Beaver Creek EA by 3TGsB50a


									                                             The Ecology Center, Inc.
                                           801 Sherwood Street, Suite B
                                               Missoula, MT 59802
                                                  (406) 728-5733
                                                (406) 728-9432 fax
                                                                                     April 4, 2002
Bill Queen, Acting District Ranger
Hebgen Lake RD-GNF-FS-USDA
PO Box 520
West Yellowstone, MT 59758

Ranger Queen:

The following are comments on the Beaver Creek Fire Salvage EA on behalf of the Ecology Center.

We believe the recent fires are a component of the forest’s natural cycle of regeneration. Considering that the forest
has evolved to include fire and have thus developed tools to regenerate and success following fire, we feel that
salvage logging may disrupt this natural process of forest regeneration. We are concerned that recovery of burned
timber may be used as a guise to extensively log burned and partially burned areas of the Beaver Creek area. The
relatively low level of human understanding of post-fire forest regeneration and potential for large detriments of
restoration actions on sensitive post-fire ecosystems suggests that a carefully contemplated, rather than hasty,
response will be essential for forest regeneration. Detailed below are concerns that the Ecology Center feels should
be addressed as the analysis proceeds.

We sincerely hope that any desire to rapidly harvest burned timber does not become an excuse to embark on a large
logging project without thoroughly investigating the ecological impacts of such a project. Beschta et al. (1995), a
commentary paper compiled by eight scientists and submitted to the current regional forester, finds that “there is
generally no need for urgency, nor is there a universal, ecologically-based need to act at all. By acting quickly, we
run the risk of creating new problems before we solve the old ones. Ecologically speaking, fires do not require a
rapid human response.” As we do not recognize a need for rapid post-fire response, we request a thorough review
of the salvage project. We also request explanation of your rationale for any perceived need to act quickly.

The fire that burned in and around the Timber Creek watershed and the Cabin Creek WMA was a natural
phenomenon. According to the EA, the fire burned in a mosaic pattern (p. 1) and may not be the unmitigated
disaster that the FS often pretends that fires are. In any event, both stand replacing fires and non-stand replacing
fires are healthy parts of Rocky Mountain ecosystems. We are especially concerned that the FS is proposing cutting
90% of trees in the 70 acres (3/6/02 cover letter) proposed for logging here. The EA should disclose what
proportion of trees to be cut are green, what proportion have been impacted by the fire to some degree but could
survive, and should disclose whether the FS is using a scientifically valid measure to determine what trees will
survive. The FS should seriously examine the ecological impacts of post-fire logging on soils, watersheds, wildlife,
plants, and other resources. Again, we fail to see the need to act quickly in order to log.

Although the current understanding of the ecological effects of salvage logging is incomplete, what we do know
suggests that salvage logging can and often has resulted in significant damage to soils, streams, and wildlife by: 1.)
eliminating or significantly reducing large, dead standing trees critical for many wildlife species; 2.) damaging the
soil through increased soil erosion and compaction, 3.) creating warmer, drier microclimate conditions (thereby
increasing fire danger); 4.) simplifying forest structure; 5.) removing important sources of nutrients and organic
material (potentially reducing long-term productivity); and 6.) encouraging the spread of noxious weeds into burned
areas. In short, salvage logging reduces important components of the forest ecosystem, and tends to further
exacerbate stresses caused by the initial disturbance event.

The Beschta et al. (1995) report questions the ecological justifications of post-fire salvage logging claiming that
while “there is little reason to believe that post-fire salvage logging has any positive ecological benefits”, “there is
considerable evidence that persistent, significant adverse environmental impacts are likely to result from salvage
logging, based on many past cases of salvage projects” (Beschta et al. 1995). In a response to Beschta et al.

commissioned by the regional forester, John Lowe, Everett (1995) conceded that there was “little to no evidence”
that post-fire salvage removal of trees limits the intensity of future fires. He also found no support for the frequent
claim of salvage projects that post-fire logging results in no more environmental damage than green harvest. The
USDA recently (2000) addressed this discussion by reviewing the results of 21 studies of post-fire logging. While
we summarize some of their findings related to individual elements of the ecosystem below, we note that their
general finding was that “we know enough about both logging activity and structural change to recommend caution”
in post-fire salvage operations. We request that GNF account for the sentiment of the public notice that
“restoration work” is a necessary response to wildfire. Please carefully detail all scientific evidence of ecological
benefits of post-fire logging utilized in project planning.

We are concerned about the appropriateness and suitability of this area (our national forests as a whole) for logging.
The FS states that a "primary purpose for salvage harvest would be to recover commercial timber products" (EA
1-2). Shouldn't other resources and values, including those brought up by the public during scoping, be considered
on an equal footing with logging on our public lands? Why isn't the FS considering post-fire needs and priorities for
other resources and values besides commercial logging?

Are alternatives A and B equally appropriate in fragile post-fire ecosystems (EA II-5)?

The alternatives examined on EA II-11 to 12 are generally more extensive than the two logging alternatives
considered. Why weren't less extensive alternatives considered? The two logging alternatives both involve logging
a large portion of the Timber Creek watershed.

Most, if not all, of the proposed cutting is not located in any areas adjacent to existing roads (Map II-1). See EA

The conditions of the forest just previous to the fires should be considered a point in a process of forest succession
rather than a static condition. Such a dynamic perspective may influence perceptions of “value loss” and “resource
damage” due to wildfire. The environmental analyses should address the potential impacts of the restoration work
in reference to a spectrum of forest conditions, rather than simply the post-fire conditions. Additionally, the
post-fire state of the forest should be assessed in order to account appropriately for elements of the ecosystem that
have been sensitized by fire.

We request that you thoroughly analyze the impacts of recent wildfire suppression activities on the forest. What
restoration activities will be undertaken to mitigate the impacts of fire suppression? For example, we request
thorough discussion and description of created fire lines. What restoration actions will be undertaken to ensure that
these fire lines are not used by ORVs or otherwise perpetuated as a source of forest fragmentation? We believe that
removing the impacts of fire suppression, rather that logging trees, represents the most justified form of restoration

The FS states that a special order was signed by the Forest Supervisor temporarily closing a limited number of
motorized routes in the area (EA 1-2). What evidence is there that these actions alone will be effective? Is
additional motorized route/access route reclamation or watershed restoration work needed at any locations in the
project area or within (or downstream from) the fire perimeter? Could or should any additional actions be
considered by the FS?

We fail to see why (1) the timeliness of logging trees, (2) riparian areas, (3) vegetation & effects, (4) invasive
plants, (5) roads, (6) recreation, (7) cultural/archaeological resources and (8) other issues raised by us in our
previous scoping letter are not considered significant issues as discussed in Appendix A (See EA II-4). Please
explain why these issues should be excluded by consideration as significant issues under NEPA criteria or fully
analyze them in an EA.

What is the relation of the mitigation measures ("features"), BMPs and protection measures in Ch. II and the
Appendices to the implementation of the project?

The EA (Ch. II and appendices) should have explained:
(1) The relative effectiveness of each proposed BMP and mitigation measure in achieving their intended goal(s);

(2) How dependent proposed BMPs and mitigation measures are on outside sources of funding, and the likely environmental
consequences should those funding sources not be realized. Any mitigation costs should be disclosed in the economic
(3) What BMP/mitigation measure failure(s), if any, have led to any needed rehabilitation in the project area from past
     management activities?
(4) How thoroughly past projects have been monitored.
The FS bases can be based on amorphous concepts such as “fact” and “experience,” which may be merely untested assertions.
The EA doesn’t disclose how effectiveness was determined in every case
How will all plan monitoring provisions be accomplished? How will impacts to resources following logging and
access route construction be monitored? How will impacts to soils, watersheds and cultural/archaeological
resources be monitored? How will impacts of recreation and access route use on resources be monitored? Will
grizzly-human encounters only be monitored in the cutting units? Will displacement and disturbance to grizzlies
and other wildlife be monitored in the cutting units or elsewhere (EA Ch. II)?

Forest fires may result in soils experiencing decreased infiltration, increased overland flow, and excess sedimentation
(Beschta et al. 1995). Contentions that ground disturbance associated with post-fire logging has the potential to
disrupt water-repellent layers and thus increase infiltration and reduce overland flow lack scientific support (USDA
2000). Although post-fire logging has some potential for reducing overland flow through the placement of logging
debris, the USDA report concludes that salvage logging will most likely “have no effect or produce more sediment
than that produced by the fire”. The authors cite several studies that find that “post-fire logging associated with road
building, conducted with ground-based log retrieval systems, or undertaken in stands having steep slopes and
sensitive soils likely will have the greatest potential for exacerbating the erosion problems typically observed in
burned watersheds.” The potential for the destabilization of soils associated with logging related ground
disturbance, road construction, and the removal of partially-live trees should be thoroughly reviewed in the planing
process for the Beaver Creek Salvage. The potential for detrimental compaction of the sensitive post-fire soils
caused by mechanical means of removing logs should be also be extensively analyzed.

The NEPA document must assess current soil conditions in order to show compliance with the objectives mandated
by Regional Policy:
        Design and implement management practices that maintain or improve soil quality. Protection of the soil
        resource should be emphasized; restoration practices should be implemented where necessary. Soil quality
        is maintained when erosion, compaction, displacement, rutting, burning, and loss of organic matter are
        maintained within defined soil quality standards.

         Design new activities that do not create detrimental soil conditions on more than 15 percent of an activity
         area. In areas where less than 15 percent detrimental soil conditions exist from prior activities, the
         cumulative detrimental effect of the current activity following project implementation and restoration must
         not exceed 15 percent. In areas where more than 15 percent detrimental soil conditions exist from prior
         activities, the cumulative detrimental effects from project implementation and restoration should not exceed
         the conditions prior to the planned activity and should move toward a net improvement in soil quality.

The USDA report (2000) finds that the removal of dead trees associated with post-fire logging has the potential for
significantly changing wildlife habitat both structurally, though removing existing and future snags and large woody
material, and functionally, by means such as reducing populations of insect prey. For example, four recent
individual studies found that post-fire logging reduced the abundance and nest density of cavity-nesting birds (USDA
2000). The impacts of the proposed restoration work on wildlife habitat should be thoroughly considered.

We are concerned that the salvage area is in the vicinity of the Cabin Creek Wildlife Management Area. The impact
of the proposed project on the wildlife in the management area should be thoroughly analyzed. We are also
concerned with the proximity of the project area with the two units of the Lee Metcalf Wilderness. See also Map
I-1. The NEPA analysis should include a thorough analysis of the impacts of the proposed project to the
functionality of the area as a wildlife corridor between the Greater Yellowstone Ecosystems and the four other core
ecosystems of the Northern Rockies. The GNF represents the initiation of the wildlife corridor that allows wildlife
to disperse out of and enter into the Greater Yellowstone Ecosystem. A recent court ruling, Marble Mountain
Audubon v. Ricey (No. 90-15389, D.C. No. CV89-170-EJG, Sept. 13, 1990) interprets NEPA to require the Forest
Service to consider biological corridors. The standard for such a review is the same “hard look” NEPA requires of
other environmental effects.

We are concerned about possible impacts on threatened and endangered species and other species with small
populations or particular resource and habitat requirements. The populations of these species may be hypersensitive
to disturbance in their sensitive post-fire state. The environmental analyses must thoroughly consider the effects of
restoration activities by evaluating habitat changes and population pressures that may influence threatened,
endangered, and sensitive species.

The EA should consider impacts to all MIS and TES species listed in the plan (GNF II-18&19) and R-1 and
USF&W lists. The FS should conduct population monitoring and population trend monitoring for all MIS and TES
species that could potentially occur in the GNF and project area. Thorough surveys using qualified persons at times
of the year and/or times of the day when species and species habitat are likely to be detected should be conducted
(EA Wildlife, Fisheries, and TES Plant Sections) The FS should determine if any MIS or TES species (or habitat)
exists in or around the project area. The FS should recognize that some species may be present in the project area
but may not be detected in surveys due to the secretive nature of the species, or for other reasons. Adequate habitat
to maintain the viability of all MIS and TES species should be provided. It is not clear that these were done.

What is the basis for determining that flammulated owls, western-big eared bats, harlequin ducks, and northern
leopard frogs have no suitable habitat in the project area and that these species should be dropped from further
evaluation (EA III-5&6)? Do any forest types that are suitable for the flammulated owl exist in the area? What is
the basis for the statement that western big-eared bats are not "primary tree users"? Do western big-eared bats use
trees and could they be impacted by the project? Does any habitat for the northern leopard frog or other
aquatic/riaprian species occur in the project area?

We are particularly concerned with project impacts to grizzly bears and lynx. One of the GNF objectives is to
“manage all ‘situation 1’acreage on the Gallatin with grizzly bear as the primary emphasis” (G-6). The
Management Goals for MA 15 are as follows:
1. Meet grizzly bear mortality reduction goals as established by the Interagency Grizzly Bear Committee.
2. Manage vegetation to provide habitat necessary to recover the grizzly bear.
3. Provide forage for livestock consistent with goal 1.
4. Provide dispersed recreation opportunities consistent with goal 1. (GNF Forest Plan III-48).
Ensuring grizzly bear viability is the foremost management goal of the area. A desire to salvage log should not
detriment this goal, particularly as MA 15 is classified as being unsuitable for timber production. Grizzly bear
population viability, both within the GNF and throughout the entire Northern Rockies should be assessed. We
understand the entire project area is in management situation 1(EA III-27). See other plan provisions.

Recently, a study of grizzly spatial needs has found that a viable population of grizzlies in the Northern Rockies
requires 147,883 km2 – 184, 919 km2 of habitat. These spatial requirements far exceed those provided for by the
USFWS recovery strategy for grizzly bears (Bader 2000b). Hence, until truly large areas are protected, the viability
of grizzly bear populations cannot be assured. See also Bader 2000a.

Population viability analysis has suggested that the core ecosystems of the Northern Rockies are not sufficiently
large to support viable populations of many wildlife species, including grizzly bears. Thus, the presence of wildlife
movement corridors is essential for the long term population viability of Grizzly Bears, and the many other species
for which their strict habitat requirements serve as an umbrella. Because grizzlies require large areas of relatively
undisturbed habitat, solving for the habitat requirements of grizzlies can assist in defining large core protected areas
and a corridor network for the maintenance of ecological integrity in the Northern Rockies.

What population viability analysis has been conducted by the USF&WS or FS regarding the grizzly bears in the
project area or greater Yellowstone ecosystem? What effect do the project (and other events/activities) have on
grizzly viability? According to the Grizzly Bear recovery plan, roads pose "the most imminent threat to grizzly
habitat today." Are road/access route densities in the area adequate relevant to the Grizzly Bear recovery plan? To
what degree do roads, access routes, off-road use, activities similar to those contemplated in this EA, and other
human activities impact the grizzly and grizzly mortality. See EA III-29&30 and Bader 2000a re. Grizzly bear
mortality/encounters. There seems to have been a large number of grizzly bear mortalities/encounters in the area.

We are concerned that the EA does not adequately analyze these factors. The FS should consider substantive
actions to limit the negative impacts associated with these factors as part of this project.

Recent court cases addressed the inadequacy of the grizzly bear recovery plan with respect to: habitat loss, disease,
threats from grizzly/livestock conflict, inadequacy of existing regulatory mechanisms, and genetic isolation (Predator
Conservation Alliance case, 1995). How does the existing recovery plan and GNF address these issues?

On EA III-26, the wording of paragraph 4 is unclear. How much of the FS roads and trails are associated with
private access? Are road densities at harmful levels? Are all motorized routes factored in? Have on the ground
surveys been conducted?

What portions of the project area are within secure areas and what portions are outside of them (EA III-26).

How did the FS determine the hiding cover, thermal cover and denning habitat levels subsequent to the fire (EA III
27-28)? We are concerned that existing conditions do not provide adequate amounts of one or more of these
components (EA III-34). Are enough of these and all other habitat components being provided for the grizzly?
How is it that removing 90% of the trees across 70 acres in a situation 1 area would not reduce habitat components
for the grizzly?

We note that the fire eliminated many grizzly food resources in the area (EA III-31). Does this mean that bears will
be traveling more? What new risks of human-bear encounters are there? What should be done about them?

How does the project meet the grizzly bear standards and objectives in GNF Plan Appx G-6 to 20? Has the FS
monitored the Appx G standards for similar projects in the greater Yellowstone ecosystem? Are these standards
being successfully carried out? What problems have occurred and how are they being addressed?

The GNF must thoroughly analyze lynx population viability and map habitat connectivity and core areas in order to
comply with the lynx conservation assessment and strategy (LCAS). The LCAS mandates that the following
standard be implemented when analyzing projects with the potential to impact lynx habitat:
          Within each LAU, map lynx habitat. Identify potential denning habitat and foraging habitat
          (primarily snowshoe hare habitat, but also habitat for important alternate prey such as red
          squirrels), and topographic features that may be important for lynx movement (major ridge
          systems, prominent saddles, and riparian corridors). Also identify non-forest vegetation
          (meadows, shrub-grassland communities, etc.) adjacent to and intermixed with forested lynx
          habitat that may provide habitat for alternate lynx prey species (LCAS 79).
The LCAS further mandates that projects “maintain habitat connectivity within and between LAUs” (LCAS 79). The
lynx analysis must map movement corridors between lynx habitat within each LAU as well as between LAUs.
Additionally, it is essential that consideration of landscape connectivity be coupled with consideration of
“topographic features that may be important for lynx movement (major ridge systems, prominent saddles, and
riparian corridors)” (LCAS 79). The NEPA analysis fails to address topographic features as they relate to lynx
movement corridors. Consideration of topographic features is essential to evaluating the matrix, the permeability of
the area surrounding lynx habitat to movement by lynx. The maps must also delineate “non-forest vegetation
(meadows, shrub-grassland communities, etc.) adjacent to and intermixed with forested lynx habitat that may provide
habitat for alternate lynx prey species” (LCAS 79).

How did the FS determine the foraging habitat and denning habitat levels subsequent to the fire (EA III 43)? Are
enough of these and all other habitat components being provided for the lynx? We note that denning habitat is
barely above the required level (LCAS 79) and may in fact be below it.

The FS reports that recreational motorized vehicle use (including snowmobile use) is occurring in the project area
(EA III-46). High use snowmobile trail and road areas exist (EA III-58). What are the impacts to the lynx?

Have snow compacting activities been mapped and monitored? Road densities? Linkage areas and highway
crossings? Refugia and potential refugia? (See LCAS)

Proper identification of suitable habitat for goshawks and monitoring should take place. What goshawk nests and
foraging areas exist in the area (EA III 50-52)?

We are concerned that the project area may not provide adequate thermal cover, hiding cover, specialized habitat
and other habitat components for the elk, especially when the post-fire conditions of the project area and motorized
use are factored in.

Habitat effectiveness for elk would drop dramatically under the logging alternatives and will drop even more if
motorized trails, not just roads, are considered (EA III-66).

All specialized habitats/features may not been identified, since aerial reconnaissance was the primary means of
identifying them (EA III 64).

Do elk always move back into an area two days after logging (EA III-65)?

What are the impacts to the Shiras moose and other big game found in the project area?

The FS should have considered the findings of the Montana Cooperative Elk-Logging Study (see GNF Plan II-17)
more fully in this EA.

What migratory birds would be directly or indirectly impacted by the project? How would MIS, TES and other rare
birds and species of concern be impacted by the project (EA-Wildlife)?

The influence of restoration work on post-fire regeneration and succession must be thoroughly addressed. We are
concerned that grass seeding and reforestation measures may prevent natural post-fire successional patterns that are
essential to the post-fire regeneration of the forest. Seeding and reforestation may alter habitat composition and
alter competition, which could result in a favoring of non-native species. As the USDA (2000) notes “Salvage
logging may decrease plant regeneration, by mechanical damage and change in microclimate”. Seeding and
reforestation aspects of the proposed projects must be carefully detailed in the environmental analyses and should be
discussed in reference to the potential natural forest post-fire regeneration. Potential impacts of logging related
disturbance on natural regeneration must be thoroughly analyzed.

The post-fire forest is extremely susceptible to the invasion of non-native plants, as many exhibit opportunistic
growth characteristics that would allow native species seedling to be outcompeted. Ground disruption and tree
removal associated with logging will further increase the forest’s susceptibility to invasive plants. Alteration of seed
sources associated with forest disruption may significantly alter forest succession patterns. Threats from non-native
species associated with restoration work must be thoroughly discussed and invasion preventing measures must be

To what degree will mitigation measures effectively reduce the introduction and spread of invasive plants? How
will the FS control the introduction and spread of invasive plants after logging and other activities have been
completed (EA Ch. II)?

We request a careful analysis of the impacts to fisheries and water quality, including considerations of sedimentation,
increases in peak flow, channel stability, risk of rain-on-snow events, and increases in stream water temperature.
The cumulative effects analysis should address the condition of the streams in relation to all past management
activities as well as considering the present proposal. Please disclose the locations of seeps, springs, bogs and other
sensitive wet areas, and the effects on these areas of the project activities.

Have all MA 7 areas been identified and protected according to GNF Plan requirements (EA III-2; EA II-6;
EA-Water Quality)

As detailed above, post-fire forests are extremely susceptible to erosion. While roads have extremely detrimental
impacts on unburned forests (through changing water flow patterns, increasing erosion, and influencing wildlife
habitat and migration), their impacts are greatly intensified on burned landscapes. We request thorough description
and mapping of any roads that will need to be built or maintained as part of the salvage project. The impacts on soil
health of any road building must be carefully investigated. The current road density and conditions of existing
roads should be thoroughly discussed. The option of obliterating roads should be considered as an alternative to
road maintenance. The anticipated future maintenance costs of any new or maintained roads should be accounted

What is the potential for sedimentation, landslides and other soil and watershed problems? The EA's discussion of
water quality, fisheries and soils are not consistent with each other.

To what extent can Beaver Creek's high sediment levels be attributed to man-caused sources (EA III-11)? What

Sediment-producing streams often create long-term effects, especially with respect to lower reaches of stream

There has already been a large amount of sediment generated from the fire (EA III-13) (and possibly from roads
and other structures downstream from the fire perimeter). Sediment generated from the proposed logging will
exceed that from the fire itself in the last two or three years of the project, depending on which logging alternative
were to be chosen (EA III-13). The EA does not properly address the long-term additive effects of sedimentation
and, in fact, adds new impacts to stream systems. Why is logging and roadbuilding appropriate here when the
watershed is expected to exceed standards

Why do the charts on EA III-13&14 show that percent of sediment over natural levels for the last year would be
higher for the no logging alternative (with reforestation) than the two logging alternatives (with reforestation)?
The chart on EA III-20 has missing headings. What does the chart purport to show? What are the criteria for the
Four Classes? Is the FS categorization accurate and based on sound inventories? What will be the impact of the
project on streams in the four TU Amendment categories?

How accurate are the models used in the EA? What assumptions were made? What is the margin of error (EA
III-21)? Is there a potential for S&Gs or other requirements to be exceeded?

How did the FS determine that there is little or no potential for genetically pure westslope cutthroat trout or Arctic
grayling in project area streams or downstream (EA-Fisheries)? What are the impacts of the project on hybridized
trout? Wild trout? What are the cumulative effects of all past, present and reasonably foreseeable events/activities
on fish and aquatic species (EA III-23)?

What roads, trails, skid trails, and other access routes could potentially used as motorized access routes in the project
area during or after the logging is completed? How do mitigation measures address soil, watershed, water quality,
aquatic species, wildlife, cultural/archaeological and vegetation related concerns along (and downstream from) these
access routes (Ch. II and Appendices)? Are these resources adequately protected? Will closures be effective?
How widely would skid trails and other logging infrastructure be spaced as a minimum? What is your basis for
concluding that logging in areas with a snow cover of 8 inches or frozen ground to a depth of 4 inches would have a
negligible effect on soils and vegetation? Other national forests in Region One define winter conditions as 24
inches of snow cover or 4 inches of frozen ground, and even these measures may be inadequate in some instances.
Why is use of skid trails and ground based logging appropriate at all here?

We are concerned about the impacts of roads, access routes, other ongoing activities and other aspects of the project,
particularly with respect to the viability of wide-ranging mammals such as wolves, grizzlies, wolverines, and martens.

The FS states that no logging will occur in inventoried roadless areas (EA III-8). Do any uninventoried roadless areas exist
in the project area? What impacts to uninventoried or inventoried roadless areas will occur? Will any irreversible or
irretrievable impacts to undeveloped or roadless areas occur?

It is imperative that the GNF realize that old growth habitat is critical to the survival of numerous species, including the boreal
owl, black-backed woodpecker, and flammulated owl. No logging should occur in old growth areas in connection with this
or any other project.

In the identification process for old-growth habitat, the analysis team should perform on-the-ground verification of areas
chosen from photo-interpretation and database examination. This is especially important in identifying areas appropriate for
old-growth designation. This verification should assess how much old growth exists in the compartments surrounding the
analysis area, and what amount of old growth would be cut in each alternative. The environmental analysis should describe
the precise criteria used to designate old growth on the forest, including who made the decisions regarding old-growth

designations, and that person’s qualifications. Old growth and mature forest components should be protected in accordance
with the plan.

Given that natural succession in old-growth tends to eliminate current old-growth stands, how will harvest of mature,
non-old-growth stands as well as old-growth stands effect the future percentage of old-growth within the overall landscape?
We are totally opposed to any reduction of the amount of old growth in the project areas, given the small percentage of
remaining public land old-growth habitat and its importance to sensitive wildlife species. The analysis should accurately
describe the sizes of old-growth stands in the areas (through use of maps and tables) and assess whether they are of sufficient
size to provide secure habitat for old-growth dependent species, including interior old-growth dependent species such as the
pine marten and goshawks.

The size, species, and distribution of trees that will be logged should be thoroughly analyzed. The EA must disclose whether
any live trees will be logged. It is also imperative that the EA discuss how dead would will be delineated and who will
implement the delineation. The size and number of trees remaining in the units after the proposed harvest should be
disclosed. Levels of snag retention must be delineated.

In their publication, “Trees and Logs Important to Wildlife in the Interior Columbia River Basin,” Bull, et al. (1997)
       This document presents new information on the retention and selection of trees and logs most
       valuable to wildlife.

      …Current direction for providing wildlife habitat on public forest lands does not reflect this new
      information. Since the publication of Thomas and others (1979), new research suggests that to
      fully meet the needs of wildlife, additional snags and habitat are required for foraging, denning,
      nesting, and roosting. Although we do not suggest specific numbers or snags to retain by forest
      type, two recent studies indicate that viable woodpecker populations occurred in areas with
      about four snags per acre.

      We suggest that the next step in snag management should involve creating a model that
      incorporates the new information on woodpecker foraging substrates (live trees, snags, and
      logs), home range sizes, number and characteristics of roost trees, multiple occupancy of snags,
      and needs for other habitat structures. Once this information is incorporated, the model may
      suggest changes to guidelines that specify numbers of snags and other habitat features by forest
      type and geographic area. Additional information on fall rates of snags, foraging needs of
      black-backed and three-toed woodpeckers, relation of the density of woodpeckers to that of
      secondary cavity nesters, and relation of snag density to woodpecker density would greatly
      improve the model.

There is a similar lack of scientifically sound management guidance in the GNF. The GNF should demonstrate that its snag
retention measures are adequate to protect woodpeckers, raptors, other birds, bats, and other snag dependent species.

We request that you document how your decisions and the selected alternatives maximize net public benefit. In
other words, you should give consideration to, and adequately document, who benefits by these projects and who
pays for them. Numerous inputs and outputs, some of which are quantifiable and others which are more qualitative
determine net public benefit. Economic analysis can provide a useful basis for evaluation only if the economic
evaluation is comprehensive and documents all costs and benefits related to the proposed action.

Economic Analysis should be conducted within a timeframe appropriate to the resources being managed. Short-term
earnings from salvage timber sales should be appropriately discounted in relation to the longer-term ecological values of the
forest. For example, the long-term cost of maintaining existing and building new roads must be considered.

Economic feasibility should not be the prime consideration of this sale; the FS must maintain all applicable standards
for soil, watershed, wildlife and other resource protection (EA Economics).

A transportation analysis & roads analysis should have been conducted to assure the decisionmaker and public that
wildlife security, soil protection and watershed protection needs are being met (EA Appx A).

What M&E monitoring activities have been conducted for MA 15 and MA 7 areas in the project area and GNF?
What was disclosed by monitoring and what action should FS take as a result of monitoring?

What impacts will the project have the recreational opportunity spectrum designations of the area (EA Appx A). On
non-motorized recreation? Economics of recreation, hunting and fishing?

We request that cumulative effects be a major focus of your analysis. Please disclose the significance of the impacts
from past activities, including those on nearby state, federal, and private land. Please include in the effects analysis
any and all reasonably foreseeable management activities in the general area. We are particularly concerned with
the cumulative impacts of grazing and logging activities.

Please take a good look at the fragmentation of wildlife habitat that continues to accumulate in western Montana and
the northern Rocky Mountains. That is, take your cumulative effects analysis to the regional level. Please provide
maps and other documentation on past harvest activities, including such information as year, regeneration success
level, and cover level for each activity in the area.

We are extremely concerned with the GNF’s apparent attempt to use wildfire, a natural forest process, as rationale to
implement a logging program. As the forests have evolved with fire, we feel that we must be extremely cautious
with interfering with post fire regeneration.

Thank you for considering our comments.


                           Sherman Bamford
                           The Ecology Center
Literature Cited

Bader M. 2000a. Wilderness-Based Ecosystem Protection in the Northern Rocky Mountains of the United States,
USDA FS Proceedings RMRS-P-15-Vol-2: 99-110.

Bader M. 2000b. Spatial needs of grizzly bears in the US Northern Rockies. Society for Conservation Biology
2000 Meeting, Missoula, MT.

Beschta, RL; Frissell, CA; Gresswell, R; Hauer, R; Karr, JR; Minshall, GW; Perry, DA; Rhodes, JJ. 1995.
Wildfire and salvage logging: recommendations for ecologically sound post-fire salvage logging and other post-fire
treatments on Federal lands in the West. Corvallis, OR: Oregon State University.

Everett, R. 1995. Letter dated August 16 to John Lowe. Review of Beschta document. On file with: U.S.
Department of Agriculture, Forest Service, Pacific Northwest Research Station, 1133 N. Western Ave., Wenatchee,
WA 98801.

U.S. Department of Agriculture, Forest Service. 2000. Environmental Effects of Postfire Logging: Literature
Review and Annotated Bibliography. Gen. Tech. Rep. PNW-GTR-486. Wenatchee, WA: U.S. Department of
Agriculture, Forest Service, Pacific Northwest Research Station.


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