April 25, 1997

Ms. Linda Duffy

Responsible Official, HAZRED Project

Ashland Ranger District

Rogue River National Forest

645 Washington Street

Ashland, OR 97520

Dear Ms. Duffy,

This letter reflects the comments on the proposed HAZRED Project by the Cascadia Fire Ecology Education Project (CFEEP). Our careful reading of the Environmental Analysis (EA) has led us to the firm conclusion that the official documentation is seriously flawed: the disclosure of impacts is incomplete, the effects analysis is inadequate, and the Project is ill-conceived. Given the importance of genuine hazard fuel reduction, the full range of ecological and social values at risk, the lack of disclosure of significant effects in the EA, and the precedent-setting nature of this project, the agency must at a minimum submit the Hazred Project to more rigorous analysis and more extensive public disclosure in an Environmental Impact Statement (EIS).

This future EIS should include a wider range of action alternatives than presented in the EA; specifically, the EIS should offer another new alternative that includes prescribed underburning and non-commercial vegetation manipulation without commercial timber sales or the use of heavy equipment. The original alternative that proposed prescribed underburning without commercial timber sales was wrongly eliminated from detailed study. It would have benefitted both the agency and the public to run this excluded alternative through the SYSDYN5 model to see what its effects on fire hazard reduction would be. The rationale for excluding this alternative is yet another example of the agency confusing means and ends. From reading the document it is clear that the primary purpose of the Project is to offer commercial timber sales, and the pretense of reducing fire hazard is the means of selling the Project to the public. If fire hazard reduction was the real, genuine goal of the Project, then the agency should be more open to the use of alternative methods besides commercial logging to achieve those ends. If the Responsible Official goes forward and selects one of the action alternatives with the flawed analyses and incomplete documentation of the current EA, then she will certainly be putting the Project at risk of administrative appeals, citizen lawsuits, and more.

Below are a number of CFEEP’s critiques of the EA for its erroneous assumptions, incomplete data, flawed analyses, and inadequate disclosure of the significant direct, indirect, and cumulative impacts of the Hazred Project:

ITEM: FAILURE TO DISCLOSE INDIRECT AND CUMULATIVE EFFECTS OF FUTURE FIRE SUPPRESSION ACTIONS ALONG RIDGELINE FUELBREAKS

To be meet the legal requirements of NEPA, the agency must disclose the foreseeable direct, indirect, and cumulative effects of proposed management activities. The document states that ÒIt is well recognized that shaded fuelbreaks alone do not provide an effective strategy for the suppression of wildfire,” and that “the combination of fire prevention and suppression activities along with the fire management strategies proposed with this project provide the most effective defense against the spread of wildfire” (p.24, EA) Furthermore, “For the modelÕs fire spread and size projections, the current fire suppression capability of local, federal, state and county wildland suppression agencies are assumed to be the same in the future as they are nowÓ p.7, AF) Indeed, using current suppression tactics and strategies, fuelbreaks and flanks must be “improved” during a wildfire suppression incident in order for them to function effectively as a containment line to stop fire spread. If fuelbreaks/flanks are intended to be the sites of future fireline construction, as the SYSDYN5 calculations assumed that they would be, then the indirect and cumulative effects of projected fire suppression actions must be analyzed and disclosed along with the rest of the Project activities. Moreover, since “worst case” scenarios were used to analyze the effects of future wildfires, so too Òworst caseÓ scenarios should be used to analyze the effects of future fire suppression actions.

To properly analyze these indirect and cumulative effects of fuelbreak/flank constructions, the agency needs to disclose the full array of probable firefighting impacts intended for those fuelbreak/flank areas. The suppression impacts that routinely occur during standard Forest Service fireline construction involve: habitat tree felling, soil disturbance by heavy equipment and handcrews, chemicals dumped in riparian zones, managed ignitions to burnout or backfire, and more. These future suppression impacts will significantly affect the wildlife habitat and water quality values in these fuelbreak sites and adjacent flank stands. To comply with NEPA, the agency needs to disclose these foreseeable indirect and cumulative effects resulting from or associated with proposed Project activities.

QUESTIONS:

--Can the proposed commercial logging alone result in a lower risk of large-scale wildfire without involving fire suppression activities? If not, why were the effects of logging analyzed, but the effects of firefighting were not?

--What kinds of fire suppression strategies and tactics were used as assumptions to run the SYSDYN5 program?

--What will be the likely foreseeable environmental effects of fire suppression actions conducted within and immediately adjacent to the fuelbreaks and flank zones?

--Are the environmental effects of habitat tree felling, soil disturbance by heavy equipment and handcrews, chemicals dumped in riparian zones, and managed ignitions to burnout or backfire more or less impactful on the environment over the long term than the effects of wildfire alone?

ITEMS: FAILURE TO ADDRESS STRUCTURAL FIRE PROTECTION AND CONTRADICTION WITH NEW FEDERAL FIRE MANAGEMENT POLICIES

The Project is wholly structured around promoting pyrophobia--the fear and hatred of forest fires. A great example is the cover of the EA for the Hazred Project: a scary photograph of huge smoke clouds billowing above the city during the 1959 Ashland Fire. In the smeary black photocopied image, it seems as if the flames are about to race into the town. Implicitly if not intentionally, the effect creates fear in the public that they could lose their homes or businesses in a raging fire coming down from the forest. We wonder if the agency hopes that most people will not even bother to read the document because the cover so effectively creates an impression intended to generate public support for the Hazred Project in order to ÒprotectÓ the town of Ashland.

Despite the dramatic image on the cover and the listing of “Human Life and Property” at the top of the list of “value at risk” (p.3,EA), nowhere else in the document does the agency raise the issue of structural fire protection in the wildland/urban interface zone. The EA fails to explain how human life and property will be protected by the proposed hazard reduction activities. Furthermore, the EA fails to disclose the direct or indirect environmental effects of the Project’s fuels management strategy on structural fire protection in the Ashland interface. In the short-term, fire hazard will actually increase dramatically due to the logging slash.

This opportunistic, propagandistic display of pyrophobia undermines the stated purposes of the Hazred Project, and worse, it contradicts emerging federal fire management policies. It may win some short-term support for commercial timber extraction, but this will come at the dear cost of needed public support for the use of prescribed fire both in this specific Project and in general ecosystem management. Indeed, in the Hazred Project, the agency might convince some of the public to endorse the commercial timber sale proposals under the impression that this will save Ashland from forest fires, but the agency will have a vastly more difficult time convincing the public to support the prescribed underburning and slash treatment portions of the Project that are essential to the alleged purpose of fire hazard reduction.

This continued state-sponsored pyrophobia directly contradicts the recent revisions of federal wildland fire policies. These new policies commit the Forest Service and other federal land management agencies to reeducate its employees and the general public about the ecological benefits of forest fires, and the economic costs of continued fire suppression strategies and tactics. Towards meeting this goal, the agency could have and should have displayed a picture of smiling Forest Service employees doing a prescribed burn on the cover of this EA instead of a wildfire threatening town. Additionally, the new federal policies mandate the development of new fire management plans. These new plans must conform to the new federal wildfire policies, and must be incorporated into Land and Resource Management Plans as well as specific Projects. With the Project’s proposed fuels management activities, the agency is making longterm commitments to an out-dated pyrophobic philosophy and obscolete suppression tactics and strategies. The agency needs to discuss how, if at all, the Project complies with the new federal wildland fire management policies.

QUESTIONS:

--How will proposed management activities affect structural fire protection in the urban/wildland interface zone?

--How will the ridgeline fuelbreaks stop a backing fire from burning downslope into the city?

--Will the design of the ridgeline fuelbreaks reduce or actually increase the risk and hazard of wildfire spreading into Ashland?

--How will the proposed hazard reduction activities of this Project be in compliance with the new federal wildland fire management policies? Will the system of ridgeline fuelbreaks impose unnecessary longterm environmental impacts because these ÒreactiveÓ fire suppression strategies and tactics may become obscolete in the near future?

--How does the agency propose to overcome its use of pyrophobia, and educate the public about the ecological role of fire in maintaining healthy forest ecosystems? How will the pyrophobia fueling the timber sale portion of the Project be counteracted to gain public support for the prescribed burning portion of the Project?

ITEM: FAILURE TO JUSTIFY THE PURPOSE AND NEED FOR THE PROJECT

The project is tiered to the Bear Watershed Analysis, the Mt. Ashland LSR Assessment, and the Northwest Forest Plan, which all discuss the need to protect the area from large-scale stand-replacing wildfires. Specific supportive passages from these documents should have been including in the EA to help public readers assess if the proposed commercial timber sales are satisfactory methods of “vegetation management” in this special area. For example, the NWF Plan focuses on precommercial thinning of plantations and prescribed understory burning as the preferred methods of fuel reduction for fire protection within LSRs. Promoting new commercial timber sales of old-growth as the primary or preferred method for vegetation management is an inappropriate activity unless and until threatened species populations have fully recovered and the inherent fire hazards of existing plantations have been reduced.

The document states that fire is a key natural disturbance mechanism (p.2,EA), yet fails to disclose how fire creates biological diversity habitat and maintains late-successional habitat and water quality. Fire is constantly presented as a bad, ÒcatastrophicÓ agent throughout the document. The documentation for the Project must include disclosure of the positive uses and natural role of fire in maintaining forest health and reducing so-called “catastrophic” fire events. This is necessary not only for the public to objectively assess the tradeoffs associated with logging vs. burning in the Project area, but also to build public education and support for future prescribed burning proposals throughout the Rogue River National Forest.

The EA consistently makes the claim that a future large-scale wildfire would be “catastrophic,” and implies that the values at risk would be severely impacted if such an event occurs. Indeed, the impression is conveyed that the impacts of wildfire would be far worse than the impacts of logging, slash-burning, and road-building. Nevertheless, the document states that Òa total of 194 fires occurred within the Analysis Area during a 34 year period” (p.3,EA) including three large fire episodes this century. The EA fails to explain, however, how it is that despite all of these earlier fires the forest is miraculously thick with spotted owls and the watershed produces superior water quality for fish and humans. Apparently, these values were not destroyed by recent large-scale or frequent small-scale fires. Indeed, the agency fails to substantiate the alleged need for protection from large-scale wildfires, and therefore, fails to justify the purpose of the Project to ÒprotectÓ the area from future fires.

The purpose and need for the Project depends on the agency’s claim that “Without the implementation of fire management strategies, the area burned by wildfire would exceed the acres of the Analysis Area in 130 years.” This is an incredibly weak justification for implementing the Project. For one thing, computer-generated fire modelling is not yet an accurate predictive science nor will it likely ever be given the variables of fire behavior and fire effects. Thus, this statement is at best highly speculative, yet it is misrepresented as a factual statement. Secondly and more importantly, from a fire ecology perspective this statement is entirely meaningless. The effects of wildfire(s) on watersheds cannot be reduced to mere total size in acreage of the forest burned. Rather, evaluation of fire effects is a qualitative, not quantitive assessment.

In many cases, frequent low-intensity fires play a positive role in maintaining forest health; hence, merely adding up the total acreage of these kind of ÒgoodÓ fires misrepresents the effects analysis. The agency fails to disclose if the potential future burned acreage in the Project area will result from a single large-scale, high intensity fire event or several smaller, low intensity fire events. There would be huge differences in environmental effects between the two kinds of fires. But even large-scale, high intensity wildfires are not uniformly destructive of social and environmental values. Indeed, there is typically a wide range of mortality effects on trees resulting from large-scale wildfires, which is precisely one of the ecological benefits of wildfire. The mere speculation that the Analysis Area will experience some kind of fire(s) over the next six generations of human beings (130 years) does not justify the kinds of direct, indirect, and cumulative environmental impacts that will result from the commercial timber sales. The agency thus fails to make a convincing argument for either the purpose or need of the Hazred Project.

Lastly, the Hazred Project will not accomplish its intended purpose to reduce the risk of large-scale fire burning inside or outside the Project area. Annual Wildfire Statistics published by the Forest Service defines the large-scale fire size class as those fires exceeding 350 acres. Despite the environmentally and economically costly logging, slash burning, and road building to allegedly reduce the risk of large-scale fires, the SYSDYN5 calculations still anticipate large fires up to 650 acres in size burning every 28 years, cumulatively burning over 18,000 acres within the next 200 years (p.24, EA). Despite the costs incurred by taxpayers for the ProjectÕs commercial logging activities, taxpayers will still have to pay an estimated 3 to 7.5 million dollars in future suppression costs. From the data presented in the EA, the Project will fail to achieve its stated purpose to ÒpreventÓ or ÒprotectÓ the area from large-scale wildfire. Again, the agency has failed to justify with reasonable logic the purpose and need for this Project.

QUESTIONS:

--What are the primary fire and fuel hazards identified in the Bear Watershed Analysis and the Mt. Ashland LSR Assessment?

--Are the construction of ridgeline fuelbreaks presented as more of a priority than precommercial thinning of previously logged stands?

--Are new commercial timber sales of old-growth and new (albeit “temporary”) roads identified in the above documents as appropriate, preferred methods of vegetation management or fire hazard reduction in this LSR/CHU? Are these activities appropriate for the cityÕs municipal watershed?

--What are the ecological and social costs of continued fire prevention and suppression? What are the ecological and social benefits of the reintroduction of managed and natural fire in the Project Area and the rest of the Forest?

--What is the agency’s definition of a “large-scale” fire? What does the agency consider to be a ÒcatastrophicÓ wildfire event? Are all large-scale fires ÒcatastrophicÓ? If so, how and why? If not, how does the agency justify the environmental impacts and economic costs of this Project if it will not achieve its stated purpose and need?

--How and why is the Project Area providing superior habitat for spotted owls and superior water quality for aquatic species and urban residents despite experiencing nearly 200 wildfires, including three large-scale fires, during this century?

--How many and what intensity of wildfires does the SYSDYN5 program speculate will burn in the Analysis Area? How many fires exceeding 350 acres can be expected bot with and without the commercial logging activities?

--How large is the Analysis Area compared to the Project Area? Are the number and frequency of fires in the Analysis Area skewing the data? Does the number and amount of fires projected for the Analysis Area exaggerate the risk of future fire occurrence within the Project area?

ITEMS: FAILURE TO ADDRESS THE PRIMARY FIRE RISK AND HAZARD, AND FAILURE TO SATISFY THE STATED PURPOSE AND NEED FOR THE PROJECT

The EA discloses that human-caused fires accounted for the majority of fires in the Analysis Area. Moreover, it mentions “an alarming increase in arson-caused fires in the early part of the 1990’s” (p.3). The primary risk of fire is not due to the flammability of the natural vegetation, but due to the carelessness or criminality of certain people. Yet, the Project does not propose to do anything to reduce this risk; indeed, the document does not even mention the issue of arson again. The agency proposes to reduce fire hazard by manipulating the fuels, but without an actual fire ignition, the concept of fire hazard has no meaning or significance.

The EA further discloses that the majority of these fires “occurred at lower elevations, primarily along roads, residential areas, and places of frequent outdoor recreation” (p.3). However, the only areas proposed for fuels manipulation are along the ridgelines within the LSR, far away from the most likely sites for fire starts. The Project does not propose to do any kind of fuels management in the areas of high to extreme fire risk and high fire hazard. If a fire starts in this area it will likely experience rapid fire spread. If the agency intends to stage its suppression efforts along the ridgelines, then it is essentially choosing an indirect attack strategy that inherently sacrifices more acreage to wildfires than direct attack strategies starting close to the likely points of ignition. From the sites of likely human-caused ignitions to the ridgelines, the acreage will by default constitute large-scale fires (greater than 350 acres in size). Hence, the commercial timber sales and other proposed fuels management activities will fail to satisfy the alleged purpose of the Project to prevent wildfires or protect the area from large-scale fires.

Finally, the dominant variable affecting the potential for a large-scale fire is not raw tonnage of fuel, but rate of fire spread. Smaller ÒflashyÓ and ÒladderÓ fuels in the 0-9 inch classes--and most especially logging slash--account for extremely rapid fire spread. Large fuels greater than 9 inches DBH are less prone to extreme fire behavior, and the large commercial grade trees that the agency desires to sell for timber in the Project are the least prone to rapid spread. Even if they were subject to such an event, it is nearly impossible for 100% of their biomass to be consumed by the fire. Ground fuels would be exhausted and weather would change long before the so-called “10,000 hour fuels” (417 days!) were consumed. Thus, even with an extreme fire event, much of the biological legacy of large downed logs, large standing snags, and large fire-killed trees would remain, thus allowing old-growth/late-successional habitat to regrow quicker than if the agency has extracted these same large sized habitat structures.

The burning window of extreme fire behavior consuming 50% of the biomass in so-called “senescent” stands is the least probable scenario; indeed, from the agencyÕs own analysis, the annual probability for such an event is barely 4% (or 96% probability that such an event will NOT occur!). More importantly, the agency admits that this fire effect is an assumption. Nowhere is evidence cited from the fire science research literature or other data to substantiate this assumption. Hence, the SYSDYN5 calculations are prone to the errors of the agency’s assumptions of fire effects.

To repeat, the large fuels are available to extreme fire behavior only during a relatively narrow portion of the fire season, when conceivably fire suppression forces could be staged nearby on high alert. The small sized fuels (0-9 inches) dry out much earlier and remain prone to extreme burning conditions for a much longer period during fire season. The small sized fuels account for rapid fire spread, the variable most affecting the possibility of a large-scale fire. That the agency intends to focus on the large commercial-grade fuels first shows the eternal timber bias that drives agency decisionmaking. The fact that small-sized, non-commercial grade live fuels are being treated almost as an after-thought reveals that commodity outputs are still the focus of the agency, even in the LSRs. If the agency was truly interested in genuine fire hazard reduction and reducing the risk of large-scale fire, it would come up with a plan that prioritizes management of small fuels, prevents the creation of additional small fuels (i.e. logging slash), and preserves existing large fuels to serve as moisture reservoirs, shading structures from wind and sun that all work to retard rapid fire spread.

QUESTIONS:

--Why is the agency only proposing fire hazard reduction activities and not fire risk reduction activities? How can the agency claim to be reducing fire hazard if it ignores fire risk, particularly the risk of future arson?

--Why was there an alarming increase of arson-caused fires in the early 1990s? Has the rate of arson increased, decreased, or remained steady since then?

--Where were the majority of arson ignitions located? Were the subsequent arson-burned areas converted into commercial salvage timber sales?

--How will the Project affect the amount and kind of arson or accidental ignitions?

--Why is the Project failing to reduce the fire hazard of lower elevation forest adjacent to residential areas? Why are ridgelines more “strategic” sites for fire suppression than the areas that are most prone to human-caused ignition?

--How committed is the agency to using the fuelbreaks for fire suppression? How will the ridgelines prevent large-scale fires when they inherently represent an indirect attack strategy that purposely sacrifices more acreage to wildfires than direct attack strategies?

--Why is the agency prioritizing the extraction of large-sized fuels instead of small-sized fuels which are more responsible for rapid fire spread?

--What fire science research, literature citations, or other data supports the agency’s assumptions that 50 to 70% of all so-called ÒsenescentÓ stands would be returned to less-than-old growth status? What would be the actual effects of wildfire on the large-sized fuels from an extreme wildfire event? How much biomass from these large-sized fuels would be reduced by fire?

ITEM: FAILURE TO ADEQUATELY DESCRIBE THE RANGE OF ALTERNATIVES

In the description of proposed actions, there is not enough information disclosed to make clear the differences between the three different categories. It is not clear how the shaded fuelbreaks qualitatively differ in the amount and kind of commercial tree extraction than the flanks. The EA states that fuelbreaks will be commercially logged to Òallow for an average of 20 to 30 foot horizontal spacing between the crowns of dominant and codominant trees.” This is a considerable range of variation that is also presented as an “average.” Thus, some trees will be closer together, but more likely, some trees will be farther apart than the average. Indeed, in the silvicultural prescriptions for units 22, 32, 34, 38, and 39, the EA states that “The situation may also occur where there will be more than 20 feet between crowns of trees because of other factors” yet it does not state what these other factors might be (could it be desire for more timber volume?). Even worse, the prescription for unit 31 states that tree spacing may range up to 60 feet between crowns. The extent of tree removal within the fuelbreaks and flanks needs to be more fully disclosed with more precise estimates and clearer presentation of data for the public to understand the significance of the environmental impacts.

Considering that several tree species can grow canopies reaching 20 to 30 feet out from the main stem, then these trees would be thinned to an average spacing of 60-90 feet horizontal from each other. That is a significant environmental effect that needs to be fully disclosed, for it is not only the canopies of trees that provide shading, but also the trunk. Indeed, research on the Willamette National Forest revealed that the stems of trees 150 feet tall with a 24 inch DBH accounts for 15-24% of the tree shade on a slope.

There is insufficient description in the EA to enable the public to distinguish the fuelbreak units from the flank units. The reduction of fuels in flank units “to a lesser degree” than fuelbreaks does not convey enough information to make the distinctions between the two kinds of units clear. The description for flanks states that Òtreatment would reduce interlocking crowns of dominant and codominant trees” but the document does not disclose how much reduction of stems and how wide the spacing between crowns the logging will leave. It becomes even less clear and more confusing in the 622 acres where flank and density management activities have been combined (p.8,EA). The differences between the three categories of units need to be clarified and given fuller description.

The EA gives the impression that prescriptions for flanks and density management/fuels reduction units will satisfy the alleged purpose and need of the Project without the need for more extensive tree removal proposed for fuelbreaks. The EA states that Òreducing continuous vertical and horizontal fuels to a lesser degree than what is proposed within the shaded fuel break...increases the likelihood for successful suppression of approaching wildfire and improves the safety conditions for firefighters by providing work areas that are more fire resistant” (p.4). Further, the EA states that prescriptions for density management/fuels reduction units will “lower the fire hazard rating within the stands treated.” If these prescriptions will, in fact, lower the fire hazard rating and provide for safe, successful fire suppression, then the agency has failed to justify proposals for greater amounts of tree removal (as prescribed for fuelbreaks).

QUESTIONS:

--If the “average” spacing between crowns is 20-30 feet, what is the upper limit on the amount of spacing between trees?

--How many trees per acre greater than 9 inches DBH will be left in fuelbreak and flank units? How many trees per acre less than 9 inches DBH will be removed in fuelbreak and flank units?

--What “other factors” will make it necessary to space tree canopies greater than 20 or 30 feet from each other?

--How do the prescriptions for fuelbreaks, flanks, and density management units compare in terms of fire hazard rating, firefighter safety, and suppression success? Is there a point of diminishing returns such that the benefits in terms of additional fire hazard reduction are counteracted by the costs of late-successional habitat or watershed quality reduction?

ITEM: FAILURE TO DISCLOSE CLEAR AND ACCURATE DATA ON AMOUNT OF TIMBER EXTRACTION

The EA states that “an estimated 2,000 to 3,500 thousand board feet (MBF) of commercial timber volume” will be removed (p.5). This is presented in a confusing, almost deceptive way. Using the symbol “MBF” makes it appear that the logging will only remove 2 to 3.5 thousand feet of timber; however, inserting the word “thousand” alongside the actual number makes it appear that in fact 2-3.5 million board feet of trees will be removed from this LSR. If that is the case, then the symbol “MMBF” should have been used. Also, 1,500,000 board feet is a fairly significant range of estimate to present the public. The agency needs to do more analysis to give a clearer and firmer estimate of the amount and extent of tree removal from the Project area.

QUESTION:

--How much total estimated timber is proposed for removal? Is it in the range of thousands or millions of board feet?

--Why can’t the agency provide a more precise figure or narrower range for the estimated amount of timber extraction?

ITEM: FAILURE TO DISCLOSE THE PRIMACY OF ECONOMIC OVER ECOLOGICAL CONSIDERATIONS IN MARKING TREES FOR CUTTING

As stated in the EA, providing commercial timber sales are not the purposes of LSRs and therefore the Hazred timber sales will not contribute to the Forest’s probable sale quantity. However, the statement that “...fire hazard reduction objectives would be the factor determining the actual volume removedÓ (p.5,EA) is less than honest disclosure of the purpose for commercial timber sales. The silvicultural prescriptions and marking guides in the ProjectÕs Analysis File repeatedly state that for helicopter logging “adequate turn volume and tree size is a consideration in designating trees for cutting.” The EA discloses that for helicopter logging, “a minimum of 500 board feet of timber within a 50 foot radius in five or six trees is needed per turn,” but the document does not disclose why this amount of volume is needed. The public is left to guess whether this is for the sake of fire hazard reduction or for the sake of increased logging profits that these guidelines are ordered for fuelbreak and flank units. These statements in the Analysis File give the strong impression without clearly stating so that economic considerations (i.e. corporate profits) are the most important criteria for marking trees to cut in fuelbreaks and flanks. This not only violates the management direction for LSRs, but also violates Forest Service regulation 36 CFR 219.27(b) which states that manipulation of vegetation shall "not be chosen for the reason of either greatest dollar return or greatest timber output alone."

QUESTIONS:

--Are commercial timber sales merely the means for implementing actions, or the actual goals of the Project?

--Which criteria is most important and will receive the primary consideration: the ecological need for adequate shade and structure in the fuelbreaks and flanks, or the economic need for profitable and efficient helicopter logging? How will the marking crews lay out sale units if ecological and economic criteria contradict each other?

--What will marking crews do if the “minimum” timber volume or tree size needed for helicopter logging cannot be attained? Will they space “leave trees” farther apart in order to get the needed timber volume? Will they skip areas that do not have trees with the minimum DBH? How will these scenarios affect the goals of hazard reduction and management of the LSR for habitat and watershed quality?

--How do the silvicultural prescriptions and marking guidelines for helicopter units comply with 36 CFR 219.27(b)?

ITEM: FAILURE TO ENSURE COMMITMENT TO FUND AND IMPLEMENT ALL PROPOSED ACTIONS OVER TIME

The document makes several references to the need for “maintenance of existing shaded fuel breaks” (p.4,8,EA) These “maintenance” units total 129 acres, and apparently do not currently meet the criteria for effective fuelbreaks. The agency needs to disclose why these exissting fuelbreaks need additional commercial timber extraction in order to function as effective fuelbreaks. It also needs to disclose why in the case of unit 7, for example, Òtoo many smaller diameter trees were left” from the original timber sale, and explain how these small diameter trees “compromise the integrity of the fuelbreak” (Specific Marking Guidelines for Unit 7, AF).

The fact that the agency failed to maintain existing fuelbreaks does not give much assurance to the public that the new fuelbreaks proposed in the Hazred Project will be maintained in the future. Throughout the Pacific Northwest there has been systematic failure to properly maintain fuelbreaks---without regular maintenance, fuelbreaks are completely ineffective. There are several causes for concern that the proposed fuelbreaks will never function according to plan due to lack of agency commitment to properly fund and manage the Project over the long-term: 1) the nature of the agency’s budget makes it fluctuates annually and makes it vulnerable to political manipulation and shifting priorities from Congress and changing Administrations; 2) the nature of the agency’s transient workforce makes it difficult if not impossible to sustain the institutional memory necessary to carry on longterm management plans and specific projects; 3) the agency continues to propose new timber sales instead of dealing with the immense backlog of untreated slash accumulations, overstocked/understocked plantations, need for road closures and removal. Considering the time frame for the fire analysis that presented the need to protect the Project area from future large-scale ÒcatastrophicÓ fires for the next 130-200 years, the agency needs to disclose to the public how it can overcome the above systemic problems, and will be able to fully fund and maintain the Project’s new fuelbreaks for the next 130 years.

The EA makes several statements to the effect that “To fully achieve hazard reduction objectives, adequate slash treatment would be necessaryÓ (p.8). Throughout the National Forests of the Pacific Northwest there is a backlog of untreated logging slash that is nearing crisis proportions. For example, on the Rogue River National Forest, the slash left from a 1990 salvage sale in the Hazred Project area has yet to be treated. The agency has shown a consistent lack of commitment to fund and implement slash treatment. Logging slash is one of the most extreme fire hazards in the managed forest. After the logging, the fire hazard within the Project area will definitely increase in the short-term (p.25,EA), and if the slash goes untreated, it will increase the fire hazard in the long-term; thus, undermining and subverting the alleged rationale for the Project. The EA fails to demonstrate with any assurance to the public that it will definitely and immediately deal with the hazardous logging slash in the fuelbreaks and flank units. On the contrary, in the chart on mitigation measures for prescribed burning, the option to Òburn within four drying months of harvestÓ is completely excluded from consideration in any of the Project units! The EA fails to disclose how the agency intends, if at all, to reduce the extreme fire hazard of logged units prior to slash treatment.

The most attractive elements of the Hazred Project are the proposals for prescribed underburning. The document reiterates the vital importance of this action: “prescribed burning is necessary within certain areas to help protect the Ashland Creek Watershed from catastrophic fireÓ (fire modelling portion, AF). Yet, the EA fails to convey any sense of commitment by the agency to fully fund and implement those actions. The time frame to accomplish the understory burning is over five years; yet, Forest Service budgets are only valid for one year. As presented in the chart on “assumptions for management strategies and actions necessary to protect the Ashland Creek Watershed and Mt. Ashland LSR,” the historic funding for general area underburning has been low-medium (p.7,AF on fire modelling). The EA fails to disclose how the agency will be able to commit adequate funding, personnel, and resources necessary to do the underburning in the near and long-term.

In addition to the budgetary constraints, there are internal cultural constraints within the agency and external social challenges that raise serious doubts that the agency will be able to implement prescribed underburning in the future. Forest Service managers, like most federal bureaucrats, do not get rewarded for taking risks. Risk of escaped fire is inherent with prescription burning, and the most risky operation of all would involve understory burning in an unroaded area. The EA fails to disclose how the underburning represents an actual increase in risk of wildfire, and how these actions will be safely implemented to reduce this risk of escaped fire. The EA fails to disclose if the District Ranger and her current fire management staff has the proper fire qualifications, burning experience, or political willpower to conduct prescribed understory burning on the scale presented in the Project.

Given several decades of the Forest Service conditioning the public to fear and loath forest fires, and given its opportunistic use of pyrophobia to promote the Hazred Project, the agency has some serious educational work to do to prepare Ashland residents to accept and support the agencyÕs burning operations. Moreover, considering the existing air quality problems of the Rogue Valley, opportunities to implement the prescribed understory burning (as well as slash burning) without impacting the air quality of adjacent human communities will likely be few and far between. The EA fails to disclose these internal cultural and external social challenges to conducting prescribed understory burning, and raises serious doubts that the agency has the will or desire to implement these essential aspects of the Project

QUESTIONS:

--How and why are existing fuelbreaks not meeting the criteria for effective fuelbreaks? How will the agency manage and maintain the new fuelbreaks so that this problem will not reoccur?

--If small diameter trees compromise the integrity of fuelbreaks, and yet helicopter loggers are unwilling to take them, how will the agency extract them from fuelbreak and flank units now and into the future?

--When will the agency deal with the fire hazard of existing slash accumulations? If the agency has been unable or unwilling to deal with slash left from earlier timber sales in the Project area, how can the public be assured that the agency will deal with the logging slash generated by the new timber sales in a timely manner?

--Why will the agency not burn slash within four months of logging? Does this mean that, by default, the slash will remain untreated on the ground for at least one season?

--How can the agency assure the public that fuelbreak maintenance and prescribed underburning will be properly funded over the next several decades given the fact that the agency deals only with annual budget appropriations?

--How can the public be assured that agency personnel will be committed to the alleged goal of the Project (fire hazard reduction in the urban interface zone) over the next 130-200 years given that normal transfers and retirements will bring in new people to the District?

--What does the agency intend to do about fuel load accumulations outside of proposed units, including the extreme fire hazards inherent in plantations?

--If the agency fails to treat logging slash, will it propose additional commercial timber extraction in the future to Òreduce fire hazardÓ in the area?

--How and when will the prescribed underburning be implemented? Does the District have the personnel with the right fire qualifications and burning experience to implement this portion of the Project?

--How does the agency intend to educate the public to gain support for prescribed understory burning and slash burning in the forest above town?

--How feasible is the prescribed underburning given the air quality problems of the Roque River Valley?

ITEM: FAILURE TO FULLY DISCLOSE THE ASSUMPTIONS AND LIMITATIONS OF THE SYSDYN5 PROGRAM

The EA overstates the abilities of the SYSDYN5 computer program, alleging that it has the ability to “estimate the long-term effects of wildfire” (p.3,EA). The SYSDYN5 can only project the frequency and range of future fires. This is different from the concept of effects, particularly ecological effects. For example, the effects of burning a pile of logging slash may be far more severe on soil resources than a fast-moving wildfire 100 times the size of that slash pile. The mere quantitative size of a wildfire does not measure the qualitative effects of that fire on watershed values or ecosystem functions. Indeed, from an ecological perspective, the “long-term effects” of a wildfire may be relevant for centuries following the actual fire event. The SYSDYN5 program does not provide information on the actual environmental effects (both positive and negative) of fires; therefore, it is an inadequate measure to assess the fire risk to values of this area.

QUESTION:

--What fire science research, scientific literature, or other data supports the agency’s assumptions of fire effects that were input into the SYSDYN5 model?

ITEM: FAILURE TO FULLY DISCLOSE THE EXTENT AND EFFECTS OF FUTURE COMMERCIAL TIMBER SALES IN THE PROJECT AREA AND LSR NECESSARY TO ACHIEVE THE PURPOSE AND NEED OF THE HAZRED PROJECT

In the fire modelling portion of the Analysis File is a chart which lists the Òassumptions for management strategies and actions necessary to protect the Ashland Creek Watershed and the Mt. Ashland LSRÓ (p.7). It appears from the chart that the agency intends to salvage log 5% of the entire Mt. Ashland LSR every year (this data also appears in a chart on page 11 of the same portion in the Analysis File). Discussion on page 10 of the Analysis File reveals the assumption that old-growth stands will experience continual entry and silvicultural treatments to minimize “senescent” conditions. Apparently, the agency intends to offer commercial “salvage” timber sales covering 100% of the LSR over the next 20 years without clearly stating this plan, discussing its relationship to the Hazred Project, or disclosing the significant direct, indirect, and cumulative effects of this ongoing ÒsalvageÓ logging.

If this is the agency’s true intentions for management of the Project area and the entire LSR/CHU, then the agency must disclose to the public where, when, and how this future commercial ÒsalvageÓ logging will occur. If this is not true, then this will change the data input to the SYSDYN5 model and alter the assessment of fire risk and hazard, thereby affecting the sense of tradeoffs between the impacts of wildfire vs. the impacts of logging and road-building. Finally, the agency needs to explain to the public why it considers ancient forest stands with abundant snags and downed logs--the very structures that produce superior habitat for spotted owls and their prey--to be “senescent,Ó “degraded,” or “sick” (p.6,AF). The EA uses these terms without adequately defining or explaining them.

QUESTIONS:

--Does the agency intend to “salvage” log 5% of the LSR every year? Under what management plan and/or agency document(s) is this activity described in detail? How do these planned commercial “salvage” timber sales conform to the Northwest Forest Plan’s Standards and Guidelines for management of LSRs?

--What are the ecological costs to wildlife habitat, water quality, and site productivity by extracting large snags and downed logs from 4,400 acres or more of this LSR?

--Does the agency really consider ancient forest stands greater than 125 years in age to be “senescent” and “sick”? What are the definitions of these terms and the criteria for determining an “overaged” or “sick” stand?

ITEM: FAILURE TO JUSTIFY PRIORITIZATION OF FUELS MANAGEMENT ACTIONS

In the fire modelling portion of the Analysis File is a chart which lists the “assumptions for management strategies and actions necessary to protect the Ashland Creek Watershed and the Mt. Ashland LSRÓ (p.7). The chart discloses that construction of shaded fuelbreak system and flanks has a low to medium probability of success, while general area underburning has a medium to high probability of success in reducing the fire hazard. Furthermore, in on Table 2.4 the EA discloses that the average cost per acre of logging with slash burning in Alternative 2 will be $592 ($241 + $351), while the average cost per acre of underburning alone is only $252 to $264. Thus, unless the agency intends not to do slash burning, the cumulative economic costs of logging will be more than twice the cost of underburning alone. These costs apparently do not include the cost of road construction/reconstruction, either. Inexplicably, the chart on p.7 of the Analysis File states that the Òrelative costÓ of fuelbreaks and flanks will be ÒmediumÓ while general area underburning will be Òhigh.Ó These two data sets do not support each other. If the real goal of the Project is fire hazard reduction rather than timber production, then the agency has failed to explain why it proposes to implement one of the most expensive and least successful fire hazard reduction strategies (logging with slash burning), while it excluded from detailed study a promising alternative that proposed to do prescribed underburning without commercial timber sales or slash burning.

QUESTIONS:

--Why is the agency prioritizing the most expensive method for fire hazard reduction (logging with slash burning and road building)?

--Why did the agency exclude an alternative with less cost to the taxpayer and a greater probability of success (prescribed underburning without commercial timber sales)?

--Why is the data between costs and probability of success inconsistent between the EA and the Analysis File?

ITEM: FAILURE TO DISCLOSE THE EFFECTS AND EFFECTIVENESS OF MITIGATION MEASURES

The Forest Service does not satisfy the public’s need for information in an EA by simply listing the mitigation measures in a table. Analysis of the effects and effectiveness of the mitigation measures must be documented and disclosed, for some so-called mitigation measures cause significant environmental impacts themselves. For example, burning concentrations of fuel in large piles creates severe impacts on soil directly below the pile, essentially sterilizing the site, while burning the same amount of fuel across a wider area causes far less severe impacts on soil resources. From the table in the Analysis File that analyzes units to be burned, approximately 594 total acres will be burned by concentrating the fuel in hand piles. The EA does not disclose any estimates of the number or size of these piles, the total amount of ground surface to be first covered by the piled fuel and then burned, or the foreseable site-specific impacts on the soil resulting from burning these piles.

Furthermore, while it states on p.15 of the EA that the agency intends to “burn soon after harvest before new live fuels have become establishedÓ as a mitigation measure to reduce smoke production and lessen the impacts on air quality, this action is specifically omitted from the table in the Analysis File on Òmitigation measures to applyÓ (Sheet 3, p.1). Finally, the promise to Òprotect any Endangered and Threatened species...with appropriate measures” (p.15) does not even come close to proper disclosure of management activities. This concern is particularly high considering the fact that the Project will be logging with a Critical Habitat Unit (CHU) for the northern spotted owl. If an owl nest site was discovered within one of the fuelbreak or flank units, then the agency must prevent any taking of habitat trees in an area 100 acres surrounding the nest. This will likely alter the effectiveness of those units. The agency needs to get consistent on its plans for mitigation measures, then fully disclose the environmental effects and management effectiveness of these measures.

QUESTIONS:

--What are the environmental effects of the mitigation measures proposed for the Project?

--How exactly will the mitigation measures lessen the negative environmental effects of Project activities?

--Does the agency intend to burn soon after logging before new live fuels have become established, or does it not intend to do so?

--How will the agency mitigate soil damage caused by burning concentrations of fuel, e.g. slash piles?

--What specific actions does the agency consider to be “appropriate measures” to protect Threatened and Endangered species such as the northern spotted owl?

ITEM: FAILURE TO DISCLOSE VALUES AT RISK FROM LANDSLIDES AND EROSION CAUSED BY LOGGING AND ROAD-BUILDING

The EA discusses in detail the effects of a “catastrophic” wildfire on the soil and streams, yet fails to fully document the effects of logging and road-building on soil and streams with the same (alarmist) detail. The purpose of NEPA documentation is to analyze the environmental effects of management activities, not the effects of natural processes which may or may not occur sometime in the future. The potential for negative effects on soil, slopes, and water quality is a key issue in this Project; yet, the disclosure of foreseeable direct, indirect, and cumulative impacts resulting from logging and road-building is woefully inadequate. For example, the EA discusses the effects of increased road use from log trucks, but does not discuss the effects resulting from bulldozers, graders, and dump trucks doing road construction, reconstruction, and Òremoval.Ó Nor does the document discuss the potential for increased landslides, soil erosion, and stream siltation resulting from the logging itself. Considering the recent traumatic experience of catastrophic landslides and flooding in downtown Ashland during the winter storms of 1997, it only seems prudent for the agency to model potential future landslide and flooding activity with the same vigor that it modelled potential future wildfire. The EA needs to disclose in detail the negative effects of logging on the soils, streams, local tourist/recreational economy, and other “values at risk” with the same depth and enthusiasm as it modelled these impacts resulting from potential future wildfire.

QUESTIONS:

--What are the precise quantitative figures for increased probability of landslides resulting from proposed logging and road-building?

--How much additional soil erosion and stream siltation will result from road construction activities?

--How much additional erosion and siltation will result from logging and prescribed burning?

ITEM: MISSING DATA AND INCOMPLETE DISCLOSURE ON SILVICULTURAL PRESCRIPTIONS AND UNIT MARKING GUIDELINES

Inexplicably, the Analysis File is missing descriptions for the silvicultural prescriptions and specific marking guidelines for units 2, 3, 5, 8, 17, 18, 19, 25, 26, 27, 28, 29, 30, 35, 36, 37, and 40. The public cannot make meaningful commentary on data that is absent from the official documentation. Additional documentation needs to be forthcoming in order to satisfy NEPA requirements for disclosure of environmental effects of this Project.

QUESTION:

--What are the silvicultural prescriptions and specific marking guidelines for units 2, 3, 5, 8, 17, 18, 19, 25, 26, 27, 28, 29, 30, 35, 36, 37, and 40. Why are these unit descriptions missing from the Analysis File?

ITEM: FAILURE TO DISCLOSE MEANINGFUL DATA ON THE EFFECTS OF LOGGING ON LATE-SUCCESSIONAL FOREST AND SPOTTED OWL HABITAT

Table 2.4 of the EA reveals that 228 acres of late-successional habitat will be logged, and then compares this to the total amount of late-successional habitat in the LSR to disclose that a mere 1.5% of the existing late-successional habitat will be removed. However, of the 1,807 acres of late-successional habitat within the Project area, removing 228 acres constitutes nearly 8% reduction of late-successional habitat from the Project area. This is a significant reduction of valuable, late-successional habitat in this special management area. The EA never identified boundaries of the Analysis Area or its relationship to the Project area. The agency is not complying with NEPA when it analyzes environmental effects across a larger geographic area in order to lessen the statistical significance of these effects within the Project area itself. The agency needs to disclose to the public the percentage of late-successional habitat it will impact within the Project area.

Furthermore, the document states that commercial logging in the fuelbreaks and flanks “will help to release the growth potential of these stands allowing for habitat developmentÓ (Biological Input ,AF). Yet, assuming that these fuelbreaks and flanks will be maintained over the next century (a big assumption), then that means these areas will be permanently removed from the closed-canopy, late-successional forest structure that is the management direction for this LSR/CHU. Reducing canopy closure to 30% (fuelbreaks) or 40% (flanks) effectively degrades these stands to become unsuitable for nesting, roosting, or foraging habitat by the spotted owl. Also, the agency has also failed to disclose the extent of planned (but not fully documented) future salvage logging throughout present and future old-growth stands in the LSR. The agency has failed to explain how managing these stands to become permanently unsuitable habitat will result in these stands developing into suitable habitat.

Consultation with USFWS was insufficient because they were led to believe that degradation of suitable habitat would only occur within a 200 foot corridor along the fuelbreaks. In the EA it states that fuelbreaks will Ògenerally average about 250 feetÓ (p.4), indicating that some fuelbreaks above this average will be even wider. Adjacent to these 250 feet fuelbreaks will be the flanks that are Òaround 300 feetÓ in width (p.4). Added together, this means that canopy-closure and suitable habitat for spotted owls will be effected for an average width of 550 feet. In areas like unit 33, however, flank units will be cut on both sides, making this degraded area a minimum of 850 feet (actually, it looks like it may exceed 1,000 feet in width from looking at the map of flank units 32, 38, and 39).

The difference between 200 and 850+ feet is extremely significant for spotted owls and other wildlife dependent on closed-canopy late-successional habitat. Spotted owls, particularly juveniles, will likely be subject to increased predation from great horned owls in these cutover areas. These fuelbreaks and flanks will create fragmentation that, although directly effecting a relatively small portion of the total landscape, has significant indirect effects over a much wider area. The document states without further explanation that “Topographic features, especially ridges...become very important for pairs in the Siskiyou Mountains” (Biological Input, Analysis File). The document needs to disclose why ridges are very important for owl pairs, and what the effects of logging will be on owls. Apparently, not only is it important that the ridges be suitable habitat, but spotted owls may not utilize adjacent suitable habitat stands if the ridgeline fragmentation prevents them from safe passage to get to these stands in the drainages. The indirect effects on spotted owl habitat from fragmentation by the fuelbreaks and flanks need to be disclosed.

The chart located in the Biological Input in the Analysis File is insufficient for disclosure of the effects on owl habitat. As the wildlife biologist notes, “Acres impacted does not mean these acres are being degraded to non-habitat status, it only means that under-burning or harvesting, to some degree, has been prescribed for these acres.” The biologist needs to make distinctions between the two different kinds of activities, logging/slash-burning/road-building vs. underburning, because the former activities degrade owl habitat while the latter activities do not. As the document states, prescribed underburning does not change owl habitat quality (p.26,EA). Thus, the document needs to disclose exactly how many acres will be degraded to unsuitable nesting, roosting, foraging habitat due specifically to logging-related activities. Again, the agency cannot add to the two kinds of activities together as a means of reducing the significance of effects.

As noted in the letter by Mr. Russell D. Peterson of the USFWS, the Forest Service does not have authorization for incidental take of spotted owls in this Project. Therefore, the USFWS needs to be reconsulted in order to inform them of the cumulative effects of habitat degradation by the fuelbreaks and their flanks along the ridgelines. Finally, the EA fails to disclose the indirect and cumulative effects of the fuelbreaks, flanks, and salvage logging on decreased nesting and prey base habitat and increased predation opportunities by great horned owls. A letter by USFWS in the Analysis File does not absolve the agency of its responsibilities to inform the public of environmental effects. The effects of this permanent degradation and removal of suitable spotted owl habitat and late-successional forest for the next century or more needs additional analysis and proper public disclosure.

QUESTIONS:

--What percentage of the late-successional habitat within the Project area will be affected by commercial logging?

--What will be the total width of cutover lands, adding together both fuelbreaks and their adjacent flanks?

--How wide will the cutover area be that comprises units 32, 33, 34, 35, 36, 37, 38, 39?

--Why were adjacent units of the same silvicultural prescription broken up into several smaller units instead of a single large unit? Was the agencyÕs intention to lower the significance of environmental effects?

--Why are ridges important for spotted owl pairs? Will the fuelbreaks and flanks fragment this area, preventing spotted owls from optimum usage of all available suitable habitat inside and adjacent to logging units?

--Why was USFWS given the figure of 200 feet for the fuelbreaks when the EA states that they will average 250 feet? How does the agency explain this discrepancy? How far above this average will the widest fuelbreaks and flanks be?

--What will be the effects on spotted owl nesting, roosting, and foraging habitat in fuelbreaks and flanks? What will be the effects on spotted owl predation in fuelbreaks and flanks?

--How many acres will be degraded to unsuitable habitat status due to logging activities?

--How long will the agency prevent the fuelbreaks and flanks from developing closed-canopy, late-successional habitat suitable for spotted owls? Will these become permanent fixtures in the forest?

ITEM: FAILURE TO DISCLOSE EFFECTS ON BIODIVERSITY

The SYSDYN5 model posits that late-successional habitat and so-called “senescent” stands will vastly increase in acreage, while early to mid-successional vegetation will decrease in acres (p.21). Since the Mt. Ashland LSRA document is not easily or widely available to the public living far away from the Ashland District Office, it is not clear from the EA whether or not this change in the forest landscape is in compliance with the LSRA. Assuming that it is, the agency needs to disclose to the public the effects on biodiversity from reducing acres of early- and mid-successional habitat. As the Forest Service’s own research shows, young natural stands are rapidly disappearing from the landscape, yet they are an important reservoir of biodiversity. Significantly, young natural stands are often the result of wildfire. Implicitly, the agency has declared the Project area to be a Òfire free zone.Ó If so, then the agency has no intention of allowing young natural stands to regenerate and grow within the Project area or the LSR. We fear that the agency is transferring the same monocrop mentality that created plantations of ÒreprodÓ into a monocrop of Òmanaged old-growth.Ó The agency needs to disclose the effects on biodiversity and young natural stands from its plan to prevent wildfires and therefore reduce the amount of early- and mid-successional habitat.

QUESTIONS:

--What will be the effects on biodiversity from a reduction in acreages of early- and mid-successional habitat?

--Are there any young natural stands located within the Project area? What will be the effects on these stands from management activities? Does the agency intend to allow--or prevent--the occurrence of natural fire effects necessary to reproduce young natural stands?

ITEM: FLAWED ANALYSIS OF VALUES AT RISK

The assumption that a large-scale fire would result in a negative impact on recreational opportunities, visual quality, or the tourist economy is not substantiated in the EA, nor supported by evidence from recent large-scale fires. For example, the experience of Yellowstone is very revealing of the economic benefits of wildfires on the ÒtouristÓ economy. Although during the wildfire, total numbers of tourists were down (thanks to newsmedia sensationalism about the “destruction” of Yellowstone), local merchants were making large profits from servicing the huge firefighting army that fought the Yellowstone fires. Many local residents were hired to work in various support services for the suppression incident. The following season, the normal number of tourists came to Yellowstone, many of them with the explicit desire to see the effects of the forest fires. And several oversized books of beautiful photographs of Yellowstone’s burned forest have been published. Fire changes the landscape but it does not ÒdestroyÓ it.

CFEEP has been leading thousands of fellow citizens on educational hikes through recent burns in Oregon, and these “tourists” marvel at the scenic wonders and recreational adventures presented by a burned forest. The assumption that recreation, scenery, or tourism will be negatively impacted by wildfire has no foundation in social science research or recent experience, and the agency needs to provide such evidence to support its assumption. On the other hand, the claim that commercial logging will not effect recreational, scenery, or tourism is preposterous, and lacks face validity. The agency needs to disclose these impacts in a future EIS

QUESTIONS:

--What social science research or economic data can the agency cite that supports the assumption that a future large-scale fire would negatively impact the tourist economy in Ashland?

--What will be the effects on recreation, scenic resources, or the tourist economy from commercial logging in the Project?

ITEM: LACK OF FULL DISCLOSURE OF EFFECTS TO SOIL AND LONG-TERM SITE PRODUCTIVITY

The EA analyzes in depth the kinds of negative effects to soil resources that results from severe wildfire, yet, the documentation simply glosses over in a single sentence the kinds of direct, indirect, and cumulative impacts on soil resources resulting from commercial logging, slash burning, and road building. These effects are not adequately analyzed or fully disclosed. The agency’s assumption that mitigation measures would ensure compliance with Standards and Guidelines for soil protection is not supported by any analysis of the effects or effectiveness of these mitigation measures.

QUESTIONS:

--What will be the effects to soil and site productivity from commercial logging, slash burning, and road-building activities?

--What will be the effects to municipal water quality and aquatic species habitat from soil erosion and siltation resulting from soil displacement activities?

ITEM: LACK OF PROPER DISCLOSURE ABOUT DIRECT, INDIRECT, AND CUMULATIVE ADVERSE ENVIRONMENTAL EFFECTS

The statement that “There are no know adverse environmental effects that would occur as a result of the implementation of this project” (p.35,EA) is utterly preposterous! A statement like that is a Òred flag warningÓ that the agency has not done its work in doing proper analysis and full disclosure of foreseeable direct, indirect, and cumulative environmental effects as a result of commercial logging, slash-burning, and road-building activities. For example, given the reduction of canopy-closure to 30% in the ridgeline fuelbreaks, with tree stems spaced a minimum 60 feet away from each other, the “leave trees” will be subject to increased windthrow after the stand has been so severely thinned. Ridgelines are particularly prone to strong winds and the phenomena of wind shear, which makes trees more susceptible to windthrow. The agency needs to analyze the potential for windthrow to reduce canopy-closure even more, reducing the ability of Òleave treesÓ to produce shade, and the effects of this impact on fire hazard, wildlife habitat, and watershed quality.

QUESTIONS:

--How does the agency define “adverse environmental effects”?

--How and why do stumps, displaced and sterilized soil, degraded wildlife and fish habitat, degraded water quality, and increased presence of exotics NOT constitute adverse environmental effects?

--What will be the potential for increased windthrow along ridgeline fuelbreaks and flanks? What will be the environmental effects of further reduction of canopy shade over time due to windthrow?

CONCLUSION

It is truly disappointing to read through the Hazred Project and see what could have been an excellent project to reduce fire hazard and risk of future stand-replacing fire become simply a smokescreen for another commercial timber sale in an area where this activity is simply unacceptable. Everywhere throughout the National Forest system, official state-sanctioned pyrophobia is being promoted in order to scare the public into supporting timber sales where they don’t belong. The commercial timber sale portion of the Project not only threatens to undermine the stated intention of reducing “catastrophic” wildfire hazard, but also guarantees to further erode the credibility of the Forest Service at this critical juncture in its history. In the wake of the Salvage Rider, the agency should be trying to recover its integrity and restore the public’s trust as a first, and fundamental, step in implementing ÒEcosystem Management.Ó The agency should be attempting to deal with the ÒpastÓ mistakes of logging and firefighting---which are still ongoing. Instead, the agency continues to propose these same failed techniques which significantly and negatively effect forest health, watershed stability, wildlife viability, and ecosystem integrity. In these respects, the Hazred Project is a disappointing preview on the ÒnewÓ management direction for the Mt. Ashland LSR, if not the entire Rogue River National Forest.

The documentation for the Hazred Project is clearly inadequate, and puts the agency at risk from administrative appeals and citizen lawsuits under for failure to comply with NEPA, NMFA, and the ESA. The Cascadia Fire Ecology Education Project is ready and willing to form a partnership with the agency to help it and the general public make the social, cultural, economic, and political changes necessary for us all to live with wild ecosystems and their vital natural processes, including forest fires. The agency missed an important opportunity to begin this process with the Hazred Project. Therefore, CFEEP demands that the agency completely withdraw the Hazred Project, and resubmit to the public documentation addressing the statements and questions above in a full-scale EIS. This forthcoming EIS should, among many other things, disclose the full array of social and ecological values at risk, the positive effects of wildfire, the negative effects of logging with slash-burning and road-building, and it should present a wider range of action alternatives oriented to genuine fire hazard reduction through restoration of natural fire ecology processes.

Sincerely,

Timothy Ingalsbee, Ph.D.

Program Director, CFEEP