APPENDIX K 

CONSIDERATION OF MAPS 

SUBMITTED BY 

SIERRA CLUB ET AL. 

 
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Appendix K

Consideration of Maps submitted by the Sierra Club et al. 

This appendix displays how the Forest Service considered the maps presented by Sierra Club et al. for the 

Cobbler II project. 

Background

The two maps included in this appendix were submitted by the Sierra Club et al. as an exhibit in their 

appeal of the 2009 Cobbler Decision Notice, and were incorporated with the statement “we again 

additionally request that the entirety of our previously submitted comments, our appeal, and all appeal 

exhibits be included in the Cobbler II project file from the onset of this renewed analysis project” in their 

subsequent comments on Cobbler II EA and Cobbler II DEIS. 

The first map they provided is entitled Exhibit D, Wilderness, IRA, and Cobbler Project proximity, 

uninventoried roadless & connectivity. The second map is a copy of the Forest Service’s map of 

Silviculture Prescriptions and Harvest Methods of Alternative B that was included in Appendix A of the 

EA and is included in Appendix A of this FEIS and will not be discussed in this appendix. 

Consideration of first map in Sierra Club et al. Appeal dated June 20, 2009

1. Their notice of appeal on the Cobbler 2009 Decision Notice in reference to their Exhibit D states on 

page 23: 

See Appeal Exhibit D which contains maps that illustrate the proximity of the Cobbler Project to 

wilderness and roadless areas, and Appeal Exhibits A and B1 which document the site-specific and 

overall conditions within the Cobbler Project units. 

Response:

Cobbler II FEIS has maps in Appendix A and Appendix H (maps H-3 to H-11) that show the 

proximity of the Cobbler II project planning area and proposed activity areas with respect to the 

Wenaha-Tucannon Wilderness, the Grande Ronde Inventoried Roadless Area (IRA), potential 

wilderness areas (PWAs), and other undeveloped lands. Disclosure of the affected environment and 

environmental effects to these areas can be found in Chapter 3 of the FEIS on pages 3-131 to 3-152. 

2. Also on page 23 their appeal notice states: 

The FS had only provided a map and other data describing the logging location, which the 9th Circuit 

determined would only let the public discover that the roadless areas would be significantly affected. 

Id. at 1232. Rather, the FS was required to disclose that significant roadless areas would be affected 

and analyze those environment effects. Id. In the FS's disclosure and analysis, the agency was 

required to disclose the unique environmental benefits provided by these areas and the impacts that 

the project would have on those qualities. See, e.g., Sierra Club v, Austin, 82 Fed. Appx. 570, 573 

(9th Cir. 2003) 

 

1

 Exhibit A contains photos and Exhibit B contains survey forms 
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Response:

See response to number 1 above, and see below the lists of indicators used to compare environmental 

effects to these areas (FEIS, Chapter 3 pages 3-134, 3-137, and 3-147). Values and features used to 

often characterize inventoried roadless areas (36 CFR 294) were used for these resource issues. 

Indicators for Wilderness: 

o Untrammeled, Undeveloped, and Natural – The Wilderness Act states that wilderness is “an 

area of undeveloped Federal land retaining its primeval character and influence, without 

permanent improvements of human habitation; and generally appears to have been affected 

primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable.” 

o Outstanding opportunities for solitude and remoteness – The Wilderness Act states that 

wilderness has “outstanding opportunities for solitude or a primitive and unconfined type of 

recreation.” This quality is about the opportunity for people to experience the wilderness; it is 

not directly about visitor experiences per se. 

Indicators for Potential Wilderness Areas/Inventoried Roadless Areas: 

The following values and features often characterize inventoried roadless areas (36 CFR 

294): 

o High quality or undisturbed soil, water, and air 

o Sources of public drinking water 

o Diversity of plant and animal communities 

o Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those 

species dependent on large, undisturbed areas of land 

o Primitive, semi-primitive, non-motorized and semi-primitive motorized classes of dispersed 

recreation 

o Reference landscapes 

o Natural appearing landscapes with high scenic quality 

o Traditional cultural properties and sacred sites and 

o Other locally identified unique characteristics 

o Change in acres of inventoried PWAs (degree of change and impact to a future evaluation of 

potential additions to the National Wilderness Preservation System in Land Management 

Planning) 

Indicators for Other Undeveloped lands: 

• Intrinsic physical and biological resources (soils, water, wildlife, recreation, fisheries, etc.) 

• Intrinsic social values (apparent naturalness, solitude, remoteness) 

• Change in acres of other undeveloped lands 

• Change in size class of other undeveloped lands 

3. On pages 23 to 24 their appeal notice states: 

As noted above, the Cobbler Project would log in undeveloped and unroaded areas contiguous with 

and clearly ecologically part of the area’s inventoried roadless and wilderness areas. Among units of 

concern that the agency failed to adequately disclose and address are all those units immediately 

adjacent to the Wenaha Tucannon Wilderness and/or the Grande Ronde IRA, and all units and 

portions of units where there exists no road barrier between these areas and the unit or portion 

thereof. Though uninventoried roadless areas are included among the project logging units, the EA 

and DN fail to disclose how many acres these area, where they are located, their ecological sitespecific conditions, or to adequately address logging and management action impacts. Appellants 

Exhibit D with a map of Cobbler Project units and a map of the location of Wilderness and IRA areas 

evidences the proximity and important ecological connectivity of much of the Cobbler Project area 
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linking the Wenaha Tucannon Wilderness with the Grande Ronde IRA. The EA and DN must be 

withdrawn, and an EIS conducted that sufficiently acknowledges and addresses these critically 

important ecological issues. 

Response:

All acres in Cobbler II project planning area (34, 000 acres) have been inventoried for PWAs showing 

locations, acreages, and proximity of proposed activities (harvest units and prescribed fire). 

Disclosure of acreages and locations are found in the FEIS, Chapter 3 pages 3-139, 3-140, 3-145, 3-

147, 3-150, and in Tables 3-55, 3-56, 3-57, 3-58, and 3-60 and in Appendix H , pages H-1 to H-6 and 

maps H-3 to H-11. 

Site-specific conditions and management actions are disclosed for the Wenaha-Tucannon Wilderness, 

PWAs including the Grande Ronde IRA and other undeveloped lands are disclosed in the FEIS, 

Chapter 3, pages 3-131 to 3-152. 

There are no activities proposed in the Wenaha-Tucannon Wilderness or to potential wilderness areas 

(PWAs) adjacent to the Wilderness (FEIS, Chapter 3, page 3-134). All acres (177,469) within the 

Wenaha-Tucannon Wilderness would remain as wilderness with implementation of any alternative 

(FEIS, Chapter 3, page 3-136). All 130 acres within the inventoried PWAs contiguous with WenahaTucannon Wilderness would remain within the PWA inventory following implementation of any 

alternative. Thus, all 130 acres would be available for evaluation of potential wilderness (FSH 

1909.12, Chapter 72) and preliminary administrative recommendations for wilderness designation 

(FSH 1909.12, Chapter 73) during forest plan revision (FEIS, Chapter 3, page 3-136). 

No road construction would occur in the Grande Ronde PWA/IRA. No roads exist in this area; 

therefore, no road use or maintenance would occur. No timber harvest would occur. No proposed 

project activity would occur on the 55 acres outside the project planning area boundary that meet 

PWA inventory criteria. Landscape prescribed fire activities are proposed in the Grande Ronde 

PWA/IRA. Approximately 7,000 acres would have landscape prescribed fire treatments in the IRA 

portion and approximately 400 acres (PWA) that extend beyond the IRA boundary and are 

contiguous to the IRA would have landscape prescribed fire treatments. Other activities proposed to 

occur in the Grande Ronde PWA/IRA would be the removal of danger trees(only trees with an 

imminent failure potential) along haul routes, and the fencing and girdling of hardwoods (only in the 

IRA portion). See the FEIS, Chapter 3, Table 3-56 for a summary of activities proposed in the 

Grande Ronde PWA/IRA and Appendix A for a map entitled Other Activities Common to Both 

Alternatives to view locations where activities would occur (FEIS, Chapter 3, page 3-140). 

All 7,960 acres (FEIS, Chapter 3, Table 3-57) identified as PWAs (including the Grande Ronde IRA) 

would remain in the PWA inventory following implementation of any alternative. Thus, all 7,960 

acres would be available for consideration in an evaluation of potential wilderness (FSH 1909.12, 

Chapter 72) and preliminary administrative recommendations for wilderness designation (FSH 

1909.12, Chapter 73) during forest plan revision (FEIS, Chapter 3, page 3-145). 

There are approximately 5,660 acres of other undeveloped lands in the Cobbler II project planning 

area. Harvest activity is proposed in approximately 635 acres in Alternative B and 210 acres in 

Alternative C(FEIS, Chapter 3, Table 3-61). Remaining undeveloped lands with no proposed harvest 

activity (5,025 acres in Alternative B and 5,450 acres in Alternative C) would retain their intrinsic 

physical, biological, and social values as described in the affected environment. They would remain 

free of developments such as forest roads timber harvest stumps. All 5,660 acres of other 

undeveloped lands (harvested and unharvested) within the project planning area would still not be a 

potential wilderness area, inventoried roadless area, or a designated wilderness area. This outcome is 
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consistent with the intent of the land allocation decisions made in the Forest Plan (FEIS, Chapter 3, 

page 3-152). 

Old forest (key issue) connectivity was disclosed in the FEIS, Chapter 3, pages 3-87 to 3-91 and also 

on pages 3-142 and 3-143 under the heading Diversity of Plant and Animal Communities, TE&S 

Species, and Species Dependent on Large Undisturbed Areas of Land. 

The Forest Service has responded to other comments and concerns presented by the Sierra Club et al. 

for this project regarding roadless, unroaded, uninventoried roadless, inventoried roadless, 

undeveloped area, and roadless expanse in Appendix G (pages G-119 to G-177) and Appendix I 

(pages I-15 to I-102) of the FEIS.