APPENDIX G 

RESPONSE TO COMMENTS 

MAY 2009 EA 

 
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INTRODUCTION 

A 30-day comment period for Cobbler Timber Sale and Fuels Reduction Project was provided for interested and affected pappropriate local, state, and federal government agencies, and Tribes. Letters requesting comments were sent to the mailinparties maintained at the Umatilla National Forest Supervisor’s Office on January 23, 2009. They included federal, state anConfederated Tribes of the Umatilla Indian Reservation, Nez Perce Indian Tribe, various environmental organizations, and (see project file for mailing list). A legal notice in our newspaper of record (East Oregonian) requesting comments was published on January 28, 2009, and l27, 2009. The Forest Service received comments from different sectors of the public, with a range of concerns and commenofficial will be considering the comments made in the decision-making process. The Forest Service received 3 responses during the 30-day comment period. Responses were received electronically and wMail. All correspondence was reviewed and our response to comments made is located later in this section. The complete is kept in the project file and is available for review at the Pomeroy Ranger District office in Pomeroy, Washington. The following table is a summary of letters received. 

Letters Received During the 30-day Comment Period for the May 2009 EA 

Letter Identification Number 

and 

Date Received 

Author(s) 

Individ

Organization 

Letter #1 

January 26, 2009 John Fullerton Boise Bu

Letter # 2 – with attachments 2, 

3, 5 and 6 

February 5, 2009 

Richard Artley Individ

Letter # 3 with Exhibit A 

attached 

February 27, 2009 

Asante Riverwind 

Oregon Chapter 

Hells Canyon Prese

League of Wildernes

Mountains Biodiv
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Comments and Forest Service Response to Comm

May 2009 EA 

LETTER #1 

JOHN FULLERTON – BOISE BUILDING 

Comment Our Response 

Letter 1 – Comment 1

The purpose and need is appropriate for this area and that should be the focus of the project. Reducing stand densities, moving forests to more historic ranges and creating healthy forests is what this project was designed to accomplish.

Your comment has been noted. 

Letter 1 – Comment 2

Alternative C does not address these goals fully and should not be considered; only the preferred alternative will fully address the issues mentioned in the purpose and need.

Your comment has been noted. 

Letter 1 – Comment 3

I would suggest 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. 

Both of these suggestions are being done. Smcruised separately from large material and wtimber sale. Thinning was considered in stanand are in Forest Plan management areas whallowed. 

Letter 1 – Comment 4

Although the project has to make some sacrifices to achieve its intent, it is overall the best action for the area, as limited short term impacts must be accepted to achieve long term goals which indecently will be mitigated. 

Your comment has been noted. 
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LETTER #2 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Comment 1

Issue #1 -- Stand Growth and Vigor? The BACKGROUND section in Chapter 1, on page 1-2 states: “Forest stands have become overstocked and are above recommended stocking levels that would maintain stand growth and vigor.” My reaction to thisis “so what.” The vast majority of foresters and silviculturists in the Forest Service went to college at land grant colleges dependant on timber industry donations. In return, these land grant colleges taught the forestry students industrial forestry. Any and all forest ecology courses were unheard of.The students graduated from college ready to manage private industrial tree farms not real forests. Unfortunately, the US Forest Service began hiring these foresters in the late 1960s. Foresters (as a percentage of the total workforce) increased from there. In the 1980s, these industrial foresters began being promoted to line-officers. Then, large scale conversion from wild, biodiverse forests to industrial tree farms was the thing to do in the Forest Service. The only people whose objective for their forest should be increased stand growth and vigor are employees of large timber corporations with their own timberland. Many species of wildlife will not survive in vigorous, fast growing forests. 

The project planning area has been altered frconditions due to fire suppression and past fopractices. A majority of current forest stands 

of fire disturbances occurring over one hundrthey have not experienced fire since then. Threpeated insect defoliation episodes followed Lodgepole pine stands have been harvested, amature stands in the project planning area arhighly susceptible to mountain pine beetle, whexperiencing an increasing population. Late 

become dominant after long periods without generally are more susceptible to disturbancethan early seral species. Forest stands have band are above recommended stocking levels tstand growth and vigor. Timber stands of serwestern larch and ponderosa pine are infillinFindings from the historical range of variabilEastside Screens show that old forest structurrange for moist forest biophysical group, but range for dry forest biophysical group in old (OFSS) structural stage. (Chapter 1 – page 1As required under the “Eastside Screens” anForest Plan. areas of heavily stocked stands aunthinned as wildlife cover. (See Appendix F 

Eastside Screens. 

Letter 2 – Comment 2

Issue #2 – You claim that your Logging and Road Construction will “improve the health” 

Contrasting the existing condition of the proj

the desired future condition identified in the FWalla Ranger Districted identified the purpoand identified in the proposed action how thethe need for action. 
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LETTER #2 

RICHARD ARTLEY 

Comment Our Response 

Your plan to log 2,500 acres (mostly tractor) and construct 0.45 miles of road and then tell the public that it will cause the forest to be healthier is a lie and a travesty! 

Summarized statements of the purpose and nChapter 1, page 1-4. Approximately 0.25 miles of road constructiowould become a closed road after project actiroad construction (0.20 miles) would be decom(Chapter 2, page 2-16). See Chapter 3 for environmental effects analyactivities by resource specialists and literatur

to L-13) used by specialists in their analysis. 

Letter 2 – Comment 3

Issue #3 – Your P&N Statements are False or Reflect a Lack of Knowledge You claim your timber sale is needed to increase forest vigor – See write-up for issue #1. You claim your timber sale is needed to increase the forest’s resilience to fire Forests are supposed to Burn. If you would have listened during your fire ecology classes in college, you would know that the natural resources in a forest benefit from fire. A forest is infinitely more than a collection of trees waiting on the stump to be logged. There is a reason that fire comes from the sky during the hottest, driest time of the year. See science Attachment #5. Also, unbiased, independent scientists nationwide agree that commercial logging increases wildfire severity. See science Attachment #2. Anyone with even basic knowledge about the benefits of a wildfire to a forest ecosystem far removed from the WUI would not even suggest that the forest be roaded and logged to prevent a fire! 

See response to Letter 2- Comment 1. Fire regime condition classes, which describe natural fire regimes in terms of fire return in

change from historical composition and densimodified in the project planning area due mahistory and fire suppression. Approximately project planning area has changed from a his(Class 1) to a moderately altered fire regime (percent of the area has changed to a significaregime (Class 3). Fuels that would have histo

during periodic wildfires have increased, and and aerial (within the canopy) fuel loadings alevels. Today, fires in the dry and moist foresmoderate to severe effects characterized by hintensity on landscapes that historically displseverity. Without treatment, the Cobbler prowould continue to transition toward condition and 3, where the risk of losing ecosystem commoderate to high. Surface fuel loads would ctree density and canopy layering would also ismall trees would serve as ladders that carry 
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LETTER #2 

RICHARD ARTLEY 

Comment Our Response 

You claim your timber sale is needed to increase the forest’s resilience to insects and disease. My first reaction is Duh. Do you even have a degree in forestry? Once again, insects and disease in trees represent a disturbance event that benefits countless other natural resources in a forest. You appear to be trying to change your forest’s characteristics such that it is neat, tidy and park-like. If you are successful, you forest will no longer have a functional biodiverse forest. Yes, insects and tree diseases kill some trees. So what. Any healthy population requires that some individuals of the total population be unhealthy and die. Without trees dying from disease the insects would not be attracted to the trees. Without insects in trees, cavity-nesting birds would have no habitat. When these trees finally do die, they will fall to the ground, decompose and replenish the organic in the soil. 

floor to the tree canopy, increasing the likelihstand-replacement fires. Fire ignitions today 

a natural disturbance process within their hisvariability pertaining to fire size, frequency, ilandscape patterns. Fuel loads in Grande Roincreasing primarily due to the lack of fire in behavior fuel models that describe how a fire 

length and rate of spread) through a particulhave also changed in the project planning arefrom historical fire behavior fuel models of fa

intensity surface fire, to fuel models represen

intensity crown-replacement fire. (Chapter 1, See Chapter 3, Vegetation, pp. 3-42 to 3-57. This project does not have an objective of wipdisease activity. Previous management, espechas caused a shift in species composition and number of layers in many stands that have crwhere the current levels of activity and suscep

than in historical times. One of the objectiveshift species composition back to closer to hisChapter 3, Table 3-22, Cover Type HRV whiseral species are below HRV and late seral spin both Moist and Dry Forest areas. Chaptelevels of potential insect and disease occurren

area, and additional maps in Appendix B of tspecialist’s report show current and previous 

areas (project file). 

Letter 2 – Comment 4

Issue #4 – Your proposed Forest Plan Amendment The Forest Plan is a contract with the public. This contract must not be 

In the project planning area there are 23 sites acres) of hardwood stands (aspen, mountain mcottonwood) that need management in order have stand vigor restored. One of the sites ne
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LETTER #2 

RICHARD ARTLEY 

Comment Our Response 

violated except under extraordinary circumstances. In Chapter 1, page 1-8 you say your FP amendment will decrease the project area acres in MA D2 (Research Natural Area) by 80 acres and decrease the project area acres in MA E2 (Timber and Big Game) by 20 acres “in order to allow vegetation management, including cutting of trees.” This statement comes straight from the pen of a “timber beast.” The most troubling change is to remove 80 acres from MA D2. Ranger Rassbach and supervisor Martin, neither of you know the purpose of designating a RNA in the first place. The RNA program was created to: 1. preserve examples of all significant natural ecosystems for comparison with those influenced by man, 2. provide educational and research areas for ecological and environmental studies, and  3. preserve gene pools of typical and endangered plants and animals. This means they should be left alone to study the ecological changes occurring in the Area (whether the changes appear to be good or bad)! 

located in the Elk Flats Meadow area (approxwhich is currently allocated in Umatilla Foresarea D2 – Research Natural Area (RNA) as a for RNA status to represent an aspen forest. Blue Mountain’s Forest Ecologist, after compPlan (1990), indicated that formal RNA desigappropriate for Elk Flats Meadow because of 

parcel, and because the aspen clones are ecotbetween forest and meadow) rather than true 

1, p. 1-3). 

Elk Flats meadow would be changed to Fores

area A9 – Special Interest Area with the Fore

Manage, preserve, and interpret areas of signifhistorical, geological, botanical, or other specia

educational, scientific, and public enjoyment p

The desired condition for management area A

for which the areas are recognized shall providrecreation opportunities for public use and enjfeatures will remain in a substantially undistur4-132).See Chapter 3, Vegetation, pp. 3-48 to 3-49 an

Letter 2 – Comment 5

Issue #5 – Forests are Supposed to Burn After reading your scoping notice I can say with complete confidence that you are proposing these projects to reduce wildfire in the forest. If you would have listened during your fire ecology classes in college, you would know that the natural resources in a forest benefit from fire! Ranger Rassbach, a forest is infinitely more than a collection of trees 

See response to Letter 2 – Comment 3. 
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LETTER #2 

RICHARD ARTLEY 

Comment Our Response 

waiting on the stump to be logged. There is a reason that fire comes from the sky during the hottest, driest time of the year. See science Attachment #5. Anyone with even basic knowledge about the benefits of a wildfire to a forest ecosystem far removed from the WUI wound not even suggest that the forest be roaded and logged to prevent a fire! Letter 2 – Comment 6

Issue #6 – Mark Rey Did anyone really think that a prior timber lobbyist could be put in charge of the Forest Service and proceed with motivation centered around protection and preservation of forest resources?

Your comment has been noted. 

Letter 2 – Comment 7

If you haven’t figured it out from reading this letter, I am outraged that you use fuels reduction and forest health as an excuse to turn the skidders loose. 

Your comment has been noted. 

Letter 2 – Comment 8

I demand that you publish a legal notice in your newspaper of record telling the public that this project is being withdrawn. Writing an honest FONSI on this project will be impossible, so if you refuse to withdraw your tragic project, I will expect to comment on your pending DEIS.

Your comment has been noted. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 1

 “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.” 

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” 

Published by the Portland Independent Media Center, August 2002. 

http://portland.indymedia.org/en/2002/08/17464.shtml

Opinion statement – not science. 

Letter 2 – Attachment 2 – Comment 2

“Despite what the commercial logging industry and the Bush administration claim, these same interests are engaged in a devious attempt to trick the public into supporting increased logging in the name of "fuel reduction projects." Those pushing this "Healthy" Forest Initiative stress the urgency with which "thinning" projects must occur. The reason for the urgency is because they are cynical. They know that the window of time for the public to react to their propaganda is short and so they must make the most of it while they can. While the health of our public forests is pressing and urgent, the real danger is not forestfire. The real danger is the lasting damage we will do to our forests ifwe do not implement a forest policy that reflects sound science. Commercial thinning is not the way for us to improve forest health; we will lose the integrity of some of the last remaining public forests if that is the approach that we chose.” The increased proximity between homes and forestland has created a situation where rural homes are at great risk when fire breaks out. However, studies have shown that the most important factor in 

Opinion statement – not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

determining the susceptibility of a home to burn is the existence of trees within a close proximity of the home. Statistics show that as long as certain fire reduction guidelines are followed at the local level of each home, the risk for ignitability during a fire occurrence is very low. Jack D. Cohen, a scientist working for the Forest Service has written studies documenting the risk reduction of home ignitability. Cohen has concluded that remote thinning projects can do little to protect homes from wildfire. Instead, he recommends that the only way to reduce the risk is to remove trees near homes. The initiatives proposed by Bush do little to encourage these measures. Instead, the focus is placed on logging of remote areas that will likely have little effect on the protection of homes from fire.” Bartha, Emily. 2002. “The Real Threat to Our Public Forests?Unsound Science & Cynical Scare Tactics” http://www.crag.org/content/index.txtLetter 2 – Attachment 2 – Comment 3

 “We need to accept that in many areas throughout the region, past forest management may have set the stage for fires larger and more intense than have occurred in at least the last few hundred years.” 

Beschta, R.L. Ph.D. et.al, 1995 “Wildfire and Salvage Logging“ 

http://www.saveamericasforests.org/congress/Fire/Beschta-report.htm

N/A - taken out of context. Statement is trueclearcutting and plantations and failure to adactivity fuels. 

Letter 2 – Attachment 2 – Comment 4

 “But decades of well-intentioned efforts to squelch wildfires, selective logging that removed the most fire-proof trees for commercial sale and a century of rapid development throughout the American West have left millions of public acres and thousands of communities at risk.” 

Bonné, Jon. “Man’s meddling worsens wildfires.”MSNBC news 

http://www.msnbc.msn.com/id/3072191/

Opinion statement – refers to past logging pr
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 5 “The fledgling U.S. Forest Service and its predecessors saw fire as a problem that destroyed far more natural resources than logging, Pyne said. When the Forest Service gained control of the national forests in 1905, its mission was to completely stop wildfire.” “Conference panelist and University of Montana professor James Burchfield said the public is no longer willing to buy the idea that trees are simply fuel for wildfire.” " ‘We've got to be really careful that we don't talk about healthy forests as all thinned forests,’ he said.” 

Boone, Rebecca, Associated Press “Wildfire not a menace, expert 

tells foresters”Deseret News, Nov 22, 2004

http://findarticles.com/p/articles/mi_qn4188/is_20041122/ai_n11490597

Opinion statement– not science. 

Letter 2 – Attachment 2 – Comment 6

 “... there is a growing body of research that finds mechanical thinning alone (logging) is seldom effective at stopping or even reducing fire intensity under severe fire conditions. Even if fuels reduction were the goal, it can be accomplished without the environmental impacts that come with logging.” 

“California: Too often thinning treatments tend to increase fire 

hazards.”Forest Policy Research

http://forestpolicyresearch.org/2008/12/19/california-too-oftenthinning-treatments-tend-to-increase-fire-hazards/

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 7

 “Why isn’t it true that ‘the more wood removed the better’? Why should ‘big, old’ trees be retained? First, larger-diameter woody materials do not pose a significant threat for wildfire ignition or spread. It is largely the finer fuels (a few inches and less in diameter) that carry fire. More important, large, old trees actually provide protection from fire spread because they are resistant to fire and their shade maintains favorable moisture conditions in the understory fuels. Too much thinning of the forest canopy can produce more rapid drying of such fuels and, thereby, more frequent and severe wildfire risk. Furthermore, ig, old trees provide critical habitat and maintain key ecosystem functions.” 

Christensen, Norman L. Jr., Ph.D., Testimony beforethe Senate 

Committee on Agriculture, Nutrition and Forestryregarding H.R. 

1904—the Healthy Forests Restoration Act of 2003 June 26, 2003 

http://wwwpaztcn.wr.usgs.gov/fire/hr_1904_testimony_christensen.pdf

This citation does not come from a peer-revie

Letter 2 – Attachment 2 – Comment 8

 “These results suggest that to reduce ignitions, the distances from a structure for managing vegetation are much smaller than the lofting distances for firebrands. Thus, beyond some relatively short distance from the structure (depending on the vegetation and topography), vegetation management has no significant benefit for reducing flame generated ignitions. Vegetation management, on the other hand, cannot be extensive enough, in a practical sense, to significantly reduce firebrand ignitions. Therefore, the structure and its immediate surroundings should be the focus for activities intended for improving ignition risk.” 

This statement is true and is well known by o
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“In high-density residential areas containing highly flammable structures (e.g., residences with flammable roofs), vegetation management may not be sufficient to prevent widespread fire destruction.” (pg. 92) 

Cohen, Jack D. Ph.D. 2003. “Structure Ignition Assessment Model 

(SIAM)”USDA Forest Service Gen. Tech. Rep. PSW-GTR-158. 1995.

http://www.fs.fed.us/psw/publications/documents/psw_gtr158/psw_gtr1

58_05_cohen.pdf

Letter 2 – Attachment 2 – Comment 9

 “Logging slash was generally left where it fell creating abnormal fuel loads in these dry forests. Thus, the potential for future epidemics of insects and disease and more destructive fires was becoming established.” “Extensive railroad logging throughout the [inland West] region created dangerous levels of dry logging slash resulting in extreme fire hazard. For example, in 1931 on the Boise National Forest, stand-destroying wildfire burned 62,000 acres of ponderosa pine/Douglas-fir forest that 

had previously experienced only surface fires for, at the least, 300 years. Observers attributed the intensity of this fire to the large volume of slash created by railroad logging in the late 1920s.” 

Covington, W.W. et. al, 1994. “Historical and anticipated changes

in forest ecosystems of the inland West of the United States.” 

http://www.haworthpress.com/store/ArticleAbstract.asp?sid=S8X5JW

WVNUDC9PX372R6E0C9FDDK9Q5D&ID=76732

We treat our logging slash. See Chapter 2, Alternatives Considered in Deand please note Chapter 2, Table 2-6 – Design Management Requirements, pp. 2-21 to 2-28. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 10

 “Some land managers and forest scientists advocate the widespread useof silvicultural treatments (of which thinning is the most widely proposed harvest-based fuels reduction method) in western roadless areas to reduce fuel loads and tree stocking levels, and thereby decrease the probability of large, intense fires. Although thinning within the context of intensive forestry is not new, its efficacy as a tool for fire hazard reduction at the landscape scale is controversial, largely unsubstantiated, and fundamentally experimental in nature thereby requiring caution particularly when applied across large landscapes.” (FEMAT 1993, Henjum et al. 1994, DellaSala et al. 1995, SNEP 1996, USDA Forest Service 2000) “There have been only a few empirical studies that have tested the relationship between thinning or fuels treatment and fire behavior on even a limited basis. In spite of hypothesized benefits, these studies, as well as anecdotal information and analysis of recent fires, suggest that thinning treatments have highly variable results. In some instances, thinning treatments intended to reduce fire hazard appear to have the opposite effect (Huff et al. 1995, van Wagtendonk 1996, Weatherspoon 1996). Such treatments may reduce fuel loads, but they also allow more solar radiation and wind to reach the forest floor. The net effect is usually reduced fuel moisture and increased flammability.” (Countryman 1955, Agee 1997) 

DellaSala, Dominick A. Ph.D. and Evan Frost. 2001 

“A Comprehensive Strategy for Roadless Area Cconservation

and Fuels Reduction in Priority Areas” 

http://www.kettlerange.org/salvagelogging/DellaSala&Frost_Comprehensive_Strategy.html

While true that thinning can increase surface reduce relative humidity and wind speeds, effvariable and depend on specific prescriptions positions. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 11

 “Fresh, dry slash of any species makes a high-intensity, unapproachable fire. A fire started in dry, fresh slash can become uncontrollable in seconds.” (pg.12) "It appears significant that many large fires in the western United States have burned almost exclusively in slash. Some of these fires have stopped when they reached uncut timber; none has come to attention that started in green timber and stopped when it reached a slash area." (pg. 14) 

Fahnestock, G.R. 1968. "Fire hazard from pre-commercially 

thinningponderosa pine." Research Paper 57, USDA, Forest Service.

http://www.fs.fed.us/pnw/pubs/journals/pnw_1968_fahnestock001.pdf

This report reflects outdated science. Stated known by our fuels managers and are the reaactivity fuels as a connected action. 

Letter 2 – Attachment 2 – Comment 12

 “The Bush administration has announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, ratherthan just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.” 

FOREST CONSERVATION NEWS TODAY, August 27, 2002 

“Bush Fire Policy: Clearing Forests So They Do Not Burn” 

http://forests.org/archived_site/today/recent/2002/tiporefl.htm

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 13

 “It is well known scientifically that "commercial logging actually increases fire severity by removing large, fire- resistant trees and leaving behind very small trees and flammable "slash debris"--branches, twigs and needles from felled trees. The removal of mature trees also decreases the forest canopy, creating hotter, drier conditions on the ground. The additional sun exposure encourages the growth of flammable brush and weeds. Reduction of flammable underbrush can reduce fire severity, and environmental groups have encouraged such projects. However, the Bush administration has grossly misused the funds that Congress appropriated for brush reduction near homes. In Sierra Nevada national forests last year, more than 90% of these fundswere instead earmarked for preparation of large timber sales focused on the removal of mature and old-growth trees miles from the nearest town." "’The Forest Service, Bush administration and anti-environmental members of Congress are spreading a great deal of misinformation about wildfire, hoping to capitalize on public fire hysteria and minimize public opposition to increased logging and roadbuilding in our national forests," said Jake Kreilick of the National Forest Protection Alliance based in Missoula, Montana. "With virtually all new timber sales couched in terms of 'reducing fuels' or 'restoring forest health,' fire hysteria has emerged as the driving force behind the Forest Service's logging program and the administration's efforts to 'streamline' our nation's environmental laws,’” Kreilick said. 

Forests.org, OVERVIEW & COMMENTARY, July 20, 2002 

http://portland.indymedia.org/en/2002/08/17464.shtml

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 14

 “Within the fire management community, widespread agreement exists for the use of landscape-scale prescribed burning to accomplish this task (reduce fuels hazards). However, within the U.S. Forest Service, there has been more of an interest in mechanical fuels reduction treatments using commercial thinning for fuelbreak construction to lower the risk of crownfires. Proponents argue that using commercial thinning to reduce canopy densities would increase firefighter safety and prescribed fire efficiency during wildfire suppression, and are necessary treatments to prepare for future prescribed burning. However, we suggest that theses kind of mechanical treatments create their own fire risks and fuel hazards that can potentially cause problems for wildland firefighter safety and prescribed fire efficacy.”  “We question the assumption that canopy fuel reduction through commercial thinning is necessary or sufficient for reducing wildfire hazards and/or introducing prescribed fire. We cite evidence that logging-induced changes in fuel composition, vegetation, and microclimate can result in increased rate of fire spread, higher fireline intensity, and more severe fire effects. This, in turn, can affect firefighter safety and efficiency, and inflate suppression costs. Instead, treatment of surface and ladder fuels through prescribed fire combined with manual pre-treatments (for example, non-commercial thinning, pruning, and hand-piling) can effectively reduce the risk of crownfires, increase firefighter safety, and improve ecosystem health. These methods also promise employment opportunities for wildland firefighters and other forest workers.” Fox, Joseph W., Ph.D. and Timothy Ingalsbee, Ph.D“Fuel Reduction for Firefighter Safety.” Published in theProceedings of the International Wildland Fire Safety SummitWinthrop, WA, Oct. 26-29, 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

1998 http://www.fire-ecology.org/research/fuel_reduction.htmLetter 2 – Attachment 2 – Comment 15

 “The scientific consensus is that large and old trees should generally beretained, especially fire-resistant species such as pines. Indeed, from an ecological perspective these are absolutely the last trees that should be removed. Large and old trees are the most likely to survive a fire and subsequently serve as focal points for recovery. Large and old trees arealso critical wildlife habitat, in part because they are the source of the standing dead trees (snags) and logs where animals live. Large old trees are essentially irreplaceable because they take centuries to reach that state.” “Logging as a part of fuel treatment programs is an issue that deserves serious consideration by everyone in the forest fire policy debates. On the one hand, traditional commercial logging operations are unlikely to improve fuel loadings significantly or alter potential fire behavior for the better. Such operations are not focused on the key ground and ladder fuels, and they also contribute additional ground and ladder fuels in the form of debris called slash.” 

Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 

2007. “Forging a Science-Based National Forest Fire Policy.” 

Issues in Science and Technology. 

http://www.issues.org/20.1/franklin.html

True, but excerpt is taken out of context. Paptraditional logging practices of regeneration hsilviculture thinning for growth and yield purfuels. See Chapter 2, Alternatives Considered in Deand please note Table 2-6 – Design Features aRequirements, pp. 2-21 to 2-28. 

Letter 2 – Attachment 2 – Comment 16

 “In eastern Oregon and Washington, Lehmkuhl et al. (1995) and Huff et al. (1995) reported a positive correlation between fuel loadings, predicted flame lengths and logging. They attributed the increased fire hazard in managed areas to slash fuels generated as a by-product of tree 

Opinion statement - author is not a fire scient
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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

removal activities (including thinning), and to the creation of dense, early-successional stands via logging that have a high fire potential. A post-fire study of the effectiveness of fuels treatments – including thinning – on previously non-harvested lands in the Wenatchee National Forest, Washington found that harvest treatments likely exacerbated fire damage (USDA 1995).” “Some land managers and forest scientists advocate the widespread use of silvicultural treatments (of which thinning is the most widely proposed harvest-based fuels reduction method) in western roadless areas to reduce fuel loads and tree stocking levels, and thereby decrease the probability of large, intense fires. Although thinning within the context of intensive forestry is not new, its efficacy as a tool for fire hazard reduction at the landscape scale is controversial, largely unsubstantiated, and fundamentally experimental in nature (Henjum et al. 1994, DellaSala et al. 1995, SNEP 1996, FEMAT 1993).” “In some instances, as noted above, thinning treatments intended to reduce fire hazard appear to have the opposite effect (van Wagtendonk 1996, Weatherspoon 1996, Huff et al.1995). Such treatments may reduce fuel loads, but they also allow more solar radiation and wind to reach the forest floor. The net effect is usually reduced fuel moisture and increased flammability (Agee 1997, Countryman 1955).” 

Frost, Evan 1999. “The Scientific Basis for Managing Fire and

Fuels in National Forest Roadless Areas” - Appendix G 

http://209.85.173.104/search?q=cache:LaOMIfF8eaoJ:www.landsinfo.o

rg/ecosystem_defense/Resources_Species_Topics/Fire/Fuels%2520man

agement%2520in%2520Roadless-
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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Frost.doc+%22Ecosystem+management+in+western+interior+forests%

22+DellaSala+Olson+Crane+1995&hl=en&ct=clnk&cd=7&gl=us

Letter 2 – Attachment 2 – Comment 17

 “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.” “According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’” 

Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style:

Cut Down the Trees!” Environmental News Service, 2008. 

http://www.ens-newswire.com/

Opinion statement– not science. 

Letter 2 – Attachment 2 – Comment 18

"Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value." 

Government Accounting Office 

“Western National Forests: A Cohesive Strategy is

Needed to Address Catastrophic Wildfire Threats” 

GAO/RCED-99-65

http://www.gao.gov/archive/1999/rc99065.pdf

Small diameter trees will be removed. See ChConsidered in Detail, pp. 2-8 to 2-32. 
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RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 19

 “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “ “As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high-value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).” “The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.” “After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire-resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as 

This citation does not come from a peer-revie
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Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"slash piles" -- unsalable branches and limbs left by logging crews.” 

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent 

Catastrophic

Fires, It Causes Them.” Published in the New York Times, May 19, 

2000 

http://www.commondreams.org/views/051900-101.htmLetter 2 – Attachment 2 – Comment 20

 “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing wildland fires ...” 

Hanson, Chad Ph.D., “Logging Industry Misleads on

Climate and Forest Fires.” Guest Commentary in New West, July 11, 

2008 

http://www.newwest.net/topic/article/logging_industry_misleads_on_cli

mate_and_forest_fires/C41/L41/

Opinion statement - taken out of context – no

Letter 2 – Attachment 2 – Comment 21

 “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. Allharvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9) 

Comments taken out of context. Noted envirconsequences only apply when post-thinning treated. See Chapter 2, pp. 2-13 to 2-16 and Table 2-6descriptions on activity and existing natural fspecific design features incorporated into pro
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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.” 

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. 

Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. 

Everett, Richard L. Ph.D. 1995. “Historical and current forest

landscapes in eastern Oregon and Washington. Part II: Linking

vegetation characteristics to potential fire behavior and related

smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA 

Forest Service, Pacific Northwest Research Station. 

https://ir.library.oregonstate.edu/dspace/bitstream/1957/4706/1/PB96155213.pdfLetter 2 – Attachment 2 – Comment 22

"The Quincy Library Group's (QLG's) fuelbreak strategy represents a

giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review." "The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management 

Opinion statement - author is not a fire scient
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RICHARD ARTLEY 

Comment Our Response 

expertise." "In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects." "Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires.""And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution." "The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a 
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RICHARD ARTLEY 

Comment Our Response 

modern-day version of 'cut and run' logging, many of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets ... a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs." 

Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical 

Analysis of the Quincy Library Group Fire Protection Plan."

Unpublished research paper. 1997. 

http://www.fire-ecology.org/research/logging-for-firefighting_2.htm

Letter 2 – Attachment 2 – Comment 23

 “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, roadbuilding, livestock grazing and aggressive firefighting are the sourcesfor "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” 

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging

for Wildfire Prevention: Facts Vs Fantasies” 

http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Opinion statement - author is not a fire scient
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RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 24 “Thus, the use of commercial logging for fire hazard reduction poses 

yet another paradox: Logging removes the trees that normally survivefires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) 

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate

fundamental questions about our relationship to fire.”The Oregon 

Quarterly, Winter 2002 

http://209.85.173.104/search?q=cache:n8ChOBpFT7wJ:www.fireecology.org/research/wildfire_paradox.pdf+%22commercial+logging%22+ineffective+wildfire&hl=en&ct=clnk&cd=6&gl=us

Opinion statement - author is not a fire scient

Letter 2 – Attachment 2 – Comment 25

"In the face of growing public scrutiny and criticism of the agency's 

logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards." "Decades of encouraging private logging companies to take the biggest, oldest, most fire-resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands." "In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these socalled thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fireOpinion statement - author is not a fire scient
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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks." 

Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest

Service: A Fire-Dependent Bureaucracy."

Missoula Independent. Vol. 14 No. 24, June 2003 

http://www.fire-ecology.org/research/USFS_fire_dependent.html

“Letter 2 – Attachment 2 – Comment 26

More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire-resilient, most commerciallyvaluable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are lesscommercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.” “Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, thecreation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.” 

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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland 

Fire.” Published by the Firefighters United for Safety, Ethics, and 

Ecology (FUSE), January 2005 

http://209.85.173.104/search?q=cache:FuTKT_jqv2oJ:www.fire.unifreiburg.de/media/A%2520Reporters%2520Guide%2520to%2520Wildland%2520Fire.pdf+ph.d.+%22fuels+reduction%22,+%22commercial+logging%22&hl=en&ct=clnk&cd=19&gl=usLetter 2 – Attachment 2 – Comment 27

 “History, not science, refutes the claim that logging helps to prevent forest fires. The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests. Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot. More logging will not fix this.” 

Keene, Roy “Logging does not prevent wildfires” 

Guest Viewpoint, the Eugene Register Guard

January 11, 2009 

Opinion statement 

“Letter 2 – Attachment 2 – Comment 28

The Peshtigo tragedy served as a deadly warning about what can happen when forest health is badly compromised -- in this case, by logging activities. In fact, Peshtigo represented the beginning of new fire cycle throughout the Great Lakes region that would not be broken 

The concerns expressed here are addressed bfor our projects (Chapter 2, Table 2-6, pp. 2-was the result of untreated slash. We treat oupertain to plantations not thinning projects. emphasized need to treat activity fuels, which 
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RICHARD ARTLEY 

Comment Our Response 

for more than 50 years.” “The removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.” “The Congressional Research Service (CRS) recently addressed theeffect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recentperiod (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting. Without adequate treatment of small woody material, logging may exacerbate fire risk rather than lower it.” 

Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department 

of the Interior 

“A Report to the President in Response to the Wildfires of 2000”, 

September 8, 2000. 

http://www.fs.fed.us/emc/hfi/president.pdf

See Chapter 2, Alternatives Considered in Dedetailed descriptions of the proposed actions. 
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RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 2 – Comment 29

 “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.” “How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.” 

Lawrence, Nathaniel, NRDC senior attorney 

“Gridlock on the National Forests” Testimony before the U.S. House 

of Representatives Subcommittee on Forests and Forest 

Health (Committee on Resources) December 4, 2001. 

http://www.nrdc.org/land/forests/tnl1201.asp

Science in this testimony is dated. Current thof these claims, which are exaggerated. Authscientist. 

Letter 2 – Attachment 2 – Comment 30

 “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logginghas side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living 

Opinion statement– not science. 
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RICHARD ARTLEY 

Comment Our Response 

in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground. 

Leitner, Brian. “Logging Companies are Responsible for

the California Wildfires.” 

 the Democratic Underground, October 30, 2003. 

http://www.democraticunderground.com/articles/03/10/30_logging.htmlLetter 2 – Attachment 2 – Comment 31

 “Salvage logging proponents also argue that the practice can reduce the risk of large, high-intensity wildfires by removing dead or dying trees that could serve as fuel in the next fire. However, there is evidence thatremoving these trees may not significantly decrease fire severity. A number of studies have shown that for some ecosystems, the major factor determining fire intensity and size is weather and not the amountof fuel (Baker 1989, Flannigan and Harrington 1988, Haines and Sando 1969, Rothermel 1995). For example, Bessie and Johnson (1995) found that fire spread and intensity were strongly related to weather conditions and only weakly related to fuel loads in the southern Canadian Rockies. Similarly, many hundreds of the thousands of acres of forests that wereintensely burned in the 1994 Tyee Fire on the Wenatchee National Forest had very low fuel loads. The Forest Service and Fish and Wildlife Service concluded that weather patterns and terrain -- not fuels -- were the major reasons why this large fire burned the way it did (U.S. Forest Service 1995, U.S. Fish & Wildlife Service 1994). Such case studies provide little evidence that salvage logging of dead and dying trees will significantly reduce wildfires.” 

Peters, R.L., E. Frost, and F. Pace. “Managing for forest ecosystem

health: A reassessment of the forest health crisis.” Defenders of 

Wildlife. April 1996.

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RICHARD ARTLEY 

Comment Our Response 

http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.htmLetter 2 – Attachment 2 – Comment 32

 “H.R 1904 does not include any specific measures to protect homes or communities. It is also inconsistent with the Western Governors' Association 10-Year Comprehensive Strategy, which does not call for any changes in existing laws. The only proven method to protect homes and communities is to reduce flammable materials in the immediate vicinity of structures, yet the definitions in H.R. 1904 would not require any activities to be near homes. Instead, the bill seeks to further subsidize the timber industry and eliminate obstacles to logging large, fire-resistant trees miles away from the nearest home. The country's top forest scientists, including the Forest Service's own scientists, have found that this kind of logging can actually increase fire risk and make fires larger and more intense.” 

Peterson, Mike from his June 26 2003 testimony to the Senate 

Agriculture, Nutrition, and Forestry Committee concerning the Healthy 

Forests Restoration Act, HR 1904. 

http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_id=2258

Opinion statement– not science. 

Letter 2 – Attachment 2 – Comment 33

 “In response to catastrophic wildfires, wide-reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore historic forest structure in those forest types that are outside of their historic 

This citation does not come from a peer-revie
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RICHARD ARTLEY 

Comment Our Response 

range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlaywas then aggregated by land management classes. Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations. Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.” Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest 

Structure Compatible? A Spatial Modeling Assessment”Published Online: by the by Association of American Geographers. Sep. 8, 2006 

http://www3.interscience.wiley.com/journal/118607503/abstract?CRETRY=1&SRETRY=0Letter 2 – Attachment 2 – Comment 34

"Fire severity has generally increased and fire frequency has generally decreased over the last 200 years. The primary causative factors behind fire regime changes are effective fire prevention and suppression strategies, selection and regeneration cutting, domestic livestock grazing, and the introduction of exotic plants." 

The context of this report is not presented. Rof plant communities. At the time of this repchanging climate on fire occurrence and seveconsidered. Many scientists now recognize thfrom cooler, wetter period in 1940s to 1970s tperiod are also factors. 
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RICHARD ARTLEY 

Comment Our Response 

Quigley, Thomas M. Ph.D., Richard W. Haynes and Russell Graham 

Tech. editors. 1996. “Integrated Scientific Assessment for

Ecosystem Management in the Interior Columbia Basin

and Portions of the Klamath and Great Basins.” 

USDA Forest Service, PNW-GTR-382, 303 p. 

http://www.fs.fed.us/pnw/publications/icbemp.shtml

Letter 2 – Attachment 2 – Comment 35

 “The Forest Service's own fire experts have found that a home's survival rate depends almost entirely on its location, its condition and itsimmediate surroundings, not on more commercial logging and roadbuilding in the backcountry.” 

representatives of 148 conservation organizations 

from a July 18, 2002 letter to Chief Dale Bosworth signed 

http://www.nativeforest.org/campaigns/public_lands/bosworth_7_18_02.htm

Opinion statement– not science. 

Letter 2 – Attachment 2 – Comment 36

 “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest.... has increased fire severity more than any other recent human activity”in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees 

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• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

(DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).” 

Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native 

Plant Society 

Excerpt from a letter to Chief Dale Bosworth and 5 members of 

congress 

http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf

Letter 2 – Attachment 2 – Comment 37

 “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.” 

Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. 

"Physicians of the Forest": A Rhetorical Critique of the

Bush Healthy Forest Initiative” 

Electronic Green Journal, Issue #19, December 2003

http://repositories.cdlib.org/uclalib/egj/vol1/iss19/art3/

Opinion statement– not science. 

Letter 2 – Attachment 2 – Comment 38

 “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and 

Opinion statement– not science. 
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Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

communities.” “Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.” 

Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to

Central Oregon Communities and the Surrounding Environment.”

Testimony before the House Committee on Resources, August 25, 2003 

http://www.fseee.org/index.html?page=http%3A//www.fseee.org/eactivist/testimony082503.shtmlLetter 2 – Attachment 2 – Comment 39 “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity. Logging, especially clear cutting, can 

This citation does not come from a peer-revie
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

change the fire climate so that fires start more easily, spread faster, further, and burn hotter causing much more devastation than a fire ignited and burned under natural conditions. If we stop the logging and stop building fire prone developments, we minimize the loss of lives and property suffered by people in fires.As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make moremoney from our losses. Just like big tobacco.”

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests

on Fire: Why Forest Management Exacerbates Loss of Lives

and Property” Published by CommonDreams.org, October 31, 2003 

http://www.commondreams.org/scriptfiles/views03/1031-10.htm

Letter 2 – Attachment 2 – Comment 40

 “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotesnearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1) “Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9) “Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19) 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20) “Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20) 

Taxpayers for Common Sense. “From the Ashes: Reducing

the Harmful Effects and Rising Costs of Western Wildfires” 

Washington DC , Dec. 2000 

http://www.ourforests.org/fact/ashes.pdf

Letter 2 – Attachment 2 – Comment 41Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.” 

Thomas, Craig. “Living with risk: Homeowners face the

responsibility and challenge of developing defenses against

wildfires.” Sacramento Bee newspaper, July 1, 2007.

Opinion of a reporter. Not peer reviewed scimistakes science findings. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.phpLetter 2 – Attachment 2 – Comment 42

"Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62) 

University of California; SNEP Science Team and Special Consultants 

1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” 

Volume 1, Chapter 4 – Fire and Fuels. 

http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

Taken out of context - refers to clearcutting. clearcutting proposed in this project. 

Letter 2 – Attachment 2 – Comment 43

 “Notably, the Administration’s wildland fire policy does not rely on commercial logging or new road building to reduce fire risks and can be implemented under its current forest and land management polices. The removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk. Fire ecologists note that large trees are “insurance for the future – they are critical to ecosystem resilience.”10 Targeting smaller trees and leaving both large trees and snags standing addresses the core of the fuels problem.11The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recentperiod (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT #2 

Statements by Scientists showing that Commercial logging INCREASES Wildfire Intensity and Rate o

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

USDOI Secretary Babbitt and USDA Secretary Glickman 

“A Report to the President in Response to the Wildfires of 2000” 

September 8, 2000 

http://www.forestsandrangelands.gov/reports/documents/2001/8-20-

en.pdf

Letter 2 – Attachment 2 – Comment 44

 “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalistsat odds with the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees. Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires. In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. Thereport found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “ 

Voss, René 

“Getting Burned by Logging,” July 2002 

The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 3 – Comment 1

“Mountain logging near streams has come under increasing scrutiny and control in the Pacific Northwest as the unique functions and benefits of streamside areas have become more apparent. These characteristics include diverse and productive plant cover and forest stands, heavy shade, abundant large and fine organic debris, control of erosion and sedimentation, and significant fish and wildlife habitat. Logging near streams can alter many of these characteristics and produce a variety of resource effects. Among the key challenges related to logging near streams are habitat improvement, integrated resource and operations planning, the development of site-specific and prioritized streamside management practices, and evaluations of logging feasibility and environmental trade-offs.” (pg. 1, cite #1) 

Adams, Paul W. Ph.D., Robert L. Beschta, Ph.D., and Henry A. 

Froehlich Ph.D. “Mountain Logging Near Streams: Opportunities 

and Challenges.” in: Proceedings, International Mountain Logging and 

Pacific Northwest Skyline Symposium, December 1988 

http://www.dof.virginia.gov/wq/resources/lit-review-2006_austin.pdf

There will be no logging near streams. StreamPACFISH interim buffers. PACFISH was adUmatilla Land and Resource Management PlAdams et al. paper (1988) was written. Impleassures that these buffers are designated. Demanagement practices will prevent damage tquality. Together the protections will maintarecovery of riparian systems at their natural See Chapter 2, Table 2-6 Design Features and Requirements, pp. 2-21 to 2-28. 

Letter 2 – Attachment 3 – Comment 2

 “Twentieth century forest management, for all its good intentions, has left a mess on the landscape.” 

Agee, Jim Ph.D., 1994, University of Washington 

http://www.andykerr.net/GenForests/ForestFiretQuotes.html

Statement is taken out of context. 

Letter 2 – Attachment 3 – Comment 3

 “The water quality and runoff of six small forest brooks have been studied since 1978. All brooks were investigated in their untouched 

This study does not apply to the Cobbler projnot peat soils, there will be no ditching and th

near streams. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

state for nearly five years, after which clear-cutting and forestry drainage were both carried out in two different ways and to two different extents on four of the basins, leaving two undisturbed throughout, as control basins.” “Water temperature, colour, and chemical oxygen demand values increased immediately after clearcutting. Large scale cutting on peat soils increased the 3-year mean leaching of organic matter by 73%, the corresponding increase after cutting on mineral soil with a protectivezone left along the brook being 23%.” “The phosphorus was predominantly in soluble form. The smaller-scale cutting on mineral soil increased the load of total phosphorus by one third in the first two years. In one of the two basins where both clearcutting and ditching were carried out, the annual load of suspended solids increased 4-fold in relation to the control value the first three years. Ditching of the soil in the other basin, which is more sensitive to erosion, caused an increase in suspended solids to a level 17 times higher than during the calibration years.” (pg. 1, cite #2) 

Ahtiainen, M. “Effects of Clear-Cutting and Forestry Drainage

on Water Quality in the Nurmes Study.” In: Symposium on the 

Hdrology of Wetlands in Temperate and Cold Regions 

1988 Jun 6; Joensuu, Finland. ; 1988; Volume 1. 

http://www.dof.virginia.gov/wq/resources/lit-review-2006_austin.pdf

Streams are protected with PACFISH interim was adopted into the Umatilla Land and ResoPlan in 1995, after this paper was written. Immonitoring assures that these buffers are descriteria and best management practices will pchannels and water quality. Together the proand provide for the recovery of riparian systerate. See Chapter 2, Table 2-6 Design Features and Requirements, pp. 2-21 to 2-28. 

Letter 2 – Attachment 3 – Comment 4

 “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.” “Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ " “But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.” 

Barry, John Byrne. “Stop the Logging, Start the Restoration” 

from The Planet newsletter 

June 1999, Volume 6, Number 5 

http://www.sierraclub.org/planet/199905/ecl1.aspLetter 2 – Attachment 3 – Comment 5

"In view of the extent and persistence of human disturbance throughout forest and watershed ecosystems, continuing to simply manage fire risk without controlling the adverse effects of logging, grazing, road building, and mining is unsound resource management; it is an approach that without careful thought could lead to further damage rather than to the intended goal of protecting forest and stream health, 

This citation does not come from a peer-revie
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

as such an approach addresses the symptoms rather than the causes." 

Beschta, Robert L. Ph.D. et al. 

1995 “Wildfire and Salvage Logging: Recommendations

for Ecologically Sound Post-Fire Salvage Management and

other Post-Fire Treatments on Federal Lands in the West”

http://www.saveamericasforests.org/congress/Fire/Beschta-report.htmLetter 2 – Attachment 3 – Comment 6

 “In some areas the use of prescribed fire without any “thinning” would be the best restoration method. Indeed, many forests in the West do not require any treatment. These are forests that for thousands of yearshave burned at long intervals and only under drought conditions, and have been altered only minimally by 20th century fire suppression. These forests are still "healthy" and thinning would only disturb them, not "restore" them. In short, the variation among our forested landscapes is much too great for one treatment to be appropriate everywhere. Where thinning is used for restoration purposes in dry forest types, removal of small diameter material is most likely to have a net remedial effect. Brush and small trees, along with fine dead fuels lying atop the forest floor, constitute the most rapidly ignited component of dry forests (young forest stands regenerating after timber harvest often burn with the greatest intensity in western wildfires). They most surely post-date management-induced alteration of dry forest fire regimes. And their removal is not so likely to increase future fire intensity, for example from increased insolation and/or the drying effects of wind.” 

from a September 9, 2002 letter to President Bush signed by: Norman 

L. Christensen, Jr., Dean Emeritus and Professor of Ecology, Duke 

This citation does not come from a peer-revie
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

University Thomas W. Swetnam, Professor of Dendrochronology & 

Watershed Management, University of Arizona Don C. Erman, 

Professor Emeritus, University of California David Perry, Professor 

Emeritus, Ecosystem Studies and Ecosystem Management, Oregon 

State University Penelope Morgan, Professor of Forest Resources, 

University of Idaho Scott Stephens, Assistant Professor of Fire Science, 

University of California Philip N. Omi, Professor of Forest Fire 

Science, Colorado State University Lisa Graumlich, Professor of Land 

Resources & Environmental Sciences, Montana State University 

William H. Romme, Professor of Forest Sciences, Colorado State 

University Paul H. Zedler, Professor of Environmental Studies, 

University of Wisconsin, Madison J. Boone Kauffman, Associate 

Professor, Department of Fisheries and Wildlife, Oregon State 

University Dr. William L. Baker, Professor (Fire Ecology and 

Landscape Ecology), University of Wyoming 

http://209.85.173.132/search?q=cache:G4yXkJiLvjMJ:www.cnr.uidaho.

edu/for_rrt383/science%2520ltr%2520fnl%2520w%252012%2520bios.

doc+%22These+forests+are+still+healthy+and+thinning%22+letter+Bu

sh&hl=en&ct=clnk&cd=2&gl=us

Letter 2 – Attachment 3 – Comment 7

 “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests. After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that ’immediate corrective action is needed.’ A new report on the audits found that the environmental studies 

Deficiencies have been corrected since this rerecommendations have been implemented by 

See Chapter 2, Table 2-6 - Design Features anRequirements, pp. 2-21 to 2-28 and page 2-28 framework for this project. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out. The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.” 

Cushman, John H. Jr. “Audit Faults Forest Service on Logging

Damage in U.S. Forests” New York Times, February 5, 1999 

http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A

35751C0A96F958260&sec=&spon=&pagewanted=print

Letter 2 – Attachment 3 – Comment 8

"The timber harvest shouldn't be dominant. It should be on an equal plane with recreation concerns, with wildlife concerns, hunting, fishing, protecting our cultural heritage. That's what the American public is asking us to do.” 

Dombeck, Mike Ph.D. "Through the 

Woods" The News Hour with Jim 

Lehrer. 19 June 1998. 

http://www.pbs.org/newshour/bb/fedag

encies/jan-june98/road_6-19.html

Opinion statement– not science. 

Letter 2 – Attachment 3 – Comment 9

 “I recently read a letter from a line officer who chided local managersfor being behind schedule relative to meeting the region’s ‘timber 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.” “We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.” "Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations." 

Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to 

all USFS employees on July 1, 1998 

http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.htmlLetter 2 – Attachment 3 – Comment 10

"The Forest Service actions were a "systematic and deliberate refusal to comply with the nation’s environmental laws." 

Dwyer, William. Federal Judge 

in his opinion text of Seattle Audubon 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Society v. Mosley, 798 F. Supp. 

 1484, 1489 (W.D. Wash. 1992) 

http://www.forestcouncil.org/learn/features/zerocut/mythfact.htmlLetter 2 – Attachment 3 – Comment 11

 “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.” 

Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 

“Call to End Logging Based on Conservation Biology.” Native 

Forest Network. 

http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm

Opinion statement– not science. 

Letter 2 – Attachment 3 – Comment 12

The proposition that forest values are protected with more, rather than less logging, and that forest reserves are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base." "On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they reduce traditional sources of timber income." 

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David 

Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified 

The Forest Plan, as amended by the Eastside areas of dense forest be left for wildlife and oharvest units, the trees to be left are the largepreference for early seral species. Trees 21 inDBH would be left with the exception of the rmoderate dwarf mistletoe infection ratings in (shelterwood and seed tree cuts) only, in moisThe number of acres from which diseased trecould be harvested is 350 (only in moist foresThis is approximately 1 percent of the total pacres) and less than 2 percent of the 25,400 acarea where timber harvest is scheduled. The number of diseased trees > 21 inches DBH th

between 10 and 50 to avoid infecting newly re(EA, Chapter 2, p. 2-12). 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Forest Management to Achieve Watershed and Forest Health: A 

Critique."

http://www.coastrange.org/documents/forestreport.pdf

See Chapter 2 and Appendix F – Consistency Screens 

Letter 2 – Attachment 3 – Comment 13

"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." 

Government Accounting Office 

“Western National Forests: A Cohesive Strategy is

Needed to Address Catastrophic Wildfire Threats” 

GAO/RCED-99-65

http://www.gao.gov/archive/1999/rc99065.pdf

Opinion statement– not science. 

Letter 2 – Attachment 3 – Comment 14

 “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs, logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs 

In all silvicultural prescriptions for this projeand western larch are the preferred leave speprescribed to regenerate lodgepole pine, westexcept where it is infected with dwarf mistletprescriptions where the mistletoe would be trregenerating stand. Larch would be thinned stocking levels where it currently exceeds tho
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred duringthe decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partiallycreated by past timber sales.” “A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)” “One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed. (10)” 

Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and

Procedures: Analysis of Alternative Systems.” A Congressional 

Research Service (CRS) report, October 30, 1995. 

There are no salvage units in this project. KV funds are not unlimited. They are used fon some timber sales there are funds availablimprovement projects within the sale area bopp. 2-32 to 2-33).
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

http://www.ncseonline.org/NLE/CRS/detail.cfm?do=do&OrderBy=Dat

e&Category=Forests&CRScode=&Title=&Authors=&Keyword=&quic

kKeyword=&MaxCount=32&start=21

Letter 2 – Attachment 3 – Comment 15

"The Forest Service keeps the vast majority of timber sale revenues, which gives it a perverse incentive to do more cutting. It has developed a huge bureaucracy around the selling of timber from national forest land." 

Hanson, Chad, Ph.D. “Logging for Dollars in National Forests” 

Special to The Sacramento Bee - November 14, 2001 

http://www.johnmuirproject.org/news-logging-for-dollars.html

Opinion statement– not science. 

Letter 2 – Attachment 3 – Comment 16

"Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes." 

Harvey, A. E., M. J. Larsen, and M. F. Jurgensen 

“Distribution of Ectomycorrhizae in a Mature

Douglas-fir/larch Forest Soil in Western Montana” 

Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-

398(6) 

http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsessionid=l2sdf2hphia2.alexandra

Logging systems and slash treatments are desmuch organic matter as practicable while baland insect and disease increase risk issues. Cuminimize or eliminate creation of traditional organics are pushed aside or removed, and wsystems are used, retain all organics on-site. See Chapter 2, Table 2-6, pp. 2-21 to 2-28 See Chapter 3, Soils, pp. 3-4 to 3-9 

Letter 2 – Attachment 3 – Comment 17

"When examining timber harvests from an ecological perspective, it isimportant to consider the wide range of effects that are a result of forestry practices." "While a certain timber harvest may only clearcut a small number of 

Fragmentation of the landscape was taken inMany areas were deferred from logging for twildlife species were examined at scales apprSee Chapter 3, Wildlife, pp. 3-83 to 3-113. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

patches within a larger ecosystem, the effects of that harvest will reach out into the surrounding area. Particularly if surrounding forest has been harvested previously, the effects of additional fragmentation could be detrimental to many species in the local and regional area." "If surrounding forest is meant to act as habitat for forest species which will not be able to survive in the open canopy environment created by the timber harvest, the matrix surrounding that timber harvest must be able to support an increase in forest species to prevent population declines. For rare, interior forest species, this effect is even more pronounced and their continued survival depends on large, residual forest patches." "Regardless of the methods or amount of area harvested, the ecological consequences must be fully understood on a regional level to prevent the loss of sensitive species which will either be directly or indirectlyaffected by timber harvest and forest habitat decline." 

Hatch, Andy. 2002. Ecological Consequences of

Timber Harvest on Forest Ecosystems. 

http://www.cserc.org/main/wildlife/timber_effects.htmLetter 2 – Attachment 3 – Comment 18

"For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be 

Opinion statement– not science. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do." 

Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public."

Evergreen magazine, October 1997. 

http://www.evergreenmagazine.com/news/quotable_quotes.html

Letter 2 – Attachment 3 – Comment 19

"SEC. 3. FINDINGS. Congress finds the following: 

Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries." 

H. R. 1494 text. April 4, 2001 

http://www.agriculturelaw.com/legis/bills107/hr1494.htm

The economic analysis presented in the Cobbaccordance with the Forest Service manual ato complete a financial analysis for timber salThe economic analysis documented in the EA monetary measures for timber and the financthe timber. Other non-timber resources affecnot measured using monetary values. The coassociated with these resources are described quantitative and qualitative measures in accoSee EA, Chapter 3 pp. 3-130 to 3-133. In addition, neither the National Forest Mananor the National Environmental Policy Act (Nspecific analyses such as the Cobbler EA to mresources (Forest Conservation Council v. UnService, Civ. No. 05-35166 (Ninth Circuit, Oc“Nothing in the NFMA or the regulations US1982 requires site-specific analyses to monetiresource. Nor does NEPA require monetizat
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

resources. FS policy also does not require monon-timber resources in timber sale economic 

Letter 2 – Attachment 3 – Comment 20

"Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences." 

Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How 

Biodiversity Sustains Us” 

from his book review of 

The Work of Nature: How the Diversity of Life Sustains Us

by Yvonne Baskin, 1997 

Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 

http://www.mikehudak.com/Articles/FromPrairieDogs9902.html

This is not peer reviewed science. 

Letter 2 – Attachment 3 – Comment 21

"As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon." "Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes. In general, 

Comments were taken out of context. Noted consequences only apply when post-thinning treated. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds."

Huff, Mark H., Roger D. Ottmar Ph.D., Ernesto Alvarado Ph.D. 

Robert E. Vihnanek, John F. Lehmkuhl Ph.D., Paul F. Hessburg Ph.D. 

and Richard L. Everett Ph.D. 1995. "Historical and Current Forest

Landscapes in Eastern Oregon and Washington. Part II: Linking

Vegetation Characteristics to Potential Fire Behavior and Related

Smoke Production." USDA Forest Service. PNW-GTR-355.

http://permanent.access.gpo.gov/websites/fsfedus/www.fs.fed.us/pnw/p

ubs/gtr355/gtr355a.pdf

Letter 2 – Attachment 3 – Comment 22

 “Linear developments may result in habitat avoidance for grizzly bears. 

Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non-hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.” “The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.” 

Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of 

This project is not in an undeveloped area. Ewere evaluated. See Chapter 3, pp. 3-104 and 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Linear Developments on Wildlife: A Review of Selected Scientific 

Literature.” Prepared for 

Canadian Association of Petroleum Producers. Arc Wildlife Services 

Ltd., Calgary. 115pp. 

http://emr.gov.yk.ca/pdf/bmp_the_effects_of_llinear_developments_on

_wildlife_a_literature_review.pdf

Letter 2 – Attachment 3 – Comment 23

"Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low-ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest." 

Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata 

"Effects of Human-Induced Changes on Hydrologic Systems."

An American Water Resources Association publication, June 1994 

http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF

Effects of past harvest and proposed harvest from landscape burning on water yield and pand cumulated with the Equivalent TreatmenThe increases are well below levels at which eto water yield, peakflows, or timing of peakflharvest and landscape burning would have nhydrologic functions; capture, storage, and reIncreased bulk density and decreased hydraumeasures of soil compaction effects. See respComment 50 which also addresses this issue aDetrimental Soil Condition analysis. Design contractual requirements are intended to minlevels of soil disturbance including compactioSee Chapter 2, Table 2-6, pp. 2-21 to 2-28 See Chapter 3, Soils, pp. 3-4 to 3-9 and HydroSee Appendix E – Soils 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 3 – Comment 24

"Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)." "Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain." "Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources lessthan four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools." 

Klein, Al 2004. Logging Effects on Amphibian Larvae

Populations in Ottawa National Forest.

http://www.nd.edu/~underc/east/education/documents/AKlein2004Preloggingsurveyofamphibianlarvaeinvernalpools.pdf

This is a student paper based on the Ottawa NMichigan and does not apply to species or conUmatilla National Forest. Proposed harvest activities, fuels treatments, and pre-commercial thinning would not occuPACFISH Riparian Habitat Conservation Arwidths range from 1-2 tree heights or 120 to 3greatest, depending on flow regime and the p(Forest Plan, 1990, as amended by PACFISHcontrolled by about 1 tree height (FEMAT, 1no effect to water temperature from these treImplementation monitoring assures that thesdesignated. Design criteria and best managemprevent damage to channels and water qualitprotections will maintain and provide for the systems at their natural rate. See Chapter 2, Table 2-6 - Design Features anRequirements, and monitoring framework fo(Chapter 2, pp. 2-21 to 2-31). See Appendix D – Best Management Practice

Letter 2 – Attachment 3 – Comment 25

"We concluded that commercial timber sales do not meet the criteria for forest restoration." 

Opinion statement– not science. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Long, Richard D., U.S. Department of Agriculture Office of Inspector 

General

"Western Region Audit Report: Forest Service National Fire Plan 

Implementation"

Report No. 08601-26-SF, November 2001. 

http://maps.wildrockies.org/ecosystem_defense/Resources_Species_Topics/Fire/Misuse%20of%20Fire%20Plan%20funds.pdf“Letter 2 – Attachment 3 – Comment 26In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.” 

Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. 

“Call for 'Sustainability' in Forests Sparks a Fire” 

Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 - 1998 

http://www.sciencemag.org/cgi/content/summary/283/5410/1996

This project complies with all current directiVegetation, Findings of Consistency, p. 3-57. 

Letter 2 – Attachment 3 – Comment 27

 “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, butalso numerous other services such as recreation and clean water.” “Our National Forest System was first established over one hundred years ago to bring an end to the reckless destruction that had ravaged 

See Appendix F – Consistency with Eastside Splanning area is above HRV in large tree cateforest single stratum (OFSS) in the dry uplanvegetation group. This project has limits and mitigations recomresource specialists on the interdisciplinary tedesigned to prevent destruction and devastat(Chapter 2, Table 2-6, pp. 2-21 to 2-28). 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

wildlife habitat and watersheds. At the time, Congress acknowledged that establishing National Forests would provide America with diversewildlife, healthy watersheds, and a sustainable supply of wood products.” “Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat. More than 3,000 species of fish and wildlife and 10,000 plant species-- including 230 endangered plant and animal species-- make their home in National Forests. Scientific research has repeatedly reaffirmed the tenet that wildlife need an abundant, healthy, and intact environment to survive. Unless the destruction of fragile ecosystems is immediately reversed through scientifically based restoration and recovery, the damage done to terrestrial and aquatic habitat will be irrevocable.” 

Martin, Rachel Ph.D. and 221 other Ph.D. Scientists. 

from an April 16, 2002 letter to President George W. Bush 

http://www.pabiodiversity.org/listserve/03-13-03.pdf

Letter 2 – Attachment 3 – Comment 28

"Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system." 

Maser, C. Ph.D., and J. M. Trappe Ph.D. 

Designated logging systems are designed to mdisturbance that would detrimentally affect band biological soil organisms. Site disturbancplanting of the kind current in 1984 is not necsilvicultural prescriptions, harvest systems, aactivity. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“The Seen and Unseen World of the Fallen Tree”, 1984

USDA Forest Service, GTR-PNW-164

http://www.fs.fed.us/pnw/publications/pnw_gtr164/

See Chapter 2, Table 2-6, pp. 2-21 to 2-28 See Chapter 3, Soils, pp. 3-4 to 3-9 and Appen

Letter 2 – Attachment 3 – Comment 29

"Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5) "Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44) 

Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin 

Ph.D. 1988 

“The Forest to the Sea: A Story of Fallen Trees”

USDA Forest Service, GTR-PNW-GTR-229

http://www.fs.fed.us/pnw/publications/pnw_gtr229/

Levels of down material that would remain aspecified and are consistent with current direunits, except regeneration units, yarding wouharvester/forwarder system, with the trees limstands and the material left there. Fuels trealogging would leave recommended levels. See Chapter 2, Table 2-6, pp. 2-21 to 2-28. 

Letter 2 – Attachment 3 – Comment 30

"In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by: 

a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.” 

McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar 

S.E. Clarke, G.H. Reeves, and L.A. Brown 

“Management history of eastside ecosystems: changes in

While it is true that logging can potentially hahas had such effects in years past, modern Fopractices, including implementation of PACFrequired in the Cobbler project, protect aquathose effects. See Chapter 2, Table 2-6, pp. 2-21 to 2-28 and pp. 3-23 to 3-42. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

fish habitat over 50 years, 1935-1992.” 1994 

GTR-321 93-181

http://www.fs.fed.us/pnw/publications/pnw_gtr321/

Letter 2 – Attachment 3 – Comment 31

 “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams. The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution offishes, reduction in fish numbers, and reduction in total biomass.” 

Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of

Logging on the Aquatic Resources of Three Headwater Streams of

the Alsea River, Oregon – Part III.” Fishery Report Number 9

Oregon Department of Fish and Wildlife. 

http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf

Citation refers to logging practices of 34 yearproject design features (Chapter 2, Table 2-6including implementation of PACFISH RHCeffects. In fact, the article cited by Mr. Riverrecommendations for prevention of the adverand the Cobbler project would implement all recommendations and more. 

Letter 2 – Attachment 3 – Comment 32

"Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling." "All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in 

Biodiversity is preserved in this project by forequirements, which include the Eastside ScrSee Appendix F – Consistency with Eastside S
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

functioning can be particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations." "Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levelstypical of managed ecosystems." 

Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., 

Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. 

J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. 

Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. 

"Biodiversity and Ecosystem Functioning: Maintaining Natural 

Life

Support Processes." Issues in Ecology No. 4. Fall 1999. 

http://www.esa.org/science/Issues/FileEnglish/issue4.pdf

Letter 2 – Attachment 3 – Comment 33

"As a result of the Forest Service's well-documented mismanagementover many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry." 

Nappier, Sharon. Lost in the Forest: How the Forest Service's

Misdirection, Mismanagement, and Mischief Squanders Your Tax 

Dollars. 

Taxpayers for Common Sense, 2002. 

http://www.taxpayer.net/forest/lostintheforest/lostintheforest.pdf

Opinion statement– not science. 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 3 – Comment 34

Agroforestry does reduce biodiversity. In forests used for logging,whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and 

catchment purposes. Management strategies for sustainable forestry are 

being developed, but there is a need for furtherinteraction among foresters, ecologists, community representatives,social scientists, and economists." 

Noble, Ian R. and Rodolfo Dirzo Ph.D.

"Forests as Human-Dominated

Ecosystems." Science Vol. 277. No. 

5325, pp. 522 - 525. 25 July 1997. 

http://www.sciencemag.org/cgi/content

/abstract/277/5325/522?maxtoshow=&

HITS=10&hits=10&RESULTFORMA

T=&fulltext=logging&searchid=11366

59907310_5043&FIRSTINDEX=0&jo

urnalcode=sci

The Forest Plan specifies areas that are reserand other areas that may be managed at diffeproject complies with that direction. (FP pp. 

Letter 2 – Attachment 3 – Comment 35

"The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees." "The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was 

Opinion statement – Survey information, not 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non-material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning." "The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed." "For example: 

• 82 percent wanted to ban clearcutting, • 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining 

undisturbed forest; and 

• 72 percent urged prohibition of logging if bear or other 

wildlife habitat would be harmed." 

"Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more important than protection of endangered species." "'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'." 

Northup, Jim. 1999. "Public Wants 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

More Wilderness,

Less Logging on Green Mountain 

NF". Press Release 

by Forest Watch, a Vermont-based 

environmental organization. 

http://www.forestwatch.org/content.ph

p?id=10

Letter 2 – Attachment 3 – Comment 36

"Each year in British Columbia more than 200,000 hectares of forest is logged, the majority of it clearcut." "Almost all of that logging activity takes place in watersheds or forested valleys that contain important surface water supplies such as reservoirs, lakes, rivers or streams. Often, valleys contain a multitude of water bodies connected with one another. The small ephemeral streams in a valley’s upper reaches feed into bigger creeks that carry water into valley-bottom rivers." "This report examines the costs to human communities and fisheries when logging-related damage to these interconnected and finely balanced water systems occurs." "As this report reveals, the costs are extremely high. If the 100 B.C. communities outside of Vancouver and Victoria who currently use unfiltered water from surface sources were forced to filter their water to get rid of unwanted sediments, the cost would be about $700 million. The ongoing cost of running the new filtration plants would be about $30 million annually. Such costs can be avoided, but only if land-use practices around surface supplies don’t muddy the water." 

N/A to Cobbler project - refers to Canada 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"Logging in watersheds also poses significant threats to the environment, particularly the critically important in-stream habitats of spawning and rearing salmon. Every time a logging road or logging operation triggers increased water runoff into streams, chances are high that elevated levels of sediment and debris are washed into waterways inhabited by fish." "To date, more than $300 million in public money has been channeled through the Crown Corporation, Forest Renewal BC, to pay for “watershed restoration” projects in the province. Expenditures to clean up streams and surrounding hillsides damaged by logging activities continue. It was recently estimated that up to 40 years of funding might be required to rehabilitate salmon habitat and surrounding forests damaged by logging." "Clearly, the public has paid and will continue to pay a steep price for logging practices that damage surface waters." 

Parfitt, Ben and Laurel Brewster. 2000. "Muddied Waters: The Case 

forProtecting Water Sources in B.C." A publication of: the Tuwanek 

Ratepayers Association, the Red Mountain Residents Association, 

the B.C. Watershed Stewardship Alliance, and the B.C. Tap Water 

Alliance. 

http://www.llbccat.leg.bc.ca/ipac20/ipac.jsp?index=BIB&term=337472

#focus

Letter 2 – Attachment 3 – Comment 37

 “Traditionally, the term ‘forest health’ has been used in a limited, utilitarian sense by professional foresters to refer to the growth and 

This project does not have an objective of wipdisease activity. Previous management, espechas caused a shift in species composition and 
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Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

vigor of trees (see Kolb et al. 1994). For example, according to one Forest Service publication, a forest is healthy when "biotic and abiotic influences on forests do not threaten management objectives now or in the future" (USFS 1993). From this perspective, a forest is healthy if trees are free from insects and pathogens and growing at maximum rates; it is unhealthy if trees are dead or dying. Anything that decreases or threatens to decrease yield (insects, disease, decaying trees, fire) is something to be controlled or eliminated. Managers therefore argue for removal and commercial utilization of trees that are perceived to be in danger from such threats.” “However, many conservationists and forest scientists have expressed concern about such thinking. This narrow definition of forest health does not consider the health of the entire ecosystem, such as water and soil quality and the diversity and interactions of other life forms. It doesnot provide guidance for management of resources other than timber. It has encouraged foresters to simplistically view insects and other nontimber elements of forest ecosystems as good or bad, based only on how they affect the growth rates of commercial tree species.” “When viewing forests from an ecosystem health perspective, scientists do not recognize the ‘forest health crisis’ described by the proponents of salvage logging who are concerned about losing economically valuable timber to fire or insects. To the scientists, insects, disease and fire are normal parts of healthy ecosystems, essential for forest regeneration, cycling of nutrients and maintaining a variety of dead and living trees for wildlife habitat. Attempts to control or eliminate these agents may lead to unforeseen and undesirable consequences. For example, widespread removal of dead and dying trees eliminates habitat required by bird species that feed on insects that attack living trees, with the

number of layers in many stands that have crwhere the current levels of activity and suscethan in historical times. One of the objective

shift species composition closer to historical lTable 3-22 p. 3-46, Cover Type HRV, which species are below HRV and late seral species both Moist and dry forest areas. See Chaptewhich shows levels of potential insect and dis

project planning area. Additional maps showprevious insect and disease areas can be foun

silviculture specialist’s report (project file). 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

result that outbreaks of pests may increase in size or frequency (Torgersen et al. 1990).” 

Peters, Robert L. Ph.D, Evan Frost, and Felice Pace. 1996 “Managing

for Forest Ecosystem Health: A Reassessment of the ‘Forest Health 

Crisis” 

http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.h

tm

Letter 2 – Attachment 3 – Comment 38

"Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands." 

Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang 

Zhu Ph.D. 

and Douglas W. MacCleery. 1992. "Forest Resources of the United 

States."

USDA Forest Service. Rocky Mt. Forest and Range Experiment Station. 

Gen. Tech. Rep. RM-234. 

http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html

Forest Service direction requires that all stanprescribed be classified as “suitable for timbeCobbler project complies with that direction.See Chapter 3, Vegetation, Findings of ConsiPlan and National Forest Management Act (N58, and Specifically Required Disclosures pp. 

Letter 2 – Attachment 3 – Comment 39

"Surveys show the public does not want cutting in National Forests." "Thousands of comments were received and reviewed when the Monongahela National Forest Plan was created back in '86. But many folks are still unhappy with the amount of timber and road building occurring there. Did the process truly incorporate the public will or did the powers that be manipulate the process to justify the continued flow of timber from the Monongahela?" 

Opinion statement- survey information - not 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"We have had some interesting discussions about public input on the Governor's committee. When I mention adopting the Federal Input Process, the managers start shaking. Too much red tape and too many ways to slow down the all-important work of 'managing' our forests." "But do we have any idea how folks want the public lands to be used? Of course there will be a wide range of ideas. A few will want lots of timber from the land. Some will want lots of deer and other game. Some will want it to be left alone. I have been able to locate three surveys that have asked this question. One survey was done by the US Forest Service, one by the UK Department of Forestry and the Kentucky Division of Fish and Game, and one by Indiana Representative McCloskey. All reveal that the majority of citizens do not want any commercial logging on public lands." 

Ragette', Bill. "Putting the Public into 

Public Lands" 

December 25, 2005 

http://www.wvhighlands.org/surveys.HTML

Letter 2 – Attachment 3 – Comment 40

 “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades. We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on 

This comment is beyond the scope of this pro
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems. The Act to Save America's Forests will: 

• Make the preservation and restoration of native biodiversity the 

central mission of Federal forest management agencies. 

• Ban extractive logging in core areas of biodiversity and the last 

remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value. 

• Protect sensitive riparian areas and watershed values by 

banning extractive logging in streamside buffer zones. 

• End clearcutting and other even age logging practices on 

federal land. 

• Establish a panel of scientists to provide guidance to federal 

forest management. 

We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery into the 21st century and beyond.” 

Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, 

Ph. D. 

and over 600 other leading biologists, ecologists, foresters, and 

scientists from 

 other forest specialties. From a 1998 letter to congress. 

http://www.saveamericasforests.org/resources/Scientists.htm
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 3 – Comment 41

 “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologicallysound plan for protecting and restoring the entire federal forest system. If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.” 

Raven, Peter, Ph.D., 

from his February 9, 2001 letter to Senator Jean Carnahan 

http://www.saveamericasforests.org/Raven.htm

See response to comment above (Comment 40

" Letter 2 – Attachment 3 – Comment 42The Washington Forests and Fish Report (FFR) has failed to ensure that aquatic habitats and water quality in eastern Washington are not damaged from the likely effects of logging and roads on peakflows and resulting impacts. Instead, the FFR clearly allows more damage to aquatic resources to occur from increased peakflows caused by logging, roads, and landings. This is likely to appreciably diminish the likelihood of the persistence of imperiled salmonids." 

This whole section refers to (is a critique of) WForest practices, which are different from the 

management practices. Moreover this commwritten by a third party, Mr. Rhodes, and altmaterial quoted and cited in the letter is peer 

itself is not. Projects on the Umatilla National Forest, incl
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"It is well-documented that roads, road construction, and logging cumulatively elevate peakflows, erosion, sediment delivery, turbidity, and sedimentation via several mechanisms (Meehan, 1991; USFS et al., 1994; Rhodes et al., 1994; UFSF and US BLM, 1997a; Beschta et al., 2004). These activities also reduce subsurface flows to streams (Megahan, 1972; Tague and Band, 2001; Hancock, 2002) and have been shown to reduce lowflows (Hicks et al., 1991)." "Flow alteration and channel alteration from sedimentation and elevated peakflows contributes to the elevation of summer water temperatures(Thuerer et al., 1985; Hicks et al., 1991; Dose and Roper, 1994; Bartholow, 2000), which is already a pervasive problem in streams draining logged watersheds in Washington (DEIS). These effects of logging-related activities combine to cause significant and long-lasting damage to populations of salmonids, amphibians, macroinvertebrates, and their habitats (Meehan, 1991; USFS et al., 1993; Rhodes et al., 1994; UFSF and USBLM, 1997a; Beschta et al., 2004, Karr et al., 2004)." "These problems are compounded because the recovery of channel form typically lags well behind the recovery in the cause of channel alteration (e.g., peakflows) (Kondolf, 1993; 1997). However, the FFR not only fails to provide a conservative limit on logging and road area to protect against elevated peak flows, it provides no limit on the amount of area disturbed by logging and roads, allowing both to increase without limit." "As discussed, studies have consistently found that logging and roads elevate snowmelt and, consequently, peak flows, in areas where 

compliance with the Umatilla National ForesManagement Plan as amended by PACFISH Forest Management Act (Chapter 3, pp. 3-13Proposed harvest activities, fuels treatments, and pre-commercial thinning would not occu

PACFISH RHCAs. RHCA widths range from depending on flow regime and the presence/a(Umatilla National Forest, 1990). Shade is cotree height (FEMAT, 1993). There would be temperature from these treatments. Design features for these actions would includ

of PACFISH/Forest Plan interim widths. Thwould prevent damage that could contribute sedimentation into channels and streams (BelProjects proposed in the Cobbler analysis havmitigated to prevent or minimize damage to gand sedimentation. Road drainage improvemon FR 6200 could cause short term, less than sedimentation. The potential for sedimentatiproposed projects is negligible. Projects propopportunity for measurable cumulative effectactions. Effects of past harvest and proposed harvest from landscape burning on water yield and pand cumulated with the Equivalent TreatmenETA percentages increase in the 4 subwaters
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

snowmelt is the primary source of peak flows. In such areas, peakflows from snowmelt annually deliver and transport the bulk of sediment. (MacDonald and Ritland, 1989; King, 1989)." "Based on available information, there is no good evidence that logging and roads do not increase larger peakflows at the watershed scale." "Jones and Post (2004) also found that logging in the Pacific Northwest reduced summer flows several years after removal. They also found that the logging exposed aquatic biota to higher levels of annual hydrologic variability which may have negative consequences for such biota (Jones and Post, 2004)." "Logging effects on organic matter in soils cumulatively reduces the ability of soils to absorb and store water. Logging significantly reducessources of soil organic matter (USFS and USBLM, 1997; Beschta et al., 2004). Soils with higher levels of soil organic matter typically have higher infiltration rates and are able to store more soil moisture (Rawls et al., 1993). Cumulative reductions in organic matter in intensively managed forests may also contribute to reduced lowflows by reducing soil moisture and organic matter (Griffith et al., in review; Perry et al., 

in prep.), infilitration rates, and total water in the soils (Rawls et al., 

1993). Griffith et al., (in review) and (Perry et al., in prep.) documented 

that soil moisture and soil organic matter in old growth stands in the Pacific Northwest were significantly higher than in comparable logged 

stands." "Clearly the FFR’s management practices for limiting sediment delivery from roads and logging can not be accurately termed “best management practices,” because they fail to incorporate management practices for 

Analysis area (Chapter 3, Table 3-8). The inclevels at which effects have been seen to wate

timing of peakflows. The proposed harvest awould have negligible effect on hydrologic funstorage, and release of water. See Chapter 2, Table 2-6 - Design Features anRequirements, and monitoring framework fo(Chapter 2, pp. 2-21 to 2-29). See Chapter 3, Hydrology, pp. 3-9 to 3-22 See Appendix D – Best Management Practice
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

doing so, that have been widely recognized as among the most effective measures." 

Rhodes, Jonathan J., Senior Scientist--Hydrologist. Columbia River 

Inter-Tribal Fish Commission 

excerpts from his comment letter on the DEIS for the Proposed 

Issuance of Multiple Species Incidental Take Permits [or ESA 4(d) 

Rules] 

Covering the Washington State Forest Practices Habitat Conservation 

Plan. 9 May, 2005. 

http://72.14.203.104/search?q=cache:NVTQoYGfdz4J:www.wflc.org/si

tefiles/advocacy/folder.2005-10-04.8285560548/folder.2005-10-

13.5531175056/Rhodes_comments_on_FFR_HCP_5-9-

05.doc++%22postfire+logging%22+-

donato&hl=en&gl=us&ct=clnk&cd=86&lr=lang_en

“Letter 2 – Attachment 3 – Comment 43I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect thisthreatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.” 

These statements are generalizations, which avalid in some settings, do not apply to the Cob1) implementation of PACFISH RHCA’s (150 buffers) will prevent sediment from project astreams, 2) Implementation of PACFISH RHthere will be no harvest of trees that could bedebris in waterways, 3) Calculations of equivclearcut/treatment acres by the District HydrCobbler Project would not produce sufficient vegetation to affect streamflows, 4) Since theharvest activities in PACFISH RHCA’s there of trees that could shade streams, and no potestream water temperatures from this source. author’s conclusion of pervasive changes due 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In my experience the most pervasiveand severe impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasivechanges due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.: 

Roelofs, Terry D. Ph.D. Testimony for the California State Water Board 

and Regional Water Quality Control Boards Regarding Waivers of 

Waste 

Discharge Requirements on Timber Harvest Plans. August 2003. 

http://74.125.113.132/search?q=cache:QNy_aih1RxEJ:edennapa.org/th

p/roelofstestimony.doc+%22timber+harvest%22+ph.d.+adverse&hl=en

&ct=clnk&cd=5&gl=us

does not apply to the Cobbler project. Moreotestimony by a third party, which although it considered opinion, it is not peer reviewed maSee Chapter 2, Table 2-6, pp. 2-21 to 2-28; anFisheries, pp. 3-23 to 3-42 for environmental 

Letter 2 – Attachment 3 – Comment 44

 “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

protective strategies made up 76 percent of the preferred management strategies and commodity-based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.” 

Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the 

Rural West”

Rural Development Perspectives, vol. 14, no. 2

http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf

Letter 2 – Attachment 3 – Comment 45

Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact, the justification for the Weeks Act in 1911 which established national forests in the east, was watershed protection. (A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.) 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

“Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, aswell as homes for a myriad of plants and wildlife that can live nowhere else.” 

Sierra Club. 2005 “Ending Commercial Logging on Public Lands” 

http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html

Letter 2 – Attachment 3 – Comment 46

"During the post-World War II housing boom, national forests were viewed as a ready supply of building material. The increased demand for timber from national forests led to more widespread use of commodity-oriented harvesting techniques such clearcutting. Along with the increased logging that followed, concern over the environment increased. In the 1960's and 1970's, several laws were enacted to protect forests. Additional laws formalized the concept of "multiple- use," whereby the uses of timber, forage, and water shared equal footing with wildlife conservation and recreation opportunities." 

USDA Forest Service. "Forest Management: A Historical 

Perspective."

http://www.fs.fed.us/forestmanagement/aboutus/histperspective.shtml

Historical perspective – not science. 

Letter 2 – Attachment 3 – Comment 47

"The development of sound forest-management policies requires that consideration be given to the economic benefits associated with 

Survey information – not science. See response to Letter 2 - Attachment 3 - Com
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

competing uses of forest resources. The benefits that may be provided under different management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasioption value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices and costs." 

Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle 

Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public

Forestlands: A Survey of the Literature.

A study conducted on behalf of the U.S. Forest Service. 

http://www.icbemp.gov/science/vincent.pdf

Letter 2 – Attachment 3 – Comment 48

"Logging removes material that supports physical, chemical, and biological functions in ecosystems. These functions include essential element cycling, carbon storage, erosion control and slope stabilization, water cycling, soil formation, and stream movement processes." 

Voller, Joan and Scott Harrison Ph.D. 

Conservation Biology Principles for Forested Landscapes, 1998 

http://www.ubcpress.ubc.ca/search/title_book.asp?BookID=1571

Down wood is available throughout the forestunits, down wood will be left in place at levels stand type. See Chapter 2, Table 2-6, pp. 2-2Features and Management Requirements. See Chapter 3, Dead Wood, pp. 3-95 to 3-101 

“Letter 2 – Attachment 3 – Comment 49Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitivewildlife. Logging typically requires roads and skid trails which create 

Opinion statement– not science. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who suggests that logging is a benefit or benign is not doing a full accounting of costs.” Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.” 

Wuerthner, George “Who Will Speak For the Forests?” 

NewWest, January 27, 2009 

http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/Letter 2 – Attachment 3 – Comment 50

"After logging, peak pipeflow was about 3.7 times greater than before logging." "The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)." 

Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow

and erosion: coastal northern California, USA." Proceedings of the 

Chengdu 

Some limited soil compaction and associated infiltration rates is anticipated and included i

under Detrimental Soil Condition discussion. increases would be expected only in areas whcreated in long enough distances such that a tcommon in this area) of sufficient intensity cotemporarily reduced infiltration capacity and measures in place at the time. Such condition

to be exceedingly rare. Subsurface pipeflow is not a concern in area proposed actions. 
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LETTER #2 – ATTACHMENT 3 

Statements by Scientists clearly indicating that Commercial Logging Harms the Proper Functioning of For

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Symposium, July 1992. IAHS Publication. No. 209, 1992 

http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF See Chapter 2, Table 2-6 

See Chapter 3, Soils, pp. 3-4 to 3-9 See Appendix E - Soils 

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 5 – Comment 1

"Recently burned areas represent an important type of habitat that many species of animals have evolved to utilize. Snags (standing dead trees) provide critical nesting and foraging habitat for birds and smallmammals, and as they decay and fall, create additional habitat for small mammals and terrestrial amphibians as coarse woody debris. Removal of the largest wood from a site is likely to have large consequences for the species of wildlife that are able to persist there. Post-fire logging is thus likely to interact with several other management objectives on the landscape." 

Campbell, John L. Ph.D, Dan C. Donato, Joe B. Fontaine 

J. Boone Kauffman Ph.D., Beverly E. Law Ph.D., and Doug Robinson 

"Biscuit Fire Study." Oregon State University Department of Forest 

Science 

N/A - No post-fire salvage logging is proposed 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

 Terrestrial Ecosystem Research and Regional Analysis. 2003. 

http://zircote.forestry.oregonstate.edu/terra/biscuit.htm

Letter 2 – Attachment 5 – Comment 2

"Erosion can occur where soil disturbance accompanies fire (e.g., during fire fighting or timber salvage operations)." "Lindenmayer et al. (2004), note that "To many ecologists, natural disturbances are key ecosystem processes rather than ecological disasters that require human repair". The authors also state that salvage harvesting activities undermine many of the ecosystem benefits of major disturbances. That removal of large quantities ofbiological legacies can have negative impacts on many taxa; and that salvage logging removes critical habitat for species, such as cavity nesting mammals, woodpeckers, invertebrates like highly specialized beetle taxa that depend on burned wood, and bryoflora closely associated with recently charred logs. The authors continue, noting that salvage logging can impair ecosystem recovery; and that some taxa may be maladapted to the interactive effects of two disturbance events in rapid succession." "Black-backed and Three-toed Woodpeckers are the species most likely to benefit from unsalvaged burns. Salvage logging in burned forests can have pronounced effects on cavity-nesting species that use post-fire habitats. Salvage logging reduces the number of available snags which impacts populations of Black-backed and Three-toed Woodpeckers, which rarely use even partially-logged post-fire forests." 

N/A - No post-fire salvage logging is proposed 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"Altman (2000) notes that preliminary indications of the importance of post-fire habitat to nest success indicate the need to avoid or minimize the salvage of burned trees in forest burns and suggests that forest harvest practices that retain snags and live trees (potential nest trees) help provide suitable habitat." "Koitlar et al (2002) note that given our limited understanding of the cumulative effects of fire suppression and post-fire salvage logging, and their effects on post-fire habitat availability across the landscape, allowing succession to proceed naturally in unsalvaged burns may benefit the most species." "Some taxa may be maladapted to the interactive effects of two disturbance events in rapid succession. Salvage logging is likely to have unanticipated consequences concerning micro-habitat for species that are associated with recovery." 

Canadian Wildlife Service 

Excerpts from their review notes for the project plans 

for the Barney Lake and False Canyon Creek fires sent to 

Robin Sharples, Environmental Assessment Coordinator 

Government of Yukon, Forest Management Branch. June 13, 2005 

http://www.emr.gov.yk.ca/pdf/barney_and_false_environment_canada

.pdf

Letter 2 – Attachment 5 – Comment 3

 “Since those early days, millions of dollars have been spent on campaigns to prevent forest fires. But researchers now know that fire is not necessarily bad. It can be a natural part of a healthy grassland or 

This is not peer reviewed science 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

forest ecosystem. Fire reduces the build-up of dead and decaying leaves, logs and needles that accumulate on the forest floor. It reduces or eliminates the overhead forest canopy, increasing the sunlight that stimulates new growth from seeds and roots. Many plants and animals have adapted to fire. Both lodgepole pine and jack pine have resin-sealed cones that stay on trees for many years. The heat of fire melts the resin and the cones pop open. Thousands of seeds then scatter to the ground and grow into new stands of pine. Woodpeckers feast on bark beetles and other insects that colonize in newly burned trees. And so, 20 years ago, Parks Canada decided that it wouldn't interfere in natural processes such as fire, insects and disease unless it had to – that is, unless people or neighbouring lands were threatened.” 

CBC News Online, July 6, 2006. “Forest Fires” 

http://www.cbc.ca/news/background/forcesofnature/forestfires.html

Letter 2 – Attachment 5 – Comment 4

 “Fire-killed trees represent an important input of dead wood or coarse woody debris on the landscape, and this substrate is now widely recognized as critical for maintaining biodiversity in managed forests (Esseen et al. 1997; Ehnström 2001; Harmon 2001; Grove 2002). Species associated with dead wood are called “saproxylic” (Speight 1989), and research in Australia (Grove 2002), Canada (Hammond et al. 2001, 2004; Saint-Germain et al. 2004), and Europe (Siitonen and Martikainen 1994; Økland et al. 1996; Martikainen 2001; Siitonen 2001; Kappes and Topp 2004; Martikainen and Kaila 2004) has 

N/A - No post-fire salvage logging is proposed 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

suggested that saproxylic insects are particularly sensitive to intensive forest management because of its effects on volume, exposure, and piece size of deadwood. Many saproxylic insects in Fennoscandian boreal forests either have been extirpated or are currently threatened by reductions in deadwood volume (Siitonen and Martikainen 1994; Martikainen 2001; Siitonen 2001; Grove 2002). In Sweden, for example, Ehnström (2001) reported that more than 1000 beetle species depend directly on dead trees for their survival and that many of those species are currently ‘red-listed’.” (pg 14) 

Cobb, Tyler P. Ph.D. and John R. Spence Ph.D. 

“Pyrophilous Beetles and Postfire Salvage Logging: A Hot

Issue for Sustainable Forest Management and Biodiversity 

Conservation.” 

Arthropods of Canadian Forests, April 2006. 

http://www.biology.ualberta.ca/bsc/pdf/forestarthropodsno2.pdf

Letter 2 – Attachment 5 – Comment 5

“Finally, as mentioned above, wildfires can also generate benefits. Many plants regrow quickly following wildfires, because fire converts organic matter to available mineral nutrients. Some plant species, such as aspen and especially many native perennial grasses, also regrow from root systems that are rarely damaged by wildfire. Other plant species, such as lodgepole pine and jack pine, have evolved to depend on stand replacement fires for their regeneration; fire is required to open their cones and spread their seeds. One author identified research reporting various significant ecosystems threatened by fire exclusion — including aspen, whitebark pine, and Ponderosa pine (western montane ecosystems), longleaf pine, pitch pine, and oak savannah 

This citation does not come from a peer-review
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

(southern and eastern ecosystems), and the tallgrass prairie. [57] Other 

researchers found that, of the 146 rare, threatened, or endangered plants in the coterminous 48 states for which there is conclusive information on fire effects, 135 species (92%) benefit from fire or are found in fire-adapted ecosystems.” [58]“Animals, as well as plants, can benefit from fire. Some individual animals may be killed, especially by catastrophic fires, but populations and communities are rarely threatened. Many species are attracted to burned areas following fires — some even during or immediately after the fire. Species can be attracted by the newly available minerals or the reduced vegetation allowing them to see and catch prey. Others are attracted in the weeks to months (even a few years) following, to the new plant growth (including fresh and available seeds and berries), for insects and other prey, or for habitat (e.g., snags for woodpeckers and other cavity nesters). A few may be highly dependent on fire; the endangered Kirtland’s warbler, for example, only nests under young jack pine that was regenerated by fire, because only fire-regenerated jack pine stands are dense enough to protect the nestlings from predators.” Congressional Research Service Report 

“Forest Fire/Wildfire Protection” 

February 14, 2005

http://www.coloradofirecamp.com/congressional_research/forest-firewildfire-effects.htm

Letter 2 – Attachment 5 – Comment 6

"First, burnt trees are part of the natural forest's ecosystem, and 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

removing them deprives organisms of habitat and nutrients." "Second, much of the timber 'salvaged' is in fact alive and thriving oldgrowth that survived the recent fire (and often several previous ones). They are the forest's heartiest survivors and a big source of biodiversity." "The ecological rationale for salvage logging is very weak. We can't think of any ecological grounds for salvage logging." 

DellaSala, Dominick Ph.D., Mike Wood Ph.D., Christine Ambrose and Dale Thornburgh Ph.D. "Healthy Forests? Scientists See Salvage Logging (not Wildfire Protection) at Center of Healthy Forests Initiative". 

Tidepool. May 20, 2003. 

http://www.tidepool.org/features/healthyF.cfm

“Letter 2 – Attachment 5 – Comment 7The Biscuit fire burned through the Siskiyou Wild Rivers area of Southwest Oregon, home to an astonishing array of rare plants, wild salmon and the largest expanse of unprotected roadless areas along the Pacific Coast. For thousands of years, fire has shaped the region's unique ecology.” “Sen. Gordon Smith calls the post-fire landscape a ‘moonscape,’ and tells us that only logging and tree planting can transform burned areas to green forests.” “The wasteland image was broadly placed in Americans' minds another time - after the Yellowstone fires of 1988. Yellowstone was 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

never salvaged, never planted and never treated with chemicals; the forest has recovered.” “The Biscuit is recovering rapidly, too, although the two forests are quite different. Such regional differences are what ecologists warn against in making the kind of apples-to-oranges comparisons Smith evokes when linking the Biscuit to another high-profile Oregon fire, the Tillamook forest.” “To suggest that environmental lawyers are impeding widespread scientific opinion also misstates the facts. Many scientists both inside and outside federal agencies have expressed legitimate concern about the scientific flaws in the Biscuit plan, but their comments have been largely ignored.” 

DellaSala Dominick A. Ph.D. and James Strittholt, Ph.D. 

“Biscuit fire salvage will harm forest.” 

Eugene Register Guard, September 24, 2004 

http://www.consbio.org/cbi/media/newspaper 

articles/ed.col.biscuit.0924.html

" Letter 2 – Attachment 5 – Comment 8Because the size of required habitats is unknown, Blackbacked Woodpeckers may be vulnerable to local extinction if, for example, post-fire salvage logging reduces or eliminates high-quality habitats(Murphy and Lehnhausen 1998). This relationship was observed in burned ponderosa pine (Pinus ponderosa)/Douglas-fir (Pseudotsuga 

menziesii) forests of southwestern Idaho, where nesting densities of Black-backed Woodpeckers were nearly six times lower in logged 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

versus unlogged units during the first nine years following fire, and non-existent thereafter (Saab and Dudley, unpublished data). Similar results were reported in burned lodgepole pine (Pinus contorta) and Douglas-fir dominated forests of Montana (Harris 1982, Caton 1996)." 

Dudley, J. G. 2005. “Home range size and foraging 

habitat of Black-backed Woodpeckers.” M.S. thesis. 

Boise State University, Idaho. 76 pgs. 

http://www.rmrs.nau.edu/publications/jdudley_thesis_final_web/jdudley_thesis_final_web.pdfLetter 2 – Attachment 5 – Comment 9

 “Trees killed by wildfire and left standing take on roles that change the ecological services they previously provided as components of a green-tree system. They still offer some shade, which in a burned environment can slow the heating of surface waters and the soil surface. They may also provide more rapid recruitment of large wood into streams. Decomposing fallen trees provide nutrients, shelter, and early structure for a rejuvenating forest floor.” “Burned forests typically support significantly different bird communities, with many species dependent on stand-replacement fires to maintain their populations across the landscape. Usually there’s an increase in cavity-nesting, insectivorous birds such as woodpeckers and certain species of flycatchers.” 

Duncan, Sally Ph.D. "Postfire Logging: Is it Beneficial to a

Forest?" USDA Forest Service. PNW Science Findings

issue 47. October 2002. 

http://www.fs.fed.us/pnw/sciencef/scifi47.pdf

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 5 – Comment 10

Lindenmayer et al. (2004), note that "To many ecologists, natural disturbances are key ecosystem processes rather than ecological disasters that require human repair". The authors also state that salvage harvesting activities undermine many of the ecosystem benefits of major disturbances. That removal of large quantities ofbiological legacies can have negative impacts on many taxa; and that salvage logging removes critical habitat for species, such as cavity nesting mammals, woodpeckers, invertebrates like highly specialized beetle taxa that depend on burned wood, and bryoflora closely associated with recently charred logs. The authors continue, noting that salvage logging can impair ecosystem recovery; and that some taxa may be maladapted to the interactive effects of two disturbance events in rapid succession." "Black-backed and Three-toed Woodpeckers are the species most likely to benefit from unsalvaged burns. Salvage logging in burned forests can have pronounced effects on cavity-nesting species that use post-fire habitats. Salvage logging reduces the number of available snags which impacts populations of Black-backed and Three-toed Woodpeckers, which rarely use even partially-logged post-fire forests." "Altman (2000) notes that preliminary indications of the importance of postfire habitat to nest success indicate the need to avoid or minimize the salvage of burned trees in forest burns and suggests that forest harvest practices that retain snags and live trees (potential nest trees) help provide suitable habitat." 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"Koitlar et al (2002) note that given our limited understanding of the cumulative effects of fire suppression and post-fire salvage logging, and their effects on post-fire habitat availability across the landscape, allowing succession to proceed naturally in unsalvaged burns may benefit the most species." "Some taxa may be maladapted to the interactive effects of two disturbance events in rapid succession. Salvage logging is likely to have unanticipated consequences concerning micro-habitat for species that are associated with recovery." 

Environment Canada – Canadian Wildlife Service. Excerpts from their 

review notes for the project plans for the Barney Lake and False 

Canyon Creek fires sent to Robin Sharples, Environmental Assessment 

Coordinator, Government of Yukon, Forest Management Branch. June 

13, 2005 

http://www.emr.gov.yk.ca/pdf/barney_and_false_environment_canada

.pdf

Letter 2 – Attachment 5 – Comment 11

"As mentioned, snags created by fire provide nest and foraging sites.” "Snags also provide important habitat features for other species (Glinslu et al. 1983; Hutto 1995; Sallabanks 1995).” 

Finch, Deborah M. Ph.D., Joseph L. Ganey Ph.D., Wang 

Yong PH.D., Rebecca T. Kimball Ph.D. and Rex 

Sallabanks Ph.D. "Effects and Interactions of Fire,

Logging, and Grazing." USDA Forest Service. Gen.

Tech. Rep. RM-GTR-292, Chapter 6. 1997. 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

http://www.rmrs.nau.edu/publications/rm_gtr292_ch6/rm_gtr292_ch6.

pdf

Letter 2 – Attachment 5 – Comment 12

"Natural forest disturbances, including fire, kill trees but remove very little of the total organic matter. Combustion rarely consumes more than 10 to 15 percent of the organic matter, even in stand-replacement fires, and often much less. Consequently, much of the forest remains in the form of live trees, standing dead trees, and logs on the ground. Also, many plants and animals typically survive such disturbances. This includes living trees, individually and in patches." "These surviving elements are biological legacies passed from the predisturbance ecosystem to the regenerating ecosystem that comes after. Biological legacies are crucial for ecological recovery. They may serve as lifeboats for many species, provide seed and other inocula, and enrich the structure of the regenerated forest. Large old trees, snags, and logs are critical wildlife habitat and, once removed, take a very long time to replace." Franklin, Jerry F. Ph.D. and James K. Agee Ph.D."Forging a ScienceBased National Forest Fire Policy."Issues in Science and TechnologyFall 2003.http://www.portlandonline.com/shared/cfm/image.cfm?id=17300

4

No question or specific comment to respond to 

planning document. 

" Letter 2 – Attachment 5 – Comment 13It is sometimes argued that following a stand-replacement fire in an old-growth forest that snags and logs are present in 'excess' of the needs of the site, in terms of ecosystem recovery. In fact, the large pulse of dead wood created by the disturbance is the only significant input of woody debris that the site is going to get for the next 50 to 150 

This is testimony regarding scientific knowledappropriate management activities following a disturbance. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

years. The ecosystem has to 'live' off of this woody debris until the forest matures to the point where it has again produced the large trees that can become the source for new snags and logs (Maser et al. 1988)." 

Franklin, Jerry F. Ph.D. Testimony to the House 

Committee on Resources, Subcommittee on 

Forests and Forest Health. July 15, 2004. 

http://www.wildfirecentral.org/facts/upload/CongrTestRestoringForest

s(071504).pdf

Letter 2 – Attachment 5 – Comment 14

"In point of fact, disturbances are natural, ecosystems have tremendous resilience and great value (human, environmental, educational). (This) comes from leaving disturbed areas alone and allowing them to recover naturally." 

Goforth, Sarah. "Log it or leave it?" Why Files. 2004. 

http://whyfiles.org/shorties/148_salvage_logging/

Opinion statement– not science. 

Letter 2 – Attachment 5 – Comment 15

 “Research had documented that, in some situations, wildfires brought ecological benefits to the burned areas — aiding regeneration of native flora, improving the habitat of native fauna, and reducing infestations of pests and of exotic and invasive species.” (pg 2) 

Gorte, Ross W. Ph.D. from a CRS report for Congress, January 18, 

2006 http://www.ncseonline.org/nle/crsreports/06Feb/RL30755.pdf

A variety of fuel treatments are proposed in tharea to address the purpose and need of the prTable 2-10, p. 2-36 - Comparison of Alternativinevitable at some point in the future. Harvest are designed to increase the probability of survearly seral species after a wildfire by reducing seral species and small trees. 

Letter 2 – Attachment 5 – Comment 16

 “Ecologists and fire experts unanimously agree that fire has served an essential role in certain ecosystems for millennia. The ecological 

This citation does not come from a peer-review
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

benefits of fire include: the creation of critical wildlife habitat in standing dead trees, increased nutrients and productivity in soil systems when burned material decomposes, improved conditions for surviving old growth trees when a surface fire moves through a system, and the regeneration of some fire dependent trees like lodgepole pine (Pinus contorta). Fire also increases availability of other fundamental building blocks of ecosystems such as moisture and sunshine by opening up the canopy and returning nutrients to the soil. Natural fire cycles maintain the diversity of habitats available to all the species in the ecosystem, from wildlife to wildflowers to fungi.” 

Gregory, Lisa Dale Ph.D. 

“Wildland Fire Use: An Essential Fire Management Tool”

A Wilderness Society Policy and Science Brief 

December 2004 

http://wilderness.org/Library/Documents/upload/ScienceBriefWildlandFireUseEssentialTool.pdf

Letter 2 – Attachment 5 – Comment 17

 “Fire is a natural process in the boreal forest. The plants and the animals rely on fire to maintain a natural balance of vegetation and wildlife abundance. Without habitat mosaics created by fire throughout the boreal forest, many species would not exist.” 

Haggstrom, Dale A and Thomas F. Paragi 

“Fire Ecology FAQs” 

http://wildlife.alaska.gov/index.cfm?adfg=fire.fire5

This citation does not come from a peer-review

Letter 2 – Attachment 5 – Comment 18

In 2007, we are witnessing one of the "worst" wildfire years in recent 

Opinion statement– not science. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

history, as measured in acres burned, suppression costs, and loss of property. We tend to view loss of property or timber value, and aesthetics. This perspective was greatly promoted by the U.S. Forest Service and the highly successful Smokey the Bear campaign that continues, albeit much reduced. When examined from a more objective, ecological perspective, the benefits of wildfire greatlyexceed the negatives. This illustrated presentation examines the ecology of wildfire and presents the case that our anthropocentric perspective often clouds a more balanced understanding of nature where even bears are benefactors of fire.” Haney, Alan Ph.D.Introduction to the keynote presentation of the 8th

annual Wisconsin Association of Lifelong Learning conference University of Wisconsin Stevens Point, October 25, 2007

http://www.uwsp.edu/conted/wall/conference.aspxLetter 2 – Attachment 5 – Comment 19

"Public land is the only hope for these burned ecosystems. These are the only places left where we can let fire play its natural role."

Hutto, Richard Ph.D., "One year after fire, 

Black Mountain is springing back to life." The

Missoulian. August 1, 2004 

http://www.missoulian.com/articles/2004/08/01/news/top/news01.txt

N/A - No post-fire salvage logging is proposed 

Letter 2 – Attachment 5 – Comment 20

"Burned forests have great ecological significance and importance. It is important for the public and policymakers to recognize the role of burned forests in maintaining wildlife populations and healthy forests."

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"From my perspective as a bird-research biologist, I have become aware of one of nature's best-kept secrets ... there are some bird species that one is hard-pressed to see anywhere else but in burned forests." "The species whose habitat distribution is more restricted than any other to burned-forest conditions is the black-backed woodpecker. Everything about it, including its jet-black coloration, undoubtedly reflects a long evolutionary history with burned forests. There are many additional bird species, including the mountain bluebird, threetoed woodpecker and olive-sided flycatcher, that also reach their greatest abundance in burned forests." "This is important because if we value and want to maintain the full variety of organisms with which we share this Earth, we must begin to recognize the healthy nature of burned forests. We must also begin to recognize that post-fire logging removes the very element (the standing dead trees) upon which each of those bird species depends for nest sites and food resources." 

Hutto, Richard L. Ph.D., "Post-fire logging is bad for

forests and wildlife." Special to The Seattle Times 

December 8, 2005. 

http://seattletimes.nwsource.com/html/opinion/2002670756_burnedfor

ests08.html

Letter 2 – Attachment 5 – Comment 21

"Far from being a 'wasted resource,' large-diameter snags and logs play critical structural and functional roles in maintaining healthy, diverse wildlife populations. Indeed, an ecologist could argue that a dead tree 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

sustains more wildlife than a live tree." "Fire-killed snags and logs provide: 

• food and shelter to wildlife, fish, and numerous insects, 

microbes, and fungi that are vital to post-fire recovery and long-term site productivity, 

• they help retard surface water runoff and help retain and 

build soil, 

• they help cycle nutrients and water to plants and soil, and • snags that fall across streams provide links between 

terrestrial and aquatic ecosystems." 

Ingalsbee, Timothy Ph.D. 2004. "Salvaging Timber;

Scuttling Forests: The Ecological Effects of Post-Fire

Salvage Logging". Western Fire Ecology Center. 

http://www.klamathforestalliance.org/Documents/scuttlingforests.html

Letter 2 – Attachment 5 – Comment 22

"Trees in a burned landscape, both dead and alive, continue to provide homes for wildlife after a fire and form the building blocks of new forests." "We need a more complete view of what a forest is." "This more complete view of forests will acknowledge, rather than ignore or distort, the science that tells us forests best serve manyhuman needs when they are viewed as vast, complex systems where uninformed actions inevitably have unintended consequences. And the science shows very clearly that post-fire salvage logging is not the way to restore forests." 

Karr, James R. Ph.D., "Nature doesn't Benefit from

Logging Fire-Damaged Lands". 

N/A - No post-fire salvage logging is proposed The objective of this project is for the stands to disturbance in ways that are within the HRV. composition and densities have made the area levels of mortality than before fire suppression 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

 Op-Ed Tacoma NewsTribune. December 8, 2005. 

http://www.thenewstribune.com/opinion/othervoices/story/5379671p4864728c.ht

Letter 2 – Attachment 5 – Comment 23

 “What you may not know, however, is that certain forms of disturbance play a vital role in sustaining our forests. Although people see wildland fires, wind and ice storms, and insect outbreaks as “catastrophes” affecting federal and nonfederal lands, over time, such events have in fact both created and helped sustain the character of many regional ecosystems.” “My remarks today are based on my ecological research over four decades, particularly on research over the past 12 years with a dozen scientists and others, examining what happens when areas affected by natural disturbances are left to regenerate on their own or when humans intervene.” 

Karr, James R. Ph.D. 

Testimony about the Forest Emergency Recovery and Research Act 

to the House Rural Revitalization, Conservation, Forestry and Credit 

Subcommittee August 2 2006 

http://agriculture.senate.gov/Hearings/hearings.cfm?hearingid=2037&

w itnessId=5628

N/A - This does not apply to this project. 

Letter 2 – Attachment 5 – Comment 24

"Natural disturbances are key ecosystem processes rather than ecological disasters that require human repair. Recent ecological paradigms emphasize the dynamic, non-equilibrial nature of ecological systems in which disturbance is a normal feature and how natural 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

disturbance regimes and the maintenance of biodiversity and productivity are interrelated." 

Lindenmayer, D.B. Ph.D., D.R. Foster Ph.D., J.F. 

Franklin Ph.D., M.L Hunter Ph.D., R.F. Noss Ph.D., F.A. 

Schmiegelow Ph.D., and D. Perry Ph.D. "Salvage

harvesting policies after natural disturbance" 

Science Vol. 303. Page 1303. February 27, 2004. 

http://inr.oregonstate.edu/download/salvage_harvesting_policies_after

_natural_disturbance.pdf

Letter 2 – Attachment 5 – Comment 25

 “Fire releases nutrients and uncovers bare soil. The blackened, bare soil warms quickly, which stimulates soil microbial activity, nutrient cycling, and plant growth. In forests, fire opens up part of the canopy to sunlight, which allows sun-loving plant species to recolonize the site.” “Following fires, plant communities go through successional changes. Many native wildlife species and popular game species, such as bobwhite quail, white-tailed deer, and wild turkey, are dependent on periodic fire to create and maintain suitable habitat. Surface fires can stimulate the growth of herbaceous foods for deer, elk, moose, and hares, and can enhance berry production for black bears and other wildlife. Small mammal populations generally increase in response to new vegetation growth, providing a food source for carnivores. Fire can also reduce internal and external parasites on wildlife.” (pg. 2) “natural disturbance such as fires, floods, and herbivory are critical in maintaining valuable ecosystem functions and creating and restoring 

This citation does not come from a peer-reviewA variety of fuel treatments are proposed in tharea to address the purpose and need of the prTable 2-10, p. 2-36 - Comparison of Activity by Removing excess stocking and understory builfrom decades of fire prevention would allow thwithin the historical range of variability of sevoccur. 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

wildlife habitat.” (pg. 7) 

Marks, Raissa 

Fish and Wildlife Habitat Management Leaflet number 37

Published by the Natural Resources Conservation Service, USDA, 

April 2006 

ftp://ftpfc.sc.egov.usda.gov/NHQ/ecs/Wild/ImportofDisturbInHabMgt.pdf

Letter 2 – Attachment 5 – Comment 26

"During recent decades, ecologists have learned that forest fires were a pervasive phenomenon in practically all forests of the world, even the rainforests. Humans have severely disrupted the natural pattern of fire across the landscape, especially during the last 100 years. Therefore, if forests are to be returned to their more 'natural' state, fire will have to be reintroduced." 

Martinez, Lori “Applications of Tree-Ring Dating” 

Laboratory of Tree-Ring Research at the University of Arizona 

February, 2000 

http://www.ltrr.arizona.edu/lorim/apps.html

See response to Letter 2 – Attachment 5 – Com

Letter 2 – Attachment 5 – Comment 27

"Logs and other woody debris, such as stumps, root wads, bark, and piles of limbs, occur on the floor of most forest ecosystems. These features provide diversity in the environment and are of varying significance as habitat for terrestrial wildlife (Winn 1976). In the Blue Mountains 179 species of vertebrates (5 amphibians, 9 reptiles, 116 birds, and 49 mammals) make some use of logs. Elton (1966, p. 279)." 

Down wood is available throughout the forest. down wood will be left in place at levels approtype. See Chapter 2, Table 2-6, pp. 2-21 to 2-2and Management Requirements. See Chapter 3, Dead Wood, pp. 3-95 to 3-101 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

"The large amount of slowly decomposing woody debris in western forests has important ecological implications in terms of mineral cycling, nutrient immobilization (Fogel and Cromack 1977 and MacMillan et al. 1977), nitrogen fixation (Cornaby and Waide 1973), and wildlife habitat." "Vertebrates use logs for a variety of reasons and in a variety of ways, the most obvious of which are for hiding cover and as sites for feeding and reproduction. A variety of animals use logs as feeding sites (Deyrup 1975). Food is carried to a log where it is eaten or stored, or it can be obtained from the log itself. Some reptiles, birds, and mammals reproduce alongside, under, or within logs.” 

Maser, Chris Ph.D., Ralph G. Anderson, Kermit Cromack Ph.D. 

Jerry T. Williams and Robert E. Martin Ph.D. "Dead and Down 

Woody Material Taken from Wildlife Habitats in Managed 

Forests the Blue Mountains of Oregon and Washington.” October 

1991. 

http://www.fs.fed.us/r6/nr/wildlife/animalinn/hab_6ddwm.htm

Letter 2 – Attachment 5 – Comment 28

"The natural recovery of streams after fires can result in improved fish habitat if we do not interfere with the natural recovery processes thatinitiate themselves soon after the fires are gone." 

Minshall, G. Wayne Ph.D, Judy L. Meyer Ph.D, Jack A. 

Stanford Ph.D, James R. Karr Ph.D and Christopher A. 

Frissell Ph.D. Excerpts from an open letter to President 

Clinton. September 19, 1994. 

http://www.metla.fi/archive/forest/1994/09/msg00047.html

No post-fire salvage logging is proposed for thiComment addresses management of habitat afproject is not a management-after-fire type of comment does not relate to the Cobbler projecletter, not a peer-reviewed article. 
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LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 5 – Comment 29 “The habitat of Black-backed Woodpeckers in Montana is early successional, burned forest of mixed conifer, lodgepole pine, Douglasfir, and spruce-fir (Hutto 1995a). They appear to concentrate in recently burned forests and remain for several years (3 to 5) before leaving due to prey source decline (Harris 1982).” “Black-backed Woodpeckers may be attracted by the clearly audible chewings of wood-boring insects in recent burns (Taylor and Barmore 1980).” 

Montana Field Guide for Black-backed Woodpeckers Current version 

http://fieldguide.mt.gov/detail_ABNYF07090.aspx

N/A - There is no burned forest habitat within planning area. 

Letter 2 – Attachment 5 – Comment 30

"Contrary to what you may think, a forest fire does not reduce everything to a lifeless ash. Instead, it leaves behind a landscape of blackened trees interspersed with remnants of green, intact forest. Post-fire specialists such as wood-boring insects quickly colonize the dead trees (snags), attracting an array of woodpeckers." "Identifying the ecological value of a post-fire structure and the characteristics that make it attractive to wildlife is important. In the boreal, salvage logging operations, which recover merchantable timber from a recently burned area, are increasingly common and have the potential to greatly reduce the availability of snags, as well as other habitat structures, created by fire. In the case of the black-backed woodpecker, Nappi and colleagues recommend that within recently 

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-101

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

burned areas, unsalvaged tracts characterized by large, less severely burned trees should be retained in northeastern North America." 

Nappi, Antoine Ph.D., Pierre Drapeau Ph.D., Jean-François 

Giroux Ph.D., and Jean-Pierre Savard Ph.D. “Snag use

by foraging black-backed woodpeckers (Picoides

articus) in a recently burned eastern boreal forest.”

The Auk 120(2): 505-511. 2003.

http://www.borealcanada.ca/research_arc_hot_e.cfm

Letter 2 – Attachment 5 – Comment 31

"Pioneer studies have shown that these post-fire forests may represent important habitats for several wildlife species and that intensive salvage logging, by removing standing snags, has several impacts on wildlife." 

Nappi, Antoine Ph.D., Pierre Drapeau, Ph.D. and Jean-Pierre 

Savard Ph.D. "Salvage Logging after Wildfire in the

Boreal Forest: Is it becoming a Hot Issue for Wildlife?" 

The Forestry Chronicle, January/February 2004. 

http://pubs.nrc-cnrc.gc.ca/tfc/tfc80067-1.html

N/A - No post-fire salvage logging is proposed 

Letter 2 – Attachment 5 – Comment 32

"Although numerous studies report a positive response to some types of harvested forest in the United States and Canada, Olive-sided Flycatchers have experienced precipitous population declines in nearly every region of its breeding range. These declines may likely be due to major deforestation on its wintering grounds. Additionally, it has been speculated that Olive-sided Flycatchers historically depended on 

Large amounts of post-fire habitat and other nis available on the entire Umatilla National Fosnags are retained within harvest areas that prfor olive-sided flycatcher. It is unclear how fospecies on its breeding range. See Chapter 2, Table 2-6, pp. 2-21 to 2-28. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-102

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

post-fire habitats, so it has been proposed that harvested forests may actually be an ecological trap: while they look similar to a post-burn forest, they may function quite differently." 

“Olive-sided Flycatcher (Contopus cooperi)” 

Audubon WatchList Online. 2002. 

http://audubon2.org/webapp/watchlist/viewSpecies.jsp?id=152

Letter 2 – Attachment 5 – Comment 33

"A common thread running through all of these studies was the importance of snags. Even dead trees have an important ecological role in the forest. They provide nesting and foraging habitat for wildlife and a seed source for regenerating tree species such as black spruce for several years after fire. They may provide favourable microclimate conditions for establishment and growth of seedlings and understorey vegetation, and constitute nutrient reserves, especially for stands with an important deciduous component." 

Purdon, Mark Ph.D., Josée Noël, Antoine Nappi Ph.D., Pierre 

Drapeau Ph.D., Brian Harvey Ph.D., Suzanne Brai 

 Ph.D., Yves Bergeron Ph.D., Sylvie Gauthier PH.D. and 

David Greene Ph.D. "The Impact of Salvage-logging

after Wildfire in the Boreal Forest: Lessons from the

Abitibi" A report by the NSERC-UQAM-UQÀT Industrial 

Chair in Sustainable Forest Management. 2002. 

http://inr.oregonstate.edu/download/impact_of_salvagelogging_after_wildfire_in_boreal_forests.pdf

N/A - No post-fire salvage logging is proposed 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-103

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 5 – Comment 34

"Forest fires have long been regarded as an interference with normal forestry practices by removing potentially viable timber allocations. Furthermore, provincial forest policies have encouraged quick clearcut harvesting of any merchantable trees (dead or alive) left within themapped perimetre of a fire ... otherwise known as salvage-logging. And because beetles colonise immediately and bore into the trees (ruining their use for lumber) harvesting also happens immediately to out race the economic loss to insects. When this happens, the natural link in boreal forest succession is ultimately broken." 

Rasmussen, Ray Ph.D., Environmental News, Volume 1, 

Issue 1. November 2001. 

http://www.ualberta.ca/~ersc/enews/EN2001a.pdf

N/A - No post-fire salvage logging is proposed 

Letter 2 – Attachment 5 – Comment 35

“Disturbances, from windthrown trees to fires, are natural in forests and are essential for forest ecosystem well being. For example, fire is a disturbance in forests, but it is also beneficial. While disturbances kill some individuals, they also open up ecological living space for recolonization by many previously excluded species. Without fire, natural succession is upset. In a forest where fire has been unnaturally suppressed for many years (50 or more), fire intolerant trees grow unchecked, suppressing and outcompeting the normally dominant fire resistant trees. Overall biodiversity is reduced. As the tree diversity declines, the habitat becomes unsuitable for a large portion of the forest species. Animal species are lost, since theanimals use the fire tolerant variety of tree species for food, shelter and nest sites. 

This citation does not come from a peer-review
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-104

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Clearcutting is not ecologically equivalent to fire, and it does not mimic the beneficial effects of fire. We need large tracts of unfragmented forests so that fires can return as a normal part of the overall forest ecosystem. If fire is unnaturally suppressed, a Southeastern longleaf pine savannah is transformed into an oakhickory forest. The most famous fire dependent species of the longleaf pine ecosystem is the Red Cockaded Woodpecker. In order to nest and reproduce, it needs the tall, old, isolated pines which have survived repeated fires. Without fire, the Red Cockaded Woodpecker will go extinct. Scientific understanding of forest ecosystems has advanced tremendously since the establishment of the national forests. The Act to Save America’s Forests would harmonize federal forest management with these new understandings, and would restore and maintain dynamic living ecosystems with native plants and animals for the long term benefit of future generations of Americans.” Reice, Seth, Ph.D.from a press conference with Senator Robert Torricelli, April 28, 1998, http://www.saveamericasforests.org/news/ScientistsStatement.htmLetter 2 – Attachment 5 – Comment 36

"Olive-sided Flycatcher densities have been found to increase in habitats that have been opened up by fires. In some areas they have been found to be closely associated with post-fire habitat. Allowing fires to burn and refraining from salvage logging is recommended. The loss of natural forest processes has had a detrimental effect upon this species." 

Robinson, J. and J. Alexander.Ph.D. “The draft

coniferous forest bird conservation plan: a strategy for

N/A - No post-fire salvage logging is proposed See response to Letter 2- Attachment 5 – Com
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-105

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

protecting and managing coniferous forest habitats and

associated birds in California.” Version 1.0. 2002. 

http://www.prbo.org/calpif/pdfs/conifer.v-1.pdf

Letter 2 – Attachment 5 – Comment 37

"Because so many animals rely on dead wood during some part of their lives, snag, limb, and log retention is an essential component of any wildlife conservation or management plan." 

Santiago, Melissa J. and Amanda D. Rodewald Ph.D.. 

"Dead Trees as Resources for Forest Wildlife". Ohio 

State University Extension Service Factsheet.

Winter 2004. 

http://ohioline.osu.edu/w-fact/pdf/0018.pdf

Snags and down logs are retained within units for the stand types. Snags are abundant in the See Chapter 2, Table 2-6, pp. 2-21 to 2-28; and Wood, pp. 3-95 to 3-101 

Letter 2 – Attachment 5 – Comment 38

"Species that breed exclusively in the first 30 years after fire may be difficult to maintain in the ecosystem without fire. Fire exclusion and post-fire salvage of dead trees after fire may reduce populations of these species over large geographic areas." 

Smith, Jane Kapler, ed. "Wildland Fire in Ecosystems:Effects of Fire on Fauna" USDA Forest Service Rocky 

Mountain Research Station. General Technical Report

RMRS-GTR-42-volume, January 1, 2000. 

http://nps.gov/fire/download/fir_eco_wildlandfireJan2000.pdf

N/A - No post-fire salvage logging is proposed Fire is being introduced back into the ecosysteSee Chapter 1, Purpose and Need for Action, p
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-106

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 5 – Comment 39

 “Ecological benefits of fire: 

• Promotes flowering of herbaceous species and fruit 

production of woody species. 

• Improves nutritional quality of plants for both wild and 

domestic animals. 

• Enhances nutrient cycling of some elements and elevates 

soil pH. 

• Maintains required habitat conditions for fire-adapted plant 

and animal species. 

• Results in a more heterogenous and diverse habitat--if 

natural fires are patchy--leaving pockets of unburned areas. 

• Prohibits wildfire conditions from developing (i.e., vast 

accumulation of highly-flammable, dead vegetation.)” 

Tanner, G.W. Ph.D., W.R. Marion Ph.D., and J.J. Mullahey Ph.D. 

“Understanding Fire: Nature's Land Management Tool” 

A Florida Cooperative Extension Service publication, July, 1991 

http://edis.ifas.ufl.edu/UW124

This citation does not come from a peer-review

Letter 2 – Attachment 5 – Comment 40

"Forest managers are increasingly aware of the significance of Aldo Leopold’s admonition that 'to keep every cog and wheel is the first rule of intelligent tinkering.' Dead wood, standing and down, is one of those 'cogs and wheels'." "In the early stages of our careers, dead wood in any form was considered the bane of foresters who had been trained to focus on the 

See Chapter 2, Table 2-6, pp. 2-21 to 2-28; Chapp. 3-95 to 3-101;and Finding of Consistency o
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-107

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

most efficient commercial production of wood and wood fiber. Snags (standing dead trees) were considered a safety hazard to woodland workers and a potential source of spreading sparks that ignited spot fires. Down woody material was considered 'fuel' that facilitated the spread of fire, a haven for vertebrate pests that hampered reforestation, and unsightly (Maser and others 1979)." "I often ponder why Aldo Leopold’s admonition about keeping 'cogs and wheels' is widely quoted and how often we are surprised at the consequences, both ecological and political, when it is ignored. By now, we should have learned that all the segments of a 'naturally' functioning ecosystem play some role in that system ... whether or not we understand all the relationships. And we should have learned by now that biological systems are significantly simplified at some peril to the maintenance of that system." "In retrospect, it is amazing that forest managers did not realize that dead wood was a critical habitat component for vertebrate and invertebrate wildlife and for the forest itself." "Perhaps the greatest challenge that faces professionals engaged in forest research and management is the organization of knowledge and insights into forms that can be readily applied. To say we don’t know enough is to take refuge behind a half-truth and ignore the fact that decisions will be made regardless of the amount of information available. In my opinion it is far better to examine available knowledge, combine it with expert opinion on how the system operates, and make predictions about the consequences of alternative management actions." 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-108

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

Thomas, Jack Ward Ph.D. "Dead Wood: From Forester’s

Bane to Environmental Boon". Keynote address at the 

symposium on ecology and management of deadwood 

in western forests, Reno, Nevada. 1999. 

http://64.233.167.104/search?q=cache:SavhPwhMtoJ:199.128.173.130/psw/publications/documents/gtr181/003_Thomas.pdf+%22jack+ward+thomas%22+keynote+1999+re

no&hl=en&lr=lang_en

Letter 2 – Attachment 5 – Comment 41

"Fire is an essential, natural and necessary part of Western forest ecology. Many species of trees can only reproduce after fires occur. Wildland fires burn underbrush and return important nutrients to the soil." 

Voss, René 

“Getting Burned by Logging,” July 2002 

The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Opinion statement – not science. 

Letter 2 – Attachment 5 – Comment 42

 “It is well known that cavity nesting birds rely on the presence of dead trees for nesting sites. Hejl et al. (2000), Saab and Dudley (1998), Caton (1996), and Hitchcox (1996).” Wilson, Seth M. Ph.D. and John J. Citta Ph.D. comments submitted to the Montana Department of Natural Resources and Conservation on the Sula State Forest Recovery and Salvage Operations September 19, 2000 

N/A - No post-fire salvage logging is proposed See response to Letter 2 – Attachment 5 – Com
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-109

LETTER #2 – ATTACHMENT 5 

Statements by Scientists clearly indicating that Wildfire Benefits Forested Ecosystems 

• Numerous references to post-fire logging were not considered because this project does not propose any post-

• References that were opinion pieces and those referencing specific geographical areas were not considered. 

RICHARD ARTLEY 

Comment Our Response 

http://64.233.167.104/search?q=cache:NIo9oJIcbfYJ:www.landsinfo.org/ecosystem_defense/Montana_State/Dept_Nat_Res/Sula%2520State%2520Forest/Sula%2520salvage%2520cmt%2520by%2520Wilson%2520and%2520Citta.doc+postfire+salvage+ph.d.&hl=en&ct=clnk&cd=47&gl=usLetter 2 – Attachment 5 – Comment 43 “Healthy ecosystems burn, and often burn by the tens of millions of acres. The spate of large wildfires we are experiencing now are not “abnormal” or an indication of “unhealthy” forest. Rather, we are seeing the natural response of a healthy forest ecosystem. Given that wildfire was so common for thousands of years, it is not surprising that recent research shows that wildfires, particularly severe wildfires, increase biodiversity. If anything, we probably need more wildfire, not less. With global warming we will probably get it, as vegetative communities adapt to new climatic realities.”

Wuerthner, George. “Logging, thinning would not curtail wildfires” 

The Register - Guard (Eugene Ore.), December 26, 2008

http://wuerthner.blogspot.com/2008/12/logging-thinning-would-notcurtail.html

This citation does not come from a peer-review
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-110

LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 6 – Comment 1

“large, severe wildfires are more weather-dependent than fueldependent,” 

Agee, James K. Ph.D. “The Severe Weather Wildfire-Too Hot to 

Handle?

Northwest Science, Vol. 71, No. 1, 1997 

http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf

No question or specific comment to respond t

planning document. 

Letter 2 – Attachment 6 – Comment 2

 “One reason that fuels reduction treatments should be limited is thatthey may not address the important effects of climate and weather on fire behavior. Some studies suggest that it is drought and warmer temperatures—not fuels accumulations—that are the major explanatoryfactors for large fires (O’Toole 2002-2003, Pierce et al. 2004). It is an unrealistic goal to return all forests to historical states, in light of the fact that agencies have no control over drought or temperature.” (pgs. 15 – 16) 

Berry, Alison Ph.D., 2007. “Forest Policy Up in Smoke: Fire 

Suppression

in the United States.” A PERC publication. 

http://www.law.northwestern.edu/searlecenter/papers/Berry_forest

_policy.pdf

This citation does not come from a peer-revie

Letter 2 – Attachment 6 – Comment 3

 “Fire intensity was correlated to annual area burned; large area burned years had higher fire intensity predictions than smaller area burned years. The reason for this difference was attributed directly to the 

No question or specific comment to respond tplanning document. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-111

LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

weather variable frequency distribution, which was shifted towards more extreme values in years in which large areas burned. During extreme weather conditions, the relative importance of fuels diminishes since all stands achieve the threshold required to permit crown fire development. This is important since most of the area burned in subalpine forests has historically occurred during very extreme weather (i.e., drought coupled to high winds). The fire behavior relationships predicted in the models support the concept that forest fire behavior is determined primarily by weather variation among years rather than fuel variation associated with stand age.” 

Bessie, W. C. Ph.D. and E. A. Johnson Ph.D. “The Relative 

Importance of Fuels and

Weather on Fire Behavior in Subalpine Forests” Ecology, Vol. 76, 

No. 3 (Apr., 1995) 

pp. 747-762. Published by: Ecological Society of America

http://www.jstor.org/pss/1939341

Letter 2 – Attachment 6 – Comment 4

 “Climatic conditions drive all big fires— not fuels. All substantial fires occur only if there is extended drought, low humidity, high temperatures and, most importantly, high winds. When conditions are "ripe" for a large blaze, fires will burn through all kinds of fuel loads. For this reason, most fires go out without burning more than a few acres; approximately 1 percent of all fires are responsible for about 95 percent to 99 percent of the acreage burned.” “Under severe conditions, fires burn through all kinds of fuel loads including thinned/logged forests. Contrary to what the U.S. Forest Service has stated about the Ojo Peak Fire, local witnesses have said the fire blew right through the hotter, drier thinned forests where the 

This citation does not come from a peer-revie
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-112

LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

cooling effect of forest canopy had been removed.” Bird, Bryan “Fires Normal Part of Ecology - Fear of fires ungrounded” Mountain View Telegraph, December 20, 2007 http://www.wildearthguardians.org/library/paper.asp?nMode=1&nLibraryID=567Letter 2 – Attachment 6 – Comment 5

 “most large fires are climatic/weather driven events, not fuels driven. Extended drought, high winds, high temperatures and low humidity enable fires to burn through all fuel loadings.” 

“California: Too often thinning treatments tend to increase fire hazards”

Forest Policy Research

http://forestpolicyresearch.org/2008/12/19/california-too-oftenthinning-treatments-tend-to-increase-fire-hazards/

This citation does not come from a peer-revie

“Letter 2 – Attachment 6 – Comment 6"Problems exist with over-generalizing the effects of fire exclusion, and misapplying data derived from short-interval forest ecosystems (e.g. ponderosa pine stands) to long-interval forest ecosystems that have not missed their fire cycles yet and are still within their historic range of variability for stand-replacing fire events (e.g. high elevation lodgepolepine or fir stands)." 

Ingalsbee, Timothy Ph.D. 2000. “Money to Burn: The Economics of 

Fire and Fuels Management, Part One: Fire Suppression. “An 

American Lands Alliance publication. 

www.fire-ecology.org/research/money_to_burn.html

This citation does not come from a peer-revie

Letter 2 – Attachment 6 – Comment 7There is a gathering body of evidence that large wildfires are not 

This citation does not come from a peer-revie
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

determined by “unnatural” fuel loading. Lodgepole pine, subalpine fir, and aspen depend on infrequent, stand-replacing, high intensity fires. Most of the B-D NF is well within the natural range of variability. In fact, dense forest stands may not be caused by fire exclusion, but by a series of consecutive wet years that boosted seedling survival and expanded the local range. Drought, wind, and low humidity, not fuels loads, drive large wildifires. Weather and climatic conditions are also the driving force behind expanding insect populations.” 

Kelly, Steve Ph.D. 2007. “Cheap Chips, Counterfeit Wilderness: 

Greenwashing Logging on Montana's Biggest National Forest.” 

Published by the World Prout Assembly 

http://www.worldproutassembly.org/archives/2007/12/cheap_chips_

cou.html

Letter 2 – Attachment 6 – Comment 8We inferred climate drivers of 20th-century years with regionally synchronous forest fires in the U.S. northern Rockies. We derived annual fire extent from an existing fire atlas that includes 5038 fire polygons recorded from 12070086 ha, or 71% of the forested land in Idaho and Montana west of the Continental Divide. The 11 regional-fire years, those exceeding the 90th percentile in annual fire extent from 1900 to 2003 (>102314 ha or ~1% of the fire atlas recording area), were concentrated early and late in the century (six from 1900 to 1934 and five from 1988 to 2003). During both periods, regional-fire years were ones when warm springs were followed by warm, dry summers and also when the Pacific Decadal Oscillation (PDO) was positive. Spring snowpack was likely reduced during warm springs and when PDO was 

No question or specific comment to respond tplanning document. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

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LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

positive, resulting in longer fire seasons. Regional-fire years did not vary with El Nino-Southern Oscillation (ENSO) or with climate in antecedent years. The long mid-20th century period lacking regionalfire years (1935-1987) had generally cool springs, generally negative PDO, and a lack of extremely dry summers; also, this was a period of active fire suppression. The climate drivers of regionally synchronous fire that we inferred are congruent with those of previous centuries inthis region, suggesting a strong influence of spring and summer climate on fire activity throughout the 20th century despite major land-use change and fire suppression efforts. The relatively cool, moist climate during the mid-century gap in regional-fire years likely contributed to the success of fire suppression during that period. In every regional-fire year, fires burned across a range of vegetation types. Given our results and the projections for warmer springs and continued warm, dry summers, forests of the U.S. northern Rockies are likely to experience synchronous, large fires in the future. 

Morgan, Penelope Ph.D., Heyerdahl, Emily K. and Gibson, Carly E. 

(2008), "Multi-season climate synchronized forest fires throughout 

the 20th century, Northern Rockies", Ecology, 89, 3: 717-728. 

http://www.firelab.org/index.php?option=com_jombib&task=show

bib&id=343

Letter 2 – Attachment 6 – Comment 9

 “While top officials blame recent fires on fuels, all the on-the-ground reports I've read focus on the weather.” 

O'Toole Randal. “Incentives, Not Fuels, Are the Problem” 

Published by the Thoreau Institute 

http://www.ti.org/fireshort.html

Opinion statement – not science. 
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LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 6 – Comment 10

 “This paper will show that built-up fuels are not the main reason, or 

even a major reason, for recent severe fires or high fire suppression costs. The weather is the prime reason for widespread fires this year as well as in 2000, 1999, and other recent years. But the major reason for increased costs is institutional: The federal land agencies, and especially the Forest Service, have a blank check to put out fires and thus have no reason to control their costs. If fuels are not the problem, then it isn’tnecessary to spend $400 million a year treating them.” 

O’Toole, Randal. 2002. “Reforming the Fire Service: An

Analysis of Federal Fire Budgets and Incentives.” The Thoreau 

Institute. 

www.ti.org/firesvc.pdf

Opinion statement– not science. 

Letter 2 – Attachment 6 – Comment 11 “The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.” 

Partridge, Arthur Dean Ph.D. Testimony to the Agriculture, Nutrition 

and Forestry Committee United State Senate. Hearing to Review 

Healthy Forests Restoration Act, HR 1904 June 26, 2003

http://www.univision.co.za/offer-dayoA2A392Cr1N3B2x_2F2du3g3-music.shtml

This citation does not come from a peer-revie
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LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 6 – Comment 12

 “A number of studies have shown that for some ecosystems, the major factor determining fire intensity and size is weather and not the amountof fuel (Baker 1989, Flannigan and Harrington 1988, Haines and Sando 1969, Rothermel 1995). For example, Bessie and Johnson (1995) found that fire spread and intensity were strongly related to weather conditions and only weakly related to fuel loads in the southern Canadian Rockies. Similarly, many hundreds of the thousands of acres of forests that wereintensely burned in the 1994 Tyee Fire on the Wenatchee National Forest had very low fuel loads. The Forest Service and Fish and Wildlife Service concluded that weather patterns and terrain -- not fuels-- were the major reasons why this large fire burned the way it did (U.S. Forest Service 1995, U.S. Fish & Wildlife Service 1994). Such case studies provide little evidence that salvage logging of dead and dying trees will significantly reduce wildfires.” 

Peters, R.L., E. Frost, and F. Pace. “Managing for forest ecosystem

health: A reassessment of the forest health crisis.” Defenders of 

Wildlife. April 1996.

http://www.magicalliance.org/Forests/Forest%20Health%20Evalua

ted.htm

This citation does not come from a peer-revie

Letter 2 – Attachment 6 – Comment 13

 “Why is the natural fire regime in most Rocky Mountain ponderosa pine–Douglas fir forests variable in severity? Extended droughts and high winds can lead to exceptional fire spread across a broad spectrum of fuel loads and forest structures. For example, almost 25,000 ha of ponderosa pine– Douglas fir forest burned on a single day (9 June 2002), driven by strong winds (Finney et al., 2003). Yet, brief episodes when the winds declined and fuel moisture rose, led to low-severity fire

No question or specific comment to respond t

planning document. 
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G-117

LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

in the same landscape (Finney et al., 2003), suggesting that extreme weather, not fuels, was the chief cause of high-severity fire under those conditions. Even during summer, ponderosa pine–Douglas fir landscapes in the Rocky Mountains are subject to rapid increases in wind speed and changes in direction from jet streams or cold fronts (Baker, 2003).” (pg. 5) 

USDA Forest ServiceBALD ANGEL VEGETATION 

MANAGEMENT PROJECT ENVIRONMENTAL ASSESSMENT. La 

Grande Ranger District, Wallowa-Whitman National Forest December 

2006 

https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/660

8/Wallowa_Whitman_Bald_Angel_Vegetation_Management_EA.p

df?sequence=1

Letter 2 – Attachment 6 – Comment 14

 “Furthermore, there is a huge misconception perpetuated by the fire fighting junta that gives people the impression that all fires can becontained or suppressed. In fact, a great deal of fire research, plus experience over the decades has shown over and over again that under conditions of extreme drought, and high winds-the very conditions that are driving all the large fires in the West at this moment-fire suppression is impossible. It is not fuels that create large fires, but periodic drought.” 

Wuerthner, George, commentary. 2006 “The Best Fire Season Ever” 

Published by the Alliance for the Wild Rockies 

http://www.wildrockiesalliance.org/issues/wildfire/bestseasonever.h

tml

This citation does not come from a peer-revie
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G-118

LETTER #2 – ATTACHMENT 6 

Statements by Scientists detailing why Weather and Climate (not fuels buildup) 

is the Real Reason for the Increase in Wildfire Frequency and Severity 

References that were opinion pieces and those referencing specific geographical areas were not cons

RICHARD ARTLEY 

Comment Our Response 

Letter 2 – Attachment 6 – Comment 15 “Climate, not fuels, drives large fires. Under conditions of extreme drought, low humidity, high temperatures and high winds, fires are unstoppable. It doesn’t matter whether you have thinned, or even clearcut the land, any residual vegetation will burn and burn well. Not surprisingly, the past decade has been a period of severe drought, high summer temperatures and low humidity. Those conditions have been coupled at times with high winds — so naturally we would expect more large blazes. Such weather-driven blazes are unstoppable and go out only when the weather changes — not because of a lack of fuels.” 

Wuerthner, George. “Logging, thinning would not curtail wildfires” 

The Eugene Register-Guard, December 26, 2008

http://wuerthner.blogspot.com/2008/12/logging-thinning-would-notcurtail.html

This citation does not come from a peer-revie
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G-119

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 1

In addition to the ecological, scientific, and legal concerns and issues herein, our organizations note that we share many of the same ecological concerns expressed by the agency in the EA. Many of these issues were raised in our previous scoping comments on this project. As such, we were surprised, that the analysis and alternatives presented fail to be based upon accurate site-specific conditions, and fail to include meaningful scientifically based provisions that are essential to protect and restore the area’s ecological integrity. Our three organizations remind the agency that federal environmental policy laws require that federal land management projects must be based upon scientifically sound recommendations, accurate site-specific conditions, responsibly address cumulative impacts issues, and incorporate effective methods. Projects must include ecologically protective and effective restoration provisions so the purpose and need goals of a project can be effectively met. Such is not the case with the Cobbler Timber Sale and Fuels Reduction Project EA, which fails to meet the requirements of the NEPA, as noted herein. 

All comments received during the scoping pconsidered in completing the EA and consid

making process (project file – scoping commPlease see the following sections in Chapter 

• Location and Area (p. 1-2) • Background (pp. 1-2 and 1-3) • Purpose and Need for Action (pp

See Chapter 2 – Alternatives See Chapter 3 for direct, indirect and cumu

See Literature Citations for science used in 

Letter 3 – Comment 2

The EA’s action alternatives significantly diverge from scientifically supportable ecologically appropriate methods to effectively reduce real forest fuels and fire risk. Consequently, implementation of the Cobbler Project would significantly harm the area’s forest environments, and fail to meet the project’s purpose and need objectives. The focus and extent of proposed logging activities exceeds that necessary and scientifically capable of achieving fire risk reduction and ecological purpose and need goals. Logging of mature and old fire resistant trees, logging in mixed 

Please see Chapter 3 for existing condition dof environmental effects, and findings of con

alternative considered in detail. See Literature Cited – pp. L-1 to L-13 for a literature, papers, and research cited by res

their reports for this project. 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

conifer forest habitat and riparian areas, road building, and heavy machinery use will adversely impact forest ecology; biodiversity; vegetation; soils; wildlife, avian, botanical & aquatic species of concern populations and habitat; riparian areas, headwaters and salmonid waterways; resulting in further degradation of the ecological integrity, wildlife and aquatic habitat, soil hydrology, and aquatic systems in and around the project area. Letter 3 – Comment 3

The project involves scientifically insupportable logging actions 

in the Grande Ronde River and Wenaha Watersheds, adjacent to the Wenaha-Tucannon Wilderness and the Wild and Scenic Grande Ronde River, and includes a 7,000 acre portion of the Grande Ronde inventoried roadless area. The proposed project area is both ecologically important and recreationally treasured for its proximity to wilderness, roadless, and important salmonid watersystems. The area is valued for its scenic vistas overlooking the Wenaha River canyon as well as Alder and Elbow Creeks, and the Grande Ronde River. Project units also include unroaded areas that have not been inventoried, but which provide critically important wildlife habitat for numerous listed species and species ofconcern. 

Please see Chapter 1 – pp. 1-11 to 1-14. No in the Wenaha-Tucannon Wilderness and thundeveloped areas within the project planni

also identifies Forest Plan management areaplanning area and what actions are proposearea. See the Forest Plan pages 4-95 to 4-19description of standards and guidelines for eon the forest. Please see Chapter 3, environmental effects 

the following sections : 

• Recreation (pp. 3-118 to 3-120) • Visual Resource (pp. 3-120 to 3-1• Wild and Scenic Rivers (pp. 3-12• Wildlife (pp. 3-83 to 3-113) 

Letter 3 – Comment 4

The presented action “alternatives” are virtually identical, and 

are clearly far more than necessary or scientifically justifiable to effectively reduce the risk of wildfire as described in the purpose and need for this project. We specifically question the lack of a substantiating scientific basis for this project. 

Several alternatives were explored when con

for the Cobbler project planning area. Thredetail and six (6) were considered but eliminstudy. See Chapter 2, Range of Alternatives and A
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

in detail, pp. 2-8 to 2-32; and Alternatives CEliminated from Detailed Study, pp. 2-33 andetails. See Literature Citations (pp. L-1 to L-13) foresource specialist in supporting the purposdevelopment of alternatives, and the environanalysis of proposed actions. 

Letter 3 – Comment 5

The EA fails to adequately disclose and address scientific research that conflicts with agency action assumptions, including the failure to disclose scientific controversy regarding the efficacy and appropriateness of the proposed actions. 

Cobbler EA includes many pages of literatuLiterature Citations). The EA documents mspecialists and references scientific sources r

development of the project and analyses of e

Letter 3 – Comment 6

The EA also fails to present a range of alternatives based upon credible science research representative of concerns in mixed conifer, old growth, and lodgepole pine forest ecosystems; and of research addressing the recovery of imperiled interior forest and aquatic species of concern. Significant scientific evidence documenting adverse impacts and failures in the effectiveness of similar management projects exists; the bulk of which has been ignored by this EA in violation of the NEPA. Based upon scientific research on the impacts of similar actions in other areas (see exhibits), the proposed logging “treatments” would result in the further cumulative degradation, fragmentation, and loss of high quality wildlife habitat and forest resources. This project area contains valuable old growth wildlife habitat, salmonid watersystems, uninventoried roadless areas; and interfaces the ecologically important Wenaha Tucannon Wilderness, the Grande Rhonde Roadless Area, and the Grande Rhonde 

See responses to Letter 3 – Comments 3 and See Chapter 3 for site-specific environmenta

findings of consistency with the Forest Plan environmental laws for resources mentioned 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Wild and Scenic River. Letter 3 – Comment 7

The proposed action was the only possible course of action to fulfill the 

purpose and need, so there was no real analysis of alternatives. The purpose and need of the Cobbler timber sale is also far too narrow. The Forest Service has limited possible actions to only scientifically controversial and largely insupportable logging actions that are incongruous with the project’s stated ecological objectives. The ForestService narrows their objectives and analysis in the EA, 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. Instead the EA focuses almost exclusively on scientifically controversial and insupportable logging actions to accomplish its stated objectives. Given the EA’s stated purpose above, the only possible action that could fulfill the need to “provide sawlogs and wood fiber products for utilization by regional and local industry” is commercial logging. Because of the narrow purpose and need, the Forest Service only analyzes two virtually identical action alternatives based primarily on commercial logging. 

See response to Letter 3 – Comment 4 aboveThe purpose and need for this project is respconsistent with the following Forest Plan goa

• To provide land and resource manag

more healthy and productive forest supplying lands, resources, uses, and local, regional, and national social an

• To provide for production and susta

fiber and insofar as possible meet prlevels consistent with various resourstandards and guidelines, and cost e

• To protect forest and range resource

unacceptable losses due to destructivthe practice of integrated pest mana

• To provide and execute a fire protec

program that is cost-efficient and reresource management goals and obj

Letter 3 – Comment 8

Here, beyond the statutorily required “no action alternative,” only two identically premised and nearly identical logging alternatives are developed for consideration. These logging alternatives differ only by extent and focus of acres logged. They do not differ in substance concerning the action methods, scientifically controversial premise, logging impacts, changes to forest stand structure and wildlife habitat, 

See response to Letter 3 – Comment 4 aboveChapter 2 of the EA was modified to addres
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

forest plan amendments, mitigations, or economic timber volume objectives. Clearly, the Forest Service completely failed to develop and consider other reasonable action alternatives in violation of NEPA. Letter 3 – Comment 9

Despite the EA’s purported ecological objectives, the primary action alternatives the Forest Service has put forth are to conduct timber harvest and commercial thinning focused to “provide sawlogs and wood fiber products for utilization by regional and local industry.” The predetermined logging and timber economics focus that has been taken by the agency is inconsistent with the multiple use management direction, the LRMP as amended by the eastside screens, and pertinent scientific research recommendations for the area’s ESA and Oregon State listed wildlife, salmonid species, management indicator species, and species of concern, and scientific research recommendations for actions in mixed conifer forest ecosystems. As such, the EA for this project is in violation of the NEPA. 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. 

See response to Letter 3 – Comment 8 aboveSee the following sections of Chapter 1: 

• Background (pp. 1-2 to 1-3) • Purpose and Need, including how 

is responsive to and consistent w(pp. 1-3 to 1-4). 

See Chapter 3 for analyses of environmentaaction alternative and alternatives considerespecifically: 

• Fisheries (pp. 3-23 to 3-42) • Threatened, Endangered, and Se

81 to 3-83). 

• Wildlife (pp. 3-83 to 3-113) • Specifically Required Disclosure

See Appendix F to review how Cobbler projthe riparian, ecosystem, and wildlife standarScreens (F-1 to F-4). 

Letter 3 – Comment 10

The EA’s purpose and need is illusory and the analysis in the EA is unsound for at least two reasons. First, the historic forest conditions and 

Your comment has been noted. Platt et al. 2006 did some computer simulati
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

forest health justification for this project is inherently flawed due to the belief that logging can correct past bad management practices, includingfire suppression. While there is limited scientific support for the removal of small diameter trees and flash fuels in frequent fire-interval lowelevation ponderosa pine forests, there is significant scientific controversy and strong recommendations against logging-thinning mixed conifer, mixed fire-severity, and moist forest ecosystems 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.” 

stand structures in Colorado and concluded did not need both wildfire mitigation and restand structures, although wildfire mitigatio

of the area. The authors stress that the studlimitations that mean that the results should 

beyond the study area and that it was not vecollected data. In an article by Agee and Skinner, 2005: Thwhere the types of fires occurring today are of the historic fires: forests that have long drand have easily combusted forest floors, sucmixed conifer, and drier Douglas-fir forests“There is broad consensus that active mananeeded in such forests and that such treatmecontinued maintenance activity.” They descforests for fuels treatment: wet Sitka spruce

and high elevation forests such as mountain fir, which historically burned infrequently bLodgepole pine forests also fit into this categproject, there is no thinning proposed in stalodgepole pine and subalpine fir. The reporDave Swanson in 2008 after a site visit to the section where he states that understory thin

larch and grand fir have a resemblance to thseverity fire, events that historically occurreregime. 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 11

Indeed, the EA ignores and fails to disclose the majority of credible peerreviewed scientific research that clearly indicates the project’s actions are 

incapable of achieving the stated ecological purposes quoted above. Instead, scientific research has clearly documented that the proposed logging actions would harm forest resilience and ecological integrity, and increase the risk and extent of severe fires in the project area (see Exhibit A). The underlying assumption that a forest is generally healthier if properly functioning parts of the forest are removed is similarly unsupported by fact. 

Forest sustainability was the focus of the vegForest sustainability was defined as an ecosyapproach that allows the utilization of forestpurposes (e.g., biodiversity, timber harvestinproducts, soil and water conservation, touriwithout undermining their availability and qfuture generations. This means that sustaininsects, diseases, and other tree-killing agen

that they jeopardize the long-term integrity, productive capacity of the forest. A conclus“a significant threat of stand-replacing distu

the Grande Ronde-Rondowa watershed that alter plant and animal structure and compoSee Chapter 3 – Vegetation, Literature Citations pp. L-1 to L-13, and Appendix F - Consistency with Eastside Scr

Letter 3 – Comment 12

The agency’s interpretations of scientifically controversial research 

addressing regional forest ecology is based upon the selective and contextually inappropriate misuse of a combination of limited scientific studies, agency assumptions, and politically-contrived timber volume agendas. While there is emerging scientific consensus concerning preEuropean settlement era forest stand compositions and varied historicalfire patterns in the region, the Forest Service has largely misapplied scientific conjecture in this project’s interpretation of “historic conditions” and in developing its planned actions within the planning 

See responses to Letter 3 Comments 9 and 1
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G-126

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

area. The resulting project is a hodge-podge of only partially accurate historic stand assumptions mixed with erroneous and misapplied scientific interpretations. Consequently, overall the project’s logging plans will result in far more ecological harm than benefit to the area’s complex ponderosa pine, western larch, Douglas and grand fir, and lodgepole pine mixed conifer forest ecosystems and their dependent wildlife, native plant, and aquatic species. Agency contentions regarding “historic forest stand conditions” are ecologically simplistic, and largely incapable of accurately representing area plant associations and forest conditions that occurred prior to human manipulation of the environment. Letter 3 – Comment 13

Forest stand “overstocking” is a term that applies to lower elevation frequent fire cycle forests, not mid and high elevation mixed conifer forests, mixed fire severity forests, and moist forests, which are naturally 

more structurally varied and dense. Due to past logging in the area, what “overstocking” actually exists occurs only within dry ponderosa pine dominant stands; primarily among young understory trees that have littleif any merchantable timber value. Significant portions of the project also contain areas with unnatural logging created openings, old logging skid trails, far too many resource damaging unmaintained logging created roads, and overall degraded forest ecosystem conditions due to a combination of past and ongoing management, including logging, road building, fire suppression, invasive plant introduction and spread, and livestock grazing, and OHV use and abuse is also a growing concern. 

Yet the proposed actions include a dangerously harmful mix of old 

growth logging and near clear-cut “regeneration” logging; unnaturally increasing the fragmentation, road density, disturbance levels, and openness of area forests. Such proposed actions would not accomplish 

The forest plant associations in this area are to the local ecosystem classification (Johnson 1992), and the existing stocking levels are evproduced guide (Powell 1999) that specifies for each tree species in each plant associatioCitations). See Chapter 3, for analysis of environmenta
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

resilience or restoration objectives, instead these actions would result in irreparable habitat and ecological degradation, and increased fire risk throughout the greater area. Letter 3 – Comment 14

Still, despite the presence of widespread cumulative management harms, a considerable portion of the planning area contains healthy maturing and old growth trees and forest stands, as well as more unmanaged roadless areas. As past high-grade logging removed many of the largest diameter trees, significantly altering the area forests, much of the project’s forest 

stands are still in the process of natural recovery from past over-logging. Old, mature, and maturing trees, including many of those planned for logging removal, play an essential role in the ongoing natural recovery process of the area’s forests. As many of the area’s old growth and large mature trees have been removed during past logging, the area’s remaining trees greater than 12” to 15” diameter provide essential foreststand structure for wildlife habitat viability and the long term ecological integrity and recovery of the area. Removing even more of the project area’s inherently fire resistant old and maturing trees as planned would be in contravention to the recommendations of the majority of scientificresearch studies and to the purported ecological portions of the project’spurpose (above). Such logging removal cannot be justified under the stated ecological “purpose and need” for this project. 

Silviculture prescriptions and marking guidleaving of early tree species and larger treesremaining stand be more resilient to disturbSee Chapter 2, Alternatives Considered in Dfor details of how alternatives would be impfor selected silvicultural prescriptions and dstand types proposed for harvest and fuels tSee Appendix F– Consistency with Eastside 

Letter 3 – Comment 15

Scientific research confirms that such fire severity reduction objectives 

are not feasible in mixed conifer stands, such as the majority of forest stands found in the Cobbler project area. 

Yet this purported “fuels reduction” project fails to adequately 

“...there are other forests that have long dry and have easily combusted forest floors, sucmixed conifer and drier Douglas-fir forests the types of fires occurring today are very uhistoric fires. While some intense fire activit
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

disclose or address cumulative issues of logging slash from other past and current projects, as well as project generated “fuels” that currently exist or will exist post-project in the area. Removal and/or reduction ofexistent logging and thinning generated fuels where appropriate should have been effectively addressed by the EA, especially given the purported purpose and need for the project. 

forests, it was not the modal type of fire sevein such forests. There is a broad consensus tmanagement of some type is needed in such 2002; McKelvey et al. 1996) and that such trneeded as a continued maintenance activity.2005). Although there has been significantly more dry ponderosa pine than in mixed conifer fostudies have shown that treatment in mixed increase stand resiliency to wildfires. Resilidefined as a forest capable of maintaining suarea after being burned by a wildfire. The ftreatment principles can increase resistance conifer stands: reduction of surface fuels, in

crown, decrease in crown density, and the reresistant species (Agee and Skinner, 2005). See Chapter 2, pp. 2-13 to 2-16 for a descripnatural fuels treatments and Table 2-6 – DeManagement Requirements. pp. 2-21 to 2-28See Chapter 3, Fuels pp. 3-57 to 3-71. 

Letter 3 – Comment 16

As planned, the project would further harm the ecological integrity or the area by its planned removal of far too many of the area’s old and mature trees, including the scientifically insupportable logging in mid and high elevation mixed conifer forests, and the logging of inherently fire resistant mature and old growth trees. Such scientifically and 

In response to your comment this section of revised to incorporate this information. See The estimate of the number of diseased tree

that would be cut within harvest units (regein moist upland forest only – 350 acres) beca
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

ecologically unwarranted logging will seriously degrade existent wildlife habitat, jeopardizing the viability of forest-dependent species of concern throughout the greater project area. The planned logging violates the purpose and need for the project and the high quality science, expert advice, and reasonableness requirements of the NEPA. Proposed logging actions violate the qualified scientific objectives that comprise the foundation of the Eastside Screens. Project logging violates fire and fuels reduction scientific recommendations. Project logging of mature and old trees and degradation of forest habitat would likely extirpate or harm thehabitat and populations of affected ESA listed species and imperiled forest dependent native species of concern in violation of the NFMA. 

mistletoe ratings of 3 or 4, as recommended pathologist, is estimated to be between 10 anp. 2-12. In regards to ESA species, please see Chapte

• Fisheries (pp. 3-23 to 3-42) • Threatened, Endangered and Se

to 3-83). 

• Wildlife (pp. 3-83 to 3-113) 

Also see Appendix F – Consistency with Easto F-4 for disclosure how Cobbler project is riparian, ecosystem and wildlife standards o

Letter 3 – Comment 17

In brief, if implemented the project would increase the risk of severe fire 

by: excessive opening of the forest structure and canopy and resultant increased solar exposure and drying; and by the increased presence in subsequent post-project years of fire-susceptible brush, grasses, invasive plants, small diameter trees and other small diameter flash-fuel prone vegetation where fire resistant maturing and older trees had previously stood. Logging slash and debris removal is dependent upon as yet nonexistent funding, and may not occur on the scale and timeline needed to avoid increasing highly fire-prone fuel loads and fire risks post-project. Proposed logging would harm forest resilience, violate forest natural/historic range of variability, degrade wildlife and aquatic habitat, irreparably harm forest soils, and fragment the area’s forests, further harming wildlife habitat and ecological integrity. 

While true that thinning can increase surfacreduce relative humidity and wind speeds, evariable and depend on specific prescriptionpositions. See Chapter 2, Table 2-6. pp. 2-21 to 2-28 - DManagement Requirements to minimize the management activities. See Chapter 3 for environmental effects anaconsistency for resources analyzed. 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 18

The project’s wood products economic goals – by which the agency plans to sacrifice the ecological integrity of the project area - are also 

illusory, especially given the ongoing economic downturn and lack of need or demand for wood products throughout the region and nation. Simply put, the project defies federal laws and policy, credible science, economic realities, and plain common sense. 

The economic analysis presented in Chapter is in accordance with the Forest Service manguidance to complete a financial analysis for 2409.18). The economic analysis documentefinancial monetary measures for timber and removing the timber. 

Letter 3 – Comment 19

The EA however, in clear violation of the requirements of the NEPA, chose to ignore substantive issues of scientific controversy, failing to 

disclose or address scientific research that contradicts or recommends against the project’s actions. Agency dismissal of scientifically based concerns and recommendations, and the EA’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 EA, including the development of a range of proposed actions. 

See responses to Letter 3 – Comments 4 and 

Letter 3 – Comment 20

We request that the agency substantiate the scientific basis of its 

proposed alternatives actions. The EA notes selective scientific research to support its thinning contentions, but fails to correlate the extent of its thinning with these studies, in particular as related to mid and high elevation mixed conifer forest ecosystems, the forests natural range ofvariability, area fire ecology cycles and patterns, affected wildlife and 

See response to Letter 3 – Comment 4 On a landscape basis, the vegetation analysistand density conditions to stand density HR(Chapter 3, Table 3-31 and 3-32, p. 3-55) See Chapter 3 for environmental effects and 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

aquatic species habitat needs and occurrence, forest structural integrity, ongoing natural recovery processes, and the full range of cumulative impacts from past and ongoing management. 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, 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 largelyscientifically insupportable at best. 

consistency for all alternatives considered in 

Letter 3 – Comment 21

The analysis within the EA must disclose which studies were incorporated in developing its proposed actions, and must also 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. 

See Chapter 1, Background and Purpose an1-2 to 1-4). See Chapter 2, Comparison of Alternatives 2-12, pp. 2-36 to 2-43) which will be included by the decision maker in making a decision, ecological science listed in the Literature CitEA that were used in the development and a

(pp. L-1 to L-13). See Chapter 3 for affected environment, envanalysis, and findings of consistency for all ain detail. These findings will also be considemaker’s final decision. 

Letter 3 – Comment 22

Alternatives presented where there exists credible scientific controversy 

must reasonably include a range of actions substantiated by the varied 

See responses to Letter 3 – Comments 4 and 
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G-132

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

research, so the public and decision-maker can choose which actions may be most effective or desirable in the long-term in a given project area. The project however, only develops two action “alternatives” (in addition to the no action ‘’ - which the agency generally never selects), both of which are commercial logging proposals that differ only marginally by the number of acres logged. Both action alternatives are based upon the same controversial logging premises. Despite NEPA’s legal requirements the EA contains no action alternatives that are developed based upon the preponderance of credible peer reviewed ecological science. Letter 3 – Comment 23

In its arbitrary dismissal of other potential alternatives, the agency fails to 

disclose the existence of any scientific controversy. Instead the agency misuses its limited selective studies, internal agency premises, and the apparent proposed logging-alternative biased prerogatives of its planningteam staff to arbitrarily and capriciously dismiss a wealth of substantive pertinent peer reviewed scientific research, management directives, the Eastside Screens - ICBEMP science recommendations and goals, and accurate site-specific conditions and concerns. These serious analysis development deficiencies violate the requirements of the NEPA, and have resulted in this ecologically harmful, legally non-compliant, logging focused timber volume EA. 

See responses to Letter 3 – Comments 4 and Also see Appendix F – Consistency with Eas

to F-4 for disclosure how Cobbler project is riparian, ecosystem, and wildlife standards Screens. 

Letter 3 – Comment 24

Further, the agency fails to effectively and adequately modify its logging 

plans to incorporate the recommendations of scientific research on the habitat and viability needs of the many affected native forest-dependent species in the greater project area. Here again, to a large extent, the EA 

See Chapter 2, Table 2-6 - Design Features aRequirements. See Chapter 3, Wildlife pp. 3-83 to 3-113. Dcumulative effects to wildlife are disclosed in 
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LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

fails to adequately disclose pertinent scientific research on affected native species. The EA fails to adequately inform the public or decisionmaker 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 actions to species of concern that are or may be within the greater project area. 

finding of consistency (p. 3-113) discloses thconsidered in detail are consistent with Forewith applicable environmental laws. See Literature Citations pp. L-4 to L-7. 

Letter 3 – Comment 25

The EA’s many scientifically controversial and insupportable claims that 

extensively logging the project area as proposed could do anything other than further degrade and harm area forests and watersystems defies NEPA’s reasonableness and accuracy requirements. The current EA mustbe withdrawn, and an EIS conducted with significantly revised ecologically based and scientifically credible alternatives. 

Your comment has been noted. 

Letter 3 – Comment 26

The project purports it will reduce fuel loadings through mechanical fuels treatments, including over two thousand acres of commercial logging. However, the mechanical fuels treatments would actually degrade and destroy habitat in both the short and long-term. The planning area includes diverse stands of forest that are green, healthy and 

thriving. The project area is home to a diverse array of species, many of which depend upon complex interior forest. The Forest Service’s proposal “to improve health, vigor, and resilience” of forest wildlife habitat in the future by destroying wildlife habitat in the present fails to make ecological sense, and is scientifically insupportable. 

The environmental effects of mechanical treanalyzed in the EA. See Chapter 3 for environmental effects anaconsistency, and specifically required discloanalyzed. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-134

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 27

Part of the stated and implied purpose and need of the project is to protect habitat, however, the project does the exact opposite. The activities planned for this sale may cause both a short-term and a longterm degradation of suitable habitat. Area forest species of concern; 

including lynx, wolverine, wolves, salmonid species, goshawk, marten, pileated and three toed woodpeckers, neotropical and migrant native bird species, and others; require extensive connective forests with mature and late-successional characteristics, including large diameter trees and healthy functioning watersheds and water systems. (Lint, 2005) It is these forests that are most fire resistant, as they have moist interiors, a complex canopy, and are impenetrable to wind. (Rhodes, 2007 and others – see below) Commercial logging the area’s mature and old fire resistant trees up to and in-part exceeding 21 inches in diameter would irreparably degrade wildlife species of concern and listed-species habitat, including connectivity, and increase the risk of fire. It is well 

documented that mechanical logging fuels treatments may not reduce the risk of fire, but it does certainly destroy habitat. 

See Chapter 3, specifically the following sect

concerns in your comment: 

• Hydrology – pp. 3-9 to 3-22 • Fisheries – pp. 3-23 to 3-42 • Wildlife - pp.3-83 to 3-113. 

Also see Appendix F – Consistency with Eas

to F-4 for disclosure how Cobbler project is riparian, ecosystem, and wildlife standards Screens. See Literature Citations, pp. L-1 to L-13. 

Letter 3 – Comment 28

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 protectiontoday, 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 

See Chapter 3, Past, Present and Reasonablpp. 3-1 to 3-4 and Wildlife – pp. 3-83 to 3-11and cumulative effects analysis for wildlife, 

connectivity. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-135

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

these populations in the present with this project’s planned logging. Letter 3 – Comment 29

Similarly, the project is premised in part on an assumption that the forests need to be protected from unspecified levels of insects and disease, and that logging is the answer to achieving such protection. However, insects, disease, fire, natural pathogens, and disturbances are

integral components of natural forest ecosystems. The EA 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. Forest wildlife and ecological systems are well-adapted to inherent pathogenic and disturbance events and endemic fluctuating levels. Wildlife are not generally extirpated by such natural processes. However, wildlife are extirpated by logging, road building, and other management disturbances proposed in this EA. The analysis fails to accurate 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. An EIS is necessary for a project of such extent and complexity, to adequately assess and disclose these and other related issues. 

The objectives of the silvicultural treatmentnot include affecting insects and diseases thalevels. The project planning area is thought historical risk for those insects and diseases tree species, because there are now higher pspecies in the stands, as a result of previous suppression. The regeneration harvest in loare at high risk of bark beetle attack is desigwood while it is in good condition, as opposedead. This objective to provide sawlogs and for utilization by regional and local industry 

Purpose and Need for the project. Removal is moderately infected with dwarf mistletoe management of the stands does not increase historical levels. See Chapter 3, Table 3-25, 33, pp. 3-56 to 3-57 that showing risk ratingThe project file has additional maps in the SAppendix B, that show insect activity from tpresent, and reports from the Zone entomol(Spiegel and Schmitt 2008 and 2009). See Chapter 3 for disclosure of environmentindirect and cumulative) on resources analy

considered in detail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-136

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 30

There is ample scientific controversy about whether mechanical fuels 

treatment reduces fire risk. Mature, old-growth stands have dense, moist interiors and little wind, which inhibit the spread of wildfire. (Morrisonand Smith, 2005; Rhodes, 2007) Fuels treatments that reduce stand density and open up the forest actually enhance fire spread, as fire moves more readily through an open environment. (Morrison and Smith, 2005; Rhodes, 2007) An opened forest allows fuels to dry out faster and winds to blow through the stand. (Morrison and Smith 2005; Rhodes, 2007) Thinning the understory is more effective at reducing fire risk than thinning the overstory. (Carey and Schumann, 2003) Complex and varied canopies may actually prevent the spread of wildfire better than dense, young, single-storied canopies. (Morrison and Smith, 2005) The Forest Service plan to disturb the canopy and interior forest conditions ofmixed conifer forests is not based in the best available science. “Although the assertion is frequently made that reducing tree density can reduce wildfire hazard, the scientific literature provides tenuous support for this hypothesis.” (Carey and Schumann, 2003, page 14). The Forest Service is at least required to discuss this very lively scientific controversy about the role of mechanical fuels treatment in reducing the risk of fire in an EIS for this proposed project. 

While true that thinning can increase surfacreduce relative humidity and wind speeds, evariable and depend on specific prescriptionpositions. In stands located along the rim of the GrandForest Road 62, the focus of treatments is to and resulting fire behavior for safe and effecactions. These strategic areas were chosen ffire is most likely to start in the Grand Ronddrainages and spread quickly on steep slopeburn into these stands on flat ground. In orand effective fire suppression in these standsburning in surface fuels with less than a 4-fonot burn into the overstory canopy. Several have documented the need to treat stands at fire from burning into tree crowns, includin2005; Mason et al. 2007; Hall and Burke, 20Reinhardt, 2001. These levels of treatment isurface fuels to reduce flame lengths, increacrowns, requiring longer flame lengths for tdecreasing crown density, which makes treeprobable. These treatment methods were emmentioned strategic locations to allow for sasuppression by keeping fire from spreading “Non-commercial treatments [by themselveto influence future stand composition; howesignificantly reduce active crown fire potent

harvest was the only treatment with the exce
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-137

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

treatment... to significantly reduce crown fiet al. 2007. 

Letter 3 – Comment 31

Despite the stated intention to protect habitat, the project EA focuses 

more heavily on commercial logging than it does on needed restoration and protection actions. Commercial thinning is especially controversial when the permitted diameter limit allows the logging of fire resistant mature and old trees, and maturing trees essential for forest ecological integrity, resilience, wildlife habitat, and watershed functioning. 

Silvicultural prescriptions and forest stand tharvest and fuels treatment, describe that thtree species and sizes would be left in command by definition, the thinned stands would levels. Information on fire resistance rating

of the Blue Mountains is located in the Silvicreport (project file). See Chapter 2, Alternatives Considered in Dand Alternatives Considered but Eliminated An alternative to use non-commercial thinnitrees rather than commercial harvest was coeliminated from detailed study (p. 2-35). See Chapter 3 for environmental effects anaconsistency, and specifically required discloAlso see Appendix F – Consistency with Easto F-4 for disclosure as to how Cobbler projthe riparian, ecosystem, and wildlife standarScreens. 

Letter 3 – Comment 32

This project not only logs mature and old trees up to 21” dbh, it proposes a series of unspecified levels of exceptions to the eastside screens 21”

dbh limit. These exceptions would allow the logging of trees of any 

See responses to Letter 3 – Comment 31 abo
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-138

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

diameter, including very large old trees for rationales of mistletoe, disease, stand density, and vigor, as well as the movement of machinery in units, landings, and road building. Letter 3 – Comment 33

Science overwhelmingly concludes that logging mature and large, fire resistant trees does not reduce the risk of fire and actually can contribute 

to more intense fires. (Brown et al 2004; Carey and Schumann, 2003; Noss et al, 2006; Rhodes, 2007; Morrison and Smith, 2005; Baker et al, 2006) A percentage of the trees to be logged in this project will be mature trees up to 21” dbh, with an additional percentage of trees over 21” dbh logged (as per the EA’s provisions noted above), yet these totals are not accurately disclosed in the EA, nor are the impacts adequately assessed and disclosed. The Forest Service apparently erroneously concludes that commercial logging of mature and old fire resistant trees is the only way to reduce the risk of fire in the planning area. The ForestService does not need to cut trees up to – and over - 21” dbh, or for that matter to cut any trees in mixed-conifer mixed-fire severity mid to high elevation forests – especially trees that evidence fire resistant mature and old characteristics. The EA plans to cut an undisclosed number of old and mature large fire-resistant trees fail to utilize the best available science. Also, the EA never “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 thinningmature stands of mixed-conifer forest. 40 C.F.R. 1507.27(b)(4). 

See response to Letter 3 - Comment 16 abov

Letter 3 – Comment 34

The EA 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. 

See Chapter 1, under the headings BackgrouNeed for Action, pp. 1-2 to 1-4. See Chapter 3, Fuels, Affected Environment
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-139

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

However, the forest is not outside of its desired condition unless the current time period without fire is longer than any time period in the areas’ history. (Rhodes, 2007) Letter 3 – Comment 35

Recent research on mixed-fire severity forests shows that fire intervals 

and severity levels vary greatly over the course of centuries. Prolonged periods of predominantly cool-moist climate with significant vegetative growth are interspersed with periods of hot-dry weather patterns, with significant landscape scale fire severity mosaic patterns. The cool-wet era of the early to mid 1800’s was followed by a gradual warming period, culminating a widespread severe fires in the late 1800’s and early 1900’s. This was followed by a gradual return to more moist and cool years. The late 1900’a and early 2000’s were again a period of warm/hot-dry weather years, with a rise in landscape scale sever fires similar to that of the early 1900’s. factors of climate change may be having varied and as yet uncertain influence in the region’s millenas-long fluctuating fire severity patterns. However, human-induced climate change remains largely unpredictable in its impacts and variations, more akin thus far to shorter-term extreme fluctuations resembling “fever-chill” patterns than a predictable gradual escalation of hot-dry periods. While insect impacts and populations are indeed documented as moving towards higher elevations, with prolonged activity, these patterns too are still likely within the range of natural variability over the long-term of time, with many other variables influencing such impacts. Ultimately, whether climate change brings greater risk of severe fires or higher levels of moisture remains a field of scientific speculation and ongoing debate. Yet, the EA fails to address or disclose any of these issues. Please again review the scientific research in our Exhibit A compilation, as this expert information is pertinent to the proposed project, and will help in 

An analysis of Climate Change has been incChapter 3, pp. 3-133 to 3-135. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-140

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

preparing the needed EIS for any forest management effort in the analysis area. Letter 3 – Comment 36

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 proposal to alter the natural fire regime of the mixedconifer forests in the best available science. 

See responses to Letter 3 – Comments 15 an “If these [mixed conifer] ecosystems are not fire hazard, large, intense wildfires will contfuture. Ecologically, high-intensity fires proimpacts because of their effects on plants, soby the modification of habitat. Large, high-ipyrodiversity and are expensive to suppresspose a great risk to firefighters and to the puprescribed fire and/or mechanical treatmenreduce fuel loads and fuel continuity in mixeecosystems.” Stephens, S.L., 1997 See Chapter 3, specifically: 

• Fisheries – pp. 3-23 to 3-42 • TE&S Plants – pp. 3-81 to 3-83 • Wildlife – pp. 3-83 to 3-113 • Specifically Required Disclosure

See Appendix F – Consistency With Eastsid

Letter 3 – Comment 37

The EA does not include a restoration alternative, or a range of other scientifically-based alternatives, even though it is “reasonable” to include 

a restoration alternative, and even though NEPA requires a full range of reasonable scientifically sound alternatives. 

See responses to Letter 3 – Comment 4 and Chapter 2 of the EA was modified to addres
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-141

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 38

The range of alternatives in the Cobbler EA is inadequate, because the EA never analyzes a restoration-only alternative. 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.” None of the action alternatives focus on scientifically supported restoration of the area’s mixed conifer forest ecosystem, even though restoration is the best approach for maintaining the wholeness of the forest and its habitat and reducing fire risk in the both the short and longterm. 

See response to Letter 3 – Comment 37 abov

Letter 3 – Comment 39

Both action alternatives both focus largely on commercial logging. However, commercial logging is an ecologically damaging, ineffective, 

scientifically controversial way to reduce the risk of natural disturbances. Commercial logging has, in fact, not been shown in any scientific literature to reduce the incidence of large-scale fire. (Carey and Schumann, 2003) Commercial logging in important habitat does not make sense in light of the objective to protect habitat. Cutting maturingand mature and old trees not only degrades wildlife habitat, but it exacerbates wildfire severity. (Brown et al, 2004; Carey and Schumann, 

See response to Letter 3 – Comment 30 See Chapter 3 for disclosure of environmentindirect and cumulative) on resources analyconsidered in detail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-142

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

2003; Noss, et al 2006; Rhodes, 2007; Morrison and Smith, 2005) See also additional studies included in Exhibit A. Letter 3 – Comment 40

Managed forests should not only support ecologically appropriate fire regimes and forest resiliency, they should also support viable populations of species. (Noss, et al 2006). The Forest Service must at least consider

an alternative that will truly protect 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 EA fails to adequately disclose and address this significant issue, and instead proposes to compound existent cumulative impacts habitat degradation with even more logging harms. 

See Chapter 2, Alternative C, pp. 2-29, whicissues of retaining the maximum amount of old forest habitat, and functional connective See Chapter 3 for environmental effects of talternative and the two action alternatives cEnvironmental effects, findings of consistendeterminations for aquatic, plant, and terrelocated in Chapter 3. 

Letter 3 – Comment 41

The EA 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, firerisk reduction, and resilience). The EA fails to include sufficient 

See responses to Letter 3 – Comments 4 and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-143

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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 analyzing a restoration alternative, the Forest Service and the public will never know how the forest will be affected without commercial logging. Similarly, without assessing a range of alternatives capable of achieving ecological objectives, the public and the decision-maker are deprived of more capable, scientifically supported, and ecologically protective alternative options. The Forest Service cannot make a fully informed decision without full analysis of a range of scientifically supported restoration alternatives. Letter 3 – Comment 42

The Forest Service must analyze an alternative that will eliminate

scientifically controversial commercial logging and all fuels treatments that are not based in sound ecological principles, as this is reasonably within the stated purpose and need of the project. Each current alternative significantly degrades viable mature and old forest habitat in mixed conifer mature and old forests, adjacent to old growth areas, roadless areas, salmonid watersystems, and wilderness. The Forest Service does not 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. TheEA claims that forest habitat is at risk of destruction by uncharacteristic fire, but does not disclose that old and mature forest habitat and connectivity are certain to be irreparably injured under this project. The 

effects to the interior mature and old forest dependent wildlife under this 

project are immediate and certain, while the risks the project is attempting to avoid are distant, hypothetical, and largely scientifically 

Chapter 2 identifies all alternatives considerpurpose and design for Alternative C (p. 2-2activities in Alternative C are designed to re

purpose and need for action by thinning ovepromote forest resiliency and reduce fuels wkey issues of elk habitat, old forest habitat, aconnective corridors See Chapter 3 for environmental effects of aconsidered in detail. An alternative that would not implement coall fuels treatments (Alternative A) was analChapter 3. Also see Appendix F – Consistency with Easto F-4 for disclosure how Cobbler project is 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-144

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

insupportable. The Forest Service must analyze alternatives that would actually “avoid or minimize adverse effects of these actions,” as NEPA requires it to do. 50 C.F.R. 1500.2(e). 

riparian, ecosystem and wildlife standards o

Letter 3 – Comment 43

Undisturbed mature forests require little or no restoration. (Baker et al, ) 

Passive restoration is the best way to return forests back to the condition first perceived by the European settlers. (McIver and Starr, 2001) At a minimum, the Forest Service must analyze an alternative that would exclude the most important mixed conifer and pine mature and old forest habitat from ecologically harmful active forest management actions and protect the area’s connective forest habitat, especially surrounding and linking old growth, roadless, salmonid waterways, and wilderness with adjacent mature and old forest, and high elevation forest habitat. Again, an EIS is needed for a project of this significance in scale and scope 

See response to Letter 3 – Comment 42 abov

Letter 3 – Comment 44

The EA only analyzes “alternatives” that are virtually identical to each other 

The Ninth Circuit has found that an EA/EIS that analyzes a noaction and other virtually identical action alternatives violates NEPA. 

Muckleshoot Indian Tribe v. U.S. Forest Service 177 F.3d 800, 813-15 

(9th Cir. 1999). The Cobbler EA takes this very same approach with its alternatives. There are only two logging action alternatives in the project EA, with three developed alternatives in total: the “no action” Alternative A; Alternative B, which commercially logs on 2,500 acres; and Alternative C, which commercially logs on 1,300 acres. The action alternatives are essentially similar, especially in regards to their 

See responses to Letter 3 – Comments 4, 31
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-145

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

foundational premise and focus on commercial logging/thinning. The overwhelming scientific recommendations do not support the EA contention that the only possible alternative in this case necessarily 

involves wide-scale commercial logging in mature and old pine and mixed conifer forest habitat, and as such both of these alternatives violate 

the NEPA, requiring that actions are based in expert advice and high quality science. In an EA, the Forest Service has a duty to fully consider alternatives to the wide-sweeping logging impacts that are posed by this project. As EAs are only allowed in place of an EIS when issues of significance are absent, or when the proposed actions are ecologically protective and well-founded in non-controversial supporting science, the far-ranging ecologically damaging actions proposed in this EA fail to meet NEPA’s requirements, and demonstrate well why an EIS is necessary for this project. The Forest Service must include a sufficientrange of scientifically credible alternatives in order to provide a basis for sound forest management decisions. Letter 3 – Comment 45

Openings would be reforested by planting - except that while the EA states that these areas “can be reforested within five years,” the EA fails 

to make this mandatory, stating that such actions are dependent on the availability of as yet unknown funding. 

See Chapter 2, Sale Area Improvements, p. See Chapter 3, National Forest ManagemenCompliance, pp. 3-57 to 3-58 and 3-137. Monitoring of past projects documents that District has not had any trouble funding its program. NFMA requires that areas harvescapable of being reforested within 5 years. Treforested within the required time frame. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-146

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 46

The EA 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 EA fails to disclose how many years may pass post-logging before Cobbler 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. Logging of old growth trees categorized by the agency as “diseased” would occur on 350 acres of moist forest. The agency claims this is only approximately 1 percent of the total planning area and less than 2 percent of the 25,400 acres of the planning area where logging is proposed. However, the EA 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 logged in the greaterplanning area. As such, the statistics cited are misleading and inaccurate, and fail the disclosure requirements of the NEPA. 

See response to Letter 3 – Comment 16. There are no units that were previously harbeen successfully reforested. Approximately were planted twice, and 1 percent of acres wtimes (Silviculture Report, project file). See Chapter 3, Past, Present, and Reasonabpp. 3-1 to 3-4, and Vegetation, pp. 3-42 to 3-Table 3-28, p. 3-53 in Chapter 3 shows the aharvest by forest stand structure category, a30 on pp. 3-53 to 3-54 the HRV analyses for alternatives that compare the effects of the pstructure HRV. 

Letter 3 – Comment 47

Clearly, the two action alternatives above, presented in the Cobbler EA, are really only one alternative applied to two different amounts of acreage. Methodology, premise, analysis, and associated actions are identical. As such, the EA egregiously fails the clear requirements of the 

NEPA pertaining to a reasonable range of scientifically based alternative development and analysis. Again, the EA’s above NEPA deficiencies exemplify why an EIS is the legally compliant and analysis-responsible 

See response to Letter 3 – Comment 31 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-147

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

procedure for the proposed project. A full range of scientifically based alternatives must be developed in a new NEPA process. Letter 3 – Comment 48

The EA violates the very core tenets of the NEPA: 

Clearly yet again, the EA itself serves as perhaps the best 

evidence that the Forest Service fails to begin to meet these most basic

NEPA requirements. The project’s contrived purpose and need, similar logging action “alternatives,” analysis failures, environmental harms, and failure to adequately disclose and address significant scientific controversy and contravention to the presented alternatives violate themost elemental requirements of the NEPA. 

Clearly the EA fails the requirements of the NEPA, necessitating 

that this EA be withdrawn and project be revised in a new legally compliant EIS analysis process that develops a full range of environmentally beneficial, scientifically based, LRMP, Eastside Screens, and legally compliant action alternatives. 

See Chapters 1, 2, and 3 of the EA, and AppWith Eastside Screens. 

Letter 3 – Comment 49

The Cobbler EA Fails to Provide a Legally Compliant Range of Alternatives 

As demonstrated above, the Cobbler EA fails to provide a 

reasonable range of alternatives that includes scientifically and 

ecologically sound management proposals. The purpose and need was designed in such a way as to constrain alternatives and, in so doing, predetermined the decision prior to NEPA analysis. 

See responses to Letter 3 – Comments 4 and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-148

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 50

The EA 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. These actions leave no room for scientifically-sound alternatives. The Cobbler EA is based upon predetermined contrived logging- biased analysis, which lead to foregone environmentally harmful and legally inadequate conclusions. 

See responses to Letter 3 – Comments 4 and See Chapter 3, for environmental effects ana

and cumulative) for all alternatives consider

of consistency with the Forest Plan, Forest S

applicable state and federal environmental lRequired Disclosures (pp. 3-136 to 3-138). 

Letter 3 – Comment 51

Violation of Alternatives Requirement in Federal Law 

In the EA, 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 ofcredible pertinent scientific research that the EA failed to disclose orassess in addressing and developing reasonable ecologically capable action alternatives. 

Chapter 2 of the EA was modified to addres

Letter 3 – Comment 52

The Forest Service Cannot Place Timber Economics Above Restoration & Resource Needs 

Chapter 2 of the EA was modified to addres
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-149

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

The Forest Service failed to include a reasonable range of 

science based alternatives; and as such this legally non-compliant EA must be withdrawn. Among scientifically reasonable alternatives not developed, though they were noted in previous comments and summarily dismissed without addressing scientific controversy and supporting scientific research recommendations, 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). 

Letter 3 – Comment 53

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 EA despite the inclusion of economic objectives such as “saw logs” and “wood fiber products.” The EA cannot be legally premised upon unsubstantiable needs and actions. Further, there are other more viable economic contributions and societal needs that are better met by protecting the areas forest ecosystems and waterways than by needlessly logging them as proposed. 

The economic analysis presented in Chapter is in accordance with the Forest Service manguidance to complete a financial analysis for 2409.18). The economic analysis documentefinancial monetary measures for timber and removing the timber. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-150

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 54

Instead of developing misplaced societally unneeded logging alternatives, the EA failed to reasonably address and develop a science

based alternatives, such as: The Forest Service must consider a scientifically-sound restoration-based 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 waterways, protection and recovery of salmonid species, ESA listed species, and species of concern habitat and populations, prevention of OHV harms, and the removal of unneeded roads and skid trails. 

Again, adhering to scientific recommendations and LRMP 

designations, commercial logging in undeveloped uninventoried roadless areas, and within special management interest areas, must be dropped. A restoration-based alternative could meet the purpose and needs of the proposed project throughout much of the area’s already managed roaded forests by providing local jobs and reducing fuel loads by removing the small-diameter flash fuels from the lower elevation frequent low intensity fire areas, where the such work has scientific support. Employment would also be provided in conducting the needed restoration described above, such as road removal, invasive plant prevention, and watersystem restoration. By failing to include noncommercial logging alternatives other than “no action” the EA violates the requirements of the NEPA, APA, and the NFMA. 

Chapter 2 of the EA was modified to addres
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-151

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 55

The Need for An EIS 

Because this proposed project includes widespread scientifically

controversial commercial logging actions in an area with significant public recreational, natural, wilderness, waterway, and wildlife values, which has extensive past and ongoing cumulative impacts issues; NEPA requires the current EA be withdrawn and a new legally compliant EISbe developed for this proposed project before a decision may be issued. As demonstrated herein, the EA has numerous legal and analysis deficiencies. The actions as currently proposed are based upon faulty and erroneous assumptions lacking credible scientific support, and would result in irreparable illegal environmental harms. The issues raised herein, which are supported by credible scientific research and legalrulings, clearly indicate that the project EA is arbitrary and capricious and scientifically and legally insupportable for a project of this extent and level of irretrievable impacts. 

See Chapter 3, for environmental effects ana

and cumulative) for all alternatives consider

of consistency with the Forest Plan, Forest S

applicable state and federal environmental lRequired Disclosures (pp. 3-136 to 3-138). An EA is prepared to document the results oanalyses and to disclose the environmental cproposed actions that are not categorically edocumentation and for which the need for adetermined. An EA is prepared to provide s

analysis for a finding of no significant impacincluded in the decision documentation. An projects that may significantly affect the quaenvironment. 

Letter 3 – Comment 56

Timber Volume Targets Driving NW Timber Sales 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 agencyprojects 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 theNEPA. Issuing EA’s such as this one, wherein undisclosed quotas set the 

See Chapter 1, this project was based on the information of the existing condition and the move toward the desired future condition as Forest Plan (FP pp. 4-1 to 4-14). No timber volume target quotas were used iproject. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-152

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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. Letter 3 – Comment 57

Terrestrial Wildlife Species:Wolves

The EA 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. 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 EA’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 EA’s apparent contention that its land management activities are compatible with wolf protection and recovery is unsupported by fact. 

See Chapter 3, Wildlife, Gray wolf, p. 3-103 of direct, indirect and cumulative effects for considered in detail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-153

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Logging the Cobbler Project would subject any current or future wolves in the area to increased risk of death from illegal human shootings. The EA must be withdrawn and an EIS conducted to correct illegal NEPA-deficient “analysis” and lack of thorough accurate disclosures and conclusions. The proposed alternatives mustbe revised to provide for the protection and recovery of Oregon’s returning wolves. 

Letter 3 – Comment 58

Lynx The project is located in the Walla Walla District’s mountain forests, in 

and within range of mixed conifer forest habitat known to be preferred by lynx, including mixed conifer forests, and connective forest habitat with roadless and wilderness areas. The proposed logging in the planning areamay adversely affect whatever lynx recovery is occurring, as lynx may use portions of this area for both nocturnal foraging as well as migratory and dispersal routes and refuge. Continuing to squeeze lynx out of their habitat range by intensively managing the land runs afoul of NFMA’s requirement that the agency maintain viable populations of wildlife that are well distributed across the landscape. 36 C.F.R. § 219.19. The USFS has an obligation to accurately assess the impacts of its project on lynx. 

Edge areas within and adjacent to dense mixed conifer forests 

provide viable habitat for many species, including potential prey speciesfor lynx. The adjacent wilderness and roadless areas also provide potential habitat, and the project area likely serves as dispersal and migration corridors, as well as supplemental habitat for lynx that may occur within, or traverse through, the project area. The proposed action 

See Chapter 3, Wildlife, pp. 3-102 to 3-103 findirect and cumulative effects for each altedetail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-154

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

alternatives which would log connective mature and old forest habitat, would result in significantly further reducing needed cover for wildlife, jeopardizing both lynx and their prey species viability across the area—in violation of the NEPA, NFMA, and the ESA. The EA 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 EA must analyze the cumulative impacts of this project on lynx prey in association with other projects on the District, Forest, and surrounding lands. 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. The EA makes little mention as to any site-specific to protocol recent surveys supporting its determinations, fails to adequately disclose surveys or survey protocol, methodology, areas or frequency. As such, the EA’s proposed actions, and inference of non-significance is arbitrary and capricious and therefore illegal. The EA must be withdrawn and a new EIS conducted which addresses and corrects these analysis deficiencies and illegalities. Letter 3 – Comment 59

Wolverine The EA fails to adequately analyze how wolverine will be affected by the proposed project. Because it is probable that the species utilizes the planning area for some life cycle needs, the USFS is required to accurately address how the commercial logging and road building 

See Chapter 3, Wildlife pp. 3-104 to 3-106 foindirect and cumulative effects for each altedetail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-155

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

projects will affect those needs and the species itself. The EA’s failure to do so, and its irresponsible dismissal of the proposed project’s likely adverse impacts to wolverine, including the project’s likely incremental role in ongoing trends pushing this species towards uplisting under the ESA, violates NEPA and NFMA. 40 C.F.R. § 1502.16 (environmental consequences); 36 C.F.R. § 219.19 (fish and wildlife resources). 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 EA, or disclose any 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 effortsneeded to begin the recovery of this species and its required habitat. Letter 3 – Comment 60

American (Pine) Marten. There is not sufficient analysis in the EA of the effects of the proposed 

project on American marten in the planning area. The forests of the Umatilla including the Cobbler 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 EA fails to adequately and responsibly address this issue. 

See Chapter 3, Wildlife, pp. 3-94 to 3-95 for indirect and cumulative effects for each altedetail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-156

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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, and 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. Letter 3 – Comment 61

Eagles 

The EA violates the NEPA by their lack of meaningful and accurate analysis, and requisite meaningful scientific disclosures and conclusions regarding eagles. 

See Chapter 3, Wildlife, pp. 3-105 to 3-107 findirect and cumulative effects for each altedetail. 

Letter 3 – Comment 62

Northern Goshawk and Other Forest Raptors The EA 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 EA fails to adequately address impacts to Goshawknesting areas, including sufficiently assessing historic nesting areas, within or adjacent to the proposed logging project. Similarly, the EA fails to adequately address potential direct and cumulative impacts harms to existing raptor nests of other species in the area. 

However the EA 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 EA fails to address the cumulative impacts of the proposed project along with 

See Chapter 2, Table 2-6, pp. 2-21 to 2-28 foincorporated in the project to protect northeforest raptors. See Chapter 3, Wildlife, pp. 3-107 to 3-108 findirect and cumulative effects for each altedetail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-157

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

past, present, and reasonably foreseeable future actions, in violation ofNEPA, 40 C.F.R. § 1508.7. We are concerned about the affect of the planned transformation of the commercial logging units from mature and old mixed-conifer multistoried forests, to more open forest areas preferred by other raptors such as red-tailed hawks, which could extirpate goshawks from logged unit areas. It is known that suitable goshawk habitat contains a mix of dense multi-storied stands for nesting – such as currently exists in the project area. The project will remove necessary foraging, fledgling, and nesting habitat, which may result in the loss of potential Goshawk nesting habitat, as these features are inextricably linked within the greater Goshawk territory, thus resulting in fewer pairs of nesting birds within the area, or a loss of either or both fledgling juveniles and/or adults to predation or other mortality associated with logging impacts. The failure of the project’s action alternatives 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. It is clear that the agency must prepare an EIS to deal with this issue legally and adequately. Letter 3 – Comment 63

Neotropical Migrant and Native Birds 

Neo-tropical migrant and native forest-dependent birds (as well 

as numerous other forest species) are in serious decades-long population declines due to the adverse cumulative impacts from over a century of commercial logging in Oregon (see “Avian Population Trends” by Brian Sharp). The EA for this planned project fails to fully and adequately

See Chapter 3, Wildlife, pp. 3-109 to 3-113 findirect and cumulative effects for each altedetail. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-158

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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 EA 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 EA 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 proposed timber sale(s) would significantly impact 

migratory birds in violation of the Migratory Bird Treaty Act, 16 U.S.C. §§ 703—712 (1994). It is well known amongst the conservation-science community that many migratory birds which are currently experiencing severe population decline trends are “strongly associated” with old and mature interior forest and related habitat. The proposed commercial “thinning” logging would likely directly kill nesting and fledgling migratory birds. The proposed logging would significantly reduce existing mature and old forest-dependent migratory bird habitat, which has already been significantly diminished due to the cumulative impacts of past management throughout much of the Umatilla National Forest, including the project area. 

The proposed logging units would irreparably fragment 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-159

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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. 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 EA. The adverse impacts that the proposed logging would have on migratory birds are supported by multiple scientific studies. 

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, goldencrowned 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 EA despite the obvious direct adverse impacts to many migratory and nativebird 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. Implementation of this project would violate both NFMA and the Migratory Bird Treaty Act. As such the mature and old pine and mixed conifer forest commercial logging portion of this project must either be withdrawn from the proposed action alternatives, or an EIS must be prepared which addresses these issues. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-160

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 64

Salmonid Waterways, Habitat, & Aquatic Resources: 

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 EA fails to disclose why this information is unavailable or when it may become available in the future. The EA 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. Despite the lack of this necessary information, the agency proposes to move forward with the Cobbler project based on deficient information and analysis in the EA rather than responsibly conduct an EIS for this project, and obtain and assess the requisite missing information. The EA also notes that “since Redband and Steelhead are both O. mykiss and juveniles are indistinguishable in the field they” were “not addressed separately in this evaluation.” Additionally, the EA clarifies: “Some fish stocks native to the area (coho, lamprey, sockeye) have been extirpated.”  The above disclosures represent significant environmental issues. Given the number of listed and regionally sensitive aquatic species in and downstream of the project area; the number of species that have already been extirpated due to cumulative degradation of natural habitat and watersystems; the extensive management actions proposed in stream reaches and upper tributary headwaters to the area’s 303(d) listed waterways; and the apparent complete lack of surveys assessing the water quality status and habitat conditions 

See Chapter 3, Hydrology and Fisheries, ppdisclosure of direct, indirect and cumulative alternative considered in detail. Fish occupancy has not been confirmed for Creek, Swamp Creek, Elk Creek or Burnt Cthey are small, remote, wilderness streams t

above their confluence with the Wenaha Rivhigh gradient that probably prevents fish usare not likely to be fish bearing beyond their Nevertheless, our present and proposed manreaches would protect fish and their habitat 

they were fish bearing. Assumption by the Fthese streams are fish bearing in their lower approach for fish that may (or may not) inhimplementation of the PACFISH RHCA’s bfor the parts of the streams within the projeprotect the any fish or their habitat that migin these streams (Chapter 2, Table 2-6, pp. 2Known fish-bearing streams within the projsurveyed, and this information is reported in Redband trout and steelhead are the same shave the same environmental needs. The inSteelhead and redband juveniles in the field environmental issue. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-161

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

within project area creeks and streams; it is clear that an EIS, not an EA, is required for a project of such scope and impacts. 

The author is misinformed. Coho were extirtrapping by the Oregon Fish Commission, ndegradation. Sockeye salmon in the Grande Wallowa Lake spawning population) were econstruction of a barrier at the lake outlet in degradation. Lamprey were extirpated by dthat species on the Columbia and Snake Rivdegradation. So considering dams as “watetrue that degradation of water systems controf these species, but no water system maniputhe Cobbler project. The commenter has misread the EA. Extenactions in stream reaches are not proposed b

An upper tributary headwater channel wouby ATV’s to transport materials for hardworeported and evaluated in the EA. It is true that there is limited data regarding 

disclosed in the EA (Chapter 3, pp. 3-23 to 3been little active management near most pronone near fish-bearing parts of streams, it is assume that they are near natural regarding 

Letter 3 – Comment 65

The EA 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 

See Chapter 3, Soils, pp. 3-4 to 3-9 and Fishefor disclosure of direct, indirect and cumula

alternative considered in detail. The status populations is addressed in Chapter 3 as is t

findings regarding effects to both fish and th
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-162

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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 proposed action impact determinations, mitigation provisions, and claims. The EA 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 proposed project areas. 

components. See Appendix D – Best Management Practicresource protection measures and mitigationSee Appendix E – Soils 

Letter 3 – Comment 66

The EA fails to adequately and accurately analyze whether the Cobbler 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 proposed project. Because the FS has failed to reasonablydemonstrate that the Cobbler sale is not inconsistent with either INFISH or PACFISH, its proposed actions are arbitrary and capricious, and likely to result in irreparable harms. 

See Chapter 2, Table 2-6 Design Features anRequirements, pp. 2-21 to 2-28. See Chapter 3, Hydrology, pp. 3-9 to 3-22 foindirect and cumulative effects for each altedetail. See Appendix D – Best Management Practicresource protection measures and mitigation

Letter 3 – Comment 67

Aquatic Species and Watershed Habitat/Water Quality Issues: Chinook Salmon, Steelhead, Redband Trout, Bull Trout, Lamprey?, Sculpin

The EA fails to accurately disclose to protocol ongoing and/or 

recent surveys for these and/or other aquatic species in the affected 

See Chapter 3, Fisheries, pp. 3-23 to 3-42 for indirect and cumulative effects for each altedetail and Specifically Required Disclosures disclosure on how the action alternatives comstate and federal laws, regulations, and polic
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-163

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

watersheds, or to explain why this has not occurred and when these surveys may be done. The EA 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 verifiableproject 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 EA proposes harmful logging and road construction in both of the Cobbler Project’s action alternatives. Despite significant scientific documentation that steelhead and bull trout are among the most critically sensitive imperiled fish species, the EA concludes the project is not likely to result in significant or apparently even cumulative harms. The EA fails to accurately disclose and addresshow 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. 

The EA fails to disclose the range of scientific controversy 

concerning logging and road building actions in salmonid waterway forests in violation of the NEPA. The proposed 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. The EA as such must be withdrawn and an EIS conducted that responsibly addresses these issues, with a range of restoration alternatives capable of protecting and restoring these imperiled species and their habitat. 

Habitat evaluation protocol is disclosed in C3-28). Waterway (stream) surveys have beereported in the EA in some detail. Chapter 

of aquatic habitat data and accompanying ediscussion of the data. The EA presents the rational for the conclusfor each aquatic habitat parameter in ChapAll timber harvest would be outside of PAC(Chapter 2, Table 2-6, pp. 2-21 to 2-28). Th120 feet or farther from intermittent streamfarther from perennial non-fish bearing stre

farther from fish bearing streams. Rashin ebuffer widths of 10 meters (approx 33 feet) wpreventing 95% of harvest related sediment channels. The buffers (PACFISH RHCA) fo

would be from about five times to nearly ten would be proportionally much more effectiv

harvest related sediment from reaching streCobbler harvest methods would produce lesdisturbance than older, traditional harvest mwould be less erosion to begin with. Detectanot be expected to reach stream channels. The proposed road building amounts to a chmiles/square mile, all distant from stream ch

hardly be termed widespread roading. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-164

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Recovery objectives are established by other as population numbers. There is no mechanproject to affect those objectives. The EA rethe potential for effects to all listed fish specaddresses the potential for reaching (as oppoobjectives. There is really no scientific controversy regaadverse effects by road building and timber recognized in the scientific literature that th

potentially adversely affect salmonid fish an

also well substantiated that proper mitigatineffectively reduce these risks to very low levproject will implement such mitigating meas

no scientific controversy about the effects of building. 

Letter 3 – Comment 68

Proposed logging and associated activities will cause cumulative impacts

that violate PACFISH and INFISH 

The project as proposed is inconsistent with the biological opinion 

foundations of PACFISH with respect to salmonid species recovery and habitat protection. The EA 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 EA, 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. Importantly, the EA aquatics cumulative impacts analysis fails to disclose the total cumulative effects of past 

See response to Letter 3 - Comment 66 abovThe WEPP model was not used in this proje
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-165

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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. Letter 3 – Comment 69

In its analysis of sediment delivery, water quality, and future large

wood input the EA failed to adequately consider and disclose steepness of slope issues, which has a direct bearing on the inevitable movement of soil and wood toward streams. 

In its analysis of sediment delivery and water quality, the EA failed 

to consider the fact the RHCA buffers may be compromised by fires, OHV 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 EA 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. 

The EA 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. 

The EA analysis of large wood and sediment failed to consider the 

impacts of removing hundreds of hazard trees from miles of haul roads. Since the EA allows removal of large logs that are felled across roads or 

See Chapter 3 for environmental effects anaaddressed in your comment. Also listed in Cpresent, and reasonably foreseeable actions cumulative environmental effects analysis foThe project design did consider the effectivewhich are implemented in this project. The some parts of the project area actually functmechanism; both cattle and OHV’s avoid thActivities proposed in the Cobbler project hmitigated to prevent or minimize damage to erosion, and sedimentation (Chapter 2, Tab28). Road drainage improvement, especially could cause short-term, less than one week, potential for sedimentation from any other pnegligible. Proposed activities offer no oppomeasurable cumulative effects with ongoing The EA clearly states that no trees would be RHCA’s. Danger trees standing inside of R
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-166

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

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 EA underestimated project impacts. 

Road reopening, maintenance, and log hauling will also unavoidably 

retard attainment of RMOs in violation of PACFISH/INFISH. BMPs are inadequate and do not assure that impacts will be avoided. 

Large areas undisturbed by roads, landings, burned slash piles, and 

logging help protect watershed values such as soil conservation, nutrient cycling, water infiltration, and uninterrupted flow of water and materials from uplands to streams. This in turn helps ensure high quality water for listed and unlisted fish and other aquatic organisms. Logging and slash burning in uninventoried roadless and mature and old forest areas will degrade watershed values by disturbing soils and increasing erosion, disrupting nutrient cycles, and depriving streams of potential large structures. The EA failed to adequately disclose the full effects oflogging and how it will degrade unroaded areas, mature and old forests, and aquatic systems. 

With respect to water quality and salmonid populations and habitat, the EA alternatives, analysis, and conclusions fail the NEPA’s high quality science, reasonableness, cumulative impacts, and site-specificaccuracy requirements. 

the timber sale. Danger trees standing in RHdropped in the safest direction, which is almtoward the stream channel, and left on site (BMPs (Appendix D) and Cobbler project de2, Table 2-6, pp. 2-21 to 2-28) will keep soil derosion at very low levels and in locations thdegradation of water quality or aquatic hab

Letter 3 – Comment 71

Forests & Fires – Myth and Reality 

The EA’s proposed actions pertaining to fire issues are premised 

upon broad brush assumptions that are not only unsubstantiated, but fail to accurately present site-specific conditions, and fail to employ high 

Although large scale fires are a natural procbeneficial to forest ecosystems, the Forest Pl

the “let it burn” strategy. This is principally 

does not manage large enough wilderness or a fire can be allowed to burn without the thr
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G-167

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

quality scientific and expert recommendations pertaining to the area’s forest types and conditions. 

While much of the area’s forests have been significantly altered from

historical ecological conditions through decades of logging, road building, and grazing, the EA’s claim that “majority of current forest stands originated as a result of fire disturbances occurring over one hundred years ago, and they have not experienced fire since then” fails NEPA’s accuracy and reasonableness requirements, and violates NEPA’s expert, science, and site-specific requirements. The EA’s assertion is unsubstantiated, with little evidence within the EA of the requisite site- specific surveys and methodology needed to determine whether there has been any fire occurrence in the project area within the past 100 years, or whether the area’s mixed-conifer, mixed severity fire forests truly have significantly altered fire patterns. 

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 EAhowever, fails to provide such site-specific discerning information in its analysis. 

The EA also fails to address the natural beneficial role of large-scale 

fires, including severe fires, and the natural mosaic patterns of large burns. Forests do not vanish from existence whole-scale due to fires. Large fires historically burned over a period of days to months. Differing wind, moisture, temperature, and weather patterns; times of burn from nocturnal to afternoon; locations of affected stands and available moisture, general topography, natural fuels breaks or high fuels levels;

private property or threatening communitieother values at risk. Cobbler project planniapproximately 5 miles from the communitieEden Bench and Bartlett Bench, a distance tcrown fire could burn through in a matter othe planning area is not located within a wilinterface, we are proposing to conduct fuel tallow firefighters the opportunity to control reached these communities. See Chapter 1, Purpose and Need, pp. 1-2 to See Chapter 3, Fuels pp. 3-58 to 3-72 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-168

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

etc. all play integral roles in determining the mosaic of fire-caused tree mortality levels and the forest structural mosaic left in fires’ wake. 

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 EA 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. Again, an EIS is needed for this proposed project. 

Letter 3 – Comment 73

Old Growth “Recruitment” 

Mature and old trees are natural components of the area’s forest 

ecosystems, and should be retained – such is the best known method to accomplish the agency’s stated goal “to accelerate old-growth recruitment.” Indeed, old growth develops best naturally, and despite years of efforts, there has been little if any documentation of successful 

management efforts to replicate, or improve upon, nature’s time-proven processes for old growth “recruitment.” NEPA requires the agency provide scientific support for its proposed actions and objectives, however, the science and evidence supporting this stated goal are lacking from the EA, and are at best scientifically controversial and largely already disproven.

N/A – We are not recruiting old growth stanSee Chapter 1, pp. 1-3 to 1-8 for Purpose anAction. 

Letter 3 – Comment 74

Lodgepole Pine & Insects, Fires, and Natural Disturbance Processes 

The EA premises a significant portion of its action plans on the 

See response to Letter 3 – Comment 29 
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G-169

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

presumed “need” and capability of logging to “restore” or otherwise positively influence lodgepole pine forest stands. The EA claims: 

“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 EA 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 sciencesupporting the proposed logging plans. 

Scientific research addressing lodgepole pine ecosystems, and the 

role of insects was ignored by the EA, though such information is critical to the stated purpose and need ecological objectives. One USFS study that addressed logging to reduce the impacts of insects over a thirty year period (1920’s to 1950’s) concluded that such actions were infeasible as they would have to “destroy the forest to save it.” Yet with the Cobbler EA, the agency repeats past failed logging proposals to reduce the risk of insects and fire in lodgepole pine forest systems where naturally growing stand density, insect mortality, corresponding fuels buildup, and high severity stand replacement fires are the natural ecological cyclic patterns. The area’s interfacing mixed conifer and ponderosa pine forests have evolved with and adapted over time to the area’s lodgepole pine stand patterns. Such species edge and interface areas fluctuate in ongoing dynamic cycles of natural variability; with stand compositions and mosaic landscape scale patterns varying in edge-interface areas in accord with climatic, fire, insect, and growth fluctuations over time. However, the EA fails to disclose or address research pertinent to these patterns and issues. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-170

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

 The EA fails to assess, and needs to disclose and analyze, the consequences of disrupting natural disturbance processes in lodgepole pine and mixed conifer forest ecosystems. Among the integral necessary benefits of periodic high severity fires are containing natural forest pathogens within the checks and balances of nature, including mistletoe, bark beetles, ips, root/fungal and other diseases; increasing nutrient availability, botanical diversity, stand vigor and growth, habitat diversity and rotation; and a host of other interrelated processes as old, and as little yet understood, as the evolution of these forests themselves. The new EISfor this project must address pertinent scientific research assessing the costs and impacts of altering natural processes in the project’s lodgepole pine and mixed conifer forests. The new EIS must incorporate and disclose scientific research and management recommendations pertinentto lodgepole pine systems and to mid to high elevation, north aspect, moist fir-dominant forests with less frequent but still recurrent mixed and/or high severity fire patterns. A reasonable informed legal decision approving the proposed actions cannot go forward under provisions of the NEPA absent these imperative scientific analysis disclosures and considerations. Letter 3 – Comment 75

Climate Change, Natural Forests Cycles, & Carbon Sequestration The forests of our region provide for significant levels of carbon sequestration, which is critically important in addressing and alleviating 

the growing harms of ongoing climate change. Forest soils as well as forest stands are critically important carbon storage reserves. Logging and soil disturbance and exposure significantly diminishes carbon storagecapacity, while natural fires and disturbance do not. Ultimately, as we arewitnessing with increasing cumulative global climate change and 

A qualitative environmental analysis for Cliincorporated in Chapter 3, pp. 3-133 to 3-13considered in detail. 
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G-171

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

ecosystem degradation, human tampering and recreation of natural ecosystems is not plausible without significant and often unforeseen harmful repercussions. The EA’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. Again, an EIS is necessary for a project of this scale, impact, and importance. Letter 3 – Comment 76

Fire Management Alternatives 

The EA fails to meaningfully incorporate utilizing scientifically 

recommended strategically placed land area treatments – SPLATS (or SPOTS, etc.). Without fully analyzing an alternative that minimizes the extent of acreage manipulated by management actions, and thereby saves limited resources while protecting natural habitat, the Forest Service and 

the public will never fully know how the ecological objectives of the proposed action could be attained without widespread commercial logging. The Forest Service cannot make an informed decision without full analysis of small diameter strategic SPLATS-style thinning and restorative actions. 

See response to Letter 3 – Comment 30 abov

Letter 3 – Comment 77

Fire Regime Condition Class Inherent Failures The Forest Service uses models are not based in best available science. It relies heavily on Fire Regime Condition Class (FRCC), which is a highly controversial method of determining the ecological status of a forest. (Morrison and Smith, 2005) 

The EA fails to adequately address the scientific controversy 

surrounding the use of Fire Regime Condition Class or the model 

The Fire Regime Condition Class (FRCC) cmay be controversial, but any method used ecological status of forests today to historicanational level is going to be imperfect. The Fsystem is one of the primary tools for definintracking success in treatment of hazardous fnumerous national directives, including: IncFuels Treatment on Federal Lands in the PaCollaborative Strategy, 2000; A Collaborati
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-172

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

methodology used in its fire risk modeling for this project. The EA states the following unverified premise based upon FRCC: 

“Fire regime condition classes, which describe deviation from natural fire regimes in terms of fire return intervals and vegetative change from historical composition and density, have been modified in the project planning area due mainly to past harvest history and fire suppression. Approximately 40 percent of the project planning area has changed from a historical fire regime (Class 1) to a moderately altered fire regime (Class 2) and 10 percent of the area has changed to a significantly altered fire regime (Class 3).” 

It is notable that even given the inaccuracies ascribed to using FRCC, theEA 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 inherentin using FRCC, this calls into serious question the “fire-risk” reduction “need” for this project at all – especially given more priority WUI areas nearer human communities, and limited agency and public resources. 

Reducing Wildland Fire Risks to CommunitEnvironment: the 10 Year Comprehensive SImplementation Plan, 2002, Protecting PeopResources: A Cohesive Fuels Treatment Strprimary issue with FRCC is that because it national scale, the data cannot be directly colevel without errors. However, FRCC can be 

applied at the correct scale, as documented b2001 article: Fire and land management plaimplementation across multiple scales. The Forest has developed fine scale FRCC data tthe project level as described in this publicais an imperfect measure for determining the it is the measure our agency has been directlike those proposed in the Cobbler project p

Letter 3 – Comment 78

The EA Must Identify the “Best Available Science” That Supports Logging in LOS Stands That are Barely Within HRV to Convert MultiStoried Old Growth Forest to Single Storied Stands. The EA does not 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. The EA must demonstrate how the “best available science” standard was considered with regards to this proposal. 

This proposal is for understory thinning of o(OFMS) to convert it to old forest single storthe stands where it is in compliance with the analysis (See Appendix F). All trees >21 inc

left, and the density of understory trees wouDepending on species composition of the resharvest fuel treatments would be done eithemechanical methods. The studies are more not reducing competition and excessive fire 

buildup of small tree stocking is more likely the old forest structure than is thinning and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-173

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

The EA Should Thoroughly Discuss the Scientific Uncertainties Associated with Logging in LOS Stands to Convert Multi-Storied Old Growth Forest to Single Storied Stands 

Several studies are referenced in the June 20Regional Office, “Guidance for ImplementinOthers are Arno et al. 1997, Agee and Skinn2006, and Reinhardt et al. 2008. See Literature Citations– pp. L-1 to L-13. 

Letter 3 – Comment 79

he EA fails to acknowledge and 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 multi-story 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. 

See response to Letter 3 – Comment 78 abov

Letter 3 – Comment 80

Reduced Habitat Connectivity This growing concern over connectivity and further habitat fragmentation 

gives rise to the need for federal land managers to look beyond meeting minimum forest plan standards for individual projects, as the case seems to be here. Rather, the Forest Service should assess how each project has the potential to affect wildlife connectivity on a broader scale, meaning at least at the forest-wide level. Connectivity concerns are heightened in this area due to the fact that the project planning area is bounded by the Wenaha-Tucannon Wilderness to the north and west and encompasses approximately 7,700 acres of the Grande Ronde inventoried roadless area (IRA)--two core habitat blocks. The project area is also within or 

See Chapter 3, Wildlife, pp. 3-83 to 3-113. Also see Appendix F – Consistency with Eas

to F-4 for disclosure how Cobbler project is riparian, ecosystem and wildlife standards o
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G-174

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

adjacent to two "Priority Conservation Opportunity Areas" identified by the Oregon Department of Fish & Wildlife’s (ODFW) recently developed “State Wildlife Action Plan,” known as the Oregon Conservation Strategy (OCS).  While the EA claims Eastside Screens direction for connective corridors will be met, it fails to substantiate such claims by eitheraccurate site-specific information or applicable scientific research pertaining to the cover needs of imperiled interior forest species. An EIS is needed to further more comprehensively assess these significant issues. Letter 3 – Comment 81

Roads, Soils, and Invasive Weeds According to the EA, about 176 miles of road have been built in the Cobbler project planning area. Our assumption is that this figure does not include “temporary” roads that are still impacting the project area or 

OHV routes. And although 111 miles of those roads are now “closed,” both action alternatives call for reopening approximately 40 miles of closed roads. Of even greater concern is the preferred alternative’sproposal for .25 miles of new road construction and .20 miles of 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. 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 be given seriousattention, particularly given the level of livestock grazing, and high influx of vehicles and humans, that occurs within the project area. The 

See Chapter 2, Table 2-6 Design Features anRequirements, pp. 2-21 to 2-28 See Chapter 3, specifically the following sect

• Soils – pp. 3-4 to 3-9 • Invasive Plants – pp. 3-76 to 3-81 • Wildlife – pp. 3-83 to 3-113 

See Appendix E – Soils for a detrimental soi

each unit. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-175

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

EA notes a list of measures to mitigate these risks, but fails to disclose the effectiveness and applicability of such measures. The new EIS must identify the success rate of these measures and substantiate claims with verifiable supporting data. Letter 3 – Comment 82

Soils & Forest’s Foundational Soil Microbial Communities Mycorrhizae & Soils 

The EA did not sufficiently recognize the importance of 

mycorrhizal fungi on forest growth and productivity. The EA failed to adequately discuss how mycorrhizae will be impacted by the proposed timber project. The EA failed to sufficiently assess how logging has affected mycorrhizae in areas nearby the analysis area. Mature and old 

growth forests within the project area are rare within the Umatilla, and must be protected from adverse logging impacts. Scientific evidence suggests that mycorrhizae and other soil organisms and processes are extremely important and are easily destroyed by ground-based logging, including thinning using BMPs as well as post-logging subsoiling, which devastates subsurface soil microbial communities upon which healthy functioning forests depend. Affected wildlife species, including prey species for raptors and predators also rely on the fungi, but there is no discussion of how the project will affect this important food source for these species. Without an adequate discussion of the impacts to soil mycorrhizae, including the harmful impacts of ground-based logging, subsoiling, and ineffectiveness of BMPs; the public and the decisionmaker are precluded from making an informed decision regarding the proposed project, and the USFS cannot assert that there will be no permanent impairment of the soil. 30 C.F.R. §§ 219.27(a)(1), 219.14(a)(2) (prohibiting activities unless technology is available to prevent impairment of soil or water resources). 

Logging systems and operational controls arminimize the extent and degree of disturban

Plan guidelines for detrimental soil conditioincludes soil compaction and potential soil epotentially damaging soil disturbance allows mycorrhizael populations from the mosaic oneeded. Linear skid trails are to be kept welnarrow as machinery facilitates reinoculatiountrafficked area (Chapter 2, Table 2-6, pp. Retention of organic matter, both above and including charcoal, is important for mycorrvigor. Project design objectives include orgawithin ranges expected for the ecotypes of thbalancing fire severity and history concernsAdjacent regeneration harvest units (clear clevels of soil disturbance during harvest and decades ago. These stands are growing quite very resilient soil characteristics. Proposed amuch lower levels of disturbance. Detrimental soil impacts tabulated as Detrim

(DSC) is discussed in the EA and listed in Abasis and in Chapter 3, Soils, pp. 3-4 to 3-9. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-176

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Soil research and surveys of similar projects confirms the 

proposed project will have detrimental impacts on soil, including destruction of microbiotic organisms, soil compaction, and soil erosion. The EA 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. 

Letter 3 – Comment 83

Biomass 

The EA fails to adequately address and disclose the extent of 

potential adverse impacts from excessive biomass utilization as part of 

this project. Short-term scientifically non-controversial 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. 

Down woody debris would be left at or abovthe Eastside Screens. See Chapter 2, Table 2-6, pp. 2-21 to 2-28; aConsistency with Eastside Screens. 

Letter 3 – Comment 84

Benefits of Insect and Mistletoe Presence Bark beetles and mistletoe are also natural processes that have benefits in 

the natural succession of the forests. The EA failed to address theimportant natural roles and benefits of these components. Instead, mistletoe and beetles are being used as scientifically insupportableexcuses for excessive harmful logging actions. The EA 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 should not be targeted for logging removal. 

See response to Letter 3 – Comment 16. Where nests are found in trees that could be 

timber markers are directed to report them biologist (Chapter 2, Table 2-6, pp. 2-21 to 2
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G-177

LETTER #3 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3 – Comment 85

Understanding the importance of snags The project as proposed would have adverse impacts on these essential components of natural forest ecosystems. 

See Chapter 3, Dead Wood, pp. 3-95 to 3-10

Letter 3 – Comment 86

We request that this EA and its proposed actions be withdrawn, and a legally compliant, ecologically protective, scientifically-founded restoration project EIS be developed for the Cobbler Project area that works with – instead of against – natural forest processes, forest resiliency, and integrity. 

Your comment has been noted. 
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Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Comment Our Response 

Letter 3- Exhibit A- Comment 1

- 2002-Kotliaretal-SAB1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 2

- 2005-Kotliaretal-GTR-fire1.pdf Opinion statement presented at a conference. 

Letter 3- Exhibit A- Comment 3

- 2006-HuttoGallo-condor1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 4

- 06357811.pdf Court Case School Fire 

N/A – Appeal documents – no specific commeproject. N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 5

- Bakeretal-for-Rest. Rmtn-JBiogeo.9-061.pdf 

The focus of this publication is to refute the athrough the restoration of pre-fire exclusion cto a low-severity fire regime that ecological rehazard mitigation can be simultaneously achielevation, dry forest ecosystems of the westerBecause this article is arguing that what workSouthwest doesn’t necessarily work in the forMountains and because it refers specifically t
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G-179

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

ponderosa pine forests, it doesn’t apply to the proposed in the Cobbler project planning are

Letter 3- Exhibit A- Comment 6

Be careful what you wish for the legacy of Smokey Bear1.pdf Opinion statement– not science. 

Letter 3- Exhibit A- Comment 7

- Beschtaetal.2004.ConBio.18.957-9671.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 8

- Chan et al_thinning_CJFR 20061.pdf 

This article about accelerating old growth attstands was conducted in the Coast Range and the Blue Mountains. 

Letter 3- Exhibit A- Comment 9

- Donato-Post-Wildfire Logging Hinders Regeneration and Increases Fire Risk1.pdf 

N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 10

- Dr. Hutto - Post-fire impacts on forests and wildlife2.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 11

- Eastside Screens - Henjum_et_al_1993 - Executive Summary1.pdf 

See the EA, Appendix F for how Cobbler pro

the Eastside Screens. 

Letter 3- Exhibit A- Comment 12
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Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

- Fire Science new study April 07.doc N/A - No post-fire salvage logging is proposed Letter 3- Exhibit A- Comment 13

- fireregimeuncert-veblen-'031.pdf 

This article discusses that some land managerassumption that fire hazard reduction througecological restoration have convergent objectecosystems in the western United States. The this implication needs to be explored on the bknowledge of historical fire regimes and foresby case basis for different forest cover types aThe Cobbler Timber Sale and Fuels Reductioproposing to treat lands within the planning abeen analyzed for historical fire regimes and project level scale by collecting site-specific in

Letter 3- Exhibit A- Comment 14

- Forest Dreams Forest Nightmares - Place Ecology 21.pdf Opinion statement– not science. 

Letter 3- Exhibit A- Comment 15

- Foster-Orwig2006_NE_forests_doing_nothing_viable1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 16

- Fuels Thinning study IAWF_ms_30Mar_Saab.doc 

This paper is about prescribed burning, not tChapter 2, Table 2-6, pp. 2-21 to 2-28 for DesManagement Requirements. 
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Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Letter 3- Exhibit A- Comment 17

- Hutto 20061.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 18

Hutto Article from Missoulian1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 19

- kou-Baker-fire scars-L.Ecol.'06a.doc N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 20

- Logging_to_Control_Insects.pdf 

This is an article that compiles results from m

do with the effectiveness and desirability of hthe objective of changing the amount of mortforest insects. In the Cobbler project, we follof the zone entomologist and pathologist for dtreatments in stands susceptible to insects tharelatively low level and occasionally increase The harvesting of lodgepole pine in stands thasusceptible to mountain pine beetle is not to pincreasing but to harvest intact trees before tstaining and rot in stands where there is reasomortality because of the stand ages. The lodgsurrounding stands is also likely to have heavfuture but is not prescribed for harvest becau
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Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

other resource values. The studies referenced respect to thinning stands with the partial objfuture mortality from insects showed varying effectiveness. Cobbler project does include ththe end of the article with regard to late and oand species diversity, soil and tree damage, an(Chapter 3, pp. 3-42 to 3-50). 

Letter 3- Exhibit A- Comment 21

- Neotropical Migrant and Native Birds section Five Buttes appeal.doc

Site specific Landbirds affected environment effects analysis for the Cobbler project are loChapter 3, pp. 3-109 to 3-113. 

Letter 3- Exhibit A- Comment 22

- OdionHanson Ecosystems1.pdf 

The results of this study and publication are s

Nevada forests of California and are not applproject. 

Letter 3- Exhibit A- Comment 23

- Rebuilding Fire-Resilient Ponderosa Pine Forests psw_gtr1981.pdf 

This report pertains to stands in the dry upla

vegetation group of the area. Approximately project planning area is dry upland forest. Trecommends the type of thinning and burninare proposing to implement (see Chapter 2, Ato 2-29). 

Letter 3- Exhibit A- Comment 24

- SCIE#28A.TXT 

Report on modern forestry vehicles and impaproperties. The determination of ecological as 

consequences of mechanized harvesting proce
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-183

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

transformation from pure spruce stands to clmixed forest stands. Discusses impacts in SwSee Chapter 3, Soils, pp. 3-4 to 3-9 for environanalysis. 

Letter 3- Exhibit A- Comment 25

- Science Black Backed WP C Hansen disertation.doc 

This is a research proposal. 

Letter 3- Exhibit A- Comment 26

- Scorched forests best left alone study finds1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 27

- Spotted Owl Timbered Rock Fire Telemetry 2003-2004 1.pdf N/A – Umatilla National Forest has no spotte

Letter 3- Exhibit A- Comment 28

- Spotted owls & post-fire habitat Bond2002.pdf See response to Letter 3-Exhibit A – Commen

Letter 3- Exhibit A- Comment 29

- spotted_owl_fire1 New Mexico study.pdf See response to Letter 3-Exhibit A – Commen

Letter 3- Exhibit A- Comment 30

- Stress Physiology1.pdf 

This article reviews the effects and adaptation

stress on trees, especially ponderosa pine and 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-184

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

are no direct applications to the Cobbler proj

Letter 3- Exhibit A- Comment 31

- Studies Find Danger to Forests in Thinning Without Burning1.pdf Opinion piece in New York Times 

Letter 3- Exhibit A- Comment 32

- Thinning and Nitrogen Fertilization1.pdf 

This is a study about fertilization of grand fir spruce budworm epidemic. This is not a trea

proposed in the Cobbler project. The part of pertinent to the Cobbler area are statements transition from ponderosa pine to grand fir afire suppression may be nutrient deficient ansusceptible to insect damage. We agree. 

Letter 3- Exhibit A- Comment 33

- Timbered Rock 9th cir court decision 7-07 OW.pdf N/A – court decision documents 

Letter 3- Exhibit A- Comment 34

- Waring_etal_FEM_20061.pdf 

This article is about modeling forest stand prscale. N/A to the Cobbler project. 

Letter 3- Exhibit A- Comment 35

Watershed Impacts of Forest Treatments to Reduce Fuels Modify Fire Behavior11.pdf 

The PRC paper narrowly focuses on the negatreatments and does not discuss or evaluate cequipment such as will be used in the Cobble
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-185

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Fuels Reduction Project. As such it does not 

magnitude of activities or effects that will occ

Design features (Chapter 2, Table 2-6) and BMspecific mitigation will limit ground disturban

fuels treatments to a mosaic of areas with sho

low risk of surface erosion. These design feat

and prevent damage to riparian and other newhich will continue to provide ecological servcapacity and recover capacity that may have In addition, specific mitigation measures have minimize erosion and sedimentation from wostreams; much needed drainage installation ohaul routes inside RHCAs. 

Letter 3- Exhibit A- Comment 36

- Abstracts_Wildfire_Charcoal.doc 

Project design and objectives include balanciretention and excessive fuels buildup with the 

areas of high severity wildfire. As the Briggs charcoal results from the incomplete burning (wood). Treatments are designed to reduce thseverity wildfire that can completely consume and moderate fire, whether prescribed or wilproduction of charcoal and retention in the sy
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-186

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Letter 3- Exhibit A- Comment 37

- Biochar_White_Paper_10-9-07_w-o_links.doc 

Umatilla National Forest is working with the Research Station (RMRS), Missoula TechnicaUmpqua NF on the creation and application opyrolysis techniques, and the impacts on soil chemical processes. We also have a RMRS stuuncharred wood decomposition and colonizaton the Pomeroy Ranger District School fire a

Letter 3- Exhibit A- Comment 38

- catastrophic windthrow and salvage logging_Rumbaitis_Can JFor Res2006.doc 

N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 39

- Evaluating wildland fire danger and prioritizing vegetation and fuels treatments.doc 

This paper describes utilizing an array of critdanger of severe wildland fire and to prioritiz

treatment. Although we did not use exactly tdetermining wildfire risk and prioritization oused much of the same criteria as presented i

Letter 3- Exhibit A- Comment 40

- Everett_94_dryoldforests_landscapes1.pdf 

This article discusses many of the design elem

planning the Cobbler project. It discusses ththat have occurred since fire suppression begchanges make the forest landscape susceptibllarger scale than historically. Many of the cowere analyzed as part of the Eastside Screens Appendix F), and Cobbler project activities a
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-187

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

those criteria. 

Letter 3- Exhibit A- Comment 41

- Fire Fuel Treatments Effectiveness Rhodes-Baker 08.pdf 

This article focuses on discussing the merits o

the effectiveness of fuel treatments at reducinexact location and timing of a fire occurrence particular location and timing of a wildfire is however, this does not preclude fire managerin strategically located areas, where if a fire wsuppression forces could access the area and Forest Plan does not allow for “let it burn” stmust be suppressed as quickly and cost effectminimum impacts to resources. 

Letter 3- Exhibit A- Comment 42

- FireWhitepaperExecutiveSummary Knoss et al.pdf Not peer reviewed science. 

Letter 3- Exhibit A- Comment 43

- Forest Dieoff in West Science 1-09.pdf 

The authors of this study conclude that increaand decreased stand densities observed in lonto regional warming and consequent drought addressed in the section on climate change in 

Letter 3- Exhibit A- Comment 44

- Forest Restoration - hydrology & soils impacts of temp roads and thinning-logging 1-09.doc 

This adaptation from a memo takes selected sparagraphs from peer reviewed literature oufocuses on the potential for most severe effect
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-188

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

of effectiveness of best management practicespotential benefits of certain activities. This p(Appendix D) and design criteria(EA, Chapteprevent damage to aquatic systems from activmitigation measures to minimize erosion and work that will occur near streams; much needinstallation on FR 6222 and use of haul route

Letter 3- Exhibit A- Comment 45

- Historic Fire Regimes PiPO CO Kaufman et al 06.pdf 

This article speaks specifically to forests in CPonderosa Pine is the dominant or co-dominathemes presented in this article do not have wimplications that would apply to Cobbler TimReduction Project. 

Letter 3- Exhibit A- Comment 46

- Hutto20081.pdf Opinion statement – not science. 

Letter 3- Exhibit A- Comment 47

- Hutto et al 2008 2.pdf Opinion statement – not science. 

Letter 3- Exhibit A- Comment 48

- IJWAug08_Wuerthner.pdf Opinion statement by photographer – not sci

Letter 3- Exhibit A- Comment 49

- Logging not the answer to pine beetle problem.doc This is a newspaper article and not peer revie
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-189

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Letter 3- Exhibit A- Comment 50

- Notes_Biochar_Forest_Post-Fire.doc See response to Letter 3 –Exhibit A - Comme

Letter 3- Exhibit A- Comment 51

- Pine_Charcoal_Contribution_Article1.pdf 

This article is about the characteristics of cha

it contribute to water holding, nutrient retentforest soil in a ponderosa pine stand. It is intnot change treatments prescribed in this area 

Letter 3- Exhibit A- Comment 52

- PlattVeblenFireRegimesTrtmntsCO'061.pdf 

This article discusses the thought that some launder the assumption that fire hazard reducttreatments and ecological restoration have coall forest ecosystems in the western United Stsuggests that this implication needs to be explexisting knowledge of historical fire regimes aon a case by case basis for different forest covlocations. The Cobbler Timber Sale and Fuelonly proposing to treat lands within the plannhave been analyzed for historical fire regimes on a project level scale by collecting site-speci

Letter 3- Exhibit A- Comment 53

- Robichaud_MacDonald_Foltz_CWE_Fuel_Mgmt.pdf 

This paper provides a useful review of literatevaluation of the potential for watershed effec

management and auxiliary treatments. The lenumeration of potential effects, and discussi
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-190

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

mitigation are similar to those used in the des2, Table 2-6, pp. 2-21 to 2-28) and analysis of cumulative watershed effects (Chapter 3, pp. 

Letter 3- Exhibit A- Comment 54

- Rumbaitis salv log study abstract1.pdf N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 55

- SC Fire & Forest restoration.doc 

This is a compilation of articles from many so

silviculture, fuels management, climate changgrazing. The articles are general in nature ananything site specific about the Cobbler proje

Letter 3- Exhibit A- Comment 56

- The Myths of Forest Health - G. Wuerthner.doc 

This is an article or book excerpt, not from pe

an opinion piece. 

Letter 3- Exhibit A- Comment 57

- Trophic consequences of postfire logging in a wolf-ungulate system N-08.pdf 

N/A - No post-fire salvage logging is proposed 

Letter 3- Exhibit A- Comment 58

- Value In Old Growth Forests - carbon storage - 08.doc Newspaper article not peer reviewed science. 
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-191

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Letter 3- Exhibit A- Comment 59

- XXXS GR.doc An EIS should be prepared pursuant to NEPA

This document is about grazing allotment NEto the Cobbler project. 

Letter 3- Exhibit A- Comment 60

FIVE BUTTES APPEAL FILE 

N/A - No post-fire salvage logging is proposed N/A – Umatilla National Forest is not a spotteN/A – No specific comments made regarding 

Letter 3- Exhibit A- Comment 61

- Columbia Basin bird conservation plan.pdf N/A – plan refers to Columbia Basin 

Letter 3- Exhibit A- Comment 62

- east slope cascades bird concervation plan.pdf N/A – plan refers to east slope of cascades 

Letter 3- Exhibit A- Comment 63

- Oregon neotropical birds map pif.pdf 

NA – map of where breeding birds of Oregon (mainly Mexico). 

Letter 3- Exhibit A- Comment 64

Forest Restoration: Impacts of Logging – thinning and Roads on Hydrology and Resilience (adapted from a memo summary by Jon Rhodes, Hydrology) 

The title of this article is a duplicate of article 

above, however, the “adaptation” is slightly dcontent is similar; This adaptation from a mesentences and paragraphs from peer reviewed context and focuses on the potential for most omits discussions of effectiveness of best mandesign features, and potential benefits of cert
Cobbler II Timber Sale and Fuels Reduction Project FEIS 

G-192

Letter #3 – Exhibit A 

• This table shows a very brief listing of titles as listed in the enclosed CD. Documents in their entirety are located • This compilation of research, reports, case law, and conservation issues does not reference specific elements, sta

that are to be considered with this project. 

• Numerous references to post-fire logging were not considered because this project does not propose any post-fir• References that were opinion pieces and those referencing specific geographical areas were not considered. 

ASANTE RIVERWIND 

Representing: 

Oregon Chapter Sierra Club 

Hells Canyon Preservation Council 

League Of Wilderness Defenders-Blue Mountain Biodiversity Project 

Project uses BMPs (Appendix D) and design Table 2-6, pp. 2-21 to 2-28) to prevent damagfrom activities and uses specific mitigation merosion and sedimentation from work that wimuch needed drainage installation on FR 622routes inside RHCAs.