Sometimes the Future...Apologia for Opinoniated Rant

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Air date: 
Mon, 04/06/2015 - 10:00am to 10:15am
Dead water, dead fish nothing: left but a river of tears

 nfmc_public@fisheriessciences.net

 
Barry Rosenberg
487 Greenhood Road
Priest Lake, Idaho 83856-8854
(208) 699-0843
barryrosenberg88@gmail.com
 
April 6, 15 AM/PMt 9:37 AM
Mark Teply
Cramer Fish Sciences Project Manager
4405 7th Ave SE, Suite 306
Lacey, WA 98503
 
Re: Comments on North Fork Mill Creek A to Z Project
 
Dear Mark,
     Thank you for providing me the opportunity to comment on the North Fork Mill Creek A to Z Project (NFMC). I also want to thank you for your prompt reply to my request for the Specialist’s Reports.
     I believe that the pre-decisional Environmental Assessment (EA) findings of No Significant Effects for the NFMC Proposed Action, Alternative (Alt) B and Alternative C are not supported by the documentation in the EA and the Specialist’s Reports. I will examine and comment on Alt B, but these comments are also relevant for Alt C although the the logging activities are much less than in Alt B.
     I do not agree with several issues that the EA finds are “outside the project scope,” or are dealt with in other documents.
GRAZING
     The EA does not provide any site specific information regarding the grazing impacts to the affected streams in the Project Area (PA). It states that the effect of current grazing allotments on water quality and riparian habitat are addressed in a separate grazing allotment plan. The name of the plan is not mentioned.
     What is the name and date of the plan, and what grazing allotments does it cover? In a seemingly contrary move, the EA finds it necessary to discuss protections from potential adverse effects to the grazing allotment from the proposed timber sale and offers enhancements such as creating up to 200 acres of openings and proposes planting them with native grass to provide more grazing area for the existing range permit.
     Have the cattle had any adverse effect on water quality and riparian habitat in the Project Area? When was the latest monitoring of site specific effects of cattle on the water resources in the PA? I could not find this information in the EA or the Specialist’s Reports.
     Alt B proposes to construct an additional 30.8 miles of new temporary road in addition to the already 65 miles of Forest Service (FS) and unmapped roads in the PA. The project also proposes to increase the amount of openings by conducting shelterwood and commercial thinning logging in the PA. These actions can make easier for the cattle to access the riparian habitat and streams which can result in additional adverse impacts to the fishery in the PA. The grazing issue is significant and should be fully examined in the EA.
     What stream segment in the PA has a TMDL due to excess coliform bacteria? Are the grazing allotment cattle contributing to the 303(d) status? This information should be provided in the EA.
CLIMATE CHANGE
     Deforestation is linked to climate change. The EA states the impact on climate change from this logging is insignificant, but the idea of cumulative effects is to consider those things that might seen insignificant but when added to other similar actions can have a significant effect. Given the EA’s way of dealing with this issue, it could excuse all particular logging activities wherever and whenever from being considered as a  contributor to climate change. The effects of deforestation on climate change should be fully considered in this EA.
 A to Z EXPERIMENT
     The EA avoids discussing the “elephant in the room.” In a precedent setting move, the Forest Service has granted Vaagen Brothers, a for profit timber corporation, broad and sweeping powers that includes designing the A to Z Project, doing the environmental analysis, writing the EA, deciding where, how, and how much to log, where and how many roads need to be constructed and just about everything else associated with a timber sale. The FS will make the decision.
     The respective missions of the FS and the for profit Vaagen Lumber Company are different and could determine the outcome, and financial and environmental impacts of the sale. It is doubtful that the FS is going choose the No Action alternative, or significantly alter the Project since Vaagen, a member of the local community and of the Northeast Washington Forest Coalition, bid one million dollars to participate in this experiment. By having Vaggen do most of the work associated with timber sale planning and management, it provides the opportunity for the Colville National Forest (CNF) to reach its timber target. It claims it cannot currently do so because of budget and staff reductions. This is a significant action and needs to be disclosed and fully discussed in the EA.
     The fact that the Proposed Action calls for a very large timber sale with an inordinately large amount of road construction could be consistent with the needs of a for-profit timber corporation. Vaagen needs to have a sale that offers a large timber volume to cover its bid price and the costs associated with the project. The public can expect large timber sales if this experiment is carried through to other timber sales. This is a national forest issue and the public throughout the country needs to know of this experiment and how it can affect the environmental outcome. The financial aspect of this experiment also needs to be fully disclosed.
WATER QUALITY
     The EA relies heavily on models in its effects analysis due to a paucity of on the ground scientifically credible quantitative monitoring information. There is no mention of quantitative monitoring to determine the effects of previous CNF timber sales to evaluate its effects predictions with reality.
     The WEPP road model and WEPP FuME are used to estimate sediment production. The EA states that the level of confidence of these models range from 1-50% is so broad that they should only be used as a means of comparison. Yet the model’s figures are used to predict sediment levels throughout the EA. It is unreasonable to put so much weight on these models given the wide range of confidence levels. How accurate are the predictions of a increase in sediment of 63% for duration of logging activities, a decrease of 1 percent in the short term, and a 65% decrease in the long term? The CNF should realize by no that logging and road construction are not surgical strikes. Do these figures include the sediment increases during Rain on Snow (ROS) events, lack of maintenance of roads and activities on non-Forest Service managed ground in the project area?
     Much is predicated on continued maintenance of new and existing roads after the project is over. Is that realistic given the reduced CNF budget and considering the poor condition of many existing roads? What percent of existing roads on CNF receive significant yearly maintenance? How many miles of CNF road received maintenance in FY 2010, 2011, 2012, 2013, 2014, 2015.
     The EA, and the Hydrology and Fishery Specialist reports lacks sufficient site specific watershed analysis for each of the affected stream drainages for the public to evaluate the environmental impacts. Is there significant bedload deposition, point and mid-channel bars, and adverse effects from cattle in site specific affected stream segments? It does mention that the streams fall short of INFISH Riparian Management Objectives (RMO) for width depth ratio, sediment, stream bank angle and large woody debris. The EA does not adequately discuss the causes and the significance not meeting the RMO. How long will the affected streams will remain impaired and how will these problems effect the fishery in the short and long term?
     What are the existing impacts to the fishery in the affected streams? The EA states that current sediment levels in project area streams are 23%. It does not adequately address the  short and long term significance of this amount of sediment deposition. What are the site specific recorded levels of sediment for each of the affected streams? What is the significance of these levels? What is the significance of the predicted increases in sediment production in each of the affected streams and project area? How are the affected streams dealing with the accumulated sediment? How long will it take for these streams to recover and meet the RMO’s given the increase in water yield and additional sediment that will be generated by the 30.8 miles of proposed new temporary road construction, logging and cattle damage? Road construction results in sediment, decommissioning the temporary roads adds another pulse of sediment. What is involved in decommissioning roads?
RAIN ON SNOW (ROS)
     Much of the logging activity takes place in areas susceptible to ROS. The timber sale proposes to build an additional 30.8 miles in addition to the existing 65 miles of road in the project area. The EA proposes 1,741 acres of shelterwood logging (avg. 75% of trees >7 inches dbh will be cut) and 2,277 acres of commercial thinning (cutting an avg. of 50% of  trees). The proposed logging will change large areas from mature forest canopy to intermediate forest canopy category. The EA fails to reveal what coefficients will be used for site specific areas to evaluate the susceptibility and intensity of a ROS event. The EA does not adequately disclose the effects of ROS events on site specific drainages that have varying amounts and types of logging, road density, spacial and other characteristics that influence a ROS event. What is the existing road density and the road density post logging/road construction in the PA? How does the CNF Forest Plan deal with road density?
     The EA does not compute Equivalent Clearcut Area (ECA). Proposed roads and logging create a large additional amount of openings in the Project Area which could significantly effect water quality, quantity and fish habitat. How many ECAs will be created by the proposed timber sale? What is the total amount of ECAs in the North Fork Mill Creek PA?
     The Hydrology Specialist’s report, Figure 19, represents the mean daily peak flows for the North Fork Mill Creek. What date is being represented by that graph? One point in time is not  an adequate means of evaluation. The use of “mean daily peak flows” is not a fair representation of flow levels. The models used to evaluate the amount of ROS flows and its impacts are no substitute for daily readings from instream gauges on the North Fork Mill Creek. 
INSECTS AND DISEASE
     One of the justifications for the A to Z project is to reduce susceptibility to insects and disease in the PA. Are the current levels of insects and disease beyond those found in a normally functioning forest? Are they trending beyond normal levels? Is there data from site specific surveys conducted in the PA to determine the current levels of insects and disease? What best available science was used to determine that the proposed logging will “improve” the current situation.
 
 
FIRE
One Purpose and Need for the Proposed Action is to “reduce the threat of severe wildfire.” What is the basis for the assumption in the EA that the PA is ripe for a severe wildfire? The EA assumes in Alt A that without this project the chances for a severe wildfire will occur with extreme effects is increased. There are many examples of wildfires that burn in a mosaic fashion leaving a naturally functioning forest without having a significant effect on soils, water quality or wildlife. Fire is an important aspect of a naturally functioning forest.
     The proposed logging will significantly open up the area and reduce the amount of existing mature forest. These logged areas will more likely be drier, warmer, susceptible to increases in wind and will generate more ground fuels than currently exist. All these characteristics have the potential to increase the risk and severity of a wildfire. The EA does not adequately discuss these increased risks. The EA also states that it will leave a lot of fine material on the ground to increase the nutrient level. What will keep the fines from burning up, especially in the areas that will be broadcast burned? The slash generated by the logging and road construction also increases the risk and intensity of wildfire.
     The proposed action alternatives do not make the PA fireproof. The issue of wildfire is controversial. There are reports by credible scientists who dispute that logging significantly reduces the risk and intensity of wildfire. None of these opposing views are presented in the EA. The EA fails in its obligation to use the best available science in its analysis. The EA needs to consider the possibility of wildfire and its effects in all the action alternatives.
CUMULATIVE EFFECTS    
     The EA needs to consider the cumulative effects on Mill Creek since another large timber sale, Middle and South Forks Mill Creek A to Z Project is to be implemented in the foreseeable future. These creeks and the North Fork Mill Creek drain into Mill Creek and could have significant direct, indirect and cumulative effects on Mill Creek.
     The EA lacks a sufficient and credible cumulative effects analysis because it does not adequately consider the past, present and site specific future activities on non Forest Service managed land in the project area. These activities need to be more carefully considered in all the cumulative effects analysis discussed in the EA.
EA relies on unreliable models to predict the effects of the proposed project because the CNF has not had a sufficient, scientifically credible quantitative monitoring program to enhance the reliability of the EA’s predictions. Is there an implementation and effects monitoring regime proposed for this project? If so, who is responsible and what are the specific elements of the proposed monitoring?
     It is hard to believe that 30.8 miles of road and 2.2 miles of road realignment plus all the ground skidding, slash piling, etc from previous activities on FS and non-FS land, combined with this proposed timber sale would not exceed soil standards considering, "Much of the surveyed area was logged and roaded, primarily 30 to 50 years ago. Substantial detrimental soil conditions (DSC) was caused by these activities.” (EA p.72) Damaged soil takes very long time to recover so existing cumulative effects of soil impacts from previous timber sales and other activities in the PA are minimized.
     The leaving of large organic debris (LOD) on ground does not replicate natural conditions. Leaving LOD post logging, and cutting many of <7” trees in the logging units will not replicate the constant feed of various size trees as occurs in natural forest.
     Many of the logging units appear to be located in high and moderate mass wasting areas according to the map in soil specialist’s reports (figure 5). Since there are no unit designations delineated on the map it is impossible to determine unit and road location in relation to moderate and high mass wasting hazard. EA fails to disclose the possibility and effects of mass wasting in areas with “moderate” rating.
 
 
Sincerely yours,
 
Barry Rosenberg
cc: Kootenai Environmental Alliance
     Selkirk Conservation Alliance
     

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