APPENDIX I 

RESPONSE TO COMMENTS 

on the DEIS 

 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-1

INTRODUCTION 

A 45-day comment period for Cobbler II Timber Sale and Fuels Reduction Project was provided for 

interested and affected publics. Letters requesting comments were sent to the mailing list of interested 

parties maintained at the Umatilla National Forest Supervisor’s Office on April 20, 2010. They included 

federal, state and local agencies, Confederated Tribes of the Umatilla Indian Reservation, Nez Perce 

Indian Tribe, various environmental organizations, and interested individuals (see project file for mailing 

list). 

A notice of availability (NOA) was published in the Federal Register on April 30, 2010. The publication 

date of the NOA in the Federal Register is the exclusive means for calculating the comment period for a 

proposed action in a DEIS. Comments were accepted until June 14, 2010. 

A legal notice, in our newspaper of record (East Oregonian), to request comments was published on May 

2, 2010. The Forest Service received comments from different sectors of the public, with a range of 

concerns and comments. The responsible official will be considering these comments made in the 

decision-making process. 

The Forest Service received eight (8) responses during the 45-day comment period. Many responses were 

received electronically with copies and some attachments sent by U. S. Mail. All correspondence was 

reviewed and our responses to those comments are located on the following pages. All correspondence 

received is kept in the project file and is available for review at the district office in Walla Walla, 

Washington. 

The following table is a summary of letters received. 

Table I-1 Letters Received During the 45-day Comment Period for Cobbler II DEIS 

Letter Identification Number and 

Date Received Author(s) 

Individual, 

Organization or Agency

Letter #1 

May 6, 2010 Jean Public Individual 

Letter # 2 

June 1, 2010 John Fullerton Boise Building 

Letter # 3 

June 10, 2010 Dave Fritts Guy Bennett Lumber Co. 

Letter #4 

June 10, 2010 Doug Heiken Oregon Wild 

Letter #5 

June 14, 2010 Preston A. Sleeger U. S. Department of Interior 

Letter #6 

June 14, 2010 Charles H. Burley American Forest Resource Council 

Letter #7 

June 14, 2010 

Asante Riverwind 

Karen Coulter 

Jennifer Schwartz 

Oregon Chapter Sierra Club 

League of Wilderness Defenders – Blue 

Mountains Biodiversity Project 

Hells Canyon Preservation Council 

Letter #8 

June 14, 2010 

Christine B. Reichgott, 

Mgr. 

U. S. EPA, Region 10, Seattle, WA 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-2

Comments Received 

and 

Forest Service Response to Comments

Letter #1 (JP) 

Jean Public 

Comment 

Number Comment and Forest Service Response 

JP-1 Comment: 

stop raping our national forests for local lumber barons. stop letting grazing take place. we 

dont have george bush in office anymore. please see that all george bush/dick cheney anti 

environmental holdovers get fired. they are the scum of the earth because they want to 

destroy earth. they have very bad activities. all of our agencies went bad under the two who 

made corporate money into american god. 

Response:

Your comment has been noted. 

Letter #2 (JF) 

John Fullerton – Boise Building 

Comment 

Number Comment and Forest Service Response 

JF-1 Comment 

I would suggest the even the preferred alternative is too small in scope and scale and many 

more acres could be treated within this area. 

Response:

Cobbler II project EIS was designed to meet Forest Plan standards and guides, 

desired conditions, and objectives for the project (see FEIS, Chapter 1, pp. 1-3 to 1-5, 

and p. 1-15 for consistency with Forest Plan goals). 

JF-2 Comment 

There is also mention of elk habitat being effected equally through the 2 action alternatives, 

how can that be, if cover quality is reduced wouldn’t forage quantity be increased? Both 

alternatives have different acres also, how can the changes be the same. 

Response:

In the EIS the environmental effects analysis discloses the environmental effects that 

are common to all action alternatives (FEIS, Chapter 3, pp. 3-94 to3-95) and also 

included in the analysis is the difference in effects by alternative (FEIS, Chapter 3, pp. 

3-95 to 3-97). 

JF-3 Comment: 

Increasing OFMS to OFSS is appropriate to attain more balanced HRV. I would suggest 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-3

Letter #2 (JF) 

John Fullerton – Boise Building 

Comment 

Number Comment and Forest Service Response 

that in all treatment units mechanical commercial thinning be considered before fire alone, 

and that the non-saw volume be optional. That will help the economic and social viability 

of this sale. 

Response:

Your comment has been noted. Please see FEIS, Chapter 2, p. 2-17 which reads that 

different small material treatments (either commercial removal or mastication) would 

be implemented, depending on the economic conditions at the time of the sale. 

JF-4 Comment: 

My point about 21” harvesting you made for me (S19-20) I was referring to the harvest of 

these trees in the warm forest which does need a FPA, and I do not believe that without 

some of the larger fir trees leaving the landscape will you ever meet stocking standards 

near HRV. You also made my point about fuel loads and crown density are the primary 

factors to fire risk, not diameter limits, yet the FS continues to have a diameter limit on 

acres that shouldn’t. 

Response:

The Umatilla Forest Plan Amendment #11, commonly known as the Eastside Screens 

requires an analysis of trees > 21” DBH. Site-specific field reviews and stand exam 

data show that on a unit basis, recommended stocking levels can be reached without 

cutting trees > 21” DBH for this project. 

Letter #3 (DF) 

Dave Fritts – Guy Bennett Lumber Co. 

Comment 

Number Comment and Response 

DF-1 Comment: 

I would recommend that the non-saw volume (small diameter trees) be optional to the 

purchaser for removal, or allow for mastication of all of it in the appraisal 

Response: 

See response to comment JF-3. 

DF-2 Comment:

I would certainly encourage the Forest Service to put this sale up for auction 

Response:

Your comment has been noted. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-4

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

OW-1 Comment: 

We urge the FS to retain the RNA land allocation but to make a site specific amendment 

that would allow non-commercial restoration treatments. Turing the RNA into a special 

interest area allows too much flexibility that could someday degrade the RNA. 

Response:

Evaluations by the Blue Mountain’s Forest Ecologist, after completion of the Forest 

Plan (1990), indicated that formal RNA designation is not appropriate for Elk Flats 

Meadow because of the small size of the parcel, and because the aspen clones are 

ecotonal (i.e. transitional between forest and meadow) rather than true aspen forest 

(FEIS, Chapter 1, p. 1-4). It was recommended by Charlie Johnson, Forest Ecologist, 

that this proposed RNA not be formalized because of the reasons listed above. 

Elk Flats Meadow (70 acres) which is currently allocated as management area D2 as a 

proposed RNA candidate (not an established RNA) would be reallocated to 

management area A9- Special Interest Area, in order to allow vegetation 

management, including cutting and leaving of trees, to preserve and or enhance 

existing aspen and encourage aspen regeneration (FEIS, Chapter 2, p. 2-23). 

If there were no reallocation of acres from D2 to A9 aspen stands in Elk Flats 

Meadow would continue to decline and management options to sustain existing aspen 

stands would be limited and could result in a possible loss of the largest aspen site on 

Walla Walla Ranger District (FEIS, Chapter 3, p. 3-59 to 3-60). 

The goal for Management Area A9 is to manage, preserve, and interpret areas of 

significant cultural, historical, geological, botanical, or other special characteristics 

for educational, scientific, and public enjoyment (Forest Plan (FP) p. 4-131). 

OW-2 Comment: 

We urge the FS to fell only real hazard trees that pose an imminent risk of falling in the 

direction of well-travelled roads. And, where firewood poaching is not a significant risk, 

the FS should fell and leave hazard trees in the forest to mitigate for the lack of large down 

wood and to provide cover for animals near roads. 

Response:

Trees with an imminent failure potential and those deemed likely to fail within a 5-10 

year period would be felled along open system roads. Only danger trees with an 

imminent failure potential would be felled on haul routes along inventoried roadless 

areas, and on closed system roads. If considered economically feasible, these trees 

would be sold as part of a timber sale. Danger trees within Riparian Habitat 

Conservation Areas (RHCAs) would be felled and left to provide additional coarse 

woody debris (FEIS, Chapter 2, p. 2-20). 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-5

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

OW-3 Comment: 

We appreciate the low level of new roads required for this project but we remain concerned 

about treatments in ecologically significant unroaded areas and the complete lack of 

adequate NEPA analysis of impacts to these areas. 

Response:

Effects to potential wilderness areas (PWAs), inventoried roadless areas (IRAs) and 

other undeveloped lands can be found in Chapter 3 of the Cobbler II FEIS (pp. 3- 131 

to 3-152). The effects to the various resources that may occupy (i.e. vegetation) or 

utilize (i.e. wildlife) any particular acre of PWA or other undeveloped land can be 

found in the corresponding resource headings in Chapter 3 of the FEIS. 

OW-4 Comment: 

In our scoping comment we specifically asked the FS to analyze the special character of 

unroaded areas and not just rely on the resource-by-resource NEPA analysis, but that’s 

exactly what the FS did: 

In areas where proposed project activity would occur on these other undeveloped lands, the 

impacts to soil, water quality, air quality; plant and animal communities; habitat for 

threatened, endangered, and sensitive species; recreation; noxious weeds; and cultural 

resources, etc. are the same as disclosed for areas of proposed project activity in previous 

resource sections of this chapter and are not reiterated here. ... Cobbler II project, ... would 

have the same cumulative effects to soil, water quality, air quality; plant and animal 

communities; habitat for threatened, endangered, and sensitive species; recreation; noxious 

weeds; and cultural resources are disclosed in previous sections of this chapter and are not 

reiterated here. 

Response:

The nature of whether an acre of ground has been previously developed or not is a 

factor that allows the public and decision-maker a clearer picture of the many aspects 

of the current environment which the proposal will act upon and potentially modify. 

All other resources either utilize and/or occupy this landscape. Therefore, the effects 

determinations made for each resource of concern, as it relates to this project, are 

accurate and a separate analysis of each acre of land that does not have a history of 

development (i.e. past timber harvest and/or forest roads) for each of the resources 

identified in Chapter 3 of the FEIS would be redundant and more importantly does 

not add any additional information for the decision-maker to consider that is not 

displayed elsewhere in the FEIS. 

OW-5 Comment: 

...unroaded areas have a unique ability to provide snag habitat compared to the managed 

landscape, but the DEIS analysis does not reflect this fact, except to admit that every acre 

that is commercially logged will experience reduced snag habitat. The DEIS lacks an 

analysis to show that the level of snags that will be retained and recruited in the future will 

meet legal requirements. Is such an analysis were conducted, the FS might discover that the 

unroaded areas are critical to meeting that need. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-6

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

Response:

The snag analysis included both roaded and unroades areas. Snag habitat was

assessed at the landscape scale using the Current Vegetation Survey (CVS) data 

collected in the Wenaha and Grande Ronde River watersheds (FEIS, Chapter 3, pp. 

3-98 to 3-101 and Figures 3-5 to 3-8). 

OW-6 Comment: 

The EIS misrepresents the effect of logging on unroaded/undeveloped areas. The EIS (p 3-

145) says that there is only a 2% reduction in unroaded areas, but in fact 635 acres out of 

5660 acres is more than 11%. That is a lot, especially given the fact that unmanaged areas 

are rare and under-represented, and logging these undeveloped areas will move the

landscape away from, instead of toward, the historic range of variability for large snags and 

other LOS components in violation of the Eastside Screens. 

Response:

An updated version of the table (DEIS, p. 3-145, Table 3-61) and figures in question 

are now displayed in Chapter 3 of the FEIS (p. 3-151, Table 3-61). In an effort to 

present the information in a more understandable manner this table was revised in 

the FEIS. 

OW-7 Comment: 

Regen harvest will violate the Eastside Screens because it will move stand away from the 

historic range of variability which includes patches of unhealthy trees and patches of snags 

which are under-represented today. 

Regen harvest will deprive the stand of the complex woody structure associated with 

natural forest regeneration. This will violate the Eastside Screens requirement to manage 

toward the historic range of variability. The Eastside Screens address not just seral stages 

but also “components” of LOS forests such as snags and dead wood. 

Regen harvest also results in early seral forests that present a fuel hazard worse than the 

forests that are being replaced. This will conflict with the purpose and need. See DellaSala, 

D.A., D.M. Olson, S.E. Barth, S.L. Crane and S.A. Primm. 1995. Forest health: moving 

beyond rhetoric to restore healthy landscapes in the inland northwest. Wildlife Society 

Bulletin 23(3): 346-356. 

Response:

See Appendix F in the FEIS for a detailed analysis of how the project is consistent 

with the Eastside Screens amendment to the Forest Plan. 

Regeneration harvest is proposed in Moist Upland Forest, which is in Scenario B in 

the Screens. There is no restriction on regeneration harvest outside of large late old 

structure (LOS) stands, and stands that are not required to maintain or enhance 

connectivity. 

Activity fuels, following harvest, will be treated according to Forest Plan standards 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-7

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

and guidelines. 

See FEIS, Chapter 2, pp. 2-16 to 2-19 for a description of activity and natural fuels 

treatments, and Table 2-6-Design Features and Management Requirements. pp. 2-24 

to 2-31. 

OW-8 Comment: 

An appropriate restoration approach should involve several aspects that we do not see 

carefully considered in the DEIS, such as: 

• identifying areas that are certain to be in need of restoration, i.e. identify the 

problem being addressed in each stand proposed for treatment; 

• identify appropriate treatments for each forest type, e.g., lodgepole manages itself, 

Ppine probably needs encroachment removed; mixed conifer needs more untreated 

patches retained; 

• identify the right mix of treated and untreated patches so as to retain important 

ecological processes associated with unmanaged stands; 

Response:

Restoration of conifer forest is not listed in the Purpose and Need section for this 

timber sale and fuels reduction project (FEIS, Chapter 1, pp. 1-4 to 1-5). Restoration 

activities and objectives for hardwoods and meadows are included in the Purpose and 

Need and in the proposed action (FEIS, Chapter 1, pp. 1-7 to 1-8). 

OW-9 Comment: 

Variable density retention is a crucial aspect of forest restoration, but the FS rejected it here 

because it would be too expensive. We think the Eastside Screens require variable density 

thinning in order to comply with the requirement to move stands toward the historic range 

of variability. The DEIS incorrectly states that the analysis of VDT would be the same as 

the proposed action, only the implementation would be different, In reality, VDT would 

result is several important benefits such as patches of early seral vegetation (that would 

develop in heavily thinned “gaps”) and patches of mortality (that would develop in 

untreated “skips”) and these outcomes would greatly enhance the overall ecological 

benefits of treatment. 

We submitted some suggested prescriptions during scoping (“Tim’s Rx.doc”) that would 

help achieve variable density retention. 

Response:

See response to comment OW-8, and response to comment AFRC-4 below. 

OW-10 Comment: 

Our scoping comments said: 

Do not focus on reducing canopy fuels because, when all things are considered, reducing 

canopy fuels will do more harm than good. The NEPA analysis must carefully account for 

and balance all the competing effects. Do not gloss over the many complexities involved in 

fuel reduction. Canopy removal may slightly reduce the chances of fire leaping from tree to 

tree but this is primarily a weather driven phenomena, and canopy removal can also 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-8

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

_increase_ fire hazard by making the whole stand hotter, dryer, and windier and increase 

the intensity of surface fires and increase canopy damage from heat and flames, and canopy 

removal increases slash production and stimulates the growth of a new layer of future 

surface and ladder fuels. Canopy reduction also has adverse effects on a variety of other 

resources including wildlife, watershed, weeds, soil, carbon, scenic. Balancing all these 

effects is complex and requires careful NEPA analysis. 

We did not find an analysis in the EIS that considers let alone integrates and balances all 

these competing influences of canopy fuel reduction. 

Response:

While true that thinning can increase surface temperatures and reduce relative 

humidity and wind speeds, effects are highly variable and depend on specific 

prescriptions and topographic positions. 

In stands located along the rim of the Grande Ronde canyon and forest road (FR) 62, 

the focus of treatments is to modify the intensity and resulting fire behavior for safe 

and effective fire suppression actions. These strategic areas were chosen for 

treatment because fire is most likely to start in the Grand Ronde or Wenaha River 

drainages and spread quickly on steep slopes up to where it would burn into these 

stands on flat ground. In order to allow for safe and effective fire suppression in these 

stands, fire must remain burning in surface fuels with less than a 4-foot flame length 

and not burn into the overstory canopy. Several scientific publications have 

documented the need to treat stands at three levels to keep fire from burning into tree 

crowns, including Agee and Skinner, 2005; Mason et al. 2007; Hall and Burke, 2006 

and Scott and Reinhardt, 2001. These levels of treatment include; reducing surface 

fuels (to reduce flame lengths), increasing the height to live crowns, (requiring longer 

flame lengths for torching to begin), and decreasing crown density, (which makes 

tree-to-tree crown fire less probable). These treatment methods were employed in the 

above mentioned strategic locations to allow for safe and effective fire suppression by 

keeping fire from spreading into crowns.

OW-11 Comment: 

The EIS has conflicting information about it’s approach to treating canopy fuels. The 

purpose and need says the need is to reduce ladder fuels. It does not say there is a need to 

reduce canopy fuels, but Chapter 3 of the DEIS seems to indicate that canopy fuel

treatments motives has leaked in to the prescriptions. “This combination of surface and 

crown fuel treatments effectively reduces the risk of initiation and propagation of crown 

fires.” (DEIS p 3-73). This is inappropriate. It is highly likely that treating canopy fuels 

will actually conflict with fuel hazard reduction objectives. 

The agency must address the opposing viewpoints regarding the manifold values of 

retaining more canopy to retain cooler temperatures and moisture. Many experts say that 

reducing ground fuels and ladder fuels should be the first priority and reducing canopy 

fuels a lesser priority. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-9

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

Response:

While true that thinning can increase surface temperatures and reduce relative 

humidity and wind speeds, effects are highly variable and depend on specific 

prescriptions and topographic positions. 

The fuels treatments proposed in the Cobbler II Project are designed to prevent the 

movement of crown fires that originate in the Grand Ronde canyon out into the 

surrounding area. Following the principles defined by Agee and Skinner (2005), this 

project proposes to reduce surface fuels, increase the height to live crown, decrease 

crown density (by removing larger diameter ladder fuels, 6-9 inches) and to keep big 

trees of fire resistant species in strategically placed units along the rim of the canyon. 

This project proposes to treat ladder fuels in the 3 to 9-inch size range. This range of 

sizes includes 10-foot to 50-foot tall trees which have branches that occur at 3 feet (off 

the ground) and extend into the upper canopy. Many of these trees are not of 

commercial size and would be removed or treated using funds not associated with the 

timber sale. The trees on the upper end of this size scale are of commercial value and 

would be harvested as part of the Cobbler II timber sale. 

OW-12 Comment: 

The DEIS also misunderstands the role of forests in the carbon cycle when it implies that 

forest disturbances are "carbon neutral" as long as the carbon regrows over several 

centuries. In fact, the time between disturbance and full carbon recovery represents a period 

when “extra” carbon is in the atmosphere contributing to climate change. 

The FS needs to document the difference in carbon storage between all the alternatives, 

including the no action (conservation) alternative, and the FS must fully mitigate for the 

effects of increased warming due to carbon emissions for the full time period that the 

logging alternative stores less carbon than the no action alternative. 

The DEIS completely fails to document the quantitative effects of logging on carbon 

storage. 

Response:

Climate change as related to forest vegetation is covered in the FEIS beginning on pg. 

3-155 of Chapter 3. “The context of this climate change analysis is that Cobbler 

project planning area is too small for a direct evaluation of potential climate change 

effects caused by the proposed actions. Our current understanding of climate science 

suggests it is difficult to establish a cause-and-effect relationship between proposed 

actions and climate change at a project scale. Therefore, no attempt was made to use 

climate change as an issue during the NEPA process, and no indicators were 

established for comparing potential climate change effects between alternatives.” 

Research studies on the topic of carbon sequestration in forest management activities 

have produced conflicting conclusions. Carbon sequestration is covered in the FEIS, 

Chapter 3, pp. 3-159 to 3-163. The statement on p. 3-160 (FEIS, Chapter 3) reads 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-10

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

“Since a young forest might get established after fire and develop for 100-300 years, 

eventually recapturing an equivalent amount of C to what was released by the fire, 

forests can be “carbon-neutral” when evaluated across long timeframes” is a 

rewording of the statement in Ryan et al. 2010: “After fire, other disturbance, or 

harvest, regenerated forests will eventually recover all of the car-bon lost so that a 

complete cycle is carbon neutral regarding storage if the recovery is long enough.” 

This is not in conflict with the concept that current emissions and future sequestration 

may be accounted for differently in climate change research. 

The reference for Ryan et al. 2010, a recent overview of this topic, is: 

Ryan, Michael G.; Harmon, Mark E.; Birdsey, Richard A.; Giardina, Christian P.; 

Heath, Linda S.; Houghton, Richard A.; Jackson, Robert B.; McKinley, Duncan C.; 

Morrison, James F.; Murray, Brian C.; Pataki, Diane E.; Skog, Kenneth E. 2010. A

synthesis of the science on forests and carbon for U.S. Forests. Issues In Ecology, 

Ecological Society of America, 13:1-16.

OW-13 Comment: 

The DEIS seems to misinterpret several studies including those by Mitchell, Hurteau, and 

North. Hurteau and North are not very useful because they assumed that there was a 100% 

chance of wildfire after fuel treatments occurred, but this is an unreasonable assumption. 

We cannot know in advance where or when or how severe future fire might be, so in order 

to modify future fire behavior fuel treatments must be widespread and on going. Mitchell 

and Harmon showed that any such ambitious program of fuel treatments would transfer far 

more carbon to the atmosphere than fire would. The only exception was very light 

treatment of forests with the most frequent fire return intervals. The logging of mixed 

conifer forests and removal of trees between 12-21” dbh would not meet that description, 

and would likely transfer more carbon to the atmosphere. 

Response:

A variety of fuel treatments are proposed in the project planning area to address the 

purpose and need of the project. See FEIS, Chapter 2, Table 2-10, pp. 2-40 to 2-41 - 

Comparison of Alternatives. 

Wildfire is inevitable at some point in the future. Harvest and fuel treatments are 

designed to increase the probability of survival of large trees and early seral species 

after a wildfire by reducing the amounts of late seral species and small trees. 

Climate change as related to forest vegetation is presented in the FEIS (Chapter 3, pp. 

3-155 to 3-163). 

There are a number of different views on the topic and still no clear science as to the 

effect of forest thinning projects and carbon storage. For an overview of this topic see 

the following reference: 

Ryan, Michael G.; Harmon, Mark E.; Birdsey, Richard A.; Giardina, Christian P.; 

Heath, Linda S.; Houghton, Richard A.; Jackson, Robert B.; McKinley, Duncan C.; 

Morrison, James F.; Murray, Brian C.; Pataki, Diane E.; Skog, Kenneth E. 2010. A

synthesis of the science on forests and carbon for U.S. Forests. Issues In Ecology, 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-11

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

Ecological Society of America 13:1-16. 

Until there is a broader scientific consensus on carbon as it relates to forest 

management, it is difficult to assess how the Cobbler II project would impact carbon 

sequestration. 

See response to comment OW-12. 

OW-14 Comment: 

The DEIS implies that wood products provide a substitution value because they have a 

smaller carbon footprint compared to other building materials. However, there are several 

problems with this proposition. The analysis that support this finding are highly flawed in 

that they failed to account for the time it takes to reabsorb the carbon after forests are 

logged, differences in the useful lifespan of different building materials, the improving 

carbon efficiency of the energy input used to make alternative building materials, the 

possibility of demand-side policies such as recycling and “demand reduction.” 

Response:

See response to comment OW-13 and SC-56. 

OW-15 Comment: 

The EIS gives no assurance that prescriptions in connective corridors would meet the intent 

of the screens, i.e. "medium diameter or larger trees are common, and canopy closures are 

within the top one-third of site potential. Stand widths should be at least 400 ft. wide at 

their narrowest point. ... some amount of understory (if any occurs) is left in patches or 

scattered to assist in supporting stand density and cover."

Response:

Treatments proposed in connective corridors are “thinning from below” a term used 

synonymously with the term “low thinning.” Low thinning can create various stand 

structures and compositions, depending on the forest type and biophysical setting. 

The objective is to release the dominant and codominant trees by removing the lower 

crown classes. Portions of units within connectivity corridors are mapped and listed, 

such that marking guides are written to ensure that Eastside Screens’ standards are 

met (FEIS, Chapter 3, p. 3-89 and Appendix F). 

OW-16 Comment: 

Table 2-6 shows that the FS has established an objective to manage snags at only 2-3 large 

(>20” dbh) snags per acre. This objective is grossly inadequate to support viable 

populations of species that depend on snags. As the FS knows, current snag habitat 

standards are outdated 

Response:

Snags would be retained at a higher level than required in the Forest Plan. Data in 

DecAID indicates that low levels (1-4 per acre) of large snags are the natural or 

‘reference condition’ in the dry forest type. In moist forest, 2-4 large snags per acre is 

common under natural conditions. The requirement to retain the largest snags helps 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-12

Letter #4 (OW) 

Doug Heiken – Oregon Wild 

Comment 

Number Comment and Response 

to ensure that snags will stand for a longer period of time than would occur with 

smaller diameter snags. (Chapter 2, p. 2-28 and Chapter 3, pp. 3-98 to 3-104). 

OW-17 Comment: 

The DEIS admits that logging will reduce snag recruitment on 2500 acres and this effect 

will be long-term. The FS needs to do more to mitigate for this effect and adopt new 

standards to ensure the viability of snag-associated species. 

Response:

Even though snags could be affected on every acre treated (assuming snags are 

present on each and every acre), the overall effect to snags in the watershed is 

moderated by the prevalence of tree-killing insects and diseases in the area. 

See response to comment OW-16.

Letter #5 (DOI) 

Preston A. Sleeger – U. S. Department of Interior 

Comment 

Number Comment and Response 

DOI- 1 Comment:

The Department of the Interior has reviewed the Draft Environmental Impact Statement for 

the Cobbler II Timber Sale and Fuels Reduction Project, Walla Walla Ranger District, 

Umatilla National Forest, Wallowa and Union Counties, Oregon. The Department does not 

have any comments to offer 

Response:

Your comment has been noted. 

Letter #6 (AFRC) 

Charles H. Burley – American Forest Resource Council 

Comment 

Number Comment and Response 

AFRC-1 Comment: 

Though the preferred alternative does address the Purpose and Need for Action, AFRC 

suggests even the preferred alternative is too small in scope and many more acres could be 

treated within this area. 

Response: 

See response to comment JF-1. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-13

Letter #6 (AFRC) 

Charles H. Burley – American Forest Resource Council 

Comment 

Number Comment and Response 

AFRC-2 Comment: 

The description of Alternative B (Preferred Alternative) starting at page 2-10 is not clear 

about what silvicultural prescriptions are being proposed for the different potential 

vegetation groups (PVGs). In particular, the regeneration harvests to address mistletoe in 

the overstory would require removal of trees over 21” diameter at breast height (dbh). On 

page 2-14 it states this would only occur on about 350 acres in moist forest only. 

Response:

Clarification of the reasoning behind the proposed management of dwarf mistletoe, 

which is in only units with regeneration prescriptions, trees > 21” with specified 

levels of dwarf mistletoe infection would be harvested, because they are likely to infect 

the regeneration that is planted or germinates underneath them. The objective is to 

prevent creating a new stand where most of the young trees are infected with high 

levels of mistletoe (see FEIS, Chapter 2, pp. 2-13 to 2-14). 

Regeneration prescriptions were applied only to some stands in Moist Upland Forest 

PVGs. This is where the types of stands were found and are described in the FEIS, 

Chapter 2, p. 2-14: 

Shelterwood and seed cuts (HSSW/HSST) - even-aged harvest

This stand regeneration method is prescribed for stands primarily stocked with 

suppressed, damaged, and diseased trees with low stocking of healthy trees. Enough 

trees are expected to remain after harvest to provide some protection from sun and 

wind to the new seedlings that would be planted or seeded in naturally. 

Seed-tree cuts (HSST) - even-aged harvest

This stand regeneration method is prescribed for stands with very few healthy trees. 

Enough trees are expected to remain after harvest to provide some seed, but not to 

provide substantial protection to the new stand. 

In the rest of the harvest units, where thinning is prescribed, healthy trees would be 

the preferred leave trees, but endemic levels of dwarf mistletoe are expected to 

remain. The dwarf mistletoe of primary concern in the Cobbler II area is in western 

larch. The proposed management is consistent with the scientific references in a new 

comprehensive set of references related to disease treatments in mixed conifer forests, 

Schmitt (2010): 

 “Because of the impacts associated with dwarf mistletoes and the ease of spread of 

infection between adjacent host trees and from overstory trees to understory hosts, a 

variety of sanitation and species manipulation strategies have been used in managed 

forests to eradicate or lessen infection intensity and incidence; primarily using 

silviculture and prescribed fire. In most cases, wildlife resource values need to be 

considered and specific strategies that address that resource included (Parks et al. 

1999; Muir and Geils 2002). Leaving endemic levels of infection which are within the 

historic range of variability (HRV) will usually meet this objective. In these cases, 

some broomed trees may be retained within the perimeter of treated stands. These 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-14

Letter #6 (AFRC) 

Charles H. Burley – American Forest Resource Council 

Comment 

Number Comment and Response 

might be isolated from treated areas or protected from prescribed fire using a variety 

of strategies. In other cases, infected stands may be left over the landscape while 

others are treated.” “Surviving residuals will spread dwarf mistletoe, if infected, to 

regeneration.” (Wicker and Leaphart 1976). 

Schmitt, C. L. 2010. Upland Moist Forests and Associated Disease Disturbances in 

the Blue Mountains—Cases for Management Action. USDA Forest Service, Blue 

Mountains Pest Management Service Center, La Grande, Oregon. 29p. 

AFRC-3 Comment: 

However, on page 2-35 under alternatives considered but eliminated from detailed 

study, you list harvesting trees over 21” dbh as one alternative no considered in detail. 

In the second paragraph you say that a forest plan amendment is not needed to remove 

trees over 21” dbh “in stands in the moist upland forest potential vegetation group 

(PVG) because old forest stand structures are within or above their historical range of 

variability (HRV).” Furthermore you state in the next paragraph that an amendment 

would be needed if cutting trees over 21” dbh were proposed for dry upland forest PVG 

and that is not the case. 

This raises several concerns: 1) the discussion of whether or not to have a forest plan 

amendment should be discussed under each alternative and not under an alternative 

eliminated from detailed study; 2) why are no trees over 21” dbh infested with mistletoe in 

the dry upland forest PVG not being proposed for removal; and 3) if the moist forest PVG 

is at or above HRV, why are there not more trees over 21” dbh being removed to achieve

the desired end results? 

Response: 

See response to comment AFRC-2. 

AFRC-4 Comment: 

One other concern AFRC has is variable density thinning. Also on page 2-35 you list this 

as an alternative eliminated from detailed study which is fine. However, we are concerned 

that this debatable silvicultural prescription will be utilized to some extent in the final 

project regardless. We agree with your rational for not developing it as an alternative and 

strongly urge you to use the same rational to not utilize it in marking guidelines for the 

final project. 

Response:

Your comment has been noted. The intent of the prescriptions is to achieve the 

suggested stocking levels on a unit basis. See number 2 under the heading 

Alternatives Considered but Eliminated from Detailed Study (FEIS, Chapter 2, pp. 2-

36 to 2-37), for a description of the variability that would be left in the stands after 

harvest.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-15

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-1 

p-1 

Comment: 

The Cobbler II EIS fails to meet NEPA’s stringent in-depth scientifically founded and 

accurate analysis requirements, as well as NEPA’s requirements for meaningful public 

involvement including the consideration of public comments. 

Response:

We respectfully disagree with this comment. See Literature citations for science 

referenced and see the FEIS, Chapter 3 for citations used by resource specialists in 

their analysis. 

On February 5, 2010 the Federal Register published a notice of intent (NOI) by the 

Forest Service to prepare an environmental impact statement for the Cobbler II 

project. A scoping letter for the EIS was sent to the mailing list of interested parties 

maintained at the Umatilla National Forest Supervisor’s Office. They included 

federal, state, and local government agencies, Confederated Tribes of the Umatilla 

Indian Reservation, Nez Perce Indian Tribe, various environmental organizations, 

and interested individuals (see project file for mailing list). Five responses were 

received, reviewed, and incorporated in the project file (FEIS, Chapter 2, p. 2-2). 

On April 20, 2010 a letter was sent to the mailing list of federal, state, local 

government, Tribes, interested environmental organizations, and individuals 

requesting comments on the DEIS. A notice of availability (NOA) for the DEIS was 

published in the Federal Register on April 30, 2010. A legal notice requesting 

comments was published in the East Oregonian on May 2, 2010. Eight responses were 

received, reviewed and incorporated in the project file. Forest Service response to 

comments received on the DEIS are located in the FEIS in Appendix I. 

SC-2 

p-8 

Comment: 

Our organizations have a long-standing interest in the sound management of this area, and 

again request the withdrawal of this EIS and the development of a scientifically founded, 

ecologically reasonable SEIS with completely revised and downscaled alternatives that 

comply with applicable environmental policy laws. 

Response:

Your comment has been noted. 

SC-3 

p-8 

Comment: 

The EIS analysis fails the objective, scientific, expert, and meaningful public requirements 

of the NEPA, as this has been manipulatively tailored to limit alternative development to 

identically premised logging actions, with the only difference being that of the extent of 

logging impacts. The EIS evades objective disclosure and incorporation of numerous 

scientific research studies provided the agency that are in contravention to the Forest 

Service’s logging plans. As a result, the decision-maker and public have again been 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-16

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

illegally deprived of objective analysis and accurate disclosures in violation of the NEPA. 

The EIS parrots the EA in its systemic failure to accurately disclose and address current 

and historical ecological conditions, and the harmful impacts of the proposed actions to the 

area’s many forest dependent species, and to the resilience and integrity of the forest 

ecosystem and salmonid waterways within and adjacent to the project area. 

Response:

See response to comment SC-1. 

Several alternatives were explored when considering treatments for the Cobbler II 

project planning area. Three (3) were analyzed in detail (FEIS Chapter 2, pp. 2-9 to 

2-35) and seven (7) were considered but eliminated from detailed study (FEIS, 

Chapter 2, pp. 2-36 to 2-39). 

See FEIS, Chapter 3 for current and historical ecological conditions and analysis of 

environmental effects to forest dependent species, forest ecosystems, and salmonid 

waterways. 

SC-4 

P-8 

Comment: 

The “new” Cobbler II EIS itself is perhaps the most convincing evidence that the Forest 

Service has completely failed to comply with the requirements of the NEPA mandating an 

objective, scientifically founded, and ecologically accurate EIS analysis including the 

development of a reasonable range of scientifically founded action alternatives. The EIS 

irrefutably evidences little more than an arbitrarily contrived and capriciously 

predetermined project. 

Response:

We respectfully disagree with this comment. The draft EIS had been prepared in 

compliance with the National Forest Management Act (NMFA), the National 

Environmental Policy Act (NEPA), other relevant Federal and State laws and 

regulation, and Umatilla National Forest Land and Resource Management Plan 

(Forest Plan) (p. 1-2). 

See response to comment SC-3. 

Also please see our response made previously in Appendix G regarding this comment 

topic: 

 page G-120, Comment 4 

 page G-121, Comment 6 

 page G-122, Comments 7 and 8 

 page G-123, Comment 9 

 page G-130, Comment 20 

 page G-131, Comment 22 

 page G-137, Comment 31 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-17

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

 page G-140, Comment 37 

 page G-141, Comment 38 

 page G-142, Comment 40 

 page G-143, Comment 42 

 page G-147, Comment 49 

 page G-148, Comment 50 

SC-5 

p-9 

Comment: 

Again, the planned logging actions of the Cobbler II Project fail to comport with the 

complex actual conditions of the forest area itself, with credible ecological science 

recommendations, with the nation’s federal environmental policy laws, and with the 

imperative need to protectively retain critically important carbon sequestration capabilities 

and functioning of our forest ecosystems. 

Response:

Please see FEIS, Chapter 3 for existing condition descriptions, analyses of 

environmental effects, and findings of consistency for each alternative considered in 

detail by resource. Also see the section in Chapter 3 of the FEIS entitled Specifically 

Required Disclosures (pp. 3-163 to 3-167) 

See FEIS, Literature Citations, pp. L-1 to L-22 for a listing of science literature, 

papers, and research cited by resource specialists in their reports for this project. 

SC-6 

p-10 

Comment: 

Again, the analysis within the EIS for Cobbler II, and the inadequate “range” of developed 

alternatives, failed to reasonably disclose and incorporate credible scientific 

recommendations capable of better achieving the stated ecological purpose and need goals 

for this project, in violation of the clear requirements of the NEPA. The EIS failed to 

accurately and sufficiently disclose the site-specific conditions of the project area forests, 

also violating the NEPA. 

Response:

See response to comments SC-4 and SC-55, and FEIS, Chapter 1, pp. 1-3 to 1-5 for

background information and the purpose of and need for action. 

SC-7 

p-11 

Comment: 

Failure to comply with the objective, accurate, scientific, meaningful public involvement 

and environmental requirements of the NEPA, and applicable federal environmental policy 

laws including the ESA, CWA, and NMFA. 

Response:

We respectfully disagree with this comment. See response to comments SC-1 and SC5 above. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-18

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-8 

p-11 

Comment: 

Scientifically insupportable logging in mixed conifer, mixed fire severity forest ecosystems 

for fuels reduction and forest health rationales. 

Response:

There is a significant body of scientific evidence supporting logging in mixed conifer 

(also known as moist upland) forests specifically for forest health. Throughout the 

EIS and Silviculture report there are multiple references pointing to relevant, up-todate scientific literature supporting the thinning of mixed conifer forests to promote a 

species composition, density, and structure that more closely resembles historical 

conditions. The results of moving the Cobbler II project planning area closer to its 

historical range of variability (HRV) for these three measures will be a forest that is 

more resilient and better able to handle future insect and disease related 

disturbances, and therefore will be, what we consider, a healthier forest. 

For a comprehensive set of references related to treatments in mixed conifer forests 

for insect and disease related disturbances, see the following:

Schmitt, C. L. 2010. Upland Moist Forests and Associated Disease Disturbances in 

the Blue Mountains—Cases for Management Action. USDA Forest Service, Blue 

Mountains Pest Management Service Center, La Grande, Oregon. 29p. 

Scott, D. W. 2010. Upland Moist Forests and Associated Insect Disturbances in the 

Blue Mountains: Supporting Science for Management Action. Report BMPMSC-10-

01. USDA Forest Service, Blue Mountains Pest Management Service Center, La 

Grande, OR. 101p. 

Together, these two references contain literally hundreds of citations to studies 

showing clear, supportable scientific evidence for treatment in mixed conifer forest 

stands for forest health rationale. 

SC-9 

p-11 

Comment: 

Scientifically controversial logging and/or insupportable excessive logging including 

mature and old growth logging in remote interior wildland forest systems 

Response:

With regards to scientifically controversial or insupportable logging, see response to 

comment SC-8 above. 

All commercial thinning prescriptions would thin from below to a specified basal 

area, generally retaining the larger diameter dominant and co-dominant trees, while 

selecting for relatively healthy trees. In units with thinning prescriptions, trees over 

21" DBH are retained for old forest structure, and are given wider spacing than 

smaller trees. The specified basal area comes from the stocking guidelines referenced 

in this project (Powell 1999) and were developed based on the fact that our forest is 

composed of many diverse plant associations, tree species, and ecological provinces. 

This guide is used as a scientific tool to help us meet the purpose and need of this 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-19

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

project. This tool allows for site-specific variability as defined by the project and 

silviculture prescriptions. Suggested stocking levels are suggested thresholds to 

maintain susceptibility of stands to insects and diseases within historical limits. The 

prescriptions for the residual basal areas after logging will leave the stands fully 

stocked.

SC-10 

p-11 

Comment: 

Failure to adequately address significant widespread cumulative impacts from past, recent, 

and ongoing logging projects throughout the District’s forest. 

Response:

Past, present, and reasonably foreseeable actions are presented in the FEIS, Chapter 

3, pp. 3-1 to 3-4. Resource specialists included relevant past, present, and reasonably 

foreseeable actions in their cumulative effects analyses which are presented in the 

FEIS, Chapter 3. 

SC-11 

p-11 

Comment: 

Scientific and legally insupportable logging, road building, and disruptive ecologically 

degrading management actions in old growth forest and uninventoried remote interior 

roadless area forests. 

Response:

With regard to thinning in old forest structure classes, see response to comment 

SC-8 and for thinning in old forest structure classes see response to comment SC-9. 

In this comment, the commenter does not define what they called “uninventoried 

roadless areas,” nor does the Forest Service have a definition of such a term, so it is 

impossible to analyze an ambiguous, undefined term. 

The Forest Service has defined all of the terminology used in the Wilderness and 

Undeveloped section of FEIS, Chapter 3, pp. 3-131 to 3-133. Effects to Potential 

Wilderness Areas, Inventoried Roadless Area, and other undeveloped lands are 

disclosed in the FEIS Chapter 3, pp. 3-133 to 3-151. 

SC-12 

p-11 

Comment: 

Failure to objectively disclose and address the full range of scientific controversy and 

research recommendations pertinent to the area’s plant association groups, salmonid 

watersystems, listed and imperiled species of concern, natural mixed severity fire patterns 

and variable fire history in this remote forest area, the importance of roadless area forest 

integrity and natural ecological process and functioning, both short and long term recovery 

of listed species and species of concern, direct and cumulative road density and 

fragmentation impacts, forest soil communities and hydrological functioning, etc 

Response:

We are unaware of scientific controversy surrounding the area’s plant association 

groups. The plant associations used in the Cobbler II project are derived from 

Johnson & Clausnitzer, 1992. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-20

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

There is really no scientific controversy regarding the potential for adverse effects by 

road building and timber harvest on salmonid watersystems. It is widely recognized 

in the scientific literature that these activities can potentially adversely affect 

salmonid fish and their habitat when they occur in Riparian Habitat Conservation 

Areas (RHCAs) or adjacent to them. It is also well substantiated that proper 

mitigating measures can effectively reduce these risks to very low levels. The Cobbler 

II project will implement such mitigating measures (FEIS, Chapter 2, Table 2-6, pp. 

2-24 to 2-31). 

See response to comments SC-3, SC-4, and SC-5. 

SC-13 

p-11 

Comment: 

Failure to develop a reasonable range of action alternatives representative of credible 

scientific research and varied management recommendations 

Response:

We respectfully disagree with this comment that a reasonable range of alternatives 

have not been considered. The EIS documents consideration of ten alternatives (see 

FEIS Chapter 2), including: the no action alternative; the proposed action; one other 

action alternative; and six alternatives considered but eliminated from detailed study. 

The alternatives considered but eliminated from detailed study are rightfully 

considered as a part of the range of alternatives considered in keeping with CEQ’s 

guidance in their document: “40 Most Asked Questions”. Question 1.a. 10 this 

document states: 

1a. Range of Alternatives. What is meant by "range of alternatives" as referred to in Sec. 

1505.1(e) 

A. The phrase "range of alternatives" refers to the alternatives discussed in environmental 

documents. It includes all reasonable alternatives, which must be rigorously explored and 

objectively evaluated, as well as those other alternatives, which are eliminated from detailed 

study with a brief discussion of the reasons for eliminating them. Section 1502.14. A 

decisionmaker must not consider alternatives beyond the range of alternatives discussed in the 

relevant environmental documents. Moreover, a decisionmaker must, in fact, consider all the 

alternatives discussed in an EIS. Section 1505.1(e). 

The Forest Service Handbook contains further discussion on the range of alternatives 

at FSH 1909.15; Section 14: 

As established in case law interpreting the NEPA, the phrase "all reasonable alternatives" has 

not been interpreted to require that an infinite or unreasonable number of alternatives be 

analyzed, but does require a range of reasonable alternatives be analyzed whether or not they 

are within Agency jurisdiction to implement (40 CFR 1502.14(c)). 

 And at FSH 1909.14.4: 

The range of alternatives considered by the responsible official includes all reasonable 

alternatives to the proposed action that are analyzed in the document, as well as other 

alternatives eliminated from detailed study. Alternatives not considered in detail may include, 

but are not limited to, those that fail to meet the purpose and need, are technologically infeasible 

or illegal, or would result in unreasonable environmental harm. 

The issue of whether or not this analysis has considered a reasonable range of 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-21

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

alternatives was brought up in comments on the original Cobbler II project and was 

responded to in the response to comments for the project (see FEIS, Appendix G, pp. 

G-120 and G-140). 

See response to comments SC-4 and SC-5. 

SC-14 

p-11 

Comment: 

Failure to sufficiently disclose and address environmental impact and management issues 

related to exponentially increasing climate change, and the critically important role natural 

and unlogged forests perform in carbon sequestration and mitigation of climate change 

impacts. Failure to disclose the incrementally harmful impacts of the planned logging upon 

localized and regional climate change, including the loss of carbon sequestration capability 

in both the short and long-term. 

Response:

See response to comments OW-12 and OW-13 

SC-15 

p-11 

Comment: 

Failure to sufficiently address significant synergistic cumulative impacts from past and 

ongoing sequential logging projects; from ongoing livestock grazing; from high road 

densities that exceed wildlife thresholds and LRMP standards; and from growing ORV use 

and impacts in the project area and across the District. 

Response:

Cumulative effects from past and ongoing activities listed above are addressed in the 

FEIS, Chapter 3 of the Wildlife section on pages 3-91 to 3-116. Open road densities 

would remain low and would not change (FEIS, Chapter 2, p. 3-94). 

SC-16 

p-11 

Comment: 

Failure to protect ecologically foundational forest soil communities and soil hydrological 

functioning; and protect native botanical species biodiversity and abundance; utilizing 

instead extensive ground damaging heavy logging machinery, widespread burning, and 

additionally failing to prohibit livestock grazing in logging and burning impacted areas for 

five to ten years post project as the minimum rest period recommended by scientific 

research. 

Response:

Design Criteria (FEIS, Chapter 2, Table 2-6) including unit layout and harvest system 

designation and Best Management Practices (Appendix D) have been chosen and 

incorporated based on extensive prior experience with similar actions as those 

proposed in adjacent areas and ecological sites. The extent of machine activity and 

anticipated disturbance levels is designed to meet Forest Plan and Regional Standards 

and Guidelines (FEIS, Chapter 3, pp. 3-4 to 3-5). Livestock grazing effects within 

logging and prescribed fire areas has been satisfactory and is included as Forest Plan 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-22

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

direction for transitory range access (FEIS, Chapter 3, p. 3-9).

SC-17 

p-11 

Comment:

Failure to reasonably protect Oregon State 303(d) listed and other critically important 

salmonid spawning watersystems, salmonid populations, and aquatic habitat from direct, 

indirect, and cumulative harm and degradation due to project actions. 

Response: 

No streams in the Cobbler II project planning area are 303d listed (FEIS, Chapter 3, 

p. 3- 15). Project design criteria (FEIS, Chapter 2, Table 2-6) and Best Management 

Practices (Appendix D) would limit sedimentation from activities and PACFISH 

RHCAs would prevent sedimentation from reaching waterways. Improvement of 

road drainage would have short-term sediment effects to Elbow Creek leading to 

long-term reduction in sedimentation. No degradation of water systems would occur 

(FEIS, Chapter 3, pp. 3-16 to 3-23). 

The EIS describes in detail the methods that would be used to protect salmonid 

spawning watersystems, salmonid populations, and aquatic habitat from direct, 

indirect, and cumulative harm due to project actions. These include things such as 

implementing PACFISH RHCA’s, leaving danger trees on site when necessary to fall 

them within RHCA’s, and implementing best management practices (FEIS, Appendix 

D).

SC-18 

p-11 

Comment: 

Legally improper use of a narrowly contrived logging purpose and need that again 

predisposes agency planning staff and the decision maker to the development and selection 

of a scientifically insupportable commercial logging volume motivated action alternative. 

Response:

We respectfully disagree with this comment with this characterization of the purpose 

and need. The purpose and need are explained in the FEIS, Chapter 1, pp. 1-3 to 1-5 

of the EIS. The purpose and need are tied to the desired future conditions described 

in the Forest Plan. The Grande Ronde River-Rondowa Analysis (see project file), 

which included the Cobbler II project planning area on Walla Walla Ranger District 

considered Forest Plan direction and existing conditions on a landscape scale and 

identified where the existing condition did not match the desired condition. A 

conclusion was reached that “a significant threat of stand-replacing disturbances 

exists within the Grande Ronde-Rondowa watershed that could dramatically alter 

plant and animal structure and composition” (FEIS, Chapter 3, p. 3-44 to 3-45).

See response to comment SC-6. 

SC-19 

p-11 

Comment: 

Failure to accurately acknowledge, objectively address, and meaningfully incorporate the 

majority of the many applicable scientific research studies and recommendations included 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-23

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

in our exhibits provided to the Umatilla National Forest (which have been submitted for a 

number of project proposals); 

Response:

See Appendix G, pp. G-178 to G-192 for Forest Service response to lists of sources 

included in exhibits received from the Sierra Club. 

Also see response to comments SC Attachment 1 to SC Attachment 96 below. 

SC-20 

p-11 

Comment: 

Despite NEPA’s more stringent analysis requirements for an EIS compared to an EA, the 

changes made between the EA and the DEIS are not substantive concerning project actions 

or analysis. Changes are largely relegated to grammatical and format corrections and 

cosmetic inferences. Despite allusions to science included in the list of references, the 

actions remain essentially identical with those proposed in the original Cobbler EA. The 

original EA analysis is founded primarily on a mix of an outdated 1990 Umatilla Forest 

Plan, USFS internal documents, and only two outdated scientific research studies cited in 

the original EA - Cochran 1993 and Powell 1999. NEPA requires the agency do more than 

merely list referenced studies, requiring these be substantively incorporated in developing 

project actions. The Cobbler II EIS instead evidences a predetermined logging project 

wherein analysis has been arbitrarily manipulated to meet the agency’s timber target goals, 

rather than a project that is well-founded in and guided by relevant scientific research and 

sound ecological objectives. Such analysis violates the requirements of the NEPA and 

President Obama’s Scientific Integrity directive. 

Response:

The introduction to Chapter 1 of the EIS reads as follows: 

In response to concerns that timber harvest and road building may change the 

character of undeveloped lands adjacent to the Wenaha-Tucannon Wilderness and 

the Grande Ronde inventoried roadless area (IRA), the Cobbler II EIS includes 

analysis of environmental effects to these resource areas and also includes a Forest 

Service site-specific inventory of areas of potential wilderness within the project 

planning area (Appendix H). Other undeveloped lands are also identified and 

analyzed for environmental effects. 

Any changes are described on the first or second page of each chapter, section or 

appendix of the FEIS entitled Changes between May 2009 EA and this FEIS. 

Also see response to comment SC-5 and SC-23. 

SC-21 

p-12 

Comment: 

The EIS proposed logging alternatives remain unchanged in substance from the original 

EA, which utilizes basal area formulas developed by Powell for the Umatilla NF in 1999. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-24

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

The original EA failed to cite or disclose any other directly referenced scientific research 

either in support or in contravention to this USFS developed basal formula. The rationale 

for utilizing Powell’s formulas in naturally complex mixed conifer forest locations is never 

addressed, and the EIS omits a wealth of other scientific research that strongly recommends 

against the basal area formula logging as planned by the EIS. The EIS only cosmetically 

attempts to address these NEPA analysis deficiencies. While it augments the record with 

additional references, it fails to substantively address these issues, and fails to develop a 

reasonable range of scientifically-founded action alternatives. Instead, the EIS merely 

repeats the same logging action alternatives, while failing to meaningfully and objectively 

address core ecological, scientific, and legal issues. The EIS fails to objectively disclose 

and address issues of conflicting science, and fails the requirements of the NEPA. 

Response:

See response to comments SC-8 and SC-9.

SC-22 

p-12 

Comment: 

The Cobbler II Project’s purpose and need premise, analysis, and action alternatives 

significantly diverge from scientifically supportable ecologically appropriate methods to 

effectively “to improve health, vigor, and resilience to fire, insects, and disease in upland 

forests that are outside their historical pre-fire suppression conditions for species 

composition (including hardwood species), structural diversity, stocking densities, and fuel 

loads.” 

Response:

See response to comment SC-8. 

SC-23 

p-12 

Comment: 

The Cobbler II Project fails the expert, reasonableness, accuracy, and scientific 

requirements of the NEPA, recently reaffirmed in President Obama’s March 9th, 2009 

Scientific Integrity Memorandum. 

Response:

We respectfully disagree with this comment. The analysis conducted for the Cobbler 

II project was conducted by journey level resource specialists, working as an 

interdisciplinary team, using the most up to date information and the best applicable 

scientific information available. This work is documented in interdisciplinary team 

meeting notes in the project file, in the specialists’ reports, and throughout the EIS. 

The Forest Service is well aware of the NEPA requirements and of the President’s 

Memorandum on Scientific Integrity. 

The fact that certain groups do not want any management in this area does not make 

the decision to manage the area in accordance with the Forest Plan inaccurate, 

unreasonable, or lacking in scientific integrity. 

SC-24 

p-14 

Comment: 

Despite having provided the agency with abundant comments, appeal, and appeal exhibit 

information, the Forest Service has failed to meaningfully and objectively address and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-25

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

incorporate this information in the NEPA analysis for the Cobbler II project. 

Response:

Please see response to comment SC-19 and SC-20. 

SC-25 

p-14 

Comment: 

NEPA requires federal land management agencies to meaningfully involve the public in 

project development, analysis, and decisions. The Cobbler II EIS fails to acknowledge the 

Forest Service’s legal responsibility under the NEPA on this significant foundational 

analysis issue. 

Response:

Again, We respectfully disagree with this comment. The FEIS documents that the 

public was involved in the original Cobbler analysis and in the Cobbler II analysis 

(FEIS, Chapter 1). There is nothing in the scoping notice that shows any violation of 

NEPA. In fact, with the same purpose and need and virtually the same proposed 

action, there are no legal or regulatory requirements to re-scope the project, but we 

chose to do so anyway in case someone had new information that we needed to 

consider. As stated in the FEIS (Chapter 1, p. 1-1): Changes incorporated in the 

Cobbler II FEIS reflect input already given by the public for the May 2009 Cobbler 

EA including all issues and comments received from scoping, 30-day review and 

comment period, appeals, and any comments received from the November 20, 2009 

scoping letter. Also see FEIS, Chapter 2, pp. 2-1 to 2-2 for Tribal and Public 

Involvement. 

See response to comment SC-1 and SC-20. 

SC-26 

p-15 

Comment: 

Our organizations request that the Forest Service define where and how the EIS reflects the 

public input in any real meaningful changes to the project? We refer directly to all our 

previous comments, our appeal, and exhibits – 

Response:

Please see response to comment SC-19 and SC-20 above. 

SC-27 

p-15 

Comment: 

the agency fails to disclose the scientific research recommendations relevant to the 

importance of all roadless areas and their connective habitat, inventoried or not. 

Response:

We respectfully disagree with this comment, the agency disclosure of wildlife species 

that benefit from large areas of undisturbed land can be found in the FEIS, Chapter 

3, pp. 3-91 to 3-117 and p. 3-142- to 3-143. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-26

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-28 

p-15 

Comment: 

The Forest Service misuses the criteria it developed for “potential wilderness areas” to 

avoid meaningfully addressing the harmful impacts of logging, extensive heavy machinery 

use, and road building within environmentally significant de-facto roadless areas – 

regardless of whether these areas may have had some level of partially apparent 

management impacts in past decades. 

Response:

The commenter has not defined what they mean by “de-facto roadless” so it is 

uncertain exactly what we have not addressed. The Cobbler II EIS addresses the 

effects of logging, including the effects of heavy logging equipment, and the effects of 

road building (FEIS, Chapter 3). The PWA environmental consequences analysis in 

included in the FEIS, Chapter 3, pp. 3-133 to 3-146. 

SC-29 

p-16 

Comment: 

The DEIS fails to disclose relevant scientific research recommendations that emphasize the 

ecological importance of protecting all roadless areas and their connective, contiguous 

habitat. The DEIS instead substitutes its contrived “pwa” inventory criteria to obfuscate the 

ecological significance of the project’s unroaded area “units.” 

Response:

The Forest Service agrees lands with values and features that often characterize 

inventoried roadless areas are increasingly important within developed landscapes in 

order to provide clean drinking water and function as biological strongholds for 

populations of threatened and endangered species. They provide areas that are 

important for biological diversity, dispersed outdoor recreation, and also serve as 

bulwarks against the spread of non-native invasive species and provide reference 

areas for study and research (36 CFR 294, page 3245). The crux of the PWA analysis 

is to determine which lands within the project planning area, aside from Inventoried 

Roadless Areas, with these characteristics may apply. 

Effects to species that are wide ranging and benefit from large areas of undisturbed 

land would be minimal or non-existent (FEIS, Chapter 3, p. 3-142 to 3-143). 

SC-30 

p-16 

Comment: 

 the DEIS fails to disclose relevant scientific research on the importance of such areas, and 

instead presents contrived artifice of an analysis seeking to diminish the importance of 

unroaded forest lands by breaking these into separate pieces despite their contiguous 

nature. Such “analysis” violates the scientific, meaningful, accuracy, and objective 

requirements of the NEPA. 

Response:

See response to comment SC-29 above. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-27

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-31 

p-16-17 

Comment: 

Even in uninventoried roadless areas, NEPA requires the FS to consider the environmental 

impacts of a proposed project because logging, road building, and/or other intrusive 

management actions in roadless areas are so environmentally irreparable that their impacts 

are far beyond the threshold for significant. First, the USFS is required to analyze the 

attributes of roadless areas, such as water resources, soils, wildlife habitat, and recreation 

opportunities. Smith v. U.S. Forest Service, 33 F.3d 1072, 1078 (9th Cir. 1994). Second, 

the USFS is required to discuss a project's impacts on areas of "sufficient size" for future 

wilderness designation. Lands Council, 529 F.3d at 1231, citing 16 U.S.C. § 1131(c). 

Response:

We respectfully disagree with this comment with this comment. The commenter does 

not define their term “uninventoried roadless areas” in their comment, nor does the 

Forest Service have a definition of such a term, so it is impossible to analyze an 

ambiguous, undefined term. 

New narrative was added to the Introduction of the IRA/PWA section of Chapter 3 in 

the FEIS. The confusion surrounding the many terms used for this issue was 

expanded. The terms used to disclose impacts to this topic are Inventoried Roadless 

Area, Potential Wilderness Area, and Other Undeveloped Lands. The term ‘uninventoried roadless areas’ has no meaning because all lands relevant to the Cobbler 

II project planning area were considered and inventoried (Cobbler II EIS-Appendix 

H) 

The Forest Service considered all lands in the project area when following the 

established procedures for what areas qualify for inclusion in the inventory of PWAs. 

We also contacted the managers of adjacent federal lands to ensure we were not 

missing additional potential wilderness areas. Procedures for identifying areas that 

quality for inclusion in the inventory of PWAs comes from Forest Service Handbook 

1909.12, Chapter 70, Section 71. The procedures in Section 71 were followed. The 

analysis was displayed when the draft EIS was released for public comment. Based 

on some of the comments received, we have updated that analysis in the final EIS. 

NEPA requirements to consider the effects of proposed actions and to inform the 

public were followed. 

Only prescribed burning and hardwood restoration activities are planned to occur in 

the Grande Ronde PWA (no proposed activities in the Wenaha-Tucannon PWA). 

Effects to other undeveloped lands are disclosed in the FEIS, Chapter 3, pp. 3-146 to 

3-152. 

Also see response to comment SC-28. 

SC-32 

p-17 

Comment: 

Instead of an accurate objective assessment of the conditions within and impacts to these 

areas, the EIS mis-employs the Forest Service’s contrived “potential wilderness area” 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-28

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

inventory criteria to avoid adequately considering the project’s irretrievable impacts to 

uninventoried roadless areas. 

Response:

We respectfully disagree with this comment. Again, the commenter does not define 

the term “uninventoried roadless areas” in their comment, nor does the Forest 

Service have a definition of such a term, so it is impossible to analyze an ambiguous, 

undefined term. 

Effects to PWA and other undeveloped lands are disclosed in the FEIS, Chapter 3 (p. 

3-133 to 3-152) and effects to the various resources that utilize these lands are 

disclosed in the remainder of Chapter 3. 

Also see response to comment SC-31. 

SC-33 

p-17 

Comment: 

The Cobbler II Project would conduct logging, road building, mechanized activities, 

thinning, and/or extensive burning in undeveloped and unroaded areas that currently 

provide ecologically important habitat and refugia. Though uninventoried roadless areas 

are included among the project units, the EIS fails to accurately disclose and address the 

ecological importance and actual contiguous roadless extent of these areas, fails to 

correctly disclose where they are located and accurately describe their ecological sitespecific conditions, and fails to adequately address the proposed project’s logging, roading, 

mechanized thinning, and other management action impacts upon these areas. The EIS as 

such is legally and environmentally deficient. 

Response:

We respectfully disagree with this comment. Commenter is again using the term 

“uninventoried roadless areas,” see response to comment SC-31 regarding this 

terminology. 

The Forest Service considered all lands in the project area when following the 

established procedures for what areas qualify for inclusion in the inventory of PWAs. 

We also contacted the managers of adjacent federal lands to ensure we were not 

missing additional potential wilderness areas. Procedures for identifying areas that 

quality for inclusion in the inventory of PWAs comes from Forest Service Handbook 

1909.12, Chapter 70, Section 71. The procedures in Section 71 were followed. 

Impacts to inventoried roadless areas, potential wilderness areas, and other 

undeveloped lands are disclosed in Chapter 3 of the FEIS, Appendix H, and specialist 

reports in the project file. Impacts to wildlife and their habitat are disclosed in the 

wildlife specialist report and summarized in Chapter 3 in relation to each PWA, IRA, 

and other undeveloped lands. The Wildlife section of Chapter 3, separate from the 

PWA and undeveloped lands section, fully disclosed impacts to wildlife and changes 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-29

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

in habitat. 

All lands within the Cobbler II project planning area were considered and 

inventoried consistent with FSH 1909.12 Ch. 71 procedures as described in the EIS 

Appendix H. 

No road construction and timber harvest is proposed within inventoried roadless 

areas as identified in the Roadless Area Conservation Rule set of maps. No road 

construction and timber harvest is proposed within potential wilderness areas as 

inventoried and displayed in the FEIS, Appendix H. The effects of project activities 

on other undeveloped lands are disclosed in the FEIS, Chapter 3 pp. 3-146 to 3-152.

SC-34 

p-18 

Comment: 

The EIS misrepresents the effect of logging on unroaded/undeveloped areas. The EIS 

inaccurately claims that there is only a 2% reduction in unroaded areas (p 3-145). However, 

the 635 acres out of 5660 acres disclosed in the EIS represents more than 11%. This is a 

significant misrepresentation that fails NEPA’s requirements, especially given the fact that 

unmanaged areas are rare and under-represented across the forest landscape.

Response:

See response to comment OW-6 above. 

SC-35 

p-18 

Comment: 

The EIS analysis fails to objectively disclose the critically important role that unroaded 

areas provide. 

The EIS fails to adequately consider and disclose the impacts of the project’s actions in 

these unroaded areas – in significant part due to its use of inappropriate criteria and 

omission of scientific research and recommendations concerning the importance of 

unroaded forests. 

Response:

We respectfully disagree with this comment. The commenter has not identified any 

scientific research that would be applicable to how we should follow the procedures 

outlined in Forest Service Handbook 1909.12, Chapter 70, Section 71. The Forest 

Service followed Forest Service direction related to areas with evidence of past 

logging and roads (FEIS, Chapter 3, pp.3-132 to 3-133 and Appendix H). The 

inventory of potential wilderness areas (PWAs) does not require scientific research; it 

is about following the procedures in the Forest Service Handbook 1909.12, Chapter 

70, Section 71, which identifies criteria for what areas qualify for placement on the 

inventory of potential wilderness areas. 

The applicable criterion related to roads is: Areas do not contain forest roads (36 CFR 

212.1) or other permanently authorized roads, except as permitted in areas east of the 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-30

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

100th meridian (sec. 71.12).

The areas which were dropped from possible inclusion in the inventory of potential 

wilderness areas because of roads, all were roads that meet the definition in 36 CFR 

212.1. 

The applicable criteria related to logging is: Timber harvest areas where logging and 

prior road construction are not evident, except as provided in Section 71.12 for areas east 

of the 100th meridian. Examples include those areas containing early logging activities 

related to historic settlement of the vicinity, areas where stumps and skid trails or roads 

are substantially unrecognizable, or areas where clearcuts have regenerated to the 

degree that canopy closure is similar to surrounding uncut areas.

The areas which were dropped from possible inclusion in the inventory of potential 

wilderness areas because of previous logging, all had readily recognizable stumps 

scattered across the areas. 

No areas were eliminated from possible inclusion in the inventory of PWAs based on 

motorized use unless they were a road. 

Impacts to inventoried roadless areas (IRAs), potential wilderness areas (PWAs), and 

other undeveloped lands are disclosed in Chapter 3 of the FEIS, Appendix H, and 

specialist reports in the project file. Impacts to wildlife and their habitat are disclosed 

in the wildlife specialist report and summarized in Chapter 3 in relation to each 

PWA, IRA, and other undeveloped lands. The Wildlife section of Chapter 3, separate 

from the PWA and undeveloped lands section, fully disclosed impacts to wildlife and 

changes in habitat. 

SC-36 

p-19-20 

Comment: 

The NEPA analysis for this project does not adequately discuss the impacts of proposed 

activities on all the many significant values of roadless/unroaded areas. Nor does this 

analysis address the importance of the forests surrounding these unroaded areas, including 

the essential connectivity adjacent stands provide. The analysis fails to address or disclose 

the cumulative impacts that would result from management actions not only in unroaded 

areas but adjacent forest stands, including the diminishment of the extent of currently 

undisturbed habitat in the project area. 

Response:

All lands within the Cobbler II project area were considered and inventoried 

consistent with FSH 1909.12 Ch. 71 procedures as described in the FEIS, Appendix H. 

Also see response to comment SC-35. 

SC-37 

P -20 

Comment: 

Landscape analysis based on historic disturbance patterns suggests that historically the 

majority of old forest and ecologically intact habitat occurred in large patches. These large 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-31

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

patches of older forests, and connectivity between LOS patches, that native fish and 

wildlife species evolved with are now severely under-represented on the forest landscape 

and must be protected and restored. The EIS analysis fails to sufficiently address these 

significant issues and must be corrected in a new SEIS process. 

Response:

We respectfully disagree with this comment. Old forest and connectivity was selected 

as a “key issue” for this project (FEIS, Chapter 2, p. 2-8) and Alternative C was 

designed to respond to this key issue (FEIS, Chapter 2, p. 2-32). Environmental 

consequences of this key issue were disclosed in the FEIS, Chapter 3, pp. 3-87 to 3-91. 

Additional information regarding how this project is consistent with the Eastside 

Screens can be found in Appendix F. 

SC-38 

p-21 

Comment: 

While the agency may attempt to claim it does not have an explicit legal obligation to 

protect these uninventoried areas (yet), the Forest Service does have a legal obligation 

pursuant to NEPA to accurately, scientifically, and objectively describe the environmental 

consequences of logging and road building in ecologically significant areas. NEPA also 

requires that the agency disclose all pertinent science, including ongoing scientific research 

and controversy. And NEPA requires the agency to develop scientifically sound 

environmentally protective action alternatives in its EIS. The analysis for this project, 

including the two developed logging alternatives, fail the requirements of the NEPA 

concerning these requirements, and the requisite disclosure of scientific research and 

recommendations pertaining to roadless and unroaded areas. 

Response:

In the FEIS Chapter 3, pp. 3-131 to 3-152 and Appendix H we fully and appropriately 

address the analysis for inventoried roadless areas, potential wilderness areas and 

other undeveloped lands within (and immediately adjacent to) the project planning 

area. 

Also see response to SC-11, SC-31, SC-33, and SC-35. 

SC-39 

p-21 

Comment: 

The EIS fails to appropriately address area roads analysis as it pertains to unroaded areas 

within and adjacent to the project area. 

Response:

There are no changes proposed to the District’s Motorized Access Travel 

Management Plan. All alternatives would be consistent with Forest Plan standards 

and guidelines for transportation (FP p. 4-11 and pp. 4-85 and 86) and Umatilla 

National Forest’s 2004 roads analysis. 

Roads are addressed in identifying which areas qualify to be on the inventory of 

potential wilderness areas, and to the other undeveloped lands in the FEIS (Chapter 

3, p. 3-132).
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-32

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-40 

p-21 

Comment: 

The EIS fails to fully and accurately disclose the current road density adjacent to unroaded 

areas within or near the planning area or sufficiently address bringing into compliance the 

current road density of the project area with LRMP standards 

Response:

We respectfully disagree with this comment. The entire project planning area was 

analyzed. About 176 miles of road have been built in the Cobbler II project planning 

area, but 111 miles of these roads are now closed. With existing closures, the open 

road density is 1.2 miles per square mile in management area E2 and 1.1 miles per 

square mile in management area C4. These open road density figures are within 

Forest Plan (p. 4-11) desired condition of an average of 2 miles per square mile or less 

Forest-wide (FEIS, Chapter 3, pp. 3-93). 

Approximately 0.25 miles of new construction is proposed (will become a closed road) 

and 0.20 miles of temporary road would be constructed and decommissioned after use 

(FEIS, Chapter 2, p. 2-19). The approximately 0.25 miles of new road would only 

slightly change road densities (increase of less than 0.01 miles per square mile) in the 

planning area. The proposed new road would be located behind a closed gate, and 

would become a closed system road. There would be no measurable change in Forestwide open road density and would not affect any component of aquatic habitat (FEIS, 

Chapter 3, pp 3-36 to 3-37 and 3-120 to 3-122). 

SC-41 

p-21-22 

Comment: 

The analysis fails to accurately disclose the road density post-project, including all roads as 

well as closed roads, skid trails and other areas that effectively function as roads. 

Response:

Road density was calculated using the Forest’s roads database and GIS system (FEIS, 

Chapter 3, p. 3-12). Road density would increase by less than 0.01 miles per square 

mile in the Wenaha-Rock Creek SWS, a negligible amount (FEIS, Chapter 3, pp. 3-16 

to 3-17 ) 

See response to comment SC-40 above. 

SC-42 

p-22 

Comment:

The analysis also fails to assess the potential and existing use of skid trails by off road 

vehicles in its analysis of the impacts to wildlife resulting from the use of the network of 

road systems and trails. 

Response:

The use of skid trails (or any undesignated route) by OHV users is not allowed on the 

Umatilla Forest. OHV use of designated roads and trails were included in the open 

road density analysis and disclosed in the FEIS, Chapter 3, p. 3-107. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-33

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-43 

p-22 

Comment: 

The analysis additionally fails to disclose the acreage of largest expanses of unroaded 

forest within, or adjacent to, the project area. Such information is imperative to an accurate 

assessment of the cumulative impacts of this project upon wildlife habitat and aquatic 

systems. 

Response: 

See FEIS, Chapter 3 (pp. 3-129 to 3-152) and Appendix H for information on the size, 

shape and configuration of PWAs and other undeveloped lands. 

Additionally, no information was provided displaying any areas of particular interest 

for the Cobbler II planning area. A map was submitted by Sierra Club et al. showing 

the entire planning area (see Cobbler II project record), however no specific acres of 

PWA or other undeveloped lands were identified. Therefore, the Forest Service must 

rely solely on our identification of these lands for the purpose of this analysis. 

Furthermore, the nature of our analysis ensures that every acre of the project 

planning area has been reviewed. 

All lands within the Cobbler II project area were considered and inventoried 

consistent with FSH 1909.12 Ch. 71 procedures as described in the FEIS, Appendix H. 

SC-44 

p-22 

Comment: 

The EIS also fails to disclose the Forest Service’s success rate in closing roads, or any 

reports or studies that have been conducted to provide this information. 

Response:

Response to this comment is outside the scope of analysis for this project. Site-specific 

information on closed roads and road density is located in the FEIS, Chapter 3, in the 

Hydrology, Fishers, Wildlife, and Transportation sections. 

SC-45 

p-22 

Comment: 

The EIS does not disclose the success rate of proposed methods to close new or 

“temporary” roads, or if the effectiveness of these types of road closures have been 

monitored elsewhere (rock placements, berms and earthen barriers, water bars, subsoiling, 

scattered woody debris, gates with locks, etc.) 

Response:

Subsoiling or ripping of road surfaces followed by the scattering of slash, logs and or 

stumps has proven to be very effective in closing and effectively stopping traffic on 

temporary roads. After several years, downfall of timber from the adjacent stands 

further blocks and reinforces the closure of temporary roads (FEIS, Chapter 2, Table 

2-6). 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-34

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-46 

p-22 

Comment: 

the new DEIS still fails NEPA’s requirements on a number of significant issues, including 

that of the lack of objective disclosures of contending science, and the largely out-ofcontext contrived manipulation of primarily Forest Service generated research as the 

supposed foundation of the agency’s “supporting science” for its proposed environmentally 

detrimental actions. The EIS failed to develop a reasonable range of scientifically 

supported action alternatives as required by the NEPA. 

Response:

We respectfully disagree with this comment. Some commenters provided lists of what 

they deemed scientific papers which disputed the scientific reports that we have used. 

We reviewed the submitted papers, some were newspaper editorials or opinion papers 

not documenting any research, and which cannot be considered scientific sources. 

Others were papers and reports we have used, but were interpreted differently than 

how the paper intended. Lastly, some were scientific papers, but they were done in 

different climatic or geographic areas from the Blue Mountains. I found the scientific 

literature that the Forest Service specialists used to be the best available and most 

applicable science. See FEIS, Appendix G (pp. G-8 to G-119 and G-178 to G-192) and 

this appendix (Appendix I, pp. I-103 to I-132) for our review of submitted exhibits. 

See response to comments SC-3, SC-4, and SC-23 listed above. 

SC-47 

p-22 

Comment: 

The new EIS continues to fail to evidence that the agency has complied with NEPA’s 

requirements for meaningful public involvement. The project remains unscientifically 

premised similarly as before, with the purpose and need essentially the same despite the 

many issues with its objectives that were clearly addressed in our previous comments and 

the previous NEPA process. Action alternatives remain essentially the same logging 

actions, new roads are still a part of the proposed project, and the agency still has failed to 

meaningfully address the many issues of scientific controversy noted in our previous 

comments, ranging from mixed conifer and mixed fire severity issues, to soil issues and 

climate change and carbon sequestration issues. 

Response:

We respectfully disagree with this comment. See response to comments SC-1, SC-3 

and SC-20 above. Also see FEIS, Appendix G pp. G-119 to G-192 to see how previous 

comments submitted were addressed. 

SC-48 

p-23 

Comment: 

The DEIS rejects a few variations of non-commercial logging alternatives, including one 

that would thin trees <9” dbh. The EIS inappropriately utilizes these to fail to acknowledge 

and develop a scientifically founded thinning alternative that employs a variable range of 

diameter limits as appropriate to scientific research recommendations addressing PAG 

forest structure and cycles, optimal/desired NRV (Natural Range of Variability), and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-35

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

wildlife habitat needs (Ch. 2-35 to 2-37), 

Response:

Forest stand data and field review showed that cutting only trees <9” dbh would not 

bring the stands that are proposed for harvest into the stocking levels recommended 

by the most appropriate stocking level guidelines. 

Also see FEIS, Chapter 2, pp. 2-36 to 2-39 under the heading Alternatives Considered, 

but Eliminated from Detailed Study. The analysis for an alternative that 

incorporated variable density thinning into the commercial and non-commercial 

thinning prescriptions would not be expected to be different from the analysis done in 

the FEIS for the Proposed Action; the difference would be in the implementation. 

Based on this information, an alternative incorporating variable density thinning was 

not separately analyzed in detail. 

SC-49 

p-23 

Comment: 

 the EIS fails to meaningfully and accurately incorporate the actual recommendations of the 

referenced science; fails to objectively disclose and address science that recommends 

against the project’s actions; fails to substantiate the specific actions of the project with 

corresponding science that supports cutting mature well-established trees >14” to 16” and 

above when trees of this diameter are deficient across the forest landscape, when snags and 

downed logs of such diameters and above are deficient; where the area is a mixed fire 

severity pattern, mixed conifer and ponderosa pine transition forest ecosystem where 

structural complexity naturally varies and includes greater density levels than the agency 

actions allow; etc. Overall, the response fails to reasonably address our substantive 

comment issues, or provide expert foundation specifically relevant to the project’s actions 

Response:

We respectfully disagree with this comment. The Eastside Screens analysis 

(Appendix F) of the Cobbler II EIS shows the current level of old forest stands with 

regard to the HRV. See also the analysis of snag populations in the FEIS, Chapter 3. 

pp. 3-98 to 3-101. 

See response to comment SC-3, SC-8, and SC-20 above. 

SC-50 

p-23 

Comment:

The DEIS fails to disclose cumulative effects, including monitoring results, from past 

projects such as Loon and others across the Umatilla NF. 

Response:

Past, present and reasonably foreseeable actions are disclosed in the FEIS, Chapter 3 

pp. 3-2 to 3-4 and cumulative effects analysis for each resource are also disclosed in 

this chapter by resource. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-36

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

The Forest Service followed CEQ’s guidance (memo dated June 25, 2005 – Guidance 

On The Consideration Of Past Action In Cumulative Effects Analysis) on the extent to 

which agencies of the Federal government are required to analyze the environmental 

effects of past actions in accordance with Section 102 of NEPA. 

SC-51 

p-24 

Comment: 

The agency fails to substantively found its subsequent claim that the purpose and need for 

action are based on site-specific knowledge of existing conditions in the project area and 

relevant scientific information. The scant science that is employed directly by the agency to 

develop its P&N and alternative actions fails to support the level of logging planned by this 

timber sale project. As well the agency fails to objectively disclose contending science or 

develop a full range of reasonable alternatives. 

Response:

See FEIS, Chapter 1, Background (pp. 1-3 to 1-4) and Purpose and Need (pp. 1-4 to 1-

5). Also see FEIS, Chapter 2, Chapter 3, and Literature Citations 

Also see response to comment SC-3 above. 

SC-52 

p-26 

Comment (Question):

Concerning Sediment, Salmonid Water Systems & Species Recovery, & Oregon State 

Listed 303(d) Waterways: Have you quantified sediment loading to streams, and how 

does the project prevent sediment from ground disturbing activities from reaching 

tributaries, streams, and the area’s Grande Ronde salmonid watersystems? 

Response:

No quantitative sediment models were used in this analysis. No streams in the 

Cobbler II project planning area are 303d listed (FEIS, Chapter 3, p 3-15). Project 

design criteria (FEIS, Chapter 2, Table 2-6) and Best Management Practices 

(Appendix D) would limit sedimentation from activities, and PACFISH RHCAs 

would prevent sedimentation from reaching waterways. A section in the FEIS, 

Chapter 3 specifically addresses the Clean Water Act and a finding of consistency 

with the CWA FEIS, Chapter 3, pp. 3-22 to 3-23. 

The Fisheries section of the FEIS, Chapter 3, pp. 3-38 to 3-39 explains in detail how 

sediment would be prevented from reaching stream channels. 

SC-53 

p-26 

Comment (Question): 

Concerning Wolf, Lynx, & Wolverine: There have been recent ODFW confirmed 

reports of wolves, including one of the first known returning wolf pairs with two young 

pups, that are establishing territory in the greater Wenaha-Tucannon and Grande Ronde 

Roadless Area, including connective habitat in the Cobbler project area. In addition to 

these recent confirmations of wolves in the project vicinity, have there been any reported 

and/or confirmed sightings of wolf, lynx, and/or wolverine in the Walla Walla District over 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-37

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

the past 20 years? Given all of these three terrestrial wildlife species require extensive 

home range and dispersal territories; have any of these past and recent sightings been 

within the greater proximity of the Cobbler II Project area? 

Response:

The Wildlife section in the FEIS, Chapter 3 acknowledges that wolves, lynx and 

wolverine could be present in the area at any given time. All three species have been 

reported in the area, but only wolves have been confirmed. Effects to wolves are 

adequately disclosed in the FEIS, Chapter 3 pp. 3-106 to 3-108. 

Lynx are not believed to inhabit the area. Please note: Umatilla National Forest is 

currently considered “unoccupied” by Canada lynx (USFS 2006). Based on the lack 

of reproduction records, limited verified records of lynx, low frequency of 

occurrences, and correlations with cyclic highs with populations in Canada, the U.S. 

Fish and Wildlife Service concluded that lynx could occur in Oregon as dispersers 

that have never maintained resident populations (USFWS 2003). 

The majority of Cobbler II project planning area is suitable for wolverine foraging, 

but no potential denning areas are known. There are no indication that wolverine do 

more than pass through on a rare occasion. Activities would not alter prey 

availability or use of the area by wolverine. 

These facts were considered and disclosed in the analysis of environmental effects for 

these species (FEIS, Chapter 3, pp. 3-105 to 3-111). 

SC-54 

p-26 

Comment (Question): 

Concerning Management Indicator Species & Regional Species of Concern: Does the 

Forest Service have population surveys completed for Management Indicator Species & 

regionally sensitive species (including pileated, northern three-toed, and other 

woodpeckers, American marten, and/or goshawk and other species) and how does the 

proposed Cobbler II project provide for viability consistent with the 1982 planning rule for 

MIS viability? 

Response:

Formal population surveys were not conducted at the project level, but key areas 

were field checked for some species. Determinations made for MIS wildlife species 

are based on past and current known occurrences of these species, field 

reconnaissance, and habitat conditions. The known or likely presence of these species 

is disclosed in the FEIS, Chapter 3, pp, 3-93 to 3-104. Monitoring of entire 

populations and habitat trends is more appropriate at the Forest or province level 

than at the scale and extent of the Cobbler II project planning area. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-38

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-55 

p-26 

Comment (Question): 

Concerning High Elevation Moist, Mixed-Conifer and Subalpine Forest: What 

scientific studies does the agency have that support the proposed project activities in higher 

elevation mixed conifer/moist forest types as a means to reduce the impact from potential 

future natural disturbance (like insects and fire)? Our conservation organizations are well 

versed in credible contemporary scientific research pertinent to the project area, much of 

which we have previously provided to the agency’s planning staff and decision making 

officials as part of our comments and appeal exhibits on Cobbler. We are not aware of any 

scientific support for going into these forests and would like to know what the Forest 

Service is relying upon in developing the proposed project, and complying with NEPA’s 

clear expert science requirements and President Obama’s Scientific Integrity 

Memorandum. Where in the previous EA (beyond the bibliography and unsubstantiated 

references to some scientific studies) are substantive scientific references and information 

presented that this project will reduce insect outbreaks? Where in the Cobbler II EIS and 

the previous Cobbler EA and Decision are the scientific references and information 

presented that this project will reduce fire risk? 

4a. Specifically, what conclusions and recommendations from which scientific studies 

support the planned logging, thinning, road use and construction, and burning actions in the 

mid and high elevation mixed conifer, mixed fire severity plant association group forests in 

the proposed Cobbler and Cobbler II Project units? In addition to the name of the study and 

its authors, we would appreciate the page(s) and or quotations where the conclusions and 

recommendations stated directly support the planned logging and related management 

actions in mixed conifer, mixed fire severity, PAGs. 

Response:

See response to comment SC-8 and see Appendix J for our consideration of best 

science. 

Also see previous response to comments in the FEIS, Appendix G, pp. G-123 to G-124, 

Comment 10; p. G-125, Comment 11; p. G-127, Comment 15; and p. G-135, 

Comment 29. 

SC-56 

p-27 

Comment (Question): 

Pertaining to Climate Change & Forest & Soil Carbon Sequestration: The EIS, 

previous EA and related Umatilla project NEPA documents claim that the agency presumes 

this project will respond to climate change by reducing the impact of future fires. However, 

readily available science shows that logging results in far more carbon emissions than 

wildfire. What science do you have to support your claims in the previous EA and related 

similar Umatilla project NEPA documents? What is your response to the Mitchell study, 

Dr. Harmon’s testimony to Congress and the declaration of Dr. Richard Waring provided 

for the similar Wildcat and Farley projects (and provided herein as part of these 

comments)? Mitchell et al specifically state that logging results in more carbon output than 

natural disturbance. Specifically, how does the agency support its claims that there will be 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-39

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

less carbon emission release due to the planned Cobbler II logging in light of these 

scientific research conclusions? 

Response:

The EIS does not claim a reduction in carbon emissions that would affect climate 

change from the proposed activities. “Our current understanding of climate science 

suggests it is difficult to establish a cause-and-effect relationship between proposed 

actions and climate change at a project scale. Therefore, no attempt was made to use 

climate change as an issue during the NEPA process, and no indicators were 

established for comparing potential climate change effects between alternatives” 

(FEIS, Chapter 3, p. 3-155) 

 

In the FEIS, Chapter 3 p. 3-160 under the heading Forest Carbon Analysis there is a 

sentence which states: “This section discusses issues associated with carbon storage 

and sequestration, carbon stocks and fluxes, and possible interactions between 

activities that would be expected to cause short-term reductions in carbon stocks 

(such as thinning and prescribed fire) in order to avoid potentially large carbon 

emissions from wildfire and other stand-replacing disturbance processes in the 

future.” 

A recent paper, A Synthesis of the Science on Forests and Carbon for U.S. Forests 

(Ryan et al. 2010), makes a similar statement in a list of strategies that “can increase 

forest carbon storage, prevent its loss, and reduce fossil fuel consumption.” “Fuel 

treatments trade current carbon storage for the potential of avoiding larger carbon 

losses in wildfire. The carbon savings are highly uncertain”. 

Mitchell is not an experimental study; the article shows results of computer modeling. 

The simulation results are similar to others, indicating variability among sites and 

treatments in carbon balance. 

Harmon is testimony before a congressional subcommittee from a forest science 

professor, presenting his opinion about how carbon sequestration should be analyzed 

and which management strategies might be successful. Waring is a declaration by 

forest science researcher, which does not constitute peer reviewed science. These 

references do not provide science that opposes methods proposed in the Cobbler II 

project. 

SC-57 

p-27 

Comment (Question): 

Pertaining to the importance of soil community integrity, hydrology and functioning ; 

and the importance of unfragmented unroaded forests; in restoring and maintaining 

forest resilience: In light of the scientific research submitted by our organizations in our

appeal of Cobbler, and related appeals of Farley and Wildcat, and the declaration of Jon 

Rhodes (provided herein as part of these comments); upon what scientific conclusions and 

recommendations does the agency base its planned ground based logging and road 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-40

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

construction and its related claims that these actions and their impacts will help restore 

forest resilience? Specifically note the title and author(s) of what research studies’ 

conclusions and recommendations support the agency’s actions and analysis claims 

pertaining to soils, soil communities, hydrology, and forest resilience? 

Response:

Rhodes 2007, catalogues the many possible effects of mechanical fuel treatments on 

many National Forests including the Umatilla. He questions whether BMPs are 

implemented consistently. Neither the proposed 0.25 miles of new system road 

construction nor the 0.20 miles of proposed temporary road construction are 

connected to the stream network and so would have no effect to hydrologic function. 

Road density would increase by less than 0.01 miles per square mile in the WenahaRock Creek SWS, a negligible amount (FEIS, Chapter 3, p. 3-16). 

Design criteria listed in the FEIS, Chapter 2, Table 2-6, p. 2-27 specifies 

decommissioning standards for proposed temporary construction. Projects proposed 

in Cobbler II project planning area have been designed and mitigated to prevent or 

minimize damage to ground cover, erosion, and sedimentation. Road drainage 

improvement, especially work on FR 6222 could cause short-term, less than one week, 

sedimentation. The potential for sedimentation from any other proposed actions is 

negligible. Project activities proposed in Alternative B offer no opportunity for 

measurable cumulative effects with ongoing actions (FEIS, Chapter 3, pp. 3-20 to 3-

21). 

Soil disturbance is limited by design, prescriptions, and extent of proposed actions 

with organic matter levels retained per cited paper(s) in the Soils section of FEIS 

Chapter 3. Earlier harvest operations with greater soil disturbance has shown little 

indication that stand reestablishment and growth rates have been negatively affected 

and that site resilience is high. 

The focus of the vegetation analysis and activity proposals is to return the forest to 

within the HRV for important stand and landscape conditions, conditions under 

which the forest and disturbance agents have evolved together (FEIS, Chapter 3, pp. 

3-43 to 3-62). 

Literature is used in specialist reports written for Cobbler II in support of treatment 

proposals includes but is not limited to: 

Agee, J.K. 1998. Everett, R., P. Hessburg, J. Lehmkuhl, M. Jensen, and P. Bourgeron. 

1994. Kolb, T.E., P. Agee, Z. Fule, N.G. McDowell, K. Pearson, A. Sala, and R.H. 

Waring.2007. Mitchell, S.R., M.E. Harmon, and K.E.B. O’Connell. 2009. van 

Mantgem, P.J., N.L. Stephenson, J.C. Byrne, L.D. Daniels, J.F. Franklin, P.Z. 

Fule,M.E. Harmon, A.J. Larson, J.M. Smith, A.H. Taylor, and T.T. Veblen. 2009 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-41

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-58 

p-28 

Comment: 

The project largely involves scientifically unfounded programmatic actions that are in 

contravention with the natural ecological functions and cycles of localized forest mosaic 

types. 

Response:

See response to comment SC-8. 

SC-59 

p-32 

Comment: 

NEPA requires that the public be meaningfully informed of factors that influence project 

development and design. The failure of the USFS to disclose that agency funding is in-part 

contingent on meeting timber volume output quotas and the failure to comparatively and 

objectively address how the planned project actions are affected in excess of scientific 

research conclusions and recommendations violates federal environmental policy law. 

Response:

See FEIS, Chapter 1, pp 1-3 to 1-5, this project was based on the background 

information of the existing condition and purpose and need to move toward the 

desired future condition as identified in the Forest Plan (FP pp. 4-1 to 4-14). 

The purpose and need for this project is responsive to and consistent with the 

following Forest Plan goals (FEIS, Chapter 1, p. 1-15): 

• To provide land and resource management that achieves a more healthy and 

productive forest and assists in supplying lands, resources, uses, and values 

which meet local, regional, and national social and economic needs. 

• To provide for production and sustained yield of wood fiber and insofar as 

possible meet projected production levels consistent with various resource 

objectives, standards and guidelines, and cost efficiency. 

• To protect forest and range resources and values from unacceptable losses 

due to destructive forest pests through the practice of integrated pest 

management. 

• To provide and execute a fire protection and fire use program that is costefficient and responsive to land and resource management goals and 

objectives. 

No timber volume target quotas were considered in planning this project 

SC-60 

p-32 

Comment: 

Concerning so-called “temporary” roads, again the agency’s response fails to address the 

issues raised in our comments, including the misleading pretention that the roads in 

question are temporary at all when instead they remain on the landscape and in other 

locations have even been re-opened for further re-use. These roads as such are in reality but 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-42

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

a euphemism for new system roads, similar in actual use pattern to the agency’s many 

closed administrative roads that may be opened to facilitate management needs. 

Environmentally the detrimental impacts of such roads persist on the forest landscape for 

decades to centuries, and as such these roads are not “temporary” in affect at all. The EIS 

as such violates the NEPA in its failure to accurately disclose the nature of such roads, and 

its failure to disclose and address the impacts of these new system roads on the area’s forest 

ecosystem and waterways. 

Response:

Approximately 0.20 miles of temporary road construction would occur off FR 6214 to 

access two harvest units (88 and 89), and would be decommissioned after timber sale 

use. This temporary road would be built on a ridge where a user-developed jeep trail 

already exists. It would not require cut and fill construction. If the road remains 

over winter, waterbars would be installed to prevent erosion. Upon completion of 

timber sale activities the road would be subsoiled, berms would be pulled into the 

roadbed. It would be revegetated with native seed, and mulching with existing slash 

would occur. The road entrance would be camouflaged to discourage use (FEIS, 

Chapter 2, p. 2-19). 

In Alternative B temporary road construction of approximately 0.20 miles (0.5 ac) is 

included in disturbance estimates for units 88 and 89 (FEIS, Chapter 3, p. 3-7 and 

Appendix E). 

About 0.20 miles of temporary road are proposed for construction between Units 88 

and 89 for skyline logging system access. There is no risk to water quality or 

hydrologic function because the location of the road is far enough away from any 

channels. Post sale work would recover soil productivity to the extent possible and 

minimize the potential for future use (FEIS, Chapter 3, pp. 3-19 to 3-20). 

Cumulatively the effects of proposed activities in combination with other existing and 

potential future effects are not expected to have lasting negative impacts to Rocky 

Mountain elk and other big game species (FEIS, Chapter 3, p. 3-97). 

Where applicable, direct, indirect and cumulative effects of temporary road 

construction are included in environmental effects analysis in the FEIS, Chapter 3. . 

See response to comment SC-45. 

SC-61 

p-32-33 

Comment: 

The DEIS claims that there is an overabundance of trees >9" dbh and <20.9" dbh; however 

the DEIS fails to disclose that overall throughout the project area, trees >16" dbh are 

present in deficient numbers as compared to the optimal natural range of variability and 

desired mature and old forest structure for the area's PAG forests and wildlife habitat. The 

EIS fails to address core issues clearly raised in our comments on the importance of 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-43

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

restoring and maintaining natural forest structure and habitat, and the rarity of tree>16” dbh 

on the forest landscape in the project area: The sad fact that the agency cannot discern any 

direction or need to address the importance of determining the mean diameter above which 

tree density does not exceed HRV levels only further serves to emphasize the lack of a 

scientifically sound basis for this commercial logging project disguised as pseudo 

restoration. Clearly, there exists no legitimate scientific basis for the level of logging 

planned of trees that are >16” dbh that are rare across the forest landscape. Instead of 

basing its planned actions on NEPA requisite accurate site-specific conditions, the EIS 

utilizes an arbitrary regional formula diameter limit of 21” dbh. Additionally, most of the 

project is located in mixed conifer PAG areas where forests are naturally structurally 

complex and dense. Science research concludes that logging-thinning is not warranted in 

most such areas – including that found throughout the majority of the Cobbler II project. 

Response:

Forest stand data do not indicate that trees of those diameter classes are deficient in 

this landscape (project file). 

With regard to management in mixed conifer PAGs, see response to comment SC-8.

SC-62 

p-33 

Comment: 

The DEIS fails to identify the "best available science" that supports logging in LOS stands. 

Ninth Circuit has held FS decisions to be arbitrary and capricious where best available 

science wasn't identified. The EIS directly cites – largely out of context - a scant few 

studies it claims supports its logging. The EIS fails to objectively disclose and address any 

of the abundant science research cited in our previous comments and appeal, and again 

included in our exhibits, that recommends against such actions or recommends against the 

levels of such actions as are planned in this project. 

The EIS as such violates the of the NEPA, which requires agency actions be well-founded 

on objectively presented, accurate scientific research, and that an EIS objectively disclose 

contending science and provide compelling evidence supporting agency actions where

these diverge from scientific recommendations and/or where these are scientifically 

controversial. 

Response:

We respectfully disagree with this comment. Resource specialists incorporated 

scientific research, considered to be the best available science, in their environmental 

effects analysis (FEIS, Chapter 3 and Literature Citations). The Forest Service 

reviewed exhibits presented by the public in their comments (see FEIS, Appendix G, 

pp. G-8 to G-118 and pp. G-178 to G-192 and this Appendix pp. I-103 to I-133. 

Some commenters provided lists of what they deemed scientific papers which 

disputed the scientific reports that we have used. We reviewed the submitted papers, 

some were newspaper editorials or opinion papers not documenting any research, and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-44

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

which cannot be considered scientific sources. Others were papers and reports we 

have used, but were interpreted differently than how the paper intended. Lastly, 

some were scientific papers, but they were done in different climatic or geographic 

areas from the Blue Mountains. I found the scientific literature that the Forest 

Service specialists used to be the best available and most applicable science. 

SC-63 

p-33 

Comment: 

Powell (1999) is outdated and is not supported by current science. The EIS response fails to 

meet NEPA’s requirements concerning the issues raised. The EIS fails to address that the 

research in question occurred over a decade ago, and that there has been a wealth of 

research that has refuted many of the speculative and unfounded conclusions and 

assumptions made in earlier studies. The agency fails to objectively acknowledge and 

address areas of scientific controversy and contention relevant to its use of these studies. 

The agency also fails to disclose areas of uncertainty and of significant localized HRV 

variations to the management formulas developed in these studies. 

Response:

See response to comment SC-8.

SC-64 

p-34 

Comment: 

The EIS response fails to objectively acknowledge that the planned action will reduce 

snags utilized by species of concern, which begin to use snags above 11” dbh for many 

medium and smaller sized cavity excavators and nesters, and above 15” for pileated and 

larger-sized species. The EIS fails to acknowledge that science clearly recommends that the 

best method to recruit snags is to maintain ongoing natural processes and mortality levels. 

The EIS fails to acknowledge that considerable portions of the planning area across the 

landscape are deficient in medium and large snags and downed logs, and that project 

actions will prolong this deficiency.

Response:

We respectfully disagree with this comment. An analysis on effects to snags can be 

found in the FEIS, Chapter 3, pp. 3-98 to 3-104. The distribution of snags is disclosed 

in Figures 3-5 to 3-8. 

SC-65 

p-34 

Comment: 

The DEIS doesn't accurately characterize HRV; prescriptions don't reflect actual HRV 

density conditions; basal area and SDI formulas are highly erroneous. The EIS doesn’t 

effectively address the comment, which is about the mixed conifer mixed fire pattern 

naturally structurally complex area’s actual HRV conditions. While the stand density 

formulations may reflect the agency’s assumptions as to “recommended stocking levels” 

these assumptions are not based on HRV levels, but instead on largely timber industry and 

silvicultural management formulas designed to minimize tree mortality that were 

developed for timber plantations, not natural forest ecosystems. The failure of the EIS to 

objectively address this significant issue violates the NEPA. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-45

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

See response to comment SC-8.

SC-66 

p-34 

Comment: 

The EIS fails to ensure scientific accuracy and integrity regarding stand density index, and 

fails to adequately analyze tree mortality levels under no action versus the action 

alternatives. The EIS repeatedly infers that, if no action is taken to reduce stand densities 

through thinning, there will be high levels of tree mortality due to wildland fire or

competition between trees and resulting beetle kill. 

Response:

With regard to the stand density index and stocking level guides used, see response to 

comment SC-8. 

Part of the purpose and need for the Cobbler II project, (FEIS, Chapter 1, p. 1-4) is to 

improve health, vigor, and resilience to fire, insects, and disease in upland forests that 

are outside their historical pre-fire suppression conditions for species composition 

(including hardwood species), structural diversity, stocking densities, and fuel loads. 

The definition of resilience used is: The capacity of a plant community or ecosystem to 

maintain or regain normal function and development following disturbance (FEIS, 

Glossary p. G-16). 

SC-67 

p-34 

Comment: 

With regard to wildland fire, this fundamental premise of the EIS is arbitrary and 

capricious on its face. The EIS lacks objective analysis that addresses the current 

susceptibility to high-intensity fire conditions. General regional evidences indicates that 

the majority of the area, even under extreme fire weather (most areas do not burn under 

such extreme fire weather) would experience a mosaic of both mixed-severity and lowintensity fire wherein very few trees overall on the forest landscape are killed. It is likely 

that the level of tree mortality that would occur under current forest stand conditions in the 

project area would be FAR less than the level of mortality that would directly result from 

the planned logging under either action alternative 

Response:

We respectfully disagree with this comment. See FEIS Chapter 3, pp. 3-62 to 3-71 for 

a description on current fuel conditions in the project planning area, and pp. 3-71 to 

3-75 for a comparison of effects to all alternatives considered in detail, including the 

No Action alternative. 

SC-68 

p-34 

Comment: 

The EIS similarly infers that, if no action is taken to reduce stand densities through 

thinning, there will be high levels of tree mortality due to competition between trees and 

resulting beetle kill, citing several studies for the proposition that the current density of the 

forest stands in the project area must be severely reduced supposedly in order to prevent 

these speculative levels of tree mortality 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-46

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

See response to comment SC-8 above. 

SC-69 

p-35 

Comment: 

the EIS planning must have utilized erroneous Site Index and UMZ values to arrive at its 

logging-thinning formulations, resulting in the proposed removal of far more trees, 

including mature and old trees up to 21” dbh, than otherwise would have been proposed if

accurate UMZ figures were used. 

Even if the EIS had used accurate UMZ figures (which it did not, as discussed above), the 

EIS nevertheless still misrepresented the scientific data, and the cited studies, by 

erroneously claiming that these studies indicate that high tree mortality levels would occur, 

relative to the impacts of the thinning itself, if no action was taken. 

Response:

See response to comment SC-8. 

SC-70 

p-36 

Comment: 

The EIS fails to provide the hard data or methodology necessary to support its assumptions 

regarding historic range of variability (HRV), and makes clearly inaccurate 

assertions/assumptions regarding HRV. The EIS repeatedly makes assertions and 

assumptions about the current stand conditions relative to HRV, but fails to provide the 

data, citations, and methodology necessary to understand whether there is any evidentiary 

basis whatsoever to their assertions. It is clear that the EIS’s HRV assumptions are 

fundamentally inaccurate, given that the EIS infers that, in the mixed-conifer forest types 

that overwhelmingly dominate the project area, high-intensity fire (and the relatively 

denser forest conditions that can allow it to occur) is somehow unnatural and is not part of 

the HRV, while in reality most of the forest in the project area has at some point in its 

natural range of variability been the result of past mixed and/or high-intensity fire(s) that 

occurred prior to logging, fire suppression, and settlement by non-Native-Americans. 

Response:

The complexity of stand conditions under mixed severity fire regimes are discussed in 

the FEIS, Chapter 3, pp. 3-45 to 3-47.

SC-71 

p-36 

Comment: 

Based upon the foregoing, and the information below regarding the low levels of large 

snags relative to the needs of native wildlife species, the EIS improperly narrowed the 

range of alternatives, and failed to consider a reasonable range of alternatives. At a 

minimum, a small-tree-only thinning alternative should have been fully considered (i.e., an 

upper diameter limit of 10-12 inches, and some significant areas left unthinned); and a 

prescribed fire only alternative should also have been fully considered. Additionally, a 14” 

dbh and a 16” dbh range of alternatives should have been developed – providing the 

agency can substantiate such levels of logging in the project’s mixed conifer mixed fire 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-47

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

pattern forests (for cutting above 12” to 14” at most such substantiation is generally 

lacking). 

Response:

The purpose and design for Alternative C was to respond to the agency’s purpose and 

need while responding to the key issues of elk habitat and old forest habitat and 

functional connective corridors. It was designed to implement project activities with 

fewer impacts on elk cover or old forest habitat (FEIS, Chapter 2, p. 2-32). 

The range of alternatives was designed to meet the purpose and need, FEIS, Chapter 

1, pp. 1-4 to 1-5. In response to your comments alternatives were considered but 

eliminated from detailed study that used non-commercial thinning of small diameter 

trees rather than commercial harvest and harvesting only trees less than 16 inches 

DBH and lower (FEIS, Chapter 2, pp. 2-36 to 2-39). 

SC-72 

p-37 

Comment: 

The EIS fails to adequately analyze the adverse impacts of stand density reduction, and 

perpetuating and worsening large snag deficits, on wildlife species that depend directly or 

indirectly upon substantial large snag densities 2009). While the area currently has 

inadequate levels of large snags for most MIS species (and the much larger groups of 

wildlife species represented by each of these MIS), the planned stand density reduction 

activities would result in even lower levels of large snags in both the short and long-term, 

spanning decades. The EIS fails to provide a reasoned quantifiable estimate of the extent of 

further reductions in large snag densities in future decades and the resulting adverse 

impacts on MIS species. 

Response:

We respectfully disagree with this comment with your statement that “the area 

currently has inadequate levels of snags” This statement is unfounded. This can be 

true in small areas, but is not true for the entire area. Likewise, snag habitat would 

be somewhat reduced in harvest units, but 85 percent of the area would not be 

affected. Retention of snags at the densities prescribed would maintain snags at an 

intermediate level for snag-associated wildlife while reducing fuels, with the long-term 

goal of making stands more resilient to disturbance (FEIS, Chapter 3-98 to 3-104). 

SC-73 

p-38 

Comment: 

The EIS Fails to Adequately Analyze the Adverse Impacts of Further Reducing Wildland 

Fire, Especially High-Intensity Wildland Fire, on Wildlife Species Dependent in Whole or 

in Part Upon Post-fire Habitat 

The EIS makes the scientifically unsound and inaccurate assumption that a loss of wildlife 

habitat and ecosystem value is caused by wildland fires, at least where moderate-intensity 

or high-intensity patches occur, and that the forest ecosystems are somehow diminished 

because such fires occur; and the EIS simply does not adequately analyze the adverse 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-48

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

impacts to wildlife species from eliminating high-intensity fire. 

Response:

The importance of burned forest to Lewis and black-backed woodpeckers is disclosed 

in the FEIS, Chapter 3, on p. 3-102 under the effect’s analysis of the No Action 

alternative and pp 3-108 to 3-110. 

SC-74 

p-40 -41 

Comment: 

The Black-backed Woodpecker is the MIS species representing post-fire habitat, where 

high-intensity fire has occurred, or areas where most or all trees are killed by beetles. It is 

a bellwether species for many other wildlife species associated with post-fire habitat. The 

Forest Service has thus far failed to explain how the viability of the Black-backed 

Woodpecker will be maintained in the forest plan planning area when the stated goal of 

current management is to eliminate its habitat through thinning designed to prevent highintensity fire, as the EIS clearly states. 

Yet the Forest Service fails to identify how many Black-backed Woodpeckers, and how 

much Black-backed Woodpecker habitat, is needed in order to maintain viable populations 

of this species in the planning area, OR how many Black-backed Woodpeckers and how 

much suitable Black-backed Woodpecker habitat there currently IS in the planning. 

Response:

There is no burned habitat currently available in the Cobber II project planning area, 

and therefore no black-backed woodpeckers are expected in the area (as disclosed in 

the FEIS, Chapter 3, p. 3-102). 

SC-75 

p-46 

Comment: 

Thinning increases fire risk. Thinning may increase fire hazard because it creates slash, 

moves fine fuels from canopy to ground, increases ignition risk, makes the forest hotter, 

dryer and windier, stimulates growth of surface and ladder fuels. Yet, the EIS response is 

speculative, and fails to meaningfully address this concern. 

Response:

Several scientific publications have documented the need to treat stands at three levels 

to keep fire from burning into tree crowns, including Agee and Skinner, 2005; Mason 

et al. 2007; Hall and Burke, 2006 and Scott and Reinhardt, 2001. These levels of 

treatment include; reducing surface fuels (to reduce flame lengths), increasing the 

height to live crowns, (requiring longer flame lengths for torching to begin), and 

decreasing crown density, (which makes tree-to-tree crown fire less probable). 

Also, the following, recently published journal article excerpt (as well as the 

remainder of the article) discusses more specifically why thinning is an appropriate 

and effective fuel treatment method. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-49

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

"The most appropriate fuel treatment strategy is often thinning (removing 

ladder fuels and decreasing tree crown density), followed by prescribed fire, 

piling and burning, mastication of fuels, or other mechanical treatments that 

reduce surface fuel amounts and often promote decomposition (figs. 18 and 21). 

This approach reduces canopy, ladder, and surface fuels, thereby reducing 

both the intensity and burn severity of potential wildfires. Restoring forests to a 

condition in which fire alone can maintain the desired conditions will take time 

(fig. 18). Wildland fire use (that is, allowing certain wildfires to burn under 

certain conditions and locations) offers some hope once homes, communities, 

and key resources are protected through thinning, prescribed fires, or other 

treatments. 

Thinning and prescribed fires can modify understory microclimate that was 

previously buffered by overstory vegetation (Scott and Reinhardt 2001; Pollet 

and Omi 2002; Weatherspoon 1996). Thinned stands (open tree canopies) allow 

incoming solar radiation to penetrate to the forest floor increasing surface 

temperatures, decreasing fine fuel moisture, and decreasing relative humidity 

compared to unthinned stands—conditions that facilitate intense fires 

(Countryman 1955; Pollet and Omi 2002). An increase in surface fire intensity 

may increase the probability of a fire exceeding the critical threshold needed to 

initiate a crown fire (Van Wagner 1977). Therefore, it is important that the gap 

between the surface and crown fuels is increased by either prescribed fire or 

pruning (fig. 18) so if a fire should occur, the potential for crown fire initiation 

is minimized. Rothermel (1983) found significant differences in fire behavior 

between a closed stand (no harvest) and an open stand (thinned). Changing 

stand structure, while ignoring surface fuels, will only affect the likelihood of 

active crown fires—it will not necessarily reduce the likelihood of surface fires 

intense enough to damage soils or cause significant overstory mortality. For 

example, figure 25 illustrates the build-up of organic layers as a function of fire 

exclusion. If only ladder and crown fuels are treated ignoring the ground fuels, 

in this situation, a fire would most likely lead to high soil burn severity and 

killing of trees through cambium kill. Moreover, surface fire intensity may be 

greater in thinned stands compared to untreated stands depending on whether 

the thinning activity adds to the surface fuels (Alexander and Yancik 1977; van 

Wagtendonk 1996; Stephens 1998). Therefore, it cannot be emphasized enough 

that all fuel layers need to be managed (over time and space) to minimize the 

unwanted consequences of wildfires (fig. 10)." 

Graham, Russell T., Theresa B. Jain and Susan Matthew, 2010. Cumulative 

Watershed Effects of Fuel Management in the Western United States. Gen. Tech. 

Report. RMRS-GTR-231. Rocky Mountain Research Station, U.S. Forest Service. 

68p. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-50

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-76 

p-46 

Comment: 

The DEIS fails to substantively address climate change and carbon cycling. DEIS analysis 

evades utilizing available science provided the agency in our prior comments and appeal 

relevant to project-specific quantification and assessment of the direct and incremental 

cumulative role of the project’s proposed actions in diminishing localized carbon cycling in 

this era of exponentially increasing climate change; FS has obfuscated and evaded its duty 

to consider and disclose carbon/climate consequences of logging. 

Response:

See response to OW-12, OW-13, and SC-56. 

SC-77 

p-47 

Comment: 

The EIS fails to take into account competing values that the Forest Service is obligated to 

consider such as wildlife needs, recreational aesthetics, continued soil productivity, natural 

variables, and the recommendations and conclusions of contending science on these and 

other ecological issues. 

Response:

We respectfully disagree with this comment. See FEIS, Chapter 1, p. 1-11 for 

information contained in the project record, Chapter 3 for disclosure of effects to 

affected resources in the proposed project planning area, and Literature Citations for 

citations used in the environmental effects analysis by resource specialists. 

SC-78 

p-49 

Comment: 

On December 14, 2009, representatives of our organizations met with Umatilla National 

Forest officials and staff, including Forest Supervisor Kevin Martin, Walla Walla District 

Ranger Mike Rassbach, then Heppner District Ranger Thomas Mafera, North Fork John 

Day District Ranger Robert Varner, Forest Silviculturalist David Powell, and Wildlife 

Biologist Mark Henjum. 

The Forest Service’s silviculturalist David Powell and wildlife biologist Mark Henjum 

acknowledged considerable agreement with scientific research recommendations and 

wildlife habitat objectives for mixed conifer forests that were provided to the agency and 

addressed in detail in our appeal of the original Cobbler Project, as well as these other two 

Umatilla projects. 

Response:

Document in project file dated March 18, 2010 signed by David Powell and Mark 

Henjum states the following: 

It is our understanding that the intent of a meeting convened in Heppner, Oregon on 

December 14, 2009 was to have a general discussion with members of the Sierra Club 

and the Blue Mountains Biodiversity Project to hopefully foster better communication 

between the Umatilla National Forest and local stakeholder groups. Our recollection of 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-51

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

the meeting is that several issues were discussed, but the discussion was not focused 

entirely on specific projects such as Cobbler, Farley, and Wildcat. 

The statement above that David Powell and Mark Henjum “acknowledge with 

considerable agreement” any issue or topic raised or discussed at the meeting, implied or 

otherwise, is incorrect. The statement is misleading and, in our view, does not accurately 

characterize the meeting or the general discussions.

SC-79 

p-50 

Comment: 

The current “EIS” is so largely in name only. It is nearly identical to the previous EA, 

containing much of the same analysis and the same alternatives. It fails NEPA’s rigorous 

requirements for a hard look, stringent objective analysis, scientific foundation including 

the disclosure of contending science and scientific controversy. 

Response:

See response to comment SC-20 above. 

SC-80 

p-50 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because it includes Scientifically insupportable logging, thinning, and 

burning in upland mixed conifer, mixed fire severity forest systems. 

Response:

See response to comment SC-8. 

SC-81 

p-50 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because Proposed actions would significantly reduce and impair the 

carbon sequestration capacity of the affected forest areas at a time when issues of logging 

contribution to carbon release, and logging caused reductions in forest carbon sequestration 

play significant roles in exacerbating exponentially increasing global and localized climate 

change. Logging degradation of carbon sequestration capacity is counter to the imperative 

societal necessity of effectively and proactively addressing, minimizing, and reducing the 

impacts of climate change. 

Response:

See response to comments OW-12 and OW-13. 

SC-82 

p-50 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because Significant degradation of critically important wildlife habitat, 

adversely impacting interior forest dependent wildlife species including ESA and Oregon 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-52

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

State listed species such as bald eagles, wolves, lynx, wolverine, salmonid species, and 

others; regional species of concern including American marten, Northern goshawk, 

Neotropical migrant and native birds, and others; and management indicator species 

including pileated, three-toed, and other woodpeckers, great gray owls, pygmy and 

flammulated owls, and others. A new SEIS is necessary to credibly assess direct and 

cumulative impacts to these many species of concern evidencing declining population and 

habitat loss trends, and develop action alternatives that are capable of maintaining and 

recovering their habitat and population abundance. 

Response:

Analysis of direct, indirect, cumulative effects and a finding of consistency for MIS, 

TE&S, northern goshawk, landbirds and salmonid species that occur in the project 

planning area and a determination of effect for listed TE&S aquatic and wildlife 

species are disclosed in the FEIS, Chapter 3, pp. 3-35 to 3-43 and 3-87 to 3-117. Also 

see Literature Citations pp. L-2 to L-7. 

SC-83 

P51 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because Wolves are known to be returning to eastern Oregon. The

project area contains unroaded potential wilderness quality forests, is adjacent to extensive 

wilderness and roadless area habitat favored by wolves, and includes connective habitat 

between wilderness areas to the northwest and roadless to the southeast of the project. 

Oregon’s first returning wolves, including a pair of wolves with two pups are confirmed to 

be establishing territory in this area. Far ranging wolverine and lynx also depend upon 

wilderness, roadless, and connective habitat such as is found within and near the project 

area. A new revised SEIS is essential to accurately addressing potential impacts of the 

proposed project upon these ESA, Oregon State, and regional species of concern. 

Response:

See response to comment SC-82 above. This comment was also responded to in the 

FEIS, Appendix G, Letter 3, Comments 57, 58, and 59 on pages G-152 to G-155.

SC-84 

p-51 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because Soil communities are the very foundation of forest resilience, 

biodiversity, and abundance. Subsurface soil community research emphasizes the critical 

importance of protecting and maintaining the ecological integrity, hydrology, and 

functioning of forest soil communities. As extensive ground and vegetation disturbing 

actions are proposed, a new SEIS is essential to developing action alternatives that 

incorporate credible scientific research recommendations capable of addressing the 

ecological purpose and need objectives of this proposed project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-53

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

Anticipated effects to soils and soil biological communities is within the range of prior 

experience in similar soil/ecological types which have satisfactory results and meet 

Forest Plan standards and guidelines (FEIS, Chapter 3, pp. 3-6 to 3-10). 

See also response to comment SC16. 

SC-85 

P51 

Comment: 

The actions proposed in the notice for the Cobbler II EIS Project are scientifically 

controversial at best, and largely not supported by credible scientific research 

recommendations because The project area contains important Grande Ronde salmonid 

watersystems, tributaries, and headwaters. A new SEIS is imperative to ascertain the direct 

and cumulative impacts issues, and short and long-term recovery objectives for salmonid 

waterways and populations within and downstream of the proposed project. The SEIS must 

disclose substantive information on analysis area waterways that are on Oregon State’s 

303(d) list as water quality impaired. The SEIS must disclose when the most recent stream 

reach surveys were conducted within and adjacent to the project area, when these surveys 

may be updated and watersystem status revised as may need be, when surveys will take 

place for as yet unaddressed waterways and their upland tributaries, and foremost –it must 

present reasonable scientifically founded action alternatives capable of restoring the area’s 

listed waterways and aquatic species populations and habitat. 

Response:

Regarding the assertion about 303(d) listed streams, see response to comments SC-17, 

SC-52, and SC-62. 

The EIS does disclose when the most recent stream reach surveys were conducted 

within and adjacent to the project area (FEIS, Chapter 3, Tables 3-13, 3-15, 3-16, and 

3-17). The EIS makes it clear that all fish-bearing stream reaches within or adjacent 

to the project boundaries have been surveyed. Dates of future re-surveys are not 

known and depend upon funding which is beyond the control of the District or Forest. 

Non-fish-bearing streams that have little potential to host fish are not normally 

surveyed, and are not likely to be surveyed in the near future. 

Regarding the assertion that the project must present alternatives capable of 

restoring the area’s listed waterways and aquatic species populations and habitat: 

The Cobbler II project is a Timber Sale and Fuels Reduction project. It is not an 

aquatic habitat restoration project. With the possible exception of water quality in 

the Grande Ronde River, streams in and adjacent to the project area are in very good 

to excellent condition, and not in need of restoration. 

SC-86 

p-57 

Comment: 

The DEIS as noted herein fails to meaningfully respond to the issues raised, including a 

meaningful response to our comments as well as an objective consideration and disclosure 

of relevant science, literature, and legal rulings applicable to this project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-54

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

See FEIS, Chapter 1, p. 1-1, Chapter 2, pp. 2-1 to 2-9 and response to comment SC19. 

SC-87 

p-57 

Comment: 

The EIS fails to adequately address and incorporate issues of scientific controversy and 

applicability, including critically important ecological objectives and concerns addressed in 

our NEPA comments on this project. 

Response:

See response to comments SC-20, SC-47 and SC-86. 

SC-88 

p-58 

Comment: 

The EIS fails to adequately disclose and address the existent significant scientific 

controversy and range of applicable credible research concerning forest conifers and aspen 

stands ecologically symbiotic interface. 

Response:

The study presented during public comment as representing this controversy is 

Kulakowski et al. 2004. The persistence of quaking aspen (Populous tremuloides) in 

the Grand Mesa area, Colorado. Ecological Applications, 14(5), 2004, pp. 1603–1614. 

This study compared a map of the current coverage of aspen stands with a map made 

in the late 1800s, in an area in the southern Rocky Mountains. The authors conclude 

that there has not been a reduction of aspen in that area from that time. The 

biophysical environment in the study is much different from that on the aspen sites in 

the Cobbler II project planning area. The authors caution against extrapolating these 

results to other areas without further research. 

Since the publication of the DEIS, a new guide to the biology and management of 

aspen that applies to the Cobbler II area has been published: Swanson, D.K.; Schmitt, 

C.L.; Shirley, D.M.; Erickson, V.; Schuetz, K.J.; Tatum, M.L.; Powell, D.C. 2010. 

Aspen biology, community classification, and management in the Blue Mountains. 

General Technical Report PNW-GTR-806. Portland, OR; U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 117 p. This 

publication supports the management proposed in the Cobbler II project.

SC-89 

p-58 

Comment: 

The EIS fails to present action alternatives that incorporate credible scientific research 

addressing the natural interwoven functioning of conifers within and adjacent to hardwood 

forest stands. 

Response:

See response to comment SC-88. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-55

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-90 

p-60 

Comment: 

The EIS’s presumptive and limited analysis failed to address many important issues raised 

during the comment period. Among these (in addition to those noted elsewhere herein) are 

the hydrological impacts of water diversions for, and grazing by, livestock; soils impaired 

from past and ongoing management practices (logging, grazing); restoring soil moisture 

availability and retention towards HRV conditions; etc. 

Response:

Cumulative effects to water quality from livestock grazing were disclosed in the 

Hydrology section of FEIS, Chapter 3. Existing ongoing actions, road use, and

livestock grazing would cumulate in an additive manner with sediment effects from 

proposed actions. Ongoing livestock grazing on the Eden C&H Allotment occurs in 

the project planning area. Cattle and other ungulates use closed and abandoned 

roadbeds as trails and use created ponds, wet areas created by damming of 

subsurface flow by roads, live streams, and ponded remains of stream flow for water 

sources. Ground cover is reduced in these areas and erosion is increased. Except for 

channel associated disturbance, this erosion does not affect surface water since there 

is no mechanism that would move it to channels. Disturbance near and in channels 

does lead to sedimentation to some unquantified degree. Most of the channels in 

activity areas are intermittent or barely perennial (seeps or small spring fed pools). 

Transport of sediment occurs during spring runoff. 

Projects proposed in Cobbler II project planning area have been designed and 

mitigated to prevent or minimize damage to ground cover, erosion, and

sedimentation. Road drainage improvement, especially work on FR 6222 could cause 

short-term, less than one week, sedimentation. The potential for sedimentation from 

any other proposed actions is negligible. Project activities proposed in Alternative B 

offer no opportunity for measurable cumulative effects with ongoing actions (FEIS, 

Chapter 3, p. 3-21). 

Effects to soil quality from past and ongoing soil disturbing activities is discussed in 

the Soils section under Direct and Indirect, and Cumulative Effects, in Chapter 3. 

Soil moisture retention restoration is not an associated activity as any loss of available 

moisture capacity (outside the permanent road system) relative to HRV conditions 

would be unmeasurable at the stand scale. Mitigation and restoration actions such as 

decompaction and/or subsoiling of high impact areas are included in contract 

requirements. 

Post-activity exposed mineral soil will be treated as necessary to reduce soil erosion 

and compaction. This may include seeding, installation of waterbars, mulching with 

native material, or subsoiling. Where possible and needed skid trails will be subsoiled 

and/or have logging slash and large wood left. (FEIS, Chapter 2, Table 2-6, p. 2-27). 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-56

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-91 

p-61 

Comment:

The analysis for this project failed to address the full range of environmental impacts, 

including cumulative impacts that are significant and growing in the area, with the 

implementation of other management projects across the District and elsewhere in the 

Umatilla and Wallowa-Whitman National Forests. Impacts to hiding and thermal winter 

range cover for native ungulates including elk, deer, and possibly moose are significant 

issues, compounded by cumulative impacts from previous and ongoing management 

actions, including grazing 

Response:

See response to comment SC-82 above. 

SC-92 

p-61 

Comment: 

The EIS failed to adequately address and accurately disclose harmful direct and cumulative 

impacts to salmonid and other aquatic species habitat. Impacts to wildlife species, 

including marten habitat, and dispersal and foraging habitat and cover for far-ranging 

species such as lynx, wolverine, and wolves have not been accurately or adequately 

addressed. Impacts to neotropical migrant and native birds, goshawks and other raptors, 

cavity nesters, as well as avian mammals such as bats, and canopy dwelling mammals 

including flying squirrels were not sufficiently nor accurately disclosed and assessed. 

Response:

Analysis of direct, indirect, cumulative effects and a finding of consistency for aquatic 

species that occur in the project planning area are disclosed in the FEIS, Chapter 3, 

pp. 3-35 to 3-43. 

For wildlife species, see response to comment SC-82 above.

SC-93 

p-61 

Comment: 

The EIS fails to comply with NEPA scientific accuracy requirements, misusing out-ofcontext and arbitrarily selected scientific recommendations as blanket formulas, instead of 

referring to these as guidance, and adjusting them to match accurate site-specific HRV 

conditions and ecological restoration objectives in the project unit areas. 

Response:

See response to comment SC-9. 

SC-94 

p-61 

Comment: 

The EIS fails to incorporate scientific research that recommends protecting most inherently 

fire-resistant overstory trees above 15 inches dbh in most instances 

Response:

We respectfully disagree with this comment. Silvicultural prescriptions and forest 

stand types proposed for harvest and fuels treatment, describe that the more fire 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-57

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

resistant tree species and sizes would be left in commercial thinning units, and by 

definition, the thinned stands would remain at full stocking levels. Information on 

fire resistance ratings for common conifers of the Blue Mountains is located in the 

Silviculture specialist’s report (project file). 

Stand data indicate that the majority of stands where thinning is proposed in this 

project area would be overstocked if an upper diameter limit of 15” was applied. This 

diameter limit would also prohibit the selection of species needed to meet the purpose 

and need of this proposed project. It would prevent silviculture prescriptions from 

creating diverse stands that are resilient to insect, disease, and fire disturbances. 

See also response to comment SC-61. 

SC-95 

p-61 

Comment: 

The EIS fails to adequately disclose and assess the harmful impacts of indiscriminate or 

difficult to control burning, whether through employing helicopters or other airborne 

methods or utilizing large-scale landscape burning practices to implement “controlled” 

burns. 

Response:

We respectfully disagree with this comment. Hand lighting (“broadcast burning”) is 

not indiscriminate. Individuals are given direction concerning how and where to 

place fire on the landscape. Aerial ignition is more random in its application of fire 

across the landscape. While it is possible that downed logs or other features may be 

impacted by this technique, fuel conditions on the ground actually determine what 

will and will not be consumed or affected. 

Effects of burning are disclosed for each affected resource in the FEIS, Chapter 3. 

SC-96 

p-61 

Comment: 

the EIS fails to develop reasonable seasonal burning restrictions (such as no or restricted 

spring burning), ecologically necessary burn area buffers, and/or precautions to protect 

eotropical and native nesting birds, rare plants, and other ecological resource concerns. 

Response:

We respectfully disagree with this comment. The EIS includes design features (FEIS 

Chapter 2, Table 2-6) which apply to all proposed activities, including burning. There 

are seasonal restrictions in elk winter range, buffers for unique wildlife habitats, and 

protection measures for raptor nest sites. In addition there is a design feature specific 

to burning which is intended to protect large trees and snags. The EIS acknowledges 

that burning might temporarily reduce bird habitat and disrupt ground nesting birds 

on a very small scale (FEIS, Chapter 3, pp. 3-115 to 3-116). Most migratory birds 

nest in May, June. Landscape burning would take place prior to the nesting period or 

would occur in the fall of the year. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-58

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-97 

p-61 

Comment: 

The EIS fails to accurately disclose the harmful ecological impacts of its so-called 

“temporary” new road construction. The EIS fails to adequately address the excessive 

harmful extent of roads in the area already. 

The project failed to sufficiently address removing excessive and resource damaging roads 

throughout the area, bringing project road density to within scientific recommendations for 

wildlife and environmental viability, as well as LRMP standards.

Response:

We respectfully disagree with this comment. See FEIS, Chapter 3 for effects to 

affected resources from proposed actions, including the construction of new 

temporary roads, and Findings of Consistency located at the end of each resource 

analysis section. 

Also see response to comments SC-5, SC-40, and SC-41. 

Reducing open road density was not a purpose and need of the Cobbler II Timber 

Sale and Fuels Reduction Project; therefore road closures were not considered under 

this project (FEIS, Chapter 1, pp. 1-4 to 1-5). 

SC-98 

p-61-62 

Comment: 

The project failed to sufficiently disclose if LRMP road density standards comport with 

recent scientific recommendations related to wildlife road density thresholds for the area’s 

species of concern, or whether these need adjustment to incorporate relevant new research. 

In particular, as wolves are a listed species known to be returning to the area, and as road 

density levels severely impact their territorial and survival viability, planning to construct 

additional roads and significantly reduce hiding cover is in direct contravention to Oregon 

State wolf plan recovery objectives. This issue was not adequately addressed within the 

EIS. 

Response:

We respectfully disagree with this comment. The open road density is quite low and 

within Forest Plan standards as disclosed in the FEIS, Chapter 3, pp. 3-93 to 3-94. 

Road densities described in the LRMP (two miles per square mile) are a desired 

future condition over the entire forest. Adjusting the desired future condition in the 

forest plan was not a purpose and need of this project. 

Proposed activities would have no direct or indirect impacts to gray wolf because no 

denning or rendezvous sites are known within the project planning area. If such 

areas are identified prior to or during project activities, steps would be taken to limit 

disturbance. The open road density in the project planning area would remain low, 

and prey species should remain abundant. Human-caused mortality of wolves should 

not increase due to implementation of this project. Wolves are highly adaptable to 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-59

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

their environment and would likely avoid areas of human activity. All contractors are 

made aware that it is illegal to kill a wolf (FEIS, Chapter 3, pp. 3-106 to 3-108). 

Also see response to comments SC-53 and SC-97. 

SC-99 

p-61-62 

Comment: 

 the EIS failed to adequately address the full range of harmful impacts from project 

implementation road use, and failed to ensure project action provisions can effectively 

prevent adverse impacts to the area’s aquatic systems, wildlife species, and other natural 

resource concerns from project design, road construction, maintenance, duration of 

implementation, and road use. 

Response:

See response to comments SC-82, SC-92, SC-96 and SC-98. 

SC-100 

p-62 

Comment: 

The EIS failed to provide action alternatives that effectively begin recovery of the area’s 

waterways that are 303(d) listed. The project as planned will further adversely impact these 

water systems. Analysis should have included action plans to effectively begin to restore 

these and other impaired waterways. 

Response:

We respectfully disagree with this comment. No streams in the Cobbler II project 

planning area are 303d listed (FEIS, Chapter 3, p. 3-15). Project design criteria 

(FEIS, Chapter 2, Table 2-6) and site-specific Best Management Practices (FEIS, 

Appendix D) would limit sedimentation from activities and PACFISH RHCAs would 

prevent sedimentation from reaching waterways. Improvement of road drainage 

would have short term sediment effects to Elbow Creek leading to long term 

reduction in sedimentation. No degradation of water systems would occur (FEIS, 

Chapter 3, pp. 3-16 to 3-23). 

SC-101 

p-62 

Comment: 

The EIS for this project again fails to accurately disclose or adequately address the 

scientific research and controversy regarding so-called “fuels reduction” thinning-logging, 

especially that which clearly recommends against the type of logging planned for the 

Cobbler “II” project 

Response:

The idea that there is a “controversy” is a matter of opinion. See response to 

comment SC-75. The publication cited in this response precisely describes the 

benefits as well as costs of thinning and surface fuel reduction aimed at reducing the 

intensity and burn severity of potential wildfires. 

See Also: 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-60

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Keyes, C.R., O’Hara, K.L., 2002. Quantifying stand targets for silvicultural 

prevention of crown fires. West. J. Appl. Forest 17, 101-109. 

Agee, J.K., Skinner, C.N., 2005. Basic principles of forest fuel reduction treatments. 

Forest Ecology and Management Volume 211: 83-96. 

Van Wagner, C.C. 1977. Conditions for the start and spread of crown fire. Canadian 

Journal of Forest Research. 7:23-24. 

Youngblood, A., et al. 2008 Changes in fuelbed characteristics and resulting fire 

potentials after fuel reduction treatments in dry forests of the Blue mountains, 

northeastern Oregon, Forest Ecol. Manage. 

SC-102 

p-63 

Comment: 

the current planned logging would exacerbate ecological harms caused by past and recent 

management, expanding these into previously unlogged and unroaded areas; further 

harming area forest integrity, increasing fire risk, and degrading wildlife and aquatic 

habitat while heightening the potential for increased spread and introduction of invasive 

exotic plants. 

Response: 

Direct, indirect, and cumulative effects are disclosed in Chapter 3 of the FEIS for 

wildlife, aquatic species and invasive plants. 

SC-103 

p-63 

Comment: 

The basal area and SDI formulations employed by the agency to base their thinning 

marking have already been shown in previous field trips to similar area forests to be highly 

erroneous (as in field trips to the Heppner District Umatilla’s Rimrock and Sunflower 

Bacon Project areas, the Ochoco’s Spears and East Maury areas, and a number of similarly 

premised logging projects on the Deschutes as well). Similar to prior regional projects the 

Forest Service once again has failed to comply with NEPA’s site-specific and scientific 

accuracy, analysis, and disclosure requirements. 

Response:

See response to comment SC-9. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-61

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-104 

p-63 

Comment: 

The faulty analysis and scientifically insupportable logging alternatives presented 

in the EIS violate the requirements of the NEPA. The project if implemented would violate 

the ESA and CWA due to adverse direct and cumulative impacts to salmonid species 

populations and habitat, as well as ESA and/or NFMA violations resulting from adverse 

harms to wolves, lynx, wolverine, marten, goshawk, neotropical migrant birds, eagles, 

other raptors, owls (including great gray, pygmy and/or flammulated owls), cavity 

excavators and nesters, and other wildlife and avian species of concern. 

Response:

We respectfully disagree with this comment. The purpose and need for treating this 

area at this time is shown in the FEIS Chapter 1 (pp. 1-4 to 1-5). The alternatives are 

described in Chapter 2. The description of each alternative includes a discussion of 

the objectives of the alternative and of the treatment methods being proposed in the 

alternative and designed features that are incorporated (FEIS, Chapter 2, pp. 2-9 to 

2-35). 

Chapter 3 of the FEIS includes an analysis of the effects of the no action alternative 

and the two action alternatives for each resource listed above in your comment (pp. 3-

14 to 3-15 and 3-22; pp. 3-23 to 3-43 and pp. 3-87 to 3-117). The analysis in Chapter 3 

is supported by scientific literature and reports that are referenced throughout this 

documentation of the analysis (FEIS, Literature Citations). The logging proposed in 

the alternatives is scientifically supportable and does meet the requirements of the 

NEPA. 

Consultation will be completed prior to signing a decision. Agreement of findings 

includes Chinook Salmon Essential Fish Habitat (EFH), which satisfies requirements 

under the Mangnuson-Stevens Fishery Conservation and Management Act. 

Also see response to comments SC-50 and SC-97 above. 

SC-105 

p-63-64 

Comment: 

NEPA requires scientific accuracy and professional expertise in agency projects. The 

disparate inconsistent analysis, methodology, and focused awareness displayed by the 

Forests Service across the region on its many varied approaches to “fuels reduction” 

projects evidences a systemic failure to incorporate the best available science and 

ecologically effective methods consistently in its project proposals and decisions. 

Response: 

This comment is not site-specifically addressed to the Cobbler II project but is a 

general statement made by the commenter. 

The best applicable available science and professional expertise was used in planning 

and analyzing the Cobbler II project (project file, specialist reports).
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-62

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-106 

p-64 

Comment: 

Steep slopes above 20° should not have any medium or greater diameter trees removed 

(trees >14”). If thinning is needed to meet ecological objectives in sloped and steep areas, 

felled trees of medium and greater diameter should be left in place to help provide for longterm slope stability as well as wildlife habitat and soil nutrients. There should be no surface 

disturbing skidding or yarding of trees >14” diameter across slopes greater than 20°. Trees 

of smaller diameter, in dense young stands on these slopes likely would have less 

detrimental ground disturbing impact, as their weight and bole size are less significant. 

Even still, contrary to EIS provisions, care should be mandated in removing smaller trees. 

Where fuel loads and controlled burn plans permit, marked trees as possible should be 

felled and left in place to assist in holding slopes or burned, with only those in strategically 

appropriate locations within frequent low severity fire PAGs in excess of acceptable fuel 

loads removed from slopes. The EIS fails to disclose scientific research addressing these 

issues, fail to disclose the actual impacts of similarly premised completed logging-thinning 

projects, and fail to incorporate reasonable and effective protective provisions, other than 

limited loosely defined and largely ineffective “Best Management Practices (BMPs). 

Response:

Yarding systems are designated depending on slope and tree size among other 

considerations. Aerial systems (with at least one-end suspension ) are typically 

designated on sustained slopes above about 35% (FEIS, Chapter 2, Table 2-6, pp. 2-24 

to 2-28). Size of individual trees is less of factor in soil disturbance than size and 

weight of the bundles of trees being yarded in each turn. BMPs have been shown to 

be highly effective at mitigating, limiting or eliminating potential soil and water 

quality adverse impacts (see FEIS, Appendix D for site-specific BMPs). 

SC-107 

p-64 

Comment: 

The EIS failed to identify and reduce sedimentation sources, failed to retain existing 

riparian vegetation and plant additional riparian shading vegetation (especially within 

upland seasonal tributaries), failed to stabilize slopes above salmonid streams, and failed to 

provide for the restoration as possible of hydrological flow patterns and levels, and 

improving stream bed cobble habitat for aquatic species, among other priority restoration 

needs the EIS again failed to incorporate or sufficiently and objectively address. 

Response:

We respectfully disagree with this comment. Road related sedimentation was 

identified (FEIS, Chapter 3, p. 3-13) and plans to remedy road problems on the 

proposed sale haul routes have been developed (FEIS, Chapter 2, pp. 2-19 to 2-20). 

Riparian vegetation will be protected by PACFISH implementation and other design 

criteria (FEIS, Chapter 2, Table 2-6).

SC-108 

p-64 

Comment: 

The EIS failed to sufficiently address the harmful impacts of the planned burning of large 

slash piles – especially if economic trends do not allow the removal of logging generated 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-63

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

slash. The EIS also failed to adequately address the increased fire risk to the area from 

thinning and logging slash and debris left in the forest post-project, or to provide for a 

reasonable removal timeline that ensures such slash is addressed within the short timeline 

this project would have limited affect on reducing fuels and fire risk. Without firm removal 

timeline provisions, especially given the current limitations of wood fiber economics, the 

project will likely significantly increase the risk of severe fire in the area far longer than the 

limited ten year period where – within frequent fire PAGs only – the project may otherwise 

have limited fuel and fire risk reduction benefit. 

Response:

We respectfully disagree with this comment. Burning of large slash piles will often 

increase the area of soils that are severely burned according to Forest Plan criteria. 

Severe burn effects from the burning of large slash piles is included in Detrimental 

Soil Condition (DSC) analysis and the estimation of the percentage of activity area 

that would be in DSC (see FEIS Chapter 3, pp. 3-6 to 3-10 and Appendix E) . 

See FEIS, Chapter 2, pp. 2-16 to 2-19, regarding the treatment of activity generated 

fuels. When feasible (within weather and contractor availability constraints) activity 

fuels are treated within two years of activity.

SC-109 

p-66 

Comment: 

The overall cumulative impacts from the extensive past and ongoing logging operations 

across the District have not been adequately addressed, especially in conjunction with 

recently completed and ongoing logging projects, in conjunction with the planned Cobbler 

II Project 

Response:

See response to comments SC-50, and SC-104. 

SC-110 

p-66 

Comment: NEPA

The limited and repetitious Environmental Assessment-styled “EIS” for the Cobbler II 

Project fails to sufficiently disclose or analyze the full extent of cumulative impacts to 

contiguous forest areas, including salmonid waterways and listed species habitat, from the 

implementation of the District’s other recent past timber sales. 

Response:

See response to comments SC-50, and SC-104. 

SC-111 

p-67 

Comment: 

The Forest Service narrows their objectives and analysis in the EIS, failing to sufficiently 

disclose and address extensive cumulative impacts issues from past and recent projects, 

failing to accurately disclose or address the harmful logging impacts of this proposed 

project, and failing to effectively address a range of restoration actions that encourage and 

restore forest resiliency and old growth forest habitat 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-64

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

See response to comments SC-50, and SC-104. 

SC-112 

p-68 

Comment:

The EIS again fails to reasonably and objectively address the scientific controversy 

surrounding the developed alternatives and their lack of scientific support. The EIS 

similarly fails to provide the decision-maker and the public with a comparative assessment 

of supportive scientific research for the undeveloped alternatives and a range of other 

feasible alternatives which were never considered at all. 

Response:

See response to comments SC-3, SC-4, SC-23, and SC-46. 

SC-113 

p-68 

Comment: 

the agency failed to consider an alternative based upon the original Eastside Screens 

scientific community recommendations and based upon wildlife indicator and species of 

concern habitat needs. Such an alternative would have limited – with minor exceptions – 

logging-thinning actions to trees less than 14”, 15”, or 16” in diameter. Instead, the EIS 

notes a possible alternative employing a 9” diameter limit, but dismisses this by stating that 

this would not reduce stand density levels to HRV, as much of the stands have trees above 

9” dbh contributing to density excess. However, the EIS fails to provide a table to 

demonstrate at above what mean diameter level stand density evidences being within or 

near HRV levels. Surveys of the project area indicate that historic stand composition in 

much of the project follows typical dense moist forest complex structural conditions. 

Where there exists site-specific evidence of drier more open forest conditions, surveys 

generally indicate that trees above 12” to 16” do not contribute to excess stand density. 

Instead, excess density – where ecologically applicable to area mixed conifer and moist 

forest PAGs at all – is largely comprised of trees from seedling to 12”-14” diameter. As 

such, a scientifically supported reasonable alternative would have been to implement a 

maximum 14” to at most 16” diameter limit in appropriate PAG areas as a scientifically 

feasible developed alternative for consideration. By sabotaging such an alternative utilizing 

the mean diameter of 9” instead of 14” or 16” the agency fails to base their developed 

alternatives on the accurate site-specific conditions of the area, and the recommendations of 

credible scientific research. 

Response:

The actual approved Eastside Screens (Decision signed 6/12/95) have been 

incorporated into the Umatilla Forest Plan (Amendment #11). This project was 

designed to meet Forest Plan standards and guides, desired conditions, and objectives 

for the project. See FEIS, Appendix F for how this project is consistent with the 

Eastside Screens. 

Silvicultural prescriptions and forest stand types proposed for harvest and fuels 

treatment, describe that the more fire resistant tree species and sizes would be left in 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-65

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

commercial thinning units, and by definition, the thinned stands would remain at full 

stocking levels. Information on fire resistance ratings for common conifers of the 

Blue Mountains is located in the Silviculture specialist’s report (project file). 

In response to your comment, an alternative to use non-commercial thinning of small 

diameter trees rather than commercial harvest was considered, but eliminated from 

detailed study for reasons listed in the FEIS, Chapter 2, pp. 2-36 to 2-39. 

SC-114 

p-69 

Comment: 

In this case, the Forest Service has drawn its purpose and need too narrowly, apparently in 

an attempt to limit the alternatives that will serve the purpose. As a result of the narrow 

purpose and need, the Forest Service undermines the NEPA process and does not give 

serious consideration to the no action alternative, or to the development of forest plan 

legally-compliant and scientifically-based restoration action alternatives. 

Response:

See response to comments SC-3, SC-4, SC-23, and SC-46. 

SC-115 

p-69 

Comment: 

the EIS again ignores and/or fails to objectively disclose and address the majority of 

credible peer-reviewed scientific research studies that clearly indicate the project’s actions 

are incapable of achieving the stated ecological purposes quoted above. 

Response:

See response to comments SC-19 and SC-46. 

SC-116 

p-70 

Comment: 

It is interesting that within the Cobbler II Project forests, the only areas the EIS 

acknowledges as ponderosa pine dominant, frequent low severity fire forest PAGs – where 

there exist some limited scientific support for ecologically careful small diameter thinning 

and burning - are found only within the Grande Ronde IRA. As these areas are not 

allowable for commercial logging due to their inventoried roadless status, the project 

instead is located entirely within scientifically inappropriate mixed conifer, mixed fire 

severity, mid and high elevation forests – where there exists no credible support for the 

logging actions planned. The EIS violates the NEPA by again failing to adequately disclose 

and address this reality, and instead obfuscating and misrepresenting the actual conditions 

of the area’s PAG forests, and scientific research conclusions. 

Response:

See response to comment SC-8. 

SC-117 

p-73 

Comment: 

The EIS however, in clear violation of the requirements of the NEPA, chose to evade and 

obfuscate substantive issues of scientific controversy, failing to objectively disclose or 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-66

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

address scientific research that contradicts or recommends against the project’s actions. 

Agency dismissal of scientifically based concerns and recommendations, and the EIS’s 

largely mere inference of scientific research reports, fails to meet the requirements of the 

NEPA to meaningfully and reasonably incorporate, disclose, and address applicable 

science within the EIS, including the development of a range of proposed actions. 

Response:

Resource specialists incorporated scientific research in their environmental effects 

analysis (FEIS, Chapter 3 and Literature Citations). The Forest Service reviewed 

exhibits presented by the public in their comments (see FEIS, Appendix G, pp. G-8 to 

G-118 and pp. G-178 to G-192 and Appendix I, pp. I-103 to 3-132. 

See response to comment SC-23.

SC-118 

p-73 

Comment: 

Cobbler II Project violates NEPA federal environmental policy law regarding the USFS 

failure to disclose and address pertinent science specific to the forest types of the project 

area, their dependent wildlife species habitat needs, salmonid aquatic systems, and climate 

change and carbon sequestration of forests 

Response:

Pertinent science was disclosed and addressed in the following pages of the FEIS: 

Fisheries pp. 3-23 to 3-43 and in Literature Citations pp. L-2to L-4; Vegetation pp. 3-

43 to 3-62 and in Literature Citations pp. L-7 to L-13; Wildlife pp. 3-87 to 3-117 and 

in Literature Citations pp. L-4 to L-7, and Climate Change and Carbon Analysis pp. 

4-155 to 3-163 and in Literature Citations pp. L-17 to L-22 and Appendix J. 

SC-119 

p-73 

Comment: 

The agency fails to develop a range of reasonable alternatives based upon credible 

scientific research that is not in accord with the myopic logging-permitting research cited 

and/or misquoted and misrepresented in the EIS, thus failing to provide the decision-maker 

and the public with a full range of reasonable scientifically supported alternatives, or even 

the awareness that the planned actions are scientifically controversial and largely 

scientifically insupportable at best. 

Response:

See response to comments SC-3, SC-4, SC-23, and SC-46. 

SC-120 

p-74 

Comment: 

The analysis within the EIS failed to adequately disclose which conclusions of what studies 

were incorporated in developing its proposed actions, and failed to also objectively disclose 

which studies recommend against such actions, providing the public and decision-maker 

with NEPA’s requisite scientifically and meaningfully informed analysis on which to 

weigh the impacts, benefits and harms, and efficacy or lack thereof, of proposed agency 

actions. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-67

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

The purpose and need for action identified in the FEIS (Chapter 1, pp. 1-4 to 1-5) was 

based upon current fuel and vegetative trends that are outside of their historical 

range of variability in Cobbler II project planning area, and by contrasting the 

existing condition with the desired future condition identified in the Forest Plan there 

is a need to: 

• Reduce stand densities in upland forest to recommended stocking levels to 

increase resiliency of stands to disturbance from insects, disease, or 

uncharacteristic wildland fire intensity. 

• Reduce competition from late seral ingrowth in stands currently dominated 

by early seral species and/or large trees in order to retain these more resilient 

trees. 

• Move forest stand structural conditions toward the historical range of 

variability 

• Modify the intensity and resulting fire behavior along the rim of the Grande 

Ronde and along Forest Road (FR) 62 for safe and effective fire suppression 

actions. 

• Return fire to Grande Ronde River canyon to maintain the character of a 

frequent fire regime, particularly in grasslands and shrubs. 

• Reduce ladder fuels to lower the risk of fire spread into the upper canopy. 

• Reduce ground fuel that would contribute to uncharacteristic wildfire 

intensity and resource damage. 

• Reduce risk of personal injury by removing danger trees along trailheads and 

haul routes used for project activities. 

The purpose and need identified follows CEQ guidance 40 CFR 1502.13 which reads 

the statement shall briefly specify the underlying purpose and need to which the agency 

is responding in proposing the alternatives including the proposed action. 

See FEIS, Chapter 2, Tables 2-10, 2-11, and 2-12 pp. 2-40 to 2-47 for a comparison of 

alternatives considered in detail by activity, purpose and need and issues analyzed for 

environmental effects. 

SC-121 

p.74 

Comment: 

Despite NEPA’s legal requirements the EIS contains no action alternatives that are 

developed based upon the preponderance of credible peer reviewed ecological science 

Response:

See response to comments SC-119 and SC-120.

SC-122 

p-74 

Comment: 

the EIS fails to adequately disclose pertinent scientific research on affected native species. 

The EIS fails to adequately inform the public or decision-maker of scientific 

recommendations against such logging, overall wildlife viability recovery objectives, 

cumulative impacts issues, and the accurate extent of the likely harmful consequences of its 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-68

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

selected actions to species of concern that are or may be within the greater project area. 

Response:

We respectfully disagree with this comment. The affected environment and 

environmental effects (direct/indirect and cumulative) to aquatic, plant and wildlife 

species are disclosed in the Fish, Plant, and Wildlife sections in Chapter 3 of the FEIS 

along with supporting references to scientific literature (Literature Citations pp. L-2 

to L-7). 

SC-123 

p-75 

Comment: 

The Forest Service fails to address cumulative impacts properly, and fails to provide any 

science showing that destroying viable mature and old mixed conifer and pine forest 

habitat in the present benefits the area’s many diverse forest species of concern in the 

future. Without protection today, the future viability of the area’s listed species and species 

of concern is absolutely uncertain. In light of the new scientific information revealing the 

importance of forest connectivity and evidencing population declines of numerous old and 

mature forest dependent species, the Forest Service makes a very risky move to further 

stress these populations in the present with this project’s planned logging. 

Response:

We respectfully disagree with this comment. Effects to old forest and many species 

associated with old forest are analyzed as a key issue in the FEIS, Chapter 3, pp. 3-87 

to 3-117. Proposed activities meet Forest Plan standards for these species and 

habitats (see Findings of Consistency Chapter 3, p. 3-117).

SC-124 

p-75 

Comment: 

Additionally, ongoing scientific research has confirmed that many old growth dependent 

species of concern continue to use even severely burned mature and old forest habitat, 

while other research concludes that many forest species of concern are deterred from 

utilizing forest habitat that has been degraded by commercial logging and thinning. 

Research concludes that logging extirpates and harms populations of goshawks, marten, 

lynx, eagles, osprey, wolverines, wolves, great gray and other owls, and many other species 

of concern, as well as populations of their prey species. The failure of the project EIS to 

disclose and address this pertinent information in its analysis deprives the public and the 

decision-maker of essential information critical to designing a reasonable project with a 

likelihood of accomplishing its purpose and need goals. 

Response:

See response to comments SC-82, SC-92, SC-96, and SC-122.

SC-125 

p-75-76 

Comment: 

The project is premised in large part on the perceived need to protect area forests and 

wildlife habitat from the effects of severe fire(s) (as well as unspecified levels of naturally 

occurring insects and disease). As such, it is extremely important that project analysis 

address scientific research that indicates affected species of concern are not extirpated from 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-69

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

forest habitat from fire – and comparatively assess scientific research that indicates these 

species are extirpated from forest habitat from commercial logging and thinning. The 

failure to include this analysis within the EIS, and the failure to include a restoration 

alternative based upon relevant scientific research violates the NEPA, precluding a legally 

acceptable decision. 

Response:

There is no claim in the EIS that fire causes extirpation of species of concern. The 

Fish, Plant and Wildlife sections in the FEIS, Chapter 3 disclose effects to affected 

species with implementation of any proposed activity for each alternative considered 

in detail. This includes TE& S species and MIS species. 

Alternative A can be considered a restoration alternative and was analyzed in detail. 

A non-commercial restoration alternative (FEIS Chapter 2, pp. 2-38 to 2-39) was an 

alternative also considered but eliminated from detailed study. 

See response to comment SC-124. 

SC-126 

p-76 

Comment: 

The EIS fails to present verifiable compelling evidence that the area’s forests are outside of 

the range of natural variability for insect, disease, and other natural pathogens and 

disturbances. 

Response:

This EIS is not addressing area forests; it is site-specifically addressing desired 

conditions in the Cobbler II project planning area. The purpose of and need for 

action in the Cobbler II project is to improve health, vigor, and resilience to fire, 

insects, and disease in upland forests that are outside their historical pre-fire 

suppression conditions for species composition (including hardwood species), 

structural diversity, stocking densities, and fuel loads (FEIS, Chapter 1, pp. 1-4 to 1-

5). 

Activities proposed in this project are to increase resiliency of stands to disturbance 

from insects, disease, or uncharacteristic wildland fire intensity. 

SC-127 

p-76 

Comment: 

The analysis fails to accurately evaluate the impacts of natural processes in comparison 

with the impacts of logging upon wildlife, forest ecological integrity, native vegetation, 

foundational soil communities, hydrology and moisture retention, and aquatic systems and 

species. 

Response:

We respectfully disagree with this comment. Evaluation of impacts of natural 

processes in comparison with impacts of logging are disclosed in the effect’s analysis 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-70

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

of the no action alternative (Alternative A) as compared to the effect’s analysis of the 

action alternatives considered in detail (Alternatives B and C) throughout FEIS, 

Chapter 3. 

SC-128 

p-77 

Comment: 

the EIS fails to objectively, impartially, and accurately “disclose[s] the extent to which the 

impact of the proposed action is scientifically controversial,” regarding the Forest Service’s 

proposal to reduce fire risk by commercially thinning mature stands of mixed-conifer 

forest. 40 C.F.R. 1507.27(b)(4). 

Response:

We respectfully disagree with this comment. See response to comment SC-101.

SC-129 

p-77 

Comment: 

The EIS does not present any proof that mixed-conifer forests are at “uncharacteristically 

severe levels” with their fuel load. The Forest Service claims are largely based upon 

projected assumptions that fuels are outside their “desired condition,” so a large fire is 

expected. 

Response:

Wildfire is inevitable at some point in the future. Harvest and fuel treatments are 

designed to increase the probability of survival of large trees and early seral species 

after a wildfire by reducing the amounts of late seral species and small trees. 

SC-130 

p-78 

Comment: 

Based upon the recommendations of the best available science, and the site specific 

conditions in the project area, the mixed-conifer forests in the project timber sale area do 

not require logging or ‘fuels’ management, especially when the “treatment” will destroy 

important old and mature connective forest habitat for regional species of concern and ESA 

listed species. Fire is a natural and inevitable component in a functioning forest ecosystem, 

and the mixed-conifer forests in the project area are within their natural range of fire 

behavior. The Forest Service has not based its analysis to alter the natural fire regime of 

the mixed-conifer forests in the best available science. 

Response:

See response to comments SC-8 and SC-124. 

We are not altering the natural fire regime. Fire suppression being the biggest 

human intervention, the natural fire regime is altered. The project proposes to 

incorporate fire safe principles to return the area closer to what can be considered a 

natural fire regime in the context of fire size and severity (FEIS, Chapter 2, pp. 2-16 

to 2-21).

SC-131 

p-78-79 

Comment: 

Again, the range of developed alternatives considered in the Cobbler II EIS is inadequate, 

because the EIS never analyzes a restoration-only alternative, and fails to develop and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-71

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

analyze a full range of scientifically supported action alternatives. A restoration-only 

alternative is certainly a reasonable alternative to consider for this purported fuels and 

fire/disturbance risk reduction project, especially considering that the stated needs of the 

project are to: 

“to improve health, vigor, and resilience to fire, insects, and disease in upland 

forests that are outside their historical pre-fire suppression conditions for species 

composition (including hardwood species), structural diversity, stocking densities, and fuel 

loads. Additionally, there is a need to provide sawlogs and wood fiber products for 

utilization by regional and local industry.” 

Response:

A non-commercial restoration only alternative was considered (FEIS, Chapter 2, pp. 

2-38 to 2-39) along with six other alternatives considered but eliminated from detailed 

study. 

See response to comments SC-3, SC-4, SC-6, SC-13, and SC-125. 

SC-132 

p-79 

Comment: 

The Forest Service must at least fully consider and develop a reasonable range of 

alternatives that are capable of truly protecting important habitat without destroying it. 

NEPA requires the agency develop science based alternatives, including a restoration-only 

alternative, as well as a full range of scientifically varied action alternatives. As the project 

contains logging units within contiguous viable habitat for species of concern, immediately 

adjacent to or within old growth, roadless, and wilderness, logging within project units 

would degrade potential habitat for ESA listed and other imperiled species of concern, 

disrupting forest connectivity and available habitat. The EIS fails to adequately disclose 

and objectively address these significant issues, and instead plans to compound existent 

cumulative impacts habitat degradation with even more logging harms. 

Response:

See response to comments SC-82, SC-92, SC-96 and SC-131.

SC-133 

p-80 

Comment: 

The EIS claims that an alternative limiting actions to non-commercial thinning using a 

maximum diameter of 9” dbh trees and below would not sufficiently reduce the risk of fire 

and meet project goals. However, the agency failed to consider other reasonable alternative 

options, including limiting felling to trees ≤12, 14, or even 16” dbh (as called for by a 

range of scientific research addressing wildlife habitat needs of imperiled avian species in 

the region, and by other research addressing restoration, fire risk reduction, and resilience). 

Though our organizations stated this fact in our previous EIS scoping comments, and in our 

previous EA appeal and comments, the agency ignored this entirely in their new EIS for the 

project. The EIS fails to include sufficient information to support its scientifically 

insupportable and/or controversial conclusions, and fails to even acknowledge the 

existence of many other scientifically supported alternative options. Without fully 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-72

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

analyzing a restoration alternative, the Forest Service and the public will never know how 

the forest will be affected without commercial logging. Similarly, as the EIS failed to 

assess a range of alternatives capable of achieving ecological objectives, the public and the 

decision-maker have been deprived of more capable, scientifically supported, and 

ecologically protective alternative options. The Forest Service cannot make a fully 

informed decision legally acceptable decision without full analysis of a range of 

scientifically supported restoration alternatives 

Response:

We respectfully disagree with this comment. The purpose and need for treating this 

area at this time is shown in the FEIS (Chapter 1, pp. 1-4 to 1-5). The alternatives are 

described in Chapter 2. The description of each alternative includes a discussion of 

the objectives of the alternative and of the treatment methods being proposed in the 

alternative (Chapter 2, pp. 2-9 to 2-35). See Alternatives Considered but Eliminated 

from Detailed Study, an alternative to use non-commercial thinning of small diameter 

trees rather than commercial harvest was considered but eliminated from detailed 

study (Chapter 2, p. 2-38). 

Chapter 3 of the FEIS includes an analysis of the effects of the no action alternative 

and the three action alternatives. The analysis in Chapter 3 is supported by scientific 

literature and reports that are referenced throughout this documentation of the 

analysis (FEIS, Literature Citations). The logging proposed in the alternatives is 

scientifically supportable and does meet the requirements of the NEPA. 

This comment was also previously addressed in the FEIS, Appendix G, Letter 3, 

Comment 41, p. G-142. 

SC-134 

p-80 

Comment: 

The Forest Service failed to present any alternative that actually protects viable old and 

mature forest habitat, that protects essential forest connectivity, and that addresses 

cumulative impacts harms throughout the project area. 

Response:

Alternative C responds to this issue by reducing effects to old forest by about 50 

percent (FEIS, Chapter 3, p. 3-91). Alternative A the No Action alternative would 

also meet these criteria to some degree (FEIS, Chapter 3, p. 3-89). 

SC-135 

p-81 

Comment: 

The agency fails to disclose that regarding mixed conifer, mixed fire severity forests, a 

substantial body of credible established and recent scientific research recommends such a 

course. In particular, recommendations in such ecosystems call for limited management 

actions, focused primarily upon watershed restoration, removal of roads, regeneration of 

old logging cuts, removal of invasive exotic plants, curtailment of harmful grazing, and 

protecting all remaining mature and old forest trees, structure, and connectivity. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-73

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response: 

Scientific literature reviewed for this project did not recommend only this limited 

management (FEIS, Literature Citations and Appendix J). 

SC-136 

p-84 

Comment: 

Openings would be reforested by planting - except that while the EIS states that these areas 

“can be reforested within five years,” the EIS fails to make this mandatory, stating that 

such actions are dependent on the availability of as yet unknown funding. 

Response:

The finding that units proposed for regeneration harvest can be reforested within 5 

years is required (NFMA; 16 U.S.C. 1604). Units where lodgepole pine is the major 

species would be prescribed for natural regeneration (165 acres). The other 

regeneration units would be planted (175 acres) see FEIS, Chapter 2, p. 2-15 

Sale area improvements (SAI) include activities which follow timber harvest and are 

intended to improve resources within the project area. They are generally funded 

with Knutson-Vandenberg (KV) funds, which are generated from the sale of timber 

(see FEIS Chapter 2, pp. 2-35 to 2-36). Historically, funds for reforestation have been 

available. 

SC-137 

p-84 

Comment: 

The EIS also fails to disclose the acreage extent of previously logged areas that are still in 

need of re-planting, the success rate of past replanting, and the range of how many years 

may pass before an area has successfully been reforested. Importantly, the EIS fails to 

disclose how many years may pass post-logging before Cobbler II units are fully reforested 

and are again capable of providing habitat for the full range of interior forest dependent 

species that are now present in the proposed logging units. 

Response:

There are no previously logged units in the area that still need reforestation. Past 

reforestation successes indicate that the regeneration units would be reforested within 

5 years of harvest. Over the landscape, stands providing various types of habitat 

would be left according to Forest Plan standards and guides, including unharvested 

stands as well as some previously harvested stands which provide this habitat in the 

interim. Thinned stands would continue to provide forest habitat for some species 

(FEIS, Chapter 3, p. 3-110). In stands proposed for regeneration prescriptions, some 

mature trees would be left in the stands after harvest as shelterwood or seed trees 

(FEIS, Chapter 2, pp. 2-12 to 2-13). These residual trees would provide structure and 

large wood in future stands, which can provide habitat to wildlife before the entire 

stand is mature (Franklin et al. 2008). The regenerated stands could be considered 

mature forest in approximately 80 to 120 years. 

SC-138 

p-84 

Comment: 

the EIS fails to account for widespread past and recent cumulative logging impacts, and 

disclose the much higher percentage of viable mature and old forest habitat would be 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-74

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

logged in the greater planning area. As well, as noted above, and in comments submitted by 

Oregon Wild also, the actual percentage figure based on the agency’s own disclosures is 

11% of the total available habitat of this type. As such, the statistics cited are misleading 

and inaccurate, and fail the disclosure requirements of the NEPA. 

Response:

We respectfully disagree with this comment. The effects to old forest in the planning 

area are disclosed in the FEIS, Chapter 3. We are unable to respond specifically to 

your 11 percent comment, without source of information and definition of ‘greater 

planning area’. 

SC-139 

p-85 

Comment: 

The original EA stated: “The amendment is being proposed under the 2008 Forest Service 

planning regulations (36 CFR 219) which allows plan amendments to be made using the 

procedures from the 1982 planning regulations during the three-year transition period (36 

CFR 219.14(b)(2).” *Note, the EIS still doesn’t effectively address this issue, as the 2008 

agency regulations have been overturned by federal courts and are no longer legally 

acceptable. 

Response:

This plan amendment is being prepared under the 2000 rule as amended with 

transition wording at 36 CFR 219.35 that allows the use of the 1982 rule procedures. [ 

See 65 FR 67568, Nov. 9, 2000, as amended at 66 FR 1865, Jan. 10, 2001; 66 FR 27554, 

May 17, 2001; 67 FR 35434, May 20, 2002; 68 FR 53297, Sept. 10, 2003; 69 FR 58057, 

Sept. 29, 2004]. The 1982 rule and the 2000 rule as amended is available online at

http://www.fs.fed.us/emc/nfma/2000_planning_rule.html 

SC-140 

p-87 

Comment: 

As such, the EIS egregiously fails the clear requirements of the NEPA pertaining to a 

reasonable range of scientifically based alternative development and analysis 

Response:

In total ten (10) alternatives were considered for this project. The alternatives range 

from not implementing any proposed activity (FEIS, Chapter 2, p. 2-10) to an 

alternative designed to use a combination of treatments to increase ecosystem 

sustainability while providing sawlogs and wood fiber products affecting both the 

local and regional economy (FEIS, Chapter 2, pp. 2-10 to 2-24). Another alternative 

was designed to address the key issues of maintaining or improving elk habitat and 

old forest habitat and functional corridors (FEIS, Chapter 2, pp. 2-32 to 2-35). Other 

alternatives considered but eliminated from detailed study range from harvesting 

trees greater than 21 inches DBH. The Forest Service also responded to comments to 

review alternatives that would use variable density thinning and one that would treat 

small-diameter fuels in only ecologically appropriate forest locations, and lastly a noncommercial restoration only alternative was considered but eliminated from detailed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-75

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

study. Rationale as to why some alternatives were not considered in detail can be 

found in the FEIS, Chapter 2, pp. 2-36 to 2-39. 

See response to comments SC-3, SC-4, SC-23, SC-46, SC-131. 

SC-141 

p-88 

Comment: 

The project’s contrived purpose and need, similar logging action “alternatives,” analysis 

failures, selection of the action alternative that “maximizes” timber economics and results 

in the most widespread environmental harms, and failure to adequately disclose and 

address significant scientific controversy and contravention to the developed alternatives 

violates the most elemental requirements of the NEPA. 

Response:

See response to comments SC-3, SC-4, SC-23, SC-46, and SC-140. 

SC-142 

p-89 

Comment: 

The EIS ignores core NEPA requirements for an adequate range of alternatives by the 

improper use of purpose/need to limit alternatives (see above). In this instance, by too 

narrowly defining the purpose and need for this project, in a manner that is at odds with 

credible scientific recommendations; and the NFMA, CWA, MBTA, ESA, and LRMP

ecological objectives and policies; the agency illegally constrains management direction 

prior to NEPA analysis and disclosure, and circumvents NEPA requirements for objective 

evaluation of all reasonable alternatives before decisions are made 

Response:

See response to comments SC-119, SC-120, SC-140 and SC-141. 

Findings of consistency with federal and state laws and Forest service regulations and 

policy and Forest Plan are disclosed at the end of each section in Chapter 3 of the 

FEIS. In addition, consistency with other laws, rules, and regulations are located in 

Chapter 3, pp. 3-163 to 3-167. 

SC-143 

p-89 

Comment: 

In the EIS, the Forest Service indicates that it considered but dismissed a range of other 

action alternatives. The Forest Service dismisses these as if they are the only other 

alternatives. However, there are other scientifically sound alternatives and a significant 

range of credible pertinent scientific research that the EIS failed to disclose or assess in 

addressing and developing reasonable ecologically capable action alternatives. 

Response:

See response to comment SC-140 above. 

SC-144 

p-89 

Comment: 

The Forest Service has failed to comply with NEPA’s alternative development 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-76

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

requirements, has failed to adequately disclose or responsibly address and incorporate 

existent scientific controversy and research, and instead has prejudiced the EIS towards the 

selection of an ecologically unwarranted harmful logging alternative by arbitrarily and 

capriciously selectively limiting the disclosed science and developed alternatives to those 

which can be manipulated to meet the Umatilla National Forests portion of the USFS 

Pacific NW region timber target goals. 

Response:

See response to comment SC-140 above. 

SC-145 

p-90 

Comment: 

the Forest Service must consider an alternative in its analysis which consists of treating 

small-diameter fuels in only ecologically appropriate forest locations (lower elevation 

ponderosa pine dominant – frequent low intensity fire plant association group forests) to 

reduce fire risk – outside of designated and uninventoried ecological roadless areas and 

higher elevation mixed fire severity mixed conifer forests (which should be left to nature’s 

time proven and scientifically recommended processes) 

Response:

This suggested alternative was addressed in Alternatives Considered, But Eliminated 

From Detailed Study section of the Cobbler II FEIS, Chapter 2 p. 2-38. 

SC-146 

p-91 

Comment: 

Functioning watersheds, diverse wildlife, and healthy soil that will sustain large-diameter 

tree growth in the future provides significant ecological and economic benefits to the 

regional and local economies, including recreation, environmental quality, water quality, 

and recovering salmonid populations and watersystems over the long-term. However, the 

myopic focus on timber as the only viable economic reality violates NEPA’s mandates to 

meaningfully address economics issues and impacts as they relate to the proposed action. 

By placing economics within the purpose and need, the agency must thoroughly disclose 

and address this issue. Current economic downturns and significantly reduced societal need 

for wood products, coupled with an over-abundance of unsold supply and consequent mill 

shut downs evidence that the purpose and need inclusion of wood products within its 

economic objectives is unfounded. However, such economic analysis and disclosures are 

missing from this EIS despite the inclusion of economic objectives such as “saw logs” and 

“wood fiber products.” 

Response:

The economic analysis presented in the FEIS, Chapter 3 (pp. 3-152 to 3-155) is in 

accordance with the Forest Service manual and handbook guidance to complete a 

financial analysis for timber sales (FSH 2409.18). The economic analysis documented 

in the EIS identifies financial monetary measures for timber and the financial costs of 

removing the timber and economic benefits to the regional economy. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-77

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-147 

p-91 

Comment: 

Instead of developing misplaced logging alternatives that clearly are not needed by 

contemporary society, the EIS failed to reasonably address and develop a science based 

alternatives, such as: The Forest Service must consider a scientifically-sound restorationbased alternative that does not prioritize commercial logging above all other options. The 

Forest Service could focus this alternative on the removal of small-diameter flash fuels 

where ecologically appropriate, the restoration of area soils, the removal of invasive exotic 

plants, the reduction and prevention of grazing harms, the recovery of 303(d) listed and/or 

other impaired and degraded waterways, protection and recovery of salmonid species, ESA 

listed species, and species of concern habitat and populations, prevention of ORV harms, 

and the removal of unneeded roads and skid trails. 

Response:

See response to comments SC-120, SC-124, and SC-140. 

SC-148 

p-92 

Comment: 

The failure of the NEPA analysis to disclose the existence of Pacific Northwest Regional 

timber volume target quotas, and their expected local national forest and ranger district 

percentages, driving agency projects and influencing the development and selection of 

alternatives violates the clear disclosure requirements of the NEPA. The failure to disclose 

that decision-makers are influenced in their selection of an alternative by the expectation 

that their forest must meet its expected contribution to the region’s timber quotas violates 

the requirements of the NEPA. Issuing NEPA documents such as this one, wherein 

undisclosed quotas set the parameters limiting the development and focus of alternatives, 

and the decision-maker’s ability to modify a project, violates the NEPA, violates agency 

compliance with environmental policy laws, and violates agency accountability to the 

nation’s public. 

Response:

See response to comment SC-120 above. The proposed project is based on the 

purpose and need for action (Chapter 1, pp. 1-3 to 1-8). 

SC-149 

p-97 

Comment:

The Forest Service needs to withdraw the EIS and conduct new SEIS analysis that 

complies with the 1982 rules, as the 2008 rules have been vacated by federal court as 

legally noncompliant with the requirements of the NFMA. The EIS is nearly identical with 

the original EA, which was tiered to the 2008 rules, yet the EIS remains the same as the EA 

despite this significant NFMA regulations change. 

Response:

See response to comment SC-139.

SC-150 

p-97 

Comment: 

The Forest Service needs to supplement the NEPA analysis to document whether and how 

the project comports with the MIS requirements in the 1982 rule, and it needs to do so with 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-78

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

full public review and meaningful involvement 

Response:

Determinations made for MIS wildlife species are based on past and current known 

occurrences of these species, field reconnaissance, and habitat conditions. The known 

or likely presence of these species is disclosed in the FEIS, Chapter 3, pp. 3-91 to 3-

104. 

SC-151 

p-98 

Comment: 

The EIS fails to adequately address the projects detrimental impacts on wolves that may 

utilize the project area, as wolf populations are known to be returning to Oregon, and have 

been reported within the Umatilla National Forest’s northeastern Oregon Ranger Districts, 

including within the greater project area. A wolf pack – including two pups - reportedly has 

recently established territory in the greater Wenaha-Tucannon Wilderness and project 

vicinity. As the project location is directly betwixt the wilderness and the large Grande 

Ronde Inventoried Roadless Area, and as wolves are far ranging carnivores that depend 

upon large intact areas of forest and wildlands to survive and thrive, it is likely that the 

project area plays a critically important key role as contiguous connective habitat between 

the wilderness and the roadless area for wolves. Wolves prefer large roadless undeveloped 

forest areas and natural ecosystems such as found in the greater project area. Wolf presence 

in Eastern Oregon and the Umatilla NF has been recognizably increasing over the past few 

years, with reports of wolf sightings growing exponentially. The EIS’s lack of 

comprehensive disclosures and adequate analysis on growing wolf use and potential

adverse project impacts, and failure to protect undeveloped unroaded areas, forest 

connectivity, and cover from logging and road building harms violates the NEPA, NFMA, 

and the ESA, and is contrary to Oregon State’s wolf recovery plan objectives. Similarly, 

the EIS’s apparent contention that its land management activities are compatible with wolf 

protection and recovery is unsupported by fact. 

Response:

We respectfully disagree with this comment with your assessment. Wolves are 

extremely resilient, as evidenced by the remarkable wolf population expansion in 

Idaho. See pages 300-302 in Mech and Boitani, 2003 - Wolves: Behavior, Ecology, 

and Conservation. Effects to wolves are adequately disclosed in the FEIS, Chapter 3, 

pp. 3-106 to 3-109. An addendum to the Wildlife Report, dated August 26, 2010, also 

indicates that a 'no effect' determination is appropriate. 

See response to comments SC-53, and SC-98. 

SC-152 

p-99 

Comment: 

The USFS has an obligation to accurately assess the impacts of its project on lynx. 

Response:

Environmental effects to lynx are disclosed in the FEIS, Chapter 3, pp. 3-105 to 3-106 

and finding of consistency is disclosed in Chapter 3, pp. 3-117. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-79

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-153 

p-100 

Comment: 

The EIS failed to provide a thorough examination of how the project will impact both hares 

and squirrels, as well as other wildlife species which are potential lynx prey. Without 

complete analysis of how these prey species will be impacted, it is impossible to quantify 

and qualify the impacts to lynx. The EIS failed to adequately analyze the cumulative 

impacts of this project on lynx prey in association with other projects on the District, 

Forest, and surrounding lands. 

Response:

See response to comment SC-152. 

SC-154 

p-100 

Comment: 

It is clear that the Forest Service has not completed NEPA required accurate analysis and 

therefore is in violation of the LCAS, as well as the ESA and NFMA. 

Response:

See response to comment SC-152. 

SC-155 

p-100 

Comment: 

The EIS makes insufficient mention as to any site-specific to protocol recent surveys 

supporting the agency’s determinations, fails to adequately disclose surveys or survey 

protocol, methodology, areas or frequency. As such, the EIS planned logging actions, and 

inference of non-significance is arbitrary and capricious and therefore illegal. 

Response:

Effects to lynx are disclosed in the FEIS, Chapter 3, pp. 3-105 to 3-106. No lynx 

surveys have been conducted in this area, but the analysis of environmental effects 

assumes that lynx could be in the area. 

This analysis is a reasoned consideration of relevant issues and alternatives related to 

the identified purpose and need, which is grounded in the desired future conditions of 

the Umatilla Forest Plan. The proposal of this project and its analysis as documented 

in the EIS and the entirety of the project record was not arbitrary and capricious. 

SC-156 

p-101 

Comment: 

The EIS fails to adequately analyze how wolverine will be affected by the planned project. 

Because it is probable that the species utilizes the project area for some life cycle needs, the 

USFS is required to accurately address how the commercial logging and road building 

projects will affect those needs and the species itself. 

Response:

Environmental effects to wolverine are disclosed in the FEIS, Chapter 3, pp. 3-108 to 

3-110. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-80

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-157 

p-101 

Comment: 

Wolverine are already listed as “Sensitive” in Oregon by the Oregon Department of Fish 

and Wildlife, however the Forest Service fails to adequately address this within the EIS, or 

disclose any meaningful consultation with ODF&W regarding recovering and protecting 

wolverine and their habitat. These failures are in violation of the requirements of the 

NEPA, and in contravention to the necessary cooperative interagency efforts needed to 

begin the recovery of this species and its required habitat. 

Response:

See response to comment SC-156. 

SC-158 

p-101 

Comment: 

There is not sufficient analysis in the EIS of the effects of the proposed project on 

American marten in the planning area. The forests of the Umatilla including the Cobbler II 

Project area have historically provided marten habitat. It is likely that at least some of the 

greater project areas still provide marten habitat—both for denning and foraging, as well as 

dispersal and travel corridors, as recent scientific research confirms that old forest 

dependent wildlife species are well adapted to the cyclic natural disturbance changes in the 

region’s fire ecology forests ever changing mosaic patterns. Research has also documented 

that martens and other forest-dependent species are not adapted to logging and road 

disturbance however, and that these management actions can extirpate and harm marten 

populations and habitat. The EIS fails to adequately and responsibly address this issue. 

Response:

Environmental effects to marten are disclosed in the FEIS, Chapter 3, pp. 3-97 to 3-

98. 

SC-159 

p-101 

Comment: 

In this case, the Forest Service failed to accurately and adequately assess how the proposed 

timber sale(s) and road construction into mature and old forests, into connective habitat 

between roadless and wilderness, and in previously unroaded areas, will impact marten. 

The Umatilla NF clearly is not meeting the requirements of NEPA and NFMA as they 

apply to pine marten, and is precluded from any further action on the proposed project as a 

result. 

Response:

See response to comment SC-158. 

SC-160 

p-102 

Comment: 

The EIS violates the NEPA by their lack of meaningful and accurate analysis, and requisite 

meaningful scientific disclosures and conclusions regarding eagles. 

Response:

Environmental effects to eagles are disclosed in the FEIS, Chapter 3, pp. 3-108 to 3-

110.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-81

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-161 

p-102-103 

Comment: 

The EIS fails to adequately address impacts to this species such as how logging removal of 

forest canopy cover, and further fragmentation of the area’s forests, will affect adult and 

juvenile goshawks and other raptors, or other direct, indirect, or cumulative effects to 

goshawks and other raptor species. The EIS fails to adequately address impacts to 

Goshawk nesting areas, including sufficiently assessing historic nesting areas, within or 

adjacent to the proposed logging project. Similarly, the EIS fails to adequately address 

potential direct and cumulative impacts harms to existing raptor nests of other species in 

the area. 

However the EIS violates the NEPA by failing to adequately and accurately disclose or 

assess this pertinent information. As such and the agency fails to uphold its responsibility 

to address these issues thoroughly as required by both the NEPA and the NFMA. The EIS 

fails to address the cumulative impacts of the project along with past, present, and 

reasonably foreseeable future actions, in violation of NEPA, 40 C.F.R. § 1508.7. 

Response:

Environmental effects to goshawk are disclosed in the FEIS, Chapter 3, pp. 3-111 to 

3-12 and consistency with Eastside Screens can be found in Appendix F. Raptor nest 

area protections are provided in project design features (FEIS, Chapter 2, Table 2-6, 

p. 2-29).

SC-162 

p-103 

Comment: 

The failure of the project’s action alternatives, including the selected action, to protect 

goshawk habitat would further reduce potential nesting and foraging habitat and thus 

violate NFMA’s requirement to maintain viable populations of these and many other forest 

canopy-dependent species, 36 C.F.R. § 219.19. 

Response:

See response to comment SC-161. 

SC-163 

p-105 

Comment: 

The EIS for this planned project fails to accurately, objectively and adequately disclose the 

current population status and trends of native forest dependent Neotropical migrant and 

native avian species within the analysis area and adjacent forest. Compliance with both the 

NFMA and the MBTA requires that all alternatives presented within the EIS, including the 

selected alternative, must be capable of protecting forest habitat for these many native 

forest species, and of reversing any current downward population trends. Such a course of 

proactive protective action is also required by the ESA and the NEPA, Presidential and 

USFS directives, and the Migratory Bird treaty Act, as well as credible conservation 

science and ethical integrity. However, in violation of these legal and ethical requirements, 

the EIS presents action alternatives which would degrade habitat and further imperil 

neotropical and native avian species populations, resulting in both individual mortality to 

these species as well as irreparable habitat and population level harms. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-82

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

Affected environment and environmental effects to birds are disclosed in the FEIS, 

Chapter 3, pp. 3-113 to 3-116. A finding of consistency for birds can be found on p. 3-

117. 

SC-164 

p-106 

Comment: 

The EIS presents action alternatives which would degrade habitat and further imperil 

neotropical and native avian species populations, resulting in both individual mortality to 

these species as well as irreparable habitat and population level harms. The Cobbler II 

timber sale(s) would significantly impact migratory birds in violation of the Migratory Bird 

Treaty Act, 16 U.S.C. §§ 703—712 (1994) 

Response:

See response to comment SC-163. 

SC-165 

p-106 

Comment: 

The project logging units would irreparably fragment migratory bird habitat. Areas that 

were not logged would also be negatively impacted by generalist bird species favored by 

the environmental conditions created in highly fragmented logged forests 

Response:

See response to comment SC-163. 

SC-166 

p-106 

Comment: 

Other avian and predator species more adapted to open logging thinned forests would move 

into the project area, further adversely impacting interior mature and old forest dependent 

neotropical and migrant avian species. The impact these abundant and highly competitive 

bird species would have on sensitive bird species dependent on less fragmented forests 

should have been adequately disclosed and evaluated in the EIS. The adverse impacts that 

the project logging would have on migratory birds are supported by multiple scientific 

studies 

Response:

See response to comment SC-163. 

SC-167 

p-106 

Comment: 

Among the many avian species experiencing population declines due to Forest Service 

logging projects are: band-tailed pigeon, rufous hummingbird, olive-sided flycatcher, 

winter wren, song sparrow, golden-crowned kinglet, pine siskin, solitary vireo, willow 

flycatcher, tree swallow, red-eyed vireo, yellow warbler, yellow-breasted chat, and others 

as well. This information was not adequately addressed in the EIS despite the obvious 

direct adverse impacts to many migratory and native bird species from the removal of 

forest canopy cover and forest structural continuity which would occur with the

implementation of this project. Failure to sufficiently disclose and comprehensively 

analyze this pertinent, essential, scientific information violates provisions of the NEPA. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-83

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Implementation of this project would violate both NFMA and the Migratory Bird Treaty 

Act. 

Response:

See response to comment SC-163. 

SC-168 

p-107 

Comment: 

The EIS insufficiently addresses the project’s direct and cumulative harms to cavity 

excavator and nesting species habitat. Project impacts would detrimentally affect these 

species abundance and distribution in the project vicinity. 

Response:

Environmental effects to northern-three toed woodpecker, pileated woodpecker, and 

other cavity nesters (Lewis' woodpecker, white-headed woodpecker, northern flicker, 

hairy woodpecker, downy woodpecker, Williamson's sapsucker, red-naped sapsucker, 

black-capped, chestnut, and mountain chickadees, and the red-breasted, whitebreasted, and pygmy nuthatches) are disclosed in the FEIS, Chapter 3, pp. 3-98 to 3-

104. 

SC-169 

p-107 

Comment: 

Overall, there exists scientific concern that the Blue Mountains forests do not currently 

support viable populations of Pileated, Black-backed, White-headed, Three-toed, Lewis’ 

and other woodpeckers, Williamson’s sapsuckers, Pygmy and other nuthatches, and other 

woodpeckers and cavity excavators. The draft EIS fails to base its claims on substantive 

protocol surveys and fails to address relevant comprehensive scientific research on these 

and related species of concern, their habitat, and forest ecological functioning. The EIS 

fails to meet NEPA’s “harder look” analysis requirements and more effective level of 

compliance with NFMA’s population monitoring protocol. 

Response:

Monitoring of populations and habitat trends is more appropriate at the Forest or 

province level than at the scale and extent of the Cobbler II project. Formal 

population surveys were not conducted at the project level, but key areas were field 

checked for some species. Determinations made for MIS wildlife species are based on 

past and current, known occurrences of these species; field reconnaissance, and 

habitat conditions. 

Also see response to comment SC-168. 

SC-170 

p-108 

Comment: 

The EIS fails to acknowledge the overall rare status of the region’s remaining multi-storied 

and other LOS habitat comparative to HRV levels. Management focus and actions as 

planned, including extensive logging alteration of LOS forest structure, would result in 

greatly compounding already extensive adverse impacts to these and other species 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-84

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

populations and habitat. The implementation of the project as proposed would result in the 

irretrievable forest landscape degradation of rare essential LOS forest habitat, 

compounding such harms with an overall failure to provide for the necessary surveys and 

monitoring for these regional species of concern and MIS focal species in violation of the 

NFMA. 

Response:

We respectfully disagree with this comment. Effects to old forest and MIS species are 

disclosed in the FEIS, Chapter 3, pp. 3-87 to 3-91 and 3-93 to 3-104. Also see FEIS, 

Appendix F for the project’s consistency with the Eastside Screens amendment to the 

Forest Plan. 

See response to comment SC-124. 

SC-171 

p-108 

Comment: 

The proposed project fails to adequately address or fully disclose the likely adverse impacts 

to cavity excavator species of its proposed actions. Federal law requires that when wildlife 

and indicator species populations evidence downward trends, the agency must act in order 

to stop such declines. 

Response:

See response to comment SC-168. 

SC-172 

p-111 

Comment: 

Listed, proposed, and sensitive aquatic species have been confirmed in the Grande Ronde 

River, Meadow Creek, Elbow Creek, Squaw Creek, Alder Creek, Bear Creek, Wenaha 

River, and Cross Canyon Creek. The EA notes that fish occupancy has not been confirmed 

for Big Hole Canyon Creek, Swamp Creek, Elk Creek or Burnt Canyon Creek, but states 

that it is likely listed-fish use at least the lower portions of these streams as well. The EIS 

fails to sufficiently disclose why this information is unavailable or when it may become 

available in the future. The EIS also discloses a general lack of site-specific stream surveys 

within the project area, failing again to note why or when these may become available. 

Response:

Big Hole Canyon Creek, Elk Creek, and Burnt Canyon Creek are in the WenahaTucannon Wilderness. It is clear from visits to their headwaters areas and from 

existing maps and aerial photography that they are remote, tiny, high gradient 

streams and would not be expected to contain fish or suitable fish habitat except 

possibly for a few hundred feet near their mouths at the Wenaha or Grande Ronde 

rivers. In the case of Squaw Creek, several high waterfalls downstream prevent fish 

access upstream into the project area. These streams were therefore of much lower 

priority for fish and aquatic habitat inventory than larger streams with known fish 

occupancy or high probability of fish occupancy. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-85

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Regarding site-specific stream surveys, the fisheries section of the FEIS is thorough 

and clearly lists the streams surveyed including dates (Chapter 3, Tables 3-13, 3-15, 3-

16, 3-17, and 3-18) and evaluates the conditions of, and effects to, twelve different 

aquatic habitat and watershed parameters, based on present scientific knowledge of 

the needs of salmonid fishes. Regarding site-specific accuracy, there are ten tables in 

the Fisheries section in Chapter 3, most with multiple columns, with site-specific data 

regarding watershed and aquatic habitat conditions in the project area. The 

evaluation is probably as site-specific as it could possibly be.

SC-173 

p-112 

Comment: 

The “EIS” fails to adequately address or disclose issues of soil stability, displaced soil 

movement patterns, erosion channels and cumulative impacts issues, sedimentation, 

airborne sediments from logging activities, stream headwaters and reaches, peak flows, 

water quality recovery concerns and objectives, salmonid populations and spawning areas, 

and other concerns. Beyond a mere list of listed-species and species of concern, and 

unsubstantiated findings (that the project is not likely to contribute sediment or degrade 

water quality or adversely affect species, etc.), the project NEPA documents fail to disclose 

sufficient information and analysis to substantiate project action impact determinations, 

mitigation provisions, and claims. 

Response:

Soil stability was considered and not found to be of concern from proposed actions 

(FEIS, Chapter 3, p. 3-5). Cumulative effects analysis for the variety of concerns 

listed is summarized on pp. 3-9 to 3-10.

SC-174 

p-112 

Comment: 

The EIS again fails to disclose adequate substantive information regarding riparian 

associated wildlife and plants, and recent surveys for aquatic habitat conditions and/or 

species of concern that may be in, near, or downstream of the project areas. 

Response:

We respectfully disagree with this comment. The FEIS does disclose information and 

surveys along with dates of aquatic habitat conditions and aquatic species, (FEIS, 

Chapter 3, Tables 3-10, 3-11, 3-13, 3-15, 3-16, and 3-17). Additional information can 

be found in the Fisheries Report in the project file. 

SC-175 

p-112 

Comment: 

The EIS fails to adequately and accurately analyze whether the Cobbler II Project is 

consistent with the standards and guidelines of INFISH and PACFISH. The agency has 

failed to conduct, assess, and disclose the necessary to protocol aquatic system surveys 

within the affected project area watersystems to reach any conclusions on the actual and/or 

potential impacts of this project. 

Response:

We respectfully disagree with this comment. The FEIS repeatedly evaluates habitat 

conditions with reference to PACFISH Riparian Management Objectives (RMO’s) 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-86

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

and states clearly the protocol used for the surveys (for example, Chapter 3, pp. 3-28 

to 3-35). 

SC-176 

p-112-113 

Comment: 

The EIS fails to accurately disclose to protocol ongoing and/or recent surveys for these 

and/or other aquatic species in the affected watersheds, or to explain why this has not 

occurred and when these surveys may be done. 

The EIS fails to present convincing evidence that it may arrive at its conclusions of 

minimal to no impact to these species and their habitat from such a widespread logging, 

roading, and burning project, given the lack of area waterway surveys and any verifiable 

project location information pertaining to waterway status, habitat, and localized aquatic 

species presence and population trends. Absent this pertinent site-specific survey 

information, and in contravention to a wealth scientific research addressing the many 

known adverse impacts of logging and road building on salmonid species populations, 

habitat, and water system quality, the EIS plans an extensive harmful logging and road 

construction project. Despite significant scientific documentation that steelhead and bull 

trout are among the most critically sensitive imperiled fish species, the EIS concludes the 

project is not likely to result in significant or apparently even cumulative harms. The EIS 

fails to accurately disclose and address how the project will affect both short and long term 

bull trout, chinook salmon, steelhead, and redband trout recovery objectives in and

downstream of the project area. 

Response:

We respectfully disagree with this comment. The FEIS does disclose the protocol of 

the surveys (Chapter 3, pp. 3-28 to 3-35). 

Contrary to the above assertion, the waterways have been surveyed and this is 

documented in the FEIS (Chapter 3, Tables 3-13, 3-15, 3-16, and 3-17). 

Project location information pertinent to waterways, habitat, and species presence, is 

presented in the FEIS(Chapter 3, Tables 3-10, 3-11, 3-12, 3-13; and related maps 

located in the project file, Fisheries Report) and this information is used as a 

component of the evaluation of the project effects. 

Evaluation of population trends requires census data over many years. Although 

population trends for evolutionary significant units of fish have been evaluated, data 

to evaluate trends for small local populations is insufficient and will not be adequate 

for years to come. That information is not necessary to ensure that management 

projects do not harm fish or degrade their habitat. Project activities were evaluated 

for effects, habitat parameter by parameter (Chapter 3, pp. 3-35 through 3-43) and 

effects to fish are disclosed. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-87

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-177 

p-113 

Comment: 

The EIS fails to disclose the range of scientific controversy concerning logging and road 

building actions in salmonid waterway forests in violation of the NEPA. The project if 

implemented would likely violate the NEPA, NFMA, CWA, and ESA with respect to 

salmonid species and their habitat, and likely result in further significant incremental harm 

to these species 

Response:

There is really little scientific controversy regarding the potential for road building 

and logging to affect salmonids or their habitat. It is well established that logging and 

road building can produce adverse effects to salmonids and aquatic habitat. This 

situation is recognized in the FEIS, Chapter 2, Table 2-6 and Chapter 3, Table 3-14 

and pp. 3-36 to 3-37, and elsewhere throughout the document). The potential for 

Cobbler II timber harvest and road building activities to produce adverse effects is 

evaluated. The project is designed to prevent adverse effects from logging and road 

building. 

SC-178 

p-113 

Comment: 

The EIS relies on faulty models absent localized information. Use of the WEPP model to 

analyze soil erosion has serious limitations that are not fully disclosed in the EIS, such as: 

WEPP can only consider one “slope” at a time, and one “activity” at a time and does not 

adequately integrate multiple slopes and activities 

Response:

The WEPP model was not used in this analysis. No sediment models were used 

(FEIS, Chapter 3, pp. 3-10 to 3-23)

SC-179 

p-113 

Comment: 

Importantly, the EIS aquatics cumulative impacts analysis fails to disclose the total 

cumulative effects of past management activities, including recent and past fires, past 

postfire salvage logging, burning and other fuels reduction actions, timber sales, previously 

clear cut areas that are young planted stands, the reopening of closed roads, road 

maintenance, landings, pile burning, biomass removal, log hauling, livestock grazing, OHV 

use and growing impacts – including areas within the project that evidence resource 

degradation, etc. 

Response:

We respectfully disagree with this comment. Chapter 3 of the FEIS does disclose 

cumulative impacts of all relevant reasonably foreseeable activities, within the 

hydrology section (pp. 3-16 to 3-23) and within the fisheries section (pp. 3-35 to 3-43) 

of the document (see CEQ Memorandum to heads of Federal Agencies, dated June 24, 

2005 regarding analysis of cumulative effects). 

SC-180 

p-114 

Comment: 

 In its analysis of sediment delivery, water quality, and future large wood input the EIS 

failed to adequately consider and disclose steepness of slope issues, which has a direct 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-88

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

bearing on the inevitable movement of soil and wood toward streams. 

In its analysis of sediment delivery and water quality, the EIS failed to consider the fact 

the RHCA buffers may be compromised by fires, ORV use, livestock grazing, and future 

projects, or disclose and address areas where there are existent cumulative impacts within 

these buffers. 

In its analysis of sediment delivery and water quality, the EIS failed to consider the fact 

that the removal of trees and future downed logs from upslope areas will reduce the 

landscape capacity for sediment storage. Standing trees and medium to large logs on the 

forest floor act as sediment traps, but if they are removed that function is eliminated. 

Response:

PACFISH RHCAs will not be entered for tree harvest or removal. RHCA widths are 

adequate to provide large wood inputs to the stream network and to prevent 

sedimentation from activities controlled by design criteria and BMPs (see FEIS, 

Chapter 2, Table 2-6 and Appendix D). 

SC-181 

p-114 

Comment:

The EIS failed to address cumulative impacts from livestock grazing or to disclose 

alternative provisions for the removal of livestock from logged and burned areas for a 

minimum of five or more years to allow the areas to recover post project. 

Response:

Environmental effects from livestock grazing are disclosed in the FEIS, Chapter 3, 

pp. 3-9, 3-20, 3-41, 3-59, 3-75, 3-83, 3-92, 3-96, 3-98, 3-110, 3-113, and 3-116. 

Cobbler II project planning area has not been burned so there were no provisions for 

removal of livestock. 

SC-182 

p-114 

Comment: 

The EIS analysis of large wood and sediment failed to consider the impacts of removing 

hundreds of hazard trees from miles of haul roads. Since the project allows removal of 

large logs that are felled across roads or outside RHCA boundaries, fallers are motivated to 

fall hazard RHCA trees toward the “money spots” (roads and upslope away from RHCAs) 

and away from streams where they would naturally fall and do the most good. By failing to 

address the incentive to log RHCAs inconsistent with the RMOs the analysis 

underestimated project impacts. 

Response:

Danger trees may be felled but not removed from RHCAs (FEIS, Chapter p. 2-20). 

Effects to water quality from danger tree felling inside RHCAs would be negligible 

(FEIS, Chapter 3, p. 3-18).

SC-183 

p-114 

Comment: 

The analysis failed to adequately disclose the full effects of logging and how it will 

degrade unroaded areas, mature and old forests, and aquatic systems. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-89

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

We respectfully disagree with this comment. Direct, indirect, and cumulative effects 

of proposed activities to the resources mentioned above are disclosed in Chapter 3 of 

the FEIS. 

SC-184 

p-114 

Comment: 

With respect to water quality and salmonid populations and habitat, the EIS alternatives, 

analysis, and conclusions fail the NEPA’s high quality science, reasonableness, cumulative 

impacts, and site-specific accuracy requirements, and as such must be withdrawn. 

Response:

We respectfully disagree with this comment. Water quality effects would be 

negligible due to design criteria and BMP implementation (FEIS, Chapter 2, Table 2-

6 and Appendix D). BMP monitoring has shown very high rates of implementation 

and effectiveness in preventing or mitigating soil exposure and prevention of erosion 

and sedimentation (FEIS, Chapter 3, p. 3-23). Site specific evaluation has been 

provided (FEIS Chapter 3, pp. 3-10 to 3-23) and cumulative effects have been

discussed.

The fisheries section of the FEIS is thorough and evaluates the conditions of, and 

effects to, twelve different aquatic habitat and watershed parameters, based on 

present scientific knowledge of the needs of salmonid fishes (FEIS, Chapter 3, pp. 3-23 

to 3-43). Regarding site-specific accuracy, there are ten tables in the fisheries section 

of the EIS, most with multiple columns, with site-specific data regarding watershed 

and aquatic habitat conditions in the project area. The evaluation is probably as sitespecific as it could possibly be.

SC-185 

p-115 

Comment: 

Generally, fire cycles in more remote forest stands were not significantly altered by fire 

suppression actions until the late 1940’s through the 1960’s. Most existent mature and old 

characteristic trees, have generally survived one or more fires in frequent fire areas, or 

grown where fire cycles were naturally less frequent and extensive. The EIS however, fails 

to provide such site-specific discerning information in its analysis. 

Response:

We respectfully disagree with this comment. Site-specific historical wildland fire 

information is disclosed in the FEIS, Chapter 3, p. 3-67. 

SC-186 

p-115 

Comment: 

The EIS also fails to address the natural beneficial role of large-scale fires, including severe 

fires, and the natural mosaic patterns of large burns. 

Response:

Although large scale fires are a natural process and can be beneficial to forest 

ecosystems, the Forest Plan does not allow for the “let it burn” strategy. This is 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-90

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

principally because the Forest does not manage large enough wilderness or roadless 

areas where a fire can be allowed to burn without the threat of burning onto private 

property or threatening communities, improvements, or other values at risk. Cobbler 

II project planning area is approximately 5 miles from the communities of Troy, 

Promise, Eden Bench and Bartlett Bench, a distance that a fast moving crown fire 

could burn through in a matter of hours. Even though the planning area is not located 

within a wildland/ urban interface, we are proposing to conduct fuel treatments that 

would allow firefighters the opportunity to control such a fire before it reached these 

communities. 

See FEIS, Chapter 1, Purpose and Need, pp. 1-4 to 1-5 and Chapter 3, Fuels pp. 3-62 

to 3-75. 

SC-187 

p-115 

Comment: 

Similarly, long-term cycles of moisture and climate determine the high points and low 

periods of fire intensity and severity as well as tree vigor and vegetative growth. These 

overarching patterns span not just decades, but centuries and epochs. The EIS fails to 

incorporate scientific research addressing these overarching patterns, which otherwise 

could help put current patterns and processes into better perspective, allowing the feasible 

development of alternatives that work with, and not against, nature. 

Response:

See FEIS, Chapter 3, pp. 3-62 to 3-64 for a description of the affected environment, 

Chapter 1, pp. 1-3 to 1-5 regarding the purpose and need for action, and Literature 

Citations for references used in the analysis.

SC-188 

p-115 

Comment: 

Lodgepole pine stands have been harvested, and the remaining mature stands in the project 

planning area are at the age to be highly susceptible to mountain pine beetle, which is 

currently experiencing an increasing population. However, the EIS fails to disclose the 

range of scientific recommendations and research pertinent to lodgepole pine forest 

systems and their dependent wildlife, or for that matter any substantive science supporting 

the proposed logging plans. 

Response:

For the assessment of risk of high stand mortality from mountain beetles, the FEIS 

relied on research found in: 

Scott, D. W. 2010. Upland Moist Forests and Associated Insect Disturbances in the 

Blue Mountains: Supporting Science for Management Action. Report BMPMSC-10-

01. USDA Forest Service, Blue Mountains Pest Management Service Center, La 

Grande, OR. 101p., including this set of references: 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-91

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Jenkins 

and others 

2008, p 21 

“Mountain pine beetle spread occurs most rapidly in old, dense 

stands comprised of a majority of large lodgepole pines. The most 

susceptible stands have trees over 80 years old, average tree 

diameters greater than 20 cm dbh, an average phloem thickness 

greater than 0.254 cm, over 18 m2/ha mean basal area, and stand 

density index between 140 and 245 (Cole and Amman, 1980; 

Berryman, 1982; Amman et al., 1985; McGregor and Cole, 1985; 

Safranyik, 1989; Anhold et al. 1996). During outbreaks, beetles infest 

the older, large diameter trees first, and eventually kill smaller trees 

as populations build (McGregor and Cole, 1985).” 

Harvest recommendations are also based on reports from field visits by a forest 

entomologist and pathologist, who found that mountain pine beetle is currently active 

at low levels and appears to be increasing in the area (Spiegel, L.H.; Schmitt, C.L. 

2008 and 2009). There are approximately 1,370 acres of lodgepole pine stands with

high potential for mortality from mountain pine beetle in the Cobbler II project 

planning area. Harvesting high risk stands in this project would assure that the wood 

would be harvested while it is sound. If the stands die from beetle attack and the dead 

trees are not harvested right away, some of the value of the wood could be lost. 

Interdisciplinary team members considered an alternative that would harvest all 

lodgepole pine stands rated with a high potential for mortality from mountain pine 

beetle (FEIS, Chapter 2, pp. 2-37 to 2-38). However, these stands are important food 

sources for woodpeckers and other wildlife, even if they experience high mortality. 

Based on this information, this alternative was considered but not analyzed in detail. 

SC-189 

p-116 

Comment: 

The EIS fails to assess, and needs to disclose and analyze, the consequences of disrupting 

natural disturbance processes in lodgepole pine and mixed conifer forest ecosystems. 

Response:

The purpose of this project is not to control unpredictable natural events like wildfire 

or insect and disease outbreaks, but to create a forest that is more resilient in 

responding to the effects of these natural disturbance agents. We are using historical 

range of variability as a basis for this resiliency across the landscape.

SC-190 

p-117 

Comment: 

The EIS’s flawed analysis, lack of scientific objectivity and breadth, and myopic focus on 

timber economics, only serves to further incrementally unravel the natural ecosystems of 

our region, with both localized and cumulative global repercussions 

Response:

Your comment has been noted. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-92

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-191 

p-119 

Comment: 

Whether trees killed by fire or windstorm are logged (post-fire, post-disturbance) makes 

relatively little difference in carbon storage. Whenever there is a natural disturbance it is 

often suggested that harvesting dead trees will release less carbon than letting them 

decompose naturally. This is based on the assumption that natural processes will rapidly 

release carbon and timber harvesting will not. This assumption is not supported by the 

likely rates of carbon release from these two processes. 

Setting aside the fact that harvest and transport of wood currently requires carbon-based 

energy, there is an inevitable release of carbon during the manufacturing and use of forest 

products. 

Depending upon the type of wood product produced, the amount of carbon released during 

manufacturing is equal to 25-50% of the harvested amount. 

In many cases harvested forests are burned for site preparation, a process that removes 

approximately 5-10% of the forest’s carbon. Combined with manufacturing losses, this 

means that timber harvest reduces total forest carbon stores by 10-25%. 

The analysis for the Cobbler II logging project does not account for these losses or fairly 

disclose and compare the effects of the No Action alternative as compared to all the action 

alternatives. 

Response:

See response to comments OW-12 and OW-13. 

SC-192 

p-120 

Comment: 

The Forest Service must consider the effect of harvest on the pool of carbon stored in the 

soils. The soils store carbon for far longer than the forest vegetation does. The analysis for 

the Cobbler II EIS logging project does not do a thorough job of disclosing these issues. 

Response:

See response to comment OW-12. 

SC-193 

p-120 

Comment: 

The starting and end points need to be specified. Often a proposed action gives the end 

point, but not the starting point. This would be similar to describing a trip by only giving 

the destination. One will have no idea of the direction or the distance to be traveled. For 

example, if one is planning on establishing a short-rotation forest plantation on agricultural 

land, then more carbon will be stored. Establishing the same type of plantation by 

converting an old-growth forest will result in a net loss of carbon to the atmosphere. 

The analysis of the Cobbler II EIS logging project again ignores this critical piece. The 

timing of the removal is critical. Otherwise, the Forest Service is using flawed accounting 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-93

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

and the consideration of logging is skewed to favor logging when the scientific reality is 

that logging punches holes in an already leaky carbon bucket. 

Response:

See response to comments OW-12 and OW-13. 

SC-194 

p-121 

Comment: 

Over a long time period forests gain carbon and eventually lose some of it when disturbed 

again. If the average carbon stores of a young forest is compared to that of an older forest, 

then one finds that the older forest stores a good deal more carbon. Therefore one is 

unlikely to gain carbon from the forest site if one converts from an older to a younger 

forest system. The analysis of the Cobbler II EIS logging project again makes this flawed 

assumption and bases its management choice on this flawed assumption. 

Response:

Cobbler II FEIS does not make this assumption. See response to comment OW-12. 

SC-195 

p-126 

Comment: 

To assure that forest projects in fact remove atmospheric carbon, it is essential that the 

actions proposed in the Cobbler II project conform to rigorous scientific principles. The 

proposal in the Cobbler II EIS does not provide assurance that that increases of carbon 

stores will be realized over time. 

Response:

Increase in carbon storage from the proposed activities is not stated in the FEIS. The 

complexity of this subject is addressed in Chapter 3, pp. 3-155 to 3-163. 

SC-196 

P 127 

Comment: 

The Cobbler II EIS claims that due to the lack of federal standards, regulatory policy, and 

federal statutes it is impossible to determine the impacts of the Cobbler II Project on 

climate change and carbon sequestration, and the failure of the EIS to incorporate the 

science and issues noted above and in our appeal Exhibit D-I through D-V, fails the ethical, 

legal, management, and scientific responsibilities of the Forest Service. The EIS must be 

withdrawn, and new requisite analysis conducted that responsibly addresses these critically 

imperative issues of climate change and forest vegetation and soil carbon sequestration. 

Response:

This is not stated in the FEIS. Our current understanding of climate science suggests 

it is difficult to establish a cause-and-effect relationship between proposed actions and 

climate change at a project scale. Therefore, no attempt was made to use climate 

change as an issue during the NEPA process, and no indicators were established for 

comparing potential climate change effects between alternatives (FEIS, Chapter 3, p. 

3-155). 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-94

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-197 

p-137 

Comment: 

The EIS fails to meaningfully incorporate utilizing scientifically recommended 

strategically placed land area treatments – SPLATS (or SPOTS, etc.). 

Response:

Strategically placed treatments are recommended by resource management specialists 

exercising professional judgment based on the purpose and need of the project, their 

experience, project constraints, the inherent features of the project area and scientific 

recommendations (Agee and Skinner 2005; Keyes and O’Hara 2002) among other 

things. 

SC-198 

p-137-138 

Comment: 

The EIS fails to adequately address the scientific controversy surrounding the use of Fire 

Regime Condition Class or the model methodology used in its fire risk modeling for this 

project. 

Response:

Fire regime condition class measures the degree of departure from reference 

conditions, possibly resulting in changes to key ecosystem components, such as 

vegetation characteristics (species composition, structural stage, stand age, canopy 

closure) as well as fuel composition, fire frequency, severity and pattern. The basis 

for the condition class rating for the EA was driven by the vegetative component of 

the condition class analysis. FRCC also looks at fire intervals missed with 90+ years 

of fire suppression we can interpret that 1 or more fire intervals have been missed. It 

is well documented that fire returned as a disturbance on a frequent basis in dry sites. 

The historical Fire regime in these dry forests is well documented and has been 

described as high frequency, low intensity and severity that maintained an open, 

park-like forest dominated by P. ponderosa (Hall, 1976; Johnson, 1994; Agee, 1994;

Hessburg et al. 2005). 

A science review of FRCC was conducted on FRCC guide book 1.0 and changes made 

to version 1.2. The science team concluded that the concept of FRCC is science based, 

and that it appropriately tries to reflect changes in vegetation and fuels conditions as 

a result of changes in fire regimes, other disturbances and land use. 

The use of FRCC in the fuels specialist report is tempered by analysis of peer 

reviewed science and interpolation of that science’s applicability to the project area. 

There is recognition in the fuels specialist report and Chapter 3 in the FEIS of the 

limitations of using FRCC alone as a predictor for landscape treatment and departure 

from historic conditions. Therefore, indicators such as fire regime (historical fire 

severity and frequency), fuel load, species composition, density, and structure and 

their associated historical ranges of variability are used to inform and improve the 

FRCC metric and site-specific analysis of the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-95

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-199 

p-138 

Comment: 

It is notable that even given the inaccuracies ascribed to using FRCC, the EIS 

acknowledges that only 10% of the area has changed to class 3, with 40% only moderately 

altered from original fire patterns, leaving half of the area within class 1. Even without 

consideration of the flaws inherent in using FRCC, this calls into serious question the “firerisk” reduction “need” for this project at all – especially given more priority WUI areas 

nearer human communities, and limited agency and public resources. 

Response:

See response to comment SC-198.

SC-200 

p-139 

Comment: 

The EIS does not objectively present scientific research including contending research and 

fails to impartially identify what the “best available science” is or entails, with respect to 

the Forest Service’s decision to log multi-story old growth stands, which are only barely 

within the HRV threshold for that forest type, in order to convert those stands to a slightly 

more deficient forest type. 

Response:

Franklin et al. 2008. The Case for Active Management of Dry Forest Types in 

Eastern Washington: Perpetuating and Creating Old Forest Structures and Functions 

“Active management is imperative to re-establish and maintain sustainable forest 

conditions, including older forest structure and function. Active management 

includes silvicultural treatments to create and maintain sustainable forest conditions 

using both mechanical and fire treatments.” 

See response to comment SC-9. 

SC-201 

p-139 

Comment: 

The EIS fails to sufficiently acknowledge and adequately discuss the high level of 

uncertainty with respect to the long-term ecological consequences of this management 

prescription for LOS stands, particularly given that most areas are also deficient in multistory old growth (as seen with many recent projects calling for amendments to the Eastside 

Screens to “treat” these areas) or are just barely within the HRV for this forest type (as is 

the case here). This discussion is essential in order for the Forest Service to demonstrate 

that it took the requisite “hard look” at the environmental consequences of its proposed 

action under NEPA 

Response:

The analysis in the FEIS showing the consistency of this project with the Eastside 

Screens (Appendix F) was done at the landscape level as directed in Blackwood 1998. 

Also see response to comment SC-200. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-96

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-202 

p-141 

Comment: 

While the EIS claims Eastside Screens direction for connective corridors will be met, it 

fails to substantiate such claims by either accurate site-specific information or applicable 

scientific research pertaining to the cover needs of imperiled interior forest species 

Response:

Substantiating the Eastside screens is beyond the scope of this project. 

See response to comment OW-15.

SC-203 

p-142 

Comment: 

Of even greater concern is the selected alternative’s authorization of .25 miles of new road 

construction and .20 miles of so-called “temporary” road construction. This combination 

of new and “temporary” road construction and re-opening of closed roads will result in 

further habitat fragmentation and remove areas of vegetated wildlife security. 

Response:

See response to comments SC-82, SC-92 and SC-96.

SC-204 

p-143 

Comment: 

Invasive weeds have the potential of being an even greater serious problem in the planning 

area and the problems posed by their introduction and spread in general are well

documented. Central to solving this problem is halting activities that further perpetuate the 

conditions where invasive weeds thrive. Logging equipment and exposed soil mean more 

vectors for invasive plants. Once introduced, they are very difficult to eradicate. This issue 

should have been given serious attention, particularly given the level of livestock grazing, 

the high influx of vehicles and humans, and the extent of ground disturbing logging and 

related project actions that the agency plans within the project area. The EIS notes a list of 

measures to mitigate these risks, but fails to disclose the effectiveness and applicability of 

such measures. 

Response:

Design features and management requirements incorporated in the design for all 

action alternatives (FEIS, Chapter 2, Table 2-6) are considered to be highly effective. 

These measures have been used successfully for past projects on Umatilla National 

Forest. Forest Plan monitoring, and annual evaluation reports have documented the 

effectiveness of these measures. 

SC-205 

p-143 

Comment: 

The EIS failed to sufficiently recognize the importance of mycorrhizal fungi on forest 

growth and productivity. The EIS failed to adequately discuss how mycorrhizae will be 

impacted by the planned logging project. The EIS failed to sufficiently assess how logging 

has affected mycorrhizae in areas nearby the analysis area. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-97

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

Cited research includes discussion of impacts to mycorrhizae populations from 

proposed activities. Design features and management requirements (FEIS, Chapter 

2, Table 2-6), and silvicultural prescriptions and fuel loadings are adjusted 

accordingly. Also, results from prior activities which are essentially identical to the 

proposed actions and on similar ecological sites (soil type, geomorphology and 

climate, Soils Specialist Report) guide conclusions for anticipated effects, and 

expectations of Forest Plan adherence. 

See response to comment SC-16. 

SC-206 

p-143 

Comment: 

Soil research and surveys of similar projects confirms the project will have detrimental 

impacts on soil, including destruction of microbiotic organisms, soil compaction, and soil 

erosion. The EIS fails to fully address these harms. Use of low impact light equipment in 

appropriate areas is also not adequately addressed or incorporated in project actions. As the 

major purpose and need premise for this project is recovering forest resilience, protection 

and restoration of ecologically foundational forest soils should have been a paramount 

priority for this project. T 

Response:

Analysis of detrimental soil impacts (including soil compaction) is discussed in the 

FEIS, Chapter 3, pp. 3-6 to 3-10. Extent and degree of Detrimental Soil Condition

(DSC) and erosion hazard is limited by unit selection (FEIS, Appendix E), layout, 

design criteria and contractual and administrative controls. Monitoring and research 

of similar projects indicate satisfactory results with proper considerations as provided 

in this project proposal. 

See response to comment SC-16.

SC-207 

p-144 

Comment: 

The EIS fails to adequately address and disclose the extent of potential adverse impacts 

from excessive biomass utilization as part of this project. Short-term scientifically noncontroversial restoration methods should be the only basis for biomass inclusion in this 

project. Limited, ecologically beneficial biomass utilization should not result in adverse 

harms to forest ecological integrity, functioning, and/or wildlife habitat needs. 

Additionally, in areas where whole tree yarding is planned, and elsewhere where the mix of 

commercial logging and non-commercial thinning would generate significant quantities of 

pile concentrated slash, the EIS failed to address the adverse impacts of such piles, and the 

infeasibility given the economic realities of both the chip and biomass markets, and the 

distance of the project area from production facilities. Piles if left concentrated in the 

forest, or scattered throughout the forest floor, will significantly increase the risk of severe 

fires throughout the project area and surrounding forests. If burned, large piles carry an 

inherent risk of fire spread. Pile burning sterilizes forest soils, requiring many decades to 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-98

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

centuries for soil community recovery. The EIS plans project actions that are inconsistent 

with the ecological objectives of the stated purpose and need, and must as such be 

withdrawn and revised. 

Response:

We respectfully disagree with this comment. See FEIS, Chapter 3, pp. 3-4 to 3-10 and 

3-62 to 3-75 for a detailed analysis of all activities proposed. 

Burning of large slash piles will often increase the area of soils that are severely 

burned according to Forest Plan criteria. Severe burn effects from the burning of 

large slash piles is included in the Detrimental Soil Condition (DSC) analysis and the 

estimation of the percentage of activity area that would be in DSC (see FEIS, 

Appendix E). 

See FEIS, Chapter 2, pp. 2-16 through 2-19, regarding the treatment of activity 

generated fuels. When feasible (within weather and contractor availability 

constraints) activity fuels are treated within two years of activity. 

In addition, retained organic matter levels are projected to be within guidelines by 

ecological site as found in Brown 2003 and Graham 1994. 

SC-208 

p-144 

Comment: 

Bark beetles and mistletoe are also natural processes that have benefits in the natural 

succession of the forests. The EIS failed to address the important natural roles and benefits 

of these components. Instead, mistletoe and beetles are being used as scientifically 

insupportable excuses for excessive harmful logging actions. The EIS needs to correct 

these inaccuracies and revise the project to provide for the appropriate role mistletoe and 

beetles. Retention of mature and old trees with and without mistletoe should be a given in 

this project. Mistletoe trees with mature and old characteristics and/or trees with active 

nests must not be targeted for logging removal 

Response:

The purpose of this project is not to control unpredictable natural events like wildfire 

or insect and disease outbreaks, but to create a forest that is more resilient in 

responding to the effects of these natural disturbance agents. We are using historical 

range of variability as a basis for this resilience across the landscape. 

See response to comment AFRC-2. 

SC-209 

p-149 

Comment: 

The Cobbler II Project EIS lacks scientific basis, and fails to objectively disclose the full 

range of credible scientific recommendations pertinent to the project’s purported purpose 

and need ecological objectives. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-99

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

Response:

We respectfully disagree with this comment. See response to comments SC-1, SC-5, 

SC-12, SC-18, SC-19, and SC-23. 

SC-210 

p-152 

Comment:

Given the growing scarcity of natural quiet coupled with the beneficial effects of natural 

quiet to most wildlife populations and the recreational experience of forest visitors, the 

Cobbler II Project NEPA documentation failed completely to address issues of natural 

quiet, disclose this as a resource worth protecting, and modify alternatives or assess how 

planned logging and associated actions will affect natural quiet throughout the project area 

during the extensive duration of the Cobbler II project implementation. The EIS’s proposed 

alternatives failed to address and incorporate an objective of retaining natural quiet (to the 

extent within the Forest Service’s control) in important landscapes and watersheds, or 

“soundsheds 

Response:

The environmental effects of project activities (including sights and sounds from the 

action) were discussed in Chapter 3 of the FEIS, see specifically the Wildlife, 

Recreation, Other Undeveloped Lands and Wenaha-Tucannon Wilderness sections. 

Additionally, new narrative was added to the FEIS describing how a sense of natural 

appearing landscape, solitude, and remoteness are potentially impacted by the sights 

and sounds of timber harvest activities (Chapter 3 pp. 3-135, 3-148, 3-150 and 3-152).

SC-211 

p-152 

Comment: 

The Cobbler II EIS fails to address the significant irreparable environmental consequences 

of the District’s sequential logging actions to overall scientific recommendations and 

agency admonitions to proactively protect and restore “wild nature” qualities and abundant 

wildlife, salmonid populations, and natural recreational qualities throughout the District’s 

forests. 

Response:

Direct, indirect, and cumulative effects for the resources mentioned above are 

disclosed in Chapter 3 of the FEIS. 

See response to comment SC-23.

SC-212 

p-154 

Comment: 

Given this developing reinterpretation of the legal requirements attendant to management 

indicator species, it is clear that the multiple mandates in NFMA and its implementing 

regulations requiring population monitoring and surveying are not being even minimally 

met for the Cobbler II project 

Response:

Determinations made for MIS wildlife and aquatic species are based on past and 

current, known occurrences of these species; field reconnaissance, and habitat 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-100

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

conditions. Whether a species is found or not, the habitat should be maintained at 

appropriate levels, which is the best way to ensure that species will be able to inhabit 

the area now and in the future. 

See also response to comment SC-213.

SC-213 

p-154 

Comment: 

This project will have adverse impacts on several terrestrial and aquatic Management 

Indicator Species, but the FS lacks monitoring data which would tell them whether the 

cumulative effects of this project and all other past, present, and future projects might be 

pushing these indicator species toward some threshold of concern for population viability. 

Response:

Existing conditions based on stream surveys and field visits along with impacts to 

Steelhead and redband trout (MIS) and their habitat are discussed in the FEIS, 

Chapter 3, pp. 3-23 to 3-35. 

Direct, indirect, and cumulative impacts to MIS wildlife species and habitat are 

disclosed in the FEIS, Chapter 3, pp. 3-91 to 3-104. Annual elk counts are done by 

ODFW in the spring. Past monitoring included the forest-wide Terrestrial Wildlife 

Inventory project, which incorporated visits to 224 plots between 2003 and 2006. The 

Terrestrial Wildlife Inventory provides evidence of presence, relative distribution and 

abundance of wildlife species, and a baseline for monitoring presence and distribution 

of management indicator species and sensitive wildlife species at the Forest scale. 

Monitoring of populations and habitat trends is more appropriate at the Forest or 

province level than at the scale and extent of the Cobbler II project planning area. 

Species assessments are currently being completed for the Blue Mountain forests as 

part of the Forest Plan revision. 

Existing aquatic habitat condition data are presented in the FEIS, Chapter 3, pp. 3-23 

to 3-35, and maps showing past activities and conditions (harvest by decade, wildfire 

by decade) are located in the project file. These data are summarized together with 

cumulative effects to aquatic habitat and species in pages 3-35- to 3-43. 

SC-214 

p-155 

Comment: 

NFMA, its implementing regulations, and subsequent case law require the Forest Service to 

know what the viable populations of MIS located in the project area are before 

management prescriptions are applied. However, the NEPA document and the underlying 

specialist reports never explain what the population levels are for the MIS. This is despite 

the fact MIS habitat will be negatively affected by this project. 

Response:

See response to comment SC-213. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-101

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

The fisheries management indicator species is rainbow/redband trout (Oncorhynchus 

mykiss) and their presence and distribution in the project area subwatersheds is well 

known (FEIS, Chapter 3, Table 3-10) and mapped (map available in the project file). 

Attempting to locally quantify population levels would in itself be very invasive of the 

habitat and harass and harm the fish. More appropriate would be to evaluate 

population status at the regional scale or that of the evolutionarily significant unit. 

This is done by the state and or by other federal agencies (NMFS, USFWS). 

SC-215 

p-158 

Comment: 

Our organizations are very concerned that the planning area does not currently support 

viable populations of White-headed, Pileated, Lewis’ and other woodpeckers and cavity 

excavators. The EIS fails to indicate substantive ongoing surveys, or comprehensive 

science, upon which it could reasonably base claims that the planning area is meeting 

100% of the potential population for Pileated and other cavity excavators, as required by 

the amended Umatilla LRMP. The failure to survey and monitor for these species and 

substantiate compliance with the amended Forest Plan violates the NEPA, and the failure to 

meet forest plan standards violates NFMA 

Response:

Woodpecker species are adapted to specific habitat types, which vary throughout the 

Umatilla Forest. For example, there is a very limited amount of potential habitat 

available for white-headed and Lewis woodpecker in the Cobbler II project planning 

area, and in fact thinning would create additional habitat. The forest is surveying for 

white-headed woodpecker in targeted areas. Pileated woodpeckers are common in 

the Cobbler II area, which provides 15,000 acres of habitat. There is no indication 

that viable populations of pileated woodpecker do not exist on Umatilla National 

Forest. Effects and findings of consistency with the Forest Plan and applicable laws 

for these and other species are disclosed in the FEIS, Chapter 3, pp. 3-108 to 3-117. 

SC-216 

p-158 

Comment: 

The NEPA analysis failed to consider significant new information on pileated and other 

woodpeckers including: pileated woodpeckers need more and larger roosting trees than 

nesting trees. They may use only one nesting tree in a year, but they may use 7 or more 

roosting trees. These and other cavity excavator species also depend upon forest canopy 

closure, mature as well as LOS forest stands, select for nest trees beginning at 15” dbh and 

above, and need a significant expanse of contiguous forest habitat. Determining pileated 

and other woodpeckers population potential based on nesting sites alone will not provide 

adequate habitat for viable populations of this species. This new information is not 

recognized in current management requirements at the plan or project level. 

Response:

See response to comment SC-215. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-102

Letter #7 (SC) 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

Comment 

Number Comment and Response 

SC-217 

p-159 

Comment: 

The EIS repeatedly offers assurance that dead wood species will be fine because 

the project will retain enough snags to comply with the forest plan and/or the eastside 

screens, but the EIS fails to disclose that these are hollow assurances based on outdated 

standards and guidelines and discredited science. 

Response:

The FEIS and Wildlife Specialist’s Report incorporate best available science. DecAID 

and other publications were used to determine the effects to said species. Project 

design criteria (FEIS, Chapter 2, Table 2-6) to maintain large snags goes beyond 

Forest Plan standards. Effects to snag-dependant species are discussed in the FEIS, 

Chapter 3, pp. 3-98 to 3-104.

SC-218 

p-159 

Comment: 

The EIS discusses dead wood habitat within the framework of the Umatilla LRMP and the 

eastside screens both of which rely on an outdated and discredited "potential population" 

method of snag habitat analysis. The FS must prepare a plan amendment to consider a wide 

range of possible replacements for the potential population method. DecAID is one such 

method but it has many flaws and the FS cannot rely on it without conducting the NEPA 

analysis and plan amendment described above. 

Response:

The snag analysis used the most current information and methods available to 

determine existing conditions and environmental effects. Amending the Forest Plan 

snag standards is beyond the scope of this analysis (FEIS, Chapter 3, pp. 3-98 to 3-

104). 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-103

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Comment 

Number Comment and Response 

SC 

Attachment 

1 

Exhibit: 

09BakerPringleFalls.pdf 

Response:

“Here I present a reconstruction of tree density and size-class structure in these 

forests about A.D. 1880 using data from the General Land Office (GLO) surveys of 

township/section lines. The purpose is to illustrate the potential value of using the 

GLO surveys to inform forest restoration.” 

Not a peer-reviewed paper; rather a preliminary discussion of a method to determine 

historic stand structure. Author cautions that research is likely to be expanded and is 

subject to change. The author suggests that the results of the reconstruction using this 

information lead to a different conclusion about the historical abundance of small 

pines and of dense mature forests than other researchers have made. No definitive 

findings are reported. This reference does not provide science that opposes methods 

proposed in the Cobbler II project.

SC 

Attachment 

2 

Exhibit: 

9th Circuit Cases on Climate Change.doc 

Response:

The Cobbler II FEIS addresses the climate change implications of the project in 

Chapter 3, pp. 3-155 to 3-163.

SC 

Attachment 

3 

Exhibit: 

50 yr trend in June temperature.pdf 

Response:

Map – change in average June temperature 1951-2006. No comment made with this 

attachment. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-104

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

4 

Exhibit: 

20090331_letter_to_Pines_landowners001.pdf 

Response: 

Letter from Jemez Ranger District, Jemez NM – to private landowners regarding 

community wildfire plan. 

SC 

Attachment 

5 

Exhibit: 

ABA NEPA Emerging Issues Final 9-4-08.pdf 

Response:

This is a survey of the developing NEPA case law in three emerging areas: climate 

change, genetic engineering and nanotechnology. This reference does not provide 

science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

6 

Exhibit: 

ABST#KO7.PDF 

Response:

This is not peer reviewed science. This reference does not provide science that 

opposes methods proposed in the Cobbler II project.

SC 

Attachment 

7 

Exhibit: 

Are we irrationally exuberant about thinning.doc 

Response:

Not a peer-reviewed paper; rather a preliminary discussion of a method to determine 

historic stand structure. Author cautions that research is likely to be expanded and is 

subject to change. No definitive findings are reported. This reference does not 

provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

8 

Exhibit: 

Area burned in 11 western states-1.doc 

Response:

Not a peer-reviewed paper. No definitive findings are reported 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-105

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

9 

Exhibit: 

ASSE#TE3.PDF 

Response:

This paper discusses the use of lidar and optical imagery for assessing forest 

disturbance and recovery in Alaska. This reference does not provide science that 

opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

10 

Exhibit: 

Bark beetles (2).doc 

Response:

This is an overview of an ongoing research project, with a link to the project proposal. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. 

SC 

Attachment 

11 

Exhibit: VEG (File is empty) 

BARK#KP5.PDF 

Response:

No response is possible.

SC 

Attachment 

12 

Exhibit: VEG - 

BarkBeetlesFuelsFire.pdf 

Response:

This review article describes that the effects of bark beetle attacks at different 

population levels are complex with regard to fire probability and severity. “The data 

showed that changes in fuels over time create periods where the potential for high 

intensity and/or severe fires increases or decreases.” It also discusses the effectiveness 

of various management strategies “By enhancing stand diversity and resiliency, 

[silvicultural] prevention strategies can help avoid unacceptable losses of valuable 

resources, maintain or enhance resource objectives, and maximize revenue in the long 

term.” This supports the methods proposed in the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-106

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

13 

Exhibit: 

BATT#0_U.PDF 

Black, S.H., D. Kulakowski, B.R. Noon, and D. DellaSala. 2010. Insects and Roadless 

Forests: A ScientificReview of Causes, Consequences and Management Alternatives. 

National Center for Conservation Science & Policy, Ashland OR.

Response:

This review article specifically addresses a recent proposal to exempt national forest 

roadless areas in Colorado from protections under the 2001 Roadless Area 

Conservation Rule. It does not apply to proposed activities in the Cobbler II project. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. 

SC 

Attachment 

14 

Exhibit: 

BATT#0BL.DOC 

Black, S.H. 2010. Report: Battling forest beetles may be counter-productive. Thinning 

backcountry unlikely to reduce fire risk or lessen beetle outbreaks, largely fueled by 

drought and higher temperatures.

Response:

This is an article about the above review article. It does not apply to proposed 

activities in the Cobbler II project. This reference does not provide science that 

opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

15 

Exhibit: 

Beetle Mania DS Revised.doc 

Wuerthner, G. Beetle Mania 

Response:

There is no indication of when or where this essay was published. The author 

attempts to explain a beetle outbreak and urges citizens to be involved in forest 

management decisions. This reference does not provide science that opposes methods 

proposed in the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-107

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

16 

Exhibit: 

Beetles in Western Forests a Natural Event - NYT 7-09.docx 

Some See Beetle Attacks on Western Forests as a Natural Event 

Response: 

News article in the New York Times about increased bark beetle activity. Various 

scientists and professionals offer opinions about whether activity is in natural range 

or is desirable. This reference does not provide science that opposes methods 

proposed in the Cobbler II project. 

SC 

Attachment 

17 

Exhibit: 

Bentz et al Bark Beetle Outbreaks in W. N America 2009.doc 

Bentz et al Bark Beetle Outbreaks in W. N America 2009: Causes and Consequences 

http://www.missoulanews.com/index.cfm?do=article.userOpinions&nav=News 

Bentz B, Allen CD, Ayres M, Berg E, Carroll A, Hansen M, Hicke J, Joyce L, 

Logan J, McMahon J, Macfarlane J, Munson S, Negrón J, Paine T, Powell J, 

Raffa K, Régnière J, Reid M, Romme W, Seybold S, Six D, Tomback D, 

Vandygriff J, Veblen T, White M, Witcosky J, Wood D (2009). Bark Beetle 

Outbreaks in Western North America: Causes and Consequences. University of 

Utah Press, ISBN 978-0-87480965-7. 42 p. 

Response: 

Provided with this citation were several paragraphs by an unidentified author. They 

appear to be opinion submitted to an online chat. The author was not in favor of 

salvaging dead trees. The Cobbler II project does not propose to salvage dead trees. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project.

SC 

Attachment 

18 

Exhibit: 

Berg & Anderson 2006 Kenai fire history.pdf 

Forest Ecology and Management 227 (2006) 275–283 Fire history of white and Lutz 

spruce forests on the Kenai Peninsula, Alaska, over the last two millennia as determined 

from soil charcoal. 

Response: 

This paper presents a method for determining fire history over long periods by dating 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-108

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

soil charcoal. Using this method, no relation between fire activity and past spruce 

beetle outbreaks was found in the area of the study. The article discusses the history 

of spruce beetle outbreaks and fire activity in white and Lutz spruce stands on the 

Kenai Peninsula, AK. The biophysical environment is very different from that of the 

Cobbler II project area and it is not clear how well the results would apply. The 

authors caution, however, that a trend of warmer summers coupled with an 

increasing human population and associated sources of ignitions may create a greater 

fire risk in all fuel types than was present during the time period covered by their 

study. This reference does not provide science that opposes methods proposed in the 

Cobbler II project. 

SC 

Attachment 

19 

Exhibit: 

Berg et al 2006 SBB outbreaks Kenai & Kluane.pdf 

Forest Ecology and Management 227 (2006) 219–232 Spruce beetle outbreaks on the 

Kenai Peninsula, Alaska, and Kluane National Park and Reserve, Yukon Territory: 

Relationship to summer temperatures and regional differences in disturbance regimes 

Response: 

The biophysical environment considered in this paper is very different from that of 

the Cobbler II project area and it is not clear how well the results would apply. The 

authors conclude that predicted increasing temperatures and CO2 levels may result 

in insect outbreaks that are outside the past HRV levels. This is similar to conclusions 

in references used in the Cobbler II FEIS. 

SC 

Attachment 

20 

Exhibit: 

Bigger.docx 

Response:

This is not a peer reviewed paper, but rather a blog about climate change and the 

future of wildfires. This reference does not provide science that opposes methods 

proposed in the Cobbler II project. 

SC 

Attachment 

21 

Exhibit: 

BIOD#XL-.PDF 

Lawler J. J., M. Mathias, A. E. Yahnke, and E. H. Girvetz. 2008. Oregon’s 

Biodiversity in a Changing Climate. Report prepared for the Climate Leadership 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-109

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Initiative, University of Oregon. 

Response: 

Authors present information based on an earlier report developed for the state of 

Washington’s Biodiversity Council. Report includes information specific to Oregon 

climate and biodiversity. Anticipated trends include increased temperatures, longer 

fire seasons and more and larger fires, shifting of tree lines upward in elevation, and 

increased disease and insect infestations and outbreaks. The authors consider how 

biodiversity can be conserved and discuss an example of a planning process to help 

select a network of areas that will be more resilient to climate change. This reference 

does not provide science that opposes methods proposed in the Cobbler II project.

SC 

Attachment 

22 

Exhibit: 

BIOS#ZSM.PDF 

Raffa, K.A et al. 2008. Cross-scale Drivers of Natural Disturbances Prone to 

Anthropogenic Amplification: The Dynamics of Bark Beetle Eruptions. BioScience Vol. 

58 No. 6. doi:10.1641/B580607 

Response: 

An article that describes the complexity of factors that are necessary for large scale 

bark beetle outbreaks to occur. Factors are listed that include climate and host tree 

availability and condition. This reference does not provide science that opposes 

methods proposed in the Cobbler II project. Similar publications from the lead 

author are cited in Schmitt 2010, Upland Moist Forests and Associated Insect 

Disturbances in the Blue Mountains: Supporting Science for Management Action. 

SC 

Attachment 

23 

Exhibit: 

Black Backed Woodpeckers Draft USFS Guidelines 2009.docx 

Response: 

This is a very rough draft not intended for distribution. Does not apply since there is 

little to no habitat for black-backed woodpeckers in Cobbler II project planning area.

SC 

Attachment 

24 

Exhibit: 

Chemical composition of forest floor.doc 

Response:

The study deals with clearcut harvest in comparison to wildfires for certain nutrients 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-110

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

in boreal forests of eastern Canada. Clearcut prescriptions are not included in the 

Cobbler II silvicultural prescriptions nor is boreal forest chemical composition a good 

comparison ecotype for Cobbler II ecotypes. 

SC 

Attachment 

25 

Exhibit: 

Clews2010-juvenile salmonid populations-climate trends.pdf 

Response: 

This report supports a conclusion that recent climate change has been responsible for 

declines of number of Atlantic salmon and brown trout in the River Wye in 

England/Wales and by extension presumes similar effects elsewhere. It also 

recommends certain management activities including increased shade, reduced water 

withdrawals, and flow augmentation as measures to counteract global climate change. 

While this report is a useful contribution to scientific knowledge regarding the 

expected effects of climate change to salmonid fishes, particularly in the Eastern 

Atlantic and the British Isles, it is difficult to see how it would pertain to the Cobbler 

II project, since the project would not alter stream flow, shade, or water temperature. 

SC 

Attachment 

26 

Exhibit: 

COLU#UUD.HTM 

Response: 

This is Partners in Flight website containing land bird conservation plans and lists 

birds of conservation concern. This information was utilized in the land bird section 

of Chapter 3, p. 3-117 where Altman 2000 is cited. 

SC 

Attachment 

27 

Exhibit: 

Contributions of Ponderosa Charcoal to Soil.doc 

Response:

Paper discusses the nature of charcoal from wildfires in Ponderosa pine forests in 

California. This reference does not provide science that opposes methods proposed in 

the Cobbler II project.

SC 

Attachment 

28 

Exhibit: 

Covington et al Forestry 2 13-63.pdf 

Journal of Sustainable Forestry 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-111

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Covington et al. 1994. Historical and Anticipated Changes in Forest Ecosystems of the 

Inland West of the United States. 

Response: 

The authors provide a summary of literature pertaining to the history and current 

condition of inland Western forests. They conclude: “we anticipate an acceleration of 

historical changes in the Inland West including increased fuel accumulations, 

lengthened fire seasons, and intensified burning conditions, all contributing to larger 

and more catastrophic wildfires. A fairly narrow window of opportunity-perhaps 15-

30 years-exists for land managers to implement ecosystem management treatments to 

restore more nearly natural and robust ecosystem structures and processes. For 

many areas it may already be too late. However, for most of the region there is still 

time for remedial actions, both to minimize the negative environmental consequences 

of these changes and to capitalize on the positive. The consequences of inaction far 

exceed those of action.” 

This reference supports methods proposed in the Cobbler II project. 

SC 

Attachment 

29 

Exhibit: 

DECL#N1C.PDF 

Waring, R.H. 2009. Declaration. 

Response:

A declaration by forest science researcher, which does not constitute peer reviewed 

science. This reference does not provide science that opposes methods proposed in the 

Cobbler II project.

SC 

Attachment 

30 

Exhibit: 

DELA#QJ7.PDF 

Youngblood et al. 2009. Delayed conifer mortality after fuel reduction treatments: 

interactive effects of fuel, fire intensity, and bark beetles. Ecological Applications, 19(2), 

2009, pp. 321–337 

 

Response:

This paper describes mortality of residual trees in thinning and/or burning units after 

4 to 6 years, on sites similar to the Dry Upland Forest PVG stands proposed for 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-112

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

treatment in Cobbler II. “While the treatments were considered an operational 

success with respect to fuel reduction (Youngblood et al. 2008), the low levels of 

delayed mortality indicate that the subtle treatment effects were within the range of 

natural disturbances that occur in similar northeastern Oregon forests.” 

“When extended beyond this first set of treatments, our study provides a foundation 

for assessing the effects of continued long-term restoration treatments for reducing 

fuels and accelerating the development of late-successional stand structure in lowelevation dry ponderosa pine and Douglas-fir forests of northeastern Oregon.” 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. The treatments in the study are similar to those proposed in Dry Upland 

Forest stands in Cobbler II, and the results are similar those expected on those units. 

SC 

Attachment 

31 

Exhibit: 

DEPR#1RR.PDF 

Depro et al. 2008. Public land, timber harvests, and climate mitigation: Quantifying 

carbon sequestration potential on U.S. public timberlands. Forest Ecology and 

Management 255 1122–1134. 

Response: 

Authors compared carbon sequestration on public lands in three scenarios, a 

“business as usual” harvest level, no timber harvest and intense timber harvest 

(similar to timber harvest practices used in the 1980s). Authors found that most 

carbon would be sequestered under the “no harvest” scenario. They do not discuss 

the risk of ecosystem loss from accumulating biomass, as many other papers do. They 

show a positive but declining sequestration rate for public timberlands under 

“business as usual” with sequestration levels highest in the first decade and falling 

after that. This reference does not provide science that opposes methods proposed in 

the Cobbler II project. 

SC 

Attachment 

32 

Exhibit: 

DRAF#5FZ.DOC 

Wuerthner, G. 2009. Draft testimony. House Subcommittee on National Parks, Forests

and Public Lands House Subcommittee on Water and Power Joint Oversight Hearing on 

"Mountain Pine Beetle: Strategies for Protecting the West 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-113

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Response: 

This is testimony before Congress by a nature photographer and author. It does not 

constitute peer reviewed science. This reference does not provide science that opposes 

methods proposed in the Cobbler II project. 

SC 

Attachment 

33 

Exhibit: 

EAGL#8-E.PDF 

Response:

This is the final rule regarding take of eagles; there are no effects to eagles from this 

project (FEIS Chapter 3, pp. 3-108 to 3-110).

SC 

Attachment 

34 

Exhibit: 

EFFE#~TH.DOC 

Law, B. Effects of forest fire on carbon emissions, climate impacts often overestimated. 

Response: 

“This research was published recently in the journal Ecosystems, and funded by the 

U.S. Department of Energy.” This appears to be an announcement or article about 

the published research. In the article, it is stated that methods used in other studies 

may have overestimated carbon released from forest fires, and that more research is 

needed on how much carbon is released from different forest types, and the results 

may be different under climate change. This reference does not provide science that 

opposes methods proposed in the Cobbler II project.

SC 

Attachment 

35 

Exhibit: 

EOFO#EV0.DOC 

Riverwind, A. Climate Change, Forest Ecology and Carbon Sequestration 

Response:

This is an opinion essay. This reference does not provide science that opposes 

methods proposed in the Cobbler II project.

SC 

Attachment 

36 

Exhibit: 

ESAM#V#V.PDF 

Response:

This is a paper regarding the use of minimum viable population size in species 

conservation. Has no bearing on this EIS.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-114

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

37 

Exhibit: 

Euro Biomass Report 6-10.doc 

Response:

This is an opinion essay. This reference does not provide science that opposes 

methods proposed in the Cobbler II project.

SC 

Attachment 

38 

Exhibit: 

Fire history Glacier Bob Montana 1.pdf 

Response:

This is a one page excerpt with a map of fire history in Montana with no references, 

title or author. It is difficult to determine where this paper came from in order to 

evaluate the context of information or its validity. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project.

SC 

Attachment 

39 

Exhibit: 

Fire Regime Condition Class.doc 

Response:

This is not a peer reviewed paper, but rather a one page table that relates FRCC to 

increases and decreases in fire hazard. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project.

SC 

Attachment 

40 

Exhibit: 

FIRE#C8@.DOC 

Response:

Commenter provided what appears to be an advertisement or short description of this 

book, possibly generated by the book’s publisher. No information or direct citations 

from this reference were provided.

SC 

Attachment 

41 

Exhibit: 

FM-AmRivComplex8-2008.pdf 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-115

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Response:

Reference appears to be a post-fire study of efficacy of fuels treatments in changing 

fire behavior of a wildfire on the Tahoe National Forest. Vegetation and topography 

are not similar to those in the project area. 

Author stated that: 

“On the whole, the forest thinning treatments we visited appear to have moderated 

fire by reducing crown torching and (slightly) increasing canopy tree survival, but 

only one treatment succeeded in both forcing fire to the surface and preserving most 

of the stand. The successful treatment was the only one which appeared to have had 

explicit reduction and removal of ladder and surface fuels. Crown thinning removes 

combustible biomass from the target stand, but is unlikely to represent sufficient 

treatment to guarantee desired fuel treatment performance under typical wildfire 

conditions.” 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. Proposed fuel reduction methods for the Cobbler II project include the 

treatment of ladder and surface fuels which was the treatment scenario that had 

success in the example cited in this reference. Also, this treatment methodology in the 

Cobbler II project is not necessarily aimed at keeping fire from burning treated 

stands, but to slow fire down so that firefighters can take suppression action. 

SC 

Attachment 

42 

Exhibit: 

FORE#8~Y.PDF 

Nunery, J.S. 2010. Forest carbon storage in the northeastern United States: Net effects of 

harvesting frequency, post-harvest retention, and wood products. Forest Ecology and 

Management xxx (2010) xxx–xxx article in press 

Response:

This study compared carbon sequestration, in northeastern US hardwood-conifer 

forests, over various harvest intensities and frequencies, including no harvest. It 

looked at the significance of including harvested wood products in carbon accounting 

at the stand scale. Mean carbon sequestration was significantly greater for ‘no 

management’ compared to any of the active management scenarios. Of the harvest 

treatments, those favoring high levels of structural retention and decreased 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-116

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

harvesting frequency stored the greatest amounts of carbon. It did not include the 

emissions benefits associated with substituting wood fiber for other construction 

materials or energy sources. It is not clear how well this study can be applied to the 

Cobbler II area. It does not provide science that opposes methods proposed in the 

Cobbler II project.

SC 

Attachment 

43 

Exhibit: 

Franklin_20071.pdf 

Letter from Jerry Franklin to Ralph Bloemers regarding Eastside Screens and School Fire 

salvage. 

Response: 

This reference is a letter providing opinion about a proposed Forest Plan amendment 

for salvage within the School Fire perimeter on the Umatilla NF. The Cobbler II 

project is not located in a post-fire environment and does not propose to salvage dead 

trees. This reference does not provide science that opposes methods proposed in the 

Cobbler II project.

SC 

Attachment 

44 

Exhibit: 

FuelRedux_CStorage.pdf 

Response:

Authors used model to determine that fuels reduction methods consistently reduced 

fire severity, but also reduced mean stand carbon storage. Suggest that “forest 

management plans aimed solely at ameliorating increases in atmospheric CO2 should 

forego fuel reduction treatments in these ecosystems, with the possible exception of 

some east Cascades Ponderosa pine stands with uncharacteristic levels of understory 

fuel accumulation.” Authors further offer that “balancing a demand for maximal 

landscape C storage with the demand for reduced wildfire severity will likely require 

treatments to be applied strategically throughout the landscape rather than 

indiscriminately treating all stands. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. 

SC 

Attachment 

45 

Exhibit: 

Granting Plaintiff's SJ Motion.pdf 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-117

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

Response:

This exhibit refers to legal cases involving the Aquatic Conservation Strategy (ACS) 

of the Northwest Forest Plan. Cobbler II project planning area is located in area 

covered by PACFISH, not in the area of the Northwest Forest Plan. This exhibit does 

not apply to Cobbler II.

SC 

Attachment 

46 

Exhibit: 

Hanson et al 2009 CB Final.pdf 

Response:

The authors suggest that the US Fish and Wildlife Service has overestimated the risk 

of wildfire in spotted owl habitat it its latest spotted owl recovery plan. 

The Cobbler II project is not located within spotted owl habitat, and bases no part of 

its purpose and need on the spotted owl recovery plan. This reference does not 

provide science that opposes methods proposed in the Cobbler II project.

SC 

Attachment 

47 

Exhibit: 

Harmon testimony 3-3-09 attachments.pdf 

Response:

A set of graphs and tables attached to Harmon testimony 3-3-09. This reference does 

not provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

48 

Exhibit: 

Harmon Testimony 3-3-09.pdf 

Harmon, M.E. 2009. Testimony Before the Subcommittee on National Parks, Forests, and 

Public Lands of the Committee of Natural Resources for an oversight hearing on “The Role 

of Federal Lands in Combating Climate Change” 

Response:

This is testimony before a congressional subcommittee from a forest science professor. 

He presents his opinion about how carbon sequestration should be analyzed and 

which management strategies might be successful. This reference does not provide 

science that opposes methods proposed in the Cobbler II project.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-118

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

49 

Exhibit: 

IMPA#MDY.DOC 

Response: 

Impact of skidding traffic on bulk density and penetration resistance of two sandy 

forest soils was examined in Putte (the Netherlands).... designated skid trails should 

also on this soil type be used to minimize the influence on the ecosystem.” 

Results are consistent with effects disclosed in the FEIS, Chapter 3, pp. 3-6 to 3-10. 

Paper appears to support use of designated skid trails, consistent with Cobbler II 

project design features (FEIS, Chapter 2, Table 2-6). This reference does not provide 

science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

50 

Exhibit: 

Insects and natural cycles.pdf 

Schowalter, T.D. Ecosystems: concepts, analyses and practical implications in IPM 

Response: 

This chapter from an unnamed book is about insect dynamics, primarily in 

agricultural systems. There are concepts that apply to forest systems that are similar 

to those in Schmitt 2010, Upland Moist Forests and Associated Insect Disturbances in 

the Blue Mountains: Supporting Science for Management Action, including “Host 

plant density and stress are two major factors affecting insect populations”. This 

reference does not provide science that opposes methods proposed in the Cobbler II 

project. 

SC 

Attachment 

51 

Exhibit: 

Insects trees climate sound.pdf 

Dunn, D. 2006. Insects, Trees, and Climate: The Bioacoustic Ecology of Deforestation 

and Entomogenic Climate Change. Santa Fe Institute Working Paper 

Response: 

Authors examine link between deforestation, climate change, and forest insects. They 

suggest that, in addition to communication through chemicals among insects (and 

probably between trees and insects), there may be bioacoustical signals being 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-119

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

produced by insects and trees which can be recognized by insects. They recommend 

more research into it, as another way to understand and manage insect population 

dynamics. This reference does not provide science that opposes methods proposed in 

the Cobbler II project. 

SC 

Attachment 

52 

Exhibit: 

IVFO#ZGK.PDF 

Response:

Information literature on the Sierra Club’s interests, activities, and beliefs.

SC 

Attachment 

53 

Exhibit: 

Jonasova_and_Prach_2004.pdf 

Jonasova and Prach. 2004. Central-European mountain spruce (Picea abies (L.) Karst.) 

forests: regeneration of tree species after a bark beetle outbreak. Ecological Engineering 

23 (2004) 15–27 

Response:

The biophysical environment and ecological interactions described in this paper are 

not similar enough to Cobbler II to provide useful science. This reference does not 

provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

54 

Exhibit: 

Jurgensen_et_al_1997.pdf 

Response: 

This paper is cited in the Cobbler II analysis and commonly on the Umatilla National 

Forest for soil resource discussion and balancing of treatments for various needs and 

associated soil impacts. 

Authors discuss potential effects of mechanical treatments and fuels reduction on soils 

in forested stands, but conclude that these activities can be conducted with minimal 

impacts. 

This reference provides information that is consistent with disclosures in the FEIS, 

Chapter 3, pp. 3-6 to 3-9. This reference does not provide science that opposes 

methods proposed in the Cobbler II project.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-120

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

55 

Exhibit: 

kauffmanet al 2004 Eco Apps livestock MFJD.pdf 

Response:

This paper discusses plant communities and soil properties of grazed and un-grazed 

dry and riparian meadows. Cobbler II project planning area is in part of the Eden 

C&H Allotment. The hydrology analysis discusses general effects of localized trailing 

and water sources. Proposed projects protect wet areas by avoidance, and offsite 

sedimentation would be negligible due to the designation and functioning of RHCAs. 

Effects of projects proposed in Cobbler II would not compound or otherwise 

cumulated with ongoing grazing effects. Evaluation of the effect of grazing on 

vegetation and soils of meadows in the Cobbler II project planning area is beyond the 

scope of the proposed project. 

SC 

Attachment 

56 

Exhibit: 

kotliar_et_al_07.pdf 

Response:

This paper provides an overview of studies concerning avian communities in post-fire 

and adjacent unburned forests. Avian observations from many studies were 

summarized showing the percentage of species found in burned and unburned 

environments including avian use by fire severity. Suggestions were included on ways 

to modify salvage logging to reduce impacts to avian species. 

The Cobbler II project is not a post-fire salvage project. This reference does not 

provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

57 

Exhibit: 

Kulakowski aspen-fire grand Mesa CO.pdf 

Kulakowski et al. 2004. The persistence of quaking aspen (Populous tremuloides) in the 

Grand Mesa area, Colorado. Ecological Applications, 14(5), 2004, pp. 1603–1614 

Response: 

This study compared a map of the current coverage of aspen stands with a map made 

in the late 1800s, in an area in the southern Rocky Mountains. The authors conclude 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-121

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

that there has not been a reduction of aspen in that area from that time. They caution 

against extrapolating these results to other areas without further research. 

SC 

Attachment 

58 

Exhibit: 

Littell et al 2009 fire climate.pdf 

Littell, J.S., et al. 2009. Climate and wildfire area burned in western U.S. ecoprovinces, 

1916-2003. Ecol. Appl. 19(4):1003-1021. 

Response: 

The authors demonstrate that wildfire area burned (WFAB) in the western U.S. was 

controlled largely by a few climate factors during the 20th century. They conclude 

that WFAB is still substantially controlled by climate, despite the possible influence of 

fire suppression, exclusion, or fuel treatment. They note that their findings do not 

address the severity of fires, just the area burned. This reference does not provide 

science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

59 

Exhibit: 

LOGG#45@.DOC 

Response:

This is not a peer reviewed paper, but rather a news article about a recently published 

review of previous literature. The publication itself talks very generally about “wet” 

forests and rainforests in Australia, Canada and the U.S. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. 

SC 

Attachment 

60 

Exhibit: 

Logging_to_Control_Insects.pdf 

Black, S.H. 2005. Logging to Control Insects: The Science and Myths Behind Managing

Forest Insect “Pests.” A Synthesis of Independently Reviewed Research. The Xerces 

Society for Invertebrate Conservation, Portland, OR. 

Response: 

This is a review report that contains statements that are not supported by the report’s 

cited literature. A major problem with the report is that it uses the term thinning 

without defining it, and uses the term logging to mean the same thing. The Cobbler II 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-122

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

analysis refers directly to the appropriate refereed or peer-reviewed literature and 

site-specific data, rather than popular review reports such as this. 

SC 

Attachment 

61 

Exhibit: 

MEIG#O3F.PDF 

Meigs et al. 2009. Forest Fire Impacts on Carbon Uptake, Storage, and Emission: The 

Role of Burn Severity in the Eastern Cascades, Oregon Ecosystems. Ecosystems 12: 

1246–1267 

Response:

Authors quantified the short-term effects of low, moderate, and high-severity fire on 

carbon pools and fluxes in the Eastern Cascades of Oregon. They found a high 

variability of C responses across the study area. They concluded that there is a need 

to account for landscape patterns of burn severity, particularly in regions such as the 

Pacific Northwest, where non-stand-replacement fire represents a large proportion of 

annual burned area. This reference does not provide science that opposes methods 

proposed in the Cobbler II project. 

SC 

Attachment 

62 

Exhibit: 

mistletoe map dnf rp.pdf 

Response: 

A map of an unknown area and project, showing mistletoe infection severity by tree 

size on some kind of grid. 

SC 

Attachment 

63 

Exhibit: 

MODE#HHA.PDF 

Ager, A., et al. 2007. Modeling wildfire risk to northern spotted owl (Strix occidentalis caurina) 

habitat in Central Oregon, USA 

Response: 

Paper discusses a probabilistic risk analysis system for quantifying wildfire threats to 

spotted owl habitat and comparing the efficacy of fuel treatment scenarios. Authors 

disclosed that “The intent was to demonstrate that substantial reduction in wildfire 

risk as measured by probabilities or expected habitat loss can be realized by 

strategically locating treatments to reduce fire spread to spotted owl habitat stands. 

Application of spatial treatment optimization (Finney, 2006), and allowing treatments 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-123

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

within spotted owl habitat in the present study would have substantially decreased the 

expected habitat loss at a given treatment intensity.” 

There is no spotted owl habitat in Cobbler II project planning area. This reference 

does not provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

64 

Exhibit: 

Mycorrhiza - Fujimura 2005.pdf 

Response:

Paper examines effects to specific genera of mycorrhizae from prescribed fire. This 

reference does not provide science that opposes methods proposed in the Cobbler II 

project.

SC 

Attachment 

65 

Exhibit: 

NEPA Anniversary Proclamation.pdf 

Response:

Letter from the President of the U.S. proclaiming the 40th anniversary of the NEPA.

SC 

Attachment 

66 

Exhibit: 

nfma regs order1.pdf 

Response: 

Legal documents regarding Forest Plans – Citizens for Better Forestry et al. vs. 

USDA. 

SC 

Attachment 

67 

Exhibit: 

NITR#1I9.DOC 

Response:

This study describes nitrogen and soil respiration levels from several ages of post 

wildfire stands in Michigan. This reference does not provide science that opposes 

methods proposed in the Cobbler II project.

SC 

Attachment 

68 

Exhibit: 

Obama Order on Scientific Integrity.pdf 

Response:

Memo from the President dated March 9, 2009 identifying his expectations designed 

to guarantee scientific integrity throughout the executive branch.
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-124

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

69 

Exhibit: 

PACI#~T@.DOC 

Stephens et al. 2010. Pacific Northwest Forests Tops at Storing Carbon. 

Wilderness Society analysis names top ten national forest “carbon banks” Press release: 

Thursday, March 4, 2010. This press release presents the results of an undescribed analysis 

by the Wilderness Society that say that the top ten carbon storing national forests in the 

U.S. are all found in the moist westside forests in Washington, Oregon and southeast 

Alaska. 

Response: 

This is a press release that presents the results of an undescribed analysis by the 

Wilderness Society that say that the top ten carbon storing national forests in the U.S. 

are all found in the moist westside forests in Washington, Oregon and southeast 

Alaska. This reference does not provide science that opposes methods proposed in the 

Cobbler II project. The Umatilla National Forest is not named as one of these 

forests. 

SC 

Attachment 

70 

Exhibit: 

Restoring Forest Wildlands - AR 3-09.pdf 

Response:

Opinion essay. 

SC 

Attachment 

71 

Exhibit: 

ROCC#HLK.PDF 

Rocca, M.E. and W.H. Romme. Beetle infested forests are not “destroyed.”

www.frontiersinecology.org

Response: 

This is a letter to an online journal. The authors offer the opinion that beetle-killed 

lodgepole forests in Colorado are not destroyed, and that actual areas of 100% 

mortality are fairly rare and typically small. They suggest that research should 

concentrate on actually quantifying extent and degree of mortality to inform 

knowledge base on insect outbreaks, whether current outbreaks are within historic 

range, and relationship to climate change. This reference does not provide science 

that opposes methods proposed in the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-125

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

72 

Exhibit: 

RommeEtAl_InsectsFireRisk_CFRI_061.pdf 

Romme, W.H., et al. Recent Forest Insect Outbreaks and Fire Risk in Colorado Forests: A 

Brief Synthesis of Relevant Research. 

Response: 

Authors conclude that: “Removing stressed or unhealthy trees, and thinning to 

prevent crowding and competition among trees, can effectively reduce the risk of an 

insect outbreak getting started in a forest stand,” but also indicate that forest 

management can’t prevent all insect outbreaks or stop outbreaks once they begin. 

This reference appears to support conclusions and information in Chapter 3 of the 

Cobbler II FEIS. This reference does not provide science that opposes methods 

proposed in the Cobbler II project. 

SC 

Attachment 

73 

Exhibit: 

Schoennagel_2009_PNAS_NFP WUI W.pdf 

Response:

Authors examined what percentage of fuels reduction projects have been 

implemented in wildland-urban interface under the National Fire Plan. 

The Cobbler II project’s purpose and need does not include protection of private 

property or reduction of fuels in the WUI. This reference does not provide science 

that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

74 

Exhibit: 

SchoennagelEtAl_SubalpineFireColo_Ecol071.pdf 

Schoenaggel, T., et al. 2007. Multidecadal climate variability and climate interactions 

affect subalpine fire occurrence, western Colorado (USA). Ecology, 88(11):2891–2902.

Response: 

Authors studied fire frequency in relation to climate fluctuations over several 

centuries. They conclude that we may expect higher fire frequency due to climate 

cycles such as El Nino, with uncertainty about the effects of possible climate change 

from increased carbon. This reference appears to support the purpose and need 

identified in the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-126

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

75 

Exhibit: 

Sestrich_thesis_2005.pdf 

Response:

This thesis is a useful contribution to a growing body of scientific literature pertaining 

to effects of wildfire on salmonid fishes, particularly to recovery of salmonid 

populations after wildfire, and invasion of non-native species following wildfire. 

However, this research was specific to effects of, and following, wildfire and has no 

direct bearing on the Cobbler II project. The author does make some 

recommendations for forest management that might make fish populations more 

resilient in the face of catastrophic disturbances. The Cobbler II project is, by and 

large, compatible with those recommendations. 

SC 

Attachment 

76 

Exhibit: 

Shirley and Erickson_aspen restoration.pdf 

Response: 

The authors describe several methods of aspen restoration utilized in their study area, 

including conifer thinning, prescribed burning, and protecting young aspen from 

herbivory. Authors conclude that hardwood restoration is challenging without 

substantial reductions in herd sizes of native ungulates. This reference does not 

provide science that opposes methods proposed in the Cobbler II project. The 

methods of aspen restoration described in the article are similar to those proposed in 

Cobbler II, and support the need for a Forest Plan amendment to change Elk Flats 

Meadow from RNA to botanical Special Interest Area 

SC 

Attachment 

77 

Exhibit: 

Sierra forest soils post fire.doc 

Response:

This study examines differences in several soil processes and properties based on 

different seasons of the burn. This reference does not provide science that opposes 

methods proposed in the Cobbler II project. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-127

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

78 

Exhibit: 

Six Euro Studies on Soils.docx 

Response:

Several studies describing impacts of various harvest types in a variety of sites in 

Europe. Descriptions of soil impacts are consistent with expected disturbance types 

and levels as described in the FEIS, Chapter 3, pp. 3-6 to 3-9 and Appendix E.

SC 

Attachment 

79 

Exhibit: 

Soil Carbon Dynamics.doc 

Response:

A short description of a book that contains a standardized protocol for measuring soil 

CO2 efflux, designed to improve future assessments of regional and global patterns of 

soil carbon dynamics. This reference does not provide science that opposes methods 

proposed in the Cobbler II project.

SC 

Attachment 

80 

Exhibit: 

Temperature sensitivity of soil carbon.pdf 

Response: 

Discusses temperature sensitivity of soil organic carbon. This study points out a 

serious weakness in the current estimates of climate change effects on soil organic 

carbon (SOC). This reference does not provide science that opposes methods 

proposed in the Cobbler II project.

SC 

Attachment 

81 

Exhibit: 

The Myth of Catastrophic Wildfire, C. Hanson.pdf 

Response:

This document is an opinion piece that has not been published in a scientifically peer 

reviewed outlet. The Earth Island Institute is not a recognized scientific outlet with 

known and replicated quality assurance and quality control processes. The document 

and its findings have not been subjected to the rigors of formal technical or peer 

review. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-128

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

This reference does not provide science that opposes methods proposed in the Cobbler 

II project. 

SC 

Attachment 

82 

Exhibit: 

THER#BIJ.DOC 

Peppin D. 2009. The role of seeding in post-fire rehabilitation and opportunities for native 

plant production. M.S. Thesis (Peter Fulé, School of Forestry and Ecological Restoration 

Institute Northern Arizona University) 

Response: 

This reference does not pertain to the activities proposed in Cobbler II. 

SC 

Attachment 

83 

Exhibit: 

Thompson_Intgrtng_Sci_Fuel_Mgt_PNWSciFi_2008.pdf 

Response:

Non-scientific piece describing development of model to assess fire risk and 

effectiveness of fuels treatments (see Ager paper). This reference does not provide 

science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

84 

Exhibit: 

TIMB#32U.DOC 

Response:

Opinion article on the rebounding of the timber industry.

SC 

Attachment 

85 

Exhibit: 

Top-Ten-carbon-forests-analysis.pdf 

Wilderness Society March 2010 

Response:

This is an article about an analysis by the Wilderness Society, using an on-line

calculator and data from the US Forest Service, that says the top ten carbon storing 

national forests in the U.S. are all found in the moist westside forests in Washington, 

Oregon, and southeast Alaska. This reference does not provide science that opposes 

methods proposed in the Cobbler II project. The Umatilla National Forest is not 

named as one of these forests. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-129

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

SC 

Attachment 

86 

Exhibit: 

TRAI#6VJ.PDF 

Traill, et al. 2009. 

Response:

Paper indicates that in general, thousands of individuals are needed to sustain any 

population. “We recommend that conservation planners include demographic and 

genetic thresholds in their assessments.”This is not feasible or applicable to a small 

area such as the Cobbler II analysis area. 

SC 

Attachment 

87 

Exhibit: 

Tree diamaeter and beetles.pdf 

Cole, W.E., and Amman, G.D. 1969. Mountain Pine Beetle Infestations in Relation to 

Lodgepole Pine Diameters. USDA Forest Service Research Note INT-95. 

Response: 

A more recent article by the second author, Amman et al. 1984, is cited in the 

silviculture report for Cobbler II, in support of the proposed lodgepole pine 

management. Other publications cited are Koch 1996 and Fettig et al. 2007. Several 

reports from the Blue Mountain Forest Service entomologist and pathologist are also 

cited (Schmitt 2009b, Spiegel and Schmitt 2008 and 2009). Cole and Amman 1969 is 

an early publication describing that large diameter lodgepole pine trees are highly 

susceptible to, and maintain populations of, mountain pine beetle. This reference 

does not provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

88 

Exhibit: 

VIIE#_EA.PDF 

Response:

Information literature on the Sierra Club’s interests, activities, and beliefs. 

SC 

Attachment 

89 

Exhibit: 

White-headed Woodpeckers NC management abstract.doc 

Response:

Species Management Abstract by the Nature Conservancy dated 1999. Does not
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-130

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

contain the most recent science and does not contain new or conflicting science not 

already utilized in this EIS.

SC 

Attachment 

90 

Exhibit: 

WHYM#L#-.PDF 

Why Mean Composite Fire Intervals do not Estimate Fire Rotation or Mean Fire Interval at a Point 

William L. Baker, Program in Ecology and Dept. of Geography 

Dept. 3371, 1000 E. University Ave.,University of Wyoming 

Response:

Mean Composite Fire Intervals (CFI) does not estimate the fire rotation and is also an 

inappropriate measure to use in determining how often to prescribe burn across 

landscapes. The fire rotation and average mean fire interval are the rates that 

landscapes and points burned, and are the appropriate rates to use in comparing fire 

regimes, and for analysis, simulation, and to set prescribed burning goals. 

The composite fire interval was not used for analysis of effects in the Cobbler II 

project.

SC 

Attachment 

91 

Exhibit: 

Wildfire protection.doc 

Response:

This is not a peer reviewed paper, but rather an opinion story about the Healthy 

Forest Restoration Act and how it affects landowners’ attitudes toward reducing 

wildfire risk on their property. This reference does not provide science that opposes 

methods proposed in the Cobbler II project.

SC 

Attachment 

92 

Exhibit: 

WYDE#C31.PDF 

16 March 2010 “Dear President Obama and Members of Congress: 

As scientists conducting research in the fields of forest and fire ecology, we feel 

compelled to provide input to Congress when proposed legislation does not accurately

represent the current state of scientific knowledge. Some current bills, including the 

“Oregon Eastside Forests Restoration, Old Growth Protection, and Jobs Act of 2009”

(the “Act”), sponsored by Senator Ron Wyden (D-OR),...”

Response: 

This is apparently testimony or a letter sent to Congress concerning the opinions of 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-131

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

the authors about proposed legislation. It is not peer reviewed science. This reference 

does not provide science that opposes methods proposed in the Cobbler II project. 

SC 

Attachment 

93 

Exhibit: 

CATA#CJH.DOC 

Rumbaitis del Rio, C.M. Changes in understory composition following catastrophic 

windthrow and salvage logging in a subalpine forest ecosystem. Can. J. For. Res. 36(11): 

2943–2954 

Response: 

Reference relates to salvage harvest following severe windthrow events. The Cobbler 

II project does not propose salvage, and no severe windthrow event has occurred in 

the project area. This reference does not provide science that opposes methods 

proposed in the Cobbler II project.

SC 

Attachment 

94 

Exhibit: 

Forest Growing Season Adaptations & Roles.doc 

Kuparinen, A. 2010. 

Response: 

This appears to be a public notice about the publication of an article about computer 

simulations of forests in Finland, not a scientific experiment. The results indicate the 

trees currently living in an area there are genetically adapted to the past climate, and 

they have to die and be replaced by a new generation for the population to evolve for 

climate change. This reference does not provide science that opposes methods 

proposed in the Cobbler II project.

SC 

Attachment 

95 

Exhibit: 

Forest Restoration - hydrology & soils impacts.doc 

Response:

This essay discusses a variety of concerns; About 0.2 miles of temporary road is 

proposed in this project, the location is not connected to the stream network and it 

would be decommissioned to prevent localized erosion and future use. Few landings 

would be needed due to proposed logging systems, road maintenance would correct 

problematic drainage reducing risk of high erosion events associated with rapid 

runoff and reduce ongoing erosion and sedimentation. Design criteria (Table 2-6), 

BMPs (Appendix D), and PACFISH RHCAs will protect surface waters from 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-132

Letter #7 (SC) - ATTACHMENTS 

Asante Riverwind – Oregon Chapter Sierra Club 

Karen Coulter – League of Wilderness Defenders – Blue Mountain Biodiversity Project 

Jennifer Schwartz – Hells Canyon Preservation Council 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their 

entirety are located in the project file. 

• This compilation of research, reports, case law, and conservation issues does not reference 

specific elements, statements, or questions that are to be considered with this project. 

• Numerous Exhibits to post-fire logging were not considered because this project does not 

propose any post-fire salvage logging. 

• Exhibits that were opinion pieces and those referencing specific geographical areas were not 

considered. 

• Responses to Exhibits previously submitted are located in Appendix G of this document pages 

G-178 to G-192. 

sedimentation.

SC 

Attachment 

96 

Exhibit: 

TROP#DZB.PDF 

Response:

Paper regarding post-fire logging, not applicable to Cobbler II project. 

Letter #8 (EPA) 

Christine B. Reichgott – U. S. EPA Region 10 

Comment 

Number Comment and Response 

EPA-1 Comment:

Components of your project which we especially support include the following: 

• Careful consideration of impacts from project activities in Riparian Habitat 

Conservation Areas (RHCAs) – along with your proposal to avoid harvest in 

RHCAs. 

• Your plans to increase the amount of Old Forest within the Historical Range of

Variation (HRV) as well as your intention to avoid activities in designated C1-

Dedicated Old Growth management areas. 

• Project specific mitigation measures for Bolander’s Spikerush, a sensitive species. 

Response:

Thank you for your supportive comments. 

EPA-2 Comment: 

We agree that managing and maintaining desired HRV and Fire Regime Condition Class 

goals – without assistance of natural fires – requires continuous activity (DEIS, G-124), to 

more fully disclose and consider the implications of a forest management strategy which 

requires continuous activity, we recommend the Final EIS discuss the likely frequency and 

intensity of future activities which would be required to maintain project achievements. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

I-133

Letter #8 (EPA) 

Christine B. Reichgott – U. S. EPA Region 10 

Comment 

Number Comment and Response 

Response:

The frequency and intensity of potential future fuels treatments would be dependent 

on the conditions in stands following treatments proposed here in this project. It is 

difficult to determine specifically what kind of maintenance would be required and 

where it would be required without seeing the finished product of these treatments. 

Typical follow up treatments would include thinning of understory ladder fuels, 

mastication and or grapple piling of activity fuels and prescribed fire to reduce 

natural and activity generated fuels. These treatments would likely need to occur in 

another 15-20 years, when ladder fuels would have regenerated and grown up under 

the crowns of older, larger trees. These future treatments would again be analyzed 

through the NEPA process, requiring further, more detailed assessment of conditions 

and effects of proposed activity at that time. 

EPA-3 Comment: 

We recommend that the Final EIS discuss how this Project’s construction of new 

temporary and permanent roads (even if they are short segments) is consistent with the 

intent of the Final Travel Management Rule (especially sub-part A). 

Response:

There is consistency with the Final Travel Management rule (36 CFR parts 212) for 

temporary and permanent road construction. Both are defined and discussed in the 

final rule and are accepted activities. 

EPA-4 Comment:

We appreciate your well researched section on climate change. 

Response:

Your comment has been noted.