Appendix F: Response to Public Commentsa123.g.akamai.net/.../11558/www/nepa/2043_FSPLT2_375374.pdf · Appendix F: Response to Public Comments_____ The Notice of Availability for the

Longleaf Ecosystem Restoration Project Final Talladega National Forest – Oakmulgee District Environmental Impact Statement

Appendix F Page 1 of 26

Appendix F: Response to Public Comments________

The Notice of Availability for the Longleaf Ecosystem Restoration Project was published in the Federal Register on July 30, 2004. During the dates, 135 copies were mailed to 104 recipients. A public meeting to discuss the DEIS was held in Brent, Alabama on August, 26, 2004. Mailing lists and meeting notes are on file at the Oakmulgee District office. During this review and comment period seven comment documents were received. This appendix displays the public comments received and provides the Forest Service’s response to those comments. Following 40 CFR Section 1503.4, Forest Service (Oakmulgee District resource specialists and program area specialists for the National Forests in Alabama) have analyzed and carefully considered all public comments received during the review period for the DEIS. They, the Forest Service, have determined that there were no substantive comments expressing concerns; that most of the comments were supportive in nature; and none of the comments resulted in a change to the preferred alternative. Analysis of Public Comments: All letters, emails, faxes, and comment forms received as public comment on the DEIS were compiled, organized, read, and analyzed by resource specialists located on the Talladega National Forest – Oakmulgee District and the Supervisor’s Office for the National Forests in Alabama. These specialists used a process known as “content analysis” which allows a systematic review of public comment through the development and use of a database tracking the commenter, and comment topic. The specialist have read all public responses in their entirety and identified discrete comments within these responses. They have related each discrete comment to a particular concern, resource consideration, or proposed management action. Every effort was made to keep each comment within sufficient context that it is a stand-alone statement. The specialists looked for not only each action or change requested by the public, but also the reason(s) behind each request in order to capture the full argument of each comment. Therefore, paragraphs within a response letter may be divided into several comments because of multiple arguments are presented, or alternatively, several paragraphs that form one coherent statement may be coded into one comment. While simple statements of opinion without rationale are captured in the process and entered into the database, it is the strength of each rationale as a complete argument that provides the specialist with basis to develop their response. Summary of Public Comments:

Figure: F-1 Summary of Comment Letters and Topics for Response Comment

Letter Number

Name of

Respondent(s)

Comment Topic for

Response: I James Moffet 1. Federally Listed vs. Lesser viability concern species.

2. Botanical survey protocols-methodology, scope, data,



recommendations, and recognition of surveyors II Larry Ford 1. Forest health

2. Timber Harvest-Economic benefits to community 3. Use of Herbicides

III Gregory Hogue 1. Alternative B 2. Biodiversity conservation “mitigation” strategies 3. Soil erosion/Water Quality in T&E Habitat 4. Use of Herbicides 5. Migratory birds

IV Heinz J. Mueller 1. Alternative D 2. Water Quality-Affonee Watershed 3. Effectiveness Monitoring 4. Lack of Objections rating-

V Alvin R. Diamond, et al

1. Botanical survey protocols-methodology, scope, data, recommendations, and recognition of surveyors

VI Keith Tassin 1. DFC for entire forest 2. Alternative F 3. Ecological Monitoring 4. Stocking 5. KBDI (prescribed fire) 6. Standard #20 7. Use of Herbicides 8. Biodiversity of ground cover-Herbicide& Fire research

VII Eric Spadgenske 1. Prescribed Fire Frequency 2. Dead wood and snags 3. RCW foraging and woodland restoration 4. Basal area reduction-<12”DBH stands 5. Seedling stocking rates, survival and understory condition 6. Seed source diversity – natural regeneration 7. Basal area reduction-.14”DBH stands 8. Fire in hardwood inclusions 9. District remaining acres 10. P.32 – Alternative C-less burning 11. P. 34 – low impact harvests 12. P 41 – prescribed fire-KBDI 13. P. 59 – use of herbicides-release 14. P. 60 – low impact harvest-roads 15. P. 64 – references in Chapter 1 16. P. 100 – natural regeneration 17. P. 100 – loblolly stands -RCW



Response to Comments: Federally Listed vs. Lesser viability concern species I-1: Public Concern: The use of the term PETS in Appendix B is inappropriate because

the species referred to are “Locally Rare” or species of lesser concern.

Response: Confusion corrected. The terms PETS often refers to those species that are federally listed as Proposed, Endangered, and Threatened and those species on the Regional Forester’s Sensitive Species list and locally rare species. The distinction between Proposed, Endangered, and Threatened species; and Sensitive species and species of lesser concern is included in the Biological Assessment (BA) in Appendix B and the Biological Evaluation (BE) in Appendix C of the FEIS, respectively. The BE specifically addresses those species listed on the Regional Forester’s Sensitive Species and locally rare species. The BA addresses federally Proposed, Endangered, or Threatened (PET) species. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Botanical survey protocols I-2 and V-1: Public Concern: The discussion of botanical surveys does not include

methodology, scope, recommendations, or recognition of surveyors.

Response: The methodology, scope, and credentials of the botanical surveyors were administrative decisions made by the Forest Botanist during the development and execution of the contracts and partnership agreements. It is not within the scope of a NEPA document to evaluate and comment on the credentials of the surveyors. However, appropriate discussion and documentation of these surveys are included in the Biological Evaluation (BE) in Appendix C of the FEIS. Additional discussion of these surveys is provided in Chapter 3, Section 4 – Understory Vegetation of the FEIS. The actual survey reports are on file at the Oakmulgee District office. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Forest Health II-1: Public Concern: National forests should be managed to provide healthy forests

for multiple benefits.

Response: Thank you for your comment. Project goals and objectives are consistent with healthy forest management. National forests management policy is established at a national level and is not within the scope of this NEPA decision. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.



Timber Harvesting II-2: Public Concern: Timber harvesting provides economic benefits to the

community in terms of money and jobs.

Response: Thank you for your comment. The economic comparison of alternatives relative to returns from timber harvesting is located in Chapter 3, Section 11 of the FEIS. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Use of Herbicides II-3, III-4, VI-7 and VII-13: Public Concern: Herbicides are an environmentally safe

tool for use in eliminating undesirable species. Herbicide application should be directed to undesirable vegetation, should consider varied effects, and should be bounded by common sense constraints.

Response: Thank you for your comment. Forest-wide standards for the use of herbicides are listed in FEIS Chapter2 – Management Standards Common to All Alternatives. These standards were developed based on scientific review and years of experience in applied management. Analysis of this subject is provided in FEIS Chapter 3, Section 3 – Overstory Vegetation, Chapter 3 Section 4 – Understory Vegetation, and the Appendix D provides sample of contract specifications for herbicide use. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Recommendation of Alternatives III-1, IV-1, VI-2, and VII-10: Public Concern: Support for a specific Alternative.

Response: The District Ranger reviewed all alternatives, as well as public comments, and utilizing the Decision Framework listed in Chapter 1 of the FEIS selected the Preferred Alternative. The rational for this decision is listed in the Record of Decision. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Mitigation for biodiversity III-2: Public Concern: Alternatives should develop biodiversity conservation

“mitigation” strategies.

Response: The premise of the Longleaf Ecosystem Restoration Project is that biodiversity will be best conserved when native species are restored to their appropriate sites and natural disturbance regimes such as fire are re-established. Chapter 2, Standards Common to All Alternatives provide management direction associated with streamside management zones, riparian, areas, rare communities, and Proposed,



Endangered, Threatened, and Regional Forester’s Sensitive Species. These standards along with the project goals and objectives serve as a means to mitigate and conserve biodiversity relative to the affected ecosystems. Various sections in Chapter 3 of the FEIS also address the affects relative to biodiversity. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Soil erosion/Water Quality in T & E Habitat III-3: Public Concern: Soil erosion control measures should be strictly followed in

areas known to support sensitive, candidate, threatened, and/or endangered species. Water quality should be protected, particularly in wet areas supporting habitat for the endangered Mitchell’s satyr butterfly (Neonympha mitchellii). Response: Thank you for your comment. Standards that are common to all action alternatives (Chapter 2, FEIS), including those relative to soil and water conservation, will be followed during Project implementation. The effects of this implementation to Mitchell’s satyr habitat are addressed in the Biological Assessment (Appendix B), with the determination that the preferred alternative is “not likely to adversely affect” the Mitchell’s satyr. The U.S. Fish and Wildlife Service has concurred with this determination. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Migratory birds III-5: Public Concern: The Forest Service should develop robust effects analysis

relative to migratory birds. Response: Species that would be affected by the proposed treatments are summarized in the FEIS Chapter 3, Section 5, through the use and analysis of Management Indicator Species (MIS). Two migratory bird MIS are analyzed, the prairie warbler and hooded warbler. Prairie warbler is associated with open-canopy, early seral habitat types and is commonly found in association with other neotropical migrants in this physiographical province such as Yellow-breasted chat, White-eyed vireo, Indigo bunting, Blue grosbeak, and Eastern wood-peewee. The preferred habitats of these species are expected to increase with all action alternatives. Hooded warbler is associated with riparian hardwood and mixed hardwood-pine stands with dense shrub layers, and is commonly found in association with migratory species such as Acadian flycatcher. These areas are not the target of this Project and population trends should not change significantly for these species in the long term (Section 3.5.4, FEIS).

Other migratory bird species would potentially be affected to some extent by the proposed actions, some of which may benefit and others of which may not. Field research (including studies conducted by Dr. Geoffrey Hill, Auburn University, Alabama) has suggested that open, fire-maintained longleaf stands provide greater



avian diversity than do dense loblolly stands in the same area. Several Partners in Flight (PIF) “priority” species require habitats that will be provided by the District’s desired future conditions, which this project will help to establish. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Water Quality in Affonee Creek Watershed IV-2 and IV-3: Public Concern: Soil erosion control measures should be strictly

followed including BMPs, and SMZs. Water quality should be protected, particularly Affonee Creek Watershed.

Response: Thank you for your comment. Forest-wide standards for watershed management are listed in FEIS Chapter2 – Management Standards Common to All Alternatives. These standards were developed to ensure that all projects comply with the requirement of the Clean Water Act. In addition, Chapter 3 Sections 1 and 2 of the FEIS provide analysis on the effects of the alternatives on soil productivity and water quality. The analysis in the Water Quality Section (3.2) concludes that there are no significant potential impacts to any of the watershed in the analysis area by any Alternative. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Lack of Objections IV-4: Public Concern: We rate proposed project as LO - Lack of Objection, provided

mitigation measures and monitoring programs, as described in the Draft EIS, are implemented. Response: No response necessary.

Remaining District Needs VI-1 and VII-9: Public Concern: A plan to address the remainder of the District needs

to be developed and implemented as soon as is practical.

Response: Thank you for your comments. Although this comment is not specific to this action but rather to future projects, it is evident from these comments that tremendous support exists for restoration of the longleaf ecosystem on the Oakmulgee district. This FEIS does not attempt to address all the longleaf restoration needs on the District. It is a strategic first step that attempts to balance restoration needs with the health risks associated with non-native conditions and the need to provide a flow and distribution of longleaf habitat within various age classes and conditions. The remaining restoration needs will be addressed through a variety of processes, some of which are already underway on projects outside the Longleaf Ecosystem Restoration Project area.

Ecological Monitoring VI-3: Public Concern: Ecological monitoring and documentation of treatments will be

crucial to drive the adaptive management process.



Response: Monitoring direction is given by the Revised Land and Resource Management Plan and is included in the Project. Project level monitoring is also addressed in Chapter 3 within each subject matter section. Monitoring will be an important part of the restoration pathway and, is expected to play a critical role in order to apply sound management techniques that will facilitate the restoration process. The District is actively working with partners to include public participation in the monitoring process. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Stocking and competition VI-4 and VII-5: Public Concern: Initial stocking levels should be lower because of

high survival rates and to develop and maintain herbaceous understory.

Response: Two of the specific goals (Chapter 1, FEIS) for this project are to manage the upland longleaf pine ecosystem to provide the desired composition, structure and function, and to re-establish a prescribed fire regime sufficient to restore and maintain the fire dependent longleaf community. The initial stocking levels listed in the alternatives provided the basis for consistent analysis of effects. Actual planting densities may vary from site to site depending on conditions, existing longleaf seed trees and/or natural regeneration, and opportunities for prescribed fire. Guidelines for understory conditions as found in the RCW Recovery Plan will serve as a touchstone for management actions. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

KBDI Critical Values VI-5 and VII-12: Public Concern: What is the critical limit on KBDI values?

Response: The Keetch-Byrum Drought Index is based on a measurement of 8 inches (0.2m) of available moisture in the upper soil layers that can be used by vegetation for evapotranspiration. The index measure is in hundredths (0.01) of an inch of water and has a range of 0 through 800, with 0 being saturated and 800 representing the worst drought condition. The Forest Service’s Southern Region has established acceptable Keetch-Byrum Drought Index (KBDI) parameters of 300 for fuel reduction burns and 450 for RCW and growing season burns. However, a variety of parameters are considered for each burn prescription, including fuel moisture, temperature, relative humidity, wind speed, wind direction, and mixing height. The KBDI parameters, and the authorities to grant exceptions, are set at the regional and forest level and thus are outside the scope of this FEIS document. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.



Standard Number 20 (Forest Wide Standard 42) VI-6: Public Concern: Lack of understanding for Management Standard # 20

Response: Management Standard #20 as listed in Chapter 2 Management Standard Common to All Alternatives is actually Forest Wide Standard 42 from the Revised Forest Plan. It states, “Growing season under-burns are not allowed on the same site more than twice in succession without an intervening dormant season burn.” Forest Wide Standard 42 is a Revised Forest Plan level decision and is outside the scope of this FEIS document. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Research -Herbicides vs. Ground Cover Diversity VI-8: Public Concern: I encourage that you promote future research on the use of

herbicides vs. ground cover diversity.

Response: Thank you for your comment. Research is not a District level decision and is outside the scope of this FEIS and ROD. The Research branch of the Forest Service has responsibility for conducting environmental research, while the national forest system is charges with managing the national forests and grasslands. However, in keeping with the goals of this project ground cover diversity will be among the parameters monitored.

Prescribed Fire Frequency VII-1: Public Concern: Fire is the most important ecological process in the evolution of

longleaf pine ecosystems. Fire return intervals exceeding 3 years should only be considered when forest stands are in a “maintenance” mode. Response: The Oakmulgee District is committed to achieving the goals of this project, one of which is to re-establish a prescribed fire regime sufficient to restore and maintain the fire dependent longleaf community. The District also acknowledges that given the history of dormant season burns and lack of burning overall, it is unlikely that a “maintenance” condition will be achieved in the near future. However given restrictions such as funding, staffing, and weather, the District accepts that some areas may have a fire return interval exceeding 3 years. Emphasis will be placed on growing season burns and shorter fire return intervals especially those in close proximity to RCW cluster sites. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Dead wood and Snags VII-2: Public Concern: Efforts should be made to maintain a continuous supply of

dead, dying trees, and persistent snags throughout the management area.

Response: Thank you for your comment. Snags and trees for future potential snags will be maintained as described in Standards Common to All Alternatives (Chapter 2, FEIS).



These standards are derived from Forest-wide Standards as listed in the Revised Forest Plan. Forest-wide Standards #2, #4, and #107 were developed to provide for sufficient snags and den trees across the Forest. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

RCW foraging and woodland restoration VII-3 and VII-17: Public Concern: The removal of loblolly pine in many instances,

especially the larger loblolly pines would have an effect on Red-cockaded woodpeckers. Older (>66) loblolly stands, if managed correctly could provide significant RCW nesting and foraging resources for much of the time necessary to develop other younger pine stands into adequate RCW foraging habitat.

Response: The short-term effects of the preferred alternative to red-cockaded woodpeckers (RCW) is acknowledged in Chapter 3, Section 6 of the FEIS and in the Appendix B: Biological Assessment. The effects of loblolly decline on older loblolly are discussed in Chapter 3, Section3 and again relative to the RCW in Section 6 of the FEIS. The basis of these analyses is that the loblolly decline is present at sufficient levels in these older loblolly stands that it is unlikely, especially given additional stresses of drought, fire, and insect infestation, that these older trees would survive at any levels sufficient to provide RCW habitat. U.S. Fish and Wildlife Service concurrence with this premise is enclosed with Appendix B: Biological Assessment. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Stocking and competition VII-4 and VII-7: Public Concern: Residual basal area in thinning should be higher

if DBH => 14 to provide for RCW and lower if DBA <= 12 for development of herbaceous ground cover.

Response: Two of the specific goals for this project are to manage the upland longleaf pine ecosystem to provide the desired composition, structure and function, and to re-establish a prescribed fire regime sufficient to restore and maintain the fire dependent longleaf community. Actual thinning densities may vary from site to site depending on local conditions. The range of desired BA in the preferred alternative is listed as an average across all sites and as a means to consistently evaluate effects. Guidelines for understory conditions and diameter classes as found in the RCW Recovery Plan will serve as a touchstone for management actions. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.



Natural Regeneration VII-6 and VII-16: Public Concern: Based upon the fact that many stands in AOC 1

have existing longleaf pines, considerations should be made to encourage natural regeneration.

Response: FEIS, Chapter 2- Summary of Actions; states that “in areas with established longleaf, remove selected longleaf retaining patches of open park-like longleaf conditions”. This action along with prescribed fire should be sufficient to encourage natural regeneration. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Fire in Hardwood Inclusions VII 8: Public Concern: How will hardwood dominated stands be protected from fire?

Response: Hardwood stands are normally treated with backing fire that is low intensity and primarily consumes the upper layer of leaf litter. Fires will generally be ignited on the ridges, where historic lightning fires once started, and will be allowed to burn into the hardwood stands, thus replicating the natural processes that shaped this ecosystem. This response to this comment did not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

Low Impact Harvests VII-11 and VII-14: Public Concern: Consideration of low impact harvest should be

applauded. Low impact logging equipment should reduce the need for, number, and size of access roads.

Response: Thank you for your comment. Currently there are local limitations to the availability of low impact logging equipment. To select this as the only means to implement this project would greatly compromise our ability to achieve the desired results. The soil and water analysis as presented in Chapters 3, Sections 1 and 2 of the FIES concluded that with listed mitigation measures the impacts to soil and water resources from traditional logging equipment would be within acceptable limits. This response to this comment does not require additional analysis, nor has it led to the consideration of additional alternatives, additional mitigation measures, modification of mitigation measures, or the modification of the preferred alternative.

References in Chapter 1 VII-15: Public Concern: Could not locate some of the references from earlier chapters

(e.g., Loomis 1976 from Chapter 1). Response: Omission corrected.



Public Comments:































Documents

Appendix F: Response to Public Commentsa123.g.akamai.net/.../11558/www/nepa/2043_FSPLT2_375374.pdf · Appendix F: Response to Public Comments_____ The Notice of Availability for the