The Ecology Center, Inc - Get Now DOC

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					                The Ecology Center, Inc.
                                   314 North First Street West
                                      Missoula, MT 59802
                                         (406) 728-5733
                                       (406) 728-5779 fax
                                   ecocenter@wildrockies.org
May 23, 2005

Dennis Duehren, District Ranger
Montpelier Ranger District
322 North 4th St.
Montpelier, ID 83254

Transmitted via email--please acknowledge receipt!

Mr. Duehren:

These are comments on the Williams Creek Aspen Restoration proposal (your April 15, 2005
scoping letter), on behalf of the Ecology Center and the Alliance for the Wild Rockies.

The reasons given for preparing separate NEPA analyses for this project and the proposed Williams
Bear Vegetation Management project in your April 15 letter are not legitimate. It is not the
separateness of the actions; literally dozens of NEPA documents for Forest Service (FS) actions are
written in the Intermountain Region each year that contain multiple actions with multiple purposes
that are little related except for common geography. The fact that the very same resources (wildlife,
water, etc.) in the same geographic area would be affected by both projects means that you must do
a single NEPA analysis, documented in an EA or EIS. At this point, it is obvious that you are trying
to avoid doing anything but a Categorical Exclusion for both projects, even though in this case CEs
would be illegal.

Your position is particularly nonsensical since the Williams Bear Vegetation Management,
supposedly “different” from the Williams Creek Aspen Restoration project, also has an aspen
restoration component.

Be real. These projects are right across the road from each other, a few feet away!

In any case, the FS ought to be revising its livestock grazing and fire suppression policies, since
they’re largely the reason behind the proposal’s need. The proposed management activities must
be integrated well with the processes that naturally shaped the ecosystem and resulted in a range
of natural structural conditions. Together with planning for “fire use” in these areas, we can
strive for fire-adapted ecosystems that would require no or minimal management activities, and
save countless taxpayer dollars.

The need for the Caribou National Forest to identify a management indicator species for aspen
communities seems obvious, if here and in other ranger district aspen management/rejuvenation
is being pursued.
Please put a copy of this letter in your file for the proposed Williams Bear Vegetation
Management project, as comments on that project also.

Please keep us on your list to receive further mailings on the proposal.

Sincerely,

/s/

Jeff Juel

And on behalf of:
Michael Garrity
Alliance for the Wild Rockies
P.O. Box 505
Helena, Montana 59624
406-459-5936

				
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