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APPENDIX I – RESPONSE TO COMMENTS

I.1Introduction

The SNF provided the Kings River Experimental Watershed Forest Health and Research Project

(DEIS) to interested parties for public comment on December 23, 2010. The Environmental 

Protection Agency published a Notice of Availability (NOA) for the DEIS in the Federal Register 

on the same date. The 45-day comment period ended on February 7, 2011. In response to the SNF

request for comments, 27 interested parties submitted comments. After breaking down each letter 

into the individual comments contained in those letters the SNF determined that 175 unique 

comments needed to be addressed. For tracking purposes, the SNF assigned a letter number1to 

each letter; and, an ID2number for each specific comment.

The Forest Service has documented, analyzed, and responded to the public comments received on 

the DEIS. Appendix I describes the comments received on the DEIS and provides the agency‟s 

response to those comments. In general, the agency responded in the following four basic ways 

to the substantive public comments as prescribed in 40 CFR 1503.4 and responses to Comments, 

of the National Environmental Policy Act (NEPA) regulations.

1. Developing and analyzing alternatives not given serious consideration in the DEIS.

2. Supplementing, improving, or modifying the analysis that the DEIS documented. 

3. Making factual corrections. 

4. Explaining why the comments do not need further Forest Service response.

I.1.1 Content Analysis Process

Forest Service direction requires that Final Environmental Impact Statements (FEIS) respond to 

substantive comments on the draft DEIS (FSH 1909.15, 24.1). Substantive comments are within 

the scope of the Proposed Action; are specific to the Proposed Action; have a direct relationship 

to the Proposed Action; and, include supporting reasons for the Responsible Official to consider 

(36 CFR 215.2). The team reviewed all specific comments and although the FS could choose to 

identify those that do not meet the substantive test, the Forest chose to respond to them all.

The SNF documented, analyzed, and summarized public comments using a process called content 

analysis. This is a systematic method of compiling and categorizing the full range of public 

viewpoints and concerns regarding a plan or project. Content analysis ensures that every 

comment is considered. Content analysis is intended to facilitate good decision-making by 

helping the IDT to clarify, adjust, or incorporate technical information into the FEIS. The process 

facilitates the Forest‟s response to comments. 

In the content analysis process, each letter receives a unique identifying number. All letters were 

analyzed and each comment was categorized by specific topics or concerns. These categorized 

comments were then given a unique number, which allows analysts to link specific comments 

back to the original letter. The comments were then entered into a table. 

Comments on the DEIS raised concerns and issues regarding the topics described below 

(categorized by chapters in the FEIS):

 

1

For example, the first comment letter received is designated letter “1”.

2

Each comment identified in a given letter was given a sequential number beginning with “1”.
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Chapter 1:The Purpose and Need for Action

o Purpose and Need

Chapter 2: Alternatives including the Proposed Action

o Adequacy and Range of Alternatives

o Support of Alternative 5

Chapter 3: Affected Environment and Environmental Consequences

o Air Quality

o Fire and Fuels

o Botanical Resources

o Economics

o Aquatic Biota

o Research

o Terrestrial Wildlife

o Soils

o Vegetation and Silviculture

Additional Comments

o Adequacy of Data and Analysis

o Technical and Editorial Accuracy

The IDT reviewed and responded to comments as categorized in the table. Comments were 

responded to individually.

I.2 Comments and Responses, Table of Contents

Chapter 1: The Purpose and Need for Action...................................................3

Purpose and Need ............................................................................................3

Chapter 2: Alternatives including the Proposed Action..................................6

Adequacy and Range of Alternatives ................................................................6

Support of Alternative 5...................................................................................10

Chapter 3: Affected Environment and Environmental Consequences ........13

Air Quality........................................................................................................13

Fire and Fuels .................................................................................................15

Botanical Resources .......................................................................................17

Economics.......................................................................................................17

Aquatic Biota ...................................................................................................21

Research.........................................................................................................28

Terrestrial Wildlife............................................................................................39

Soils ................................................................................................................53

Vegetation and Silviculture..............................................................................53

Additional Comments.......................................................................................60

Adequacy of Data and Analysis.......................................................................60

Technical and Editorial Accuracy ....................................................................67
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Chapter 1: The Purpose and Need for Action

Purpose and Need

PN-1. The Purpose and Need for Action (pp. 1-10 to 1-11) does not include timber harvest, 

but as you know, all the Action Alternatives in Chapter 2 include timber harvest. And the 

Economics Section (3-5) in Chapter 3 makes it clear that KREW is dependent on timber 

harvest and commercial sale (at low prices) of that timber. So, cheap timber sale may be 

driving this project and not just forest health and research. [Comment Number: 2-16]

Response: The SNF accurately reflects the need in Section 1.4 of the DEIS for forest resilience to 

reduce the effects of uncharacteristic wildfire, drought, invasive species and insect attacks. This 

is done through reduction in stand density to increase tree vigor. Reduction in stand density 

results in timber removal and to be good stewards of the public‟s money the SNF obtains revenue 

where it can to offset its goals of ecological restoration. As Section 3-5 shows all alternatives 

result in the SNF spending federal funding. The SNF is meeting its mission of ecological 

restoration of the forest using timber sales as one of the many tools to achieve this objective.

PN-2. The resiliency and sustainability of an ecosystem is defined by a variety of attributes, 

including the health and persistence of rare species. The actions proposed in the DEIS fail 

adequately to minimize impacts to fisher and Yosemite toad. This failure jeopardizes their 

persistence in the project area. This outcome is contrary to the stated purpose and need to 

create a more sustainable landscape and Forest Service direction to conserve species at risk.

[Comment Number: 3-6]

Response: The aquatic biological assessment/evaluation for the KREW project discloses that 

direct effects (mortality) to Yosemite toad could occur as a result of proposed activities. Given 

the isolation of the occupied meadows within the project area from the nearest known sites, it also 

appears re-colonization would be unlikely in the event that the apparent meta-population 

represented by the project area were extirpated. A variety of conservation measures (buffers and 

limiting operating periods) for the species have been considered and rejected due to inability to 

collect data meaningful to address research questions from treatments within the remaining 

portions of the KREW Bull watershed. The Yosemite toad limited operating period adopted for 

the project excludes project activities in the KREW Bull watershed between 5/1 and 7/15 and 

provides an element of protection for breeding, rearing, and post-breeding movement by adults to 

foraging sites. However, adult toads in foraging remain susceptible to project activities if the 

foraging site is within a treatment area.

As described in the aquatic biological assessment/evaluation for the KREW project, most of the 

indirect effects to Yosemite toad would be related to habitat alteration. Thinning is proposed 

within the red fir, Sierra mixed-conifer, and ponderosa pine vegetation types, based on the 

California Wildlife Habitat Relationship (CWHR) model. The primary changes reduce size group 

5 to size group 4 and reduce density over a 20-30 year period. CWHR habitat quality from the 

proposed treatments would generally remain unchanged for Yosemite toad. However, a reduction 

in stand density for smaller diameter lodgepole pine would improve the habitat quality based on 

CWHR. Overall the CWHR quality of Yosemite toad habitat remains unchanged (maintained) 

following the proposed treatments. 

The KREW Project analysis shows that for Yosemite toad and fisher the effects of the project are 

“may affect individuals but is not likely to lead to federal listing or loss of viability.” See DEIS 

Table 2-12 (which is Table 2-16 in the FEIS) which is supported by the analysis in Chapter 3-7 

and Chapter 3-9. The SNF believes that by enhancing the resilience of the forest and adding fire 

back into the ecosystem, habitat for sensitive species will be enhanced as factors potentially 
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Sierra National Forest 4

degrading habitat such as high tree density related drought related stresses, effects of 

uncharacteristic wildfire, invasive species and insect attack are diminished. Additionally more 

specific scientific knowledge on the effects of forest treatments will allow the forest to tailor 

future forest treatments based on scientific data rather than projections and professional 

judgment. As the effects of the project do not result in federal listing and loss of viability of the 

species and important habitat and critical knowledge enhancement will occur, the SNF believes 

that the project comports with the purpose and need for the project. 

PN-3. The purpose and need also calls attention to public health and safety. However, the 

Bull unit where about half of the thinning treatments are proposed does not occur near to 

communities and is outside of the wildland urban interface. Current conditions in the Bull 

unit are predicted to be dominated by surface and passive fires under severe (97th 

percentile) fire weather conditions (DEIS, p. 3.2-20; Fuels Report, p. 10). The remoteness 

from human communities and the current condition of the landscape do not reflect an 

urgent need to log the Bull unit. [Comment Number: 3-8] 

Response: A purpose of KREW is the urgent need for ecological restoration in the headwaters in 

the Kings River watershed to improve forest health and reduce the risk of severe fire as stated in 

Chapter 1 in Section 1.4. Though it is true that there is no WUI in the Bull unit, there is the 

need to address stand densities, forest health and the increasing risk of severe wildfire. The Forest 

Service recognizes the need for community protection but it also recognizes the need for restoring 

forest health at the landscape level. 

These trees may be removed for other reasons, including: (1) reducing canopy bulk density to 

reduce crown fire spread (Stephens and Moghaddas 2005, Safford et al. 2009) in stands treated 

for public and firefighter safety, (2) decreasing intermediate-sized ladder fuels that have 

continuous fuels to the ground (North et al. 2009), (3) increasing the growth and reducing 

drought-stress to large-diameter pines and oaks by removing shade-tolerant competitors, (4) 

decreasing tree densities on the middle to upper slope topographic positions to facilitate 

heterogeneity across the forested landscape (North et al. 2010), (5) reducing operational hazard, 

(6) increasing stand heterogeneity and enhancing regeneration of shade-intolerant pines and oaks 

through the creation of tree gaps or increase in size of existing small-sized gaps (Bonnicksen and 

Stone 1982), (7) increasing long-term carbon sequestration by increasing growth rates of largediameter fire-resilient trees (North et al. 2009, Hurteau and North 2010), and (8) reducing stand 

densities to promote tree growth and forest stands that are resilient to fire, insect outbreaks, and 

future climate change.

There is ample evidence that fuel and forest restoration treatments will be effective at reducing 

fuel loads, fire severity, and crown fire risk when surface fuels are treated in concert with ladder 

fuels, which includes the removal of select trees between 12” and 30” dbh (e.g., Hurteau and 

North 2008, Stephens et al. 2009, North et al 2009). There is also sufficient scientific support for 

fuel treatment effectiveness in mitigating the negative impacts of wildfire (e.g., Skinner et al. 

2004, Safford et al. 2009). However, it should be noted that there is very little scientific support 

for removing trees >30 inches in diameter for the purposes of reducing fire risk or achieving 

ecological restoration objectives.

Additionally, several pages of text have been added to Section 3.8.2 to improve the readers‟ 

understanding of the KREW design with regard to consistency between the Providence and Bull 

Units. For example, thinning treatments at the Providence and Bull Units have to be as similar as 

possible for watersheds at the two Units to serve as replicates (an important part of the study 

design), thus fuels treatments in the Bull Unit which is not in WUI cannot be burned differently 

that in Providence.
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Sierra National Forest 5 4/7/2011

PN-4. The need to conduct research is also identified as a purpose. The need is defined in 

terms of understanding the effect of management practices on headwater streams. 

Fundamentally, there is nothing in the study design that requires activities of a specific level 

of disturbance be examined. Activities that result in less disturbance, yet still meet project 

objectives are legitimate treatments to study. Information from such a study would be of 

direct benefit in areas like the Providence unit where there are apparent conflicts among 

fisher management and meeting other objectives. [Comment Number 3-9:]

Response: We regret that the document was not clear enough about why the proposed alternative 

is necessary to meet the complete purpose of KREW; however, the complete KREW Research 

Study Plan is available on the PSW web site as a PDF and was incorporated by reference in 

Section 1.4 of the DEIS. Several pages of text have been added to Section 3-8.2 to improve the 

readers‟ understanding of the KREW design with regard to a “specific level of disturbance” and 

consistency between the Providence and Bull Units. For example, thinning treatments at the 

Providence and Bull Units have to be as similar as possible for watersheds at the two Units to 

serve as replicates (an important part of the study design), thus thinning in Providence where 

fisher occur cannot have “less disturbance” than in Bull. Many scientists and organizations (e.g., 

Sierra Nevada Adaptive Management Project, California Regional Water Quality Control Board, 

California Department of Forestry and Fire Protection, Dr. L. MacDonald of the Colorado State 

University, Dr. S. Cooper of UC Santa Barbara) believe the proposed alternative is necessary to 

achieve KREW‟s science potential.

PN-5. Based on the change in focus of the purpose and need in the DEIS, the references to 

pre-1850 forest conditions should be removed from the Table 2-12. Elsewhere in Table 2-12 

are attributes that appropriately evaluate the degree to which the alternatives address the 

purpose and need, stated in Chapter 1, to ―Restore resilient forest structure: increase 

resilience, reduce tree densities to increase tree vigor.‖ [Comment Number: 3-17]

Response: The SNF is unaware of a “change of focus” for this project‟s purpose and need. The 

purpose and need has remained consistent since the publication of the NOI. The reference to pre1850 forest conditions was reevaluated. The SNF agrees that addressing pre-1850 forest 

conditions in DEIS Table 2-12 is not useful and this has been removed from the FEIS and is no 

longer in FEIS Table 2-16 which replaced DEIS Table 2-12.

The SNF appreciates the commenter‟s support for the component of the purpose and need to

“restore resilient forest structure: increase resilience, reduce tree densities to increase tree vigor.” 

Keep in mind that restoring a resilient forest structure is one component of three in the purpose 

and need. This Project also is needed to protect public health and safety by reducing fire and 

fuels and obtaining needed knowledge of the effects of forest treatments. 

PN-6. We ask that Table 2-12 be revised to reflect the contribution that Alternative 3 could 

make to improve our understanding about the response of headwater systems to 

management. [Comment Number: 3-18]

Response: Text has been added to FEIS Table 2-16 which replaced DEIS Table 2-12. 

PN-7. Forest resilience is an appropriate and necessary objective for the KREW project 

area stands, and stand density must be reduced to prevent loss of the large trees from insect 

epidemics as described in the purpose and need for the projects. [Comment Number: 13-5]

Response: The SNF agrees that it is imperative to reduce stand density in the KREW Project area 

to ensure resilience and prevent tree loss.

PN-8. The adverse effect of white pine blister rust, which is killing white pines including 

sugar pine, in the Sierra Mountains must be considered, and a strategy developed to 
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Sierra National Forest 6

perpetuate this premier species of the Sierras. Catastrophic fire will kill the large 

remaining sugar pines that may carry the resistant gene while the use of prescribed fire 

without protection for young sugar pine will eliminate it from the stands faster than would 

otherwise occur. The best hope for perpetuating sugar pine seems to be planting of blister 

rust resistant seedlings, which requires active management and site preparation, which 

should be explained in the final Decision Notice. [Comment Number: 13-6]

Response: In Chapter 2 description of Alternative 2 Section 2.3.2.2 and echoed for Alternative 4 

& 5 discussing reforestation, the DEIS specifies that “rust resistant sugar pine will be planted if 

rust resistant planting stock is available from the Tree Improvement Program.” The decisionmaker will determine what aspects of the alternatives are included in the final decision. The 

HSRD has a sugar pine retention strategy to conserve and promote sugar pine. The strategy 

involves: a) collection and testing of seed from blister rust resistant candidate trees, b) retaining 

sugar pine free of blister rust within treatment units, c) planting rust resistant sugar pine in areas 

suited for sugar pine growth, d) improving the health and vigor of sugar pine through thinning, e) 

protecting and improving the vigor and health of proven rust resistant seed trees.

PN-9. A human/social effect of the no action alternative should be noted. If no 

merchantable timber is harvested as a result of this project (and cumulatively other 

projects on the Sierra NF), the one remaining sawmill at the southern end of the Sierra 

Nevada range in Terra Bella, CA will likely close. The sawmill in Standard, CA, is 

currently being renovated at significant expense, based on the prediction of a stable 

province wide supply of timber. Although timber from the KREW project may not be 

hauled to the Standard mill, it will contribute to the total regional timber supply. In 

addition to the direct loss of local employment and tax base, the Sierra NF would experience 

significantly higher costs for future fuel treatment projects; many would become totally 

uneconomical. Environmentally, any timber not harvested on the Sierra NF would have to 

be replaced by timber products imported from other areas of the world since California 

and the United States already import most of the timber we use. Environmental controls in 

most of these source regions are much less rigorous than in the Proposed Action.

[Comment Number: 13-8]

Response: Information has been added to the Economic Section 3-5 in Chapter 3 discussing local 

sawmills and economics related to this infrastructure. 

Chapter 2: Alternatives including the Proposed Action

Adequacy and Range of Alternatives

ARA-1. We suggest that methods other than logging should be used to achieve the final goal 

of restoring the forest. Introduce fire at the beginning. It seems your ultimate goal is to 

restore fire to the landscape. Why wait? Begin right away. The nearby National Parks 

utilize prescribed burning in forest areas and up to within 200 feet of structures to achieve 

the same fuels reduction and forest restoration goals very economically and very safely. The 

National Parks do not rely on logging in 1⁄4 mile defense zones and 1 1⁄4 mile threat zones. 

National Park management is the sort suggested in the work of Jack Cohen at the U.S. 

Forest Service Fire Lab in Missoula Montana. Yet you fail to consider his work in the DEIS. 

We should say ―still fail‖ since we have time and again recommended that Cohen be 

considered in project design. [Comment Number: 2-2]

Response: Jack Cohen has written several papers on home ignitability and the need to address 

residential structure survivability. The home ignition zone and preventing home ignition falls 

within the responsibility of the private property owner. In his 2008 paper, Cohen states that “the 
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Forest Service‟s primary responsibility and objective for structure fire protection is to suppress 

wildfire before it reaches structures. These findings are consistent with Forest Service Manual 

direction, section 5137”. In addition, in a 1996 paper, Cohen and Butler found that thinning trees 

to produce gaps in the flame front significantly reduces radiant exposure, and that a firefighter‟s 

maximum radiant exposure is well below exposures necessary for piloted wood ignitions. They 

also found that defensible space requires more vegetation fuel hazard reduction than fuels 

reductions required for preventing piloted wood ignitions. Refer to FEIS Section 3-2.3.3 on page 

3.2-12. 

In your comments you ask “why wait”, as shown in DEIS Table 3.2-7. The HSRD Understory 

Burn Program described on pages 3.2-29 though 31 shows the prescribed fire program that is 

already underway on the district. The 20,000 acre burn program has been in effect since 1994 and 

applies fire to treated and natural stands for the direct purpose on reducing fuel loading and ladder 

fuels. 

Cohen, J.D., B.W. Butler. (1998). Modeling potential ignitions from flame radiation exposure 

with implications for wildland/urban interface fire management. In: Proceedings of the 13th

conference on fire and forest meteorology, vol. 1. 1996. October 27-31; Lorne, Victoria, 

Australia. Fairfield, WA: International Association of Wildland Fire; 81-86.

Cohen, Jack, 2008. The wildland-urban interface fire problem: a consequence of the fire 

exclusion paradigm. Forest History Today. Fall 2008.

ARA-2. In the Summary it is revealed there is no Action Alternative based on fire use 

rather than commercial logging. [Comment Number: 2-7]

Response: Alternative 3 is the Fuels Reduction Only Alternative. The summary does explain that 

for this alternative “as part of the emphasis on fuels reduction, the defense zone thin would 

remove trees up to 20 inches dbh.”

ARA-3. On p. 1-15 in reference to a court order (Judge England) that the Forest Service 

―Include a detailed consideration of project alternatives, including a non-commercial 

funding alternative, for all new fuel reduction projects....‖, the Regional Forester seems to 

be dodging that requirement and then promoting Alternative 3 with logging, with a 

stumpage value of only $22,546 as shown in Table 3-5-1 on p. 3.5-8. We believe Judge 

England intended that there be a totally non-commercial alternative for projects with fuels 

reduction. With that in mind, we suggest that a fire use alternative with no commercial 

component and no logging activity is required. [Comment Number: 2-17]

Response: Alternative 3 is the Noncommercial Funding Alternative as stated in Section 2.3.3.1 p. 

2-43 of the DEIS. This alternative “focuses on reducing fire hazard to meet fuels objectives” as 

stated in Section 2.3.3 p. 2-43. The FS‟s policy related to the England Noncommercial Funding 

Alternative titled R5 Guidance on Meeting Judge England’s November 4, 2009 Order to Include 

a Noncommercial Funding Alternative at the Project Level for Sierra Nevada Framework Forests 

Fuel Reduction Projects states that “A noncommercial funding alternative is an alternative where 

the sole purpose is to achieve the fuels reduction element of the purpose and need and where all 

the proposed treatments are solely directed at reducing hazardous fuels. The noncommercial 

funding alternative must be considered and analyzed in detail.

In a noncommercial funding alternative, there can be NO additional timber harvesting added 

beyond that needed to meet the fuel reduction purpose and need. It is not permissible to add 

in additional timber harvest for the purpose of increasing economic returns beyond any harvesting 

appropriate solely to meet the fuel reduction purpose and need.” Emphasis added. The policy 

states that timber harvest can be a component of the Noncommercial Funded Alternative, as

Alternative 3 includes, as long as there is no harvest beyond that needed to meet the fuel 
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Sierra National Forest 8

reduction purpose and need. This is the case with Alternative 3. Thinning is limited to trees that 

are needed to be removed to meet fuels objectives only and therefore Alternative 3 is 

appropriately designated as the Noncommercial Funding Alternative.

The commenter proposes a fire use alternative with no commercial component and no logging 

activity. This alternative was addressed in the FEIS in Section 2.4 Alternatives Considered but 

Eliminated from Detailed Study as it does not meet the needs of forest health and resiliency, 

research and only partially meets the need for fuels reduction. This alternative is outside the 

scope of the purpose and need.

ARA-4. Paragraph 3 on p. 2-43 states that Alternative 3 does not meet all the purpose and 

need. We submit that Alternative 3 thus should not exist. We do believe that a fire use 

alternative with no logging can be written that would meet the purpose and need.

[Comment Number: 2-23]

Response: The commenter states that as Alternative 3 does not fully meet the purpose and need it 

should not be included in the EIS. To generate a reasonable range of alternative a different 

emphasis is placed on meeting aspects of the purpose and need. CFR 220.5(e) states that: “The 

EIS shall document the examination of reasonable alternatives to the Proposed Action. An 

alternative should meet the purpose and need and address one or more significant issues related to 

the Proposed Action. Since an alternative may be developed to address more than one significant 

issue, no specific number of alternatives is required or prescribed.” In this case there are three 

needs being met by the alternatives: forest resilience, public health and safety/fuels reduction and 

research. The range of alternatives in the EIS emphasize one or the other of these needs at the 

extreme ends of the range while still somewhat meeting the other stated needs and include an 

alternative that can meet all the needs. All of the needs must be met for an alternative to be part 

of the DEIS and ultimate FEIS however the relative degree to which an alternative meets these 

three components can vary. The Fire and Fuels need is met equally across all alternatives;

however, treating below the level described in the DEIS, which has been suggested by 

commenters, does not fully meet the Fire and Fuels need and meets only a small increment of the 

forest resiliency need while not meeting the research need (see Section 3.8). (See Section 2.4 of 

the FEIS for a more complete explanation for why an alternative that does not fully meet the Fire 

and Fuels objective was not analyzed in detail.) Alternative 3 was designed to range on the 

outskirts of meeting the forest resiliency need and the need for knowledge while fully meeting the 

need for Fire and Fuels reduction and public health and safety. Alternative 3 is the 

Noncommercial Funding Alternative and is required by Court Order to be included in all analyses 

for which fire and fuels reduction is a need whether or not it meets the purpose and need. 

ARA-5. On page 3.5-1, paragraph 2, the DEIS proclaims that ―economics will not be an 

overriding consideration for selection of any alternative for the KREW Project. Instead, 

alternative selection will be based on the alternative that best accomplishes the purpose and 

need of the project.‖ But economics seems to have been the reason for elimination of any 

totally non-commercial logging alternative. [Comment Number: 2-32]

Response: Section 2.4.2 is in error and has been deleted in the FEIS as stated in response to ARA3 [Comment Number: 2-17], Alternative 3 fully meets the requirements for the Noncommercial 

Funding Alternative.

ARA-6. On its face the DEIS fails to fully consider a reasonable range of alternatives 

because it does not fully consider any alternatives that do not violate the forest plan’s 

protections for imperiled wildlife species. The DEIS must fully analyze an alternative that 

would fully comply with these forest plan requirements, and must provide all of the analysis 

and outputs with regard to effects of this alternative with regard to stand structure and 
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wildland fire, and insect mortality, so that it can be directly compared to the other 

alternatives. [Comment Number: 4-1]

Response: The commenter expresses concern that since all the alternatives include plan 

amendments a reasonable range of alternatives was not included in the DEIS. 40 CFR 220.5(e) 

states that: “The EIS shall document the examination of reasonable alternatives to the Proposed 

Action. An alternative should meet the purpose and need and address one or more significant 

issues related to the Proposed Action. Since an alternative may be developed to address more 

than on significant issue, no specific number of alternatives is required or prescribed.” The plan 

amendments were added to every alternative to allow the research to occur. Without the plan 

amendments (1) the treatments on the land would not be able to be completed in one season so 

that measurement of research outcomes would be rendered useless, and (2) the areas allowed for 

treatment in the research areas would be diminished significantly as the riparian zone, a critical 

area for research findings would be precluded, and in the case of the fisher den site buffers and 

the goshawk nesting buffers, the research area itself would be diminished below a threshold of 

research significance. Although LOPs were changed, the changes were minimized to the extent 

possible ranging from 75 days or less in length at the end of the LOP. A great deal of discussion 

and consideration was given to the reduction in time of these LOPs to strike a balance between 

protection of the species and the ability to accomplish the research goals. The plan amendments 

relating to denning and nesting buffers are only in the research areas and the plan amendments 

only last through the research implementation period (less than 5 years). The entire project 

effects analysis covers 30 years. The SNF took a very careful and considered look at the plan 

amendments and determined that to meet the research purpose and need the plan amendments 

were necessary in every alternative. Without these plan amendments the research aspect of the 

purpose and need cannot be met and therefore an alternative that does not include these plan 

amendments does not meet the test of a “reasonable alternative” as defined in 40 CFR 220.5 (e).

This alternative was addressed in the FEIS in Section 2.4 Alternatives Considered but Eliminated 

from Detailed Study as it does not meet the needs of forest health and resiliency, research and 

fuels reduction. This alternative is outside the scope of the purpose and need.

ARA-7. Though the DEIS initially describes a purpose and need that is clearly broad 

enough to allow full consideration of action alternatives that would comply with these forest 

plan requirements for wildlife (DEIS, pp. 1-10 through 1-11), the DEIS then violates 

NEPA’s requirement to fully consider a reasonable range of alternatives by refusing to fully 

consider alternatives that do not meet the strict basal area and stand density reduction 

targets of the Kings River ―research plan‖, referenced on p. 1-10 of the DEIS, thus 

arbitrarily and illegally narrowing the purpose and need. [Comment Number: 4-2]

Response: The commenter expresses concern that the research plan identified in the purpose and 

need section “arbitrarily and illegally” narrows the purpose and need. 40 CFR 1502.13 states 

...”The statement shall briefly specify the underlying purpose and need to which the agency is 

responding in proposing the alternative including the Proposed Action.” The research aspect of 

the purpose and need described in the DEIS (pp. 1-10 and 11) is to “understand the impacts of 

these forest restoration treatments on the environment.” A research plan was developed and 

referenced; however, the DEIS analyzes a range of treatment options including treating to 

differing tree dbhs and treating in riparian areas differently. Research in order to achieve 

scientific results does constrain the alternatives; however, there is still variability in treatment 

options and these were explored in the DEIS. Differences in tree stand density and basal area 

(“Stem area of trees”) can be found in FEIS Table 2-16 (which replaced DEIS Table 2-12). 

Although, the research aspect of the purpose and need constrains the alternatives, there is 

remaining variability that allows differing stand density and basal areas across the alternatives. 

The SNF‟s choice of purpose and need was not arbitrary or illegal. The range of alternatives 
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Sierra National Forest 10

incorporates both uneven-aged strategies (Alternative 2), even-aged strategies (alternative 3) 

multi-aged strategies (Alternative 4) and combinations of these treatment strategies (Proposed 

Action). Each of these alternatives varies basal area retention and canopy cover retention 

guidelines. Pages 2-36, 2-37, 2-49, and 2-50 of the DEIS detail the basal area and canopy cover 

retention guidelines.

ARA-8. In addition, the DEIS (p. 2-60) refuses to fully consider a non-commercial thinning 

alternative—i.e. one that would only remove very small trees (less than 10 inches dbh), 

vaguely claiming that such an alternative was deemed to be ―impractical, expensive, and 

financially risky to be implemented‖. However, because the DEIS refuses to fully analyze 

this small-tree thinning alternative, the DEIS fails to provide any basis to support this 

statement. Moreover, the DEIS’s refusal to analyze a non-commercial thinning alternative 

violates the order by Judge England that such an alternative must be fully analyzed so that 

public can judge on its own the relative merits of such an alternative. This is especially 

unacceptable, given the information discussed below showing that intensity of wildland fire 

can be very effectively reduced with a 10‖ dbh limit, and also that insect mortality of stands 

at or around the density of the current KREW stands, in terms of basal area, is LOWER 

than the basal area mortality that would result from a 10‖ dbh limit, which means that a 

small-tree thinning alternative would meet the stated purpose and need of preventing and 

reducing stand mortality (DEIS, p. 1-10) better than the Proposed Action or the other 

action alternatives considered in the DEIS. [Comment Number: 4-3]

Response: Page 2-60 of the DEIS was in error and the FEIS reflects deletion of this section. 

Alternative 3 is the non-commercial funding alternative as specified in the DEIS Section 2.3.3.1 

p. 2-43. This alternative “focuses on reducing fire hazard to meet fuels objectives” as stated in 

Section 2.3.3 p. 2-43. The FS‟s policy related to the England Noncommercial Funding 

Alternative titled R5 Guidance on Meeting Judge England’s November 4, 2009 Order to Include 

a Noncommercial Funding Alternative at the Project Level for Sierra Nevada Framework Forests 

Fuel Reduction Projects states that “A noncommercial funding alternative is an alternative where 

the sole purpose is to achieve the fuels reduction element of the purpose and need and where all 

the proposed treatments are solely directed at reducing hazardous fuels. The noncommercial 

funding alternative must be considered and analyzed in detail.” There are no tree diameter limits 

specifies in this policy. The SNF has determined that to meet the fire and fuels objectives of the 

Project that treatments described under Alternative 3 (tree removal up to 20 inches) is necessary. 

Several stands within the project are overly dense in the 11-20 inch diameter class (refer to the 

FEIS Table 3.11-2 :Tree basal area by species for each stand and Section 3-11.3.7 Forest 

Structure – Stand Density and Canopy Cover) and are at risk to passive and active crown fire. 

Currently 65 percent of the project area is at risk for sustaining high to moderate fire severity –

tree damage; over the next 30 years this increases to 90 percent of the project area. Thinning to 

20 inches dbh to reduce fire hazard under Alternative 3 would occur in six stands within the 

KREW Project: four stands in the Providence unit and 2 stands in Bull unit. As shown in Table 

3.11-4: Tree numbers for each alternative across all project areas only 28000 trees in the 11-

20” dbh class would be removed across the 3057 acre project area under Alternative 3, this 

averages 9 trees per acre. Please see responses to PN-3 [Comment Number: 3-8] and FF-4 

[Comment Number: 4-14] for further explanation. 

Support of Alternative 5

SA-1. The California Forestry Association supports Alternative 5 – The Proposed Action.

[Comment Number: 1-1]
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 11 4/7/2011

Response: Thank you for your support. The decision-maker will consider your opinion while 

making his decision.

SA-2. I write to you as a California Registered Professional Forester (RPF) and the 

Hydrologist for the Southern Sierra Critical Zone Observatory (SSCZO) in full support of 

the implementation of the tree thinning and prescribed fire treatments for KREW in 2011, 

as described in alternative 5 of the draft Environmental Impact Statement: Kings River 

Experimental Watershed Forest Health and Research Project. [Comment Number: 7-1]

Response: We thank Mr. Meadows, hydrologist for the SSCZO and registered professional 

forester, for his support of Alternative 5.

SA-3. My only comment would be an endorsement of the Proposed Action – Hybrid Forest 

Health – Alternative #5. Additionally, I would propose that the field work associated with 

the project be implemented with all speed and the contract for the work be advertised as 

soon as possible. [Comment Number: 8-2]

Response: We thank Mr. Molen for his support of the Proposed Action, Alternative 5.

SA-4. I write in support of implementation of tree thinning and prescribed fire treatments 

in 2011, as described in Alternative 5 of the draft EIS ―Kings River Experimental 

Watershed Forest Health and Research Project.‖ By implementing the proposed 

treatments, the Forest Service would push forward much needed research that has been 

brought to the brink of implementation under the careful watch of Dr. Carolyn Hunsaker 

and her Kings River Experimental Watershed (KREW) team. [Comment Number: 9-1]

Response: We thank Dr. Riebe, part of the SSCZO, for his endorsement of Alternative 5.

SA-5. I support the implementation of the tree thinning and prescribed fire treatments for 

the Kings River Experimental Watersheds (KREW) in 2011, as designed by Dr. Carolyn 

Hunsaker, and described in alternative 5 of the draft EIS, ―Kings River Experimental 

Watershed Forest Health and Research Project.‖ [Comment Number: 11-1]

Response: We thank Mr. Smith, UC Merced, for his support of Alternative 5.

SA-6. By carrying out the mechanical thinning and prescribed fire treatments described in 

alternative 5 of the draft Environmental Impact Statement (EIS) ―Kings River 

Experimental Watershed Forest Health and Research Project‖, the information necessary 

to design broader Kings River and Sierra Nevada management actions will become 

available to the U.S. Forest Service and to other stakeholders. The research at KREW is 

unique in its design and addresses positive, negative, or neutral effects from forestrestoration activities, generating information that will be used by state, private and federal 

land managers in coming decades as they address ever-more daunting challenges of forest 

adaptive management in the Sierra Nevada. [Comment Number: 12-2]

Response: We appreciate Dr. Guo‟s support of Alternative 5 and how it supports the unique 

KREW design to address adaptive management.

SA-7. I, along with foresters from AFRC member companies, reviewed the KREW Project 

in the field several times over the past five years and our member foresters have 

participated in developing the Proposed Actions in the current NEPA analysis. We have 

reviewed the Proposed Actions as given in the environmental documents and on the Sierra 

NF web site.

We strongly support implementation of the Proposed Actions for the KREW Project 

because they best meet the purpose and need for the projects. [Comment Number: 13-1]
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 12

Response: We thank the American Forest Resource Council for being informed about the KREW 

Project over the years and its support of Alternative 5.

SA-8. As a professor and researcher from the University of California Merced, I support 

the treatment activities as outlined in alternative 5 of the draft EIS, Kings River 

Experimental Watershed Forest Health and Research Project. [Comment Number: 16-1]

Response: We thank Dr. Bales, lead scientist for the SSCZO, for his support of Alternative 5.

SA-9. The California Department of Forestry and Fire Projection (CAL FIRE) strongly 

supports the implementation phase of the Kings River Experimental Watersheds (KREW) 

project in 2011, as designed by Dr. Carolyn Hunsaker, and described in Alternative 5 of the 

Draft EIS, ―Kings River Experimental Watershed Forest Health and Research Project.‖ 

We believe there is a definite need for this type of watershed study to be conducted in the 

Sierra Nevada...

....In conclusion, let me reiterate that CAL FIRE very strongly supports moving forward 

with the implementation phase of Dr. Hunsaker’s KREW project without further delays.

[Comment Number: 18-1]

Response: We thank the California Department of Forestry and Fire Protection‟s (CAL FIRE) for 

their support for the implementation of Alternative 5 without further delays.

SA-10. The purpose of this letter is to strongly support the implementation of the proposed 

thinning and prescribed fire treatments in the Kings River Experimental Watersheds 

(alternative 5 of the draft EIS). ... In summary, the proposed treatments are a ―real-world‖ 

example of the types of treatments that are likely to be implemented on public lands in the 

future, and there is a severe lack of data on the effects of such treatments in the Sierra 

Nevada. The risk of adverse effects on runoff and erosion are nearly zero, while the 

potential scientific return from conducting these treatments is very high. For this reason I 

strongly advocate the adoption of alternative 5 in the draft EIS. [Comment Number: 21-1]

Response: We thank Dr. MacDonald, Colorado State University, for his support of Alternative 5 

and the need for data on such forest treatments.

SA-11. We are glad to see that much thought has gone into your proposal and recommend 

Alternative 5 from the document. [Comment Number: 22-1]

Response: We thank the Society of American Foresters, High Sierra Chapter, for supporting 

Alternative 5.

SA-12. Sierra Forest Products supports Alternative 5 – the Proposed Action. This 

alternative best reduces the threat of catastrophic fire, restores forest health while 

providing for research opportunities. [Comment Number: 23-1]

Response: We thank Sierra Forest Products for their support of Alternative 5 for both forest 

health and research opportunities.

SA-13. I support the implementation of the tree thinning and prescribed fire treatments for 

the Kings River Experimental Watersheds (KREW) in 2011, as designed by Dr. Carolyn 

Hunsaker, and described in alternative 5 of the draft EIS, ―Kings River Experimental 

Watershed Forest Health and Research Project.‖ [Comment Number: 25-1]

Response: We acknowledge that Revive the San Joaquin supports the implementation of 

Alternative 5.

SA-14. I am writing to express support for the 2011 implementation of the tree thinning 

and prescribed fire treatments for the Kings River Experimental Watersheds (KREW) 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 13 4/7/2011

research project. These treatments, as designed by Dr. Carolyn Hunsaker, and fully 

described in alternative 5 of the draft EIS, ―Kings River Experimental Watershed Forest 

Health and Research Project‖ are a critical step to examine the impacts of current forest 

management practices in the Sierra Nevada. [Comment Number: 26-1]

Response: We thank Ms. Stacy, UC Merced, for her support of Alternative 5.

Chapter 3: Affected Environment and Environmental 

Consequences

Air Quality

AQ-1. Why is there no GHG emissions analysis? [Comment Number: 1-5]

Response: An analysis of Greenhouse Gas emissions has been added to the Air Quality section of 

Chapter 3, in Section 3.1. 

AQ-2. The discussion of air quality should include the adverse effects on air quality of 

substituting and transporting forest products long distances into California if those 

products are not produced locally in California. Since the Sierra NF is located closer to 

major population centers than other forest product exporting areas, the environmental cost 

of transporting these products is less. 

Given the fact that forest products will be produced in other parts of the state and world 

and substituted for the wood products not produced on the Sierra NF, the same emissions 

from logging activities will be released into the atmosphere even if no logging is done on the 

Sierra NF. [Comment Number: 13-7]

Response: The Forest Service recognizes that emissions factors from exhaust hydrocarbons 

produced from the long haul transportation of lumber in to California would be greater than that 

created when lumber is produced locally. To model those emissions that could be produced for 

the transport of lumber from other states or countries into California is outside the scope of the 

KREW EIS as this is not currently proposed as part of the project nor is it reasonably foreseeable. 

AQ-3. The FEIS should discuss how emissions from the proposed project and alternatives 

would affect air quality, including visibility, within the impact area. Impacts to the listed 

Class 1 airsheds should be assessed as well as specific measures that would be included as 

part of the project to minimize those impacts to air quality in these areas. [Comment 

Number: 27-1]

Response: Effects from emissions, fugitive dust and visibility from the proposed project and 

alternatives are addressed in Section 3.1 of the DEIS. The design criteria for the protection of 

public health and Class I Airsheds is listed in Chapter 2, section 2.3.1.8 Design Measures – Best 

Available Control Measures (BACMs) for prescribed fire as required under Section 190 of the 

Clean Air Act (CAA) and developed by the EPA are listed in the Air Quality Section on page 2-

22. The full Conformity Determination and Air Quality Specialist Report are available on 

request.

AQ-4. We recommend that the FEIS include a discussion of the potential health effects 

resulting from the prescribed fire treatments and other vegetation management activities. 

A screening process should be conducted to determine which aspects of human health could 

be impacted. The Forest Service should partner with local, State, and federal health 

departments to conduct the appropriate analysis, and to determine appropriate and 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 14

effective mitigation measures to address potential adverse health impacts, particularly from 

smoke. [Comment Number: 27-2]

Response: An air quality determination has been conducted on the Proposed Action and its 

alternatives as required by the CAA. The potential for human health effects resulting from 

prescribed fire and other vegetation treatments are provided in the cumulative effects analysis in 

Chapter 3, Sections 3.1 Air Quality, 3.11 Vegetation and Silviculture and 3.12 Effects of Ground 

Application of Glyphosate on Human Health and Safety. The full Conformity Determination and 

Air Quality Specialist Report are available on request. 

AQ-5. We recommend the FEIS include a more detailed description of climate change and 

the implications for successful reforestation. For example, describe and evaluate projected 

climate change impacts on the frequency of high intensity storms, magnitude of rain events 

and severity and frequency of insect outbreaks, droughts, and fire seasons, and their effects 

on the success of reforestation efforts. We encourage the Forest Service to elaborate on 

aspects of the project’s research related to climate change, including temperature and 

precipitation, and how they can be incorporated into the goals of successful fuel 

management and watershed restoration. [Comment Number: 27-3]

Response: Greenhouse Gas (GHG) emissions and climate change information has been added to 

the Air Quality Section (Chapter 3 section 3.1) of the FEIS. GHG emission calculations are not 

required under the Clean Air Act General Conformity Rule and are not considered a criteria 

pollutant under the California Clean Air Act; an attempt to display the role Carbon Dioxide -CO2

emissions from this project plays in climate change is discussed. Due to limitations in available 

GHG calculators, the contributions from agriculture through silviculture treatments, carbon flow 

and the burning of biomass are not readily quantifiable and figures displayed this report show 

general CO2 emissions compared to state limits.

The Providence Unit of KREW currently receives precipitation as both rain and snow, while the 

Bull Unit is snow dominated. Scientists believe that the lower elevation research watersheds 

currently serve as a surrogate for how higher elevation watersheds will function with climate 

change (predicted to be 1 to 2 degrees C (similar in degrees F). PSW operates 10 stream flow 

monitoring sites, four meteorology towers (precipitation, snow depth, wind, solar insulation, 

temperature, and relative humidity), and two snow pillows on the research watersheds (see 

Appendix A for all measurements); eight years of baseline data have been collected. PSW also 

has an air pollution monitoring site in watershed P301 that is part of the National Atmospheric 

Deposition Network. In addition, five years of summer ozone and nitrogen concentrations have 

been measured in this research area and provide a good understanding of air pollution stress to 

this ecosystem. The National Science Foundation (NSF) is funding the Southern Sierra Critical 

Zone Observatory which has added many measurement sites of snow depth and soil moisture at 

several depths on the Providence research watersheds. NSF has also funded a transect of flux 

towers that measure weather conditions from the base to the top of the forest canopy; one of these 

towers is located in the Providence Unit at P301, and one is north of the Bull Unit. NSF's 

National Ecological Observatory Network will add more flux towers to this research area with a 

transect extending from the valley up to the crest of the Sierras; they selected this location to 

study climate change also. Through collaboration, an intense network of both climate and 

hydrology instruments is in place to address climate change in the southern Sierra Nevada. Some 

of these scientists are very interested in how the thinning and fire treatments will affect both 

watershed attributes that will be under stress from climate change and forest canopy weather.

Currently the average temperature across the 600-m average elevation range is only 1 to 2 

degrees C warmer in the lower versus upper elevation research watersheds. The annual 

precipitation is 75-95 percent snow at the Bull Unit versus 20-50 percent at the Providence Unit. 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 15 4/7/2011

Measurements indicate that about one third less water would flow in the streams from high 

elevation headwaters in the southern Sierra as temperatures increase 1 to 2 degrees C. Peak 

discharge lagged peak snow accumulation on the order of 60 days at the higher elevations and 20 

to 30 days at the lower elevations. Climate change is expected to result in earlier runoff, and the 

KREW data indicate the number of days that shift might be in the future.

GHG effects were also addressed in Section 3.11 Vegetation and Silviculture.

AQ-6. We recommend that the Final EIS estimate the quantities of greenhouse gas 

emissions resulting from mobile and non-mobile sources during project implementation. As 

appropriate, mitigation measures for direct sources of greenhouse gas emissions should be 

considered. [Comment Number: 27-4]

Response: Greenhouse Gas (GHG) emissions and climate change information has been added to 

the Air Quality Section (Chapter 3 section 3.1) of the FEIS. GHG emission calculations are not 

required under the Clean Air Act: General Conformity Rule and are not considered a criteria 

pollutant under the California Clean Air Act; an attempt to display the role Carbon Dioxide -CO2

emissions from this project play in climate change is discussed. Due to limitations in available 

GHG calculators, the contributions from agriculture through silviculture treatments, carbon flow 

and the burning of biomass are not readily quantifiable and figures displayed this report show 

general CO2 emissions compared to state limits.

Fire and Fuels

FF-1. On p. 1-1 appears the phrase ―fire and fuels treatments‖. How are these defined in 

relation to one another? [Comment Number: 2-9]

Response: Fire treatments are the use of management applied fire such as underburns and

broadcast burns to reduce or remove hazardous debris buildup (needles, small twigs, branches 

and logs) on the forest floor. Fire treatments can also kill small (generally less than 10 inches in 

diameter) shade intolerant trees and girdle brush species by cooking the cambial layer. Fuel 

treatments are treatments such as thinning young shade tolerant trees from below the forest 

canopy, limbing up trees to reduce the fuel ladder into mature trees, mechanical brush removal 

through dozer piling and slash (thinning and logging fuels created by the treatment activity) piling 

and pile burning. Fire treatments can be used in conjunction with fuel treatments to reach desired 

condition faster and better protect critical habitat features, or fire as a treatment can be used alone. 

Fire as a stand-alone treatment takes multiple entries (three to four entries over fifteen to twenty 

years) to reach the desired condition.

FF-2. On p. 1-7, 4th paragraph, it says that we have an immature understanding of systems 

of the Sierra Nevada. Yet your DEIS proposes to manage with other than natural processes 

even after much such ill-informed logging, grazing, and fire suppression management over 

the last 160 years. The DEIS should then provide plans for a different and more natural 

type of management, not just more logging and fire suppression. [Comment Number: 2-14]

Response: Fire suppression policies and grazing strategies are outside the scope of this project. 

While perfect knowledge of forest processes and resulting structures does not exist, CEQ 

regulation CFR 1502.24 requires that the Forest Service will insure the scientific integrity of 

analysis. This has been interpreted to require use of the best available science. This project 

proposes to add to the current body of scientific knowledge used to guide forest management and 

environmental analysis. The best available current science is used in the analysis of effects. 

The Proposed Action and action alternatives propose to use prescribed fire alone, prescribed fire 

and mechanical treatments, and mechanical treatment alone. Using natural processes alone to 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

Appendix I

Sierra National Forest 16

compare treatment results in no comparison at all. Prescribed fire alone would not meet the 

research purpose and need of the project.

FF-3. On p. 3.5-5, paragraph 3, it is stated that ―Additional appropriated dollars would 

need to be requested to complete any of the action alternatives.‖ We wonder what could be 

saved should a different alternative be put in effect with an entirely different method. 

Prescribed fire as used by the National Parks would provide that. [Comment Number: 2-34]

Response: Fuels treatments with or without commercial timber harvest require appropriated 

dollars to complete. Treatments such as tractor piling of natural fuels hazards such as brush and 

downed woody debris cost about $300 dollars per acre (2009 contract averages). Burning piles 

cost about $71-$200 dollars per acre depending on location (distance from private property and 

permanent infrastructure such as campgrounds). Prescribed fire – underburn treatments cost 

approximately $125 dollars per acre on average depending on location and size of burn units. The 

2009 Turtle Underburn cost approximately $40 per acre to ignite 2300 acres while the 2010 

Barnes II burn cost $150/acre to burn about 300 acres; larger burn units have a lower cost per acre 

average. The use of managed natural ignitions such as the 2009 Tehipite Fire (Sierra National 

Forest and Sequoia/Kings Canyon N.P.) and the 2010 Sheep Fire (Sequoia/Kings National Park 

and Sequoia National Forest) take money to manage, monitor, for line construction and control, 

protection of historical features and recreational assets which are all part of the cost of managing 

fires. All use of prescribed and managed natural fires with in the San Joaquin Valley Unified Air 

Pollutions Control District (SJVUAPCD) costs the land management agencies (State and Federal 

agencies) and are paid for out of appropriated dollars. The Sierra National Forest paid $17,600 

dollars in air fees to the SJVUAPCD for the 2009 Tehipite Fire alone. The majority of costs to 

maintain a burn program as well as complete hazardous fuels reduction projects are paid for out 

of appropriated federal funds or with some small assistance from collaborators. We partner with 

California Department of Fish and Game, Pacific Gas and Electric and the Fresno County 

Sportsmen‟s Club to complete projects that are integrated with wildlife to benefit both wildlife 

habitat and fuels reduction objectives. All fees paid for managing fire (such as the National Parks) 

requires federal dollars, either through appropriated funds or through emergency suppression 

dollars. 

FF-4. The DEIS, on page 1-10, claims that the primary purpose of the project is to 

reduce/prevent tree mortality. However, the DEIS fails to explain why, for fire and fuels 

purposes, it proposes to remove many mature fire-resistant trees up to 30 inches in 

diameter, and over 30 inches in diameter. Contrary to the implication of the DEIS, removal 

of intermediate-sized and large trees is unnecessary where the purpose is to effectively 

reduce the potential for severe fire. [Comment Number: 4-14]

Response: Although the commenter states that the DEIS has a primary purpose, it should be 

noted that the purpose and need explains that there are three needs being met by the project: 

forest resilience, public health and safety/fuels reduction and research.

Regarding this issue and fuel treatment effectiveness with tree diameter classes (over 12 inch 

diameter), most trees in these intermediate to larger size classes do not serve to function as 

significant ladder fuels, as stated in North et al. (2009). However, these trees may be removed for 

other reasons, including: (1) reducing canopy bulk density to reduce crown fire spread (Stephens 

and Moghaddas 2005, Safford et al. 2009) in stands treated for public and firefighter safety, (2) 

decreasing intermediate-sized ladder fuels that have continuous fuels to the ground (North et al. 

2009), (3) increasing the growth and reducing drought-stress to large-diameter pines and oaks by 

removing shade-tolerant competitors, (4) decreasing tree densities on the middle to upper slope 

topographic positions to facilitate heterogeneity across the forested landscape (North et al. 2010), 

(5) reducing operational hazard, (6) increasing stand heterogeneity and enhancing regeneration of 
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Sierra National Forest 17 4/7/2011

shade-intolerant pines and oaks through the creation of tree gaps or increase in size of existing 

small-sized gaps (Bonnicksen and Stone 1982), (7) increasing long-term carbon sequestration by 

increasing growth rates of large-diameter fire-resilient trees (North et al. 2009, Hurteau and North 

2010), and (8) reducing stand densities to promote tree growth and forest stands that are resilient 

to fire, insect outbreaks, and future climate change.

There is ample evidence that fuel and forest restoration treatments will be effective at reducing 

fuel loads, fire severity, and crown fire risk when surface fuels are treated in concert with ladder 

fuels, which includes the removal of select trees between 12” and 30” dbh (e.g., Hurteau and 

North 2008, Stephens et al. 2009, North et al 2009). There is also sufficient scientific support for 

fuel treatment effectiveness in mitigating the negative impacts of wildfire (e.g., Skinner et al. 

2004, Safford et al. 2009). However, it should be noted that there is very little scientific support 

for removing trees >30 inches in diameter for the purposes of reducing fire risk or achieving 

ecological restoration objectives.

FF-5. Prescribed Fire Use: The use of prescribed fire is ideal since fire is a part of a natural 

ecosystem and its effects cannot be fully duplicated by any means known today. The 

management goals in this plan cannot be attained with prescribed fire alone. The forests

stands need to be thinned first to reduce the number of live trees to natural numbers. The 

reduction of live fuel will reduce the intensity of the fire and make follow-up burns feasible.

[Comment Number: 22-5]

Response: Thank-you for your support. The Forest Service agrees that the use of fire alone will 

not fully accomplish the purpose and need of restoring forest resilience or in meeting the needs 

for research. Prescribed fire as a stand-alone treatment has a limited season of application due to 

weather and air constraints and cannot be applied uniformly across the landscape. The use of 

thinning treatments and prescribed fire in combination provides the opportunity to reach the 

desired condition faster and will allow for the use of fire in maintaining a resilient landscape.

Botanical Resources

BR-1. On p. 1-8, paragraph 2, the DEIS suggests meadow physical conditions need to be 

maintained and restored. But the Forest Service is presently in the business of planning for 

dramatically altering meadow profiles with pond and plug construction. We do not want to 

see that occurring in this project area nor anywhere else in the Sierra Nevada. Big Meadows 

in the Giant Sequoia National Monument (Hume Lake Ranger District) has already been 

damaged by implementation of a pond and plug project. [Comment Number: 2-15]

Response: The Sierra NF has not planned plug and pond improvements in the KREW EIS project 

for any meadow improvements. This should allay your concern about plug and pond methods 

being used on the KREW project, as they will not be used.

BR-2. On p. 2-63 the DEIS shows 3 acres of noxious weeds to be treated with chemical. The 

plan should be changed to use hand control with noxious weed removal on such a limited 

acreage. [Comment Number: 2-29]

Response: Alternative 3 is an alternative with no herbicide treatment for vegetation with manual 

treatment of noxious weeds proposed instead of treating with glyphosate. Therefore, suggested 

treatment offered by the commenter is being considered in the range of action alternatives.

Economics

E-1. We believe an Economics criteria should be added to Chapter 2.5 Comparison of 

Alternatives so that the reader and decision maker have an understanding of whether or 
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Appendix I

Sierra National Forest 18

not it’s reasonable to conclude any given action alternative is economically feasible. Simply 

bringing forward information from Chapter 3.5 (Economics) would be useful. [Comment 

Number: 1-2]

Response: A Benefit/Cost Ratio for each alternative was included in the DEIS Table 2-12 on page 

2-67. The FEIS contains additional rows in Table 2-12 reflective of additional economics‟ 

indicators to inform the public and decision-maker in summary form. 

E-2. The economics section of the DEIS supports the idea that jobs are needed in our society 

and that forest work can provide jobs. Implementation of methods related to Cohen’s work 

could provide significant numbers of forest jobs without the need for heavy logging.

[Comment Number: 2-3]

Response: Implementation of Cohen‟s methodology could provide significant opportunities for 

jobs. Please see response to ARA-1 [Comment Number: 2-2], that this falls under “the 

responsibility of the private property owner.” In 2009, the State of California has implemented 

new fire clearance requirements expanding from 30 feet of clearing around structures to 100 feet, 

somewhat addressing Cohen‟s work. Such consideration of these opportunities and effects is 

more a question of public policy and is not within the scope of the purpose and need, nor the 

evaluations, of the alternatives considered for this project. 

E-3. In the DEIS there are many faults that editors did not successfully correct. While some 

of these are just mechanical, others are content oriented. Nevertheless all these faults make 

the DEIS difficult to read and even misleading at times. This is significantly so in the 

Chapter 3 section on economics. Tables in that section are incorrectly labeled and numbers 

incorrectly totaled, among other things. This of course is a violation of the requirement 

under the National Environmental Protection Act (NEPA) that the DEIS be clear and 

understandable. Because of such faults, we ask that the DEIS be corrected and resubmitted 

for review by the public. The amount of damage that this project could do to the 

environment is consequential in relation to the benefits of completing it as described in the 

DEIS. [Comment Number: 2-4]

Response: The FEIS has been edited and strengthened to clarify the document. The Economics 

section has been rewritten in an attempt to increase understanding and clarity. The analysis has 

also been expanded with new, and missed, information such as temporary road costs, and current 

market conditions included. 

Alternative 3, Fuels Reduction (20” maximum Diameter Cut) has been identified as the 

alternative required by Judge England addressing the Sierra Nevada Forest Plan Amendment, 

2001 (also known as Framework 2001) decision. The original Tables 3-5-2 and 3-5-2a have been 

deleted, because they were a redundant sub-analysis performed to address and display the 

commercial aspects of the harvest portion of the various proposals.

In addition, aspects of research needs, “limited operating periods”, and operations scheduling 

requirements have been reviewed for feasibility.

The commenter feels that due to incorrect labeling of Tables and number totaling that the 

Economics section should be rewritten and recirculated. 40 CFR 1502.9(a) requires revision of a 

DEIS “if a draft statement is so inadequate as to preclude meaningful analysis, the agency shall 

prepare and circulate a revised draft of the appropriate portion.”

The DEIS Economic Section did contain errors that required correction. As stated in the 

Economics Section of the DEIS, Section 3.5, economics are based on many assumptions and 

variables that change constantly depending on market and other conditions. As the DEIS stated 

“The economic analysis provides an approximate comparison of costs between alternatives.” 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 19 4/7/2011

Although it is the intent of the SNF to provide clear information to the public, even with some 

inaccuracies in the numerical calculations and table labeling, the relative economic values across 

the alternatives are displayed for consideration and information. As the relative economic values 

are addressed there is meaningful analysis in the economic section and there is not a need to 

recirculate the document. The FEIS will include correctly labeled tables and correctly added 

totals.

E-4. At the bottom of p. 3.5-5 is stated, ―The FS assumes that the contract will be a 

stewardship contract due to the low total volume offered in millions (MM) of board feet, 

and the volume per acre (less than 3.0 Mbf) as this is not financially attractive to private 

enterprise as the costs will demonstrate.‖ This is not surprising. According to the late forest 

economist Bob Wolf (he drafted the National Forest Management Act) the Forest Service 

has always lost money on timber sales, ever since the Forest Service came into existence in 

1905. He said that only very rarely did any individual project ever show positive returns to 

the Government. On the other hand, how much of the timber is from trees from 20 to 30 

inches dbh? The mill can capitalize on those while crying crocodile tears as they will be 

deriving timber under Alt 5 for only $36,091 and the work will be subsidized by service 

contracts. All that convoluted arrangement needs to be more clearly stated in a revised 

DEIS. [Comment Number: 2-35]

Response: The Forest is not required to process a timber sale contract or an Integrated Resources 

Service Contract and will employ the most advantageous path available to the government, and 

the most efficient means available, at the point of contracting. Like most government institutions, 

there is no mandate that the Forest Service “make money” from its projects. Most government 

institutions are not designed to be profit generating institutions. It is the objective of the Forest 

Service to manage the federal lands entrusted to it for the greatest good, for the greatest number, 

over the long run. There are Directives requiring minimum payments for stumpage, which are 

addressed in the economic analysis. Timber cannot be sold for less than its minimum value. 

Regardless of the contracting forms employed, the analysis demonstrates that both the Forest 

Service and any potential contractor face significant “risks” involved in implementing the project.

E-5. At the top of page 3.5-6 is the admission that, ―Late in the analysis it was determined 

that some of the roads were temporary roads.‖ Temporary roads add costs to the project. 

So those costs of temporary roads are not figured into the economic analysis. So Table 3-5-1 

on p. 3.5-8 has zero values for temporary roads expenses. That does affect the economic 

outlook for this project. The analysis needs to be corrected. [Comment Number: 2-36]

Response: Please see response to E-3 [Comment Number: 2-4]. The DEIS (p.3.5-6) also 

explained that temporary roads do not alter the relative comparative cost of the alternatives as the 

cost for the temporary roads are part of an equal in each alternative and therefore the comparative 

cost would remain the same.

E-6. Various values in Table 3-5-1 on p 3.5-8 do not add up. Those values need to be 

corrected and made consistent. Furthermore, some of the descriptive information in the 

table is incorrect. The same applies to Tables 3-5-2 and 3-5-2a on p. 3.5-9. Thus the 

economic analysis is flawed. We should expect better. With such problems it seems 

uncertain that the analysis is truly valid. [Comment Number: 2-37]

Response: Please see response to E-3 [Comment Number: 2-4]. 

E-7. On p.3.5-10 in a section on costs is ―Surface Replacement Costs‖. That refers to asphalt 

damage repair costs for log truck traffic from ―this project‖ on the ―Sherman Pass Road 

(22S05)‖. What on Earth is that all about? That road is nearly 90 miles away between the 

Kern River and Hwy 395 in the Sequoia National Forest. Are some of the figures in the 
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Sierra National Forest 20

economic analysis borrowed from other projects not related to KREW? All figures need to 

be verified and then the DEIS can be submitted to the public again once all appropriate 

changes are made. [Comment Number: 2-38]

Response: Please see response to E-3 [Comment Number: 2-4].

E-8. On p. 3.5-14 is stated, ―Values will vary by market conditions at the time of sale and 

value may vary significantly due to variation of actual volume from the sample plot 

estimates, variation in landscape and vegetation, or economic feasibility of individual 

units.‖ This will impact the supposed research needs since data collection will be altered by 

market demands. We suggest that contracts mandate when work will be done IF the KREW 

research component is important to complete. Otherwise, it is obviated that research really 

is not an important component after all. [Comment Number: 2-39]

Response: Please see response to E-3 [Comment Number: 2-4]. Aspects of research needs, 

“limited operating periods”, and operations scheduling requirements have been reviewed for 

feasibility, as noted in the new economics section. Scheduling of items and operations, as well as 

„limited operating periods” and employment of PAL (Project Activity Level) fire precautionary 

industrial operations shut down requirements are incorporated, in all timber and Integrated 

Resource Service contract forms, and will be implemented.

E-9. Table 3-5-7 on p. 3.5-15 is titled USFS Cost/Benefit Analysis, but the bottom line of 

that table is labeled Benefit/Cost, the reciprocal of the title. What is that all about?

[Comment Number: 2-40]

Response: Noted and corrected. Please see response to E-3 [Comment Number: 2-4].

E-10. The Benefit/Cost value in line E of Table 3-5-7 on p. 3.5-15 is very low and is 

primarily based (see Table 3-5-4 on p. 3.5-12) on 0.9 miles of new road and 3 miles of 

reconstructed road that are claimed as road investment benefits at $305,000, while 

stumpage revenues to the Government are only $36,091. So the Benefit/Cost Ratio is almost 

entirely based on building roads and not on timber management or anything else. And this 

does not account for the temporary roads (see # 32, above). We believe that reveals a BIG 

need to change management design for the KREW Project. Thus a new DEIS is needed.

[Comment Number: 2-41]

Response: Please see response to E-3 [Comment Number: 2-4]. The analysis considers all 

significant benefits and costs for the project implemented considering various options for 

contracting implementation. Benefits and costs, as well as some financial risk assessments are 

compared for the entire project for various “stake holders.”

E-11. Profitability – We hope that the project includes enough value from the timber to pay 

for the project and hopefully make a profit. This would likely require harvesting of larger 

trees in quantities sufficient to pay for the less profitable portions of the project. If the 

project pays its own way and is a success it will be easier to reproduce in other locations. 

This would allow forest restoration on a larger scale once the process has proven successful.

Comment Number: 22-2]

Response: The analysis demonstrates that both the Forest Service and any potential contractor 

face significant “risks” involved in implementing the project. Table 3-5-1 indicates the metric 

values of the timber presented by the various alternatives. Those values need to be compared to 

the required road costs to extract the timber displayed in Table 3-5-3 lines B, D, and F. There are 

various disparities between the Mandatory Minimum Selling Values and the estimated road costs. 

These values are based on an average operator efficiency and are therefore more “risk” analysis 

than “value” analysis. At the time of accepting contract bids or proposals, the market is a prime 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 21 4/7/2011

determinate of outcome rather than Forest Service Estimates. Some of the risk may be managed 

by the form and “packaging” of the project in the potential array of possible contracts. 

E-12. The one suggestion we have is that a summary of the Economics from 3-5 be include 

in the 2.5 Comparison of Alternatives. [Comment Number: 23-3]

Response: DEIS Table 2-12 (p. 2-67) contained the Economics reflective row labeled “FS 

benefit/cost ratio.” The FEIS contains additional rows in FEIS Table 2-16 (which replaced DEIS 

Table 2-12) reflective of additional economics‟ indicators to inform the public and decisionmaker in summary form. 

Aquatic Biota

AB-1. Due to the importance of these occupied meadows to the overall distribution and

persistence of Yosemite toad we asked in our scoping comments for conservation measures 

to be designed to limit the potential to crush any life stage of this species and to limit 

damage to burrows. Design measures or an alternative was not developed to address this 

issue. The DEIS clearly identified that this population of Yosemite toad may be extirpated. 

Federal listing of this species is already warranted. Extirpation of this significant population 

is not consistent with Forest Service direction to not contribute to a trend toward federal 

listing. [Comment Number: 3-3]

Response: As noted in the comments, wider buffers and limiting operating periods surrounding 

breeding habitat for Yosemite toads had previously been rejected due to conflicts with objectives 

for research. Sierra Forest Legacy (SFL) proposal to provide 500-meter buffers around breeding 

meadows was considered during the evaluation of comments. The 500-meter buffer would 

exclude approximately 75 percent of the KREW project area from any treatment. This mitigation 

was not accepted as a design measure due to inability to collect data meaningful to address 

research questions from treatments within the remaining portions of the KREW Bull watershed.

In the Federal Register of 12/10/2002 (FR Doc 02-3800), the USFWS established the Yosemite 

toad as a candidate species for federal listing under the Endangered Species Act. The finding was 

that the overall magnitude of threats to the species was moderate, and the overall immediacy of 

threats was moderate and non-imminent. It was assigned a Listing Priority Number (LPN) of 11 

out of 12 (1 represents greatest threat). While it was concluded that proposing to list Yosemite 

toad was warranted, an immediate proposal to list was precluded by other high priority listing 

actions. The Federal Register of 11/9/2009 presented a description of progress on listing actions.

The Yosemite toad retained a LPN of 11 during the 2009 evaluation and no more recent listing 

evaluations are available.

Among the historic and current range information considered under the 2002 candidate listing 

was that Yosemite toad currently occurred from 91 locations throughout the overall Sierra 

National Forest. The Sierra National Forest has conducted additional surveys for Yosemite toad 

since the information was included for the 2002 listing. The Forest has 300 meadows known to be 

used for breeding by Yosemite toad, with an additional 10 meadows where lifestages other than 

tadpoles have been observed. The aquatic biological assessment/evaluation for the KREW project 

disclosed that direct effects (mortality) to the species could occur as a result of proposed 

activities. Given the isolation of the occupied meadows within the project area from the nearest 

known sites, it also appears re-colonization would be unlikely in the event that the apparent metapopulation represented by the project area were extirpated. The species was determined as 

warranted for listing in 2002, thus the KREW Project would not be expected to contribute to a 

trend resulting in that determination. The project aquatic biological assessment/evaluation was 

provided to the US Fish and Wildlife Service to evaluate whether the determinations used in the 

analysis were correct.
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 22

AB-2. Key to our participation or support in scientific study is the principle that the 

experimental design does not compromise at-risk species. From early in the planning of the 

KREW project, we have indicated that the issues related to fisher and Yosemite toad 

conservation are acute and need to be addressed. The Proposed Action and alternatives as 

presently designed still fail to address the conservation needs of these species. [Comment

Number: 3-5]

Response: As previously noted, conservation measures for Yosemite toad that would extend 

buffers of no activity around breading meadows were considered during the evaluation of 

comments. This mitigation was not accepted as a project design measure due to inability to 

collect data meaningful to addressing research questions from treatments within the remaining 

portions of the KREW Bull watershed. We do not define conservation as protection of every 

individual, but rather, sustaining populations over time. The Bull and Providence Unit 

watersheds serve as replicates for the thin and burn treatments; therefore, they need to receive 

essentially as similar a treatment as possible to be compared. During research design, the buffer 

width to be evaluated was discussed among research and Forest staff and set at 100 ft from the 

edge of stream banks or the green edge of meadows. If Providence meadows received a 100-ft 

buffer and Bull meadows received a 500-ft buffer, then effects on meadows cannot be compared 

and no replicate exists. The buffer width needs to be the same for all experimental watersheds.

A Yosemite toad limiting operating period, excluding project activities within the KREW Bull 

watershed between 5/1 and 7/15 has been added as a design measure. Examination of the species‟ 

life history indicates long movements (200-800 meters) from overwintering sites to breeding 

meadows are common for adults (although most females do not return to the meadow annually). 

Adults spend less than two weeks at meadows during breeding. Similar movements (200-800 

meters) take place post-breeding with adults moving to foraging sites. Breeding, Eggs, tadpoles, 

and metamorphosis all occur within meadows with protective buffers, thus direct affected would 

not be anticipated. Sub-adults venture from the meadow during their second year and move to 

foraging sites both within and beyond project buffers. 

The adults appear to be the lifestage most susceptible to direct affects from the KREW Project. 

They may be particularly vulnerable during their post-breeding movement to foraging sites 

(adults move to breeding meadows during spring when roads remain closed by snow). Martin 

(2008) indicates post-breeding movements to foraging sites occur over a relatively short period of 

less than two days. After monitoring post-breeding movement of adult toads on the Sierra 

National Forest, Liang (2010) reported most movements to foraging sites occurred within 3-1/2 

weeks post breeding, although long movements may occur beyond that time. Breeding varies by 

water year type (snowpack), meadow aspect, and spring temperatures, but would be expected to 

occur from late May to early June in the project area during most years. The Yosemite toad 

limiting operating period for the KREW Bull watershed provides 30-50 days of no activity and 

would be expected to reduce probability of project-related direct effects to post-breeding adults 

moving to foraging sites. Once at the foraging sites and after the no activity period, adults would 

remain susceptible to direct effects if the foraging site is located within a proposed treatment unit. 

Application of BMPs 1-10 and 1-12 focuses use of existing skid trails and landings. These areas 

would have some level of compaction from past use and less likely to have rodent burrows that 

might be used for cover by foraging adult toads. Underburning, and tractor piling would occur 

within foraging habitat and it is also likely some new skid trails would be necessary. Thus, overall 

direct effects from project activities to adult toads could result.

Research often poses risk to species, but the importance of the new information is weighed 

against the risk. This comment is puzzling since the fisher research that the Sierra Forestry 
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Sierra National Forest 23 4/7/2011

Legacy supports on the SNF involves risks to individuals of this species--putting collars on fisher 

and anesthetizing animals to take samples.

It is illogical to ask for mitigation of effects when part of the purpose of the Project is to perform 

research to quantify whether there are positive, negative, or no effects from the forest 

management practice. Implementation monitoring can verify whether mitigation measures are 

effective, but that is not the purpose of research. The PSW KREW research is designed for cause 

and effect monitoring and research to answer information gaps (see Section 1.3.2 Management 

Direction, Adaptive Management subsection). KREW has and would continue to gather unique 

data on the Yosemite toad (adult movement and habitat use). The Providence Unit has a very 

long history of fisher monitoring by PSW Fresno scientists, and they will continue to monitor 

fisher in the Providence Unit.

And pertaining to Pacific fisher, the DEIS Table 3-9-14 and Section 3-9.4.4 show that the 

Proposed Action (Alt.5) will only reduce 12 acres of the 1,502 total acres of fisher habitat in the 

project area immediately after treatment, which is less than 1 percent of the entire fisher habitat 

in project area. And the project area is expected to have net increase of fisher habitat 30 yearspost treatment. The Proposed Action retains nearly all fisher habitat and it goes further by

retaining, and promoting the future development off, important fisher habitat features, such as by 

retaining: (1) all large live trees greater than 30 inches dbh; (2) most mid-sized trees 20-30 inches 

dbh; (3) many other trees smaller than 20 inches dbh; (4) all large snags greater than 15 inches 

dbh, unless they are a safety hazard; (5) all oaks; and other habitat features. Additionally, 50

percent of the project area that is inhabitated by fishers will not be thinned, thus maintaining high 

canopy cover there as well as other locations in the project area. And a project-wide LOP will be 

implemented during the fisher denning period to avoid direct impacts to these animals. 

Additionally, our detailed, multi-scale cumulative effects assessment of fisher habitat, provided in 

the DEIS Section 3-9.4.4 and Table 3-9-17, shows that the short-term 12 acre loss of fisher 

habitat, as a result of Alternative 5, is less than 0.06 percent of fisher habitat available at small 

and larger scales of assessment, which also takes into consideration the habitat conditions after 

past, present and foreseeable future actions. Cumulative effects assessments of Alternatives 2-4 

show a similar result (Wildlife BABE and FEIS 3-9.4.3). It is entirely incorrect for the 

commenter to claim that the KREW Project does not include adequate measures to conserve 

Pacific fisher; in contrast, these alternatives help ensure fisher habitat and populations will be 

sustained on the forested landscape over the long-term by retaining their most important habitat 

needs and reducing the risk of wildfire, which could eliminate large swaths of fisher habitat if not 

reduced. All of this is done in conjunction with the US Forest Service performing its other public 

service responsibilities, goals, and objectives as a responsible land management agency, which 

also includes forest management research.

AB-3. Table 2-12 (DEIS, p. 2-66) implies that there are differences in activities proposed in 

riparian area among the alternatives. We were not able to find a description of those 

differences in Chapter 2. The section on design measures (DEIS, p. 2-34) identifies among 

other things two measures that apply to all alternatives:

WldBMP 10- Conserve riparian ecosystems by implementing streamside 

management zone protection measures.

WldBMP 11- Create a system of Old Forest Linkages (OFL) that are 300 ft buffers 

along perennial streams with an overstory forest canopy cover of at least 50-60

percent and greater tree basal area as compared with adjoining forests.

As presented in the DEIS, other aquatic standards, with the exception of igniting prescribed 

fire, appear to be the same among the alternatives. (See for example DEIS, p., 2-23 and 2-

24). Please more clearly explain the basis for concluding that Alternative 4 ―Meets research 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

Appendix I

Sierra National Forest 24

objectives in large part except for riparian areas‖ (DEIS, p. 2-66, Table 2-12). [Comment 

Number: 3-15]

Response: The differences in treatments within the RCAs are a result of the thinning strategy that 

applies to the unit within which each RCA is located for each alternative. FEIS Table 2-16 has 

been added to Chapter 2 to more clearly describe the RCA treatments. 

Streamside Management Zones (SMZs) are defined based on channel class and slope (see section 

3-6) and are subject to more strict design measures (e.g. no mechanized equipment) and Best 

Management Practices (BMPs). The BMP list in Appendix C has been revised to more clearly 

state the requirements within RCAs and SMZs.

An Old Forest Linkages (OFL) is being created along Providence Creek and is located outside 

research areas. This perennial stream was the only one within the project area that was suited for 

this treatment.

AB-4. We also do not see a specific description of the activities that are proposed within the 

riparian conservation areas (RCAs). As defined in the DEIS, these zones are intended to be 

managed for the benefit of the aquatic and riparian habitats. See for example BMPs 1-18 

and 1-19 (Aquatics BA/BE, p. 29) that indicate activities will be designed and limited to 

activity that maintains or improves riparian and aquatic values.‖ The actions being 

proposed are not clear and it cannot be evaluated how these will maintain or improve 

conditions within the RCA. [Comment Number: 3-16]

Response: FEIS Table 2-16 has been added to Chapter 2 to more clearly describe proposed 

treatments with the RCAs. BMPs 1-18 and 1-19 in the Aquatics BA/BE, along with BMPs 

described in Appendix C are designed to maintain the integrity of hydrologic system, protect 

water quality, and to protect and maintain riparian habitat and species. 

Exceptions to some management requirements and BMPs (as described in FEIS Table 2-16) have 

been made within the Research Watersheds as part of the research project design. These 

exceptions are inconsistent with the current standards and guidelines contained in the Sierra 

Nevada Forest Plan Amendment Record of Decision (2004 ROD) and the Sierra National Forest 

Land and Resource Management Plan. The KREW DEIS and FEIS contain minor plan 

amendments because of these inconsistencies.

AB-5. We asked during scoping comments that these measures be incorporated into the 

project design. The measures recommended by Sanders (2006) or other conservation 

measures were not incorporated into the project design. Instead, intensive activities are 

proposed within the 300-foot riparian conservation area (RCA) associated with meadows 

utilized by Yosemite toad. The proposed activities are not consistent with direction in the 

forest plan to enhance or maintain habitat for meadow dependent species within the RCA.

[Comment Number: 3-29]

Response: As noted in your comments, 500-foot buffers surrounding breeding habitat for 

Yosemite toads and a limiting operating period of 5/1 – 8/15 proposed by Sanders (2006) had 

previously been rejected due to conflicts with objectives for research. Also, please see response 

to AB-2 [Comment Number: 3-5].

The KREW project is not consistent with S&Gs for RCAs regarding impacts to threatened, 

endangered or sensitive species because it does not have measures to avoid impacts to Yosemite 

toad from ground disturbing activities that are part of the project. Exceptions to some 

management requirements and BMPs (as described in FEIS Table 2-16) have been made within 

the Research Watersheds as part of the research project design. An amendment to the Sierra 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 25 4/7/2011

National Forest Land and Resources Management Plan regarding this inconsistency is part of the 

decision for this project.

AB-6. The activities proposed within 300 feet of meadows occupied by or providing suitable 

habitat for Yosemite toad were not designed to enhance or maintain habitat. As clearly 

described in the BE (p. 81) the proposed activities place this meta-population at serious risk 

of extirpation and the remoteness of this site to other Yosemite toad occurrences could 

prevent recolonization of the site. This outcome is in direct conflict with the direction in the 

forest plan and is likely to increase the trend toward Federal listing under the Endangered 

Species Act. [Comment Number: 3-30]

Response: As previously noted, the KREW project is not consistent with S&Gs for RCAs 

regarding impacts to threatened, endangered or sensitive species because it does not have 

measures to avoid impacts to Yosemite toad from ground disturbing activities that are part of the 

project. An amendment to the Sierra National Forest Land and Resources Management Plan 

regarding this inconsistency is part of the decision for the KREW Project. Also, please see 

responses to AB-2 [Comment Number: 3-5] and AB-5 [Comment Number: 3-29].

The aquatic biological assessment/evaluation for the KREW Project discloses that direct effects 

(mortality) to Yosemite toad could occur as a result of proposed activities. Given the isolation of 

the occupied meadows within the project area from the nearest known sites, it also appears recolonization would be unlikely in the event that the apparent meta-population represented by the 

project area were extirpated. As previously noted, the species was determined as warranted for 

listing in 2002, thus the KREW Project would not be expected to contribute to a trend resulting in 

that determination. More than 200 meadows used for breeding by Yosemite toad have been 

identified on the Forest since the 2002 listing determination. The project aquatic biological 

assessment/evaluation was provided to the US Fish and Wildlife Service to evaluate whether the 

determinations used in the analysis were correct.

AB-7. The alternatives should be revised to comply with the forest plan and to include the 

conservation measures recommended by Sanders (2006) or other such measures that 

enhance and maintain habitat utilized by Yosemite toad. [Comment Number: 3-31]

Response: The 500-foot buffers surrounding breeding habitat for Yosemite toads proposed by 

Sanders (2006) had previously been rejected due to conflicts with objectives for research. 

A limiting operating period between 5/1 and 8/15 for Yosemite toad also was previously rejected. 

The significance of the 8/15 date corresponds to the expected completion of metamorphosis, thus 

provide protection for toad breeding and rearing sites. However, a limited operating period 

excluding project activities during 5/1 – 7/15 would be included for the KREW project as a 

conservation measure to reduce effects from noise on breeding toads, and provide a level of 

protection to adults that might be vulnerable during movements from breeding sites to foraging 

sites. Data collected by Martin (2008) and Liang (2010) suggest most post-breeding movements 

to foraging sites has occurred by 7/15. Rearing of toads through metamorphosis that might occur 

between and 7/15 – 8/15 is within meadows that no have no activities proposed, thus no 

disturbance would be anticipated.

AB-8. The proposed activities that adversely affect Yosemite toad also do not meet the 

research objectives stated in Chapter 1. Chapter 1 identified the KREW project as designed 

to achieve forest restoration goals with a research component ―to characterize headwater 

ecosystems and assess the response of the ecosystem to these management practices. The 

forest ecological restoration management practices include treatments designed to reduce 

the effects of uncharacteristic wildfire, drought, invasive species and insect attack, while 

maintaining/restoring habitat for plants and wildlife species including sensitive species such 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

Appendix I

Sierra National Forest 26

as California spotted owl, Pacific fisher, and Yosemite toad.‖ Chapter 1 specifically 

identifies that habitat for Yosemite toad will be maintained and restored. As described 

above, the Proposed Action or alternatives clearly does not meet this purpose and need for 

Yosemite toad. [Comment Number: 3-33]

Response: The California Wildlife Habitat Relationship (CWHR) model was utilized for the 

analysis of Yosemite toad. The model was developed and maintained by the California 

Department of Fish and Game. The CWHR notes that similar high elevation toads are capable of 

900 meter movements. The limited data on toad movements collected from Martin (2008) and 

Liang (2010), suggest some movements exceeding 1 kilometer, although in general the CWHR 

movement information is representative. 

Under the KREW proposal, all of the Action Alternatives includes activities within occupied 

Yosemite toad habitat (900 meters surrounding occupied breeding meadows). As described in the 

Aquatic BA/BE for the KREW project, most of the indirect effects to Yosemite toad would be 

related to habitat alteration. Thinning is proposed within the red fir, Sierra mixed-conifer, and 

ponderosa pine CWHR types. The primary changes reduce size group 5 to size group 4 and 

reduce density over a 20-30 year period. CWHR habitat quality from the proposed treatments 

would generally remain unchanged for Yosemite toad. However, a reduction in stand density for 

smaller diameter lodgepole pine would improve the habitat quality based on CWHR. Overall the 

CWHR quality of habitat remains unchanged (maintained) following the proposed treatments. 

AB-9. The Forest Service is required to ―rigorously explore and objectively evaluate all 

reasonable alternatives.‖ 40 CFR 1502.14 (a). The purpose of these requirements is to 

―provide a clear basis for choice among options for the decisionmaker and the public.‖ 40 

CFR 1502.14. With respect to den buffers and habitat buffers for occupied Yosemite toad 

habitat, the DEIS does not provide alternatives to the proposed approach of over-riding 

these protections. Alternatives that address the issue could include: Creating den buffers for 

all areas within the project 

Creating den buffers for the non-experimental unit portion of the project

Creating 500-foot buffers (no disturbance) around meadows occupied by Yosemite 

toad (Sanders 2006)

Creating 500-meter buffer around pools occupied by Yosemite toad (Martin 2009)

Establishing a limited operating period for Yosemite toad to minimize killing 

animals

Identifying dispersal areas with high return rates for Yosemite toad and delineating 

buffers to those areas

Establishing a limited operating period (LOP) during the breeding and dispersal 

season for Yosemite toad (Sanders 2006) 

The conservation measures above directly address reducing the adverse impact of the 

project on at-risk species and could potentially avoid jeopardizing the persistence of 

individuals and placing the populations at risk. These measures should be evaluated in the 

DEIS. [Comment Number: 3-34]

Response: The 500-foot buffers surrounding breeding habitat for Yosemite toads proposed by 

Sanders (2006) had previously been rejected due to conflicts with objectives for research. The 

Bull and Providence Unit watersheds serve as replicates for the thin and burn treatments; 

therefore, they need to receive essentially as similar a treatment as possible to be compared. 

During research design, the buffer width to be evaluated was discussed among research and 

Forest staff and set at 100 ft from the edge of stream banks or the green edge of meadows. If 

Providence meadows received a 100-ft buffer and Bull meadows received a 500-ft buffer, then 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 27 4/7/2011

effects on meadows cannot be compared and no replicate exists. The buffer width needs to be the 

same for all experimental watersheds. 

A proposed 500-meter buffer around Yosemite toad breeding meadows was considered during the 

evaluation of comments to the draft environmental impact statement for the KREW project. The 

500-meter buffer would exclude approximately 75 percent of the KREW Project area from any 

treatment. This mitigation was not accepted as a design measure due to inability to collect data 

meaningful to addressing research questions from treatments within the remaining portions of the 

KREW Bull watershed.

The limiting operating period between 5/1 and 8/15 proposed by Sanders in 2006 for Yosemite 

toad was previously rejected. The significance of the 8/15 date corresponds to the expected 

completion of metamorphosis, thus provide protection for toad breeding and rearing sites. 

However, a limited operating period excluding project activities during 5/1 – 7/15 would be 

included for the KREW project design as conservation measure to reduce effects from project 

noise on breeding toads, and provide a level of protection to adults that might be vulnerable 

during movements from breeding sites to foraging sites. Data collected by Martin (2008) and 

Liang (2010) suggest most post-breeding movements to foraging sites has occurred by 7/15. 

Rearing of toads through metamorphosis that might occur between and 7/15 – 8/15 is within 

meadows that no have no activities proposed, thus no disturbance would be anticipated. Also, 

please see response to ARA-6 [Comment Number: 4-1].

There is limited data available on toad dispersal. Liang (2010) notes some instances of apparent 

fidelity, but there is not enough data to determine what might be considered as a basis for a high 

return rate. 

Use of over-the-snow logging to reduce probability of direct effects to Yosemite toad from 

ground disturbing equipment was considered during evaluation of comments to the draft 

environmental impact statement for the KREW project. The measure was not further developed 

due to there being no level of confidence that the equipment might be available during period 

necessary to implement the project. More information on why over-the-snow logging was not 

included as an alternative considered in detail is available in FEIS Section 2.4.

AB-10. The alternatives as designed also jeopardize the persistence of fisher and Yosemite 

toad in the project area. [Comment Number: 3-37]

Response: A conservation measure for a limited operating period excluding project activities in 

the KREW Bull watershed between 5/1 and 7/15 would be incorporated as a project design 

measure to benefit Yosemite toad. The measure should provide protection to breeding and 

rearing toads, along with protection during most post-breeding movements to foraging sites, 

which is a time they might be vulnerable to direct effects.

As previously noted, the project aquatic biological assessment/evaluation was provided to the US 

Fish and Wildlife Service to evaluate whether the determinations used in the analysis were 

correct.

Sierra National Forest understands the importance of sustaining fisher populations. We plan and 

design our management to address the conservation of that species as well as other wildlife 

species and other forest resources and uses. We are not proposing clearcutting forests, instead we 

are proposing forest thinning that also retains majority of the forest biomass, including all large 

trees (>30 inches dbh) and nearly all moderate sized trees (20-30 inches dbh), as well as many 

smaller trees, all oak trees, and all large snags unless deemed a safety hazard. We also included 

extensive areas of no thinning management within the project area. Additionally, our cumulative 

effects analysis has taken into consideration past, present and foreseeable vegetation management 

in and around the project area (DEIS and FEIS - Section 3.9.4.3 and 3.9.4.4 and the December 
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Sierra National Forest 28

2010 Wildlife BABE – Sec. 3.3.3 and 3.3.4), and shows that the Proposed Actions will reduce 

only 12 acres of fisher habitat immediately after treatment, which is only 0.8 percent of the fisher 

habitat in the project area; 0.05 percent fisher habitat within a 3.1 mile buffer of the project area; 

0.03 percent of the Kings River Project Area; and 0.003 percent of the Southern Sierra Nevada 

fisher population area. This analysis includes past, present and foreseeable future vegetation 

management projects, including Forest Service project and adjoining private lands. Through this 

design and analysis, and our other responses to comments TW-3 through TW-11, we have not 

found any reason to believe that our management will significantly affect or even imperil the 

local fisher population nor the Southern Sierra Nevada fisher population as a whole. On the 

contrary, this management helps ensure fisher habitat, and the fisher population will be sustained 

on this landscape for the future. 

Research

R-1. You have not made it clear what novel hypotheses will be explored through KREW 

data collection so that new concepts might be developed. Without describing such 

hypotheses, you cannot entertain the public to comment on the validity of any parts of the 

scientific component of the KREW Project. [Comment Number: 2-1]

Response: We regret that the commenter was unable to identify the many questions that the 

KREW research is designed to answer; we have added text to Section 3-8.2 for clarification. The 

goals and objectives of the research are discussed in the DEIS on 3-8.2; the adaptive management 

questions are listed in Section 1.3.2; the full 127 page, peer-reviewed Research Study Plan was 

referenced and available to readers on the PSW web site as a PDF; and the entire set of 

measurements that KREW takes were provided in appendix A of the DEIS. The Research Study 

Plan defines the research problem, objectives, and methods; and it provides three conceptual 

models as examples of what the research is trying to accomplish (i.e., stream discharge, soil loss, 

and vegetation). 

R-2. On p. 1-7, 2nd paragraph, it says, ―Supporting the research design is a primary goal 

for project management direction and development.‖ The research design, however, is 

neither complete nor clear in the DEIS nor in the PSW link to which the DEIS refers on p. 

1-10. See www.fs.fed.us/psw/programs/snrc/water/kingsriver. At the PSW site, for example, 

the water chemistry section is entirely blank as of 1/13/11. [Comment Number: 2-12]

Response: The entire Research Study Plan is on the PSW web site (see response to R-1). There 

are some links on the web site that do not have text, and we are sorry this confused the reader.

R-3. Under 3-5.2 on page 3.5-1 is stated, ―Limited funds are available for forest health 

management and research efforts on federal lands and therefore these funds must be used 

as efficiently as possible to achieve the greatest benefit. There is a need to use economicallyefficient methods to implement projects and achieve restoration objectives. The benefits to 

FS research include larger scale studies than dedicated research budgets can normally 

support. The benefits to the FS lands management wing include the knowledge rendered 

from studies for consideration on future proposals and project design formulation and 

NEPA analysis.‖ Our concern is that contracts for KREW Project work will not mandate a 

timeframe and thus the data collection for the research will not be appropriate as the mill 

owners decide when they want to do things. Then the research component will be of lesser 

value if not lost altogether for certain parts of the research. Additionally, since the 

investigator, C. Hunsaker has announced a retirement date; we have concern whether the 

research will be completed at all after her retirement. [Comment Number: 2-33]
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 29 4/7/2011

Response: All contracts for KREW will comply with the Record of Decision. A need for 

research is to complete tree harvests in one field season therefore each alternative will address the 

research portion of the purpose and need.

The PSW and SNF staffs have been in discussion about the logistics of implementing the forest 

thinning since the design of the KREW research study; the watersheds selected for thinning

versus underburning were based on the landscape and on-the-ground logistics. Contracts for 

thinning on research areas have been successfully executed before by Region 5 for PSW; 

examples include the Teakettle Experiment on the Sierra National Forest and Blacks Mountain 

Experiment on the Lassen National Forest. Forest and research staffs prepare the request for bids 

and the contract together and monitor the contractor‟s work on the ground. Research scientists 

that have invested 10 years of their career in developing a state-of-the-science experiment like 

KREW are going to be very careful about the implementation of the treatments so the quality of 

the research results are not compromised.

Dr. Hunsaker has not announced a retirement date. No long-term research would ever get started 

if potential retirement of staff was the determining factor. 

R-4. The DEIS (p. 1-10) appears to imply that the other studies ongoing in the KREW 

watersheds and larger area (e.g., NEON, Critical Zone Observation Program) are somehow 

dependent on the KREW project being implemented. This is not the case. These other 

studies will continue whether or not the KREW treatments are implemented. [Comment 

Number: 3-10]

Response: The Sierra Forest Legacy does not indicate that they spoke with the National Science 

Foundation (NSF) or any of their projects‟ lead scientists to support the statement that “these 

other studies will continue whether or not the KREW treatments are implemented.” If KREW 

treatments are not implemented, the PSW has no reason to continue running the stream and 

meteorology monitoring instruments; the SSCZO is dependent on data from these instruments. 

The NSF has stated the importance of KREW to the SSCZO (Dr. T. Abrajano), and several of the 

collaborating scientists (Dr. C. Riebe of University of Wyoming, Dr. R. Bales of UC Merced, Ms. 

E. Stacy of UC Merced., Mr. M. Meadows) support Alternative 5, plan to study the proposed 

forest management treatments, and believe that failure to implement the KREW treatments as 

designed by scientists will jeopardize continued funding for their research.

R-5. The continued implementation of the KREW agenda is clearly critical to the SSCZO 

and the Critical Zone Observatory Program.

With this note, I would like to express my unqualified support for the implementation of the 

tree thinning and prescribed fire treatments for the Kings River Experimental Watersheds 

(KREW) in 2011, as designed by Dr. Carolyn Hunsaker (see alternative 5 of the draft EIS, 

―Kings River Experimental Watershed Forest Health and Research Project). KREW provides 

much needed data on Sierra Nevada headwaters which are critical for California’s water 

supply and for understanding climate change affects. [Comment Number: 5-1]

Response: We thank the headquarters staff of the National Science Foundation (NSF) for their 

comment about the national and California importance of KREW through its collaboration with 

the Critical Zone Observatory Program. This Program supports the thinning and fire treatments 

of alternative 5 and confirms that the implementation of the KREW agenda is critical to the 

Southern Sierra Critical Zone Observatory.

R-6. The holistic nature, rigorous design, and geographic location of KREW have attracted 

state and national attention and financial investment precisely because these are 

irreplaceable assets. The fact that the Providence Site of KREW is now one of the first 

three National Science Foundation’s (NSF) funded Critical Zone Observatories is testimony 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 30

to the critical need for KREW. This effort, which brings seven universities together to work 

with Dr. Hunsaker for at least five years, is at the forefront of critical zone observatory 

research. NSF researchers have also picked this location as part of California’s contribution 

to the National Ecological Observatory Network (NEON). It is no accident that he State of 

California has been investing in KREW since 2005, the Forest Service and State have 

invested five million dollars in KREW research, and the NSF has invested at least an 

additional five million dollars. [Comment Number: 5-2]

Response: We thank the National Science Foundation for commenting on the “holistic nature and 

rigorous design” of the KREW research, the diverse set of collaborators, and the substantial 

investment of funds from the Forest Service, State of California, and the NSF.

R-7. I strongly support the continuation of the Kings River Experimental Watershed 

(KREW) research project, because it represents cutting-edge research that will provide 

information critical to making informed decisions about the management of watersheds and 

water resources in the western U.S. [Comment Number: 6-1]

Response: We thank Dr. Cooper, University of California, Santa Barbara, for supporting the 

continuation of the KREW research through the forest treatments.

R-8. I believe that the KREW research project is particularly valuable for the following 

reasons.

Rigorous Design. The KREW experiment has been rigorously designed, with 16 

sites being surveyed in 1999 and 10 sub-basins being monitored since 2002. These 

sub-basins will be assigned, in a factorial design, to treatments with and without 

controlled burns and selective logging. When combined with the long premanipulation dataset, we will be able to directly, statistically compare the effects of 

controlled burns and selective logging, alone and in combination, on watersheds and 

their drainage streams.

Long-term pre-manipulation dataset. Data on the physical, chemical, and biological 

characteristics of KREW watersheds and drainage streams have been collected 

since 1999. As a consequence, we have a rich dataset for both describing the 

characteristics of these systems and examining changes in these systems with 

selective logging and controlled burns. After the large amounts of time and effort 

directed to amassing a large pre-manipulation dataset, it would be a large waste of 

time and resources to not carry out the manipulations and monitor their impacts.

Comprehensive nature. Many biological, chemical, and physical variables are being 

measured in terrestrial and stream environments as part of this project, so the 

results of this project will provide a comprehensive view of fire impacts on a large 

array of natural resources.

Large scale of manipulations. The controlled burns and selective logging will be 

done at the scale of entire sub-basins, the scale of interest to managers, and the 

results will reveal the responses of entire watersheds to these manipulations. 

Because large-scale manipulations often engender numerous long-term and indirect 

effects on the ecology of terrestrial and stream environments, this experiment will 

allow a direct assessment of fire and logging management practices on ecological 

systems at realistic scales.

Management implications. This large scale experiment will produce data showing the 

effects of key management practices, such as controlled burns and selective logging, on 

water, soils, vegetation, water chemistry, and the stream biota, all natural resources of 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 31 4/7/2011

central interest to the U.S. Forest Service. These results, then, will guide management and 

policy decisions regarding the sustainable use of natural resources, as well as allow 

managers to balance economic, environmental, recreational, and safety interests. As a 

consequence, this research addresses many of the U.S.F.S’s core mandates. [Comment 

Number: 6-2]

Response: We agree with Dr. Cooper that the KREW research project is valuable for the 

following reasons: rigorous design, long-term pre-manipulation data, comprehensive nature, 

scale of manipulations, and importance of results for future management and policy decisions.

R-9. This is a well-designed, rigorous, ongoing study which has already produced a solid 

baseline for examining the effects of management practices on critical natural resources. 

Discontinuing this study at this point would be a huge waste of time, energy, and money 

because the goals on which the study was focused could not be met, the data collected to 

date would be much less valuable, and no data relevant to key management concerns would 

be produced. As a consequence, I strongly urge you to allow the planned KREW 

treatments to proceed so that the KREW studies can be completed, providing the data that 

are needed to make informed management and policy decisions. [Comment Number: 6-3]

Response: We thank Dr. Cooper for his comment on the nature of the KREW research: “welldesigned and rigorous.” We share his opinion that discontinuing this study would be a “huge 

waste of time, energy, and money.”

R-10. KREW provides much needed data on Sierra Nevada headwaters which are critical 

for California’s water supply and for understanding climate change affects. The elevation 

range where KREW is located is the rain-snow transition zone for this part of the Sierra 

Nevada. This zone is likely more sensitive to climate change, since an increase in 

temperature could shift the precipitation regime from snow to rain dominated. A 

precipitation regime shift would have unknown affects on the hydrology of the system—

impacting vegetation, aquatic and terrestrial organisms, fire risk and severity, and people. 

The SSCZO integrates vital data collected by KREW in research focused on hydrologycentered processes occurring from the bedrock to the atmospheric boundary layer. In 

tandem, these projects provide monitoring equipment, data streams, analysis, and modeling 

efforts critical in identifying and mitigating impacts from climate change and land 

management in the Sierra Nevada. [Comment Number: 7-2]

Response: We agree with Mr. Meadows that KREW will supply much needed data on Sierra 

Nevada headwaters.

R-11. The research provided by both the SSCZO and KREW are important for identifying 

impacts from land management that have not been identified for the Southern Sierra. The 

mechanical thinning and prescribed fire treatments are designed to meet the research goals 

of KREW and the SSCZO. The data provided by these projects will provide vital insight 

into a broad set of research questions that include: forest restoration, fuel loading, water

quality and supply, nutrient cycling, soil formation and productivity, and ecosystem 

productivity to name a few. The research treatments are patchy in nature and will not affect 

more than about 1,000 acres of habitat for any species of concern. Furthermore, several 

species of concern are monitored heavily within the KREW project, including the Pacific 

fisher, the spotted owl, and the Yosemite toad. KREW is unique in its design to address 

effects (positive, negative, or neutral) from forest management activities that could be used 

by federal, state, and private land managers and stakeholders in the Sierra Nevada.

[Comment Number: 7-3]
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Sierra National Forest 32

Response: We thank Mr. Meadows for his comment that the KREW research is “unique in its 

design” and valuable to federal, state, and private land managers. We also appreciate his 

recognition that the species of concern are “monitored heavily within the KREW project.”

R-12. Many of the impacts that we expect from forest management and treatments are 

based on assumptions made from research carried out in other regions of the country and 

world. The Sierra Nevada lacks a comparable research site, both in scope and purpose, to 

KREW and the SSCZO. The KREW site gives us the ability to study forest management 

and processes at a local scale; results from these studies may be used to predict process 

behaviors and inform management decisions on the regional scale. It is for these and many 

other reasons that I support the Kings River Experimental Watershed Forest Health and 

Research Project. [Comment Number: 7-4]

Response: We agree with Mr. Meadows that the Sierra Nevada lacks a research site to compare 

impacts from forest management and treatments to those studied in other parts of the country and 

world.

R-13. Since its inception, KREW has been providing a crucial data stream on watershed 

processes in Sierra Nevada headwaters. Maintaining the KREW data steam is important to 

understanding how California’s water supply and ecosystems will respond to climate 

change in years to come. KREW has attracted state and national attention and has also 

garnered external financial investment from the National Science Foundation (NSF); in 

2007, the Providence Creek watershed, which is part of the KREW network, became one of 

the first three Critical Zone Observatories (CZOs) funded by NSF in a national effort to 

focus research on interdisciplinary studies of biogeochemistry, geomorphology and 

hydrologic processes. The Southern Sierra CZO has brought seven universities (including 

my own) together to work with Dr. Hunsaker for the last 4 years. Providence Creek has also 

been selected as California’s contribution to the National Ecological Observatory Network 

(NEON); this will bring additional attention and prestige to KREW. The State of California 

has been investing in KREW since 2005. Together, the Forest Service (FS) and State have 

already invested roughly five million dollars in KREW research. [Comment Number: 9-2]

Response: We agree with Dr. Riebe, that “KREW has been providing a crucial data stream on 

watershed processes in Sierra Nevada headwaters.” He is also correct about the diverse financial 

and science support and involvement, including the National Ecological Observatory Network.

R-14. If the implementation of the proposed treatments is stymied, some of that collective 

investment (from the FS, the State and NSF) will go for naught, negating many months of 

preparation and expense by Hunsaker and her team. This negative outcome will likely 

impinge on our collective ability to attract further investment from NSF. Hence, failure to 

implement the treatments would, without question, be a negative outcome for all parties 

concerned – especially to the extent that it hamstrings efforts to understand issues related to 

changing water supply of 40 million Californians. [Comment Number: 9-3]

Response: We agree with Dr. Riebe that not implementing the proposed treatments “will likely 

impinge on our collective ability to attract further investment from NSF.”

R-15. Measurements at KREW have been designed to address specific research questions 

related to forest restoration – not just fuels reductions – in an effort to gain holistic insight 

into restoration strategies. The project has been developed over the years by research and 

management to meet the objectives of both parties.

This collaboration must continue, with targets on forest restoration which produces uneven 

ages, both vertically and horizontally, and a patchy landscape that is consistent with 

historical information about pre-disturbance conditions. The KREW mission is designed to 
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Sierra National Forest 33 4/7/2011

develop a sensible silviculture treatment plan that can be practically applied by typical 

ranger districts, with cost-neutral (or better) options for both mechanical and fire 

treatments. Importantly, the KREW mission differs from the somewhat more academic 

pursuits of the CZO, in that it is designed to produce practical solutions to forest 

restoration problems that include restoring conditions that promote diversity across 

ecosystem components. If funding and support of the KREW effort continues (including 

treatments outlined in the EIS), it has potential to go down as an important contribution in 

understanding how to sustainably manage forest ecosystems. Hence, I stand in full support 

of the proposed treatments in the KREW watersheds. [Comment Number: 9-6]

Response: We thank Dr. Riebe for his statements about the need and value of the KREW 

research, including the statement that KREW is designed to gain holistic insight into restoration 

strategies, not just fuels reduction.

R-16. The purpose of the submittal is to re-state that as the Program Manager for the 

Sierra Resource Conservation District’s Upper San Joaquin River Watershed Stewardship 

program that we continue to support the Kings River Experimental Watershed (KREW) 

research program. In fact, as we have previously stated, that it is imperative that this 

research continue to proceed. [Comment Number: 10-1]

Response: We thank the Sierra Resource Conservation District for its continued support of the 

KREW research program.

R-17. The continuation of the KREW research project will keep many people involved, 

including university professors, students, and staff, state and federal agencies, and the 

National Science Foundation. [Comment Number: 11-2]

Response: We appreciate the recognition that the KREW research has diverse involvement and is 

important to local, state, and federal organizations; and UC staff, students, and professors.

R-18. The KREW Project is important to me because I previously worked as a hydrologic 

technician in the Caspar Creek Experimental Watershed near Fort Bragg, California. The 

data gathered from there and the Pacific Northwest does not correlate well with data 

collected so far under the unique KREW research design. The Sierra Nevada and the coast 

ranges of the west coast have vastly different ecosystem components. The riparian zones in 

the Providence and Bull sites of KREW are substantially smaller than the Pacific Northwest 

and other parts of the Sierra Nevada. A broad set of research questions still need to be 

answered for KREW, as in the case of water quality, soil erosion, nutrient cycling, carbon 

storage, vegetation improvement, fuel loadings, riparian areas, air pollution effects, climate 

change, and stream ecosystems. [Comment Number: 11-3]

Response: We agree with Mr. Smith that no appropriate data exist from other western watershed 

experiments to apply to management of the southern Sierra Nevada headwaters. We appreciate 

the recognition that questions need to be answered for the riparian headwaters and that KREW is 

designed to do this.

R-19. The ecosystem research proposed at the Kings River Experimental Watersheds 

(KREW) is absolutely essential for building the knowledge base needed for adaptive 

management of forest land in California’s Sierra Nevada. While it is acknowledged that 

these forests are currently not in a sustainable condition, past research and management 

practices fail to provide a clear, widely accepted path to achieve such a condition. Research 

done at a relatively small scale at KREW is designed to provide the data and information 

needed to manage forests at a larger scale. [Comment Number: 12-1]
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Sierra National Forest 34

Response: We thank Dr. Guo, UC Merced, for his statement on the need for the KREW research 

on forest management practices.

R-20. The broad set of research questions include water quality, soil erosion, nutrient 

cycling, carbon storage, vegetation improvement, fuel loadings, riparian areas, air pollution 

effects, climate change and stream ecosystems. The level of disciplinary integration at 

KREW is unique and is not being replicated in the Sierra Nevada or any other site that can 

adequately inform management decisions in the Sierra National Forest. [Comment 

Number: 12-3]

Response: We agree with Dr. Guo that KREW addresses a broad set of research questions not 

being “replicated in the Sierra Nevada or any other site.”

R-21. Baseline measurements for the research component of the KREW project have been 

underway for several years and it is critical that the treatments be implemented as 

described in the DEIS to complete this valuable research for the southern Sierra Nevada 

Mountains. [Comment Number: 13-3]

Response: We appreciate the American Forest Resource Council‟s recognition of the long-term 

pre-treatment data collection at KREW and the importance of implementing the treatments to 

provide “this valuable research for the southern Sierra Nevada Mountains.”

R-22. I am writing in support of the tree thinning and prescribed fire treatments that 

KREW was designed to evaluate for forest restoration. I have been involved in KREW 

research for over a decade now, working with Dr. Hunsaker and have published a recent 

paper with her on this very important project. [Comment Number: 14-1]

Response: We thank Dr. Johnson for his continued support of the alternative that KREW 

research was designed to evaluate.

R-23. We at the University of Nevada, Reno, like researchers at several other institutions, 

have conducted research on fire and fire mitigation strategies, but there is no study that I 

know of that has a more comprehensive plan for measurement of such effects, ranging from 

soil to water quality (my area) to vegetation, wildlife, and stream biota. The KREW 

watershed study if by far the most ambitious and comprehensive study of fire and fire 

mitigation that has ever been attempted, and it is of utmost importance that these 

experimental treatments been implemented without further delay. Both the scientific 

community and forest managers need this information, as prescribed fire and fire 

mitigation measures are already taking place over a wide scale, and many of the 

environmental effects are as yet unknown. I sincerely hope that the delays that have 

occurred in implementing this vital project will come to an end. They serve no purpose 

other than to prevent us from obtaining valuable information. [Comment Number: 14-2]

Response: We agree with Dr. Johnson that the KREW research is one-of-a-kind and the 

experimental data are needed by both scientists and forest managers.

R-24. Once again I want to comment on the value of this study in providing scientific 

foundations on which informed management decisions can be made. This project is 

destined to become a classic example of large-scale, long duration investigations of 

headwater forest ecosystems, and how the management of forest practices can be 

coordinated to maintain the ecological integrity of watersheds. Since 1999, with Professor 

Scott Cooper of the UC Santa Barbara Department of Ecology, Evolution and Marine 

Biology, we’ve been conducting biological surveys of streams to establish a monitoring 

baseline of stream health measures (aquatic invertebrate life) that will be used to evaluate 

the effects of planned timber harvest and prescribed fire management treatments. The 
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Sierra National Forest 35 4/7/2011

stream invertebrate monitoring studies share the goal of the larger KREW premise that 

integrated and adaptive management must begin with improved scientific information on 

the forested headwater stream habitats of the Sierra Nevada. [Comment Number: 15-1]

Response: We appreciate Dr. Herbst‟s continued support for the need for KREW research and the 

recognition that KREW is “destined to become a classic example of large-scale, long duration 

investigations of headwater forest ecosystems, and how the management of forest practices can 

be coordinated to maintain the ecological integrity of watersheds.”

R-25. Understanding the role of forest harvest practices and prescribed burning within the 

watershed landscape of the central Sierra Nevada will be essential to planning and guidance 

of water resource management. The quality and quantity of water used in much of 

California has its origin in the central Sierra so the lessons learned from this landmark 

study will provide important guidance on how to protect water resources used in California. 

Indeed, the insights gained should inform forest management in source-area watersheds 

elsewhere in western US regions where urban and agricultural uses depend on adequate 

protection of headwater streams. KREW has recently been selected as a Critical Zone 

Observatory by the National Science Foundation, so there is further added value for 

continued research. [Comment Number: 15-2]

Response: We agree with Dr. Herbst that the insights gained from the KREW experiment should 

inform forest management elsewhere in western US regions where urban and agricultural uses 

depend on adequate protection of headwater streams.

R-26. I consider this a premier example of public-service research: studies that provide 

crucial information on how to manage public resources for multiple beneficial uses while 

involving minimal threats to the habitats under study. We have much to gain through the 

continuation of this project, and much to lose if it is abandoned. Many years of 

painstakingly-collected data and multidisciplinary integration will be for naught. I strongly 

urge you and others involved in decisions regarding the experimental treatments at KREW 

to allow these planned treatments to proceed. [Comment Number: 15-3]

Response: We thank Dr. Herbst for his statement that “this is a premier example of public-service 

research.” We agree that we have much information to gain from the proposed treatments “while 

involving minimal threats to the habitats under study.”

R-27. Because of the strong base of research provided at Kings River Experimental 

Watersheds (KREW) by Dr. Carolyn Hunsaker and her colleagues with the Pacific 

Southwest Research Station (PSW), U.S. Forest Service, I have initiated additional research 

into the hydrologic, biogeochemical, geomorphologic responses of the KREW catchments to 

perturbations associated with climate change and land-management actions. My colleagues 

from the University of California (Merced, Berkeley, Davis, Irvine, plus U. Nevada) and I 

have invested over $600,000 in additional instrumentation and about $1,000,000 per year in 

research at these catchments. The U.S. National Science Foundation (NSF) is the sponsor of 

this research, through a highly competitive Critical Zone Observatory Grant. We were one 

of six sites across the U.S. selected for this highly visible and prestigious award. [Comment 

Number: 16-2]

Response: We appreciate Dr. Bales‟ comment that the NSF research is interested in studying the 

perturbations on the catchments associated with both climate change and land-management 

actions. We also appreciate the substantial amount of funding and collaboration he has brought to 

this research site.

R-28. We view KREW as an ideal long-term research site, and NSF is interested in planning 

for additional major investments in research and supporting infrastructure in future years. 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 36

The KREW catchments cross the rain-snow transition, the elevation range where effects of 

change are thought to be most severe, are the only location in the Sierra Nevada currently 

equipped for this research. The magnitude of research investments in the Sierra Nevada is 

unprecedented, and is yielding and unparalleled understanding of how these systems 

function and respond. [Comment Number: 16-3]

Response: We acknowledge Dr. Bales‟ interest in planning for additional major investments in 

research and supporting infrastructure in future years at KREW and the importance of 

understanding how these systems function and respond.

R-29. This letter is in support of the forest treatments proposed at the Kings River 

Experimental Watershed (KREW). I am writing this statement of support on behalf of the 

Sierra Nevada Adaptive Management Project (SNAMP) UC Science Team. Our project 

scientists plan to use data from these treatments to improve our understanding of the effects 

of fuels and forest health treatments on SNAMP study sites. [Comment Number: 17-1]

Response: We thank the Sierra Nevada Adaptive Management Project (SNAMP) for its support 

of the proposed forest treatments and the interest in using data from these treatments to improve 

their understanding of treatments on SNAMP study sites.

R-30. For example, SNAMP’s Water Quality and Quantity Team are using KREW data to 

help parameterize and test their field-data driven models. By necessity due to expense, the 

intensive hydrological monitoring in SNAMP is limited to two small catchments in each of 

the two SNAMP study areas, and we hope to use pre and post treatment KREW data to be 

able to extrapolate our results across the larger SNAMP landscape to address questions on 

a larger, more management-relevant scale. [Comment Number: 17-2]

Response: We are pleased that SNAMP is using KREW data to help parameterize and test their 

models and that such comparison/collaboration can help extrapolate their results across larger 

landscapes.

R-31. Several attempts by CAL FIRE watershed staff to help fund this type of project in the 

early 1990’s were rejected due to the costs involved. Therefore, when Dr. Hunsaker’s began 

her project several years ago, we were delighted that this type of study was finally 

undertaken. We do not want to see it fail now that so much excellent pre-project data 

collection has occurred. ... We were all impressed with the quality of the research being 

conducted by Dr. Hunsaker. [Comment Number: 18-2]

Response: We appreciate that CAL FIRE has recognized the need for a study such as KREW 

since the early 1990‟s, and thank the organization for their kind words about the quality of the 

current research.

R-32. ...our work has not included collection of instream monitoring data (i.e., pumped 

water samples and turbidity data) that provide a connection between instream conditions 

and management practices occurring on hillslopes in the watershed. We have also not 

collected instream monitoring data documenting the effects of prescribed fire and 

mechanical thinning. With the implementation of thinning and prescribed fire treatments, 

the KREW project will provide important data for the southern part of the Sierra Nevada. 

.... It is clear that we need a better understanding of the impacts of fuel reduction 

treatments, such as the prescribed fire and mechanical thinning treatments to be used on 

the KREW sites, on water quality. .... A greater knowledge base is clearly needed so that we 

can widely implement fuel reduction treatments without significantly degrading soil 

properties and water quality. CAL FIRE is keenly interested in this topic. Since the 

KREW project has been designed to test the impacts of these types of practices, it will 

supply much needed information addressing these very important topics.
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Additionally, CAL FIRE believes that the KREW project is providing much needed data on 

Sierra Nevada headwaters, which are critical for California’s water supply and for 

understanding climate change affects. [Comment Number: 18-3]

Response: We appreciate that CAL FIRE believes there are important and unique questions that 

KREW research will answer that the research they have financially supported has not addressed.

R-33. The Central California Regional Water Quality Control Board (Central Valley Water 

Board) is writing in support of the United States Forest Service Pacific Southwest Research 

Station’s ―Kings River Experimental Watershed Forest Health and Research Project‖ 

(KREW Project). The Central Valley Water Board recognizes that there is a paucity of 

data regarding cause-and –effect linkages between forest management and water quality in 

the Sierra Nevada. The KREW Project seeks to fill some of these knowledge gaps through 

rigorous experimentation at multiple spatial and temporal scales. Experimentation and 

learning are critical steps for optimizing management practices and regulatory processes in 

the presence of uncertainty (i.e., adaptive management). [Comment Number: 19-1]

Response: We thank the Central California Regional Water Quality Control Board for their 

support of the KREW experiment and agree that there is “a paucity of data regarding cause-andeffect linkages between forest management and water quality in the Sierra Nevada.”

R-34. The KREW Project is beneficial because it will quantify baseline conditions for 

several physical water quality variables that the Central Valley Water Board regulate, 

including temperature, turbidity, and suspended sediment. The project will also measure 

several chemical variables include monitoring for nitrate, pH, and electrical conductivity. 

By applying various treatments (e.g. thinning and prescribed fire) while implementing best 

management practices (BMPs), managers have the ability to determine whether these types 

of management activities are consistent with meeting water quality objectives acr5oss 

multiple spatial and temporal scales. This information is vital for commonsense regulation 

of forested watersheds in our region.

By increasing the knowledge base regarding land use interactions with watershed processes, 

we increase the potential for forest management to meet ecological and societal goals while 

still achieving water quality objectives. [Comment Number: 19-2]

Response: We are pleased that the Central California Regional Water Quality Control Board 

believes that the KREW data on the proposed management treatments will help them meet water 

quality objectives and that this information is “vital for commonsense regulation of forested 

watersheds in our region.”

R-35. For more than a decade I have been conducting research related to the hydrologic 

effects of forest management in the Sierra. This means that forest managers are largely 

managing by ―feel‖, yet it is a truism that without monitoring one is not really managing, 

In other words, one had to be qualitatively and or quantitatively assessing the effects of 

their management activities in order to be truly managing as opposed to guessing.

KREW is the only sustained, watershed-scale research project related to forest management 

in the Sierra. At this point several million dollars have been invested in the initial 

characterization and baseline monitoring but in the absence of any management activities 

the net scientific return from this investment will be limited. However, if the proposed 

treatments can be implemented with the associated intensive monitoring, this can provide 

essential guidance to both public and private forest managers as well as regulatory agencies 

such as CalFire and the Water Quality Control Board. The proposed research is 

particularly timely as the WQCB is currently reviewing the USFS waiver for best 
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Sierra National Forest 38

management practices to minimize non-point pollution from forest management activities, 

and a key limitation in this process is the lack of relevant data. [Comment Number: 21-2]

Response: We agree with Dr. MacDonald that without monitoring data such as KREW would 

collect on forest management, the Forest Service and others are managing by “feel” and not “truly 

managing.” We appreciate the comment that KREW is timely since the WQCB is currently 

reviewing the USFS waiver for best management practices to minimize non-point pollution and a 

key limitation in this process is the “lack of relevant data.”

R-36. I cannot speak on the effects of the proposed treatments on specific plants or animals 

but I can speak with some authority on the likely effects of these treatments on erosion, 

runoff and sediment yields .... My primary concern with respect to the treatments is not 

that the treatments will have an adverse effect on soils and aquatic resources, but that the 

effects might be too small to be detected given the spatial and temporal variability 

characteristic of natural streams, and the accuracy of our measurements. ...It is important 

to recognize that any reduction in the proposed intensity or extent of the treatments may 

greatly reduce the scientific value of conducting these treatments, as it will be increasingly 

difficult to detect a chance, and measuring no change provides much less information for 

managers than treatments that result in detectable change. [Comment Number: 21-3]

Response: We agree with Dr. MacDonald that “any reduction in the proposed intensity or extent 

of the treatments may greatly reduce the scientific value of conducting these treatments.”

R-37. This letter is written in support of implementing management practices that support 

the Kings River Experimental Watershed (KREW) Study design. [Comment Number: 24-1]

Response: We thank Dr. Ice, National Council for Air and Stream Improvement, for supporting 

implementation of the forest management practices that support KREW research.

R-38. The National Academy of Science report Hydrologic Effects of a Changing Forest 

Landscape identified a lack of research on the effectiveness of contemporary Best 

Management Practices (BMPs) as a major issue for the forest community. Over the last 

several years I have followed the progress of the KREW Study with great interest. Testing 

the effects of thinning and prescribed fire on water resources contributes important new 

information for the Sierra Nevada Mountains.

I urge you to conduct the planned thinning and prescribed fire treatments so the KREW 

project can proceed and so a unique and important watershed research opportunity is not 

lost. No other paired forest watershed studies in the Sierra Nevada Mountains can address 

uneven-aged forest management and the impacts of prescribed burning to the extent that 

this well-designed study can. [Comment Number: 24-2]

Response: We appreciate Dr. Ice‟s comment that the National Academy of Science identified a 

“lack of research on the effectiveness of contemporary Best Management Practices as a major 

issue for the forest community.” We also appreciate the comment that the KREW research is 

unique, important, and well designed.

R-39. Dr. Hunsaker’s research and her work in the Kings River watershed provides the 

necessary scientific foundation for our research and studies on the San Joaquin River...

Healthy forests are essential to a healthy water supply and our region could greatly benefit 

from on-the-ground projects that will provide the practical and scientific basis for future 

research efforts and forestry jobs. The Sierra Nevada forests need this type of baseline 

research project to unlock the potential for new Green Jobs throughout the Sierra Nevada 

range. With a roadmap for forest recovery, local groups can begin planning for a new 

generation of forestry projects that will allow our forests to recover from years of neglect 
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Sierra National Forest 39 4/7/2011

and damaging forestry practices....Dr. Hunsaker’s research expands traditional forestry 

practices to include ecosystem-level analyses that will benefit other efforts in the Sierra 

Watersheds, and help get our Sierra Nevada forests and communities back on track to 

healthy, safe and sustainable practices. [Comment Number: 25-2]

Response: We are glad that results from KREW research are expected to be useful to the work of 

reviving the San Joaquin River and possibly providing new “Green Jobs” in the Sierra Nevada. 

We also appreciate that this organization believes the proposed Project can “help get our Sierra 

Nevada forests and communities back on track to healthy, safe, and sustainable practices.”

R-40. KREW is unique in its holistic watershed-level focus and emphasis on long-term 

forest regeneration. Any reduction in the intensity of the treatments would detract from the 

relevance of the results. [Comment Number: 26-2]

Response: We agree with Ms. Stacy that any reduction in the intensity of treatments “would 

detract from the relevance of the results.”

R-41. The complexity of the system requires that this project yield management-relevant 

data while the challenging economic realities of research and forest management compel an 

economic return on the investment. As designed the 2011 implementation of these 

treatments will leverage research already completed at the KREW site, while sales of timber 

will cover a large portion of the costs. Further delay or modification of treatments will 

impose severe financial constraints on the project and may result in the termination of the 

KREW collaboration. This disastrous loss would be a waste of the time and resources 

invested thus far in the project, and I hope that it can be avoided by the timely 

implementation of the treatments. [Comment Number: 26-3]

Response: We agree that “further delay or modification of treatments will impose severe financial 

constraints on the project and may result in the termination of the KREW collaboration,” and that 

this would be a loss.

Terrestrial Wildlife 

TW-1. In paragraph 2 of p. 2-43 is admission that intensive fuel treatments in Defenses 

Zones will degrade habitat in Alternative 3 and that Threat Zone habitats will also be 

degraded under other Action Alternatives. [Comment Number: 2-22]

Response: Some of the language in the second paragraph of page 2-43, under “2.2.2.1 How the 

Alternative Was Developed” was incorrect and that paragraph has been revised. The intent of 

fuels reduction management is to reduce the potential for large scale, high intensity wildfire that 

could eliminate large portions of mature and older-aged forests, and these are habitats needed by 

many of our most sensitive wildlife species, such as fishers and spotted owls. The statements 

made in this paragraph are only intended to state why Alternative 3 was developed; they are not, 

however, an analysis of neither the impacts nor a final determination made for impacts to species 

habitats; that are provided in Chapter 3. The statements on page 2-43 only acknowledge the 

potential concerns for habitat impacts as a result of the other action alternatives; therefore

Alternative 3 was added as part of the range of alternatives to assess those impacts. The effects 

of all alternatives on habitat are described and compared in Chapter 3.

Please also review the response to TW-10 [Comment Number: 3-25], which provides a summary 

the analysis conducted by the Conservation Biology Institute (CBI) (Spencer et al. 2008) 

comparing the effects of fuels management to the effects of wildfire on fisher habitat. Results of 

the fire simulations demonstrated that fuels reduction management may effectively reduce the 

extent and severity of fire on the landscape over a 50-year time span. Given the right 

combinations of treatment rate, intensity, and location, the benefits to fishers of reducing fire 
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Sierra National Forest 40

outweigh the cumulative negative effects of the treatments themselves on fishers. Across the 

broad spatial scales CBI examined, given specific assumptions disclosed in Spencer et al. (2008) 

about how thinning treatments affect fuel characteristics, fire spread rates, and fire severity, and 

within the finite combinations of fire regimes and treatments tested, it was concluded that the 

long-term positive effects of fuel treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on fisher. 

This was especially true assuming a more severe fire regime in the future. Truex and Zielinski 

(2005) documented an expected short-term detrimental habitat change for fishers as a result of 

fire and fuels reduction treatments. Spencer et al. (2008) places the tradeoffs of short-term 

habitat degradation for long term benefit in clear context for the southern Sierra Nevada fisher 

population and habitat as a whole, demonstrating specific conditions where short-term detriment 

for long-term habitat maintenance is acceptable.

TW-2. The Proposed Action in the DEIS falls short of the appropriate balance and 

unnecessarily degrades fisher habitat placing this population at greater risk of extirpation.

[Comment Number: 3-1]

Response: The DEIS Table 3-9-14 and Section 3-9.4.4 show that the Proposed Action (Alt.5) 

will only reduce 12 acres of the 1,502 total acres of fisher habitat in the project area immediately 

after treatment, which is less than 1 percent of the entire fisher habitat in project area. And the 

project area is expected to have net increase of fisher habitat 30 years-post treatment. The 

Proposed Action retains nearly all fisher habitat and it goes further by: (1) retaining all large live 

trees greater than 30 inches dbh; (2) most mid-sized trees 20-30 inches dbh; (3) many other trees 

smaller than 20 inches dbh; (4) all large snags greater than 15 inches dbh, unless they are a safety 

hazard; (5) all oaks; (6) retention of large portions of the project area with high canopy cover; (7) 

implementing a project-wide LOP during the fisher denning period; and (8) retention of other 

important habitat features. Additionally, our detailed, multi-scale cumulative effects assessment 

of fisher habitat, provided in the DEIS Section 3-9.4.4 and Table 3-9-17, shows that the shortterm 12 acre loss of fisher habitat, as a result of Alternative 5, is less than 0.06 percent of fisher 

habitat available at small and larger scales of assessment, which also takes into consideration the 

habitat conditions after past, present and foreseeable future actions. The assessment of 

Alternatives 2-4 also shows a similar minimal affect (Wildlife BABE and FEIS 3-9.4.3). The 

action alternatives help ensure mature forests, fisher habitat and fisher populations will be 

sustained on the landscape over the long-term by retaining their most important habitat needs, 

while also reducing the risk of large scale loss of habitat due to wildfire, while simultaneously 

allowing the US Forest Service to perform its other public service responsibilities, goals, and 

objectives, as a responsible land management agency; including forest management research.

TW-3. The DEIS fails to evaluate the application of the protection required by the forest 

plan for den site protection and requested in our scoping comments. [Comment Number: 3-

2]

Response: In response to scoping comments, a new subsection, with maps and tables, has been 

added to the FEIS (Sections 3-9.4.3 and 3-9.4.4) as well as the Terrestrial Wildlife BEBA 

(Section 3.3.4.5) to further document our assessments of the affects of the project on fisher home 

den buffer habitats. For example our assessment of the only fisher den known to be present in the 

project area in 2010 (Fisher #19) shows that 48 percent of the den buffer area and 55 percent of 

the home range within the project area will not be thinned at all, under any alternative. Also 

treatments that will occur in the remaining area will only convert less than two percent of the 

fisher habitat in those areas to non-fisher habitat, under all action alternatives immediately after 

treatment, as well as 30 years post-treatment. Additionally, 75 percent to 100 percent of those 

areas will have at least 60 percent canopy cover or greater (CWHR Class D) immediately after 

treatment as well as 30 years post-treatment. This analysis shows that the alternatives, including 
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Sierra National Forest 41 4/7/2011

the minor Forest Plan amendments for fisher den buffers, will retain nearly all fisher habitats in 

den buffer areas in the project area. Through this design and analysis, we have not found any 

reason to believe that our management will significantly affect or even imperil the local fisher 

population nor the Southern Sierra Nevada fisher population as a whole. On the contrary, this 

management helps ensure fisher habitat, and the fisher population will be sustained on this 

landscape for the future.

TW-4. We asked in our scoping comments on the DEIS that fisher den buffers and home 

ranges be delineated and that the relationship between the proposed treatments and 

existing vegetation be evaluated and displayed. We requested this information to allow us to 

compare the effects of the alternatives on fisher and known denning areas. This information 

is not presented in the DEIS or biological evaluation (BE). The BE does to a limited extent 

identify the location of den site buffers for a number of sites, but does not specifically state 

what areas within the buffer would be subject to treatment. We also asked that the DEIS 

identify the existing canopy cover and the canopy cover estimated to remain following 

treatment of each unit. This information is not presented in the DEIS or BE. The DEIS does 

summarize the post-treatment canopy cover for the entire area to be treated, but this is not 

the level of detail we requested for review. [Comment Number: 3-19]

Response: The average canopy cover shown in Table 3-25 on page 106 of the BABE has been 

updated with analysis showing the average canopy cover in the area inhabited by fishers (the 

Providence management area) initially begins with 61 percent and then only decreases by 8

percent (to 53 percent) immediately after treatment. The tables that reflect this average canopy 

cover in the BABE and EIS have been updated. It is important to note that this is an average 

across the entire area, and the preferred alternative retains high canopy cover over large portions 

of the area inhabited by fisher. For example, 50 percent of the Providence management area (the 

area inhabited by fishers) will not be thinned at all, thus the higher canopy cover of those areas 

will be retained. Additionally, areas that are thinned will return to their pre-treatment canopy 

cover through time as tree canopies grow. Our analysis also shows that 75 percent to 100 percent

(depending on alternative selected) of the 2010 fisher home range and den buffer areas will have 

at least 60 percent canopy cover immediately after treatment, as well as 30 years post-treatment 

(FEIS Section 3-9.4.4 and Terrestrial Wildlife BABE Section 3.3.4.5). This KREW Project forest 

management retains adequate areas of high canopy cover as well as other areas of moderate 

canopy cover to support the various needs of Pacific fisher.

TW-5. The analysis in the BE primarily relies on defining suitable habitat for fisher as 

moderate to larger tree stands with greater than 40 percent canopy cover. This focus 

overlooks the importance of high canopy cover and contiguous blocks of forest with high 

canopy for both den sites and throughout the home range (Zielinski et al. 2004a, Purcell et 

al. 2009, Lofroth et al. 2010). The environmental analysis should be revised to distinguish 

between areas with dense canopy cover and the importance of this type of habitat to fisher.

[Comment Number: 3-20]

Response: Measurement of canopy cover estimates in Mazzoni (2002) and Purcell (2009) did not 

use the same methodology as in the KREW Project, which is based on Forest Vegetation 

Simulation (FVS) modeling. According to Purcell et al. (2009), their estimates for canopy cover 

at fisher resting sites (average: 73.7 percent) are based on field methods (i.e., moosehorn) that 

overestimate canopy cover relative to FVS model methodology. The calibrated canopy cover 

estimates based on FVS is 64 percent canopy cover (Purcell et al. 2009), and the range of fisher 

studies in the southern Sierra Nevada is 58 percent to 69 percent (based on FVS model 

estimation; see Purcell et al. 2009 for table of studies). 
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We concur that research shows fisher rest and den sites tend to have high canopy cover (Purcell et 

al. 2002, Truex et al. 1998). However, research also has shown that canopy cover composition 

throughout fisher home ranges is variable, including some areas with low canopy cover (Mazzoni 

2002; Zielinski et al. 2004). Therefore, a “one size fits all” formula of canopy cover across the 

entire landscape is not an ecologically appropriate management guideline. For example, 

extrapolating the canopy cover needs of den and rest sites across the entire landscape is not 

addressing other needs of an animal, such as prey abundance which in some cases may require 

more open canopy cover. 

Landscape topography is one element that substantially influences wildlife habitat use patterns, 

such as Pacific fisher (Underwood et al. 2010). For example, habitat types in riparian areas and 

lower slopes are much different than ridge tops and upper south facing slopes, and their use is 

different. The KREW Project strives to incorporate topography in its design, which is supported 

by Underwood et al. (2010). The preferred management strategy is to maintain or maximize 

canopy cover in portions of the landscape, while allowing for localized reductions in canopy 

cover over other portions of the forest landscape (e.g. ridge tops) to enhance forest heterogeneity, 

understory diversity, tree regeneration, and habitats for prey species. 

KREW management retains high canopy cover over large portions of the area inhabited by fisher. 

For example, 50 percent of the Providence management area will not be thinned, thus the higher 

canopy cover of those areas will be retained. And the other portions of the landscape that will be 

thinned will return to their pre-treatment canopy cover through time as tree canopies grow. Our 

analysis also shows that 75 percent to 100 percent of the 2010 fisher home range and den buffer 

areas will have at least 60 percent canopy cover (CWHR Class D) immediately after treatment, as 

well as 30 years post-treatment (FEIS Section 3.9.4.4 and Terrestrial Wildlife BABE Section 

3.3.4.5). 

The KREW management retains adequate areas of high (e.g. >55%) canopy cover as well as 

other areas of moderate (e.g. 40-55%) canopy cover to support the various needs of Pacific fisher. 

It is important to remember that clearcutting is not proposed; rather only some portions of the 

project area will be thinned to a moderate canopy cover and those areas will continue to have

forest cover that provides suitable habitat for fisher foraging and other uses. Our management 

also retains and develops important fisher habitat features throughout the project area such as all 

trees greater than 30 inches dbh, most trees 20-30 inches dbh, most snags greater than 15 inches 

dbh, and all oaks. 

As stated in the KREW DEIS and FEIS Section 3.9.4.4 and the December 2010 Wildlife BABE 

Section 3.3.4.5 and the February 2011Wildlife BABE Section 3.3.4.5, our proposed management 

for all action alternatives retains, as well as promotes further development of fisher rest sites 

above and beyond the 17 per acre recommended as a minimum by the Fisher Sustainability 

Analysis Tool (FAST) (USDA Forest Service 2009). And contrary to the analytic model stated 

by the commenter, we will not be reducing the average canopy cover to 35-40 percent, but instead 

will initially reduced the average to about 53 percent (in the Providence area) with subsequent 

natural regrowth after treatment, but this is only an average and large portions will have higher 

cover of not thinned at all. 

Our management provides adequate fisher rest structures and canopy cover to sustain the Pacific 

fisher, while also reducing other serious short and long-term threats to the fisher population that 

includes lack of habitat heterogeneity, death of oak trees due to coniferous tree competition, and 

the potential for forest stand replacing wildfires, which would be a highly serious threat to the 

fisher population. These and other elements of the KREW project alternatives are a balanced 

approach to sustaining fisher habitat and fisher populations while also meeting our other public 

service mandates, directives, goals and objectives.
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It is also important to note that the research projects reporting canopy cover preferences for fisher 

were conducted within limited habitat conditions of forests, with limited ages and past history 

(i.e. a snap shot in time of some managed forests with a limited set of habitat quality) and may 

not reflect the full range of habitat variability that historically sustained fishers through time. For 

example, historical forest conditions supported fishers for thousands of years, and those forest 

conditions most likely included areas of relatively open forests (due to frequent low intensity 

wildfires) with large live and dead tree structures, as well as patches of high canopy cover (Agee 

et al. 2007; North 2006; North and Keeton 2008; Skinner and Chang 1996; Stephens 2004;

Stephens et al. 2007). The high density of fishers in more open forests of the Kern Plateau gives 

some indication of the variability of canopy cover needed by Pacific fisher populations. Further 

research is needed to determine that natural range of canopy cover habitat variability that best 

supports fishers and their prey species. 

All forest ecosystems are dynamic, and have always been so, and the fisher has evolved with that 

dynamic and ever-evolving matrix of habitat types and canopy cover. This project proposes 

limited forest thinning (not clearcutting) and the retention and further growth of all large trees and 

nearly all large snags. Our comprehensive analysis shows that the preferred alternative is not 

expected to significantly affect the long-term sustainability of fishers. Specifically, the preferred 

alternative is affecting less than 1 percent of the total habitat of the southern Sierra Nevada fisher 

population and our cumulative effects analysis (DEIS and FEIS Sec. 3.9.4.3 and 3.9.4.4 and the 

December 2010 and February 2011 Wildlife BABE 3.3.3 and 3.3.4) has shown that this proposed 

project, combined with other past, present and foreseeable future actions, including those on the 

adjacent Southern California Edison private lands, will not significantly affect the fisher.

TW-6. This analysis is important at both the home range and rest site scales. At the home 

range scale (e.g., across the planning area) the BE (p. 106) reports that the existing canopy 

cover in the KREW unit is approximately 57 percent. This is somewhat lower than the 

above research indicates is favorable for fishers. The Proposed Action and alternatives 

reduce this canopy cover to approximately 49 percent. Because this area is actively used by 

female fishers, the desired or favorable condition for fisher would be to maintain or 

increase canopy cover. [Comment Number: 3-21]

Response: Please see response to TW-4 [Comment Number 3-19] and TW-5 [Comment Number: 

3-20]. Also, it is important to remember that rest/den sites occur in clumps of dense canopy 

cover frequently interspersed within a mosaic of habitat types across the landscape including 

areas with less canopy cover. It is therefore consistent with fisher habitat use data specific to the 

KREW project area that the landscape-wide forest canopy cover might be less than the 60% yet 

still maintain an adequate amount of rest/den sites to support fisher populations. 

TW-7. Recent efforts to apply rest site characterizations to the prediction of rest site 

suitability across the landscape indicate that thinning treatments can significantly reduce 

the quality of rest sites. Zielinski et al. (2010) used forest inventory and analysis (FIA) data 

from rest sites to create a model predicting rest site suitability. When thinning treatments 

were applied to actual landscapes on the Sierra National Forest suitability was reduced 

significantly for treatments that imposed 30‖ or greater diameter limits and reduced canopy 

close to 35-40 percent. Less intensive treatments (e.g., 12‖ dbh limit and retention of 60 

percent canopy cover) resulted in only modest reductions in landscape level suitability for 

resting. This information and analytical tool should be used to evaluate the effects of the 

alternatives on fisher denning and resting sites. This tool could also be used to identify 

treatment units for which a less intensive treatment would benefit fishers while still meeting 

other project objectives. [Comment Number: 3-22]
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Response: As stated in the KREW DEIS and FEIS Section 3.9.4.4 and the December 2010

Wildlife BABE Section 3.3.4.5 and the March 2011Wildlife BABE Sec. 3.3.4.5, our proposed 

management for all action alternatives retains and promotes further development of fisher rest 

and den sites in an amount above and beyond the 17 sites per acre recommended by the Fisher 

Sustainability Analysis Tool (FAST) (USDA Forest Service 2009) (Section 3.9.4.4 FEIS and Sec. 

3.3.4.5 BABE). And contrary to the analytic model stated by the respondent, we will not be 

reducing the average canopy cover to 35-40 percent, but instead the preferred action will initially 

reduced the average to about 53 percent (see response to TW-4) in the area inhabited by fishers, 

including large portions of the area with canopy cover greater than 50-60 percent including 50 

percent of area fish habitation area will not be thinned at all (Section 3.9.4.4 FEIS and Sec. 

3.3.4.5 BABE). 

Our management provides adequate fisher rest structures and canopy cover to sustain the Pacific 

fisher, while also reducing other serious short and long-term threats to the fisher population that 

includes lack of habitat heterogeneity, death of oak trees due to coniferous tree competition, and 

the potential for large scale stand replacing wildfires, which would be a highly serious threat to 

the fisher population. These and other elements of the KREW Project alternatives are a balanced 

approach to sustaining fisher habitat and fisher populations while also meeting our other public

service mandates, directives, goals and objectives.

TW-8. The proposed changes to the den site buffer management were not analyzed in the 

DEIS or BE. Two changes are proposed for all alternatives. First, the limited operating 

period is shortened while simultaneously being applied over the entire project area. This 

has the likely limited benefit of reducing disturbance to undetected den sites. The benefit is 

limited in this case because fishers are intensively surveyed, collared and tracked in the 

project area. The potential for undetected fishers to be denning in the project area is low.

[Comment Number: 3-23]

Response: As stated in response to TW-3 [Comment Number: 3-2], we have added a new 

subsection, with maps and tables, to the FEIS (Sections 3-9.4.3 and 3-9.4.4) as well as the 

Terrestrial Wildlife BEBA (Section 3.3.4.5) to further document our assessments of the affects of 

the project on fisher home den buffer habitats. Pertaining to the first point made by the 

commenter, the current Forest Service Limiting Operating Period (LOP) standard is limited to 

den site buffers only; however, for this project we have provided additional protection to the 

fisher by implementing a similar LOP across the entire project area in the event that researchers 

are not able to capture and radio-collar all female fishers in the area. And, we have substantial 

assurance from the last three years of fisher research in and around the project area (Craig 

Thompson, 2011 pers. comm.), that by moving the ending date of the LOP from June 30 to June 

15, we will be avoiding the most vulnerable denning period and the period when denning females 

and kits are least mobile for avoiding treatment activities. 

TW-9. The second change is to eliminate the restriction to treat only surface and ladder 

fuels within den buffers that occur in the wildland urban interface (WUI). There is no 

assessment of the specific location of the den buffer(s) and the management activities 

proposed within the buffers(s). The effects of reducing or degrading habitat quality on 

specific den sites are not evaluated. [Comment Number: 3-24]

Response: As stated previously (Response to TW-3 [Comment Number: 3-2]), we have included 

a more detailed analysis of fisher den site buffer habitats and the expected changes as a result of 

each of the action alternatives (FEIS Sections 3.9.4.3 and 3.9.4.4 and Terrestrial BABE3.3.4.5). 

TW-10. There is no analysis demonstrating that treatment within den site buffers is 

necessary to ―achieve fuels objectives for the urban wildland intermix zone‖ (USDA Forest 

Service 2004, p. 61). [Comment Number: 3-25]
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Response: Treatments within the den site buffer are needed as part of our holistic approach to 

reducing the potential for wildfires that could start in, or sweep through, this particular portion of 

the urban wildland intermix zone. Loss of large portions of fisher habitat, such as what has 

recently occurred in Sequoia National Forest, is a very serious threat to the long-term 

sustainability of fisher, thus fuels treatment in these types of areas is an important part of our 

comprehensive landscape approach for reducing wildfire risk.

The Conservation Biology Institute (CBI) conducted a computer simulation study of the 

interactions between fuels management, forest fires, fisher habitat, and the fisher population in 

the southern Sierra Nevada (Spencer et al. 2008). The study area included the Stanislaus, Sierra, 

and Sequoia National Forests and Yosemite and Sequoia-Kings Canyon National Parks. This 

transparent, objective, and highly collaborative process was guided and informed by input from a 

group of independent science advisors and stakeholders. 

Results of the simulations demonstrated that treatments may effectively reduce the extent and 

severity of fire on the landscape over a 50-year time span. Given the right combinations of 

treatment rate, intensity, and location, the benefits to fishers of reducing fire outweigh the 

cumulative negative effects of the treatments themselves on fishers. Across the broad spatial 

scales CBI examined, given specific assumptions disclosed in Spencer et al. (2008) about how 

thinning treatments affect fuel characteristics, fire spread rates, and fire severity, and within the 

finite combinations of fire regimes and treatments tested, it was concluded that the long-term 

positive effects of fuel treatments (due to the reduction of fire hazard) outweigh the short-term 

negative effects of fuel treatments (due to immediate loss of forest biomass) on fisher. This was 

especially true assuming a more severe fire regime in the future. Truex and Zielinski (2005) 

documented an expected short-term detrimental habitat changes for fishers as a result of fire and 

fuels reduction treatments. Spencer et al. (2008) places the tradeoffs of short-term habitat 

degradation for long term benefit in clear context for the southern Sierra Nevada fisher population 

and habitat as a whole, demonstrating specific conditions where short-term detriment for longterm habitat maintenance is acceptable. 

TW-11. The DEIS should analyze the effects of implementing the direction in the forest plan 

for den buffer management and determine if treatment within the buffer is necessary to 

meet fuel objectives. [Comment Number: 3-26]

Response: The purpose and need of the project was not only to reduce the potential of wildfire 

but also to improve forest health and conduct research. The research was designed specifically to 

assess the effects of various thinning treatments on hydrology and water quality, thus some 

flexibility is needed in our standard and guidelines to allow the strict timelines and management 

measures need for quality research. Without allowing this flexibility to conduct research on 

variable forest management, we are not rightfully following our public mandate to use the best 

information and adapting our management to accomplish our public mandates. And as a 

secondary benefit to this research, the PSW Kings River Fisher Study, which began in 2007, will 

be monitoring and assessing how the proposed management modifications will affect fishers, 

providing valuable insights for the design of future management and conservation actions. 

TW-12. The den buffers were explicitly intended to remain in effect ―long as habitat 

remains suitable or until another Regionally-approved management strategy is 

implemented‖ (USDA Forest Service 2004, p. 61). A forest plan amendment for den buffer 

management was already been granted on the Sierra National Forest in 2010. We expect the 

forest to not make further exceptions to den buffer management. [Comment Number: 3-27]

Response: The Non-significant amendments requested for fisher densite buffers is not a serial 

approach for the Sierra National Forest management team. On the contrary, the Sierra National 

Forest has followed those den site buffer standard and guidelines for vegetation management 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 46

projects since they were developed, except for unique research projects: the Sugar Pine Adaptive 

Management Project in 2010 and the Kings River Experimental Watershed (KREW) Project in 

2011. These particular projects require some management flexibility, and strict timelines, to 

allow us to adequately conduct reliable forest research that is needed for our forest management 

responsibilities. Without some flexibility in these guidelines, projects such as these multi-million 

dollar research projects would lose substantial public investments and valuable data collection 

opportunities would be lost. It is also important to note that in both these instances Sierra 

National Forest went well beyond the current fisher conservation standard by implementing an 

LOP across the entire project areas, rather than limiting it to only in the den site buffers. Also, 

please see response to AB-2 [Comment Number: 3-5].

Sierra National Forest will continue to consider using non-significant Forest Plan amendments 

when management and research justifies the need and environmental analysis shows the effects to 

be limited and reasonable to sustain the species. Forest land management is a complex process 

that requires us to test and assess the best approaches to management and that in-turn allows us to 

meet the many obligations we have as federal land stewards and managers.

TW-13. The simple inference in the BE (p. 110) suggesting that perceived habitat stability 

on the Sierra National Forest combined with an ―increasing spatial distribution‖ indicates 

that management activities have not reduced suitability should be revised in light of the 

above information.

Management activities are estimated to negatively influence habitat quality and such effects 

can have subtle and long lasting impacts to individuals. Small populations, such as this 

fisher population, are especially at risk to disturbance. This risk to species persistence is not 

adequately disclosed or mitigated in the DEIS.

The above information should be considered in evaluating the potential effect of 

management on persistence of individual fishers and the population dynamic as a whole.

[Comment Number: 3-28]

Response: The Sierra National Forest understands the importance of sustaining fisher 

populations. We plan and design our management to address the conservation of that species as 

well as other wildlife species and other forest resources and uses, we are not proposing 

clearcutting forests with the KREW Project, instead we are proposing forest thinning that also 

retains majority of the forest biomass, including all large trees and nearly all moderate sized trees 

20-30 inches dbh, as well as many smaller trees, all oak trees, and all large snags unless deemed a 

safety hazard. We also included extensive areas (50 percent) of no thinning management within 

the project area. Additionally, our cumulative effects analysis has taken into consideration past, 

present and foreseeable vegetation management in and around the project area (DEIS and FEIS 

Sections 3.9.4.3 and 3.9.4.4 and the December 2010 Wildlife BABE Sections 3.3.3 and 3.3.4), 

and it shows that the Proposed Actions will reduce only 12 acres of fisher habitat, which is 0.8 

percent of the fisher habitat in the project area; 0.05 percent fisher habitat within a 3.1 mile buffer 

of the project area; 0.03 percent of the Kings River Project Area; and 0.003 percent of the 

Southern Sierra Nevada fisher population area. This analysis includes past, present and 

foreseeable future vegetation management projects, such as the adjoining private lands, as well as 

projects on Forest Service lands. Through this design, planning, and analysis we have not found 

any reason to believe that our management will imperil the local fisher population nor the 

Southern Sierra Nevada fisher population as a whole. On the contrary, this management helps 

ensure fisher habitat, and the fisher population will be sustained on this landscapes for the future. 

TW-14. The KREW Wildlife BE’s analysis of impacts to Pacific fishers and Spotted owls 

relies on the statement (p. 14 of Wildlife BE) that, within ―California spotted owl and 

Pacific fisher habitat areas‖, the Forest Service would ―limit thinning to 20‖ or less 
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Sierra National Forest 47 4/7/2011

diameter‖ under Alternative 2, and that the Proposed Action, Alt. 5, would incorporate Alt. 

2’s requirements within the boundaries of the experimental watershed. However, in the 

DEIS’s description of Alt. 2, I could find no reference to a 20‖ dbh limit in Pacific fisher 

and Spotted owl habitat areas. In fact, the DEIS’s description of Alt. 2 (DEIS, pp. 2-36 

through 2-38) specifically states that trees up to 30 inches in diameter would be removed in 

the thinned areas under Alt. 2. [Comment Number: 4-5]

Response: Thank you for brining this to our attention. The reference to spotted owl and fisher 

habitat areas (p. 14 of Wildlife BE) is incorrect and should have only referred to spotted owl 

PACs. That statement has been corrected in the Wildlife BABE. The original statement did not 

have any bearing on the assessment of project affects on fisher habitat. 

Also in the DEIS and FEIS, Chapter 2 Section 2.3.1.1, all action alternatives include a “Spotted 

Owl Nest Buffer Thin” where only ladder fuels less than six inches dbh will be thinned. The 

DEIS and FEIS, Chapter 2 Sections 2.3.2.2, 2.3.4.2, and 2.3.5.2 also include a prescription that 

treatments would “retain 1 – 2 acre “fisher rest sites” within stands of CWHR size class 5M, 5D, 

and 6. Fisher rest sites are pockets of large diameter trees (>24 inches) key fisher resting habitat 

attributes (large trees with pockets of decay, dense canopy, proximity to water).”

TW-15. The problem is that the determination of the 2001 and the 2004 Sierra Nevada 

Forest Plan Amendments, that their prescriptions would still ensure the viability of the 

Pacific fisher, were based upon the assumption that the protections for fishers found in the 

Standards and Guidelines of the 2001 and 2004 forest plans would be followed. Since it is 

now clear that the Sierra National Forest does not intend to follow those Standards and 

Guidelines designed to ensure fisher viability, and since the fisher only lives in the southern 

portion of the Sierra Nevada, on Sierra and Sequoia national forests generally, this 

development fundamentally undermines the conclusions of the 2001 and 2004 forest plans 

that they would ensure Pacific fisher viability in the Sierra Nevada. In light of this, the 

forest plan amendments proposed in this project are not ―non-significant‖; rather, they are 

highly significant amendments which would require, under NEPA, a complete re-analysis of 

the entire fisher analysis contained in the 2001 and 2004 Sierra Nevada Forest Plan 

Amendments. Without such an analysis, the Forest Service cannot determine that these 

amendments will not jeopardize the Pacific fisher populations, threaten their viability, or 

cause a trend towards federal listing under the ESA. [Comment Number: 4-12]

Response: The response to TW-12 [Comment Number: 3-27] is also applicable for responding to 

this comment. Additionally, our cumulative effects analysis has taken into consideration past, 

present and foreseeable vegetation management in and around the project area (DEIS and FEIS -

Section 3.9.4.3 and 3.9.4.4 and the December 2010 Wildlife BABE – Sec. 3.3.3 and 3.3.4). That 

analysis shows that the Proposed Actions will reduce only 12 acres of fisher habitat immediately 

after treatment, which is 0.8 percent of the fisher habitat in the project area; 0.05 percent fisher 

habitat within a 3.1 mile buffer of the project area; 0.03 percent of the Kings River Project Area; 

and 0.003 percent of the Southern Sierra Nevada fisher population area. Through this project 

design, planning, and environmental analysis, we have not found any reason to believe that our 

management will imperil the local fisher population nor the Southern Sierra Nevada fisher 

population as a whole. On the contrary, this management helps ensure fisher habitat, and the 

fisher populations will be sustained on this forested landscapes through future decades. 

TW-16. The DEIS (p. 3.9-28 and p. 3.9-46) claims that Table 3-9-3 divulges all of the other 

logging projects—past, present, and reasonably foreseeable future projects—within the 

Kings River Project Area (100,000 acres). However, Table 3-9-3 shows no such thing; nor 

could I find any other table in the DEIS which reveals the cumulative effects, including 

current and future effects from other adjacent/nearby projects within the 100,000-acre 
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Sierra National Forest 48

area. The DEIS fails to include a cumulative effects analysis of adverse impacts on Pacific 

fishers and California spotted owls within the 100,000-acre KRP area from past, present, 

and reasonably foreseeable similar logging projects, such as the current Dinkey North and 

Dinkey South logging projects, and the proposed (and reasonably foreseeable) East Fork 

and Soap Root projects, portions of the latter of which would abut portions of the KREW 

Providence section. [Comment Number: 4-13]

Response: The DEIS reference to Table 3.9.3 on pages 3.9-28 and 3.9-29 was intended to 

reference Tables 3-1 through 3-4 of the DEIS, and that has been corrected in the FEIS, including 

reference to the past, present and foreseeable actions described in Section of 3.4. The Cumulative 

Effect section on pages 28-31 of the KREW DEIS is only a summary review of past, present and 

foreseeable actions relevant to all alternatives, thus a subheading has been added to the FEIS to 

clarify that section. 

Contrary to the commenter‟s assertion, detailed cumulative effects analysis was provided for 

Pacific fishers, California spotted owls and the other wildlife species in the DEIS (Section 3-

9.4.4). There are five pages of cumulative effects assessments of the fisher (pages 3.9-45 through 

3.9-49 of the DEIS) and two pages of cumulative effects assessment for spotted owl (pages 3.9-

36 through 3.9-38 of the DEIS) – they are provided under the subheading entitled “Cumulative 

Effects.” Additional detailed cumulative effects assessments also are included in the December 

2010 KREW Wildlife BABE Section 3.3.4 for each species, for all alternatives. To assist the 

reader however, we have now summarized more of the cumulative effects analysis shown in the 

Wildlife BABE, as well as more details of the direct and indirect effects and brought them into 

the KREW FEIS (Sections 3.9.4.3 through 3.9.4.4) to help assure no further confusion.

The cumulative effects analysis includes assessments at multiple scales, including at the project 

area buffer scale, Kings River Project Area or Ranger District scale; and at the subpopulation 

and/or regional scale. This analysis uses GIS vegetation information updated with the effects of 

other current and foreseeable projects that have reliable vegetation change estimates, such as the 

Dinkey North and South, Soaproot, East Fork, and 10S18 projects. Please refer to the 

“Cumulative Effects” sections within each alternative subsection of the Wildlife BABE for 

detailed information.

TW-17. Project documents fail to adequately disclose and discuss the fact that patches of 

high-intensity fire support very high levels of native biodiversity and many wildlife species 

depend upon such habitat (Hutto 1995, Hutto 2006, Noss et al. 2006, Hanson 2010, Swanson 

et al. 2010). Instead, the DEIS inaccurately implies that high-intensity fire patches are 

simply something to be avoided and prevented at all costs. There is no sound scientific basis 

for this. [Comment Number: 4-16]

Response: The statement by Noss et al. (2006) that species diversity is often highest following a 

natural stand-replacement event (e.g., fire), is based on a broadly generalized statement by 

Lindenmeyer and Franklin (2002) that encompasses forest ecosystems of the world, not 

specifically any forest type in the Sierra Nevada or even the western United States. Within Sierra 

Nevada mid-elevation forests, biodiversity of plants, fungi, and wildlife is not greatest in highseverity burned patches, but is maximized in diverse landscapes that incorporate a matrix of burn 

severities, forest seral stages (including managed forests), and most importantly, habitat diversity 

(Graber 1996, Wayman and North 2007, Meyer et al. 2008, Kennedy and Fontaine 2009, Vierling 

and Lentile 2009). This includes prey species for sensitive forest species, such as Pacific fisher 

and California spotted owl (Waters and Zabel 1998, Roberts et al. 2009) and species dependent 

on high severity burned patches (Kennedy and Fontaine 2009, Kotliar et al. 2009). Similarly, 

Hutto (1995) pertains specifically to northern Rocky Mountain forest ecosystems and its 

applicability to Sierra Nevada forest ecosystems is highly limited. 
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Sierra National Forest 49 4/7/2011

Swanson et al. (2010) does provide an informative general summary of the importance of earlysuccessional ecosystems in forested landscapes. However, this review is broadly applied to 

forested ecosystems throughout the world and incorporating different disturbance regimes. The 

importance of these early-seral stages for Sierra Nevada mixed-conifer and Ponderosa pine 

forests are limited in spatial scale, where the majority of high-severity patches are typically less 

than 1 acre in size (Stephenson et al. 1991, Piirto and Rogers 2002). 

Our fuels management is designed to reduce the risk of uncharacteristic, large scale stand 

replacing wildfires. We call such wildfires uncharacteristic because if wildfire occurred within 

our present forest conditions, in many locations, they could erupt into an intensity and size not 

typical for the natural range of variability prior to when fire suppression began. For 

approximately 100 years most fires were suppressed and fuels built-up in our forests significantly 

increased greater than during the historic natural range of variability. Therefore, without 

moderate fuels reduction practices, by prescribed fires and thinning (such as the KREW action 

alternatives), many wildfires would burn more intensely and at larger scales than typical for the 

natural range of variability, thus significantly reducing the amount of mature and older forests 

over years or decades of time and also potentially threatening the viability of many wildlife 

species dependent on those habitats, such as fisher and spotted owl. Small scale high intensity 

burns have developed occasionally on the Sierra National Forest either through prescribed fire or 

occasional wildfires, thus this type of burn does exist. And these types of small scale, high 

intensity burns create some forest heterogeneity and possibly greater biological diversity within 

forests that are otherwise monotypic in age, structure and plant species, yet the risks for 

substantial looses to our nation‟s public national forests are also are too great to extensively 

promote high intensity burns given the current condition of our forests and the potential risk to 

residences and other forest uses. Thus we manage our National Forest with a more realistic and 

pragmatic sustainable ecosystem management approach. This management includes conservation 

of wildlife species and other natural resources, fuels management, protection of private and 

public property, and providing sustainable commercial harvest to support our local economies. 

Our fuels management is only one part of a comprehensive forest management program that 

manages for multiple national forest uses in a balanced, sustainable manner. Also, please see 

responses to TW-18 [Comment Number: 4-17] and TW-19 [Comment Number: 4-18].

TW-18. The DEIS’s sections on the California spotted owl (DEIS, pp. 3.9-7 through 3.9-8, 

3.9-21 through 3.9-22, and pp. 3.9-32 through 3.9-37 fail to adequately divulge or analyze 

the fact that recent research reveals that California spotted owls preferentially select 

unlogged high-severity fire patches for foraging, while selecting unburned or low-severity 

areas for roosting (Bond et al. 2009); and the DEIS erroneously implies (DEIS, p. 3.9-22) 

that patches of high-intensity fire would be wholly negative for Spotted owls. High-intensity 

fire patches enhance habitat (e.g., montane chaparral, large downed logs, snags) for the 

Spotted Owl’s small mammal prey species (Bond et al. 2009). The most recent scientific 

evidence makes clear that Spotted Owls benefit from natural heterogeneity created by 

patches of high-severity fire—habitat that is not mimicked by logging. Unlogged highintensity fire patches, with their rich array of montane chaparral and high abundance of 

large snags and downed logs (which, again, is not mimicked by logging), provide suitable 

foraging habitat for Spotted Owls (Bond et al. 2009), and the Project documents are obliged

to acknowledge this. [Comment Number: 4-17]

Response: Please see response to TW-17 [Comment Number: 4-16] as well as the following.

There is an important distinction between habitat use and habitat suitability. Bond et al. (2009) 

only addresses the former, as no information related to California spotted owl demography or 

occupancy rates or habitat quality measures were evaluated in this brief study. Moreover, the 

results from Bond et al. (2009) are highly limited due to (1) extremely low effective sample size 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 50

(e.g., owl pairs are not independent during the nesting season), (2) lack of pre-fire data, and (3) 

lack of information as to whether studied owls were inexperienced population „floaters‟ or prefire residents, and (4) limited sample size, area, and extent of vegetation plots. Consequently, not 

all high-severity burned areas can be considered suitable habitat for California spotted owls. 

A more robust analysis of the effects of wildland fire on California spotted owl site occupancy 

and densities in Yosemite National Park demonstrates that this species is not negatively impacted 

by fire if sites are dominated by a patchwork of unburned, low-severity, and moderate-severity 

patches (Roberts et al. 2011). Areas exposed to large patches of high-severity fire and lacking 

suitable basal area and canopy cover are characterized by lower rates of spotted owl occupancy. 

High-severity fire also makes up a small portion of the burned landscape, primarily in smaller 

patches approximating historical conditions. Spotted owl occupancy is most consistently and 

positively associated with basal area and canopy cover. Therefore, it is reasonable to assume that 

forest restoration treatments (including wildland fire) that maximize these features and enhance 

stand and landscape heterogeneity will be most effective at promoting habitat for California 

spotted owl.

TW-19. The DEIS (p. 3.11-20) misrepresents two studies, Verner et al. (1992) and Spencer 

et al. 2008, falsely claiming that these studies ―clearly indicate that high severity fire 

threatens Pacific fisher and California spotted owl habitat‖. As discussed in the paragraph 

above, recent research establishes that California spotted owls preferentially select 

unlogged high-intensity fire patches for foraging. The DEIS is obviously cherry-picking 

and distorting scientific data to justify the proposed logging. Moreover, Verner et al. (1992) 

never investigated the relationship between Spotted owls and high-intensity fire—it merely 

assumed that there would be a negative relationship. It has now been scientifically 

established—by a study which did directly investigate the relationship—that this 

assumption was incorrect. Similarly, Spencer et al. (2008) did not directly investigate the 

relationship between Pacific fishers and unlogged patches of high-intensity fire. Rather, it 

merely assumed that there would be a negative relationship. While this issue requires 

further study, it is worth noting that, in the most recent Pacific fisher detection surveys 

conducted by the Forest Service (Rick Truex’s study) across the whole of the fisher’s range 

in the southern Sierra, i.e., in 2009, the highest occupancy rates were on the Kern Plateau, 

most of which has burned in wildland fire—much of it high-intensity—during 2002-2004, 

and very little of which was salvage logged after the fire. A number of the detections were 

inside the fire perimeters, even in high-intensity fire areas. The Kern Plateau was dropped 

from the fisher surveys inexplicably in 2010 for the first time since the study began in 2002. 

It should also be noted that, like California spotted owls, Pacific fishers evolved with an 

active fire regime of mixed-intensity fire, including high-intensity fire patches. Also, the 

Pacific fisher’s diet is predominantly comprised of small mammal and other prey species 

that are more associated with montane chaparral, dense pockets of conifer regeneration, 

snags, and downed logs—i.e., the type of habitat created by high-intensity fire—rather than 

with closed-canopy old-growth forest (Zielinski et al. 1999). [Comment Number: 4-18]

Response: Pacific fisher and California spotted owl are adapted to the low-severity, relatively 

high-frequency fire regimes of Sierra Nevada mid-elevation forests (e.g., mixed conifer, 

Ponderosa pine; Skinner and Chang 1996). Mixed-severity fire regimes are typically found in 

upper montane forests (Collins and Stephens 2010) that are considered low-quality habitat for 

these sensitive species. Therefore, it is reasonable to assume that these sensitive species are not 

adapted to larger patches of high-severity fire that are historically common in upper montane 

forests but relatively rare in mid-elevation forests.

The high severity fire that the DEIS refers to is not small “high-intensity fire patches,” in contrast, 

the DEIS refers to uncharacteristic large scale, stand replacing wildfires to which our present day 
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Sierra National Forest 51 4/7/2011

forests are susceptible to as a result of decades of fire suppression. Our fuels management 

program attempts to reduce those types of uncharacteristic large scale events. There is a 

significant difference between the high-intensity patches that the commenter refers to and those 

of large scale stand replacing wildfire that could develop within the current excessive fuels buildup in many areas of our national forests. Sierra National Forest also manages for a many public 

services, needs and uses, such as recreation, ecosystem management, water quality, protection of 

private and public property, and sustainable wood products to support local and regional 

communities. Our fuels management program needs to blend with, and provide for, those other 

services, needs and uses. Our management takes these, as well as wildlife habitat conservation 

and management, into consideration when designing, developing and implementing a balanced 

approach to national forest management.

TW-20. The DEIS completely fails to indicate that there would be adverse impacts of the 

Project on the Black-backed Woodpecker, which is the only MIS bellwether species for all 

wildlife species associated with snags in heavily burned forest. This habitat type is very 

ecologically important, and supports high levels of native biodiversity (Swanson et al. 2010). 

The Project would affect Black-backed Woodpeckers for two reasons. First, recent science 

shows that pre-fire logging, consistent with the type of mechanical (commercial) thinning 

proposed in this Project, substantially reduces habitat suitability for Black-backeds even if 

the affected area later burns in a wildland fire, likely due to reduced potential densities of 

large snags upon which the birds forage (Hutto 2008, Hutto and Hanson 2009). [Comment 

Number: 4-19]

Response: We did not assess black-backed woodpeckers because black-backed woodpecker 

habitat is not within the project area. Studies conducted by the USDA Pacific Southwest 

Research Station found that on the Sierra National Forest, black-backed woodpeckers inhabit 

high elevation lodgepole pine forests at low densities, they appear to breed successfully there, and 

this habitat does not appear to be sink habitat (Purcell, 2011 pers. comm.). In the Sierra Nevada, 

black-backed woodpeckers also are associated with high-severity burns, but not dependent on 

them (Purcell, 2011 pers. comm.). Sierra National Forest‟s management sustains this woodpecker 

species, particularly considering that we have approximately 32,000 acres of high elevation 

lodgepole pine forests and a large portion of that habitat is conserved within the Wilderness 

Areas. 

TW-21. The DEIS predicts that the Proposed Action would serious reduce or totally 

eliminate the potential for moderate or high severity fire (passive or active crown fire) in 

the thinned areas. Black-backeds depend upon areas burned at higher fire severities (Hutto 

2008). Further, the Project would threaten the viability of the Black-backed Woodpecker 

by further reducing potential habitat across the landscape. The MIS Report does not even 

include a section analyzing the impacts of the Project on the Black-backed Woodpecker. 

This is an especially serious analytical omission given that the Sierra National Forest is the 

only national forest in the entire Sierra Nevada that does not have a single patch of 

unlogged moderate/high-severity burned forest that is large enough and recent enough to 

provide enough habitat for even one single high-quality Black-backed Woodpecker 

territory (generally at least 300 acres of moderate/high-intensity burn area, unlogged, less 

than 8 years old for one pair) (see, e.g., Siegel et al. 2010 monitoring results, finding only 

one fire area, North Fork fire of 2002, that could potentially contain Black-backeds on the 

Sierra N.F., and finding no Black-backed occupancy there). [Comment Number: 4-20]

Response: Please see response to TW-20 [Comment Number: 4-19].

TW-22. The mechanical thinning and prescribed fire treatments described in the EIS will 

meet the research goals of KREW and provide data on forest restoration. The KREW 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

Appendix I

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research treatments are patchy, with minimal disturbance to habitat for any species of 

concern. KREW research is designed to assess positive, negative, and neutral effects of 

forest restoration activities that could be used by state, private, and federal land managers 

on the Sierra Nevada. Hence information about disturbance to habitat (and its negative 

impacts on species) will be useful, to the extent that it informs how not to implement 

restoration. [Comment Number: 9-4]

Response: We concur and appreciate your approval of this very important research.

TW-23. Either way information from the treatments will be illuminating, and worth the 

small risks to the fisher, the Yosemite toad, and the spotted owl (for example). It’s worth 

pointing out that treatments in the Bull Creek watersheds will have no impact on the fisher 

because the watersheds are too high in elevation to support the fisher. In the case of the 

Yosemite toad, FS-sponsored research in the area should help keep track of and thus 

minimize impacts to this species of concern. Similarly, although the Providence Creek 

watersheds lie within fisher and owl habitat, it has been monitored by the Pacific Southwest 

Research Station (PSWRS) for more than 10 years, so it should be possible to minimize 

impacts to both the spotted owl and the fisher, as well as the Yosemite toad. [Comment 

Number: 9-5]

Response: We concur. The value of this forest management research will be highly valuable, 

and there will be relatively small risks to those three species, as our assessments have found, and 

studies will monitor the effects.

TW-24. A scaled-down silviculture prescription chosen over an evaluation of short-term 

and long-term effects of forest restoration is pointless and not worth the investment. The 

main objective of KREW was to acquire effective and important data on damaged 

ecosystems by taking designed and acknowledged risks to improve forest conditions. The 

KREW Project will benefit a diversity of ecosystem components and should not focus on a 

single or a few species of current concern. [Comment Number: 11-4]

Response: We concur. This research only involves forest thinning, not clearcutting, and large 

portions (50 percent in the Providence area) of the project area will not be treated with thinning. 

And our assessment of this thinning has shown that the research project will not threaten the 

viability of species and will provide some long-term benefits to help sustain them on the 

landscape. 

TW-25. The SNAMP Pacific Fisher Team is also collaborating with fisher research at the 

KREW site to expand their knowledge of the status of fisher population in the southern 

Sierra Nevada. Response of fisher to fuels and forest health treatments is the main objective 

of SNAMP research, and treatments at the KREW site could potentially increase the 

inferences able to be made about the relationships between forest treatments and fisher.

[Comment Number: 17-3]

Response: We concur. The KREW project provides valuable additional information, within a 

different area, on the effects of forest management on fisher, which will be important for 

sustaining that species over the long-term.

TW-26. CAL FIRE is confident that the prescribed fire and thinning treatments have been 

designed to adequately protect all state and federally listed wildlife species. The intense 

data collection on fuel loading and vegetation in KREW project area will provide useful 

data for modeling and species habitat information. Dr. Hunsaker, her staff, and project 

cooperators have shown that any risk from the treatments will not be long term or 

substantial, and is acceptable given the new information the research will provide on many 

aspects of the forest ecosystem. [Comment Number: 18-4]
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 53 4/7/2011

Response: We concur.

TW-27. Sensitive Species Management: ....This natural condition will make the forest more 

resilient to the changes in the environment. The Pacific fisher and California spotted owl 

are both considered sensitive species by the USFS. ...These species have shown their own 

resilience and will continue to thrive with this management. The process to make their 

forest home more resilient will improve the condition for both the forest and the species that 

depend on it for their livelihood. Therefore restoring the forest will improve the habitat 

quality for those species living in the forest. This study has the potential to prove this while 

doing nothing may continue the degradation /loss of the forest habitat when the inevitable 

catastrophic wildfire reduces the habitat to ash. [Comment Number: 22-6]

Response: We concur.

Soils

S-1. At the end of paragraph 3 on p. 1-7, ―soil productivity‖ is not in Appendix E. Where is 

it? [Comment Number: 2-13]

Response: The reference to Appendix E at the end of paragraph 3 on page 1-7 of the FEIS is 

referring to the 2001 Sierra Nevada Forest Plan Amendment (SNFPA 2001). Please see 

SNFPA, 2001, Volume 4, Appendix E, page E-111 to E-113.

S-2. In Table 2-12 on p. 2-66 under soils the DEIS says no detrimental soil disturbances are 

expected. If that is the case, then why should you collect data regarding soil carried by 

water in the research component? A set of novel hypotheses need to be offered to the public 

so we can see the validity of plans for the research. [Comment Number: 2-31]

Response: No detrimental soil disturbance refers to ground disturbing activity that would exceed 

soil quality standards. The proposed project research goals includes answering soil management 

questions and filling key soil productivity information gaps that were originally proposed in the 

2001 SNFPA as opposed to designing their research based on hypothesis. These key soil 

productivity information gaps are stated in Chapter 1 - Purpose of and Need for Action, Section 

1.3 - Background, Key Soil Productivity Gaps of the FEIS. These questions address 

understanding natural background rates for soil health/productivity, including shallow soil water 

chemistry, erosion and sediment rates, and soil and litter characteristics (soil porosity, O horizon 

thickness). The research design including questions related to soil health and productivity is 

further discussed in Chapter 3-8, Affected Environment and Environmental Consequences, 

Research of the FEIS. More specific research measurements are listed in Appendix A - Research 

Measurements of the FEIS.

Vegetation and Silviculture

VS-1. Throughout the document where wood waste disposal is addressed, there’s no 

mention of removal as an option. With the Biomass Crop Assistance Program likely to 

restart shortly, there may be an opportunity where the BCAP Matching Payment program 

can overcome the cost of transportation to move wood waste to a biomass powerplant 

rather than masticating or piling and burning. Therefore the option of removal should be 

included in the DEIS. (Additional information presented on emissions of burning vs.

biomass). [Comment Number: 1-3]

Response: The Draft EIS discusses biomass removal as an opportunity. Pages 2-10 and 3-11 of 

the Draft EIS refer to biomass removal; however biomass removal is contingent on sufficient 

value or appropriated dollars to accomplish the removal. In addition, the research design requires 
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Sierra National Forest 54

the use of conventional logging within research watersheds. Conventional logging systems leave 

the tops and limbs of harvested trees in the woods and bring the bole (log) to the landing. 

Harvested trees within research watersheds preclude biomass (generally). Outside of research 

watersheds mechanical whole tree harvests can be used. Typical mechanical harvest systems 

leave the tree tops and limbs attached to the tree bole until they arrive at the landing. Mechanical 

harvest systems provide an opportunity for biomass. The description of treatments will be 

clarified to discuss the use of conventional harvests vs. typical mechanical harvests and the 

opportunities for biomass.

VS-2. In Table 2-12, p. 2-61, Alternative 2 is shown to involve the ―inverse J curve concept‖. 

We believe that is not a valid concept and that since Alt 2 and Alt 4 are combined into the 

Alternative 5 ―hybrid‖, that Alt 5 is thus not valid. [Comment Number: 2-27]

Response: Valid or reasonable (CEQ terminology) alternatives are those that address the purpose 

and need for action (see CEQ regulations 40 CFR 1500.2, 40 CFR 1502.14 and 1505.1 which 

establishes the responsibility to consider and document reasonable alternatives in the EIS 

process). The uneven-aged system responds to the needs of ecological restoration, increase 

resilience to insect attack and reduce potential fire severity. The DEIS currently displays that the 

treatments proposed in Alternative 2, 4 and 5 do indeed address and respond to the purpose and 

need. On page 2-35 the DEIS discusses the intent of the alternative relative to the purpose and 

need. The analysis contained within chapter 3 of the DEIS discusses how well the alternative 

meets the purpose and need relative to analysis indicators. While examples of how well each 

alternative (including Alternatives 2 and 5) meet the purpose and need can be found throughout 

the document, the fire and fuels Chapter 3.2 provides an example of how the uneven-aged 

methodology is responsive to the desired condition to reduce potential fire severity. The analysis 

on page 3.2-16 and 3.2-17 discusses the effects on fire severity. Figure 3-2 and Table 3-2-4 of 

this analysis indicates that fire severity is reduced for all action alternatives. Similar analysis of 

effects can be found throughout the DEIS.

The CEQ provided additional guidance (40 questions) to a reasonable range of alternatives; CEQ 

indicated that a reasonable range is those that are within the capability of the agency. 

Reasonable alternatives include those that are practical or feasible from the technical and 

economic standpoint and using common sense, rather than simply desirable from the standpoint 

of the applicant (question 2a of forty questions). The High Sierra Ranger District has applied the 

uneven-aged treatments on two projects most recently (1996) that include the 10S18 project and 

Big Creek ecological recovery project.

The uneven-aged system is used to achieve the desired condition (restoration, research, fuels 

reduction). While the uneven-aged inverse J system is used, it has been modified to achieve the 

desired conditions relative to both structural restoration, and fuels reduction. Specifically 

uneven-aged system incorporates 1) regeneration in openings (this mimics historic regeneration 

patterns), 2) protection of fisher rest sites, 3) creation of multistoried stands (heterogeneity at the 

stand scale -important for wildlife), 4) reduces surface and ladder fuels, 5) retention of large trees 

> 30”.

The uneven-aged system is a regeneration system. Removals are tied to insuring a continuous

supply of trees in all age/size classes. Tree removals are often called individual tree selection; 

however this individual selection system has been modified to create regeneration in clumps or 

existing openings. Growing space is allocated across all age/size classes and in clumps (openings) 

when possible and results in a characteristic inverse J distribution. There are no intermediate 

treatments, unlike an even-aged system where regeneration and intermediate treatments 

(thinning) occur at distinct or discrete time frames. Tree removals are geared to creating a 
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structure consistent with historic forest and 2004 LRMP guidelines. Reentry would occur when 

tree density exceeded thresholds for density and insect induced mortality are exceeded. 

In contrast GTR-220 uses a multiaged silviculture or structures where as few as two age/size 

classes are promoted. Multiaged silviculture is a subset of uneven-aged silviculture, but is not 

constrain by a particular distribution. It is important to note that the tools need to implement this 

multi-aged system have yet to be created (leaf area index). Thus we remain with existing 

prescriptive tools (basal area and stand density index) to allocate tree growing space. A flat tree 

distribution is proposed to allocate tree growing space. Tree removals are not tied to creating 

opportunities for regeneration, but rather on what should remain relative to key species (fisher or 

owls) and reintroducing fire when possible. This type of tree removal would be called a “free 

selection” in silviculture and is applied to achieve ecological restoration. Where fire cannot be 

reintroduced at a return interval sufficient to maintain structures, then treatments by necessity 

would occur repeatedly. Heterogeneity is created at both the stand and landscape scale to create 

resilience in the face of drought, fire, pollution and insects.

GTR-220 is silent on regeneration, but does not preclude and particular silviculture system. GTR220 does specifically call out in inverse j-curve. In particular the inverse-j shaped tree 

distribution resulting from the encroachment of shade tolerant conifers in mixed conifer forest is 

called out as in appropriate. This distribution is used in the traditional use of the inverse j-curve:

The reverse-J diameter distribution prescribes a stand structure with a surplus of small trees and 

limited space for large trees. Such a distribution is inconsistent with historical Sierran mixedconifer forests where fire reduced small-tree abundance while retaining fire-resistant, largediameter trees (north and others 2009).

The uneven-aged system proposed in KREW avoids the effects of traditional uneven-aged 

systems on forest structure by retaining large trees, allocating high proportion of growing space to 

large trees and reducing small trees consistent with fuels hazard reduction and wildlife needs 

(fisher need small trees).

VS-3. In Table 2-12 on p. 2-65 many trees up to 30 inches would be removed under the 

Alternative 4 prescription. Since Alternative 4 is to be based on North et al., 2009 (GTR220), it would seem that only smaller trees (like 12 inches) should be in that prescription. 

The rationale seems unclear. Furthermore, the tree numbers for Alternatives 2, 4, and 5 

seem inconsistent. These numbers need to be clarified with explanation. [Comment 

Number: 2-30]

Response: In Chapter 2 Section 2.3.2.2, Alternative 2 describes the researcher‟s conceptual vision 

of how tree removal decisions would be made (2-48) to achieve ecological restoration. A set of 

criteria/priorities and tree density retention guidelines for application of GTR-220 has been 

developed. The tree density guideline reflects the recommendation of GTR-220 to create 

landscape heterogeneity and is displayed on page 3-11.16 table 3-11-3. 

Tree removals in Alternative 4 are focused on retaining and improving shade intolerant pine and 

oak, increasing landscape heterogeneity and reducing fire severity. A set of criteria to help guide 

forest workers in moving from concept to application appears in Appendix B of the KREW 

Vegetation and Silviculture Specialist Report. A summary of these criteria will be incorporated 

into the FEIS.

A review of the number of trees represented throughout the document for removal indicates that 

DEIS Table 2-12 page 2-65 represents trees removed and trees remaining following treatments 

are consistent with most other tree removal numbers presented in the DEIS. The exception is 

DEIS Table 3-9-7 on page 3.9-26 that in correctly shows the removal of trees larger than 35”. 

This error will be corrected in the Final EIS. 
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VS-4. The DEIS (p. 1-10) states: Currently these conifer stands are well above normal 

stocking levels (stand densities) resulting in a decline in growth, vigor and resiliency thus 

increasing a stand’s potential for higher rates of mortality. The data presented in Appendix 

D does not support this claim. Current stocking levels for about 21 percent of the area to be 

treated are less than 60 percent SDI max (DEIS, Appendix D). 

This data does not support the claim that stocking is ―well above normal stocking levels.‖ 

Furthermore, the concern expressed about ―higher rates of mortality‖ fails to recognize the 

benefits of tree mortality and density related defects that could lead to the development of 

living and dying trees with attributes that are important to the creation of denning and 

resting sites for fishers. [Comment Number: 3-7]

Response: The term normal stocking is inappropriately used and creates confusion related to the 

relationship of tree density and relative risk of insect attack and poor tree vigor. The Sentence 

should have read - Currently these conifer stands are well above the zone of density mortality 

(lower limit of self thinning) resulting in a decline in growth, vigor and resiliency thus increasing 

a stand’s potential for higher rates of mortality.

The DEIS displays and discusses the existing condition relative to stand density on pages 3-11-

12. The DEIS indicates that 83 percent of the project is at an elevated risk of density and insect 

mortality, 36 percent (83 percent-48 percent) at an eminent risk and 17 percent (100 percent-83

percent) at low risk. Following application of treatments in the action alternatives, the acres 

subject to low risk of insect mortality range from 31 percent to 25 percent of the project area 

(treated and untreated areas). The resulting areas subject to density induced mortality range from 

69 percent to 75 percent of the project area. That is that a majority of the project area would 

remain at tree densities that can created snag habitat.

VS-5. We note that since 2006 basal area has increased or decreased more than 70 units for 

some stands and reflect up to a 37 percent change for a given unit from 2006 conditions. We 

would like to follow up with your staff to understand the factors that caused these 

differences in the data sets and how this translates to stand conditions. [Comment Number: 

3-14]

Response: There are differences between the data presented in the 2006 KRP FEIS and the 

KREW DEIS. The differences are due:

1) A higher resolution mapping of vegetation was used to display patches (polygons) of 

vegetation used in summaries of forest parameters (e.g. Basal Area) and computer 

simulations.

2) Stand and tree data collected by Pacific Southwest researchers was used to represent data 

within research watersheds. Researchers collected data on an intensive grid. This 

research collected data replaced stand exam data used in the 2006 FEIS.

3) Computer models were used to grow data from 2006 to present time.

VS-6. Setting aside the inconsistency of the proposed treatments with the forest plan, the 

completion of the proposed activities within 500 feet occupied meadows (Sanders 2006) is 

not necessary to increase forest resilience, reduce the risk of uncharacteristic fire, or 

address public health and safety.

The occupied meadows are located primarily in Units 811, 838, and 1057. Current stand 

densities range from 45 to 49 percent of SDI max. These densities are well below the lower 

limit of self thinning (i.e., 60 percent SDI max) and are not at high risk of density induced 
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Sierra National Forest 57 4/7/2011

mortality. The predicted fire type for the current condition in the areas around occupied 

meadows (DEIS, p. 3.2- 20) also indicates that fire risk is not extreme. A rough comparison 

of the occupied habitat map (DEIS, p. 3.7-47) and the fire type map indicate that surface 

and conditional fire is estimated to occur near these meadows under extreme weather 

conditions. This means that under more commonly encountered fire weather conditions fire 

type would be even less of a concern.

Further, as indicated from an examination of the fire type maps for any alternative, there 

are collateral benefits to adjacent untreated areas from the treated areas. That is to say, the 

occupied meadow and its buffer will benefit from treatments adjacent to them and this will 

affect predicted fire types in the treated and untreated areas. Thus, the treatments within 

the 300-foot RCA around these meadows or a 500-foot buffer around a meadow occupied 

by Yosemite toad are not necessary to address forest health or fire risk concerns. [Comment 

Number: 3-32]

Response: The DEIS identifies two threshold levels for density induced and insect mortality: 35 

percent of maximum SDI and 60 percent of maximum SDI. Please see response to VS-7 

[Comment Number: 4-15] for a more complete description of limiting density. While the average 

SDI ranges from approximately 50 to 44 percent of maximum SDI. This average rating does not 

capture that local tree density exceeds the 60 percent of maximum SDI across approximately 30 

to 42 percent of stand acres for stands 811, 838, and 1057. These areas are at a “high” risk to 

density induced mortality. The upper threshold describes a density when density induced 

mortality is imminent. That is when tree density exceeds this level trees are at extreme risk. The 

lower limit of 35 percent of maximum identifies a tree density when trees are at an elevated risk 

to density induce mortality. The average stand condition reflects stands that are at an elevated 

risk to density induced mortality. However, portions (42 to 31 percent) are at extreme risk to 

density induce mortality. In addition, the areas above the lower threshold continue to pose a risk 

of mortality to pine species that are experiencing more mortality compared to their frequency in 

the KREW tree population.

A similar analysis of the area subject to high severity fire and crown fire (passive, active, and 

conditional) indicates that large percentages of these stands remain at risk to high severity fire 

and crown fire. High severity fire could occur in the existing condition on approximately 30 

percent to 60 percent of these stands. Similarly approximately 30 to 55 percent of stands could 

experience some fire crowning under severe fire conditions.

Treatments seed to meet the purpose and need to reduce fire severity, increase resilience, and 

restoration. 

VS-7. The DEIS (p. 3.11-21) misrepresents the scientific data by inaccurately claiming that 

limiting SDI and maximum SDI are the same, citing Oliver (1995). In fact, Oliver (1995) 

specifically and explicitly states that limiting SDI (365) has a much lower value than 

maximum SDI (SDI-max) for ponderosa pine-dominated forests, and presents data in Fig. 1 

of Oliver (1995) showing many ponderosa stands with SDI values at or near the SDI-max of 

571. The misrepresentation of limiting-SDI and SDI-max in the DEIS is the same 

misrepresentation that was found to be illegal on August 5, 2009 by the federal district 

court in the Champs case (Case No. 2:08-cv-01897-JAM-JFM). The Forest Service’s motion 

for reconsideration, based upon the Oliver declaration, was denied November 20, 2009. The 

decision was not appealed. Moreover, in the ponderosa pine plots in California within 

natural forest stands (i.e., not plantations), the densest plots increased to basal areas well 

over 200 square feet per acre with very little beetle mortality (5-10 percent of basal area, on 

average, every decade or so) after the stands reached about 85 years of age (Oliver 2005, 

Fig. 1). The stands in the Project area are mostly natural forests generally over 85 years of 
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age. By erroneously equating limiting-SDI with SDI-max, the DEIS creates the false 

impression that the existing stands are far denser than they really are—i.e., a false 

impression that they are at a much higher proportion of the ―maximum‖ SDI than they 

really are, and that, therefore, there is much more competition between trees than there 

really is. Nowhere does the Project data predict, under the No Action, levels of future beetle 

mortality higher than the basal area mortality that would occur directly from the Proposed 

Action from chainsaws themselves. [Comment Number: 4-15]

Response: The DEIS does not equate maximum SDI and limiting SDI. Rather the DEIS 

discusses the distinction between endemic insect mortality, limiting density and the transition 

between these tree densities and there relation to maximum SDI. DEIS Page 3-11-21 states “The 

transition from endemic insect mortality occurs well before the maximum SDI is reached (Oliver, 

W 1995, Oliver and Uzoh 1997).” However, the commenter incorrectly explains the use of 

maximum SDI identified by Oliver. Oliver clarified the distinction made in his research.

First, the Court states: “SDI-Max and limiting-SDI are . . . distinct scientific concepts with

fundamental differences.” This is not correct. SDI-Max and limiting-SDI are closely related

concepts, particularly when it comes to managing ponderosa pine in California. In California, 

the “limiting SDI” of 365 referred to in my 1995 paper is effectively the maximum SDI, since 

bark beetles constrain the density of pines. As a result, it is common in the silvicultural profession 

to refer to 365 as the maximum SDI for ponderosa pine in California, rather than the “limiting 

SDI.” While the terms “SDI-Max” and “limiting-SDI” can have different meanings in certain 

contexts, it is neither scientifically nor professionally incorrect to use 365 as the maximum SDI 

for ponderosa pine in California. 4. Second, because it is proper to use 365 as the SDI-Max for 

ponderosa pine, Joseph Sherlock correctly states in his paper “Integrating Stand Density 

Management with Fuel Reduction” that “Bark beetles define ponderosa pine’s maximum SDI at 

365 . . . .” This finding did not mischaracterize my 1995 paper, but instead recognized that the 

limiting SDI of 365 becomes the practical maximum SDI where bark beetles are present.

The DEIS uses SDI as an index or indicator of density induced mortality and insect mortality. 

Stands at higher percentage of SDI are at greater risk of both insect attack and density induced 

mortality. These episodic waves of mortality are often triggered by drought or snow damage. 

Oliver in his 1997 research indicates that tree mortality in thinned stands ranged from 7 percent 

for open grown trees to 30 percent in thinned stands left in dense condition. In another study 

Oliver (2005) found that within thinned stands mortality increased after 10 to 20 years. 

Guarin and Taylor (2005) found that in unthinned mixed conifer stands, similar to those found in 

the project area, mortality due to drought and insects ranged from approximately 39 percent to 59

percent. This study also found that ponderosa pine and white fir where most often killed. Guarin 

and Taylor (2005) also found that the tree density (trees ha_1) of standing dead trees, which is an 

index of recent tree mortality, was also much higher in the Sierra Nevada study site than in forests 

with an active fire regime (similar to restoration objectives for the project). On average, the Sierra 

Nevada forests studied have >100-fold more dead trees (mean = 730 trees ha_1) than Baja 

California forests (3–23 trees ha_1) with the average plot contain approximately 2 snags per acre. 

In another study, Macomber and Woodcock 1994 found that within one drought and insect 

episode (1988-1991) in Northern Sierra Nevada white fir forest that 15 percent of standing 

volume was killed. Approximately 10 drought cycles have occurred over the last 100 years.

Another study by Grulke and others (2009) describes the progress of mortality during severe 

drought cycles. After the chronic drought in the San Bernardino Mountains (2002), bark beetles 

attacked, and there were clusters of tree mortality. However, the average stand tree mortality rate 

was near 0 percent. After the chronic and severe drought, tree mortality (primarily ponderosa 

pine) from both bark beetle and drought increased to approximately 5 percent at the stand level. 
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Sierra National Forest 59 4/7/2011

In the spring following the wet winter, bark beetle populations reached epidemic proportions, and 

42 percent of the stand had died. 

While past mortality episodes in forest similar to KREW project area provide a range of mortality 

(see above), a study by Mantgem and Stephens 2007 indicates that the tree mortality rate has 

increased over the past two decades in temperate forests of the Sierra Nevada at a rate of 

approximately three percent per year. 

The episodic nature and intensity of tree mortality described by studies for other California 

forests are indicative of the types of mortality that can or have occurred in the project area. These 

studies also indicate that tree density, insects, pollution and drought (similar to trees grown under 

the no action alternative) create a synergy that leads to the decline of tree vigor and a 

predisposition to fire severity (Grulke and others 2009). 

While proposed treatments in action alternatives remove trees and reduce tree density and 

improve tree vigor, the no action alternative allows stands to increase in tree density waiting for a 

drought cycle and eventual mortality at rates far higher than forests with fire regimes and forest 

structures that are consistent with the forest restoration purpose and need. Droughts will come 

and tree density will increase. Increasing stress from tree density, pollution and climate change 

will result in increased tree mortality. Tree mortality of 15 to 50 percent basal experienced in the 

past by similar or neighboring forests may actually be low estimates of mortality. A wildfire 

would result in additional mortality. 

In contrast proposed treatments under action alternatives remove from 0 to 23 percent of stand

basal area. 

However, this simple metric (basal area changes) does not capture the fundamental differences in 

tree physiology that occur between vigorous trees growing in less dense forests (like action 

alternatives) and those grown under increasing tree density (like the no action). Grulke and 

others (2009) summarized this fundamental loss in tree vigor.

VS-8. These projects are designed to restore a healthy forest stands and naturally 

functioning ecological processes across a large landscape while treating a large area of 

forest with unacceptably high fuel loading. As the project documents amply demonstrate, 

conifer forests in the Southern Sierra Nevada will be affected by catastrophic wildfires 

sooner or later if forest fuels are not treated. Similarly, if overstocked stands are not 

thinned to appropriate densities, some combination of drought, disease, or insects will 

destroy the most desired components of the forest as has happened over the past few years 

on the San Bernardino NF. The Clear Creek Project on the Sequoia NF also burned in the 

summer of 2007 before planned and contracted fuel treatments could be completed because 

of litigation. [Comment Number: 13-2]

Response: The analysis in the EIS reflects the need for thinning and fuels reduction (see tree 

density effects and fire severity effects in the vegetation section) and additional analysis will be 

added that compares the effects of the no action and action alternatives tree density and mortality 

to the San Bernardino National Forest insect mortality.

VS-9. Tree Size: In order to adequately conduct full uneven-aged management, all tree 

sizes should be part of the management. While this was discussed in the DEIS, it appears 

that trees over 30‖ DBH will not be managed. During the first entry, it may work to only 

manage trees less than 30‖ DBH. In future entries some larger trees in the stands should be 

harvested for good stand development, habitat enhancement, and fire protection. Without 

the removal of key trees over 30‖ DBH, large trees will stagnate due to competition. The 

stand health would eventually suffer from this lack of management. [Comment Number: 

22-3]
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Sierra National Forest 60

Response: Please see response to VS-2 [Comment Number: 2-27] above.

VS-10. Pre-European: The goal is to restore the forest to pre-1850 conditions. This was a 

pine dominated forest with far less of an incense cedar and white fir component. The only 

way to achieve this conversion is to harvest large percentages of cedar and fir of all sizes. 

Leaving these trees behind in abundance will maintain high canopy closures and a seed 

source for these shade tolerant trees. This combination of canopy and see will ensure the 

continued abundance of these species. [Comment Number: 22-4]

Response: We agree that removals should be focused on intolerant species and the improvement 

of pine and oak health and vigor. The DEIS identifies this emphasis on pages 2-27 and 2-28. 

Tree removals in Alternative 4 are focused on incense cedar and fir. This emphasis on removal of 

shade tolerant species is found on page 2-48.

VS-11. Adaptive Management: We hope that future entries using adaptive management 

are planned since multiple entries over time are needed to manage a forest. Some lessons 

will be learned during the first entry that can be improved on for future treatments. If a 

plan is not in place for some future stand treatments something must be put into some 

USFS process, if not into this DEIS itself. [Comment Number: 22-7]

Response: There are no current plans for future entries. Future treatments will be based on the 

condition and plans at that time. However, the Regional Forester for Region 5 directed that 

treatments should be planned so there effectiveness lasts 20 years (Blackwell 2004). As the 

effectiveness of treatments wane additional treatments could be planned as they become “ripe” 

for decision. 

Additional Comments

Adequacy of Data and Analysis 

AD-1. In rebuttal to Chad Hansen’s contrarian positions, I thought Hugh Safford in the 

Regional Office had prepared a rebuttal that was available to all Forests to use in NEPA 

documents such as the KREW DEIS. Do you have access to the Hugh Safford paper? 

[Comment Number: 1-4]

Response: The SNF has been in communication with Hugh Safford and relevant information has 

been gathered to use while considering responses to comments on the DEIS.

AD-2. ―Management Direction‖ on p. 1-4 suggests the 2004 Framework is final. Isn’t 

litigation over that is still in progress? [Comment Number: 2-11]

Response: Although the 2004 Framework ROD was litigated and a revised EIS is being written, 

the DEIS accurately reflects that prior to a new ROD being signed the 2004 ROD is operative and 

the 2004 ROD is the management direction that we are currently using.

AD-3. On p. 2-15 the DEIS says 7.4 miles of road construction. But Table 3-5-4 (p. 3.5-12) 

shows only 0.9 mile of construction and 3 miles of reconstruction. These values are 

contradictory. [Comment Number: 2-19]

Response: The FEIS has been corrected to show that there is no new road construction and the 

appropriate number of miles of reconstruction in both pp. 2-15 & 16 and in the Economics 

Section.

AD-4. In the second section of Table 2-12 on p.2-62, it might make more sense to have 

actual values rather than percentages. [Comment Number: 2-28]
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Response: The IDT for the project considered your suggestion and determined that percentages 

were a useful way of conveying the information. Percentages are presented to incorporate 

recommendations in GTR-220 to increase the proportion of large trees “Stand treatments that 

significantly reduce the proportion of small trees and increase the proportion of large trees 

compared to current stand conditions will improve forest resilience” (North and others 2009).

AD-5. Because the Forest Service violated NEPA in adopting the 2004 Framework, logging 

projects that implement and rely upon the 2004 Framework are also contrary to law [see 

e.g., Klamath Siskiyou Wildlands Ctr. v. Boody, 468 F.3d 549, 562 (9th Cir. 2006), Northwest 

Ecosystem Alliance v. Rey, 2006 WL 44361, at *8 (W.D. Wash. 2006), Citizens for Better 

Forestry v. USDA, 2009 WL 1883728, at *13 (N.D. Cal. 2009)]. Thus, to the extent that the 

KREW Project implements any of the changes to the 2001 Sierra Nevada Forest Plan 

Amendment made by the 2004 ROD, the project is contrary to law.[Comment Number: 3-4]

Response: The commenter expresses concern that projects predicated on the 2004 Framework 

decision violate NEPA and NFMA. August and September 2008 court decisions found “that the 

2004 Framework complied with the provisions of the National Environmental Policy Act (NEPA) 

and the National Forest Management Act (NFMA), except to the extent that the 2004 Framework 

was implemented without sufficient review of alternatives other than the chosen option.” Judge 

England‟s November 2009 ruling (United States District Court Eastern District of California No. 

2:05-cv-00205-MCE-GGH Memorandum and Order dated 11/04/09) denied the request to enjoin 

the Forest Service from continuing to develop projects based on the 2004 Framework but rather 

required the violation to be addressed by development of a supplemental EIS (which is underway 

and currently out for public comment) and by requiring future fuels reduction projects to have a

non-commercial funding alternative. The 2004 Framework can legally be used as the basis for 

projects as long as the project complies with Judge England‟s November 2009 ruling. The 

KREW project, which has a fuels component in the purpose and need, contains a non-commercial 

funding alternative (Alternative 3) which is compliant with Judge England‟s instructions in the 

November 2009 ruling and therefore the project is not contrary to law as asserted.

AD-6. There are inconsistencies in the maps and table presented that make it difficult to 

understand the area being affected by the treatments. For instance, Table 1-2 (DEIS, p. 1-

13) indicates the following information:

Reported in Table 1-2 (acres)

Providence

Thinned inside experiment 183

Thinned outside experiment 741

Total 924

Bull

Thinned inside experiment 494

Thinned outside experiment 250

Total 744

Grand total 1,668

This summary does not appear to match the area affected reported in the tables in Chapter 

2. For instance, Table 2-4 reports a total of 1,715 acres being thinned. The tables in 

Appendix D reflect a third characterization of the area affected; the total area in that 

appendix proposed for tree removal is 2,169 acres. [Comment Number: 3-11]

Response: All of the Tables describing the treatment acres will be double checked and verified 

numbers will be included in the FEIS. The treatment acre discrepancy noting 15 acres out of 

1670 is 0.9 percent of the treated area and 0.4 percent of the acres in the Project area. The Tables 

in Appendix D reference a different project – the Kings River Project. Appendix D is presented 
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Sierra National Forest 62

to help the public understand the concept of the pre-1850 forest condition and the design of 

Alternative 2. The numeric treatment acres are reflective of the specific project being discussed 

in the paper and not the KREW Project. Although the paper discusses a different project, the 

SNF believes that the paper‟s concepts have applicability to the KREW project.

AD-7. The map of ―timber sale units‖ (Figure 2-1) also appears to be different from the 

tables or summaries mentioned above and other maps in the DEIS. For instance, Unit 299 is 

reported to have 103 acres in Figure 2-1, whereas Table 2-4 reports this as 129 acres of 

thinning and 28 acres with no thinning. Figure 2-1 also includes units that are not 

referenced elsewhere (e.g., Unit 6, 31 acres) and units appear in tables but are not indicated 

on this map (e.g., Unit 306 is in Table 2-4 and Appendix D, but does not appear on a map). 

The ―timber sale unit‖ map is also different from the other maps in Chapter 2. For 

example, the areas to be thinned shown in Figure 2.8 (DEIS, p. 2-42) are, in some cases, 

more extensive than the areas shown in Figure 2-1 and in other cases less extensive.

[Comment Number: 3-12]

Response: We agree that figure 2-1 contains stand numbers that do not appear in other sections of 

DEIS. The map was intended to display locations of tree removal across each stand. Stand 

numbers presented on figure 2-1 reflect a stand identification used for field crews and not 

presented elsewhere in the document. The FEIS will correct the stand identification scheme to be 

consistent with other EIS sections.

AD-8. Given these types of discrepancies in the data being presented, it is difficult to assess 

the impacts of the project on the environment. It also calls into question the data that used 

in the biological evaluation to evaluate impacts on sensitive resources such as fisher and 

Yosemite toad. We ask that the DEIS be revised to present a consistent and clear 

description of the alternatives, including detailed maps and tables characterizing the area 

affected. [Comment Number: 3-13]

Response: Please see AD-3 [Comment 3-11] to clarify the perceived conflicts between Appendix 

D and Treatment Tables in the DEIS. There is an apparent misunderstanding of the use of 

Appendix D. Figures in Chapter 2 (Figure 2-1 and 2-2) display what is called “Unit IDs” these 

are different units than Plan IDs used elsewhere in the document. To clarify the project the FEIS 

will reflect a consistent use of Plan IDs which are the units on which the analysis was based. The 

alternatives and all the figures in Chapters 1, 2 and the intro to 3 were reviewed for consistency 

and clarity. All figures in the Chapters mentioned were replaced with figures that are clearer. 

The Tables in Chapter 2 have all been reverified for accuracy and consistency.

AD-9. We do not believe that the KREW DEIS adequately addresses the comments we 

submitted during scoping. [Comment Number: 3-35]

Response: The commenter expresses concern that their scoping comments were not adequately 

addressed. It was the intent of the SNF to include all significant issues in the DEIS for analysis. 

As per FSH 1909.15 Chapter 10 p. 4 states:

“There shall be an early and open process for determining the scope of issues to be addressed and 

for identifying the significant issues related to a Proposed Action. This process shall be termed 

scoping . . .

(a) As part of the scoping process the lead agency shall:

(1) Invite the participation of affected Federal, State, and local agencies, any affected Indian tribe, 

the proponent of the action, and other interested persons (including those who might not be in 

accord with the action on environmental grounds), unless there is a limited exception under 

§1507.3(c). An agency may give notice in accordance with §1506.6.

(2) Determine the scope (§1508.25) and the significant issues to be analyzed in depth in the 

environmental impact statement.
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 63 4/7/2011

(3) Identify and eliminate from detailed study the issues which are not significant or which have 

been covered by prior environmental review (§1506.3), narrowing the discussion of these issues 

in the statement to a brief presentation of why they will not have a significant effect on the human 

environment or providing a reference to their coverage elsewhere. ...”

The SNF has gone through a methodical process, (documented in our project record), to identify 

the issues displayed in Section 1.8 of the DEIS. The SNF read and considered every scoping 

comment and consolidated the individual issues into the overarching issues presented in the DEIS 

which were approved by the Forest Supervisor. These issues were followed throughout the 

document and analyzed.

AD-10. The DEIS does not meet the stated purpose and need, fails to develop a reasonable 

range of alternatives that address the issues, and fails adequately to disclose impacts.

[Comment Number: 3-36]

Response: The SNF believes that the DEIS meets the requirements of NEPA in that the 

reasonable range of alternatives displayed in the DEIS flows from the stated needs winnowed by 

the stated purposes of the Project described in Chapter 1 of the DEIS. These alternatives address 

the issues within the scope of the purpose and need and the DEIS analysis accurately discloses the 

impacts to relevant resource areas. (See summary in Table 2-12 supported by the analysis in 

Chapter 3 resource sections.)

The three components of the need for the project are: restoring a resilient forest, protecting public 

health and safety through fire and fuels reduction and obtaining necessary knowledge about the 

effects of forest treatments on the ecosystem. All of these needs must be met for an alternative to 

be part of the DEIS and ultimate FEIS however the relative degree to which an alternative meets 

these three components can vary. The research need is met to the greatest extent by Alternative 2 

and Alternative 5 as the most potential ground disturbance utilizing a common forest treatment is 

likely to provide the most useful information. (See Section 3-8 and Table 2-12.) The Fire and 

Fuels need is met equally across all alternatives however treating below the level described in the 

DEIS, which has been suggested by commenters, does not fully meet the Fire and Fuels need and 

meets only a small component of the other needs for the Project. (See Section 2.4 of the FEIS for 

a more complete explanation for why an alternative that does not fully meet the Fire and Fuels 

objective was not analyzed in detail.) Alternative 3 was designed to range on the outskirts of 

meeting the forest resiliency need and the need for knowledge while fully meeting the need for 

Fire and Fuels reduction and public health and safety. Alternative 3 is the non-commercial 

funding alternative and is required to be included in all analyses for which fire and fuels reduction 

is a need. Alternative 4, based on GTR-220, was designed to maximize the forest resilience need 

for the project while although not maximizing the research need, the research need is met outside 

of riparian areas. GTR 220 is thought to be the current “best science” addressing treatments for 

forest health.

Alternative 5 fully meets the Fire and Fuels need (health and safety), the Forest Health/resiliency 

need and the need for more knowledge and understanding. Alternative 5 forest treatments are 

modeled after the ROD for the 2004 SNFPA and thought to be representative of one of the 

common forest thinning practices.

By varying the alternatives to emphasize fully meeting one need while minimizing other needs 

the SNF has created the outer boundaries of the range of alternatives with Alternative 5 meeting 

all of the needs.

The three identified issues crystallized from the scoping comments were: (1) The effect of 

removing 20 – 30 inch dbh trees to wildlife species; (2) the effect of the alternatives on the 

viability and habitat of wildlife and aquatic species and (3) the effects of the use of herbicides on 

people and wildlife. Alternative 3 only allows trees to be cut up to 20 dbh and uses no herbicide 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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Sierra National Forest 64

so the effects of issues 1 and 3 will be demonstrated by comparing Alternative 3 with the other 

action alternatives. As Alternative 3 has the lightest touch on the land while still meeting part of 

the purpose and need for the project it also reflects the issue of minimizing effects on the viability 

and habitat of wildlife and aquatic species. Alternative 4, due to its sensitivity to aspect and slope 

is also thought to be a wildlife sensitive approach. The effect of the alternatives on species 

viability and habitat is addresses in detail in Sections 3-7 (Aquatic Biota) and 3-9 (Terrestrial 

Wildlife). The effect of 20 – 30 inch dbh tree removal, herbicide risk and viability and habitat of 

terrestrial and aquatic species are summarized in DEIS Table 2-12 and FEIS Table 2-16 (which 

replaced DEIS Table 2-12). 

The SNF has done a detailed impact analysis of a variety of resource areas that potentially could 

be affected by the alternatives. Please see DEIS and FEIS Sections 3-1 through 3-12 and DEIS 

Table 2-12 and FEIS Table 2-16 (which replaced DEIS Table 2-12). In summary, the DEIS and 

FEIS meet the stated purposes and needs, contain a reasonable range of alternatives which 

address the issues and discloses impacts.

AD-11. The small population sizes and limited numbers of these two species place additional 

importance of individuals to the persistence of these species. For these reasons, the proposed 

project violates the National Forest Management Act (NFMA) and direction to maintain 

viable populations across the planning area. We ask that the DEIS and alternatives be 

revised to comply with NEPA and NFMA and that a revised DEIS be circulated for public 

comment. [Comment Number: 3-38]

Response: As shown in DEIS Table 2-12 and FEIS Table 2-16 (which replaced DEIS Table 2-12) 

the action alternatives do not lead to a federal listing or loss of viability of any forest sensitive 

species or are likely to adversely affect any threatened and endangered species. The commenter 

notes that NFMA requires the maintenance of viable populations across the planning area. 

Maintenance of viable populations of forest sensitive species was the result of our analysis which 

is in compliance with NFMA. As the document complies with NEPA and NFMA there is no 

requirement for recirculation. 

AD-12. The DEIS is a mess. I do not recall seeing a DEIS with so many fundamental 

inconsistencies and basic errors on core issues. The inconsistencies are so substantial an 

numerous that they render the DEIS incomprehensible, both in terms of what the action 

alternatives would actually do, as well as in terms of the impacts of the action alternatives 

and the bases for them. [Comment Number: 4-4]

Response: The SNF acknowledges that like most draft documents, the DEIS contains errors and 

inconsistencies. A draft and comment system is designed to identify these errors and 

inconsistencies and correct them prior to a final decision being made. Some of the 

inconsistencies identified by the commenters were unfortunate misunderstandings which are 

being clarified and other commenters felt that the document was helpful, clear and informative. 

Although care was made to explain a complex project and its affects, the FEIS has been 

strengthened to clarify the alternatives and their effects as appropriate. 

As per FSH 1909.15 Chap 10 Section 18.2 (2) (c) (3) (pg 43 of 44) “Agencies: (3) Revision. If a 

draft statement is so inadequate as to preclude meaningful analysis, the agency shall prepare and 

circulate a revised draft of the appropriate portion..... (40 CFR 1502.9(a)”

The DEIS provides meaningful analysis throughout Chapter 3. The errors and inconsistencies 

cited in the comment letter are minor in relation to the 315 pages of analysis. With the volume of 

analysis there is bound to be some inconsistencies. Note that AD-19 [Comment Number: 8-1], 

AD-20 [Comment Number: 13-4], and AD-22 [Comment Number: 23-2] found the document to 

have meaningful analysis. 
Kings River Experimental Watershed Forest Health and Research Project Environmental Impact Statement

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AD-13. While the unit numbers in the DEIS’s description of alternatives section match the 

unit numbers in Appendix G of the DEIS, which presents unit-by-unit descriptions of 

reductions in basal area, stand density index, canopy cover, etc., the maps showing the 

location of the ―Timber Sale Units‖ (DEIS, Figs. 2-1 and 2-2) do not include most of the 

units in both the description of alternatives section (DEIS, pp. 2-8 through 2-59) or the units 

mentioned in App. G of the DEIS, and many of the ―Timber Sale Units‖ shown on the maps 

are not mentioned in the description of alternatives section or App. G. This error and 

inconsistency prevents the reader from knowing where, on the landscape, most of the 

timber sale units would be located, which prevents the reader from knowing where the most 

intensive logging would occur relative to the locations of Pacific fisher den sites and buffers 

and California spotted owl nest stands, Protected Activity Centers (PACs), and Home 

Range Core Areas (HRCAs), which, in turn, renders the DEIS’s analysis of adverse impacts 

inadequate under NEPA. [Comment Number: 4-6]

Response: We agree that DEIS Figure 2-1 contains stand numbers that do not appear in other 

sections of DEIS. The map was intended to display locations of tree removal across each stand. 

Stand numbers presented on DEIS Figure 2-1 reflect a stand identification used for field crews 

and not presented elsewhere in the document. The FEIS will correct the stand identification 

scheme to be consistent with other EIS sections. All the Figures in Chapter 2 have been updated 

to make them more readable and useful to the reader. An explanation of stand identifiers has 

been added to the FEIS in Section 2.1.

AD-14. App. G of the DEIS shows unit-by-unit data for the action alternatives, in terms of 

effects on canopy cover, basal area, SDI, and trees 10-20‖ and 20-30‖ dbh. However, 

nowhere does the DEIS present unit-by-unit data on the existing density of trees 10-20‖ and 

20-30‖ dbh (the DEIS, p. 3.9-26, only presents summary data on these size categories, 

averaged across the entire project area, for trees ―retained‖, and only presents unit-by-unit 

data in App. G on trees ―removed‖). Thus, we have no way of knowing the intensity of 

removal of larger trees in each unit—a factor which is essential to know, depending upon 

whether a given unit is within a Pacific fisher den site/buffer or Spotted owl PAC. Without 

this information, the analysis of impacts is simply inadequate and incomplete. [Comment 

Number: 4-7]

Response: The data of the number of trees remaining in 10-20, 20-30 sizes classes will be 

provided in the FEIS.

AD-15. I asked for the Forest Vegetation Simulator (FVS) data for the no action and action 

alternatives, including FVS outputs for a non-commercial thinning (small-tree thinning) 

alternative. While I was sent a CD with FVS outputs, these outputs correspond to unit 

numbers that do not correspond to either the units numbers on the maps in the DEIS (Figs. 

2-1 and 2-2), the unit numbers in the description of alternatives (DEIS, pp. 2-8 through 2-

59), OR the unit numbers described in App. G of the DEIS. Once again, this makes it 

impossible for the public to determine where the greatest impacts would occur relative to 

the location of core habitat for sensitive species like the fisher and spotted owl. Moreover, it 

also prevents the public from being able to verify the accuracy and integrity of the 

discussion of impacts in the DEIS relative to the FVS outputs upon which that discussion is 

ostensibly based. [Comment Number: 4-8]

Response: The data used for the FVS follows a hierarchy that allows for a detailed display of 

vegetation patches (simulation unit) within each stand for each year of the projection. The 

metadata describing each field in both the input and output was provided along with the modeling 

data requested. A description of modeling methods will be included in the project record and 
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Sierra National Forest 66

available to the public. The modeling methods report will describe how each simulation unit is 

represented in each of the project stands.

AD-16. I asked for the FVS data on this project soon after receiving the notice of 

availability of the DEIS. However, the first CD sent to me was corrupted and unusable. 

The second CD sent to me (just over two weeks before the comment deadline on the DEIS) 

was unusable for several reasons. First, as discussed above, the unit numbers did not match 

those in the DEIS. Second, the data was hopelessly jumbled. Rows of data for the units 

were out of place, and were mixed in with other units, preventing an evaluation of the data. 

Third, there was no clear identification of pre-thinning (baseline) conditions for the action 

alternatives with regard to wildland fire effects (i.e., where data was presented for 2010, or 

2012, for example, it was not clear whether that was for the pre-thinning or post-thinning 

circumstance). [Comment Number: 4-9]

Response: The metadata describing each field in both the input and output was provided along 

with the modeling data requested. The metadata labeled - krew modeling appendix 

modelingv1.docx- was made available to those who requested data. This appendix provided both 

the plan_id (unique stand identifier) used in the DEIS for each stand. The appendix provided 

also described which data was for before thinning and after thinning.

AD-17. Alternative 2 claims (DEIS, p. 2-35) to rely upon an unpublished internal memo 

from the Sierra National Forest, described as ―Rojas 2004‖, which is found in App. D of the 

DEIS, and the DEIS claims (p. 2-35) that this would restore ―historical pre-1850 forest 

condition‖. However, ―Rojas 2004‖ is just a six-page memo which ostensibly summarizes 

various historical data sets, and nowhere does the Rojas 2004 document, or the studies upon 

which it claims to rely, state that the current density of trees 24-30 inches in diameter is 

currently higher than what it was historically in the Kings River area. In fact, the cited 

studies indicate that trees over 24 inches in diameter have declined, relative to historical 

densities, in substantial part due to logging. For example, Bouldin (1999), cited in App. D of 

the DEIS, found a large decline in trees over 24‖ dbh since the 1930s in the Sierra Nevada, 

as well as a decline in trees over 36‖ dbh. Appendix D also refers to Figures H1 through H5 

to support its conclusions, but nowhere are those figures to be found in App. D or anywhere 

else in the DEIS. Without these figures, it is impossible to know the basis, or if there is a 

basis, for the conclusions in App. D and the description of Alt. 2 (DEIS, p. 2-35). [Comment 

Number: 4-10]

Response: This document was published incompletely in the KREW DEIS. The complete 

document was previously provided in all versions of the KRP NEPA analysis. The complete 

Rojas 2004 report will be reproduce in the KREW final EIS.

Rojas 2004 provides a summary of data that describes the historical forest conditions of the 

Southern Sierra Nevada.

AD-18. The DEIS claims that, for the Proposed Action (Alt. 5), units outside of the Kings 

River experimental watershed would be governed by prescriptions described for Alt. 4, 

which the DEIS claims implements the North et al. (2009) General Technical Report (GTR) 

from the Forest Service. The DEIS (p. 3.9-26, Table 3-9-7) states that, in the ―Bull‖ portion 

of the project area (about half of the proposed thinning), Alt. 5 would reduce very large 

trees over 35‖ dbh from 7/acre currently to 5/acre. The DEIS states that units within the 

Kings River experiment area would be governed by the prescriptions of Alt. 2, which has a 

30‖ dbh limit (DEIS, p. 2-36 through 2-37), and also states that, within the Bull portion of 

the project area, 494 acres would be thinned within the experimental forest area and 250 

acres would be thinned outside of the experimental forest area (DEIS, p. 1-13, Table 1-2). 

Given this, the reduction of very large trees over 35‖ dbh from 7 to 5 trees per acre, i.e., 29 
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Sierra National Forest 67 4/7/2011

percent reduction, in the Bull portion is entirely due to the 250 acres out of 744 acres 

proposed for thinning under the Proposed Action (since 494 acres out of the 744 acres in the 

Bull portion are governed by Alt. 2, which has a 30‖ dbh limit), i.e., the reduction from 7 to 

5 very large trees per acre over 35‖ dbh is an average across the entire 744 acres proposed 

for thinning in the Bull portion of the project area. This means that the proportion of the 

very large trees over 35‖ dbh that would be removed in the 250 acre portion of Bull 

ostensibly governed by Alt. 4, the North et al. (2009) GTR, would be much higher than 29

percent. Since the 250 acres governed by the North et al. GTR represent about one-third of 

the total area proposed to be thinned in the Bull portion, this necessarily means that the 

MAJORITY of the very large trees over 35‖ dbh are proposed for removal in the North et 

al. GTR portion of Bull. There is nothing in North et al. (2009) that in any way 

recommends or endorses such removal of very large old-growth trees—the very trees that 

have declined by far the most since historical times due in large part to logging. This is a 

serious misrepresentation of North et al. (2009)—a misrepresentation made even worse by 

the fact that much of this intensive logging of very large (over 35‖ dbh) old-growth trees 

would occur within California spotted owl home ranges. [Comment Number: 4-11]

Response: Locations in the DEIS which may have indicated that the alternatives include thinning 

trees up to 35” have been corrected to accurately reflect that trees will maximally be thinned to 

less than 30” dbh. Table 3-9-7 errors are corrected in the FEIS.

AD-19. Reviews of the documents indicate a thorough and complete compilation of the 

necessary information. [Comment Number: 8-1]

Response: We thank Mr. Molen for his comment that the document is adequate.

AD-20. The environmental effects of the Proposed Action are analyzed in great detail and 

appropriate mitigation measures are planned for adverse effects. We realize that there will 

always be some uncertainty over potential unanticipated effects of the Proposed Action, but 

the adverse environmental effect of ―no action‖ is far worse as documented in the record. 

Of all the environmental effects analyzed, discussion of what happens to Pacific fisher 

habitat under the no treatment action illustrates this point the best. With no stand and fuel 

treatment, the critical Pacific fisher habitat is inevitably lost to catastrophic fire, while with 

the Proposed Action there is some short term reduction in the quality of the habitat, but 

fisher habitat is maintained over its range. Similar effects are noted for other key 

environmental concerns. [Comment Number: 13-4]

Response: The SNF agrees that the effects of taking no action are more impacting on many of the 

resource areas that the effects of taking action. This formed the basis of our purpose and need.

AD-21. The Department of the Interior has received and reviewed the subject document 

and has no comments to offer. [Comment Number: 20-1]

Response: The SNF appreciates the Department of the Interior taking the time to review the 

KREW Project DEIS.

AD-22. We found the document to be very comprehensive. [Comment Number: 23-2]

Response: It is the SNF‟s intent to have a comprehensive analysis of the effects of the 

alternatives.

Technical and Editorial Accuracy

TE-1. The title on the Abstract page of this DEIS says ―Final‖ EIS. That is misleading.

[Comment Number: 2-5]
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Sierra National Forest 68

Response: Although the DEIS does have the word “final” rather than “draft” on the cover page 

information which is an error, the cover of the document and the header of every page of the 

document has the word “draft”. The SNF is certain that the one error did not mislead the public.

TE-2. The very important ―North General Technical Report (GTR)‖ (see Abstract page) is 

not in correct citation format. That needs to be corrected. [Comment Number: 2-6]

Response: The citation for the North General Technical Report has been correctly formatted in 

the FEIS.

TE-3. The Table of Contents is incomplete and has page number errors. [Comment 

Number: 2-8]

Response: The FEIS Table of Contents is complete and contains accurate page numbers.

TE-4. The brief ―History‖ section on p. 1-3 leads to more questions about how the forest

was structured in the past. [Comment Number: 2-10]

Response: Although the commenter did not provide specifics of what led to more questions, the 

SNF has reviewed the history section on p.1-3 and edited the information for clarity.

TE-5. On p. 2-9 at the end of paragraph 2 the DEIS refers to Appendix X when it actually is 

Appendix A that has information on parameters for the research component. [Comment 

Number: 2-18]

Response: The FEIS has been corrected to appropriately refer to Appendix A.

TE-6. Standards and Guidelines (pp 2-16 to 2-19) are not clear. [Comment Number: 2-20]

Response: The SNF has reviewed Section 2.6.1.6 (pp. 2-16 to 2-19) and clarified language.

TE-7. Chapter 2 pages are labeled as though they are in Ch 5. [Comment Number: 2-21]

Response: Chapter 2 is correctly identified in the footer in the FEIS.

TE-8. Table 2-6 on p. 2-45 has no units listed. [Comment Number: 2-24]

Response: Units have been added to Table 2-6 in the FEIS.

TE-9. Table 2-11, p. 2-56 has no units listed. [Comment Number: 2-25]

Response: Units have been added to Table 2-11 in the FEIS.

TE-10. At the bottom of p. 2-60 the DEIS states a totally non-commercial alternative was 

not developed. We believe that is arbitrary and capricious by simply concluding, without 

explanation, that such would be ―impractical, expensive, and financially risky.‖ [Comment 

Number: 2-26]

Response: Section 2.4.2 is in error and has been deleted in the FEIS as stated in response to 

comment 2-17; Alternative 3 fully meets the requirements for the Noncommercial Funding 

Alternative.

TE-11. Table 3-9-7 (p. 3.9-26) shows trees greater than 35 inches dbh will be removed from 

the Bull and Providence areas. Such large trees must be retained. [Comment Number: 2-42]

Response: Table 3-9-7 has been edited to be consistent with the rest of the DEIS to show only 

trees up to 30 inches dbh maximum would potentially be thinned.