Environmental Assessment
Comment Letter #2 – Bill Barton – Native Forest Council
Response
2-1
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Knox Hazardous Fuels / Forest Health Project
2-2
2-3
2-4
2-5
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Environmental Assessment
2-1 – Soils The damage done to soils, including soil nutrients, is addressed in Chapter 3, Soils section. This damage is within Forest Plan standards. 2-2 – Climate The Knox Project is designed to restore the health and resilience of forest ecosystems. Additionally, proposed actions may improve the capability of the landscape to withstand climate change stresses. This includes proposed aspen treatments, where removal of competing conifers is expected to be effective in increasing light and water availability to aspen. A recent study completed on the Lassen National Forest showed a significant increase in total aspen stem density after competing conifers were removed (Jones et al. 2005). We acknowledge that climate change could affect the ability to restore the historic distribution of aspen across the landscape. There may be areas where the ability to restore aspen in a historically occupied location may be reduced as a result of climate change. To address your concern related to the ability to achieve the “historic condition” for aspen, the desired condition in the “need” statement has been adjusted. Reference to achieving the historical condition has been removed. The revised desired condition is a landscape composed of healthy aspen stands with a mix of age classes. 2-3 – Insects/Disease/Soils The reduction in soil nutrients is disclosed in Chapter 3, Soils section. Soil water absorbing capacity is reduced by compaction and puddling, which are disclosed in Chapter 3, Soils section. These reductions are within Forest Plan standards. Insect and disease are natural parts of the forest life cycle as discussed in Chapter 3, Forest Vegetation, Affected Environment. In addition, the Blue Mountains Entomologist reviewed the project area and a summary of the report is
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included in the same section. Recommendations include treatment to reduce impacts from forest insects and disease where stands are overstocked or over-represented by fire intolerant species. Most of the stands have been entered in the past which is disclosed in Chapter 3, Forest Vegetation, Historic Conditions however, neither action alternative proposes treatment in an existing plantation nor creates one. 2-4 – Economics The methodology and assumptions, the variability of harvest and the economic efficiency are discussed in the EA, Economics Section. The economic analysis acknowledges the importance of the economic value of ecosystem services or environmental amenities in the overall effects analysis. The costs or benefits of ecosystem services are not well defined at the project level in terms that provide comparison of commensurate dollar-quantified values. Contingent valuation methods for determining economic values of ecosystem services consist of extensive primary data collection that is expensive and generally undertaken for broad-scale, landscape decisions such as basin-wide planning efforts. The economic analysis provides one aspect of the overall comparison of the direct, indirect and cumulative effects of the project. Other natural resource benefits or environmental amenities are considered in the EA, such as changes to the diversity, and quality and quantity of wildlife habitat for both game and non-game terrestrial species. 2-5 – Fish Extinctions The sub-species of redband trout (Oncorhynchus mykiss gairdneri – Columbia River redband trout) (Behnke 1992) potentially affected by the proposed action are not currently Federally listed as Threatened or Endangered under the Endangered Species Act (ESA). That is not to say that this sub-species of red-band trout do not face present and future threats to their existence, however this project, being consistent with Forest Plan standards and INFISH, would not likely contribute to a trend towards Federal listing or cause a loss of viability to the population or species; as outlined in Chapter 3, Fisheries section and the Aquatic Biological Evaluation. Additionally, Minckley et al. 1991 describe that the ESA encourages the listing of not only full species as imperiled, but also subspecies and undescribed populations as well. This is to say that if O. mykiss gairdneri, a subspecies of Oncorhynchus mykiss, were imperiled they then they would more than likely be listed under the ESA’s protection. Instead they are listed as Sensitive with the State of Oregon and Region 6 of the Forest Service. As Minckley et al. (1991) goes on to further point out, “compilations dealing with continental fauna indicate substantially more imperiled taxa east of the continental divide than west.” Implying that the attention given to imperiled western North American taxa may be disproportional to the attention that should be given to imperiled taxa throughout the rest of the continent, primarily in the east where numerous large human population and industrial centers exist.
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