real estate markets (and property tax payments to the County) are heavily influenced by the condition of the surrounding forests. While the national forests' "desirable environmental attributes" are acknowledged by the DEIS to play a role in people's decisions to live in the QLG area, the aesthetic and amenity values of a healthy, attractive, fire-safe forest landscape are not considered to be affected by the different alternative management schemes studied in the DEIS.

   But forest conditions are affected by Forest Service management, for better or worse. Property values, public safety, and public facilities and infrastructure (roads, bridges, culverts, dams, power lines) within and adjacent to national forest lands are placed at risk by the fire and fuels management policies and practices of the Forest Service. Large-scale, catastrophic wildfires also impose huge burdens on county highway departments and public service districts to repair and/or replace roads, bridges, and watersheds that destabilize and degrade in the years following large conflagrations. While it would be impractical at this late date to ask that detailed economic cost forecasts be made for public infrastructure costs due to forest fires under each of the alternatives, the Final EIS ought to discuss qualitatively the very real and potentially significant linkages between healthy, fire-safe forests and private property values, public safety, and public infrastructure.

   The very communities most concerned about the “indirect effects” of Forest Service management, particularly the fire hazard to themselves and the surrounding forests, are the communities most interested in working with the Forest Service. County Fire Safe Councils can help link the communities and the Forest Service in mutually beneficial efforts to plan and fund fuel reduction projects at the forest-community interface that tie into the Forest Service DFPZs. These possibilities should be taken account of in the Final EIS and in all subsequent project planning.

   This was clearly a major issue raised by environmentalists, wildlife biologists, and QLG. In the QLG scoping comments of January 19, 1999 (attached as Appendix Q-15) we specifically asked that the EIS consider the effects of the “offbase” and “deferred” landbase exclusions when analyzing the environmental effects of the Pilot Project. (Appendix Q-15, pg 1) We pointed out that the off base areas “include large blocks of late seral old growth, relatively undisturbed ecosystems, and many critical watersheds. These areas, along with the 'deferred' areas, are important in the conservation of old-forest, aquatic, riparian, and meadow ecosystems.” (Op. cit., p.6)

   Therefore we are greatly disappointed that the first mention of the environmental advantages of the landbase allocations initiated by QLG is buried all the way back in Chapter 3, page 108 of the DEIS, which states, “The amount of landbase in reserves will contribute to habitat suitability and connectivity for forest carnivores. Those alternatives that provide the most reserved lands, including RCHAs under SAT, in both the short term (5 years) and provide for future options after the 5 years, probably contribute to better opportunities for connectivity between suitable habitat parcels.” This is as close as the DEIS gets to acknowledging the ecological significance of the QLG landbase allocation. Indeed, the DEIS fails to identify the landbase allocation aspect of the Act and of the QLG Community Stability Proposal in describing Alternative 2 in Chapter 2.

   In current Forest Plans many of the QLG off-base lands and all the deferred lands are open to road building, logging, and some are dedicated to intensive timber production. The DEIS fails to disclose the extent to which many of them are available for salvage and sanitation logging under “Limited Timber Management” and related provisions of the existing plans. Using information contained in the Lassen and Plumas National Forest Land and Resource Management Plans and associated FEISs, we estimate that of the 466,000 acres designated “Offbase” and “Deferred” in Alternative 2, all but 22,000 acres are open to salvage and what the Lassen Forest Plan refers to as “Limited Timber Management” under current Land Management Plans. Please refer to Appendix Q-14 for further analysis on this issue.

   An accurate comparison of land allocations between alternatives is further obscured by the DEIS maps that use different and undefined terminologies for different alternatives. What do the terms “Areas Scheduled for Timber Harvest Activities” and “Areas Scheduled for Limited Timber Harvest” on Figure 2.1 mean? Neither the decisionmaker nor the public can properly evaluate and compare Alternative 1 to the other alternatives without clear and consistent definitions of terminology.

   The alternative maps also lump different factors together differently in the “Non-Project Area” map layer (white in Figures 2.1 through 2.5 of the DEIS).

   But the uneven consideration of alternatives and impacts extends beyond non-comparable maps of the alternatives. The DEIS discussion of “Old Forest Vegetation” is apparently based on preliminary work of the Sierra Nevada Forest Plan Amendment EIS Team (DEIS Ch.3, p.38) rather than on more widely credible, published, peer-reviewed scientific authorities. Despite this weakness in scientific rigor, the DEIS nevertheless recognizes that different sizes of late successional/old growth (LS/OG) forest blocks are not created ecologically equal. Those LS/OG acreages of great size (“hundreds or thousands of acres” says the DEIS on Chapter 3, page 39) are one of the distinguishing characteristics of this important resource. Yet the DEIS defies the prevailing wisdom and tallies LS/OG acres in patches as small as five acres each, treating all acres equally without regard to their surrounding forest structures and seral stages. Tables 3.12, 3.13, and 3.14 and their accompanying discussions on pages 41 and 42 of DEIS Chapter 3 display acres of LS/OG and ALSEs aggregated by landbase classification, but without distinguishing highly valuable large-block LS/OG acres from small-patch acres. The QLG landbase allocations now represented in Alternative 2 capture most, if not quite all, of the extant large blocks of LS/OG, by virtue of designating all the RARE II wildlands and more as “off base” and/or “deferred.” But that important fact is not disclosed in the DEIS.

   Indeed, the fact that LS/OG and suitable spotted owl habitat acreages are analyzed without regard to patch size and in patches as small as 5 acres each is not revealed in the DEIS, but it needs to be disclosed in the final EIS. We only discovered that the analysis was including very small patches in the LS/OG and suitable habitat counts by asking questions in meetings held during the DEIS public comment period.

The attempt to change the CASPO Guidelines in the Final EIS and Record of Decision.

   After publication of the DEIS, during the public comment period, the HFQLG EIS Team proposed new “HFQLG - EIS California Spotted Owl Suitable Habitat Management Guidelines” [New Guidelines] that would be applied to Alternatives 2, 3, and 4. (See Appendix Q-3 for a copy of these guidelines.) QLG opposes the addition of the New Guidelines to DEIS alternatives because:

   (1) The Act requires Pilot Project resource management activities to abide by the “California Spotted Owl Sierran Province Interim Guidelines” [CASPO Guidelines] “or the subsequently issued guidelines, whichever are in effect.” The New Guidelines are not consistent with this provision of the Act, because: (a) Existing CASPO Guidelines were adopted at the Regional level, and the HFQLG EIS team has no authority to amend the CASPO Guidelines at the local level; and (b) Amendments of the CASPO Guidelines leading to “subsequently issued guidelines” are now being considered at the Regional level under the Sierra Nevada Framework for Conservation and Cooperation (SNFCC). In specifying adherence to “subsequently issued guidelines” the Act clearly refers to this Regional process, which grew out of the earlier DEIS, RDEIS, and “FACA Committee” efforts to establish permanent CASPO Guidelines.

   (2) The New Guidelines are not supported by any reference to science-based reports that would justify the HFQLG EIS Team's claims that habitat would not be degraded and that the potential for crown fire initiation would be reduced. (Please refer to QLG's discussion above on the failure of the DEIS to analyze and consider the potential advantages of fuel reduction for wildlife habitat, owl viability, human safety, and other positive effects on forest health and sustainability, or to give adequate attention to that potential as a decision factor.)

   (3) The New Guidelines would make a major change in the DEIS without giving the public an opportunity to consider those changes and respond to them during the comment period. (4) In any case, an attempt to differentiate among the 5-year or longer term effects of alternatives, on the basis that one alternative would abide by existing CASPO Guidelines and another would adopt the New Guidelines, cannot be justified, because permanent guidelines are now being considered by Region 5 in the SNFCC, and the decision (now promised by the end of 1999) that comes out of that process will either change the Interim Guidelines or ratify their continued application. Even if the Regional decision is delayed somewhat, a local decision to adopt New Guidelines or stick with the CASPO Guidelines can have little or no effect on HFQLG Pilot Project implementation, because few if any projects can be ready for implementation until the year 2000, and all projects implemented after the Regional decision must abide by the same permanent Regional guidelines, no matter which HFQLG alternative is adopted.

   Again we refer the reader to Steve Self's analysis, Appendix Q-1, and Dr. Jared Verner's review of relevant spotted owl habitat issues, Appendix Q-2 attached.

IV. Additional detailed support for QLG's recommendation of Alternative 2 and opposition to the other alternatives.

Fire and Fuels.

Substitution of “area treatments” for DFPZs. A transition from Defensible Fuel Profile Zone construction to area-wide fuel treatment is intended to be the second stage of the long-term strategy suggested by QLG, but that must occur after an adequate network of fuelbreaks is actually in place. QLG does not believe that an adequate fuelbreak network can be established at a construction rate of less than 40,000 acres per year for five years, which is the minimum level the Act requires. If the actual construction rate turns out to be significantly higher than the minimum 40,000 acres per year, or if experience gained during the first few years of the Pilot Project proves that an earlier transition to part fuelbreaks and part area treatments is a superior strategy, it would be consistent with “adaptive management” and the “pilot project” to approach Congress seeking authority to implement the adjusted strategy. However, until an adequate DFPZ network is actually assured and takes shape on the ground, no such change in the strategy specified by the Act is justified or would be supported by QLG.

DFPZ Prescriptions. Chapter 2, page 8, footnote 3 describes a DFPZ, and refers the reader to Appendix J for further information. An essential element of DFPZ design is its provision of transport and operational capability for use of the DFPZ in fire suppression activities. For this purpose and from the beginning QLG has suggested that a DFPZ should normally include an existing road, which would provide rapid access, an excellent anchor line for fire suppression operations, and safe retreat if that becomes necessary. (Please see Appendix Q-6 for an expanded QLG statement on the fuelbreak strategy.) We believe that virtually all of the mapped DFPZs do in fact contain existing roads for this purpose. However, the DEIS DFPZ description referred to above fails to mention roads or other adequate access in the footnote, and Appendix J mentions a road only in passing and fails to indicate its strategic significance. Appendix J then compounds the confusion by saying that “...area treatments not associated with DFPZs...” were “...mapped based on a coarse scale analysis of areas most at risk for large, damaging fires and within close proximity to existing road systems.”

   These DEIS descriptions imply that roads have pretty much the same relationship to DFPZs as they have to area treatments, but actually that is not the case. The inclusion of a road (or other reliable provision for rapid access, efficient fireline operations, and safe retreat) should be stated as an essential element of DFPZ design, because that is what was intended, it is how a DFPZ has been described most consistently in other references, and it is how DFPZs have always been mapped (except in the rare instance where a short unroaded link might have been needed to provide continuity). On the other hand, there is no such requirement for area treatments, and there is no stated intention to use them as a strategic base for fire suppression activity.

   The incomplete and unbalanced description in the DEIS, of the actual relationships of roads to DFPZs and to area treatments, makes it impossible for the reader to reach a fair evaluation of the crucial differences between Alternative 2 and the other action alternatives regarding the level of fire suppression effectiveness, efficiency, and safety that each alternative would provide.

The DFPZ Strategy versus the Area Treatment Strategy. The DEIS fails to make an adequate or well-founded evaluation of the difference in effectiveness between the DFPZ strategy of Alternative 2 and the area treatment strategy introduced into Alternatives 3 and 4.

   In DEIS chapter 3, section 3.3.9, page 127, it is reported that, for fires greater than 100 acres during a recent 27 year period:

“One percent of these fires burned 98 percent of the acres.”

“An increase of acres burned in lightning fires often resulted from a shortage of specialized firefighting resources during multiple lightning fire events.”

   These facts indicate that large fires, and the potential for multiple simultaneous lightning ignitions to result in a large fire, support QLG's belief that large fire potential is the highest priority factor to be addressed in fuel reduction and fire protection strategies.

   This discussion is made more difficult by the fact that the Forest Service calls anything 100 acres and greater a “large fire,” and fails to provide standard terminology that distinguishes between a 100-acre fire, a 1,000-acre fire, a 10,000-acre fire and a 50,000-acre fire. In this discussion, QLG uses the term “large fire” or “very large fire” to mean a fire from about 10,000 acres to 50,000 acres, sometimes larger. We're talking about that one-percent of fires that burned 98 percent of the acres. Conversely, we say “small” or “mid-size” for the other 99 percent of fires.

   Unfortunately, in describing the fire effects that would result from adopting each alternative, the DEIS is content to analyze mostly small and mid-size fires, uses methods that are over-reliant on simulations of small fires and limited burn periods, and draws invalid conclusions about the behavior of very large fires on the basis of analyzing and simulating mid-size and smaller (sometimes much smaller) fires.

   The difficulties caused by over-reliance on small- and mid-size fire simulations is compounded by the fact that two kinds of fire behavior simulation were employed in the simulations most relied on, and it is not always clear which of them was used to support each part of the discussion or reach each conclusion. These simulations were run by Mark Finney on his FARSITE computer model, and are reported in a document, “Some Effects of Fuel Treatment Patterns on Fire Growth: A Simulations Analysis of Alternative Spatial Arrangements,”contained in the EIS Project File. We do not believe that Mr. Finney's results can legitimately be extrapolated to support the conclusions apparently based on them in the DEIS. (Please see Appendix Q-5 for a detailed critique of the Finney simulations and the mis-use of their conclusions in the DEIS.)

Maintenance of DFPZs. Chapter 3, pg 132. The DEIS says “Maintenance. Design projects with higher crown densities when this will reduce the chance of crown fire spread and reduce the amount of understory shrub component that will require more frequent maintenance.” It is difficult to know exactly what is being proposed in that sentence.

a. If “this” refers to a choice between two potential treatments, one resulting in a crown density higher than the other, then the first condition could never be satisfied, because we can find no justification in the literature on crown fire propagation for the assumption that “higher crown densities” will ever “reduce the chance of crown fire spread.” The usual assumption is just opposite. Other factors being equal (e.g. ground fuel, fire ladder fuel, moisture content, terrain, and weather), it has been found that a stand's susceptibility to crown fire propagation is closely related to crown bulk density. The greater the crown density, the more likely the propagation of a crown fire.

b. If it means to say that both potential treatments would reduce crown density, and “this” is intended not to refer to “higher crown density” but to the fact that either one would “reduce the chance of crown fire spread,” then perhaps one could get to the question of effect on shrub growth and maintenance. If that interpretation was intended, it was not stated clearly enough to be comprehensible to the public or to provide adequate direction to Forest Service personnel who would implement the EIS.

   In either case, when considering the management of crown density there are several tradeoffs to be considered, including a potential tradeoff between the advantage of reducing crown density to reduce susceptibility to crown fire propagation, and the advantage of shading the forest floor to control the rate of shrub growth. But this tradeoff should be analyzed in terms of the relative risks and hazards actually involved, not just be stated in general terms or as a conclusion that higher crown densities should be tolerated where the resulting need for maintenance could thereby be reduced.

   The Fire and Fuels folder in the Project File includes a page headed “DFPZ Maintenance Schedule” that says

“Assumptions used for maintenance burning of the DFPZs. The natural fire return interval in Ponderosa, Mixed Conifer, and Eastside Pine all include 10 years within their average natural return range. Therefore 10 years was selected as the average for all the DFPZs.”

   That is not an adequate analysis of the required maintenance interval for several reasons, including: (1) It provides no data or other support for the assumption made, that natural return interval is equal to required maintenance interval; (2) It ignores the fact that suppression capability exists and will continue to exist, whereas the “natural fire return interval” generally refers to the pre-1850's era where suppression was not a factor; (3) It ignores limits that air quality concerns have placed and will continue to place on the use of prescribed fire; and (4) The natural fire return interval of pre-1850 forests is different from what would exist in “natural” forests with today's distributions of tree size and resultant crown densities, so the assignment of 10 years to a supposed natural fire return interval is more questionable, and the connection of that to a required maintenance schedule is even more tenuous.

   A proper analysis of the required maintenance interval must account for the capability of suppression to protect against intolerable fire effects in the treated areas for periods that could go well beyond the natural fire return intervals. On evidence of fire history studies, early descriptions, and early photos, there were plenty of ignition sources in the pre-suppression era to start a fire about as often as enough fuel accumulated to support a fire. But that is not the threshold where fire hazard from the accumulating fuel is so great that prescribed fire must burn it right then. Suppression capability can be used to extend the period of safe accumulation of natural fuel, and that capability must be a factor in deciding how often accumulating fuel must be removed, and where the balance point is among all other factors involved. Those factors include the relative hazard of higher versus lower crown densities, and the hazard to the public of more frequent burning with prescribed fire, including air qualify effects.

Alternative 5 fails to “follow the science” regarding ALSEs.

   SNEP deals most directly with the ALSE (Area of Late Successional Emphasis) concept in SNEP Addendum Ch.3, p.53 (Franklin et al, Alternative Approaches to Conservation...). Alternative 5 specifies that “ALSEs are deferred from mechanical treatment or fuels management.” (DEIS ch 2, pg 17). This seriously perverts the intention and words of the SNEP scientists, whose recommendation was that:

“reserve areas would be actively managed to achieve the primary objective of maintaining high quality LS/OG forests; i.e., they are not areas where all human activities are excluded...,” and “...the most appropriate activities... are prescribed fire and managed wildfires, mechanical treatments are likely to be important in some portions. These include forest stand thinning to reduce fuel levels and creation of shaded fuel breaks.” [Italics added] (SNEP Addendum Ch. 3, p.61).

   The SNEP scientists conclude their work with a schematic design of the ALSE prescription on a map of the Camp Creek area on the El Dorado National Forest. That map shows the ALSE as an area that includes a network of linear features called “Defensible fuel profile zones (shaded fuelbreaks)”, “biomass then prescribed burn” areas and other “prescribed burn” areas (SNEP Addendum, Ch.3, p.70). The depiction of the ALSEs in Alternative 5 as areas where only prescribed fire would be used is in direct contradiction to the science developed in SNEP. Creation of ALSEs without active management is “political” science masquerading as the real thing. The advocates of Alternative 5 can state that the management prescription in Alternative 5 is their desire, but their opinion is clearly not science that meets the tests of NEPA.

Conformance with other Federal Law and Policy.

   The Act specifically mandates that the Pilot Project “shall be implemented to the extent consistent with applicable federal law...”(Sec (c) (3). This requires conformance to the letter, spirit, and intent, not only of laws that pertain specially to the Forest Service, but also of other laws, including those described below.

   Laws with special application to the Forest Service include: the Organic Act (1897), which established two primary purposed, favorable conditions for water flows and a continuous supply of timber; Multiple Use Sustained Yield Act (MUSY, 1960), which added recreation, wildlife, range, watershed, and fish to best meet and serve human needs; and the National Forest Management Act (NFMA, 1976), which requires comprehensive planning, monitoring, and evaluation. (Brief descriptions taken from “A Brief history of Forest Service Mandates and Programs - How It Has Shaped Forest Service Mission and Values,” on the El Dorado NF web site.)

   Other laws and policies applying to the Forest Service include:

Clean Air Act. The Environmental Protection Agency (EPA) is currently conducting a process to revise regulations covering fires. Their 1998 Interim Air Quality Policy on Wildland and Prescribed Fire seeks to develop protocols for use of prescribed (and naturally occurring) fire in wildlands and agricultural lands.

   The interim policy “urges air quality mangers to participate in public land use planning activities which involve selecting appropriate resource management activities.”(p.8). Air quality managers are urged to “participate in evaluating and selecting alternative resource management tools.” (p.16). The policy calls on land managers to develop Smoke Management Plans designed to reduce emissions from fires by attempting to:

1. Minimize the area burned

2. Reduce the fuel loading in the area to be burned,

3. Reduce the amount of fuel consumed by the fire and

4. Minimize emissions per ton of fuel consumed.” (p.20)

   This mandate for federal land managers in the QLG area (particularly regarding objectives 2, 3, and 4) is met through cogeneration opportunities at stand- alone and lumber mill sited biomass electric generators. Biomass that is burned in an electric generation plant produces 96 percent less air pollution than burning that biomass in a prescribed fire.

   The Maidu stewardship program now being undertaken in the area is intended, among other things, to determine the best times of the year to burn for different attributes (including air quality).

   The QLG related biomass-to-ethanol research (now being conducted through Department of Energy and California Energy Commission auspices) is intended to improve air quality in at least three ways: (1) support the large scale removal of fuel that is at great hazard of burning in very large wildfires; (2) dispose of that fuel by processes that cause very much less air pollution than would be caused by disposing of it in prescribed fire; and (3) provide a local source of ethanol, which is used as a gasoline additive to reduce motor vehicle emissions. Alternative 2 would best support these activities and opportunities, and thus Alternative 2 best conforms to the Clean Air Act.

Clean Water Action Plan. The US EPA's Clean Water Action Plan (1998, available at http://cleanwater.gov/action/toc.html) describes the methods by which the federal government intends to implement certain provisions of the Clean Water Act. In Chapter 3, “America's Watersheds; the Key to Clean Water,” it calls for setting watershed priorities and developing “Watershed Restoration Action Strategies” with “states, tribes ...public agencies and private sector organizations and citizens”. Chapter 2, “Actions to Strengthen Core Clean Water Act Programs,” calls for efforts to “enhance natural resource stewardship” and notes that on federal lands “The need to continue advancing a coordinated and cooperative approach has never been greater”. This chapter calls for efforts to:

1. Increase forest road maintenance and obliteration.

2. Enhance the condition of riparian areas and stream corridors.

3. Sustain forest health to protect watersheds and water quality.

4. Improve the health of federal rangelands.

5. Prevent water pollution from abandoned/active mines.

6. Increase understanding of ecosystems at the watershed scale.

   All of these goals are specific attributes of the QLG plan, the Act that implements the QLG plan, and the ongoing activities of local watershed groups. Alternative 2 best carries out the intent and specifications of the Clean Water Action Plan.

Presidents Council on Sustainable Development. An early publication of the Presidents Council on Sustainable Development, “Sustainable America—a New Consensus for Prosperity, Opportunity and Healthy Environment for the Future,” (February, 1996, available at http://www.whitehouse.gov/PCSD), included chapter 5 on “ Natural Resources Stewardship” which includes the following:

   The Council endorses the concept of collaborative approaches to resolving conflicts.

   In its meetings and task force groups, the Council found that communities, citizens, and other stakeholders across the country are inventing and using their own collaborative processes. For example, stakeholders within the Feather River Watershed in Northeastern California, an area containing portions of three national forests--Plumas, Lassen and Tahoe—created a forum for people living there to use “common sense to achieve obvious goals: healthy forests and healthy small town economies through time.” Known as the Quincy Library Group (named for the library in Quincy, California where it holds its meetings), the community based group began by developing a management plan for the 2.5 million acres of prime federal timber land and is now working on steps to carry it out.

   Alternative 2 in the DEIS best defines the “steps to carry it out.”

National Environmental Policy Act (42 USC Sec.4321). This statute has endured for thirty years as the underlying environmental law because, from its inception, it sought to place the citizens of the United States within the context of the natural environment, rather than exclude them from it. Title I of the Act clearly strives for that balance in calling on the Federal Government (in the following excerpts) to be responsible

“to the end that the Nation may”—


2. assure for all Americans safe, healthful, productive and aesthetically and culturally pleasing surroundings;...

3. attain the widest range of beneficial uses without degradation, risk to health or safety...;


5. achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life's amenities;

6. enhance the quality of renewable resources....

...(c)...each person has a responsibility to contribute to the preservation and enhancement of the environment.

A twenty-five year report (1997) on the effectiveness of NEPA begins with a letter from the then chair of the President's Council on Environmental Quality, Kathleen A. McGinty, who notes:

...NEPA charges CEQ [the Council on Environmental Quality] and all federal agencies with achieving “productive harmony” among our environmental, economic and social objectives. NEPA directs federal agencies to open their doors, bring the public in, and offer genuine opportunities for participation and collaboration in decision making.

...Clearly NEPA is much more than environmental impact statements and environmental assessments. It is an eloquent and inspiring declaration which, well before the term “sustainable development” became widely used, called for integration of our varied aspirations as a society....

   QLG maintains that Alternative 2 will profoundly carry out the intent and letter of the National Environmental Policy Act.

V. Suggestions to correct errors, improve the DEIS analysis of alternatives and their effects, and to deal more completely with other issues of significance.

   In this section we make suggestions in the order the subject matter appears in the DEIS. It includes simple editorial corrections as well as suggestions on subject matter. Additional suggestions may appear in Appendix Q-11 on socio-economic issues, and in Appendix Q-16, a copy of our earlier letter to the HFQLG EIS Team (June 29th), which originally raised some of the points that are repeated below.

DEIS page numbers are referenced in the format “chapter - page,” so 1-4 means ch 1, pg 4.

Abstract. Middle of first paragraph: “...approximately 43,500 acres of small group selection and individual tree harvest, protection of certain late-successional old growth stands, and a program of riparian management.” This says the TOTAL of small group selection and individual tree harvest is 43,500 acres, whereas there would be 43,500 acres of small group selection alone, plus whatever individual tree harvest is added within the overall acreage limit. It needs a comma, and can be made clear if you omit the first “and,” and add the word “selection.” Suggest “...approximately 43,500 acres of small group selection, individual tree selection harvest, protection of...”

Sum-2 and 1-3 correctly state that “Individual tree selection may also be utilized within the pilot project area.” However, 2-8, second paragraph, says that “...individual tree selection treatments will be scattered throughout the planning area.” The “planning area” is defined to include off-base and deferred areas, where individual tree selection would not be permitted by the Act. This is a serious mis-statement of Alt 2 intentions.

Sum-4, Issue 3, Economic Stability. A rewrite is required that eliminates the bias against timber management and recognizes the short and long term benefits of the pilot program.

The assumption that all concerns are about whether the timber industry has value sets the stage for continued and repeated mis-interpretation in the DEIS of the true value of timber-related industry to the affected counties. Why is it an issue to decide whether a community is fully “dependent” on the timber industry? Is it not enough to consider whether the timber industry is just possibly a valuable contributor in many ways to the economic, social, and ecological well-being of that community and the whole area? When the DEIS starts with the assumption that questions posed by the opposition are the only questions at issue, it is difficult later to come up with an even-handed analysis and evaluation of the actual questions at issue, which are:

Will economic stability best be provided by the proposed action?

Which of the alternatives will best provide it?

(See QLG Appendix Q-11 for more discussion of these issues.)

Sum-8. Socio-Economic Considerations, paragraph 2. The Timber Industry is not a monolith. During the 20 year period, family owned sawmills that were totally dependent on a stable supply of timber from the US Forest Service began to disappear throughout the landscape. Companies with sawmills and timberlands survived the reduction period. Timberland owners without sawmills enjoyed a period of increased competition and stumpage for their timber sales. During this period of “relative stability” 65 sawmills closed in California. In the pilot project area, family owned sawmills closed in Burney, Susanville, Quincy, Sloat, Oroville, Marysville.

Sum-8. Last line under Roadless Area Management. Page 3-23, Table 3.6, says the acres affected in Alt 1 are 7,000, not 9,800.

Sum-9. First paragraph under Fish and Wildlife Resources. “This risk is incrementally less with Alternative 4 and Alternative 5.” First the word “incrementally” says only “in pieces,” it does not quantify anything. Second, this conclusion is valid only if you note that it takes no account of potential fire effects. (See comment about page 2-4.)

Sum-11. Bottom paragraph. “...but they can effect off-site resources and ecosystems.” The meaning here is “affect” not “effect.”

Sum-12. Final sentence. “Economic impacts will vary by the level of commodity extraction in each alternative.” This is an extraordinarily narrow view. Perhaps greater and longer lasting economic effects will result from whether we achieve adequate fire protection or maintain water quality, and from the indirect impacts of these questions on recreation and tourism activity.

1-1. Bottom paragraph. “The Act directs the Secretary of Agriculture, acting through the Forest Service, to complete an environmental impact statement to establish and conduct a pilot project...” It's actually the other way around. The Act directs the Secretary to conduct the pilot project, which starts at completion of the EIS and ROD. Perhaps a minor point, but it is not consistent with correct descriptions elsewhere in the DEIS.

1-1. Bottom paragraph. The phrases “...group selection harvest, individual tree selection harvest ...” should be changed to the wording of the Act, “... group selection and individual tree selection, uneven aged forest management prescriptions to achieve a desired future condition of an all-aged, multistory, fire resilient forest.”

1-1. Bottom paragraph. “... the Act identifies that within [specified areas], management activities will not occur...” The Act does not prohibit ALL management activities in these areas, only the activities specified in the Act. “...certain specified management activities will not occur...”

1-2. Purpose and Need. Change the wording regarding “harvest” to conform to the Act, as noted in the earlier comment.

1.3. Riparian Management. This section should state that project planners and affected permitees should coordinate at the earliest possible time to avoid scheduling grazing in the area of the project.

1.3. Bottom paragraph. “...unless the amendment or revision [of the three LRMPs] are completed earlier.” First, either “amendments and revisions ... are” or “amendment or revision ... is...” Second, this fails to make the crucial point that the required amendments or revisions have certain conditions imposed on them by the Act. It is important to make clear, for example, that amendments made through the Sierra Nevada Conservation Framework process, as currently drafted, would not terminate the Pilot Project. “...revisions ...as directed by the Act are completed earlier.”

1-4. Pilot Project area and exclusions. Omit “and local communities” from the sentence.

1-6. Significant Issues. Starting here and throughout the DEIS “public response” and “concerns that exist” are listed which reflect only a negative view of the Act. We believe we heard and saw in your public scoping meetings and in the written comment a much wider view of the issues. Where have you stated the public's concern for strategic fuel reduction, not just the potential problems of such activity? Where have you reflected a public desire for road access, not just road restrictions? Why is economic stability framed as a question of whether the timber industry is vital? Is there not a significant economic issue here even if timber is perhaps less important to local economies than it once was?

1-6. Issue 3: Economic Stability. This section is biased against the implementation of resource management activities and fails to acknowledge the short and long term benefits of pilot to the amenities, aesthetics, recreation, and tourism interests. Please see our further explanation of this and related issues in QLG Appendix Q-11.

1-7. Other Applicable Laws, Regs and Policy. The Pilot Project is governed by more than the National Forest Management Act. The Organic Act, Multiple Use Sustained Yield Act, and Weeks Act directly apply, the later reference to Endangered Species Act, Clean Water Act, and National Historic Preservation Act should be listed here instead of under Environmental Justice. Other applicable laws, regulations, or policies should also be listed and their application explained.

1-8. Forest Plan Amendment. This section should include vegetation management prescriptions for DFPZs and area-wide fuel treaments in the list of elements to be amended into LRMPs in this decision. This is required by 36 CFR 219.15.

1-9. Environmental Justice. Move the references to specific laws 1.11 and list them under 1.10, as suggested above. Provide a definition of the term or concept of “Environmental Justice” in the Glossary. Efforts to consult during the planning and implementation of projects must be expanded to include at least Counties, Fire Districts, County Fire Safe Councils and the California Department of Forestry and Fire Protection.

2-3. Fourth paragraph's first sentence states that implementing HFQLGFRA would necessitate second commercial entry during the CASPO interim guidelines on some stands. How many stands would be so affected? How many acres would be so affected? How many owl pairs would be impacted? Where are these places? If site-specific counts were not made, what are the data and reasoning in support of the statement?

2-3. Last two paragraphs mis-characterize CASPO interim guidelines regarding hazard tree removal policies (not part of interim guidelines) and supplementing open-canopied overstories with smaller-diameter trees (also not in the guidelines, but a CASPO Technical Assessment Team recommendation). DEIS omits the CASPO guideline to augment snag-deficient stands.

2-4. Table 2.1 misstates snag densities required by CASPO; should be shown as a minimum of 4 of the largest snags per acre.

2-4. Paragraph below Table 2.1. This statement should be reflected in the Summary discussion of management effects on wildlife habitat. (See comment about Sum-9.)

2-5, middle of page. “Appendix B displays by suitable strata (vegetation type), the percentage available where group selection is feasible.” Perhaps you meant Appendix E.

2-5, paragraph following above reference. Are the 110,000 acres part of the 536,000 acres, or in addition?

2-6, first paragraph. This characterization of existing Forest Plan direction is inaccurate.

(1) The Transition Zone Adaptive Management Strategy proposed by Bliss, et al, in 1996 did not qualify as an “adaptive management strategy” exception to the CASPO Guidelines, but only provided information to be considered, as made clear by Forest Service management at the time.

(2) The Atencio letter of 1995 did not amend either the CASPO Guidelines or the Forest Plan.

(3) The forest carnivore networks have never been amended into Forest Plans in the manner prescribed by law (i.e. satisfying NFMA and NEPA process requirements) and have not been publicly disclosed.

(4) Allowable Sale Quantities (ASQs) have not beeen recalculated and amended into the Forest Plans, though program levels have been dramatically lower than projected output levels and the scheduled times for Forest Plan review and amendment if necessary have passed by.

(5) The Chief's 18-month suspension of new road constuction in roadless areas does not remain in effect for the full 5-year period of the Pilot Project, especially since the suspension has been in effect for some time and the Pilot Project has not yet started.

Figure 2.1. The Map legend categories need to be defined for “Areas Scheduled for Limited Timber Harvest Activities” and “Areas Scheduled for Timber Harvest Activities.” However, to make a fair and official comparison this map of the “No Action” alternative should show existing general land allocations.

2-8. The description of Alternative 2 has individual tree selection going on “throughout the planning area” which is not the same as the pilot project area. Genuine hazard trees aside, this is not an accurate statement. (See comment above, about Sum-1 and 1-3, which refers to this page.)

2-10. First paragraph. “... higher than levels expected under existing Forest Plans.” and

2-11. First paragraph. “... more...than current management.” These both refer to commodity output levels, but apparently employ different baselines. If you intended to imply a difference between “expected under existing” plans and “current management,” you must be specific in stating the output levels of each assumption, so that the public can make valid comparisons.

2-10. First line at top of page claims that the “program level for timber sale offer . . . [would be] substantially higher than levels expected under existing Forest Plans.” Although “levels expected” is not the same concept as “Allowable Sale Quantity” set in Forest Plans, the implication is clear. But the projected 319 MMBF (plus biomass) is substantially lower than the combined ASQs of the affected forest plans. It would be appropriate to state BOTH the official ASQs in the existing Forest Plans AND the levels expected.

2-11. Issue: Economic Stability. The statement that Alt-2 provides 60% more merchantable timber outputs than current management is not supported by the data in Table 2.3 and Appendix A. Instead, those data give the following comparison of Alternative 2 to Current Management:

Alterative 2 sawlog volume: About 250% of current.
biomass volume: 122% of current.
total volume: 210% of current

The statement that Alternative 2 treats 300,000 acres of vegetation shows that the Forest Service plans to implement only 85% of the capacity authorized by the Act. To enhance the socio-economic benefits, 10,000 additional acres of treatment per year should be added to Alternative 2, Table 2.3.

2-11. First paragraph under Alternative 3. “It is similar to Alternative 2 with additional emphasis on using a combination of area fuel treatments and linear DFPZs...” What is “additional” about it? The total fuel treatment area is less (36 to 55 thousand acres a year vs 40 to 60 thousand) and the amount of “real” DFPZ is only about one third of that in Alternative 2.

2-13. Issue: Economic Stability, Alternative 3. The same change should be made as noted above, regarding “60 percent more merchantable timber.”

Figures 2.3 and 2.4 (Maps). DFPZs are identified as “priority” DFPZs. That term is not mentioned or explained in the text or elsewhere we can find.

2-13. Paragraph just above “Alternative 4.” “...area-wide fire hazard reduction treatments that broaden or replace some of the DFPZ's.” About two thirds of the DFPZ acres are replaced, which is “most” not “some” of them.

2-14. Paragraph below mid-page, numbered 3, and 2-17. Equivalent statement regarding Alternative 5.

“ALSE comprise 172,000 acres that are available for management under the existing Forest Plans.” This is not an accurate statement, and introduces confusion in several ways. (1) Table 3.14 (pg 3-42) gives a breakdown of ALSE acreage by Forest (presumably nearly identical to the Planning Area), which shows a total of 397,434 acres. Of those, 172,067 are in the QLG “on base” area, and that is apparently the number you used. But it is not the acreage “available for management under the existing Forest Plans.” (2) If you are going to make a fair comparison of the effect of alternatives on the management of areas identified as ALSE in SNEP, you must show that Alternative 2 protects at least 225,367 acres of it in the off-base and deferred areas, then show whatever addition protection is claimed by Alts 4 and 5.

2-16. Footnote 5. The DEIS refers people to SNEP for a definition of the “SNEP buffers” instead of defining that concept in the DEIS text or an Appendix. This is not adequate, because (1) SNEP gives two formulas, but the DEIS doesn't say which one was used, the DEIS doesn't say which one, and (2) the SNEP formula is not valid, according to statements and documents put out by the Sierra Nevada Conservation Framework team. The “average 540 foot width” listed in DEIS Table 2.3 and Table 3.5 cannot be computed by any reasonable application of either of the formulas from SNEP. The actual formula used should be shown and explained in the Final EIS.

2-17. Item #4 in middle of page: Prohibiting timber production on these National Forest System lands would require more than forest plan amendments. This section should point out that the authorizing statutes for the Forest Service, such as the Organic Act, Multiple Use Sustained Yield Act (MUSY), and the National Forest Management Act (NFMA), would have to be amended regarding these Forests by Congress to make such a prohibition legal.

2-18. Alternative 5, Economic Stability. Should read “Alternative 5 provides 12 percent...”, not Alternative 2. Also, the negative affects of Alternative 5 should be shown here: (Table 3.50 information)

Personal Income to families 86%
Employment private 68%
Employment USFS 29%
Gross Forest Receipts 89%
Forest Reserve Revenues 89%
Economic Opportunities 83%

And what are the social/economic impacts to County assistance programs with 900 more people out of work in the Pilot Project area?

2-19. How do mitigations for TES species, heritage resources, and water & soil resources differ from current directions and practices?

2-20. Soil Quality Analysis Standards (SQS) should be explained, not just “incorporated by reference.”

2-21. Third and fourth lines from the top of page contain a curious statement that needs a lot more explanation and definition: “Factors such as ground cover and large woody material become secondary and can be waived in critical fuel treatment areas.” Define a critical fuel treatment area. How many of them are there, where are they, and how are they determined? When is appropriate to mitigate ground cover loss and/or large woody material loss, and when is it appropriate to simply waive the requirements to do so? How is that determination made?

2-21. Item #1 in top half of page: What are “critical soils”? When will “critical soils” be identified? Why can't that be done now (especially if it's an office exercise rather then field work) to evaluate DFPZ and other activity placements?

2-23. This section on wildlife mitigation measures refers to forest carnivore networks as though these networks are officially designated. They are not in the forest plans, but were merely alluded to as yet-to-be-developed. Where are these networks, and what vegetation types are presently in them? What are the design standards for them? How many habitat blocks and of what size are they? How many connectors? Define and/or describe “preferred habitats,” “travel corridors,” and “gaps.” How many gaps are permissible per corridor? How big is a gap? How many gaps per mile can be allowed in a corridor? How many gaps does it take to cause fragmentation?

2-24. Last sentence on the page includes the statement, “use of mechanical treatments in natural stands may conflict with other resource management objectives.” Define what is meant by “natural stand.” How many “natural stands” are slated for treatment under each alternative? Where are these natural stands, and can they be avoided in project layout?

2-27. Table 2.3. Should say whether the “Net Decrease in Road Miles” is classified roads or unclassified roads. Road changes by alternative should be described and mapped.

Table 2.3 also needs additional columns that display Allowable Sale Quantities (ASQs) from the Land and Resource Management Plans (LRMPs), and current volume levels for each forest, then the projected volume per year for Alternatives 1 to 5.

2-28. Table 2.4. The Final EIS should explain exactly how the Regional Forester's letter of May 1, 1998, applies only to Alternative 4.

3-2. Table 3.2 “Planning Area and Landbase Considerations” would be much more meaningful if there were tables for each alternative that showed the various acreage totals for the various categories of deferrals, exclusions, moratoria, and protective withdrawals. How many acres of LSOG 4 & 5 are in the QLG “deferred” lands? How many acres of LSOG 4 & 5 are in the “available for group selection” land category? How many acres of QLG “deferred” lands would otherwise be affected by the road construction moratorium?

3-3. Last paragraph. Where, and how many acres, are the “forested areas frequently entered for harvesting” that have lost top soil? Without documenting the nature, extent, and distribution of forest acres that have suffered reduced soil productivity, how are the alternatives to be analyzed or evaluated? How can effects be measured later? The entire “Soil Productivity and Condition” section needs footnotes and area-specific data presentation.

3-6. Bottom of page features two paragraphs opining the loss of aquatic and riparian plant and animal communities. Could a map be prepared to show the streams where native communities still exist, and where they are gone; where headwaters populations of fishes are now isolated from each other; where is habitat unsuitable for cold-water fishes?

3-8. End of fifth paragraph. What are the “normal protective measures” the DEIS assumes will be used to make sure adequate ground-covering woody residues are left? This takes us back to the “waiving” of cover and wood requirements on page 2-21.

3-14 and 3-23. Tables 3.4 and 3.6. Two comments:

(1) It is impossible to see any common sense in the relationship of the “Increased Equivalent Roaded Area” entries and the other road-related data in the table. In the form of road decommissioning and obliteration, reconstruction, and relocation, Alternatives 2 and 3 provide about eight times as much beneficial effect as Alternative 5, yet they get the same ho-hum rating for “Overall roading change significance.” In contrast, on the subject of ERAs, Alternative 5 gets a rating that will too easily be interpreted as 20 to 40 times as good as Alternatives 2 and 3. This is a classic case of giving too much attention to a very questionable rating system because it so easily gives numerical results.

(2) These tables (or some other table in the DEIS) should give similar comparisons by alternative of net fuel reductions (or failure to reduce, due to offsetting growth) and the accompanying reductions (or increases) of fire hazard.

3-18. Reduction of Near Stream Roads. “Approximately 100 of near steam roads...” 100 of what? Miles?

3-19. Same question as above. 67 of what?

3-41. Two tables are mis-labeled. The table at top of the page is apparently 3.10, and the table in the middle should be 3.11.

3-52. Table 3.18. Entry for Alt 2 regarding LS/OG 4/5 contradicts the description of Alt 2 on page 2-8, third paragraph, which says “...stands ranked LS/OG 4 and 5 are deferred from timber harvest and road construction activities.”

3-128, Figures 3.3 and 3.4. There is no differentiation between the bars of the graph in the printed copy. They are both solid black. It appears from other information that top on the legend is left on the graph, but it should be possible to see this at a glance.

3-136. Just below mid-page. “Spotting would occur over 2.5 mile wide DFPZs (see Appendix J).” Should be “0.25 mile wide DFPZs.”

3-145. Alternative 4, Direct, Indirect, and Cumulative Effects. “1453” cultural heritage resources should be “625.”

3-146. Alternative 5, Direct, Indirect, and Cumulative Effects. DEIS says that “Direct effects to prehistoric lithic scatters and other sites containing obsidian may be substantial.” and “...a significant increase in the number of determinations of eligibility and data recovery (mitigation) programs required before burning may begin.” An estimate of how these factors affect the numbers that are prominently displayed regarding the other alternatives must be displayed. The “raw” acreage numbers suggest “829” is the number for 40,000 acres of treatment. Do the “substantial” effects and “significant increase” in determinations raise or lower that number, and by how much?

3-151. Affected Environment. Refers to Appendix S. Many (perhaps all) copies of the DEIS are missing about 60 percent of the subjects listed in the table of contents for Appendix S.

3-152. Forest Ecosystem and Regional Economics. This and the part of it carried forward into the Summary must display the various and cumulative impacts of government policies on forest management, and the direct and secondary impacts of those policies on businesses in the various communities and the region. Please see QLG Appendix Q-11 for detailed discussion on this point.

3-153. Labor. Working women are an important minority group to acknowledge, in that they are a part of the labor force that greatly benefits from stable economies and healthy environments. The DEIS makes no mention of the Civil Rights Impact Analysis that is required by Executive Order.

3-154. Public Education. The DEIS must clearly display the significance of the Forest Reserve Revenues to schools in the Pilot Project area. What % of annual school budgets are Forest Reserve Revenues? What have they been over the past 25 years? What education programs/resources are reduced with the reduction in Forest Reserve Revenues?

3-154. Labor. The possibility should be considered the “discouraged workers (unemployed persons not seeking work)” are created by the lack of good paying forest-related jobs in the Pilot Project area that will allow an individual to work, live and raise a family.

3-155 Local Timber Industry. The 1998 season gives to narrow a view of the dynamics of the timber industry. Greater clarity and definition are needed regarding Timber Companies, Large Companies, Smaller Companies, SBA program, and the SSTS program. This section reveals a

lack of understanding of the Small Business Administration (SBA) program and how the various large and small manufactures and contractors are affected. The Small Salvage Timber Sale (SSTS) is a subset of the SBA program and both have employee levels for participation. This lack of understanding has biased the statistics against large companies. The data used in this section is at the end of Appendix T, not V as listed.

The various assumptions relative to percentages and values need to be reworked because 50% and not 8% on the Lassen and 72% and not 18% of the sales on the Plumas went to small business.

To capture the significance of a stable Forest Service timber management program on the communities, the period of influence must go back twenty-five years to measure the true impacts.

Brown's (1995) report referencing 13,000 job losses in Pacific North West is not relative to the situation created by the Cal-Owl policies. A better question would be how many manufacturing and woods jobs were lost because of the roller coaster timber management program and policies of the national forests. Family owned and Forest Service dependent manufacturing facilities were heavily impacted by the lack of stability in the Forest Service timber sale program.

3-156. Bottom paragraph. “The combined capacity of these plants was approximately 260 MWh in the year 1998.” If this number is correct, it is in terms of MW, not MWh. However, see our Appendix Q-17 for other corrections on this subject.

3-157. Recreation and Tourism. The alternatives vary in the fire protection they would afford, and the effect of catastrophic fire on recreation and tourism should be analyzed and displayed. Other aspects of recreation are discussed in more detail in Appendix Q-11 attached.

3-158. Grazing. Unless the permittees, purchasers, and the Forest Service work on the scheduling and implementation of Resource Management Activities to avoid conflicts, they will develop. Importance of working together in this area must be amplified.

3-158. Forest Reserve Revenues. The values shown in Appendix S are lower than other published figures. These numbers should be reviewed carefully and corrected in the Final EIS.

include for each alternative the annual operating budget, the total gross forest revenue receipts for each alternative, the economic impacts on recreation, tourism, and grazing, and the actual impacts on county school budgets.

DEIS Appendices:

Map B. First, the two areas of special interest, LS/OG 4 and 5, and ALSEs) are given colors so close together that it isn't possible to see the distinction on the map. Second, the printing makes it appear that many ALSE areas are rimmed by lines of LS/OG 4 and 5, which isn't likely to be true.

Regarding Maps E through I, there is no reference on or accompanying the maps that says where to find an explanation of the data sources and methods for map construction. Most of this is in Chapter 3, section 3.3.9, but it is not easy to find.

Map E. Fire Occurrence Areas. There isn't any obvious connection to an explanation of what is defined as a “fire occurrence area” or a quantification of the scale from low to high. Without an explanation of what it means, this map isn't just useless, it could be seriously misleading.

Map F. All Fires Since 1900. The legend is confusing. “Large fire perimeters” are said to be shown in blue. But a “perimeter” is the line around something, which is different from the “areas” apparently shown (in part) in blue. Then large parts of the “blue” areas are actually colored pink, so apparently the convention is that all the colored areas are blue “underneath,” with the SW-W aspects colored pink “on top.” Since every fire area appears to be colored blue by that definition (some small ones with a nearly complete pink overlay), the map appears to say that these are simultaneously “all fires” and “large fires,” which surely cannot be the case.

Map H. Ignition Risk Map. The legend changes the label from “ignition risk” to “ignition risk priority,” which sounds like something different. It implies a judgment on how much management attention must be paid to that part of the map, not just on how frequently ignitions occur. There is no explanation of what constitutes a high, moderate, or low risk.

Map I. Fire Susceptibility Analysis. There is no explanation, even in 3.3.9, of what the numerical rankings actually mean, or what weight is given to each element of a particular ranking.

Map J. Current Risk of Cumulative Watershed Effects. Finally there is a reference to a specific appendix. Unfortunately “Refer to Appendix XX” appears to have been a placeholder that was not brought up to date before publication, and in fact we can't find any explanation in any of the appendices.

A-2. Table of “Pilot Area - Harvest Acres”. Bottom line, “Grand Total / Ave” numbers appear to be seriously in error. Apparently each Grand Total was divided by 18, whereas the other sub-total averages in the table were calculated by dividing by 6 (the six years tabulated).

J-1. Last line on page. “When these objectives do not conflict with CASPO Interim Guidelines” is not a sentence.

J-2. Minimum fuel loading. “Up to 10-15 tons per acre” is not a logical statement of what you probably intend, since it would permit zero tons (which is in the range of “up to 10-15 tons”) to qualify as a minimum.

J-2. Near bottom of page. “In Alternatives 3 and 4, area treatments not associated with DFPZ's are the second step...” This is not compatible with the specifications of alternatives 3 and 4, which give the same acreage per year for each kind of treatment over the whole 5-year period.

Tables J-3 and J-4 (last two pages in Appendix J). Basal Area is said to be in cubic feet per acre. The correct unit is square feet per acre.

Tables K-1 and K-5. These list “capacities” and “production” of electric power from biomass burning facilities during 1998. Either the titles should be the same or the numbers should be different.

(1) The normal assumption is that “production” must fall short of capacity, because no machine can normally run at full capacity year round, so it is hard to believe the titles are correct, because there are identical totals for Butte, Lassen, Plumas, and Amador counties, and for the SNEP portions of Shasta (Burney) and Tuolumne (Jamestown and Sonora). (The Plumas and Burney entries appear to reflect capacity, not production, so it seems likely that K-1 is mis-titled.)

(2) In any case, it is unlikely that Sierra County is producing 20 MW when its capacity is only 18 MW. Please see our Appendix Q-17 for other corrections on this subject.

Appendix X, starting at the page that contains Table 1. “Emissions by Alternative.”

Tables 1, 2, and 3 fail to state whether the acres and emissions are total for the project or by the year. The page with Table 6, first paragraph under Table 6, says “Alternative 1 would generate the lowest projected emission of 6267 tons per year.” According to the two paragraphs ahead of that statement, it appears that the total project emissions for an alternative are determined by adding up the subtotals for an alternative in Tables 1 through 3. However, those subtotals for Alternative 1 add up to 11,594 tons, which is not consistent with either 6,267 tons per year or 6,267 tons total.

Appendix X, Table 4. This says that Alternative 1 would save 9,528 tons per year of PM-10 and PM-2.5 per year. How is it possible for Alternative 1 to produce 6,267 (or 11,594) tons per year, and save 9,528 tons per year, when Table 6 shows that the total historical level of both PM-10 and PM-2.5 was only 7,688 tons per year?

Appendix X, Table 5 on 16th page shows that all counties are “non-attainment” of State PM10 standards, even though all meet the Federal standards. What the State standards are, and how far out of attainment each county is, should be explained.

We thank you for the opportunity to comment on the Draft EIS, and we remain available for consultations on further improvement of the Final EIS and associated processes, as provided for in the Act.



Linda L. Blum Edward C. Murphy
Corresponding Secretaries


Attached are Appendices Q-1 through Q-17:

Q-1. Comments Regarding DEIS and BA Assessments Related to Potential Effects on Spotted Owls. Prepared by Steve Self.

Q-2. Review of “A Preliminary Report on the Status of the California Spotted Owl in the Sierra Nevada.,” by Jared Verner.

Q-3. HFQLG-EIS California Spotted Owl Suitable Habitat Management Guidelines, proposed by the EIS Team; and QLG Spotted Owl Analysis, by G. Rotta.

Q-4. QLG letter to Steve Clausen, Sierra Nevada Framework Project, regarding “SNEP” riparian buffer widths.

Q-5. QLG Critique of the Simulations of Fuel Treatment Pattern Effects and the Misuse of Those Results in the DEIS.

Q-6. The Fuelbreak Strategy, a QLG paper adopted in January 1997.

Q-7. Regeneration Silviculture as Proposed by the Quincy Library Group, October 1998.

Q-8. “A Conservationist Response to 'Major Silvicultural Systems and Their Application,' by Region 5, US Forest Service”, 1986, by Michael Yost.

Q-9. Group Selection Silviculture System - A Planning Example. Scott Holmen & Robert Heald.

Q-10. Ten-year Diameter and Basal Area Growth of Trees Surrounding Small Group Selection Openings. Philip M. McDonald, et al, USFS PSW Station, 1996.

Q-11. Additional QLG Views on Socio-Economic Issues.

Q-12. Draft Data Format for Tracking Pilot Project Implementation, prepared by Frank Stewart, County Forester.

Q-13. Version 1.3 of the Forest Health Pilot Monitoring Plan.

Q-14. Compaison of Allocatioin of Roadless Lands in Current Forest Plans and in the QLG Pilot Project.

Q-15. QLG letter of January 19: Scoping Comments responding to the HFQLGFRA Notice of Intent.

Q-16. QLG letter of June 29th to HFQLG EIS Team regarding errata and food for thought.

Q-17. Wood Fired Power Plants in and around the QLG Area. Bob Allen, Burney Forest Products.

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