Appendix 7 Responses to Comments on the DEISa123.g.akamai.net/7/123/11558/abc123/forestservic...ISSA3 . An alternative that would delete Forest-wide standard TEST34 was considered

Appendix 7 Responses to Comments on the DEIS

Response to Comments on the DEIS

1

Responses to Comments on the DEIS In addition to a Notice of Availability of the DEIS in the Federal Register on December 24, 2009, and a legal notice in The Idaho Statesman announcing release of the DEIS on December 24, 2009, a summary of the DEIS outlining the alternatives and associated environmental analysis, and providing an opportunity to comment, was mailed to 92 individuals, agencies, and/or groups on December 21, 2009. The entire DEIS was sent to 24 agencies, organizations and individuals, in the appropriate format requested by each. In addition, the entire DEIS was posted on the Forest’s website, with paper and electronic (CD) copies available upon request. In April 2010, the EIS summary was sent to approximately 15 individuals and organizations that inadvertently were missed in December 2009, with copies of the entire DEIS available upon request. In response, a total of 22 letters were received: Agencies Idaho Department of Parks and Recreation Idaho Department of Fish and Game US EPA US Department of the Interior, Office of Environmental Policy and Compliance Individuals Ned Pence Jean Public (2 letters) Ron Hamilton Glenn Jacobsen Becky Johnstone Frank Shirts; Ronald and Leslie Shirts Stephen T. Harshfield Larry and Janet Harshfield Organizations Idaho State Snowmobile Association Defenders of Wildlife The Wilderness Society The Lands Council/Alliance for the Wild Rockies Idaho Conservation League American Forest Resource Council Boise Cascade (Boise Building Supply) Intermountain Forest Association Idaho Forest Products Group The following section contains photocopies of comments received and the Interdisciplinary Team’s responses to those comments. Responses to individual statements in the letters can be cross-referenced by the corresponding numbers in the page margins.


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ISSA1

ISSA1

Section 2.4.2.2 of the DEIS discloses that Alternative B (Proposed Action) was updated prior to release of the DEIS to address public comments and preliminary analysis. This update noted that priorities for future investigations of potential wolverine and human conflicts were incorporated into the Proposed Action, to address requests for a wolverine conservation approach that identifies what and where conflicts exist (with site-specific, tailored mitigation as needed). The update also acknowledged investigations of potential wolverine-human conflicts in southwest Idaho forests (supported by the Idaho State Snowmobile Association). As noted in section 2.4.2.2, it is anticipated that these investigations will be expanded to include the Boise NF.


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ISSA2 ISSA3

ISSA2 ISSA3

An alternative that would delete Forest-wide standard TEST34 was considered but eliminated from detailed study (section 2.4.1.6, DEIS). This alternative was eliminated from detailed study for several reasons, including the Forest’s intent to address winter motorized recreation through future travel management efforts, because winter motorized recreation is not part of the purpose and need for developing the WCS and associated Forest Plan amendment. Moreover, based on disclosures in the FEIS for the 2003 Forest Plan concerning TEST34, disclosures in the WCS DEIS, informal consultation with the U.S. Fish and Wildlife Service, and discussions with local biologists, the Responsible Official determined that TEST34 is still appropriate and needed to address suitable habitat conditions for the lynx. As discussed in Chapter 4 of the Forest Plan, adaptive management is the foundation of planning and management (USDA Forest Service 2003a, p. IV-3). The WCS and associated amendments are not static, but will evolve over time as the science concerning management of resources evolves and/or baseline habitat conditions change. The 2010 addendum to the 2003 Biological Assessment for the WCS and associated Forest Plan amendments specifically addresses changes in lynx habitat baseline conditions resulting from recent large fires and the latest scientific understanding about the influence of snowmobiling and skiing on lynx and their habitat (FEIS, Appendix 6).


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NP1 NP2 NP3 NP4 NP5

NP1 NP2 NP3 NP4 NP5

Comment acknowledged. Comment acknowledged. The Forest has developed a “key points” document accompanying the FEIS in an attempt to simplify and clarify key content while retaining technical accuracy. Active management MPCs (e.g. MPCs 3.2, 4.2, 5.1 and 6.1) allow managers to choose whether to use mechanical or fire tools to achieve management objectives based on site-specific situations and the specific MPC multiple-use objectives. An alternative considered but dropped from detailed study would have allocated passive management MPCs (e.g. MPCs 1.2, 2.2, 2.1, 4.1a and 4.1c) to active management MPCs (DEIS, section 2.4.1.2). These passive management MPCs typically limit or prohibit mechanical treatments, and encourage use of fire. This alternative was dropped due to overriding conflicts with other multiple-use objectives (DEIS, section 2.4.1.2). The DEIS discloses that biomass volumes have not been included in the estimates of Total Sale Program Quantity (TSPQ), because markets for this product are still in the development phase, and utilization is currently low and hampered by a lack of infrastructure. If an anticipated market in southwest Idaho develops in the next 5-10 years, adjustments in TSPQ, and the Allowable Sale Quantity (ASQ) as appropriate, will be made at a future date (DEIS, section 3.5.3.1, “Calculation of Total Sale Program Quantity”). As disclosed in the Record of Decision (ROD) accompanying the FEIS, the rationale for the decision describes how this Forest Plan amendment will affect the Forest’s ability to manage resources important to the American people, both now and in the future. The DEIS also provides a detailed discussion of the effects of this decision on the social and economic conditions (DEIS, section 3.7).


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NP6 NP7 NP8

NP6 NP7 NP8

The proposed Forest Plan amendment would not change the area currently designated in the Forest Plan for wildland fire use, nor would it increase the amount of prescribed fire currently intended under FMOB04. A key effect of the amendment would be to reduce restrictions on the use of prescribed fire in the ecosystems most in need of restoration (nonlethal and mixed1 fire regimes). Currently about one-quarter of these fire regimes have been assigned to MPC5.2, which restricts the use of prescribed fire and makes it difficult to achieve FMOB04. This effect has been clarified in the FEIS, sections 3.4 and 3.4.5.1.2. The DEIS acknowledges this comment in section 3.4.5.1.2: “although management direction would not limit prescribed fire in these alternatives, there is macrovegetation that would not be appropriate to manage with prescribed fire based on current concerns about fire effects and risk even if the landscape were within historical condition. . . Achieving the often narrowly defined objectives for using prescribed fire on sites with tall shrubs is difficult because the prescription windows necessary to reduce the risk of escape and limit stand-mortality are very narrow.” (DEIS, 3.4.5.1.2, p. 254) The DEIS, section 1.2.2, discloses that project needs address the need to balance wildlife habitat restoration with other objectives. More specifically, Forest Plan amendments are needed to “add or modify existing management direction to emphasize retention of large snags while balancing other objectives associated with a given Management Prescription Category (MPC) (e.g., the desire the provide for economically viable timber harvest on lands suitable for timber production,” and to “balance wildlife habitat restoration needs with multiple-use objectives and allow exemptions for treatments that respond to emergencies, provide for public health and safety, and allow for the exercise of existing rights and other statutory requirements.” (DEIS, section 1.2.2, pp. 11-12). The DEIS, section 2.5.1, describes how each alternative considered in detail would respond to the needs for change identified in Chapter 1.


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9

NP9 NP10 NP11

NP9 NP10 NP11

The Forest acknowledges that it is impossible to know exactly what constitutes historical conditions. However, the Forest did derive its information about historical conditions from a variety of sources including stand and landscape reconstructions, early explorer journal descriptions, 19th century photographs, and other evidence (DEIS, section 3.2.1.3). When comparing this information against the current landscape conditions, the Forest does conclude that policies and actions in the past several decades have resulted in the numbered effects. The desired condition for fire in the 2003 Forest Plan states: “Fire-both prescribed and wildland—is used as a tool to achieve and maintain vegetative conditions and desired fuel levels. Fire plays it natural role where appropriate and desirable, but is actively suppressed where necessary to protect life, investments, and valuable resources. Fire operates within historical fire regimes appropriate to the vegetation type and management objectives.” (USDA Forest Service 2003a, p. III-38; emphasis added). One intent of the Forest Plan is to balance the use of fire with other restoration tools to help achieve desired conditions across the Forest. Therefore, returning the historical role of fire may meet management objectives in some, but not all, parts of the Forest (DEIS, section 3.4.1). See response to comments NP7, NP8 and NP10.


10

NP12

NP12

See response to comment NP2 above.


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NP13

NP13

The definition of large tree size class described in Appendix A was established based on the 1996 Mapping Existing Vegetation and Land Cover across Western Montana and Northern Idaho conducted by the University of Montana. This size class is consistent with the diameter breaks from the General Technical Report WO-67, Existing Vegetation Classification and Mapping Technical Guide Version 1.0 (Brohman and Bryant 2005) which establishes tree size classes as 20.0-29.9 inches d.b.h. and greater than or equal to 30.0 inches d.b.h. These breaks will be used to define large (20.0-29.9) and very large (>30.0) for the updated Forest-level mapping to maintain consistency with the 1996 existing vegetation coverage developed by the University of Montana. These size breaks are the same as those included in the 2003 Forest Plan (USDA Forest Service 2003a).


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NP14

NP14

Comment acknowledged. However, as noted in the DEIS, section 3.7.4.4, a slight increase in timber outputs could be realized under Alternative B (the preferred alternative), compared to Alternative A, if the amendment implemented under Alternative B helps resolve social issues regarding forest management, thereby reducing social constraints on timber management.


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14

NP15

NP15

The objective for prescribed fire is 100,000 acres, not 150,000 acres per decade. The 100,000 acres of prescribed fire (FMOB08) and the 145,000 acres of mechanical alone or in combination with fire contribute to VEOB08, which calls for completing at least 215,000 acres of treatments to maintain or restore desired vegetative and wildlife source habitat conditions, and FMOB04, which calls for treating 50,000 acres of hazardous fuels in the WUI. (DEIS, Volume 2, Appendix 2 (Forest Plan Chapter III, Forest-Wide Management Direction)). As noted in the response to comment NP6, the area currently designated for wildland fire use (WFU) is not changing. Outside the WFU area, wildfires will be managed primarily for protection objectives per current policy.


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NP16 NP17

NP16 NP17

See response to comment NP8 above. Section 3.1.5 and Appendix 5 of the DEIS describes those resources that the interdisciplinary team determined would not be measurably affected by the WCS and proposed Forest Plan amendments, as compared to the effects described in the 2003 FEIS for the Forest Plan. These resources included soil, water, riparian and aquatic resources, among others. In addition, section 1.2.1 of the DEIS describes the purpose for this project; namely, to complete a comprehensive WCS for the Forest and to amend the 2003 Forest Plan to integrate the action components of the WCS. This section also notes that a short-term emphasis will be placed on restoring habitats of greatest conservation concerns, such as those associated with white-headed woodpecker. Section 1.8 of the DEIS describes eight specific needs for the project, including the need to balance wildlife habitat restoration needs with multiple-use objectives.


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NP18

NP18

As described in the DEIS, section 1.1.3, the amendment is intended to provide for restoration of habitat for wildlife species of greatest conservation concern using conservation principles founded on best available science. This includes providing well-distributed habitats with conditions close to those under which the species evolved (founded on the historical range of variability) balanced with providing other goods and services.


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JP1 JP2 JP3 JP4 JP5 JP6

JP1 JP2 JP3 JP4 JP5 JP6

The DEIS discloses that the Forest Plan amendment is developed using the procedures made available under the 1982 NFMA regulations (DEIS, section 1.3.1). These regulations note that plans developed under these regulations “ . . . shall provide for multiple use and sustained yield of goods and services from the National Forest System in a way that maximizes long term net public benefits in an environmentally sound manner.” (36 CFR 219.1) The DEIS discloses that one of eight “needs” for this project is to “balance wildlife habitat restoration needs with multiple-use objectives, and allow exemptions for treatments that respond to emergencies, provide for public health and safety, and allow for the exercise of existing rights and other statutory requirements.” (DEIS, section 1.2.2, need #8) The Forest has developed a “key points” document accompanying the FEIS to try to simplify language while retaining accuracy of the underlying technical concepts. See response to comment JP1 above. The FEIS contains a list of agencies, organizations and individuals to whom the DEIS was sent. The planning record includes a list of those to whom earlier scoping materials were sent. Notices of Intent to Prepare an EIS were published in the Federal Register, and the project has appeared on the Forest’s Schedule of Proposed Actions (SOPA) since 2006. Comment acknowledged.


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JP7

JP8 JP9 JP10 JP11

JP7 JP8 JP9 JP10 JP11

Section 3.3.7.5 of the DEIS discloses the effects of the action alternatives on wolverine, a species associated with Family 3. This analysis notes that under either Alternative B or C, the sustainability outcome is predicted to remain within outcome C- Suitable environments are distributed frequently as patches and/or exist at low abundance. Section 3.1.5 and Appendix 5 of the DEIS describes those resources (including air quality) that the interdisciplinary team determined would not be measurably affected by the WCS and proposed Forest Plan amendments, as compared to the effects described in the 2003 FEIS for the Forest Plan. See response to comment JP1. The DEIS in section 3.7.3.2 summarizes the Federal legislation that authorizes payments to counties. As documented in the “Literature Cited” section of the DEIS, numerous scientific publications are cited throughout the document, many of which have been developed in the last few years. The conservation principles upon which the WCS is based are widely accepted and among the best supported precepts of conservation biology (Noss 2007) (DEIS, section 1.1.3)


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JP12

JP12

See response to comment JP1 above.


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21


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RH1 RH2 RH3 RH4

RH1 RH2 RH3 RH4

The State of Idaho engaged multiple conservation partners in development of the State CWCS (ID CWCS 2005, Acknowledgements). The Idaho CWCS provides an essential foundation for the future of wildlife conservation planning in Idaho. As stated in the “Purpose” section, the CWCS is a strategy document to support subsequent conservation planning by partners. It is intended to provide information and general guidance that will be useful in developing more specific conservation plans for at-risk species, such as the Forest WCS and associated Forest Plan amendments. Section 3.2 of the DEIS summarizes the tradeoffs of continued management under MPC 5.2 vs. 5.1 or 3.2 to vegetation restoration, and section 3.3 provides a similar discussion for wildlife habitat restoration. Comment acknowledged; see also response to RH2. Regardless of the mix of MPCs adopted, Forest managers recognize the importance of providing a sustainable and recurring wood product supply to help restoration efforts and to meet multiple use objectives on NFS lands (DEIS, section 3.5.1). Section 3.7.3.2 of the DEIS discusses recent changes in the local area, including the substantial transition in the wood products industry. Section 3.7.5.3 and 3.7.4.4 discuss the effects of Alternatives B and C, respectively, on jobs and income within identified local communities. Both alternatives anticipate some increase in jobs and income. However, several foreseeable future actions outside the control of the Forest Service could cumulatively affect community jobs and income (including those in the timber industry). These foreseeable future actions include Idaho’s announced drop in timber offering on State lands in southwest Idaho, recent closure of the sawmill at LaGrande, and resumption of the 25% fund payments in lieu of Secure Rural Schools payments.


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RH5 RH6 RH7 RH8 RH9

RH5 RH6 RH7 RH8

As discussed in Chapter 4 of the Forest Plan, current Forest Plan monitoring includes implementation, effectiveness and validation monitoring (USDA Forest Service 2003a). Results of annual monitoring on the Boise NF have been reported annually from 2004-2007 (planning record). The 2008-2009 report is anticipated to be published in late 2010, and the 5-year evaluation report is expected to be published in 2011. Monitoring has been based on accepted procedures and protocols and has involved experts within and outside the Forest Service that were not directly involved with projects monitored. The amended Forest Plan would provide for fuelwood collection. The WCS and proposed amendments do not propose direction to change the current firewood collection allowances. However, proposed direction would instruct responsible officials to consider the need to address those impacts of fuelwood collection that might be affecting achievement of desired conditions, through subsequent site-specific project planning, travel planning or annual firewood program planning (DEIS, Volume 2, Appendix 2 (Forest Plan Chapter 3, “Common MPC Management Direction”)). The DEIS, sections 3.4.1.2 and 3.4.6.2, discuss the importance of coordinating hazardous fuels treatments across boundaries, particularly given the variability in fuel conditions that can occur on adjacent ownerships. While municipal, county and state requirements and their relationship to hazardous fuels management can be addressed during site-specific project development, these requirements are too variable to address at the programmatic scale of this amendment. The modeling platform used for the amendment (the Vegetation Dynamics Development Tool [VDDT]) does not allow for the same level of precision in describing silvicultural treatments as past modeling platforms. However, yields were developed by the Forest


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RH9

silviculturists based on the 2003 Forest Plan revision products, and how various silvicultural treatments ranging from even to uneven-aged would be implemented in broadly defined growth stages. Alternative A was used as the baseline. The ASQs projected for Alternatives B and C were developed from the same set of assumptions as applied to Alternative A, regarding the outcomes of treatments. However, the differences in yields relate to the types of treatments that might be used to meet the intent of the individual alternative, and the effects of the proposed standards and guidelines. For example, in Alternative A, it was assumed that the yield from a regeneration harvest such as a shelterwood would be greater than in Alternatives B and C because proposed standards WIST08 and VEST03 would eliminate or substantially reduce products removed from a final overstory removal, even though the treatment could result in similar outcomes. Details can be found in the VDDT technical report, included in the planning record. Ponderosa pine and western larch legacy trees contribute to ecological functions when alive as well as dead (as large snags). The large tree desired conditions described in section 3.2.5.6.1 of the DEIS should be able to accommodate these features.


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RH10 RH11 RH12 RH13

RH10 RH11 RH12 RH13

Please see response to comment RH8. Appendix 4 of the DEIS summarizes the detailed planning record documentation that includes assumptions for stocking rates and treatment timeframes used in Forest Vegetation Simulator (FVS) modeling for the 2003 Forest Plan FEIS (USDA Forest Service, 2003b, Appendix B, page B-15). Section 3.5 of the WCS DEIS discloses anticipated timber yield associated with each alternative and its contribution to supporting the local and regional timber industry. As to biomass, refer to response NP4 above. See response to comment NP6 and NP7 above. The Forest Plan objective for prescribed fire was developed in 2003 based on the existing fire management organization, budgets, traditional prescription windows and availability of suitable burning days within affected airsheds. Forest fire management personnel reviewed the 2003 Forest Plan objective during development of the WCS amendment and determined the objective was still reasonable. See response to comment RH11. Prescribed fire was represented as a maintenance treatment (DEIS, Volume 2, Appendix 4, section 3.2, page 8) in vegetative growth stages (primarily medium and large tree size class, low and moderate canopy cover class) in PVGs where it was assumed, based on input from fire management specialists and silviculturists, that the mortality from prescribed fire would not increase over the mortality projections included in the yield estimates. The Forest Plan does not contain management direction that specifically includes a road mileage/square mile value. The road mileage/square mile value found in Appendix B of the Forest Plan is intended to be used as an “indicator” as to the “functionality” of soil, water, riparian and aquatic resources (USDA Forest Service, 2003a, Appendix B).


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RH14 RH15 RH16 RH17

RH14 RH15 RH16 RH17

Both the Vegetation Resources and Wildlife Resources sections in the DEIS have been updated in the FEIS to provide a better assessment of active versus passive management areas and their respective benefit or hindrance in achieving restoration objectives. Chapter IV of the 2003 Forest Plan includes monitoring designed to assess whether or not live vegetation is at, or moving towards desired conditions as described in Appendix A of the Forest Plan (USDA Forest Service 2003a, “Monitoring Elements,” p. IV-8). Comment acknowledged. Section 3.7.5.4 of the DEIS notes that the 25 percent fund revenue would not be commensurate with the increase in Alternative C’s effective TSPQ because much of Alternative C’s timber volume would likely be generated through stewardship contracts, in which the timber revenue is not returned to the US Treasury but instead used to offset the cost of associated needed restoration activities such as precommercial thinning. The yield estimates account for mortality from endemic levels of insects and disease. However, synergistic disturbances such as blowdown that facilitate insect irruptions are too unpredictable to include as a potential source of mortality. The VDDT modeling conducted for the analysis did include stochastic events like the 2006 and 2007 wildfires and cyclic outbreaks of insects such as tussock moth because there was a documented history of these types of occurrences and effects (DEIS, section 3.2.3.2;, Appendix 4, section 8). Unpredictable events such as those described in RH16 would be addressed during periodic Forest Plan monitoring to determine whether they have enough effect on projected outcomes such as ASQ to warrant adjusting objectives. As discussed in the DEIS, section 1.1, assessing habitats that support the diversity of native and desired non-native wildlife species that occupy the planning unit (i.e., the Forest) is very complex. To reduce this complexity,


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Forest Plan amendments will be completed through a four-phase approach, over the next four to five years.

The Responsible Official recognizes the concern raised that several species use combinations of forested and rangeland communities, as well as riparian and wetland habitats. Following the framework of conservation concepts and principles discussed in Chapter 1, section 1.1.4 and Appendix 1 of the EIS, Forest managers believe they will be able to integrate the various species’ needs as the WCS amendment process is carried out over four phases. However, the Responsible Official also recognizes that because the risk to appropriate integration is higher using a phased approach, the Forest might need to revisit in a subsequent phase direction developed under an earlier phase.


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RH18 RH19 RH20 RH21 RH22 RH23 RH24 RH25 RH26 RH27

RH18 RH19 RH20 RH21 RH22 RH23

Because of the risks described in comment RH18, objectives for whitebark pine regeneration were established in the 2003 Forest Plan (VEOB01). To help promote this objective, high priority watersheds were identified via the WCS amendment, and objectives targeted at restoring whitebark pine added to MAs that included these watersheds. A recent program emphasis on whitebark pine restoration has generated many activities, including planting seedlings genetically resistant to whitebark pine blister rust (results of 2004-2007 annual monitoring on the Boise NF in the planning record). Forestwide standard TRST01 identifies the minimum number of established trees per acre within plantations (USDA Forest Service 2003a). These numbers would not change through this amendment. Site-specific prescriptions will account for the effects of rotation age, residual trees and legacy trees on stocking rates. The DEIS states: “The use of poisons to control pocket gophers or other rodents has affected great gray owls’ prey abundance.” (DEIS, section 3.3.6.6.1, p. 193) The disclosure does not imply owls are directly killed by the poison baits, but that the prey they rely upon are less abundant because the poisons kill the prey. The Forest has developed an implementation guide for identifying ponderosa pine and western larch legacy trees. The indicators are bark, branching and crown characteristics based on Identifying Old Trees and Forests in Eastern Washington by Van Pelt (2008). Logs are discussed in the DEIS, section 3.2.4.4 (large coarse woody debris) and in section 3.3.6, as well as in Appendix 2 (Forest Plan Appendix A, Snags and Coarse Woody Debris; and Appendix E). The definition of monitoring on page 365 is consistent with why, how, when and where Forest Plan monitoring is conducted.


29

RH28

RH24 RH25 RH26 RH27 RH28

Comment acknowledged. The 2003 Forest Plan identifies a standard in MPC 1.1 (Existing Wilderness) and MPC 1.2 (Recommended Wilderness), which states “Mechanical vegetation treatments, including salvage harvest, are prohibited.” (USDA Forest Service 2003a, pp. III-82 through III-83). As disclosed in the DEIS, section 1.1.1, while Forest Plans guide site-specific project activities, decisions to implement site-specific projects are made after completing a separate environmental analysis and public involvement under NEPA. In addition, as noted under section 3.7.4.4, a slight increase in timber outputs could be realized under Alternative B (the preferred alternative), compared to Alternative A, if the amendment implemented under Alternative B helps resolve social issues regarding forest management, thereby reducing social constraints on timber management. The DEIS in section 3.5.5.2.5, “Mix of Timber Sale and Stewardship Contracting,” discusses the trade-offs of different requirements within MPCs on timber sale economics. Assumptions concerning tree losses from fire and insects are disclosed in section 3.2 and Appendix 4 of the DEIS. Both Alternatives B and C would provide opportunities to double treatment levels from that supported by current budgets, staff resources and economic situations: from 20.5 MMBF (current TSPQ) to about 40 MMBF (potential under Alternatives B and C). In light of projected budgets and economic forecasts for the remainder of this planning period (3-8 years), considering an alternative that accelerates treatment levels by more than double was not considered realistic or necessary.


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GJ1 GJ2 GJ3 GJ4 GJ5 GJ6 GJ7

GJ1 GJ2 GJ3 GJ4 GJ5 GJ6

The Forest’s 1956 - 2008 fire occurrence database was used to develop wildfire profiles for the VDDT modeling in order to account for the stochastic influences of wildfire over time and the effect on vegetative conditions and wildlife habitat (DEIS, section 3.2.3.4). The DEIS in section 3.2.5.7.1 displays the acres of modeled wildfire and relationship to recent fire seasons. Appendix 4 and section 3.2 of the DEIS (Effects of Wildland Fire) provides additional detail on how fire was represented. Findings from the amendment will be used to facilitate fire suppression decisions through the Wildland Fire Decision Support System (WFDSS). Comment acknowledged. The Forest has developed a “key points” document accompanying the FEIS in an attempt to simplify and clarify key content while retaining technical accuracy. The term “old forest” habitat was derived from the ICBEMP. The term is intended to differentiate the condition from broadly defined stages such as “overmature,” of which “old forest” would be a subset. Also, commonly used terms such as “overmature” also come with varied interpretations; they are often applied differently between and among agencies and the public. The FEIS in section 3.1.7 includes a detailed discussion of the rationale for evaluating “old forest habitat.” One of the criteria for establishing attributes to characterize old-forest habitat is that the attributes had to be elements collected during stand examination or forest inventory so no assessment costs would be incurred. The Forest is updating the inventory and building a database in order to establish the vegetation baseline, including old-forest habitat. This assessment is anticipated to be completed by the end of 2010. Comment acknowledged. Comment acknowledged.


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GJ8 GJ9 GJ10 GJ11 GJ12 GJ13 GJ14 GJ15

GJ7 GJ8 GJ9 GJ10

Hann et al. 1997 found that throughout western North American, ponderosa pine and western larch have been intensively harvested because of their high value as wood products and firewood. Wisdom et al. 2000 identified that these tree species also are two of the most widespread and valuable species for a suite of vertebrates of conservation concern. Bull et al. 1997 found that many species of cavity-using wildlife rely on ponderosa pine and western larch snags because they provide some of the most suitable nest and roost sites, owing to characteristics of the wood and its decay patterns. The science reflected in these publications, which were cited in the DEIS, were used in developing the WCS and associated Forest Plan amendments. Site-specific silvicultural prescriptions will consider how to address trees infected with disease during restoration activities. Decisions on removing or leaving these trees will depend on both short- and long-term restoration objectives. If leaving diseased trees would impede achievement of the short- and/or long-term objectives, they would be addressed during treatments to insure they did not result in unintended effects. Insects and their effects on vegetation and subsequently wildlife habitat were included as part of the VDDT modeling (DEIS, sections 3.2.3.4 and 3.2.5.7; Appendix 4, section 3.3). The effects of insect epidemics on vegetation management, adjacent landowners and development of management options were not part of the purpose and need of the amendment and therefore were not addressed. The Appendix A desired conditions for snags are a range with a lower and upper limit (DEIS, Appendix 2 (Forest Plan Appendix A)). Proposed amendment direction provides an upper limit for snag retention for commercial salvage sales in MPCs 4.2, 5.1 and 6.1 (suited timberlands). (DEIS, Appendix 2 (Forest Plan Chapter 3, “Common MPC Management Direction”).


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GJ11 GJ12 GJ13 GJ14 GJ15

Restoration objectives under Alternatives B or C apply to all forest acres, including those in plantations. The current conditions of these plantations, and their lack of historical legacy vegetation, will present some of the greatest challenges for restoration. Under Alternative B, most of these plantation areas, while reallocated from MPC 5.2 to 5.1, remain in the suited timber base. Removing wood products as an outcome of achieving restoration needs is still an important multiple-use objective on these acres. The DEIS discloses that biomass volumes have not been included in the estimates of Total Sale Program Quantity (TSPQ), because markets for this product are still in the development phase, and utilization is currently low and hampered by a lack of infrastructure. If an anticipated market in southwest Idaho develops in the next 5-10 years, adjustments in TSPQ, and the Allowable Sale Quantity (ASQ) as appropriate, will be made at a future date (DEIS, section 3.5.3.1, “Calculation of Total Sale Program Quantity”). Please see response to comment RH27. The amended Forest Plan would provide for fuelwood collection. The WCS and proposed amendments do not propose direction to change the current firewood collection allowances. However, proposed direction would instruct responsible officials to consider the need to address those impacts of fuelwood collection that might be affecting achievement of desired conditions, through subsequent site-specific project planning, travel planning or annual firewood program planning (DEIS, Appendix 2 (Forest Plan Chapter 3, “Common MPC Management Direction”)). Assumptions for growth modeling were developed by local and Regional vegetation management specialists and silviculturists in 2003 and updated in 2010 (DEIS, Appendix 4; project record documentation). The Forest


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recognizes the importance of ASQ and TSPQ to help the FEIS evaluate wood supplies in the timbershed. However, the Forest also believes identifying an “effective TSPQ” facilitates effects disclosures that are more realistic based on today’s economic situation and that predicted in the near future. Its purpose is to support economic disclosures in this EIS; it is not intended to imply another value or ceiling per Forest Service planning requirements and the NFMA.


34

GJ16 GJ17

GJ16 GJ17

As stated in the DEIS, the rating or “value” displayed by alternative for percentage of standard timber sale versus stewardship contracting is not intended to be absolute but to provide a relative ranking between alternatives. (DEIS, section 3.5.5.2.5) The FEIS has been updated to include two additional maps for species that should help clarify actual habitat distribution across the planning unit based on best available data and assumptions as to source habitat a species is likely to use. The first map displays “current source habitat” polygons and the second map displays fire regime acres applicable to a species, which provides an indicator of “potential” habitat acres. (FEIS, section 3.3).


35

IDPR1 IDPR2

IDPR1 IDPR2

As described in section 2.4.1.4 of the DEIS, an alternative that would have adopted the measures described was considered but eliminated from detailed study for several reasons, including the belief that developing mitigation tailored to address conflicts in a specific location, rather than trying to resolve potential conflicts with a “one-size-fits-all” Forest Plan standard or guideline. The FEIS in section 3.7.3.2 has been expanded from the DEIS to include data for snowmobiles. In addition, the limitations and caveats regarding the use of these data are now disclosed in this section.


36

IDPR3 IDPR4 IDPR5

IDPR3 IDPR4 IDPR5

The FEIS in section 3.7.3.2 has been expanded from the DEIS to include data for snowshoers. The FEIS in section 3.7.3.2 from the DEIS has been revised to include updated data for snowmobiles. In addition, the limitations and caveats regarding the use of these data are now disclosed in this section. On March 15, 2010, members of the WCS team met with Mr. Cook to clarify his concerns. During that meeting, Mr. Cook indicated that since the WCS and proposed Forest Plan amendments will not directly affect recreation use or access, he concurs with the Forest’s position that a detailed recreation analysis in the WCS EIS is not needed (project record, meeting notes). Note: The various enclosures are current and historical registration data for snowmobiles, ATVs, UTVs and motorbikes by county in Idaho.


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BJ1 BJ2 BJ3 BJ4 BJ5 BJ6 BJ7 BJ8 BJ9

BJ1 BJ2 BJ3 BJ4 BJ5 BJ6 BJ7

Section 3.2.3.2 of the DEIS describes the source information for the HRV. Though climate change was not addressed in the HRV development, this section also describes how the HRV can be a basis for addressing climate change. The DEIS notes that under Alternative B (the preferred alternative), all acres currently assigned to MPC 5.2 would be reallocated to MPC 5.1 (DEIS, section 2.4.2.2.2). MPC 5.1 would produce wood products as an outcome of achieving restoration objectives for a variety of multiple uses (DEIS, section 3.1.4). In addition, the DEIS in section 3.7.4 describes the effects of all three alternatives on local economies. See response to comment BJ2. Section 1.2 of the DEIS notes that a short-term emphasis of the WCS is restoring habitats associated with species of greatest conservation concern, such as the wolverine and white-headed woodpecker. Section 3.3 describes the effects of the alternatives on wildlife, including northern goshawk, which has taken advantage of departed landscapes. See response to comment BJ1. Section 2.4.1.2 of the DEIS describes an alternative considered but eliminated from detailed study that would reallocate low- to mid-elevation ponderosa pine forests currently assigned to passive management to active management. Most of these acres occur within IRAs. The type and extent of mechanical treatments and road building called for under active management is incompatible with the themes (Primitive or Backcountry/Restoration) to which these areas were assigned under the Idaho Roadless Rule. Appendix 2 of the DEIS details proposed Forest Plan amendments, including a new component of monitoring element 28 that would track progress of


38

BJ8 BJ9

restoration activities in priority watersheds identified in the WCS. Habitat areas for species are identified based on local and scientific information available for species and species groups as to the habitats they use and need. Habitat areas have been prioritized based on those that were identified as of greatest conservation concern (see FEIS, section 3.3.4.1.2). Based on site-specific situations during subsequent project level assessments, the Responsible Official will determine the appropriate balance between human uses in an area and the need to conserve habitat and associated species. The Responsible Official will consider a project area’s relationship to Forest Plan management prescription categories (MPCs) and their associated emphasis and requirements to identify the balance that should be promoted. For example, in MPC 3.2, which emphasizes restoration of wildlife habitat, the management emphasis would be expected to favor wildlife habitat and associated species needs where consistent with regulation. However in MPC 4.2, which emphasizes roaded recreation, the balance would tip in favor of recreation where consistent with regulation. In MPC 5.1, which emphasizes a greater diversity of multiple uses, a greater balance between uses and resource needs would be encouraged. As described in section 1.2 of the DEIS, the purpose of this project is limited to completing a comprehensive WCS for the Forest and amending the 2003 Forest Plan to integrate actions needed to implement the WCS.


39



The FEIS in section 3.1.5 notes that the effects of the proposed Forest Plan amendment on several resources, including nonnative plants and air quality, is tiered to that disclosed in the 2003 FEIS for the Forest Plan, because nonnative plants, air quality and other identified resources would not be measurably affected by either of the action alternatives analyzed in this EIS. See response to comment BJ9. The DEIS in section 1.1.1 notes that decisions to implement site-specific projects are made after completing a separate environmental analysis and public involvement under NEPA. Need #8 for this project, as described in section 1.2.2 of the DEIS, notes that wildlife habitat restoration needs to be balanced with other multiple use objectives. See response to comment BJ9. See response to comment BJ9. See responses to comments BJ9 and BJ13.


40



See response to comment BJ9. See response to comment BJ11. See response to comment BJ2. In addition, section 3.5.3.1 of the DEIS discusses biomass volumes, noting that ASQ and TSPQ will be adjusted, as appropriate, at a later date if a developing biomass market in southwest Idaho is realized. Forest Plan monitoring is funded through appropriations for inventory and monitoring (IM). In addition to IM funding, a portion of the appropriated dollars for each resource functional area are used to support monitoring of their respective program area. The Forest also coordinates with researchers and state agencies to monitor overlapping monitoring needs such as water quality, wildlife species occurrence, recreational use, etc. As noted in section 1.1.3 of the DEIS, the WCS will complement the Idaho Comprehensive Wildlife Conservation Strategy by building on the broadscale conservation needs identified in the Idaho CWCS for the Forest area. In addition, the Forest has and will continue to meet periodically with the Idaho Department of Fish and Game as the WCS is finalized and implemented. Although ICBEMP created several models, the Forest assumed this question pertains to the VDDT model. Issues related to use of the model are described in Section 3.2.3.2 of the DEIS. See response to comment BJ9.


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See response to comment BJ13. As noted in section 2.4.2.2 of the DEIS, Alternative B (the preferred alternative) includes an exemption to proposed standards concerning old forest and large snags that allows activities for protection of life and property during an emergency event. See response to comment BJ9 See response to comment BJ9. As noted in section 2.4.2.2 of the DEIS, Alternative B (the preferred alternative) includes an exemption to proposed standards concerning old forest and large snags that allows activities to meet hazardous fuel reduction objectives within WUIs. See response to comments BJ13 and 9. The planning record includes all comments received during scoping and the Forest Service responses to them. In addition, the Council on Environmental Quality (CEQ) NEPA regulations note that the “lead agency shall . . . determine the scope and the significant issues to be analyzed in depth in the environmental impact statement.” (40 CFR 1501.7(a)(2))


42

BJ31 BJ32 BJ33 BJ34 BJ35

BJ31 BJ32 BJ33 BJ34 BJ35

See response to comment BJ9. See response to comment BJ8. See response to comment BJ11. The DEIS in section 2.4.1.4 notes that an alternative that would close areas identified as suitable wolverine denning habitat to snowmobiling, helicopter skiing and other forms of intensive use during the winter recreation period was considered but eliminated from detailed study, in part because finer-scale investigations are needed. The DEIS in section 2.4.1.6 notes that a current Forest Plan standard (TEST34) that specifies no net increase in groomed or designated over-the-snow routes or play areas is still appropriate and needed to address suitable habitat conditions for the lynx. In addition, the DEIS in section 2.4.2.2 notes that Alternative B (the preferred alternative) was updated to include priorities for future investigations of potential wolverine and human conflicts – an effort similar to that supported by the Idaho State Snowmobile Association.


43

BJ36 BJ37 BJ38

BJ36 BJ37 BJ38

The habitat assessments summarized and disclosed in section 3.3 of the DEIS do include habitat available in IRAs. These areas typically fall within MPCs 1.1, 1.2, 3.1, 4.1a and 4.1c, which are sometime referred to collectively as “passive management areas.” Proposed amendments do not change the current allowances for motorized over snow recreation in the planning unit, including IRAs. Proposed amendments identify areas where there may be potential conflicts between winter recreation uses and wildlife so that subsequent, more detailed, site-specific assessments can be completed to determine if an actual conflict exists that should be addressed through mitigation (DEIS, Appendix 2, “Management Area Direction;” Appendix 3). However, before any mitigation could be applied other than in an emergency situation, subsequent NEPA analysis and decision must be completed before it can be implemented. The DEIS in section 2.4.1.5 notes that an alternative that would, in part, add management direction to prohibit trapping was considered but eliminated from detailed study for several reasons, including the fact that the State of Idaho regulates trapping; the Forest Service does not have the authority to prohibit trapping within priority wolverine habitat areas on the Forest.


44

FS1 FS2

FS1 FS2

On December 8, 2008, a corrected Notice of Intent (NOI) to Prepare an EIS for the WCS was published in the Federal Register. This NOI noted that one EIS was to be prepared to disclose the environmental effects of proposed nonsignificant amendments to the three Southwest Idaho Ecogroup (SWIE) 2003 Land and Resource Management Plans (Forest Plans) [Boise, Payette and Sawtooth NFs]. However, a second corrected NOI was published in the Federal Register on April 22, 2009. This second corrected NOI noted that three EISs will be prepared (one for each Forest) instead of one EIS addressing all three Forests. As noted in section 1.1 of the DEIS, this EIS addresses proposed changes in land and resource management direction for the Boise National Forest.


45

FS3 FS4 FS5

FS3 FS4 FS5

As noted in section 1.1 of the DEIS, this EIS addresses proposed Boise Forest Plan amendments for Phase 1: Forested Biological Communities. Subsequent phases and corresponding analyses will be addressed at a later time. See response to comments FS1 and FS3. See response to comments FS1 and FS3.


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47

LJH1 LJH2 LJH3 LJH4 LJH5 LJH6

LJH1 LJH2 LJH3 LJH4 LJH5 LJH6

Comment acknowledged. The effects of Alternative A are disclosed in Chapter 3 of the DEIS. A March 2009 update on the WCS, published on the Forest’s website (www.fs.fed.us/r4/boise) noted that the vegetation “baseline” was updated to reflect the results of the fires (project record). The updated baseline indicated that acres of grass and shrubs increased and acres of large trees decreased only slightly. The greatest change occurred in dense stands of small lodgepole pine and spruce-fir. Section 1.1.3 of the DEIS notes that the WCS and associated Forest Plan amendments rely on this updated baseline. Need #8 for this project, as described in section 1.2.2 of the DEIS, notes that wildlife habitat restoration needs to be balanced with other multiple use objectives. The DEIS in section 1.2 notes that a short-term emphasis of the WCS is restoring habitats associated with species of greatest conservation concern, such as the wolverine and white-headed woodpecker. The effects of the proposed Forest Plan amendments on wildlife are disclosed in the EIS in Chapter 3, and on fish, in Appendix 5. See response to comment LJH3. See response to comment LJH3.

http://www.fs.fed.us/r4/boise�

Documents

Appendix 7 Responses to Comments on the DEISa123.g.akamai.net/7/123/11558/abc123/forestservic...ISSA3 . An alternative that would delete Forest-wide standard TEST34 was considered