Darcy Pederson, Ranger by q2ENdC71

VIEWS: 2 PAGES: 12

									June 18, 2001

Darcy Pederson, Ranger
Clearwater Ranger District
Rt2, Box 465
Grangeville, ID 83530

Dear Ranger,

The Lands Council, National Forest Protection Alliance, and Forest Conservation
Council are responding to the Draft EIS for the Meadow Face Stewardship Pilot Project.
The Lands Council is submitting these as additional comments to those submitted by
Friends of the Clearwater. This timber sale would log 3915 acres, build 12.8 miles of
road, reconstruct 14.5 miles and extract 22.5 million board feet. As U.S. citizens, the
members of our groups, as well as the American public, are equal stakeholders in this
part of the Nez Perce National Forest. While we understand that a few local parties have
gotten together to discuss resource extraction from this area, we feel it is inappropriate
for the Stewards of the Nez Perce National Forest (SNP) to speak for anyone but
themselves. National Forests are owned by all U.S. citizens. We hope that our comments
will assist with the recovery of the Meadowface area, which has been severely degraded
by logging, road building and grazing.


Purpose and Need too Narrowly Defined:

We have serious concerns about the narrow purpose and need for this project. We
consider the damage that is likely to occur with all action alternatives, and the elimination
of a restoration alternative that would not log, spray herbicides or build roads to be a
serious oversight. We are concerned that the Forest analyzed a project area that has too
many roads, stream bank and water resource damage from past logging and road
building, noxious weeds from logging and importing weed sources – and only created
alternatives that build more roads, remove more trees, expose more soils, and spray the
area with herbicides.
The quick dismissal of an alternative that would not create further damage, and the lack
of understanding of what a no logging, no road building, no spray restoration alternative
could do is proof that this project is narrowly construed, arbitrary and capricious. On
page 2-4 the Forest fails to capture what The Lands Council and others have asked for in
restoration. By mis-representing our request, and narrowly defining the purpose and
need, the Forest is violating NEPA in the context of public participation and range of
alternatives. A key part of any restoration project is returning fire to the landscape.

Since the Forest Service has failed to include the opinions of those commenters who
would like to see such an alternative, as well as the two thirds opinion of the American
public who do not want their forests commercially logged, we believe the NEPA
requirements to consider reasonable alternatives has been violated.

We find the DEIS fails to disclose the impacts on the following:

      Disrupting successional forest vegetation cycles by clearcutting and thinning.
      Fire dependent species – what is the impact from fire suppression, logging and
       continued fire suppression? We notice one paragraph on 3-131, which states
       generic impacts but does not look at site specific impacts, or species specific
       impacts (the exception being it mentions the black-backed woodpecker is fire
       dependent, but says nothing about population viability or any other species).
      The role of livestock in disrupting successional cycles and change of transitory
       range is not analyzed in the Meadowface DEIS


We are very concerned about the narrow and incomplete historic range of variability
(HRV) analysis. We find there is no analysis of the historic range of variability of the
following:

Elk, soil disturbance, roads, cattle, logging units, slash piles, clearcuts, noxious weeds,
fire dependent species, wolverine, wolf, lynx

Old Growth: The DEIS has re-evaluated the MA20 old growth and now finds the area has
2850 acres of MA20 (old growth), rather than 1735 acres. We question this new finding
and find the validation process is suspect. Even so, it appears as though Alternative 2
will drop the old growth below Forest Plan requirements.

The plan to clearcut high elevation stands, VRU 7 and 10, to reduce old growth to
seedling stages (FEIS at 1-12) is unacceptable. First, the area is not outside the range of
variability by any accounting. Second, to speculate that some of the area might have
burned, even though the fire frequency is 150-300 years, and that the “cure” is to clearcut
is unscientific at best. Third, the map clearly shows numerous clearcuts in this area, we
find it difficult to believe the area is lacking in areas with saplings and young forest.
While it is conceivable some acres might have missed a fire, we know for a fact that
clearcutting was never part of the forest process.
Does logging old growth really meet the purpose and need of restoration? We oppose the
amendment to allow logging in old growth in the VRU 3 – and believe this is a
significant violation of the Forest plan that has not been adequately analyzed. Here is an
area where fire could be returned, without logging, but was not considered in the narrow
range of alternatives. Why not expand the prescribed fire program that is described on 3-
72? A comparative analysis that addresses the cost of prescribed fire alone (which could
involve two or three stages), compared with logging, road building and slash treatment is
not analyzed.

The loss of natural fire intervals, suppression of natural insect cycles from logging and
fire suppression does need to be addressed.

Photos and text from the John Leiberg, 1898 USGS Bitterroot Forest Survey indicate this
area may not be abnormally dense, as the DEIS suggests. The Meadowface project area,
which is at the extreme west edge of the old Bitterroot Forest Reserve, is part of the
Clearwater Basin that Leiberg studied over a hundred years ago. His discussion,
particularly the parts about forest succession on pages 361-364, indicate that this area
underwent great variations in stand composition and fire frequency, and that climate and
moisture shaped this area far more than 60 years of fire suppression has.

The implication is that the Forest Service is focused on a narrow snapshot in time and
attempting to manage on that basis, while it is likely that successional processes are far
more influential. We have included some of this discussion from the Leiberg report at
the end of our comments. The point is that the range of alternatives seems to have no
connection to the historical cycles of the project area. Instead, the project seems driven
by an urge to create a timber sale and manage fuel loads, far from private residences.

We should also note that the blind review of the Wenatchee Dry Site strategy (Hessburg
and Lemkuhl 1999) found that using prescribed fire alone could restore dry site areas
such as the Meadow Face. We believe this would be more economical, restore soil and
vegetation, and create less impact to the landscape.

The charts on page 1-10 show that VRU 3 stands; warm and cool aspects, have a zero
historic incidence of 3 layer stands. Where is the evidence to support this point of view?

An emphasis of this project seems to be on creating single story LOS stands. This
implies that the District knows how the forest should be and how it can be managed to be
that way. What site-specific evidence is there that this area is outside the historic range of
variability? We think fire ring analysis is one piece of information that can be used to
estimate stand density but what about the trees that grew and burned repeatedly?

Even is one were to assume that the area had or needs a higher proportion of single story
LOS stands, what basis is there that logging and extensive crown and stem removal will
accomplish this goal? The historical record suggests that logging never created this type
of structure, fire and insects/pathogens did. We cannot conceive of a natural event that
would remove entire trees from a site, as logging does, except volcanic explosions and
avalanches. Please provide evidence that your action alternative will actually result in
long-term progress to single stage LOS.

Hydrology: The NEZSED model shows increases in sediment with every action
alternative. Alternative 2 would allow logging in riparian area RHCA’s as well as
landslide prone RHCA’s and therefore appears to be an illegal alternative. It is unclear to
the reviewer how the degraded condition of fish habitat (DEIS at 3-49) will be improved
by road construction and riparian logging – especially when the model shows increased
sediment spikes for every action alternative for at least five years. The actions that would
reduce sediment could be done without the logging and road building, but this alternative
was never even considered. This is particularly problematic since bull trout; steelhead
and possibly Chinook salmon inhabit the South Fork Clearwater.

Forest Processes: The Forest should take into account the positive and historical roles in
which parasites and other forest pathogens play in the forest to wildlife, fungi, and other
wildlife which depend upon pathogens – but this is not apparent in the EA, which focuses
on the narrow objective to achieve late-old structure. Positive attributes of inherent fungi,
insects, bacteria, birds, and myriad of forest parts other than wood are ignored. The
resilient or self-healing nature of forest ecosystem likewise is disregarded.” Please
include in the final Meadow Face EA the positive/beneficial attributes of pathogens in the
forest to wildlife, genetic biodiversity, and other aspects of the forest.

Over two years ago commenters asked that “In your range of alternatives that you
develop, please include a no-logging, restoration-based alternative.” This alternative
would include road obliteration, reintroduction of fire, road decommissioning, and other
activities, which do not include industrial logging. This is not intended to be an academic
exercise; it is a reasonable alternative that is supported by the majority of U.S. citizens
(polling shows two-thirds of Americans want to end the timber sale program). By
narrowly construing the purpose to include a timber sale, a range of economically viable
restoration alternatives has been eliminated.

The project comes at a time when the focus is on wildfire and protecting humans and
their property. We have the following questions concerning the relationship of the
Meadow Face project to the National Fire Plan:

   1.      Is any National Fire Plan money being used for this project?
   2.      How will this project affect the wildland-urban interface?
   3.      How many slash piles are there currently in the Meadow Face analysis area”
   4.      How many slash piles will exist, by alternative, after the project area is
           logged? How many after 5 years post logging?
   5.      What type of fuels in tons per acre, on a unit-by-unit basis (fine fuels, down
           woody debris, dead and standing, green, etc.)?
   6.      What will be the “fuel per acre” after logging, by alternative?

The soil discussion does not say if any proposed units are currently above that standard –
what is the site specific, unit-by-unit compaction and detrimental soil conditions? Soils
and the effectiveness of restoring soils are mentioned in Appendix D; but the
effectiveness of soil mitigation and the impacts, by alternatives, within logging units are
not disclosed. Subsoiling does not work in many types of soils, such as those with rocks,
extensive roots, etc. What is the effectiveness and likelihood to succeed of the proposed
soil mitigation?

Logging Impacts: How many landings are there in RHCA’s currently, what is their size
and location, and how much will they be enlarged. How many new or reconstructed
landings will there be in the project area, by alternative?

Cultural resources: The cultural resource section is lacking and does not meet Forest Plan
standards. It is not possible to analyze the impacts, by alternatives, by saying cultural
resources will be addressed, as the units are layed out (DEIS at 2-22). The sites in the
area were said to be found during previous timber sales and other projects. Since some of
the proposed units are in old growth, it seems likely that these areas were missed in
previous surveys. Will a trained, professional archaeologist be on site to analyze this
proposal before the Decision is made? If the surveys are made after the Decision, roads
and some logging could occur near sites, precluding the protection of those sites. Cultural
burning is not analyzed. We consider this project to be lacking with regards to analysis of
cultural resource impacts.


Economic Analysis is Lacking and Fails to Disclose the Economic Impacts

The Lands Council, Forest Conservation Council and the National Forest Protection
Alliance are tax-exempt, public interest organizations with individual and business
members throughout the United States. We are concerned with the adverse economic
effects of the national forest logging program, and the Forest Service’s failure to quantify
such effects at the project level or for the program as a whole. The logging program
increases costs of water purification and filtration, decreases the value of private
timberlands, unfairly competes against alternative fiber and building material businesses,
increases wildfire risk, increases repair and maintenance costs for highways and public
roads, and decreases the number of jobs in recreation, tourism, fisheries, and alternative
forest products. The Meadow Face sale will jeopardize the viability of species that thrive
in standing or naturally disturbed forests, intervene in natural disturbance processes that
are vital to ecosystem sustainability, and degrade water quality and watershed condition.

The Nez Perce National Forest Timber Sale Program must be suspended until the Nez
Perce National Forest LRMP is amended or revised in a manner that maximizes net
public benefits. These changes are required by the Multiple-Use Sustained Yield Act
(“MUSY”), the Forest and Rangeland Renewable Resources Planning Act of 1974
("RPA"), the National Environmental Policy Act (“NEPA”), the Administrative
Procedure Act (“APA”), the National Forest Management Act (“NFMA”), the Global
Climate Change Prevention Act (“GCCPA”), as well as the Forest Service Handbook and
Manual implementing these regulations and rules.
That the National Forest Timber Sale Program in its entirety be suspended until the RPA
Program is revised to (a) incorporate information about all of the natural resource
benefits associated with unlogged forests; (b) incorporate information about all of the
direct, indirect, and cumulative socio-economic costs of the timber sale program, and; (3)
maximize net public benefits. These changes are required by the Multiple-Use Sustained
Yield Act (“MUSY”), the Forest and Rangeland Renewable Resources Planning Act of
1974 ("RPA"), the National Environmental Policy Act (“NEPA”), the Administrative
Procedure Act (“APA”), the National Forest Management Act (“NFMA”), the Global
Climate Change Prevention Act (“GCCPA”), as well as the Forest Service Handbook and
Manual implementing these regulations and rules.

National Forests generate vast economic benefits simply by existing as natural
ecosystems. When National Forests are logged, these benefits are lost, resulting in
externalized costs to communities, businesses, and individuals that derive economic
benefits from unlogged forests. By law, the United States Forest Service (“Forest
Service”) must fully account for all benefits and all costs of natural resource management
decisions and make those decisions in a manner that maximizes net public benefits.
These requirements appear frequently in the Multiple-Use Sustained Yield Act
(“MUSY”), the Forest and Rangeland Renewable Resources Planning Act of 1974
("RPA"), the National Environmental Policy Act (“NEPA”), the Administrative
Procedure Act (“APA”), the National Forest Management Act (“NFMA”), the Global
Climate Change Prevention Act (“GCCPA”), and Forest Service Regulations and Rules.

The Meadow Face Timber Sale is a Product of Inter-related Planning Decisions at the
National, Forest, and Project Levels. The Forest Service’s analysis of the Meadow Face
Timber Sale is the end result of inter-related planning decisions and analyses made at the
national, forest, and project level. 36 C.F.R. § 219.4. At the national level, the Forest
Service prepares the Renewable Resources Program (RPA), which determines output
levels for all national forest resources based upon a comprehensive environmental and
economic assessment of present and anticipated demands for and supply of renewable
resources from forests in all ownership. At the forest level, the Forest Service has
prepared the Nez Perce National Forest Land and Resource Management Plan (“LRMP”),
which is an “extension” of the RPA Program and which identifies lands that are suitable
for timber sales, the amount of timber to be offered each year, and under what conditions
timber sales will be offered. At the project level, the Forest Service makes decisions
about the specific configuration of individual timber sales, including Meadow Face
Timber Sale. At each level, the Forest Service must engage in environmental and
economic analyses of its decisions as required by the National Environmental Policy Act.

The Forest Service Has Failed to Incorporate All Natural Resource Benefits into
Timber Sale Planning Decisions at the National, Forest, and Site Specific Level.

In making the analyzing the alternatives for the Meadow Face Timber Sale EA as well as
programmatic decisions to adopt the Nez Perce National Forest LRMP and the RPA
Program, the Forest Service failed to incorporate information about the economic value
of unlogged forests. (See Declarations of Ed Whitelaw, Thomas Power, Randal O’Toole,
Karyn Moskowitz, Jeff Debonis, and John Talberth, incorporated here by reference and
on file with the Regional Forester). These include the economic benefits associated with:

   1)  recreational opportunities and tourism;
   2)  commercial and recreational fisheries within the boundaries of the Nez Perce
       National Forest and downstream and offshore;
   3) habitat for important game species and hunting both within and outside of the
       Nez Perce National Forest;
   4) water for cities, industries, businesses, and individual households downstream
       from the Nez Perce National Forest;
   5) the regulation of water flowing through rivers and streams, including flood
       control;
   6) non-timber forest products such as wild mushrooms, herbs, and medicinal
       plants;
   7) mitigation of global climate change through absorption and storage of vast
       amounts of carbon;
   8) enhancing the quality of life of neighboring communities;
   9) harboring biological resources that either have value now or have as yet
       unknown but potentially large economic and social value;
   10) harboring biological and genetic resources that can improve the long-term
       productivity of all forest land;
   11) pest-control services provided by species that prey on agriculture and forest
       pests, and;
   12) pollination services provided by species that pollinate important forest and
       agricultural crops.

These are important economic benefits generated by National Forests in every part of the
nation, including the Nez Perce National Forest. (See Declarations of Robert Costanza,
Rex Cullum, Laura Erickson, Al Espinosa, Larry Evans, Brock Evans, Timothy
McDevitt, Ron Mitchell, Karyn Moskowitz, Jerry Murphy, Ronel Paddock, Thomas
Power, John Talberth, Mary Vogel, Thomas Vuyovich, and Ed Whitelaw, incorporated
here by reference and on file with the Regional Forester). The Forest Service has
extensive literature and sources of data that it can rely upon to quantify the magnitude of
these economic benefits at the national, forest, and project level. (See Declarations of
Robert Costanza, Ed Whitelaw, Thomas Power, John Talberth, and Karyn Moskowitz,
incorporated here by reference and on file with the Regional Forester).

Failure to incorporate information about these benefits into the Meadow Face Timber
Sale decision, the Nez Perce National Forest LRMP, and the RPA violates numerous
statutes, regulations, and rules governing Forest Service management activities described
below.

The Forest Service Must Incorporate Externalized Costs into Timber Sale Planning
Decisions at the National, Forest, and Site Specific Level.
Before making the site-specific decision to implement the Meadow Face Timber Sale as
well as programmatic decisions to adopt the Nez Perce National Forest LRMP and the
RPA Program, the Forest Service must incorporate information about externalized costs
passed on to communities, businesses, and individuals when National Forests are logged.
(See Declarations of Ed Whitelaw, Thomas Power, Randal O’Toole, Karyn Moskowitz,
Jeff Debonis, and John Talberth, incorporated here by reference and on file with the
Regional Forester). These include the direct, indirect, and cumulative economic costs
associated with:

   1)    lost recreational opportunities and decreased tourism;
   2)    degraded commercial and recreational fisheries within the boundaries of the Nez
         Perce National Forest and downstream and offshore;
   3)    degraded habitat for important game species and loss of hunting opportunities
         both within and outside of the Nez Perce National Forest;
   4)    increased pollution of water for cities, industries, businesses, and individual
         households downstream from the Nez Perce National Forest and increased costs
         of water filtration;
   5)    increased flooding and disruption of the normal flows in rivers and streams.
   6)    loss of non-timber forest products such as wild mushrooms, herbs, and
         medicinal plants;
   7)    exacerbation of global warming through release of greenhouse gasses;
   8)    diminished quality of life of neighboring communities;
   9)    loss of biological resources that either have value now or have as yet unknown
         but potentially large economic and social value;
   10)   loss of biological and genetic resources that can improve the long-term
         productivity of all forest land;
   11)   diminished pest-control services provided by species that prey on agriculture
         and forest pests;
   12)   diminished pollination services provided by species that pollinate important
         forest and agricultural crops.
   13)   lost jobs and income associated with timber production on private lands that is
         displaced by Nez Perce National Forest timber sales;
   14)   lost jobs and income associated with the production of alternative and recycled
         products that is displaced by subsidized Nez Perce National Forest timber sales;
   15)   death, injury, and property damage associated with logging on the Nez Perce
         National Forest, and;
   16)   increased risk of wildfires caused by adverse changes in microclimate, increased
         human access, and slash generated by timber sales.

These externalized costs are generated by National Forest logging in every part of the
nation, including the Nez Perce National Forest. (See Declarations of Garrick Beck,
Robert Costanza, Rex Cullum, Laura Erickson, Al Espinosa, Larry Evans, Brock Evans,
Timothy McDevitt, Ron Mitchell, Karyn Moskowitz, Jerry Murphy, Cara Nelson, Ronel
Paddock, Thomas Power, John Talberth, Mary Vogel, Thomas Vuyovich, and Ed
Whitelaw, incorporated here by reference and on file with the Regional Forester). The
Forest Service has extensive literature and sources of data that it can rely upon to
quantify the magnitude of these externalized costs at the national, forest, and project
level. (See Declarations of Robert Costanza, Ed Whitelaw, Thomas Power, John
Talberth, and Karyn Moskowitz, incorporated here by reference and on file with the
Regional Forester).

The Meadow Face analysis must incorporate externalized costs into the Meadow Face
Timber Sale EA, the Nez Perce National Forest LRMP, and the RPA violates numerous
statutes, regulations, and rules governing Forest Service management activities described
below.

Violations of the Multiple Use and Sustained Yield Act “MUSY.”

By failing to incorporate important natural resource benefits and externalized costs into
the Meadow Face Timber Sale EA, the Nez Perce National Forest LRMP, and the RPA,
the Forest Service has violated the Multiple Use and Sustained Yield Act. Without
incorporating natural resource benefits and externalized costs into these decisions, the
Forest Service cannot meet MUSY’s requirements to administer National Forests for all
of their resources, to maximize public benefits, and to give due consideration to the
relative resource values of all National Forest resources. 16 U.S.C. § 528; 529; 531.

Violations of the Forest and Rangeland Renewable Resources Planning Act “RPA,” the
National Forest Management Act “NFMA,” and their Implementing Regulations.

By failing to incorporate natural resource benefits and externalized costs into the
Meadow Face Timber Sale analysis the Nez Perce National Forest LRMP, and the RPA,
the Forest Service has violated the Forest and Rangeland Renewable Resources Planning
Act and the National Forest Management Act. Without incorporating natural resource
benefits and externalized costs into these decisions, the Forest Service cannot meet the
RPA and NFMA’s requirements to secure the maximum benefits of multiple use
sustained yield management, to conduct comprehensive economic assessments of all
National Forest resources, to identify all costs and all benefits associated with RPA
Program outputs, to insure consideration of the economic aspects of renewable resource
management, to improve Forest Service accountability when it prepares annual budgets
and reports to Congress on the costs and benefits of its programs, and to conserve forests
and promote the use of recycled products. 16 U.S.C. § 1600(7); 1601(d)(1); 1600(3);
1602(2); 1604(g)3; 1606(a); 1606(b); 1606(c); 1606(d).

The Forest Service must follow the regulations implementing the RPA and NFPA, which
require that the Forest Service maximize net public benefits, evaluate the relative values
of all National Forest resources, consider all market and non-market costs and all benefits
of management decisions, and assign monetary values to goods and services to the extent
that they can be assigned. 36 C.F.R. § 219.1; 219.4(a)1; 219.4(b)1ii; 219.12; 219.13;
219.14.

Violations of the National Environmental Policy Act and its Implementing Regulations
By failing to incorporate important natural resource benefits and externalized costs into
the Meadow Face Timber Sale analysis, the Nez Perce National Forest LRMP, and the
RPA, the Forest Service has violated the National Environmental Policy Act. Without
incorporating important natural resource benefits and externalized costs into these
decisions, the Forest Service cannot meet NEPA’s requirements to fully disclose the
direct, indirect, and cumulative economic impacts of the timber sale program and to give
appropriate consideration to environmental amenities in decision-making. 42 U.S.C. §
4332 (C); 4332 (B).

By failing to utilize appropriate professional expertise capable of disclosing all natural
resource benefits and externalized costs, the Forest Service is in violation of NEPA’s
mandate to rely upon a systematic and interdisciplinary approach to decision making. 42
U.S.C. § 4332 (A).

The Forest Service must disclose direct, indirect, and cumulative economic impacts,
identification of environmental effects and values in adequate detail so that they can be
compared with economic and technical analyses, rigorous analysis of the benefits of
implementing the “no action” alternative in timber sales, and use of appropriate
professional expertise. 40 C.F.R. § 1501.2(a); 1501.2(b); 1502.6; 1502.16; 1502.24;
1507.2(a); 1507.2(b); 1508.7; 1508.8; 1508.27.

The Forest Service must follow its Environmental Policy and Procedures Handbook,
which reiterate requirements set forth in NEPA and the CEQ Regulations implementing
NEPA. FSH 1909.15. These requirements also appear in the Forest Service Manual.
FSM 1950.

Violations of the Administrative Procedures Act

The Forest Service must incorporate important natural resource benefits and externalized
costs into the Meadow Face Timber Sale analysis, the Nez Perce National Forest LRMP,
and the RPA, the Forest Service has violated the Administrative Procedures Act. Sources
of information and methodologies for quantifying these benefits and costs are readily
available and used by the Forest Service and other federal agencies outside the context of
the timber sale program. In light of this, the decision to ignore these benefits and costs
violates the APA’s prohibitions on making decisions that are arbitrary, capricious, and
unreasonable. 5 U.S.C. § 706.

Violations of the Forest Service’s Economic and Social Analysis Handbook.

By failing to incorporate important natural resource benefits and externalized costs into
the Meadow Face Timber Sale analysis, the Nez Perce National Forest LRMP, and the
RPA, the Forest Service has violated provisions of its Economic and Social Analysis
Handbook requiring that the Forest Service maximize net public benefits and fully
account for all market and non-market benefits and costs in the context of market studies,
economic efficiency analysis, and economic impact assessments of its plans and
programs. FSH 1909.17.11.1; 1909.17.14.1; 1909.17.14.11; 1909.17.14.6; 1909.17.23.
Violations of the Forest Service’s Timber Sale Preparation Handbook.

By failing to incorporate important natural resource benefits and externalized costs into
the Meadow Face Timber Sale analysis, the Nez Perce National Forest LRMP, and the
RPA, the Forest Service has violated provisions of its Timber Sale Preparation Handbook
requiring that all marketed and non-marketed costs and benefits be addressed in analyses
of the financial and economic efficiency of individual timber sales and the timber sale
program, as a whole. FSH 2409.18.13.1; 2409.18.32.

Violations of the Forest Service Manual.

By failing to incorporate important natural resource benefits and externalized costs into
the Meadow Face Timber Sale analysis, the Nez Perce National Forest LRMP, and the
RPA, the Forest Service has violated numerous provisions of the Forest Service Manual.
These include provisions that require the Forest Service to manage the timber sale
program so that total benefits exceed total costs, to account for non-timber economic
effects in its timber sale analyses, to ensure that economic values used in economic
efficiency and economic impact assessments adequately reflect biological, economic, and
social conditions, and that economic and social impacts and costs and benefits inform all
decisions. FSM 2403.4; 2403.5; 1971.5; 1970.1(1), (2), (3); 1970.2; 1970.3(1), (5).

USFS Timber Sales are the end result of inter-related planning decisions and analyses
made at the national, forest, and project level. 36 C.F.R. § 219.4. At the national level,
the Forest Service prepares the Renewable Resources Program (RPA), which determines
output levels for all national forest resources based upon a comprehensive environmental
and economic assessment of present and anticipated demands for and supply of
renewable resources from forests in all ownership. At the forest level, the Forest Service
has prepared the Nez Perce National Forest Land and Resource Management Plan
(“LRMP”), which is an “extension” of the RPA Program and which identifies lands that
are suitable for timber sales, the amount of timber to be offered each year, and under
what conditions timber sales will be offered. At the project level, the Forest Service
makes decisions about the specific configuration of individual timber sales, including
Meadow Face sale. At each level, the Forest Service must engage in environmental and
economic analyses of its decisions as required by the National Environmental Policy Act.

The Forest Service is required by law to manage national forest system lands and
programs to maximize social and economic benefits for the American people. As with
other projects planned on the Nez Perce National Forest and throughout Region 1, the
Forest Service has failed to complete an economic analysis that provides the public with a
full and fair accounting of net economic benefits. Instead, the economic analysis is
limited to net costs incurred by the Forest Service and project administrators.

The EA and project should place any economic value on existing uses and functions of
the sale area, including recreation, flood control, pest control, carbon sequestering, and
many other “ecosystem services.” In addition, the economic analysis must consider a
wide range of costs that will be incurred by the public through loss of these “ecosystem
services” and other externalized costs such as increased flooding, increased risk of death,
injury, and property damage from logging operations, and increased fire risk.

In summary, we find the EA is lacking in many respects. Given that the Meadow Face
project is the main “product” for the Clearwater Ranger District this year, a thorough
economic and biological analysis is needed. We don’t believe a project like this makes
sense in terms of the National Fire Plan priority or in terms of restoration/recovery of the
Meadow Face analysis area. We hope our input has proven valuable for the Forest.

Sincerely,


Mike Petersen

								
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