From: katie_calder@nps.gov on behalf of YOSE Superintendent, NPS 

<yose_superintendent@nps.gov> 

Sent: Friday, June 06, 2014 1:30 PM 

To: FS-comments-pacificsouthwest-stanislaus 

Cc: Linda Mazzu; Joe Meyer; Gus Smith; Lisa Acree; Alan Schmierer 

Subject: Re: Rim Recovery 

Attachments: Rim Fire Recovery DEIS Comments.pdf 

enclosure included 

On Fri, Jun 6, 2014 at 1:27 PM, YOSE Superintendent, NPS <yose_superintendent@nps.gov> 

wrote: 

OFFICIAL ELECTRONIC MAIL - NO HARD COPY TO FOLLOW

National Park Service

Yosemite National Park

P.O. Box 577

Yosemite, California 95389

In Reply Refer To: 

L7619 (YOSE-PM)

Susan Skalski, Forest Supervisor 

Stanislaus National Forest 

19777 Greenley Road 

Sonora, CA 95370 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-1
Re: Rim Fire Recovery Draft Environmental Impact Statement comments

Dear Ms. Skalski: 

The National Park Service (NPS) at Yosemite National Park appreciates the opportunity to 

provide comments regarding the Stanislaus National Forest’s Draft Environmental Impact 

Statement for Rim Fire Recovery (Rim Fire DEIS). While the Rim Fire started well outside the 

boundaries of Yosemite National Park, nearly 79,000 acres burned inside the park. The NPS 

anticipates that cross-boundary fires will continue, and perhaps increase, and is supportive of this 

project’s goal of “reducing the size and severity of future fires.” 

We first provided scoping comments in a letter dated December 29, 2013. We have reiterated 

these comments with corresponding page numbers from the Rim Fire DEIS for your further 

consideration (Enclosure 1). The following list summarizes our previous comments along with 

additional comments on the development of the Final Environmental Impact Statement. 

NEPA and NHPA Compliance 

• Identify the “Purpose” of the plan to guide actions that will achieve the ecological, research, 

recreational, and economic objectives of the USFS. 

• Describe the “Needs” for the plan as statements of existing conditions that need to be changed, 

problems that need to be remedied, and policies and mandates that need to be implemented. 

• Provide the Rim Fire Programmatic Agreement for public and agency review. 

• Include the Yosemite National Park Burned Area Emergency Response Plan in the analysis of 

cumulative effects. 

Alternatives 

• Avoid transport of invasive species by washing all earth-moving equipment. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-2
• Retain survivor trees particularly in high severity areas as important habitat and seed sources 

for regeneration. 

• Retain smaller diameter snags (approximately 14 inches in diameter at breast height) near green 

tree islands, near intact forest borders, at elevations higher than 5,000 feet for black-backed 

woodpecker habitat. 

• Treat fuel, snags, and slash to limit severity and duration of future fires with particular 

consideration for high severity areas and green tree islands. 

• Address better identification to delineate the park-forest boundary between Hodgdon Meadow 

and Camp Mather. 

Impact Analysis 

• Analyze impacts to all qualities of Wilderness character including undeveloped, natural, 

untrammeled, and primitive or unconfined recreation. 

• Consider Wilderness impacts in treatments adjacent to Yosemite Wilderness. 

The NPS appreciates the opportunity to provide input during this public review. We thank you 

for your consideration of our comments. 

Sincerely, 

/s/ Don L. Neubacher (original signature on file) 

Don L. Neubacher 

Superintendent 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-3
Enclosure: Rim Fire Recovery DEIS Comment Table 

Electronic cc: 

Linda Mazzu, Division Chief, Resources Management and Science, Yosemite National Park 

Joe Meyer, Branch Chief, Physical Science and Landscape Ecology, Yosemite National Park 

Gus Smith, Fire Ecologist, Yosemite National Park 

Lisa Acree, Acting Branch Chief, Environmental Planning and Compliance, Yosemite National 

Park 

Alan Schmierer, Wilderness and NEPA Coordinator, Pacific West Regional Office 

-- 

Office of the Superintendent

Yosemite National Park

209-372-0496

YOSE_Superintendent@nps.gov

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-4
Rim Fire Comments 

Page/Paragraph Comment

7/7 PURPOSE: 

The purpose of the plan is not overtly stated in this section. Purpose 

is a broad statement of goals that the USFS intends to fulfill by taking 

action. Example – The purpose of this plan/EIS is to guide actions in 

order to:

 Restore the forest at a landscape scale

 Conserve ecological structures, processes, and functions that 

are desirable and sustainable for future forested conditions

 Bring areas back to a more historic heterogeneous structure 

where fire complements and sustains the system instead of 

destroying it

 Restore ecosystem function, process, and resiliency by 

addressing issues related to vegetative composition and 

structure, forest health, fuels, hardwood and wildlife habitat 

improvement, and socio-economic objectives.

 Repair infrastructure to allow for appropriate administration

 Research the unique scale and intensity of the Rim Fire to 

answer questions and provide more information on a wide 

range of research topics

 Provide for public health and safety 

NEEDS: Needs should be statements of existing conditions that 

need to be changed, problems that need to be remedied, and 

policies and mandates that need to be implemented. The need for 

the plan should emphasize that the effects of the Rim Fire present 

immediate threats to public safety, administration, and forest 

ecology. Capture economic value through salvage logging is not a 

problem that needs to be remedied. It draws too specific a 

conclusion thereby limiting the development of a range of 

alternatives. Here are some suggested need statements:

 The Rim Fire has left an opportunity for salvage logging

 Public and worker safety is at risk due to the hazardous trees 

which resulted from the Rim Fire.

 The Rim Fire directly and indirectly caused damage to 

essential roads 

GOALS: The items listed as needs for the plan are better stated as 

overarching goals and objectives of the plan. Enhancing habitat and 

hydrologic function, and improving forest resiliency are also goals.

19/5 Primary Objectives

“The action alternatives represent a wide range of perspectives 

designed to address the purpose and need (Chapter 1.03) and the 

issues identified through scoping (Chapter 1.08).”

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-5
Delete the word “wide” as the alternatives in reality present a narrow 

range of actions.

19/5 “The purpose and need includes five primary objectives identified for 

the proposed action (Chapter 1.03).”

The identified “purpose and need” present solutions and objectives 

rather than problems to be solved by actions in the alternatives.

20/1 Table 2.01-1 Primary Objectives

The “purposes” identified in the table represent actions rather than 

foundational objectives upon which action alternatives can be 

derived.

24/5 If research is a primary objective of the plan, it should be a 

component of each action alternative.

25/6 Salvage and Fuel Reduction

Ensure that this section addresses the NPS scoping comment: 

“Whether salvage treatments will also include fuels treatments, and 

how the slash will be treated. Fuel loading in high severity patches 

can be extremely high and can change fire behavior in subsequent 

fires and can change the trajectories of forest succession.”

And also: “Whether brush will be treated in reforested areas. If brush 

is not treated, survival of saplings in subsequent fires will likely be 

negligible.”

26/4 Add a stipulation to retain a number of trees that have survived to 

address the NPS scoping comment “Trees that survived the Rim 

Fire, particularly in high severity areas, could be important habitat to 

wildlife species that cross the park-forest boundary, or that 

seasonally migrate from high elevations to low elevations.”

And also: “Green (i.e. survivor) trees and islands of green trees 

within the large, high severity patches should be treated as important 

resources. These trees/islands may be the seed source nucleus for 

future regeneration patterns. Fuels should be treated in green tree 

islands to reduce the severity of subsequent fires. Large diameter 

snags within the green tree islands should be retained for wildlife 

habitat, as trees burned in the Rim Fire will not provide habitat for all 

snag obligates.”

26/4 Add a stipulation to retain a number of 14” diameter trees address 

the NPS scoping comment: “Black backed woodpecker habitat, 

which includes smaller diameter snags (approximately 14 inches in 

diameter at breast height), near green tree islands, near intact forest 

borders, at elevations higher than 5,000 feet.”

27/ 7, 8, 9, and 

11

Actions need to be affirmative. Remove the word “consider” and 

replace with a strong action statement:

7. Consider Retain additional snags and downed logs to meet 

habitat needs in Old Forest Emphasis Areas (OFEA), Spotted 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-6
Owl Home Range Core Areas (HRCA), and forest carnivore 

connectivity corridor (FCCC).

8. Consider avoiding Avoid construction of new landings and 

skid trails within PACs. 

9. Consider avoiding Avoid road construction within 0.25 

miles of nest roost sites. 

11. Consider mitigating Mitigate areas where roadside hazard 

treatments are within PACs and HRCAs by adding acreage to 

the PACand/or HRCA equivalent to the treated acres of the 

most suitable habitat available.

27/12 Add the following statement to prevent the spread of invasive plants:

 All staff working on site shall be informed of, and follow best 

management practices for preventing the introduction and spread 

of non-native, invasive species. Equipment previously used outside 

the forest must be cleaned before leaving any paved surface. All 

digging, drilling, or earth-moving equipment will be cleaned prior 

to arrival at the project or staging areas to minimize the 

importation of non-native plants.

45/6 Hazard Tree Removal Only

“It does not meet the purpose and need to capture the economic

value since most of this habitat includes the largest and most dense 

stands of dead trees within the burn.”

Hazard tree removal could be done as salvage logging and would 

therefore allow for some economic value. Large, dense stands could 

still be useful from an economic standpoint.

46/2 Retain 100 Percent Black-Backed Woodpecker Modeled Pairs

“It does not meet the purpose and need to capture the economic 

value since most of this habitat includes the largest and most dense 

stands of dead trees within the burn.”

Under Alt 1, salvage logging could still take place in roughly 7,000 

acres which could still be economically valuable.

46/4 Retain 75 Percent of the Black-Backed Woodpecker Modeled Pairs

“It does not meet the purpose and need to capture the economic 

value since most of this habitat includes the largest and most dense 

stands of dead trees within the burn.”

Under Alt 1, salvage logging could still take place in roughly 14,000

acres which could still be economically valuable.

46/6 Retain Pre-Fire Spotted Owl PAC Boundaries, No PAC Remapping 

or Retiring

“It does not meet the purpose and need to capture the economic 

value since most of this habitat includes the largest and most dense 

stands of dead trees within the burn.”

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-7
Under Alt 1, salvage logging could still take place outside the PAC 

boundaries, which could still be economically valuable.

60/4 “Most perceived as negative effects to the visual resource (flush cut 

stumps, hand/machine piles, treatment edges, ground disturbance, 

and untreated slash) occurs during implementation. This initial phase 

is short term and does not represent the completed treatment. At the 

conclusion of treatment, visual signs of activity (i.e., cut stumps or 

track and tire marks) may still be evident but would dissipate over 

time. Evidence of burning on trees and ground features naturally 

occur in forests with wildfire regimes.“

The first sentence seems to be missing some words or punctuation.

This does not take into account our scoping comment “Trees that 

survived the Rim Fire, particularly in high severity areas, could be 

important habitat to wildlife species that cross the park-forest 

boundary, or that seasonally migrate from high elevations to low 

elevations.”

131 Assumptions Specific to Cultural Resources

salvage timber and hazard trees adjacent to 

Maintenance Level 2 roads through mechanical, cable and 

helicopter harvest methods will have no adverse effect to 

cultural resources. 

construction of temporary roads will not affect the integrity of 

cultural resource sites within the project boundary. 

within site boundaries can have a beneficial effect on cultural 

resources. Harvest of these trees would lessen the potential 

for damage to already fragile bedrock mortar outcrops and 

historic earthworks such as ditches, roads trails and railroad 

grades

These assumptions need to be backed up with information of how 

the cultural resources will be protected from impacts. Please 

describe how tree removal, road construction, jackpot burning, 

hazard tree removal, etc. avoid ground disturbance and other 

impacts to surface and subsurface deposits in areas with 

archeological resources. Please allow public review of the Rim Fire 

Programmatic Agreement.

132 “Utilizing previous archaeological inventories from past projects that 

meet current survey standards (1986 to present) nearly 53 percent of 

the proposed treatment areas were eliminated from further inventory”

Please describe the basis for eliminating these areas from further 

study (due to slopes greater than 40%?)

133/4 “The Rim Recovery project identifies 30,402 acres for salvage with 

an additional 15,253 acres of Maintenance Level 2 roads for hazard 

tree removal. These 45,655 acres constitute the Rim Recovery

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-8
project APE. A pre-field review determined that 26,425 acres of the 

APE had been previously surveyed for cultural resources through 

various other projects. An additional 7,921 acres were eliminated due 

to slopes greater than 40 percent. The result of these surveys 

identified 1,901 prehistoric and historic properties within the project 

boundary of which 756 are located within or adjacent to treatment 

units and adjacent to Maintenance Level 2 roads likely to be affected 

by this project.”

These acreages don’t match up with what is in the alternatives 

descriptions. It would be clearer if they were presented by alternative 

in a table.

133/7 Tuolumne Me-Wuk Tribal Council Tuolumne Band of Me-Wuk 

Indians

134/7 Infinite there are many archeological sites in the burned area, but 

there are not “infinite” sites. Please replace infinite with many.

Furthermore, the problems associated with vegetation islands are 

very different from fire-caused exposure of surface archeological 

deposits. This is a separate potential indirect beneficial effect of the 

action alternatives and should be discussed separately from the 

surface exposure and post-project monitoring.

236/10 “In the geographic extent, visuals (project activity), noise and dust 

produced during ground based and helicopter operations may 

negatively disrupt the solitude qualities of Wilderness character. The 

amount of work proposed within a half mile of Wilderness is expected 

to be completed within a matter of weeks to months; therefore, 

negative effects to Wilderness solitude would be limited in duration. 

Additionally, trailheads would be closed during operational periods, 

which would greatly reduce potential effects to Wilderness 

experience. Effects of trailhead closures are discussed in detail in the 

Chapter 3.08 (Recreation).”

This analysis only addresses opportunities for solitude, which is only 

one of 5 quality of Wilderness character. The removal of trees may 

affect the “untrammeled” quality as it is a human action that affects 

natural systems. Restoration of ecological systems and processes 

may result in beneficial impacts to the “natural” character of 

Wilderness. 

Consider soundscape impacts to Wilderness areas within Yosemite 

National Park. 

453/1 Consider that Yosemite National Park has prepared a Burned Area 

Emergency Response Plan to address park lands affected by the fire 

and will likely request Emergency Stabilization and Burned Area 

Rehabilitation funding for additional recovery actions. The park is not 

proposing major restoration actions for fire recovery and can provide 

more information as requested.

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-9
PARKS RE"CRE"ATi<?NaWATr:RrR9NT 

Susan Skalski. Forest Supervisor 


Stanislaus National Forest 


Attn: Rim Recovery 


19777 Greenley Road 


Sonora, CA 95370 


e-mail: comments-pacificsouthwest-stanislaus@fs.fed.us 


RE: Rim Fire Recovery (43033), Draft Environmental Impact Statement (DEIS) 

Dear Ms. Skalski: 

The City ofBerkeley, as a Jessee ofthe Berkeley Tuolumne Camp which was affected by the 


Rim Fire, offers the follow comments in response to the DEIR. 


Chapter 3.08 Recreation 

On page 170 of the DEIS there is a statement that reads " Berkeley-Tuolumne Camp was 

completely destroyed in the Rim Fire and may be rebuilt." This is not an accurate statement. As a 

matter of record, I request that the section be changed to read as follows: 

A majority, but not all, of the Berkeley-Tuolumne Camp was destroyed in the Rim Fire. It 

is the intent ofthe City ofBerkeley, in cooperation with the Stanislaus National Forest, to 

rebuild the camp. 

Chapter 3.10 Society, Culture, and Economy 

On page 172 ofthe DErS it is stated "In the case ofthe Berkeley Tuolumne Camp, the entire 

facility was destroyed by the Rim Fire and is currently not available." Again, this is not accurate 

and I request the following language be substituted. 

A majority ofthe Berkeley-Tuolumne Camp was destroyed in the Rim Fire and is CtUTently 

not available for use. 

The same section also states "To the extent the combined capacity of these facilities has been 

diminished, there has been a proportionate decrease in the size ofthe visitor-serving economy in 

Tuolumne County." It would be more accurate to state: 

To the extent the combined capacity of these facilities has been diminished, there has been 

a propo11ionate decrease in the size ofthe visitor-serving economy in Tuolumne County 

and for the respective Cities and organizations operating the camps and resorts. 

2180 Milvia Street, 3rd Floor, Berkeley, CA 94704 -1122 Tel: 510.981.6700 TDD: 510.981.6903 Fax: 


510.981 .6710 


E-mail: parks@ci.berkeley.ca.us 


Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-10
Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-11
From: katie_calder@nps.gov on behalf of YOSE Superintendent, NPS 

<yose_superintendent@nps.gov> 

Sent: Tuesday, June 17, 2014 1:24 PM 

To: FS-comments-pacificsouthwest-stanislaus 

Cc: Linda Mazzu; Joe Meyer; Gus Smith; Lisa Acree; Alan Schmierer 

Subject: Rim Recovery 

Attachments: RMS Rim Fire DEIS Comments (2) (1).pdf 

OFFICIAL ELECTRONIC MAIL - NO HARD COPY TO FOLLOW

National Park Service

Yosemite National Park

P.O. Box 577

Yosemite, California 95389

In Reply Refer To: 

L7619 (YOSE-PM)

Susan Skalski, Forest Supervisor 

Stanislaus National Forest 

19777 Greenley Road 

Sonora, CA 95370 

Re: Rim Fire Recovery Draft Environmental Impact Statement comments (Yosemite 

Boundary Resource Management)

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-12
Dear Ms. Skalski:

The National Park Service (NPS) at Yosemite National Park appreciates the opportunity to 

provide comments regarding the Stanislaus National Forest’s Draft Environmental Impact 

Statement for Rim Fire Recovery (Rim Fire DEIS). 

On June 6, 2014 we provided initial comments on the Rim Fire DEIS which addressed National 

Environmental Policy Act considerations and underscored our scoping comments (sent 

December 29, 2013). Attached are additional comments addressing resource management 

considerations near boundaries with Yosemite National Park. 

The NPS appreciates the opportunity to provide input during this public review. We thank you 

for your consideration of our comments.

Sincerely,

 /s/ Don L. Neubacher (original signature on file)

Don L. Neubacher

Superintendent

Attachment: Rim Fire Recovery DEIS Comment Table (Yosemite Boundary Resource 

Management)

Electronic cc: 

 Linda Mazzu, Division Chief, Resources Management and Science, Yosemite National 

Park

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-13
 Joe Meyer, Branch Chief, Physical Science and Landscape Ecology, Yosemite National 

Park 

 Gus Smith, Fire Ecologist, Yosemite National Park

 Lisa Acree, Acting Branch Chief, Environmental Planning and Compliance, Yosemite 

National Park

 Alan Schmierer, Wilderness and NEPA Coordinator, Pacific West Regional Office

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-14
Rim Fire Comments 

Page/Paragraph Comment

General 

comment

The White Wolf Critical Habitat Unit for the Yosemite Toad extends in 

the park towards Bald Mountain (near Ackerson Meadow) and Aspen 

Valley.

General 

comment

Opening up camping in the Forest will relieve pressure placed on 

Yosemite campgrounds. 

General 

comment

The treatment map identifies a large clear-cut to be placed on the 

park boundary near Hazel Green. Will this clear-cut be visible from 

the Big Oak Flat Road, a major road inside the park? Please 

consider mitigations to offset the potential visual impacts.

10/Figure 1.04-1 It is difficult to understand scale and extent of the treatments with this 

map because of a lack of detail and large scale. 

17/5b “Application of sporax may affect implementation of the logging 

because it is not necessary and adds costs.”

Why is sporax application unnecessary if it prevents root rot? Is it 

unnecessary because sporax is ineffective or that USFS is not 

concerned with root rot?

32/Figure 2.02-1 Forest carnivore connectivity corridor map is illegible. Difficult to 

ascertain if connectivity is being maintained.

41/4 Borax use and pesticide use is mentioned within BMP, however, on 

p17 it is specified that sporax will not be used. On p264 it is 

mentioned borates will be used. It is unclear if they will be used on 

not.

52/1 Invasive plants are identified to greatly increase in population 

because of disturbance and increased vectors. However, the 

invasive plant treatments identified in section 3.06 (Invasive plants) 

do not seem to adequately mitigate the risk.

53/9

307/7

For California Spotted Owl, alternative 1 ‘may affect individuals and 

is likely to result in a trend toward federal listing or loss of viability’.

Conversely, page 307 states “The cumulative contribution under this 

alternative may affect individual territories, but is not expected to 

affect the viability of this species”

54/1

321/3

For Great Gray Owl, alternative 1 ‘may affect individuals and is likely 

to result in a trend toward federal listing or loss of viability’.

Conversely, page 321 states “The cumulative contribution under this 

alternative may affect individual territories, but is not expected to 

affect the viability of this species”

54/2

334/6

For Northern Goshawk, alternative 1 ‘may affect individuals and is 

likely to result in a trend toward federal listing or loss of viability’ in 

regards to Northern goshawk. 

Conversely, page 321 states “The cumulative contribution under this 

alternative may affect individual territories, but is not expected to 

affect the viability of this species”

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-15
United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance 

Pacific Southwest Region

333 Bush Street, Suite 515 

San Francisco, CA 94104 

IN REPLY REFER:

(ER 14/0313)

Filed Electronically 

16 June 2014

Susan Skalski, Forest Supervisor

Stanislaus National Forest

19777 Greenley Road 

Sonora, CA 95370 

Subject: Draft Environmental Impact Statement (DEIS), US Forest Service (USFS), Rim Fire 

 Recovery, Stanislaus National Forest, California

Dear Ms. Skalski:

The Department of the Interior, on behalf of the National Park Service (NPS) at Yosemite 

National Park appreciates the opportunity to provide comments regarding the Stanislaus National 

Forest’s Draft Environmental Impact Statement for Rim Fire Recovery (Rim Fire DEIS). While 

the Rim Fire started well outside the boundaries of Yosemite National Park, nearly 79,000 acres 

burned inside the park. The NPS anticipates that cross-boundary fires will continue, and perhaps 

increase, and is supportive of this project’s goal of “reducing the size and severity of future 

fires.”

NPS first provided scoping comments in a letter dated December 29, 2013. We have reiterated 

these comments with corresponding page numbers from the Rim Fire DEIS for your further 

consideration (Table 1). The following list summarizes our previous comments along with 

additional comments on the development of the Final Environmental Impact Statement.

NEPA and NHPA Compliance:

• Identify the “Purpose” of the plan to guide actions that will achieve the ecological, 

research, recreational, and economic objectives of the USFS.

• Describe the “Needs” for the plan as statements of existing conditions that need to be 

changed, problems that need to be remedied, and policies and mandates that need to be 

implemented.

• Provide the Rim Fire Programmatic Agreement for public and agency review.

• Include the Yosemite National Park Burned Area Emergency Response Plan in the 

analysis of cumulative effects.

Alternatives:

• Avoid transport of invasive species by washing all earth-moving equipment.

• Retain survivor trees particularly in high severity areas as important habitat and seed 

sources for regeneration.

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-16
• Retain smaller diameter snags (approximately 14 inches in diameter at breast height) 

near green tree islands, near intact forest borders, at elevations higher than 5,000 feet for 

black-backed woodpecker habitat.

• Treat fuel, snags, and slash to limit severity and duration of future fires with particular 

consideration for high severity areas and green tree islands.

• Address better identification to delineate the park-forest boundary between Hodgdon 

Meadow and Camp Mather.

Impact Analysis:

• Analyze impacts to all qualities of Wilderness character including undeveloped, natural, 

untrammeled, and primitive or unconfined recreation.

• Consider Wilderness impacts in treatments adjacent to Yosemite Wilderness.

The Department of the Interior appreciates the opportunity to provide input during this public 

review. We thank you for your consideration of our comments.

Sincerely,

Patricia Sanderson Port 

Regional Environmental Officer 

cc: 

Director, OEPC

OEPC Staff Contact, Lisa Treichel, (202) 208-7116, Lisa_Treichel@ios.doi.gov

Don L. Neubacher, Superintendent, Yosemite National Park 

Linda Mazzu, Division Chief, Resources Management and Science, Yosemite National Park 

Joe Meyer, Branch Chief, Physical Science and Landscape Ecology, Yosemite National Park

Gus Smith, Fire Ecologist, Yosemite National Park

Lisa Acree, Acting Branch Chief, Environmental Planning and Compliance, Yosemite National 

Park

Alan Schmierer, Wilderness and NEPA Coordinator, Pacific West Regional Office 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-17
Table 1

Page/Paragraph Comment

7/7 PURPOSE: 

The purpose of the plan is not overtly stated in this section. Purpose is a 

broad statement of goals that the USFS intends to fulfill by taking action. 

Example – The purpose of this plan/EIS is to guide actions in order to: 

• Restore the forest at a landscape scale 

• Conserve ecological structures, processes, and functions that are 

desirable and sustainable for future forested conditions 

• Bring areas back to a more historic heterogeneous structure where 

fire complements and sustains the system instead of destroying it 

• Restore ecosystem function, process, and resiliency by addressing 

issues related to vegetative composition and structure, forest health, 

fuels, hardwood and wildlife habitat improvement, and socioeconomic objectives. 

• Repair infrastructure to allow for appropriate administration 

• Research the unique scale and intensity of the Rim Fire to answer 

questions and provide more information on a wide range of research 

topics 

• Provide for public health and safety 

NEEDS: Needs should be statements of existing conditions that need to be 

changed, problems that need to be remedied, and policies and mandates that 

need to be implemented. The need for the plan should emphasize that the 

effects of the Rim Fire present immediate threats to public safety, 

administration, and forest ecology. Capture economic value through salvage 

logging is not a problem that needs to be remedied. It draws too specific a 

conclusion thereby limiting the development of a range of alternatives. Here 

are some suggested need statements: 

• The Rim Fire has left an opportunity for salvage logging 

• Public and worker safety is at risk due to the hazardous trees which 

resulted from the Rim Fire. 

• The Rim Fire directly and indirectly caused damage to essential roads 

GOALS: The items listed as needs for the plan are better stated as 

overarching goals and objectives of the plan. Enhancing habitat and 

hydrologic function, and improving forest resiliency are also goals. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-18
19/5 Primary Objectives 

“The action alternatives represent a wide range of perspectives designed to 

address the purpose and need (Chapter 1.03) and the issues identified through 

scoping (Chapter 1.08).” 

Delete the word “wide” as the alternatives in reality present a narrow range 

of actions. 

19/5 “The purpose and need includes five primary objectives identified for the 

proposed action (Chapter 1.03).” 

The identified “purpose and need” present solutions and objectives rather 

than problems to be solved by actions in the alternatives. 

20/1 Table 2.01-1 Primary Objectives 

The “purposes” identified in the table represent actions rather than 

foundational objectives upon which action alternatives can be derived. 

24/5 If research is a primary objective of the plan, it should be a component of

each action alternative. 

25/6 Salvage and Fuel Reduction 

Ensure that this section addresses the NPS scoping comment: “Whether 

salvage treatments will also include fuels treatments, and how the slash will 

be treated. Fuel loading in high severity patches can be extremely high and 

can change fire behavior in subsequent fires and can change the trajectories 

of forest succession.” 

And also: “Whether brush will be treated in reforested areas. If brush is not 

treated, survival of saplings in subsequent fires will likely be negligible.” 

26/4 Add a stipulation to retain a number of trees that have survived to address the 

NPS scoping comment “Trees that survived the Rim Fire, particularly in high 

severity areas, could be important habitat to wildlife species that cross the 

park-forest boundary, or that seasonally migrate from high elevations to low 

elevations.” 

And also: “Green (i.e. survivor) trees and islands of green trees within the 

large, high severity patches should be treated as important resources. These 

trees/islands may be the seed source nucleus for future regeneration patterns. 

Fuels should be treated in green tree islands to reduce the severity of 

subsequent fires. Large diameter snags within the green tree islands should 

be retained for wildlife habitat, as trees burned in the Rim Fire will not 

provide habitat for all snag obligates.” 

26/4 Add a stipulation to retain a number of 14” diameter trees address the NPS 

scoping comment: “Black backed woodpecker habitat, which includes 

smaller diameter snags (approximately 14 inches in diameter at breast 

height), near green tree islands, near intact forest borders, at elevations 

higher than 5,000 feet.” 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-19
27/ 7, 8, 9, and 

11 

Actions need to be affirmative. Remove the word “consider” and replace 

with a strong action statement: 

7. Consider Retain additional snags and downed logs to meet habitat needs in 

Old Forest Emphasis Areas (OFEA), Spotted Owl Home Range Core Areas 

(HRCA), and forest carnivore connectivity corridor (FCCC). 

8. Consider avoiding Avoid construction of new landings and skid trails 

within PACs. 

9. Consider avoiding Avoid road construction within 0.25 miles of nest roost 

sites. 

11. Consider mitigating Mitigate areas where roadside hazard treatments are 

within PACs and HRCAs by adding acreage to the PAC and/or HRCA 

equivalent to the treated acres of the most suitable habitat available. 

27/12 Add the following statement to prevent the spread of invasive plants: 

• All staff working on site shall be informed of, and follow best 

management practices for preventing the introduction and spread of 

non-native, invasive species. Equipment previously used outside the 

forest must be cleaned before leaving any paved surface. All digging, 

drilling, or earth-moving equipment will be cleaned prior to arrival at 

the project or staging areas to minimize the importation of non-native 

plants. 

45/6 Hazard Tree Removal Only 

“It does not meet the purpose and need to capture the economic value since 

most of this habitat includes the largest and most dense stands of dead trees 

within the burn.” 

Hazard tree removal could be done as salvage logging and would therefore 

allow for some economic value. Large, dense stands could still be useful 

from an economic standpoint. 

46/2 Retain 100 Percent Black-Backed Woodpecker Modeled Pairs 

“It does not meet the purpose and need to capture the economic value since 

most of this habitat includes the largest and most dense stands of dead trees 

within the burn.” 

Under Alt 1, salvage logging could still take place in roughly 7,000 acres 

which could still be economically valuable. 

46/4 Retain 75 Percent of the Black-Backed Woodpecker Modeled Pairs 

“It does not meet the purpose and need to capture the economic value since 

most of this habitat includes the largest and most dense stands of dead trees 

within the burn.” 

Under Alt 1, salvage logging could still take place in roughly 14,000 acres 

which could still be economically valuable. 

46/6 Retain Pre-Fire Spotted Owl PAC Boundaries, No PAC Remapping or 

Retiring 

Rim Fire Recovery (43033) 

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Letters from Federal, State and Local Agencies

L-20
“It does not meet the purpose and need to capture the economic value since 

most of this habitat includes the largest and most dense stands of dead trees 

within the burn.” 

Under Alt 1, salvage logging could still take place outside the PAC 

boundaries, which could still be economically valuable. 

60/4 “Most perceived as negative effects to the visual resource (flush cut stumps, 

hand/machine piles, treatment edges, ground disturbance, and untreated 

slash) occurs during implementation. This initial phase is short term and does 

not represent the completed treatment. At the conclusion of treatment, visual 

signs of activity (i.e., cut stumps or track and tire marks) may still be evident 

but would dissipate over time. Evidence of burning on trees and ground 

features naturally occur in forests with wildfire regimes.”

The first sentence seems to be missing some words or punctuation. 

This does not take into account our scoping comment “Trees that survived 

the Rim Fire, particularly in high severity areas, could be important habitat to 

wildlife species that cross the park-forest boundary, or that seasonally 

migrate from high elevations to low elevations.” 

131 Assumptions Specific to Cultural Resources 

• Removal of salvage timber and hazard trees adjacent to Maintenance 

Level 2 roads through mechanical, cable and helicopter harvest 

methods will have no adverse effect to cultural resources. 

• New road construction, reconstruction, maintenance and construction 

of temporary roads will not affect the integrity of cultural resource 

sites within the project boundary. 

• Removal of hazard trees and commercial value logs within site 

boundaries can have a beneficial effect on cultural resources. Harvest 

of these trees would lessen the potential for damage to already fragile 

bedrock mortar outcrops and historic earthworks such as ditches, 

roads trails and railroad grades 

These assumptions need to be backed up with information of how the 

cultural resources will be protected from impacts. Please describe how tree 

removal, road construction, jackpot burning, hazard tree removal, etc. avoid 

ground disturbance and other impacts to surface and subsurface deposits in 

areas with archeological resources. Please allow public review of the Rim 

Fire Programmatic Agreement. 

132 “Utilizing previous archaeological inventories from past projects that meet 

current survey standards (1986 to present) nearly 53 percent of the proposed 

treatment areas were eliminated from further inventory” 

Please describe the basis for eliminating these areas from further study (due 

to slopes greater than 40%?) 

133/4 “The Rim Recovery project identifies 30,402 acres for salvage with an 

additional 15,253 acres of Maintenance Level 2 roads for hazard tree 

Rim Fire Recovery (43033) 

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Letters from Federal, State and Local Agencies

L-21
removal. These 45,655 acres constitute the Rim Recovery project APE. A 

pre-field review determined that 26,425 acres of the APE had been 

previously surveyed for cultural resources through various other projects. An 

additional 7,921 acres were eliminated due to slopes greater than 40 percent. 

The result of these surveys identified 1,901 prehistoric and historic properties 

within the project boundary of which 756 are located within or adjacent to 

treatment units and adjacent to Maintenance Level 2 roads likely to be 

affected by this project.” 

These acreages don’t match up with what is in the alternatives descriptions. 

It would be clearer if they were presented by alternative in a table. 

133/7 Tuolumne Me-Wuk Tribal Council Tuolumne Band of Me-Wuk Indians 

134/7 Infinite there are many archeological sites in the burned area, but there are 

not “infinite” sites. Please replace infinite with many. 

Furthermore, the problems associated with vegetation islands are very 

different from fire-caused exposure of surface archeological deposits. This is 

a separate potential indirect beneficial effect of the action alternatives and 

should be discussed separately from the surface exposure and post-project 

monitoring. 

236/10 “In the geographic extent, visuals (project activity), noise and dust produced 

during ground based and helicopter operations may negatively disrupt the 

solitude qualities of Wilderness character. The amount of work proposed 

within a half mile of Wilderness is expected to be completed within a matter 

of weeks to months; therefore, negative effects to Wilderness solitude would 

be limited in duration. Additionally, trailheads would be closed during 

operational periods, which would greatly reduce potential effects to 

Wilderness experience. Effects of trailhead closures are discussed in detail in 

the Chapter 3.08 (Recreation).” 

This analysis only addresses opportunities for solitude, which is only one of 

5 quality of Wilderness character. The removal of trees may affect the 

“untrammeled” quality as it is a human action that affects natural systems. 

Restoration of ecological systems and processes may result in beneficial 

impacts to the “natural” character of Wilderness. 

Consider soundscape impacts to Wilderness areas within Yosemite National 

Park. 

453/1 Consider that Yosemite National Park has prepared a Burned Area 

Emergency Response Plan to address park lands affected by the fire and will 

likely request Emergency Stabilization and Burned Area Rehabilitation 

funding for additional recovery actions. The park is not proposing major 

restoration actions for fire recovery and can provide more information as 

requested. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-22
State of California - Natural Resources Agency EDMUND G. BROWN JR., Governor 

DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director 

Central Region 

1234 East Shaw Avenue 

Fresno, California 93710 

(559) 243-4005 

www.wildlife.ca.gov 

June 16, 2014 

Susan Skalski, Forest Supervisor 

Stanislaus National Forest 

Attn: Rim Fire Recovery 

19777 Greenley Road 

Sonora, California 95370 

Subject: 	Stanislaus National Forest 

Draft Environmental Impact Statement for Rim Fire Recovery 

Federal Register Vol. 79, No. 100, May 23, 2014 

Dear Ms. 	Skalski: 

The California Department of Fish and Wildlife (Department) has reviewed the draft 

Environmental Impact Statement (EIS) for Rim Fire Recovery (Project) posted in the 

Federal Register; Vol. 79, No. 100, dated May 23, 2014, prepared by the United States 

Forest Service (Forest Service). On August 17, 2013, the Rim Fire ignited, and over 

several weeks, burned approximately 257,000 acres, making it the third largest wildfire 

in the history of the State of California. The above mentioned Project is being proposed 

in the Stanislaus National Forest to aid in achieving the specific goal of creating a fire 

resilient forest where fire is an integral part of the system and not a landscape altering 

force, as is described in the Forest Service Forest Plan as a long-term management 

goal. Project-related activities in the Forest Service's preferred alternative 

(Alternative 1) include: 28,326 acres of salvage logging (24, 127 acres ground based, 

16 acres ground based/skyline swing, 2,930 acres helicopter, and 1,253 acres of skyline 

treatments); 7,626 acres of biomass removal; 24, 143 acres of machine piling and 

burning; 4, 199 acres of jackpot burning; hazard tree removal along 341 miles of 

existing roads; 5.4 miles of new road construction; 13.2 miles of temporary road 

construction; 319.9 miles of road reconstruction; and 216.1 miles of road maintenance; 

creation and implementation of 7 rock quarry sites; and the usage of 81 water source 

sites necessary for road construction activities and long-term resource needs. The 

Project description indicates that none of the proposed treatments will occur within 

Wilderness, Inventoried Road less Areas, or wild classification segments of a designated 

Wild and Scenic River. 

The Department recognizes the necessity to minimize fuel load for future forest 

resiliency and aid in achieving goals set forth by the Forest Service Forest Plan; and 

improve road and drainage infrastructure as a means to restore and improve proper 

hydrologic function within the Rim Fire area. The Department has concerns regarding 

Conserving Ca{ijornia)s WiU[ife Since 18 70 


Rim Fire Recovery (43033) 

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Letters from Federal, State and Local Agencies

L-23
Susan Skalski 

June 16, 2014 

Page2 

wildlife habitat and specific species avoidance measures in relation to activities · 

proposed in the Project description. Wildlife habitat within an area as large as the Rim 

Fire requires a diversified approach to retain the values needed to protect wildlife 

resources. Diversity to protect wildlife habitat can include complete removal to 

complete retention of dead timber. Specific areas of species emphasis are desirable 

since the needs of some species are in direct conflict with the needs of other species. 

The amount and type of treatments along with the juxtaposition of the treatments and 

timing of the implementation all play a role in the positive or negative effect the 

treatments will have on wildlife resources. Given t~e Project scale, it is impossible to 

prepare comments that would adequately address the wildlife needs for every species 

for each treatment area. Therefore, we have provided specific comments on wildlife 

species guilds or topical areas and recommendations on how Project impacts can be 

addressed to minimize impacts or result in future improvements. 

Project Comments 

In general, the Department supports the proposal for treatment units to remove timber 

from areas impacted by the Rim Fire. The Department supports a cooperative working 

relationship in the specific treatment area design as the level of impact or benefit to 

wildlife populations will be achieved based on site specific juxtaposition of treatment and 

retention areas. Diversified and healthy wildlife populations are best sustained through 

maintaining and improving the habitats present, enhancing the edge effect on 

represented habitats, and preserving connectivity for species movements and 

migrations. The Rim Fire has the potential to create large expanses of monotypic 

habitats and block migratory corridors. Therefore, the Department supports alternatives 

that will enhance the attributes which will have the highest potential for wildlife 

population maintenance and enhancement. Alternatives 3 and 4 have potential for 

wildlife population sustainability over an extended time period and include specific 

wildlife measures. Provisions for the Forest Carnivore Connectivity Corridor (FCCC) 

and Critical Deer Winter Range will increase the potential for wildlife maintenance and 

enhancement in the treatment areas. 

Large blocks of untreated areas will exist in all the alternatives. The Yosemite National 

Park portion will not be treated; the cumulative result on the entire Rim Fire footprint 

area with treatments would favor increasing habitat diversity that is desirable. Use 

areas by some species, such as the black-backed woodpeckers, and displaced animals 

is unknown and speculative, yet there are known migratory corridors that are only 

treated in Alternative 3. Failure to treat the migratory corridors would increase the 

impact on migratory wildlife. Therefore, the Department recommends the selection of 

Alternative 3. Further, per the draft EIS Alternative 3 would include: 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-24
Susan Skalski 

June 16, 2014 

Page 3 

• 	 FCCC Forest Plan Amendment, to designate a four (4) mile wide FCCC as 

habitat for old-forest habitat associated species. 

• 	 Reduced amount of new road construction. 

• 	 3,064 acres in additional treatment units to enhance the Critical Deer Winter 

Range. 

• 	 Research and monitoring component that address several post-fire and postsalvage impacts. 

• 	 Decreased risk of habitat alterations and vectors due to additional 

management requirements for invasive species. 

• 	 Improved soil cover and erosion hazard ratings. 

• 	 Increased surveys for special status species. 

• 	 Additional and increased avoidance, minimization, and mitigation measures 

for special st?tus species. 

The Department encourages the Forest Service to implement Alternative 3, rather than 


Alternative 1. Further, the Department recommends the Forest Service address the 


following concerns in the final EIS, and incorporate our recommendations into the 


Department's preferred alternative, Alternative 3. · 


Great gray owl (GGO) (Strix nebulosa), California spotted owl (CSO) (Strix 

.occidentalis) and northern goshawk (NOGO) (Accipiter gentilis): Per the draft EIS, 

the Forest Service's preferred alternative, Alternative 1, may affect GGO, CSO, and 

NOGO individuals and is likely to result in a trend toward loss of viability. The 

Department's preferred alternative, Alternative 3, may affect GGO, CSO, and NOGO 

individuals but is not likely to result in a trend toward loss of viability. The Rim Fire . 

. impacted 46 CSO Protected Activity Centers (PAC), 25 NOGO PACs, and 13 GGO 

PACs. Incorporating protection measures, such as those in Alternative 3, are essential 

for the continued viability of these species in the Rim Fire area. Further, the GGO 

population in California is extremely small and is isolated from other GGO populations 

putting the species in danger of extinction within the state. Hull et al. (2010) indicates 

that the Sierra Nevada population is a distinct lineage with respect to the larger species 

range in North America, and should be designated as a separate subspecies based on 

molecular data and life history differences. Again, the Department highly encourages 

the Forest Service to implement Alternative 3. 

Based on the Alternative 3 Project description, the Department is unclear if avoidance 

measures will be employed in the event that a CSO, GGO, or NOGO detection is made· 

Rim Fire Recovery (43033) 

Environmental Impact Statement

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Letters from Federal, State and Local Agencies

L-25
Susan Skalski 

June 16, 2014 

Page4 

at a previously undocumented and/or unrecognized location within the Project area. 

Known CSO, GGO, and NOGO activity centers and historic nesting sites were 

destroyed or significantly impacted during the Rim Fire. Displacement from activity 

centers and nesting sites may increase the potential for CSO, GGO, and NOGO 

detections in previously undocumented and undetected locations. The Department 

recommends inclusion of avoidance measures in the EIS addressing the protection of 

CSO, GGO, and NOGO in the event of detection, from March 1 through August 15, and 

that the measures be implemented throughout the life of the Project. It is recognized 

that the majority of the Project area is impacted to the degree that territories are not 

likely to occur in heavily burned areas. Habitat islands with live trees should be 

considered as potential displacement areas, and surveyed if occurrence is adjacent to a 

treatment area. The Department also advises that areas exhibiting key habitat 

characteristics for CSO and/or GGO nesting, foraging, and dispersal, within or in the 

vicinity of Project-related activities, be surveyed for by a qualified biologist prior to 

Project-related activities. The Department requests notification of any CSO, GGO, or 

NOGO detections as a result of surveys or observations made during Project-related 

activities. 

Wildlife Movement Corridors: Terrestrial wildlife will need the ability to travel between 

winter and summer range areas. Failure to open and maintain the movement corridors 

can result in migration blockage. Treatments with the Rim Fire are critical in the 

Tuolumne Deer Herd winter range and migration corridors. Maintaining migratory 

corridors for wildlife is an important element that needs to be conserved throughout the 

Stanislaus National Forest. Although the proposed action will provide benefits through 

many of the known corridors, not all the migratory corridors are known or included in 

treatments. Left untreated, the jackstrawed trees can result in a barrier to migratory 

wildlife and impact the survival and ultimately the remaining populations utilizing the 

area. Therefore, the Department recommends the Forest Service conduct ongoing 

monitoring of the wildlife populations to assess if additional site-specific treatments may 

be needed in the future. Currently, the Department has store-on-board global 

positioning system (GPS) collars on 50 adult female deer within the Rim Fire area. The 

location data from these collars will not be collected for two (2) years when the collars 

drop. The data from these collars will be valuable for assessing the use areas, 

migration corridors, and effects of the completed actions. The Department can provide 

information to the Forest Service on specific known movement corridors. Follow up 

actions to assess and evaluate the proposed action should be considered as many of 

the provisions proposed are not well documented and could be used in future post-fire 

decisions. 

Snags: The Department supports biomass and salvage operations as important tools 

for future forest recovery. Snags are an important wildlife component and are listed in 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-26
Susan Skalski 

June 16, 2014 

Page 5 

the Project with retention standards. The Department recommends snags for retention 

be defined in the Project as not all snags are equal in value to wildlife. Within the 

proposed treatment units, the Department recommends a mosaic pattern for snag 

retention. Clumps or small groups of snags or'untreated areas, rather than individual, 

evenly spaced snags will provide essential habitat for fire dependent species and create 

a beneficial edge effect. Retention of the largest snags generally provides the most 

benefit to wildlife. 

Wildlife Management 

There will be wildlife impacts, and for this reason the Department would like to 

recommend that some specific targeted wildlife management and mitigation be 

incorporated into the Project. Listed below are potential mitigation measures that the 

Department recommends be included in the Project. 

• 	 Snag creation adjacent to meadows throughout the forest in unburned areas 

currently not occupied by great gray owls to enhance the potential for future 

use by displaced owls. 

• 	 Meadow Protection and Enhancement. Over time, some meadows had pine 

encroachment and were in the process of type conversion. There is currently 

an opportunity to maintain and enhance these meadows in a way that will 

result in long term habitat improvements. There are some meadows with a 

ring of small live trees around the meadow where the fire intensity was low 

and not sufficient to.kill the encroaching trees. An opportunity exists where 

these meadows can be enlarged back to their original size. Therefore, the 

Department recommends that the meadows be considered specifically for 

their potential for restoration and enhancement. Decreasing the pine 

encroachment is desirable. Improving the potential water retention would 

decrease long term encroachment. 

• 	 Planting of oaks in areas where fire intensity killed existing oaks. Replanting 

oaks will benefit wildlife and, should be a component of the wildlife movement 

corridor management and diversity to sustain forest resilience. 

Future Fuel Breaks: The Project does not include the formation of fuel breaks which 

should be considered as a component to the salvage operation. The Department 

recommends the Forest Service include the creation of fuel breaks to allow habitat 

management, forest resilience, and protection from future catastrophic fire events in the 

Project design. Designation of fuel breaks as a component of other features such as 

migration. corridors, or deer winter range habitat management would be a beneficial 

component of the salvage operation. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-27
Susan Skalski 

June 16, 2014 

Page 6 

Dust Abatement and Water Drafting: The draft EIS indicates dust abatement will 

occur within the Project area; it is unclear if surface water will be used as the sole · 

method for dust abatement. The Department has concerns regarding water drafting 

from surface waters during times of drought. The Department encourages the Forest 

Service to investigate other means of dust abatement and road treatment methods to 

minimize the amount of water needed. The Department also advises the use of storage 

tanks to collect water gradually (i.e., over a 24-hour period), and to include recovery 

times between pumping events. Further, the Department encourages the Forest 

Service to incorporate best management practices into the Project design that reflect 

this historic drought. 

The Department appreciates the opportunity to provide comments on this Project. 

Depending upon any additional information or survey results related to this Project, the 

Department may have additional comments and recommendations regarding 

avoidance, minimization, and mitigation of Project impacts to habitat and special status 

species. If you have any questions on these issues, please contact Margarita Gord us, · 

Senior Environmental Scientist (Specialist), at 559-243-4014, extension 236, or by 

electronic mail at Margarita.Gordus@wildlife.ca.gov. 

Jeffrey R. Single, Pμ. 

Regional Managw 

cc: 	 United States Fish and Wildlife Service 

2800 Cottage Way, Suite W-2605 

Sacramento, California 95825 

California Regional Water Quality Control Board 


Central Valley Region 


1685 E Street 


Fresno, California 93706 


John Ramaley, Review Team Chair· 


California Department of Forestry and Fire Protection 


1234 East Shaw Avenue 


Fresno, California 95370 


ec: 	 See Page Seven 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-28
Susan Skalski 

June 16, 2014 

Page 7 

ec: 	 Stanislaus National Forest 

comments-pacificsouthwest-stanislaus@fs. fed. us 

Adam Frese, Forester I, Cal Fire 


Adam.Frese@fire.ca.gov 


Guy Anderson, Forester I, Cal Fire 


Guy.Anderson@fire.ca.gov 


California Department of Fish and Wildlife 

Brian Beal, Senior Environmental Scientist (Supervisor), CDFW 

Terry Palmisano, Environmental Program Manager, CDFW 

Greg Gerstenberg, Senior Environmental Scientist (Supervisor), CDFW 

Daniel Applebee, Senior Environmental Scientist, CDFW 

Nathan Graveline, Environmental Scientist, CDFW 

Margarita Gordus, Senior Environmental Scientist, CDFW 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-29
Susan Skalski 

June 16, 2014 

Page 8 

Literature 

Hull, T.M., J.J Keane, W.K. Savage, S.A. Godwin, J.A. Shafer, E.P. Jepsen, R. 

Ferhardt, C. Stermer, H.B. Ernest. 2010. Range-wide genetic differentiation among 

North American great gray owls (Stirx nebulosa) reveals a distinct lineage restricted to 

the Sierra Nevadas, California. Molecular Phylogenetics and Evolution, 56: 212-221. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-30
STATE OF CALIFORNIA-CALIFORNIA STATE TRANSPORTATION AGENCY EDMUND G BROWN JR. Gqvemor 

DEPARTMENT OF TRANSPORTATION 

DISTRICT 10 

P.O. BOX 2048, STOCKTON, CA 95201 

(1976 E. DR. MARTIN LUTHER KING JR. BLVD. 95205) 

PHONE (209) 948-7112 Flex your power! 

FAX (209) 948-7164 Be energy efficient! 

TTY 711 

June 16, 2014 

10-TU0-120-PM 41.2/56.5 

Stanislaus National Forest 

Rim Fire Recovery 

DEIS 

Maria Benech 


Stanislaus National Forest, Attn: Rim Recovery 


19777 Greenley Road 


Sonora, CA 95370 


Dear Ms. Benech: 

The California Department of Transportation (Department) appreciates the opportunity to 

provide comments in response to the Draft Environmental Impact Statement (DEIS) for the Rim 

Fire Recovery project which would salvage dead trees to capture economic value; remove roadside 

hazard trees to protect public and worker safety; reduce fuels for future forest resiliency; improve 

roads for hydrologic function; and, enhance wildlife habitat within the area burned by the Rim Fire 

in August and September of2013. Approximately twelve miles of the right ofway of State Route 

(SR) 120 are included in the project area. 

The Department provided comments regarding the Scoping Package for the project in a letter 

dated January 3, 2014. The DEIS and the Transportation Report prepared for the project do not 

address the Department's comments in any significant way. Comments from the January 3, 2014 

letter are reiterated below for your reference. To the extent that the chosen alternative 

implements project activities requiring issuance of encroachment permits from the Department, 

these comments can be addressed through application ofDepartment standards and procedures in 

the review of the encroachment permits for the project. 

The Rim Fire Recovery Treatment Units maps do not appear to show treatment within the right 

of way of SR 120. This is consistent with the Department's understanding that tree removal 

within the highway right of way would be addressed by the Rim Fire Hazard Tree Removal 

project. The Department provided comments for the Hazard Tree Removal Enviromnental 

Assessment in a letter dated April 9, 2014. 

The Rim Fire Recove1y Road Treatments maps identify reconstruction of eleven Forest Service 

roads with encroachments on SR 120 and one skid zone east of Buck Meadows that appears to be 

in the SR 120 right of way. The exact scope of activities that may take place in the highway right 

of way is unclear. 

"Ca/trans improves mobility across California" 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-31
2 

Ms. Benech 

June 16, 2014 

An encroachment permit from the Department would be needed for any project activities, 

including traffic control, which would encroach into the SR 120 right of way. Appropriate 

environmental studies and the environmental document for the project must be submitted along 

with the encroachment permit application. These studies must include an analysis of potential 

impacts to any cultural sites, biological resources, areas of known or suspected hazardous waste 

concern, and/or other resources within affected portion(s) of the SR 120 right ofway. 

Use and reconstruction of existing Forest Service roads and encroachments should incorporate 

stonn water best management practices to reduce sediment tracking onto SR 120. Road 

reconstruction under encroachment permits will be subject to current Departmental standards. 

Project activities, including the operation of equipment within the SR 120 right of way, present 

the potential to alter drainage patterns and affect SR 120 drainage facilities. Project design and 

environmental evaluation should anticipate the need to maintain existing drainage patterns and to 

mitigate for any changes to peak flows to Department facilities. 

Traffic control for any operations on the highway will need to confonn to the California Manual 

on Uniform Traffic Control Devices. Traffic control windows will be needed, and work on 

SR 120 should be scheduled to minimize impacts during the peak tourism season. 

Changes in the Department's storm water permit, effective July 1, 2013, affect the use of the 


Department's storm water permit to cover activities authorized by issuance of encroaclunent 


petmits. The Forest Service will need to obtain all storm water permitting directly from the 


Central Valley Regional Water Quality Control Board (Regional Buar<l), an<l reporting will be 


. made directly to the Regional Board. Storm water permitting documentation and plans are 


required as part of a complete encroachment permit application. 

If you have any questions or would like to discuss these comments, please contact Carl Baker at 

(209) 948-7325 (e-mail: carl.baker@dot.ca.gov), or me at (209) 948-7 11 2 (e-mail: 

john.gedney@dot.ca.gov). 

Office 

JOHN 

u:Qof

GEDNEY

Rural Planning 

, Chief 

~ & Administration 

c: 	 Bev Shane, Director, Tuolumne County Community Resources Agency 


Darin Grossi, Executive Director, Tuolumne County Transportation Council 


"Ca/trans improves mobility across California " 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-32
County Administrator's Office 


Craig L. Pedro 

Co1111ty Admi11istrator 

Tuolumne County Administration Center 


2 South Green Street 


Sonora, CA 95370 


Phone (209) 533-5511 


Fax (209) 533-5510 


www.tuolumnecounty.ca.gov 


June 16, 2014 

Susan Skalski, Forest Supervisor 

Stanislaus National Forest 

Attn: Rim Recovery 

19777 Greenley Road 

Sonora, CA 95370 

Re: Comments on the Rim Fire Recovery Draft Environmental Impact Statement 

Dear Supervisor Skalski: 

The Tuolumne County Natural Resources Committee is pleased to comment on the Draft 

Environmental Impact Statement for the Rim Fire Recovery project. The forest devastation 

produced by the Rim Fire cannot be overstated and a robust recovery effort is required to 

make the forest safe and to reforest. Ofthe four alternatives proposed in the DEIS, 

Tuolumne County supports the principles contained in alternatives one and three. 

The Tuolumne County Board of Supervisors has repeatedly called for the maximum 

removal of burnt timber for its economic value and for its various healthy forest benefits. 

Of the four alternatives listed in the DEIS, alternatives one and three best meet this criteria. 

Timber removal will also help maintain a navigable forest for migrating deer. 

The County is pleased to see significant biomass removal using a variety of methods; 

however, the County encourages more removal rather than pile burning. Transporting the 

biomass to an energy producing plant such as Pacific Ultra Power will prevent unnecessary 

air pollution caused by pile burning and will generate electricity. The areas where the fire 

burned particularly hot can benefit from mulching and chipping to avoid erosion and to 

encourage forest regeneration. 

The County is pleased that an Emergency Situation Determination was granted, thereby 

allowing project implementation to move forward more quickly. Furthermore, the County 

recommends taking similar actions to ensure a timely project implementation. In the short 

time since the fire, some areas are already seeing some evidence of bug infestation. Should 

lengthy lawsuits ensue, the timber value will plummet, leaving the forest susceptible to 

similar future wildfires . 

... serving the Board ofSupervisors, departments, and the community as good stewards ofthe County'sfiscal 


and human resources through collaborative, professional and ethical leadership. 


Rim Fire Recovery (43033) 

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L-33
Tuolumne County's economy, especially tourism was directly impacted by the Rim Fire; 

making the forest safe and healthy for all to enjoy should be the ultimate goal. It cost $127 

Million in direct costs to fight the Rim Fire, not to mention the ecological impacts from air 

pollution and other community impacts to schools and especially the elderly. Tuolumne 

County encourages a strong recovery project which is embodied in alternatives one and 

three of the DEIS. We look forward to working with the Stanislaus National Forest to 

move this project forward in a timely fashion. 

Sincerely, 

~~J~ 

c~~Ro County Administrator 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-34
San Francisco 

Water Power Sewer 

Operator of the Hetch Hetchy Regional Water System 

Post Office Box 160 

Moccasin, CA 95347 

T 209.989.2012 

F 209.989.2104 

Junction of Hwy 49 and Hwy 120 

June 16, 2014 

Stanislaus National Forest 

Attn: Rim Fire Recovery 

19777 Greenley Road 

Sonora, C A 95370 

R E: Comments on Rim Fire Recovery (43033), Draft Environmental Impact 

Statement 

Dear Ms. Skalski: 

The San Francisco Public Utilities Commission (SFPUC) appreciates the 

opportunity to comment on the Rim Fire Recovery (43033) Draft Environmental 

Impact Statement. The SFPU C submitted comments dated January 3, 2014 in 

response to the Notice of Intent To Prepare an Environmental Impact 

Statement for Rim Fire Recovery published December 6, 2013, in Vol. 78 No. 

235 of the Federal Register. The comments below supplement the information 

in the January 3, 2014 letter. 

The SFPU C provides retail drinking water and wastewater services to the City 

of San Francisco, wholesale water to three Bay Area counties, and green 

hydroelectric and solar power to our municipal departments. We operate the 

Hetch Hetchy Project, located within Yosemite National Park and the 

Stanislaus National Forest in the Upper Tuolumne River watershed. The Hetch 

Hetchy Project supplies water and power to the City of San Francisco and 

surrounding Bay Area communities, and regulates stream flow in the Upper 

Tuolumne River, Cherry Creek, and Eleanor Creek. 

The Rim Fire burned within the SFPU C approved standby watersheds 

administered by the United States Forest Service (USFS). The approved 

standby watersheds affected by USFS activities include Cherry Lake 

watershed, Cherry Creek sub-watershed (downstream of Cherry Lake and 

Lake Eleanor to the Cherry Creek diversion and into the aqueduct), and the 

Tuolumne River sub-watershed (downstream from the National Park Service 

[NPS] boundary to Early Intake reservoir). The SFPU C has concerns related to 

potential contamination of the standby watersheds that may affect water 

quality. 

The current drought conditions throughout the State, including the Tuolumne 

River watershed, have significant effects on the availability of water we can 

supply to our 2.6 million customers in the Bay Area. At this point in the water 

year (October 1 through September 30), we don't expect to get any additional 

significant precipitation, which would make this the driest consecutive 3-year 

period in the 90-year record for which we have collected precipitation data. In 

response, we are working to repair the Lower Cherry Aqueduct (LCA, damaged 

in the Rim Fire), which would restore SFPUC' s historic capacity for accessing 

Edwin M. Lee 

Mayor 

Vince Courtney 

President 

Ann Moller Caen 

Vice President 

Francesca Vietor 

Commissioner 

Anson Moran 

Commissioner 

Art Torres 

Commissioner 

Harlan L. Kelly, Jr. 

General Manager 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-35
the Cherry Creek standby watershed for domestic drinking water supply during 

dry periods. We are working to make the LCA functional within this calendar 

year. Ongoing work includes acquiring a permit from the California Department 

of Public Health. Since it is increasingly likely that these standby watersheds, 

for which the SPFU C has water rights, will be used for domestic water supply 

for extended periods of time starting as early as November 2014, our concerns 

related to potential effects from salvage logging activity (e.g., turbidity) have 

also increased. 

Purpose and Need 

The SFPU C supports the USFS management goals and overall purposes. The purpose 

and need identified on page 8 includes: Capture Economic Value through Salvage 

Logging; Provide Worker and Public Safety; Reduce Fuels for Future Forest Resiliency; 

Improve Road Infrastructure to Enhance Hydrologic Function; and Enhance Wildlife 

Habitat. Table 2.01-1 also identifies "Research" as a primary objective. 

Although not covered by this EIS, SFPU C supports restoration and reforestation efforts 

(e.g., shaded fuel breaks) in future proposed projects. This applies to both harvest units 

and burned areas between harvest units. 

The Enhance Wildlife Habitat purpose and need includes retaining burned forest across 

the landscape. The SFPU C understands the potential need to retain habitat for wildlife 

dependent on post fire environments. However in standby watersheds, the SFPU C 

prefers restoration to a forested landscape where appropriate (e.g., salvage timber 

harvesting and reforestation). 

Proposed Action 

General Comments 

The SFPU C supports all three action alternatives (Alternatives 1, 3, and 4) but is only 

providing comments on the Preferred Alternative (Alternative 1). The USFS proposed 

action includes: 

salvage of dead trees; removal of hazard trees along roads open to the 

public and roads used to access and implement proposed treatments; 

fuel reduction for future forest resiliency to fire; and, road improvements 

for proper hydrologic function. Implementation is expected to begin 

summer 2014 and continue up to 5 years. Roadside hazard trees will be 

designated for removal using the Hazard Tree Guidelines for Forest 

Service Facilities and Roads in the Pacific Southwest Region, April 2012 

(Report RO-12-01). Dead trees in salvage units will be designated for 

removal based on "no green needles visible from the ground". 

Much of the east side of Cherry Lake has a mosaic burn that retained green crowned 

trees. Sampling in this area indicated that some of the green crowned trees have 

significant cambium damage and may not survive. Returning to harvest tree mortality or 

leaving significant amount of dead/dying trees does not meet the USFS stated goals and 

creates more potential water quality impacts over time. 

2 

Rim Fire Recovery (43033) 

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L-36
USFS Report #RO-11-011

 provides salvage tree marking guides to allow trained tree 

markers to designate trees highly susceptible to mortality. The SFPU C suggests using 

trained tree marking crews that use established USFS marking guidelines and specific 

prescriptions developed (or reviewed) by a USFS Certified Silviculturist with 

Interdisciplinary (ID) Team input. 

SFPU C staff reviewed some of the burned portions of the standby watersheds. The 

following comments are based on field surveys, moderate/high burn intensity maps, and 

aerial photos: 

• West Side of Cherry Lake. The USFS 2010 Forest Plan classifies all treatment units 

within the General Forest Management Area. 

> Unit D09: The USFS Groveland Ranger District applied (or planned to apply) for 

funding from the USFS Regional Office for the Granite Watershed Road 

Restoration Project. One purpose of this project was to close the road in Unit 

D09. The SFPU C wrote a letter of support for this project in 2011. Map 1 

indicates this road will be reconstructed. The SFPU C prefers that this road be 

used only for administrative purposes and either be decommissioned or 

otherwise closed at the end of restoration activities (e.g., to be a temporary road 

through timber harvesting and reforestation). 

> Unit D12: Reviews indicate this unit could extend a little to the south and much 

further to the north. The dead plantations outside of D12 are the same size and 

age as the trees within D12. The SFPU C prefers that the entire area be salvage 

harvested and restored to a forested condition. It is unclear what will occur to the 

dead plantations not included as units (-600+ acres). 

• East Side of Cherry Lake. The USFS 2010 Forest Plan classifies all treatment units 

within the Wildlife Management Area. Observations indicate a mosaic burn and 

underburn throughout most of the area. Units 011A and 012 are the only units 

mapped with moderate/high burn intensities, although all the designated units (Units 

O08 through 12) exist in areas of concentrated mortality. 

Burn intensities increased as the fire moved from Cherry Lake towards Lake Eleanor. 

Green crowned trees may be dead and some browned crowned trees may be live 

depending on cambium condition and whether the terminal buds are live. Based on 

probable continued burned tree mortality, the entire area east of Cherry Lake to the 

NPS boundary could be one unit and be marked as described in Report # RO-11 -01. 

Another option is to maintain the individual units but designate the remaining area for 

salvage as trees die within the time period of this proposed project. 

• Tuolumne River Sub-watershed near Camp Mather. The USFS 2010 Forest Plan 

classifies all treatment units within the Scenic Corridor Management Area. SFPU C 

would appreciate quick action near Camp Mather (Units Q14a, 14b, and U02). 

SFPU C would appreciate harvesting in the burned areas to the west and north of 

Camp Mather that are currently not included in Map 1. 

• Granite Creek watershed. The SFPU C appreciates and supports efforts to mitigate 

soil movement and debris flows that could potentially impact Holm Powerhouse. The 

SFPU C supports all restoration efforts and encourages reforestation throughout the 

1

 US Forest Service, Region 5, Forest Health Protection May 2011 (Report # RO-11 -

01); Marking Guidelines for Fire-Injured Trees in California, by Sheri L. Smith and 

Daniel R. Cluck 

3 

Rim Fire Recovery (43033) 

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L-37
area. 

Comments on Management Requirements 

4c, page 26. Falling trees into watercourses at greater than 45 degrees from 

perpendicular could divert water flow into and erode streambanks. This potentially 

increases turbidity and negatively impacts water quality. Strategically placed logs across 

watercourses could slow water flow and create aquatic habitat. The SFPU C requests 

that this requirement include professional input on a site-specific basis. 

Table 2.03-3, Application of Registered Borate Compound, page 41. Table 2.03-3 does 

not specify application to stumps from green trees only. This contradicts Item 6 on page 

43 that specifies "(green trees only)." Please ensure consistency with "green trees only" 

as it may not be necessary to apply this pesticide if trees are dead without any green 

needles (USFS Report No. R06-012). The SFPU C does not dispute the analysis on 

pages 85 and 285, although applying only to green dying trees would better meet the 

USFS stated economic goals and minimize pesticide use in the watersheds. 

Comments on Road Use, Improvements, and Maintenance 

SFPU C has specific concerns (detailed in SFPUC' s scoping letter dated January 3, 

2014) with Forest Roads 1N14, 1N04, 1N86, 1N96, 1N96E, 1N82, 1N07, and 1S02. 

SFPUC' s concerns are generally addressed in the purpose and need item 4 on page 8 

and in management requirements (Table 2.03-3, page 37). The specific concerns were 

not located in the EIS other than Roads 1N14, 1N04, 1N86, 1N96, 1N96E, 1N82 being 

designated for reconstruction in Appendix E, pages 509, 510, and 512. 

SFPU C would appreciate the USFS contacting and working with Hetch Hetchy Water 

and Power (HHWP) staff when working on these roads: 

1. Forest road 1N14 is a primary access road to Lake Eleanor for SFPU C and 

Yosemite National Park. 

a. Associated units O01, O02, O201. 

b. Surface replacement 

c. Grading and drainage. Upon completion timber operations the road should be 

graded, culverts and ditches cleaned. 

d. Improvements, crossing. Please coordinate drainage improvements with 

HHWP. 

2. Forest road 1N04from its origin to the intersection with 1N14. 

a. The road has a number of survey benchmarks on the dam used to monitor 

movement. The monuments should be identified and left undisturbed. 

b. During grading surface material should be floated back across the road and 

not cast off the road. 

3. Burnout Ridge Road is a new spur road off 1N86 and provides access to the Burnout 

Ridge Communication site. 

a. Associated units N03 

2

 Report No. R06-01, 3420 Evaluation, March, 2006. Efficacy Of Treating Live Vs. 

Dead Stumps With Sporax® To Prevent Annosus Root Disease. John Kliejunas and 

James Allison, Plant Pathologists, Pacific Southwest Region, and William Otrosina 

Plant Pathologist, Southern Research Station 

4 

Rim Fire Recovery (43033) 

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b. Grading and drainage. This road has a steep approach to the facility and 

should not be used for skidding. Upon completion timber operations the road 

should be graded, culverts and ditches cleaned. 

4. Forest roads 1N96, 1N96E, 1N82 are primary project roads used and maintained by 

HHWP. 

a. Associated units N01 

b. Grading and drainage. Upon completion of timber operations the road should 

be graded, culverts and ditches cleaned. 

Historically the Cherry Lake Road has not been used as a primary haul route from the 

junction of 3N01S (aka Jawbone cutoff) to the junction 1S02 (aka Mather Road). This 

area is very steep; road width is narrow and has experienced numerous slides in the 

past. In addition, Rim Fire effects have created significant additional rock fall hazard. 

During the winter months the north slope of the Tuolumne River canyon does not receive 

any direct sunlight resulting in icy road conditions that require bi-weekly or daily sanding. 

HHWP maintenance crews conduct snow removal on Cherry Lake road during the winter 

months from State Route 120 to it terminus at Cherry Compound. 

5. Forest road 1N07, Cherry Lake road north of Tuolumne River. The Cherry Lake road 

is the primary access road used by HHWP personnel. In addition HHWP invests in 

annual improvements to drainage and pavement. 

a. Associated units M05, N01 

b. Crossings other than existing should be avoided. Landing on the road should 

be avoided. If crossings are proposed other than existing, coordinate with 

HHWP ROW Maintenance Manager on approach design, timing, and 

equipment type. 

6. Forest road 1N07, Cherry Lake road south of the Tuolumne River. The Cherry Lake 

road is the primary access road used by HHWP personnel. In addition HHWP invests 

in annual improvements to drainage and pavement. 

a. Associated units W03, W05, V04 

b. The junction of 1N07 and 1S02 (Mather road) is a significant location on the 

HHWP project. The top of Intake Hill is a convergence of facilities; both power 

transmission and distribution lines as well as access roads all share this small 

area. Directly below this point at the bottom of the canyon is the Intake 

Switchyard. Several watercourses pass through both roads and drain into 

the switchyard at which point they are diverted into the Tuolumne River. 

c. All slash should be removed or stabilized above the high water mark along 

the watercourses between 1N07 and 1S02. 

d. Landing location should be coordinated with HHWP ROW Maintenance 

Manager prior to start of operations. 

7. Forest Road 1S02 (Mather Road) is the primary access route for SFPU C staff and 

the general public visiting the National Forest, Yosemite National Park (Hetch Hetchy 

Reservoir) and Camp Mather. Traffic can be heavy at times. The road is set along 

the rim of the Tuolumne River Canyon and passes through several steep cliff areas. 

a. Associated units W06, U01, U02, U03 

b. Public Safety is a primary concern. 

i. During haul set up traffic lights to control traffic on narrow segments, 

blind corners and steep slopes. 

ii. Establish a maximum speed of 25 through steep cliff areas. 

iii. Restrict hauling during the week leading up to the Strawberry Festival 

and part of the week after. 

5 

Rim Fire Recovery (43033) 

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Letters from Federal, State and Local Agencies

L-39
iv. Avoid hauling logs during the winter months. 

Comments on Power Transmission and Distribution Lines & Riqht-of-Wav 

The following mitigations for "Power Transmission and Distribution Lines & Right-ofWay" were also not found in the draft EIS: 

• Working around transmission lines. 

a. Minimum "Safe Clearance^', organized by operating voltage, are specified by 

Cal/OSHA, California Public Utilities Commission General Order 95 and the 

National Electrical Safety Code (NESC). For the appropriate clearances 

related to HHWP facilities, it is best to assume you are working near 

energized 230,000 volt transmission lines. Follow all safety guidelines when 

working under or adjacent to transmission lines. 

b. No jackpot piling within the wire zone on the transmission ROW. 

c. No whole tree processor piles allowed on the transmission ROW. 

e. No decking logs against towers. 

f. No landing logs and loading trucks in the wire zone. 

g. Notify HHWP ROW Maintenance Manager prior to falling operations adjacent 

to tranmssion ROW in units N01, W05, W06, U01 and U03. 

• Working around distribution lines. 

a. Follow CAL OSHA guidelines for working with boom type equipment.. 

b. No jackpot piling within 50' of the centerline on the distribution ROW. 

c. No whole tree processor piles allowed within 150' of the centerline on the 

distribution ROW. 

e. No decking logs against distribution poles. 

f. No skidding within 25' of guy wires. 

g. No landing logs and loading trucks in the power distribution ROW unless 

approved by HHWP ROW Maintenance Manager. 

h. Notify HHWP ROW Maintenance Manager prior to falling operations adjacent 

to power distribution ROW in units N01, W05, W06, U01 and U03. 

Thank you for the opportunity to provide our comments. We look forward to further 

involvement and discussion with Stanislaus National Forest staff on the Rim Fire 

Recovery project. 

Sincerely, 

~Pd/i Tim Ramirez 

Natural Resources and Lands Management Division Manager 

cc: Margaret Hannaford, Division Manager, SFPUC-HHWP 

Andrew DeGraca, Division Manager, SFPUC-WQ 

Mike Vroman, ROW Maintenance Manager, SFPUC-HHWP 

Ellen Natesan, Planning and Compliance Manager, SFPUC-NRL M 

Peter Dean, Regulatory Specialist, SFPUC-NRL M 

Tom Francis, Watershed Forester, SFPUC-NRL M 

Deborah Craven-Green, Permitting Manager, SFPUC-BE M 

Moccasin Records 

6 

Rim Fire Recovery (43033) 

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Appendix L 

Letters from Federal, State and Local Agencies

L-40
nn-'Ho',^
 

A"NZJ UNITBD STATES EN\iIRONMENTAL PROTECTION AGENCY


REGION IX '.t, -re
 '44 pnot€o' 75 Hawthorne Street
 

San Francisco. CA 94105-3901 

June 12,2Ol4 

Susan Skalski, Forest Supervisor 

Stanislaus National Forest 

Attn: Rim Recovery 

19777 Greenley Road 

Sonora, CA95310 

Subject:	 Draft Environmental Impact Statement for the Rim Fire Recovery Project, Stanislaus 

National Forest, California. (CEQ# 20140141) 

Dear Ms. Skalski: 

The U.S. Environmental Protection Agency has reviewed the Draft Environmental Impact Statement for 

the Rim Fire Recovery Project, Stanislaus National Forest, California. Our review is provided pursuant 

to the National Environmental Policy Act, Council on Environmental Quality regulations (40 CFR Parts 

1500-1508), and our NEPA review authority under Section 309 of the Clean Air Act. 

The Proposed 	Action would initiate the first step of recovery through the salvage of dead trees across 

more than 28 thousand acres of the Stanislaus National Forest, and would include 5.4 miles of new road 

construction,13.2 miles of temporary roads, 319.9 miles of road reconstruction, and,216.I miles of road 

maintenance deemed necessary for safe timber salvage operations. The document also proposes the use 

of both helicopter and tractor landings to facilitate timber removal. We appreciate that the project limits 

the number of landings within Protected Activity Centers for species of concern. We recommend that 

the FEIS include a closure and restoration plan for the proposed temporary roads and landings when the 

project is completed. 

The EPA commends the Forest Service for limiting operations in areas containing species of concern 

such as spotted owls, goshawks, great gray owls, and bald eagles, in order to avoid direct adverse 

impacts to the species. While salvage of dead trees could destroy some potential habitat, we understand 

that the Forest Service anticipates that the vast amount of remaining unlogged charred and/or dead trees 

may be enough to sustain the surviving wildlife species dependent on post-fire environments. We 

recommend that the Final Environmental Impact Statement include the results of consultation with the 

United States Fish and Wildlife Service. 

The project location contains potential areas of importance historically, culturally, and spiritually to 

local Tribes such as the Tuolumne Me-Wuk and Chicken Ranch Rancheria. We recognizethatTribal 

Consultation is an important component of the decision-making process associated with this project, and 

encourage the Forest Service to continue meaningful consultation, throughout the NEPA process, with 

all potentially affected tribal governments. We recommend that the results of consultations with tribal 

govemments and with the Tribal Historic Preservation Office/State Historic Preservation Office be 

included in the FEIS. 

Rim Fire Recovery (43033) 

Environmental Impact Statement

Appendix L 

Letters from Federal, State and Local Agencies

L-41
EPA has rated the DEIS and all action alternatives as Lack of Objections-LO (see enclosed "summary 

of Rating Definitions"). We support the best management practices and resource protection measures 

included in the project design. We recommend that the Final EIS incorporate the additional measures 

and information specified above. 

Thank you for the opporlunity to review this DEIS. We also appreciate the Forest Service's coordination 

with us prior to and during our review, via workshops. phone calls and a site visit. When the FEIS is 

released, please send one hard copy and one CD to the address above (mail code: ENF-4-2). If you have 

any questions, please contact me at (415) 972-3521, or have your staff contact James Munson, the lead 

reviewer for this project. James can be reached at (415) 972-3852 or Munson.James@epa.gov. 

Sincerely, @ts$ 

Kathleen Martyn Goforth, Manager 

Environmental Review Section 

Enclosure: Summary of the EPA Rating System 

Rim Fire Recovery (43033) 

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Appendix L 

Letters from Federal, State and Local Agencies

L-42
SUMMARY OF EPA RATING DEFINITIONS*
 

This rating system was developed as a means to summarize the U.S. Environmental Protection Agency's (EPA) level of 

concern with a proposed action. The ratings are a combination of alphabetical categories for evaluation of the environmental 

impacts of the proposal and numerical categories for evaluation of the adequacy of the Environmental Impact Statement (EIS). 

ENVIRONMENTAL IMPACT OF THE ACTION 

((LO" (I-ack of Objections) 

The EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. The 

review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than 

minor changes to the proposal. 

" E C " (Envir onm e ntal C o nc ern s) 

The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. 

Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the 

environmental impact. EPA would like to work with the lead agency to reduce these impacts. ( (

E O" ( E nvir o nme ntal Obj e c tio n s) 

The EPA review has identified significant environmental impacts that should be avoided in order to provide adequate 

protection for the environment. Corrective measures may require substantial changes to the preferred alternative or 

consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends to work 

with the lead agency to reduce these impacts. 

('EfJ " (E nviro nme ntally U ns atisfactory ) 

The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory 

from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce 

these impacts. If the potentially unsatisfactory impacts are not corected at the final EIS stage, this proposal will be 

recommended for referual to the Council on Environmental Quality (CEQ). 

ADEOUACY OF THE IMPACT STATEMENT 

Category "1" (Adequate) 

EPA believes the draft EiS adequately sets forth the environmental impact(s) of the preferred alternative and those of the 

alternatives reasonably available to the project or action. No furlher analysis or data collection is necessary, but the reviewer 

may suggest the addition of clarifying language or information. 

C ate g ory " 2 " (I ns uffi cie nt I nformatio n) 

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in 

order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within 

the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. The 

identified additional information, data, analyses, or discussion should be included in the final EIS. 

Category "3" (Inadequate) 

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or the 

EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed in 

the draft EIS. which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes 

that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full 

public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 

309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft 

EIS. On the basis of the potential significant impacts involved, this proposal could be a candidate for referual to the CEQ. 

*From EPA Manual 1640, Policy and Procedures for the Review of Federal Actions Impacting the Enviroqment. 

Rim Fire Recovery (43033) 

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L-43
TUOLUMNE ME-WUK TRIBAL COUNCIL 


Post Office Box 699 


TUOLUMNE, CALIFORNIA 95379 


Telephone (209) 928-5300 


Fax (209) 928-1677 


30 June 2014 

Susan Skalski, Forest Supervisor 


Stanislaus Nation Forest 


19777 Greenly Road 


Sonora, Ca lifornia 95370 


SUBJ: DRAFT ENVIRONMENTAL IM PACT STATEMENT Rim Fire Recovery (43033) 

Dear Supervisor Skalski, 

The Tuolumne Band of Me-Wuk Indians has reviewed the above referenced and endorses Alternative 4. 

The Tribe believes this alternative is more realistic and obtainable as it addresses the issues and 

concerns related to Forest Snag Habitat, New Road Construction, Wildlife Habitat, and Soil and 

Watershed Impacts. 

The two proposed actions in Alternative 4 for Salvage and Fuel Reduction and Hazard Tree Removal and 

Fuel Reduction had multiple benefits. The first benefit would be to socio-economic values. The creation 

of jobs would be seen as a beneficial economic impact to the region, as well as the ability to capture the 

· 	·economic value of a perishable commodity in a timely manner. The second benefit is to the health and 

safety of human life and property. The harvesting of dead timber reduces the existing fuel load of 

standing dead trees to protect multiple resources including soils and watersheds from future highintensity fires. The third benefit is the proposed actions for Wildlife Habitat Enhancement. The action 

addresses issues and concerns by proposing additional wildlife habitat enhancement including biomass 

removal in Critical Deer Winter Range and the Forest Carnivore Connectivity Corridor Amendment. The 

fourth benefit will be to address impacts to soil and watersheds that has resulted from the Rim Fire. The 

proposed actions for soil address erosion control and soil stability is imminent to forest health and water 

quality. The fifth and last benefit is research. This action will help answer wildlife, fuels, watershed, and 

soil questions regarding the impacts and evaluation of proposed activities. This is a unique opportunity 

for university and other specialists to study the effect of a fire of this scale and intensity. 

In regards to cultural resources, the Tribe has been consulted in the development of a specialized 

agreement entitled "Programmatic Agreement Among the United States Forest Service, Stanislaus 

National Forest, the California State Historic Preservation Office, and the Advisory Council on Historic 

Preservation, Regarding eh Compliance and Adverse Effects to Historic Properties caused by the Rim Fire 

Emergency, Tuolumne County, California" and will be a concurring party signatory. 

Rim Fire Recovery (43033) 

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The Tribe's biggest concern is Alternative 2-No Action. The number one negative impact would leave 

tens to hundreds of tons of fuel per acre that would be a perfect environment for another catastrophic 

fire. Leaving existing hazard trees to fall on their own as a result of natural forces would cause roads to 

likely remain closed to public access and rending access for firefighting virtually impossible. The cost for 

future activities where removal of this material is essential to implementation would be far more 

expensive and perhaps become cost prohibitive. The negative impacts to recreation would impede 

public access by administrative access constrained, closure of areas for dispersed camping and firewood 

gathering not allowed. Also the potential impact for soil erosion rates will remain high and could be very 

detrimental in the event of a wet rainy season. The opportunity for research would be lost. Without any 

proposed actions the forest will become nothing more than brush fields that would have detrimental 

effects to our forest's health. 

If you have any question, please do not hesitate to contact Tribal Liaison Reba Fuller. 

Sincerely, 

:z =====-=<............_ 


Kevin Day, Tribal Chairman 

Cc: Randy Moore, Region 5, Regional Forester 

Rim Fire Recovery (43033) 

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Appendix L 

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