Feedback on the Draft EIS Myrtle HFRA Project 7/17/06
Comments on the Draft EIS • DEQ • Idaho Conservation League • Wild West Institute • Selkirk Conservation Alliance • Kootenai Environmental Alliance • The Lands Council • Total content is bout 50 pages. • Most comments from the conservation groups are viewpoints, statements and opinions. Issues that are outside the scope of this project and better dealt with at the forest plan level. The Myrtle HFRA project is used as a place to voice their opinion. • The comment from each organization are available in electronic format – see Patty Perry.
Chapter 1 – Draft EIS • Using the collaboration process from the Interim Field Guide for community based HFRA projects, the goals and objectives for the Myrtle Creek HFRA project are to: • 1) Maintain Myrtle Creek watershed as a source of high quality drinking water for the City of Bonners Ferry; • 2) Reduce hazardous fuels in the Myrtle Creek watershed and adjacent forests; • 3) Trend vegetation in Myrtle Creek watershed and adjacent forest towards conditions that would be less susceptible to catastrophic fire, while maintaining and restoring habitat for fish and wildlife species.
Aquatics • Concerned about road density of 2.6 mi/mi2 in the watershed. • Did the HFRA collaboration process accurately depict the extensive damage done to the analysis area by previous actions similar to the ones proposed in this DEIS? • Question the validity of the computer modeling used to predict changed in water yield and sediment production. • The cumulative effects of on-forest and off-forest activities are not adequately considered.
Fuels • Logging will allow increased more sun on the ground which will dry the fuels and allow the wind into the stand - creating more flammable conditions than if left fully shaded. • We question what ecosystem components are threatened in the project area in the event of fire, how a stand replacement fire would be outside of the historic range of variability, and what evidence exists to show that high intensity fires did not burn within dry-site forests in the Selkirk Mountains. • The DEIS reveals the facts of ecosystem damage of increased fire severity caused by logging, yet fails to adequately factor in this risk as would be elevated by the Proposal.
Fisheries • The DEIS does not clearly indicate if viable populations of native trout have been maintained in the project area. The degraded fisheries conditions noted in the DEIS clearly show that the desired effects on water quantity and fish habitat have not taken place. • Deposits of sediment, along with bedload scour, streambed instability, and stream bank erosion have seriously and adversely affected water conditions and fish habitat in Snow Creek, Myrtle Creek and tributaries. The water temperature problems that currently exist will be further impacted with the planned logging activities.
Vegetation Management – Old Growth • Disagree that the FS meets the forest plan standard of 10% coverage of old growth across the Idaho Panhandle National forests. • Disagree that understory fires (20-40 years apart) used to create and maintain the dry site old growth stand at approximately 30% - 60% canopy cover. • Don’t believe the proposed thinning and under burning prescription for the dry site old growth stands. • Disagree with logging as a tool that could start to restore stand composition, structure and the biological diversity of the these stands.
Wildlife • The question becomes whether the Myrtle Creek HFRA Project as presented in the Myrtle DEIS will indeed maintain and/or restore habitat for fish and wildlife. Alliance for the Wild Rockies and Selkirk Conservation Alliance have grave concerns regarding the potential impacts of the project on grizzlies and their habitat. • Concerned about helicopter logging, disturbance to grizzly bears and keeping areas secure in a bear management unit (BMU).
Soils • The Region One Soil Quality Standards (SQS) recognize a threshold level of damage in “activity areas” yet the DEIS fails to meet NEPA’s cumulative effects analysis requirements in that it does not disclose levels of past soil compaction and other damage using the same analysis area concept. The DEIS is written as if cumulative “activity area” soil damage amounts in any given watershed are irrelevant. • We are troubled that tractor logging is proposed for 34 acres in Unit D4, an area of unstable slopes, with slumping roads and past clearcuts surrounding the area. This would certainly appear to fit the definition of a landslide-prone area and be protected under INFISH guidelines. The Forest Service should modify the proposal to avoid entering these areas.
Roadless Areas • We are opposed to logging within roadless areas, regeneration harvest prescriptions, the proposed areas of large openings, contend there is a lack of cumulative effects analysis. • We believe that the logging proposed in these roadless areas will adversely impact the few areas in the Myrtle watershed that are ecologically intact and has the potential to further degrade water quality rather than protect it. • The analysis of the project’s effects on roadless areas is wholly inadequate.
Openings • We are very concerned with the extensive silvicultural treatments proposed, and would like information as to why openings one to five acres in size, and openings over 40 acres in size have been proposed and how the Forest Service established this seemingly arbitrary number. • We are opposed to the 942 acres of regeneration harvest is proposed using irregular shelterwood and seed tree with reserve tree methods, much of it within IRAs, with openings proposed over 40 acres, and in units that exceed soil quality standards. These openings over 40 acres are proposed in 7 units (B1, B4, B5, B6, D6, E3, and G1).
Road management • The effect of 40 miles of road reconstruction on OHV use is not disclosed or discussed in the DEIS. With significant miles of newly reconditioned roads, there is likely to be an increase in motorized activity. This has the potential to impact wildlife, create additional erosion and sedimentation and disturb non-motorized users. The effect of this road reconstruction and its direct and indirect effects must be adequately disclosed and analyzed. • Forty miles of road reconstruction in these drainages is a concern for our organizations. While we understand the role of reconstruction in reducing sediment, we are concerned that many of the road segments may currently be “brushed in” and are not a significant source of sediment to streams. The location, intensity and purpose of the 40 miles of road reconstruction should be clearly displayed in the FEIS. To Clarify: • Approximately 40 miles of haul routes are proposed to be reconditioned using standard timber sale contracts. • Those roads not used for hauling timber would use appropriated funds for watershed restoration work. • Road decommissioning work is prioritized on page 2-12 of DEIS. • Most road decommissioning work was analyzed under the Myrtle Cascade EIS of 2001. This DEIS is analyses the effects of decommissioning the 1309 UA spur road and the temporary 402C road (page 2-11 DEIS).
Modifications • Drop D4 (34 acres) • Move Unit “F1” to the NE for half its length to protect area above intake.