Clear Creek Integrated Project Environmental Assessment

United States Department of Agriculture Forest Service September 2013

Environmental Assessment

Clear Creek Integrated Project

Volume 2 Appendix D—Response to Comments

Boise National Forest Lowman Ranger Districts Boise County, Idaho

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Appendix D Response to Comments

List of Tables

Table D-1. Response to Comments for the Boise County Board of County Commissioners on the Clear Creek Integrated Project Review Environmental Assessment ............................................................................................................1

Table D-2. Response to Comments for Larry Miller, Miller Pinewood Estates, on the Clear Creek Integrated Project Review Environmental Assessment............3

Table D-3. Reponses to Comments for the Idaho Conservation League on the Clear Creek Integrated Project Review Environmental Assessment ......................5

TableD-4. Response to Comments for the Alliance for the Wild Rockies on the Clear Creek Integrated Project Review Environmental Assessment ....................19

Table D-5. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment ...................................................68

Table D-6. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment—Attachment #1—Timber Harvest Opposing Views.................................................................................................129

Table D-7. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment, Opposing Views—Attachment #3—Fuels Reductions Ineffective ...........................................................................190

Table D-8. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment Opposing Views—Attachment #4—Roads ..................................................................................................................247

Table D-9. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment—Opposing Views—Attachment #9a—Glyphosate...............................................................................................295

Table D-10. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review EA Opposing Views—Attachment #11—Cohen...............399

Table D-11. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment, Opposing Views—Attachment #18—Label Directions Unsafe ...................................................................................442

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Appendix D Response to Comments

List of Acronyms and Abbreviations ARO Appeal Reviewing Officer BLM Bureau of Land Management BMP Best Management Practices BNF Boise National Forest CI Crowning Index cm Centimeters CP Conservation principle CT Commercial thin CWD Coarse woody debris DD Detrimental Disturbance DN Decision Notice EA Environmental Assessment EIS Environmental Impact Statement EPA Environmental Protection Agency ESA Endangered Species Act FEIS Final Environmental Impact Statement FONSI Finding of No Significant Impact Forest Plan Boise National Forest Land and Resource Management Plan Forest Boise National Forest FSM Forest Service Manual FY Fiscal Year GAO Government Accounting Office GRAIP Geomorphic Road Analysis and Inventory Package GTR General technical report HRV Historic range of variability HUC Hydrologic Unit Code ICBEMP Interior Columbia Basin Ecosystem Management Project IDFG Idaho Department of Fish and Game IDT Interdisciplinary Team IRA Inventoried Roadless Area MIS Management Indicator Species ML Maintenance Level MPC Management Prescription Category MVUM Motor Vehicle Use Map NCT Noncommercial thinning NEPA National Environmental Policy Act NFMA National Forest Management NFS National Forest System NMFS National Marine Fisheries Service OHV Off-highway vehicle OSV Over-snow vehicle PFA Post-fledging family area PNF Potential net value ppm Parts per million Project Clear Creek Integrated Project

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Response to Comments Appendix D

PVG Potential Vegetation Group RCA Riparian Conservation Area ROD Record of Decision ROS Recreational Opportunity Spectrum SFL Surface Flame Length SOP Standard Operating Procedure TAR Travel Analysis Report TEPCS Threatened, Endangered, Proposed, and Candidate Species TSRC Total Soil Resource Commitment USDA U.S. Department of Agriculture USFWS U.S. Fish and Wildlife Service VDT Variable Density Thin WCI Watershed Condition Indicator WCS Wildlife Conservation Strategy WUI Wildland-urban Interface

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Appendix D Response to Comments Tables

Table D-110. Response to Comments for the Boise County Board of County Commissioners on the Clear Creek Integrated Project Review Environmental Assessment

Comment Forest Service Response

BOISE COUNTY BOARD OF COUNTY COMMISSIONERS

P. 0. Box 300 July 30, 20l3

Idaho City, Idaho 83631 (208) 392-4431

FAX (208) 392-4473

Barbara M. Balding Jamie A. Anderson Vicki L. Wilkins Mary T. Prisco Chair,District 1 Commissioner District 2 Commissioner District 3 Commissioner Clerk to the Board

Ms. Nadine Hergenrider, Project Team Leader Lowman Ranger District 7359 Highway 21 Lowman, ID 83637

Dear Ms. Hergenrider,

Thank you for this opportunity to comment on the environmental assessment (EA) for the Clear Creek Integrated Project. Boise County participated in the collaborative partnership between the Forest Service and the Boise Forest Coalition in 2010 and 2011. We appreciate the consideration of their recommendations of management in developing the proposed actions for this project.

Thank you for your participation in the Boise Forest Coalition collaborative partnership and for your support in developing the recommendations for management used in development of the Proposed Action for the Clear Creek Integrated Project.

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Response to Comments Tables Appendix D


Boise County supports Alternative B as the proposed action. We support the alternative's management goals of desired species composition, particularly for early seral ponderosa pine, and structural conditions more consistent with the historical fire regimes that would develop in these patches. We agree these changes would improve resistance and resilience to disturbances that would be more consistent with their respective fire regimes. We support the integrated approach that includes improvements for transportation, recreation and aquatic habitats.

Thank you for your support. The Clear Creek Integrated Project EA identifies Alternative B as the Proposed Action. As stated on page 2-5 of the document, Alternative B was developed to meet the Project’s purpose and need and includes project design features described in EA section 2.4.4.

Thank you again for this opportunity to comment. Boise County Commissioners are in support of the proposed action and agree that the proposal responds to the purpose and needs of Boise County residents.

Sincerely,

Boise County Board of County Commissioners

Thank you again for your support.

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Table D-111. Response to Comments for Larry Miller, Miller Pinewood Estates, on the Clear Creek Integrated Project Review Environmental Assessment


LM-01

Larry Miller 618 S. Orchard Boise, ID 83705 [NOTE – the following comments were received via phone by Nadine Hergenrider, Team Leader, on July 19th and 22nd.]

Mr. Miller has a concern regarding noxious weeds both on and off private property. He isn’t familiar with the details of the proposal, so his concern at this time is not necessarily with the proposal, but is with the noxious weed situation in general.

The Agency shares Mr. Miller’s concern regarding the spread of noxious weeds. The Clear Creek Integrated Project includes Design Features NX-1 through NX-11 (EA section 2.4.4.4), developed specifically to prevent introductions of noxious weeds, or where these weeds currently exist, to avoid or minimize the spread of these weeds that might result from the activities proposed. The Forest also implements an Integrated Weed Management program forestwide, which utilizes an array of effective tools that will best meet the Forest’s responsibility for noxious weed control, while minimizing adverse effects to nontarget resources and operating within the constraints of time, money, and human resources (Black 2013).

LM-02

We also talked about the unauthorized road (UA48) that accesses the Miller Pinewood estates water system. This road is proposed to be added to the NF road system and would be gated at its junction with 562. Public motorized travel on the road would not be allowed. He agrees with this proposal and noted that they have had quite a bit of vandalism at the site in recent years.

Thank you for supporting this proposal.

LM-03

General concerns are related to water quality (Graney Creek) and vegetation in the area. His ties to the community go back to 1945. He is concerned about the noxious weed situation as well as maintaining a natural appearance to the vegetation. He agrees that there is a need to gate the road that accesses the Miller Pinewood Estates water source site.

Regarding the natural appearance of the vegetation, the vegetation management proposals under the action alternatives have been designed to implement the Forest Plan strategy, which will result in vegetative landscapes that have a more natural appearance, consistent with the landscapes

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observed historically.

As stated in EA section 1.2, “The vegetation management strategy of the Forest Plan calls for managing within the historic range of variability (HRV), using a combination of passive and active management. The strategy is based on the assumption that conditions that fall within the HRV will promote a network of habitats to support the diverse array of native and nonnative vertebrate wildlife species. … An underlying philosophy of the 2010 Forest Plan and the integrated WCS is that restoring desired vegetative conditions to within the HRV and emulating natural disturbance processes across landscapes will contribute to species conservation and recovery…” Regarding noxious weeds, please refer to the response to LM-01. Regarding the road that accesses the water source site, please refer to LM-02 (comment and response).

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Table D-112. Reponses to Comments for the Idaho Conservation League on the Clear Creek Integrated Project Review Environmental Assessment

Comm # Comment Forest Service Response

ICL-01

John Kidd, District Ranger Attn: Nadine Hergenrider, Project Leader Lowman Ranger District 7359 Highway 21 Lowman, Idaho 83637

comments- intermtn-boise- [email protected]

August 19, 2013 Re: Clear Creek Integrated Project Environmental Assessment Dear John and Nadine:

Thank you for considering our comments on the Clear Creek Integrated Project Environmental Assessment. Since 1973, the Idaho Conservation League has been Idaho’s voice for clean water, clean air and wilderness—values that are the foundation for Idaho’s extraordinary quality of life. The Idaho Conservation League works to protect these values through public education, outreach, advocacy and policy development. As Idaho's largest state-based conservation organization, we represent over 25,000 supporters who wish to see Idaho’s forests and watersheds managed sustainably and restored.

The Idaho Conservation League has appreciated the opportunity to engage in the development of this project as a member of the

Comment acknowledged

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Boise Forest Coalition. We look forward to a continuing dialogue with the Boise National Forest on this project and submit these comments for your consideration as you refine the proposal and consider alternative approaches to meet the project’s purpose and need.

ICL-02

The Idaho Conservation League supports the objectives of this project, the integrated nature of the project, and the intent to restore lower elevation dry-site forests. We strongly support efforts to reduce sediment input into streams through culvert replacement and road decommissioning, and also support the proposal to reconnect aquatic habitat, improve recreational opportunities and to reduce fire risk in the Wildland Urban Interface (WUI). We also appreciate the proposal to apply a Variable Density Thinning (VDT) approach in the mid to high elevation forests. We do have some concerns with the removal of larger diameter trees and look forward to seeing more specific prescriptions and implementation of other projects that may shed light on the proposed VDT. We also appreciate that the project avoids timber cutting roadless areas and focuses primarily on thinning, burning and maintenance treatments.

We appreciate your support of the objectives identified for the Clear Creek Integrated Project. Your concerns are addressed in the comment responses below.

ICL-03

We do have concerns about the 599 acres of timber harvest in higher elevation forests which are largely functioning appropriately and are not in clear need of restoration.

The EA does not state that the mid- to upper-elevation areas are in need of restoration. Rather, the intention of the proposed management actions is to maintain the current range of desired conditions while trending toward the development of old forest habitat components (EA section 2.4.2.1.2).

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ICL-04

As such, we encourage you to closely consider whether Alternative C may achieve the purpose and need in a timely manner. Although this alternative produces less money, it also costs far less to implement and appears to be more fiscally conservative. We feel confident that Alternative C would have a smoother pathway ahead and would reduce the potential time for project implementation.

In the decision rationale, the Responsible Official will discuss how costs of implementing the selected alternative are balanced against the achievement of the various purposes and needs identified in Chapter 1, section 1.5.

ICL-05

Finally, we encourage you to closely monitor the outcomes associated with this project and to work closely with the Boise Forest Coalition and other partners to share the results of the project.

The Forest is fully committed to working closely with the Boise Forest Coalition and other partners to share the results of this Project.

ICL-06

Once again we thank you for the opportunity to submit comments on this project. Please feel free to contact me if you have any questions or require additional information Sincerely,

Jonathan Oppenheimer John Robison Senior Conservation Associate Public Lands Director [email protected] [email protected] (208) 345-6933 (208) 345-6933x13

Thank you for your continued interest in this Project.

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mailto:[email protected]




ICL-07

Idaho Conservation League comments on the Clear Creek Integrated Project Environmental Assessment

Should vegetation maintenance and restoration treatments in the Project area be implemented, and, if so, which forested stands should be treated, and what silvicultural prescriptions and methods should be applied?

As stated above, we support the objectives of this project, the integrated nature of the project, and the intent to restore lower elevation dry-site forests and to reduce fire risk in the Wildland Urban Interface (WUI). We also appreciate the proposal to apply a Variable Density Thinning (VDT) approach in the mid to high elevation forests. We do have some concerns with the removal of larger diameter trees and look forward to seeing more specific prescriptions and implementation of other projects that may shed light on the proposed VDT. We also appreciate that the project avoids timber cutting roadless areas and focuses primarily on thinning, burning and maintenance treatments.

We appreciate your support of the objectives identified for the Clear Creek Integrated Project. Your concerns are addressed in the comment responses below.

ICL-08

We do have concerns about the 599 acres of timber harvest in higher elevation forests which are largely functioning appropriately and are not in clear need of restoration.

The EA does not state that the mid- to upper-elevation areas are in need of restoration. Rather, the intention of the proposed management actions is to maintain the current range of desired conditions while trending toward the development of old forest habitat components (EA section 2.4.2.1.2).

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ICL-09

As such, we encourage you to closely consider whether Alternative C may achieve the purpose and need in a timely manner. Although this alternative produces less money, it also costs far less to implement and appears to be more fiscally conservative. We feel confident that Alternative C would have a smoother pathway ahead and would reduce the potential time for project implementation.

In the decision rationale, the Responsible Official will discuss how costs of implementing the selected alternative are balanced against the achievement of the various purposes and needs identified in Chapter 1, section 1.5.

ICL-10

Regarding silvicultual prescriptions, we would like to see additional design features developed to ensure that all ponderosa pine, Douglas fir and Grand fir that meet legacy criteria are retained. Alternatively, the Forest Service could develop a diameter limit per stand and species based on stand data. Because the mature tree component is underrepresented across the Boise National Forest, the majority of all particularly large native trees, regardless of species, need to be protected for both wildlife and as part of the forest’s natural heritage. In addition, the Forest Plan and Wildlife Conservation Strategy highlight the value of these mature trees for wildlife. This approach is warranted throughout the entire project area, but would be particularly important if the Forest Service selects Alternative B which includes 599 acres of higher elevation stands.

Design Feature VE-4 (EA section 2.4.4.7) was established to retain all legacy ponderosa pine and legacy-like Douglas-fir trees. Grand fir does not exist within the Project area. The FEIS for the revised Forest Plan states, “…acres of forests that meet the definition of large tree size class are deficient in nearly all forest types compared to historical” (USDA Forest Service 2010b, p. 12). The FEIS continues, “…large old ponderosa pine are likely scarce” (USDA Forest Service 2010b, p. 26). The FEIS focuses on the development of large tree size class and old forest habitat, with an emphasis on restoring underrepresented seral species including ponderosa pine and western larch. The Forest Plan emphasizes retaining trees with certain characteristics (legacy or legacy-like). Overall, a key goal of the 2010 Forest Plan is to develop more stands that are in the large tree size class with old forest habitat characteristics and that provide source habitat for wildlife species such as white-headed woodpecker and flammulated owl, which use ponderosa pine forests. In the mid- to upper-elevation areas of Clear Creek, the goal is to maintain and promote Douglas-fir, which is

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the early seral species important to old forest habitat in these forested communities. The goal is not a one-size-fits-all preservation of all individual large trees or of source habitats dominated by later seral conifers, such as subalpine fir, that are abundant across large areas of the Forest (EA section 3.2; USDA Forest Service 2010b). All stands proposed for treatment that are currently in the large tree size class would remain in the large tree size class (EA section 3.2.4.1). Design Feature VE-7, which identifies diameter retention requirements by species and treatment theme, was developed to meet Purpose and Need #1 and Purpose and Need #3 (EA section 1.5).

ICL-11

A study of the characteristics of old-growth forest in the Intermountain Region38 found that Douglas fir exhibited old growth characteristics between 18” and 24” dbh, as did Ponderosa pine at 20” dbh, and as did grand fir above 24” dbh, provided that these trees were 200 years or older. We also understand that there may be some circumstances in which a diameter limit could directly conflict with the purpose and need. For example, a 20” dbh grand fir could be growing right next to a 35” dbh ponderosa pine and could compete for nutrients and serve as a ladder fuel into the canopy. The Forest Service could consider a design feature based on a 20” diameter limit that might offer additional flexibility in limited circumstances. Such an approach could give foresters the flexibility they need when they need it and old growth species the certainty that sufficient mature tree habitat would be preserved. For example, the Soda Bear Project on the Malheur

The document compiled by Hamilton (1993) describes a set of minimum qualification criteria that in combination define old-growth forests. Page 5 of Hamilton (1993) states“…the teams developed a set of minimum qualification criteria that in combination define old-growth [forests]”, not old-growth trees. Appendix E of the 2010 Forest Plan uses a similar approach for defining old forest habitat: stands that meet all the criteria contained in Table E-2 would then meet the definition of old forest habitat. Some of the Table E-2 criteria are based on trees ≥20 inches dbh However, an important attribute of old forest habitat is not captured in Table E-2—namely, legacy trees or trees with legacy-like characteristics (USDA Forest Service 2010a, Appendix E, p. E-27). Specific characteristics about these trees, not just size or age,

38 Characteristics of Old-Growth Forests in the Intermountain Region, USDA Forest Service, 1993, compiled by Ronald Hamilton.

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National Forest started with a prescription that preserved all trees with old growth characteristics and all trees 21” dbh and greater. They then incorporated a design feature that allowed for tree removal of trees greater than 21” if they were determined to be less than 150 years old. They also added a design feature to address the circumstance when a large diameter tree is competing with an even larger, more desirable tree and poses a risk to the larger tree. From the center of the larger, more desirable tree, the Forest Service established a circle equivalent to two times the diameter of the drip line. Should a less desirable tree occur within this area, it could be considered for removal. While this example may not be directly applicable here, a similar design feature might help address these concerns.

make them important for wildlife. While these types of trees are generally older and larger, not all old and/or large trees exhibit desirable characteristics. The intent of the legacy tree direction in the Forest Plan is to emphasize retention of trees with certain important ecological attributes that contribute to functional wildlife habitat conditions which cannot be captured by the stand metrics (e.g., tree size) identified in Table E-2 (USDA Forest Service 2010a).

The initial prescription for the Proposed Action for the Soda Bear Project, scoped in 2010 (USDA Forest Service 2010, Malheur National Forest), was retention of all trees ≥21 inches dbh and all trees ≥150 years old. After public comments were received, these 2 prescriptive elements were separated into 2 different alternatives: Alternative 2, based on the diameter at breast height prescription of 21 inches and Alternative 3 based on the age prescription of ≥150 years old (2011 Malheur National Forest, Soda Bear Project Environmental Analysis, Chapter 2). The Responsible Official selected Alternative 3 to be implemented, primarily using Van Pelt (2008) (January 2012 Soda Bear Project Decision Notice). Because the Malheur National Forest ended up addressing the potential conflict through 2 separate alternatives, the design feature identified in Comment ICL-11 was not carried forward; therefore, no effects analysis was done to determine whether the design feature provided the intended flexibility. Subsequently, we do not have a basis for understanding the applicability of a similar design feature to the Project area.

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ICL-12

Should the transportation system be managed within the Project area as recommended in the TAP and which road management treatments should be implemented? In terms of transportation, we support the proposed road decommissioning as proposed. We recommend that the Forest Service conduct additional watershed restoration work as part of the next scheduled project in this area. In terms of temporary roads, we do have concerns about soil disturbance, noxious weed and habitat fragmentation and request that the Forest Service ensure that the decommissioning and reclamation of these roads take place during the same season in which the roads are constructed.

Watershed restoration work is ongoing and would be considered in each future proposal in this area. In response to this comment, a new design feature, TR-12, has been added: The time between the construction and decommissioning of each temporary road shall be minimized to the extent practicable. When practical, both activities (construction and decommissioning) shall take place during the same field season.

ICL-13

Should recreation management activities in the Project area be implemented and which of the proposed trails/trailhead improvements should be implemented? Should NFS road 562 and spur roads leaving this road within the Logging Gulch Area be designated as a motorized ATV recreation trail? We support the proposed recreation management activities but are concerned by the overlap in motorized and non-motorized uses and ask that the Forest Service seek additional ways such to separate potentially conflicting uses. These methods could include the development of additional hiking trails if ecologically appropriate, seasonal closures on motorized use, or slower speeds for motorized users along these shared routes.

Alternatives B and C both address this concern directly. Currently, there is a lack of nonmotorized trail systems in the Project area. Alternatives B and C would develop new opportunities for nonmotorized recreation, including a nature trail in the Park Creek vicinity and a loop trail system designed for mountain bikes but open to all forms of nonmotorized use (EA section 1.5, Purpose and Need #5). Many of the current and proposed motorized trails are under seasonal restrictions (EA section 3.12; Design Features WI-1 and WI-2).

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ICL-14

Should culvert treatments be implemented to improve access to aquatic habitat in the Project area? As stated above, we strongly support efforts to reduce sediment input into streams through culvert replacement and road decommissioning, and also support the proposal to reconnect aquatic habitat, improve recreational opportunities. We are disappointed that the work needed to address the ford issue was not included in this project and strongly encourage the Forest Service to prioritize this project.

We appreciate your support of the proposed culvert replacement and road decommissioning, which are intended, in part, to reduce sediment to streams, reconnect aquatic habitat, and improve recreation opportunities. As identified in EA section 2.3.1, the Responsible Official considered an alternative to treat the ford crossing of Clear Creek by NFS road 545 but eliminated this alternative from detailed study. However, as stated in section 2.3.1, the District has decided to analyze treatment of the upper crossing of NFS road 545 in a separate project in the near future. Road use data collection was initiated in 2012 and will be completed in 2013. The District intends to seek funding through fisheries and recreation resources for the ford treatment.

ICL-15

What design features and/or mitigation measures should be applied to activities to mitigate undesirable effects?

Legacy trees Please see potential design features concerning legacy trees.

Design Feature VE-4 already addresses ponderosa pine and Douglas-fir as specified in the comment. Grand fir does not occur in the Clear Creek area and therefore was not included in the design feature. Refer to the response to ICL-10.

ICL-16

Goshawk protections

The Forest Service needs to ensure protections of the required alternate/replacement nest stands in addition to the existing known nest site.

Nesting habitat was assessed to determine compliance with the intent of Forest Plan Standard WIST05 and Guideline WIGU07 (refer to project record: Forest Plan Consistency documentation). The assessment is based on key habitat components and recommendations found in Reynolds et al. (1992), including the identification of alternate and replacement nesting habitat. Home ranges typically consist of nest areas, PFAs, and foraging areas. The nest area forms the core of the

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territory and is immediately surrounded by the PFA. These represent the center of activity for the pair, the area in which the fledglings spend most of their time upon leaving the nest (while learning to fly and to acquire prey), and that portion of the home range in which goshawks exhibit territorial behavior. Home ranges include a larger foraging area surrounding the core habitats. While the management recommendations were developed for southwest forests, the general concept of providing for key habitat components is applicable to central Idaho and thus was utilized in assessing compliance with the Forest standards and guideline identified above. The southwest forest management recommendations from Reynolds et al. (1992) did not take a hands-off approach, but recognized treatments may be needed to develop or maintain habitat for goshawks. One goshawk nest site has been identified in the Project area. A pair of goshawks was observed one time at the nest site in May 2007; however, young were not produced at the site that year. Subsequent monitoring has not found the nest occupied. However, the site has not been monitored every season since 2007; therefore, for the purposes of the analysis, the site was considered “active” (occupied and productive), and the standard and guideline were applicable. The nest site itself does not fall within a stand that was modeled as nesting habitat, although such a stand is near and would be part of the 30-acre area surrounding the nest. Nesting habitat was identified in the appropriate PVGs (PVGs 2–9), tree size class (large),

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stand canopy covers (40% or greater), and size (patches 30 acres or larger). These modeling parameters are based on a combination of literature review and consideration of vegetation attributes for known goshawk nesting sites elsewhere on the District. Nesting habitat in the vicinity of the known site would be reduced in the short term (2016) under the action alternatives, as would overall nesting habitat within the analysis area (1,801 acres under the action alternatives versus 2,370 acres under the No Action Alternative). Because habitat would be reduced, the availability of alternate and replacement nesting habitat became important. The assessment completed to determine compliance with the standard (WIST05) looked at the amount and location of suitable nesting habitat available to goshawk within the analysis area under the action alternatives. Suitable nesting habitat remained abundant in the short term and the long term (1,801 acres and 4,660 acres, respectively) (EA section 3.4.3.8). Location of the nesting habitat is also important, particularly if an identified PFA is present. In this case, an actual PFA has not been identified, due to the lack of observed territorial behavior. Rather, the assessment looked at the location of suitable, alternate nesting habitat in context with other source habitat (i.e., a block of approximately 600 acres that would include 90 acres of suitable nesting habitat, 90 acres of replacement nesting habitat, and an additional 420 acres of source habitat utilized during the post-fledging period). At least 5 such blocks are present in the analysis area and would continue to provide

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nesting and PFAs for goshawks following implementation of the action alternatives. Because of the post-treatment abundance of suitable and replacement nesting habitat within the analysis area (approximately 1 home range), no additional design features were needed to ensure that alternate nest sites would be available for goshawks.

ICL-17

Snags We appreciate the 10” diameter limit on snags but are concerned about the potential loss of snags due to firewood cutters. We recommend designating any particularly important snags for wildlife as no cut trees. These snags need to be monitored to ensure their continued existence.

The action alternatives did not include objectives for modifying the existing fuelwood management within the Project area. Three factors made it unnecessary to include such objectives in the Proposed Action: limitations set on fuelwood removal by existing general permit conditions and topography within the Project area, current and projected snag densities, and proposed reductions in open roads that facilitate loss of snags. No NFS lands within the project area are closed to fuelwood gathering, except as defined by general permit (i.e., RCAs, State highways, or developed sites). Travel for the purposes of fuelwood gathering is allowed off-road in areas where such travel is allowed for dispersed camping on the current MVUM. Topography prohibits off-road travel throughout much of the Project area. In addition, off-road travel is not allowed for dispersed camping (and therefore fuelwood gathering) along the main Clear Creek road (NFS road 582) from its junction with Idaho Highway 21 to NFS road 515, because dispersed camping is allowed only at designated sites. Due to the limitations on off-road travel along NFS road 582 and the natural limitations on off-road travel created by the topography in much of the remaining area, the area of impact from

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fuelwood gathering was assessed by the IDT Wildlife Biologist to be relatively narrow (150–200 feet upslope of roads and <100 feet on the downslope side). Snag densities were compared with desired densities established by the Forest Plan (EA section 3.4.2.2). Current medium snag densities (10–19.9 inches dbh) were below desired range in PVGs 2 and 4. Snag densities were within desired range for all other PVGs except PVG 8, which was above the desired range. Under the action alternatives, snag densities were projected to be within or above desired conditions for all PVGs in both the short term (2016) and the long term (2044). The model for future snag densities could not take into account the loss of snags to fuelwood gathering; however, the projections were based in part on existing snags, which reflect current fuelwood management and influence projected snag numbers into the short term (2016). The action alternatives would result in a reduction in road density. Roads facilitate the removal of snags for fuelwood; therefore, fewer roads would translate into fewer snags lost to fuelwood removal in the future. Roads open to the public during any portion of the fuelwood season (May–November) would be reduced from 1.7–1.4 mi/mi2 (EA section 3.4.2.3). Because snag densities were projected to increase and be within or above desired conditions defined for the Forest Plan and because reduced open road densities are expected to improve retention of snags, no proposal was made to modify existing fuelwood management (through signing of snags or otherwise) within the Project area.

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A new design feature (WI-9) and monitoring requirement have been added to the Final EA for both action alternatives to mitigate the effects of fuelwood collection of large snags along open roads. See EA sections 2.4.4.10 and 2.4.5.

ICL-18

RCAs The EA states that one-site potential tree height would be used for perennial streams and intermittent streams used for fish spawning, but recommend using 2 site potential tree heights for such purposes.

Site-specific field visits were made to 6 RCA locations in the Project area, covering a variety of stream types. Completed field observation forms with photos can be found in the project record. The 11 riparian functions and processes identified in Appendix B of the Forest Plan were used to delineate RCAs. The action alternatives include multiple vegetation treatments and various recreation-related and numerous road-related activities. All of these treatments and activities are located in the Lower Clear Creek 6th field HUC. No known spawning and rearing locations exist in this HUC. The only proposed action in the Upper Clear Creek 6th field HUC (spawning and rearing habitat) is road decommissioning activities. Within the Upper Clear Creek 6th field HUC, no road decommissioning is proposed near Clear Creek (designated critical bull trout habitat). Road decommissioning is proposed to occur on small tributaries not known to support bull trout populations. One site potential tree height is adequate to support riparian function and protect bull trout downstream (residing in Clear Creek) from potential effects associated with this action. Project design features will require erosion control measures that are expected to mitigate, to the extent possible, any potential negative effects.

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TableD-113. Response to Comments for the Alliance for the Wild Rockies on the Clear Creek Integrated Project Review Environmental Assessment


AWR #1

August 19, 2013 Nadine Hergenrider, Project Team Leader Lowman Ranger District 7359 Highway 21 Lowman, Idaho 83637

Transmitted via email to [email protected] This letter is comments on the Clear Creek Environmental Assessment (EA), on behalf of the Alliance for the Wild Rockies. We appreciate that the EA analyzes Alternative C, included to address the forest plan issue of “habitats in mid- to upper-elevation forests were found to be, overall, less departed from historical conditions” (EA at 1-1) along with the disclosure that areas Alternative C leaves untreated compared to Alternative B are not departed from Forest Plan desired conditions.


AWR #2

We recall that the Forest Service believed that the inclusion of commercial treatments in mid- to upper-elevation forests for Alternative B was necessary to fund aquatic and other active restoration activities included in the Clear Creek project. We had previously gone on record, both at project- and forest plan-level discussions, stating that lands logged unsustainably in the past cannot be relied upon to provide timber and thus fund restoration of those same lands. The EA’s economics analysis accords with our beliefs: despite logging less than half the commercial timber as Alternative B and including virtually the same suite of restoration activities as Alternative B, Alternative C would cost

Both action alternatives would generate a PNV revenue loss (EA section 3.14.3.3, Table 3-103). The Alternative B loss (-$215,700) is less than the loss from Alternative C (-$247,100). As disclosed, none of the alternatives is positive in regard to the financial efficiency analysis. Alternative A (-$280,800) is less costly than the action alternatives, with Alternative B (-$592,900) creating more deficit than Alternative C (-$578,500). EA section 3.14.3.3, Table 3-103, discloses the

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taxpayers less money. And the ecological risks of further timber extraction are proportional to the amount of acres affected by new logging and road building activities.

anticipated costs associated with other projects and restoration activities within the project area. Other projects and restoration expenditures associated with Alternative B would be about $1,287,400, while those costs for Alternative C would be about $1,208,800. The supplemental funding needed to fully implement Alternative B would be about $1,503,100, and for Alternative C, the funding would be about $1,455,900. Alternative A would require no supplemental funding, since none of the project activities listed in EA section 3.14.3.3, Table 3-103, would occur.

Disclosures regarding the ecological risks associated with each alternative are included in Chapter 3 of the EA. The risks are considered in detail, by alternative, for each resource addressed.

AWR #3

We support the inclusion of decommissioning of unneeded roads, the removal of fish passage barriers, the road maintenance work where resource impacts are occurring, and development of nonmotorized trails as features of the project. Such actions would improve ecological conditions and quiet recreational experiences in the project area.


AWR #4

We are less certain that there needs to be “a connected system of motorized trail riding opportunities in the Clear Creek drainage and neighboring drainages to the east” (EA at 1-11) since the EA does not demonstrate a shortage of such opportunities in the vicinity, and since the cumulative adverse impacts this type of use presents to aquatic and terrestrial wildlife habitats, the potential conflict with quiet recreation, and the impacts on wilderness values in roadless areas.

The need for a connected system of motorized trail opportunities in this area was identified during Forest Plan revision in 2003. The Forest Plan revision effort considered how best to mix the variety of recreational interests across the planning unit in a way that would be consistent with both the ROS analysis and management prescription category. Refer to EA section 1.8 (Forest Plan Direction Relative to the Project Area), section 3.12 (Recreation Resources), and section 3.16

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(Inventoried Roadless Areas). The revision of the Forest Plan in 2003 and subsequent amendments to this plan in 2010 included extensive public involvement (USDA Forest Service 2003; USDA Forest Service 2010a,b,c).

The Forest Plan, as amended in 2010, includes the following Recreation Resource objective:

Objective 1054 Evaluate and develop a plan for a motorized trail extension of the Kirkham Trail that ties into the Deadwood trail system to enhance motorized recreation opportunities.

By changing the designation of NFS road 562 from ML 1 to an NFS trail in Alternatives B and C, the Forest will be contributing to the accomplishment of Forest Plan objectives identified during Forest Plan revision in 2003. Furthering accomplishment of the objective identified above, in part, would enhance motorized recreation opportunities and extend the Kirkham Trail opportunities towards the Deadwood trail system. Utilizing the current infrastructure will also reduce resource disturbance that might otherwise occur with new trail construction (refer to the project record document concerning options considered and to EA section 3.12).

Currently, NFS road 562 is open to OHV use; designating this road as a trail will allow trail maintenance to occur. Regularly maintaining the current infrastructure will avoid or minimize potential impacts to aquatic and terrestrial habitats. In addition, these trails are closed seasonally to minimize impacts to big

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game (EA section 2.4).

The proposed Kirkham Trail reroute in the Project poses very little risk to aquatic species or WCIs (EA sections 3.6 and 3.7). Effects, including cumulative effects, of this action are expected to be minimized because the proposed activities are located on a ridge divide, no stream crossings are present, and the action is located outside the RCA. The impacts of motorized trails on wildlife are discussed in EA section 3.4.2.3, which includes an assessment of cumulative effects. The Wildlife Resource analysis also considered the conservation risks associated with motorized trails during the individual species discussions and analysis (EA section 3.4.3).

AWR #5

We are also not certain about the prescribed burning in roadless areas, since many scientific studies indicate that ecological integrity of roadless and other unmanaged lands are high as compared to roaded and managed lands.

For the low- to mid-elevation areas, we are defining ecological integrity as providing Family 1 source habitat, specifically for white-headed woodpecker, and old forest habitat (Purpose and Need 1). Current conditions within PVGs 1, 2, and 3 are departed from desired conditions (EA section 3.3.5.2.3). The prescribed burning is proposed in the IRAs to restore desirable structural conditions and connect patches within the IRA to patches outside of the IRA. Additionally, the affected IRAs are part of a bigger landscape area that must be included to safely implement the prescribed burn.

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AWR #6

We would also support elimination or replacement of the ford crossing of Clear Creek by NFS Road 545 (EA at 2-1, 2) as soon as possible, including adding that action to this project and analysis.

As identified in EA section 2.3.1, the Responsible Official considered an alternative to treat the ford crossing of Clear Creek by NFS road 545 but eliminated that alternative from detailed study. However, as stated in this section 2.3.1, the District has decided to analyze treatment of the upper crossing of NFS road 545 in a separate project in the near future. Road use data collection was initiated in 2012 and will be completed in 2013. The District intends to seek funding through fisheries and recreation resources for the ford treatment.

AWR #7

The EA does not validate of the boundaries of the roadless inventory for the project area. It appears that uninventoried roadless areas adjacent to the Inventoried Roadless Areas (IRAs) are present and that their wilderness values may be impacted by project activities. The EA does not include an evaluation of the Wilderness character of these uninventoried roadless areas. To our groups, this is a significant omission, partly because of the Forest Service policy to never change IRA boundaries (IRAs will always be analyzed in NEPA documents differently than other lands even when they are immediately adjacent and equally deserving of protection). Previous analyses, such as for the Idaho Roadless Rule, did not look to make boundary adjustments. Smaller-scale NEPA analyses such as for Clear Creek are the logical way to do this. We support Wilderness designation for the Deadwood and Red Mountain IRAs, as proposed in the Northern Rockies Ecosystem Protection Act, recently re-introduced into Congress—with due consideration for adjacent lands’ eligibility. If not with the Clear Creek EA, when and how will the Forest Service consider boundary adjustments of IRAs in this area?

The EA includes a discussion of the historic treatments and disturbances in the areas within and immediately adjacent to the Deadwood and Red Mountain IRAs; see EA sections 3.16.2 and 3.16.3, respectively. Impacts to these IRAs from the proposed activities are disclosed in the EA. The Roadless Resource Technical Report includes more detail regarding the impacts of proposed activities on wilderness qualities/attributes and roadless area characteristics. Recommendations for Wilderness designation are made at the Forest Plan level, not the project level. Under the 2010 Forest Plan, the IRAs are assigned to MPC 4.1c–Undeveloped Recreation: Maintain Unroaded Character with Allowance for Recreation Activities. As required under the Idaho Roadless Rule, the Chief of the Forest Service is the Responsible Official concerning boundary corrections or modifications. Details are stated at 36 § 294.27, Corrections and Modifications:

“Correction or modification of designations made

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Comm # Comment Forest Service Response pursuant to this subpart may occur under the following circumstances: (a) Administrative corrections. Administrative corrections

to the maps of lands identified in § 294.22(c) include, but are not limited to, adjustments that remedy clerical errors, typographical errors, mapping errors, or improvements in mapping technology. The Chief may issue administrative corrections after a 30-day public notice and opportunity to comment.

(b) Modifications. The Chief may add to, remove from, or modify the designations and management classifications listed in § 294.29 based on changed circumstances or public need. The Chief shall provide at least a 45-day public notice and opportunity to comment for all modifications.”

AWR #8

Also, the EA does not provide rationale for adding unauthorized road UA27 (0.3 mi.) to the road system, adjacent to an IRA boundary.

UA27 (0.32 miles) is not currently in the database as a system road; however, on-the-ground UA27 appears to be the last segment of NFS 582E. Another segment (0.31 miles) identified as the end of 582E in the database is proposed for decommissioning. On the ground, this segment appears to be a spur of 582E, rather than part of the main road. The notes in Table 14 of the Clear Creek Travel Analysis Report (2013) state that UA27 is “where the road actually is,” referring to NFS road 582E (also known as the Cup Creek road).

AWR #9

The EA mentions summer homes on national forest land in the project area that are managed under a special use permit. Following the defensible space treatments around the summer homes to be carried out under this project, how would the Forest Service insure that treatments are maintained in future years as trees and other vegetation re-grow in these same home ignitions zones? Also, the EA does not disclose if defensible space treatments have been done for the homes in the private

Long Creek Summer Homes: The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the

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subdivision Miller’s Pinewood Estates that this project is to help protect.

homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component. Following proposed treatments in the low- to mid-elevation areas, including identified WUI areas, “treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means” (EA section 3.3.5.2.2). Miller-Pinewood Estates: The Project area boundary was defined by the subwatershed boundary, which encompasses a portion of the Miller Pinewood Estates. The residents of Miller Pinewood Estates were invited to participate in the coalition, by the Boise Forest Coalition, but chose not to actively participate. The lands within the Miller Pinewood Estates are privately owned; therefore, the landowners are required to provide defensible space, through implementation of vegetation treatments and/or modification of structure materials. Information on funding and treatment options for the Miller Pinewood Estates homeowners and landowners can be found through the Idaho Lands Resource Coordinating Council, the Idaho State Forest

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Action Plan (http://www.forestactionplans.org/states/idaho), and Idaho Firewise (http://www.idahofirewise.org/). To date, some landowners within the Miller Pinewood Estates have addressed defensible space needs, while others have not yet completed this work.

The Project is focused on reducing the fire behavior in and around the WUI, as described in Purpose and Need 2: “Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas” (EA section 1.5). Furthermore, section 3.3.1 states the following: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.” EA section 3.3.4.1.1 states, “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory. This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the

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http://www.forestactionplans.org/states/idaho

http://www.idahofirewise.org/



stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” EA section 3.3.5.2.4 states that treatments as proposed would result in “the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” Also, “These more open-crowned stands also increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire

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approaches the WUI areas” as described in section 3.3.4.1.1.

AWR #10

Further following up on the issue of Alternative B’s proposed logging of habitats in mid- to upper-elevation forests not departed from historical conditions, and the EA’s characterizing this as “maintenance treatments”, we note there are no scientific references cited in the EA that validate the assumption that such treatments would somehow increase resistance or resilience—in ecological terms. Indeed, the EA indicates that “Modeling illustrates that some benefits of the restorative treatments are not realized until 40 or more years beyond implementation.” (3-96.)

The EA, section 1.5, Purpose and Need #3, states that conditions as they relate to the fire regime are not departed, and we do not identify that treatments would increase resilience and resistance. In the discussion of landscape patch and pattern (EA section 3.2.5), maintenance was defined as maintaining or increasing Douglas-fir, which is an important earlier seral species of the old forest habitat within the mixed2 fire regime.

Treatments within the mid to upper elevations are designed to emulate disturbance regimes, as identified in EA section 3.2.1.2.2. Given the recent beetle outbreaks within the project area (2011 aerial detection), the treatments were designed to capture the pattern of such disturbance events.

AWR #11

The EA indicates that the Travel Analysis Process (2012) recommended changes to the road and trail system. It is not clear that this has led to the Alternatives including the minimum travel system needed to manage the forest in the project area in an ecologically sustainable manner. There is no economics analysis in the EA that estimates the annual maintenance costs of the resulting system and compares those costs to expected annual budgets for the same. The ecological impacts of an under-maintained travel system are not disclosed in the EA.

The Clear Creek Watershed TAR identified a recommended road system and the annual road maintenance cost associated with the recommended road system. Annual road maintenance costs for the road system in the Clear Creek watershed could be reduced 13% from the current estimated cost of $171,505, down to the future estimated cost of $149,340, if recommendations were implemented. The TAR will be posted on the project Web site to provide access to this information.

The Project proposed transportation treatments that would implement many actions needed to achieve the recommended road system identified in the Travel

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Analysis Report. Some recommendations from the Clear Creek watershed TAR would not be implemented as part of the Project because they address areas outside of the Project area.

See Purpose and Need #4 for a discussion related to the transportation activities and the recommended road systems (EA section 1.5); also see the Transportation System discussion in EA section 3.11. Project area road maintenance costs for the 3 alternatives are discussed in EA section 3.11.3.1; a cost reduction of $4,855 would occur under Alternatives B and C.

The TAR documents the risk assessment associated with each road segment that influenced the generation of the recommended road system. The ecological effects, positive and negative, of proposed road-related activities are disclosed in the various resource sections, including the following:

• Effects to wildlife species, section 3.4 • Effects to hydrologic resources, section 3.6 • Effects to fisheries, section 3.7 • Effects to soils TSRC and DD, section 3.8

AWR #12

The action alternatives would result in trees >20” dbh (other than ponderosa pine) being logged. Given the acknowledged paucity of large trees on the landscape, this seems to be in excess of—and contradictory to—meeting ecological goals. We appreciate that the Boise NF is willing to monitor the achievement of species composition, etc. goals comparing the use of the EA’s methodology vs. diameter limits under the Emmett District’s Scriver project, but the jury will still be out on

The FEIS for the revised Forest Plan states “…acres of forests that meet the definition of large tree size class are deficient in nearly all forest types compared to historical” (USDA Forest Service 2010b, p. 12). The FEIS continues “…large old ponderosa pine are likely scarce” (USDA Forest Service 2010b, p. 26). The FEIS focuses on developing the large tree size class and old forest habitat, with an emphasis on restoring

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the results of that study long after you plan to make the Clear Creek decision. We believe that setting more conservative diameter limits works towards building trust that the Forest Service is committed to addressing the need to maintain large trees on the landscape to compensate for losses of large trees from past management.

underrepresented seral species including ponderosa pine and western larch. The Forest Plan emphasizes retaining trees with certain characteristics (legacy or legacy-like). Overall, the goal of the Forest Plan is to develop more stands that are in the large tree size class with old forest habitat characteristics and that provide source habitat for wildlife species such as white-headed woodpecker and flammulated owl, which use ponderosa pine forests. In the mid- to upper-elevation areas of Clear Creek, the goal is to maintain and promote Douglas-fir, which is the early seral species important to old forest habitat in these forested communities. The goal is not a one-size-fits-all preservation of all individual large trees or of source habitats dominated by later seral conifers, such as subalpine fir, that are abundant across large areas of the Forest. All stands proposed for treatment that are currently in the large tree size class would remain in the large tree size class (EA sections 3.2.4.1). EA section 3.2.4.1 discusses the effects of the alternatives on large tree size class. EA section 3.4.2 discusses the effects on old forest habitat and large-tree habitat. As disclosed, Design Feature VE-7 requires the maintenance of all trees >20 inches dbh in the low- to mid-elevation treatment areas; this design feature is common to both action alternatives. Under Alternative B only, maintenance treatments in the mid- to upper-elevations allow for removal of later seral species when removal is necessary to promote the maintenance or recruitment of Douglas-fir, as described above. Also refer to EA section 3.2.2 for discussions concerning tree size classes affected by the different

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prescriptions to be applied.

AWR #13

We are concerned that the inclusion of mechanical treatment and prescribed burning of activity fuels in Riparian Conservation Areas (RCAs) risks riparian, aquatic, and bull trout habitat. Whereas there is a track record of monitoring INFISH under the PACFISH/INFISH Biological Opinion, the aquatic strategy of the Boise NF’s forest plan is more lax in this regard than the INFISH amendment it replaced. We also believe you need to formally consult on PACFISH/INFISH on bull trout critical habitat since bull trout critical habitat was designated after PACFISH/INFISH was adopted. This should be a programmatic consultation across bull trout critical habitat. We don’t believe the potential additional “take” has been adequately considered, nor would it be consistent with the best science. Do you have a take permit for bull trout for this project? If not please get one from the U.S. FWS. Also, “Riparian corridors are used extensively by fisher”, which is a Sensitive species likely extirpated from the project area by past management.

Regarding bull trout and their habitat, the Biological Assessment for the Clear Creek Integrated Project analysis assigned a “not likely to adversely affect” determination to all activities except for the Big Spruce Creek culvert removal and replacement activities. The noncommercial thinning and prescribed burning component within the RCA is occurring in lower Clear Creek (outside of known spawning and rearing habitat). This habitat is used as a bull trout migratory corridor. These proposed activities are not expected to interfere with pre- or post-migrating fish (see section 3.7.2.2.1 for rationale). Project design features (WF-7, FF-1, FF-4, and FF-5) would mitigate potential impacts associated with the proposed activities. A species would not be considered extirpated from the project area unless some evidence exists that the species occupied the area historically. IDFG’s element database did not contain any records (current or historical) of fisher in the Project area, nor have fisher been detected during survey work conducted by the Forest Service. A recent review of fisher in Idaho (IDFG 2010a) indicated that the Forest is at the southern edge of the species’ range in Idaho. Observations are rare, and in the Project area, no observations have been recorded. The Wildlife Technical Report discusses affected fisher habitat in riparian corridors and notes that no ‘discrete’ stand examination data are available for riparian corridors (i.e., riparian areas generally included as part

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of a larger stand with adjacent upland vegetation). Effects to RCAs are discussed qualitatively in the technical report. These discussions also appear in EA section 3.4.3.5. Further clarifications will be made to this section of the EA to more fully address this comment.

AWR #14

At p. 2-18, the EA states that some sediment/road problems would be addressed “whenever funding becomes available.” We understand the scarcity of funding for road maintenance but do not understand why the Forest Service is proposing a later Decision Memo when funding does become available. (Id.) That would seem to result in more analysis and process, whereas this EA should provide all the maintenance analysis needed to include those actions in this project Decision.

All maintenance needs are included in each action alternative. However, footnote 36 of the EA states the following: “All 59 sites tied to sediment road problems occur on Maintenance Level 2 and 3 roads. The actions needed to eliminate or reduce the sediment input to the streams fall under the group of activities considered road maintenance. Under Alternative B, 36 of these sites would be addressed through maintenance activities in support of commercial vegetation treatments or through the Forest’s standard road maintenance program; under Alternative C, 33 sites would be addressed in this manner. The remaining 23 sites under Alternative B and 26 sites under Alternative C would be addressed as part of the Forest’s standard road maintenance program whenever funding becomes available. These maintenance actions fall under Categorical Exclusion 36 CFR 220.6(d)(4) and do not require authorization through this Decision Notice/FONSI, and thus may be implemented before, during, or after actions authorized in this DN/FONSI” … without further NEPA analysis.

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AWR #15

Given the threats posed to whitebark pine given likely climate change scenarios and indirect affects of fire suppression, the should not just be avoided only when “practicable” (2-28). This is a species that warrants listing under the ESA.

Whitebark pine is a Candidate species for listing under the Endangered Species Act due to a rangewide decline in this “keystone” species. Many factors, including climate change and past fire management strategies, have contributed to the decline of whitebark pine (EA section 3.9.2.1). The Forest is committed to restoring and maintaining whitebark pine populations (USDA Forest Service 2010a, VEGO06 and VEOB01). Dead whitebark pine trees are also valuable for wildlife, erosion control, soil fertility, and aesthetic reasons. No activities are proposed in the areas of known concentrated whitebark pine occurrence. While whitebark pine may occur incidentally in the vegetation types where activities are proposed (as described in the Botanical Technical Report and Biological Evaluation, page 43), The Forest Plan directs that “trace” species should be retained where they are found, particularly species in decline, including whitebark pine (USDA Forest Service 2010a, Appendix A, p. A-9).

Design Feature RP-3 is in place to ensure protection of whitebark pine in the Project activity areas. Forest crews are trained to recognize the species and will use a mark-and-avoid strategy to protect whitebark pines within activity areas. The reference to retention of whitebark pine where “practicable” allows the removal of whitebark specimens that pose a human safety risk, per OSHA requirements, or where no practicable avoidance strategy can be used during vegetative and road management activities. While such situations do arise, they have rarely occurred in past experience.

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AWR #16

We appreciate that, if implemented, the Forest Service’s monitoring “will also determine if the area treated by the gap and thin prescriptions exceed the identified thresholds, 20% (gap) and 40% (thin) of a stand.” (2-40). Given the inherent uncertain delineation between gaps and thinned areas, we are interested in how this would be monitored quantitatively.

More work would be required by crews during the layout phase of the timber sale to identify where the thin prescriptions and gap prescriptions would be applied. The work will vary depending on the slope and general terrain of an individual treatment unit. This additional work would likely include delineating the boundaries from which the area of each type of prescription could be calculated and applied. A detailed implementation monitoring protocol would be developed prior to implementation and posted on the project Web site. If Alternative B is selected, this protocol will be shared with the commenter, as well as others interested in this protocol.

AWR #17

The EA states: This analysis incorporates management direction, findings, and conclusions in the Final Environmental Impact Statement Supporting Forest Plan Amendments to Integrate the Boise National Forest WCS, Phase 1: Forest Biological Community (WCS; USDA Forest Service 2010b). Since our appeal of the WCS was not successfully resolved, the issues expressed in our appeal of the WCS Record of Decision remain unresolved. We fully incorporate our March 24, 2010 comments on the WCS Amendments Draft EIS and our August 23, 2010 appeal of the WCS ROD within these comments, since the Clear Creek project as proposed in this EA exemplifies many of those previously expressed concerns.

Comments in your March 24, 2010, letter concerning the WCS Draft EIS were fully responded to in the July 2010 FEIS (Appendix 7, pp. 68–88). Appeal points found in your August 23, 2010, appeal of the 2010 WCS ROD were fully addressed in the ARO’s decision issued on January 28, 2011. In this appeal decision, the ARO affirmed Forest Supervisor Cecilia R. Seesholtz’s ROD approving the Forest Plan Amendments to Facilitate Implementation of the 2010 Plan Scale Wildlife Conservation Strategy: Phase 1—Forested Biological Community.

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AWR #18

The project area does not provide habitat conditions that assure viability of Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and management indicator wildlife species. The BNF did not monitor population trends of old-growth MIS under the original forest plan, and still has insufficient monitoring data to assure that viability is being maintained. The RFP/WCS does not disclose the amount, distribution, and quality of habitat needed to assure viability, and because old growth is lacking in the project area this is why forest habitat that soonest will mature into old growth cannot be spared. The EA does not cite the results of monitoring or scientific studies that validate any assumption that logging will “maintain current trends toward development of” or facilitate necessary old-growth habitat conditions. As the EA indicates, “the dynamic relationship between habitat conditions and species persistence is not yet well understood for many species” (EA at 1-23). The EA at 3-90 states that “In general, models are believed to accurately portray trends in habitat abundance and quality for the various wildlife species.” The Committee of Scientists (1999), commissioned by the Forest Service at the beginning of the process of revising NFMA regulations, state: “Habitat alone cannot be used to predict wildlife populations…The presence of suitable habitat does not ensure that any particular species will be present or will reproduce. Therefore, populations of species must also be assessed and continually monitored.” (Emphasis added.) The EA indicates that the presence of some of the Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and management indicator wildlife species is not even confirmed in the project area, despite historical conditions or expected use.

“project area does not provide habitat conditions that assure viability of Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and management indicator wildlife species”

The project area is not an appropriate scale at which the viability of the analyzed species populations would be assessed. None of the species has a range or population that is limited to the project area. Section 2.3 of the Wildlife Technical Report states that the analysis area for direct, indirect, and cumulative effects is defined for each species based upon the presence of the species or its habitat; the area where proposed activities are planned; and the outermost extent where effects to a species or its habitat would be expected. The project area is only identified as the analysis area for TEPCS, focal species, or MIS when the range of the species does not overlap the Project area, habitat is not present in the project area, or habitat is present but will be unaffected by proposed activities. The relationship of the analysis area to the analysis completed at the Forest Plan level to determine sustainability of terrestrial wildlife species is referred to within those species write-ups if the species or its habitat will be affected by proposed activities. “BNF did not monitor population trends of old-growth MIS under the original forest plan” There are no “old-growth MIS” identified in the Forest Plan. Three terrestrial wildlife species have been identified under the 2010 Forest Plan. Monitoring for MIS is completed at the Forest scale, not at a project scale. Annual monitoring for Forest MIS is documented

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in the annual monitoring report. The most recent report is available on the Forest Web site and is titled “Boise National Forest Land and Resource Management Plan Cumulative Monitoring and Evaluation Report FY 2004–2011” (USDA Forest Service 2012). Table 14 on page 77 of this report identifies the reason the MIS in the Forest Plan were selected (USDA Forest Service 2012). “BNF….still has insufficient monitoring data to assure that viability is being maintained” MIS are selected because their populations are believed to reflect the effects of management activities. Population monitoring is conducted to determine trend relative to implementation of management activities. MIS are not selected to monitor their viability. Refer to the previous paragraph.

“The RFP/WCS does not disclose the amount, distribution, and quality of habitat needed to assure viability, and because old growth is lacking in the project area this is why forest habitat that soonest will mature into old growth cannot be spared” “Old growth” is an incorrect term. Old forest was evaluated at the scale of the Forest, and the amount, distribution, and quality of habitat believed to exist at that scale under historic disturbance processes are defined in Volume 2, Appendix 2, of the FEIS for the Forest Plan: see Appendix 4 (Analysis Process for Forested Vegetation and Terrestrial Wildlife) for discussion on how amounts were estimated; Appendix A (Vegetation) and Appendix E (Terrestrial Wildlife

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Resources) for discussion of distribution (patch and pattern); and Appendix E for discussion of habitat quality and desired attributes of old forest habitat. The old forest habitat analysis for the Project area (EA section 3.4.2.1 and specifically Tables 3-31, 3-32, and 3-33) shows that the acres moving into the large tree size class are greater under Alternatives B and C than under Alternative A; this fact indicates that those areas are likely to continue on a trajectory toward developing old forest. EA section 3.2 (Vegetation Resources) shows that trees in the medium size class will remain within similar amounts under Alternatives A, B, and C for the modeled time frames (see Table 3-5, p. 3-16); these amounts ensure that stands in the next tier to develop into old forest habitat will continue to move toward old forest habitat conditions.

“The EA does not cite the results of monitoring or scientific studies that validate any assumption that logging will ‘maintain current trends toward development of’ or facilitate necessary old-growth habitat conditions” The EA analysis tiers to the analysis completed in support of the 2010 Forest Plan amendments (USDA Forest Service 2010a,b,c). Scientific studies are cited throughout the FEIS completed in support of the 2010 amendments to the Forest Plan; these studies support use of active vegetation management, including use of commercial logging, to facilitate restoration of Forest Plan desired vegetative conditions, including old forest habitat (refer to previous discussion concerning “old growth” versus “old forest habitat”). While citations are

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included throughout section 3.2 of the FEIS, a summary of supporting studies was provided in the rationale for eliminating an alternative from detailed study in the FEIS. This alternative requested lands to be allocated from an active management prescription to a passive management prescription (USDA Forest Service 2010b, section 2.4.1.1, pp. 25–28). “As the EA indicates, ‘the dynamic relationship between habitat conditions and species persistence is not yet well understood for many species’ (EA at 1-23)”

This statement is found in the Review EA in section 1.9.6.2 and is intended to acknowledge the complexity of ecological relationships between abiotic and biotic factors and organisms. The statement does not mean that nothing is known or understood, and it acknowledges that the level of information that is known can vary by species. “The Committee of Scientists (1999), commissioned by the Forest Service at the beginning of the process of revising NFMA regulations, state: ‘Habitat alone cannot be used to predict wildlife populations…The presence of suitable habitat does not ensure that any particular species will be present or will reproduce. Therefore, populations of species must also be assessed and continually monitored’ (Emphasis added.)”

These statements from the Committee of Scientists Report (1999) are excerpted from a robust discussion of the concepts of focal species and sustainability under

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section 3A, Ecological Sustainability, subheading “The Elements of Ecological Sustainability.” This discussion is targeted at scales larger than a project (e.g., national forest, ecoregion). As mentioned previously, populations of selected species (MIS) are monitored at the scale of the Forest, not the scale of a project.

“The EA indicates that the presence of some of the Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and management indicator wildlife species is not even confirmed in the project area, despite historical conditions or expected use”

Surveys have been completed for some TEPCS, focal species, or MIS and are documented in EA section 3.4.1, as well as under “Existing Conditions” discussions found throughout section 3.4 for each species . In addition to targeted surveys, a review of historic occurrence records was also completed to determine if a species is known to have occurred in the analysis area. A lack of occurrence records or the absence of a detection during a field survey does not confirm absence of a species; therefore, if source habitat is present in the analysis area, the habitat is assumed to be occupied, regardless of confirmed detections past or present, and the potential for effects to the species of interest is assessed, including direct, indirect, and cumulative impacts.

AWR #19

The reduction/losses in snag densities are a major risk posed by the proposed vegetation management activities. These are habitat components necessary for many of the Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and

Snags were assessed in various sections of the EA:

Section 3.2.6.1: Vegetation – Snags Section 3.4.2.1: Wildlife – Old Forest and Large-Tree

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management indicator wildlife species, reduced by ongoing activities such as fuelwood gathering, or past cumulative management activities. Alternative C poses less risk that Alternative B, since snag densities would be lower in treated areas.

Habitat

Section 3.4.2.2: Wildlife – Snag and Coarse Woody Debris Habitat Common to All Habitat Families Section 3.4.3: Wildlife – various individual species discussions Comment AWR #19 is related to the effects of vegetation treatments on snags. Of the EA sections discussing snags, section 3.2.6.1 is the section that directly displays the result of vegetation treatments (the analysis area was limited to the vegetation treatment areas). Lower numbers of snags are not predicted across all time frames or PVGs for the action alternatives (vegetation treatments). Compared to the No Action alternative, the action alternatives would result in higher snag densities in the low- to mid-elevation stands in the short term (2016), due to the proposed broadcast burning. For all other combinations of PVGs and time periods, the action alternatives would result in snag densities equal to or less than those expected under Alternative A. The analysis acknowledges that Alternative B has the potential for lower snag densities than Alternative C. This is due to the reduced potential for snag loss due to OSHA safety requirements during harvest operations (short-term) and due to removal of live trees which reduces future recruitment. The wildlife resource analysis areas included the vegetation treatment areas as well as adjacent habitat in order to assess how treatments affected the larger landscape area utilized by wildlife species. Analysis relative to snags and wildlife is included the Wildlife

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Resource EA sections noted above in the opening paragraph. Snag densities were utilized as an indicator of habitat quality. The desired conditions are to fall within the size classes and densities defined in the Forest Plan (Appendix A and Appendix E [old forest]). The higher end of the desired range is believed to represent higher-quality habitat (EA section 3.4.3), due to reduced competition for resources (snags) and a higher likelihood that suitable conditions (rotten snags for weak excavators, slipping bark) would be present at any given time. Snag habitat quality within vegetation treatment areas would be higher for Alternatives B and C than for Alternative A in the short term; but Alternatives B and C would contribute to lower-quality habitat than Alternative A would in the long term. Snag habitat quality would be higher for Alternative C than for Alternative B, because Alternative C has lower potential for short-term loss due to OSHA safety requirements and higher recruitment potential in the long term in the mid- to upper-elevation treatment areas. Snag loss risks related to fuelwood gathering and past vegetation management are tied to road density, which was utilized as a risk indicator during analysis. In summary, the analysis presented in the EA displays the differences in snag densities due to vegetation treatments and utilizes snag densities when describing effects to wildlife species and habitats. Road densities were used as an indicator of risk, including the risk of snag reduction resulting from fuelwood gathering and vegetation management. In addition, a new design feature (WI-9) and monitoring

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requirement have been added to the Final EA to mitigate effects of fuelwood collection along open roads. This design feature would apply to both action alternatives. See EA sections 2.4.4.10 and 2.4.5.

AWR #20

The EA does not utilize the best scientific information in its consideration of protection measures for northern goshawk nest stands and post-fledging areas (PFAs). “The known nest site is within a stand proposed for treatment under Alternative B.” We believe that Reynolds et al. 1992 supports maintaining 60% of the forest in northern goshawk PFAs in the oldest large tree medium- to closed-canopy conditions. We cannot tell if the EA’s protections would prioritize maintaining the oldest forest available in the PFAs. How are you ensuring that there is a viable breeding population of goshawks on the BNF?

“does not utilize the best scientific information in its consideration of protection measures for northern goshawk nest stands and post-fledging areas (PFAs)…..” Reynolds et al. (1992) was developed for the forests that occur in the southwestern United States. While the basic concept of providing for nesting areas, PFAs, and foraging areas is applicable to central Idaho, some of the more specific vegetation recommendations could/should not be directly applied to the forests within the Project area, which differ ecologically from southwestern forests. Reynolds et al. (1992) also noted the importance of shifting management away from a single species and stand-level management toward managing forests at the larger landscape level, thus maintaining biodiversity and healthy functioning ecosystems. Forest’s WCS (USDA Forest Service 2010a) takes a similar approach and is built upon the foundational concept that the risk of losing species, processes, or genetic diversity within populations is thought to increase along with increasing departure of vegetation from the HRV. Thus, the desired conditions for wildlife habitat across the planning unit are to remain within, or move toward, conditions that fall within the HRV. These conditions are described in Appendix A of the Forest Plan (USDA

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Forest Service 2010a).

“How are you ensuring that there is a viable breeding population of goshawks on the BNF?” The analysis completed for the northern goshawk under the FEIS for the 2010 amendments to the Forest Plan (USDA Forest Service 2010a) showed the species is well distributed across its range on the Forest, and suitable habitat is generally broadly distributed, providing the species resilience to changed conditions in its habitat at finer scales. This finding is consistent with the state rank of this species as apparently secure in Idaho. In Idaho and at the scale of the Forest planning unit, the northern goshawk has been determined to be secure; therefore, at a project level, effects to individuals would not result in a change in the status of this species. Note that viability is not assessed at the project scale; therefore, the analysis completed for the Forest provides the evidence for sustainability of the species at the scale of the planning unit (USDA Forest Service 2010a). “…supports maintaining 60% of the forest in northern goshawk PFAs in the oldest large tree medium- to closed-canopy conditions” An actively used PFA has not been identified in the vicinity of the known nest documented in 2007. Goshawks have been observed at the site only one time (May 2007). The site has not been found to be occupied or productive in subsequent calling surveys in 2008 or during nest monitoring. For the project, this historic information supported the assumption that goshawks are

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likely present and reproducing in the analysis area. At the project level, the key habitat components for goshawk would be provided within the context of the established desired conditions, which fall within the historical range of variability of local forest types (PVGs). Five potential nesting and PFA “blocks” were identified for the project area during an assessment to determine compliance with Forest Plan Standard WIST05 (project record, CC_WL_NOGO_FPConsistency_Aug2013). The five potential nesting and PFA habitat blocks are summarized below:

• Potential PFA No. 1 (628 acres): LargeTree (≥40% CC) = 323 acres, MediumTree (≥40% CC) = 118 acres; % mature forests (MT & LT) with moderate to high canopy cover = 70.2%.

• Potential PFA No. 2 (630 acres): LT (≥40% CC) = 126 acres, MT (≥40% CC) = 315 acres; % mature forests with moderate to high canopy cover = 70.1%.



• Potential PFA No. 5 (815 acres): LT (≥40% CC) = 753 acres, MT (≥40% CC) = 0 acres; % mature forests with moderate to high canopy

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cover = 92.4%.

The Clear Creek goshawk analysis area includes enough source habitat capacity to provide for a single home range. Within this area, 5 potential PFAs/nesting areas would be available after implementation of the action alternatives.

The canopy cover and tree size characteristics of the potential PFAs are appropriate for the ecological conditions in the Clear Creek area and are consistent with recommendations under Reynolds et al. (1992). Refer to EA section 3.4.3.8.

AWR #21

For Canada lynx, the EA also does not identify the best available science it is relying upon as its management direction. Little pre- and post-project quantitative analysis of habitat conditions for the two Lynx Analysis Units is included in the EA. Effects from snowmobiles and other over-snow vehicles (OSV) is mentioned non-quantitatively, but the EA does not consider how such “take” can be minimized or avoided. Please formally consult with the US FWS on lynx and get a take permit.

A biological assessment for effects to lynx from the Project was completed. The assessment determined that the project was “not likely to adversely affect” lynx and that “take” would not result from implementation of the federal action. Consultation with USFWS under Section 7 of the Endangered Species Act is ongoing. The draft biological assessment and determination have been reviewed by the USFWS and approved for final submission (indicating agreement with the analysis and determination). Since no “take” is anticipated, a “take permit” is not required. Based on consultation with USFWS, a 7(d) determination has been made, and a letter of concurrence is expected from USFWS. Several literature and data resources were utilized and referenced in the Canada lynx discussion in the EA (section 3.4.3.10), including the Canada Lynx Conservation Assessment and Strategy (Ruediger et al. 2000). This analysis also tiers to the FEIS supporting the 2010 Forest Plan amendment; this FEIS also

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includes several literature and data resources (USDA 2010(b), section 3.3.7.3).

AWR #22

The black-backed woodpecker is a Management Indicator Species for the BNF. The black-backed woodpecker is quite distinguishable because its habitat is comprised predominately of insect infested or burned over stands. “Insect infestations and recent wildfire provide key nesting and foraging habitats” for the black-backed woodpecker and “populations are eruptive in response to these occurrences” (Wisdom et al. 2000). A major purpose of the project is to negate the natural occurrence that the black-backed woodpecker biologically relies on; the emphasis in reducing the risk of stand loss due to stand density coupled with the increased risk of stand replacement fire events. Given that this purpose would be expected to be consistent over a large portion of the forest plan “Restoration” Management Area lands, how is viability of a species to be assured, if habitat suppression is to be a forestwide emphasis via the forest plan?

Purpose and Need #1 and Purpose and Need #2 (EA section 1.5) are related to promoting vegetation conditions that occurred historically (prior to European man’s influence) in low- to mid-elevation forests. The low- to mid-elevation forests in the Project area include PVG 1 (Dry Ponderosa Pine/Xeric Douglas-fir), PVG 2 (Warm Dry Douglas-Fir/Moist Ponderosa Pine), and portions of PVG 3 (Cool Moist Douglas-fir) where ponderosa pine is a major seral species. Historically, PVGs 1 and 2 were maintained by a nonlethal fire regime as open forests dominated by ponderosa pine or ponderosa pine and Douglas-fir. Generally, the potential for stand-replacing wildfires or risk of insect and disease outbreaks was low in these PVGs. Frequent, low-intensity fires would have generated some constant level of snags in forest stands but would not typically have provided large concentrations of snags at any one time unless uncharacteristic fire events or insect and disease outbreaks occurred. Most studies do not describe black-backed woodpeckers in forest stands similar to those that can develop under PVGs 1 and 2, unless an uncharacteristic stand-replacing fire event occurred. Additionally, many low- to mid-elevation stands lie within FMU 2 (WUI), and fire suppression would be the likely response to fire starts within the area. Black-backed woodpecker habitat on the Forest occurs in PVGs 3 through 10. These PVGs are capable of

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developing the structural characteristics typical of unburned habitats used by black-backed woodpeckers (dense forest conditions with larger-diameter trees and higher canopy cover conditions) and the structural characteristics of disturbed habitats used by the species (i.e., endemic/epidemic mountain pine beetles and fire are part of the disturbance regime in these vegetative communities). The overlap of a Forest Plan restoration focus (Family 1) with black-backed woodpecker habitat (Family 2) occurs in PVG 3. The Forest Plan amendment (USDA Forest Service 2010 a,b,c) that incorporated Phase I of the WCS recognized that some species within Family 2 would experience reductions in source habitat as vegetation conditions in the lower-elevation forests (Family 1 source habitats) were restored or moved toward the HRV. EA section 3.4.3.3.3 states that source habitat for the black-backed woodpecker increases under all alternatives in the short term and the long term. Variations occur between alternatives but are primarily attributable to management activities in PVG 3 that affect source habitat. Table 31 on page 58 of the Wildlife Technical Report displays the change in source habitat quantity, habitat patch size, and number of potential home ranges by alternative in the short term and the long term. Modeling results show that proposed management activities in all 3 alternatives will continue to provide >2,700 acres of habitat post-implementation (short-term) and >5,000 acres of source habitat in the long term. There is approximately a 13% increase in habitat between current and short-term conditions. In all 3 alternatives, these acres will occur in an array of patch

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sizes that are consistent with mixed1 and mixed2 fire regimes. An estimate of the number of home ranges that could occur in these habitat patches shows that the number of territories will increase in the short term and the long term. For all alternatives, the long-term increase in habitat is approximately 2 times more habitat than is estimated currently. “how is viability of a species to be assured, if habitat suppression is to be a forestwide emphasis via the forest plan?” A discussion of viability is not appropriate at the project scale; rather, the role of the project analysis is to assess the effects of proposed activities on a species (i.e., black-backed woodpecker) and to place those effects in context with assessments completed at higher scales to understand the context and significance of project-level effects to the species. The analysis for the black-backed woodpecker completed for the Forest in the FEIS for the Forest Plan (USDA Forest Service 2010) determined this species and its habitat are well distributed across the Forest. The final EA, section 3.4.3.3, will clarify the focal species discussion as to the relationship of the black-backed woodpecker analysis for the project to the watershed and to the Forest to clarify its contribution to Plan-level findings.

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AWR #23

The EA’s cumulative effects discussion fails to adequately consider quantitative loss of habitat of the American three-toed woodpecker, white-headed woodpecker, black-backed woodpecker, pileated woodpecker, fisher, boreal owl, flammulated owl, Canada lynx, great gray owl, northern goshawk, mountain quail, wolverine, Townsend’s big-eared bat, Columbia spotted frog, and gray wolf, over time in the project area and forestwide, due to management activities. It also fails to disclose population trends forestwide over time.

“cumulative effects discussion fails to adequately consider quantitative loss of habitat…over time in the project area and forestwide, due to management activities”

A quantitative assessment over time requires the availability of stand examination data that can be modeled into the future; this type of assessment would reflect changes resulting from management activities as well as changes that would occur in the absence of management. Stand examination data were available for a portion of the Project area and were used to model source habitat for the existing conditions (2012), conditions immediately after implementation (2016), and in the long term (2044). These data were used to quantitatively describe effects for many species and to represent changes occurring as a result of the alternatives over a 30-year time period. Stand examination data were not available for the larger cumulative effects areas described for many species; therefore, the cumulative effects analysis relied on a different data set (Landsat imagery). Landsat imagery can appropriately be used to describe the existing vegetation condition at larger scales (above the site scale or project scale); however, vegetation cannot be modeled to reflect projected future changes resulting from succession and natural disturbances or from management activities. Rather, the analysis relied on the project wildlife biologist’s knowledge of natural succession and disturbance processes and effects of management activities to qualitatively describe trends in habitat condition within the cumulative effects analysis

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area, taking into account quantitative changes occurring within the smaller Project analysis area. Refer to EA section 3.4.1 (Methodology). The cumulative effects analysis area varies by species and is described for each species in EA section 3.4. A particular cumulative effects area is selected because the area encompasses the extent of the projected effects, or if a larger area was selected, to display how the project does or does not contribute to maintenance or restoration of habitat within a watershed (smallest unit assessed for the WCS). The largest cumulative effects area was for Canada lynx and includes 2 lynx analysis units. No cumulative effects area included the entire forest; therefore, there was no discussion of effects at that scale. “cumulative effects discussion fails to adequately consider quantitative loss of habitat…over time …forestwide, due to management activities” The Project analysis does not need to restate the analysis completed at the scale of the Forest for the identified species. Project-level analysis needs only to refer to the Forest Plan analysis if it is relevant to understanding the project in relation to the larger-scale, Plan-level conclusions for the species. Cumulative effects and the quantitative change to source habitat for the identified species, over time, at the scale of the Forest, can be found in the FEIS for the Forest Plan (USDA Forest Service 2010). “cumulative effects discussion … fails to disclose population trends forestwide over time”

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The population trend for Forest Plan MIS is discussed in EA section 3.4.3.18. MIS are representative species whose habitat conditions or population changes are used to assess the impacts of management activities on similar species in a particular area (USDA Forest Service 2010b, p. 440).

AWR #24

Given that quantitative analysis is minimal for most Threatened, Endangered, Proposed, Candidate, Sensitive, focal, and management indicator wildlife species in the EA, viability cannot be assured in the context of a project that further reduces habitat in an area already cumulatively degraded by past and ongoing actions. The EA does not consider how ongoing impacts such as OSV use and fuelwood gathering can be minimized or avoided.

“quantitative analysis is minimal”

Quantitative analysis was used for most species and included indicators for source habitat abundance, source habitat abundance due to conditions outside the HRV, patch size, number of patches greater than or equal to the home range, road/trail density, snag densities, log densities, and others. Indicators vary by species, and many species have several quantitative indicators. Quantitative analysis in the EA may appear to be minimal; however, the quantitative analysis the EA contains is actually a summary of data presented in detail in the Wildlife Technical Report (343 pages). “viability cannot be assured” Viability is not assessed at the project level, because that is not an appropriate scale. The WCS evaluated the sustainability of wildlife species on the Forest. This evaluation is documented in the FEIS for the Forest Plan (USDA Forest Service 2010b). The Forest Plan was recently amended to incorporate direction needed to maintain and restore habitat for sustainable wildlife populations on the Forest. The Project was developed using the direction found in the amended Forest Plan, and the project supports maintenance and restoration of sustainable wildlife habitat. The wildlife species found

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within the Project area also occur elsewhere across the Forest, and effects to individuals from project actions would not affect populations that occur across the Forest. Canada lynx (threatened) would not be adversely affected by the project actions (EA section 3.4.3.10), nor would the actions jeopardize the continued existence of wolverine, a species recently proposed for listing (EA section 3.4.3.12). For all species with habitat within the Project area, the analysis concluded that the cumulative effects analysis area would continue to provide habitat for the species and support a well-distributed and connected network of habitat on the Forest. According to the analysis, this conclusion applies even to those species whose habitat was reduced or degraded. “EA does not consider how ongoing impacts such as OSV use and fuelwood gathering can be minimized or avoided” The transportation activities proposed under the action alternatives implement recommendations from the Clear Creek Watershed TAR. During the travel analysis process, risks related to wildlife were considered during development of the recommended road system. While these risks are presented generally in the TAR (2012, 2013), they include the negative effects that roads have on snag abundance (i.e., roads facilitate the removal of snags for fuelwood) (EA section 3.4.2.3). The TAR recommendations include decommissioning and closing of roads and would reduce the impacts of the fuelwood program in some locations. The Travel Analysis Process and report did not assess or make recommendations for

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OSVs, because the defined scope of the analysis focused on roads and non-OSV motorized trails. Present and ongoing snowmobile grooming activities were considered in the cumulative effects discussions for applicable species. Appendix A, Table A-1 (pp. A-7 through A-8), clearly identifies this activity as one considered by the IDT. In addition, a new design feature (WI-9) and monitoring requirement have been added to the Final EA to mitigate effects of fuelwood collection along open roads. This design feature would apply to both action alternatives. See EA sections 2.4.4.10 and 2.4.5.

AWR #25

The proposed logging and burning would further degrade some habitat conditions for elk, despite the fact that bull numbers and ratio to cows are below IDFG objectives, and that populations have declined since earlier surveys, and current calf:cow ratios are well below normal and of concern for the IDFG. The EA does not disclose how forest plan direction for elk can be achieved.

“The proposed logging and burning would further degrade some habitat conditions for elk” The comment does not specifically identify what degrading effects from logging and burning are of concern. Degrading effects discussed in the wildlife analysis (EA section 3.4.3.13) are related to increased disturbance and noxious weeds on winter-spring range. “The EA does not disclose how forest plan direction for elk can be achieved”

The NEPA process includes a review of the action alternatives for consistency with Forest Plan direction, including direction related to elk. A detailed Forest Plan consistency document has been prepared for this project and is included in the project record.

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AWR #26

Since most of the Watershed Condition Indicators (WCIs) are “Functioning at Risk” or “Functioning at Unacceptable Risk” for the Clear Creek watershed, it is remarkable that bull trout persist here. This should not be taken for granted, especially given the lack of a reliable population trend analysis, the presence of Critical Habitat, and the “Likely to Adversely Affect” determination for bull trout. We appreciate that the project would reduce road density and other road impacts, and thus reduce press disturbances to habitat. However we believe that minimizing the impacts of new roads is also warranted. And as stated above, an economically viable travel system must be identified and impacts in RCAs must be avoided. As it stands, proposed and ongoing activities represent “take” under the ESA that is not being minimized or avoided.

The “take” associated with this project is due to the Big Spruce Creek culvert removal and replacement activities. Specific project design features, pre- and post-project checklists, and USFWS terms and conditions will be used during the construction phase of the project to reduce sediment delivery and avoid impacts to bull trout residing in Big Spruce Creek (EA, Design Feature WF-19 and Appendix C). The biological assessment for effects to bull trout determined that all other project activities are “not likely to adversely affect” the species (EA, sections 3.7.2.2.20 and 3.7.3).

AWR #27

For WCIs, the EA does not explain how the status of “Functioning” would ever be achieved. It seems that depressed habitat conditions for bill trout will be the accepted norm.

The Project has short- and long-term benefits to bull trout population indicators and multiple WCIs (EA Table 3-77). These short- and long-term benefits will be realized in the future as data are collected in 6th field HUCs and environmental baselines are updated. The results of this project are expected to improve many WCIs. The fisheries analysis concluded that none of the temporary negative effects of implementing the project will result in a “degraded” condition for any of the WCIs.

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AWR #28

“(T)he 2012 Clear Creek TAP and the 2004 road inventory (GRAIP) … reveals that several roads within RCAs are contributing sediment to streams.” (3-269.) It is not clear in the EA that identification of those road problems is adequately reflected in the prioritization of Project restoration actions.

EA section 3.6.3.1.2 (Hydrology) and section 3.11.3.4.2 (Transportation Systems) specifically describe how the GRAIP road inventory information was used to prioritize road treatments that would reduce sediment delivery from roads to streams. Figure 3-36 provides spatial locations of high sediment delivery sites as identified by GRAIP, and Figure 3-47 describes how those locations are prioritized for treatment. Figure 2-6 (Transportation system changes proposed under Alternatives B and C) displays the road sediment treatments combined priority rating that would be applied if Alternative B or Alternative C is selected. Priority ratings range from Priority 1 treatment areas (i.e., highest priority) through Priority 7 treatment areas (i.e., lowest priority).

AWR #29

The EA does not provide a quantitative analysis of the sediment generated by use of the roads for log hauling. Even where roads are properly maintained, use by heavy equipment and other vehicles may degrade road surfaces noticeably during project activities, resulting in potential increase of sediment yield into streams. The EA’s fisheries analysis also does not consider the risk of landslides due to activities on vulnerable slopes.

Assumptions and references associated with sediment models used for this analysis are described in EA section 3.6.2.3 (Hydrology). Effects of transportation management activities on sedimentation, including road improvements to facilitate log hauling, are included in the discussion in section 3.6.3.1.2. Sediment delivery values associated with transportation management are assumed to be inclusive of all uses of those transportation facilities. Sediment modeling can be found in Table 3-70 of the EA. Design Feature WF-9 restricts management activities on slopes that have a high or moderate hazard rating for landslides. Temporary road construction is not expected to

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adversely affect bull trout and their habitat, because most temporary roads are located outside of RCAs. Mitigations have been included as part of the project design features (WF-9 and WF-15), and RCA buffers will protect aquatic resources.

AWR #30

The EA states that “Currently, tree density is some stands is depressing tree growth rates” in its discussion justifying mechanical treatments within RCAs. We don’t believe that such tree density is in any way not natural. Being some of the wettest habitats in the forest, riparian areas generally exhibit high densities of all vegetation, including trees.

The RCAs delineated for the Project were based on one site-potential tree height for both perennial and intermittent streams (EA, Design Feature WF-1). Because of the conservative nature of RCA delineation and to capture the full suite of riparian processes and functions, RCAs include more area than the “green-line” or what is considered the riparian vegetative community. The RCA can and most often does include upland vegetation. The actual riparian influence can be very narrow in all but wide channel topography. The upland vegetation within the RCA is the vegetation proposed for treatment.

Proposed treatments within RCAs are noncommercial thinning of trees <8 inches dbh. No treatment would occur within one average tree height or 20 feet from the stream, whichever is greater (Design Feature WF-7). In the Project area, this nontreated area would extend beyond the riparian community. Treatments would focus on reducing uncharacteristic ladder fuels and creating diverse patches of variable density, similar to treatment objectives described for commercial thinning treatments (EA section 3.2.2.1.1) of upland vegetation in the RCA. The quotation in Comment AWR #30 was taken from the Fisheries section of the EA. The EA will be clarified

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to be consistent with the discussion above concerning the purpose of treatments in RCAs.

AWR #31

The EA does not provide any indication of the reliability or accuracy of the soil survey methodology relied upon for this analysis. Only “A small sample of sites was surveyed” (3-306) therefore reliability of the estimates of detrimental soil disturbance (DD) is questionable.

The quoted statement refers to soil health assessments collected within the analysis area to evaluate current soil condition, as stated in section 3.8.1 of the EA. DD was not estimated using these assessments; rather, it was calculated using the definition of DD found in EA section 3.8.3 and assumptions about effects of previous and proposed management activities on DD as described in section 3.8.3.1.

AWR #32

The EA did not consider detrimentally disturbed soils outside of project activity areas, despite indications that soil productivity in such other locations within the project area are just as important for hydrologic functioning, sustained yield of timber, and overall land productivity. Also see Project Design Feature WF-14 in terms of differences between Alternatives B and C.

EA section 3.8.3 describes the use of activity areas for the DD analysis.

AWR #33

For this analysis, the EA does not quantify the soil damage from dedicated skid trails within units as DD, rather it is considered part of the more permanently damaged total soil resource commitment (TSRC) areas. This novel analysis approach results in the underestimating of DD caused by project activities, potentially obscuring the need for soil mitigation measures for activity areas, and fails to comply with the forest plan DD standard. Moreover, since we are unaware of the existence of any valid project area or forestwide inventory of TSRC, it appears that the Forest Service is merely attempting to dodge its duty to maintain and protect this resource—so fundamental and vital to every other component and function of these forest ecosystems.

The definitions for DD and TSRC can be found in the EA at the beginning of sections 3.8.3.1 and 3.8.4.1, respectively. Current conditions for TSRC have been calculated for the project area and are included in section 3.8.4.2 of the EA.

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AWR #34

Also, there is plenty of monitoring and scientific research that indicates far fewer than16 trips of a skidder are needed to result in DD conditions. (3-308.)

Without a cited reference, the information in this comment cannot be evaluated. The research presented in EA section 3.8.3.1. (i.e., Clayton 1990 and Froelich et al. 1983) supports the assumption concerning 16 trips.

AWR #35

Given that compliance with the DD standards is an issue pertaining to the particular conditions of each activity area, the EA fails to disclose the quantitative measures or estimates for each activity area. This does not satisfy NEPA or NFMA requirements.

In section 3.8.3, the EA provides a summary of the estimates of total DD by alternative and the range of DD (i.e., the lowest and highest estimate within each activity area; these data are sufficient to determine compliance with Forest Plan Standard SWST02. The DD values of each individual activity area are included in the project record and will be made available as an appendix in the Final EA, Appendix C, section 3.

AWR #36

“Under Alternative B, 7 of the 73 of activity areas may require implementing Design Features WF-13 and WF-14 (section 2.4.4.9) to ensure DD levels do not exceed 15% following completion of Project activities.” (3-310.) The EA does not provide any indication of the efficacy of the design features (mitigation) proposed.

Design Feature WF-14 (EA, p. 2-36) would treat skid trails in a manner that would provide for increased infiltration potential, mitigating the soil DD in the temporary and short-term time frames. Over time, soil quality in these areas would naturally return to preharvest levels. The Final EA will provide clarification of the objective of Design Feature WF-14.

AWR #37

The analysis methodology utilizes measures of soil damage as a proxy for insuring another ecosystem characteristic—soil productivity. It is the latter that is emphasized under the NFMA, yet trends or reductions in soil productivity are not estimated. Further, we note that although “Soil nutrient cycling and compaction are the two main factors in determining soil quality” (3-307), for the EA soil quality is only represented by DD and TSRC (Id.), not trends or effects on nutrient cycling.

Forest Plan Standard SWST02 and the thresholds of allowable soil DD or TSRC are designed to ensure that the components of soil quality (i.e., compaction and nutrient cycling) are within an acceptable range. The threshold levels for DD associated with SWST01 are taken from Forest Service Manual 2550. As noted in FSM 2550 policy, these DSD parameters help establish the management framework for sustaining soil quality and hydrologic function while

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providing goods and services outlined in forest plans, consistent with NFMA mandates. Use of 15% of the aerial extent as an indicator of whether mandates of NFMA are being met is a reasonable assumption to include in the Agency’s management framework for sustaining soil quality and hydrologic function and is based on science and the experience of experts, as discussed below. Section 2551.3 of the Region 4 Supplement to FSM 2550 (March 14, 2011) states the following under Soil Management, Standards and Guidelines:

“Soil quality standards and guidelines provide soil management indicators that help determine when changes in soil properties would result in significant change or impairment to soil quality. Soil quality standards and guidelines provide for the maintenance of soil properties that affect soil quality and hydrologic function. …The standards and guidelines are used to define management practices to improve or maintain soil quality and watershed condition. Soil quality standards or guidelines may be determined at Regional, Forest Plan, or individual project levels. …”

The Region 4 Supplement goes on to describe examples of soil quality guidelines for Detrimental Soil Disturbance (DSD), Effective Ground Cover, and Above-ground Organic Matter. Examples include the following description from Detrimental Soil Disturbance:

“(1) In an activity area where existing conditions of detrimental soil disturbance are equal to or below 15

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percent of the area, management activities should leave the area in a condition of 15 percent or less detrimental soil disturbance following completion of the management activities and foreseeable future activities. (2) In an activity area where existing conditions of detrimental soil disturbance exceed 15 percent of the area, management activities should include mitigation and restoration so that detrimental soil disturbance levels are less than 15% or move back toward 15 percent or less following completion of the management activities.”

Consistent with the FSM examples, the Forest Plan includes Standard SWST02, which reads as follows: “Management activities that may affect soil detrimental disturbance (DD) shall meet the following requirements: a) In an activity area where existing conditions of DD are below 15 percent of the area, management activities shall leave the area in a condition of 15 percent or less detrimental disturbance following completion of the activities. b) In an activity area where existing conditions of DD exceed 15 percent of the area, management activities shall include mitigation and restoration so that DD levels are moved back toward 15 percent or less following completion of the activities.” To estimate soil DD, it is essential that the glossary definitions for activity area, detrimental soil disturbance and total soil resource commitment (TSRC) are clearly understood.”

Both FSM 2550 and the Region 4 supplement provide

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multiple references that were used in support of the soil management program nationally and in Region 4 (the Forest falls within Region 4 of the Forest Service). Refer to FSM 2550.6 for references that are pertinent to all regions of the Forest Service. The following are references specified in the Region 4 supplement:

Brown, James K., Elizabeth D. Reinhardt, and Kylie A. Kramer. 2003. Coarse woody debris: Managing benefits and fire hazard in the recovering forest. Gen. Tech. Rep. RMRSGTR-105. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 16 p. Debano, L. F., D. G. Neary, and P. F. Folliott. 1998. Fire’s effects on ecosystems. New York: John Wiley and Sons Inc. 333 p. USDA, NRCS. 2010. Field Indicators of Hydric Soils in the United States, A Guide for Identifying and Delineating Hydric Soils. Version 7.0, 2010. ftp://ftpfc.sc.egov.usda.gov/NSSC/Hydric_Soils/FieldIndicators_v7.pdf USDI/USDA Technical Reference 1737-19. 2003. Riparian Area Management: Riparian-Wetland Soils. ftp://ftp.blm.gov/pub/nstc/techrefs/Final%20TR%201737-19.pdf

Field Book for Describing and Sampling Soils. Avail at http://soils.usda.gov/technical/fieldbook/ Graham, R. T. 1994. Managing coarse woody debris in forests of the Rocky Mountains. Ogden, UT: Intermountain Research Station. 13 p. map; 28 cm.

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http://soils.usda.gov/technical/fieldbook/



USDA Forest Service. 2001. Region 4 Forest Service soil quality monitoring methods. Unpublished document, USDA Forest Service, Intermountain Region, Ogden, UT.

USDA Forest Service. 2010. Region 4 Forest Service soil interpretations guide. Unpublished document, USDA Forest Service, Intermountain Region, Ogden, UT. Harvey, A. E. 1997. Decaying organic materials and soil quality in the Inland Northwest: a management opportunity. General Tech. Report INT-225. USDA, Forest Service. Howes, S., J. Hazard, and M. Geist. 1983. Guidelines for sampling some physical conditions of surface soils. R6-RWM- 146-1993. USDA Forest Service, Pacific Northwest Region.

Page-Dumroese, D. S., M. Jurgensen, W. Elliot, T. Rice, J. Nesser, T. Collins, and R. Meurisse. 2000. Soil quality guidelines for forest sustainability in northwestern North America. Forest Ecology and Management 138:445–462. Page-Dumroese, D., A. Harvey, and M. Jurgensen. 1995. A guide to soil sampling and analysis on the National Forests of the Inland Northwest United States. GTR INT-GTR-326. USDA Forest Service, Rocky Mountain Research Station. U.S. Department of Agriculture, Natural Resources Conservation Service. 2007. National Soil Survey Handbook, title 430-VI. [Online] Available at

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http://soils.usda.gov/technical/handbook/

AWR #38

The EA also does not consider how noxious weeds detrimentally impact the productivity of the soil and land.

Of all the nonnative plants present on the Forest, noxious weeds present the most immediate and disruptive threat to ecosystem function. Negative impacts created by invasive weed species include impacts to landscape and soil productivity, as well as effects on recreational experiences, forest regeneration, wildlife and livestock forage, native plant resources associated with tribal rights, fire cycles, nitrogen cycling, riparian and hydrologic function, and water quality (Non-native/Noxious Weed Technical Report, page 1): USDA Forest Service 2004; Idaho State 2011; Duncan 1997; Lacey et al. 1989). The presence of noxious weeds in the Project area also creates negative impacts on resource values. These impacts are addressed through design features (EA section 2.4.4.4, Nonnative Plants/Noxious Weeds, NX-1 to NX-11, pp. 2-27 through 2-28) whose implementation will help determine/verify existing weed locations and planning treatments and prevent introduction and spread of new weed invasions.

AWR #39

Despite the fact that “The success of integrated weed management largely depends on effective implementation of detection, prevention, control, containment, and monitoring practices” (3-349), the EA does not cite any monitoring data that demonstrates the Forest Service can effectively deal with the spread of weeds caused by management activities.

Forest Service Invasive Species Management Policy (FSM 2900; Non-native/Noxious Weed Technical Report, p. 4) states that all Forest Service management activities are to be designed to minimize or eliminate the possibility of establishment or spread of invasive species on the NFS lands and those adjacent.

Within the Project area, weed treatment options include biological control agents, mechanical treatments, specifically formulated herbicides, and combinations of

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these treatment options. An example of effective weed management in the project area is the treatment of a population of the biennial plumeless thistle through mechanical removal of seedheads. This treatment prevents reproduction and is to be followed by herbicide treatment to kill the remaining plants and prevent germination of residual seed. The combination of treatments will effectively eradicate this infestation (Clear Creek Project, Noxious Weed Control and Design Features White Paper, page 3). The EA has been updated to clarify the Forest’s Integrated Weed management approach for treatment, and the Forest Program’s standard operating features for application of herbicides have been added as design features (refer to Appendix C). Specific design features for the Project (EA section 2.4.4.4, Nonnative Plants/Noxious Weeds, NX-1 to NX-11, pages 2-27 through 2-28) address weed prevention and treatment through use of weed-free seed mixes and other products, revegetation, equipment cleaning, inventory, pretreatment and monitoring of existing populations where management activities are proposed, public awareness campaigns, use of clean sites, and weed reporting.

AWR #40

And we note that, ironically, even noticing weed infestations so that treatment may be prioritized is dependent upon management activities being carried out in a given area (3-354), rather than because of systematic weed surveys.

The Forest incorporates the “early detection, rapid response” approach to preventing the establishment of new noxious weed populations on the Forest (EA section 3.10.2, Noxious Weeds, Affected Environment). For weed inventory and monitoring, the Forest prioritizes and targets high-risk, high-traffic areas, where noxious weeds or other invasive species are

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likely to be introduced and spread, such as roads, trails, recreation sites, livestock trailing routes, and areas of soil disturbance caused by management activities or wildfires.

In 2012, the Forest acquired new GIS mapping and weed database capabilities that allow permanent tracking of weed inventory, monitoring, and treatment. These new tools will allow Forest personnel to follow weed populations from their detection through treatment and post-treatment monitoring. Using these tools in the Project area will also improve recordkeeping for amount and type of infestations, herbicide use, biocontrol population location and maintenance, and treatment outcomes.

Specialists in Forest’s Noxious Weed program, along with resource specialists and other personnel, play an important role in locating and reporting noxious weed populations. Utilizing personnel from a variety of disciplines, who access diverse Forest landscapes, increases the opportunities for weed detection and subsequent treatment.

AWR #41

“A Transportation Analysis Process (TAP) report was completed in 2012 to recommend the Minimum Road System (MRS) needed for Forest Management and Travel Access Management.” (3-356). We note that there is no metric of economic sustainability utilized by the EA’s analysis.

EA section 3.11 describes how the project moves toward meeting the recommended road system through various metrics (listed in section 3.11.1.1). EA section 3.11.3.1.2, Table 3-99, discloses the estimated annual and deferred maintenance costs by alternative. The Clear Creek Watershed TAR (2013), section 5.3, discusses the influence of the economic analysis on the recommended transportation system. The TAR details how the Interdisciplinary Team weighed the monetary

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benefits and the intangible benefits that an efficient transportation system can facilitate. Section 2.5 in the TAR (2013) discloses that the ML 3 roads within the watershed were analyzed in 2003 Forest-scale roads analysis supporting the revision of the Forest Plan. TAR (2013) section 2.6, Table 9, discloses that approximately $117,505 of annual and deferred road maintenance costs are associated with ML 3 roads within the watershed. This cost represents about 68.4% of the total estimated annual and deferred road maintenance costs in the watershed. In addition, section 2.4 of the TAR (2013) discusses NFS road 582 as a primary access route to developed and nondeveloped recreation sites outside of the analysis area. The cost associated with NFS road 582 is about $81,600 of the estimated $171,505 in road maintenance costs within the Clear Creek watershed, or about 47.6% of the total estimated road maintenance cost.

AWR #42

Thank you for your attention to our concerns. It is our intention that you include in the record and review the literature and other cited documents. Please keep us on the list to receive further communications on this proposal.

Sincerely, Michael Garrity Alliance for the Wild Rockies P.O. Box 505 Helena, Montana 59624 406-459-5936

Thank you for your continued interest in this project. The literature referenced below is contained in the Clear Creek project record and/or the 2010 Forest Plan FEIS Amendment record.

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AWR #43

References cited

Committee of Scientists, 1999. Sustaining the People’s Lands. Recommendations for Stewardship of the National Forests and Grasslands into the Next Century. March 15, 1999.

Reynolds, R. T., R. T. Graham, M. H. Reiser, R. L. Bassett, P. L. Kennedy, D. A. Boyce, Jr., G. Goodwin, R. Smith, and E. L. Fischer. 1992. Management recommendations for the Northern goshawk in the southwestern United States. Rocky Mountain Forest and range Experiment Station and Southwest Region Forest Service. US Dept. of Agriculture, Gen. Tech. Rpt. RM-217.

Wisdom, Michael J.; Richard S. Holthausen; Barbara C. Wales; Christina D. Hargis; Victoria A. Saab; Danny C. Lee; Wendel J. Hann; Terrell D. Rich; Mary M. Rowland; Wally J. Murphy; and Michelle R. Eames. 2000. Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications. General Technical Report PNW-GTR-485 United States Department of Agriculture Forest Service Pacific Northwest Research Station United States Department of the Interior Bureau of Land Management General Technical Report PNW-GTR-485. May 2000.

The literature referenced below is contained in the Clear Creek project record and/or the 2010 Forest Plan FEIS Amendment record.

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Table D-114. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment No. COMMENT FOREST SERVICE RESPONSE

DA 01

Dick Artley 415 NE 2nd Street Grangeville, Idaho 83530 208-983-0181 [email protected]

[retired forest planner, NEPA legal compliance reviewer, forest NEPA coordinator, and forest appeals/litigation coordinator --- Nez Perce National Forest, Idaho, also FEI instructor (Corvallis, Oregon)] Dear Deputy Forest Supervisor Smith,

Opening Statements for Deputy Forest Supervisor Smith

After reading the pre-decisional EA for the Clear Creek Integrated project I must assume you are uncaring and not worthy of the public trust.

You are uncaring because you have approved a pre-decisional EA for a timber sale that will require real restoration work for many years to fix the ecosystem damage you will inflict with the Clear Creek Integrated project. You know this yet you will allow the purchaser to plunder the natural resources in and downstream from the sale area because that’s how obedient line-officers are expected to act. You should be ashamed to turn you back on the countless natural resources that will be harmed. The Boise National Forest is owned by 310 million Americans and you have chosen to trash the recreational opportunities in the area to please corporate America. These people expect USFS decision-makers to protect and conserve their national forests for future generations. You are untrustworthy because the pre-decisional EA contains numerous statements describing how the Clear Creek Integrated timber

Refer to detailed responses to comments DA 01 through DA 64 below. Also, please refer to detailed responses to the following Opposing Views attachments:

• Opposing Views Attachment #1: Respected Scientists Reveal Certainty that Natural Resources in the Forest are harmed (and some destroyed) by Timber Harvest Activities.

• Opposing Views Attachment #3: Harvesting Trees to Reduce Fuels is not only Ineffective at Reducing the Risk of Fire Damage to Human Structures but Harms the Forest Ecosystem.

• Opposing Views Attachment #4: Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest.

• Opposing Views Attachment #9a: Herbicides Containing Glyphosate should Never be Applied to Areas where Mammals (including humans), Fish, or Birds Might Visit. Even Casual Contact Causes Lethal Diseases.

• Opposing Views Attachment #11: Any NEPA Document that Analyzes Treatments to Reduce the Risk of Fire Damage to Homes Located in the WUI must Analyze a Dr. Jack Cohen Alternative in Detail.

• Opposing Views Attachment #18: Following Label Directions on “Approved”

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No. COMMENT FOREST SERVICE RESPONSE

sale will enhance the health of the forest’s natural resources.

Comment #1: Deputy Forest Supervisor Smith, after you read the statements by hundreds of well respected biological scientists who hold Ph.D.s in the attachments to these comments who describe the multiple ways logging harms or destroys the natural resources in the forest please answer the following question:

Why does an intelligent public land manager reject the science literature authored by unbiased, independent scientists and instead believe a single TMA or timber staff (or other USFS employees) with financial incentives to prepare or set the stage to prepare commercial timber sales?

I cannot respect anyone who accepts taxpayer’s money and uses it to provide profit opportunities for corporations while simultaneously trashing the public’s land.

Herbicides Containers does not Assure Safety.

DA 02 Opening Statements for some Members if the IDT

Some members of the IDT know that a few USFS line-officers are obsessed with the notion that they must propose projects that provide natural resource extraction corporations with the opportunity for profit while simultaneously plundering the natural resources on public land. Some members of the IDT also know that Deputy Forest Supervisor Smith’s reasons to propose the Clear Creek Integrated timber sale is budget and timber target related. The non-timber and non-engineering members of the IDT know they have the responsibility to care for and preserve the natural resources on public land. Incredibly, they indicate their approval of this tragic timber sale by allowing their names to be included as preparers. The American people depend on you. Someday you will regret following Deputy Forest Supervisor Smith and not doing the right thing

Refer to the response to DA 01.

The purpose and need for this project is clearly articulated in section 1.5 of the EA.

Each resource specialist has provided detailed effects disclosures for the alternatives assessed in Chapter 3 of the EA.

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for the American people. Living with that guilt isn’t easy. I know.

Nadine, Kathryn, Joe, Kari, Terry, Danelle, Zachary, and Lisa you all know you are allowing your good names to be associated with actions that are the antithesis of what you learned is best for the natural resources you represent. You know this timber sale will hammer the resources for which you are responsible.

I hope the IDT members spend the time to read the attachments to these comments. The attachments represent just a small sample of the literature authored by independent, unbiased scientists (most with Ph.D.s) who describe the many ways the forest’s natural resources are seriously harmed by logging and road construction.

With the statements of several hundred Ph.D. scientists you will all be justified to tell Deputy Forest Supervisor Smith “NO.” Your good names are being used to show justification for a systematic dismantling of the proper functioning of a myriad of natural resources in the forest by logging. Deputy Forest Supervisor Smith uses your names to help prepare NEPA documents for needless timber sales. Are you all aware that the USFS has been predicting (and secretly hoping for) a “timber famine” for many decades?

It’s not too late for the IDT members to act. For the sake of the unborn kids who will need wild places to explore when the population of the United States reaches 500 million in 37 years please tell Deputy Forest Supervisor Smith that you will be writing the truth in the final EA. Indeed, this is the essence of NEPA and an expectation of public employees. Please tell Deputy Forest Supervisor Smith that if the final EA still has lies you want your name removed from the list of preparers.

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DA 03 My pre-decisional EA review summary

I have reviewed the pre-decisional EA for the Clear Creek Integrated timber sale. I am very disappointed that the Boise National Forest is spending my tax money to serve the natural resource extraction corporations. Deputy Forest Supervisor Smith, based on your tragic timber sale proposal you appear to be one of those line-officers who believe liquidating merchantable conifer trees is the most important thing a line-officer can do. Most USFS line-officers (including you) are using the term “to manage” as a synonym for “to log.” Your kind believes the USFS folly that an unmanaged area is an unlogged area.

Refer to the responses to DA 01 and DA 02.

The purpose and need for this project is clearly articulated in section 1.5 of the EA.

DA 04 The Documents that are in the Literature Cited Section of the Pre-Decisional EA have been Carefully Selected to Omit the Truth that Activities Associated with Logging and Roading ALWAYS Cause Natural Resource Degradation.

Refer to the responses to DA 01, DA 02, and DA 03.

Also, please refer to detailed responses to the following Opposing Views attachments:




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DA 05 The attachments to these comments present the “responsible” opposing views of hundreds of independent, unbiased Ph.D. biological scientists who describe the resource damage caused by the majority of commercial timber and road construction sale activities taken at any location, on any topography, at any elevation, at any time. Deputy Forest Supervisor Smith, your responses to each of these opposing views is governed by 40 C.F.R. § 1502.9(a). Please remember, by definition, a viewpoint is a personal opinion, so don’t reject the opposing views because they are “opinions.”

This member of the public has provided the electronic links to the source documents for each opposing view for you to verify that a Ph.D. biological scientist authored the opposing view. Comment: Please include (and cite) the source documents for the opposing views contained in the attachments to these comments in the Literature cited section of the final EA. The public pays you to tell them the truth. The source documents for the opposing views will provide a balance with the pro-timber harvest references you include now. The public should be told both sides of the story.

Refer to the responses to DA 01, DA 02, DA 03, and DA 04. Also, please refer to detailed responses to the following Opposing Views attachments:






• Opposing Views Attachment #18: Following Label Directions on “Approved” Herbicides Containers does not Assure Safety.

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The literature referenced by Mr. Artley in each of the Opposing Views documents identified above has been entered into the project record. The referenced literature that was applicable to the analysis is cited in the EA. Document links provided by Mr. Artley that were no longer correct and for which Mr. Artley did not provide a replacement link per requests on August 11, 2013 (refer to the project record e-mail documentation), have not been included in the record, because they could not be located. However, where possible, the IDT attempted to respond to the “view” that was quoted.

DA 06 Nearly all literature available written by independent, unbiased scientists describes the major long term damage that logging inflicts on the natural resources in the forest. The attachments to these comments quote over 100 Ph.D. biological scientist explaining their research conclusions proved this damage occurs.

Comment: Deputy Forest Supervisor Smith, in this pre-decisional EA you have chosen to reject the research conclusions of many independent, unbiased scientists. Instead, you choose to take the advice of USFS timber employees who are paid to “get out the cut.” Please tell the public why you believe your TMA and/or the forest Timber Staff Officer and reject the findings of experts with no financial gain whether the sale is offered or not.

40 C.F.R. § 1502.9(a) does not allow the Responsible Official to:

1) respond in general to all opposing views in a few paragraphs, or 2) respond with general statements that the adverse effects described by the scientists were “considered” or “analyzed.”

Please refer to detailed responses to the following Opposing Views attachments:




• Opposing Views Attachment #9a: Herbicides Containing Glyphosate should

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Never be Applied to Areas where Mammals (including humans), Fish, or Birds Might Visit. Even Casual Contact Causes Lethal Diseases.



DA 07 It’s a good idea for competent line-officer to examine every statement in their NEPA documents and give them the following litmus test: If a member of the public alleges the USFS statements are untrue and/or illegal, how would a District Court Judge rule.

Comment: Please comply with 40 C.F.R. § 1502.9(a) by responding to each opposing view in Attachments #1 and #4.

Simply telling the public that you considered the opposing views is not enough. You MUST respond to each responsible opposing view. You won’t like it, but it’s the law.

Remember, there are environmental groups that monitor the Boise National Forest who retain pro-bono attorneys.

See the responses to comments DA 01 through DA 06. Attachments #1 and #4, as well as attachments #3, #9a, #11, and #18, have been responded to in detail.

As stated in section 1.9.16 of the EA, “This EA has been prepared under NEPA (42 USC 4321 et seq., 40 CFR 1500-1508) and the Forest Plan as amended in 2010 (USDA Forest Service 2010a and 2010b).”

DA 08 If the Responsible Official is Really Concerned about Aquatic Species’ Health the Final EA MUST Indicate that All Temporary Roads will be Obliterated after Use and the Responsible Official Must do it

The pre-decisional EA indicates temporary road construction is a connected action to this timber sale. The pre-decisional EA indicates

As stated in EA section 2.4.2.1.4, “These temporary roads would be decommissioned following treatment activity.”

Design Feature WF-16 specifically states the

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that temporary roads will be decommissioned after use.

At page 2-10 the pre-decisional EA states: “2.4.2.1.4 Miles of Temporary Road Needed to Support All Vegetation Management

Approximately 4.6 miles of temporary road would be constructed to facilitate the vegetation treatments described above. These temporary roads would be decommissioned following treatment activity. Refer to Figure 2-4.” At page 2-16 the pre-decisional EA states:

“Decommission approximately 5.5 miles of currently unauthorized roads that were not intended to be part of the long-term road system in the area. These roads were used for past logging or are user-created; these types of roads are not maintained as part of the transportation system. Approximately 22 road segments are proposed for decommissioning, ranging from 0.03 miles to 0.8 miles in length. The entrance to each road would be recontoured for a minimum of 100 feet where feasible; otherwise, the entrance would be blocked with earthen barriers and/or rocks to deter motorized access. Drainage features would be installed as needed, and affected road segments would be seeded with grass seed; in select locations, conifers would be planted and the roadbed recontoured. Motorized OSV use would be allowed if the decommissioned road is located within an area open to motorized OSVs. No change to the District MVUMs would be needed for 4.2 miles of the roads being decommissioned, because those miles are currently not open to public motorized use. Approximately 1.3 miles of the unauthorized roads proposed for decommission are currently identified as motorized trails open to public motorized use on the MVUM in the Logging Gulch area. These 1.3 miles will be

following:

WF-16—Unauthorized roads used to facilitate proposed mechanical treatments will be identified as temporary roads (refer to Figure 2-6 [Alternative B] and Figure 2-8 [Alternative C]). During prolonged periods of nonuse, install waterbars and cross-ditches on these temporary roads following spacing criteria in WF-13. Upon completion of use of these temporary roads, carry out the following activities:

a. Recontour access points for a minimum of 100 feet where feasible; otherwise, block the entrance with earthen barriers and/or rocks to deter unauthorized motorized access.

b. Remove all culverts and restore stream bank to the preexisting channel.

c. Sign the roadbed as closed to motorized use to deter unauthorized motorized access.

d. Rip the road prism to a minimum depth of 18 inches to address soil compaction and initiate soil restoration.

e. Construct waterbars or cross-ditches where needed to provide adequate drainage, and install erosion control measures to minimize sediment delivery.

f. Apply grass seed to affected road segments; and in select locations, plant conifers on recontoured sections to expedite vegetative recovery and further reduce potential sediment delivery.

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removed from the MVUM and no longer open to public motorized use (Figure 2-7). “

Please understand your contradiction. Some unauthorized roads discussed above are temporary roads constructed decades ago and not decommissioned as the public was promised. These roads have been pumping sediment into the streams every time it rains.

Comment: Deputy Forest Supervisor Smith, if you cared more about the aquatic species health in the Boise National Forest than you do “getting out the cut” you would apply the most effective sediment reduction measures that exist to eliminate the sediment originating from temporary roads. Please obliterate all temporary roads after use and tell the public this will be done in the final EA.

An obliterated road contains no running surface, because the natural sideslope that existed before the road was constructed is reestablished. Not obliterating a road because the line-officer will use it again to haul logs from the area means the road is not temporary! Therefore the road should be constructed to system road standards, or not at all. Decommissioning these roads will not remove the running surface. Therefore, since temporary roads are outsloped with no ditch, sediment will be generated during precipitation events, find its way to streams and harm the aquatic resources for decades until the next timber sale reconstructs the so-called “temporary” road. Then the riparian resource cycle of destruction begins again.

The final EA will clearly state these roads will be obliterated after use.

DA 09 Deputy Forest Supervisor Smith it Appears that Volume Accumulation is more Important to you than Reducing the Risk that Human will Burn to Death should a Wildfire Occur

Seven specific purpose and needs for this project are identified in section 1.5 of the EA. While these are listed as #1 through #7, the number order does not

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The pre-decisional EA at page 1-2 states:

“Hazardous fuels management in the wildland–urban interface (WUI). The Project area falls within a WUI identified in the Boise County Wildfire Protection Plan (CWPP) (Boise County 2003). Both the Boise CWMP and the Forest Service identified residential areas within this WUI that are at risk due to hazardous fuel conditions that exist on surrounding lands, including those within the Clear Creek Project area. The Proposed Action would help reduce existing hazardous ladder fuel conditions within the WUI. Forest-wide guideline WIGU18 states that both hazardous fuel reduction and wildlife habitat conservation and restoration objectives should be met when they are not in conflict (USDA Forest Service 2010c, pp. 12–13). “

Clearly THE most important responsibility of a public land manager is to protect the safety of the public living near national forest land should a wildfire occur. This means all caring, competent public servants must take the most effective action to reduce the risk of fire damage to homes located in the WUI. To do otherwise by responding to less important Purpose & Need statements defines a line-officer obsessed with volume.

Comment: The public living in the WUI wants to know why you place merchantable tree removal actions described in the Purpose & Need more important than human lives. Much of your P&N describes what a private industrial tree farm manager would strive to do on the land under his/her control. Why does mimicking private industrial tree farm transcend the importance of reducing the risk of homes burning?

reflect a priority or emphasis.

Purpose and Need #2 was specifically developed to address hazards within the WUI: “Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas.” The vegetation management strategy on the Forest is clearly spelled out in the 2010 Forest Plan. This strategy is summarized in EA section 1.2: “The vegetative management strategy for the Forest Plan calls for managing within the historic range of variability (HRV), using a combination of passive and active management. The strategy is based on the assumption that conditions that fall within the HRV will promote a network of habitats to support the diverse array of native and nonnative vertebrate wildlife species.” Section 1.2 of the EA goes on to state the following: “… The Proposed Action would help reduce existing hazardous ladder fuel conditions within the WUI. Forestwide guideline WIGU18 states that both hazardous fuel reduction and wildlife habitat conservation and restoration objectives should be met when they are not in conflict.” As disclosed in EA Chapter 3, section 3.3, both hazardous fuel reduction and wildlife habitat conservation and restoration objectives will be met within WUI treatment areas.

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DA 10a

Dr. Jack Cohen is a USFS fire physicist working in Missoula, Montana. He has devoted his entire working career researching methods to reduce the risk of fire damage to homes located in the WUI.

Comment: Deputy Forest Supervisor Smith since you ignore the most effective fire damage risk reduction actions in existence today in favor or using the fuels-reduction excuse to “get-out-the-cut” please tell the public your acceptable conversion using human deaths/MBF. Comment: Please comply with 40 C.F.R. § 1502.9(a) by responding to each opposing view in Attachments #3 and #11.

See the responses to comments DA 01 through DA 09. How the alternatives reduce fire risk is fully disclosed in EA Chapter 3, section 3.3.

Attachments #3 and #11, as well as attachments #1, #4, #9a, and #18, have been responded to in detail.

As stated in section 1.9.16 of the EA, “This EA has been prepared under NEPA (42 USC 4321 et seq., 40 CFR 1500-1508) and the Forest Plan as amended in 2010 (USDA Forest Service 2010a and 2010b).”

DA 10b

Dr. Cohen recommends removing fine flash fuels within a few hundred feet of a home at risk. That’s why kindling is used to start a fire in the fireplace, Deputy Forest Supervisor Smith, you have not chosen to analyze a Dr. Cohen alternative in detail. A Cohen alternative would propose to spend earmarked fire funding to:

• educate the public with by providing each homeowner in the WUI written material that summarizes Dr. Cohen’s findings.

• educate the public using USFS organized public meetings to answer questions about the types of fine fuels that Dr. Cohen recommends should be removed.

• and most importantly offer USFS labor to help elderly and disabled people living in the WUI (with their written permission) to remove the fine fuels near their home as Dr. Cohen suggests.

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component.

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DA 11 Dr. Cohen states: “Research results indicate that the home and its immediate surroundings within 100-200 feet (30-60 meters) principally determines the home ignition potential during severe wildland-urban fires. Research has also established that fire is an intrinsic ecological process of nearly all North American ecosystems. Together, this understanding forms the basis for a compelling argument for a different approach to addressing the wildland-urban fire problem.” (Pg. 1 – abstract) Source for quote above: Wildland-Urban Fire—A different approach http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed.

The 100–200 feet of the home ignition zone is managed by the Forest Service. As a participant in the collaborative group, the Forest Service is trying to reduce hazards in the home ignition zone prior to the arrival of a wildland fire, as suggested by Dr. Cohen.

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1).

Furthermore, section 3.3.3.1 of the EA states the following: “Although the probability of ignition is unpredictable. Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as

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http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf



ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

DA 12 Dr. Cohen states: “Extensive wildland vegetation management does not effectively change home ignitability.” (Pg. 5)

Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

Comment: Dr. Cohen states “Extensive wildland vegetation management does not effectively change home ignitability.” How does the Clear Creek Integrated timber sale differ such that his conclusion is not true in the timber sale location?

The citation Mr. Artley provided for Dr. Cohen’s statement is incorrect. The actual source for the quotation is “Reducing the Wildland Fire Threat to Homes: Where and How Much.”

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself.

The quotation cited in DA 12 is taken out of context to oppose vegetative treatments within the WUI. For fuller context, note that the cited publication also states the following: “This should not imply that wildland vegetation management is without a purpose and should not occur for other reasons.” Additional purpose and needs of the Project are restorative in nature and thus indirectly benefit the WUI in the low- to mid-elevation forests; see EA section 1.5:

Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1. Purpose and Need 2: Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3);

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http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/%7E/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf





where forests are at an elevated risk, reduce hazards, particularly in WUI areas. Restoring PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what current exists (i.e., high stand densities, abundant ladder fuels, low canopy base heights, and/or a dense shrub component) will provide more open-crowned stands, which increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas (summarized from EA section 3.3.4.1.1).

DA 13 Dr. Cohen states: “As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5) Source for quote above: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself, which is the responsibility of the homeowner.

The property surrounding the Long Creek summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed.

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http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf



DA 14 Dr. Cohen states: “Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands.” (Pg. 4)

Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States

Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

The citation Mr. Artley provided for Dr. Cohen’s statement is incorrect. The actual source for the quotation is “Structure Ignition Assessment Can Help Reduce Fire Damages in the WUI.”

The Project is focused on reducing the fire behavior in and around the WUI. The property surrounding the Long Creek summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component. An additional purpose and need of the Project is restorative in nature and thus benefits the WUI; see EA section 1.5:

Purpose and Need 2: Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas.

The goal is to restore PVGs 1, 2, and 3, where the

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WUI is located, to a more characteristic vegetative state than what currently exists. As stated in EA section 3.3.4.1.1 “…high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory.” And section 3.3.4.1.2 continues, “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” “These more open-crowned stands also increase the

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safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas” (EA section 3.3.4.1.1).

DA 15 Dr. Cohen states: “Past reports and recommendations as well as experimental research and modeling suggest that W-UI fire-loss mitigation should concentrate on the residence and its immediate surroundings. Any strategy for effectively reducing the W-UI fire problem must initially focus on residential fire resistance.” (Pg. 5 – Conclusion) Source for quotes above: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself, which is the responsibility of the homeowner.

The property surrounding the Long Creek summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component.

DA 16 Dr. Cohen states: “Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-UI fire loss problem.” (Pg. 9) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United

The citation Mr. Artley provided for Dr. Cohen’s statement is incorrect. The actual source for the quotation is “What is the Wildland Fire Threat to Homes?” The paper cited by Mr. Artley in DA 16, as corrected, is not available at the location provided; and could

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States


not be located.

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself, which is the responsibility of the homeowner. EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1).

Additional purpose and needs of the Project are restorative in nature and thus benefit the WUI; see EA section 1.5:

Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1. Purpose and Need 2: Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas. The goal is to restore PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists. As stated in EA section 3.3.4.1.1, “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and

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a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory”. “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area”. And EA section 3.3.4.1.2 continues, “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and

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severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

EA sections 3.2.2.1.1 and 3.2.2.1.2 state that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

As disclosed in the EA, treatments beyond the WUI play a role in overall safety factors within the WUI. As stated in the EA: “These more open-crowned stands also increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas,” as described in section 3.3.4.1.1.

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DA 17 Dr. Cohen states: “Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction.” (Pg. 10) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

The citation Mr. Artley provided for Dr. Cohen’s statement is incorrect. The actual source for the quotation is “What is the Wildland Fire Threat to Homes?”

The paper referred to by Mr. Artley in DA 17 as corrected is not available at the location provided, and the paper containing DA 17 citation could not be located. Additional purpose and needs of the Project are restorative in nature and thus benefit the WUI; see EA section 1.5.

Also, refer to the response to DA 16.

DA 18 Dr. Cohen states: “Thus, wildland fuel reduction that is effective for reducing the wildland fire intensity might be insufficient for reducing the destruction of highly ignitable homes. In contrast, a low home ignition potential reduces the chances of fire destruction without extensive wildland fuel reduction. These findings indicate that the W-UI home fire loss problem is a home ignitability issue largely independent of landscape fuel reduction issues.” (Pg. 10) Source for quote above: What is the Wildland Fire Threat to Homes?

Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

The paper referred to in DA 18 is not available at the location provided and could not be located elsewhere. The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself.

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service owns the lands surrounding the

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http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf



summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component. Also, please refer to the responses to DA 16 and DA 17.

DA 19 Dr. Cohen states: “Vegetation management to prevent ignitions from radiation does not require extensive vegetation removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for a 20 meter flame height.” (Pg. 86 – Conclusions) Source for quote above: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management

Presented at the 13th Fire and Forest Meteorology Conference. Lorne, Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf

The paper cited in DA 19 is not available at the location provided and could not be located elsewhere.

The property surrounding the Long Creek summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component. Also, please refer to the responses to DA 16, DA 17, and DA 18.

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http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf




DA 20 Dr. Cohen states: “Many scientists and natural resource agencies suggest extensive fuel treatments to reduce the possibility of severe and intense wildfires that could damage ecosystems, destroy property, and take human life (USDA Forest Service, 2000; GAO, 2003a,b). However, there are a number of misconceptions and misunderstandings about fuel treatments and their use as a panacea for fire hazard reduction across the United States (Finney and Cohen, 2003; Franklin and Agee, 2003).” (Pg.1998) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States


The findings presented in DA 20 are not disputed in the Project EA.

DA 21 Dr. Cohen states: “Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ‘‘fire-proof’’ important areas. It would be virtually impossible to exclude fire from most temperate terrestrial ecosystems because ignition sources are prevalent and fuels cannot be eliminated. Ignition is rarely affected by fuel treatment.” (Pg.1998) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). EA section 3.3.3.1 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions

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No. COMMENT FOREST SERVICE RESPONSE Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf can alter the last 3 factors and greatly influence fire

severity and intensity should a wildfire occur.”

DA 22 Dr. Cohen states: “Bessie and Johnson (1995) show weather (fuel moisture and wind) is far more important than fuels in determining fire behavior; reducing fuels may have a limited impact on fire occurrence.” (Pg.1999) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

EA section 3.3.3.1 states the following: “Although the probability of ignition is unpredictable, once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

The Purpose and Need for the Project is consistent with what is cited in Mr. Artley references on page 1999 first paragraph, “Even the most intensive fuel treatment may be rendered ineffective by the dynamics of large wildfire behavior, so designing treatments to minimize adverse fire effects may be a more effective strategy than designing treatments that attempt to exclude fires.” Similarly, Purpose and Need #2 states treatments will reduce not eliminate risk: “Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas” (EA section 1.5). And EA section 3.3.4.1.2 states, “Given existing conditions currently there could be an increase in the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the

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nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

And EA section 3.3.5.2.4 states, “…surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.”

EA section 3.3.5.2 can be summarized as follows: Following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural

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conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means.

The above disclosure in the EA is consistent with findings in the cited article.

DA 23 Dr. Cohen states: “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). EA section 3.3.3.1 states, “Although the probability of ignition is unpredictable…”, “once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.” Also refer to response DA-22.

DA 24 Dr. Cohen states: “It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, and the degree to which the residential structures

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to

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themselves can ignite that determine if the residences are vulnerable.” (Pg.1999) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself. The property surrounding the Long Creek summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildland fire from the vegetative component.

DA 25 Dr. Cohen states: “Thinning to reduce crown fire potential requires careful evaluation of the tradeoffs in treatment effects on potential surface fire behavior and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result in increased potential surface fire behavior, for several reasons. First, thinning reduces the moderating effects of the canopy on windspeed, so surface windspeed will increase (Graham et al., 2004). It also results in increased solar radiation on the forest floor, causing drier surface fuels. It may also cause an increase in flammable grassy and shrub fuels over time, due to the

The findings presented in DA 25 are not disputed in the Project EA. Refer to the responses to DA16, DA 17, and DA 18. In addition, treatments as proposed would result in “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A,

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reduced tree competition.” (Pg.2000)

Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States


thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases” (EA section 3.3.5.2[and by reference the same in 3.3.5.3]).

“Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes” (EA section 3.3.5.3).

DA 26 Dr. Cohen states: “Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000)

Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf


See the response to DA 25.

DA 27 Dr. Cohen states: “Treating fuels may not improve ecosystem health. Ecosystem restoration treatment and fuel treatment are not


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synonymous. Some ecosystem restoration treatments reduce fuel hazard, but not all fuel treatments restore ecosystems. Ecosystem restoration treatments are often designed to recreate presettlement fire regimes, stand structures and species compositions while fuel treatment objectives are primarily to reduce fuels to lessen fire behavior or severity—this is known as ‘’hazard Reduction.’’ Achieving fuel hazard reduction goals in the absence of ecosystem restoration is insufficient (Dombeck et al., 2004; Kauffman, 2004).” (Pg.2000) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States


Refer to the responses to DA 16, DA 17, and DA 18.

In addition, (EA section 3.3.5.2[and by reference the same in 3.3.5.3]).states, “Proposed treatments would include a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives” Noncommercial thinning (NCT): “These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species

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composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen” (EA section 3.3.5.2[and by reference the same in 3.3.5.3]). “Additionally a low to moderate intensity prescribed fire broadcast maintenance burning would be applied after mechanical and fuel treatments, to further reduce fine fuels, promote regeneration of desired species, and gain the ecological benefits of fire within these landscapes. Fuels reduction treatments within RCAs must be consistent with design features. Treatments would re-pattern tree size classes, resulting in a combination of overstory and understory groups, clumps, and openings of varying number and sizes. This re-patterning would reduce stand densities and decrease the continuity of ladder fuels, thereby reducing the risk of a surface fire transitioning to a crown fire. These improvements would increase the likelihood that wildfire behavior would be characteristic for the fire regime” (EA section 3.3.5.2.3). Effects of these treatments as described in section

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3.3.5.2.4, would result in “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes”

These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with fire (prescribed and/or wildfire). (EA section 3.3.5.2.2).

DA 28 Comment: Jack Cohen is a fellow USFS employee who holds a Ph.D. in fire physics. After decades of research on how best to protect homes from fire damage during a wildfire, Dr. Cohen concludes fuels reduction logging is ineffective. Dr. Cohen’s advice is sought out worldwide. Dr. Cohen is one the world’s experts on methods to reduce the risk that homes will burn during a wildfire. Deputy Forest Supervisor Smith, you have chosen to reject Dr. Cohen’s research

As demonstrated by the detailed responses to the following attachments, Dr. Cohen’s research and conclusions have clearly been considered in this analysis:

• Opposing Views Attachment #3: Harvesting Trees to Reduce Fuels is not only Ineffective

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conclusions and instead take the advice of your TMA and FMO. at Reducing the Risk of Fire Damage to Human Structures but Harms the Forest Ecosystem.


DA 29 Comment: Dr. Cohen states “Ecosystem restoration treatment and fuel treatment are not synonymous.” How does the Clear Creek Integrated timber sale differ such that Dr. Cohen’s conclusion is not true in this timber sale location?



DA 30 Dr. Ingalsbee and Dr. Fox state: “We cite evidence that logging-induced changes in fuel composition, vegetation, and microclimate can result in increased rate of fire spread, higher fireline intensity, and more severe fire effects.” (Abstract-2nd paragraph)

Source for quote above: Fuel Reduction for Firefighter Safety Published in Proceedings of the International Wildland Fire Safety Summit Winthrop, WA, Oct. 26-29, 1998 http://www.fusee.org/docs/fuelbreaks/fuel_reduction_copy.htm

Comment: Dr. Ingalsbee and Dr. Fox say “logging- induced changes in fuel composition, vegetation, and microclimate can result in increased rate of fire spread, higher fireline intensity, and more severe fire effects.” What scientific evidence does the Responsible Official have showing this is untrue?

In the cited article, Dr. Ingalsbee and Dr. Fox go on to say the following: “Instead, treatment of surface and ladder fuels through prescribed fire combined with manual pre-treatments (for example, non-commercial thinning, pruning, and hand-piling) can effectively reduce the risk of crown fires, increase firefighter safety, and improve ecosystem health.” As stated previously, the Project is a restoration project that includes treatments, both in the WUI and outside the WUI, that will reduce fire behavior such as crown fire and surface flame lengths.


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http://www.fusee.org/docs/fuelbreaks/fuel_reduction_copy.htm



DA 31 Dr. Ingalsbee states: “Time does not permit me to go into details about the prescriptions for the HazRed project, but the community "freaked out" when they saw the results of the timber marking crew: over 8,000 trees over 20 inches DBH marked for cutting, including a couple rare 6 foot DBH sugar pines. The community felt that HazRed was essentially a timber sale functioning as a "Trojan Horse" to set the precedent for commercial logging in an improper place using fuels reduction as an illegitimate excuse.” Source for quote above: "Analysis Paralysis" to Agency-Community Collaboration in Fuels Reduction for Fire Restoration: A Success Story From an Oral presentation to the Conference on Fire, Fuel Treatments and Ecological Restoration: Proper Place, Appropriate Time, April 18, 2002 Fort Collins, CO http://www.fire-ecology.org/research/FtCollins_speech.html

Comment: The public detests commercial logging in their national forest land, especially when the reason given for the logging is untrue does not help them during a wildfire. Many members of the public know fuels reduction logging is an excuse to get volume.

Refer to the responses to comments DA 09 through DA 30. Also, please note the following statement from section 1.3 of the EA:

“In September 2010, a collaborative group called the Boise Forest Coalition was formed, bringing together diverse interests to engage in planning a multifaceted forest project. The citizen-led Boise Forest Coalition represents several public and organizational interests and has an open membership. Soon after their formation, the Coalition partnered with the Forest to provide input on the Clear Creek Integrated Project. The Coalition’s goal for involvement in the Project was to offer recommendations that address the following resource, economic, recreational, and societal needs: 1) bull trout (Salvelinus confluentus) recovery, 2) forest health, 3) ecological restoration, 4) fish and wildlife habitat, 5) a variety of trail-related recreational pursuits, 6) fuel hazard reduction around summer homes, and 7) job opportunities and production of forest products. The Coalition worked in a collaborative fashion, including consultation with the Forest Service, for about one year to develop a set of recommendations. The Boise Forest Coalition’s recommendations provide one basis for the Proposed Action. Information on the Boise Forest Coalition and their involvement with the Forest can be found at www.idahoforestpartners.org/planning-and-organizational-resources.html.”

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http://www.fire-ecology.org/research/FtCollins_speech.html

http://www.idahoforestpartners.org/planning-and-organizational-resources.html




The recommendations from this collaborative group (representing various interest groups and individuals) formed the basis for the Proposed Action presented in the EA.

DA 32 Dr Agee states: “large, severe wildfires are more weather-dependent than fuel-dependent,” Source for quote above: “The Severe Weather Wildfire-Too Hot to Handle?” Northwest Science, Vol. 71, No. 1, 1997

http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf

Comment: The Clear Creek Integrated timber sale removes fuels to reduce wildfire severity and rate of spread in spite of what Dr. Agee says. Why is his statement that fires are more weather –dependent than fuel-dependent not the case here?

The cited quotation from View #1 is the hypothesis that Agee’s paper debates. The following text is the paragraph from which the quotation is extracted:

“Recent statements in the scientific literature and popular press suggest that recent large, severe wildfires in western North America are largely due to extreme weather. The long-accepted view of fire behavior as a function of fuels, weather, and topography has changed for some from an equilateral fire triangle, where each factor can be significant, to a distorted isosceles triangle with a wide base being the weather contribution to fire behavior. This ‘weather hypothesis’ that all large, severe wildfires are more weather-dependent than fuel-dependent….” Agee concluded the following: “Attempts to apply either the ‘fuel hypothesis’ or ‘weather hypothesis’ to all western landscapes are as misguided as our now-abandoned attempts this century to develop a grand, unified model of plant succession…Let us not repeat the same mistake now with our views on disturbance in ecosystems: there is not a one-size-fits all approach. Although the physical principles of fire apply everywhere, different forest types with unique organisms and fuels types, and differing environments, will assure that fire behavior will have

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a range of important contribution factors: not always fuel, and not always weather….” EA section 3.3.3.1states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

DA 33 Dr. Alison states: “One reason that fuels reduction treatments should be limited is that they may not address the important effects of climate and weather on fire behavior. Some studies suggest that it is drought and warmer temperatures—not fuels accumulations—that are the major explanatory factors for large fires (O’Toole 2002-2003, Pierce et al. 2004). It is an unrealistic goal to return all forests to historical states, in light of the fact that agencies have no control over drought or temperature.” (pgs. 15 – 16) Source for quote above: “Forest Policy Up in Smoke: Fire Suppression in the United States.” A PERC publication, 2007

http://www.law.northwestern.edu/searlecenter/papers/Berry_forest_policy.pdf

Comment The EA does not indicate that fire behavior is highly dependent on climate and weather on fire behavior … more than fuels accumulations.

The cited publication, Berry (2007), was not located at the Web site provided. However, the publication was found athttp://www.isnie.org/assets/files/papers2007/berry.pdf In the paragraph following the cited statement from which View #3 is extracted, Berry states this: “Fuels reduction treatments are only necessary in some areas, such as ponderosa pine and longleaf pine forests that are adapted to frequent, low-intensity fires. This fire regime makes up about half of federal forests, about three-quarters are in need of fuels reduction treatments—a total of 83 million acres (FMI 2001). At a rate of 2.5 million acres per year, this area could be treated for hazardous fuels reduction in about 33 years. Also, these forests are likely the easiest to treat for fuels reduction, and therefore least costly.”

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Purpose and Need #2 of the Project is to reduce fuel buildup and ladder fuel continuity within the low-elevation ponderosa pine forests in order to reduce the risk of uncharacteristic surface and crown fire; this purpose and need is consistent with Berry’s recommendations (EA page 1-8).

Also see the response to DA 32.

DA 34 Dr. Bessie and Dr. Johnson state: “Fire intensity was correlated to annual area burned; large area burned years had higher fire intensity predictions than smaller area burned years. The reason for this difference was attributed directly to the weather variable frequency distribution, which was shifted towards more extreme values in years in which large areas burned. During extreme weather conditions, the relative importance of fuels diminishes since all stands achieve the threshold required to permit crown fire development. This is important since most of the area burned in subalpine forests has historically occurred during very extreme weather (i.e., drought coupled to high winds). The fire behavior relationships predicted in the models support the concept that forest fire behavior is determined primarily by weather variation among years rather than fuel variation associated with stand age.” Source for quote above: “The Relative Importance of Fuels and Weather on Fire Behavior in Subalpine Forests”Ecology, Vol. 76, No. 3 (Apr., 1995), pp. 747-762. Published by the Ecological Society of America

http://www.jstor.org/pss/1939341

Comment Why don’t USFS fire behavior models support the concept that forest fire behavior is determined primarily by weather?

Agee (1997), the source cited in DA 32, states the following: “Bessie and Johnson [1995] do an excellent job in establishing weather as a primary factor affecting wildfire size in subalpine forests near the boreal forest ecotone in Alberta, and the title of their paper clearly states that it focuses on subalpine fir forests. As none of the tree dominants are fire-resistant (all are thin-barked), these fires are also high-severity fires. However, the implied generality of some statements in the paper have encouraged others, including those quoted in the popular press, to conclude that the results of this study are applicable everywhere. Evidence from studies in other areas suggests that these statements should not be generalized to all forest types.”

“The ‘weather hypothesis’ can be accepted for subalpine forests, where fires are infrequent, often intense, and of high severity.”

“While the first two forest types might suggest that the ‘weather hypothesis’ is indeed robust, the third forest type provides ample evidence that fire severity, even in large fires, can be fuel dependent. Mixed-conifer forests of several types that have ponderosa

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pine as a dominant had a historical fire regime of frequent fires, typically of low-intensity and low-severity (Agee 1993).” As stated in EA section 3.17.2, “Mitchell et al. [2009] concluded that ‘effected stand severity’ from wildfire may be decreased by increasing the removal of understory (e.g. ladder fuels)…They stated, however, that this finding is most likely correlated with forests that historically had frequent fire where overall biomass levels may be uncharacteristically high now compared to historical levels. In forests with historically long fire return intervals…treatments likely do not provide the same benefit since these types of forests are less likely to be ‘departed’ and fire severity is more often a function of weather [drought] than fuel.”

Also see the response to DA 32.

DA 35 Dr. Kelly states: “There is a gathering body of evidence that large wildfires are not determined by “unnatural” fuel loading. Lodgepole pine, subalpine fir, and aspen depend on infrequent, stand-replacing, high intensity fires. Most of the B-D NF is well within the natural range of variability. In fact, dense forest stands may not be caused by fire exclusion, but by a series of consecutive wet years that boosted seedling survival and expanded the local range. Drought, wind, and low humidity, not fuels loads, drive large wildifires. Weather and climatic conditions are also the driving force behind expanding insect populations.” Source for quote above: “Cheap Chips, Counterfeit Wilderness: Greenwashing Logging on Montana's Biggest National Forest.” Published by the World Prout Assembly, 2007

The paper cited in View #35 is not available at the location provided. See the responses to DA 32, DA 33, and DA 34. In addition to the treatments discussed in these previous responses, “Prescribed fire broadcast maintenance burns would also be applied following the mechanical and fuel treatments discussed above, to further reduce fine fuels, promote regeneration of desired species (i.e., ponderosa pine and aspen), and gain the ecological benefits of fire within these landscapes” (EA section 2.4.2.1.1).

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http://www.worldproutassembly.org/archives/2007/12/cheap_chips_cou.html

Comment: The Clear Creek Integrated timber sale removes fuels to reduce wildfire severity and rate of spread in spite of what Dr. Kelly says. Why are Dr. Kelly’s statements that fires are driven by drought, wind, and low humidity not the case in this post-fire area? Also, how will you replicate the fire benefits to the natural resources that exist in your timber sale area if the fires don’t occur?

DA 36 Dr. Partridge states: “The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.” Source for quote above: Testimony to the Agriculture, Nutrition and Forestry Committee United State Senate. Hearing to Review Healthy Forests Restoration Act, HR 1904 June 26, 2003 http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml

Comment Why don’t USFS fire behavior models support the fact that the principal factors affecting fire are temperature and moisture, not fuels?


DA 37 Dr. Mike Dombeck (past USFS Chief) states: “The priority for fuels management should be the wildland-urban interface (WUI) and municipal watersheds, not fire-burned trees in the backcountry. Source for quote above: “Wildfire Policy and Public Lands: Integrating Scientific Understanding with Social Concerns across Landscapes” Published in: Conservation Biology Volume 18, No. 4, August 2004, page 887

How each of the alternatives assessed in detail reduces fire risk/hazard within the WUI is disclosed in EA section 3.3. The economic cost of the various actions that would be taken to accomplish purpose and need is clearly identified in EA section 3.14.

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http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml




http://www.sierraforestlegacy.org/Resources/Conservation/FireForestEcology/FireScienceResearch/FireEcology/FireEcology-Dombeck04.pdf

Comment: Actions similar to the Clear Creek Integrated timber sale are precisely what USFS Chief Dombeck says should not occur because the cost is high and it does not reduce the fire damage risk for people living in the WUI.

DA 38 Dr. Schoennagel, Dr. Veblen and Dr. Rommie state: “Variation in daily area burned was highly correlated with the moisture content of 100-hour (2.5- to 7.6- cm diameter) and 1000-hour dead fuels (Turner et al. 1994). Once fuels reached critical moisture levels later in the season, the spatial pattern of the large, severe stand replacing fires was controlled by weather (wind direction and velocity), not by fuels, stand age, or firefighting activities (Minshall et al. 1989,Wakimoto 1989, Turner et al. 1994).” (Pg. 666)

Source for quote above: “The Interaction of Fire, Fuels, and Climate across Rocky Mountain Forests” Bioscience, July 2004 / Vol. 54 No. 7 http://www.montana.edu/phiguera/GEOG430/PurdyFireFieldTrip/Schoennagel_et_al_2004_Bioscience.pdf

Comment: In the response to comments in the final NEPA document please tell the public why Dr. Schoennagel, Dr. Veblen and Dr. Rommie are wrong when they all agree that “once fuels reached critical moisture levels later in the season, the spatial pattern of the large, severe stand replacing fires was controlled by weather (wind direction and velocity), not by fuels or stand age.”

The findings of #38 are not disputed in the Project EA. The paper from which the quotation was extracted also states the following: “Therefore, we expect fuel-reduction treatments in high-elevation forests to be generally unsuccessful in reducing fire frequency, severity, and size, given the overriding importance of extreme climate in controlling fire regimes in this zone. Thinning also will not restore subalpine forests, because they were dense historically and have not changed significantly in response to fire suppression. Thus, fuel-reduction efforts in most Rocky Mountain subalpine forests probably would not effectively mitigate the fire hazard, and these efforts may create new ecological problems by moving the forest structure outside the historic range of variability (Veblen 2003, Romme et al. 2004).” “In contrast, for many low-elevation, dry ponderosa pine forests, it is both ecologically appropriate and operationally possible to restore a low-severity fire regime through thinning and prescribed burning (Covington et al. 1997, Allen et al. 1998, 2002). Fuels rather than climate appear to be the most significant factor affecting fire spread and severity in

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http://www.montana.edu/phiguera/GEOG430/PurdyFireFieldTrip/Schoennagel_et_al_2004_Bioscience.pdf




these forests. Fire suppression in dry ponderosa pine forests appears to have contributed to an unprecedented buildup of fuels and to the occurrence of high-severity fires. Indeed, the objectives of fire mitigation and forest restoration generally converge in forests of this type.”

The treatments proposed in the low-elevation ponderosa pine forests in the Project area (EA section 3.4.2.2) are consistent with the conclusions from Schoennagel et al. (2004); see Purpose and Need #2 (EA section 1.5). Treatments in the mid- to upper-elevation forests are for a purpose other than fuel reduction, as these areas are currently close to or within desired conditions (EA section 1.5, Purpose and Need #3).

DA 39 Dr. Schoennagel and her research team conclude: “We assessed the extent to which these treatments were conducted in and near the wildland–urban interface (WUI), where they would have the greatest potential to reduce fire risk in neighboring homes and communities. Although federal policies stipulate that significant resources should be invested in the WUI, we found that only 3% of the area treated was within the WUI, and another 8% was in an additional 2.5-km buffer around the WUI, totaling 11%.” Source for quote above: “Implementation of National Fire Plan treatments near the wildland–urban interface in the western United States”from Proceedings of the National Academy of Sciences, May 1, 2009 http://spot.colorado.edu/~schoenna/images/Schoennagel_2009_PNAS_NFP.pdf

Comment: Dr. Schoennagel is a research scientist in CU-Boulder's

The Project contains a wildland-urban interface purpose and need (EA section 1.5, Purpose and Need #2).

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http://spot.colorado.edu/%7Eschoenna/images/Schoennagel_2009_PNAS_NFP.pdf

http://spot.colorado.edu/%7Eschoenna/images/Schoennagel_2009_PNAS_NFP.pdf



geography department. Her research team included Dr. Cara R. Nelson, Dr. David M. Theobaldc, Dr Gunnar C. Carnwathb, and Dr. Teresa B. Chapmana. The Responsible Official should not ignore their conclusion that most fuels reduction timber sales are located far from the WUI where they are much less likely to reduce the risk that homes located in the WUI will burn.

DA 40 Matthew Koehler states: “As news reports about the wildfires came in from the western U.S. during August of 2000, Mark Rey must have seen some opportunity among the flames.

That's because Mark Rey, the timber industry and the Forest Service recognize that the wildfires of 2000 may perhaps be their last real opportunity to return to the glory days of the Reagan Administration, when taxpayer-subsidized logging and roadbuilding dominated our national forests - regardless of the consequences. And regardless of the truth. At the time of the 2000 wildfires, Rey - a former timber industry lobbyist with the unique knack for finding excuses to "get the cut out" - was serving as a staff member for the U.S. Senate Committee on Energy and Natural Resources. In this capacity, Rey was the brains behind staunchly pro-timber Senator Larry Craig's (R-ID) efforts to dramatically increase logging and roadbuilding on America's national forests.”

Source for quotes above: “Mark Rey Wants to Take Our Forests Away Author: Matthew Koehler A Native Forest Network publication, 2003 http://www.nativeforest.org/campaigns/public_lands/rey1_5_30_02.htm

Comment: The public expects the men and women who they pay to

The vegetation management strategy on the Forest is clearly spelled out in the Forest Plan as amended in 2010. This strategy is summarized in section 1.2 of the Project EA: “The vegetative management strategy for the Forest Plan calls for managing within the historic range of variability (HRV), using a combination of passive and active management. The strategy is based on the assumption that conditions that fall within the HRV will promote a network of habitats to support the diverse array of native and nonnative vertebrate wildlife species.” Section 1.2 of the EA goes on to state the following: “… The Proposed Action would help reduce existing hazardous ladder fuel conditions within the WUI. Forestwide guideline WIGU18 states that both hazardous fuel reduction and wildlife habitat conservation and restoration objectives should be met when they are not in conflict.” As disclosed in EA section 3.3, both hazardous fuel reduction and wildlife habitat conservation and restoration objectives will be met within WUI treatment areas.

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http://www.nativeforest.org/campaigns/public_lands/rey1_5_30_02.htm

http://www.nativeforest.org/campaigns/public_lands/rey1_5_30_02.htm



care for their national forests to understand how national policies created by a timber lobbyist (Mark Rey) appointed by Bush to increase the cut from national forests is still driving the agency to do things the public abhors.

DA 41 The Mother Jones magazine concludes: “While most environmentalists do not argue with the basic approach, they charge that too many old, large trees are being cut down under this rubric of "fuels reduction," and that federal land managers are allowing commercial logging operations to cut too many large trees too far from cities or towns, where the clearing has no real impact on human safety.”

“ "It's a classic bait-and-switch," says Timothy Ingalsbee, director of the Western Fire Ecology Center, an Oregon-based advocacy group. "They want to do commercial logging and call it fuels reduction." “ Source for quotes above: “Fight Fire With Logging? Published in Mother Jones, July 31, 2002

http://www.motherjones.com/politics/2002/08/fight-fire-logging

Comment Most USFS fuels logging is in merchantable timber that can be logged and sold. Small trees are a greater fire hazard, yet the USFS ignores this fuel.


DA 42 Of course we all know President Bush felt that managing a national forest to maintain a fully functioning, healthy forest ecosystem was nonsense because it restrained the resource extraction corporations from having their way with public land for short term profit. This is why he installed timber lobbyist Mark Rey as Undersecretary of Agriculture. Rey was directed to set USFS policy that would result in more national forest logging. Rey capitalized on the fires of 2000 and 2002. He conjured up the need to “remove hazardous fuels.” The public still believes that fuels reduction logging near the WUI is an


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http://www.motherjones.com/politics/2002/08/fight-fire-logging



effective way to reduce the risk of fire damage.

Comment: Most intelligent line-officers realize that the USFS had sold them a bill of goods regarding hazardous fuels. Clearly, fuels reduction is an excuse to log.

DA 43 If the final EA for the Clear Creek Integrated timber sale does not analyze a Dr. Cohen alternative in detail it will be necessary to inform the public in your area about Dr. Cohen’s superior fire risk reduction methods myself. I’ll tell the public in your area that you have chosen not to act to protect the safety and homes of the people who live in the WUI. We both know that USFS national leaders abhor bad press … and deal harshly with USFS line-officers whose actions were exposed in the newspapers and were the basis for the bad press.

EA section 2.3 (“Alternatives Eliminated from Detailed Study”) and section 2.4 (“Alternatives Analyzed in Detail”) describe the alternatives that were considered for the Project. Detailed responses to comments DA 09 through DA 30, above, and a detailed response to the following attachment clearly describe how each of the alternatives addresses Dr. Cohen’s findings.


In attachment #11, view #39 cites a document titled “Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States” by Reinhardt, Keane, Calkin, and Cohen. The authors of that article conclude the following: “Fuel treatment is an important management tool for reducing fire hazard. However, confusion exists as to the purpose and potential effectiveness of fuel treatment activities. We feel that fuel treatments should be used to reduce fire severity and intensity instead of fire occurrence. We also believe that fuel

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treatments should attempt to increase ecosystem resilience, especially in wildland settings. The range of variation of historical stand and landscape composition and structures should be used as guides but not targets. While WUI areas should be managed primarily for protection of structures and people, care should be given to ensure these fire hazard reduction treatments produce conditions that are within the historical range of variation. Exotics, climate change, and other human-induced factors will influence fuel treatment effects in the future and these factors should be addressed in all fire management plans. However, the influence of these factors will not diminish the need to treat fuels and restore fire-prone ecosystems. In fact, these factors increase the need to create landscapes that are as resilient as possible. … Successful integration of fire management and land management program objectives can result in treatments that restore ecosystems as well as treating fuels. … Fuel treatments should not be used to reduce or eliminate fire from landscapes. Fuel treatment programs should be designed in concert with new fire suppression policies to encourage the return of fire to the landscape to improve the resilience and sustainability of US ecosystems.” Activities proposed in the Project area in the low- to mid-elevation forests, which include the WUIs, are designed to do exactly what is recommended by the authors (including Dr. Cohen) above. Concerns regarding Alternative B—namely, whether treatments in the mid- to upper-elevation forests will maintain

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conditions—have already been addressed under Alternative C. Mr. Artley’s remaining concerns are unclear, as no other proposed activities have been identified as potentially inconsistent with what Dr. Cohen and the other authors above are advocating with regard to WUIs and across broader landscapes.

Thus, because the Responsible Official believes the action alternatives do incorporate the applicable aspects of Dr. Cohen’s findings identified by Mr. Artley, and because Alternative C appears to address the only potential concern raised by Mr. Artley and other commenters (i.e., whether mid- to upper-elevation treatments maintain/improve resilience), the Responsible Official has concluded that consideration of an additional alternative is not warranted.

DA 44 My Pending Media Contact

If the final EA is released to the public with no Dr. Cohen fire risk reduction methods alternative analyzed in detail, I will write an letter to the editor briefly describing Dr. Cohen’s fire damage reduction methods that the Responsible Official refuses to analyze or acknowledge.

My letter will contain the link to the WEB site which explains Dr. Cohen’s methods. Dr. Cohen’s WEB site shows photos of post-fire conditions. The most striking photo shows several homes that were unburned where the fine fuels were removed per Dr. Cohen’s recommendations. The rest of the homes burned to the ground. The photo descriptions indicates that the USFS had removed hazardous fuels on national forest land adjacent to the WUI areas where the


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burned homes were located.

These pictures tell the story better than words. My letter to the editor will suggest that the public contact Regional Forester Rasure and ask her why she allows a line-officer to remain in R-4 who believes volume accumulation is a higher priority to you than protecting the public.

How many people in the areas covered by these newspapers will approve of you putting the public at risk to please the corporation that purchases the timber sale?

My letter to the editor will suggest that the public contact Supervisor Seesholtz and ask why she believes volume accumulation and creating private industrial tree farm conditions (the major goals of your P&N) is a higher priority than human lives and assets.

DA 45 I suggest you read the Boise Statesman if you choose to put volume ahead of peoples lives. [email protected]

The court of public opinion is often more effective than a court of law. Indeed, it sells newspapers when they publish articles about corrupt Federal agency employees who use taxpayer dollars to prepare projects that provide opportunities for corporations to reap profit at the expense of the public

In your spare time read the truth contained at the link below. The evidence is clear. Mark Rey capitalized on the fires of 2000 and 2002 to guarantee more timber sales for the corporations he lobbied for prior to Bush appointing him to Undersecretary of Agriculture. “Why the National Fire Plan is a Trojan Horse for Logging--Burning Questions” By George Wuerthner Ph.D. Published by CounterPunch, June 12-14,


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2009 http://www.counterpunch.org/2009/06/12/burning-questions/

DA 46 The P&N should be expressed as goals. Fuels reduction is not a goal. It’s one alternative to the goal of saving lives and homes in the WUI should a wildfire occur. As I have shown there are other alternatives that meet this goal.


DA 47 The Clear Creek Integrated Timber Sale is Inconsistent with what the American Public wants in their National Forests The following quote comes from forest service publication that describes what the public wants from their national forests: “The public sees the restriction of mineral development and of timber harvest and grazing as being more important than the provision of natural resources to dependent communities (although this is still seen as somewhat important).” (Pg. 28)

Source: “Survey results of the American public’s values, objectives, beliefs, and attitudes regarding forests and grasslands: A technical document supporting the 2000 USDA Forest Service RPA Assessment”. Gen. Tech. Rep. RMRS-GTR-95. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 111 p. Link to Complete Report: http://www.fs.fed.us/rm/pubs/rmrs_gtr095.pdf

Comment: This timber sale is inconsistent with what the public wants the agency employees administering the national forest to do as documented in the USFS-authored document: Gen. Tech. Rep. RMRS-GTR-95. Explain why you feel that you have been given the authority to violate the public trust.

Comment: There is no “timber famine” as the USFS has been so fond of predicting for many decades. There is no shortage of raw materials

Section 1.3 of the EA states the following:

“In September 2010, a collaborative group called the Boise Forest Coalition was formed, bringing together diverse interests to engage in planning a multifaceted forest project. The citizen-led Boise Forest Coalition represents several public and organizational interests and has an open membership. Soon after their formation, the Coalition partnered with the Forest to provide input on the Clear Creek Integrated Project. The Coalition’s goal for involvement in the Project was to offer recommendations that address the following resource, economic, recreational, and societal needs: 1) bull trout (Salvelinus confluentus) recovery, 2) forest health, 3) ecological restoration, 4) fish and wildlife habitat, 5) a variety of trail-related recreational pursuits, 6) fuel hazard reduction around summer homes, and 7) job opportunities and production of forest products. The Coalition worked in a collaborative fashion, including consultation with the Forest Service, for about one year to develop a set of recommendations. The Boise Forest Coalition’s recommendations provide one basis for the Proposed Action. Information on the Boise Forest Coalition and their

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http://www.fs.fed.us/rm/pubs/rmrs_gtr095.pdf



for paper and wood products in the United States otherwise the owners of private timberland would not be exporting their lumber. The public doesn’t want their public land logged for any reason. You violate the public trust in your zeal to serve your timber industry masters.

involvement with the Forest can be found at www.idahoforestpartners.org/planning-and-organizational-resources.html.” The recommendations from this collaborative group (representing various interest groups and individuals) formed the basis for the Proposed Action presented in the EA. The 2010 FEIS supporting the amendments to the Forest Plan included a detailed assessment of the wood products market and the importance of the wood products industry to the local economies (refer to USDA Forest Service 2010a,b; FEIS section 3.5 [Timberland Resources] and section 3.7 [Socio-Economic Environment]).

DA 48 Herbicides containing Glyphosate, Methyl Parathion, Triclopyr, Imazapyr, and Imidacloprid must Never be used on Public Land for Any Reason

The pre-decisional EA at page 2-28 states that weeds will be treated on roads and trails before they are closed. Unfortunately the type of treatment is not disclosed.

“NX-11—Prior to road and trail closures or decommissioning, treat weeds on those roads and trails. Re-inspect the closed/decommissioned roads and trails and follow up with appropriate treatment and documentation.” Comment: The chemicals listed above kill aquatic life even if the concentrations of the chemical in water are very low. Fish deaths will occur in the streams in the project area and the herbicide toxicity will extend many miles downstream. Herbicides must never be allowed to contact water … even so-called aquatic-safe herbicides.

Design Feature NX-11 has been updated and a new section added to Appendix C of the EA which describes in detail the types of treatments to be applied and the Forest’s standard operating procedures for application of herbicides. Resource effects disclosures in Chapter 3 have been updated as applicable.

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DA 49 These chemicals are also quite toxic to mammals (including humans), birds and insects. Under some conditions they are lethal. They cause:

• birth defects • non-Hodgkin’s lymphoma • mitochondrial damage • cell asphyxia • miscarriages • attention deficit disorder • endocrine disruption • DNA damage • skin tumors • thyroid damage • hairy cell leukemia • Parkinson disease • premature births • decrease in the sperm count • harm to the immune system in fish • death of liver cells • severe reproductive system disruptions • chromosomal damage

Comment: Please comply with 40 C.F.R. § 1502.9(a) by responding to each opposing view in Attachments #9a and #18.

Attachments #9a and #18 have been responded to in detail. Section 1.9.16 of the EA states the following: “This EA has been prepared under NEPA (42 USC 4321 et seq., 40 CFR 1500-1508) and the Forest Plan as amended in 2010 (USDA Forest Service 2010a and 2010b).”

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DA 50 Here are some facts reported in several periodicals that beg for a response from the Responsible Official: Gut punch: Monsanto could be destroying your microbiome SOURCE: Grist, May 23, 2013 Link to the article: http://grist.org/food/gut-punch-monsanto-could-be-destroying-your-microbiome/?utm_campaign=weekly&utm_medium=email&utm_source=newsletter&[email protected]

Article excerpt:

“The “safest” herbicide in the history of science may be harming us in ways we’re just beginning to understand. And now for the really bad news: Because too much is never enough, the Environmental Protection Agency just raised the allowable limits for how much of that chemical can remain on the food we eat, and the crops we feed to animals — many of which end up on our plates as well. If you haven’t guessed its identity yet, it’s Monsanto’s Roundup, a powerful weed killer.”

Comment: The Responsible Official proposes to apply a toxic substance to public land based on outdated safety research done by a lab paid by Monsanto. This is recent safety research that is missing from USFS herbicide safety documents.

Please refer to detailed responses to the following Opposing Views attachments:


• Opposing Views Attachment #18: Following Label Directions on “Approved” Herbicides Containers does not Assure Safety. In addition, Appendix C of the EA and Black (2013) in the project record, also reference other studies concerning safety research that focuses on use of this herbicide, such as Tu et al. (2001) (i.e., the Nature Conservancy).

DA 51 Judge calls for compromise Wallowa herbicide plan SOURCE: Capital Press, November 2012

Link to the article: http://www.capitalpress.com/print/mp-wallowa-herbicide-111612 Article excerpt:

“Earlier this year, U.S. District Judge Michael Simon ruled that

Refer to Appendix C of the EA and the following project record documentation: Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18.

EA Chapter 3 also addresses use of herbicides and the potential effect on resources, as applicable. Resource disclosures were clarified in some sections

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http://grist.org/food/gut-punch-monsanto-could-be-destroying-your-microbiome/?utm_campaign=weekly&utm_medium=email&utm_source=newsletter&[email protected]




http://www.ncbi.nlm.nih.gov/pubmed/18273882

http://www.regulations.gov/%23!documentDetail;D=EPA-HQ-OPP-2012-0132-0009

http://www.capitalpress.com/print/mp-wallowa-herbicide-111612

http://www.capitalpress.com/print/mp-wallowa-herbicide-111612



the U.S. Forest Service violated environmental law by insufficiently studying the cumulative effects of the program. The agency argued the herbicide project in the Wallowa-Whitman National Forest should nonetheless remain in effect to prevent further damage from invasive species. An environmental group countered that allowing the herbicide project to proceed unimpeded would harm sensitive fish.”

Comment: The Responsible Official proposes to apply a toxic substance to public land and does not complete cumulative effects analysis describing the likely damage to many living things in the forest including humans.

in the Final EA.

DA 52 DANISH WATER CONTAMINATED BY ROUNDUP®, BAN IMPOSED SOURCE: Third World Network, September 2003

Link to the article: http://www.twnside.org.sg/title/service76.htm Article excerpt:

“Denmark has imposed a ban on the spraying of glyphosates as of 15 September 2003 following the release of data which found that glyphosate, the active ingredient in Monsanto’s Roundup® herbicide (RR) has been contaminating the drinking water resources of the country. The chemical has, against all expectations sieving down through the soil and polluting the ground water at a rate of five times more than the allowed level for drinking water, according to tests done by the Denmark and Greenland Geological Research Institution (DGGRI) as reported below.

Refer to Appendix C of the EA and the following project record documentation: Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18. Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Ferg and Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990;

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“When we spray glyphosate on the fields by the rules it has been shown that it is washed down into the upper ground water with a concentration of 0.54 micrograms per litre. This is very surprising, because we had previously believed that bacteria in the soil broke down the glyphosate before it reached the ground water,” says DGGRI.

We hope you will find the information provided useful. “ “ Comment: The USDA is more lenient than Denmark when human lives may be threatened.

Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005]

DA 53 New Study Links Monsanto’s Roundup to cancer SOURCE: Herbicide Tolerance, June 2001

Link to the article: http://www.biotech-info.net/glyphosate_cancer.html Article excerpt:

“A recent study by eminent oncologists Dr. Leonard Hardell and Dr. Mikael Eriksson of Sweden, has revealed clear links between one of the world’s biggest selling herbicide, glyphosate (commonly known as Roundup®, marketed by Monsanto), to non-Hodgkins lymphoma, a form of cancer - NHL. There are even requests for permits for higher residues on genetically engineered foods because they are highly resistant to herbicides, instead of reducing herbicide use, glyphosate resistant crops may result in increased residues. They are already on sale. Farmers knowing that their crop will tolerate or resist being killed off by the herbicides will tend to use them more liberally. There have been no risk/benefit analysis carried out, so the regulatory authorities have failed to implement the precautionary principle with respect to GMOs.”

Comment: The Responsible Official proposes to apply a toxic

Refer to Appendix C of the EA and the following project record documentation: Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18. EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).

Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

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substance to public land that causes cancer.

DA 54 Glyphosate: World’s Top Weed Killer May Kill You Too According to New Study

SOURCE: Health Impact News Daily, 2013 Link to the article: http://healthimpactnews.com/2013/glyphosate-worlds-top-weed-killer-may-kill-you-too-according-to-new-study/

Article excerpt: “Glyphosate is assumed to be safe for humans. As a result, it’s become the world’s best-selling herbicide. However, a groundbreaking study documents that it may actually be fueling the plague of chronic & immune diseases, including cancer and autism. This study documents the underlying systemic damage produced by glyphosate, then discusses how that damage leads to specific diseases.”

Comment: The Responsible Official proposes to apply a toxic substance to public land that may cause autism.


EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

DA 55 Roundup Weed Killer May Cause Parkinson’s, Cancer, Other Problems

SOURCE: AboutLawsuits.com, April 26th, 2013 Link to the article: http://www.aboutlawsuits.com/roundup-weed-killer-health-problems-45773/ Article excerpt:

“Exposure to the commonly used weed killer Roundup may be linked to a risk of serious health problems, including Parkinson’s disease, cancer, Alzheimer’s disease and autism, according to the findings of new research. In a study published in the journal Entropy on April 18, researchers identified a link between glyphosate, the active


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http://healthimpactnews.com/2013/glyphosate-worlds-top-weed-killer-may-kill-you-too-according-to-new-study/




http://www.aboutlawsuits.com/roundup-weed-killer-health-problems-45773/



http://www.mdpi.com/1099-4300/15/4/1416



ingredient in the herbicide Roundup, and a toxic reaction among humans that may cause serious health injuries. The findings suggest that repeated use of the weed killer or ingesting food products treated with Roundup may be harmful to an individual’s health.”

Comment: The Responsible Official proposes to apply a toxic substance to public land that recent research indicates may be linked to Parkinson’s disease.

DA 56 New study reveals how glyphosate in Monsanto's Roundup inhibits natural detoxification in human cells

SOURCE: Natural News, May 2013 Link to the article: http://www.naturalnews.com/040482_glyphosate_Monsanto_detoxification.html

Article excerpt:

“(NaturalNews) The modern age of industrial agriculture and manufacturing has dumped heavy metals, carninogens, plastics, and pesticides into the environment at alarming rates. These toxins are showing up in most human tissue cells today. One distinct chemical may be trapping these toxins in human cells, limiting the human body's ability to detoxify its own cells. In a new peer reviewed study, this sinister chemical, glyphosate, has been proven to inhibit the human cell's ability to detoxify altogether. Glyphosate, found in Monsanto's Roundup, is being deemed by publishers of the new study "one of the most dangerous chemicals" being unleashed into the environment today.”

Comment: The Responsible Official proposes to apply a toxic man-


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http://www.naturalnews.com/040482_glyphosate_Monsanto_detoxification.html



made chemical on public land that causes cancer.

DA 57 Remember:

Monsanto earned $937 million, or $1.74 per share, in the quarter ended in May 2012. Source: http://finance.yahoo.com/news/monsanto-3q-profit-soars-maintains-view-122512083--finance.html USDA Secretary Vilsack has such close ties to the biotech industry its frightening. Source: http://articles.mercola.com/sites/articles/archive/2009/10/10/Obama-Monsanto-Alliance-Too-Close-for-Comfort.aspx

It’s easy to figure out why independent labs have been highly paid by Monsanto to do studies and research and conclude that glyphosate is safe if used according to label directions. MONEY!

Refer to Appendix C of the EA and the following project record documentation Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18.

DA 58 The courts require agencies to “consider important aspects of the problem.”

Under the APA, a court may set aside an agency action if the court determines that the action is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A); see also Marsh, 490 U.S. at 375-77 (arbitrary and capricious standard applies to agency findings which involve agency expertise). One of many judges quotes on this subject is shown below:

“Consequently, we may reverse the decision as arbitrary or capricious only if the agency relied on factors Congress did not intend it to consider, entirely failed to consider an important aspect of the problem, offered an explanation that ran counter to the evidence before the agency, or offered one that is so implausible that it could not be ascribed to a difference in view or the product of agency expertise.”

Refer to Appendix C of the EA and the following project record documentation Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18.

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http://finance.yahoo.com/news/monsanto-3q-profit-soars-maintains-view-122512083--finance.html

http://finance.yahoo.com/news/monsanto-3q-profit-soars-maintains-view-122512083--finance.html

http://articles.mercola.com/sites/articles/archive/2009/10/10/Obama-Monsanto-Alliance-Too-Close-for-Comfort.aspx

http://articles.mercola.com/sites/articles/archive/2009/10/10/Obama-Monsanto-Alliance-Too-Close-for-Comfort.aspx



Source: SIERRA CLUB v. BOSWORTH. An Appeal to 9th Circuit from the United States District Court for the Eastern District of California, Filed December 5, 2007 Link to the Court opinion: http://caselaw.findlaw.com/us-9th-circuit/1175742.html Comment: Of course Deputy Forest Supervisor Smith after reading this material you are in denial. You believe that the USFS would approve nothing that might harm (or kill) the wildlife in the forest and the human visitors. Except for aquatic life, the killing will take time they won’t die of cancer for a few years. Would you spray the weeds in your yard with Roundup® and allow your children or grandchildren to play in the same area?

DA 59 After reading the statements in the attachments #9a AND #18 written by unbiased, independent scientists do you have 100% trust in your trust in whatever document assures the safety of the herbicides ised to accomplish the ongoing Lowman Ranger District Noxious Weed Program written using safety data provided by a lab paid by the herbicide manufacturer to conduct safety analysis? With the influence of corporations in America things like this happen too often. Why do you think a Republican in Congress inserted the Monsanto Protection Act as a rider to the “Consolidated and Further Continuing Appropriations Act, 2013" signed by President Obama into law in March 2013 to avert a government shutdown? The Act would not be needed if the chemicals manufactured by Monsanto weren’t lethal. Noxious weeds and non-native invasive plant species are a huge problem on public lands. Please use alternatives to lethal chemicals in spite of the fact they cost more. Deal with them in a safe way! Deal with them in a way that doesn’t kill things besides the weeds. Spending more money to pull them by hand and biological control would be the

Refer to Appendix C of the EA and the following project record documentation Black (2013) and Tu et al. (2001). Also refer to the detailed responses to attachments #9a and #18. Appendix C of the EA has been updated to discuss the scope of the Forest’s integrated weed management program and the standard operating procedures (i.e., design features) that would be used in application of any herbicides in response to pretreatment objectives in Design Features NX-6 and NX-11.

Black (2013) also describes that both biological controls and manual removal of weeds were considered as options to meet pretreatment objectives for Design Features NX-6 and NX-11. However, as described by Black, while biological controls and manual removal will be used to meet long-term noxious weed prevention and treatment objectives,

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wisest tax dollar you will ever spend.

Comment: Deputy Forest Supervisor Smith, please tell the public the number of mammals, birds and fish that will be exposed to cancer causing chemicals that you consider acceptable to treat noxious weeds, knowing there are more expensive, effective alternatives to these herbicide treatment.

these options would not be successful in the initial pretreatments for the reasons given below. Disadvantages of using biocontrol agents for weed control include the following:

• Uncertainty about the effectiveness of approved agents in controlling the target weed

• Risk of unintended, adverse impacts on native vegetation and other organisms

• Potential difficulty in adapting the bio-agent to varying climatic conditions (in order to ensure successful propagation)

• Does not always work, and in most cases, does not eradicate the target weed

Disadvantages of using mechanical treatments:

• They are typically most effective in removing or preventing production of weed seeds. Larger infestations of weeds are very difficult to control with mechanical treatment and may require multiple treatment types. For the Project, some areas that will be pretreated are large.

• Hand pulling and grubbing of weeds is less effective on rhizomatous than nonrhizomatous weed species because rhizomatous species have a well-developed root system and carbohydrate reserves and often leave root fragments in the ground. Some weeds to be treated in the Project area fall under this category.

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• Some weed species such as leafy spurge respond to mechanical treatment by aggressively resprouting, even if only small root fragments are left in the soil. As identified in EA section 3.10, several acres in the Project area are susceptible to this weed.

• Mechanical treatments must be repeated several times a year for many years to eradicate weed species that are prolific seed producers and that have built up a residual seed bank in the soil.

• To be most effective, mechanical treatment must occur before seed production occurs.

The range of alternatives includes at least the Proposed Action and the No Action alternative. In this case the proposed weed pretreatments are the same under Alternatives B and C, except fewer acres would be disturbed under Alternative C, since treatment in the mid to upper elevations would not occur under this alternative.

Typically, additional alternatives are added, provided they address the purpose and need for the project and address an issue or respond to some other need for an alternative, as determined by the Responsible Official. For environmental assessments, Forest Service NEPA procedures explain that no specific number of alternatives is required or prescribed, and when no unresolved conflicts exist concerning alternative uses of available resources, the EA need only analyze the Proposed Action and proceed without consideration of additional alternatives

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(36 CFR 220.7(b)).

In the case of the Project, for reasons stated above, the Responsible Official has determined that herbicide pretreatments are the only option to meet the purpose and need. Also, when herbicide use complies with label requirements and the design features outlined in Appendix C, the best available science that the Agency is aware of does not validate the health concerns raised by the commenter.

DA 60 Conclusion

Please notify this member of the public when the DN/FONSI and final EA are posted online, the legal notice of decision is published in your newspaper of record, and the 45-day appeal period begins. Comment: Deputy Forest Supervisor Smith, I know the game being played here. The line officer receives timber funding for each FY. You know all the TIMBER funding must be spent each FY or your funding will be less the following year and you will be reprimanded by your supervisor. Thus, you are forced to sell timber sales whether they are ecologically justified or not based on the advice of your timber staff and/or TMA who are paid to “get out the cut.”

Refer to the responses to comments DA 1 through DA 59 above. The commenter is on the mailing list and will be notified of the release of the DN/FONSI and Final EA.

DA 61 Comment: Deputy Forest Supervisor Smith, I have seen it before. When the end of the FY is approaching there is a frantic effort to find a timber sale anywhere, which means creating untrue, trumped-up reasons for the sale and inserting them into the NEPA document’s Purpose and Need.

Refer to the responses to comments DA 1 through DA 59 above.

DA 62 Comment: The volume attainment scheme goes like this. The merchantable trees are first found in the woods. Then the IDT is instructed to develop a believable reason for logging them. This


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becomes the P&N and the public deception (a.k.a. the NEPA process) begins.

DA 63 Comment: Deputy Forest Supervisor Smith, you have 314 million bosses. If you worked in the private sector, received instructions from your bosses who provide the money for your salary, and then took action to please a special interest and ignored your boss’s instructions how long would you keep your job?


DA 64 Remember, a judge might be reviewing your responses to these comments. Put yourself in his or her place. They are paid to detect a defendant who is lying to enhance their positive image with their employer. Why am I doing this? I love the concept of public land more than you can imagine. The population of the United States is estimated to double (623 million people) in 92 years. Undeveloped publically owned land will be priceless. Developing this land now for short-term corporate profit is criminal. Sincerely,

Dick Artley’s scanned signature is contained in the “signature” attachment.

CC: to Interdisciplinary Team Members who care more about maintaining the health of the countless natural resources in the forest

Refer to the responses to comments DA 1 through DA 59 above. Also, please refer to detailed responses to the Opposing Views attachments:




• Opposing Views Attachment #9a: Herbicides Containing Glyphosate should Never be Applied to Areas where Mammals (including humans), Fish, or Birds Might Visit. Even Casual Contact Causes Lethal

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than they do volume.

Diseases. • Opposing Views Attachment #11: Any

NEPA Document that Analyzes Treatments to Reduce the Risk of Fire Damage to Homes Located in the WUI must Analyze a Dr. Jack Cohen Alternative in Detail.


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Table D-115. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment—Attachment #1—Timber Harvest Opposing Views


Timber Harvest Opposing View #1–The following document contains pertinent color pictures showing logging damage, thus the article text is not shown here. Please use the link below to access the article. Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and Implications”

Clearcuts and forest fragmentation, Willamette NF, Oregon. From: Cascadia Wildland Project, Spring 2003 http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pdf

The document defines fragmentation, discusses which species groups are most vulnerable to the effects of fragmentation, and presents a discussion of potential effects resulting from fragmentation. The document summarizes information found in other literature resources, including studies and literature reviews. One color photo was found, and it was on the front page of the document. The photo was labeled “Clearcuts and forest fragmentation, Willamette NF, Oregon.” The document appears to be part of a project supported by Cascadia Wildlands, an organization self-described as “grassroots conservation.”

The referenced photo is not applicable to the vegetation treatments being proposed in the Project. No clearcuts are being proposed, and the treatments would not result in distinct edges as shown in the photo. Vegetation treatments are described in the EA, sections 2.4.2, 2.4.3, and 2.4.4. The Forest Plan was recently amended (USDA Forest Service 2010 a,b,c) to incorporate a WCS. The strategy was built upon a set of conservation principles, with a long-term goal of maintaining or effectively restoring representative, resilient, and redundant networks of habitats across the Forest. Nine conservation principles form the basis for assessing current baselines, threats, and risks at both the Forest scale (or mid scale) and the project scale (or site scale); some of these principles are directly related to avoiding or minimizing the effects of fragmentation (USDA Forest Service 2010a,

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Appendix E, pp. E-6 through E-22). These conservation principles were considered during the planning and design of the Project and in the analysis of the project effects. See EA sections 1.5, 3.4.1, 3.4.2, and 3.4.3.

View #1 also included the following: “... conservation and protection, at least for endangered species, should be effectively taken into consideration. Efforts must be directed to identify these crucial species or group of species as well as the processes that affect them in the habitats if management plans are to be more effective (Noss 2001)…” Species of conservation concern were identified during the development of the Forest’s (Phase I) WCS (USDA Forest Service 2010a, Appendix E, E-4). The current strategy is built upon the conservation needs of species of concern that utilize forested source habitat communities (Phase I). In addition, the Project-level analysis considered potential effects on other TEPCS species.

Timber Harvest Opposing View #2 - “Timber harvest operations have been shown to have many effects on adjacent watercourses and on the aquatic ecosystems they support. This may occur from introductions or loss of woody debris, loss of riparian vegetation, accelerated stream bank and bed erosion, the alteration of natural channel form and process, and the reduction of stream habitat diversity. However, the existing literature indicates one of the most insidious effects of logging is the elevation of sediment loads and increased sedimentation within the drainage basin. Sediment generation from various forestry practices has been studied

View #2 is presented as a “literature review” that “examined the effects of increased sediment load and sedimentation on aquatic ecosystems emphasizing forestry operations that generate elevated sediment loads.” This paper is a conference proceeding, not a peer-reviewed scientific publication. The author’s credentials are not provided.

Water quality and the effects of timber harvest and roads on sedimentation were analyzed, and the

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extensively in the past. Forestry practices which generate suspended sediments include all operations that disturb soil surfaces such as site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road construction and maintenance.”

Anderson, P.G. 1996. “Sediment generation from forestry operations and associated effects on aquatic ecosystems” Proceedings of the Forest-Fish Conference: Land Management Practices Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta. http://www.alliance-pipeline.com/contentfiles/45____Sediment_generation.pdf

discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality Watershed Condition Indicators [Sediment]).

Furthermore, opposing view #2 provides a discussion under the heading “Mitigation Measures” that describes how “the delivery of sediments to streams resulting from disturbances can be largely circumvented by proper design and planning.” The action alternatives include water quality–specific mitigation measures, described in section 2.4.5 (Design Features). Design features relevant to sediment delivery include WF-1, WF-8, WF-11, WF-15, and TR-8.

Timber Harvest Opposing View #3 - “Timber harvest will remove dead and dying material from the site and inhibit the recruitment of downed woody material as time progresses. Timber harvest and associated reduced structural complexity and reduced age and size class diversity are all known to reduce population abundance and diversity of ants and a number of birds. For instance, ants are documented to require downed woody material in a variety of sizes and in all stages of decomposition (Torgersen and Bull, 1995). This is an attribute that is negatively correlated with harvest of the dead and dying trees and positively correlated with natural succession, especially after disturbance. Ants and birds are known to predate on insect species which cause mortality to trees, serving as a potentially important population control in the case of epidemics or before they occur (Campbell, Torgersen and Srivastava, 1983). Structural and functional characteristics associated with unlogged forests are also important for canopy arthropods, which play an important role in regulating pest outbreaks (Schowalter, 1989). Structural complexity, functional diversity, diversity of ecological process and diversity of structure in roadless areas are all expected to be less

The ideas presented in View #3 are not contained in the cited paper.

The Project would not remove dead and dying material from the forest (EA section 3.2.2). Design Feature VE-5 would require logs to be brought back into the unit to supplement the large (>15-inch) coarse woody debris (EA section 2.4.4.7). Structural diversity would be maintained as dictated by the Forest Plan. Endemic populations of bark beetles and other insects would remain (section 3.2.6.1.2) Vegetative treatments (harvest) would not occur in an Inventoried Roadless Area (EA section 1.9.9).

No clearcutting would occur in the project area that might create an edge effect (EA section 2.4.4.8). The canopy and understory tree density will be reduced, which in turn would reduce population abundance of

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susceptible to the outbreak of pests and regulate insect activity in surrounding homogenized forests (Schowalter and Means, 1989; Franklin, Perry, Schowalter, Harmon, McKee and Spies, 1989). A large body of scientific evidence also indicates that increased edge effect and increased sunlight into stands, resulting from reduced canopy cover associated with timber harvest, can directly promote the population abundance, productivity and persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989).” “Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf

bark beetles and other insects (EA sections 3.2.2 and 3.2.1.2.2). The strategy outlined in the 2010 Forest Plan for restoration of forest resources is similar to what is prescribed in the referenced paper.

Timber Harvest Opposing View #4 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.”

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml

This article does not indicate whether Dr. Barry has conducted any independent research on the topics he covers in this paper. Dr. Barry does not cite any specific scientific literature; instead, in this article, Dr. Barry states the following: “It is well known scientifically that commercial logging actually increases fire severity by removing large, fire- resistant trees and leaving behind very small trees and flammable "slash debris"--branches, twigs and needles from felled trees. The removal of mature trees also decreases the forest canopy, creating hotter, drier conditions on the ground. The additional sun exposure encourages the growth of flammable brush and weeds. Reduction of flammable underbrush can reduce fire severity, and environmental groups have encouraged such projects. However, the Bush administration has grossly misused the funds that Congress appropriated for brush reduction near homes. In Sierra Nevada national forests last year, more than 90% of these funds were instead earmarked for preparation of large timber

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sales focused on the removal of mature and old-growth trees miles from the nearest town."

Timber Harvest Opposing View #5 - “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.” “Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ " “But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.”

Barry, John Byrne. “Stop the Logging, Start the Restoration” from The Planet newsletter June 1999, Volume 6, Number 5 http://www.sierraclub.org/planet/199905/ecl1.asp

View #5 references an opinion paper that does not specifically cite supporting scientific literature. As identified in the Purpose and Need, the purpose of vegetation treatments within the Project area is for restoration and to address fuel/wildfire risk within the WUI… it is not to maximize timber or other commodities. As stated in section 1.2 of the EA, “The 2010 Forest Plan identifies the majority (70%) of the land within the Project area as MPC 5.1 (Restoration and Maintenance Emphasis). Although the land allocated within MPC 5.1 is within the suited timber base, the treatment emphasis is on forest maintenance and restoration, with wood products generated as an outcome or by-product of these activities. The Proposed Action entails removal of wood products as a by-product of forest restoration and maintenance on acres in the suited timber base.”

Timber Harvest Opposing View #6 - “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.

After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and

View #6 references a news story about audits conducted on projects implemented between 1995 and 1998, as noted in the second paragraph of the quotation. Most of the issues described were implementation related. The article states that prior Forest Service Chief

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that ’immediate corrective action is needed.’

A new report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out.

The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.” Cushman, John H. Jr. “Audit Faults Forest Service on Logging Damage in U.S. Forests” New York Times, February 5, 1999 http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A35751C0A96F958260&sec=&spon=&pagewanted=print

Mike Dombeck directed review teams to inspect implementation in all regions of the Forest Service to make sure projects were complying with NEPA documents and regulation. These procedures were put in place on the Forest, as on all National Forests, in the late 1990s.

The article also discusses concerns about planning and include the following:

• Poorly done NEPA • No surveys for ESA species • Decisions not based on sound science

Regarding NEPA, the introduction of Chapter 1 of the EA states the following: “This document has been prepared under the National Environmental Policy Act [(NEPA); 42 U.S.C. 4321 et seq., 40 CFR 1500-1508] and the Forest Plan as amended in 2010 (USDA Forest Service 2003a, 2010a).” Consistency with ESA is clearly stated in section 1.9.3 of the EA. The Responsible Official’s determination that best available science was used to inform the analysis in the EA is discussed in section 1.9.17.2; how best available science informs the decision to be made and why will be clearly disclosed in the DN for this project.

Timber Harvest Opposing View #7 - "The timber harvest shouldn't be dominant. It should be on an equal plane with recreation concerns, with wildlife concerns, hunting, fishing, protecting our cultural heritage. That's what the American public is asking us to do.”

The quotation cited in View #7 is a portion of a statement made by Mike Dombeck in his capacity as chief of the Forest Service, during a discussion of the impacts of a proposed moratorium on road building

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Dombeck, Mike Ph.D. "Through the Woods" The News Hour with Jim Lehrer. 19 June 1998. http://www.pbs.org/newshour/bb/fedagencies/jan-june98/road_6-19.html

within Inventoried Roadless Areas. Dombeck was commenting on the logging industry in Idaho. His statement in its entirety reads as follows:

“The timber harvest shouldn't be dominant. It should be on an equal plane with recreation concerns, with wildlife concerns, hunting, fishing, protecting our cultural heritage. And if we work within that philosophical framework of working within the limits of the land, everybody benefits. And that's what the American public is asking us to do. The reason that we've been involved in some of the level of controversy that we have is because that shift is occurring and change is occurring. And change is always difficult to deal with.”

The Project does not propose road building in IRAs.

Timber Harvest Opposing View #8 - “I recently read a letter from a line officer who chided local managers for being behind schedule relative to meeting the region’s ‘timber targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.” “We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.”

"Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of

View #8 quotes an extract from a letter from Mike Dombeck, Forest Service Chief, on the 100th anniversary of Gifford Pinchot’s first day as a Forest Service employee. As discussed under Purpose #3, section 1.5, “Forested lands within MPC 5.1 in the Project area are part of the suited timber base under the Forest Plan. Providing wood products from these lands, while pursuing forest restoration and maintenance, is an important Forest Plan multiple-use objective. Regional sawmills process most wood products removed from suited lands on the Forest, including those on the Lowman Ranger District. As noted in the 2010 ROD (USDA Forest Service 2010c), providing wood products as an outcome of forest maintenance and restoration

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our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations." Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to all USFS employees on July 1, 1998 http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.html

treatments that contribute to sustaining a wood products processing industry is essential to continuing forestland restoration and maintenance services in southwest Idaho and supporting local and regional economic sustainability.”

Timber Harvest Opposing View #9 - “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.”

“The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.”

Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Call to End Logging Based on Conservation Biology.” Native Forest Network. http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm

View #8 cites a letter released by the Sierra Club, National Forest Protection Alliance, and others; the letter, addressed to President Bush, urged the president to end commercial logging on America's national forests and invest in scientifically supported forest restoration projects. Refer to the responses to view #5 and view #8.

Timber Harvest Opposing View #10 - “The Bush administration has View #10 references information from several

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announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.” “Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm

editorials and news stories about the Healthy Forest Initiative that were consolidated by Forest.org into a single document. EA section 3.3.3.1 discusses past wildfires that have occurred in the Clear Creek Watershed; sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments on wildfire crowning index and surface flame lengths; “…surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.”

Timber Harvest Opposing View #11 - "The proposition that forest values are protected with more, rather than less logging, and that forest reserves are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base. (page 2)"

"On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they

The quoted material is from the introduction of the cited document. The paper is a science panel critique of what was described as the panel’s attempt to “address the validity of the concepts and assumptions supporting forest policies and plans that call for active management of essentially the entire forest estate, and which specifically reject the consideration of biological reserves and nontraditional harvest techniques, such as structural retention.”

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reduce traditional sources of timber income. (page 2)"

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." http://www.coastrange.org/documents/forestreport.pdf

“Silviculture can, and in some cases has been adapted to more closely approximate natural disturbances, grow trees to longer rotations, and with the hope of providing habitat for at least some species requiring complexly structured forests. These silvicultural approaches hold substantial promise as techniques that provide for higher levels of native forest diversity following timber harvest, both initially and over the long term.”

EA section 3.3.3.2 discusses the intermix of fire regimes; section 3.2.5 discusses different patch and pattern conditions that would develop from management and from no treatment; and section 3.4 describes the variety of habitats that would develop for various species known to occupy and/or have habitat in the area. Though the areas not proposed for treatment are not “reserves” as identified in this paper, they will develop “reserve-like” vegetative characteristics, in contrast to the areas proposed for treatment. That, in combination with the reduction in road density, could be described as moving toward a “reserve” effect.

Timber Harvest Opposing View #12 - “Consequently, we specifically criticize the “simplified structure-based management” approaches derived from simple structural models and traditional silvicultural systems such as clearcutting. In our view, the assumptions underpinning simplified structure-based management (SSBM) are not supported by the published scientific literature on structural development of natural forests, disturbance ecology, landscape ecology and conservation biology, or by the relationships between ecosystem structures and processes. In this report, we review scientific findings associated with each of these areas with particular attention to the over-simplified structural models associated with SSBM and

View #12 is a quotation from the paper listed under view #11, not the paper cited in view #12. Refer also to the response to view #11. As stated above, the purpose of the critique was to “address the validity of the concepts and assumptions supporting forest policies and plans that call for active management of essentially the entire forest estate, and which specifically reject the consideration of biological reserves and nontraditional harvest techniques, such as

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the importance and viability of forest reserves to achieve various ecological goals. (page 2) “We do not believe, however, that scientific literature or forestry experience supports the notions that intensively managed forests can duplicate the role of natural forests, or that sufficient knowledge and ability exist to create even an approximation of a natural old-growth forest stand.” (page 3)

Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 2007. “Forging a Science-Based National Forest Fire Policy.” Issues in Science and Technology. A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf

structural retention.”

The authors of this article further state the following: “Thinning densely stocked, young to mid-aged stands can increase tree vigor, encourage understory growth, and enhance structural complexity. Management regimes such as those involving variable density thinning and the creation of coarse woody debris and decadence in living trees (e.g., cavities), may be very effective in creating structural complexity in managed stands (see, e.g., Carey et al. 1996). Hence, we support the notion that silvicultural activities — structure-based management in the broadest sense — can assist in the maintenance of biological diversity and other ecological services in managed stands.”

Management actions associated with the Project are not intended to create the “simplified structure-based management” criticized by Franklin et al. (2000). Instead the proposed actions are designed to develop the various attributes Franklin et al. identify as important. Variable density thinning and thin-from-below (EA section 2.4.2.2.1) would be implemented in a manner that develops stand structural conditions such as clumps and groups in order to contribute to large tree and old forest habitat (EA section 2.4.2.1.1). These treatments, in addition to prescribed fire, endemic insects, and other disturbance processes, will contribute to desired levels and types of snags and coarse woody debris over time (EA section 3.2.6.1.2, Alternative B).

Timber Harvest Opposing View #13 - “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our

View #13 is about the Healthy Forest Initiative. Refer to the responses to views #1, #3, #4, #8, and #11.

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national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.”

“According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’”

Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut Down the Trees!” Environmental News Service, 2008. http://www.ens-newswire.com/ens/aug2002/2002-08-23g.asp

Timber Harvest Opposing View #14 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."

"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."

Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf

View #14 concerns a GAO report to the Subcommittee on Forests and Forest Health, Committee on Resources, House of Representatives, which directed the federal agencies to develop a cohesive strategy for addressing the risk of large wildfires. The extracted portion is from a section titled “A Cohesive strategy is needed for addressing numerous barriers to effective action.” On the acres proposed for treatment within the Project area, the current wildfire hazard is moderate to high (EA, page 3-64, Table 3-28). The proposed treatments are primarily variable density thinning and thin-from-below (EA section 2.4.2.2.1 pages 2-5 through 2-9), with design features to retain the largest trees (EA, page 2-31, Table 2-5). These actions would reduce the wildfire hazard to lower levels than the current condition and would result in a lower wildfire hazard than No the Action Alternative (Alternative A) over time (EA Table 3 28).

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Timber Harvest Opposing View #15 - “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs, logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred during the decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partially created by past timber sales.” “A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)”

“One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed.

Refer to the responses to views #1, #3, #4, #8, and #11.

In addition, EA section 1.4.1 (Land Management History of the Project Area) discusses some of the effects associated with past management activities and wildfire. Regarding K-V funds, FSH 2409.19(01) states the following: “The Knutson-Vandenberg Act (K-V) of June 9, 1930 (16 U.S.C. 576-576b; 46 Stat. 527), as amended by the National Forest Management Act of October 22, 1976 (16 U.S.C. 1600 et seq.) (FSM 1011), is the authority for requiring purchasers of National Forest timber to make deposits to finance Sale Area Improvement (SAI) activities needed to protect and improve the future productivity of the renewable resources of forest lands on timber sale areas. Activities include SAI operations, maintenance and construction, reforestation, timber stand improvement, range, wildlife and fish habitat, soil and watershed, and recreation. Public Law 109-54 of August 2, 2005, further amended the K-V Act to allow the collection and use of K-V funds for watershed restoration, wildlife habitat improvement, control of insects, disease, and noxious weeds, community protection activities, and the maintenance of forest roads within the Forest Service region in which the timber sale occurred: Provided that such activities may be performed through the use of contracts, forest product sales, and cooperative agreements.” The article concludes that “wildlife managers have an incentive to support timber sales that damage wildlife

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(10)”

Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems.” A Congressional Research Service (CRS) report, October 30, 1995. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215

habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staff employed.” This statement is the opinion of the article’s author, not the Agency. As identified in the responses to views #1, #3, #4, #8, and #11, the Project is a restoration project. Any K-V funds generated from the project would be a result of vegetation management activities designed, in part, to restore habitat, not damage it.

Timber Harvest Opposing View #16 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “ “As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high-value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).” “The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.” “After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire-resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the

Refer to the response to view #14.

Smaller understory trees (ladder fuels) are the primary contributor to the current condition of moderate to high wildfire hazard (EA, page 3-63). This type of hazard poses a high risk of losing larger trees to crown fire. The proposed treatments are variable density thinning and thin-from-below, with design features to retain the largest trees (EA, page 2-31, Table 2-5). “The reduction in wildfire hazard would be accomplished by reducing ladder fuels and treating activity fuels, thereby limiting the fire’s ability to transition from a surface fire to a crown fire” (EA, page 3-72). “The prescription would “promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire resistant species, such as ponderosa pine, and discriminate against tree species less resistant to wildfire…” “The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a

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remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.” Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://www.commondreams.org/views/051900-101.htm

lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine” (EA, page 3-72 to 3-73).

Fuel treatment activities, alone or in combination, would be implemented to reduce the fire risk associated with the fuels created by the commercial treatment of trees ≥8 inches dbh and noncommercial treatment of trees <8 inches dbh These activities could include lop and scatter, jackpot or hand piling, whole tree yarding and burning at landings, and broadcast burning (EA, pp. 3-75 to 3-80). A temporary increase would occur in surface fuel loads and potential flame lengths associated primarily with the fuels created by the noncommercial treatments; however, this hazard would abate over time as a result of the proposed treatments and natural decay. After 3 years, the surface fuels created by the mechanical treatments would not be expected to have increased the wildfire hazard over the current condition (EA pp. 3-77 to 3-78).

Timber Harvest Opposing View #17 - "The Forest Service keeps the vast majority of timber sale revenues, which gives it a perverse incentive to do more cutting. It has developed a huge bureaucracy around the selling of timber from national forest land." Hanson, Chad, Ph.D. “Logging for Dollars in National Forests” Special to The Sacramento Bee - November 14, 2001 http://www.johnmuirproject.org/news-logging-for-dollars.html

The paper includes 2 science documents about the effects of salvage harvesting following wildfire, particularly stand-replacing wildfire. The Project does not propose salvage harvesting.

Timber Harvest Opposing View #18 - “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing

View #18 quotes a guest commentary that cites several peer-reviewed science documents about climate change

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wildland fires …”

Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and Forest Fires.” Guest Commentary in New West, July 11, 2008 http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest_fires/C41/L41/

and fire regimes.

EA section 3.17 discusses climate change and its relationship to vegetative conditions within the project area, and EA section 3.3.5 discusses the effects of the proposed activities on wildfire crowning index.

Timber Harvest Opposing View #19 - "Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes." Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in Western Montana” Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-398(6) http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsessionid=l2sdf2hphia2.alexandra

The quote originates from the introduction of the cited document, which states the following: “Increased tree utilization potentially reduces the organic parent materials (litter and woody residues) available for soil-formation processes.”

EA section 3.8 discusses the potential effects of timber harvest and prescribed fire on disturbance of surface soils and effective ground cover.

Timber Harvest Opposing View #20 - "For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do."

Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public."

As disclosed in EA sections 1.10 through 1.12 and Chapter 4, a concerted effort has been made to involve other federal and state agencies, local county representatives, tribal governments, conservation communities, and individuals throughout the environmental analysis process. As noted in section 1.12, issues and concerns were identified and addressed in various ways (e.g., alternative development, full effects disclosure, incorporation of additional design features). This effort to encourage community involvement will continue through the time when the decision is issued and during implementation for those who want to monitor the project’s success in achieving desired outcomes.

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Evergreen magazine, October 1997. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public-v2.html Timber Harvest Opposing View #21 - "SEC. 3. FINDINGS.

Congress finds the following:

Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries."

H. R. 1494 text. April 4, 2001 http://www.agriculturelaw.com/legis/bills107/hr1494.htm

View #21 references findings cited in the development of legislation titled

“National Forest Protection and Restoration Act of 2001,” which was referred back to the committee. No literature is specifically cited. A discussion of the effects of the proposed project on the following resources can be found in the EA:

• Hydrology—refer to section 3.6 • Fisheries—refer to section 3.7 • Recreation—refer to sections 3.12, 3.15, and 3.16

Timber Harvest Opposing View #22 - "Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences." Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Biodiversity Sustains Us” from his book review of The Work of Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997 Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 http://www.mikehudak.com/Articles/FromPrairieDogs9902.html

View #22 provides a quotation that is actually a combination of 2 different sections of text. The first sentence of the quotation is extracted from the following: “Human tampering with nature has not been without costs. Baskin examines some of those incurred by the accidental or even deliberate introduction of alien species into ecosystems ill-equipped to function with them.” The second sentence in the quotation is a preface that discusses other examples of changes that have occurred from human uses. (The first example is about clearcuts in the Pacific Northwest, and the second example is crops/forest plantations that have contributed to human pollen allergies.) None of the extracted sections apply to any activities associated with the project.

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http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public-v2.html

http://www.agriculturelaw.com/legis/bills107/hr1494.htm

http://www.mikehudak.com/Articles/FromPrairieDogs9902.html



The project does not propose clearcutting, crop planting, or creation of forest plantations (refer to sections 1.5 and 1.6).

Timber Harvest Opposing View #23 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9) “As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.”

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E70?sequence=1

Effects of fuels created by mechanical treatments are disclosed in the EA in sections 3.3.5.2 and 3.3.5.3, “…the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.” The effects described in these sections are consistent with those described in the science discussed in view #23.

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Timber Harvest Opposing View #24 - "The Quincy Library Group's (QLG's) fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review."

"The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management expertise." "In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects." "Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires."

"And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution." "The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of 'cut and run' logging, many

The project does not propose fuel breaks, which are the focus of the cited paper (see EA sections 1.5, 1.6, and 2.4).

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of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets … a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs." Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan." Unpublished research paper. 1997. http://www.fire-ecology.org/research/logging-for-firefighting_2.htm

Timber Harvest Opposing View #25 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Section 1.4 discusses past timber harvest, reforestation, road building, fire suppression, and livestock grazing that have occurred in the project area. Sections 1.3, 1.4, and 1.5 discuss the role these past human uses may have had in developing the current conditions within the project area.

Timber Harvest Opposing View #26 - "Since the 'New Perspectives' program of the early 1990s, the agency has tried to dodge public opposition to commercial logging by using various euphemisms, such as this gem from the Siskiyou National Forest: Clearcuts are called 'minimum green tree retention units.' Accordingly, Forest Service managers have believed that if they simply refer to logging as 'thinning,' or add the phrases 'fuels reduction' or 'forest restoration' to the title of their timber sale plans, then the public

EA section 3.2.2 fully discloses, in detail, the silvicultural prescriptions that are proposed under the action alternatives.

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will accept these projects at face value, and business-as-usual commercial logging can proceed. In the face of multiple scandals and widespread public skepticism of the Forest Service's credibility, it seems that only Congress is buying the agency's labeling scheme."

Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to Wildfires” published in the Portland Oregonian, August 6, 2002 http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.html

Timber Harvest Opposing View #27 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://fireecology.org/research/wildfire_paradox.pdf

The action alternatives must be implemented utilizing design features VE-2, VE-3, and VE-4, which can be found in section 2.4.4.7.

Treatments as proposed in the WUI and non-WUI stands would include a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site: “This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring

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retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.” (Clear Creek Integrated Restoration Project sections 3.3.5.2 and 3.3.5.3) Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen. (EA sections 3.3.5.2 and 3.3.5.3)

Effects of fuels created by mechanical treatments are disclosed in the EA in sections 3.3.5.2 and 3.3.5.3; “…the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning

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and jackpot burning.

Additionally a low to moderate intensity prescribed fire broadcast maintenance burning would be applied after mechanical and fuel treatments, to further reduce fine fuels, promote regeneration of desired species, and gain the ecological benefits of fire within these landscapes. Fuels reduction treatments within RCAs must be consistent with design features. Treatments would re-pattern tree size classes, resulting in a combination of overstory and understory groups, clumps, and openings of varying number and sizes. This re-patterning would reduce stand densities and decrease the continuity of ladder fuels, thereby reducing the risk of a surface fire transitioning to a crown fire. These improvements would increase the likelihood that wildfire behavior would be characteristic for the fire regime. (EA section 3.3.5.2.3) These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or mechanical treatments. (EA section 3.3.5.2.2)”

Timber Harvest Opposing View #28 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the

See the response to view #27.

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net effect of these logging projects is to actually increase fire risks and fuel hazards." "Decades of encouraging private logging companies to take the biggest, oldest, most fire-resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands."

"In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks." Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html

Timber Harvest Opposing View #29 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire-resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.” “Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even


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more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.”

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm

Timber Harvest Opposing View #30 - “Linear developments may result in habitat avoidance for grizzly bears. Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non-hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.”

“The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.”

Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of Linear Developments on Wildlife: A Review of Selected Scientific Literature.” Prepared for Canadian Association of Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. http://www.capp.ca/getdoc.aspx?DocId=24902&DT=PDF

The referenced document is a review of selected literature focusing on effects to large mammals from roads and linear developments created by the oil and gas industries such as those found in western Canada. The literature review was conducted by Arc Wildlife Services Ltd., under contract to the Canadian Association of Petroleum Products, Alberta Energy and Utilities Board, and Nova Gas Transmission Ltd. The document is divided into several sections, including methodology, definitions, corridors, disturbance effects, linear development types, species/group summaries, and mitigating measures. The stated intent was that the literature would be used as a reference but would not be read in its entirety. Linear features discussed in the document and applicable to the Project include roads and trails. Species and group summaries that may have applicability to the Project include wolf, medium-size carnivores (specifically, wolverine, fisher, and lynx), elk, and birds. Six disturbance effects were reviewed: individual disruption (wolf, wolverine, elk, and bald eagle), habitat avoidance (wolf, wolverine, fisher, lynx, elk, bald eagle, and goshawk), social disruption (elk), habitat disruption or enhancement

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(wolf, lynx, elk, and peregrine), direct and indirect mortality (wolf, wolverine, lynx, elk, and bald eagle), and population effects (wolf and elk). Species applicable to the Project with documented effects are noted in parentheses after each disturbance effect in the list above. The wildlife analysis for this project includes a section (EA section 3.4.2.3) that discusses the effects of linear features on wildlife. The analysis identifies 17 road/trail-associated factors that negatively impact wildlife and lists project focal species with documented effects related to each factor. The authors of the article cited in view #30 (Jalkotzy et al. 1997) do not identify any new factors that were not considered during the analysis for the Project, though they do describe some factors differently (i.e., social disruption may result from one or more factors that negatively affect the population). In addition to the section discussing the general effects of roads and trails on wildlife, the EA includes an assessment of the risks to individual species from these linear features (section 3.4.3). Also, roads are a risk indicator for some conservation principles considered during analysis.

The quotation regarding wolverine has been pulled out of full context. The full paragraph reads as follows: “The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.

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Conversely, in the north where they are more common, some wolverines tolerate civilization to the extent of scavenging at dumps and living adjacent to urban areas.

Wolverine are discussed in Review EA section 3.4.3.12. Wolverine were recently proposed for listing under the Endangered Species Act. Habitat loss and range contraction resulting from climate change were identified as the primary threat. As habitat and populations shrink, other factors such as harvest and loss of genetic diversity threaten species sustainability and persistence. The influence of human development was considered during the analysis for the Project.

Timber Harvest Opposing View #31 - “History, not science, refutes the claim that logging helps to prevent forest fires.

The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests. Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot. More logging will not fix this.”

Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.highbeam.com/doc/1G1-192070397.html

The quoted material in view #31 is not contained in Keene’s 2009 opinion article.

Section 1.4.1 of the EA describes the land management history of the project area, including past timber harvest. The EA acknowledges that past timber harvest as well as wildfire and fire suppression have contributed to the current vegetative conditions (EA p. 1-7). EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to prevent wildfires but to alter the conditions (EA p. 3-60) that lead to undesirable ecological effects (EA section 3.2.5.1) and undesirable social effects (EA p. 3-57).

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Timber Harvest Opposing View #32 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds. Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?” Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html

EA section 3.3.4 discusses the existing conditions as they relate to crowning index and surface flame lengths: in WUI currently, the SFLs are between 4 and 6 feet and the CI indicates a moderate risk and in Non-WUI, The CI indicates that the wildfire hazard is a moderate-to-high risk.

Sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments under the action alternatives on crowning index and surface flame lengths; “… surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” Effects of fuels created by mechanical treatments are disclosed in the EA in sections 3.3.5.2 and 3.3.5.3; “… the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning

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and jackpot burning.”

Timber Harvest Opposing View #33 - "Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low-ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest." Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata "Effects of Human-Induced Changes on Hydrologic Systems." An American Water Resources Association publication, June 1994 http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF

The quotation originates from the introduction of the cited document, which contains no other references to changes in bulk density/soil compaction. The focus of the paper is on slope stability associated with changes in soil moisture or subsurface flow that may occur from use of heavy equipment during logging operations or other disturbance. EA sections 3.8.3 and 3.8.4 discuss effects of the different activities (timber harvest and roads) on soil disturbance. EA section 3.8.5 includes the discussion of potential effects of the activities on slope stability.

Timber Harvest Opposing View #34 - "Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)."

"Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain." "Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources less than four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging

The spotted salamander is an eastern species that ranges from Ontario, Canada, south to Texas and extends to the eastern coast (NatureServe 2012); therefore, this species would not be impacted by the proposed project activities. The effects analysis for this project addresses potential impacts to one amphibian species, the spotted frog.

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disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools." Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest. http://www.nd.edu/~underc/east/education/documents/AKlein2004Pre-loggingsurveyofamphibianlarvaeinvernalpools.pdf

Timber Harvest Opposing View #35 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.” Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. http://frames.nacse.org/6000/6269.html

Effects of fuels created by mechanical treatments are disclosed in EA in sections 3.3.5.2 and 3.3.5.3; “… the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.” The effects described in these sections are consistent with those described in the best available science and addressed in view #23. Please note that the first quotation appears to contradict the scientific findings cited in view #23, which found a more conclusive relationship between wildfires and areas previously harvested.

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Timber Harvest Opposing View #36 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.”

“How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.”

Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp


EA sections 3.8.3 and 3.8.4 disclose the potential effects to soils that may be caused by alternative timber harvest methods and logging equipment scenarios. Section 3.6.2 discloses potential effects on water quality.

Timber Harvest Opposing View #37 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground.

Leitner, Brian. “Logging Companies are Responsible for

The article refers to clearcutting and thinning. Clearcutting is not a proposed activity/silvicultural prescription. EA section 3.2.2 fully discloses, in detail, the silvicultural prescriptions that are proposed under the action alternatives, and the intended outcomes of these prescriptions. EA section 3.3.5 discusses the effects of proposed treatments on wildfire crowning index. Effects of fuels created by mechanical treatments are disclosed in the EA, sections 3.3.5 and 3.3.6.

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the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html

Section 3.4.2.1 discloses the effects of the alternatives on old forest and large tree habitat.

Timber Harvest Opposing View #38 - "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://maps.wildrockies.org/ecosystem_defense/Resources_Species_Topics/Fire/Misuse%20of%20Fire%20Plan%20funds.pdf

This quotation relates to the use of National Fire Plan Rehabilitation and Restoration Funds. The cited report questioned whether in Region 1, National Fire Plan Rehabilitation and Restoration Program funds were appropriately used to prepare and administer projects involving commercial timber sales. The report concludes only that “commercial timber sales do not meet the criteria for forest restoration” as defined by the National Fire Plan selection criteria for specific projects in question on the Bitterroot National Forest.

This report did not make a general conclusion about commercial timber harvest and restoration. Refer to the responses to view #5 and view #8 for information on the purpose and need for this project and the importance of using vegetation management to meet restoration objectives in the Project area.

Timber Harvest Opposing View #39 - “In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.” Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998 http://www.sciencemag.org/content/283/5410/1996.summary

To provide context, view #39 goes on to state: “First, the committee suggests, the Forest Service should assess the “ecological integrity” of a planning area, looking at broad factors such as the proportion of old-growth forests, stream flows, wildfire frequency, and the amount and distribution of large dead trees. Because these factors vary over time, the committee argues that the benchmark for assessing integrity must be their “historic range of variability,” with that range, in effect, being the conditions before European settlement. The more current conditions fall outside the

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historic range, the report argues, the lower the ecological integrity; the lower the ecological integrity, the greater the risk to ecological sustainability. Armed with this information, the Forest Service would then create plans to safeguard ecological integrity; economic and social activity could take place within this constraint. Second, the Forest Service should identify a set of “focal species”: native species whose abundance and wellbeing would be indicators of the functioning of the larger ecological system. Forest planners would then seek “to provide ecological conditions needed to protect and, as necessary, restore the viability of focal species.” Although “protect” and “restore” are strong standards, they would be a departure from current regulation, which requires the agency to “insure” the viability of all native populations.” EA section 1.2 describes how the project would implement the concepts described in view #39, which are embodied in the 2010 Forest Plan, including detailed discussions in Appendix A and Appendix E of the Forest Plan.

Timber Harvest Opposing View #40 - "Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system." Maser, C. Ph.D., and J. M. Trappe Ph.D. “The Seen and Unseen World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW-164 http://www.fs.fed.us/pnw/publications/pnw_gtr164/

The 2010 Forest Plan (Appendix A, pages A-10 through A-15) includes desired conditions for snags and coarse woody debris for many of the reasons cited in view #40. EA sections 2.4.4.7 and 2.4.4.10 include design features for the retention and development of snags and coarse woody debris, and section 3.2.6 discusses the effects of the alternatives on snags and coarse woody debris.

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Timber Harvest Opposing View #41 - "Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5)

"Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44)

Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA Forest Service, GTR-PNW-GTR-229 http://www.fs.fed.us/pnw/publications/pnw_gtr229/

Though the cited paper discusses forest ecosystems in the Pacific Northwest, the concepts apply to central Idaho. The action alternatives include design features (EA section 2.4.4.7) that retain large ponderosa pine (Design Feature VE-7) and all legacy-like Douglas-fir (Design Feature VE-4), which are typically the most mature trees in the stands. We were unable to find the second quotation on page 44 of the cited paper; therefore, we could not determine what “tree parts” refers to. However, EA sections 2.4.4.7 and 2.4.4.10 include design features for the retention and development of snags and CWD, and section 3.2.6 discusses how the effects of the alternatives on snags and CWD help create stand diversity.

Timber Harvest Opposing View #42 - "In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by:

a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.”

McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of eastside ecosystems: changes in fish habitat over 50 years, 1935-1992.” 1994 GTR-321 93-181 http://www.fs.fed.us/pnw/publications/pnw_gtr321/

Water quality and the effects of timber harvest and roads on sedimentation and temperature were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality). The effects of sedimentation on channel pattern and morphology, including bank stability and channel width, were analyzed, and the discussion is included in sections 3.6 (Hydrology) and 3.7 (Fisheries).

Change in drainage network, change in peak/base flows, and disturbance regime (including slope stability) due to roads have been analyzed, and the discussion is included in the Hydrology section of the

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EA. This discussion can be found in sections 3.6 (Hydrology), 3.7 (Fisheries), and 3.8 (Soils).

Timber Harvest Opposing View #43 - “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams.

The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution of fishes, reduction in fish numbers, and reduction in total biomass.”

Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of Logging on the Aquatic Resources of Three Headwater Streams of the Alsea River, Oregon – Part III.” Fishery Report Number 9 Oregon Department of Fish and Wildlife. http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf

Water quality and the effects of timber harvest and roads on sedimentation and stream temperature were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality). The effects of sedimentation on channel pattern and morphology, including bank stability and channel width, were analyzed, and the discussion is included in section 3.6 (Hydrology).

Change in drainage network, change in peak/base flows, and disturbance regime (including slope stability) due to roads have been analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in sections 3.6 (Hydrology), 3.7 (Fisheries), and 3.8 (Soils). Aquatic habitat conditions—including pool frequency and quality, the occurrence of large pools, and the occurrence of large woody debris—have been analyzed, and the discussion can be found in EA section 3.7 (Fisheries).

Timber Harvest Opposing View #44 - "Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling." "All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in functioning can be

The first quotation in view #44 is not in Naeem et al. 1999. Naeem et al. (1999, page 5 and 6) concluded the following: “…declining species richness can lead to declines in

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particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations." "Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levels typical of managed ecosystems."

Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining Natural Life Support Processes." Issues in Ecology No. 4. Fall 1999. http://www.esa.org/science_resources/issues/TextIssues/issue4.php

overall levels of ecosystem functioning. This is especially pronounced at lower levels of diversity. This finding is particularly relevant to current ecological change, since most ecosystems are being transformed into managed systems which typically contain only a few dominant species, whereas the natural ecosystems they replaced typically contained tens to hundreds of species.” “…at least one species per functional group is essential to ecosystem functioning. Having more than one species per functional group may or may not alter overall levels of ecosystem functioning, but it may nevertheless insure against loss of functioning in times of disturbance if species within functional groups are able to replace or compensate for one another.” “…the nature of an ecosystems response to declining biodiversity is dependent on community composition, that is, on which species are lost and which remain.” Section 1.4.1 of the EA describes the land management history of the project area, including past timber harvest. The EA acknowledges that past timber harvest as well as wildfire and fire suppression have contributed to the current vegetative conditions (EA, page 1-7).

One of the purposes and needs of the project is to develop habitat for Family 1 wildlife species (EA section 1.5, Purpose #1). Family 1 species are of conservation concern due to declining populations. The proposed management activities are targeted at developing habitat for these species (EA p. 1-2).

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Section 3.4.3.1.3 describes the effects of the alternatives on development of source habitat for Family 1 species. The action alternatives maintain existing Family 1 habitat, and they develop greater amounts of Family 1 habitat in the long term than the No Action alternative would. Based on the criteria described by Naeem et al. (1999), the proposed actions increase biodiversity within the project area.

Timber Harvest Opposing View #45 - "As a result of the Forest Service's well-documented mismanagement over many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry."

Nappier, Sharon. Lost in the Forest: How the Forest Service's Misdirection, Mismanagement, and Mischief Squanders Your Tax Dollars. Taxpayers for Common Sense, 2002. http://www.ourforests.org/fact/lostintheforest.pdf

The quotation is taken from an opinion article. EA section 3.14, Economic Assessment, provides a summary of how dollars allocated to this project have been, or are planned to be, spent.

Timber Harvest Opposing View #46 - "Agroforestry does reduce

biodiversity. In forests used for logging, whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and catchment purposes. Management strategies for sustainable forestry are being developed, but there is a need for further

interaction among foresters, ecologists, community representatives, social scientists, and economists." Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human-Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997. http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=&fulltext=logging&searchid=1136659907310_5043&FIRSTINDEX=0&journalcode=sci

EA section 3.2.5 describes how areas proposed for treatment and those not proposed for treatment would contribute to landscape diversity. However, the contrast will not be as dramatic as that described in view #46, because the examples of “intensive use” are primarily clearcuts, which are not a proposed treatment. Sections 2.4.4.7, 2.4.4.8, and 2.4.4.9 describe design features that help contribute to the conservation of various elements (e.g., snags and CWD) and portions of the landscape (e.g., RCAs); these design features are similar to the strategies described in cited paper.

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Timber Harvest Opposing View #47 - "The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees."

"The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non-material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning."

"The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed."

"For example:

• 82 percent wanted to ban clearcutting, • 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining

undisturbed forest; and • 72 percent urged prohibition of logging if bear or other wildlife

habitat would be harmed." "Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more

View #47 cites comments that are specific to t management strategies on the Green Mountain National Forest; therefore, the quotations are not specifically relevant to the Project on the Forest.

As stated in EA section 1.3, in September 2010, a collaborative group called the Boise Forest Coalition was formed, bringing together diverse interests to engage in planning a multifaceted forest project. The citizen-led Boise Forest Coalition represents several public and organizational interests and has an open membership. Soon after their formation, the Coalition partnered with the Forest to provide input on the Project. The Coalition’s goal for involvement in the project was to offer recommendations that address the following resource, economic, recreational, and societal needs: 1) bull trout (Salvelinus confluentus) recovery, 2) forest health, 3) ecological restoration, 4) fish and wildlife habitat, 5) a variety of trail-related recreational pursuits, 6) fuel hazard reduction around summer homes, and 7) job opportunities and production of forest products. The Coalition worked in a collaborative fashion, including consultation with the Forest Service, for about 1 year to develop a set of recommendations. The Boise Forest Coalition’s recommendations provide one basis for the Proposed Action. Information on the Boise Forest Coalition and their involvement with the Forest can be found at www.idahoforestpartners.org/planning-and-organizational-resources.html. In addition, public views of the management strategy being implemented on the Forest per its Forest Plan, as

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important than protection of endangered species."

"'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'."

Northup, Jim. 1999. "Public Wants More Wilderness, Less Logging on Green Mountain NF". Press Release by Forest Watch, a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10

amended in 2010, are disclosed in the response to public comment sections of the 2003 FEIS supporting the 2003 revised Forest Plan, and the subsequent 2010 FEIS supporting the amendment to the Forest Plan to incorporate a comprehensive wildlife conservation strategy (USDA 2003c; USDA 2010). Rationale for Forest Plan decisions concerning strategies and how they address comments can be found in the Records of Decision for each Plan (USDA 2003b and USDA 2010).

Timber Harvest Opposing View #48 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk."

“Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.” Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://motherjones.com/politics/2002/08/fight-fire-logging

View #48 refers to the National Fire Plan. Effects of proposed treatments on wildfire crowning index are discussed in EA section 3.3, Fire and Fuels.

Timber Harvest Opposing View #49 - “In response to catastrophic wildfires, wide-reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in

The cited article also includes the following text:

“Fire mitigation and restoration models derived from other ponderosa pine ecosystems (e.g., Covington and

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denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore historic forest structure in those forest types that are outside of their historic range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then aggregated by land management classes. Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations. Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.” Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001

Moore 1994; Kaufmann et al. 2001; Kaufmann et al. 2003) should not be extrapolated to the montane zone of Boulder County in lieu of conducting intensive, site specific data collection in the potential management area. Analogously, the specific results reported here should not be uncritically applied to other areas of ponderosa pine ecosystems. Rather, the approach and methodology of the current study can inform management discussion and guide data collection procedures in other ecosystems.” “In places where restoration of historic forest structure is the primary goal and the historic fire regime included high-severity fires, forest managers must actively communicate the political, financial, and managerial difficulties of maintaining forests within a potentially hazardous state.”

The cited paper discusses the historical role of fire in the ponderosa pine ecosystems of the Colorado Front. The authors describe the fire regime as “mixed,” which includes stand-replacing fire. They conclude that not all ponderosa pine forests should be returned to a “nonlethal” state if the goal is to create historical conditions. This this conclusion formed the basis for the second paragraph quoted in view #49.

The Fire and Fuels Technical Report discusses the assignment of nonlethal and mixed1 fire regimes to the PVGs in the project area that include ponderosa pine. Within the context of the 2010 Forest Plan, Appendix A, the fire regime assignments are a desired condition that projects such as Clear Creek would implement. As described in the FEIS for the 2010

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Forest Plan amendment, maintaining ponderosa pine ecosystems in a wildfire stand-replacing condition, while recognized as part of the HRV, would not achieve the goals of conserving and restoring these imperiled ecosystems and the wildlife species associated with them in the near term.

Timber Harvest Opposing View #50 - "Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands." Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang Zhu Ph.D.and Douglas W. MacCleery. 1992. "Forest Resources of the United States." USDA Forest Service. Rocky Mt. Forest and Range Experiment Station. Gen. Tech. Rep. RM-234. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html

The project area is on lands determined to be suitable for timber production as defined by the MPCs assigned by the 2010 Forest Plan (EA section 1.9.6.3); timberland suitability assessment criteria are summarized in the 2010 FEIS supporting amendments to the Forest Plan (USDA Forest Service 2010b, section 3.5).

Timber Harvest Opposing View #51 - "Fire severity has generally increased and fire frequency has generally decreased over the last 200 years. The primary causative factors behind fire regime changes are effective fire prevention and suppression strategies, selection and regeneration cutting, domestic livestock grazing, and the introduction of exotic plants." Quigley, Thomas M. Ph.D., Richard W. Haynes and Russell Graham Tech. editors. 1996. “Integrated Scientific Assessment for Ecosystem Management in the Interior Columbia Basin and Portions of the Klamath and Great Basins.” USDA Forest Service, PNW-GTR-382, 303 p. http://www.fs.fed.us/pnw/publications/icbemp.shtml

The science findings resulting from ICBEMP, such as the one partially quoted by the commenter in view #51, were integral in informing disclosures in the FEIS supporting both the 2003 Revised Forest Plan (USDA 2003a,b,c) and the 2010 amendments to the Forest Plan (USDA Forest Service 2010a). The Project implements the strategies outlined in the Forest Plan (EA sections 1.2 and 1.8). The 2003 FEIS, Chapter 1, page 1-31, states the following: “In January of 2003 a Memorandum of Understanding (MOU) was entered into … The purpose of this MOU is to cooperatively implement The Interior Columbia Basin Strategy to guide the amendment and revision of forest (Forest Service) and resource management (BLM) plans and project implementation

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on public lands administered by the Forest Service and Bureau of Land Management throughout the Interior Columbia Basin (USDA Forest Service et al. 2003). This strategy incorporates the scientific assessment information found in, “An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins” (Quigley and Arbelbide 1997a, b, c, d), the analyses supporting or developed as part of ICBEMP, the “Integrated Scientific Assessment for Ecosystem Management” (ICBEMP 1996b) developed by ICBEMP as a guide for implementation, and all reports generated by the ICBEMP project. … Key findings contained in this strategy were considered and used in the development of the Proposed Action (Alternative 2) for Forest Plan revisions, as well as other action alternative management strategies outlined in the FEIS (Chapter 2) …” Chapter 1 of the 2010 FEIS, page 7, states the following: “This analysis also draws on principles and science generated as part of the Interior Columbia Basin Ecosystem Management Project (ICBEMP) (Raphael et al. 2000; Wisdom et al. 2000). In the ICBEMP Memorandum of Understanding (MOU) and Strategy 2003, the Forest Service agreed that “management plans shall address ways to maintain and secure terrestrial habitats that are comparable to those classified by the science findings as source habitats” (USDA Forest Service et al. 2003a,b).

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Timber Harvest Opposing View #52 - “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades.

We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems.

The Act to Save America's Forests will:

• Make the preservation and restoration of native biodiversity the central mission of Federal forest management agencies.

• Ban extractive logging in core areas of biodiversity and the last remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value.

• Protect sensitive riparian areas and watershed values by banning extractive logging in streamside buffer zones.

• End clearcutting and other even age logging practices on federal land.

• Establish a panel of scientists to provide guidance to federal forest management. We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery

The project is in an area that has been managed in the past (EA section 1.4.1). The project does not propose clearcutting (section 1.6 and 1.9.6) and is not in areas with outstanding biological value (section 1.8.9). Treatments in roadless areas are prescribed fire designed to emulate historic patterns; design features are included for conservation of riparian areas (EA section 2.4.4.9); and the purpose of the project is to improve (low-elevation) or maintain (upper-elevation) landscape diversity (EA section 1.5 and 3.2.5 [Vegetation Landscape Patch and Pattern]; section 3.4 [Wildlife]; section 3.6 and section 3.7 [Fisheries and Other Aquatic Resources]; and section 3.9 [Botanical]).

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into the 21st century and beyond.”

Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Ph. D. and over 600 other leading biologists, ecologists, foresters, and scientists from other forest specialties. From a 1998 letter to congress. http://www.saveamericasforests.org/resources/Scientists.htm

Timber Harvest Opposing View #53 - “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologically-sound plan for protecting and restoring the entire federal forest system. If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.” Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Carnahan http://www.saveamericasforests.org/Raven.htm

The project is in an area that has been managed in the past (EA section 1.4.1), and treatments in Inventoried Roadless Areas include prescribed fire designed to emulate historic conditions (section 3.16). These treatments are consistent with the Idaho Roadless Rule (section 1.9.9).

Timber Harvest Opposing View #54 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any

EA section 3.3 discusses the effects of proposed treatments on wildfire crowning index and the effects related to the activity fuels that will be produced.

EA sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments on crowning index and surface

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other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).” Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf

flame lengths; “… surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3; “… the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.” Section 3.3.5.1 discusses the effects of not doing any treatments on crowning index and surface flame lengths. Surface fire behavior would stay relatively consistent in both the nonlethal and mixed1 fire regimes, but if a wildfire were to occur and a surface fire transitioned to the crowns, stand-replacing fire behavior would likely result. This type of fire behavior could potentially increase over time due to the

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continued departure of vegetative conditions from desired conditions. The risk of lethal fire, which is an uncharacteristic event in the nonlethal fire regimes, would continue to increase. Some lethal fire would be expected historically in a mixed1 fire regime. However, the percentage of overstory tree mortality would likely exceed 50% within the analysis area, which would be uncharacteristic for the mixed1 fire regime. The project has a restoration emphasis and is therefore focused on retaining species composition, large tree habitat, and old forest habitat (see design features VE-2 and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in sections 3.3.5.2 and 3.3.5.3. Treatments as proposed in the WUI and non-WUI stands would include a VDT, and a thin-from-below prescription would be used to CT and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. “This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa

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pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.

Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.” Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2.

Timber Harvest Opposing View #55 - “I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review

The views presented in the cited article are specific to coastal salmonids in California.

Water quality and the effects of timber harvest and roads on sedimentation and stream temperature were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection

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panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect this threatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.” “Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In my experience the most pervasive and severe impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasive changes due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.”

1. Roelofs, Terry D. Ph.D. Testimony for the California State Water Board

2. and Regional Water Quality Control Boards Regarding Waivers of Waste

3. Discharge Requirements on Timber Harvest Plans. August 2003. http://webcache.googleusercontent.com/search?q=cache:QNy_aih1RxEJ:edennapa.org/thp/roelofstestimony.doc+%22timber+harvest%22+ph.d.+adverse&hl=en&ct=clnk&cd=5&gl=us

3.6.2 (Water Quality).

The effects of sedimentation on channel pattern and morphology, including bank stability and channel width, were analyzed, and the discussion is included in section 3.6 (Hydrology Resources). Change in drainage network, change in peak/base flows, and disturbance regime (including slope stability) due to roads have been analyzed, and the discussion is included in the Hydrology, Fisheries, and Soils sections of the EA, sections 3.6, 3.7, and 3.8, respectively.

Aquatic habitat conditions—including pool frequency and quality, the occurrence of large pools, and the occurrence of large woody debris—have been analyzed, and the discussion can be found in section 3.7 (Fisheries), which also includes specific discussions concerning habitat elements.

Timber Harvest Opposing View #56 - “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how

Public views of the management strategy being implemented on the Forest per its Forest Plan, as amended in 2010, are disclosed in the response to Public Comment sections of the 2003 FEIS supporting

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Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, protective strategies made up 76 percent of the preferred management strategies and commodity-based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.”

Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural Development Perspectives, vol. 14, no. 2 http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf

the 2003 revised Forest Plan, and the subsequent 2010 FEIS supporting the amendment to the Forest Plan to incorporate a comprehensive wildlife conservation strategy (USDA Forest Service 2003c, 2010). Rationale for Forest Plan decisions concerning strategies and how they address comments can be found in the Record of Decision for each Plan (USDA Forest Service 2003b, 2010).

Timber Harvest Opposing View #57 - “Once clear-cutting has occurred, regulation and human silvicultural practices become responsible for the revegetation that follows. The creation of new forest succession patterns are the result of human control over the growing environment. Rather than proceeding at a natural pace, humans attempt to speed up the forest succession process to quickly return to a situation where harvesting is again possible. Reforestation of the disturbed area after clear-cutting also emphasizes maintaining control over the distribution and quality of forest species.

Simplification is a state that results from the forest being harvested before it reaches maturity. Logging simplifies forest ecosystems (Dudley et al 1995) by narrowing the age range of the stand and suppressing diversification through repeated harvesting, burning to remove slash, and replanting with hybrid seedlings. Simplification affects the health and productivity of the forest because simplified forests lack the variety found in older stands,

The cited paper examines the effects of clearcutting on forest ecosystems. The Project does not propose clearcutting (EA section 1.9.6[#3]).

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including species diversity, vertical structure, and microhabitat. From an ecological standpoint, a simplified forest of a particular age has less overall bio-mass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of merchantable timber.

Scott, Mark G. “Forest Clearing in the Gray’s River Watershed 1905-1996” A research paper submitted in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE in GEOGRAPHY Portland State University, 2001 http://www.markscott.biz/papers/grays/chapter1.htm

Timber Harvest Opposing View #58 - “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.” Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. "Physicians of the Forest": A Rhetorical Critique of the Bush Healthy Forest Initiative” Electronic Green Journal, Issue #19, December 2003 http://escholarship.org/uc/item/4288f8j5

The cited paper presents a viewpoint regarding the need to develop the Healthy Forest Initiative policy; the paper does not address the specific actions proposed by the Project.

EA section 3.14, Economic Assessment, provides a summary of how dollars allocated to this project have been, or are planned to be, spent.

Timber Harvest Opposing View #59 - “Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact, the justification

The project area is not “virgin forest,” since the majority of the area has been previously managed (EA section 1.4.1). EA section 3.14, Economic Assessment, provides a summary of how dollars allocated to this project have been, or are planned to be, spent.

Section 3.7 of the 2010 FEIS supporting Forest Plan

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for the Weeks Act in 1911 which established national forests in the east, was watershed protection. (A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.)

“Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, as well as homes for a myriad of plants and wildlife that can live nowhere else.” Sierra Club. 2005 “Ending Commercial Logging on Public Lands” http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html

amendments to incorporate a comprehensive wildlife strategy includes a detailed discussion of how various economic sectors contribute to local and regional economies influenced by activities on the Forest.

Timber Harvest Opposing View #60 - “Timber harvesting in British Columbia influences (a) forest hydrology; (b) fluvial geomorphology; (c) terrain stability; and (d) integrated watershed behavior. Impacts on forest hydrology are well understood and include increased average runoff, total water yield, increased storm runoff and advances in timing of floods. Stream channels and valley floors are impacted differently by fine sediment, coarse sediment and large woody debris transport. Terrain stability is influenced through gully and mass movement processes that are accelerated by timber harvesting. Impacts on integrated watershed behavior are assessed through disturbed sediment budgets and lake sediments.” Slaymaker, Olav Ph.D. “Assessment of the Geomorphic Impacts of Forestry in British Columbia” AMBIO: A Journal of the Human Environment 29(7):381-387. 2000 http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381

The referenced paper focuses on the implications of British Columbia’s current policy for sustainable land management. As is widely recognized, forest management activities can influence hydrologic processes and functions that can affect terrain stability and watershed response. For the Project, the EA discusses potential effects of timber harvest on the following: Forest Hydrology—sections 3.6

Slope (terrain) Stability—section 3.8 Watershed Condition—sections 3.6 and 3.7 via WCIs

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Timber Harvest Opposing View #61 - “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and communities.” “Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.” Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to Central Oregon Communities and the Surrounding Environment.” Testimony before the House Committee on Resources, August 25, 2003 http://www.propertyrightsresearch.org/2004/articles6/testimony_of_andy_stahl.htm

The cited paper presents a viewpoint regarding the need to develop the Healthy Forest Initiative. Refer to the responses to views #48, #49, #56, and #59.

Timber Harvest Opposing View #62 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles. The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity. Logging, especially clear cutting, can change the fire climate so that fires start more easily, spread faster, further, and burn hotter causing much more devastation than a fire ignited and burned under natural conditions. If we stop the logging and stop building fire prone developments, we minimize the loss of lives and property suffered by

The cited paper presents a viewpoint regarding the need to develop the Healthy Forest Initiative. Refer to the responses to views #48, #49, #56, #59, and #61.

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people in fires.

As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make more money from our losses. Just like big tobacco.” Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm

Timber Harvest Opposing View #63 - “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotes nearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1) “Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9)

“Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19)

“Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20)

“Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private

NOTE—We were unable to locate the full article cited in view #63.

The action alternatives include design features (EA section 2.4.4.7) that retain large ponderosa pine (Design Feature VE-7) and all legacy-like ponderosa pine and Douglas-fir (Design Feature VE-4), which are generally the most fire-resistant trees in the project area. EA Section 3.3 discusses the effects of proposed treatments on wildfire crowning index.

EA section 3.2 discloses that the action alternatives would increase the growth rates of medium tree size class stands through treatments that would reduce the density of smaller trees.

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timber companies, not to reduce the risk of fire.” (pg. 20)

Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000 http://www.ourforests.org/fact/ashes.pdf

Timber Harvest Opposing View #64 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.”

Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php

The article cited in view #64 also states the following:

“Forest managers and scientists agree that the most hazardous fuels in the forest are dry grass, pine needles, tree limbs and brush, and eliminating them should be the first priority. The focus of a good fuels management plan must be on reducing those fuels that ignite and spread wildfire, while keeping the large, older trees that are resistant to fire. Those big trees provide shade and keep the forest floor moist and the wind speed down. Because fire behavior is contingent upon local conditions, a ‘one-size-fits-all’ prescription is not the answer.” The action alternatives include design features (EA section 2.4.4.7) that retain large ponderosa pine (Design Feature VE-7) and all legacy-like ponderosa pine and Douglas-fir (Design Feature VE-4), which are generally the most fire-resistant trees in the project area. EA Section 3.3.5 discusses the effects of proposed treatments on wildfire crowning index and the effects related to the activity fuels that will be produced.

Timber Harvest Opposing View #65 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has

The cited report focused on findings in the Sierra Nevada ecosystems. However, many of the conclusions and goals apply to central Idaho and the Project. The

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increased fire severity more than any other recent human activity."(pg.62)

University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

committee of scientists that prepared the report recommend the following:

“Substantially reduce the potential for large high-severity wildfires in the Sierra Nevada in both wildlands and the wildland-urban intermix.” “Restore historic ecosystem functions of frequent low- and moderate-severity fire.”

Both of these goals are similar to the goals of the Project (EA section 1.5).

Timber Harvest Opposing View #66 - "During the post-World War II housing boom, national forests were viewed as a ready supply of building material. The increased demand for timber from national forests led to more widespread use of commodity-oriented harvesting techniques such clearcutting. Along with the increased logging that followed, concern over the environment increased. In the 1960's and 1970's, several laws were enacted to protect forests. Additional laws formalized the concept of "multiple-use," whereby the uses of timber, forage, and water shared equal footing with wildlife conservation and recreation opportunities." USDA Forest Service. "Forest Management: A Historical Perspective." http://www.fs.fed.us/forestmanagement/aboutus/histperspective.shtml

The Forest Plan, which the Project implements, was developed within the framework of the very laws referenced by view #66. The RO) for both the 2003 Revised Forest Plan (pp. ROD-35 through ROD-39) and the 2010 amended Forest Plan (USDA Forest Service 2010a, pp. 29–38) include specific determinations regarding consistency with these laws.

Timber Harvest Opposing View #67 - "The development of sound forest-management policies requires that consideration be given to the economic benefits associated with competing uses of forest resources. The benefits that may be provided under different management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasi-option value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices

The article cited in view #67 states the following: “Studies have been conducted which examine the benefits derived from management alternatives for westside forests. There is an absence of studies that speak directly to the management issues concerning eastside forests, however, where the issues are in many respects different. Any eastside forest management plan can be expected to contain many dimensions, including the role of prescribed fire versus wildfire, the role of

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and costs."

Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public Forestlands: A Survey of the Literature. A study conducted on behalf of the U.S. Forest Service. http://www.icbemp.gov/science/vincent.pdf

forest thinning and other forms of harvesting (including salvage logging), the possible use of restoration projects, and many other factors. It can be argued that the biological, physical, political, and institutional constraints affecting the management alternatives are not well defined at this point.”

Given the above conclusion, the findings from view #67 cannot be applied to the Project area, which would be considered an “eastside” forest within the context of this report.

Timber Harvest Opposing View #68 - “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalists at odds with the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees. Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires. In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “

Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml

The article cited in view #68 states the following: “Most experts now agree, for example, that in some areas excessively high levels of undergrowth can cause unnaturally severe fires, and that reducing these hazardous fuels is warranted.”

The action alternatives include design features (EA section 2.4.4.7) that retain large ponderosa pine (Design Feature VE-7) and all legacy-like ponderosa pine and Douglas-fir (Design Feature VE-4), which are generally the most fire-resistant trees in the project area. In the lower elevations, proposed treatments would be a thin from below (section 3.2.2.1), which generally retains the larger trees. Treatments in the upper elevations (section 3.2.2.2) have been designed to emulate historic conditions, improve the mix of mid-seral species, and provide a diversity of vegetation conditions consistent with that expected historically. EA section 3.2.2 discusses the scientific context for

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using this type of treatment as a restoration tool.

Timber Harvest Opposing View #69 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.”

Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html

EA Section 3.3.5 discusses the effects of proposed treatments on wildfire crowning index and the effects related to the activity fuels that will be produced.

Timber Harvest Opposing View #70 - “Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitive wildlife. Logging typically requires roads and skid trails which create chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who suggests that logging is a benefit or benign is not doing a full accounting of costs.” Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.” Wuerthner, George “Who Will Speak For the Forests?” NewWest, January 27, 2009 http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/

View #70 quotes an opinion paper that does not cite scientific literature to support the specific opposition points. The EA discusses potential impacts of the alternative timber harvest and road activities on the following:

• Soil Compaction/Soil Quality—section 3.8 • Wildlife—section 3.4 • Water Quality/Hydrologic Processes—section 3.6 • Aquatics/Fish Habitat—section 3.7 • Noxious Weeds—section 3.10 • Species Composition and Age Class—section 3.2 • Fire Regimes—section 3.3

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http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/



Timber Harvest Opposing View #71 - "After logging, peak pipeflow was about 3.7 times greater than before logging." "The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)."

Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow and erosion: coastal northern California, USA." Proceedings of the Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992 http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF

The increase in peak pipeflow cited in view #71 occurred after clearcut logging. The Project does not propose to use clearcut harvest methods (EA section 1.9.6.3[#3]).

“The use of heavy equipment…” reference in this article is pertains to the use of an alternative cable yarding system to avoid an unintended influence on the study results. The potential impacts of the timber harvest alternatives on soil compaction and slope stability are discussed in EA section 3.8.

Timber Harvest Opposing View #72 - “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, but also numerous other services such as recreation and clean water.”

“Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat.” “It is now widely recognized that commercial logging has damaged ecosystem health, clean water, and recreational opportunities-- values that are highly appreciated by the American public. The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service and independent economists have estimated that timber accounts for only 2.7

View #72 cites an opinion article.

Refer to the responses to views #1, #3, #4, #8, #11, #48, #49, #56, and #59.

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percent of the total values of goods and services derived from the National Forests, while recreation and fish and wildlife produce 84.6 percent.”

From an April 16, 2002 letter to President Bush asking him to stop all logging in the national forests. http://www.forestwatch.org/content.php?id=108 Note: After the link has been opened, scroll to the bottom and follow the link to “Scientist's No Logging Letter.pdf 64KB” This will show the complete letter and the signatories.

Mr Artley’s attachment #1 identifies the 221 scientist who signed the letter.

Comment: The Responsible Official ignores the statements of 221 unbiased, highly educated biological scientists who point out the common natural resource degradation resulting from commercial timber sales based on the word of a handful of foresters and silviculturists who will gain personally when the timber sale is sold. Clearly, the Responsible Official prefers to let representatives from resource extraction corporations choose the projects on the forest.

Timber Harvest Opposing View #73 - “Recently, so called "salvage" logging has increased on national forests in response to a timber industry invented "forest health crisis" which points the finger at normal forest processes of fire, fungi, bacteria, insects and other diseases. In fact the crisis in the national forests is habitat destruction caused by too much clearcutting.

My long-term studies of forest diseases in Idaho show the loss by disease and insect activity in all age classes of forests to be less than or slightly more than 1 percent per year over the past thirty-eight years. These findings are consistent with Forest Service national level data. Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the

The project does not propose salvage logging (section 1.6) or clearcutting (section 1.9.6.3[#3]). EA section 3.2.7 discusses the effects of the project on insects, which are a contributor to the development of snags and coarse woody debris, important biological elements within the project area. EA section 3.2.5 discusses the role that proposed treated areas combined with areas not proposed for treatment result in moving toward the desired landscape diversity. Water quality and the effects of timber harvest and roads on sedimentation and stream temperature were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection

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forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.”

Partridge, Arthur Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm


The effects of sedimentation on channel pattern and morphology, including bank stability and channel width, were analyzed, and the discussion is included in section 3.6 (Hydrology) in the WCI conclusions for WCI-(Stream Channel Conditions and Dynamics.

Change in drainage network, change in peak/base flows, and disturbance regime (including slope stability) due to roads have been analyzed, and the discussion is included in the Hydrology and Soils sections of the EA. This discussion can be found in sections 3.6 (Hydrology) and 3.8 (Soils). Aquatic habitat conditions—including pool frequency and quality, the occurrence of large pools, and the occurrence of large woody debris—have been analyzed, and the discussion can be found in section 3.7 (Fisheries) under the disclosures concerning habitat elements. Finally, the EA discloses the effects of the project on the transportation system (i.e., road management activities) in section 3.11.

Timber Harvest Opposing View #74 - “CONCLUSIONS In our overview of the impacts of forest management activities on soil erosion and productivity, we show that erosion alone is seldom the cause of greatly reduced site productivity. However, erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term site productivity and may lead to sustained periods

EA section 3.8 discloses the potential short-term and long-term direct, indirect, and cumulative effects of the activities proposed under the action alternatives on soil quality.

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of extended erosion that could exacerbate degradation.

Managers should be concerned with harvesting impacts, site preparation disturbances, amount of tree that is removed, and the accumulation of fuel from fire suppression. On erosion-sensitive sites, we need to carefully evaluate such management factors.” Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on erosion and soil productivity. Proceedings of the Symposium on Soil Quality and Erosion Interaction, Keystone, CO, July 7, 1996. Ankeney, IA: Soil and Water Conservation Society. 16 p. http://forest.moscowfsl.wsu.edu/smp/docs/docs/Elliot_1-57444-100-0.html

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Table D-116. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment, Opposing Views—Attachment #3—Fuels Reductions Ineffective


Fuels reduction Opposing View #1 - “large, severe wildfires are more weather-dependent than fuel-dependent,”

Agee, James K. Ph.D. “The Severe Weather Wildfire-Too Hot to Handle? Northwest Science, Vol. 71, No. 1, 1997 http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf

View #1 is the hypothesis that Agee’s paper debates. The quoted statement was extracted from the following paragraph: “Recent statements in the scientific literature and popular press suggest that recent large, severe wildfires in western North America are largely due to extreme weather. The long-accepted view of fire behavior as a function of fuels, weather, and topography has changed for some from an equilateral fire triangle, where each factor can be significant, to a distorted isosceles triangle with a wide base being the weather contribution to fire behavior. This ‘weather hypothesis’ that all large, severe wildfires are more weather-dependent than fuel-dependent….” Agee concluded the following: “Attempts to apply either the ‘fuel hypothesis’ or ‘weather hypothesis’ to all western landscapes are as misguided as our now-abandoned attempts this century to develop a grand, unified model of plant succession…Let us not repeat the same mistake now with our views on disturbance in ecosystems: there is not a one-size-fits all approach. Although the physical principles of fire apply everywhere, different forest types with unique organisms and fuels types, and differing environments, will assure that fire behavior will have a range of important contribution factors: not always fuel, and not always weather….”

EA section 3.3.3.1 states the following: “Once an

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ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

Fuels reduction Opposing View #2 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.”

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.”

Fuels reduction Opposing View #3 - “One reason that fuels reduction treatments should be limited is that they may not address the important effects of climate and weather on fire behavior. Some studies suggest that it is drought and warmer temperatures—not fuels accumulations—that are the major explanatory factors for large fires (O’Toole 2002-2003, Pierce et al. 2004). It is an unrealistic goal to return all forests to historical states, in light of the fact that agencies have no control over drought or temperature.” (pgs. 15 – 16) Berry, Alison Ph.D., 2007. “Forest Policy Up in Smoke: Fire Suppression in the United States.” A PERC publication. http://www.law.northwestern.edu/searlecenter/papers/Berry_forest_policy.p

Berry (2007) was not located at the Web site provided. However, the article was found at http://www.isnie.org/assets/files/papers2007/berry.pdf. In the paragraph following the one from which view #3 is extracted, Berry states the following: “Fuels reduction treatments are only necessary in some areas, such as ponderosa pine and longleaf pine forests that are adapted to frequent, low-intensity fires. This fire regime makes up about half of federal forests [of which] about three-quarters are in need of fuels

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df reduction treatments—a total of 83 million acres (FMI 2001). At a rate of 2.5 million acres per year, this area could be treated for hazardous fuels reduction in about 33 years. Also, these forests are likely the easiest to treat for fuels reduction, and therefore least costly.” One of the purposes and needs of the Project is to reduce fuel buildup and ladder fuel continuity within the low-elevation ponderosa pine forests in order to reduce the risk of uncharacteristic surface and crown fire, consistent with Berry’s recommendations (EA section 1.5, purpose and need 2).

See also the response to view #1.

Fuels reduction Opposing View #4 - “Fire intensity was correlated to annual area burned; large area burned years had higher fire intensity predictions than smaller area burned years. The reason for this difference was attributed directly to the weather variable frequency distribution, which was shifted towards more extreme values in years in which large areas burned. During extreme weather conditions, the relative importance of fuels diminishes since all stands achieve the threshold required to permit crown fire development. This is important since most of the area burned in subalpine forests has historically occurred during very extreme weather (i.e., drought coupled to high winds). The fire behavior relationships predicted in the models support the concept that forest fire behavior is determined primarily by weather variation among years rather than fuel variation associated with stand age.”

Bessie, W. C. Ph.D. and E. A. Johnson Ph.D. “The Relative Importance of Fuels and Weather on Fire Behavior in Subalpine Forests” Ecology, Vol. 76, No. 3 (Apr., 1995) pp. 747-762. Published by: Ecological Society of America

Agee (1997), cited in view #1, states the following: “Bessie and Johnson [1995] do an excellent job in establishing weather as a primary factor affecting wildfire size in subalpine forests near the boreal forest ecotone in Alberta, and the title of their paper clearly states that it focuses on subalpine fir forests. As none of the tree dominants are fire-resistant (all are thin-barked), these fires are also high-severity fires. However, the implied generality of some statements in the paper have encouraged others, including those quoted in the popular press, to conclude that the results of this study are applicable everywhere. Evidence from studies in other areas suggests that these statements should not be generalized to all forest types.” “The ‘weather hypothesis’ can be accepted for subalpine forests, where fires are infrequent, often intense, and of high severity.”

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http://www.jstor.org/pss/1939341 “While the first two forest types might suggest that the ‘weather hypothesis’ is indeed robust, the third forest type provides ample evidence that fire severity, even in large fires, can be fuel dependent. Mixed-conifer forests of several types that have ponderosa pine as a dominant had a historical fire regime of frequent fires, typically of low-intensity and low-severity (Agee 1993).” As stated in the EA (p. 3-451), “Mitchell et al. [2009] concluded that ‘effected stand severity’ from wildfire may be decreased by increasing the removal of understory (e.g. ladder fuels)…They stated, however, that this finding is most likely correlated with forests that historically had frequent fire where overall biomass levels may be uncharacteristically high now compared to historical levels. In forests with historically long fire return intervals…treatments likely do not provide the same benefit since these types of forests are less likely to be ‘departed’ and fire severity is more often a function of weather [drought] than fuel.” Regarding the subalpine fir (mixed2 fire regime) within the Project area, the EA states (p. 3-82) the following: “In the mixed2 fire regime, the risk of a sustained crown fire decreases; however, it is expected to stay within desired conditions; that is lethal fire would still be expected to occur consistent with that experienced historically.”

Fuels reduction Opposing View #5 - “Climatic conditions drive all big fires— not fuels. All substantial fires occur only if there is extended

The paper referred to in view #5 is not available at the location provided.

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drought, low humidity, high temperatures and, most importantly, high winds. When conditions are "ripe" for a large blaze, fires will burn through all kinds of fuel loads. For this reason, most fires go out without burning more than a few acres; approximately 1 percent of all fires are responsible for about 95 percent to 99 percent of the acreage burned.” “Under severe conditions, fires burn through all kinds of fuel loads including thinned/logged forests. Contrary to what the U.S. Forest Service has stated about the Ojo Peak Fire, local witnesses have said the fire blew right through the hotter, drier thinned forests where the cooling effect of forest canopy had been removed.” Bird, Bryan “Fires Normal Part of Ecology - Fear of fires ungrounded” Mountain View Telegraph, December 20, 2007 http://www.wildearthguardians.org/library/paper.asp?nMode=1&nLibraryID=567

See the responses to views #1 and #3.

Fuels reduction Opposing View #6 - “The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.”

“Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.”

Fuels reduction Opposing View #7 - “As someone with first-hand experience in fire hazard reduction and first-hand knowledge of the forest management field, as well as someone with lifelong roots in the Durango

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3)

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http://www.wildearthguardians.org/library/paper.asp?nMode=1&nLibraryID=567

http://forests.org/archived_site/today/recent/2002/tiporefl.htm



community, I am abhorred by the destruction, nearly amounting to clear cutting, that is taking place around our community under the guise of “fire hazard reduction.” “ Coe, Nathan J. “Forestry shouldn’t be an ‘industry’ “ Durango Herald, February 12, 2011 http://www.durangoherald.com/article/20110213/OPINION03/702139987/Forestry-shouldn%E2%80%99t-be-an-%E2%80%98industry%E2%80%99

that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.”

The silvicultural treatments proposed in each action alternative are discussed in detail in EA section 3.2.2. As disclosed in this section, clearcutting is not one of the treatments proposed.

Fuels reduction Opposing View #8 - “First, most large fires are climatic/weather driven events, not fuels driven. Extended drought, high winds, high temperatures and low humidity enable fires to burn through all fuel loadings. Many of the large Western fires in recent years were in forests that had been previously logged and/or thinned, with little apparent effect on fire spread or severity.” Forest Policy Research paper 2008 “Montana: Blackfoot Clearwater Stewardship Proposal is all about selling out to Pyramid lumber” http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwater-stewardship-proposal-is-all-selling-out-to-pyramid-lumber/

The paper referred to in view #8 is not available at the location provided. The referenced article was originally published as a guest opinion in the Missoulian newspaper. See the responses to views #1 and #3.

Fuels reduction Opposing View #9 - “most large fires are climatic/weather driven events, not fuels driven. Extended drought, high winds, high temperatures and low humidity enable fires to burn through all fuel loadings.”

Forest Policy Research paper 2008 “California: Too often thinning treatments tend to increase fire

The paper referred to in view #9 is not available at the location provided.

The referenced article was originally published by the Sierra Forest Legacy.

See the responses to views #1 and #3.

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http://www.durangoherald.com/article/20110213/OPINION03/702139987/Forestry-shouldn%E2%80%99t-be-an-%E2%80%98industry%E2%80%99

http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwater-stewardship-proposal-is-all-selling-out-to-pyramid-lumber/

http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwater-stewardship-proposal-is-all-selling-out-to-pyramid-lumber/

http://forestpolicyresearch.org/2008/12/19/california-too-often-thinning-treatments-tend-to-increase-fire-hazards/


Comment Forest Service Response hazards” http://forestpolicyresearch.org/2008/12/19/california-too-often-thinning-treatments-tend-to-increase-fire-hazards/

Fuels reduction Opposing View #10 - “The primary driver of fire is not beetle kill. It’s climate,” said Barry Noon, a wildlife ecology professor at Colorado State University and an author of the report. “It’s drought and temperature.” “The report was authored by Noon; Clark University professor Dominik Kulakowski ; Scott Black, executive director of the Xerces Center for Invertebrate Conservation and Dominick DellaSala, president and chief scientist for the National Center for Conservation Science and Policy.”

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/

The findings presented in view #10 are not disputed in the Project EA. See the response to view #4.

Fuels reduction Opposing View #11 - “ “Extensive areas of dead trees have understandably led to widespread concern about the increased risk for forest fires,” said Dominik Kulakowski, one of the report’s authors and a professor of geography and biology at Clark University in Worcester, Mass. “This is a logical concern, but the best available science indicates that the occurrence of large fires in lodgepole pine and spruce-fir forests is mainly influenced by climatic conditions, particularly drought.” “

Gable, Eryn “Battling beetles may not reduce fire risks – report” The Xerces Society Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/

The findings presented in view #11 are not disputed in the Project EA. See the response to view #4.

Fuels reduction Opposing View #12 - “Reducing burnable biomass, however, does not eliminate wildfires, because fuel reduction does not

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the

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http://www.coloradostate.edu/

http://www.clarku.edu/

http://www.xerces.org/

http://www.xerces.org/

http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/


http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/




directly alter the dryness of the biomass or the probability of an ignition.”

Gorte, Ross W. Ph.D. “Wildfire Damages to Homes and Resources: Understanding Causes and Reducing Losses” A CRS report for Congress, June 2, 2008 http://www.nationalaglawcenter.org/assets/crs/RL34517.pdf

conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). EA section 3.3.3.1 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

Fuels reduction Opposing View #13 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."

"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."

Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65

The project has a restoration emphasis and is therefore focused on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3. Treatments as proposed in the WUI and non-WUI stands would include (section 3.2.2.1.1), “A VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy

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http://www.gao.gov/archive/1999/rc99065.pdf would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.”

Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire and mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.

Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2.

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Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3: “the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.” As described in EA section 3.3.4, current vegetation conditions are outside the range of desired conditions relating to the fire regimes. EA section 3.3.4 states the following: “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” The current wildfire hazard within the stands is moderate to high. Under the No Action alternative (EA section 3.3.5.1), the wildfire hazard remains moderate to high. Under the action alternatives (EA sections 3.3.5.2 and 3.3.5.3), treatments would reduce

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the wildfire risk, making it low to moderate.

Fuels reduction Opposing View #14 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “ “As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high-value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).” “The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.” “After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire-resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.”

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://www.commondreams.org/views/051900-101.htm


EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the Wildland Urban Interface (WUI), as stated in section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.”

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Fuels reduction Opposing View #15 - “Emerging science demonstrates that the real culprit for creating more wildfires — including southern California's blazes — is not "fuels" but climate and weather. Climate change simply means we must learn to live with more wildfires. Humankind can be pretty smart (we made it to the Moon), but we can also be pretty stupid (we're destroying the lungs of the planet for profit). One thing, however, is certain: Mother Nature knows best. So let's be responsible and stop logging the publicly owned forests, let them recover and let God and nature back in.” Hermach, Tim. “The Skinny on Thinning, Should we save the forest from itself?” Published by the Eugene Weekly Viewpoint, 11/1/07 http://www.forestcouncil.org/tims_picks/view.php?id=1211

The paper referred to in view #15 is not available at the location provided. See the response to view #1.

Fuels reduction Opposing View #16 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9) “As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material

Effects of fuels created by mechanical treatments are disclosed in EA section 3.3.5.2.

The effects described in the EA are consistent with those described in the science discussed in view #16.

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decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.”

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E70?sequence=1

Fuels reduction Opposing View #17 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.”

“How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Opposing View Correction: The quotation provided in view #17 contains errors in the second paragraph; in the original, cited text, the paragraph reads as follows: “How can the sources of these problems also be their solution? This internal contradiction needs more than Smokey Bear myths to be resolved. It is time for Congress to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1).

The project has a restoration emphasis and is therefore

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focused on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3. Treatments as proposed in the WUI and non-WUI stands would include “a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.” “Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural

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conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire and mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.” Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2.

Fuels reduction Opposing View #18 - "Problems exist with over-generalizing the effects of fire exclusion, and misapplying data derived from short-interval forest ecosystems (e.g. ponderosa pine stands) to long-interval forest ecosystems that have not missed their fire cycles yet and are still within their historic range of variability for stand-replacing fire events (e.g. high elevation lodgepole pine or fir stands)." Ingalsbee, Timothy Ph.D. 2000. “Money to Burn: The Economics of Fire and Fuels Management, Part One: Fire Suppression. “An American Lands Alliance publication. www.fire-ecology.org/research/money_to_burn.html

The quotation provided in view #18 is not located in the cited paper.

Regarding the subalpine fir (mixed2 fire regime) within the Project area, the EA (page 3-82) states the following: “In the mixed2 fire regime, the risk of a sustained crown fire decreases; however, it is expected to stay within desired conditions; that is lethal fire would still be expected to occur consistent with that experienced historically in the mixed2 fire regimes….” See also the responses to views #3 and #4.

Fuels reduction Opposing View #19 - “Congress should prohibit the use of commercial timber sales and stewardship contracts for hazardous fuels reduction projects. Commercial logging removes the most ecologically valuable, most fire-resistant trees, while leaving behind highly flammable

Refer to the responses to views #13 and #17.

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small trees, brush, and logging debris. The use of "goods for services" stewardship contracts also encourages logging larger, more fire-resistant trees in order to make such projects attractive to timber purchasers. The results of such logging are to increase fire risks and fuel hazards, not to reduce them. The financial incentives for abusive logging under the guise of "thinning" must be eliminated.”

Ingalsbee, Timothy Ph.D., “National Fire Plan Implementation: Forest Service Failing to Protect Forests and Communities” American Lands Alliance, March 2002 http://www.fire-ecology.org/policy/ALA_fire_policy_2002.html

Fuels reduction Opposing View #20 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://fireecology.org/research/wildfire_paradox.pdf

Smaller understory trees (ladder fuels) are the primary contributor to the current condition of moderate to high wildfire hazard (EA, page 3-63). This ladder fuel condition poses a high risk of losing larger trees to crown fire. The proposed treatments are variable density thinning and thin-from-below, with design features to retain the largest trees (EA, page 2-31, Table 2-5). “The reduction in wildfire hazard would be accomplished by reducing ladder fuels and treating activity fuels, thereby limiting the fire’s ability to transition from a surface fire to a crown fire” (EA, section 3.3.5.2.1). The treatment prescription would “promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire resistant species, such as ponderosa pine, and discriminate against tree species less resistant to wildfire…The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to

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increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine” (EA, section 3.3.5.2.1). Fuel treatment activities, alone or in combination, would be implemented to reduce the fire risk associated with the fuels created by the commercial treatment of trees ≥8 inches dbh and noncommercial treatment of trees <8 inches dbh These activities could include lop and scatter, jackpot or hand piling, whole tree yarding and burning at landings, and broadcast burning (EA, page 3-75 to 3-81). A temporary increase would occur in surface fuel loads and potential flame lengths associated primarily with the fuels created by the noncommercial treatments; however, this hazard would abate over time as a result of the proposed treatments and natural decay. After 3 years, the surface fuels created by the mechanical treatments would not be expected to have increased the wildfire hazard over the current condition (EA, page 3-77 to 3-78).

Fuels reduction Opposing View #21 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards."

"Decades of encouraging private logging companies to take the biggest, oldest, most fire-resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly


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increased the flammability of forestlands."

"In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks."

Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html

Fuels reduction Opposing View #22 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire-resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.”

“Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.”

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.”


No regeneration harvest treatments, and consequently no plantations, are proposed. The 50 acres of proposed interplanting (EA page 1-13, Table 1-3) would be to ensure that gaps contain some regeneration. However, trees planted in gaps would be arranged to mimic natural establishment rather than planted using a spacing scheme.

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Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm

Fuels reduction Opposing View #23 - “For example, use of taxpayer dollars and resources on deficit timber sales that remove fire-resilient old-growth trees and leave behind untreated logging slash, violate federal environmental laws in planning or implementation, or are deceptively labeled as “fuels reduction” or “forest restoration” projects when they actually increase fuel hazards or degrade ecological integrity, is an ethical as well as an ecological issue. These kind of anti-ecological, unethical forest management projects also adversely affect firefighter and community safety by diverting limited federal dollars away from genuine hazardous fuels reduction activities, and by degrading ecological conditions in ways that increase wildfire rate of spread, intensity, or severity.”

Ingalsbee, Timothy Ph.D. and Joseph Fox, Ph.D. “Firefighters United for Safety, Ethics, and Ecology (FUSEE): Torchbearers for a New Fire Management Paradigm” A poster presentation at the Third International Fire Ecology and Management Congress, Association for Fire Ecology November 13-17, 2006 http://fusee.org/docs/AFE_FUSEE_display_abstract.pdf


Fuels reduction Opposing View #24 - “History, not science, refutes the claim that logging helps to prevent forest fires.

The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests.

Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot.

The quoted material in view #24 is not contained in the cited opinion article.

EA section 1.4.1 describes the land management history of the project area, including past timber harvest. The EA acknowledges that past timber harvest as well as wildfire and fire suppression have contributed to the current vegetative conditions (EA page 1-7).

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More logging will not fix this.”

Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.highbeam.com/doc/1G1-192070397.html


Fuels reduction Opposing View #25 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds. Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?” Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html


Fuels reduction Opposing View #26 - “There is a gathering body of evidence that large wildfires are not determined by “unnatural” fuel loading. Lodgepole pine, subalpine fir, and aspen depend on infrequent, stand-replacing, high intensity fires. Most of the B-D NF is well within the natural range of variability. In fact, dense forest stands may not be caused by fire exclusion, but by a series of consecutive wet years that boosted seedling survival and expanded the local range.

The paper referred to in view #26 is not available at the location provided. See the responses to views #1 and #4.

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Drought, wind, and low humidity, not fuels loads, drive large wildifires. Weather and climatic conditions are also the driving force behind expanding insect populations.” Kelly, Steve Ph.D. 2007. “Cheap Chips, Counterfeit Wilderness: Greenwashing Logging on Montana's Biggest National Forest.” Published by the World Prout Assembly http://www.worldproutassembly.org/archives/2007/12/cheap_chips_cou.html

Fuels reduction Opposing View #27 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.” Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. http://www.fs.fed.us/emc/hfi/president.pdf


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Fuels reduction Opposing View #28 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.”

“How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.”

Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp

EA section 3.3.4 discusses the existing conditions as they relate to crowning index (CI) and surface flame lengths (SFLs): “In WUI currently, the SFLs are between 4 and 6 feet and the CI indicates a moderate risk and in Non-WUI, the CI indicates that the wildfire hazard is a moderate-to-high risk.”

EA sections 3.3.5.2 and 3.3.5.3 discuss effects of proposed treatments under the action alternatives on crowning index and surface flame lengths: “Surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3: “The fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot

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burning.”

Fuels reduction Opposing View #29 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground. Leitner, Brian. “Logging Companies are Responsible for the California Wildfires .” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html

The project has a restoration emphasis and is therefore focused on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3.

Treatments as proposed in the WUI and non-WUI stands would include “a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and

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aspen in order to accomplish restoration objectives.”

“Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire and mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.”

Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2. EA sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments on crowning index and surface flame lengths: “Surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases.

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Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.”

Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3: “the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.”

Fuels reduction Opposing View #30 - “Almost seven times more forested federal land burned during the 1987-2003 period than during the prior 17 years. In addition, large fires occurred about four times more often during the latter period.” “The increases in fire extent and frequency are strongly linked to higher March-through-August temperatures and are most pronounced for mid-elevation forests in the northern Rocky Mountains. The new finding points to climate change, not fire suppression policies and forest fuel accumulation, as the primary driver of recent increases in large forest fires.”

“More Large Forest Fires Linked To Climate Change” Adapted from materials provided by the University of Arizona ScienceDaily, July 10, 2006 http://www.sciencedaily.com/releases/2006/07/060710084004.htm

The findings presented in view #30 are not disputed in the Project EA. In addition, the paper from which the quotation was extracted states the following: “Climate model projections suggest warmer springs and summers are more likely to occur in the West, amplifying the region's vulnerability to wildfires, the researchers note in their article. The researchers suggest that more severe fires could change forest composition so drastically that the western forests, which currently store atmospheric carbon dioxide, could become a source of atmospheric CO2. Additional carbon dioxide could further warm the climate and exacerbate the fire problem.

Swetnam was initially skeptical that climate was driving recent large-scale changes in fire frequency. Doing this research changed his mind. ‘I had thought it was primarily fuel load. These results

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suggest that for most western U.S. forests, climate is a primary driver and fuel is secondary.’ He added, ‘In the Southwest we know we have a fuel problem. You lay on top of that warming temperatures and now we have the worst of both situations— changed forests and changed climate.”

EA section 3.17 discloses the effects of climate change on vegetative conditions within the project area and the strategy for addressing this disturbance in combination with changes in other disturbance agents. The strategy described for the project area is to develop adaptive capacity and resilience as recommended by Millar et al. (2007) and Forest Service Manual 2020. Adaptive capacity is defined as the ability to adjust to environmental change. FS Manual 2020 defines resilience as the ability of a system to absorb disturbance while retaining basic structure and function and the capacity to adapt to stress and change (EA page 3-450).

In addition, as stated in the EA on page 3-34, “In the mid- to upper-elevation forests, past harvest practices, wildfire suppression, and small wildfires have created small patches across the landscape. In addition, insects and competitive mortality have produced a variety of fine-scale structural conditions within patches. Overall, the patches within the mid- to upper-elevation forests fall within desired conditions, although the patches are closer to the smaller end of the size range, in part due to the complex terrain within the Clear Creek watershed. Patches are predominately large tree size class with Douglas-fir, a codominant in the overstory,

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but a greater amount of climax subalpine fir in the understory. Without disturbance, these patches will eventually become dominated by subalpine fir, the climax species, in the overstory as succession advances. The aim of the proposed treatments would be to maintain vegetative stages that support old forest habitat, including perpetuating early seral Douglas-fir, which would maintain a condition that is somewhat unique compared to other mid- to upper-elevation areas across the District. Unlike mid- to upper-elevation forests within other watersheds on the District, the Clear Creek 5th HU has experienced few large-scale wildfires in recent years (EA Figure 3-2). Although a small portion of the 1989 Lowman Fire (about 6,000 acres of the 44,150 acres) -burned into the low- to mid-elevation forests in the project area, the mid- to upper-elevation forests have been relatively unaffected by recent fire (only 42 acres of the 32,000 acre Red Mountain fire burned into the Clear Creek 5th HU). On the District and to the immediate east, about 96,000 acres have burned within the past 10 years (since 2003). The 2007 Sheep Trail Fire burned 6,220 acres just north of the Project area adjacent to the Red Mountain Fire (EA Figure 3-2). Immediately to the west, the 44,200-acre Rattlesnake Fire burned onto the District. These fires produced a variety of effects similar to the historical fire regime within the mid- to upper-elevation forests; however, the number and extent within a short time period have developed extensive patches of early seral condition across the larger landscape. In part, the proposed treatments would maintain the existing fine-scale structural

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diversity within the existing patches in the Clear Creek watershed as well as increase the chances of maintaining early seral Douglas-fir.”

Fuels reduction Opposing View #31 - “We inferred climate drivers of 20th-century years with regionally synchronous forest fires in the U.S. northern Rockies. We derived annual fire extent from an existing fire atlas that includes 5038 fire polygons recorded from 12070086 ha, or 71% of the forested land in Idaho and Montana west of the Continental Divide. The 11 regional- fire years, those exceeding the 90th percentile in annual fire extent from 1900 to 2003 (>102314 ha or ~1% of the fire atlas recording area), were concentrated early and late in the century (six from 1900 to 1934 and five from 1988 to 2003). During both periods, regional- fire years were ones when warm springs were followed by warm, dry summers and also when the Pacific Decadal Oscillation (PDO) was positive. Spring snowpack was likely reduced during warm springs and when PDO was positive, resulting in longer fire seasons. Regional- fire years did not vary with El Nino-Southern Oscillation (ENSO) or with climate in antecedent years. The long mid-20th century period lacking regional- fire years (1935-1987) had generally cool springs, generally negative PDO, and a lack of extremely dry summers; also, this was a period of active fire suppression. The climate drivers of regionally synchronous fire that we inferred are congruent with those of previous centuries in this region, suggesting a strong influence of spring and summer climate on fire activity throughout the 20th century despite major land-use change and fire suppression efforts. The relatively cool, moist climate during the mid-century gap in regional- fire years likely contributed to the success of fire suppression during that period. In every regional- fire year, fires burned across a range of vegetation types. Given our results and the projections for warmer springs and continued warm, dry summers, forests of the U.S. northern Rockies are likely to experience synchronous, large fires in the future.”

Morgan, Penelope Ph.D., Emily K. Heyerdahl Ph.D., and Carly E. Gibson


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2008 "Multi-season climate synchronized forest fires throughout the 20th century, Northern Rockies", Ecology, 89, 3: 717-728. http://www.firelab.org/index.php?option=com_jombib&task=showbib&id=343

Fuels reduction Opposing View #32 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk." “Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.” Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://www.motherjones.com/news/feature/2002/08/fireplan.html


Fuels reduction Opposing View #33 - “Fuel reduction treatments should be forgone if forest ecosystems are to provide maximal amelioration of atmospheric carbon dioxide over the next 100 years,' the study authors wrote in their conclusion. 'If fuel reduction treatments are effective in reducing fire severities in the western hemlock, Douglas-fir forests of the west Cascades and the western hemlock, Sitka spruce forests of the Coast Range, it will come at the cost of long-term carbon storage, even if harvested materials are used as biofuels.’ ” Oregon State University Research Science Centric, July 9, 2009

The paper cited in view #33 also states the following: “The study authors concluded that fuel reduction may still make more sense in east-side Cascade Range and other similar forests, but that the west-side Cascades and Coast Range have little sensitivity to forest fuel reduction treatments - and might be best utilized for their high carbon sequestration capacities.”

The conclusions of the cited study are similar to those of Mitchell et al. (2009) and Turner et al. (1995). Mitchell et al. concluded that “‘effected stand severity’

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http://www.sciencecentric.com/news/article.php?q=09070918-forest-fire-prevention-efforts-will-lessen-carbon-sequestration-add-greenhouse-warming

from wildfire may be decreased by increasing the removal of understory (e.g. ladder fuels) that can consequently lower overall biomass combustion, thereby allowing for an increase overall in carbon storage. They stated, however, that this finding is most likely correlated with forests that historically had relatively frequent fire where overall biomass levels may be uncharacteristically high now compared to historical levels. In forests with historically long fire return intervals…treatments likely do not provide the same benefit since these types of forests are less likely to be ‘departed’ and fire severity is more often a function of weather [drought] than fuel” (EA pages 3-451 to 3-452).

Turner et al. (1995) stated that findings for Pacific Northwest forests are not applicable to Rocky Mountain forests, because of differences in growth rates and disturbance regimes (EA page 3-455).

Fuels reduction Opposing View #34 - “While top officials blame recent fires on fuels, all the on-the-ground reports I've read focus on the weather.”

O'Toole Randal. “Incentives, Not Fuels, Are the Problem” Published by the Thoreau Institute http://www.ti.org/fireshort.html

The cited paper is an opinion piece that does not reference any scientific literature.


Fuels reduction Opposing View #35 - “This paper will show that built-up fuels are not the main reason, or even a major reason, for recent severe fires or high fire suppression costs. The weather is the prime reason for widespread fires this year as well as in 2000, 1999, and other recent years. But the major reason for increased costs is institutional: The federal land agencies, and especially the Forest Service, have a blank check to put out fires and thus have no reason to control their costs. If fuels are not the


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problem, then it isn’t necessary to spend $400 million a year treating them.”

O’Toole, Randal. 2002. “Reforming the Fire Service: An Analysis of Federal Fire Budgets and Incentives.” The Thoreau Institute. www.ti.org/firesvc.pdf

Fuels reduction Opposing View #36 - “Post-fire reports on individual fires make little or no mention of excess fuels. Instead, fire scientists agree that drought is the cause of the severe fires in recent years. This year’s Rodeo- Chedisky Fire, the largest fire in Arizona history, was on heavily managed and thinned federal lands, not an untouched wilderness brimming with excess fuels.”

O’Toole, Randal. “Money to Burn?” Regulation, Winter 2002 – 2003 http://www.cato.org/pubs/regulation/regv25n4/v25n4-6.pdf

The findings presented in view #36 are not disputed in the Project EA.

Fuels reduction Opposing View #37 - “The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.” Partridge, Arthur Dean Ph.D. Testimony to the Agriculture, Nutrition and Forestry Committee United State Senate. Hearing to Review Healthy Forests Restoration Act, HR 1904 June 26, 2003 http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml

The paper referred to in view #37 is not available at the location provided and could not be located elsewhere. See the response to view #12.

Fuels reduction Opposing View #38 - “A number of studies have shown that for some ecosystems, the major factor determining fire intensity and

The paper referred to in view #38 is not available at the location provided and could not be located elsewhere.

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size is weather and not the amount of fuel (Baker 1989, Flannigan and Harrington 1988, Haines and Sando 1969, Rothermel 1995). For example, Bessie and Johnson (1995) found that fire spread and intensity were strongly related to weather conditions and only weakly related to fuel loads in the southern Canadian Rockies. Similarly, many hundreds of the thousands of acres of forests that were intensely burned in the 1994 Tyee Fire on the Wenatchee National Forest had very low fuel loads. The Forest Service and Fish and Wildlife Service concluded that weather patterns and terrain -- not fuels -- were the major reasons why this large fire burned the way it did (U.S. Forest Service 1995, U.S. Fish & Wildlife Service 1994). Such case studies provide little evidence that salvage logging of dead and dying trees will significantly reduce wildfires.” Peters, R.L., E. Frost, and F. Pace. “Managing for forest ecosystem health: A reassessment of the forest health crisis.” Defenders of Wildlife. April 1996. http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.htm

EA section 3.3.3.1 states the following: “Although the probability of ignition is unpredictable, once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.” Furthermore, as the quotation provided in view #38 states, “Such case studies provide little evidence that salvage logging of dead and dying trees will significantly reduce wildfires.”

The Project is focused on restoration, with emphasis on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3. Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2; as noted in this section, salvage logging is not proposed.

Fuels reduction Opposing View #39 - “H.R 1904 does not include any specific measures to protect homes or communities. It is also inconsistent with the Western Governors' Association 10-Year Comprehensive Strategy, which does not call for any changes in existing laws. The only proven method to protect homes and communities is to reduce flammable materials

View #39 is a comment about H.R. 1904, not the Project.

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in the immediate vicinity of structures, yet the definitions in H.R. 1904 would not require any activities to be near homes. Instead, the bill seeks to further subsidize the timber industry and eliminate obstacles to logging large, fire-resistant trees miles away from the nearest home. The country's top forest scientists, including the Forest Service's own scientists, have found that this kind of logging can actually increase fire risk and make fires larger and more intense.” Peterson, Mike testimony to the Senate Agriculture, Nutrition, and Forestry Committee concerning the Healthy Forests Restoration Act, HR 1904. June 26 2003 http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_id=2258

Fuels reduction Opposing View #40 - “We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.” Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001

Data collected for the Project is site specific. EA section 3.3.34 states the following: “Existing stand conditions were validated through District stand exams (1984–2008) and field reconnaissance in 2010 by District fuels specialists.” Furthermore, EA section 3.2.1.2.2 provides the following information: “Data sources used for analyzing all indicators were stand examination data collected between 1984 and 2008 using nationally consistent Common Stand Examination (CSE) protocols for acquiring vegetation information. CSE protocols provide the procedures for describing vegetation composition, structure, and productivity within an ecological framework (USDA Forest Service 2010a). Stand examination data were collected based on a random plot sample and were averaged to represent stand conditions as a whole. For analysis purposes, stands were tracked as the smallest analysis unit.”

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EA section 3.3.4 discusses the existing conditions: “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory. This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity.

Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area. In Non-WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high

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intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” The project has a restoration emphasis and is therefore focused on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3. Treatments as proposed in the WUI and non-WUI stands would include “a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed,

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intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.

Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire and mechanical treatments. The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.”

Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2. EA sections 3.3.5.2 and 3.3.5.3 “discuss the effects of proposed treatments on crowning index and surface flame lengths: surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the

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risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” Effects of fuels created by mechanical treatments are disclosed in EA in sections 3.3.5.2 and 3.3.5.3: the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.

Fuels reduction Opposing View #41 - “While most of us have suffered with the unavoidable fire-related anxieties, we have also been impressed by the hard work and heroism of both neighbors and anonymous firefighters. But others have tried to profit from the fires and the primordial fears they evoke. The forest products industry has been in the lead in this exploitation of other people's hard times. The forest products industry wants access as cheaply as it can get it to as much wood fiber as possible. It once had privileged access to forested public lands. As the frontier economy has faded and government give-aways have fallen out of political favor, the forest products industry's

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters

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privileged grip on public resources has begun to slip. The current forest fires offer them an opportunity to try to regain some of their lost clout. The fires, timber industry spokespersons claim, are the result of restrictions on commercial logging on public lands. If all of these lands had been logged, they assert, the fires would not be burning. It is the federal government and the environmentalists they are in cahoots with who have caused the fires that now threaten us. As one timber industry advocate baldly said, "I never saw a clearcut burn." Nothing could be further from the truth. Of course clearcuts burn. When long, hot summers dry out the grasses, brush, and logging wastes, they can flare explosively. When they grow thick with closely packed young trees, they present exactly the fire danger we are wrestling with now. The logging roads provide human access that is the source of the vast majority of forest fires.

If roading and logging eliminated the threat of wildfire, most of the fires that threaten us now would not be burning. Look at where these fires are: They are largely burning on the forest-urban interface in areas adjacent to intense human activity. In Western Montana, for instance, the fires are in are burning in the forests adjacent to some of the rapidly growing residential areas in the nation, the Bitterroot, Helena, and Clark Fork Valleys. These are not roadless areas that have never been logged. Quite the contrary, they are areas that were roaded and logged in the past. Those roads often have then provided access for the human activity that now dominates these areas, including the home building, residential settlement of the last two decades, and recreational activity. The trees now burning are usually second growth that followed past logging.” Power, Thomas Ph.D. ”Thee Politics of Forest Fires -- The Abuse of Other People's Hard Times.” 8/15/2000 Thomas Michael Power is the Professor and Chairman of the Economics

involved with suppression activities.”

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Comment Forest Service Response Department, University of Montana

http://www.forwolves.org/ralph/tompower.htm

Fuels reduction Opposing View #42 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).” Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society

Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf

The EA acknowledges that timber harvest and road building have effects on most resources, including those listed in view #42. These effects are discussed in numerous sections in the EA:

• 3.2 (Vegetation) • 3.3 (Fire and Fuels) • 3.4 (Wildlife) • 3.5 (Air Quality) • 3.6 (Hydrology) • 3.7 (Fisheries) • 3.8 (Soils) • 3.9 (Botanical Resources) • 3.10 (Noxious Weeds) • 3.11 (Transportation Systems) • 3.12 (Recreation Resources) • 3.13 (Cultural Resources) • 3.14 (Economic Assessment) • 3.15 (Scenic Environment) • 3.17 (Climate Change)

Fuels reduction Opposing View #43 - “No evidence suggests that spruce–fir or lodgepole pine forests have experienced substantial shifts in stand structure over recent decades as a result of fire suppression. Overall, variation in climate rather than in fuels appears to exert the largest influence on the size, timing, and severity of fires in subalpine forests (Romme and

The paper referred to in view #43 is not available at the location provided. However, the paper was located at another source. The findings presented in view #43 are not disputed in the Project EA. In addition, the paper from which the

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Despain 1989, Bessie and Johnson 1995, Nash and Johnson 1996, Rollins et al. 2002). We conclude that large, infrequent standreplacing fires are “business as usual” in this forest type, not an artifact of fire suppression.” (Pg. 666)

“Variation in daily area burned was highly correlated with the moisture content of 100-hour (2.5- to 7.6- cm diameter) and 1000-hour dead fuels (Turner et al. 1994). Once fuels reached critical moisture levels later in the season, the spatial pattern of the large, severe standreplacing fires was controlled by weather (wind direction and velocity), not by fuels, stand age, or firefighting activities (Minshall et al. 1989,Wakimoto 1989, Turner et al. 1994).” (Pg. 666)

Schoennagel, Tania Ph.D., Thomas T. Veblen Ph.D., and William H. Rommie Ph.D. “The Interaction of Fire, Fuels, and Climate across Rocky Mountain Forests” Bioscience, July 2004 / Vol. 54 No. 7


quotation was extracted states the following:

“Therefore, we expect fuel-reduction treatments in high-elevation forests to be generally unsuccessful in reducing fire frequency, severity, and size, given the overriding importance of extreme climate in controlling fire regimes in this zone. Thinning also will not restore subalpine forests, because they were dense historically and have not changed significantly in response to fire suppression. Thus, fuel-reduction efforts in most Rocky Mountain subalpine forests probably would not effectively mitigate the fire hazard, and these efforts may create new ecological problems by moving the forest structure outside the historic range of variability (Veblen 2003, Romme et al. 2004).”

“In contrast, for many low-elevation, dry ponderosa pine forests, it is both ecologically appropriate and operationally possible to restore a low-severity fire regime through thinning and prescribed burning (Covington et al. 1997, Allen et al. 1998, 2002). Fuels rather than climate appear to be the most significant factor affecting fire spread and severity in these forests. Fire suppression in dry ponderosa pine forests appears to have contributed to an unprecedented buildup of fuels and to the occurrence of high-severity fires. Indeed, the objectives of fire mitigation and forest restoration generally converge in forests of this type.” The treatments proposed in the low-elevation ponderosa pine forests in the Project area (EA section 3.4.2.2) are consistent with the conclusions from Schoennagel et al. (2004) and are based on purpose #2 (EA, section 1.5). Treatments in the mid-to-

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upper elevation forests are for a purpose other than fuel reduction as these areas are currently close to or within desired conditions (EA purpose and need 3).

Fuels reduction Opposing View #44 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.”

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm

The cited paper is an opinion piece that does not reference any scientific literature.

See response to view #20. View #44 contradicts views #30, #31, #35, and #43, which state that climate, not other factors, cause “forest fires to rage for hundreds of miles.”

Fuels reduction Opposing View #45 - “Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20)

“Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20) Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000

The paper referred to in view #45 is not available at the location provided. EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.”

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Fuels reduction Opposing View #46 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.” Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php

EA sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments on crowning index and surface flame lengths: “surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.”

Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3: the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.

The project has a restoration emphasis and is therefore focused on retaining species composition, large tree habitat, and old forest habitat (see Design Features VE-2, VE-3, and VE-4, EA section 2.4.4.7). The silvicultural prescriptions are designed for restoration, as described in EA sections 3.3.5.2 and 3.3.5.3.

Treatments as proposed in the WUI and non-WUI

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stands would include “a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80 square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives.

Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire and mechanical treatments. The

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thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen.” Descriptions of silvicultural prescriptions can also be found in EA section 3.2.2.

In addition to the quoted text provided in view #46, the cited article includes the following statement: “The focus of a good fuels management plan must be on reducing those fuels that ignite and spread wildfire, while keeping the large, older trees that are resistant to fire. Those big trees provide shade, keep the forest floor moist and the wind speed down. Because fire behavior is contingent upon local conditions, a ‘one-size-fits-all’ prescription is not the answer".” The Project proposes to do what this article refers to as good fuels management.

Fuels reduction Opposing View #47 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62) University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf



Fuels reduction Opposing View #48 - “Why is the natural fire regime in most Rocky Mountain ponderosa pine–Douglas fir forests variable in

The quotation is actually from an attachment to the cited document (USDA Forest Service 2006 EA, Baker

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severity? Extended droughts and high winds can lead to exceptional fire spread across a broad spectrum of fuel loads and forest structures. For example, almost 25,000 ha of ponderosa pine– Douglas fir forest burned on a single day (9 June 2002), driven by strong winds (Finney et al., 2003). Yet, brief episodes when the winds declined and fuel moisture rose, led to low-severity fire in the same landscape (Finney et al., 2003), suggesting that extreme weather, not fuels, was the chief cause of high-severity fire under those conditions. Even during summer, ponderosa pine–Douglas fir landscapes in the Rocky Mountains are subject to rapid increases in wind speed and changes in direction from jet streams or cold fronts (Baker, 2003).” (pg. 5)

USDA Forest Service BALD ANGEL VEGETATION MANAGEMENT PROJECT ENVIRONMENTAL ASSESSMENT. La Grande Ranger District, Wallowa-Whitman National Forest, December 2006 https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/6608/Wallowa_Whitman_Bald_Angel_Vegetation_Management_EA.pdf?sequence=1

et al. 2006); the correct citation for the quoted text is from “Fire, fuels and restoration of ponderosa pine–Douglas fir forests in the Rocky Mountains, USA; Journal of Biogeography; pages 1–19.

The Project EA does not dispute that extreme weather (extended drought and high winds) rather than fuels can lead to exceptional fire spread and be the chief cause of high-severity fire when these conditions occur. EA section 3.3.3.2 discusses the assignment of nonlethal and mixed1 fire regimes to the PVGs in the project area that include ponderosa pine. Within the context of the 2010 Forest Plan, Appendix A, the fire regime assignments are a desired condition that projects such as Clear Creek would implement. As described in the FEIS for the 2010 Forest Plan amendment, while part of the historic fire regime, maintaining ponderosa pine ecosystems in a stand-replacing condition, would not achieve the goals of conserving and restoring these imperiled ecosystems and the wildlife species associated with them in the near term. Refer also to the discussion about white-headed woodpecker in section 1 of the EA.

Fuels reduction Opposing View #49 - “Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires.

In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “

The cited paper is an opinion piece that does not reference any scientific literature. See the response to view #20.

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https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/6608/Wallowa_Whitman_Bald_Angel_Vegetation_Management_EA.pdf?sequence=1



Voss, René, “Getting Burned by Logging,” July 2002, The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml

Fuels reduction Opposing View #50 - “The federal assistance could include funding to help state and local governments mitigate the beetle infestations, the presence of which increases the risk of forest wildfires that endanger surrounding communities and infrastructure, said supporters of the bill.” “Kulakowski, a former research scientist at the University of Colorado at Boulder and current professor at Clark University in Massachusetts, discounted this notion during his testimony. He said climate, not insects, plays the most important role in forest fires, as wildfires are more likely to occur during droughts.” Walsh, Jeremy “Scientist: Money to fight beetles as fire mitigation not productive” Durango Herald, April 23, 2010 http://durangoherald.com/sections/News/2010/04/23/Scientist_Money_to_fight_beetles_as_fire_mitigation_not_productive/

The paper referred to in view #50 is not available at the location provided. See the responses to views #1 and #3.

Fuels reduction Opposing View #51 - “New research published this week in the journal Science says that global warming may be causing more intense wildfires in the western United States. The researchers found that increases in large wildfire activity in the western United States over the past 25 years is ‘strongly associated with increased spring and summer temperatures and an earlier spring snowmelt.’ " Westerling, Anthony Ph.D., “Does Global Warming Increase Forest Fires?” NPR, Talk of the Nation, July 7, 2006

http://www.npr.org/templates/story/story.php?storyId=5541423

View #51 cites an opinion piece; the findings this view presents are not disputed in the Project EA. See the response to view #30.

Fuels reduction Opposing View #52 - “Indeed, climatic conditions drive View #52 cites an opinion piece; the findings this view

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http://www.baltimorechronicle.com/firelies_jul02.shtml

http://durangoherald.com/sections/News/2010/04/23/Scientist_Money_to_fight_beetles_as_fire_mitigation_not_productive/

http://durangoherald.com/sections/News/2010/04/23/Scientist_Money_to_fight_beetles_as_fire_mitigation_not_productive/

http://www.npr.org/templates/story/story.php?storyId=5541423



all big fires — not fuels. All substantial fires occur only if there is extended drought, low humidity, high temperatures and, most importantly, high winds. Wind, in particular, is critical. Wind increases fire spread exponentially.

When conditions are "ripe" for a large blaze, fires will burn through all kinds of fuel loads. By contrast if the forest is wet like Oregon's coastal forests, you can have all the fuel in the world, and it won't burn. For this reason, most fires go out without burning more than a few acres. By contrast, when you have drought, low humidity, high temperatures and wind, a few blazes will grow into huge fires. For this reason, approximately 1 percent of all fires are responsible for about 95 to 99 percent of the acreage burned.” Wuerthner, George “The Climate Factor - Forest thinning won't deter the coming large fires” Eugene Weekly, December 6, 2007 http://www.eugeneweekly.com/2007/12/06/views3.html

presents are not disputed in the Project EA.


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http://www.eugeneweekly.com/2007/12/06/views3.html



Fuels reduction Opposing View #53 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.”

Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html

EA sections 3.3.5.2 and 3.3.5.3 discuss the effects of proposed treatments on crowning index and surface flame lengths: surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes. Effects of fuels created by mechanical treatments are disclosed in EA sections 3.3.5.2 and 3.3.5.3: “the fuel generated from the NCT treatments would remain on-site, but the arrangement would be in a variable distribution, creating a jackpot-like fuel loading across the units. Fuels would be further reduced through a combination of hand piling/burning and jackpot burning.”

Fuels reduction Opposing View #54 - “For example, the Forest Service justifies the Elliston Face timber sale on the basis of reducing what they call “hazardous” fuels (which as an ecologist I call woody biomass). To quote the FS, “This project would reduce wildland fire risk and help protect lives, communities, and ecosystems from the potential consequences of a high-

View #54 cites an opinion piece; no scientific references are provided to indicate which studies were consulted in the writing of the cited opinion. Furthermore, the project mentioned in view #54 is located on the Helena National Forest, near the town of

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intensity wildland fire within treatment areas.” “

“The Forest Service makes these assertions even though the statement is full of falsehoods, misleading and/or unproven assumptions.”

“even the Forest Service’s own analysis concludes that logging of the Elliston Face will have some adverse impacts on soils, watersheds, wildlife, scenery and recreation. So we need to ask whether the potential effects of a fire that may not occur for a century or more is worth the negative impacts created by the logging process now?”

“The Forest Service’s own analysis has six indicator species— including pileated woodpecker, hairy woodpecker, martin, northern goshawk. These species depend on dead snags and down wood that pine beetles and wildfire create. But the FS treats beetles and wildfire as unwelcome events.” “the FS exploits the fears of misinformed citizens. One can only conclude the agency is still the handmaiden to the timber industry rather than a public servant working on behalf of all citizens of the country.” Wuerthner, George “Forest Service misses education opportunity” Published in NewWest, June 2010

http://www.newwest.net/topic/article/elliston_face_is_yet_another_example_of_forest_service_malfeasance/C564/L564/

Elliston, Montana, and is not site specific to the Project.

Finally, the opinions presented in view #54 are not disputed in the Project EA.

Fuels reduction Opposing View #55 - “Ultimately, fuels do not control fires. If the climate/weather isn’t conducive for fire spread, it doesn’t much matter how much dead wood you have piled up, you won’t get a large fire. As an extreme example, think of all the dead wood lying around on the ground in old-growth West Coast rainforests — tons of fuel, but few fires — because it’s too wet to burn. Large blazes are driven by a combination of extreme drought, low humidity, high temperatures and, most importantly, wind. These conditions do not occur in the same place at the same time very frequently — which is why

View #55 cites an opinion piece; the findings this view presents are not disputed in the Project EA.


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there are often decades to centuries between major blazes and most fires go out without burning more than a few acres.” Wuerthner, George “Pine Beetle Fears Misplaced” Helena Independent Record, March 25, 2010 http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d-001cc4c002e0.html

Fuels reduction Opposing View #56 – The following opposing view is so compelling, accurate and detailed it is shown in its entirety below. Why the National Fire Plan is a Trojan Horse for Logging Burning Questions

By George Wuerthner Ph.D. Published by CounterPunch, June 12-14, 2009, http://www.counterpunch.org/wuerthner06122009.html

(1) A couple of years ago I went on a show me tour of a Forest Service Thinning project that was funded under the National Fire Plan (NFP). A group of us, including some forest service employees, a university fire researcher, country commissioners, timber interests, and the like gathered at the Forest Service office. The district ranger explained that we were going to see a fuel reduction project designed to protect the small town where we were standing. After giving preliminary background on the proposed timber sale, we got into a bunch of Forest Service vehicles and drove out of town. And drove. And drove. And drove. Eighteen miles from the town, we got out of the car to look at the thinning project. (2) Standing among some ponderosa pine that had already been logged, many of them quite sizeable judging by the stumps, the district ranger and other Forest Service employees explained how this thinning project was designed to reduce the spread of fire into the community and eliminate so called “catastrophic fires.” The presumption being that such fires are a result of fire suppression and fuel build up. The solution, proponents of logging

Paragraphs 1 through 8—These paragraphs refer to a field trip to a National Fire Plan project area on a forest in Oregon and not the Clear Creek Integrated Project. Paragraphs 9 and 10—A full citation is not provided. However, the paper that appears to be referenced is Schoennagel et al. 2009; Implementation of National Fire Plan treatments near wildland-urban interface in the western United States; PNAS; Vol. 106 (26): 10706–10711. Though the Clear Creek Integrated Project is not a National Fire Plan project using HFRA authorities, it does contain a wildland-urban interface treatment component (EA, section 1.5, Purpose and Need #2) and is linked to a County Wildfire Protection Plan (EA section 1.2).

Paragraph 11—A portion of the WUI includes the Long Creek Summer home area (EA section 1.4), where the Forest Service is the landowner.

Paragraphs 12 and 13—See the responses to views #4, #30, and #43.

Paragraph 14—This paragraph refers to West Coast rainforests; the information is not relevant to the Clear Creek Integrated Project.

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http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d-001cc4c002e0.html

http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d-001cc4c002e0.html



argued, is to thin the forests and reduce fuels, hence eliminate large blazes.

(3) After all he and the others finished their presentation, they took questions and comments. The county commissioners said some approving remarks about how it was great the Forest Service was finally getting back into logging. The timber guys were happy—especially since they had retooled their mill to take smaller diameter trees. In general everyone seemed pleased with the proposal. (4) Then I raised my hand, and asked why they were cutting trees here, when the town was eighteen miles away. Shouldn’t they be thinning there? There was a silence. The district ranger, a reasonably intelligent and informed guy, kicked at the dust. He started to smile a bit and almost seemed relieved that I had posed the obvious question. (5) Finally he spoke and admitted yes they should probably be thinning next to the town if the goal was to protect the town but he indicated that he was under pressure just to get the cut out and the timber volume was greater here. He also admitted to us under further questioning that the thinned forests--under reduced competition resulting from the thinning efforts-- would likely grow back quickly, and largely negate much of the supposed value of fuel reduction. (6) He went on to explain that long before they had completed the full project (tens of thousands of acres) they would have to come back and log the original acreage to maintain its effectiveness as a fuel reduction. In truth, he didn’t see how they were going to implement the project successfully.

(7) I pointed to the surrounding pines which appeared to be similar size and age. Oh, yes, I was told by the university fire researcher that was because in 1860 or so there had been a large stand replacement fire in the basin and most of the trees had regrown from that event. (8) I said that was interesting since 1860 was before any white settlement in the area. In other words before there was any logging, grazing or fire suppression to create “unnatural” fuel build ups, so how could the basin full of ponderosa pine burn up in a stand replacement blaze if fuel build up is what creates large stand replacements fires? No response. The idea had apparently not occurred to anyone before. But the admission demonstrated clearly to me that the generalization that fire suppression is responsible for most large blazes may be overstated.

Paragraphs 15 through 17—See the responses to views #4, #30, and #43. Paragraph 18—The information presented is not disputed in the Clear Creek Integrated Project EA.

Paragraph 19—About Southwest ponderosa pine forests not ponderosa pine forests in the Clear Creek area. Paragraph 20—See responses to views #4, #30, and #43.

Paragraphs 21 through 24—The information presented is not disputed in the Project EA. See the responses to views #1, #3, #20, #24, #30, #43, and #48. Paragraphs 25 and 26—The information presented is not disputed in the Project EA. See view #1.

Paragraphs 27 and 28—The EA acknowledges that this project is an initial step, not a final step, in the Clear Creek area, as stated in section 3.3.5.2.2: “The objective of the restorative treatment is to create stand and fuel conditions that can eventually be maintained with prescribed fire or mechanical treatments.” See the response to Paragraphs 1-8. Paragraphs 21 through 29—Discussions in these paragraphs are not disputed in the Project EA. Refer to the responses to view #13, #17, and #45 through #48.

Paragraphs 30 through 32—These paragraphs comment on county zoning, which is not applicable to the Project.

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(9) Now a new review study that looked at implementation of the Forest Health plan in the West by Tania Schoennagel and colleagues from the University of Colorado, Colorado State and University of Montana lends credence to ideas I and other critics have been suggesting for years.

(10) Schoennagel et al. reviewed 44,000 fuel treatments done across the West under the rubric of the National Fire Plan (NFP). Despite the fact that the plan directs that treatments should be done where they would be most effective at reducing fire hazards to homes and communities, their analysis showed that only 3% of all thinning projects were in the so called “Wildlands Urban Interface” (WUI). Most were like the thinning project I visited in Oregon—miles from any community.

(11) They also noted that the majority of land (83%) that could be treated within the WUI lies on private property. In other words, even if thinning did work to reduce fire intensity and spread, the focus on federal lands does little to effectively protect homes and communities. Many studies have demonstrated that the most cost effective means of reducing fire hazard to homes and towns is to reduce the flammability of individual homes, not by logging the forests. (12) A further problem touched on by the review is a failure to acknowledge by thinning proponents that climate plays a major role in driving large fires. If you have severe drought, low humidity and high winds—especially high winds—nothing can effectively stop a blaze.

(13) Basically you have to wait until the weather conditions change. In the hierarchy of factors that affects fire spread, climate trumps fuels.

(14) By contrast, if the weather/climate conditions are not favorable for fire spread, it doesn’t matter how much fuel you have, you won’t get a large blaze. There are tons of fuels per acre in West Coast rainforests, yet these forests seldom burn because they never dry out sufficiently for a blaze to grow into a large fire, even if one starts by lightning or from people. Yet there is more fuel in those forests per acre than you would find in a hundred

Paragraph 33—See the response to view #42.

Paragraph 34—This paragraph presents an opinion about the National Fire Plan. Paragraph 35—This paragraph presents an opinion about timber harvest. The purpose of the treatments proposed for the Project is discussed in EA section 1.5, Purpose and Need.

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acres of a drier forest.

(15) Similarly, many high elevation forests in the West—think lodgepole pine in Yellowstone—are typically too wet to burn in most years. That is why fires in such forest types are infrequent, but when they do occur, they tend to be large blazes that kill many of the trees. (16) The vast majority of acreage burnt in recent years by large fires isn’t in the low elevation forests that may have been influenced by fire suppression and fuel-build up. They are occurring in forests that normally burn in mixed intensity to severe intensity stand replacement fires when conditions are right for such blazes. Considering that we have experienced extraordinary drought in many parts of the West, the fact that we are seeing large fires may not be “abnormal”. Large stand replacement fires are exactly what one would expect in such forest types under severe climatic/weather conditions. (17) And these forests types—including higher elevation forests of subalpine fir, lodgepole pine, as well as moister lower elevation forests of Grand fir, western red cedar, western larch and other species—make up the majority of all forest types in much of the Northwest and Northern Rockies. For instance, one study found that 96% of the forest types in the Northern Rockies of Idaho and Montana are either low elevation moist montane forests or higher elevation forest types. These forest types have long intervals between fires and tend to burn only when climatic conditions are favorable for fire spread. As a result the fuel loading in the majority of these forest acres are not likely to have been altered due to fire suppression. (18) But new research from around the West is even questioning the old that generalization that lower elevation dry montane forests were always characterized by low intensity frequent blazes. This idea, sometimes called the “Southwest Ponderosa Pine Model”, has come to dominate the common perception about all forest types and fire behavior. (19) In the Southwest ponderosa pine forests, there is good evidence to suggest that wildfire was frequent and tended to maintain open forest stands

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dominated by widely spaced large fire resistant pines. With fire suppression, logging, and livestock grazing, these forests are today stocked more densely, and some suggest, more prone to stand replacement blazes. (20) People around the West apply this Southwest model to all forest types, even remote high elevation forests where few fires were successfully suppressed, and where natural fire intervals are much longer—meaning that fire suppression could not have contributed to significant alternation in fuel loads. (21) However, muddling the waters further even on the Southwest ponderosa pine model is that researchers are finding is that in some parts of the country including Colorado, Idaho, Montana, Washington, Oregon, and elsewhere that stand replacement fires may be “natural” even in lower elevation dry montane forests dominated by ponderosa pine and Douglas fir. In other words, stand replacement blazes even in these forests are not out of the ordinary. (22) This research suggests that under some climatic conditions, even these forests will burn and burn well like the ponderosa pine filled basin I had visited on the FS tour that had burned in a stand replacement fire in 1860, long before fire suppression could have had an influence. It is now acknowledged that it’s quite possible for forests dominated by low intensity blazes may occasionally burn under severe weather conditions as stand replacement fires as well.

(23) If climate overrides fuels, then fuel reductions are not likely to have a significant impact at stopping the prevalence of large fires. And this appears to be borne out in how fires have burned throughout the West. The actual effectiveness of logging forests to reduce fuels and thus fire spread and intensity has had mixed results. There appears to be some places where fuel reductions appear to have reduced fire spread and fire intensity. However, there are plenty of examples of blazes around the West where fires raced through heavily thinned and logged stands, even clearcuts.

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(24) In my informal review of these fires, it appears that thinning may work under less than severe climate/weather conditions, but fails when climate/weather conspires to support large blazes. In other words, even if thinning “appears” to work under less severe conditions, it typically fails under severe weather/climate conditions of extended drought and high winds—which is one factor why there are “mixed” results reported on the effectiveness of thinning in the scientific literature. (25) Other factors contributing to mixed findings of thinning effectiveness include no precise definition of what constitutes thinning. How many trees per acre do you remove, and what size tree affects fire and fuels. Thinning may actually exacerbate fire spread by opening the forest to more heat and wind. (26) Plus thinning can increase small diameter fuels which are the major factor in fire spread, so most research suggests that thinning effectiveness is greatly enhanced if the area is burned after logging to remove fine fuels. But most thinning operations do not use pre-burning to reduce fine fuels after logging operations are completed. (27) The time since a forest was thinned is yet another factor. The effectiveness of a thinning on fuel loading rapidly declines, which is why they cannot be thought of as a one-time treatment. Thinning reduces competition and opens up a forest canopy permitting rapid growth of understory shrubs and trees—which are the major components of fire spread. (28) Depending on the vegetation, studies have shown that within 10-20 years, fuel loading can often return to pre-thinning levels. Thus any thinning done to supposedly reduce fire hazards must be thought of as an on-going treatment that requires continual maintenance. Doing such maintenance over millions of acres is impossible. That is another reason to focus thinning on the WUI and not miles from towns.

(29) Even if thinning did work to a degree, that doesn’t mean it’s the best

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solution to the perceived problem. Again circling back to the Schoennagel review, much of the “problem” isn’t large fires—which have always occurred in the West under severe climatic conditions—rather it is the result of expansion of new housing into the wildlands.

(30) According to their review the Wildlands Urban Interface increased 61% between 1970 and 2000. This is primarily a result of inadequate or none-existent zoning. Had county commissioners, most of whom are so called “private property advocates”, implemented strong zoning to concentrate housing in appropriate less fire prone areas, much of the hand wringing over fires could be avoided. Indeed, one could suggest that anti zoning zealots—often the same people who advocate logging—are the source of the fire hazard problem. (31) Beyond zoning, reducing home flammability has been shown to be very effective at reducing housing losses to fire. Over the past five years, I have visited many fires where homes were incinerated. In the majority of the homes I have seen, the fire did not actually reach the house. I have striking photos of burned out basements with green trees surrounding the home. (32) In almost all cases, what has occurred is a spark carried by the wind lands on some house with a wooden shake roof covered with pine needles and the house burns to the ground. Installation of a metal roof, in many cases, is all that is needed to reduce home flammability significantly. Even subsidizing the replacement of wooden roofs with metal in vulnerable homes may be far less expensive than fighting fires and wasting tax dollars on money losing timber sales. (33) Finally, and I always circle back to this last factor, logging is not benign. There is no such thing as a “good” logging operation. There are few truly “sustainable” logging operations. These are clever ruses to deceive the public. Logging always has significant ecological impacts and we should always enunciate them. Whether the benefits that may accuse from logging

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in terms of wood products, and even in some cases, a reduction in fire hazard are worth the true ecological costs is often difficult to determine because few reviews fully articulate the real costs. (34) My observations of so called fire reductions projects observed throughout the West is that most are nothing more than an excuse to log. The NFP is a Trojan Horse. Using fear of fire, and ignorance about fire ecology and what conditions support large blazes, logging proponents have so far been successful at duping the public, many politicians, and even some environmental organizations into supporting inappropriate logging proposals. (35) I personally would feel a lot better about any logging proposal if the FS and other supporters just came out and said, the reason we are logging is to get some timber out of the woods. Then we could have an honest debate about whether this is really in the public interest. Instead, far too many timber sales are wrapped up in the flag of fuel reductions that are neither effective nor in appropriate locations. The Schoennagel et al. review just gives further credence to this perspective. The review can be found at www.pnas.org

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http://www.pnas.org/


Table D-117. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment Opposing Views—Attachment #4—Roads


Road Construction Opposing View #1–“Fragmentation has been considered as one of the most major factors that lead to the decline of many wildlife species (Brittingham and Temple 1983, Yahner 1988, Winslow et al. 2000) because fragmentation tends to decrease population productivity (Robinson et al. 1995). Therefore, Meffe states that “fragmentation has become a major subject of research and debate in conservation biology” (Meffe et al. 1997, p. 272). Forest fragmentation usually occurs when large and continuous forests are divided into smaller patches as a result of road establishment, clearing for agriculture, and human development (Robinson et al. 1995, Meffe et al. 1997).” (Pg. 1)

“Generally, habitat fragmentation is an ecological process in which a large patch of habitat is divided into smaller patches of habitats. Usually, this process is caused by human activities (roads, agriculture, and logging). It also reduces the value of the landscape as habitat for many species (plants and animals). Fragmentation alters natural habitat in many ways, including reduction of patches’ sizes, increment of distances between similar patches, and increment of edges and predation (Brittingham and Temple 1983, Robinson et al. 1995).” (Pp. 2 and 3) Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and Implications” http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pdf

The referenced document defines fragmentation, discusses which species groups are most vulnerable to the effects of fragmentation, and presents a discussion of potential effects resulting from fragmentation. The document summarizes information found in other literature resources, including studies and literature reviews. The document appears to be part of a project supported by Cascadia Wildlands, an organization self-described as “grassroots conservation.” The Forest Plan was recently amended (USDA Forest Service 2010 a,b,c) to incorporate a WCS. The strategy was built upon a set of conservation principles, with a long-term goal of maintaining or effectively restoring representative, resilient, and redundant networks of habitats across the Forest. Nine conservation principles form the basis for assessing current baselines, threats, and risks at both the Forest scale (or mid scale) and the project scale (or site scale); some of these principles are directly related to avoiding or minimizing the effects of fragmentation (USDA Forest Service 2010a, Appendix E, E-6 through E-22). These conservation principles were considered during the planning and design of the Project and in the analysis of the project effects. See EA Sections 1.5, 3.4.1, 3.4.2, and 3.4.3 and the Wildlife Technical Report, Appendices A, B1, and B2.

The following CPs directly address fragmentation:

• CP 2—Habitat in contiguous blocks is better than fragmented habitat.

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• CP 3—Large blocks of habitat containing large populations of species are superior to small blocks of habitat containing few individuals.

• CP 5—Interconnected blocks of fragmented habitat are better than isolated blocks, and dispersing individuals travel more readily through habitat resembling that preferred by the species in question.

• CP 8—Continuous, nonfragmented riparian and wetland systems are better than fragmented habitat.

Indicators have been identified for each of the CPs. Road density is used as a risk indicator for CPs 2 and 8.

In addition to the CPs and indicators used to analyze effects on individual species, the wildlife analysis considered the influence that roads and trails have on wildlife and their habitat. Seventeen road- and trail- associated factors were identified that negatively affect wildlife. Habitat loss and fragmentation was 1 of the 17 factors (EA section 3.4.2.3) identified during the analysis, with all project focal species being affected by this factor to some degree. This analysis further supported the use of road density as an indicator of risk to species persistence within the analysis area. The analysis determined that Alternatives B and C would reduce total road densities or open road densities within source habitat for white-headed woodpecker, black-backed woodpecker, boreal owl, fisher, flammulated owl, great gray owl, northern goshawk, pileated woodpecker, Canada lynx, mountain quail,

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wolverine, wolf, elk (vulnerability), and spotted frog. The analysis also documented the effects from temporary road construction (EA Section 3.4.2.3). Design features (EA Section 2.4.4) have been included to minimize and avoid some impacts of roads, including impacts related to noxious weeds (NX-1 through NX-11) and management of temporary, closed, and decommissioned roads (TR-1, TR-8, TR-10, and TR-12).

Road Construction Opposing View #2–"Debris slides over a 20-year period were inventoried on 137,500 acres of forested land in the Klamath Mountains of southwest Oregon. Frequency during the study period was about one slide every 4.3 years on each 1,000 acres-an erosion rate of about 1/2 yd3 per acre per year. Erosion rates on roads and landings were 100 times those on undisturbed areas, while erosion on harvested areas was seven times that of undisturbed areas. Three-quarters of the slides were found on slopes steeper than 70 percent and half were on the lower third of slopes." "Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests."

Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr and R. R. Ziemer Ph.D. "Logging and forest roads related to increased debris slides in southwestern Oregon." Journal of Forestry Vol. 83, No. 4. 1985. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF

The findings presented in view #2 were developed from analysis of aerial photographs taken between 1956 and 1976. The study area was the coastal mountains of southwest Oregon, where annual precipitation ranged from 50 to 150 inches. By contrast, the Project area receives <25 inches of annual precipitation. The concluding sentence from the referenced abstract states the following: “Results serve as a guide to appraising slide risk associated with planned timber harvests or road construction on forested slopes.” EA Section 3.8 includes a discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses the direct, indirect, and cumulative effects to slope stability that could result from the timber harvest and road activities proposed under the different alternatives.

Road Construction Opposing View #3–" ‘Roads may have unavoidable effects on streams, no matter how well they are located, designed or maintained. The sediment contribution to streams from roads is often much greater than that from all other land management activities combined,

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection

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including log skidding and yarding.’ (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.” “Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.watertalk.org/wawa/ecosci.html


Road Construction Opposing View #4–“Plot-level studies have demonstrated the ability of forest roads to intercept and route both subsurface and surface overland flow more efficiently to the stream network. Significant amount of subsurface throughflow can be intercepted by the road, as a function of the road cut depth and the current saturation deficit, and then redirected, concentrating the flow in particular areas below the road. Road drainage concentration increases the effective length of the channel network and strongly influences the distribution of erosional processes. The concept of wetness index has been used in the study as a surrogate for subsurface throughflow, and the effect of forest roads on subsurface throghflow rerouting has been assessed by evaluating the changes in terms of draining upslope areas. A threshold model for shallow slope instability has been used to analyse erosional impacts of drainage modifications. In the model, the occurrence of shallow landsliding is evaluated in terms of drainage areas, ground slope and soil properties (i.e., hydraulic conductivity, bulk density, and friction angle). The model has been used to generate hypotheses about the broader geomorphic effect of roads. Modeling results have been compared with available field data collected in north-eastern Italy.” Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi “Evaluating the Effects of Forest Roads on Shallow Landsliding” Geophysical Research Abstracts, Vol. 5, 13312, 2003 http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf

Change in drainage network, change in peak/base flows, and disturbance regime, including the potential for landslide occurrence due to roads, have been analyzed, and the discussion is included in section 3.6 (Hydrology), section 3.7 (Fisheries), and section 3.8 (Soils).

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http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf



Road Construction Opposing View #5–“A large scale land use experiment has taken place over the last 40 years in the mountainous areas of the northwestern U.S. through timber harvesting. This land use change effects the hydrology of an area through two mechanisms:

• Clear-cut logging which causes changes in the dynamics of Rain-On-Snow (ROS) events due to changes in the accumulation and ablation of snow caused by vegetation effects on snow interception and melt; and

• Construction and maintenance of forest roads which channel intercepted subsurface flow and infiltration excess runoff to the stream network more quickly.” Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins “Predicting the Effects of Forest Roads on Streamflow using a Distributed Hydrological Model” from a poster presented at the fall meeting of the American Geophysical Union, San Francisco, CA, December 1996. http://www.ce.washington.edu/~lxb/poster.html

We were unable to locate the cited document.

No clearcut logging is associated with any of the action alternatives (EA section 1.9.6.3[#3]). Change in drainage network, change in peak/base flows, and disturbance regime, including the potential for landslide occurrence due to roads, have been analyzed, and the discussion is included in section 3.6 (Hydrology), section 3.7 (Fisheries), and section 3.8 (Soils).

Road Construction Opposing View #6–"Many of the conclusions and assumptions contained in the Roads Report are based on analysis of the positive contributions of roads. Negative socio-economic effects of roads have been, in large part, glossed over. The general view expressed in the Roads Report is that overall, roads make a positive socio-economic contribution." "The Socio-Economic Effects section has been constructed to overwhelmingly support the contention that the benefits of roads outweigh the costs. In order to arrive at such a conclusion, however, certain important economic costs and concepts have been omitted." "A serious problem with the Roads Report is its lack of discussion concerning the economic costs arising from the negative ecological effects

The Clear Creek watershed TAR identified both risks and benefits of roads. Risks related to safety, watershed and aquatics, terrestrial wildlife, noxious weeds, maintenance cost, stream crossings, location within a roadless area, location within a landslide-prone area, and location within a RCA were included in the assessment. Values and benefits for roads were also identified and considered during the analysis process. Values and benefits considered were related to access for recreation, minerals or energy extraction, cooperative or cost-share agreements with other entities, and forest administration, including fire protection in urban interface areas. The IDT conducting

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of roads. Despite overwhelming scientific data linking roads and sedimentation (Bennett 1991; Grayson et al. 1993; Lyon 1984; Megahan 1980; McCashion and Rice 1983; Wade 1998; Williams 1998), the socio-economic costs of mitigating the effects of this sedimentation receive no mention in the Roads Report. Such costs are central to and should be included in any socio-economic assessment of forest roads."

the analysis considered both risks and value/benefits when identifying a recommended road system. The Project transportation management actions (Alternatives B and C) (EA section 2.4.2.2) propose to implement several of the recommendations resulting from the Clear Creek watershed travel analysis, which took into account the risks associated with roads as well as the value or benefits of those roads. Several sections within the EA discuss various risks or benefits related to roads; these sections include Vegetation: Snags and Coarse Woody Debris (3.2.6), Fire and Fuels (3.3), Wildlife Habitat Indicators (3.4.2), ESA/R4-Sensitive/Focal Species Addressed in Detail (3.4.3), Air Quality (3.5), Hydrology (3.6), Fisheries (3.7), Soils (3.8), Botanical (3.9), Noxious Weeds (3.10), Transportation (3.11), Recreation (3.12), Scenic Environment (3.15), and Inventoried Roadless Areas (3.16). These sections discuss the risks and benefits of roads in terms that relate to the resource; no attempt is made to convert these risks and benefits into monetary values. However, some of the monetary costs of maintaining roads or of mitigating resource concerns are discussed in EA Section 3.11 (Transportation) and Section 3.14 (Economics).

Road Construction Opposing View #7–"The present road system constitutes a legacy of current and potential sources of damage to aquatic and riparian habitats, mostly through sedimentation, and to terrestrial habitats through fragmentation and increased access" (Amaranthus et all 1985)." "The failure of the Report to properly address mitigation costs associated

The article cited is an opinion paper offering review and comment on a second draft of “Forest Service Roads: A Synthesis of Scientific Information,” which was produced by the USDA Forest Service. The cited paper was written by Daniel Brister, University of Montana, Environmental Studies Program, in

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with the ecological effects is a serious problem that needs to be addressed in future drafts. Similarly, passive-use values need to be taken seriously and considered throughout the Roads Report. In order to rectify these problems, most of the Socio-Economic Effects subsections will have to be reworked. Failing to do so, the Roads Report will paint an incomplete picture of the costs and benefits associated with the Forest Service's road program." Brister, Daniel. "A Review and Comment on: Forest Service Roads: A Synthesis of Scientific Information, 2nd Draft, USDA Forest Service." December 1998. http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio-economic-impacts

December 1998 to assist the Forest Service in subsequent drafts. The quotations displayed by Mr. Artley are taken from Brister’s paper. Brister’s article suggests that the Forest Service include, in the final document, an assessment of socioeconomic impacts of forest system roads, which includes impacts to aquatic, riparian, and wildlife and associated habitats from road management, fragmentation, and access. The final document, “Forest Roads: A Synthesis of Scientific Information” (General Technical Report PWN-GTR-509), was published in May 2001 by the Pacific Northwest Research Station, Portland, Oregon. Refer to the response to view #6 for an overview of the TAP developed specifically to inform road-related decisions within the Project area.

Water quality and the disclosure of effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in sections 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality). The effects to fisheries from sedimentation caused by road management activities are discussed in EA section 3.7.2.2.20, Integration of Species and Habitat Conditions. For additional information about how road management affects wildlife and wildlife habitat, please refer to the response to view #1.

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http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio-economic-impacts

http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio-economic-impacts



Road Construction Opposing View #8–"Sediment input to freshwater is due to either the slower, large-scale process of soil erosion, or to rapid, localized “mass movements,” such as landslides. Forest practices can increase the rate at which both processes occur. Most sediment from forestry arises from landslides from roads and clearcuts on steep slopes, stream bank collapse after riparian harvesting, and soil erosion from logging roads and harvested areas. Roads, particularly those that are active for long periods of time, are likely the largest contributor of forestry-induced sediment (Furniss et al. 1991)."

"Sediment can increase even when roads comprise just 3% of a basin (Cederholm et al. 1981)."

"More than half the species present in the study area will likely be negatively impacted by sedimentation from logging roads." "In areas made highly turbid (cloudy) from sedimentation, the foraging ability of adults and juveniles may be inhibited through decreased algal production and subsequent declines in insect abundance, or, for visual-feeding taxa dependent on good light, through their inability to find and capture food. Highly silted water may damage gill tissue and cause mortality or physiological stress of adults and juveniles."

Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 "Evaluating effects of large-scale salvage logging for mountain pine beetle on terrestrial and aquatic vertebrates." Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest Service. http://warehouse.pfc.forestry.ca/pfc/25154.pdf

No clearcut logging is associated with any of the action alternatives (EA Section 1.9.6.3[#3]). No commercial harvest within riparian areas is proposed under any of the action alternatives (EA sections 2.4.2 and 2.4.3; Table 2-8). Water quality and the disclosure of effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in sections 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality).

Road Construction Opposing View #9–"The road construction and right-of-way logging were immediately detrimental to most aquatic invertebrates in South Fork Caspar Creek"

"Salmonid populations decreased immediately after the road construction."

The effects to fisheries from sedimentation caused by road management activities are discussed in EA section 3.7.2.2.20, Integration of Species and Habitat Conditions.

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"Sustained logging and associated road construction over a period of many years do not afford either the stream or the 'fish population a chance to recover." Burns, James W., "Some Effects of Logging and Associated Road Construction on Northern California Streams." Transactions of the American Fisheries Society, Volume 1, Number 1, January 1972. http://www.fs.fed.us/psw/publications/4351/Burns72.pdf

Road Construction Opposing View #10–“In the temporal analysis, from 1950 to 1993, logging and road building in the study area clearly modified landscape patterns. Increased landscape fragmentation is evident in measures of smaller mean patch and core areas, reduced patch size variability, increased patch and edge density, and higher edge contrast.”

Buttenfield, Barbara P. Ph.D. and David R. Cameron “Scale Effects and Attribute Resolution in Ecological Modeling” A paper presented at 4th International Conference on Integrating GIS and Environmental Modeling Banff, Alberta, Canada, September 2 - 8, 2000 http://www.colorado.edu/research/cires/banff/pubpapers/158/

Refer to the responses to views #1 through 9.

Road Construction Opposing View #11–“Forest roads apparently can serve as a partial filter to the movements of some amphibian species”

deMaynadier, Phillip G. and Malcolm L. Hunter, Jr. “Road Effects on Amphibian Movements in a Forested Landscape” From Natural Areas Journal (2000) Volume: 20, Issue: 1, Pages: 56-65 http://www.mendeley.com/research/road-effects-on-amphibian-movements-in-a-forested-landscape/

The effects analysis for this project addresses potential impacts to one amphibian species, the spotted frog (EA Section 3.4.3.17). In summary, potential disturbance impacts could occur from instream culvert replacement activities and thinning within RCA corridors under all action alternatives. However, proposed activities under Alternatives B and C would incrementally improve water quality within source habitat waterbodies and would improve mobility along source habitat waterways via aquatic organism passage (AOP) culvert installation (EA Sections 3.4.3.17 and 3.7). Design features (EA section 2.4.4.9) were developed, in part, to minimize impacts to RCA source habitat. The

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http://www.colorado.edu/research/cires/banff/pubpapers/158/

http://www.mendeley.com/research/road-effects-on-amphibian-movements-in-a-forested-landscape/

http://www.mendeley.com/research/road-effects-on-amphibian-movements-in-a-forested-landscape/



movements of amphibians are related to WCI) used in the analysis, specifically, “Road density/location” and “Riparian Conservation Areas.” Roads within riparian areas would be reduced under the action alternatives, in every time frame (temporary, short-term, and long-term). RCAs would be negatively impacted in the temporary time frame due to restorative treatments that result in increased disturbances and sediment within riparian areas; however, these areas would incrementally improve in the long term. While riparian conditions would improve as a result of the action alternatives, risks associated with the WCIs remain moderate to high, indicating that amphibian movements would continue to be affected by the remaining road system.

Road Construction Opposing View #12–"Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road." Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks made to Forest Service employees and retirees at the University of Montana. February 1998. https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm

The cited quote is not an accurate quotation from Chief Dombeck’s speech. Dombeck’s statement, taken from the cited source, reads as follows: “The benefits of forest roads are many. But they also often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road.”

The effects of proposed maintenance of existing roads, the effects of proposed construction and improvements of other roads, and the reasons for and benefits of decommissioning roads no longer needed to support management objectives within this area are disclosed in each resource section in the EA.

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https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm





Road Construction Opposing View #13–"Few marks on the land are more lasting than roads." "The negative effects on the landscape of constructing new roads, deferring maintenance, and decommissioning old roads are well documented. Unwanted or non-native plant species can be transported on vehicles and clothing by users of roads, ultimately displacing native species. Roads may fragment and degrade habitat for wildlife species and eliminate travel corridors of other species. Poorly designed or maintained roads promote erosion and landslides, degrading riparian and wetland habitat through sedimentation and changes in streamflow and water temperature, with associated reductions in fish habitat and productivity. Also, roads allow people to travel into previously difficult or impossible to access areas, resulting in indirect impacts such as ground and habitat disturbance, increased pressure on wildlife species, increased litter, sanitation needs and vandalism, and increased frequency of human-caused fires." EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, "National Forest System Road Management." http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day-03/g5002.htm

This view presents an excerpt from a March 3, 2000, Federal Register Notice posted by the Forest Service. The Forest Service concluded that it needed to review its forest road system policy, 1 of 4 emphasis items in the Agency’s National Resource Agenda. The Agency proposed to revise 36 CFR Part 212 to shift the emphasis from transportation development to managing environmentally sound access. The first quoted sentence is taken out of context; in fuller context, the statement reads as follows: “Few marks on the land are more lasting than roads. Yet, forest roads are essential for forest use and often serve as the backbone of rural transportation networks.” Please refer to the response to view #1 for more detail concerning effects to wildlife and wildlife habitat. EA Section 3.8 includes a discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses the direct, indirect, and cumulative effects to slope stability that could result from the timber harvest and road activities under the different alternatives.

Water quality and the disclosure of effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in sections 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality).

Change in drainage network, change in peak/base flows, and disturbance regime, including the potential for landslide occurrence due to roads, have been

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analyzed, and the discussion is included in section 3.6 (Hydrology), section 3.7 (Fisheries), and section 3.8 (Soils). The effects to fisheries from sedimentation caused by road management activities are discussed in EA section 3.7.2.2.20, Integration of Species and Habitat Conditions.

Road Construction Opposing View #14–“Fragmentation caused by roads is of special interest because the effects of roads extend tens to hundreds of yards from the roads themselves, altering habitats and water drainage patterns, disrupting wildlife movement, introducing exotic plant species, and increasing noise levels. The land development that follows roads out into rural areas usually leads to more roads, an expansion process that only ends at natural or legislated barriers.” “Forest Fragmentation and Roads” Eastern Forest Environmental Threat Assessment Center U.S. Forest Service - Southern Research Station http://www.forestthreats.org/publications/su-srs-018/fragmentation

The cited document discusses the relationship between roads and habitat fragmentation across the United States. The information is general in nature. The paper does not provide site-specific or species-specific information relative to the Project; the paper does not provide information relevant to the management of Forest MIS or designated threatened, endangered, or sensitive species.

View #14 lists introduction of exotic plant species, disturbance impacts to wildlife, and disruption of wildlife movements as potential impacts that could occur as a result of road fragmentation of habitat. EA Section 3.4.2.3 discusses 16 road-associated factors negatively impacting wildlife: snag reduction, down log reduction, edge effects, hunting, trapping, poaching, collection, harassment or disturbance at specific use sites, collisions, movement barrier, displacement or avoidance, chronic negative interactions with humans, physiological response, snow compaction, routes for competitors and predators, and noxious weed effects. Road-associated risks were also assessed for individual species (EA section 3.4.3); these risks are tied to conservation principles utilized during analysis and the

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species-specific impacts to these species resulting from roads. See the response to view #1 for additional wildlife-related information.

Regarding soils productivity, the article concludes with the following statement: “Overall, forest land was slightly more remote from roads than other landcover types.” EA Section 3.8 describes TSRC, which is the conversion of productive land to essentially nonproductive sites for periods of >50 years. TSRC is a metric that can be used to characterize how the expansion or decrease in roads influences soil and hydrologic processes across forested lands. Section 3.8 discusses the varying ranges of TSRC from road activities by alternative. The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and 3.7 (Fisheries) of the EA. Habitat fragmentation and the effects on fisheries are discussed in section 3.7.

Road Construction Opposing View #15–“A huge road network with vehicles ramifies across the land, representing a surprising frontier of ecology. Species-rich roadsides are conduits for few species. Roadkills are a premier mortality source, yet except for local spots, rates rarely limit population size. Road avoidance, especially due to traffic noise, has a greater ecological impact. The still-more- important barrier effect subdivides populations, with demographic and probably genetic consequences. Road

The cited document discusses road impacts to species at a national and global level, including Britain and Australia. The references this document makes to roadside vegetation and roadkill issues are primarily linked to improved roads with maintained (mowed) margins, not narrow, native-surfaced forest roads such as those found in the Project area. The document also

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networks crossing landscapes cause local hydrologic and erosion effects, whereas stream networks and distant valleys receive major peak-flow and sediment impacts. Chemical effects mainly occur near roads. Road networks interrupt horizontal ecological flows, alter landscape spatial pattern, and therefore inhibit important interior species. Thus, road density and network structure are informative landscape ecology assays. Australia has huge road-reserve networks of native vegetation, whereas the Dutch have tunnels and overpasses perforating road barriers to enhance ecological flows. Based on road-effect zones, an estimated 15–20% of the United States is ecologically impacted by roads.” Forman, Richard T. and Lauren E. Alexander “Roads and their Major Ecological Effects” Annual Review of Ecology and Systematics, Vol. 29: 207-231, November 1998 http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&journalCode=ecolsys.1

raises the issue of disturbance and avoidance, mainly in the context of high-use, high-speed roads; this issue does not apply to the Project. However, wildlife disturbance from roads in general does apply to small forest roads and to this project, especially in terms of open roads and the potential impacts to elk and wolves. Finally, the document identifies roads as barriers that can negatively influence species diversity and fragment populations.

The Forest WCS (USDA Forest Servuce 2010a) identified road-associated risk factors for wildlife species on the Forest (Nutt et al. 2010). The risk factors identified by the WCS for Family 1 and Family 2 species analyzed for this project include 1) reductions in snag or CWD from firewood gathering, 2) loss of large live trees from harvest activities, 3) roads acting as a vector for invasive species, 4) habitat fragmentation caused by harvest activities made possible by road access, and 5) negative edge effects caused by road fragmentation of forest interior habitats. Refer to the responses to view #1 and view #14. View#15 specifically mentions impacts to wildlife from roadkill, avoidance, and roads as barriers. EA section 3.4.2.3 includes collisions (death or injury from a motorized vehicle running over or hitting an animal), displacement or avoidance (spatial shifts in populations or individual animals away from human activities on or near roads, trails, or networks), and movement barrier (interference with dispersal or other movements as posed by a road or trail itself or by human activities on or near roads, trails, or networks) as road-associated

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http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&journalCode=ecolsys.1



factors negatively impacting wildlife.

In addition, view #15 mentions the consequences of barriers on population demographics and genetic interchange. The impacts of roads and other factors affecting populations were considered during selection of CPs and indicators for the WCS. Please refer to the Forest Plan Appendix E, pages E-7 through E-14, for additional detail on the conservation principles. As previously noted, the CPs and indicators were utilized during planning for the Project and during analysis of project effects on wildlife.

Water quality and the disclosure of effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in sections 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality).

The effects to fisheries from sedimentation caused by road management activities are discussed in EA section 3.7.2.2.20, Integration of Species and Habitat Conditions. The action alternatives include specific mitigation measures relating to water quality; these measures are described in section 2.4.4.9, Design Features. Design features relevant to sediment delivery include WF-1, WF-7 through WF-16, and WF-19.

Road Construction Opposing View #16–“Questions to consider: Roads dramatically alter forest ecosystems

1. Does the management prescription account for the ecological effects of the road construction and maintenance activities associated with carrying

A travel analysis was conducted for the Clear Creek watershed (which includes the Project area) and is documented in the TAR. The Clear Creek watershed TAR identified both risks and benefits of roads. Risks

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out such activities?

2. Have alternatives to road building been considered? How does the plan attempt to address the effects of roads?” (page 37) Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique."A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf

related to safety, watershed and aquatics, terrestrial wildlife, noxious weeds, maintenance cost, stream crossings, location within a roadless area, location within a landslide-prone area, and location within a RCA were identified and included in the assessment. Values and benefits for roads were also identified and considered during the analysis process. Values and benefits considered were related to access for recreation, minerals or energy extraction, cooperative or cost-share agreements with other entities, and forest administration, including fire protection in urban interface areas. The IDT conducting the analysis considered both risks and value/benefits when identifying a recommended road system.

The action alternatives assessed in detail in the EA include different road management activities (refer to Table 2-9, Transportation Treatments by Alternative). The transportation management activities proposed under Alternatives B and C (action alternatives) would implement several recommendations that were the result of the Clear Creek watershed travel analysis process.

Several sections within the EA discuss the ecological effects of roads; these sections include Vegetation: Snags and Coarse Woody Debris (3.2.6), Fire and Fuels (3.3), Wildlife Habitat Indicators (3.4.2), ESA/R4-Sensitive/Focal Species Addressed in Detail (3.4.3), Air Quality (3.5), Hydrology (3.6), Fisheries (3.7), Soils (3.8), Botanical (3.9), Noxious Weeds (3.10), Scenic Environment (3.15), and Inventoried Roadless Areas (3.16).

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Road Construction Opposing View #17–“The authors warned that cutting roads into current roadless areas could bring much more harm to wildlife, soil and fisheries than the beetle-killed trees pose to the forest.” Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/

The Project does not propose any commercial harvest or road development within Inventoried Roadless Areas (see EA section 3.16).

Road Construction Opposing View #18–"Rarely can roads be designed and built that have no negative impacts on streams. Roads modify natural drainage patterns and can increase hillslope erosion and downstream sedimentation. Sediments from road failures at stream crossings are deposited directly into stream habitats and can have both on-site and off-site effects. These include alterations of the channel pattern or morphology, increased bank erosion and changes in channel width, substrate composition, and stability of slopes adjacent to the channels."

"All of these changes result in important biological consequences that can affect the entire stream ecosystem. One specific example involves anadromous salmonids, such as salmon and steelhead, that have complex life histories and require suitable stream habitat to support both juvenile and adult life stages."

"A healthy fishery requires access to suitable habitat that provides food, shelter, spawning gravel, suitable water quality, and access for upstream and downstream migration. Road-stream crossing failures have direct impacts on all of these components." Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan "Diversion Potential at Road-Stream Crossings." USDA Forest Service. 9777 1814—SDTDC. December 1997.

http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf

Water quality and the disclosure of effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality).

The effects to fisheries from sedimentation caused by road management activities are discussed in EA Section 3.7.2.2.20, Integration of Species and Habitat Conditions. The action alternatives include specific mitigation measures relating to water quality; these measures are described in Section 2.4.4.9, Design Features. Design features relevant to sediment delivery include WF-1, WF-7 through WF-16, and WF-19. The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in sections 3.6 (Hydrology) and 3.7 (Fisheries) of the EA. Habitat fragmentation and the effects on fisheries are discussed in section 3.7.

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Road Construction Opposing View #19–“Barry Noon, a professor of wildlife ecology at Colorado State University, noted that scientific research has consistently shown the adverse effects of roads on hydrologic processes and fish and wildlife populations.

“One of the key things to recognize is the effects of the roads extend far beyond their immediate footprint,” Noon said. For example, “in terms of hydrology, the roads are leading to faster runoff of water, often with great increases in sedimentation, particularly following storm events, and roads in watersheds often lead to increases in the intensity of floods.” “

These changes degrade fish habitat because of the increased sedimentation that leads to decreases in water quality, Noon said. And roads fragment wildlife habitat and create areas that animals avoid, often as result of increased hunting, he said.” Gable, Eryn “Battling beetles may not reduce fore risks – report” Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/

The cited article discusses a recent report on the mountain pine beetle epidemic in Colorado and how best to manage forests in the context of limited funding and roadless areas designations.

Please refer to the response to view #1 for how road management alternatives considered in the Project area affect wildlife and wildlife habitat. Please refer to the responses to views #1, #14, and #15.

Road Construction Opposing View #20–"Roads and skid trails have been identified as a major contributor to increased turbidity of water draining logging areas resulting in increases from 4 to 93 parts per million (Hoover, 1952). Forest roads have been found to have erosion rates from one to three orders of magnitude greater than similar undisturbed areas (Megahan, 1974) and perhaps account for as much as 90 percent of all forest erosion (Megahan, 1972). Forest roads can also cause soil erosion and stream sedimentation, which adversely impact on the nation’s water quality (Authur et al., 1998). Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the forest road system." In: Proceedings of the conference 34 international erosion control association; ISSN 1092-2806. [Place of publication unknown]: International Erosion Control Association: 301-310.

Water quality and the effects of roads and timber harvest on sedimentation and turbidity were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and subsection 3.6.2 (Water Quality).

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Comment Forest Service Response http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf

Road Construction Opposing View #21–"Roads have well-documented, short- and long-term effects on the environment that have become highly controversial, because of the value society now places on unroaded wildlands and because of wilderness conflicts with resource extraction."

"(Road) consequences include adverse effects on hydrology and geomorphic features (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, use conflicts, destructive human actions (for example, trash dumping, illegal hunting, fires), lost solitude, depressed local economies, loss of soil productivity, and decline in biodiversity."

Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of Scientific Information." USDA Forest Service, General Technical Report PNW-GTR-509. http://www.fs.fed.us/pnw/pubs/gtr509.pdf

The cited GTR PNW-GTR-509 describes the effects roads have on ecosystems. It is a companion paper to “Roads Analysis: Informing Decisions about Managing the National Forest Transportation System” (USDA Forest Service 1999). The GTR details the known issues related to road impacts on physical and biological resources, road impacts at various scales, and the socioeconomics of roads. The report then describes the known science surrounding these issues. The focus of the report is to help the reader understand how roads function in the landscape. Specifically, the GTR addresses habitat fragmentation, habitat loss, displacement or avoidance, roadkill, reduction in species diversity, negative edge effects, fragmentation of interior habitats, vectors for invasive species, poaching, reduced densities of snags and logs, collisions, and movement barriers. The terrestrial wildlife species analysis portions of this document focus on findings from Wisdom et al. (2000).

The wildlife analysis for the Project included an assessment of the effects of linear features (roads and trails) on wildlife; EA section 3.4.2.3 details this information. The analysis identified 17 road/trail-associated factors, including 13 from Wisdom et al. (2001), that negatively impact wildlife; the analysis also included lists of project focal species with documented effects related to each factor. Risks associated with linear features were also assessed for individual species (EA section 3.4.3). Road density is a risk indicator for some conservation principles utilized

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to develop a WCS for the Forest. These principles were considered/utilized during planning and analysis for the Project. The Project analysis determined that Alternatives B and C would reduce total road densities or open road densities within source habitat for white-headed woodpecker, black-backed woodpecker, boreal owl, fisher, flammulated owl, great gray owl, northern goshawk, pileated woodpecker, Canada lynx, mountain quail, wolverine, wolf, elk (vulnerability), and spotted frog. Lower road densities or open road densities, combined with design features, would reduce impacts related to the presence or use of roads. These impacts include loss of habitat/habitat components, habitat fragmentation, disturbance at sensitive sites, displacement from otherwise suitable habitat, and increased vulnerability to mortality (hunting, poaching, collisions, trapping, incidental trapping) (EA sections 3.4.2. 3 and 3.4.3).

See also the responses to views #1, #14, and #15.

Road Construction Opposing View #22–"Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands." Hann, W.J. et al. 1997 Landscape dynamics of the Basin. Pp. 337-1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405 http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf

The science findings resulting from the Interior Columbia Basin Ecosystem Management Project (ICBEMP), such as the one partially quoted in view #22, were integral in informing disclosures in the FEIS supporting both the 2003 Revised Forest Plan (USDA 2003a,b,c) and the 2010 amendments to the Forest Plan (USDA 2010). The Project implements the strategies outlined in the Forest Plan. The 2003 FEIS, Chapter 1, page 1-31, states the following: “In January of 2003 a Memorandum of

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Understanding (MOU) was entered into … The purpose of this MOU is to cooperatively implement ‘The Interior Columbia Basin Strategy’ to guide the amendment and revision of forest (Forest Service) and resource management (BLM) plans and project implementation on public lands administered by the Forest Service and Bureau of Land Management throughout the Interior Columbia Basin (USDA Forest Service et al. 2003). This strategy incorporates the scientific assessment information in ‘An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins’ (Quigley and Arbelbide 1997a,b,c,d), the analyses supporting or developed as part of ICBEMP, the ‘Integrated Scientific Assessment for Ecosystem Management’ (ICBEMP 1996b) developed by the Interior Columbia Basin Ecosystem Management Project (ICBEMP) as a guide for implementation, and all reports generated by the ICBEMP project. … Key findings contained in this strategy were considered and used in the development of the Proposed Action (Alternative 2) for Forest Plan revisions, as well as other action alternative management strategies outlined in the FEIS (Chapter 2) …” [emphasis added]

Road Construction Opposing View #23–“Many forested landscapes are fragmented by roads, but our understanding of the effects of these roads on the function and diversity of the surrounding forest is in its infancy. I investigated the effect of roads in otherwise continuous forests on the macroinvertebrate fauna of the soil. I took soil samples along transects leading away from the edges of unpaved roads in the Cherokee National Forest in the Southern Appalachian mountains of the United States. Roads

A travel analysis was conducted for the Clear Creek watershed (which includes the project area) and is documented in the TAR. The Clear Creek watershed TAR identified both risks and benefits of roads. Risks related to safety, watershed and aquatics, terrestrial wildlife, noxious weeds, maintenance cost, stream crossings, location within a roadless area, location

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significantly depressed both the abundance and the richness of the macroinvertebrate soil fauna. Roads also significantly reduced the depth of the leaf-litter layer. These effects persisted up to 100 m into the forest. Wider roads and roads with more open canopies tended to produce steeper declines in abundance, richness, and leaf-litter depth, but these effects were significant only for canopy cover and litter depth. The macroinvertebrate fauna of the leaf litter plays a pivotal role in the ability of the soil to process energy and nutrients. These macroinvertebrates also provide prey for vertebrate species such as salamanders and ground-foraging birds. The effect of roads on the surrounding forest is compounded by the sprawling nature of the road system in this and many other forests. My data suggest that even relatively narrow roads through forests can produce marked edge effects that may have negative consequences for the function and diversity of the forest ecosystem.”

Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Macroinvertebrate Soil Fauna of the Southern Appalachian Mountains” http://www.jstor.org/stable/2641904

within a landslide-prone area, and location within a RCA were identified and included in the assessment. Values and benefits for roads were also identified and considered during the analysis process. Values and benefits considered were related to access for recreation, minerals or energy extraction, cooperative or cost-share agreements with other entities, and forest administration, including fire protection in urban interface areas. The interdisciplinary team conducting the analysis considered both risks and value/benefits when identifying a recommended road system.

The action alternatives assessed in detail in the EA include different road management activities (refer to Table 2-9, Transportation Treatments by Alternative). The transportation management activities proposed under Alternatives B and C (action alternatives) would implement several recommendations that were the result of the Clear Creek watershed travel analysis process.

Several sections within the EA discuss the ecological effects of roads; these sections include Vegetation: Snags and Coarse Woody Debris (3.2.6), Wildlife Habitat Indicators (3.4.2), ESA/R4-Sensitive/Focal Species Addressed in Detail (3.4.3), Hydrology (3.6), Fisheries (3.7), Soils (3.8), Botanical (3.9), and Noxious Weeds (3.10).

Road Construction Opposing View #24–“Roads remove habitat, alter adjacent areas, and interrupt and redirect ecological flows. They subdivide wildlife populations, foster invasive species spread, change the hydrologic network, and increase human use of adjacent areas. At broad scales, these

The cited article looks at the dynamics of road networks over time and how they impact landscape patterns. More specifically, the study looked at relationships between road density changes,

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impacts cumulate and define landscape patterns.” Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D., Murray K. Clayton Ph.D., Roger B. Hammer Ph.D., and Charlotte E. Gonzalez-Abraham Ph.D. “Road Development, Housing Growth, and Landscape Fragmentation In Northern Wisconsin: 1937–1999” Ecological Applications: Vol. 16, No. 3, pp. 1222-1237. http://www.esajournals.org/doi/abs/10.1890/1051-0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journalCode=ecap

development, and landscape patterns, focusing on housing development. Regarding wildlife, the reference mentions in a broad context roads as sources of habitat fragmentation, spread of invasive species, and increased human use or presence.

Please refer to the responses to view #1 and view #21 for more detail concerning effects to wildlife and wildlife habitat. Change in drainage network due to roads has been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

Road Construction Opposing View #25–“Last winter was unusually wet in the Pacific Northwest. The result was landslides all over caused by logging roads; five people died, spawning streams were ruined, water supplies were contaminated and the flooding was tremendously aggravated. According to David Bayles, conservation director of the Pacific Rivers Council, aerial surveys documented more than 650 landslides in February in Washington and Oregon alone. The stupidest and most dangerous practice is allowing logging roads on steep slopes — that's really asking for it. You may ask yourself why the taxpayers are expected to pony up to build roads for profitable logging companies. Build roads for the timber companies in order to stimulate the U.S. logging, paper and building industries. There's just one problem. A lot of U.S. logs get shipped overseas, mostly to Japan. We're actually subsidizing Japanese companies while doing terrible damage to our environment and not helping the U.S. job scene much except when it comes to cutting

Start with the assumption that the U.S. Forest Service a component of the Department of Agriculture, is simply an auxiliary branch of the timber industry and you'll pretty much have the picture of what's going

Effects of proposed activities, including road-related activities, on slope stability are addressed in detail in section 3.8 of the EA. Design Features WF-9, WF-10, and FF-6 (EA section 2.4.4) are specific to slope stability and are included in Alternatives B and C to reduce the threats associated with management action that might initiate landslides. Overall, these design features for Alternatives B and C would identify and avoid landslides and landslide-prone areas within harvest units. Road decommissioning would reduce the long-term potential for road failure (EA sections 3.8.5.3.2 and 3.8.5.4.2). Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality). The effects of roads on water drainage patterns are

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on. Last winter, the Forest Service refused a bid at a timber auction from an environmentalist who wanted to save, not harvest, a stand of evergreens in the Okanogan National Forest in Washington. Instead, the Forest Service accepted a bid of $15,000 from a logging company that cut 3.5 million board-feet of lumber in that stand. Try to find a price like that at Home Depot.”

Ivins, Molly Creators Syndicate, August 3 1997 08 03 http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html

included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA. Regarding the export of logs overseas, 36 CFR 223.188 specifically prohibits the exporting of unprocessed Federal timber:

36 CFR 223.188: Prohibitions against exporting unprocessed Federal timber. No person who acquires unprocessed timber originating from Federal lands west of the 100th meridian in the contiguous 48 States may export such timber from the United States, or sell, trade, exchange, or otherwise convey such timber to any other person for the purpose of exporting such timber from the United States. This prohibition does not apply to specific quantities of grades and species of such unprocessed Federal timber that the Secretary of Agriculture determines to be surplus to domestic manufacturing needs.

Road Construction Opposing View #26–"Although disturbance patches are created by peak flow and debris flow disturbances in mountain landscapes without roads, roads can alter the landscape distributions of the starting and stopping points of debris flows, and they can alter the balance between the intensity of flood peaks and the stream network's resistance to change."

Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of roads on hydrology,

The effects of roads on water drainage patterns and slope stability are included in the analysis in the EA (sections 3.6 through 3.8). Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

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geomorphology, and disturbance patches in stream networks." Conservation Biology 14, No. 1. 2000. http://www.jstor.org/stable/2641906

Road Construction Opposing View #27–"In the Pacific Northwest, the two main processes that contribute to sediment production are mass failure and surface erosion from forest roads (Fredriksen 1970, Reid and Dunne 1984). In the Clearwater River basin in the State of Washington, as much as 40 percent of the sediment produced in the watershed was attributed to logging roads (Reid 1980)."

Kahklen, Keith. "A Method for Measuring Sediment Production from Forest Roads." Pacific Northwest Research Station, USDA Forest Service. Research note PNW-RN-529, April 2001. http://www.fs.fed.us/pnw/pubs/rn529.pdf

EA section 3.8 and the associated Soils Resource Technical Report include discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses the direct, indirect, and cumulative effects to slope stability that could result from the road activities proposed under the different alternatives.

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection 3.6.2 (Water Quality).

Road Construction Opposing View #28–"It is indisputable that roads are one of the greatest threats to the ecological integrity of forested systems and associated river, wetland, lake, and coastal ecosystems. Yet, the USFS has failed to adopt a policy that mandates reversing the worst ecological effects of roads, or that precludes incursion of roads into roadless areas. Despite widespread recognition of these facts, the USFS diverts staff and money to extraordinarily costly salvage logging projects at the expense of reducing the extent of the road network or undertaking needed fine-fuels reductions in unburned forests."

Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt from a letter to the Subcommittee on Forests & Forest Health U.S. House of Representatives. 3 July, 2002.

Forest Service policy concerning road management is found in part in the Code of Federal Regulations and Forest Service Manual (FSM) direction. FSM 7710.1 states the following:

1. Travel Management (36 CFR Part 212, Subparts A, B, and C). Subpart A of these regulations establishes requirements for administration of the forest transportation system, including roads, trails, and airfields, and contains provisions for acquisition of rights-of-way. Subpart A also requires identification of the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of NFS lands and use of a science-based roads

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Comment Forest Service Response http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from_beschta.htm

analysis at the appropriate scale in determining the minimum road system. Subpart B describes the requirements for designating roads, trails, and areas for motor vehicle use and for identifying designated roads, trails, and areas on a motor vehicle use map (MVUM). Subpart C provides for regulation of use of over-snow vehicles on NFS roads, on NFS trails, and in areas on NFS lands.

1. FSM 7712, Travel Analysis, states the following:

Travel analysis assesses the current forest transportation system and identifies issues and assesses benefits, problems, and risks to inform decisions related to identification of the minimum road system per 36 CFR Part 212.5(b)(1) and designation of roads, trails and areas for motor vehicle use per 36 CFR Part 212.51. Travel analysis is not a decision-making process. Rather, travel analysis informs decisions relating to administration of the forest transportation system and helps to identify proposals for changes in travel management direction (ex. 01).

The Clear Creek watershed TAR assessed the risks and problems posed by existing roads within the watershed by resource area; risks relating to safety, watershed and aquatics, terrestrial wildlife, noxious weeds, maintenance cost, stream crossings, location within a roadless area, location within a landslide-prone area, and location within a RCA were identified and included in the assessment. Risks associated with each

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individual road were used to develop recommendations for the road system. These recommendations and the process used to develop them are found in the Clear Creek Watershed TAR (USDA Forest Service 2013). Several of these recommendations were included in the transportation management activities proposed under the action alternatives (EA sections 2.4.2 and 2.4.3). EA section 3.11 includes an overview of the outcome of the Clear Creek watershed travel analysis, specific to the Project area. Regarding the construction of new roads into roadless areas, National Forests in Idaho are governed by 36 CFR Part 294, Special Areas; Roadless Area Conservation; Applicability to the National Forests in Idaho; Final Rule. In the case of the Project, no road management activities are proposed in roadless areas (EA section 3.16).

Road Construction Opposing View #29–“Forest fragmentation, as scientists call the intentional felling of woodland, is actually two processes. In populated areas such as the Atlantic seaboard, it means reduction in the size of forest tracts, usually due to suburbanization and development. In less inhabited areas--northern New England, for example--forest fragmentation refers to isolation of one patch of forest from another by logging, or by the building of roads or power lines.”

Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament as experts ponder the decline of dozens of forest species” National Wildlife http://www.nwf.org/News-and-Magazines/National-Wildlife/Birds/Archives/1992/Singing-the-Blues-for-Songbirds.aspx

The specific point this view intends to make about fragmentation relative to the Project is unclear. Refer to the responses to views #1, #14, and #21 for discussions relating to fragmentation. Four of the conservation principles adopted in the 2010 Forest Plan amendments concern fragmentation (see response to view #1); conservation principles are to be used in project design and to inform effects disclosures (refer to Forest Plan guideline WIGU15). The 4 conservation principles regarding fragmentation (along with the other conservation principles, identified in Appendix E of the Forest Plan) were used in the development of the Project alternatives and to inform

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effects disclosures for those alternatives.

Road Construction Opposing View #30–"The compaction of forest road soils is known to reduce aeration, porosity, infiltration rates, water movement, and biological activity in soils. Research indicates that soil bulk density, organic matter, moisture, and litter depths are much lower on roads than on nearby forest lands. Macropores, which provide soil drainage and infiltration, have been shown to significantly decrease in size as a result of road construction and use. Reduced infiltration and increased compaction promote soil erosion, especially during the seasonal southwestern monsoon rains (Elseroad 2001)."

"Physical disturbances caused by road construction and vehicle use create ideal conditions for colonization by invasive exotic plant species. The use of roads by vehicles, machinery, or humans often aids the spread of exotic plant seeds. Once established, they can have long-term impacts on surrounding ecosystems and can be difficult to remove."

"Roads are known to cause habitat fragmentation. Many create ecological 'edges' with different plant species, light levels, and hiding cover, all of which may alter animal survival, reproductive success, and movement patterns. The introduction of exotic plants can disrupt the availability of native vegetation used by wildlife for food and shelter (Trombulak and Frissell 1999)." "Forest roads often develop a water-repellent soil layer caused by lack of vegetative cover and changes in soil composition. This can substantially influence how runoff is processed. Erosion, the formation of water channels beside the road, and increased sediment loads in nearby streams are common results of this process (Baker 2003)." "Because they provide easier access to many forest tracts, forest roads often allow more human-caused fires to be ignited." Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona

The cited reference looks at the dynamics of road networks over time and how they impact landscape patterns. More specifically, the study looked at relationships between road density changes, development, and landscape patterns, focusing on housing development. Regarding wildlife, the reference mentions in a broad context roads as sources of habitat fragmentation, spread of invasive species, and increased human use or presence.

Please refer to the responses to views #1, #14, #15, and #21 for specific information about how the EA addresses road effects to wildlife and wildlife habitat.

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University Ecological Restoration Institute publication Working Paper 12. June, 2005. http://www.eri.nau.edu/en/information-for-practitioners/restoring-forest-roads

Road Construction Opposing View #31–"Almost everywhere people live and work they build and use unimproved roads, and wherever the roads go, a range of environmental issues follows." "Among the environmental effects of unimproved roads, those on water quality and aquatic ecology are some of the most critical. Increased chronic sedimentation, in particular, can dramatically change the food web in affected streams and lakes." "The nearly impervious nature of road surfaces (or treads) makes them unique within forested environments and causes runoff generation even in mild rainfall events, leading to chronic fine sediment contributions." "If we look at the issue of what we need to learn or the research priorities for forest road hydrology, I would argue that the areas of cutslope hydrology and effectiveness of restoration efforts are perhaps most critical." "At a few sites in the mountains of Idaho and Oregon a substantial portion of the road runoff (80–95%) came from subsurface flow intercepted by the cutslope (Burroughs et al., 1972; Megahan, 1972; Wemple, 1998)."

Luce, Charles H. Ph.D., 2002. "Hydrological processes and pathways affected by forest roads: what do we still need to learn?" Hydrologic Processes: 16, 2901–2904. http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%20HP.pdf


Road Construction Opposing View #32–"Roads in the watershed contribute to sediment production by concentrating runoff, thereby increasing sediment load to the stream network. Most unimproved (dirt) roads connect either directly or indirectly with streams and, therefore, act as extensions of stream networks by effectively increasing watershed drainage

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and in subsection

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density and subsequently sediment loads to streams. In the South Fork subwatershed of Squaw Creek, road connectivity has resulted in an increase in effective drainage density of approximately 250%. Throughout the Squaw Creek watershed, it is estimated that dirt roads potentially contribute as much as 7,793 metric tons/year to the watershed sediment budget." Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Road Effects on Stream Channel Networks in an Eastern Sierra Nevada Watershed." Journal of the Nevada Water Resources Association, Volume 2, Number 2, Fall 2005. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_article4.pdf


The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

Road Construction Opposing View #33–“One of the greatest impacts of roads and (especially motorized) trails is their effect on the hydrology of natural landscapes, including the flow of surface and ground water and nutrients. These hydrologic effects are responsible for changes to geomorphic processes and sediment loads in roaded areas (Luce and Wemple 2001).” (pg. 12)

Malecki, Ron W. “A New Way to Look at Forest Roads: the Road Hydrologic Impact Rating System (RHIR)” The Road-RIPorter, Autumn Equinox, 2006 http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and section 3.6.2 (Water Quality). See the response to view #32.

Road Construction Opposing View #34–"A study was made on 344 miles of logging roads in northwestern California to assess sources of erosion and the extent to which road-related erosion is avoidable. At most, about 24 percent of the erosion measured on the logging roads could have been prevented by conventional engineering methods. The remaining 76 percent was caused by site conditions and choice of alignment. On 30,300 acres of commercial timberland, an estimated 40 percent of the total erosion associated with management of the area was found to have been derived


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from the road system."

McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging roads in northwestern California: How much is avoidable?" Journal of Forestry 8(1): 23-26.

http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf

Road Construction Opposing View #35–"Research has shown that roads can have adverse impacts on the water quality on the forest landscape (Authur et al. 1998; Binkley and Brown 1993; Megahan et al. 1991). The forest road system has been identified by previous research as the major source of soil erosion on forestlands (Anderson et. al 1976; Patric 1976; Swift 1984; Van Lear et al. 1997). Furthermore, roads are cited as the dominant source of sediment that reaches stream channels (Packer 1967; Trimble and Sartz 1957; Haupt 1959)." McFero III, Grace, J. "Sediment Plume Development from Forest Roads: How are they related to Filter Strip Recommendations?" An ASAE/CSAE Meeting Presentation, Paper Number: 045015, August 1-4, 2004.

http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf

See response to view #34.

Road Construction Opposing View #36–“Overall, roads had a greater impact on landscape structure than logging in our study area. Indeed, the 3-fold increase in road density between 1950–1993 accounted for most of the changes in landscape configuration associated with mean patch size, edge density, and core area.”

McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and logging on landscape structure in the San Juan Mountains, Colorado (USA)”Landscape Ecology, Volume 16, Number 4 / May, 2001 http://www.springerlink.com/content/w12557624742tv77/


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Road Construction Opposing View #37–“Road construction in remote areas appears to be the major long term impact of resource extraction industries and the most significant problem facing grizzly bears in most locations. Open roads are an influence in all 5 ways that people affect bears. Vehicles on roads can harass bears, displace them from quality habitats, and cause reduced bear use of altered habitats, such as cutting units. Bears that are displaced from roads may cause social disruption in areas away from roads. Finally, roads permit access for many people and some of these will shoot bears.” (Pg. 62)

McLellan, Bruce N. “Relationships between Human Industrial Activity and Grizzly Bears” Bears: Their Biology and Management, Vol. 8 International Conference on Bear Research and Management February 1989 (1990), pp. 57-64 http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/McClellan_8.pdf

Grizzly bears are not known to exist on the Forest.

Road Construction Opposing View #38–“Erosion from forest roads can be a large source of sediment in watersheds managed for timber production.” Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from Forest Roads in Washington State” from a presentation presented at the 2003 Geological Society of America meeting. http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and section 3.6.2 (Water Quality).

Road Construction Opposing View #39–“Today, addressing the adverse impacts of forest roads is consistently identified as one of the highest watershed restoration priorities in U.S. forests—in many forested watersheds in the western United States there is a greater road density than stream density. It is simply irrational to spend millions of dollars subsidizing further forest road construction when we are simultaneously spending millions of dollars to offset detrimental effects associated with


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similar actions in the past.”

Montgomery, David Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm

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Road Construction Opposing View #40–“Nothing is worse for sensitive wildlife than a road. Over the last few decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity - habitat destruction and fragmentation, edge effects, exotic species invasions, pollution, and overhunting - are aggravated by roads. Roads have been implicated as mortality sinks for animals ranging from snakes to wolves; as displacement factors affecting animal distribution and movement patterns; as population fragmenting factors; as sources of sediments that clog streams and destroy fisheries; as sources of deleterious edge effects; and as access corridors that encourage development, logging and poaching of rare plants and animals.”

"Most public agencies disregard the ecological impacts of roads, and attempt to justify timber roads as benefiting recreation and wildlife management. Even when a land manager recognizes the desirability of closing roads, he or she usually contends that such closures would be unacceptable to the public."

“The Forest Service and other public agencies will claim that road closures, revegetation, and other restorative measures are too expensive to be implemented on a broad scale. But much of the approximately $400 million of taxpayers' money squandered annually by the Forest Service on below-cost timber sales goes to road-building. Road maintenance is also expensive. Virtually all of this money could be channeled into road closures and associated habitat restoration. This work would be labor-intensive, and providing income to the many laid off loggers, timber sale planners, and road engineers -- for noble jobs, rather than jobs of destruction!” Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the Road to Destruction” Wildlands CPR http://www.wildlandscpr.org/ecological-effects-roads

The cited reference is an opinion piece that discusses the effects of all roads in general and potential mitigation measures to reduce the effects. Many of the effects discussed in the cited paper are those associated with paved, well-maintained, high-speed roads. However, lower-standard, unpaved Forest roads can have some of the same effects. Specifically, the article addresses the following potential road-related impacts: roadkill, road aversion, isolation of populations, barriers, negative edge effects, invasive weeds, loss of forest interior habitats, brown-headed cowbird parasitism, human access, poaching, collisions, snag removal, and increases in fire ignitions. Under the Impacts on Terrestrial Habitat section, the article states that “A narrow logging road with no maintained verge would not be expected to generate substantial edge effects, particularly if surrounded by a tall forest canopy. In this sense, the road would not differ much from a hiking trail (even trails create some edge effects, however, such as invasion of weedy plants caused by pant-legs dispersal). As forest roads are ‘improved,’ road clearance increases and allows more penetration of sunlight and wind. Edge species are then attracted to these openings. Two-lane roads with maintained rights-of-way and all interstate highways are lined by edge habitat. A forest criss-crossed by improved roads may be largely edge habitat, and its value for conservation of native flora and fauna diminished accordingly.” This rationale acknowledges that small forest roads typically have much less of an impact on wildlife than larger, higher-volume road

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systems.

See the responses to views #1, #14, #15, and #21. The negative road-associated factors noted in the cited reference are included in EA section 3.4.2.3 (Road and Trail Influence on Wildlife and Wildlife Habitat) or are covered by Forest adopted conservation principles and indicators utilized during analysis (Wildlife Technical Report, Appendices A, B1, and B2).

Road Construction Opposing View #41–“Numerous studies have reported lower densities of breeding Ovenbirds (Seiurus aurocapillus) adjacent to forest edges. However, none of these studies has considered habitat use and reproductive success to address mechanisms underlying the observed pattern, and most were conducted in fragmented landscapes and ignored juxtapositions of forest with narrow openings such as roads. We studied the influence of forest roads on Ovenbird density in an extensively forested region of Vermont, evaluating habitat use and reproductive success relative to mechanisms proposed to explain the density-edge relationship. Territory densities on seven study plots were 40% lower within edge areas (0 to 150 m from unpaved roads) than within interior areas (150 to 300 m from roads). We simulated the distribution of Ovenbird territories and concluded that passive displacement, where birds perceive habitat interfaces as boundaries and limit their territories entirely to forest habitat, did not account for the observed density-edge pattern. Territory size was inversely related to distance from roads, providing an alternative explanation for reduced densities near edges and suggesting that habitat quality was higher away from roads. Pairing success was lower within edge areas than within interior zones, but the difference was not statistically significant. The proportion of males that produced fledglings did not differ between edge and interior areas. We conclude that habitat quality for Ovenbirds may be lower within 150 m of unpaved roads in extensive forested landscapes,

Ovenbirds were not analyzed for this project, as this species’ range does not overlap with the analysis area and the species is not found in Idaho. However, the focus of the cited document is primarily the negative edge effects of roads on forest interior species, a concern that does apply to the proposed project. Please refer to the responses to views #1, #14, #15, and #21. Negative edge effects and habitat loss/fragmentation were identified as negative road-associated factors influencing wildlife and habitat (EA section 3.4.2.3). Virtually all focal species included in the analysis are affected to some degree by one or both factors (EA section 3.4.2.3). Road risks were quantified and discussed for individual species in EA section 3.4.3. Road density has specifically been identified as a risk indicator for conservation principles addressing habitat fragmentation. This indicator was utilized by Agency personnel in assessments supporting the development of the Forest WCS (USDA Forest Service 2010) and during planning and analysis for the Project.

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affecting territory density and possibly reproductive success.”

Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): 937-946. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html

Road Construction Opposing View #42–“Increasingly, previously extensive, continuous tracts of forest are being reduced to widely dispersed patches of remnant forest vegetation by logging and road-building, but few measures of the effects of roads on forest fragmentation are available. Fragmentation affects animal populations in a variety of ways, including decreased species diversity and lower densities of some animal species in the resulting smaller patches. This study seeks to quantify the effects of roads and logging activities on forest habitat.” “Roads precipitate fragmentation by dissecting previously large patches into smaller ones, and in so doing they create edge habitat in patches along both sides of the road, potentially at the expense of interior habitat. As the density of roads in landscapes increases, these effects increase as well. McGurk and Fong (1995) considered the additive effects of clearcuts and roads, but did not measure the amount of associated edge habitat. Thus a more direct measurement of the impacts of roads on landscapes is needed.” Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution of Roads to Forest Fragmentation in the Rocky Mountains." Conservation Biology 10: 1098-1106. http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm

This study looked at habitat fragmentation and negative edge effects in coniferous forests of Wyoming; the paper discusses how the fracturing of interior forests may impact forest interior species. The study concluded that roads associated with logging activities often have potentially detrimental impacts on animal and plant communities. The authors suggested that timber harvests should be planned to minimize impacts on the landscape and exacerbation of the current landscape fragmentation problems on many forestlands. Please refer to the responses to views #1 and #14 for more information regarding fragmentation. Additional information is also provided in the responses to view #15 and view #21.

Road Construction Opposing View #43–“Erosion on roads is an important source of fine-grained sediment in streams draining logged basins of the Pacific Northwest. Runoff rates and sediment concentrations from 10 road segments subject to a variety of traffic levels were monitored to produce sediment rating curves and unit hydrographs for different use levels and


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types of surfaces. These relationships are combined with a continuous rainfall record to calculate mean annual sediment yields from road segments of each use level. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface.” Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml

Road Construction Opposing View #44–"Roads are associated with high sediment inputs and altered hydrology, both of which can strongly influence downstream channel habitats. Roads are also important as a source of indirect human impacts and as an agent of vegetation change and wildlife disturbance." "Any ground disturbance increases the potential for erosion and hydrologic change, and roads are a major source of ground disturbance in wildlands. Compacted road surfaces generate overland flow, and much of this flow often enters the channel system, locally increasing peak flows. Localized peak flows are also increased where roads divert flow from one swale into another, and where roadcuts intercept subsurface flows."

"Overland flow from the road surface is a very effective transport medium for the abundant fine sediments that usually are generated on road surfaces. Road drainage also can excavate gullies and cause landslides downslope in swales. Cut and fill slopes are often susceptible to landsliding, and road-related landsliding is the most visible forestry-related erosional impact in many areas." Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss 1994. "What do we know about Roads?" USDA Forest Service.

EA section 3.8 describes TSRC. TSRC is a metric used to characterize how roads influence soil productivity. Section 3.8 discusses the varying ranges of TSRC from road activities by alternative.

EA section 3.8 and the associated Soils Resource Technical Report include discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses the direct, indirect, and cumulative effects to slope stability that could result from the road activities proposed under the different alternatives. Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and section 3.6.2 (Water Quality). The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads

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http://www.fs.fed.us/psw/publications/reid/4Roads.htm have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

Road Construction Opposing View #45–"Disturbances from roadbuilding and logging changed the sediment/discharge relationship of the South Fork from one which was supply dependent to one which was stream power dependent, resulting in substantial increases in suspended sediment discharges." "Road construction and logging appear to have resulted in increases in average turbidity levels (as inferred from suspended sediment increases) above those permitted by Regional Water Quality Regulations." Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. 1979. "Watershed's Response to Logging and Roads: South Fork of Caspar Creek, California, 1967-1976." USDA Forest Service, Research Paper PSW-146.

http://www.fs.fed.us/psw/publications/rice/Rice79.pdf


Road Construction Opposing View #46–"Sediment eroded from gravel roads can be a major component of the sediment budget in streams in this region (Van Lear, et al, 1995)." Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road Erosion, Sediment Transport and Model Validation in the Southern Appalachians." Presented at the Second Federal Interagency Hydrologic Modeling Conference, July 28 – August 1, 2002. http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf


Road Construction Opposing View #47–“Early studies of elk were among the first to address effects of roads on wildlife, establishing a precedent for subsequent research on a wide range of terrestrial and aquatic species. These early elk-roads studies included those reported in a symposium on the topic in 1975 (Hieb 1976), the seminal studies of Jack Lyon in Montana and

The cited document describes the current knowledge on road effects to elk; outlines how a distance-band approach could be used instead of the traditional road density approach to assess road effects to elk and habitat effectiveness; and discusses the broader

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northern Idaho (Lyon 1979, 1983, 1984), the Montana Cooperative Elk-Logging Study (Lyon et al. 1985), and work by Perry and Overly (1977) in Washington and Rost and Bailey (1979) in Colorado. As research and analysis techniques have become more sophisticated, particularly with the advent of geographic information systems (GIS) and high-resolution remote imagery, the study of effects of roads on terrestrial and aquatic communities has evolved into a unique discipline of “road ecology” (Forman et al. 2003). Road effects are far more pervasive than originally believed and include such disparate consequences as population and habitat fragmentation, accelerated rates of soil erosion, and invasion of exotic plants along roadways. Indeed, “in public wildlands management, road systems are the largest human investment and the feature most damaging to the environment” (Gucinski et al. 2001:7). Summaries of the effects of roads on wildlife habitats and biological systems in general have been compiled by Forman and Alexander (1998), Trombulak and Frissell (2000), Gucinski et al. (2001), Forman et al. (2003) and Gaines et al. (2003).” Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger 2005. “Effects of Roads on Elk: Implications for Management in Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor, The Starkey Project: a synthesis of long-term studies of elk and mule deer Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf

implications of road-related policies and land management with regard to elk. This document was used in the effects analysis for elk for the Project and was referenced accordingly.

The elk effects analysis is located in EA section 3.4.3.14. The elk effects analysis for the EA used a distance-band approach to describe security habitat and vulnerability, and summer habitat. The indicator used to assess impacts to elk security habitat and vulnerability was the amount and distribution of security cover habitat greater than 0.5 miles from open motorized routes (EA section 3.4.3.14). Summer habitat was assessed by defining an area of influence within which elk may be displaced from otherwise suitable habitat. A 1,800-meter band was used around all roads that were open to some form of motorized travel, either public or administrative use. A 1,500-meter area-of-influence band was used for trails. These distance bands were based on distances referenced in study findings on the Starkey Experimental Forest in Oregon (Rowland et al. 2005; Wisdom et al. 2004) and reflect those distances beyond which elk response is minimal or greatly diminished. In summary, the analysis found that under Alternative B or Alternative C, the amount of security cover greater than 0.5 miles from an open motorized route would increase slightly (2%) following implementation. The area of influence on summer habitat would decrease slightly (1%) following implementation.

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Road Construction Opposing View #48–“The consequences of road construction to wildlife are generally negative. Roads result in increased human access, habitat fragmentation, disturbance, and in some cases direct mortality due to vehicle collisions.”

“Research has documented an 80% decline in grizzly bear habitat use within 1 km of open roads used by motorized vehicles in Montana9. This has been ascribed either to bears avoiding humans or to the selective over-harvest of bears habituated to humans that would otherwise more fully use areas heavily influenced by people.”

Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads” The Interagency Forest Ecology Study Team (INFEST) newsletter http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm

The cited article addresses road-related habitat issues in Alaska and speaks specifically about effects to grizzly/brown bears. Specific effects included in the discussion are habitat fragmentation, avoidance and underutilization of habitat adjacent to roads, and direct mortality resulting from hunting, poaching, and negative interactions with humans. While grizzly bears do not occur in the Project area, the referenced effects of roads do impact other species, including species analyzed for the Project. The list of project focal species affected by these negative road-associated factors is found in EA section 3.4.2.3, Road and Trail Influence on Wildlife and Wildlife Habitat, Table 3-39. Roads were identified as a risk and considered during the individual species analysis in EA section 3.4.3. Road density is a Forest Plan conservation principle indicator that was utilized during planning and analysis for the Project.

Road Construction Opposing View #49–“The effects of forest roads on hydrology are related to the effects of forest clearing. Most logging requires road access, and the roads often remain after the logging, so there are both short and long-term effects.94 Forest road surfaces are relatively impermeable. Water readily runs over the road surface and associated roadside ditches, often directly to a stream channel, with the net effect of extending channel networks and increasing drainage density.95 In addition to providing conduits for overland flow, forest roads involve slope-cuts and ditching that may intersect the water table and interrupt natural subsurface water movement.96 This diversion of subsurface water may be quantitatively more important than the overland flow of storm water in some watersheds.97 The importance of roads in altering basin hydrology has been underscored

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and section 3.6.2 (Water Quality). The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

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in paired-watershed studies and recent modeling studies.98 “ (Pgs. 730 and 731) Shanley, James B. and BeverleyWemple Ph.D. “Water Quantity and Quality in the Mountain Environment” Vermont Law Review, Vol. 26:717, 2002 http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf

Road Construction Opposing View #50–"Roads are often the major source of soil erosion from forested lands (Patric 1976)." "Generally, soil loss is greatest during and immediately after construction."

Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in the Southern Appalachian Mountains." Southern Journal of Applied Forestry 8: 209-216. 1984. http://cwt33.ecology.uga.edu/publications/403.pdf

Soil erosion or sediment production and delivery resulting from roads and other proposed management activities are fully addressed in EA section 3.6.

Road Construction Opposing View #51–“More subtle causes of habitat loss include the construction of roads and power lines. These linear barriers also have been correlated with a decline in neotropical migrant songbirds (Berkey 1993; Boren et al. 1999; Ortega and Capen 2002). Whether by forest conversion or the construction of roads and power lines, fragmentation subdivides habitat into smaller and smaller parcels. The result is an increase of edge habitat, or the boundary between intact forest and surrounding impacted areas. Small forests with large amounts of edge habitat are a hostile landscape for nesting neotropical migratory songbirds. In these areas, songbirds face two great threats: 1) the loss of eggs and nestlings to predators and, 2) parasitism by cowbirds.” Switalski, Adam “Where Have All the Songbirds Gone? Roads, Fragmentation, and the Decline of Neotropical Migratory Songbirds” Wildlands CPR, September 8, 2003 http://www.wildlandscpr.org/node/213

The cited article addresses potential causes for the apparent decline in songbird populations, listing loss of habitat as the major factor and construction of roads and power lines as a more subtle cause. According to the article, the primary issue in regard to road fragmentation of songbird habitat is creation of edge habitat and the fracturing of interior forest habitat, which can lead to nest predation, brood parasitism, noise disturbance, or avoidance.

EA section 3.4.2.3, Road and Trail Influence on Wildlife and Wildlife Habitat, identified 17 road/trail-associated factors that negatively affect wildlife, including habitat fragmentation and edge effects. The effects of roads were considered in this section and in EA section 3.4.3, which addresses effects to individual species, including migratory bird species. Roads were

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considered a risk indicator for species, as noted in Table 3-39 (EA section 3.4.2.3) and described in the individual species discussions (EA section 3.4.3). The WCS and the 2010 amended Forest Plan identified a set of conservation principles designed to provide for sustainable wildlife habitat and populations on the Forest (USDA Forest Service 2010a, Appendix E). Indicators were developed for each conservation principle (project record, Wildlife Technical Report, Appendix A). Road density is a risk indicator for CPs #2, #6, and #8. The CPs/indicators (USDA Forest Service 2010a, Appendix E) were considered/analyzed during planning/analysis for the Project (project record, Wildlife Technical Report, Appendix B). The effects of roads are discussed in EA section 3.4.2.3 (Road and Trail Influence on Wildlife and Wildlife Habitat) and section 3.4.3 (Endangered Species Act, Region 4 Sensitive, and Focal Species Addressed in Detail); the effects of roads were also considered in an assessment of the conservation principles for project focal species (documented in the Wildlife Technical Report, Appendices B1 and B2).

The specific CPs that were considered/analyzed for the Project are described below. Please refer to the Forest Plan, Appendix E, for additional information regarding conservation principles and use.

• CP #2: Habitat in contiguous blocks is better than fragmented habitat.

• CP #6: Blocks of habitat that are in areas where the direct and indirect effects of human

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disturbance are low are more likely to provide all elements of species’ source environments than areas where it is not.

• CP #8: Continuous, nonfragmented, riparian and wetland systems are better than fragmented habitat.

Road Construction Opposing View #52–“Roads are a widespread and increasing feature of most landscapes. We reviewed the scientific literature on the ecological effects of roads and found support for the general conclusion that they are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads of all kinds have seven general effects: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans. Road construction kills sessile and slow-moving organisms, injures organisms adjacent to a road, and alters physical conditions beneath a road. Vehicle collisions affect the demography of many species, both vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly successful. Roads alter animal behavior by causing changes in home ranges, movement, reproductive success, escape response, and physiological state. Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all species and ecosystems are equally affected by roads, but overall the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems. More

The cited reference is a literature review that addresses the effects of roads on terrestrial and aquatic resources. It recommends building no roads in sparsely or unroaded areas and encourages removal of unneeded roads. The article identifies the following road-related impacts: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans (hunting, general disturbance, landscape modification).

EA section 3.4.2.3, Road and Trail Influence on Wildlife and Wildlife Habitat, identified 17 road/trail-associated factors that negatively affect wildlife, including snag reduction, down log reduction, habitat loss and fragmentation, edge effects, hunting, trapping, poaching, collection, harassment or disturbance at specific use sites, collisions, movement barrier, displacement or avoidance, chronic negative interactions with humans, physiological response, snow compaction, routes for competitors and predators, and noxious weed effects. The effects of roads are also discussed in EA section 3.4.3, which addresses effects to individual species. Roads were considered a risk indicator for species as noted in Table 3-39 (EA

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experimental research is needed to complement post-hoc correlative studies. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic biota.” Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. “Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, February 2000 http://www.transwildalliance.org/resources/200922144524.pdf

section 3.4.2.3) and described in the individual species discussions (EA section 3.4.3). Please refer to the responses to views #1, #14, #15, and #21 for additional information.

EA section 3.8 describes TSRC. TSRC is a metric used to characterize how roads influence soil productivity. Section 3.8 discusses the varying ranges of TSRC from road activities by alternative. EA section 3.8 and the associated Soils Resource Technical Report include discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses direct, indirect, and cumulative effects to slope stability that could result from the road activities proposed under the different alternatives.

Water quality and the effects of roads on sedimentation were analyzed, and the discussion is included in the Hydrology section of the EA. This discussion can be found in section 3.6 (Hydrology) and section 3.6.2 (Water Quality). The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA.

Chemical contaminants/nutrients are addressed in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA. A design feature, WF-18 (section 2.4.4.9), was

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specifically developed to minimize or avoid effects to resources from application of magnesium chloride during dust abatement activities.

Road Construction Opposing View #53–"Roads are a major contributor to habitat fragmentation because they divide large landscapes into smaller patches and convert interior habitat into edge habitat. As additional road construction and timber harvest activities increase habitat fragmentation across large areas, the populations of some species may become isolated, increasing the risk of local extirpations or extinctions (Noss and Cooperrider 1994)."

"Habitat fragmentation creates landscapes made of altered habitats or developed areas fundamentally different from those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994 in Meffe et al. 1997). Adverse effects of habitat fragmentation to both wildlife populations and species include:

"Increased isolation of populations or species, which leads to:

• Adverse genetic effects; i.e. inbreeding depression (depressed fertility and fecundity, increased natal mortality) and decreased genetic diversity from genetic drift and bottlenecks,

• Increased potential for extirpation of localized populations or extinction of narrowly distributed species from catastrophic events such as hurricanes, wildfires or disease outbreaks,

• Changes in habitat vegetative composition, often to weedy and invasive species,

• Changes in the type and quality of the food base, • Changes in microclimates by altering temperature and moisture

regimes, • Changes in flows of energy and nutrients,

The cited document provides guidance to assist resource specialist in assessing the potential impacts of roads and highways on terrestrial and aquatic habitats, species, and ecosystem processes. It is a review document compiled of relatively current peer-reviewed and scientific “gray” literature, and it presents a range of potential impacts of roads and highways to species, habitats, and ecological processes. The document concentrates on elk but is applicable to most other wildlife species. Please refer to the responses to views #1, #14, #15, #21, #47, and #51.

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• Changes in the availability of cover and increases edge effect, bringing together species that might otherwise not interact, potentially increasing rates of predation, competition and nest parasitism, and

• Increased opportunities for exploitation by humans, such as poaching or illegal collection for the pet trade."

Watson, Mark L. "Habitat Fragmentation and the Effects of Roads on Wildlife and Habitats." Background and Literature Review 2005. http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/2004EffectsofRoadsonWil dlifeandHabitats.pdf

Road Construction Opposing View #54–"Our analysis also indicated that >70 percent of the 91 species are affected negatively by one or more factors associated with roads." "Roads in forested areas increase trapping pressures for martens and fishers, resulting in significantly higher captures in roaded versus unroaded areas (Hodgman and others 1994) and in logged versus unlogged areas, in which the difference was again attributed to higher road densities in logged stands (Thompson 1994). Secondary roads also might increase the likelihood that snags and logs will be removed for fuel wood. This could impact fishers, martens and flammulated owls, and also could have a negative effect on the prey base for goshawks (Reynolds and others 1992)." "An additional, indirect effect of roads is that road avoidance leads to underutilization of habitats that are otherwise high quality." Wisdom, Michael J., Richard S. Holthausen Ph.D. Barbara C. Wales Ph.D., Christina D. Hargis Ph.D. Victoria A. Saab Ph.D., Danny C. Lee Ph.D. Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000.

The cited reference was used as a foundational component in the development of the Forest WCS (Nutt et al. 2010), providing information and guidance on species habitat associations and relationships for species of the Interior Columbia River Basin. The WCS was integrated into the 2010 Forest Plan. Please refer to the responses to views #1, #14, #15, #21, #47, and #51. The EA analyzed potential effects to the fisher (EA section 3.4.3.5), flammulated owl (EA section 3.4.3.6), and northern goshawk (EA section 3.4.3.8) and considered the effects of roads on these species.

The American marten was not analyzed for the Project. This species does not have status as a threatened, endangered, candidate, proposed, Region 4 sensitive, or management indicator species, and the species was not selected as a project focal species. The effects of roads on snags and logs (marten habitat components) are discussed in EA section 3.4.2.3, and effects to snags and coarse woody debris are discussed in EA section

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http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wisdom_et_al_2000/Vol_2a.pdf

3.4.2.2 and section 3.2.6.

Road Construction Opposing View #55–“According to the DEIS, the Forest now manages a total of 5,914 miles of roads across the Forest. Scientific literature has established that roads have numerous widespread, pervasive and, if left untreated, long-lasting biological and physical impacts on aquatic ecosystems that continue long after completion of construction. (Angermeier et al. 2004). Roads increase surface water flow, alter runoff patterns, alter streamflow patterns and hydrology, and increase sedimentation and turbidity. Roads are the main source of sediment to water bodies from forestry operations in the United States. (US EPA 2002). Road construction can lead to slope failures, mass wasting and gully erosion. Road crossings can act as barriers to movement for fish and other aquatic organisms, disrupting migration and reducing population viability. (Schlosser and Angermeier 1995). Chemical pollutants that enter streams via runoff, such as salt and lead from road use and management, compound these impacts. Most of these adverse effects are persistent and will not recover or reverse without human intervention. The techniques for road remediation are well established, agreed upon and readily available. (Weaver et al. 2006).” (Pg. 2)

Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou National Forest Travel Management Team http://www.pacificrivers.org/protection-defense/comment-letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf

EA section 3.8 and the associated Soils Resource Technical Report include discussion on the current science and guidance applied to the analysis of management activities that may influence slope stability. Section 3.8 discloses direct, indirect, and cumulative effects to slope stability that could result from the road activities proposed under the different alternatives.


The effects of roads on water drainage patterns are included in the analysis in the EA. Change in drainage network and change in peak/base flows due to roads have been analyzed, and the discussion is included in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA. Chemical contaminants/nutrients are addressed in section 3.6 (Hydrology) and section 3.7 (Fisheries) of the EA. A design feature, WF-18 (section 2.4.4.9), was specifically developed to minimize or avoid effects to resources from application of magnesium chloride during dust abatement activities. Best management practices (BMPs) used to address road management needs were developed from those provided in the National Core BMP Technical Guide

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http://www.pacificrivers.org/protection-defense/comment-letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf

http://www.pacificrivers.org/protection-defense/comment-letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf



(USDA Forest Service, FS-990a, April 2012).

Road Construction Opposing View #56–“Fires do not leave a large road network in place (assuming the blaze was not suppressed otherwise there may be dozer lines, etc.). Logging creates roads that fragment habitat and generally increase human access, both of which affect the use of the land by wildlife. Moreover, roads and logging equipment can become vectors for the dispersal of weeds.”

Wuerthner, George 2008 “Ecological Differences between Logging and Wildfire” http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html

The cited article is an opinion piece that addresses the ecological differences of logging compared to wildfire. The author discusses what he considers the benefits of wildfire and the impacts from logging; he then describes the ecosystem functions performed by fire. Potential road-related impacts listed in the article include habitat fragmentation, human access, disturbance, habitat avoidance (grizzly bears), hunting, poaching, and vectors for invasive weeds.

Please refer to the responses to view #1 and view #40.

Road Construction Opposing View #57–“Forest fragmentation occurs when large, contiguous blocks of forest are broken up into isolated islands by development, roads, or clearing for agriculture. Just as inbreeding among the royal families of Europe spread hemophilia, forest fragmentation negatively impacts the long term sustainability of both plant and animal communities. Geographic isolation results in inbreeding and diminishes biodiversity.”

Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Land Trust newsletter, 2004 http://www.ourbetternature.org/forestfrag.htm

The cited article broadly discusses the potential causes of forest fragmentation, including road-related impacts, impacts to human health, and economic impacts. Road-related impacts listed in the article include habitat fragmentation, inbreeding and diminished biodiversity stemming from isolation of populations, roadkill, and increased predation of woodland birds.

Please refer to the responses to view #1 and view #40.

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http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html

http://www.ourbetternature.org/forestfrag.htm


Table D-118. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment—Opposing Views—Attachment #9a—Glyphosate


Glyphosate safety opposing view #1 - “Chronic Effects of Glyphosate versus Formulations: Throughout this study glyphosate itself showed no chronic effects on developing tadpoles. The tadpoles reared in the formulations Roundup Original® and Transorb® did show significant physical abnormalities. Abnormalities were also found upon exposure to the surfactant POEA. For all endpoints POEA showed practically identical results to the Roundup Original® formulation whereas the same cannot be said for the Transorb® formulation. The surfactant used in the Transorb formulation is not known (being protected as “Trade Secret”), but has been described as a “surfactant blend”. This “surfactant blend” may be responsible for inhibition of metamorphosis, as well as the skewed sex ratio towards female seen in the present study.

Developmental abnormalities induced by Roundup are likely a result of endocrine disruption. The thyroid axis can be greatly affected by corticoids and sex steroids which influence hypothalamic and pituitary control (See Dodd and Dodd, 1976, and Hayes, 1997 for review). Corticoids, sex steroids and prolactin have caused delayed metamorphosis and decreased size by both antagonizing and inhibiting thyroid action (Hayes, 1997). Sex steroid can induced sex reversal and intersex in amphibians and mammals, while low thyroid levels interfere with vitellogenesis. A concentration at which the animals were not effected (NOEC) by The Roundup formulations was not determined by this study.

Howe, Christina Ph.D., Michael Berrill Ph.D., and Bruce D. Pauli 2001 “The Acute and Chronic Toxicity of Glyphosate-Based Pesticides in Northern Leopard Frogs” http://www.trentu.ca/biology/berrill/Research/Roundup_Poster.htm

As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses using an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. A design feature will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identifies applicable SOPs.

To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas.

Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.

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[a] Glyphosate safety opposing view #2 - “After spraying, glyphosate herbicides can remain in soils for long periods. The herbicide can drift onto neighbouring fields, streams or hedges… Glyphosate reduces nitrogen fixation. Roundup reduces the growth of mycorrhizal fungi.

[b] Roundup kills beneficial insects. It wipes out habitat for birds and animals… It is hazardous to earthworms.

[c] Glyphosate causes genetic damage to fish. It is "extremely lethal to amphibians", according to assistant professor of biology Rick Relyea at the University of Pittsburgh.

[d] Roundup can increase the spread and severity of plant diseases (see WRM Bulletin no. 18).

[e] “Glyphosate herbicides can have a range of impacts on human health, including genetic damage, skin tumours, thyroid damage, anaemia, headaches, nose bleeds, dizziness, tiredness, nausea, eye and skin irritation, asthma and breathing difficulties. Several studies have indicated a link between glyphosate herbicides and non-Hodgkin's lymphoma, a type of cancer.”

Lang, Chris “Glyphosate herbicide, the poison from the skies” WRM's bulletin Nº 97, August 2005 http://www.wrm.org.uy/bulletin/97/Glyphosate.html

As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. A design feature will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identifies applicable SOPs. Regarding the use of herbicides, the Agency does not rely on any single source of information to make a determination of what would be the proper and safe use of herbicides. A primary source of information that guides the Agency in its use of herbicides is the “Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas.” This document was published by an independent conservation organization, “The Nature Conservancy Wildland Invasive Species Team” (Tu et al. 2001 as revised through 2005).

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. [a] Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high

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adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Feng and Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990; Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005] The effects to fungi are addressed by the following information: “Roberts and Berk (1993) investigated the effects of Roundup® on chemoattraction of the protozoa Tetrahymena pyriformis and found that it significantly interfered with chemoreception but not motility. Doses of glyphosate <10 ppm were stimulatory to soil microflora including actinomycetes, bacteria, and fungi, while concentrations >10 ppm had detrimental impacts on microflora populations in one study (Chakravarty and Sidhu 1987). While some short-term studies (<30 days) found glyphosate caused significant

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impacts to microbial populations, Roslycky (1982) found that these populations rebound from any temporary increase or decrease within 214 days. Similarly, Tu (1994) found that microorganisms recovered rapidly from treatment with glyphosate and that the herbicide posed no long-term threat to microbial activities” (Tu et al. 2001, as revised through 2005). [b] and [c] Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.” [d] Regarding effects to plants, Tu et al. (2001 as revised through 2005) states the following: “Glyphosate is metabolized by some, but not all plants (Carlisle and Trevors 1988). It is harmless to most plants once in the soil because it is quickly adsorbed to soil particles, and even when free, it is not readily absorbed by plant roots (Hance 1976). The half-life of glyphosate on foliage has been estimated at 10.4 to 26.6 days (Newton et al. 1984). Roy et al. (1989b) found 14% and 9% of applied glyphosate accumulated in the berries of treated blueberry and raspberry bushes,

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respectively. These residues dissipated from the fruit with a half-life of <20 days for blueberries and <13 days for raspberries (Roy et al.1989b).” The article referenced by Mr. Artley does not include sources from which the conclusions concerning spread and severity of plant diseases can be reviewed and validated as to applicability to the Project. [e] Tu et al. (2001) identify safety measures as follows: “Safety Measures:

Some glyphosate formulations are in EPA toxicity categories I and II (the two highest categories) for eye and skin exposure. Care should be taken and protective clothing worn to prevent accidental contact of these formulations on skin or eyes.

Human Toxicology: EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).”

[a] Glyphosate safety opposing view #3 - “In California, where there is a mandatory system of reporting pesticide poisoning, Glyphosate is the third most common cause of pesticide illness in farm workers. It is the most common form of reported pesticide poisoning in landscape gardeners.” “Two separate studies in Sweden have linked exposure to Glyphosate to Hairy Cell Leukemia and Non Hodgkins Lymphoma. These types of cancers were extremely rare, however non-Hodgkins lymphoma is the most rapidly increasing cancer in the Western world. It has risen by 73% in the USA since 1973. Another study has found a higher incidence of Parkinson disease amongst farmers who used herbicides, including

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Pesticide application on the Forest (Forest) is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides.

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glyphosate.”

“Other studies show that Glyphosate and commercial herbicides containing Glyphosate cause a range of cell mutations and damage to cell DNA. These types of changes are usually regarded as precursors to cancer and birth defects.” “Studies show that exposure to Glyphosate is associated with a range of reproductive effects in humans and other species. Research from Ontario, Canada found that a father's exposure to Glyphosate was linked to an increase in miscarriages and premature births in farm families.”

[b] “Glyphosate caused a decrease in the sperm count of rats and an increase in abnormal and dead sperms in rabbits. Pregnant rabbits exposed to Glyphosate had a decrease in the weight of their babies.”

Leu, Andre “Monsanto's Toxic Herbicide Glyphosate: A Review of its Health and Environmental Effects” Organic Producers Association of Queensland, May 15, 2007 http://www.organicconsumers.org/articles/article_5229.cfm

To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Individuals applying pesticides are required to wear personal protective equipment.

Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day.

[b] Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

[a] Glyphosate safety opposing view #4 - “Symptoms of exposure to glyphosate include eye irritation, blurred vision, skin rashes, burning or itchy skin, nausea, sore throat and difficulty breathing, headache, lethargy, nose bleeds and dizziness.

In lab tests, glyphosate and herbicides containing glyphosate caused genetic damage to human and animal cells. Studies of farmers and other people exposed to glyphosate herbicides link this exposure to increased risks of cancer, miscarriages and attention deficit disorder. Additional laboratory tests have confirmed the results of these studies. Laboratory evidence indicates that glyphosate herbicides can reduce production of sex hormones.

[a] EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). “LD50” is a measurement used to describe an herbicide’s toxicity; the LD50 is the dose received orally or dermally that kills half the population of study animals. Very few people, even among applicators, are exposed to herbicide doses as high as the LD50, especially when proper safety precautions are taken (Tu et al. 2011). All pesticides used on the Forest for vegetation management have been evaluated for risks to human health and the environment. These risk assessments are

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[b] Studies of glyphosate contamination of water are limited, but new results indicate that it can easily contaminate streams in both agricultural and urban areas. [c] Glyphosate herbicides cause more off-target damage incidents than all but one other herbicide — 2, 4-D. [d] Glyphosate herbicides cause genetic damage and harm to the immune system in fish. In frogs, glyphosate herbicides cause genetic damage and abnormal development.” Long, Cheryl. “Hazards of the World’s Most Common Herbicide” Mother Earth News, October/November 2005 http://www.motherearthnews.com/Organic-Gardening/2005-10-01/Hazards-of-the-Worlds-Most-Common-Herbicide.aspx

available for review from the Forest Health Protection Unit of USFS State and Private Forestry (Black 2013). Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified

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by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas.

Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. [c] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize herbicide application to nontarget organisms and areas. These include not applying herbicides if wind speed exceeds 8 mph (or less, depending on the herbicide label) and not applying herbicides if weather reports indicate rainfall would occur within 3 hours after application.

Total losses to runoff generally do not exceed 5%–10% of the total applied, even following heavy rains (Taylor and Glotfelty 1988). High soil adsorption capacity, low rates of application, and low rainfall reduce total runoff and contamination of local waterways (Bovey et al. 1978). As per standard management practices on the Forest, application rates would be the minimum rates necessary to control target species. These rates are often below those recommended on the label.

[d] Tu et al. (2001, as revised through 2005) concluded

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that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

Glyphosate safety opposing view #5 - “Very low doses of some types of the herbicide Roundup can endocrine disruptor the formulations' toxicity may be tied to their "inactive" ingredients rather than the active weed-killing ingredient glyphosate.

French scientists report that a number of Roundup formulations tested at very dilute concentrations can alter hormone actions and cause human liver cells to die within 24 hours of treatment.

The toxicity of some of the formulations was independent of how much glyphosate - the active herbicide in Roundup - they contained, suggesting it is other "inert" ingredients that may alone - or in combination with each other and/or the weed killer - assault the cells. This study's results are similar to prior studies - as reported in a recent Environmental Health News article - that find human embryo cells are affected more by the Roundup formulations and an inert ingredient than by the active ingredient.

The levels of Roundup used in this study are similar to what is typically found in food crops or animal feed treated with Roundup. Because of this, it is possible that people, livestock and wildlife may be exposed to levels of the herbicide mix that can damage cells.” Martin, Negin P. Ph. D. “Monsanto's Roundup More Deadly to Liver Cells than Glyphosate Alone” Organic Consumers Assn., August 18, 2009 http://www.organicconsumers.org/articles/article_18842.cfm

Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.

Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides and surfactants. These are briefly described below.

Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013). Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be

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working in or around the area the same day.

Glyphosate safety opposing view #6 - “A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].

In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

“New Study Links Monsanto's Roundup to Cancer” Organic Consumers Association PRESS RELEASE, June 22, 2009 http://www.organicconsumers.org/Monsanto/glyphocancer.cfm

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record.

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.

Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013). Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day.

Glyphosate safety opposing view #7 - “Safe, effective management and control of established exotic-weeds requires input from and the joint effort of scientists from several distinct disciplines, including biological control specialists, chemical control specialists, wildlife ecologists, animal science specialists, economists, and the public. The basic premise of IPM centers on

As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use

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employing first biological and other non-chemical pest controls, with the use of chemical pesticides only as a last resort. Since pesticide effects on public health and the environment cost the United States a conservatively estimated $9 billion per year, this should be a much welcome change.”

Pimentel, David Ph.D., “True lntegrated Weed Management: Pesticides as a last resort”from a Beyond Pesticides publication, 2004 http://www.beyondpesticides.org/infoservices/pesticidesandyou/Fall%2004/Montanas%20War%20On%20Weeds.pdf

of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. Options to be utilized for noxious weed control in the Project area include biological control agents; mechanical treatments such as hand pulling, chopping, and cutting; and herbicides specifically formulated for forests, rangelands, and riparian areas (Black 2013).

Glyphosate safety opposing view #8 - “Glyphosate was ranked third worst among all pesticides causing severe health problems among those working in agriculture in the State of California.” “The application of glyphosate causes the production of phyto-oestrogens in legumes. These phyto-oestrogens mimic the role of hormones in the bodies of mammals who ingest them. Hence, they may cause severe reproductive system disruptions. The data on estrogen-content of the plants submitted by Monsanto does not reflect the real scope of this problem, because the tested plants were grown in a glyphosate-free environment.” “Possible human health impacts of Monsanto's transgenic glyphosate-resistant soybeans” Third World Network http://www.twnside.org.sg/title/weiz-cn.htm

Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

All pesticides used on the Forest for vegetation management have been evaluated for risks to human health and the environment. These risk assessments are available for review from the Forest Health Protection Unit of USFS State and Private Forestry (Black 2013).

[a] Glyphosate safety opposing view #9 - “Glyphosate (N-(phosphonomethyl) glycine, C3H8NO5P), a herbicide, used to control unwanted annual and perennial plants all over the world. Nevertheless, occupational and environmental exposure to pesticides can pose a threat to nontarget species including human beings.

[b] Therefore, in the present study, genotoxic effects of the herbicide

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize herbicide application to nontarget organisms and areas. These include not applying herbicides if wind speed exceeds 8 mph (or less, depending on the herbicide

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http://www.twnside.org.sg/title/weiz-cn.htm



glyphosate were analyzed by measuring chromosomal aberrations (CAs) and micronuclei (MN) in bone marrow cells of Swiss albino mice. A single dose of glyphosate was given intraperitoneally (i.p) to the animals at a concentration of 25 and 50 mg/kg b.wt. Animals of positive control group were injected i.p. benzo(a)pyrene (100 mg/kg b.wt., once only), whereas, animals of control (vehicle) group were injected i.p. dimethyl sulfoxide (0.2 mL). Animals from all the groups were sacrificed at sampling times of 24, 48, and 72 hours and their bone marrow was analyzed for cytogenetic and chromosomal damage. Glyphosate treatment significantly increases CAs and MN induction at both treatments and time compared with the vehicle control (P<.05). The cytotoxic effects of glyphosate were also evident, as observed by significant decrease in mitotic index (MI). The present results indicate that glyphosate is clastogenic and cytotoxic to mouse bone marrow.” Prasad, Sahdeo, Ph.D., Smita Srivastava Ph.D., Madhulika Singh Ph.D., and Yogeshwer Shukla Ph.D. “Clastogenic Effects of Glyphosate in Bone Marrow Cells of Swiss Albino Mice” Journal of Toxicology Volume 2009 (2009), Article ID 308985, 6 pages http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2809416/

label) and not applying herbicides if weather reports indicate rainfall would occur within 3 hours after application. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013). [b] Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

[a] Glyphosate safety opposing view #10 - “PITTSBURGH--The herbicide Roundup® is widely used to eradicate weeds. But a study published today by a University of Pittsburgh researcher finds that the chemical may be eradicating much more than that.

Pitt assistant professor of biology Rick Relyea found that Roundup®, the second most commonly applied herbicide in the United States, is "extremely lethal" to amphibians. This field experiment is one of the most extensive studies on the effects of pesticides on nontarget organisms in a natural setting, and the results may provide a key link to global amphibian declines.

[b] In a paper titled "The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities," published in the journal Ecological Applications, Relyea examined how a pond's entire

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize herbicide application to nontarget organisms and areas. These include not applying herbicides if wind speed exceeds 8 mph (or less, depending on the herbicide label) and not applying herbicides if weather reports indicate rainfall would occur within 3 hours after application.

Total losses to runoff generally do not exceed 5%–10% of the total applied, even following heavy rains (Taylor and Glotfelty 1988). High soil adsorption capacity, low

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http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2809416/



community--25 species, including crustaceans, insects, snails, and tadpoles--responded to the addition of the manufacturers' recommended doses of two insecticides--Sevin® (carbaryl) and malathion--and two herbicides--Roundup® (glyphosate) and 2,4-D.

Relyea found that Roundup® caused a 70 percent decline in amphibian biodiversity and an 86 percent decline in the total mass of tadpoles. Leopard frog tadpoles and gray tree frog tadpoles were completely eliminated and wood frog tadpoles and toad tadpoles were nearly eliminated. One species of frog, spring peepers, was unaffected.”

Reeves, Walter. “Roundup®highly lethal to amphibians, finds University of Pittsburgh researcher” The Georgia Gardener, 2009 http://www.walterreeves.com/tools_chemicals/article.phtml?cat=22&id=889

rates of application, and low rainfall reduce total runoff and contamination of local waterways (Bovey et al. 1978). [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.

Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

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Glyphosate safety opposing view #11 - “For all nine species of larval anurans, the Kruskal-Wallis analyses detected significant effects of pesticide concentration on mortality (p # 0.002; Fig. 1). The subsequent mean comparisons, using Dunnett’s tests, indicated the lowest concentrations that caused significantly greater mortality than the control (p , 0.05). For two species (bullfrogs and spring peepers), 1 mg a.e./L of glyphosate caused significantly greater mortality than the control. For the remaining seven species (green frogs, leopard frogs, wood frogs, Cascades frogs, American toads, western toads, and gray tree frogs), 2 mg a.e./L of glyphosate was the lowest concentration to cause significantly greater mortality than the control. Based on the probit analyses, the estimated LC5096-h values for the nine species of larval anurans ranged from 0.8 to 2.0 mg a.e./L (Table 2).”

Relyea, Rick A. Ph.D. and Devin K. Jones “The Toxicity of Roundup Original Max to 13 Species of Larval Amphibians” Environmental Toxicology and Chemistry, Vol. 28, No. 9, pp. 2004–2008, 2009 http://www.pitt.edu/news2009/Roundup.pdf


Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

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Glyphosate safety opposing view #12 – [a] “A recent study of Roundup presents new evidence that the glyphosate-based herbicide is far more toxic than the active ingredient alone. The study, published in the June 2005 issue of Environmental Health Perspectives, reports glyphosate toxicity to human placental cells within hours of exposure, at levels ten times lower than those found in agricultural use. The researchers also tested glyphosate and Roundup at lower concentrations for effects on sexual hormones, reporting effects at very low levels. This suggests that dilution with other ingredients in Roundup may, in fact, facilitate glyphosate's hormonal impacts.”

[b] “The evidence presented in the recent study is supported by earlier laboratory studies connecting glyphosate with reproductive harm, including damaged DNA in mice and abnormal chromosomes in human blood. Evidence from epidemiological studies has also linked exposure to the herbicide with increased risk of non-Hodgkin's lymphoma, and laboratory studies have now begun to hone in on the mechanism by which the chemical acts on cell division to cause cancer. A Canadian study has linked glyphosate exposure in the three months before conception with increased risk for miscarriage and a 2002 study in Minnesota connected glyphosate exposure in farm families with increased incidence of attention deficit disorder.” “Rethinking Roundup” Pesticide Action Network North America (PANNA) Update, August 5, 2005 http://www.panna.org/node/466


[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species. [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

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Glyphosate safety opposing view #13 - “Our studies show that glyphosate acts as a disruptor of mammalian cytochrome P450 aromatase activity from concentrations 100 times lower than the recommended use in agriculture, and this is noticeable on human placental cells after only 18 hr, and it can also affect aromatase gene expression. It also partially disrupts the ubiquitous reductase activity but at higher concentrations. Its effects are allowed and amplified by at least 0.02% of the adjuvants present in Roundup, known to facilitate cell penetration, and this should be carefully taken into account in pesticide evaluation. The dilution of glyphosate in Roundup formulation may multiply its endocrine effect. Roundup may be thus considered as a potential endocrine disruptor. Moreover, at higher doses still below the classical agricultural dilutions, its toxicity on placental cells could favor some reproduction problems.” Richard, Sophie Ph.D., Safa Moslemi Ph.D., Herbert Sipahutar, Nora Benachour and Gilles-Eric Seralini Ph.D., 2005 “Differential effects of glyphosate and Roundup on human placental cells and aromatase”

Mindfully.org http://www.mindfully.org/Pesticide/2005/Glyphosate-Roundup-Placental24feb05.htm

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species.

Glyphosate safety opposing view #14 - “There are serious health implications from the use of this pesticide. There is a long list of reported toxic effects from glyphosate exposure and this Swedish study provides compelling evidence of the links between glyphosate and cancer.”

“Swedish study shows links between glyphosate and cancer” The European NGO Network on Genetic Engineering, 1999 http://www.gene.ch/genet/1999/Jun/msg00018.html



Individuals applying pesticides are required to wear

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http://www.mindfully.org/Pesticide/2005/Glyphosate-Roundup-Placental24feb05.htm

http://www.gene.ch/genet/1999/Jun/msg00018.html



personal protective equipment.


Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Glyphosate safety opposing view #15 - “This review suggests that the silvicultural use of glyphosate needs to be re-evaluated with respect to non-target impacts on amphibians in B.C. In addition, knowledge gaps hinder effective and realistic assessment of these impacts. Glyphosate impacts can be species-specific in amphibians, but acute toxicity values are known for only two native B.C. amphibians (the Wood Frog, Rana sylvatica, and the Leopard Frog, R. pipiens). The impact of glyphosate herbicides on salamander species and on terrestrial stages of amphibians is not well understood. There is insufficient information on the levels of glyphosate contamination in small ephemeral wetlands, which are favoured habitats of amphibians, and which may be exposed to direct overspraying with herbicide under current use guidelines. Although the surfactant in glyphosate herbicides, POEA, has been identified as potentially the primary ingredient causing toxicity to amphibians, the option of using surfactants of lower toxicity has not been assessed. These knowledge gaps need to be addressed so that best management practices can be developed to minimize non-target impacts on amphibians from the use of glyphosate herbicides in

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther

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forestry.” (Pg. iii)

Govindarajulu, Purnima P. Ph.D. “Literature review of impacts of glyphosate herbicide on amphibians: What risks can the silvicultural use of this herbicide pose for amphibians in B.C.?”

British Columbia Ministry of Environment, Wildlife Report No. R-28, June 2008 http://www.llbc.leg.bc.ca/public/pubdocs/bcdocs/442206/finishdownloaddocument.pdf

than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #16 - “E. Wider ecological concerns of the genetically engineered soya beans

1. Glyphosate is a broad-spectrum herbicide which will have major impacts on biodiversity (see Greenpeace Report, 1998, and references therein). It kills all plants indiscriminately. This will destroy wild plants as well as insects, birds, mammals and other animals that depend on the plants for food and shelter. In addition, Roundup (Monsanto's formulation of glyphosate) can be highly toxic to fish. Glyphosate also harms earthworms and many beneficial mycorrhizal fungi and other microorganisms that are involved in nutrient recycling in the soil. It is so generally toxic that researchers are even investigating its potential as an antimicrobial (Roberts et al, 1998).”

Affidavit submitted by Mae-Wan Ho Ph.D. , August 12, 1998 http://www.i-sis.org.uk/greenpeace.php?printing=yes

Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

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http://www.i-sis.org.uk/greenpeace.php?printing=yes



Glyphosate safety opposing view #17 - “Glyphosate was formerly considered relatively non-toxic however there is now a considerable body of evidence for deleterious effects of Roundup, glyphosate and its adjuvants on a wide range of non-target species, including humans.

In 2003 the Danish Government announced unprecedented restrictions on glyphosate following analyses which demonstrated that it had been percolating through the soil and polluting the ground water at a rate 5-times that allowable for drinking water. Subsequently, another study confirmed that both glyphosate and its degradation product amino-methylphosphonic acid (AMPA) can leach through structured soils thereby posing a potential risk to the aquatic environment (5). More recently, an analytical method for glyphosate and AMPA based on liquid chromatography coupled to electrospray tandem mass spectrometry has been applied to water samples previously found to contain glyphosate (6). The glyphosate concentrations in the re-anaylzed samples were found to be 2 – 14 –fold higher than previously (6) suggesting that contamination of groundwater and other aquatic systems by glyphosate may be even greater than previously thought.” Brennan-Rieder, Denise Ph.D. June, 2008 “PROPOSED COSMETIC PESTICIDE BAN IN PROVINCE OF ONTARIO SCIENTIFIC BASIS FOR BANNING BOTH SALE AND USE OF SYNTHETIC PESTICIDES” http://www.pesticidereform.ca/RoundupDrBrennan-Rieder.PDF


Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Feng and Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990; Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005]

Glyphosate safety opposing view #18 – [a]“1. Glyphosate was ranked third worst among all pesticides causing severe health problems among those working in agriculture in the State of California.

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize

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[b] 2. The application of glyphosate causes the production of phyto-oestrogens in legumes. These phyto-oestrogens mimic the role of hormones in the bodies of mammals who ingest them. Hence, they may cause severe reproductive system disruptions. The data on estrogen-content of the plants submitted by Monsanto does not reflect the real scope of this problem, because the tested plants were grown in a glyphosate-free environment (see above).”

Tappeser, Beatrix Ph.D. and Christine von Weizsacker “Possible human health impacts of Monsanto's transgenic glyphosate-resistant soybeans” Third World Network http://www.twnside.org.sg/title/weiz-cn.htm

human exposure to herbicides. These are briefly described below.

• Individuals applying pesticides are required to wear personal protective equipment.

• Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day.

[b] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

Glyphosate safety opposing view #19 – [a] “A recently published study by Italian researchers [3] examined the toxicity of four popular glyphosate based herbicide formulations on human placental cells, kidney cells, embryonic cells and neonate umbilical cord cells and surprisingly found total cell death of each of these cells within 24 hours. The researchers reported several mechanisms by which the herbicides caused the cells to die including: cell membrane rupture and damage, mitochondrial damage and cell asphyxia. Following these findings, the researchers tested G, AMPA and POEA by themselves and concluded that, ‘It is very clear that if G, POEA, or AMPA has a small toxic effect on embryonic cells alone at low levels, the combination of two of them at the same final concentration is significantly ’deleterious’.

[b] Although previous researchers have proposed that the supposed ‘inert ingredients’ alter the role of cell membrane disruptors in fish, amphibians, microorganisms [4] and plants [5], independent of G, this study is the first of its kind to report similar findings in human cells. The researchers concluded that, “the proprietary mixtures available on the market could cause cell damage and even death around residual levels to be expected,

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.



[b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.

Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1

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especially in food and feed derived from R [Roundup] formulation-treated crops” which are pervasive in GM-soya.”

“Toxicity of Glyphosate” Natural Communities magazine, July 16th, 2009 http://naturalcommunitiesmag.com/2009/07/16/gm-soy-destroy-the-earth-and-humans-for-profit/

(inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

Glyphosate safety opposing view #20 – [a] “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name "Round Up," causes birth defects when applied in doses much lower than what is commonly used in soy fields.

[b] The study was directed by a leading embryologist, Dr. Andres Carrasco, a professor and researcher at the University of Buenos Aires. In his office in the nation's top medical school, Dr. Carrasco shows me the results of the study, pulling out photos of birth defects in the embryos of frog amphibians exposed to glyphosate. The frog embryos grown in petri dishes in the photos looked like something from a futuristic horror film, creatures with visible defects—one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.” Trigona, Marie “Study Released in Argentina Puts Glyphosate Under Fire” Znet, July 28, 2009 http://www.zcommunications.org/study-released-in-argentina-puts-glyphosate-under-fire-by-marie-trigona

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species. [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and

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http://naturalcommunitiesmag.com/2009/07/16/gm-soy-destroy-the-earth-and-humans-for-profit/

http://naturalcommunitiesmag.com/2009/07/16/gm-soy-destroy-the-earth-and-humans-for-profit/

http://www.zcommunications.org/study-released-in-argentina-puts-glyphosate-under-fire-by-marie-trigona

http://www.zcommunications.org/study-released-in-argentina-puts-glyphosate-under-fire-by-marie-trigona



more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #21 - “Controversy exists around the use of herbicides more commonly used by home gardeners, such as, 2, 4-D and Roundup. A manufacturer supported review of studies found Roundup safe for use around humans while anti-herbicide groups cite studies that find it affecting human embryonic, placental, and umbilical cells in vitro as well as testosterone development in mice.”

1. Vinje, Eric, “Chemical Quandary: The Problem with 2. Pesticides, Herbicides and Chemical Fertilizer”

Planet Natural http://www.planetnatural.com/site/garden-chemicals.html




Glyphosate safety opposing view #22 - “According to Mr. Carrasco’s research, even tiny quantities of glyphosate could cause embryonic malformations in frogs and thus, by extrapolation, may have implications for humans.

“I suspect the toxicity classification of glyphosate is too low ... in some cases this can be a powerful poison,” Mr Carrasco told the Financial Times in an interview. He says residents near soya-producing areas began reporting problems from 2002, a couple of years after the first big harvests using genetically modified seeds, which were approved for use in Argentina



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in 1996.

Research by other Argentine scientists and evidence from local campaigners has indicated a high incidence of birth defects and cancers in people living near crop-spraying areas. One study conducted by a doctor, Rodolfo Páramo, in the northern farming province of Santa Fé reported 12 malformations per 250 births, well above the normal rate.”

Weber, Jude and Hal Weitzman “Argentina Pressed to Ban Crop Chemical” The Financial Times, UK, May 29, 2009





Glyphosate safety opposing view #23 –[a] “Fish and aquatic invertebrates are more sensitive to Roundup than terrestrial organisms.[24] Glyphosate is generally less persistent in water than in soil, with 12 to 60 day persistence observed in Canadian pond water, yet persistence of over a year have been observed in the sediments of ponds in Michigan and Oregon.”[9] “The EU classifies Roundup as R51/53 Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.”[25]

“Although Roundup is not registered for aquatic uses[26] and studies of its effects on amphibians indicate it is toxic to them,[27] scientists have found that it may wind up in small wetlands where tadpoles live, due to inadvertent spraying during its application. A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.”[28] [b] “In 1996, Monsanto was accused of false and misleading advertising of glyphosate products, prompting a law suit by the New York State attorney general.[42] Monsanto had made claims that its spray-on glyphosate based herbicides, including Roundup, were safer than table salt and "practically

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. [a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the National Marine Fisheries Service (NMFS), where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack

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http://en.wikipedia.org/wiki/Fish

http://en.wikipedia.org/wiki/Invertebrates

http://en.wikipedia.org/wiki/Roundup%23cite_note-Giesy2000-23

http://en.wikipedia.org/wiki/Roundup%23cite_note-epa_reds-8

http://en.wikipedia.org/wiki/Roundup%23cite_note-autogenerated3-24

http://en.wikipedia.org/wiki/Roundup%23cite_note-25






non-toxic" to mammals, birds, and fish.”[43]

“Environmental and consumer rights campaigners brought a case in France in 2001 for presenting Roundup as biodegradable and claiming that it left the soil clean after use; glyphosate, Roundup's main ingredient, is classed by the European Union as "dangerous for the environment" and "toxic for aquatic organisms". In January 2007, Monsanto was convicted of false advertising.[44] The result was confirmed in 2009.”[45]

“On two occasions, the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate.[46][47][48] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding "routine falsification of data" that it was "hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits".[49][50][51] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million dollars in restitution.[32][52][53] Craven laboratories performed studies for 262 pesticide companies including Monsanto.”

“Monsanto has stated that the studies have been repeated, and that Roundup's EPA certification does not now use any studies from Craven Labs or IBT. Monsanto also said that the Craven Labs investigation was started by the EPA after a pesticide industry task force discovered irregularities.”[54]

Wikipedia, the free encyclopedia, April 10, 2010 http://en.wikipedia.org/wiki/Roundup#Toxicity_2

sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.

Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.” [b] The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. Conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Glyphosate safety opposing view #24 - “In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate ‘yielded increased risks for NHL.’ They stress that with the rapidly increasing use of glyphosate since the time

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on

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http://en.wikipedia.org/wiki/Uterus








http://en.wikipedia.org/wiki/Roundup%23Toxicity_2



the study was carried out, ‘glyphosate deserves further epidemiologic studies.’ “

DaSilva, Guy MD, “New Study Links Monsanto's Roundup to Cancer” daSilva Institute - Antiaging & Functional Medicine http://www.dasilvainstitute.com/article.asp?artid=18&areacode=ITN

information contained in the project record.


Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day.


Glyphosate safety opposing view #25 - “These latest studies confirm a wealth of evidence on the toxicities of glyphosate and Roundup formulations [2] ( Glyphosate Toxic & Roundup Worse , SiS 26), and pinpoint the different sites of action, all of which result in cell death. Epidemiological studies have previously linked glyphosate to spontaneous abortions, non-Hodgkin lymphoma, and multiple myeloma. Laboratory studies showed that glyphosate inhibits transcription in sea urchin eggs and delays development. [b] Brief exposures to glyphosate in rats caused liver damage, and adding

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. [a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.

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http://www.dasilvainstitute.com/article.asp?artid=18&areacode=ITN

http://www.i-sis.org.uk/GTARW.php



the surfactant in Roundup had a synergistic effect, causing greater liver damage. Roundup was also found to be much more lethal to frogs than to weeds, and could have contributed to the global demise of amphibians within the past decades,” [3]

Ho Mae-Win Ph.D. and Brett Cherry “Death by Multiple Poisoning, Glyphosate and Roundup” an Institute of Science in Society news release submitted to the USDA November 2, 2009 http://current.com/146im4c



[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic

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species.” Glyphosate safety opposing view #26 - “Terrestrial toxicity:

[a] A number of species of birds, mammals and beneficial insects suffer population loses through habitat and/or food supply destruction resulting from the use of glyphosate. There are also direct lethal and sublethal effects.

- Birds LD50 (mg/kg body weight) >3851 - Beneficial Insects oral LD50 >100ug/bee. (Cox 1995b; IPCS 1994)

[b] Exposure to freshly applied Roundup killed more than half of three species - a parasitoid wasp, a lacewing, and a ladybug - and more than 80 percent of a predatory beetle. Carabid beetle populations have shown significant decline and slow recovery after glyphosate application (Asterarki et al., 1992; Brust, 1990; Hassan 1988)

Glyphosate adversely affects a number of soil and plant fauna, such as the beneficial predatory mites. However, it prolonged larval survival of the foliar-feeding nematode Nothanguinea by 50% thus increasing the damage done by this pest. (Carlisle & Trevore, 1987; Eijsackers 1985) [c] Glyphosate may inhibit a number of fungi that decompose dead plant material. Roundup applied to the soil in repeated doses had a substantial adverse effect on the growth rate of earthworms. The reproductive capacity and the total population in the soil could be expected to fall following repeated low doses of biocides. IPCS, however, classifies glyphosate as having low toxicity to earthworms with a No Observed Effects Concentration of 158mg/kg. (Grossbard 1985; IPCS, 1994; Springett and Gray, 1992) Laboratory studies show significant effects on nitrogen fixation, denitrification and nitrification. (IPCS 1994) Watts, Meriel and Ronald Macfarlane, “Glyphosate” A Pesticide Action Network - Asia and the Pacific publication, 1999


[a] Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” [b] Most field studies suggest that effects on terrestrial invertebrates are due to secondary effects on vegetation. The less toxic formulations of glyphosate do not appear to present any risks to terrestrial organisms other than terrestrial plants (SERA 2011). [c] The effects to fungi are addressed by the following information: “Roberts and Berk (1993) investigated the effects of Roundup® on chemoattraction of the protozoa Tetrahymena pyriformis and found that it significantly interfered with chemoreception but not motility. Doses of glyphosate <10 ppm were stimulatory to soil microflora including actinomycetes, bacteria, and fungi, while concentrations >10 ppm had detrimental impacts on microflora populations in one study (Chakravarty and Sidhu 1987). While some short-term studies (<30 days) found glyphosate caused significant impacts to microbial populations, Roslycky (1982) found that these populations rebound from any temporary increase or decrease within 214 days. Similarly, Tu (1994) found that microorganisms recovered rapidly from treatment with glyphosate and

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Comment Forest Service Response http://www.poptel.org.uk/panap/pest/pe-gly.htm that the herbicide posed no long-term threat to

microbial activities” (Tu et al. 2001, as revised through 2005).

Glyphosate safety opposing view #27 - Regarding your article, Mystery of Disappearing Honeybees (SiS 34), I am a Dutch beekeeper in the east of the Netherlands near Germany, and we see the same problem with bees, as in Belgium, Germany, France and the whole of Europe. In the Netherlands the government is set to give permission for growing GMOs, even in such a very small country. It will cause a lot of damage: bad for biodiversity, the earth, water, air, drinking water and food.

I just lost 68 percent of my bees, and I blame the city workers who sprayed glyphosate twice at the end of October last year. My beehives were 4 metres from the spray, whereas the legal distance is 200 metres. By the beginning of January 2008, the bees started to die. The municipal authorities in villages and small cities spray glyphosate on weeds in public places, gardens and footpaths. In big cities, they would use steam instead of weed killers.

I did a ‘test’ in September 2007 with a bit of glyphosate, and within three or five minutes, the bees were dead. It is very important for the city workers to give people warning when they spray, but they never do.

We must study the toxic effects of GMOs and glyphosate, for the sake of the next generation, our children, as well as the sick and old people.

Broek, Hans van den, “Glyphosate kills bees” The Institute of Science in Society Science in Society #38, summer 2008 http://www.i-sis.org.uk/SIS38lettersToTheEditor.php

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Most field studies suggest that effects on terrestrial invertebrates are due to secondary effects on vegetation. The less toxic formulations of glyphosate do not appear to present any risks to terrestrial organisms other than terrestrial plants (SERA 2011).

Glyphosate safety opposing view #28 –[a] “Glyphosate herbicides can have a range of impacts on human health, including genetic damage, skin tumours, thyroid damage, anaemia, headaches, nose bleeds, dizziness,

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize

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http://www.i-sis.org.uk/MysteryOfDisappearingHoneybees.php

http://www.i-sis.org.uk/MysteryOfDisappearingHoneybees.php

http://www.i-sis.org.uk/SIS38lettersToTheEditor.php



tiredness, nausea, eye and skin irritation, asthma and breathing difficulties. Several studies have indicated a link between glyphosate herbicides and non-Hodgkin's lymphoma, a type of cancer. [b] Not surprisingly, considering the amount of money that Monsanto makes from sales of glyphosate products, the company plays down the health risks of glyphosate. Monsanto claims that glyphosate herbicides pose only a "low risk to human health" as long as glyphosate is used "according to label directions". “ Lang, Chris, “Glyphosate herbicide, the poison from the skies” WRM's bulletin Nº 97, August 2005 http://www.wrm.org.uy/bulletin/97/Glyphosate.html

human exposure to herbicides. These are briefly described below.



[b] The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Glyphosate safety opposing view #29 - “A 1999 study, A Case-Control Study of Non-Hodgkin Lymphoma and Exposure to Pesticides, (American Cancer Society, 1999), found that people exposed to glyphosate are 2.7 times more likely to contract non-Hodgkin Lymphoma. A Finnish study shows that glyphostate decreases the defenses of enzymes of the liver and intestines.18 RoundUp, as a mixture of all its ingredients, has been shown to shut down a powerful antioxidant in the liver that detoxifies harmful compounds so they can be excreted through bile. A paper published

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service

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in August 2000 shows that RoundUp alters gene expression and inhibits necessary steroid production by disrupting a particular protein expression. In 2002, a paper shows that RoundUp can also affect early cell division processes in embryos.19”

“chemicalWATCH Factsheet” Published by Beyond Pesticides, August 2009 http://www.beyondpesticides.org/pesticides/factsheets/Glyphosate.pdf

employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Glyphosate safety opposing view #30 - “The USDA first deregulated Roundup Ready alfalfa in 2005. Internal emails recently obtained by Truthout show that Monsanto worked closely with regulators to edit its original petition to deregulate the alfalfa. One regulator accepted Monsanto's help in conducting the USDA's original environmental assessment of the alfalfa.

Farmers and biotech opponents soon filed a lawsuit against the USDA to challenge the initial deregulation. In 2007, a federal court ruled that the USDA did not consider the full environmental impacts of Roundup Ready alfalfa and vacated the agency's decision to deregulate the alfalfa. Monsanto and its allies appealed the decision, and last year, the Supreme Court reversed the lower court's ruling, but ordered the USDA to produce an Environmental Impact Statement (EIS) on the alfalfa before allowing it back into America's fields.

The USDA released a final EIS on Roundup Ready alfalfa in late 2010, and the GE alfalfa was fully deregulated on January 27. The USDA went on to approve two more GE seeds within weeks of the alfalfa decision. Roundup Ready alfalfa was deregulated just weeks after USDA Secretary


This citation discusses a lawsuit about Roundup Ready alfalfa, which is not related to this project.

Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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http://www.truth-out.org/why-monsanto-always-wins67976

http://www.truth-out.org/why-monsanto-always-wins67976

http://www.truth-out.org/big-win-biotech-usda-deregulates-monsanto-alfalfa67373

http://www.truth-out.org/feds-approve-monsanto-herbicide-resistant-crops67796



Tom Vilsack was pressed by Republican Congressmen, some of whom recently received campaign contributions from Monsanto and the biotech industry, to dump a proposal to geographically isolate Roundup Ready alfalfa from organic and conventional alfalfa and, instead, legalize the GE seed without any government oversight. The latest lawsuit filed by CFS and its allies argues that the final EIS ignores or downplays the threats Roundup Ready alfalfa poses to conventional alfalfa farms and the environment.” Ludwig, Mike “Farmers Sue USDA Over Monsanto Alfalfa – Again” Truthout, March 25, 2011 http://www.truth-out.org/farmers-sue-usda-over-monsanto-alfalfa-again68656

Glyphosate safety opposing view #31 - “JH: You said you had found that very low doses of glyphosate had caused these effects on aromatase. Are they the kind of doses that would be used in practical agriculture in the European Union?”

“GE-S: They are about ten to 100 times less than the doses used by agricultural workers. One has to be cautious because these are in vitro results but we do not want to wait for death when the precautionary principle suggests a need for measures to avoid any harmful effects on foetuses and children.”

1. “Glyphosate disrupts of human hormones” An interview with Professor Gilles-Eric Seralini Ph.D. Published by ecochem http://www.ecochem.com/ENN_glyphosate(2).html

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs

325

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http://www.truth-out.org/farmers-sue-usda-over-monsanto-alfalfa-again68656

http://www.ecochem.com/ENN_glyphosate(2).html



throughout their career (Black 2013).

Glyphosate safety opposing view #32 - “The December/January 2010 issue of The Organic & Non-GMO Report featured an interview with Robert Kremer, an adjunct professor in the Division of Plant Sciences at the University of Missouri, whose research showed negative environmental impacts caused by glyphosate, the main ingredient in Monsanto's Roundup herbicide, which is used extensively with Roundup Ready genetically modified crops.” “The widespread use of glyphosate is causing negative impacts on soil and plants as well as possibly animal and human health. These are key findings of Don Huber, emeritus professor of plant pathology, Purdue University.”

Roseboro, Ken “Monsanto's Glyphosate Problems: Scientist Warns of Dire Consequences with Widespread Use” The Organic and Non-GMO Report, Posted June 14, 2010


Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Feng and Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990; Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005]

Glyphosate safety opposing view #33 – [a] “There is, indeed, direct evidence that glyphosate inhibits RNA transcription in animals at a concentration well below the level that is recommended for commercial spray application. Transcription was inhibited and embryonic development delayed in sea urchins following exposure to low levels of the herbicide and/or the surfactant polyoxyethyleneamine. The pesticide should be

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize herbicide application to nontarget organisms and areas. These include not applying herbicides if wind speed exceeds 8 mph (or less, depending on the herbicide

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considered a health concern by inhalation during spraying [4].”

[b] “New research shows that a brief exposure to commercial glyphosate caused liver damage in rats, as indicated by the leakage of intracellular liver enzymes. In this study, glyphosate and its surfactant in Roundup were also found to act in synergy to increase damage to the liver [5].” Ho, Mae-Wan Ph.D. and Prof. Joe Cummins Ph.D. “Glyphosate Toxic & Roundup Worse” An Institute of Science in Society publication, 07/03/05 http://www.i-sis.org.uk/GTARW.php

label) and not applying herbicides if weather reports indicate rainfall would occur within 3 hours after application. Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment.

Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Glyphosate safety opposing view #34 - “In contrast to malathion, Roundup had strong direct effects on the tadpoles. Roundup caused a 40% reduction in total tadpole survival and biomass. The impact of Roundup (with POEA

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize

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[polyethoxylated tallow-amine] surfactant) is consistent with previous laboratory studies in a variety of species. Mann and Bidwell (1999) estimated LC5048h at 3.9 to 15.5 mg active ingredient (AI)/L in four species of Australian tadpoles while Perkins et al. (2000) estimated LC5096h values of 12.4 mg AI/L in the African clawed frog (Xenopus laevis). In both studies, it was clear that the high toxicity of Roundup was caused by the POEA surfactant and not from the active ingredient (glyphosate). Lajmanovich et al. (2003) examined the impact of Kleeraway (another formulation of glyphosate that contains the POEA surfactant) on a South American tadpole (Scinax nasicus) and found an LC5048h of 1.74 mg AI/L. In North American tadpoles (Bufo americanus, Rana pipiens, and R. clamitans), Edginton et al. (2004) found LC5096h of 1.5–4.7 mg AI/l using Vision (a formulation that also includes the POEA surfactant). For the three species used in our mesocosm experiment, Relyea (2005b) found LC5016d values of 1.4 mg AI/L for gray tree frogs, 2.5 mg AI/L for American toads, and 2.5 mg AI/L for leopard frogs. All of this suggests that Roundup with the POEA surfactant can cause substantial mortality in larval amphibians.” Relya, Rick A. Ph.D., Nancy Schoeppner and Jason T. Hoverman, “Pesticides and Amphibians: The Importance of Community Context”

Ecological Applications, 15(4), July 1, 2005, pp. 1125–1134 http://www.mindfully.org/Pesticide/2005/Roundup-Amphibians-Community1jul05.htm

effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the National Marine Fisheries Service (NMFS), where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #34 - “The decline in amphibians across the globe has sparked a search for the causes, and recent evidence suggests a connection with pesticides. However, for most pesticides, tests on amphibians are rare and conducted only for short durations (1 to 4 days) and without natural stressors. Recent studies have discovered that the stress of

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below.

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http://www.mindfully.org/Pesticide/2005/Roundup-Amphibians-Community1jul05.htm



predator cues in the water can make insecticides much more lethal to larval amphibians, but it is unknown whether this phenomenon can be generalized to other types of pesticides. Using six species of North American amphibian larvae (Rana sylvatica, R. pipiens, R. clamitans, R. catesbeiana, Bufo americanus, and Hyla versicolor), I examined the impact of a globally common herbicide (Roundup) on the survival of tadpoles for 16 days with and without the chemical cues emitted by predatory newts (Notophthalmus viridescens). LC5016-d estimates varied from 0.55 to 2.52 mg of active ingredient (AI)/L, which was considerably lower than the few previous studies using Roundup (1.5 to 15.5 mg AI/L). Moreover, in one of the six species tested (R. sylvatica), the addition of predatory stress made Roundup twice as lethal. This discovery suggests that synergistic interactions between predatory stress and pesticides may indeed be a generalizable phenomenon in amphibians that occurs with a wide variety of pesticides.”

Relyea, R.A. Ph.D. “The Lethal Impacts of Roundup and Predatory Stress on Six Species of North American Tadpoles”

Archives of Environmental Contamination and Toxicology v 48, n. 3, April 1, 2005 http://www.mindfully.org/Pesticide/2005/Roundup-Tadpoles-Relyea1apr05.htm

To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.



Glyphosate safety opposing view #35 - “Species richness was reduced by 15% with Sevin, 30% with malathion, and 22% with Roundup, whereas 2,4-D had no effect. Both insecticides reduced zooplankton diversity by eliminating cladocerans but not copepods (the latter increased in abundance). The insecticides also reduced the diversity and biomass of predatory insects and had an apparent indirect positive effect on several species of tadpoles, but had no effect on snails. The two herbicides had no effects on zooplankton, insect predators, or snails. Moreover, the herbicide 2,4-D had no effect on tadpoles. However, Roundup completely eliminated


Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described

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two species of tadpoles and nearly exterminated a third species, resulting in a 70% decline in the species richness of tadpoles. This study represents one of the most extensive experimental investigations of pesticide effects on aquatic communities and offers a comprehensive perspective on the impacts of pesticides when nontarget organisms are examined under ecologically relevant conditions.”

Relyea, R.A. Ph.D. “The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities” Ecological Applications v 15, n. 2, April 1, 2005 http://www.mindfully.org/Pesticide/2005/Roundup-Aquatic-Communities1apr05.htm

below.


Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #36 - “He is joined in his conclusions by Robert Bellé, from the National Center for Scientific Research (CNRS) biological station in Roscoff (Finistere), whose team has been studying the impact of glyphosate formulations on sea-urchin cells for several years. This recognized model for the study of early stages of cancer genesis earned Tim Hunt the 2001 Nobel Prize in medicine. In 2002, the Finisterian team had shown that Roundup acted on one of the key stages of cellular division.


To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a

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The Breton team has recently demonstrated (Toxicological Science, December 2004) that a "control point" for DNA damage was affected by Roundup, while glyphosate alone had no effect. "We have shown that it's a definite risk factor, but we have not evaluated the number of cancers potentially induced, nor the time frame within which they would declare themselves," the researcher acknowledges. A sprayed droplet could affect thousands of cells. On the other hand, "the concentration in water and fruits is lower, which is rather reassuring." Morin, Herve “Roundup Doesn’t Poison Only Weeds” Le Monde (France) March 12, 2005 http://www.mindfully.org/GE/2005/Roundup-Poison12mar05.htm

100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #37 - “We have evaluated the toxicity of four glyphosate (G)-based herbicides in Roundup (R) formulations, from 105 times dilutions, on three different human cell types. This dilution level is far below agricultural recommendations and corresponds to low levels of residues in food or feed. The formulations have been compared to G alone and with its main metabolite AMPA or with one known adjuvant of R formulations, POEA. HUVEC primary neonate umbilical cord vein cells have been tested with 293 embryonic kidney and JEG3 placental cell lines. All R formulations cause total cell death within 24 h, through an inhibition of the mitochondrial succinate dehydrogenase activity, and necrosis, by release of cytosolic adenylate kinase measuring membrane damage. They

Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

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also induce apoptosis via activation of enzymatic caspases 3/7 activity. This is confirmed by characteristic DNA fragmentation, nuclear shrinkage (pyknosis), and nuclear fragmentation (karyorrhexis), which is demonstrated by DAPI in apoptotic round cells. G provokes only apoptosis, and HUVEC are 100 times more sensitive overall at this level. The deleterious effects are not proportional to G concentrations but rather depend on the nature of the adjuvants. AMPA and POEA separately and synergistically damage cell membranes like R but at different concentrations. Their mixtures are generally even more harmful with G. In conclusion, the R adjuvants like POEA change human cell permeability and amplify toxicity induced already by G, through apoptosis and necrosis. The real threshold of G toxicity must take into account the presence of adjuvants but also G metabolism and time-amplified effects or bioaccumulation. This should be discussed when analyzing the in vivo toxic actions of R. This work clearly confirms that the adjuvants in Roundup formulations are not inert. Moreover, the proprietary mixtures available on the market could cause cell damage and even death around residual levels to be expected, especially in food and feed derived from R formulation-treated crops.”

Benachour, Nora and Gilles-Eric S ralini “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”

Chem. Res. Toxicol., 2009, 22 (1), pp 97–105 DOI: 10.1021/tx800218n Publication Date (Web): December 23, 2008 http://pubs.acs.org/doi/abs/10.1021/tx800218n

Glyphosate safety opposing view #38 - “We exposed human liver HepG2 cells, a well-known model to study xenobiotic toxicity, to four different formulations and to glyphosate, which is usually tested alone in chronic in vivo regulatory studies. We measured cytotoxicity with three assays (Alamar Blue®, MTT, ToxiLight®), plus genotoxicity (comet assay), anti-

Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally

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estrogenic (on ERα, ERβ) and anti-androgenic effects (on AR) using gene reporter tests. We also checked androgen to estrogen conversion by aromatase activity and mRNA. All parameters were disrupted at sub-agricultural doses with all formulations within 24 h. These effects were more dependent on the formulation than on the glyphosate concentration. First, we observed a human cell endocrine disruption from 0.5 ppm on the androgen receptor in MDA-MB453-kb2 cells for the most active formulation (R400), then from 2 ppm the transcriptional activities on both estrogen receptors were also inhibited on HepG2. Aromatase transcription and activity were disrupted from 10 ppm. Cytotoxic effects started at 10 ppm with Alamar Blue assay (the most sensitive), and DNA damages at 5 ppm. A real cell impact of glyphosate-based herbicides residues in food, feed or in the environment has thus to be considered, and their classifications as carcinogens/mutagens/reprotoxics is discussed.” Gasnier, Céline Ph.D., Coralie Dumont Ph.D., Nora Benachour Ph.D., Emilie Clair

Ph.D., Marie-Christine Chagnon Ph.D. and Gilles-Eric Séralini Ph.D. “Glyphosate-based herbicides are toxic and endocrine disruptors in human cell lines” Available online 17 June 2009 http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6TCN-4WJBC0R-1&_user=10&_coverDate=08%2F21%2F2009&_rdoc=1&_fmt=high&_orig=search&_origin=search&_sort=d&_docanchor=&view=c&_searchStrId=1591140451&_rerunOrigin=scholar.google&_acct=C000050221&_version=1&_urlVersion=0&_userid=10&md5=2adfd01803a911a1ff1eda15564d337e&searchtype=a

biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

Glyphosate safety opposing view #39 - “In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate ‘yielded increased risks for NHL.’ They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, ‘glyphosate deserves further epidemiologic studies.’ “


• Individuals applying pesticides are required to

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"New Study Links World's Biggest Selling Pesticides to Cancer Swedish Study Finds Exposure to Glyphosate and MCPA Increases Risk for Non-Hodgkin's Lymphoma"

Press Release PAN AP, June 21, 1999 http://www.mindfully.org/Pesticide/Monsanto-Roundup-Glyphosate.htm

wear personal protective equipment. • Treatments will be coordinated with Forest

Service employees who may be working in or around the area the same day.

Glyphosate safety opposing view #40 - “There is, indeed, direct evidence that glyphosate inhibits RNA transcription in animals at a concentration well below the level that is recommended for commercial spray application. Transcription was inhibited and embryonic development delayed in sea urchins following exposure to low levels of the herbicide and/or the surfactant polyoxyethyleneamine. The pesticide should be considered a health concern by inhalation during spraying [4].”

New research shows that a brief exposure to commercial glyphosate caused liver damage in rats, as indicated by the leakage of intracellular liver enzymes. In this study, glyphosate and its surfactant in Roundup were also found to act in synergy to increase damage to the liver [5]. Three recent case-control studies suggested an association between glyphosate use and the risk of non-Hodgkin lymphoma [6-8]; while a prospective cohort study in Iowa and North Carolina that includes more than 54 315 private and commercial licensed pesticide applicators suggested a link between glyphosate use and multiple myoeloma [9]. Myeloma has been associated with agents that cause either DNA damage or immune suppression.” Ho, Mae-Wan Ph.D. and Prof. Joe Cummins “Glyphosate Toxic & Roundup Worse” Institute of Science in Society report 07/03/05 http://www.i-sis.org.uk/GTARW.php





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Comment Forest Service Response Glyphosate safety opposing view #41 - “New scientific studies link Roundup (glyphosphate), the most widely used herbicide in the world, to a host of health risks, such as cancer, miscarriages and disruption of human sex hormones.”

Long, Cheryl “Hazards of the World’s Most Common Herbicide” Mother Earth News, October/November 2005 http://www.motherearthnews.com/Organic-Gardening/2005-10-01/Hazards-of-the-Worlds-Most-Common-Herbicide.aspx




Glyphosate safety opposing view #42 - “A series of studies has found that farmers develop non-Hodgkin's lymphoma more often than other people do, but until now it has been difficult for scientists to explain why this increase occurs. New research, however, shows that exposure to the herbicide glyphosate, commonly sold as Roundup, is one explanation. The study was published in 2003 by researchers at the National Cancer Institute, the University of Nebraska Medical Center, Kansas University Medical Center, and the University of Iowa College of Medicine.”

Study Links Herbicide use and Cancer A Northwest Coalition for Alternatives to Pesticides publication, 2010 http://www.pesticide.org/the-buzz/study-links-herbicide-use-and-cancer

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

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Comment Forest Service Response Glyphosate safety opposing view #43 - “5. SUMMARY OF GLYPHOSATE IMPACTS ON AMPHIBIANS

[a] This summary is derived almost entirely from toxicological studies on tadpoles and late-stage anuran embryos. The impact of glyphosate herbicides on other amphibians and other life stages is virtually unknown.

• • Recent studies have shown that tadpoles are one of the vertebrate groups most sensitive to the toxicity effects of most commercial formulations of glyphosate herbicides, including Vision.

• • The estimated LC50 values for some species of amphibians are at or below the expected environmental concentration (EEC) of 1.43 mg a.e./L of Vision (Table 1). Most LC50 values are calculated from experimental durations of 24 to 96 hours, but at low concentrations death may not occur until after 96 hours. This suggests that amphibians may be even more sensitive than the published LC50 values suggest.

• • Although LC50 values have traditionally been used to set hazard quotients, recent risk analysis methodology suggests that LC10 values are better for judging population- level impacts of environmental contaminants (Solomon and Thompson 2003). In at least one published study, all North American amphibian larvae tested to date had LC10 values estimated at or below the EEC for Vision, especially at pH higher than 7.0.

• • In addition to direct mortality effects, glyphosate herbicides also cause sublethal effects, including reduced growth and development rates, behavioural impairment, and genomic effects. The population-level consequences of these sublethal effects have not been tested under field conditions. For example, reduced growth and development rates, which have been documented under laboratory conditions, could translate into increased mortality if amphibian larvae are unable to metamorphose before the end of the season. Similarly, impaired behavioural response to prodding under

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.


Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.” [b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader

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laboratory conditions could translate to increased susceptibility to predators under field conditions.

• • Impacts have been shown to be synergistically enhanced by interaction with some environmental factors. Of particular concern is that the effects of glyphosate herbicide may be greater when pond pH is 7 or higher (Edginton et al. 2004a). Amphibians in general avoid acidic conditions, preferring to breed in ponds with higher pH, which could increase their vulnerability to glyphosate herbicide impacts.

[b] • More detailed toxicological studies indicate that the toxicity of glyphosate herbicides arises not from the active ingredient, glyphosate, but from the surfactant, POEA.

• • POEA is thought to interfere with the synthesis of collagen and to reduce the branchial cartilage in the gills of tadpoles and to cause lysis of gill epithelial cells in fish. This could result in loss of osmotic stability and asphyxiation. The toxic mode of action in terrestrial, postmetamorphic amphibians is not known at formulations without POEA surfactants, such as Rodeo, and formulations with other surfactants, such as Roundup Biactive, have reduced toxicity to amphibians. (pg. 31)

Govindarajulu, Purnima P. Ph.D., “Literature review of impacts of glyphosate herbicide on amphibians: What risks can the silvicultural use of this herbicide pose for amphibians in B.C.?” British Columbia Ministery of the Environment, Wildlife Report No. R-28, June 2008 http://www.llbc.leg.bc.ca/public/pubdocs/bcdocs/442206/finishdownloaddocument.pdf

Activator, and Ad-Wet 90.


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Glyphosate safety opposing view #44 - “Chronic Effects of Glyphosate versus Formulations: Throughout this study glyphosate itself showed no chronic effects on developing tadpoles. The tadpoles reared in the formulations Roundup Original® and Transorb® did show significant physical abnormalities. Abnormalities were also found upon exposure to the surfactant POEA. For all endpoints POEA showed practically identical results to the Roundup Original® formulation whereas the same cannot be said for the Transorb® formulation. The surfactant used in the Transorb formulation is not known (being protected as “Trade Secret”), but has been described as a “surfactant blend”. This “surfactant blend” may be responsible for inhibition of metamorphosis, as well as the skewed sex ratio towards female seen in the present study. Developmental abnormalities induced by Roundup are likely a result of endocrine disruption. The thyroid axis can be greatly affected by corticoids and sex steroids which influence hypothalamic and pituitary control (See Dodd and Dodd, 1976, and Hayes, 1997 for review). Corticoids, sex steroids and prolactin have caused delayed metamorphosis and decreased size by both antagonizing and inhibiting thyroid action (Hayes, 1997). Sex steroid can induced sex reversal and intersex in amphibians and mammals, while low thyroid levels interfere with vitellogenesis. A concentration at which the animals were not effected (NOEC) by The Roundup formulations was not determined by this study.” Christina Howe, Ph.D., Michael Berrill Ph.D., and Bruce D. Pauli “The Acute and Chronic Toxicity of Glyphosate-Based Pesticides in Northern Leopard Frogs” Amphibian Ecology and Pathobiology, August 14, 2002 http://www.trentu.ca/biology/berrill/Research/Roundup_Poster.htm



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Glyphosate safety opposing view #45 –

[a] “Concern #1: Roundup is only intended for terrestrial use, not aquatic use While it may be intended for terrestrial use, there is overwhelming evidence that Roundup gets into aquatic habitats, typically through inadvertent (or unavoidable) aerial overspray (Newton et al. 1984, Goldsborough and Brown 1989, Feng et al. 1990, Thompson et al. 2004). To determine the effect on amphibians, Relyea (2005a) simulated a direct overspray of a small wetland using pond mesocosms (1000-liter tanks). The result was widespread death for many species and the death rate was much higher than expected based on previous studies of Roundup. It is relatively common knowledge that Roundup should not be applied to large ponds and lakes, but it seems to be much less commonly appreciated that many amphibians are not produced in large ponds and lakes due to predation by fish. Instead, small temporary wetlands that may appear to be unimportant and only have 6" of water can, in fact, produce thousands of tadpoles. These small, temporary pools are either not avoided or not avoidable by aerial pesticide applications. Moreover, Roundup is not only lethal to amphibian larvae. New studies have found that Roundup can be highly lethal to terrestrial amphibians as well (Relyea 2005c).” [b] “Concern #2: The application rate of Roundup was 7 times too high

The application rate of 6 ounces per 300 square feet came directly from the label of Monsanto's "Roundup Weed and Grass Killer". What Monsanto is claiming is that the application rate for this Roundup is higher than their listed application rate for other forms of Roundup. However, both application rates come from Monsanto. Moreover, it is well accepted by Monsanto and the applicators of Roundup that some types of weeds require up to four times the recommended application rate to be effective.”

[a] As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. A design feature will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identifies applicable SOPs. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas.

Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS

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[c] “Concern #4: A past risk assessment has shown that Roundup poses minimal risk to amphibians The risk assessment was conducted by Giesy et al. (2000), in cooperation with Monsanto, and the assessment was based on the available data at that time. For amphibians, data only existed for four species of Australian tadpoles and one species of African frog. From these studies, the LC50 estimates (the amount of pesticide needed to kill 50% of the animals) were 4 to 16 mg a.i./L (Mann and Bidwell 1999, Perkins et al. 2000). More recent LC50 laboratory data for North American amphibians demonstrate that North American amphibians are much more sensitive; LC50 values range from 0.5 to 4.7 mg a.i./L (Edginton et al. 2004, Relyea 2005b). According to U.S. Fish and Wildlife classifications, this means that Roundup can no longer be considered slightly to moderately toxic, but rather moderately to highly toxic to North American amphibians.”

Relya, Rick Ph.D. “Roundup is Highly Lethal” Dr. Relya Responds to Monsanto’s Concerns Regarding Recent Published Study Mindfully.org, April 1, 2005 http://www.mindfully.org/GE/2005/Relyea-Monsanto-Roundup1apr05.htm

Resource Areas of Concern.

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species. [c] Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005), found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #46 - “Based on the best available information, the Agency makes a Likely to Adversely Affect determination for the CRLF from the use of glyphosate. Additionally, the Agency has determined that there is the potential for modification of CRLF designated critical habitat from the use of the chemical.

This assessment indicates that direct effects to the terrestrial-phase CRLF eating broadleaf plants, small insects and small herbivorous mammals on a dietary-basis may be at risk following chronic exposure to glyphosate at application rates of 7.5 lb a.e./A and above (forestry, areas with impervious surfaces and rights of way). In addition, for one particular formulation (Registration No. 524-424), medium and large-


To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is

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sized CRLF’s eating small herbivorous mammals on a dose-basis may be at risk following acute exposure at an application rate of 5.5 lb formulation/A (industrial outdoor uses). At the lowest application rate of 1.1 lb formulation/A, there is potential risk to medium-sized CRLF’s eating small herbivorous mammals on a dose-basis (ornamental lawns and turf).” (Pg. 173)

Carey, Stephen, Tanja Crk, Colleen Flaherty, Pamela Hurley, James Hetrick, Keara Moore, and Silvia C. Termes “Risks of Glyphosate Use to Federally Threatened California Red-legged Frog (Rana aurora draytonii) -- Pesticide Effects Determination”

A Report by the Environmental Fate and Effects Division Office of Pesticide Programs Washington, D.C. 20460, October 17, 2008 http://www.epa.gov/espp/litstatus/effects/redleg-frog/glyphosate/determination.pdf

300 feet from the high-water mark.



Glyphosate safety opposing view #47 –[a] “Glyphosate is the poster child for the global pesticide controversy due to its place in the ongoing debate over mega-farming and genetically engineered crops. Industry scientists say it's one of the safest herbicides in the world, while independent scientists have discovered potential links among the widespread use of glyphosate-based herbicides and non-Hodgkin's lymphoma, birth defects and even attention deficit disorder. [b] Research also shows that additives like surfactants in glyphosate in herbicides like Roundup are more toxic than glyphosate itself and can increase the toxicity of glyphosate.” “The war on invasive species is a war on a fact of life. Humans have caused or exacerbated these species "invasions" by changing habitats and introducing species to new areas, and now we are trying to turn back the

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.



[b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader

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http://archive.truthout.org/war-over-genetically-modified-crops-gets-ugly-birth-defects-superweeds-and-science-intimidation64915



clock in an attempt to prevent nature from taking its new course. As long as people attempt to dominate the land, extract its resources and shape it to their liking, there will be money to be made and dramatic consequences for other livings things. The search for a balance between supporting our collective desire to prosper and a healthy natural world is sure to spark more heated debates for years to come.”

Ludwig, Mike “Special Investigation: The Pesticides and Politics of America's Eco-War” Published by Truthout, June 9, 2011 http://www.truth-out.org/pesticides-and-politics-americas-eco-war/1307539754

Activator, and Ad-Wet 90.


Glyphosate safety opposing view #48 - “We also observed a gradual loss of the r3 and r5domains in embryos treated with GBH (compare Figure 5E,Fwith D), which resembles the results observed in frog embryos in the krox-20 domains (Figures 1B and 2E). Hybridization with the c-shh probe showed that, as in Xenopus, the prechordalmesoderm domain is preferentially lost in GBH-treated chick embryos (compare Figure 5G with H,I). As the GBH concentra-tion increases, the expression along the embryonic dorsal midline also gradually disappears (Figure 5H,I).Therefore, our experiments with chick embryos further extend conclusions from studies about the teratogenic effects of GBHin amphibians to other vertebrate species. DiscussionThe results presented above argue that both GBH and glyphosate itself interfere with key molecular mechanism sregulating early development in both Xenopus and chicken embryos, leading to congenital malformations. Sublethal doses of the herbicide (430 µM of glyphosate in 1/5000 dilutions ofGBH) and injections leading to a final concentration of 8 to 12µM of glyphosate in the injected side of the embryo were sufficient to induce serious disturbances in the expression of slug, otx2, and shh. These molecular phenotypes were correlated with a disruption of developmental mechanisms involving the neural crest, embryonic dorsal midline formation, and cephalic patterning.

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS

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http://www.truth-out.org/pesticides-and-politics-americas-eco-war/1307539754



Because glyphosate penetration through the cell membrane requires facilitation by adjuvants present in com-mercial formulations (5, 6), we tested the effects of glyphosate alone by directly microinjecting it into Xenopus embryos. The similarity of the phenotypes obtained in both situations suggests that they are attributable to the active principle of GBH and not to the adjuvants. We will discuss our results in the following context: (1) the correlation of our phenotypes with those observed in animal models with an impairment of RA signaling or deficits in the expression of critical genes that control embryonic development;(2) the probable mechanisms underlying the phenotypes induced by GBH and glyphosate; (3) possible correlations with clinical cases of human offspring exhibiting malformations in zones exposed to GBH. Misregulation of RA, shh, and otx2 Are Involved in Cephalic Malformations and Neural Crest-Derived Pheno-types Reminiscent of the Effects of GBH and Glyphosate. The phenotypes obtained after GBH treatments or injections of glyphosate alone are strikingly reminiscent of those observed as a consequence of an excess of RA signaling in vertebrates and humans. Acute or chronic increase of RA levels leads to teratogenic effects during human pregnancy and in experimental Figure 4. Phenotype induced by GBH is mediated by an increase of RA signaling (A). Analysis of RA activity with the reporter plasmid RAREZ. All embryos were injected with the reporter plasmid RAREZ, except for uninjected controls, and left untreated or were treated as indicated in the figure until stage 14-15, when they were processed. Results are expressed as arbitrary luminiscence units per µg of protein. A two-tailed t test was employed to analyze the significance in the difference of the means. ** p < 0.01; *** p < 0.0001. (B-G) WMISH for shh and otx2 at tailbud stages. (B) Control embryo. Notochord (n);floor plate (fp); brain (space between bars), eye (arrowhead). (C)Embryo treated with 1/5000 GBH manifesting microcephaly (spacebetween bars), reduced eyes (arrowhead), diminished Shh signalingfrom the prechordal mesoderm (arrow), and shortened A-P axis (78%,n)9).” (Pg. 6) Alejandra Paganelli, Victoria Gnazzo, Helena Acosta, Silvia L. López, and

Resource Areas of Concern.

Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.” Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species.

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Andrés E. Carrasco “Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling” Publicado por NOGAL DE VIDA, May 20, 2010 http://nogaldevida.blogspot.com/2010/08/glyphosate-based-herbicides-produce.html

Glyphosate safety opposing view #49 – [a] “Although there is only a handful of studies on the safety of GM soybeans, there is considerable evidence that glyphosate—especially in conjunction with the other ingredients in Roundup—wreaks havoc with the endocrine and reproductive systems. ‘I think the concentration of glyphosate in the soybeans is the likely cause of the problem,’ says Ewen. Glyphosate throws off the delicate hormonal balance that governs the whole reproductive cycle. ‘It’s an endocrine buster,’ says Ewen, ‘that interferes with aromatase, which produces estrogen.’ Aromatase is required by luteal cells to produce hormones for the normal menstrual cycle, but it’s those luteal cells that have shown considerable alterations in the rats fed GM soybeans. [b] Glyphosate is also toxic to the placenta, the organ which connects the mother to the fetus, providing nutrients and oxygen, and emptying waste products. In a 2009 French study at the University of Caen, scientists discovered that glyphosate can kill the cells in the outer layer of the human placenta (the trophoblast membrane), which in turn can kill the placenta. The placenta cells are, in Ewen’s words, ‘exquisitely sensitive to glyphosate.’ Only 1/500th the amount needed to kill weeds was able to kill the cells. The amount is so small, according to the study authors the ‘residual levels to be expected, especially in food and feed derived from R[oundup] formulation-treated crops’ could be enough to ‘cause cell damage and even [cell] death.’ Furthermore, the effect of the toxin may bioaccumulate, growing worse with repeated consumption from Roundup laden foods. Smith, Jeffery “Genitically Modified Soy Diets Lead and Uterus

[a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.



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http://nogaldevida.blogspot.com/2010/08/glyphosate-based-herbicides-produce.html






Changes in Rats” foodconsumer.org, September 22, 2010 http://www.foodconsumer.org/newsite/Safety/gmo/genetically_modified_soy_diets_0910100128.html

Glyphosate safety opposing view #50 – [a] “Such reports gained further traction after an Argentine government scientist, Andres Carrasco conducted a study, "Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling" in 2009.

The study, published in the journal Chemical Research in Toxicology in 2010, found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying. It also found that malformations caused in frog and chicken embryos by Roundup and its active ingredient glyphosate were similar to human birth defects found in genetically modified soy-producing regions. "The findings in the lab are compatible with malformations observed in humans exposed to glyphosate during pregnancy," wrote Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires. "I suspect the toxicity classification of glyphosate is too low.” “

[b] “Fagan told HuffPost that among developmental biologists who are not beholden to the chemical industry or the biotechnology industry, there is strong recognition that Carrasco’s research is credible.” "For me as a scientist, one of the reasons I made the effort to do this research into the literature was to really satisfy the question myself as to where the reality of the situation lies,” he added. “Having thoroughly reviewed the literature on this, I feel very comfortable in standing behind the conclusions Professor Carrasco came to and the broader conclusions that we come to in our paper.” “We can’t figure out how regulators could have come to the conclusions that they did if they were taking a balanced took at the science, even the

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species.

[b] Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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http://www.foodconsumer.org/newsite/Safety/gmo/genetically_modified_soy_diets_0910100128.html

http://big.assets.huffingtonpost.com/carrasco_0.pdf

http://big.assets.huffingtonpost.com/carrasco_0.pdf

http://pubs.acs.org/journal/crtoec



science that was done by the chemical industry itself.”

Graves, Lucia. “Roundup: Birth Defects Caused By World's Top-Selling Weedkiller, Scientists Say” by Lucia Graves Published on Friday, June 24, 2011 by Huffington Post http://www.commondreams.org/headline/2011/06/24-4

Glyphosate safety opposing view #51 - "This study was just routine," said Russian biologist Alexey V. Surov, in what could end up as the understatement of this century. Surov and his colleagues set out to discover if Monsanto's genetically modified (GM) soy, grown on 91% of US soybean fields, leads to problems in growth or reproduction. What he discovered may uproot a multi-billion dollar industry. After feeding hamsters for two years over three generations, those on the GM diet, and especially the group on the maximum GM soy diet, showed devastating results. By the third generation, most GM soy-fed hamsters lost the ability to have babies. They also suffered slower growth, and a high mortality rate among the pups. And if this isn't shocking enough, some in the third generation even had hair growing inside their mouths—a phenomenon rarely seen, but apparently more prevalent among hamsters eating GM soy.”

“In addition to the GMOs, it could be contaminants, he said, or higher herbicide residues, such as Roundup. There is in fact much higher levels of Roundup on these beans; they're called "Roundup Ready." Bacterial genes are forced into their DNA so that the plants can tolerate Monsanto's Roundup herbicide. Therefore, GM soy always carries the double threat of higher herbicide content, couple with any side effects of genetic engineering. Without detailed tests, no one can pinpoint exactly what is causing the reproductive travesties in Russian hamsters and rats, Italian and Austrian

The exposure level of the test subjects in the cited study far exceeds the level proposed for use in this project.


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mice, and livestock in India and America. And we can only speculate about the relationship between the introduction of genetically modified foods in 1996, and the corresponding upsurge in low birth weight babies, infertility, and other problems among the US population. But many scientists, physicians, and concerned citizens don't think that the public should remain the lab animals for the biotech industry's massive uncontrolled experiment.

Alexey Surov says, "We have no right to use GMOs until we understand the possible adverse effects, not only to ourselves but to future generations as well. We definitely need fully detailed studies to clarify this. Any type of contamination has to be tested before we consume it, and GMO is just one of them."

Smith, Jeffery “Genetically Modified Soy Linked to Sterility, Infant Mortality” foodconsumer.org, September 22, 2010

http://www.foodconsumer.org/newsite/Watch-List/genetically_modified_soy_linked_to_sterility_infant_mortality_22.html

Glyphosate safety opposing view #52 - “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name "Round Up," causes birth defects when applied in doses much lower than what is commonly used in soy fields.

The study was directed by a leading embryologist, Dr. Andres Carrasco, a professor and researcher at the University of Buenos Aires. In his office in the nation's top medical school, Dr. Carrasco shows me the results of the study, pulling out photos of birth defects in the embryos of frog amphibians exposed to glyphosate. The frog embryos grown in petri dishes in the photos looked like something from a futuristic horror film, creatures with visible defects—one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.

"We injected the amphibian embryo cells with glyphosate diluted to a concentration 1,500 times than what is used commercially and we allowed

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize

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the amphibians to grow in strictly controlled conditions." Dr. Carrasco reports that the embryos survived from a fertilized egg state until the tadpole stage, but developed obvious defects which would compromise their ability to live in their normal habitats.

Trigona, Marie “GMO – Monsanto Soy Herbicide could Pose Health Risks” Americas Program, Center for International Policy (CIP), July 13, 2009 http://www.internationalnews.fr/article-36061426.html

application in nontarget areas.


Glyphosate safety opposing view #53 - “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name “Round Up,” causes birth defects when applied in doses much lower than what is commonly used in soy fields. The study was directed by a leading embryologist, Dr. Andres Carrasco, a professor and researcher at the University of Buenos Aires. In his office in the nation’s top medical school, Dr. Carrasco shows me the results of the study, pulling out photos of birth defects in the embryos of frog amphibians exposed to glyphosate. The frog embryos grown in petri dishes in the photos looked like something from a futuristic horror film, creatures with visible defects-one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.” Trigona, Marie “Study released in Argentina puts glyphosate under fire” SOURCE Americas Program, Center for International Policy, USA, July 13, 2009 Published by Prism Webcast News http://prismwebcastnews.com/2009/08/06/study-released-in-argentina-puts-



Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and

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Comment Forest Service Response glyphosate-under-fire/ more than 300 feet from surface water in NMFS

Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #54 - “Relyea found that Roundup caused a 70 percent decline in amphibian biodiversity and an 86 percent decline in the total mass of tadpoles. Leopard Frog tadpoles and Gray Treefrog tadpoles were completely eliminated and Wood Frog tadpoles and toad (Bufo) tadpoles were nearly eliminated. One species of frog, Spring Peepers, was unaffected. "The most shocking insight coming out of this was that Roundup, something designed to kill plants, was extremely lethal to amphibians," said Relyea, who conducted the research at Pitt’s Pymatuning Laboratory of Ecology. "We added Roundup, and the next day we looked in the tanks and there were dead tadpoles all over the bottom." “ Roundup Ravages Riparian Residents” The Center for North American Herpetology. NEWS RELEASE 18 April 2005 http://www.csupomona.edu/~cmbrady/courses/bio304/Roundup.htm

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther

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http://prismwebcastnews.com/2009/08/06/study-released-in-argentina-puts-glyphosate-under-fire/

http://www.csupomona.edu/%7Ecmbrady/courses/bio304/Roundup.htm



than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #55 - “False Research [a] The EPA has twice caught scientists deliberately falsifying results at research laboratories hired by Monsanto to study glyphosate. In 1983, the EPA revealed that Industrial Biotest Laboratories (IBL) routinely falsified results of their 1971 research performed on glyphosate. Tests performed at IBL included eleven out of nineteen total chronic toxicology studies on glyphosate; studies instrumental in its retaining registration in 1974. In 1991, the EPA alleged that Craven Laboratories, another lab hired by Monsanto to study the effects of glyphosate, had falsified test results. Several methods were used, including manipulation of equipment and notebook entries.”

[b] “Alaska has an economic and cultural dependence on the welfare of salmon and other fish species, so it is particularly vital for Alaskans to know that glyphosate, and even more so glyphosate herbicides, are acutely toxic to fish. The toxicity of glyphosate, which is most potently dangerous to younger fish, increases as water temperature rises. Ironically, the use of glyphosate causes water temperatures to increase for several years following treatment,

[a] This article verifies that the EPA uses independently derived criteria to evaluate the quality of studies it receives. Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below.

To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified

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as the herbicide kills shading vegetation. This is significant in more than one way for salmon, as juvenile salmon require cold water to thrive under even normal environmental circumstances. The effects of glyphosate on fish have been documented using rainbow trout, which exhibited erratic swimming and labored breathing, effects which can increase the risk that fish will be eaten, as well as affecting ability to feed, migrate, and reproduce.” James, Carrie “Aerial Herbicide Spraying” SitNews (Ketchikan, Alaska) June 19, 2004 http://www.sitnews.us/0604Viewpoints/061904_carrie_james.html

by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas.


Glyphosate safety opposing view #56 - “Worldwide, amphibian populations are reported to be in a state of decline. Causative factors are incompletely understood. In ecosystems of northeastern North America, multiple stressors of pesticide contamination and acidification may be involved. As an initial component of a multi-tier investigation, the effects of forest-use herbicides Vision® (glyphosate) andRelease® (triclopyr) are being studied using Xenopus laevis, Rana pipiens and Rana clamitans. Two different life stages of amphibians, embryos (blastula stage) and larvae (Gosner stage 25), are being used. Interactive effects of various herbicide concentrations and pH (5.5 and 7.5) are being studied using the organisms exposed in 96hr static renewal tests. The Frog Embryo Teratogenesis Assay - Xenopus (FETAX) protocol is used for the embryo stage for the determination of mortality, malformation and growth data. The larval


To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would

351

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exposures are being developed and refined to compare sensitivities to the FETAX assay. The larval 96hr static renewal exposure is followed by a 10-day water-only recovery period. Sensitivities are being compared to determine the appropriateness of the exotic amphibian Xenopus laevis for toxicity testing. Results on toxicity to date indicate that Vision® is more toxic to all species at pH 7.5 than at pH 5.5. The reverse has been shown for Release®. In addition, the larval stage has consistently been shown to be more sensitive than the blastula stage. Understanding species sensitivities and herbicide/pH interactions will aid in altering forestry herbicide use patterns to minimize effects on amphibians and other non-target organisms.” Edginton, Andrea N.Ph.D. “Multiple stressor effects in amphibians: herbicide/pH interaction” A presentation at the 5th Annual of the Canadian Amphibian and Reptile Conservation Network, September 22-25, 2000 http://www.carcnet.ca/past_meetings/2000/pastmeeting2000.php

be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern. Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

Glyphosate safety opposing view #57 - “We have evaluated the toxicity of four glyphosate (G)-based herbicides in Roundup (R) formulations, from 105 times dilutions, on three different human cell types. This dilution level is far below agricultural recommendations and corresponds to low levels of residues in food or feed. The formulations have been compared to G alone and with its main metabolite AMPA or with one known adjuvant of R formulations, POEA. HUVEC primary neonate umbilical cord vein cells have been tested with 293 embryonic kidney and JEG3 placental cell lines. All R formulations cause total cell death within 24 h, through an inhibition of the mitochondrial succinate dehydrogenase activity, and necrosis, by release of cytosolic adenylate kinase measuring membrane damage. They also induce apoptosis via activation of enzymatic caspases 3/7 activity. This is confirmed by characteristic DNA fragmentation, nuclear shrinkage (pyknosis), and nuclear fragmentation (karyorrhexis), which is demonstrated by DAPI in apoptotic round cells. G provokes only apoptosis, and HUVEC are 100 times more sensitive overall at this level. The

Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

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http://www.carcnet.ca/past_meetings/2000/pastmeeting2000.php



deleterious effects are not proportional to G concentrations but rather depend on the nature of the adjuvants. AMPA and POEA separately and synergistically damage cell membranes like R but at different concentrations.

Benachour, Nora and Gilles-Eric Seralini “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells” Chemical Research in Toxicology, 2009, 22 (1), pp 97–105 http://pubs.acs.org/doi/abs/10.1021/tx800218n

Glyphosate safety opposing view #58 – [a] “Case example: Okanogan NF Integrated Weed Management Environmental Assessment (EA) (1997, 1999)

The Okanogan NF Integrated Weed Management EA for 1997 received many comments from the public asking for documentation and analysis of the risks of herbicides to human health and safety, yet all of these concerns for safety were lumped into a single issue on p. 15-16:

Noxious weed populations can degrade recreational experiences by decreasing the desirability of campsites, replacing native plant populations in developed and dispersed areas and changing the scenery. Herbicide contact could pose risks to human health through skin exposure, inhalation, or ingestion. Some noxious weeds also pose risks to human health.

[b] The marginalization of human health as mere “issues” rather than actual hazards suggests that there was never any intention of questioning the safety or use of herbicides, except in a very limited fashion, and this is borne out in the analysis section. Two years later the Okanogan NF prepared a second EA (1999) and through another public comment process, the issues identified through public comments were exactly the same.

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

[b] As stated on page 3-350 of the Review EA, “Weed

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Why are the issues of public health ignored? According to the rationalization given in the EA (Okanogan NF, 1997, p. 17), public comments were addressed in a “higher level document”. In other words, concerns about human health and safety were not considered in the EA. By its limited scope, the agency effectively avoids having to consider issues that it doesn't want to.

The purpose of an EA is to assess a problem, propose and evaluate alternatives and select the most effective remedy, which should be the least harmful to the environment. In this case, the alternative to use herbicides had been selected prior to doing an analysis. The EA was only used to justify a predetermined decision rather than truly explore alternatives.”

From Chapter 3. Adverse impacts in the report: “Risky Business: Invasive species management on National Forests - A review and summary of needed changes in current plans, policies and programs”

A publication of the Kettle Range Conservation Group, February, 2001

http://kettlerange.org/weeds/Chapter-3.html

infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs, some of which are identified above.

Glyphosate safety opposing view #59 - “In one study, for instance, we exposed neural stage embryos and newly hatched tadpoles of green frogs to low levels of the herbicide glyphosate. Following 96 hours of exposure to the herbicide, surviving animals were moved to fresh water. Nominal glyphosate concentrations of 1.2 to 4.0 ppm initially caused tadpoles paralysis from which they eventually recovered. During the first 24 hours of exposure to 8.0 ppm, all tadpoles either died or were completely paralysed. Furthermore, almost all of the survivors from the first 24 hours of exposure died before the completion of the 96-hour exposure period. Follow-up tests indicated that much of the toxicity could be attributed to the surfactant used in the RoundUp® formulation of glyphosate.”

Pauli, Bruce and M. Berrill Ph.D. “Pesticides and Behaviour in Tadpoles”

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water

354

http://kettlerange.org/weeds/Chapter-3.html



In Environmental Contaminants and Amphibians in Canada http://www.open.ac.uk/daptf/froglog/FROGLOG-16-5.html

mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark. In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.


lyphosate safety opposing view #60 - “BUENOS AIRES – The herbicide used on genetically modified soy – Argentina’s main crop – could cause brain, intestinal and heart defects in fetuses, according to the results of a scientific investigation released Monday.

Although the study “used amphibian embryos,” the results “are completely comparable to what would happen in the development of a human embryo,” embryology professor Andres Carrasco, one of the study’s authors, told Efe.” “Carrasco said that the research found that “pure glyphosate, in doses lower than those used in fumigation, causes defects ... (and) could be interfering in some normal embryonic development mechanism having to do with the way

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.

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http://www.open.ac.uk/daptf/froglog/FROGLOG-16-5.html



in which cells divide and die.”

“ “The companies say that drinking a glass of glyphosate is healthier than drinking a glass of milk, but the fact is that they’ve used us as guinea pigs,” he said.”

“Herbicide Used in Argentina Could Cause Birth Defects” Latin American Herald Tribune, April 30, 2009 http://www.progressiveconvergence.com/roundup-report -Argentina.htm

Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

lyphosate safety opposing view #61 - “DENVER, Colo.— Recognizing the threat posed by expanding use of dangerous pesticides across 18 western states, competition from invading bullfrogs, nonnative diseases, and loss of wetlands, the U.S. Fish and Wildlife Service will announce tomorrow their conclusion that western populations of the northern leopard frog may warrant protection under the Endangered Species Act.”

“The use of Roundup (a proprietary herbicide containing glyphosate), which is lethal to amphibians even at recommended levels according to recent studies, also threatens the western leopard frog. Roundup Ready crops (resistant to Roundup so the herbicide can be broadly applied to kill weeds) comprise a significant portion of crop acreage in the midwestern United States. In 2004, Roundup Ready soybean crops comprised 89 percent of all soybean crops in Iowa, 82 percent in Minnesota, 92 percent in Nebraska, 82 percent in North Dakota, and 95 percent in South Dakota.” Western Leopard Frogs Move a Step Closer to Protection -- U.S. Fish

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack sprayers, hand sprayers, or wipers to minimize application in nontarget areas.

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http://www.progressiveconvergence.com/roundup-report-Argentina.htm



and Wildlife Service: Pesticides, Disease, Invasive Species, and Habitat Loss May Threaten Native Frogs with Extinction Center for Biological Diversity news release, June 30, 2009 http://www.biologicaldiversity.org/news/press_releases/2009/western-leopard-frog-06-30-2009.html

Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.


Glyphosate safety opposing view #62 - “Eduardo Neaves, a 12-year-old, went swimming in a canal in Coral Gables, Florida that was contaminated with four times the recommended amount of RoundUp herbicide. The child became completely paralyzed, and five years after the incident suffers residual nervous system damage. The EPA, according to this article, in 1985 reported on the case of a 59-year-old woman in Tennessee who has suffered central nervous system damage after exposure to RoundUp. Monsanto's original neurotoxicity studies on RoundUp were ruled invalid by the EPA due to "extensive gaps in the raw data supporting study findings and conclusions. There has been no requirement for a new study on the neurotoxicity of RoundUp.” “Anecdotal Evidence of RoundUp's Toxicity” Natures Country Store From July 1987 edition of The Progressive, and article entitled 'Weed Kil ler' http://www.naturescountrystore.com/roundup/page7.html

The article link provided by Mr. Artley does not contain the excerpts provided in this comment; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide

357

http://www.biologicaldiversity.org/news/press_releases/2009/western-leopard-frog-06-30-2009.html

http://www.biologicaldiversity.org/news/press_releases/2009/western-leopard-frog-06-30-2009.html

http://www.naturescountrystore.com/roundup/page7.html



applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Glyphosate safety opposing view #63 - “A group of international scientists has released a report detailing health and environmental hazards from the cultivation of genetically modified (GM) Roundup Ready soy and the use of glyphosate (Roundup®) herbicide.

The report, GM Soy: Sustainable? Responsible?,[1] highlights new research by Argentine government scientist, Professor Andrés Carrasco,[2] which found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying. “The findings in the lab are compatible with malformations observed in humans exposed to glyphosate during pregnancy,” said Carrasco.” Antoniou, Michael, Paulo Brack Ph.D., Andrés Carrasco Ph.D., John Fagan, Mohamed Ezz El-Din Mostafa Habib Ph.D., Paulo Yoshio Kageyama Ph.D., Carlo Leifert Ph.D, Rubens Onofre Nodari Ph.D., Walter A. Pengue Ph.D. “GM Soy: Sustainable? Responsible?” GM Watch, 13 September 2010 http://www.globalresearch.ca/index.php?context=viewArticle&code=ANA20101010&articleId=21382

The article link provided by Mr. Artley does not contain the excerpts provided in this comment; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

Glyphosate safety opposing view #64 – [a] “Three recent studies show that Roundup, which is used by farmers and home gardeners, is not the safe product we have been led to trust.

A group of scientists led by biochemist Professor Gilles-Eric Seralini from the University of Caen in France found that human placental cells are very sensitive to Roundup at concentrations lower than those currently used in

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize the amount of herbicide applied. Typically, application rates would be the minimum rates necessary to control target species.

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http://www.globalresearch.ca/index.php?context=viewArticle&code=ANA20101010&articleId=21382

http://www.globalresearch.ca/index.php?context=viewArticle&code=ANA20101010&articleId=21382



agricultural application.

[b] An epidemiological study of Ontario farming populations showed that exposure to glyphosate, the key ingredient in Roundup, nearly doubled the risk of late miscarriages. Seralini and his team decided to research the effects of the herbicide on human placenta cells. Their study confirmed the toxicity of glyphosate, as after eighteen hours of exposure at low concentrations, large proportions of human placenta began to die. Seralini suggests that this may explain the high levels of premature births and miscarriages observed among female farmers using glyphosate.”

Heong, Chee Yoke “New Evidence Establishes Dangers of Roundup” Third World Resurgence, No. 176, April 2005

Re-published by Project Censored http://www.projectcensored.org/top-stories/articles/13-new-evidence-establishes-dangers-of-roundup/

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Glyphosate safety opposing view #65 - “Colombia - A Colombian court on Friday ordered the government to suspend immediately aerial spraying of drug crops with the herbicide glyphosate, a potential blow to President Andres Pastrana's anti-cocaine offensive. Bogota Judge Gilberto Reyes Delgado, ruling in favor of indigenous groups that had protested the spraying program, said he had asked the government to provide studies on glyphosate's effects on the environment and human health.”

“Ecuador recently asked Colombia to stop aerial crop spraying near the border the two nations share over fears glyphosate could harm Ecuadoreans'

Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use

359

http://www.projectcensored.org/top-stories/articles/13-new-evidence-establishes-dangers-of-roundup/

http://www.projectcensored.org/top-stories/articles/13-new-evidence-establishes-dangers-of-roundup/



health and damage subsistence crops in the region's jungle towns.”

“Columbian Court Suspends Aerial Spraying of Roundup on Drug Crops” Reuters, July 27, 2001 Republished by Mindfilly.org http://www.mindfully.org/Pesticide/Roundup-Drug-Spray-Colombia.htm

of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs. Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, and truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013).

Glyphosate safety opposing view #66 - “In short, Monsanto's Roundup Ready technology is emerging as an environmental disaster. The question isn't why a judge demanded an environmental impact study of Roundup Ready sugar beets in 2010; it's that no one did so in 1996 before the technology was rolled out. After all, the Union of Concerned Scientists was already quite, well, concerned back then.”

“As I wrote in June, rather than spark a reassessment of the wisdom of relying on toxic chemicals, the failure of Roundup Ready has the U.S. agricultural establishment scrambling to intensify chemical use. Companies like Dow Agriscience are dusting off old, highly toxic poisons like 2, 4-D and promoting them as the "answer" to Roundup's problems.”

Philpott, Tom. “Why Monsanto is paying farmers to spray its rivals’ herbicides” Grist, October 20, 2010 http://www.grist.org/article/food-2010-10-20-why-monsanto-paying-farmers-to-spray-rival-herbicides/

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature.


360

http://www.mindfully.org/Pesticide/Roundup-Drug-Spray-Colombia.htm

http://www.grist.org/article/How-the-agrichemical-industry-turns-failure-into-market-opportunity

http://www.pesticideinfo.org/Detail_Product.jsp?REG_NR=00022800238&DIST_NR=007401%23Ingredients

http://www.grist.org/article/food-2010-10-20-why-monsanto-paying-farmers-to-spray-rival-herbicides/

http://www.grist.org/article/food-2010-10-20-why-monsanto-paying-farmers-to-spray-rival-herbicides/



Glyphosate safety opposing view #67 - “Glyphosate is no more than slightly toxic to fish, and practically non-toxic to amphibians (McComb 1990) and aquatic invertebrate animals.” (page 4) “For glyphosate and its formulations, findings are from studies conducted by the manufacturer. These studies have been presented to EPA to support product registration, but may not be available to the public. (page 5)

“Since the 1988 rating, EPA has concluded that glyphosate should be classified as having evidence of noncarcinogenicity for humans. There was no convincing evidence of carcinogenicity in new studies in two animal species (Dykstra and Ghali 1991). (page 7) “Glyphosate Herbicide Information Profile” Forest Service Pacific Northwest Region, February, 1997 http://www.fs.fed.us/r6/nr/fid/pubsweb/gly.pdf


This comment supports data from the project record. EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

Glyphosate safety opposing view #68 – [a] “Two new studies indicate that Monsanto's herbicide, Roundup, is a hormone-disruptor and is associated with birth defects in humans. Farm families that applied pesticides to their crops in Minnesota were studied to see if their elevated exposure to pesticides caused birth defects in their children. The study found that two kinds of pesticides -- fungicides and the herbicide Roundup -- were linked to statistically significant increases in birth defects. Roundup was linked to a 3-fold increase in neurodevelopmental (attention deficit) disorders. [EHP Supplement 3, Vol. 110 (June 2002), pgs. 441-449.]

[b] “A recent test tube study reveals that Roundup can severely reduce the ability of mouse cells to produce hormones. Roundup interferes with a fundamental protein called StAR (steroidogenic acute regulatory protein). The StAR protein is key to the production of testosterone in men (thus controlling male characteristics, including sperm production) but also the production of adrenal hormone (essential for brain development),

The article link provided by Mr. Artley does not contain the excerpts provided in this comment; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. [a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

[b] Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” Surfactants and dyes used on the Forest are Activator

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carbohydrate metabolism (leading to loss or gain of weight), and immune system function. The authors point out that "a disruption of the StAR protein may underlie many of the toxic effects of environmental pollutants." [EHP Vol. 108, No. 8 (August 2000), pgs. 769-776.]”

“Monsanto’s Roundup Herbicide Threatens Public Health” Rachel's Environment and Health News, issue 751, Sept. 5, 2002. Reprinted by Organic Consumers Association http://www.organicconsumers.org/Monsanto/roundup92502.cfm

http://www.whale.to/b/roundup_h.html

90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

Following the Label Directions on “Approved” Herbicide Containers does not Assure Safety Herbicide Safety Testing Opposing View #69 - “Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices.

Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data."44 IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate-containing products were performed by IBT, including 11 of the 19 chronic toxicology studies.45 A compelling example of the poor quality of IBT data comes from an EPA toxicologist who wrote, "It is also somewhat difficult not to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination."46 (Emphasis added.) In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262

This article verifies that the EPA uses independently derived criteria to evaluate the quality of studies it receives.


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pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.49 The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.48 Although the tests of glyphosate identified as fraudulent have been replaced, these practices cast shadows on the entire pesticide registration process.” Cox, Caroline, “Quality of Toxicology Testing” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995. Northwest Coalition for Alternatives to Pesticides, Eugene, OR. Glyphosate, Part 1: Toxicology http://www.inspiringlandscapes.com/hope/glyphos8.htm

Herbicide Safety Testing Opposing View #70 - “In 2004 the “Counterpart Regulations,” strongly supported by industry, were proposed to streamline EPA’s pesticide review process at the expense of the most vulnerable life forms in our country, Endangered and Threatened Species aka Listed Species (1,265 species are “Listed”). The critical change these regulations bring about is elimination of the requirement for consultations with wildlife experts at the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) by EPA reviewers evaluating adverse impacts of pesticides on Listed Species and their habitats. RCC opposed the Counterpart Regulations with comments, but, sadly, the Regulations were issued in final form on July 29, 2004, despite our objections. Over 125,000 public comments were received by the Fish and Wildlife Service, and they ran 2 to 1 against the Counterpart Regulations.

As stated on page 1-20 of the Review EA, “The Proposed Action was assessed to determine the effects on threatened and endangered plant and animal species.” Consultation requirements with the U.S. Fish and Wildlife Service have been met on all species identified by the Service: Canada lynx, bull trout, yellow-billed cuckoo, whitebark pine, and North American wolverine.”

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RCC Insight: Apparently, the public’s concerns did not make a difference to the people at FWS and NMFS, or did they? We wonder whether the scientists involved with protecting wildlife at both “Services” would want to be bringing their experience and knowledge to bear on decisions made by EPA with respect to pesticides, if it were up to them. Perhaps they would prefer to be part of the evaluation process and they do not concur with finalizing the Counterpart Regulations. However, the fact is that decision-makers, by finalizing these changes, support an action that will weaken Endangered Species’ protection from poisoning and habitat degradation due to pesticides. This latest environmental rollback can mean increasingly hazardous conditions in rivers, lakes and wetlands. A further risk is weakening of the Endangered Species Act itself. (Text of our “Comments” is available through our website -- rachelcarsoncouncil.com)”

“Species from Pesticides – Weakened” Rachel Carson Council Inc., Issues & Insights October, 2004 http://www.rachelcarsoncouncil.org/index.php?page=issues-insights-october-2004 Herbicide Safety Testing Opposing View #71 – [a] “Used in yards, farms and parks throughout the world, Roundup has long been a top-selling weed killer. But now researchers have found that one of Roundup’s inert ingredients can kill human cells, particularly embryonic, placental and umbilical cord cells.

Until now, most health studies have focused on the safety of glyphosate, rather than the mixture of ingredients found in Roundup. But in the new study, scientists found that Roundup’s inert ingredients amplified the toxic effect on human cells—even at concentrations much more diluted than those used on farms and lawns. One specific inert ingredient, polyethoxylated tallowamine, or POEA, was more deadly to human embryonic, placental and umbilical cord cells than the herbicide itself – a finding the researchers call “astonishing.”

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. [b] These comments support data from the project record.

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http://www.scientificamerican.com/article.cfm?id=genetically-modified-crops-survive-weed-whacking-herbicide



“The research team suspects that Roundup might cause pregnancy problems by interfering with hormone production, possibly leading to abnormal fetal development, low birth weights or miscarriages. Monsanto, Roundup’s manufacturer, contends that the methods used in the study don’t reflect realistic conditions and that their product, which has been sold since the 1970s, is safe when used as directed. Hundreds of studies over the past 35 years have addressed the safety of glyphosate. “Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that's out there,” said Monsanto spokesman John Combest. “It's used in public parks, it's used to protect schools. There's been a great deal of study on Roundup, and we're very proud of its performance.” [b] The EPA considers glyphosate to have low toxicity when used at the recommended doses.

“Risk estimates for glyphosate were well below the level of concern,” said EPA spokesman Dale Kemery. The EPA classifies glyphosate as a Group E chemical, which means there is strong evidence that it does not cause cancer in humans.” Weed-Whacking Herbicide Proves Deadly to Human Cells By Crystal Gammon and Environmental Health News June 23, 2009

http://www.scientificamerican.com/article.cfm?id=weed-whacking-herbicide-p

EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

Herbicide Safety Testing Opposing View #72 - “However, the U.S. government regulatory agencies seem to have given Monsanto a long rope. The clout Monsanto enjoys in the U.S. government is by no means incidental. According to the Organic Consumers Association, Clarence Thomas, before being the Supreme Court Judge who put George W. Bush in office (in his first term), was a Monsanto lawyer; Anne Veneman, the U.S. Secretary of Agriculture, was on the board of directors of Monsanto's Calgene Corporation; Donald Rumsfeld, the Secretary of Defence, was on


Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for

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http://www.scientificamerican.com/topic.cfm?id=cancer

http://www.scientificamerican.com/author.cfm?id=1937





the board of directors of Monsanto's Searle Pharmaceuticals; Secretary of Health Tommy Thompson received $50,000 in donations from Monsanto during his winning campaign for Wisconsin's governorship; and the two Congressmen who received the most donations from Monsanto during the last election were Larry Combest (Chairman of the House Agricultural Committee) and John Ashcroft (the Attorney-General).”

“A multinational Exposed” Frontline, Volume 22 - Issue 05, Feb. 26 - Mar. 11, 2005 http://www.hinduonnet.com/fline/fl2205/stories/20050311003312500.htm

pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Herbicide Safety Testing Opposing View #73 – [a] “A recent study which shows clear links between exposure to the herbicide glyphosate and non-Hodgkin's lymphoma (NHL), a form of cancer that afflicts the lymphatic system, has caused worldwide concern over the safety of the herbicide on humans. The study was conducted by eminent oncologists Dr Lennart Hardell and Dr Mikael Eriksson of Sweden and published in the journal Cancer by the American Cancer Society on March 15.”

“Monsanto's Argument: Previous evaluations conducted by the US Environmental Protection Agency (EPA) and the World Health Organization (WHO) suggest that glyphosate is not a mutagenic or carcinogenic. WHO and the Food and Agriculture Organization (FAO) have approved the safety of glyphosate residues in genetically-engineered Roundup Ready soyabeans. [b] PAN's Counter Argument:

The EPA and WHO evaluations were done more than five years ago and based mainly on data submitted to them by Monsanto. These evaluations did conclude that "there is no evidence of mutagenicity or

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. [a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.



Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. [b] Tu et al. (2001, as revised through 2005) concluded

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carcinogenicity" based on the available data, but they do not support definitive assertions that glyphosate "is not mutagenic or carcinogenic". Previous EPA and WHO evaluations which made similar claims for other chemicals had to be revised as new evidence came to light.

The establishment of the WHO's Acceptable Daily Intake (ADI) is based on limited studies using limited parameters which do not account for vulnerable groups such as children, the elderly, the sick and other groups that might have increased susceptibility to glyphosate exposure.”

“Concerns Over Glyphosate Use” The Sun (Malaysia), Friday August 20, 1999 http://www.poptel.org.uk/panap/archives/glywb.htm

that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

Herbicide Safety Testing Opposing View #74 – [a] “To protect our health, the U.S. Environmental Protection Agency (EPA) sets maximum legal residue levels for every pesticide, for dozens of crops. But a new study in the respected journal Toxicology has shown that, at low levels that are currently legal on our food, Roundup could cause DNA damage, endocrine disruption and cell death. The study, conducted by French researchers, shows glyphosate-based herbicides are toxic to human reproductive cells.” [b] “Solvents and surfactants, legally considered ‘inert ingredients,’ are mixed with glyphosate in products such as Roundup weed killer to create chemical formulations that increase mobility and more direct access to the cells. ‘Those same factors that aid penetration into a plant, also aid penetration into the skin,’ says Vincent Garry, professor emeritus of pathology at the University of Minnesota. ‘These chemicals are designed to kill cells.’ ”

“Herbicide manufacturers are subject to fewer rules in the testing of inert ingredients than they are for active ingredients, explains Caroline Cox, research director at the Center for Environmental Health in Oakland, Calif. ‘The tests the EPA requires for inert ingredients cover only a small range of

[a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. [b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.


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potential health problems,’ Cox says. ‘Testing for birth defects, cancer and genetic damage are required only on the active ingredients. But we’re exposed to both.’ ” “ ‘Our bodies are gigantic spider webs of chemical communications that work in the parts-per-trillion range,’ says Warren Porter, professor of zoology and environmental toxicology at the University of Wisconsin. ‘When you put so-called ‘insignificant’ amounts of toxic chemicals into the mix, you have a molecular bull in a china shop. The possibilities for impact are endless.’ ”

Kimble-Evans, Amanda “Roundup Kills more than Weeds” Mother Earth News, December 2009/January 2010 http://www.motherearthnews.com/Sustainable-Farming/Roundup-Weed-Killer-Toxicity.aspx?page=2

Herbicide Safety Testing Opposing View #75 - “Glyphosate is of relatively low oral and dermal acute toxicity. It has been placed in Toxicity Category III for these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV the lowest). The acute inhalation toxicity study was waived because glyphosate is nonvolatile and because adequate inhalation studies with end-use products exist showing low toxicity.” (Pg. 2)

“Glyphosate does not cause mutations.” (Pg. 2) “EPA conducted a dietary risk assessment for glyphosate based on a worst-case risk scenario, that is, assuming that 100 percent of all possible commodities/acreage were treated, and assuming that tolerance-level residues remained in/on all treated commodities. The Agency concluded that the chronic dietary risk posed by glyphosate food uses is minimal.” (Pg. 3)

“Occupational and residential exposure to glyphosate can be expected based

This comment supports data from the project record.

EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).


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http://www.motherearthnews.com/Sustainable-Farming/Roundup-Weed-Killer-Toxicity.aspx?page=2




on its currently registered uses. However, due to glyphosate's low acute toxicity and the absence of other toxicological concerns (especially carcinogenicity), occupational and residential exposure data are not required for reregistration.” (Pg. 3)

“Glyphosate is no more than slightly toxic to birds and is practically nontoxic to fish, aquatic invertebrates and honeybees. Due to the presence of a toxic inert ingredient, some glyphosate end-use products must be labeled, ‘Toxic to fish,’ if they may be applied directly to aquatic environments. Product labeling does not preclude off-target movement of glyphosate by drift. EPA therefore is requiring three additional terrestrial plant studies to assess potential risks to nontarget plants.

EPA does not expect that most endangered terrestrial or aquatic organisms will be affected by the registered uses of glyphosate.” (Pg. 4) “Based on current data, EPA has determined that the effects of glyphosate on birds, mammals, fish and invertebrates are minimal.” (Pg. 5) “Regulatory Conclusion

The use of currently registered pesticide products containing the isopropylamine and sodium salts of glyphosate in accordance with the labeling specified in this RED will not pose unreasonable risks or adverse effects to humans or the environment. Therefore, all uses of these products are eligible for reregistration.” (Pg. 6) “R.E.D. FACTS Glyphosate”

EPA publication - EPA-738-F-93-011, September 1993 http://www.epa.gov/oppsrrd1/REDs/factsheets/0178fact.pdf

Herbicide Safety Testing Opposing View #76 - “The findings of Richard et al. (2005) are an important addition to our understanding that the health and environmental effects of formulated pesticide products are not fully reflected in tests conducted on the active ingredient(s) alone. It has been long known that the adjuvants (commonly and misleadingly called "inert"


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ingredients) may be toxic and may enhance or supplement the toxic effects of the active pesticidal ingredient. In the case of glyphosate-containing products, this phenomenon was well demonstrated in the data submitted to the (EPA) by the registrant (Monsanto), and summarized by the U.S. EPA in the Reregistration Eligibility Document (RED) for glyphosate (U.S. EPA 1993). For example, based on the registrant's own tests of acute toxicity to freshwater fish, the U.S. EPA classified technical grade glyphosate as "slightly toxic" to "practically non-toxic" and formulated products ranged from "moderately toxic" to "practically non-toxic." Tested alone, the surfactant adjuvant (identified as "inert") was "highly toxic" to "slightly toxic." Similar differences were reported in tests of acute toxicity to freshwater invertebrates. Based in part on the data in the glyphosate RED (U.S. EPA 1993), the New York State Attorney General's office successfully pursued an action against Monsanto in 1996 (Attorney General of the State of New York 1996). At that time, Monsanto was making advertising claims about the toxicity of the Roundup products based on data from tests on the active ingredient alone. Such claims are scientifically unfounded and inherently deceptive. The Attorney General's action was facilitated by the availability of at least some limited information about the inert ingredients and their toxicity. That same sort of information enabled Richard et al. (2005) to conduct their study. Unfortunately, that is not always the case, and for many pesticide products, little or no information about the identity of inert ingredients is publicly available. Registrants are generally required to conduct acute toxicity tests on formulated products, but they traditionally conduct chronic toxicity tests on the active ingredient alone. Even when formulated products are tested, the identity of inert ingredients is rarely revealed in the open literature, publicly available regulatory documents, or product labels. Therefore, independent research is stymied, and the public is ill-informed in the marketplace.”

Séralini, Gilles-Eric “Issue: Cumulative Impacts to Amphibians


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Species” A Laboratoire de Biochimie et Biologie Moleculaire publication, Université de Caen, February 2006 http://www.signaloflove.org/clearcutting/reports/cumulativeimpactstoamphibian

Herbicide Safety Testing Opposing View #77 - “FACT: The EPA (Environmental Protection Agency) does not test pesticides for safety. It relies on the manufacturers’ test data to make judgments. Recent probes have found that the experiments on which these data have been based, have been designed to show only what the manufacturer would like them to show. This criticism of self-serving misrepresentation can be aimed equally validly at irresponsible experimenters bent on demonstrating toxicity of a given pesticide. It seems that however this problem is approached, the EPA needs to take more affirmative action and responsibility. This is not likely to happen, as the EPA’s research program increasingly relies on corporate joint venture, according to agency documents obtained by Public Employees for Environmental Responsibility (PEER). Indeed, a study by the Government Accountability Office (the investigative arm of Congress – the same people who first told us of the $640 toilet seats and $1,000 hammers purchased with Department of Defense money), in April 2005, concluded that the EPA lacks safeguards to “evaluate or manage potential conflicts of interest” in corporate research agreements, as they are taking money from corporations that they are supposed to be regulating.”

“MYTH: The Government tests pesticides for safety before they are sold” Wild Ones Journal, Nov 17, 2006 http://www.for-wild.org/download/roundupmyth/roundupmyth.html

The article link provided by Mr. Artley does not contain the excerpts cited in this comment; thus, we were unable to locate and review the cited information. The link currently (as of August 2013) is an opinion piece that provides a discussion on the “need to control [invasive species] for the sake of a large number of natives that are being displaced by these plants, and ecosystems that are being disrupted.” The article further states that “To gain control of these culprits we may need to consider the thoughtful and careful use of herbicides.” The article then describes how glyphosate may be used in a way that is consistent with the mission of Wild Ones to “promote biodiversity and sustainable practices.” The response below is based on information contained in the project record.


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http://www.for-wild.org/download/roundupmyth/roundupmyth.html



Herbicide Safety Testing Opposing View #78 - “FACT: The primary focus of the Federal Insecticide, Fungicide, and Rodenticide Act, originally enacted in 1947, was to provide federal control of pesticide distribution, sale, and use. The act has been amended many times over the years. One of these amendments permitted manufacturers protection of trade secrets. It is under these provisions that manufacturers circumvent a law that originally intended all information to be known – at least by the EPA. The fact that today, with mass spectrometers, chemistry can determine the makeup of the inert ingredients, leaves only the end consumer in the dark.

In 1990 the Office of the Attorney General of New York filed a request that all inert ingredients in pesticides be made public. The request was repeated a number of times through the decade, to no avail. Sixteen years later, in August of 2006, the attorneys general of 14 states have filed a similar petition to the EPA. This time the EPA is obliged to respond within a given time period.”

“MYTH: There are laws…” Wild Ones Journal, Nov 17, 2006 http://www.for-wild.org/download/roundupmyth/roundupmyth.html

The article link provided by Mr. Artley does not contain the excerpts cited in this comment; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.


Herbicide Safety Testing Opposing View #79 - “A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].”

“In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

“O' Neill concluded: 'The EPA when authorising Monsanto's field trials for




Pesticide application on the Forest is completed by

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Roundup-ready sugar beet did not consider the issue of glyphosate. They considered this to be the remit of the Pesticides Control Service of the Department of Agriculture. Thus nobody has included the effects of increasing the use of glyphosate in the risk/benefit analysis carried out. It is yet another example of how regulatory authorities supposedly protecting public health have failed to implement the 'precautionary principle' with respect to GMOs.' “ O' Neill, Sadhbh “RoundUp—Lymphoma Connection” Genetic Concern, June 22, 1999 http://www.hancock.forests.org.au/docs/herbicidesUpdate0602.htm

employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Herbicide Safety Testing Opposing View #80 – [a] “Glyphosate-containing products are acutely toxic to animals, including humans. Symptoms include eye and skin irritation, cardiac depression, gastrointestinal pain, vomiting, and accumulation of excess fluid in the lungs. The surfactant used in a common glyphosate product (Roundup) is more acutely toxic than glyphosate itself; the combination of the two is yet more toxic.”

[b] “Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices.” “Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data." “44

“IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate-containing products were performed by IBT, including 11 of the 19 chronic toxicology studies.45 A compelling example of the poor quality of IBT data comes from an EPA toxicologist who wrote, "It is also somewhat difficult

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. [b] Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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not to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination." “46 (Emphasis added.) “In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262 pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.” “49 “The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.”48 Cox, Caroline. “Glyphosate, Part 1: Toxicology” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995 http://terrazul.org/Archivo/Glyphosate_Fact_Sheets.pdf

Herbicide Safety Testing Opposing View #81 - “EPA Investigates Monsanto An internal memorandum by an official of the U.S. Environmental Protection Agency [EPA], has accused EPA of conducting a "fraudulent" criminal investigation of Monsanto, the St. Louis chemical corporation. [1] The 30-page memo, from William Sanjour to his supervisor, David Bussard, dated July 20, 1994, describes a two-year-long criminal investigation of Monsanto by EPA's Office of Criminal Investigation (OCI).

The Sanjour memo says EPA opened its investigation on August 20, 1990 and formally closed it on August 7, 1992. "However, the investigation itself and the basis for closing the investigation were fraudulent," the Sanjour


Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the

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http://www.ejnet.org/rachel/rhwn400.htm%231



memo says.

According to the Sanjour memo:

• EPA's investigation of Monsanto was precipitated by a memo dated February 23, 1990, from EPA's Dr. Cate Jenkins to Raymond Loehr, head of EPA's Science Advisory Board.

• The Jenkins memo said that EPA had set dioxin standards relying on flawed Monsanto-sponsored studies of Monsanto workers exposed to dioxin, studies that had showed no cancer increases among heavily exposed workers.

• Attached to the Jenkins memo was a portion of a legal brief filed by the plaintiffs as part of a trial known as Kemner v. Monsanto, in which a group of citizens in Sturgeon, Missouri had sued Monsanto for alleged injuries they had suffered during a chemical spill caused by a train derailment in 1979.

• The Jenkins memo had not requested a criminal investigation; instead Jenkins had suggested the need for a scientific investigation of Monsanto's dioxin studies. But in August 1990, EPA's Office of Criminal Investigation (OCI) wrote a 7-page memo recommending that a "full field criminal investigation be initiated by OCI."

• Plaintiffs in the Kemner suit made the following kinds of allegations (which we quote verbatim from the Sanjour memo):

“Monsanto failed to notify and lied to its workers about the presence and danger of dioxin in its chlorophenol plant, so that it would not have to bear the expense of changing its manufacturing process or lose customers;...

"Monsanto knowingly dumped 30 to 40 pounds of dioxin a day into the Mississippi River between 1970 and 1977 which could enter the St. Louis food chain; "Monsanto lied to EPA that it had no knowledge that its plant

registrants (SERA 2011).




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effluent contained dioxin;

"Monsanto secretly tested the corpses of people killed by accident in St. Louis for the presence of dioxin and found it in every case;...

"Lysol, a product made from Monsanto's Santophen, was contaminated with dioxin with Monsanto's knowledge." [The Sanjour memo says that, at the time of the contamination, "Lysol (was) recommended for cleaning babies' toys and for other cleaning activities involving human contact."]

"The manufacturer of Lysol was not told about the dioxin by Monsanto for fear of losing his business;

"Other companies using Santophen, who specifically asked about the presence of dioxin, were lied to by Monsanto;... "Shortly after a spill in the Monsanto chlorophenol plant, OSHA measured dioxin on the plant walls. Monsanto conducted its own measurements, which were higher than OSHA's, but they issued a press release to the public and they lied to OSHA and their workers saying they had failed to confirm OSHA's findings;

"Exposed Monsanto workers were not told of the presence of dioxin and were not given protective clothing even though the company was aware of the dangers of dioxin;

"Even though the Toxic Substances Control Act requires chemical companies to report the presence of hazardous substances in their products to EPA, Monsanto never gave notice and lied to EPA in reports; "At one time Monsanto lied to EPA saying that it could not test its products for dioxin because dioxin was too toxic to handle

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in its labs."...

“EPA Investigates Monsanto” RACHEL'S HAZARDOUS WASTE NEWS #400, July 28, 1994 http://www.ejnet.org/rachel/rhwn400.htm

Herbicide Safety Testing Opposing View #82 – [a] “A study by French researchers at the University of Caen of glyphosate residue discovered that the inert ingredients in the herbicide (solvents, preservatives, surfactants) increased the toxic effect on human cells. According to the researchers, glyphosate residue can cause birth defects. “This clearly confirms that the [inert ingredients] in Roundup formulations are not inert,” wrote the study authors. “Moreover, the proprietary mixtures available on the market could cause cell damage and even death [at the] residual levels” found on Roundup-treated crops.” [b] “Another study by Argentine scientists also found that glyphosate can cause birth defects at doses considerably lower than what is commonly used on crops, in this case, soybeans. The researchers injected amphibian embryo cells with glyphosate diluted to a concentration 1,500 times less than what is used commercially. The embryos grew into tadpoles with obvious birth defects.” “A 2001 study by Swedish oncologists discovered links between non-Hodgkin’s lymphoma and glyphosate. The Swedish researchers found that Swedish people with non-Hodgkin’s lymphoma were 2.3 times more likely to be exposed to glyphosate.

Monsanto spokesperson John Combest defended the safety of Roundup. “Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that’s out there. It’s used in public parks, it’s used to protect schools. There’s been a great deal of study on Roundup, and we’re very proud of its performance.” “

Cheeseman, Gina-Marie, “Can A Company That Makes Roundup Be

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment.


Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a

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http://www.ejnet.org/rachel/rhwn400.htm



http://www.gmwatch.org/latest-listing/1-news-items/11252-roundup-proves-deadly-to-human-cells

http://www.triplepundit.com/author/ginamarie/


Comment Forest Service Response Sustainable?” TriplePundit, November 20th, 2009 http://www.triplepundit.com/2009/11/can-a-company-that-makes-roundup-be-sustainable/

certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Herbicide Safety Testing Opposing View #83 - “Over twenty years ago, the dangers of Monsanto's glyphosate as well as its associated GMOs were known scientifically to cause human health difficulties and Swedish researchers years ago in the Journal 'Cancer' noted glyphosate was connected to human cancer. Anyway, many scientists and public health workers researching it were fired. It's a mad empire's rush--the U.S empire and its corporate proxies--to desire (hell, the reality of) to own the world's food and dominate the whole world. It is destroying thousands of years of biodiversity security in the process. And Monsanto's empire of glyphosate is in virtually everything in the USA and worldwide. One foolish company, one corrupt federal government of the USA. Everyone should learn more about Monsanto in the film "The World According to Monsanto." (90 minutes). Monsanto's corporate contract should be revoked for endangering world health and killing off global crop biodiversity of thousands of years of work destroyed in one generation--in the mad rush to dominate the whole world's biodiversity.

Monsanto and the USA will go down in history as the organizations that caused most biological devastation and human suffering in human history.”

“MONSANTO RoundUp (glyphosate) Empire causes BIRTH DEFECTS...in amphibian embryos, humans?” Portland independent media center, May 3, 2009 http://portland.indymedia.org/en/2009/05/391045.shtml






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http://www.triplepundit.com/2009/11/can-a-company-that-makes-roundup-be-sustainable/





Herbicide Safety Testing Opposing View #84 - “BUENOS AIRES, Apr 15 , 2009 (IPS) - Glyphosate, the herbicide used on soybeans in Argentina, causes malformations in amphibian embryos, say scientists here who revealed the findings of a study that has not yet been published.”

"The observed deformations are consistent and systematic," Professor Andrés Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires medical school and lead researcher on the National Council of Scientific and Technical Research (CONICET), told the Inter Press Service news agency IPS.

Reduced head size, genetic alterations in the central nervous system, an increase in the death of cells that help form the skull, and deformed cartilage were effects that were repeatedly found in the laboratory experiments, said the biologist.

The news was reported Monday by the Argentine newspaper Página 12.

Monsanto’s head of communications in Argentina, Fernanda Pérez Cometto, told IPS that the company has "several studies that show that the herbicide is harmless to humans, animals and the environment."

Valente, Marcela “Scientists Reveal Effects of Glyphosate” HEALTH-ARGENTINA, April 15 , 2009 http://www.ipsnews.net/news.asp?idnews=46516

The piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature.

Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).

Herbicide Safety Testing Opposing View #85 – [a] “It’s amazing how many organics people still think it’s OK to just use a bit of Roundup on those weeds in the bush or the driveway, or …. of course, not on the food, but the bush, that’s OK isn’t it?

Well, no, actually it isn’t, and here’s why: Roundup and various other formulations of the active ingredient glyphosate, have the potential to cause serious health and environmental effects, and have caused some severe poisoning problems. [b] Thorough PR by the developer of Roundup, Monsanto, has resulted in the widespread belief that glyphosate is ‘safe’. Registration processes have generally supported this attitude, and there are no national or international bans. However, independent scientific studies and widespread poisonings in


[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when

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http://www.ipsnews.net/news.asp?idnews=46516



Latin America resulting from aerial application are beginning to reveal the true effects of the world’s most widely used herbicide.”

Watts, Meriel Ph.D. “Roundup's Not OK” ORGANIC NZ, November/December 2009

http://www.livingorganics.co.nz/roundups-not-ok.php

used as intended and label directions are followed.

[b] As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs. Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, and truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013).

Herbicide Safety Testing Opposing View #86 - Research on genetically modified seeds is still published, of course. But only studies that the seed companies have approved ever see the light of a peer-reviewed journal. In a number of cases, experiments that had the implicit go-ahead from the seed company were later blocked from publication because the results were not flattering. "It is important to understand that it is not always simply a matter of blanket denial of all research requests, which is bad enough," wrote Elson J. Shields, an entomologist at Cornell University, in a letter to an official at the Environmental Protection Agency (the body tasked with regulating the environmental consequences of genetically modified crops), "but selective

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily

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denials and permissions based on industry perceptions of how ’friendly’ or ’hostile’ a particular scientist may be toward [seed-enhancement] technology." Shields is the spokesperson for a group of 24 corn insect scientists that opposes these practices. Because the scientists rely on the cooperation of the companies for their research - they must, after all, gain access to the seeds for studies - most have chosen to remain anonymous for fear of reprisals. The group has submitted a statement to the EPA protesting that "as a result of restricted access, no truly independent research can be legally conducted on many critical questions regarding the technology." It would be chilling enough if any other type of company were able to prevent independent researchers from testing its wares and reporting what they find - imagine car companies trying to quash head-to-head model comparisons done by Consumer Reports, for example. But when scientists are prevented from examining the raw ingredients in our nation’s food supply or from testing the plant material that covers a large portion of the country’s agricultural land, the restrictions on free inquiry become dangerous.

“Do Seed Companies Control GM Crop Research?” Scientific American, Editorial, August 2009 edition, published 21 July 2009 Reprinted by Combat-Monsanto.org http://www.combat-monsanto.co.uk/spip.php?article399

identified and less likely to be consumed by humans.

Herbicide Safety Testing Opposing View #87 - “France’s highest court has ruled that U.S. agrochemical giant Monsanto had not told the truth about the safety of its best-selling weed-killer, Roundup. The court confirmed an earlier judgment that Monsanto had falsely advertised its herbicide as “biodegradable” and claimed it “left the soil clean.” Roundup is the world’s best-selling herbicide.


Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are

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http://www.scientificamerican.com/article.cfm?id=do-seed-companies-control-gm-crop-research

http://www.combat-monsanto.co.uk/spip.php?article399



French environmental groups had brought the case in 2001 on the basis that glyphosate, Roundup’s main ingredient, is classed as “dangerous for the environment” by the European Union. In the latest ruling, France’s Supreme Court upheld two earlier convictions against Monsanto by the Lyon criminal court in 2007, and the Lyon court of appeal in 2008, the AFP news agency reports.

Monsanto already dominates America’s food chain with its genetically modified seeds. Now it has targeted milk production. Just as frightening as the corporation’s tactics, including ruthless legal battles against small farmers, is its decades-long history of toxic contamination.” France Finds Monsanto Guilty of Lying Infowars Ireland, November 23, 2009

http://info-wars.org/2009/11/23/france-finds-monsanto-guilty-of-lying/

minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Herbicide Safety Testing Opposing View #88 – [a] “Monsanto created Roundup in the 1970's to kill weeds and has since catapulted this product to be the world's number one selling herbicide. Before the patent on Roundup was set to expire in 2000, Monsanto needed a surefire way to keep the profits of Roundup from bottoming out. Monsanto quickly began purchasing the majority of the world's seed companies while simultaneously creating GMOs that farmers needed to sign contractual agreements to only use Roundup. Subsequently, revenue from Roundup never dropped and in fact topped more than $4 billion in 2008, up 59% from 2007 [2]. GM-soy is estimated to be present in up to 70% of all food products found in US supermarkets, including cereals, breads, soymilk, pasta and most meat (as animals are fed GM-soy feed). Although Monsanto has consistently relied on industry-funded data to declare the safety of GM-soy and glyphosate, objective research published in peer-reviewed journals tells another story.

[a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. [b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. EPA classified glyphosate as a “Group E” carcinogen

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http://info-wars.org/author/protocol22/


http://www.naturalnews.com/herbicide.html

http://www.naturalnews.com/Monsanto.html

http://www.naturalnews.com/farmers.html

http://www.naturalnews.com/food.html



[b] Toxicity of Glyphosate

A recently published study by Italian researchers [3] examined the toxicity of four popular glyphosate based herbicide formulations on human placental cells, kidney cells, embryonic cells and neonate umbilical cord cells and surprisingly found total cell death of each of these cells within 24 hours. The researchers reported several mechanisms by which the herbicides caused the cells to die including: cell membrane rupture and damage, mitochondrial damage and cell asphyxia. Following these findings, the researchers tested G, AMPA and POEA by themselves and concluded that, "It is very clear that if G, POEA, or AMPA has a small toxic effect on embryonic cells alone at low levels, the combination of two of them at the same final concentration is significantly deleterious.” Damato, Gregory Ph.D., “GM-Soy: Destroy the Earth and Humans for Profit”

Fourwinds10.com, May 27, 2009 http://www.fourwinds10.com/siterun_data/science_technology/dna_gmo/news.php?q=1243529527

or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).

Herbicide Safety Testing Opposing View #89 - “If you're still not convinced that Roundup is a highly toxic and persistent pesticide, read on, while at the same time remembering the other contributions that Monsanto has made to society such as: Saccharin, Astroturf, agent orange, dioxin, sulphuric acid, polychlorinated biphenyls (PCBs), plastics and synthetic fabrics, research on uranium for the Manhattan Project that led to the construction of nuclear bombs, styrene monomer, an endless line of pesticides and herbicides (Roundup), rBGH (recombinant bovine growth hormone that makes cows ill), genetically engineered crops (corn, potatoes, tomatoes, soy beans, cotton), and it's most significant product to date; Lies, Factual Distortions and Omissions. Here's one of the distortions that Monsanto had on its website a while back.



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http://www.naturalnews.com/toxicity.html

http://www.fourwinds10.com/siterun_data/science_technology/dna_gmo/news.php?q=1243529527




‘Sustainability - the idea that the resources and people of this world are finite. That for any business decision we make, we must consider the effect it will have on us and our children. That the products we make must not use up all of a natural resource, or even worse, contaminate what is left behind.’ " “Everything you Never Wanted to Know about Monsanto’s Modus Operandi (M.O.)” Mindfully.org http://www.mindfully.org/Pesticide/Monsanto-Roundup-Glyphosate.htm

Herbicide Safety Testing Opposing View #90 – [a] “ "The U.S. response (to questions about biotech crop safety) has been an extremely patronizing one. They say 'We know best, trust us,'" added Gurian-Sherman, now a senior scientist at the Union of Concerned Scientists, a nonprofit environmental group.” “So far, that confidence has been lacking. Courts have cited regulators for failing to do their jobs properly and advisers and auditors have sought sweeping changes.” “The developers of these crop technologies, including Monsanto and its chief rival DuPont, tightly curtail independent scientists from conducting their own studies. Because the companies patent their genetic alterations, outsiders are barred from testing the biotech seeds without company approvals.” “The agreements disallow any research that is not first approved by the companies. "No truly independent research can be legally conducted on many critical questions regarding the technology," the scientists said in their statement.” [b] “Outside researchers have also raised concerns over the years that glyphosate use may be linked to cancer, miscarriages and other health problems in people.”

Gillam, Carey “Patents Trump Public Interest in Monsanto's Ag


[a] Concerns about conduct and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011). [b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area

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Empire - Special Report: Are Regulators Dropping the Ball on Biocrops?” Reuters, April 13, 2010


the same day.


Herbicide Safety Testing Opposing View #91 – “Defining Toxic Asbestos is an extreme example, which I use here and in my book Pick Your Poison: How Our Mad Dash to Chemical Utopia is Making Lab Rats of Us All to make a point, but many other “nontoxic” products could be full of toxic chemicals. I’m hoping this essay leaves you with a general distrust of the nontoxic label, both in the past and currently. When you see “nontoxic” on a product, keep the following facts in mind:

• “Nontoxic” can still legally mean that there are no immediate, acute hazards as determined by the LD50 and LC50 tests.

• “Nontoxic” may mean there are little or no chronic data available on the substance. If the substance is not acutely toxic, and one can’t prove it is toxic in the long term, many manufacturers feel that they have the right to call it nontoxic. Even if there are studies showing that the substance is toxic, manufacturers in the United States have traditionally waited for absolute, unequivocal proof, which in most cases is never available because we don’t study our chemicals.

• An art material is “nontoxic” if a toxicologist paid by the manufacturer decides it is safe. The dramatic failure in this labeling procedure was illustrated with the lead ceramic glazes and asbestos-

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

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http://www.powells.com/partner/32513/biblio/62-9780470550915-0





containing materials such as talc. Asbestos-containing talcs are still found in some art and craft materials today.

Some art materials that have never been evaluated by a toxicologist may be labeled “nontoxic” illegally due to weak enforcement of the art materials labeling law. For example, in 1995, a cameraman and a reporter from Channel 9 in New York went with me to a major art materials outlet. That night on the evening news, we showed viewers about a dozen imported products that did not conform to the law, some labeled “nontoxic,” which were being sold illegally. This is still true today, and a little research will lead you to many sources of noncompliant “nontoxic” products.

• Labeling of ordinary consumer products is pretty much up to the manufacturer and its paid advisers. Because there is no enforcement mechanism in the regulations for the chronic hazard labeling of ordinary consumer products, there is not much incentive to provide warnings.

• There is no regulatory requirement to warn consumers about damage to most of the body’s organs, such as the lungs, the liver, and the kidneys. Only four types of chronic hazards are covered by the Federal Hazardous Substances Act regulations. These are cancer, and developmental, reproductive, and neurological damage.”

Rossol, Monona “Say What? A Chemical Can Damage Your Lungs, Liver and Kidneys and Still Be Labeled "Non-Toxic"?” Ms. Rossol is a research chemist, author and member of the American Industrial Hygiene Association May 9, 2011 http://www.alternet.org/story/150888/say_what_a_chemical_can_damage_your_lungs%2C_liver_and_kidneys_and_still_be_labeled_%22non-toxic%22?page=entire

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http://www.alternet.org/story/150888/say_what_a_chemical_can_damage_your_lungs%2C_liver_and_kidneys_and_still_be_labeled_%22non-toxic%22?page=entire




Herbicide Safety Testing Opposing View #92 - Monsanto's Claims Independent Research Findings

[a] Roundup has a low irritational potential for eye and skin and otherwise is not a risk to human health.

Roundup is amongst the top most reported pesticides causing poisoning incidents (mainly skin irritation) in several countries. It also causes a range of acute symptoms including, recurrent eczema, respiratory problems, elevated blood pressure, allergic reactions.

[b] Roundup does not cause any adverse reproductive effects

In laboratory tests on rabbits glyphosate caused long lasting, harmful effects on semen quality and sperm counts.

Roundup is not mutagenic in mammals.

DNA damage has been observed in laboratory experiments in mice organs and tissue.

[c] Roundup is environmentally safe.

• In the agricultural environment, glyphosate is toxic to some beneficial soil organisms, beneficial arthropod predators, and increases crops' susceptibility to diseases.

• [d]Sub-lethal doses of glyphosate from spray drift damages wildflower communities and can affect some species up to 20 metres away from the sprayer.

• [e] The use of glyphosate in arable areas may cause dieback in

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

[b] EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).

[c] The effects to fungi are addressed by the following information: “Roberts and Berk (1993) investigated the effects of Roundup® on chemoattraction of the protozoa Tetrahymena pyriformis and found that it significantly interfered with chemoreception but not motility. Doses of glyphosate <10 ppm were stimulatory to soil microflora including actinomycetes, bacteria, and fungi, while concentrations >10 ppm had

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hedgerow trees.

[f] Roundup is rapidly inactivated in soil and water.

• Glyphosate is very persistent in soils and sediments.

• Glyphosate inhibited the formation of nitrogen fixing nodules on clover for 120 days after treatment.

• Glyphosate residues were found in lettuce, carrot, and barley when planted a year after glyphosate was applied.

Roundup is immobile and does not leach from soils.

• Glyphosate can readily desorb from soil particles in a range of soil types. It can be extensively mobile and leach to lower soil layers.

• Glyphosate can be carried by soil particles suspended in run off.

[g] Roundup does not contaminate drinking water when used by local authorities on hard surfaces.

In the UK, levels of glyphosate above the EU limit have been detected by the Welsh Water Company every year since 1993. The Drinking Water Inspectorate recommends that glyphosate be monitored, particularly, in areas where it is used by local authorities on hard surfaces.

[h] It is nearly impossible for glyphosate resistance to evolve

In 1996, glyphosate resistant ryegrass was discovered in Australia.

detrimental impacts on microflora populations in one study (Chakravarty and Sidhu 1987). While some short-term studies (<30 days) found glyphosate caused significant impacts to microbial populations, Roslycky (1982) found that these populations rebound from any temporary increase or decrease within 214 days. Similarly, Tu (1994) found that microorganisms recovered rapidly from treatment with glyphosate and that the herbicide posed no long-term threat to microbial activities” (Tu et al. 2001, as revised through 2005).

Tu et al. (2001, as revised through 2005) concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” [d] Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, and truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013).

[e] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting effects to hedgerow trees. [f] Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Feng and

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in weeds.

Outcrossing in oilseed rape crops (and the transfer of genes from transgenic crops) occurs over a short distance and can be easily managed.

The densities of oil seed rape pollen are much higher and their dispersal patterns differ from around large fields compared to those found in experimental plots. Wind dispersal of pollen occurs over much greater distances and at higher concentrations than predicted by experimental plots. Significant levels of gene flow from transgenic oil seed crops is inevitable.

Roundup Ready crops will reduce levels of herbicide use.

Herbicide resistant crops will intensify and increase dependency on herbicide use in agriculture rather than lead to any significant reductions. A variety of herbicides will have to be reintroduced to control glyphosate resistant volunteers, feral populations of crops and resistant weeds.

Source: References cited in Health and Environmental Impacts of Glyphosate, (Details available from the Pesticides Trust [now PAN UK]).

PAN UK “Resistance to glyphosate” This data was first published in Pesticides News No. 41, September 1998, page 5

http://www.pan-uk.org/pestnews/Issue/pn41/PN41p5.htm

Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990; Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005] [g] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.

In riparian zones, herbicides with aquatic labels would be used for spot treatments and applied with backpack

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sprayers, hand sprayers, or wipers to minimize application in nontarget areas. Additionally, herbicide mixing sites must be farther than 100 feet from surface water in riparian zones and more than 300 feet from surface water in NMFS Resource Areas of Concern.

Regarding fish and other aquatic organisms, Tu et al. (2001, as revised through 2005) found that “It appears that under most conditions, rapid dissipation from aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.” [h] Weed resistance is not a primary consideration in the current risk assessment except to note that application rates for glyphosate are being increased primarily in agricultural crops that are tolerant to glyphosate. Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of resistance and outcrossing.

Herbicide Safety Testing Opposing View #93 – [a] “When Sofía lost her newborn, she soon realized that such losses were all-too-common in her small community of Ituzaingó Annex. Aerial spraying with Monsanto’s herbicide RoundUp had climbed dramatically in the region as the number of acres planted with the company’s “RoundUp Ready” soy crops grew. [b] Sofía and other concerned mothers went door to door collecting stories about health problems in each family — basically conducting the community’s first-ever epidemiological study. “The Mothers of Ituzaingó”

[a] As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses

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discovered the community’s cancer rate to be 41 times the national average, and rates of neurological problems, respiratory diseases and infant mortality were astonishingly high. In response, the mothers launched a “Stop the Spraying!” campaign.”

Schafer, Kristin, “Mother takes on Monsanto, wins global prize” Published in GroundTruth, April 13, 2012 Pesticide Action Network North America

http://www.panna.org/blog/mother-takes-monsanto-wins-global-prize

resource and public safety concerns through SOPs/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs.

Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, and truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013).

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below.

Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

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http://www.panna.org/blog/mother-takes-monsanto-wins-global-prize



Herbicide Safety Testing Opposing View #94 – “But humans are much bigger than insects and the doses to humans are miniscule, right? During critical first trimester development, a human is no bigger than an insect, so there is every reason to believe that pesticides could wreak havoc with the developing brain of a human embryo. But human embryos aren't out in corn fields being sprayed with insecticides and herbicides, are they? A recent study showed that every human tested had the world's most popular pesticide, Roundup, detectable in their urine at concentrations between five and twenty times the level considered safe for drinking water.

The autism epidemic and the disappearance of bees are just two of many self-imposed disasters from allowing our world, including Utah, to be overwhelmed by environmental toxins. Environmental protection- including the smallest and most vulnerable among us - is human protection.” Moench, Brian, MD., “The Autism Epidemic and Disappearing Bees: A Common Denominator?” Published in Truthout, April 21, 2012 http://truth-out.org/news/item/8586-the-autism-epidemic-and-disappearing-bees-a-common-denominator


erbicide Safety Testing Opposing View #95 – “A formula seems to have been made to not only ruin the agricultural system, but also compromise the health of millions of people worldwide. With the invent of Monsanto’s Roundup Ready crops, resistant superweeds are taking over farmland and public health is being attacked. These genetically engineered crops are created to withstand large amounts of Monsanto’s top-selling herbicide, Roundup. As it turns out, glyphosate, the active ingredient in Roundup, is actually leaving behind its residue on Roundup Ready crops, causing further potential concern for public health.” Barrett, Mike, “Monsanto’s Roundup Ready Crops Leading to Mental


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http://www.ithaka-journal.net/herbizide-im-urin

http://truth-out.org/news/item/8586-the-autism-epidemic-and-disappearing-bees-a-common-denominator

http://truth-out.org/news/item/8586-the-autism-epidemic-and-disappearing-bees-a-common-denominator

http://naturalsociety.com/monsantos-roundup-superweeds-consuming-4-million-hectares/



Illness, Obesity” Natural Society, December 15, 2011 Source: http://naturalsociety.com/monsanto-roundup-ready-crops-decreased-gut-flora/

Herbicide Safety Testing Opposing View #96 – “Asked about the harmlessness of Roundup, Lovera replies, “That’s the PR behind Roundup – how benign it was and you can drink it and there’s nothing to worry about here. There are people who dispute that.” For example there is an accusation that Roundup causes birth defects. “We don’t buy the benign theory,” continues Lovera, “But what’s really interesting is that we aren’t going to be having this conversation pretty soon because Roundup isn’t working anymore.” Jill Richardson, “Monsanto controls our food, poisons our land, and influences all three branches of government.” Alternet, April 18, 2013 Source: http://www.alternet.org/food/how-monsanto-went-selling-aspirin-controlling-our-food-supply?paging=off

Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. To maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Herbicide Safety Testing Opposing View #97 – “Heavy use of the world's Project areas where glyphosate application may be

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http://naturalsociety.com/monsanto-roundup-ready-crops-decreased-gut-flora/

http://naturalsociety.com/monsanto-roundup-ready-crops-decreased-gut-flora/

http://www.theecologist.org/blogs_and_comments/commentators/other_comments/938661/the_inside_story_on_monsanto_and_the_glyphosate_birth_defect_data.html

http://www.alternet.org/food/how-monsanto-went-selling-aspirin-controlling-our-food-supply?paging=off

http://www.alternet.org/food/how-monsanto-went-selling-aspirin-controlling-our-food-supply?paging=off



most popular herbicide, Roundup, could be linked to a range of health problems and diseases, including Parkinson's, infertility and cancers, according to a new study. The peer-reviewed report, published last week in the scientific journal Entropy, said evidence indicates that residues of "glyphosate," the chief ingredient in Roundup weed killer, which is sprayed over millions of acres of crops, has been found in food. Those residues enhance the damaging effects of other food-borne chemical residues and toxins in the environment to disrupt normal body functions and induce disease, according to the report, authored by Stephanie Seneff, a research scientist at the Massachusetts Institute of Technology, and Anthony Samsel, a retired science consultant from Arthur D. Little, Inc. Samsel is a former private environmental government contractor as well as a member of the Union of Concerned Scientists.”

Carey Gillam, “Heavy use of herbicide Roundup linked to health dangers-U.S. study” Reuters, April 25, 2013

Source: http://www.reuters.com/article/2013/04/25/roundup-health-study-idUSL2N0DC22F20130425

needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.





Conclusion The results of independent, unbiased research on glyphosate-containing herbicides indicate this chemical is causing: birth defects, non-Hodgkin’s lymphoma, mitochondrial damage, cell asphyxia, miscarriages, attention deficit disorder, endocrine disruption, DNA damage, skin tumors, thyroid damage, hairy cell leukemia, Parkinson

As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Agency endorses use of an integrated weed management program that selects

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http://www.reuters.com/article/2013/04/25/roundup-health-study-idUSL2N0DC22F20130425

http://www.reuters.com/article/2013/04/25/roundup-health-study-idUSL2N0DC22F20130425



disease, premature births, decrease in the sperm count, harm to the immune system in fish, death of liver cells, severe reproductive system disruptions and chromosomal damage.

the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through SOPs/mitigation.





Of course the Responsible Official will stop at nothing trying to disprove and ridicule the authors and source documents. How? The Responsible Official will claim they are:

not peer reviewed,

“gray” literature,

As required by CEQ at 40 CFR Sec. 1503.4, “Response to comments”:

(a) An agency preparing a final environmental impact statement [or environmental assessment] shall assess and consider comments both individually and collectively, and shall respond by one or more of the

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trade journals,

subscriptions published by industrial/environmental organizations, newspapers, magazines, and internet blogs, and just opinions

means listed below, stating its response in the final statement. Possible responses are to:

1) Modify alternatives including the proposed action. 2) Develop and evaluate alternatives not previously

given serious consideration by the agency. 3) Supplement, improve, or modify its analyses. 4) Make factual corrections. 5) Explain why the comments do not warrant further

agency response, citing the sources, authorities, or reasons which support the agency's position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or further response.

(b) All substantive comments received on the draft statement (or summaries thereof where the response has been exceptionally voluminous), should be attached to the final statement whether or not the comment is thought to merit individual discussion by the agency in the text of the statement. (c) If changes in response to comments are minor and are confined to the responses described in paragraphs (a)(4) and (5) of this section, agencies may write them on errata sheets and attach them to the statement instead of rewriting the draft statement. In such cases only the comments, the responses, and the changes and not the final statement need be circulated (Sec. 1502.19). The entire document with a new cover sheet shall be filed as the final statement (Sec. 1506.9).

As displayed above, all comments received in Attachment 9a have been responded to and addressed in 1 or more of the 5 ways identified above under 40

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CFR 1503.4(a). When a linked article in a comment could not be located so as to allow the Agency to fully understand the context of the comment, the Agency responded based on what was provided as a quote or paraphrase from the identified document. Responses may also indicate that the referenced article is gray literature, not peer reviewed, etc., if that fact is relevant to the subsequent Agency response.

Please read Dan Rather’s very recent September 22, 2011 investigative report about the EPA’s corrupt approval process of man-made chemicals: http://www.panna.org/blog/dan-rather-pesticides-bees

Mr. Rather’s report is in reference to the toxicity of neonicotinoids, a class of insecticide widely considered by some beekeepers to be a causal factor in honeybee colony collapse disorder. Herbicides proposed for use to address nonnative or noxious weeds in the Project area, such as glyphosate, do not contain neonicotinoids.

Ask yourself this. Am I willing to subject animals and/or humans to a painful cancer death based on 10 year-old USFS data provided to them by the Monsanto Corporation? Any reasonable land manager would never apply this herbicide given the evidence.

The EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns. Regarding the use of herbicides, the Agency does not rely on any single source of information to make a determination of what would be the proper and safe use of herbicides. A primary source of information that guides the Agency in its use of herbicides is the “Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas.” This document was published by an independent conservation organization, “The Nature Conservancy Wildland Invasive Species Team,” (Tu et al. 2001, with revisions through 2005).

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http://www.panna.org/blog/dan-rather-pesticides-bees



Would you allow your kids/relatives to expose themselves to this poison? Then why do you assault others people with the deadly substance … especially when there are alternatives to noxious weed eradication? How do you sleep at night knowing your actions might cause birth defects, non-Hodgkin’s lymphoma, mitochondrial damage, cell asphyxia, miscarriages, attention deficit disorder, endocrine disruption, DNA damage, skin tumors, thyroid damage, hairy cell leukemia, Parkinson disease, premature births, decrease in the sperm count, harm to the immune system in fish, death of liver cells, severe reproductive system disruptions and chromosomal damage? You know what to do.


The EA will be edited to state that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns.

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Table D-119. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review EA Opposing Views—Attachment #11—Cohen


ANY NEPA Document that Analyzes Treatments to Reduce the Risk of Fire Damage to Homes

Located in the WUI must Analyze a Dr. Jack Cohen Alternative in Detail.

EA section 2.3 (Alternatives Eliminated from Detailed Study) and section 2.4 (Alternatives Analyzed in Detail) describe the alternatives that were considered for the Project. The responses below disclose how these alternatives address Dr. Cohen’s research and conclusions.

Dr. Cohen’s background Dr. Jack Cohen is a research fire physicist who does his research in the Forest Service's Missoula Fire Sciences Laboratory at the Rocky Mountain Research Station. Dr. Cohen is a Forest Service employee. His research findings clearly show that commercial logging to reduce fuels will not protect homes from wildfire damage in the Wildland Urban Interface (WUI).

Dr. Cohen’s Research Findings Represent Best Science and Empirical Evidence Shows his Fire Damage Risk Reduction Methods that remove the Fine Fuels Near the Home are Far Superior to Hazardous Fuel Removal Dr. Cohen Is likely the only Ph.D. fire physicist in America who specializes in determining the best actions to reduce the risk of wildfire damage to homes. Dr. Cohen is a well published scientist-author. He has published 12 peer-reviewed scientific papers summarizing his research findings.

Please see the responses to views #1 through #50, below.

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Independent Sources Emphasize the Effectiveness of Dr. Cohen’s Fire Damage Risk Reduction Methods “Homeowners are their own first line of defense. Saving a home from wildfire depends primarily on two factors: roofing material and the quality of the “defensible space” surrounding it.

8 Research Physical Scientist Jack

Cohen noted after visiting homes that survived the Rodeo-Chediski Fire and those that were consumed, that had homeowners followed guidelines for creating defensible space—described as creating an area around a structure where fuels and vegetation are treated, cleared, or reduced to slow the spread of fire—more homes would have survived.”

Fact Sheet: Understanding Fire and Fire Behavior Ontario Aviation and Forest Fire Management http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf

Please see the responses to views #1 through #50, below. The Clear Creek EA disclosures are consistent with Dr. Cohen’s conclusions concerning the importance of creating defensible space around structures and the contribution of these treatments to reducing risk of impacts from wildfire. The EA disclosures also concur with Dr. Cohen’s conclusion that such risk would remain elevated if no treatments are implemented.

Dr. Cohen’s opposing view #1–“Research results indicate that the home and its immediate surroundings within 100-200 feet (30-60 meters) principally determines the home ignition potential during severe wildland-urban fires. Research has also established that fire is an intrinsic ecological process of nearly all North American ecosystems. Together, this understanding forms the basis for a compelling argument for a different approach to addressing the wildland-urban fire problem.” (Pg. 1 – abstract) Source: Wildland-Urban Fire—A different approach http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf

The paper referred to in view #1 is not available at the location provided and could not be readily located elsewhere. The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed.

The 100–200 feet of the home ignition zone is NFS land. The Forest Service supported the collaborative

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http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf

http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf



group as requested and is trying to treat the home ignition zone prior to the arrival of a wildland fire, as suggested by Dr. Cohen. EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1).

Furthermore, EA section 3.3.3 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

Dr. Cohen’s opposing view #2–“A senior physicist at the Stanford Research Institute, C.P. Butler (1974), coined the term "urban-wildland interface" and described this fire problem as follows:

"In its simplest terms, the fire interface is any point where the fuel feeding a wildfire changes from natural (wildland) fuel to man-made (urban) fuel.” (Pg. 1)

Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

View #2 presents one definition of a wildland-urban interface (WUI). For the Project, a different definition, from the National Wildfire Coordination Group (NWCG), was applied to assist in the identification of the WUI. This definition describes a WUI as “an area where residential developments intermingle with wildland fuel” (EA section 3.3.1). In the Project, WUI stands were further delineated based on proximity to values at risk (e.g., summer homes), alignment of prevailing wind, and the CI and SFL assessments (project record Fire and Fuels Technical Report).

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Dr. Cohen’s opposing view #3–“The results of the diverse analytical methods are congruent and consistently indicate that ignitions from flames occur over relatively short distances--tens of meters not hundreds of meters. The severe-case estimate of SIAM indicates distances of 40 meters or less. Experimental wood walls did not ignite at 10 meters when exposed to experimental crown fires. And, case studies found that vegetation clearance of at least 10 meters was associated with a high occurrence of home survival.” (Pg. 4) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed.

The WUI treatments proposed in the Project will thin vegetation around the structures within 10 meters of the structures, a distance supported by the cited publication (see EA section 3.3.5.2.2).

Dr. Cohen’s opposing view #4–“Analyses of southern California home losses done by the Stanford Research Institute for the 1961 Belair-Brentwood Fire (Howard and others 1973) and by the University of California, Berkeley, for the 1990 Painted Cave Fire (Foote and Gilless 1996) are consistent with SIAM estimates and the experimental crown fire data. Given nonflammable roofs, Stanford Research Institute (Howard and others 1973) found a 95 percent survival with a clearance of 10 to 18 meters and Foote and Gilless (1996) at Berkeley, found 86 percent home survival with a clearance of 10 meters or more.” (Pgs. 3 and 4) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself, which is the responsibility of the homeowner. The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands)

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were discussed.

The WUI treatments proposed in the Project will thin vegetation within 10 meters of the structures, a distance supported by the cited publication (see EA section 3.3.5.2.2).

Dr. Cohen’s opposing view #5–“Extensive wildland vegetation management does not effectively change home ignitability.” (Pg. 5)

Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself. The quotation presented in view #5 is taken out of context from the cited publication. The publication further states the following: “This should not imply that wildland vegetation management is without a purpose and should not occur for other reasons.” Additional Purpose and Needs of the Project are restorative in nature and thus benefit the WUI; see EA section 1.5: Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1.


Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state

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than what currently exists High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component, will provide more open-crowned stands which increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas as summarized in EA section 3.3.4.1.1.

Dr. Cohen’s opposing view #6–“Home ignitability also dictates that effective mitigating actions focus on the home and its immediate surroundings rather than on extensive wildland fuel management. Because homeowners typically assert their authority for the home and its immediate surroundings, the responsibility for effectively reducing home ignitability can only reside with the property owner rather than wildland agencies.” (Pg. 5) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf



Dr. Cohen’s opposing view #7–“As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5)

Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999.


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Comment Forest Service Response http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

Dr. Cohen’s opposing view #8–“Home ignitability implies that homeowners have the ultimate responsibility for WUI home fire loss potential. As shown, the ignition and flammability characteristics of a structure and its immediate surroundings determine the home fire loss potential. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for WUI home fire loss, is the homeowner's choice and responsibility.” (Pg. 5) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf


Dr. Cohen’s opposing view #9–“However, public and management perceptions may impede homeowners from taking principal responsibility. For example, the Federal Wildland Fire Management, Policy and Program Review (1995) observes, ‘There is a widespread misconception by elected officials, agency managers, and the public that wildland/urban interface protection is solely a fire service concern.’ In a Journal of Forestry article, Beebe and Omi (1993) concur, stating that, ‘Public reaction to wildfire suggests that many Americans want competent professionals to manage fire flawlessly, reducing the risks to life, property, and public lands to nil.’ These statements agree with Bradshaw's (1988) description of the societal roles in the WUI problem. He observes that homeowners expect that fire protection will be provided by others. Contrary to these expectations for fire protection, the fire services have neither the resources for effectively protecting highly ignitable homes during severe WUI fires, nor the authority to reduce home ignitability.” (Pg. 6) Source: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego,


Per the 2013 Interagency Standards for Fire and Fire Aviation Operations (Chapter 5, USFS Program Organization and Responsibilities, page 5-17), “The Forest Service will apply strategy and tactics to keep wildland fires from reaching structures, as prudent to do so, considering risk management for firefighters and

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California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf

the public, fire behavior, values at risk including natural resources, availability of firefighting resources, and jurisdictional authorities. There should not be an expectation that the Forest Service will “wrap” or set up and administer sprinklers around privately owned structures. The Forest Service shall not take direct suppression actions on structures other than those that tactically reduce the threat of fire spread to them or enter structures or work on roofs of structures for the purpose of direct suppression actions.”

Dr. Cohen’s opposing view #10–“Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands.” (Pg. 4) Source: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component. An additional purpose and need of the Project is restorative in nature which also benefits the WUI; see EA section 1.5: Purpose and Need 2: Maintain forests in a condition at

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low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas.

Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists will reduce wildfire risks. As stated in section 3.3.4.1.1: “…high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory.” “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the

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area.”

These more open-crowned stands also increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas (EA section 3.3.4.1.1).

Dr. Cohen’s opposing view #11–“Past reports and recommendations as well as experimental research and modeling suggest that W-UI fire-loss mitigation should concentrate on the residence and its immediate surroundings. Any strategy for effectively reducing the W-UI fire problem must initially focus on residential fire resistance.” (Pg. 5 – Conclusion)

Source: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI. Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf

The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself. The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

Dr. Cohen’s opposing view #12–“Instead of all fire protection responsibilities residing with fire agencies, homeowners take responsibility for assuring firewise conditions and the initial fire defense of their residences during wildland fires. The fire agencies become a community partner that provides information, coordinates and assists in meeting firewise requirements, and provides fire suppression assistance.” (Pg. 5)

Source: Structure Ignition Assessment can Help Reduce Fire Damages in


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the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf

Dr. Cohen’s opposing view #13–“My examination suggests that the abundance and ubiquity of pine needles, dead leaves, cured vegetation, flammable shrubs, wood piles, etc. adjacent to, touching and or covering the homes principally contributed to the residential losses.” (Pg. 4) Source: Examination of the Home Destruction in Los Alamos Associated with the Cerro Grande Fire July 10, 2000 Source: USDA Forest Service, Rocky Mountain Research Station, Missoula, Montana, 2000. http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20copy.pdf

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

Dr. Cohen’s opposing view #14–The wildland fire management approach for preventing WUI fire disasters largely addresses the wildfire outside the home ignition zone rather than a home's ignition potential as determined by the conditions within the home ignition zone. Since 2000, agency fire management policy initiatives have emphasized fire suppression." (Pg. 24)

Source: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI, as stated in EA section 3.3.1: “Management objectives within a WUI include reducing risk of impacts from unplanned wildfire to these structures and to the firefighters involved with suppression activities.” The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in

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http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20copy.pdf

http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf



size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

Per the 2013 Interagency Standards for Fire and Fire Aviation Operations (Chapter 5, USFS Program Organization and Responsibilities, page 5-17), “The Forest Service will apply strategy and tactics to keep wildland fires from reaching structures, as prudent to do so, considering risk management for firefighters and the public, fire behavior, values at risk including natural resources, availability of firefighting resources, and jurisdictional authorities.”

Dr. Cohen’s opposing view #15–"Preventing WUI fire disasters requires that the problem be framed in terms of home ignition potential. Because this principally involves the home ignition zone, and the home ignition zone primarily falls within private ownership, the responsibility for preventing home ignitions largely falls within the authority of the property owner. Preventing wildfire disasters thus means fire agencies helping property owners mitigate the vulnerability of their structures. The continued fire management focus on fire suppression suggests the WUI fire problem persists largely as a consequence of framing the WUI fire problem primarily in terms of the fire exclusion paradigm." (Pg. 25)


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Source: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf Dr. Cohen’s opposing view #16–"The continued focus on fire suppression largely to the exclusion of alternatives that address home ignition potential suggests a persistent inappropriate framing of the WUI fire problem in terms of the fire exclusion paradigm." (Pg. 25)

Source: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf


EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

Dr. Cohen’s opposing view #17–“For the same reason, mitigating home The paper referred to in view #17 is not available at the

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ignition potential during extreme wildland fires must focus activities within and immediate to the residential area, i.e. the home ignition zone. But the home ignition zone largely corresponds to private property. Thus, with minor exception, the authority for effectively reducing the home ignition potential belongs to homeowners. Public land management agencies can facilitate homeowner mitigations and these agencies may be able to reduce fire intensities and the extent of burning around communities. But these agencies cannot accomplish the necessary and sufficient actions necessary to prevent residential fire disasters during extreme fire conditions by treating beyond the home ignition zone.” (Pg. 2) Source: Thoughts on the Wildland-Urban Interface Fire Problem, June 2003 http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf

location provided and could not be located elsewhere.

See the responses to views #1 through #16.

Dr. Cohen’s opposing view #18–“A home with its immediate surroundings (about 100-150 feet from the structure) is called the Home Ignition Zone. Many factors about the HIZ determine the potential for ignition during a wildland fire, such as flammable wood roofs and materials like trees, grass, decks, or adjacent structures leading up to a home.” (Pg. 1) Source: Saving Homes from Wildfires: Regulating the Home Ignition Zone Published in Zoning News, May 2001 http://www.battle-creek.net/docs/fire/Zoning.pdf


Dr. Cohen’s opposing view #19–“SIAM calculations indicate that large wildland flame fronts (e.g., forest crown fires) will not result in piloted wood ignitions (e.g., the typical variety of exterior wood walls) at distances greater than 40 meters (Cohen and Butler [In press]).” (Pg. 4) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

The paper referred to in view #19 is not available at the location provided and could not be located elsewhere. The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself.

Dr. Cohen’s opposing view #20–“Field studies conducted during the The paper referred to in view #20 is not available at the

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http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf

http://www.battle-creek.net/docs/fire/Zoning.pdf




International Crown Fire Modeling Experiment (Alexander et al. 1998) provided measured data for comparisons with SIAM model estimates. Total heat transfer (radiation and convection) and ignition data were obtained from heat flux sensors placed in wooden wall sections. The instrumented walls were located on flat, cleared terrain at 10, 20, and 30 meters downwind from the edge of the forested plots. The forest was variably composed of an overstory of jack pine (Pinus banksiana) about 13 meters high with an understory of black spruce (Picea mariana). The spreading crown fire produced flames approximately 20 meters high.” (Pg. 5)

Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

location provided and could not be located elsewhere.


Dr. Cohen’s opposing view #21–“Five burns were conducted where wall sections were exposed to a spreading crown fire. As the crown fires reached the downwind edge of the plot, turbulent flames extended into the clearing beyond the forest edge. In two of the five burns, flames extended beyond 10 meters to make contact with the wall section placed at 10 meters from the forest edge. When flame contact occurred, the walls ignited; however, without flame contact, only scorch occurred. The wooden panels at 20 and 30 meters never ignited and the panel at 30 meters never scorched.” (Pg. 6)

Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf


Dr. Cohen’s opposing view #22–“Case studies of actual W-UI fires provide an independent comparison with SIAM and the crown fire experiments. The actual fires incorporate a wide range of fire exposures. The case studies chosen examine significant factors related to home survival for two fires that destroyed hundreds of homes. The Bel Air fire resulted in 484 homes destroyed (Howard et al. 1973) and the Painted Cave fire destroyed 479 homes (Foote 1994). Analyses of both fires indicate that


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home ignitions depend on the characteristics of a home and its immediate surroundings. Howard et al. (1973) observed 95 percent survival for homes with nonflammable roofs and a vegetation clearance of 10 to 18 meters. Foote (1994) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 7) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

Dr. Cohen’s opposing view #23–“The high survival rate for homes with nonflammable roofs and 10-20 meter vegetation clearances included firebrands as an ignition factor, thus indicating that firebrand ignitions also depend on the ignition characteristics of the home and the adjacent flammable materials.” (Pg. 8) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf



Dr. Cohen’s opposing view #24–“Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-UI fire loss problem.” (Pg. 9) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf



EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). Additional purpose and needs of the Project are

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restorative in nature and thus benefit the WUI; see EA section 1.5: Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1. Purpose and Need 2: Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas. Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists will reduce wildfire risks. As stated in section 3.3.4.1.1: “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory.” “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense

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shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

And EA section 3.3.4.1.2 states, “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” As a result of treatments under Alternative C or B, the EA analysis concludes (EA, sections 3.3.5.2 and 3.3.5.3): In conclusion, in the nonlethal and mixed1 fire regimes under Alternative C [or B], CI and SFL results indicate that in 2016 and 2044, the surface fire behavior

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and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative C [or B] as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Alternative C [or B] would likely decrease the difficulty and cost of suppressing wildfire, because fire behavior would be more characteristic under this alternative. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes. In the mixed2 fire regime, the risk of a sustained crown fire decreases; however, it is expected to stay within desired conditions as lethal fire is still expected to occur as is historically occurred in the mixed2 fire regimes, but the patch sizes will be more characteristic due to the breakup of the overstory fuels. Concerns about firefighter and public safety would be reduced, as would the risk of uncharacteristic landscape patches. If a wildfire were to occur outside of the proposed treatment areas, it would break up the fuel continuity across the landscape. As a result, the analysis area would become more resistant to the potential of a large severe wildfire running from crown to crown in the nonlethal and mixed1 fire regime and fire behavior in the mixed 2 fire regime would be expected to result in patch sizes more typical of the

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historic condition.”

Dr. Cohen’s opposing view #25–“Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction.” (Pg. 10) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

The paper referred to in view #25 is not available at the location provided and could not be located elsewhere. See response to view #24.

Dr. Cohen’s opposing view #26–“Fire losses depend on home ignitions and home ignitions depend on home ignitability. Thus, home ignitability, being limited to a home and its immediate surroundings, offers us the opportunity to separate the W-UI structure fire loss problem from other landscape-scale fire management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as identifying and mapping the potential for W-UI residential fire destruction, identifying appropriate and effective mitigating actions, and determining who should take responsibility for home ignitability.” (Pg. 10) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf


See the responses to view #2 and view #11.

Dr. Cohen’s opposing view #27–“Thus, wildland fuel reduction that is effective for reducing the wildland fire intensity might be insufficient for reducing the destruction of highly ignitable homes. In contrast, a low home ignition potential reduces the chances of fire destruction without extensive wildland fuel reduction. These findings indicate that the W-UI home fire loss problem is a home ignitability issue largely independent of landscape fuel reduction issues.” (Pg. 10) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

The paper referred to in view #27 is not available at the location provided and could not be located elsewhere. The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself. The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in

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which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

Also see response to view #24.

Dr. Cohen’s opposing view #28–“The extent of the home ignition zone corresponds more to specific home and community ownership than to the landscapes of federal, state and local land management agencies. This suggests a corresponding responsibility for W-UI home fire loss potential residing with homeowners and communities. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for W-UI home fire loss, is a homeowner and community choice and responsibility.” (Pg. 11) Source: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf



Dr. Cohen’s opposing view #29–“Model results indicate that ignitions from flame radiation are unlikely to occur from burning vegetation beyond 40 meters of a structure. Thinning vegetation within 40 meters has a significant ignition mitigation effect.” (Pg. 81)

Source: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management Presented at the 13th Fire and Forest Meteorology Conference. Lorne,


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Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf

Dr. Cohen’s opposing view #30–“Vegetation management to prevent ignitions from radiation does not require extensive vegetation removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for a 20 meter flame height.” (Pg. 86 – Conclusions) Source: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management Presented at the 13th Fire and Forest Meteorology Conference. Lorne, Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf

The paper referred to in view #30 is not available at the location provided and could not be located elsewhere. See the responses to view #13 and view #25.

Dr. Cohen’s opposing view #31–“Miracles aside, the characteristics of the surviving home and its immediate surroundings greatly influenced its survival.” (Pg. 15) Source: Preventing Disaster Home ignitability in the Wildland-Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf


Dr. Cohen’s opposing view #32–“Based on severe-case assumptions of flame radiation and exposure time, SIAM calculations indicate that wild-land flame fronts comparable to crowning and torching trees (flames 20 meters high and 50 meters wide) will not ignite wood surfaces at distances greater than 40 meters (Cohen and Butler, in press). Figure 2 shows the radiant heat a wall would receive from flames depending on its distance from the fire. The incident radiant heat flux, defined as the rate of radiant energy per unit area received at an exposed surface, decreases as the distance increases.” (Pg. 17) Source: Preventing Disaster Home ignitability in the Wildland-Urban


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http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf



Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf

Dr. Cohen’s opposing view #33–“Analyses of both fires indicate that home ignitions depend on the characteristics of a structure and its immediate surroundings. Howard et al. (1973) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 19)

Source: Preventing Disaster Home ignitability in the Wildland-Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf



Dr. Cohen’s opposing view #34–“Using the model results as guidance with the concurrence of experiments and case studies, we can conclude that home ignitions are not likely unless flames and firebrand ignitions occur within 40 meters of the structure. This finding indicates that the spatial scale determining home ignitions corresponds more to specific home and community sites than to the landscape scales of wildland fire management. Thus, the W-UI fire loss problem primarily depends on the home and its immediate site.” (Pg.20) Source: Preventing Disaster Home ignitability in the Wildland-Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf



Dr. Cohen’s opposing view #35–“Thus, the W-UI fire loss problem can be defined as a home ignitability issue largely independent of wildland fuel management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as defining and locating potential W-UI fire problems (for example, hazard assessment and mapping), identifying appropriate mitigating actions, and


See the responses to views #2, #11, and #25.

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determining who must take responsibility for home ignitability.” (Pg.20)


Dr. Cohen’s opposing view #36–“The W-UI fire case studies indicated approximately 90 percent survival with a vegetation clearance on the order of 10 to 20 meters for homes with nonflammable roofs. Thus, the case studies support the general flame-to-structure distance range of 10 to 40 meters as found through modeling and experiments.” (Pg.20)




Dr. Cohen’s opposing view #37–“A change needs to take place in the relationship between homeowners and the fire services. Instead of home-related presuppression and fire protection responsibilities residing solely with fire agencies, homeowners must take the principal responsibility for ensuring adequately low home ignitability.” (Pg.21) Source: Preventing Disaster Home ignitability in the Wildland-Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf



Dr. Cohen’s opposing view #38–“Many scientists and natural resource agencies suggest extensive fuel treatments to reduce the possibility of severe and intense wildfires that could damage ecosystems, destroy property, and take human life (USDA Forest Service, 2000; GAO, 2003a,b). However, there are a number of misconceptions and misunderstandings about fuel treatments and their use as a panacea for fire hazard reduction across the

The findings in view #38 are not disputed in the Project EA.

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United States (Finney and Cohen, 2003; Franklin and Agee, 2003).” (Pg.1998) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

Dr. Cohen’s opposing view #39–“Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ‘‘fire-proof’’ important areas. It would be virtually impossible to exclude fire from most temperate terrestrial ecosystems because ignition sources are prevalent and fuels cannot be eliminated. Ignition is rarely affected by fuel treatment.” (Pg.1998)

Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf


EA section 3.3.3.1 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

Dr. Cohen’s opposing view #40–“Treating fuels to facilitate suppression is an example in circular logic. If fuel treatment makes suppression more successful in general, then less area will be burned in the short run and more acreage will tend to burn under extreme conditions, when suppression is ineffective. The inevitable result is that more area is burned in fewer, more unmanageable events with greater consequences. In addition, fire suppression leads to continued fuel accumulation and, in turn, more difficult conditions for suppression. This phenomenon has been described as ‘‘the

The first 2 purpose and needs of the Project are restorative in nature, as stated in EA section 1.5:

Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source

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wildland fire paradox’’ (Brown and Arno, 1991). Rather than creating conditions where fire is easier to suppress, fuel treatments should strive to create conditions where fire can occur without the need for suppression.” (Pg.1998)


habitat blocks for Family 1.


The above purpose and needs are addressed in EA section 3.3.3.4: “For the purposes of this assessment, wildfire hazard is based on the current fire behavior compared to what would have occurred historically as defined by the historical fire regimes. As applied, the wildfire hazard represents a departure from the vegetative conditions that resulted from historical fire behavior. For example, in the absence of fire in nonlethal and mixed1 fire regimes, forest canopy cover increases, ladder fuels become more abundant and continuous, and the risk of uncharacteristic fire events (i.e., greater lethal effects to trees and/or extent of resulting patches) is much greater than would have been expected historically. Under these conditions, a greater probability exists that surface fires will move from the ground into the crowns of trees, facilitating rapid, and in many cases lethal, fire movement throughout the area (Crane and Fisher 1986).”

The purpose and needs are further reflected in section 3.3.4.1.1: “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder

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fuels increase the likelihood of a surface fire transitioning into the overstory.” And in section 3.3.4.1.1, “In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

And in section 3.3.4.1.2, it states “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

The Project is not treating fuels to facilitate suppression actions. The project treatments are intended to begin

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restoring characteristic stand conditions of the fire regimes in order to restore fire to its proper function, as reflected in the effects analysis of the EA, section 3.3.5.2.4: “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” EA sections 3.2.2.1.1 and 3.2.2.1.2 state, that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

Dr. Cohen’s opposing view #41–“Bessie and Johnson (1995) show weather (fuel moisture and wind) is far more important than fuels in determining fire behavior; reducing fuels may have a limited impact on fire occurrence.”

EA section 3.3.3.1 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous

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(Pg.1999)


factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.”

As the article that Mr. Artley references on page 1999, the first paragraph states, “Even the most intensive fuel treatment may be rendered ineffective by the dynamics of large wildfire behavior, so designing treatments to minimize adverse fire effects may be a more effective strategy than designing treatments that attempt to exclude fires.” This concept is reflected in Purpose and Need 2: “Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas”. And EA section 3.3.4.1.2 states the following, “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result

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in landscape patches and patterns not consistent with the landscape that historically existed in the area.” And EA section 3.3.5.2.4 states the following, “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases. Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes.” And EA sections 3.2.2.1.1 and 3.2.2.1.2 state that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

The above discussion from the EA is consistent with what the referenced article is discussing.

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Dr. Cohen’s opposing view #42–“Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf


EA section 3.3.3.1 states the following: “Once an ignition source is provided, the likelihood of a wildfire becoming a stand-replacing fire depends on numerous factors, such as fuel moisture content, weather conditions, topography, fuel loading, stand density, and the presence of multiple vegetation layers that act as ladder fuels. Management actions can alter the last 3 factors and greatly influence fire severity and intensity should a wildfire occur.” EA sections 3.2.2.1.1 and 3.2.2.1.2 state, that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

Dr. Cohen’s opposing view #43–“Since the home ignition zone largely occurs on private lands, most land management agencies do not have the authority to mitigate the WUI ignition potential directly (Cohen, 2000b). However, the opportunity exists to explicitly define responsibilities for the WUI fire potential (i.e. the home ignition zone) consistent with areas of


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jurisdiction and separately from ecological wildfire issues.” (Pg.1999)


Dr. Cohen’s opposing view #44–“It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, and the degree to which the residential structures themselves can ignite that determine if the residences are vulnerable.” (Pg.1999) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

EA section 3.3 describes the effects of the proposed activities on wildfire hazard. The intent of the treatments is not to “prevent” wildfires but to alter the conditions (EA section 3.3) that lead to undesirable ecological effects (EA section 3.2.5) and undesirable social effects (EA section 3.3.4.1.1). The Project is focused on reducing the fire behavior in and around the WUI. This project does not address the ignitability of a structure itself.

The property surrounding the summer homes is NFS land and is leased via special use permit to the owner of each summer home structure and its lot; lots vary in size, and this fact is reflected in the special use permit. Planning for the Project was a collaborative process in which the summer home owners were a participant. Through the collaborative effort, the roles and responsibilities of the homeowner (re the structure and the lot) versus the roles and responsibilities of the Forest Service (re surrounding Forest Service lands) were discussed. Since the Forest Service manages the NFS lands surrounding the summer home structures and the lots, the Forest Service has the responsibility to reduce the threat of wildfire from the vegetative component.

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Dr. Cohen’s opposing view #45–“WUI fuel treatments can be designed such that an extreme wildfire can occur in the WUI without having a residential fire disaster. Although general wildfire control efforts may not benefit from fuel treatments during extreme fire behavior, fuel modifications can significantly change outcome of a wildfire within a treatment area. Research has shown that a home’s characteristics and its immediate surroundings principally determine the WUI ignition potential during extreme wildfire behavior (Cohen, 2000a,c, 2003, 2004). The area that primarily determines WUI ignition potential is called the home ignition zone (Cohen, 2001). WUI fuel treatments can address the home ignition zone by removing flammable materials immediately adjacent to residences” Pg. 1999) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf


An additional purpose and need of the Project is restorative in nature and thus benefits the WUI; see EA section 1.5:


Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists will reduce wildfire risks. As stated in section 3.3.4.1.1: “…high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory.” “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and

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severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” “These more open-crowned stands also increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas”, as described in EA section 3.3.4.1.1. EA sections 3.2.2.1.1 and 3.2.2.1.2 state, that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

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Dr. Cohen’s opposing view #46–“Treating fuels may not reduce suppression expenditures. It is a natural mistake to assume that a successful fuel treatment program will result in reduced suppression expenditures. Suppression expenditures rarely depend directly on fuel conditions, but rather on fire location and on what resources are allocated to suppression. The only certain way to reduce suppression expenditures is to make a decision to spend less money suppressing fires.” (Pg. 2000) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

The findings presented in view #46 are not disputed in the Project EA. EA section 3.3.5.2.4 states the following: “If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases.”

Dr. Cohen’s opposing view #47–“Thinning to reduce crown fire potential requires careful evaluation of the tradeoffs in treatment effects on potential surface fire behavior and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result in increased potential surface fire behavior, for several reasons. First, thinning reduces the moderating effects of the canopy on windspeed, so surface windspeed will increase (Graham et al., 2004). It also results in increased solar radiation on the forest floor, causing drier surface fuels. It may also cause an increase in flammable grassy and shrub fuels over time, due to the reduced tree competition.” (Pg.2000) Source: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition-Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

The findings presented in view #47 are not disputed in the Project EA. However, additional purpose and needs of the Project are restorative in nature and thus benefit the WUI; see EA section 1.5: Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1.


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Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists will reduce wildfire risks. As stated in section 3.3.4.1.1: “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory.” “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

And in EA section 3.3.4.1.2, “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a

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surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

EA sections 3.2.2.1.1 and 3.2.2.1.2 state, that following proposed treatments in the low to mid elevation areas including identified WUI areas, treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire or through mechanical means

“These more open-crowned stands also increase the safety of ingress and egress for firefighters, landowners, and members of the public when fire approaches the WUI areas”, as described in section 3.3.4.1.1.

Treatments as proposed would result in “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing

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conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases.” Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes” as described in sections 3.3.5.2.4.

Dr. Cohen’s opposing view #48–“Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000)


The findings presented in view #48 are not disputed in the Project EA.


Dr. Cohen’s opposing view #49–“Treating fuels may not improve ecosystem health. Ecosystem restoration treatment and fuel treatment are not synonymous. Some ecosystem restoration treatments reduce fuel hazard, but not all fuel treatments restore ecosystems. Ecosystem restoration

The findings presented in view #49 are not disputed in the Project EA. However, additional purpose and needs of the Project

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treatments are often designed to recreate presettlement fire regimes, stand structures and species compositions while fuel treatment objectives are primarily to reduce fuels to lessen fire behavior or severity—this is known as ‘’hazard Reduction.’’ Achieving fuel hazard reduction goals in the absence of ecosystem restoration is insufficient (Dombeck et al., 2004; Kauffman, 2004).” (Pg.2000)


are restorative in nature and thus benefit the WUI; see EA section 1.5: Purpose and Need 1: Maintain old forest habitat components where present in low- to mid-elevation forests and promote achievement of old forest habitat conditions in the medium and the large tree size classes. Increase habitat within identified source habitat blocks for Family 1. Purpose and Need 2: Maintain forests in a condition at low risk to uncharacteristic wildfire within the lower-elevation forest types (PVGs 1, 2 and 3); where forests are at an elevated risk, reduce hazards, particularly in WUI areas. Restoring vegetation in PVGs 1, 2, and 3, where the WUI is located, to a more characteristic vegetative state than what currently exists will reduce wildfire risks. As stated in section 3.3.4.1.1: “In the WUI, high stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component are uncharacteristic for the nonlethal and mixed1 fire regimes and increase the potential for a surface fire to transition into the overstory canopy. Multilayered canopies and ladder fuels increase the likelihood of a surface fire transitioning into the overstory”. “This uncharacteristic stand condition, combined with higher flame lengths, creates opportunities for surface fires to transition into the crowns. But current conditions in the overstory limit the opportunities for fire to transition into an active crown fire and perpetuate through the stands. In areas with high stand densities, abundant ladder fuels, low canopy base heights, and a dense

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shrub cover, a surface fire that transitions into the crowns in the nonlethal fire regime could result in lethal fires, which can burn at a high intensity and severity. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate-to-high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.”

And EA section 3.3.3.4.1.2 states, “High stand densities, abundant ladder fuels, low canopy base heights, and a dense shrub component increase the potential for a surface fire to transition into the tree crowns. This uncharacteristic stand condition in the nonlethal fire regime could support lethal fires that have the potential to burn at a high intensity and severity over a large portion of the project area. Similar stand conditions exist in the mixed1 fire regime; this regime would characteristically have small patches produced by fires of moderate to high intensity and severity. However, the uncharacteristic stand condition increases the risk that wildfire would result in landscape patches and patterns not consistent with the landscape that historically existed in the area.” Treatments as proposed in the WUI and non-WUI stands “…would include a VDT (Variable Density Thin), and a thin-from-below prescription would be used to commercial thin (CT) and remove trees ≥8 inches dbh, with the goal of retaining approximately 80

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square feet of basal area of the largest trees on-site. This prescription would promote the desired large tree component and appropriate species composition, favoring the retention of large-diameter fire-resistant species, such as ponderosa pine, and discriminating against tree species less resistant to wildfire; the continuous tree canopy would be broken into groups consistent with the HRV. The treatment would focus on removing trees from the lower crown canopy that were not typically seen in historical stands and that contribute to increases in ladder fuels (e.g. suppressed, intermediate, and to a lesser extent, co-dominant trees). Treatments would also concentrate on removing late seral species such as Douglas-fir, while favoring retention of ponderosa pine. If current openings make up <10% of a stand to be treated, small openings up to 0.75 acres may be created, consistent with historical patterns in the nonlethal fire regime. A focus species in these smaller openings will be ponderosa pine and aspen in order to accomplish restoration objectives” (EA sections 3.3.5.2.1). Noncommercial thinning (NCT): These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with fire (prescribed and/or wildfire). The thinning would be by hand, removing trees ≤8 inches dbh from the lower crown canopy (such as suppressed, intermediate, and to a lesser extent, co-dominant trees) in order to

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promote the desired stand structure. This treatment would preferentially remove late seral species such as Douglas-fir while favoring retention of ponderosa pine and aspen (EA sections 3.3.5.2.2).

Additionally, a “Low to moderate intensity prescribed fire broadcast maintenance burning would be applied after mechanical and fuel treatments, to further reduce fine fuels, promote regeneration of desired species, and gain the ecological benefits of fire within these landscapes. Fuels reduction treatments within RCAs must be consistent with design features. Treatments would re-pattern tree size classes, resulting in a combination of overstory and understory groups, clumps, and openings of varying number and sizes. This re-patterning would reduce stand densities and decrease the continuity of ladder fuels, thereby reducing the risk of a surface fire transitioning to a crown fire. These improvements would increase the likelihood that wildfire behavior would be characteristic for the fire regime” (EA section 3.3.5.2.3). EA section 3.3.5.2.4 further describes the effects of the treatments discussed above: “…the surface fire behavior and the risk that a wildfire ignition would become a sustained crown fire would be lower in the treated areas, compared to the risk under existing conditions and Alternative A, thereby reducing the potential for uncharacteristic wildfire behavior and effects (size, intensity, and severity). If a wildfire were to start within the project area, greater flexibility in suppression tactics would be possible under Alternative

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B (or C) as vegetative conditions move toward desired conditions and the risk of stand-replacing wildfire behavior decreases.” “Structure conditions would be more similar to those that occurred historically, and the fire effects would be more characteristic of the nonlethal and mixed1 fire regimes”

As stated in the EA, “These restoration treatments would focus on creating stand structural conditions (e.g., tree spacing, grouping, species composition) that will contribute to development of large tree and old forest habitat. The objective of the restorative treatment is to create stand and fuel conditions that can be eventually maintained with prescribed fire” (EA section 3.3.5.2.2).

Dr. Cohen’s opposing view #50–“Conversely, some fuel treatments can reduce fuels but create stands that are quite dissimilar from their historical analogs. Examples include mastication treatments that break, chip, or grind canopy and surface woody material into a compressed fuelbed and thinning treatments that remove the fire adapted species and leave shade-tolerant, late successional species.” (Pg.2000)



Concluding Comments

Nearly all Forest Service projects that claim to lessen the risks to homeowners living in the WUI propose to reduce hazardous fuels. The NEPA documents that analyze these fuels reduction treatments conveniently do not mention Dr. Cohen’s methods because the Purpose & Need is to


The purpose and need for the Project is stated in section 1.5 of the EA. EA section 1.9 discloses that both action alternatives

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reduce fuels … not (emphasis added) to protect homeowners as it should be. Reducing hazardous fuels is an alternative way to lessen the risks to homeowners living in the WUI. It is definitely not a goal or objective unto itself and should never appear in the Purpose & Need. However there is a reason most USFS line-officers deal with WUI risks this way. They know hazardous fuels reduction treatments include the logging of merchantable trees which produces volume and helps them meet the Line-Officers who propose hazardous fuels reduction projects are clearly more interested in accumulating volume than they are protecting the public in the WUI.

There are laws that prohibit such actions by a public servant whose salary is partially paid by the families living in the WUI.

would be consistent with law and regulatory requirements applicable to this project and its proposals.

Table D-120. Response to Comments for Dick Artley on the Clear Creek Integrated Project Review Environmental Assessment, Opposing Views—Attachment #18—Label Directions Unsafe


Herbicide Label Directions Opposing View #1 - “Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices. Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data."44 IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate-containing products were performed by IBT, including 11 of the 19 chronic

This article verifies that the EPA uses independently derived criteria to evaluate the quality of studies it receives. While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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toxicology studies.45 A compelling example of the poor quality of IBT data comes from an EPA toxicologist who wrote, "It is also somewhat difficult not to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination."46 (Emphasis added.) In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262 pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.49 The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.48 Although the tests of glyphosate identified as fraudulent have been replaced, these practices cast shadows on the entire pesticide registration process.”

Cox, Caroline, “Quality of Toxicology Testing” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995. Northwest Coalition for Alternatives to Pesticides, Eugene, OR. Glyphosate, Part 1: Toxicology http://www.inspiringlandscapes.com/hope/glyphos8.htm

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http://www.inspiringlandscapes.com/hope/glyphos8.htm



Herbicide Label Directions Opposing View #2 - “In 2004 the “Counterpart Regulations,” strongly supported by industry, were proposed to streamline EPA’s pesticide review process at the expense of the most vulnerable life forms in our country, Endangered and Threatened Species aka Listed Species (1,265 species are “Listed”). The critical change these regulations bring about is elimination of the requirement for consultations with wildlife experts at the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) by EPA reviewers evaluating adverse impacts of pesticides on Listed Species and their habitats. RCC opposed the Counterpart Regulations with comments, but, sadly, the Regulations were issued in final form on July 29, 2004, despite our objections. Over 125,000 public comments were received by the Fish and Wildlife Service, and they ran 2 to 1 against the Counterpart Regulations. RCC Insight: Apparently, the public’s concerns did not make a difference to the people at FWS and NMFS, or did they? We wonder whether the scientists involved with protecting wildlife at both “Services” would want to be bringing their experience and knowledge to bear on decisions made by EPA with respect to pesticides, if it were up to them. Perhaps they would prefer to be part of the evaluation process and they do not concur with finalizing the Counterpart Regulations. However, the fact is that decision-makers, by finalizing these changes, support an action that will weaken Endangered Species’ protection from poisoning and habitat degradation due to pesticides. This latest environmental rollback can mean increasingly hazardous conditions in rivers, lakes and wetlands. A further risk is weakening of the Endangered Species Act itself. (Text of our “Comments” is available through our website -- rachelcarsoncouncil.com)”

“Species from Pesticides – Weakened” Rachel Carson Council Inc., Issues & Insights October, 2004 http://www.rachelcarsoncouncil.org/index.php?page=issues-insights-october-2004

As stated on page 1-20 of the Review EA, “The Proposed Action was assessed to determine the effects on threatened and endangered plant and animal species.” Requirements for consultation with the USFWS have been met on all species identified by the Service: Canada lynx, bull trout, yellow-billed cuckoo, whitebark pine, and North American wolverine.”

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Herbicide Label Directions Opposing View #3 – [a] “Used in yards, farms and parks throughout the world, Roundup has long been a top-selling weed killer. But now researchers have found that one of Roundup’s inert ingredients can kill human cells, particularly embryonic, placental and umbilical cord cells. Until now, most health studies have focused on the safety of glyphosate, rather than the mixture of ingredients found in Roundup. But in the new study, scientists found that Roundup’s inert ingredients amplified the toxic effect on human cells—even at concentrations much more diluted than those used on farms and lawns. One specific inert ingredient, polyethoxylated tallowamine, or POEA, was more deadly to human embryonic, placental and umbilical cord cells than the herbicide itself – a finding the researchers call “astonishing.” “The research team suspects that Roundup might cause pregnancy problems by interfering with hormone production, possibly leading to abnormal fetal development, low birth weights or miscarriages.

Monsanto, Roundup’s manufacturer, contends that the methods used in the study don’t reflect realistic conditions and that their product, which has been sold since the 1970s, is safe when used as directed. Hundreds of studies over the past 35 years have addressed the safety of glyphosate. “Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that's out there,” said Monsanto spokesman John Combest. “It's used in public parks, it's used to protect schools. There's been a great deal of study on Roundup, and we're very proud of its performance.” [b] The EPA considers glyphosate to have low toxicity when used at the recommended doses.

“Risk estimates for glyphosate were well below the level of concern,” said EPA spokesman Dale Kemery. The EPA classifies glyphosate as a Group E

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.


[b] These comments support data from the project record.



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http://www.scientificamerican.com/article.cfm?id=genetically-modified-crops-survive-weed-whacking-herbicide



chemical, which means there is strong evidence that it does not cause cancer in humans.”

Weed-Whacking Herbicide Proves Deadly to Human Cells By Crystal Gammon and Environmental Health News June 23, 2009 http://www.scientificamerican.com/article.cfm?id=weed-whacking-herbicide-p

Herbicide Label Directions Opposing View #4 - “However, the U.S. government regulatory agencies seem to have given Monsanto a long rope. The clout Monsanto enjoys in the U.S. government is by no means incidental. According to the Organic Consumers Association, Clarence Thomas, before being the Supreme Court Judge who put George W. Bush in office (in his first term), was a Monsanto lawyer; Anne Veneman, the U.S. Secretary of Agriculture, was on the board of directors of Monsanto's Calgene Corporation; Donald Rumsfeld, the Secretary of Defence, was on the board of directors of Monsanto's Searle Pharmaceuticals; Secretary of Health Tommy Thompson received $50,000 in donations from Monsanto during his winning campaign for Wisconsin's governorship; and the two Congressmen who received the most donations from Monsanto during the last election were Larry Combest (Chairman of the House Agricultural Committee) and John Ashcroft (the Attorney-General).”

“A multinational Exposed” Frontline, Volume 22 - Issue 05, Feb. 26 - Mar. 11, 2005 http://www.hinduonnet.com/fline/fl2205/stories/20050311003312500.htm

The article link provided by Mr. Artley is no longer active; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Herbicide Label Directions Opposing View #5 – [a] “A recent study which shows clear links between exposure to the herbicide glyphosate and non-Hodgkin's lymphoma (NHL), a form of cancer that afflicts the lymphatic system, has caused worldwide concern over the safety of the herbicide on humans. The study was conducted by eminent oncologists Dr Lennart Hardell and Dr Mikael Eriksson of Sweden and published in the journal Cancer by the


[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to

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http://www.scientificamerican.com/topic.cfm?id=cancer




http://www.hinduonnet.com/fline/fl2205/stories/20050311003312500.htm



American Cancer Society on March 15.”

“Monsanto's Argument: Previous evaluations conducted by the US Environmental Protection Agency (EPA) and the World Health Organization (WHO) suggest that glyphosate is not a mutagenic or carcinogenic. WHO and the Food and Agriculture Organization (FAO) have approved the safety of glyphosate residues in genetically-engineered Roundup Ready soyabeans. [b] PAN's Counter Argument:

The EPA and WHO evaluations were done more than five years ago and based mainly on data submitted to them by Monsanto.

These evaluations did conclude that "there is no evidence of mutagenicity or carcinogenicity" based on the available data, but they do not support definitive assertions that glyphosate "is not mutagenic or carcinogenic".

Previous EPA and WHO evaluations which made similar claims for other chemicals had to be revised as new evidence came to light.

The establishment of the WHO's Acceptable Daily Intake (ADI) is based on limited studies using limited parameters which do not account for vulnerable groups such as children, the elderly, the sick and other groups that might have increased susceptibility to glyphosate exposure.”

“Concerns Over Glyphosate Use” The Sun (Malaysia), Friday August 20, 1999 http://www.poptel.org.uk/panap/archives/glywb.htm

herbicides. These are briefly described below.


Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. Standard operating procedures (SOPs) include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. [b] Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

Herbicide Label Directions Opposing View #6 –[a] “To protect our health, the U.S. Environmental Protection Agency (EPA) sets maximum legal residue levels for every pesticide, for dozens of crops. But a new study in the respected journal Toxicology has shown that, at low levels that are

[a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily

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currently legal on our food, Roundup could cause DNA damage, endocrine disruption and cell death. The study, conducted by French researchers, shows glyphosate-based herbicides are toxic to human reproductive cells.” [b] “Solvents and surfactants, legally considered ‘inert ingredients,’ are mixed with glyphosate in products such as Roundup weed killer to create chemical formulations that increase mobility and more direct access to the cells. ‘Those same factors that aid penetration into a plant, also aid penetration into the skin,’ says Vincent Garry, professor emeritus of pathology at the University of Minnesota. ‘These chemicals are designed to kill cells.’ ” “Herbicide manufacturers are subject to fewer rules in the testing of inert ingredients than they are for active ingredients, explains Caroline Cox, research director at the Center for Environmental Health in Oakland, Calif. ‘The tests the EPA requires for inert ingredients cover only a small range of potential health problems,’ Cox says. ‘Testing for birth defects, cancer and genetic damage are required only on the active ingredients. But we’re exposed to both.’ ” “ ‘Our bodies are gigantic spider webs of chemical communications that work in the parts-per-trillion range,’ says Warren Porter, professor of zoology and environmental toxicology at the University of Wisconsin. ‘When you put so-called ‘insignificant’ amounts of toxic chemicals into the mix, you have a molecular bull in a china shop. The possibilities for impact are endless.’ ”

Kimble-Evans, Amanda “Roundup Kills more than Weeds” Mother Earth News, December 2009/January 2010 http://www.motherearthnews.com/Sustainable-Farming/Roundup-Weed-Killer-Toxicity.aspx?page=2

identified and less likely to be consumed by humans.

[b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed.

Herbicide Label Directions Opposing View #7 - “Glyphosate is of relatively low oral and dermal acute toxicity. It has been placed in Toxicity

This comment supports data from the project record.

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Category III for these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV the lowest). The acute inhalation toxicity study was waived because glyphosate is nonvolatile and because adequate inhalation studies with end-use products exist showing low toxicity.” (Pg. 2)

“Glyphosate does not cause mutations.” (Pg. 2)

“EPA conducted a dietary risk assessment for glyphosate based on a worst-case risk scenario, that is, assuming that 100 percent of all possible commodities/acreage were treated, and assuming that tolerance-level residues remained in/on all treated commodities. The Agency concluded that the chronic dietary risk posed by glyphosate food uses is minimal.” (Pg. 3) “Occupational and residential exposure to glyphosate can be expected based on its currently registered uses. However, due to glyphosate's low acute toxicity and the absence of other toxicological concerns (especially carcinogenicity), occupational and residential exposure data are not required for reregistration.” (Pg. 3) “Glyphosate is no more than slightly toxic to birds and is practically nontoxic to fish, aquatic invertebrates and honeybees. Due to the presence of a toxic inert ingredient, some glyphosate end-use products must be labeled, ‘Toxic to fish,’ if they may be applied directly to aquatic environments. Product labeling does not preclude off-target movement of glyphosate by drift. EPA therefore is requiring three additional terrestrial plant studies to assess potential risks to nontarget plants.

EPA does not expect that most endangered terrestrial or aquatic organisms will be affected by the registered uses of glyphosate.” (Pg. 4) “Based on current data, EPA has determined that the effects of glyphosate on birds, mammals, fish and invertebrates are minimal.” (Pg. 5) “Regulatory Conclusion

EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

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The use of currently registered pesticide products containing the isopropylamine and sodium salts of glyphosate in accordance with the labeling specified in this RED will not pose unreasonable risks or adverse effects to humans or the environment. Therefore, all uses of these products are eligible for reregistration.” (Pg. 6) “R.E.D. FACTS Glyphosate”

EPA publication - EPA-738-F-93-011, September 1993 http://www.epa.gov/oppsrrd1/REDs/factsheets/0178fact.pdf

Herbicide Label Directions Opposing View #8 - “The findings of Richard et al. (2005) are an important addition to our understanding that the health and environmental effects of formulated pesticide products are not fully reflected in tests conducted on the active ingredient(s) alone. It has been long known that the adjuvants (commonly and misleadingly called "inert" ingredients) may be toxic and may enhance or supplement the toxic effects of the active pesticidal ingredient.

In the case of glyphosate-containing products, this phenomenon was well demonstrated in the data submitted to the (EPA) by the registrant (Monsanto), and summarized by the U.S. EPA in the Reregistration Eligibility Document (RED) for glyphosate (U.S. EPA 1993). For example, based on the registrant's own tests of acute toxicity to freshwater fish, the U.S. EPA classified technical grade glyphosate as "slightly toxic" to "practically non-toxic" and formulated products ranged from "moderately toxic" to "practically non-toxic." Tested alone, the surfactant adjuvant (identified as "inert") was "highly toxic" to "slightly toxic." Similar differences were reported in tests of acute toxicity to freshwater invertebrates. Based in part on the data in the glyphosate RED (U.S. EPA 1993), the New York State Attorney General's office successfully pursued an action against Monsanto in 1996 (Attorney General of the State of New York 1996). At that time, Monsanto was making advertising claims about the toxicity of the



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Roundup products based on data from tests on the active ingredient alone. Such claims are scientifically unfounded and inherently deceptive. The Attorney General's action was facilitated by the availability of at least some limited information about the inert ingredients and their toxicity. That same sort of information enabled Richard et al. (2005) to conduct their study. Unfortunately, that is not always the case, and for many pesticide products, little or no information about the identity of inert ingredients is publicly available. Registrants are generally required to conduct acute toxicity tests on formulated products, but they traditionally conduct chronic toxicity tests on the active ingredient alone. Even when formulated products are tested, the identity of inert ingredients is rarely revealed in the open literature, publicly available regulatory documents, or product labels. Therefore, independent research is stymied, and the public is ill-informed in the marketplace.”

Séralini, Gilles-Eric “Issue: Cumulative Impacts to Amphibians Species” A Laboratoire de Biochimie et Biologie Moleculaire publication, Université de Caen, February 2006 http://www.signaloflove.org/clearcutting/reports/cumulativeimpactstoamphibian

Herbicide Label Directions Opposing View #9 - “FACT: The EPA (Environmental Protection Agency) does not test pesticides for safety. It relies on the manufacturers’ test data to make judgments. Recent probes have found that the experiments on which these data have been based, have been designed to show only what the manufacturer would like them to show. This criticism of self-serving misrepresentation can be aimed equally validly at irresponsible experimenters bent on demonstrating toxicity of a given pesticide.

It seems that however this problem is approached, the EPA needs to take more affirmative action and responsibility. This is not likely to happen, as

The article link provided by Mr. Artley does not contain the excerpts cited in this comment; thus, we were unable to locate and review the cited information.

The link currently (as of August 2013) is an opinion piece that provides a discussion on the “need to control [invasive species] for the sake of a large number of natives that are being displaced by these plants, and ecosystems that are being disrupted.” The article further states that “In order to gain control of these culprits we may need to consider the thoughtful and

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the EPA’s research program increasingly relies on corporate joint venture, according to agency documents obtained by Public Employees for Environmental Responsibility (PEER). Indeed, a study by the Government Accountability Office (the investigative arm of Congress – the same people who first told us of the $640 toilet seats and $1,000 hammers purchased with Department of Defense money), in April 2005, concluded that the EPA lacks safeguards to “evaluate or manage potential conflicts of interest” in corporate research agreements, as they are taking money from corporations that they are supposed to be regulating.”

“MYTH: The Government tests pesticides for safety before they are sold” Wild Ones Journal, Nov 17, 2006


careful use of herbicides.”

The article then describes how glyphosate may be used in a way that is consistent with the mission of Wild Ones to “promote biodiversity and sustainable practices.” The response below is based on information contained in the project record. While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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Herbicide Label Directions Opposing View #10 - “FACT: The primary focus of the Federal Insecticide, Fungicide, and Rodenticide Act, originally enacted in 1947, was to provide federal control of pesticide distribution, sale, and use. The act has been amended many times over the years. One of these amendments permitted manufacturers protection of trade secrets. It is under these provisions that manufacturers circumvent a law that originally intended all information to be known – at least by the EPA. The fact that today, with mass spectrometers, chemistry can determine the makeup of the inert ingredients, leaves only the end consumer in the dark.

In 1990 the Office of the Attorney General of New York filed a request that all inert ingredients in pesticides be made public. The request was repeated a number of times through the decade, to no avail. Sixteen years later, in August of 2006, the attorneys general of 14 states have filed a similar petition to the EPA. This time the EPA is obliged to respond within a given time period.”

“MYTH: There are laws…” Wild Ones Journal, Nov 17, 2006 http://www.for-wild.org/download/roundupmyth/roundupmyth.html

The article link provided by Mr. Artley does not contain the excerpts cited in this comment; thus, we were unable to locate and review the cited information. The response below is based on information contained in the project record. Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.


Herbicide Label Directions Opposing View #11 - “A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].”

“In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

“O' Neill concluded: 'The EPA when authorising Monsanto's field trials for

Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below.



Pesticide application on the Forest is completed by

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Roundup-ready sugar beet did not consider the issue of glyphosate. They considered this to be the remit of the Pesticides Control Service of the Department of Agriculture. Thus nobody has included the effects of increasing the use of glyphosate in the risk/benefit analysis carried out. It is yet another example of how regulatory authorities supposedly protecting public health have failed to implement the 'precautionary principle' with respect to GMOs.' “

O' Neill, Sadhbh “RoundUp—Lymphoma Connection” Genetic Concern, June 22, 1999 http://www.hancock.forests.org.au/docs/herbicidesUpdate0602.htm

employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Herbicide Label Directions Opposing View #12 – [a] “Glyphosate-containing products are acutely toxic to animals, including humans. Symptoms include eye and skin irritation, cardiac depression, gastrointestinal pain, vomiting, and accumulation of excess fluid in the lungs. The surfactant used in a common glyphosate product (Roundup) is more acutely toxic than glyphosate itself; the combination of the two is yet more toxic.”

[b] “Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices.” “Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data." “44

“IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate-containing products were performed by IBT, including 11 of the 19 chronic toxicology studies.45 A compelling example of the poor quality of IBT data

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. [b] While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

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comes from an EPA toxicologist who wrote, "It is also somewhat difficult not to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination." “46 (Emphasis added.)

“In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262 pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.” “49

“The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.”48

Cox, Caroline. “Glyphosate, Part 1: Toxicology” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995 http://terrazul.org/Archivo/Glyphosate_Fact_Sheets.pdf

Herbicide Label Directions Opposing View #13 - “EPA Investigates Monsanto An internal memorandum by an official of the U.S. Environmental Protection Agency [EPA], has accused EPA of conducting a "fraudulent" criminal investigation of Monsanto, the St. Louis chemical corporation. [1] The 30-page memo, from William Sanjour to his supervisor, David Bussard, dated July 20, 1994, describes a two-year-long criminal investigation of Monsanto by EPA's Office of Criminal Investigation (OCI). The Sanjour memo says EPA opened its investigation on August 20, 1990 and formally closed it on August 7, 1992. "However, the investigation itself


While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is

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http://www.ejnet.org/rachel/rhwn400.htm%231



and the basis for closing the investigation were fraudulent," the Sanjour memo says. According to the Sanjour memo:

• EPA's investigation of Monsanto was precipitated by a memo dated February 23, 1990, from EPA's Dr. Cate Jenkins to Raymond Loehr, head of EPA's Science Advisory Board.

• The Jenkins memo said that EPA had set dioxin standards relying on flawed Monsanto-sponsored studies of Monsanto workers exposed to dioxin, studies that had showed no cancer increases among heavily exposed workers.

• Attached to the Jenkins memo was a portion of a legal brief filed by the plaintiffs as part of a trial known as Kemner v. Monsanto, in which a group of citizens in Sturgeon, Missouri had sued Monsanto for alleged injuries they had suffered during a chemical spill caused by a train derailment in 1979.

• The Jenkins memo had not requested a criminal investigation; instead Jenkins had suggested the need for a scientific investigation of Monsanto's dioxin studies. But in August 1990, EPA's Office of Criminal Investigation (OCI) wrote a 7-page memo recommending that a "full field criminal investigation be initiated by OCI."

• Plaintiffs in the Kemner suit made the following kinds of allegations (which we quote verbatim from the Sanjour memo):

“Monsanto failed to notify and lied to its workers about the presence and danger of dioxin in its chlorophenol plant, so that it would not have to bear the expense of changing its manufacturing process or lose customers;... "Monsanto knowingly dumped 30 to 40 pounds of dioxin a day into the Mississippi River between 1970 and 1977 which could enter the St. Louis food chain;

based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011). Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area the same day. Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

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"Monsanto lied to EPA that it had no knowledge that its plant effluent contained dioxin; "Monsanto secretly tested the corpses of people killed by accident in St. Louis for the presence of dioxin and found it in every case;... "Lysol, a product made from Monsanto's Santophen, was contaminated with dioxin with Monsanto's knowledge." [The Sanjour memo says that, at the time of the contamination, "Lysol (was) recommended for cleaning babies' toys and for other cleaning activities involving human contact."] "The manufacturer of Lysol was not told about the dioxin by Monsanto for fear of losing his business; "Other companies using Santophen, who specifically asked about the presence of dioxin, were lied to by Monsanto;...

"Shortly after a spill in the Monsanto chlorophenol plant, OSHA measured dioxin on the plant walls. Monsanto conducted its own measurements, which were higher than OSHA's, but they issued a press release to the public and they lied to OSHA and their workers saying they had failed to confirm OSHA's findings;

"Exposed Monsanto workers were not told of the presence of dioxin and were not given protective clothing even though the company was aware of the dangers of dioxin;

"Even though the Toxic Substances Control Act requires chemical companies to report the presence of hazardous substances in their products to EPA, Monsanto never gave notice and lied to EPA in reports; "At one time Monsanto lied to EPA saying that it could not test its products for dioxin because dioxin was too toxic to handle in

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its labs."...

“EPA Investigates Monsanto” RACHEL'S HAZARDOUS WASTE NEWS #400, July 28, 1994 http://www.ejnet.org/rachel/rhwn400.htm

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Herbicide Label Directions Opposing View #14 – [a] “A study by French researchers at the University of Caen of glyphosate residue discovered that the inert ingredients in the herbicide (solvents, preservatives, surfactants) increased the toxic effect on human cells. According to the researchers, glyphosate residue can cause birth defects. “This clearly confirms that the [inert ingredients] in Roundup formulations are not inert,” wrote the study authors. “Moreover, the proprietary mixtures available on the market could cause cell damage and even death [at the] residual levels” found on Roundup-treated crops.”

[b] “Another study by Argentine scientists also found that glyphosate can cause birth defects at doses considerably lower than what is commonly used on crops, in this case, soybeans. The researchers injected amphibian embryo cells with glyphosate diluted to a concentration 1,500 times less than what is used commercially. The embryos grew into tadpoles with obvious birth defects.” “A 2001 study by Swedish oncologists discovered links between non-Hodgkin’s lymphoma and glyphosate. The Swedish researchers found that Swedish people with non-Hodgkin’s lymphoma were 2.3 times more likely to be exposed to glyphosate.

Monsanto spokesperson John Combest defended the safety of Roundup. “Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that’s out there. It’s used in public parks, it’s used to protect schools. There’s been a great deal of study on Roundup, and we’re very proud of its performance.” “

Cheeseman, Gina-Marie, “Can A Company That Makes Roundup Be Sustainable?” TriplePundit, November 20th, 2009 http://www.triplepundit.com/2009/11/can-a-company-that-makes-roundup-be-sustainable/

[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.


[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below.



Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

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http://www.gmwatch.org/latest-listing/1-news-items/11252-roundup-proves-deadly-to-human-cells

http://www.triplepundit.com/author/ginamarie/





Herbicide Label Directions Opposing View #15 - “Over twenty years ago, the dangers of Monsanto's glyphosate as well as its associated GMOs were known scientifically to cause human health difficulties and Swedish researchers years ago in the Journal 'Cancer' noted glyphosate was connected to human cancer. Anyway, many scientists and public health workers researching it were fired. It's a mad empire's rush--the U.S empire and its corporate proxies--to desire (hell, the reality of) to own the world's food and dominate the whole world. It is destroying thousands of years of biodiversity security in the process. And Monsanto's empire of glyphosate is in virtually everything in the USA and worldwide. One foolish company, one corrupt federal government of the USA. Everyone should learn more about Monsanto in the film "The World According to Monsanto." (90 minutes). Monsanto's corporate contract should be revoked for endangering world health and killing off global crop biodiversity of thousands of years of work destroyed in one generation--in the mad rush to dominate the whole world's biodiversity.

Monsanto and the USA will go down in history as the organizations that caused most biological devastation and human suffering in human history.”

“MONSANTO RoundUp (glyphosate) Empire causes BIRTH DEFECTS...in amphibian embryos, humans?” Portland independent media center, May 3, 2009







Herbicide Label Directions Opposing View #16 - “BUENOS AIRES, Apr 15 , 2009 (IPS) - Glyphosate, the herbicide used on soybeans in Argentina, causes malformations in amphibian embryos, say scientists here who revealed the findings of a study that has not yet been published.”

"The observed deformations are consistent and systematic," Professor Andrés Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires medical school and lead researcher on the National Council of

The piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature .

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Comment Forest Service Response Scientific and Technical Research (CONICET), told the Inter Press Service news agency IPS. Reduced head size, genetic alterations in the central nervous system, an increase in the death of cells that help form the skull, and deformed cartilage w ere effects that were repeatedly found in the laboratory experiments, said the biologist.

The new s was reported Monday by the Argentine new spaper Página 12.

Monsanto’s head of communications in Argentina, Fernanda Pérez Cometto, told IPS that the company has "several studies that show that the herbicide is harmless to humans, animals and the environment."

Valente, Marcela “Scientists Reveal Effects of Glyphosate” HEALTH-ARGENTINA, April 15 , 2009 http://www.ipsnews.net/news.asp?idnews=46516



Herbicide Label Directions Opposing View #17 – [a] “It’s amazing how many organics people still think it’s OK to just use a bit of Roundup on those weeds in the bush or the driveway, or …. of course, not on the food, but the bush, that’s OK isn’t it?

Well, no, actually it isn’t, and here’s why: Roundup and various other formulations of the active ingredient glyphosate, have the potential to cause serious health and environmental effects, and have caused some severe poisoning problems. [b] Thorough PR by the developer of Roundup, Monsanto, has resulted in the widespread belief that glyphosate is ‘safe’. Registration processes have generally supported this attitude, and there are no national or international bans. However, independent scientific studies and widespread poisonings in Latin America resulting from aerial application are beginning to reveal the true effects of the world’s most widely used herbicide.”

Watts, Meriel Ph.D. “Roundup's Not OK” ORGANIC NZ, November/December 2009 http://www.livingorganics.co.nz/roundups-not-ok.php


[a] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90. Spray adjuvants used on the Forest are generally biodegradable and not hazardous or listed as Level 1 (inert ingredients of toxicological concern) or Level 2 (potentially toxic inert ingredients) compounds when used as intended and label directions are followed. [b] As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to state that the Forest endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and

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treatment needs and at the same time addresses resource and public safety concerns through standard operating procedures/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable SOPs.

Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, and truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013).

Herbicide Label Directions Opposing View #18 - Research on genetically modified seeds is still published, of course. But only studies that the seed companies have approved ever see the light of a peer-reviewed journal. In a number of cases, experiments that had the implicit go-ahead from the seed company were later blocked from publication because the results were not flattering. "It is important to understand that it is not always simply a matter of blanket denial of all research requests, which is bad enough," wrote Elson J. Shields, an entomologist at Cornell University, in a letter to an official at the Environmental Protection Agency (the body tasked with regulating the environmental consequences of genetically modified crops), "but selective denials and permissions based on industry perceptions of how ’friendly’ or ’hostile’ a particular scientist may be toward [seed-enhancement] technology." Shields is the spokesperson for a group of 24 corn insect scientists that opposes these practices. Because the scientists rely on the cooperation of the companies for their research - they must, after all, gain access to the seeds for studies - most have chosen to remain anonymous for fear of reprisals.

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs procedures include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans.

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The group has submitted a statement to the EPA protesting that "as a result of restricted access, no truly independent research can be legally conducted on many critical questions regarding the technology." It would be chilling enough if any other type of company were able to prevent independent researchers from testing its wares and reporting what they find - imagine car companies trying to quash head-to-head model comparisons done by Consumer Reports, for example. But when scientists are prevented from examining the raw ingredients in our nation’s food supply or from testing the plant material that covers a large portion of the country’s agricultural land, the restrictions on free inquiry become dangerous.

“Do Seed Companies Control GM Crop Research?” Scientific American, Editorial, August 2009 edition, published 21 July 2009 Reprinted by Combat-Monsanto.org http://www.combat-monsanto.co.uk/spip.php?article399

Herbicide Label Directions Opposing View #19 - “France’s highest court has ruled that U.S. agrochemical giant Monsanto had not told the truth about the safety of its best-selling weed-killer, Roundup. The court confirmed an earlier judgment that Monsanto had falsely advertised its herbicide as “biodegradable” and claimed it “left the soil clean.” Roundup is the world’s best-selling herbicide. French environmental groups had brought the case in 2001 on the basis that glyphosate, Roundup’s main ingredient, is classed as “dangerous for the environment” by the European Union. In the latest ruling, France’s Supreme Court upheld two earlier convictions against Monsanto by the Lyon criminal court in 2007, and the Lyon court of appeal in 2008, the AFP news agency reports. Monsanto already dominates America’s food chain with its genetically


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http://www.combat-monsanto.co.uk/spip.php?article399



modified seeds. Now it has targeted milk production. Just as frightening as the corporation’s tactics, including ruthless legal battles against small farmers, is its decades-long history of toxic contamination.”

France Finds Monsanto Guilty of Lying Infowars Ireland, November 23, 2009 http://info-wars.org/2009/11/23/france-finds-monsanto-guilty-of-lying/

Herbicide Label Directions Opposing View #20 – [a] “Monsanto created Roundup in the 1970's to kill weeds and has since catapulted this product to be the world's number one selling herbicide. Before the patent on Roundup was set to expire in 2000, Monsanto needed a surefire way to keep the profits of Roundup from bottoming out. Monsanto quickly began purchasing the majority of the world's seed companies while simultaneously creating GMOs that farmers needed to sign contractual agreements to only use Roundup. Subsequently, revenue from Roundup never dropped and in fact topped more than $4 billion in 2008, up 59% from 2007 [2].

GM-soy is estimated to be present in up to 70% of all food products found in US supermarkets, including cereals, breads, soymilk, pasta and most meat (as animals are fed GM-soy feed). Although Monsanto has consistently relied on industry-funded data to declare the safety of GM-soy and glyphosate, objective research published in peer-reviewed journals tells another story. [b] Toxicity of Glyphosate A recently published study by Italian researchers [3] examined the toxicity of four popular glyphosate based herbicide formulations on human placental cells, kidney cells, embryonic cells and neonate umbilical cord cells and surprisingly found total cell death of each of these cells within 24 hours. The researchers reported several mechanisms by which the herbicides caused the cells to die including: cell membrane rupture and damage, mitochondrial damage and cell asphyxia. Following these findings, the researchers tested G, AMPA and POEA by themselves and concluded that,

[a] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of ingestion. SOPs include adding dyes to herbicide mixes so treated vegetation is easily identified and less likely to be consumed by humans. [b] Surfactants and dyes used on the Forest are Activator 90 (non-ionic), Bullseye Spray Pattern Indicator (dye), Cayuse, HiLight (dye), R-11 Spreader Activator, and Ad-Wet 90.



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http://info-wars.org/author/protocol22/


http://www.naturalnews.com/herbicide.html

http://www.naturalnews.com/Monsanto.html

http://www.naturalnews.com/farmers.html

http://www.naturalnews.com/food.html

http://www.naturalnews.com/toxicity.html



"It is very clear that if G, POEA, or AMPA has a small toxic effect on embryonic cells alone at low levels, the combination of two of them at the same final concentration is significantly deleterious.”

Damato, Gregory Ph.D., “GM-Soy: Destroy the Earth and Humans for Profit” Fourwinds10.com, May 27, 2009 http://www.fourwinds10.com/siterun_data/science_technology/dna_gmo/news.php?q=1243529527

Herbicide Label Directions Opposing View #21 - “If you're still not convinced that Roundup is a highly toxic and persistent pesticide, read on, while at the same time remembering the other contributions that Monsanto has made to society such as: Saccharin, Astroturf, agent orange, dioxin, sulphuric acid, polychlorinated biphenyls (PCBs), plastics and synthetic fabrics, research on uranium for the Manhattan Project that led to the construction of nuclear bombs, styrene monomer, an endless line of pesticides and herbicides (Roundup), rBGH (recombinant bovine growth hormone that makes cows ill), genetically engineered crops (corn, potatoes, tomatoes, soy beans, cotton), and it's most significant product to date; Lies, Factual Distortions and Omissions. Here's one of the distortions that Monsanto had on its website a while back. ‘Sustainability - the idea that the resources and people of this world are finite. That for any business decision we make, we must consider the effect it will have on us and our children. That the products we make must not use up all of a natural resource, or even worse, contaminate what is left behind.’

“Everything you Never Wanted to Know about Monsanto’s Modus Operandi (M.O.)” Mindfully.org http://www.mindfully.org/Pesticide/Monsanto-Roundup-Glyphosate.htm

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.”

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Herbicide Label Directions Opposing View #22 – [a] “ "The U.S. response (to questions about biotech crop safety) has been an extremely patronizing one. They say 'We know best, trust us,'" added Gurian-Sherman, now a senior scientist at the Union of Concerned Scientists, a nonprofit environmental group.” “So far, that confidence has been lacking. Courts have cited regulators for failing to do their jobs properly and advisers and auditors have sought sweeping changes.” “The developers of these crop technologies, including Monsanto and its chief rival DuPont, tightly curtail independent scientists from conducting their own studies. Because the companies patent their genetic alterations, outsiders are barred from testing the biotech seeds without company approvals.” “The agreements disallow any research that is not first approved by the companies. "No truly independent research can be legally conducted on many critical questions regarding the technology," the scientists said in their statement.” [b] “Outside researchers have also raised concerns over the years that glyphosate use may be linked to cancer, miscarriages and other health problems in people.”

Gillam, Carey “Patents Trump Public Interest in Monsanto's Ag Empire - Special Report: Are Regulators Dropping the Ball on Biocrops?” Reuters, April 13, 2010 http://www.commondreams.org/headline/2010/04/13-0


[a] While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

[b] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below.


Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a

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certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013).

Herbicide Label Directions Opposing View #23 – “Defining Toxic Asbestos is an extreme example, which I use here and in my book Pick Your Poison: How Our Mad Dash to Chemical Utopia is Making Lab Rats of Us All to make a point, but many other “nontoxic” products could be full of toxic chemicals. I’m hoping this essay leaves you with a general distrust of the nontoxic label, both in the past and currently. When you see “nontoxic” on a product, keep the following facts in mind:

• “Nontoxic” can still legally mean that there are no immediate, acute hazards as determined by the LD50 and LC50 tests.

• “Nontoxic” may mean there are little or no chronic data available on the substance. If the substance is not acutely toxic, and one can’t prove it is toxic in the long term, many manufacturers feel that they have the right to call it nontoxic. Even if there are studies showing that the substance is toxic, manufacturers in the United States have traditionally waited for absolute, unequivocal proof, which in most cases is never available because we don’t study our chemicals.

• An art material is “nontoxic” if a toxicologist paid by the manufacturer decides it is safe. The dramatic failure in this labeling procedure was illustrated with the lead ceramic glazes and asbestos-containing materials such as talc. Asbestos-containing talcs are still found in some art and craft materials today.

Some art materials that have never been evaluated by a toxicologist may be labeled “nontoxic” illegally due to weak enforcement of the art materials labeling law. For example, in 1995, a cameraman and a reporter from Channel 9 in New York went with me to a major art materials outlet. That night on the evening news, we showed viewers about a dozen imported

The opinion piece referenced by Mr. Artley does not cite a source that has been published in a scientifically peer-reviewed outlet with known and replicated quality assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993).


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products that did not conform to the law, some labeled “nontoxic,” which were being sold illegally. This is still true today, and a little research will lead you to many sources of noncompliant “nontoxic” products.

• Labeling of ordinary consumer products is pretty much up to the manufacturer and its paid advisers. Because there is no enforcement mechanism in the regulations for the chronic hazard labeling of ordinary consumer products, there is not much incentive to provide warnings.

• There is no regulatory requirement to warn consumers about damage to most of the body’s organs, such as the lungs, the liver, and the kidneys. Only four types of chronic hazards are covered by the Federal Hazardous Substances Act regulations. These are cancer, and developmental, reproductive, and neurological damage.”

Rossol, Monona “Say What? A Chemical Can Damage Your Lungs, Liver and Kidneys and Still Be Labeled "Non-Toxic"?”

Ms. Rossol is a research chemist, author and member of the American Industrial Hygiene Association May 9, 2011


Herbicide Safety Testing Opposing View #24 Monsanto's Claims Independent Research Findings

[a] Roundup has a low irritational potential for eye and skin and otherwise is not a risk to human health.

Roundup is amongst the top most reported pesticides causing poisoning incidents (mainly skin irritation) in several countries. It also causes a range of acute symptoms including, recurrent eczema, respiratory problems, elevated

[a] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below.


Treatments will be coordinated with Forest Service employees who may be working in or around the area

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blood pressure, allergic reactions.

[b] Roundup does not cause any adverse reproductive effects

In laboratory tests on rabbits glyphosate caused long lasting, harmful effects on semen quality and sperm counts.

Roundup is not mutagenic in mammals.

DNA damage has been observed in laboratory experiments in mice organs and tissue.

[c] Roundup is environmentally safe.

• In the agricultural environment, glyphosate is toxic to some beneficial soil organisms, beneficial arthropod predators, and increases crops' susceptibility to diseases.

• [d]Sub-lethal doses of glyphosate from spray drift damages wildflower communities and can affect some species up to 20 metres away from the sprayer.

• [e] The use of glyphosate in arable areas may cause dieback in hedgerow trees.

[f] Roundup is rapidly inactivated in soil and water.

• Glyphosate is very persistent in soils and sediments.

• Glyphosate inhibited the formation of nitrogen fixing nodules on clover for 120 days after treatment.

• Glyphosate residues were found

the same day.

Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013). [b] EPA classified glyphosate as a “Group E” carcinogen or a chemical that has not shown evidence of carcinogenicity in humans (EPA 1993). [c] The effects to fungi are addressed by the following information: “Roberts and Berk (1993) investigated the effects of Roundup® on chemoattraction of the protozoa Tetrahymena pyriformis and found that it significantly interfered with chemoreception but not motility. Doses of glyphosate <10 ppm were stimulatory to soil microflora including actinomycetes, bacteria, and fungi, while concentrations > 10 ppm had detrimental impacts on microflora populations in one study (Chakravarty & Sidhu 1987). While some short-term studies (< 30 days) found glyphosate caused significant impacts to microbial populations, Roslycky (1982) found that these populations rebound from any temporary increase or decrease within 214 days. Similarly, Tu (1994) found that microorganisms recovered rapidly from treatment with glyphosate and that the herbicide posed no long-term threat to microbial activities” [Tu et al. 2001, as revised through

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in lettuce, carrot, and barley when planted a year after glyphosate was applied.

Roundup is immobile and does not leach from soils.

• Glyphosate can readily desorb from soil particles in a range of soil types. It can be extensively mobile and leach to lower soil layers.

• Glyphosate can be carried by soil particles suspended in run off.

[g] Roundup does not contaminate drinking water when used by local authorities on hard surfaces.

In the UK, levels of glyphosate above the EU limit have been detected by the Welsh Water Company every year since 1993. The Drinking Water Inspectorate recommends that glyphosate be monitored, particularly, in areas where it is used by local authorities on hard surfaces.

[h] It is nearly impossible for glyphosate resistance to evolve in weeds.

In 1996, glyphosate resistant ryegrass was discovered in Australia.

Outcrossing in oilseed rape crops (and the transfer of genes from transgenic crops) occurs over a short distance and can be easily managed.

The densities of oil seed rape pollen are much higher and their dispersal patterns differ from around large fields compared to those found in experimental plots. Wind dispersal of pollen occurs over much greater distances and at higher concentrations than predicted by experimental plots. Significant levels of

2005]

Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation sold as Rodeo® is registered for aquatic use.” [d] Currently, all herbicide use on the Forest occurs via ground-based application. Backpack sprayers, compressed air hand sprayers, truck-mounted and TV/UTV-mounted sprayers are used to spot-spray individual weeds or small patches, while boom sprayers are used to broadcast-spray large or continuous area infestations (Black 2013). [e] Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting effects to hedgerow trees. [f] Glyphosate is highly water soluble, but unlike most water-soluble herbicides, glyphosate has a very high adsorption capacity. Once glyphosate contacts soil, the herbicide is rapidly bound to soil particles, rendering it essentially immobile (Roy et al. 1989a; Ferg and Thompson 1990). Unbound glyphosate molecules are rapidly degraded at a steady and relatively rapid rate by soil microbes (Nomura and Hilton 1977; Rueppel et al. 1977). Bound glyphosate molecules also are biologically degraded, at a steady but slower rate. The half-life in soil averages 2 months but can range from weeks to years (Nomura and Hilton 1977; Rueppel et al. 1977; Newton et al. 1984; Roy et al. 1989a; Feng and Thompson 1990; Anton et al. 1993). Although the strong adsorption of glyphosate allows residue to

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gene flow from transgenic oil seed crops is inevitable.

Roundup Ready crops will reduce levels of herbicide use.

Herbicide resistant crops will intensify and increase dependency on herbicide use in agriculture rather than lead to any significant reductions. A variety of herbicides will have to be reintroduced to control glyphosate resistant volunteers, feral populations of crops and resistant weeds.

Source: References cited in Health and Environmental Impacts of Glyphosate, (Details available from the Pesticides Trust [now PAN UK]).

PAN UK “Resistance to glyphosate” This data was first published in Pesticides News No. 41, September 1998, page 5 http://www.pan-uk.org/pestnews/Issue/pn41/PN41p5.htm

persist for over a year, these residues are largely immobile and do not leach significantly. Feng and Thompson (1990) found that >90% of the glyphosate residues were present in the top 15 cm of the soil and were present as low as 35 cm down the soil column in only 1 of 32 samples. Adsorption to soil particles prevents glyphosate from being taken up by the roots of plants. [Tu et al. 2001, as revised through 2005] [g] Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize effects to riparian areas. These are briefly described below. To minimize adverse effects to aquatic organisms, herbicides with nonaquatic labels are applied outside a 100-foot riparian buffer zone (from the high-water mark), except in Resource Areas of Concern identified by the NMFS, where the riparian buffer zone is 300 feet from the high-water mark.


Regarding fish and other aquatic organisms, Tu et al. 2001, as revised through 2005, found that “It appears that under most conditions, rapid dissipation from

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aquatic environments of even the most toxic glyphosate formulations prevents build-up of herbicide concentrations that would be lethal to most aquatic species.”

[h] Weed resistance is not a primary consideration in the current risk assessment, except where application rates for glyphosate are being increased primarily in agricultural crops that are tolerant to glyphosate. Project areas where glyphosate application may be needed are not used for agricultural purposes, limiting the risk of resistance and outcrossing.

Herbicide Label Directions Opposing View #25 - “FACT: The EPA (Environmental Protection Agency) does not test pesticides for safety. It relies on the manufacturers’ test data to make judgments. Recent probes have found that the experiments on which these data have been based, have been designed to show only what the manufacturer would like them to show. This criticism of self-serving misrepresentation can be aimed equally validly at irresponsible experimenters bent on demonstrating toxicity of a given pesticide.”

Herbicide Myths Vs. the Facts Published by Wild Ones, November 2006 http://www.for-wild.org/download/roundupmyth/mythvfact.html

The article link provided by Mr. Artley does not contain the excerpts cited in this comment; thus, we were unable to locate and review the cited information. The link currently (as of August 2013) is an opinion piece that provides a discussion on the “need to control [invasive species] for the sake of a large number of natives that are being displaced by these plants, and ecosystems that are being disrupted.” The article further states that “In order to gain control of these culprits we may need to consider the thoughtful and careful use of herbicides.”

The article then describes how glyphosate may be used in a way that is consistent with the mission of Wild Ones to “promote biodiversity and sustainable practices.” The response below is based on information contained in the project record. While any study (published or unpublished) can be

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http://www.for-wild.org/download/roundupmyth/mythvfact.html



falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

Herbicide Label Directions Opposing View #26 - “The extraordinary influence of the biotechnology industry has made U.S. regulation of GM crops largely a rubber-stamp process designed to increase public confidence in, rather than ensure the safety of, genetically modified foods. Weaknesses shared by all three agencies include uncritical reliance on the data and conclusions of the financially interested GM crop developer in regulatory decisionmaking; dogmatic adherence to politically-motivated doctrines such as “substantial equivalence” designed to ease companies’ regulatory path to approval; and blindness to the substantial economic harm suffered by U.S. farmers thanks to governmental and industry negligence. As continuing contamination episodes provoke more scientifically-oriented regulators in Europe and Japan to reject shipments of U.S. foodstuffs with untested GM content, one can only hope that the often severe economic fallout for U.S. farmers (if nothing else) will convince U.S. regulators to leave politics behind, and finally adopt a more objective, stringent, and science-based regulatory system.”

Is Government Up to Task Published in the January/February 2007 issue of Biotechnology http://www.centerforfoodsafety.org/pubs/FDLI%20Paper%20-%20Jan-Feb%202007.pdf


Herbicide Label Directions Opposing View #27 – [a] “GAO's review found that EPA and FTC make limited use of their authority over unacceptable safety advertising c aims. GAO found the same situation

The opinion piece referenced by Mr. Artley does not cite sources that have been published in a scientifically peer-reviewed outlet with known and replicated quality

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http://www.centerforfoodsafety.org/pubs/FDLI%20Paper%20-%20Jan-Feb%202007.pdf

http://www.centerforfoodsafety.org/pubs/FDLI%20Paper%20-%20Jan-Feb%202007.pdf



nearly 4 years ago and recommended that EPA take steps to strengthen and improve its program for regulating such claims. Neither EPA nor FTC is taking formal enforcement action against safety claims by manufacturers and distributors. Since 1986 EPA has taken only one formal enforcement action involving a lawn care pesticide safety claim made by a manufacturer, while FTC has taken no enforcement action in this area. EPA officials told GAO that safety advertising claims are still a low enforcement priority because of limited resources and because other violations such as pesticide misuse continue to be its primary concern. Fm believes EPA is better able to handle pesticide safety claims because of its technical expertise and legislative authority.

[b] FTC has not acted against claims by professional pesticide applicators, over which EPA has no authority, because it believes EPA has been successfully handling applicator claims informally through its regional offices. Although EPA and Fm officials have discussed GAO's 1986 recommendation, no formal arrangement has been made to ensure that questionable applicator claims would be given appropriate attention. The lawn care pesticides industry is making claims that its products are safe or nontoxic. GAO's review found nine instances of safety claims, such as "completely safe for humans," made by manufacturers, distributors, and professional applicators. EPA, using its standards for pesticide labels, considers that these claims, when made by manufacturers and distributors, are false and misleading. Such claims are prohibited by because they differ substantially from claims allowed to be made as part of the approved registration. GAO believes that without an effective federal enforcement program, the lawn care pesticides industry will continue to make such claims that could, among other things, persuade consumers to purchase a service they otherwise might not use or discourage the use of reasonable precautions to minimize exposure, such avoiding recently treated areas.”

“LAWN CARE PESTICIDES - Risks Remain Uncertain While Prohibited

assurance and quality control processes. The following discussion is from project record documents whose conclusions were based on peer-reviewed literature. [a] While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

[b] As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to establish that the Forest endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through standard operating procedures/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below. Individuals applying pesticides are required to wear personal protective equipment. Treatments will be coordinated with Forest Service employees who may be working in or around the area

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Safety Claims Continue”

United States General Accounting Office Report to the Chairman, Subcommittee on Toxic Substances, Environmental Oversight, Research and Development, Committee on Environment and Public Works, U.S. Senate, March 1990 GAO/RCED-90-134

http://www.getipm.com/government/fi fra-laws/gao-rpt.htm

the same day.


Herbicide Label Directions Opposing View #28 - “2,4-D has been evaluated by the European Union and included on its list of approved herbicides, stating inter alia that "the review [of 2,4-D] has established that the residues arising from the proposed uses, consequent on application consistent with good plant protection practice, have no harmful effects on human or animal health."[30] Concern over 2,4-D is such that it is currently not approved for use on lawns and gardens in Sweden,[31] Denmark, Norway, Kuwait and the Canadian provinces of Québec [32] and Ontario.[33] 2,4-D use is severely restricted in the country of Belize. In 2005, the United States Environmental Protection Agency approved the continued use of 2,4-D.[34] In Canada, the Pest Management Regulatory Agency (PMRA) has placed a condition of registration on 2,4-D such that the 2,4-D registrant(s) must provide the PMRA with a required developmental neurotoxicity study by September 20, 2009.[35] According to the PMRA, the due date of the study has since been extended to early 2010.”

2,4-Dichlorophenoxyacetic acid Published by Wikipedia http://en.wikipedia.org/wiki/2,4-Dichlorophenoxyacetic_acid

As stated on page 3-350 of the Review EA, “Weed infestations are monitored and treated through the Forest Noxious Weed Program.” However, the EA is not clear about what this program requires. Thus, the EA will be edited to establish that the Agency endorses use of an integrated weed management program that selects the best tool to meet noxious weed prevention and treatment needs and at the same time addresses resource and public safety concerns through standard operating procedures/mitigation. Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to herbicides. These are briefly described below.


Treatments will be coordinated with Forest Service employees who may be working in or around the area

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http://www.getipm.com/government/fifra-laws/gao-rpt.htm

http://en.wikipedia.org/wiki/2,4-Dichlorophenoxyacetic_acid%23cite_note-29






http://en.wikipedia.org/wiki/2,4-Dichlorophenoxyacetic_acid



the same day.


Herbicide Label Directions Opposing View #29 - “According to the lawsuit, Parker became the subject of hostile treatment by his supervisors after complaining about what he called a "systemic problem" when it came to proper pesticide use across several forests in New Mexico and Arizona.” Former Forest Service Official Files Lawsuit over Firing by Susan Montoya Bryan Associated Press August 10, 2007 http://earthhopenetwork.net/former_forest_service_official_files_lawsuit_firing.htm





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http://www.ap.org/

http://earthhopenetwork.net/former_forest_service_official_files_lawsuit_firing.htm



“(Beyond Pesticides, February 17, 2011) According to a recent investigative report, a company known for conducting scientific research for the pesticide industry has, in an attempt to refute research linking pesticides to Parkinson’s disease, paid a U.S. government agency, the National Institute for Occupational Safety and Health (NIOSH), to prove that certain pesticides are safe. According to the report, the company, Exponent Inc., is a member of CropLife America, a trade group that represents pesticide manufacturers, and also has worked regularly for Syngenta, which makes paraquat, one of the chemicals it is looking prove as safe. Specifically, the company is looking to refute the research which shows that even small amounts of agricultural chemicals, maneb and paraquat, when combined, can raise the risk of Parkinson’s disease. According to the report, managing scientist of Exponent, Laura McIntosh, PhD, said in an interview that the company donated the money and sought participation at NIOSH to enhance the credibility of its study of maneb and paraquat; they wanted to make their research “bulletproof.” “

Beyond Pesticides Daily News Blog entry was posted on Thursday, February 17th, 2011 Source: http://www.beyondpesticides.org/dailynewsblog/?p=4965


While any study (published or unpublished) can be falsified, these types of incidents with the design, conduct, and reporting of studies that are submitted to the EPA for pesticide registration are minor. The design of studies that are submitted for pesticide registration is based on strict guidelines for both the conduct and reporting of studies. These guidelines are developed by the EPA and not by the registrants (SERA 2011).

“It's been the official mantra of pesticide companies for decades: "The dose makes the poison." While it makes intuitive sense — you'd think that the more of a chemical you're exposed to, the sicker you'll get — the science has, in fact, been saying otherwise for years. A team of 12 scientists recently released a report calling on EPA to completely revamp the way they evaluate chemicals, to better reflect this now fully understood reality: Tiny amounts of certain chemicals can have devastating effects on human health.

It’s all about the hormones. Our systems are largely regulated by these powerful chemical messengers, and the intricate process of fetal


Design features will be added to Chapter 2, section 2.4.4.4 (Nonnative Plants/Noxious Weeds), that more clearly identify applicable standard operating procedures that minimize human exposure to

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http://investigativereportingworkshop.org/investigations/toxic-influence/story/exponent-inc-herbicide-paraquat-parkinsons-disease/

http://investigativereportingworkshop.org/investigations/toxic-influence/story/exponent-inc-herbicide-paraquat-parkinsons-disease/

http://www.beyondpesticides.org/dailynewsblog/?cat=166

http://www.beyondpesticides.org/gateway/pesticide/paraquat.htm

http://www.beyondpesticides.org/gateway/pesticide/maneb.htm

http://www.beyondpesticides.org/dailynewsblog/?p=4965

http://edrv.endojournals.org/content/early/2012/03/14/er.2011-1050.full.pdf+html

http://www.panna.org/science/biomonitoring/body-burden-health



development is all but completely orchestrated by them.

The bad news is, some synthetic chemicals look a lot like our natural hormones to the “hormone receptor” trigger cells that turn many functions on and off in our bodies. Particularly for the developing systems of infants and children, it’s often the timing — not the dose — that matters most.”

Schafer, Kristin, “Low doses matter hugely, say scientists” Published in Groundtruth, April 2, 2012 Source: http://www.panna.org/blog/low-doses-matter-hugely-say-scientists

herbicides. These are briefly described below.


Pesticide application on the Forest is completed by employees who are certified pesticide applicators, or directly supervised in the field by a certified pesticide applicator. A certified pesticide applicator completes training programs pertaining to the principles of proper handling and use of pesticides. In order to maintain a certification for pesticide application, individuals are required to complete continuing education programs throughout their career (Black 2013). Typically, application rates would be at the minimum necessary to control target species.

Conclusion When dealing with health issues like this that involve the unaware public it’s better to be safe than sorry.



Tu et al. 2001, as revised through 2005, concluded that “Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, and at least one formulation

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http://www.panna.org/science/biomonitoring/body-burden-health

http://www.panna.org/children

http://www.panna.org/children

http://www.panna.org/blog/low-doses-matter-hugely-say-scientists

http://www.panna.org/blog/low-doses-matter-hugely-say-scientists



sold as Rodeo® is registered for aquatic use.”




As the Responsible Official please do not direct your staff to prepare denial or ‘it doesn’t apply to this project” statements.

As required by CEQ at 40 CFR Sec. 1503.4 “Response to comments”:

(a) An agency preparing a final environmental impact statement [or environmental assessment] shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed below, stating its response in the final statement. Possible responses are to:

6) Modify alternatives including the proposed action.

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7) Develop and evaluate alternatives not previously given serious consideration by the agency.

8) Supplement, improve, or modify its analyses. 9) Make factual corrections. 10) Explain why the comments do not warrant further

agency response, citing the sources, authorities, or reasons which support the agency's position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or further response.

(b) All substantive comments received on the draft statement (or summaries thereof where the response has been exceptionally voluminous), should be attached to the final statement whether or not the comment is thought to merit individual discussion by the agency in the text of the statement.

(c) If changes in response to comments are minor and are confined to the responses described in paragraphs (a)(4) and (5) of this section, agencies may write them on errata sheets and attach them to the statement instead of rewriting the draft statement. In such cases only the comments, the responses, and the changes and not the final statement need be circulated (Sec. 1502.19). The entire document with a new cover sheet shall be filed as the final statement (Sec. 1506.9). As displayed above, all comments received in Attachment 18 have been responded to and addressed in 1 or more of the 5 ways identified above under 40 CFR 1503.4(a). When a linked article in a comment could not be located so as to allow the Agency to fully understand the context of the comment, that problem was identified, and the Agency responded based on

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what was provided as a quote of paraphrase of the identified document. Responses may also indicate that the referenced article is gray literature, not peer reviewed, etc., if that fact is relevant to the subsequent Agency response.

Most reasonable managers would not take the chance of killing someone even if the probability of it occurring were low.

Are you ready to take this risk?





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Clear Creek Integrated Project Environmental Assessment

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Transcript of Clear Creek Integrated Project Environmental Assessment