Hwy 46 FEIS Appendix 

374

Appendix J – Response to Comments on the Draft 

Environmental Impact Statement (DEIS)

Introduction

The Detroit Ranger District provided the public with a 45-day comment period for the Hwy 46 Project 

Draft Environmental Impact Statement (DEIS). The comment period began on October 20, 2017 and 

ended on December 4, 2017. Twenty-three letters were received from members of the public, federal 

officials, and public interest organizations.

Content Analysis

A standardized content analysis process was conducted to analyze the public letters received on the DEIS. 

Content analysis is designed to extract comments from each letter received, evaluate similar comments 

from different letters, and identify topics of concern. Additionally, content analysis ensures that every 

comment is considered fairly and accurately represents the breadth and depth of the public’s viewpoints. 

All letters and comments have been treated equally. They are not weighted by status of respondents or 

organizational affiliation and it does not matter if an idea was expressed by hundreds of people or a single 

person.

During the content analysis process, each letter was assigned a unique tracking number. Content analysts 

then read letters in their entirety and proceeded to identify discrete comments within them. Each letter 

may have contained anywhere from one to fifty comments. Each comment was coded based on a 

particular concern, resource consideration, or proposed management action expressed.

How to Use This Comment Response Document

While all comments were reviewed and considered, only specific written comments as identified in 36 

CFR 218.2 received a detailed response in the document below. Examples of specific written comments 

include those comments that provided new information; identified a new issue; identified a new way to 

meet the purpose and need; pointed out a flaw in the analysis; or identified a different source of credible 

research. General statements of support, opposition, or alternative preferences; comments outside the 

scope of the project; comments pertaining to issues already decided by law, regulation or policy; or 

comments already addressed in the draft Environmental Impact Statement (DEIS) are not included.

In some cases, comment may have been summarized or paraphrased and similar comments may have 

been grouped into public concern statements. Pages, chapter, or sections cited within the response to 

comments refer to the Hwy 46 Project Final Environmental Impact Statement (FEIS) unless otherwise 

noted.

A complete record of all letters, including names and addresses of individuals, agencies, and 

organizations that submitted a letter during the 45 day comment period, is available online in the Hwy 46 

EIS Public Reading Room at https://cara.ecosystemmanagement.org/Public//ReadingRoom?Project=47109 or in the project file located at the Detroit Ranger 

District. 
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Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Why did the FS move forward with the DEIS given 

that these fires have such an enormous impact on 

the entire purpose and need for this project? It is 

wildly inappropriate that the only opportunity the 

public will have to weigh in on the FS's analysis of 

this important fire will be in the administrative 

appeal stage. The FS could have simply waited a 

month to publish this DEIS. The fires are out now, 

please re submit for public comment the DEIS with 

the fire-analysis.

DEIS/ Public 

Involvement

We moved forward with the DEIS because initial 

review of the effects from the fires indicated that 

the fires did not meet the purpose and need of the 

Hwy 46 project. The fires burned a total of 2,921 

acres in the project area, but directly affecting 

only eight treatment units. The effects from the 

fires are fully analyzed in Chapter 3 of the FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

What the DEIS does not mention is that there has 

been a large fire in or adjacent to the project area. 

There has been associated management activities, 

commercial logging, fuels reduction, fire break 

creation that is not referenced in this DEIS. The FS 

needs to take a hard look at what the impacts of 

this recent fire, and whether or not this project is 

still needed.

For example, how much of the project area burned 

this past summer? How much early seral habitat

was created? Did any of these areas contain sugar 

pine? How much of the hazardous fuel reduction 

around Breitenbush was already conducted during 

the fire-logging activities?

Please inform us if any of the burned areas 

contained sugar pine because the need for any 

sugar restoration at all could have been taken care 

of by the burning this past summer.

The FEIS analyzes the effects from the 2017 fires 

in Chapter 3. 

RAVG satellite data was used combined with 

field reconnaissance to determine the burn 

severity in the project area. Areas identified as 

moderate or high severity were judged to have 

created early seral habitat. Based on this, 521 

acres of new early seral habitat was created in 

2017.

Several units with sugar pine shelterwood 

prescriptions did burn to various degrees. The fire 

was generally very low intensity in these units, 

mostly burning ground fuels with occasional 

torching of individual trees. These areas were 

visited by the District Silviculturist and were 

judged to still be in need of treatment. The vast 

majority of trees over 7” dbh will likely survive 

so the shelterwood cuts will still be necessary to 

establish sugar pine. The FEIS addresses the fires 

impact on these units. Within the hazardous fuels 

treatment units (units 170, 210, 270) 

approximately 10% of the work proposed in unit 

170 was accomplished during fire suppression 

activities utilizing a prescription similar to the one 

proposed in the DEIS. This work involved cutting 
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Commenter Comment Resource Topic Response

and chipping material under 7” DBH or less, and 

no logging equipment was used inside these units. 

No work was conducted in units 210 or 270.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS does state that one purpose and need for the 

project is commercial logging to "supply a reliable 

supply of timber products." This is only applicable 

to the matrix lands within the project area, and the 

public is still not made aware of how much timber 

was commercially logged during the fire season. 

How many board feet, what age of trees, where 

was the logging located? Is there still a need to 

supply timber products after the logging associated 

with the fire for which no NEPA analysis was 

conducted. These are cumulative impacts that need 

to be considered, especially given the proximity 

and relative location to the project area.

Purpose and Need The Willamette National Forest Land and 

Resource Management Plan has a goal to produce 

an optimum and sustainable yield of timber, based 

on growth potential of the land which is 

compatible with multiple use objectives and 

meets environmental requirements for soil, water, 

air and wildlife habitat quality (USDA, 1990). 

This plan was amended by the Northwest Forest 

Plan in 1994 and recognized “the need for forest 

products from forest ecosystems is the need for a 

sustainable supply of timber and other forest 

products that will help maintain the stability of 

local and regional economies on a predictable and 

long-term basis” (pages 1 – 4). 

During the fire, some roads had a narrow strip 

(usually not more than 10 feet wide) of trees 

removed on one side to enhance the fire break 

created by the road. The stands from which these 

trees were taken were plantations, likely ranging 

in age from 30 to 50 years old. Log decks were 

created along the roads and sold as saw logs. The 

volume sold within the project area totaled 0.445 

million boardfeet. The location of these saw log 

decks were on the #810, #840, #850, and #870 

roads. Other smaller material decked in this area 

and others will either be sold as commercial 

firewood or made available to the public for 

personal use firewood. Although some of this 

fireline treatment did occur in Hwy 46 units in 

this area, the effect on vegetation within those 

units was minimal. Only trees immediately 

adjacent to the road were cut.
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Commenter Comment Resource Topic Response

Most of the higher intensity burns within the 

project area occurred away from open system 

roads. No salvage of fire killed trees has occurred 

within the project area.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

In numerous sections through the DEIS the FS 

limits operation activities to certain dates because 

of impacts to various species, impacts to 

recreation, impacts to the Breitenbush community.

These restrictions are never centralized in one 

place in the DEIS. Would the FS please put in one 

place what activities are permitted when, which 

would make monitoring of any logging operations 

feasible.

General Appendix I in the FEIS displays restrictions in 

each unit. 

The design elements for the project with specifics, 

including dates of operations or restrictions are

displayed in Table 13, FEIS page 45-60

Andy Geissler, 

AFRC

These "out of scope" issues do not result in 

development of alternatives. AFRC would like the 

Forest Service to disclose the scientific evidence 

that supported the notion that the deferral of fireregenerated stands warrants being a Key Issue

rather than an Out of Scope Issue, and thus, the 

development of alternative 3.

Issues As stated on page 30 in the DEIS a “key issue” 

represents an unresolved conflict associated with 

the proposed action. For this project harvest 

treatments in fire regenerated stands was 

determined to be a key issue because the 

“unresolved conflict” could not be resolved with 

mitigation or design elements and alternative 3 

was developed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We appreciate that the FS developed an alternative 

that omitted from treatment naturally fireregenerated stands from logging in Alternative 3. 

The DEIS notes that these stands are different than 

the plantations slotted for logging because they are 

older, have larger trees, have developing 

understories with a greater diversity of tree species. 

This gets to our request in the scoping comments to 

provide detailed information on the condition of 

each stand proposed for treatment. Essentially we 

wanted the FS to elaborate on the significant 

difference between the plantations in the project 

area and the fire-regenerated stands. However, the 

Alternatives As stated in the Draft Silviculture Prescriptions on 

pages 12-13 (posted on the project website):

Plantations are generally characterized by dense 

monocultures of Douglas-fir. 

Naturally regenerated stands are older than the 

plantations in this project, and tend to have larger 

trees. A few of these natural stands have relic 

older trees scattered within them that are remnants 

from before the fire that regenerated the stand. 

These stands are similar to the plantations in that 

there is high competition between the overstory 

trees and suppression in the regeneration.
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Commenter Comment Resource Topic Response

DEIS still largely lumps both of these areas 

together for analysis, simply noting that the stands 

are "similar" while proposing them for largely 

identical logging prescriptions. The public needs to 

be made aware of the significant difference of 

these forest types.

The tables included in the Draft Silviculture 

Prescriptions include individual unit information 

including Unit Current Conditions in table 11.

Andy Geissler, 

AFRC

We would recommend that the design feature focus 

on tree characteristics rather than DBH. In general, 

using DBH to describe silvicultural prescriptions 

runs the risk of prohibiting the harvest of the 

optimal tree to meet your desired end results in any 

given part of the treatment area.

Harvest 

prescription

The assumption that a legacy tree is a remnant 

from a previous stand is correct. The 30” dbh 

description for legacy trees was used to reduce 

ambiguity in interpretation of what a legacy tree 

is for this project. This diameter break was based 

on field observations and stand exam data 

collected for this project, it was never intended to 

be a default for all projects. During unit 

reconnaissance by the District Silviculturist, it 

was noted that all trees observed that were judged 

to be legacy trees were greater than 30” dbh. 

There were also no trees observed that would be 

designated for harvest in a DxD prescription that 

were over 30”. However, your comments are 

appreciated and a description of what a legacy 

tree is will be added to the prescription incase a 

situation arises that contradicts the 30” diameter 

limit.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia Wildlands and Oregon Wild urges the 

Forest Service to omit the proposed regeneration 

harvest designed to create artificial early seral 

forest. Mature forest conservation remains a much 

more important conservation priority than the 

creation of early seral forest. There is not really a 

shortage of early seral forest which is abundant on 

non-federal land. The sheer quantity of early seral 

on private lands partially compensates for the lack 

of habitat quality. Also, wildlife associated with 

early seral forest are not at risk. Those species 

Early Seral 

Habitat

As stated in the DEIS, historic amounts of early 

seral for the Breitenbush watershed were 

estimated to be 9% of the area. In 2013, analysis 

by Helmig and Kurtis indicated that the watershed 

had 4% of its acreage in an early seral stage. 

Using RAVG satellite data, it is estimated that the 

2017 wildfires contributed an additional 1.6% of 

the area in moderate to high intensity fire which 

will develop into early seral. The only non-federal 

land within the watershed is a hot springs resort, 

and does not contribute to early seral habitat. The 
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Commenter Comment Resource Topic Response

generally tend to be mobile, generalists and 

opportunistic.

intent for this project is overall watershed health. 

Both early and late seral are an important part of a 

healthy, functioning watershed. As stated in the 

DEIS, increasing both early and later seral stages 

is an important focus of the project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

At a regional scale there is no shortage of early 

seral forest. In fact, there's already too much early 

seral in Oregon. Janet Ohmann. Trends in Early 

Seral Forest at the Stand and Landscape Scale. 

http://www.slideshare.net/ecoshare/janet-lohmann-trends-in-early-seral- forest-at-the-standand-landscape-scale. (Slides 12, 29 show there is 

"no shortage of early seral" in Coastal Oregon, and 

early seral "exceeds the HRV" [historic range of 

variability].)

Please address these conflicting scientific opinions 

and studies on the overall abundance of early seral 

habitat in the DEIS.

Early Seral 

Habitat

The scale of a landscape is relative to the metric 

being studied. For the purposes of early seral 

habitat for this project, the landscape scale is the 

5th field watershed. The overall health of the 

Breitenbush Drainage is the focus of this project. 

Analyzing at the State wide scale is beyond the 

scope of this project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Efforts to artificially enhance or create early seral 

habitat and introduce sugar pine should recognize 

that climate change might take care of this for us, 

and in fact might make it much harder to hang on 

to the mature forests we have. "Ecologically, 

increased distribution and frequency of 

disturbances may result in increased distribution 

and dominance of early successional ecosystems 

dominated by fire adapted species..." Lemieux, 

Christopher J., Daniel J. Scott, Rob G. Davis and 

Paul A. Gray. 2008. Changing Climate, 

Challenging Choices: Ontario Parks and Climate 

Change Adaptation. University of Waterloo,

Department of Geography: Waterloo, 

Ontario...Conversely, it may become harder to 

maintain existing late-seral ecosystems and 

species, so existing late-successional old-growth 

Early Seral 

Habitat /Sugar 

Pine

The article cited was based on climate change in 

Ontario, Canada, which is in a completely 

different part of the continent and has a different 

weather pattern and completely different 

vegetation than the project area and therefore is 

not relevant to this EIS. A search of the cited 

literature did not reveal the quotation given, nor 

was any discussion of early seral habitat or sugar 

pine found. Having a healthy stand of sugar pine 

in the watershed to continue healthy, mature 

conifer coverage in climate change may be very 

critical to watershed stability in this area.
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Commenter Comment Resource Topic Response

forests should be retained in order to avoid making 

the LSOG shortage worse.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Please provide an estimate (and the scientific 

support/data for this estimation) of the amount of 

early-seral forest that existed in the Hwy 46 project 

area.

Early Seral 

Habitat

This information was provided in the Vegetation 

section (Chapter 3.1) of the FEIS. The estimate 

was 9% of the Breitenbush watershed was early 

seral habitat historically and the document cited is 

Helmig and Kurtis, 2013, which is an unpublished 

paper available in the project record.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Also given that it is recognized that private timber 

lands and small-scale agricultural lands can 

provide early-seral habitat for species like deer and 

elk, please quantify the amount of early-seral 

habitat being provided in the project area and 

watershed by these types of operations.

Early Seral 

Habitat

This information is provided in the FEIS (Chapter 

3). There is no private timber land within the 

project area to provide early seral habitat.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Also in the FEIS, please analyze the amount of 

early seral anticipated to be created in the Pacific 

Northwest and the project area from fire. This is 

especially significant here given the ongoing fire at 

the time this DEIS was published.

Early Seral 

Habitat

The amount of early seral created by the 2017 

wildfires is discussed in the FEIS. Analyzing 

projected early seral outside of the project area is 

beyond the scope of this project.

Nick Cady for 

Cascadia 

Wildlands, 

If the Forest Service does decide to proceed in 

these areas, it should develop an alternative with 

very low diameter limits on the tree felling and 

Sugar Pine 

Restoration

Using a diameter limit to select trees for harvest is 

a viable alternative for a “thin from below” 

prescription in some situations, however at least 
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Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

limiting the logging to hand felling and leaving the 

felled trees in place to contribute to biological 

material for these areas. Again, focusing sugar pine

restoration in plantations where there will be 

greater canopy openings and access to sunlight 

would be a better area for these efforts.

two things are necessary to make this type of 

prescription effective: 1. The stand needs to be 

fairly uniform in size distribution across the area 

to be treated, and 2. very thorough data needs to 

be collected to ensure that the diameter break 

selected will yield the desired results. Most of the 

stands selected are either variable across the stand 

or have a structure in which cutting only the 

smaller trees will not provide enough reduction in 

tree competition to allow sugar pine to establish 

successfully. In addition, the amount of data 

collection required to comfortably determine what 

the diameter limit would be is not available for 

most of the units.

Considering the steep terrain in which the sugar 

pine units are located, hand felling will likely be 

the only option.

Commercial logging provides the mechanism that 

allows for the treatment of these stands. Funds are 

not currently available to pay for a service 

contract to fall the trees without the money 

generated by commercial harvest. If all the trees 

were felled and left on site, it would create a 

significant fuel buildup and hinder the planting of 

sugar pine and other species. If a fire were to 

become established within the next several years, 

the resulting high intensity burn would kill most 

of the trees in the stand, including the sugar pine. 

This past summer fire did enter unit 83, which has 

more sugar pine in it than any other unit in the 

project. The lack of fuel on the forest floor 

resulted in a cool burn in much of the unit, 

allowing most of the trees to survive. Treatment 

will still be needed in this unit to establish a new 

cohort of sugar pine.
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Commenter Comment Resource Topic Response

The selection of units for sugar pine restoration 

was primarily based on evidence of sugar pine 

existence (either past or present) in the stand, or 

based on close proximity to stands with sugar 

pine with similar elevation and aspect. Unit 33 is 

a plantation that met the proximity, elevation, and 

aspect elements and is having sugar pine planted 

in it.

Karen Sjogren According to the table, the objective of restoring 

Sugar Pine's is met not only by the shelterwood 

cut, but also by an undisclosed acreage of thinning, 

gap creation, and dominant trait release. Page 76 of 

the "Forest Vegetation" section states that a total of 

94 acres will be treated, equivalent to the 

Shelterwood acreage in table 3. Please clarify.

There is some confusion as to the total acreage 

involved, which I think is over 94 acres since some 

sugar pine will be planted in the gaps. Please 

clarify. Again, the photographs (Fig 17) are 

convincing but there needed to be more 

information on the success (?) of the 2003 project.

Sugar Pine In Hwy 46, the acres listed as Sugar Pine 

Shelterwoods are the acres intended for sugar pine

restoration. In these stands, the overstory is being 

modified to create the best possible conditions for 

sugar pine seedling establishment. In other units 

that have gaps created for wildlife, sugar pine 

may also be planted with other species, although 

conditions may not be ideal for their 

establishment. Since the underlying purpose of 

these gaps is not for sugar pine restoration, they 

were not labeled as such. If the sugar pine 

becomes established in these areas, it will be 

considered a secondary benefit.

Karen Sjogren Although sugar pine restoration is a very small part 

of this project, alternative 2 does remove a fair 

volume of timber. The justification for this should 

have included an analysis of the somewhat similar 

2003 Sugar Pine Project, which involved treating 

187 acres of existing sugar pine by heavily 

thinning a 30' radius around them. As I asked in 

my scoping comments (first paragraph), how 

successful was this project in promoting the health 

and growth of those stands of sugar pine? Did it 

make them more fire resistant? This would seem 

particularly relevant since those stands are close to 

those proposed for treatment in the highway 46 

project.

Sugar Pine Although both the shelterwood prescriptions in 

this project and the prescriptions in the 2003 

project are both designed to improve sugar pine, 

there are some key differences in the objectives of 

both projects. The prior project involved thinning

around existing sugar pine, sometimes referred to 

as “daylighting”. As sugar pine grow older they 

become less tolerant of competition from 

neighboring trees, which can ultimately lead to 

their demise either from fire, insects, or lack of 

sunlight. The prior treatments addressed that issue 

and were designed to retain the sugar pine already 

established there. These treatments were 

appropriate for that area because there were a 
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Commenter Comment Resource Topic Response

fairly high number of sugar pine in the stands that 

were treated. 

The units proposed for treatment in the Hwy 46 

project do not have the high stocking of sugar

pine that the previous projects stands did. Several 

of the stands do not have any sugar pine currently 

in them. The goal of these prescriptions, in which 

planting of rust resistant sugar pine is an integral 

part, is to restore the species to areas that they are 

either fading from or have already disappeared. It 

does appear that at least one stand in the 2003 

project had a similar prescription, and there is a 

picture of that stand in the FEIS. There are some 

sugar pine seedlings beginning to establish in that 

stand, either from planting or naturally 

regenerated.

As to the fire resistance of the previously treated 

stands, it is difficult to say if the sugar pine would 

survive fire in those stands, there are many factors 

to consider. The most important one is the 

intensity of the fire. If weather and fuel conditions 

support a running crown fire to enter the stand, a 

daylighting treatment would do little to save the 

trees. However, the thinning of the stand around 

the sugar pine, such as with the shelterwoods 

proposed in this project, as well as reductions of 

the slash through prescribed burning, greatly 

reduce the likelihood of such a fire taking place 

there.

Karen Sjogren Will the sugar pine planted be resistant to the bark 

beetles that killed off mature trees in the 1980's?

Sugar Pine Sugar pine have two primary threats, whitepine 

blister rust and bark beetles. There are no 

genetically bark beetle resistant sugar pine that we 

are currently aware of. There is genetically rust 

resistant sugar pine, however, and that is what 

will be planted as part of this project. The best 
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Commenter Comment Resource Topic Response

defense for bark beetles is to have healthy, 

vigorous trees. The shelterwoods prescribed will 

reduce inter-tree competition for the sugar pine 

and should increase their resistance to bark 

beetles.

Karen Sjogren Tables 6 and 8 summarize the forest age classes for 

each alternative, and address the concerns of many 

that older stands will be targeted. These tables are a 

good idea, but either some of the figures are 

incorrect or there needed to be an explanation how 

they were arrived at.

Stand ages Stand ages were determined by individual tree 

ages collected with an increment corer during 

stand exam.

Steve Sheehy Oregon's old growth forests need to be protected 

not logged

Stand age No old growth stands are being proposed for 

harvesting in any alternative of this projects. 

Hazardous fuels activities in units 170 and 270 

around the Breitenbush property will be limited to 

cutting brush and thinning trees less than 7 inches 

dbh.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The agency must protect mature forests because 

they are the best candidates to grow and develop 

into old-growth habitat in the shortest time frame

Stand age Some of the mature stands in the project area are 

experiencing competition due to high tree 

densities. Thinning treatments in these stands are 

designed to increase tree growth and accelerate 

species diversity in the mid-story, ultimately 

moving those stands to an old-growth structure in 

a shorter time frame than if left in their current 

condition.

Early seral habitat creation in some of these 

stands increases structural diversity at the 

landscape level, creating habitat for a wider 

variety of plant and animal species and replicating 

natural processes, such as fire, that shaped the 

landscape historically.

Daphne Stone with global warming, we need to do everything 

possible to keep the forests cool so that all forest 

organisms survive this gradual but drastic change

Stand condition The long term effects of climate change in the 

Pacific Northwest are uncertain at this time. One 

of the best ways to make our forests more resilient 

to changes is to reduce stress on the trees. Trees 
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Commenter Comment Resource Topic Response

that are experiencing less competition from other 

trees have more access to water, light, and 

nutrients and will have more resources available 

to them to cope with the possible effects of 

climate change such as drought and insects. 

Thinned stands are also more resistant to stand 

replacing fire. Treatments prescribed for this 

project, including the thinning of dense stands of 

trees, will improve forest health and resiliency to 

the possible effects of climate change in the 

future.

Andy Geissler, 

AFRC

The Highway 46 EIS indicates that 877 acres of 

potential treatment units will be "skipped" and 260 

acres will be treated to result in openings (regen 

harvest, GTRs, gaps). While this level of openings 

exceeds most Forest Service vegetation 

management projects that we review, we still 

would like to see the District strive toward a better 

balance on future projects than 877:260. With that 

said, we urge the District to at least implement 

those openings analyzed in the proposed alternative 

of the EIS

Skips Virtually all of the skips within proposed units are 

due to protection buffers for riparian areas, special 

habitat areas, or areas within the unit that do not 

need silvicultural treatment due to low stocking or 

tree size. The initial location of the proposed units 

are generally determined by the boundary of past 

harvest units, the buffer locations determined later 

which ultimately define the amount of unit 

acreage in skips. In stands where skips are 

required due to Forest Plan direction, additional 

skip acres are added if these defined skips do not 

adequately provide the required amount. This was 

only required for about four units in this project.

Linda Cummens If the use of trees were done in a sustainable 

habitat method Oregon wouldn't have groups of 

mountains stripped illegally beyond the sight of 

most citizens to unproductive dirt.

Clear cutting this area specified for a National 

Monument will turn it and a beautiful part of this 

state that earns much more through tourist 

activities into an ugly place with polluted water all 

living creatures drink.

As stated in Appendix B of the FEIS, this project 

proposes to thin approximately 2,500 acres of 

plantations and fire regenerated stands that are 

overstocked, leaving 40 – 100 trees per acre. 

Early seral units and wildlife gaps, amounting to 

93 acres, will have 7 to 8 trees per acre left in 

them and will be planted with seedlings to a 

stocking level of 150 -200 trees per acre. Native 

grasses will also be planted in these units as 

forage for big game. “No harvest” buffers will 

protect all streams and riparian areas. All 
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Commenter Comment Resource Topic Response

prescriptions are in alignment with the Willamette 

Forest Plan and the Northwest Forest Plan

direction of sustainable forestry. Historic amounts 

of early seral in the Breitenbush Watershed were 

measured at 9% of the watershed. Even with the 

new early seral created by the 2017 fires, early 

seral in the watershed is currently only at 5.6% of 

the watershed. One of the goals of this project 

was to create more quality early seral, but in 

looking for areas where plant associations would 

create true quality early seral, no additional 

opportunities were found.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Additionally in the FEIS, please take into account 

the episodic nature of fires and the natural creation 

of early seral habitat. Areas the size of this project 

area could go without large-scale stand replacing 

fires for extended periods. The current condition of 

forests in the project area may therefore be within 

the historic range of variability. Looking at larger 

scales, there are very large fires not far away from 

this project area (such as the B&B fire, and all the 

Sisters District fires) where early seral habitat is 

abundant. The project area is potentially between 

fire cycles right now, but future fire can be 

expected to create abundant early seral habitat in 

time.

Fire Fire return intervals within the western Cascades 

and the Hwy 46 planning area are indeed highly 

variable. The project only proposes a 0.3% 

increase in early seral creation within the planning 

area. This combined with the early seral created 

by the 2017 fires and that already present would 

only create approximately one third of the early 

seral that is believed to be within the historic 

range of variability, allowing for future fire 

disturbance to add to that number and still be 

within the historic range.

Freres Freres requests prebunching in skyline units be 

allowed at purchaser’s discretion

Soils Each unit was studied (field surveyed) for terrain 

suitability (i.e. unstable ground, etc.) and 

accessibility, those site conditions and slopes 

determined that at least 51 units were not feasible 

for pre-bunching operations. Pre-bunching will be 

allowed in the units where the terrain is suitable.

Nick Cady for 

Cascadia 

Wildlands, 

Our organizations prefer that there is no 

commercial logging in riparian reserves, and no 

tree removal in these areas. Even when these areas 

Riparian 

Reserves

Regarding the first comment that further tree 

removal will exacerbate problems of nutrient 

depletion in Riparian Reserves, the belief that 
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Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

have been logged in the past, we believe these 

areas are suffering from the previous removal of 

biological material that leads to depletion in 

nutrients that would have recruited from natural 

mortality. Further tree removal will acerbate these 

problems, and again that the benefits from 

increased openings do not outweigh the costs will 

removal, and that these openings will naturally 

occur over time with natural mortality. Alternative 

3 reduces by a couple hundred acres the proposed 

riparian logging acreage, but there is no Alterative 

that omits Riparian logging or restricts riparian 

logging to an alternative that contains all noncommercial logging with all trees felled remaining 

in place. Additionally, the only riparian reserve 

areas that should be targeted, should be formerly 

logged second growth, not naturally regenerating 

areas.

these areas are already suffering from nutrient 

depletion is not based on any existing local data 

or conditions. As stated in the FEIS, p 304, the 

DECAID analysis of downed logs and snags on 

the watershed scale documents that the 

“abundance of downed logs currently is similar to 

what was historically present within the 

Breitenbush River watershed.” Project design 

features minimize additional loss of downed

wood: All existing down wood will be retained 

within Riparian Reserves to maintain aquatic 

objectives” (FEIS, p. 58).

The commenter states that the openings created 

do not outweigh the costs. The FS recognized that 

there are tradeoffs. DEIS on page 115: “In some 

cases, maintaining and/or restoring each one of 

the ACS Objectives can be a balancing act with 

trade-offs. For example, to meet the riparian 

vegetation objectives (“species composition and 

structural diversity of plant communities” and 

“habitat to support well distributed populations of 

native plant, invertebrate and vertebrate riparian 

dependent species”) in young, dense conifer 

stands, a common silvicultural tool is to remove 

overstory density to encourage understory growth 

and structural development. Removal of overstory 

density, however, could potentially lead to 

increased thermal loading or reduction of wood 

volume available for recruitment. Because of 

these trade-offs, we carefully balance conflicting 

objectives based on characteristics of each 

waterbody and adjacent riparian area.” 

Regarding the comment that these openings will 

occur on their own naturally over time, the FS 

recognizes this on page 125 of the FEIS: “Desired 
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Commenter Comment Resource Topic Response

riparian conditions – high species and structural 

diversity with large dead and down wood – would 

slowly develop over time (several decades) and 

depend solely on natural thinning events (stem 

exclusion mortality and disturbance). Without 

management to increase the abundance of 

deciduous and herbaceous vegetation in dense, 

conifer-dominant stands, ecosystem productivity 

would remain at relatively low levels.” 

Deciduous leaves along stream channels are a 

critical component to adding nutrients to these 

systems.

Alternative 3 addresses the 4th comment that 

recommended “the only riparian reserve areas that 

should be targeted, should be formerly logged 

second growth, not naturally regenerating areas”. 

In regards to the comment that [there is no 

Alterative that]. . . restricts riparian logging to an 

alternative that contains all non-commercial 

logging with all trees felled remaining in place,” 

the FS did not consider this as a viable treatment

on this scale.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia strongly objects to logging riparian 

reserve stands over 80 years old. There is just no 

need. The superficial resemblance to younger 

stands is not a reason to log these older stands. At 

this age, stand growth has slowed and they need to 

hold onto their biomass and let it begin 

accumulating in live and dead pools.

Riparian 

Reserves

In line with the Aquatic Conservation Strategy, 

the Forest Service’s goal is to improve riparian 

conditions on a watershed scale. In the Purpose 

and Need, we state (FEIS, p18): Maintain 

conditions in currently functioning portions of 

Riparian Reserves. In overstocked, coniferdominant portions lacking structural and species 

diversity, attain Aquatic Conservation Strategy 

Objectives. Regardless of their age, these stands 

are currently dense monocultures with very little 

structural or species diversity at present. 

In the Breitenbush Watershed, even-aged conifer 

dominated riparian stands are overrepresented and 
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Commenter Comment Resource Topic Response

diverse riparian communities are 

underrepresented. In the FEIS, p 113, we stated: 

“Within the scale of the Hwy 46 project area (Figure 35), approximately 91% of Riparian

Reserves are conifer-dominant and less than 2% 

are deciduous-dominant (trees and shrubs) (Table 

26). Approximately 2.6% are mixed conifer and 

deciduous, which occur primarily in late-seral 

stands along the Breitenbush River. The results of 

this landscape-scale analysis reveal a very low 

abundance of deciduous species and are 

corroborated by surveys at the stand scale, where 

dense conifers dominate Riparian Reserves and 

there is often a lack of understory development 

and species diversity.”

In the FEIS, p 115, we further state: Of 1,458

acres of Riparian Reserve within the proposed 

(Alternative 2) units, 973 acres (68% have been 

harvested in the past, and are considered 

plantations. Approximately 462 acres (31%) are 

considered fire regenerated and have not been 

managed, though most of these are in similar 

condition to past regeneration harvested Riparian 

Reserves due to stand replacing fires around the 

turn of the century. Riparian stands proposed for 

commercial thinning treatment are a combination 

of plantations created after clear-cut harvesting 

and natural fire regenerated areas. All of the 

plantation stands and most of the older fire 

regenerated stands are considered to be in the 

stem exclusion structural stage. Riparian stands to 

be treated are considered to be in the stem-

exclusion stage.

Riparian stand conditions were individually 

assessed on a unit by unit basis with multiple 
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Commenter Comment Resource Topic Response

resource specialists to determine if treatment

would benefit or retard attainment of ACS 

objectives. Studies and forest stand classifications 

have shown that the maximum mean annual 

increment (an indication of tree growth) is 

achieved much later than 80 years in these types 

of stands (and soil type) (see Section 3.1). This 

suggests that in some stands, 80 years is an 

arbitrary threshold and that there is significant 

stand and structural resemblance to younger 

stands. Alternative 3 addresses the commenters 

concern that no riparian reserves over 80 years are 

logged.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia is concerned that a reduction in instream 

wood recruitment violates the "do not retard" 

standard of the Aquatic Conservation Strategy. 

Logging in the riparian reserves to create bigger 

trees faster which would then presumably fall in 

streams emphasizes only large wood recruitment 

instream while ignoring the equally important need 

for wood recruitment in the upland portion of the 

riparian reserves. We are also concerned the Forest 

Service will perpetuate the myth that thinning

enhances future wood recruitment, when in reality 

any increase in very large wood in the distant 

future comes that the expense of significant 

reduction in wood recruitment in functional sizes 

classes. Please take a hard look at these issues and 

trade-offs in the DEIS.

Aquatic 

Conservation 

Strategy

In regard to the first and second concern, we 

acknowledge in Section 3.3.4 that "in some cases, 

maintaining and/or restoring each one of the ACS 

Objectives can be a balancing act with trade-offs. 

For example, to meet the riparian vegetation 

objectives (“species composition and structural 

diversity of plant communities” and “habitat to 

support well distributed populations of native 

plant, invertebrate and vertebrate riparian 

dependent species”) in young, dense conifer 

stands, a common silvicultural tool is to remove 

overstory density to encourage understory growth 

and structural development. Removal of overstory 

density, however, could potentially lead to 

increased thermal loading or reduction of wood 

volume available for recruitment. Because of 

these trade-offs, conflicting objectives were 

carefully balanced based on characteristics of 

each waterbody and adjacent riparian area." 

(DEIS, p 125).

We have added language to the FEIS (Section 

3.3.4) addressing wood recruitment in the upland 
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Commenter Comment Resource Topic Response

portion of the Riparian Reserves and an analysis 

of the tradeoffs. 

In regard to the third concern, a hard look was 

taken and is discussed on page 149: “Current rates 

of large wood recruitment, provided mostly by 

stem mortality (from competition, disease, wind 

and snow downed trees) and bank erosion, would 

be maintained. Alternative 1 would provide a 

slightly higher rate of natural in-stream wood 

recruitment compared to the action alternatives. 

Where the action alternatives protect about 90% 

of the wood recruitment zones, the No-Action 

alternative would protect 100%. In some streams, 

recruitment trees are of sufficient size to meet 

ACS Objectives (Appendix E), but in other 

streams with small diameter riparian stands the 

aquatic benefit is limited, namely through the 

reduced ability to store sediment and organic 

matter and contribute to habitat forming processes 

(e.g. scour). Though small wood has some value, 

particularly in the smaller headwater reaches, the 

longevity of recruited small diameter trees is 

short-lived, as they break down through abrasion 

and decomposition more rapidly compared to 

large trees. Small diameter trees are also more 

likely to be transported out of the system. In-

stream wood abundance is low for most streams 

in the project area and is largely due to the lack of 

large enough wood to remain stable in channels.”

Additionally, as discussed on page 292,

“Densities in proposed unit Riparian Reserves

range from 75 to 397 TPA, averaging 200 TPA. 

In contrast, recent forest research in the Coast 

Range and Western Cascades indicates that 

existing old growth stands developed with natural 
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Commenter Comment Resource Topic Response

stand densities of 40 to 60 conifers per acre 

(Tappeiner et al 1997; Poage & Tappeiner 2002). 

As stated in the DEIS page71, thinning to 

densities of 40-100 TPA is prescribed, which are 

still greater than natural stand densities. 

Therefore, down wood resulting from continued 

stand development is expected to be considerably 

higher in these stands than typically found in 

naturally regenerated stands.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We suggest that any efforts to actively restore 

riparian forests for the benefit of certain species 

should be treated as scientific experiments and 

proceed cautiously, skeptically, and with robust 

pre- and post- treatment data collection efforts. 

Hypothesized effects of thinning on riparian forest 

structure and the use of that structure by targeted 

species should be tested against empirical data.

Riparian 

Thinning

No riparian thinning is being done for restoration 

of certain species, but rather as for restoration to 

increase structural and species diversity in the 

stands. The only proposed treatment that is 

targeting a certain species is the Sugar pine 

restoration and these treatment prescriptions are 

done in the uplands outside of Riparian reserves. 

The sugar pine units that also have Riparian 

Reserves would just have commercial thinning in 

the Riparian Reserves to improve stand and 

species diversity.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Density-dependent versus density-independent 

mechanisms. The agencies often emphasize that 

mortality is not a significant contributor to 

instream wood recruitment, implying that the effect 

of thinning on density dependent mortality may not 

be a big deal. However, the agencies also need to 

recognize that thinning in potential wood source 

areas significantly reduces the total amount of 

wood available for natural processes to act upon. 

Since natural disturbance occurs in both thinned 

and unthinned stands, the proper comparison is not 

between density-dependent versus densityindependent sources of dead wood, but rather the 

total recruitment of dead wood from all sources in 

thinned versus unthinned areas.

Riparian thinning In regards to the first statement, “The agencies 

often emphasize that mortality is not a significant 

contributor to instream wood recruitment, 

implying that the effect of thinning on density 

dependent mortality may not be a big deal”, in the 

FEIS on pages 124-125, the FS acknowledges that 

under no action, “Current rates of large wood 

recruitment, provided mostly by stem mortality, 

(from competition, disease, wind and snow 

downed trees) and bank erosion, would be 

maintained.” On page 128, we cite Benda and 

Bigelow’s 2014 study that “found that in managed 

forests of the Cascades Range, where bank 

erosion and tree mortality are the dominant wood 

recruitment processes, 90% of in-stream wood 
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Commenter Comment Resource Topic Response

originated from within about 8 meters (26 feet) of 

stream channels and the remaining 10% is 

supplied from a distance equivalent to one tree 

height.”

In regards to the second statement: “However, the 

agencies also need to recognize that thinning in 

potential wood source areas significantly reduces 

the total amount of wood available for natural 

processes to act upon”, the FS does recognize in 

the FEIS on pages 129-130 that thinning in 

potential wood source areas does reduce the total 

amount of wood available for natural processes to 

act on, especially in the intermediate-term. While 

these reductions in wood recruitment would occur 

in the individual unit level Riparian Reserves, the 

FS does not agree with the commenter that these 

reductions are “significant”, as the proposed 

treatment commercially thins only 2.5% of 

Riparian Reserves in the Breitenbush Watershed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We do appreciate that the Forest Service 

considered some "streamside fall and leave" 

treatments, DEIS at 44, but we are unclear on why 

these prescriptions were limited to the thin 60 foot 

no- harvest buffers. Trees outside of these buffers 

are going to be large enough to reach these streams 

and much of the science discussed above urges the 

retention of trees outside of these thin no-harvest 

buffers to benefit downed food in these riparian 

areas. We would like to see an explanation with 

scientific support of why the fall and leave strategy 

is not important outside of the 60-foot no harvest 

buffers selected by the FS in the FEIS.

Riparian reserves As stated in the DEIS on pages 78 and 103-106, 

the project area and Breitenbush watershed as a 

whole are deficient in hardwoods along streams. 

Hardwood foliage not only provide riparian 

diversity but important sources of nutrients and 

food sources to riparian and aquatic organisms. 

Management activities are designated to meet the 

ACS objectives on a watershed scale. It is clearly 

documented in the DEIS that riparian vegetation 

diversity is lacking on a watershed scale, in 

addition to a limited instream large-wood 

component. Increasing riparian diversity, 

specifically increasing the streamside hardwood 

component was the primary objective for these 

treatments with additional benefit of augmenting 

instream large wood component. On page 120 of 
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Commenter Comment Resource Topic Response

the DEIS, we detail how these areas selected for 

streamside treatment were carefully identified. 

While “fall and leave” treatments beyond the 

inner 60 feet no-harvest buffer would have 

additional benefits to increase upland course 

down woody debris in the Riparian Reserves, the 

watershed is currently within the range of natural 

variability for downed wood, so it was not 

targeted as a needed restorative treatment activity 

for Riparian Reserves in this project area. 

This further clarification has been provided in the 

FEIS as requested in Section 3.3.4. The FS does 

appreciate the commenter’s recognition of the 

benefits of the fall and leave treatments and will 

consider these treatments on greater scales in 

future planning areas.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS notes that both Alternatives will have 

negative impacts on stream flows in the project 

area. The chart on page 114 of the DEIS notes 

these negative riparian impacts associated with 

logging which is generally prohibited in the 

riparian areas. However, the Forest Service also 

states that these impacts "would be immeasurable 

and are therefore not anticipated to be adverse." Id. 

How are the effects immeasurable if on the 

following page the decrease in flows is measured? 

This is an ACS violation.

Riparian impacts As explained in Chapter 3, we use the Aggregate 

Recovery Percentage (ARP) model to analyze 

how the proposed alternatives will affect stream 

flows. Following the 2017 Whitewater fires, we 

re-ran the model due to changed watershed 

conditions. As we adjusted the model’s canopy 

cover inputs to reflect the changed post-fire 

conditions, we also discovered some other 

significant errors in the model’s inputs that was 

run for the DEIS. We corrected these inputs in the 

re-run of the model and as indicated in the FEIS, 

Chapter 3, resulting ARP values are and will 

remain well above the threshold for any of the 

alternatives with no impacts to stream flows 

expected. A full description of this correction and 

results is detailed in Attachment A of the FEIS 

Hydrology Specialist Report.

Karen Sjogren Prescribed burning 23% of the thinning acreage in 

Riparian Reserves strikes me as excessive for fire 

Riparian 

Reserves

Allowing fire to back down into Riparian 

Reserves would have less impact than alternative 
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Commenter Comment Resource Topic Response

which is only "backing into" the reserves. Is some 

of this acreage pile burning?

approaches, such as constructing hand-line around 

the entirety of the reserves or pile burning in 

treated areas in the reserves. In the FEIS, 23% 

represented an absolute maximum of potential 

Riparian Reserve acreages that could potentially 

be underburned. It does not represent pile burning 

acreage. It was calculated from the total acres of 

Riparian Reserves within any units that were 

proposed have underburning. A more realistic 

estimation acres of Riparian Reserves that would 

be underburned is to consider just the portions of 

units that would likely underburned (as opposed 

to the entire unit itself).

In response to this comment, the Fuels Specialist 

and Hydrologist reviewed all the proposed 

underburning units with Riparian Reserves and 

were able to provide a more realistic range of 

Riparian Reserve acres that might be impacted by 

underburning. Based on stand conditions and 

logistical needs, several units and many portions 

of units would not be underburned after all. Please 

see the FEIS, Chapter 3 for updated estimates to 

acreage of Riparian Reserve affected by 

underburning activities.

Pamela Lauer Please take into consideration that a diverse 

riparian zone creates a healthy watershed. A stand 

of only sugar pines, only douglas firs, only any one 

plant cannot adequately provide shelter, shade and 

resources for a thriving watershed.

Watershed 

management

We strongly agree with this statement. This is a 

key point about why these Riparian Reserves are 

proposed for treatment. On the watershed scale 

we are lacking diversity in our riparian areas. The 

riparian reserves proposed for treatment currently 

exhibit very low diversity in species and structure, 

essentially plantations at the present time. The 

goal of the proposed action in Riparian Reserves 

is to increase species and structural diversity in 

alignment with the ACS. Of the proposed units 

that have Sugar pine restoration, the Riparian 
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Commenter Comment Resource Topic Response

Reserve portions and other portions of those units 

have silvicultural prescriptions to increase species 

and stand diversity. Thinning will encourage more 

shade tolerant species such as western hemlock 

and western red cedar to grow into the mid-story, 

as well as allowing all trees to grow faster and 

produce larger snags in the future. As indicated on 

page 42 of the DEIS, zero acres of Riparian 

Reserve are proposed for Sugar Pine Restoration.

Daphne Stone Cutting forests, especially old forests, along 

riparian corridors significantly warms water in the 

streams. Right now we need to do everything we 

can to counter the warming and protect streams. 

Stream temperatures are critical for insects and fish 

in them

Stream 

temperatures

With the exception of the fall and leave treatment

streamside areas, there is no cutting of trees in the 

primary shade zone. Cutting in the secondary 

shade zone will not reduce canopy cover below 

40%. Based on the modeling in the Willamette 

TMDL (2012), this proposed treatment will not 

significantly increase stream temperature.

Karen Sjogren I know that recent fires were not reasonably 

foreseeable, but did they change any of the analysis 

in the Hydrology Section?

Hydrology / Fire 

impacts

Yes, the fire did change some existing conditions. 

Post-fire related updates to the FEIS include 

changes to Peak Flow analysis/ARP model inputs 

and results; riparian conditions, sediment delivery 

potential to streams, and suppression-line 

activities. Changes to the proposed action include 

decommissioning of additional road miles that 

were opened for the suppression activities and 

possible future changes to stream buffer widths/ 

Riparian Reserve Treatment in Unit 83. Please see 

the FEIS for more specifics.

Karen Sjogren The summaries is excellent. The first sentence, 

however, contradict the top of page 7, with respect 

to the effects of the project on UW ESU Spring 

Chinook salmon (I believe p.7 is incorrect) Why is 

Section 7 consultation with NOAA/NMFS so late? 

(May 2018)

Fisheries There was an error on Page 7. That error has been 

corrected. Section 7 consultation with NMFS is 

taking anywhere from 8-12 months. Consultation 

cannot begin until all of the design elements have 

been completed.

Karen Sjogren The wider buffers are still important to protect 

ESA listed fish, and these are detailed on p. 141. 

Fisheries There is no proposed under-burning within 172 

feet of any MIS/ESA fish bearing stream in the 
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Commenter Comment Resource Topic Response

The added commercial thinning n Alternative 2 is 

made more acceptable by the fact that this activity 

will not be allowed within 172' of ESA-listed fish 

habitat or the 20 units adjacent to streams with 

Management Indicator species. It is also important 

to me that no hazardous fuels treatments will occur 

within 172' of streams. Do these restrictions for 

MIS/ESA species apply to underburning/pile 

burning also?

Hwy 46 EIS. The Riparian Reserve Buffer widths 

along MIS/ESA fish bearing streams is 344’. 

Some underburning may occur (backing fire) in 

the outer portion of the Riparian Reserve (172-

344). Limited Pile burning may occur, outside 

100 feet, in ground based units near MIS/ESA 

streams.

Bill Richardson

for Rocky 

Mountain Elk

Foundation

For the past 16 years volunteers of the RMEF and 

Oregon Hunters Association, with support of the 

USFS, ODFW, BPA and PGE have developed and 

enhanced wildlife forage within the Highway 46 

Project area, primarily within the transmission line 

right of way. The purpose of the volunteer work is 

to compensate for the lack of early seral habitat

due to lack of active forest management. The 

volunteer work has been successful in making it 

possible for a remnant population of black-tailed 

deer and Roosevelt elk to persist within the project 

area.

Wildlife These projects have removed invasive plants in 

the powerline corridor and converted those areas 

to meadows and native shrub species. These areas 

have concentrations of deer and elk which have 

limited options for early seral forage in the rest of 

the project area. One of these areas is along the 

Northern boundary of Breitenbush Resort where 

deer and elk are regularly observed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Further, from an ecological perspective there is no 

such thing as too much wood. Cascadia believes 

that the current standards for snags and dead wood

were a product of political compromise and are 

biologically outdated. More dead wood is needed 

to meet a wider variety of life needs and more 

green trees are needed over time to recruit that 

dead wood. The Forest Service can't continue to 

manage against dead wood while its standards are 

known to be inadequate.

Dead wood Willamette National Forest standards and 

guidelines for dead wood and snags are being met 

in the planning area. In addition the most recent 

science is derived from the DECAID website and 

integrated into analysis for this project area.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

Cascadia Wildlands and Oregon Wild urges the 

Forest Service to omit the proposed regeneration 

harvest designed to create artificial early seral 

forest. Mature forest conservation remains a much 

Wildlife / Early 

Seral Habitat

Maintaining all ecosystems present at a landscape 

level is an important part of Forest Service 

direction. Early seral habitat is below historical 

levels in the Breitenbush watershed. The only 
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398

Commenter Comment Resource Topic Response

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

more important conservation priority than the 

creation of early seral forest. There is not really a 

shortage of early seral forest which is abundant on 

non-federal land. The sheer quantity of early seral 

on private lands partially compensates for the lack 

of habitat quality. Also, wildlife associated with 

early seral forest are not at risk. Those species 

generally tend to be mobile, generalists and 

opportunistic.

Also given that it is recognized that private timber 

lands and small-scale agricultural lands can 

provide early-seral habitat for species like deer and 

elk, please quantify the amount of early-seral 

habitat being provided in the project area and 

watershed by these types of operations. 

private land in the Watershed is the Breitenbush 

Resort which is not expected to be converted to 

early seral habitat’

Private timber land and agricultural lands are not 

present in the project area.

Karen Sjogren The author includes some existing early seral 

habitat in the Project Area not mentioned 

elsewhere in the text besides power lines- 2 acres 

of natural meadows and 30 acres of timber harvest 

less than 20 years ago (Table 19 gives this total as 

20 acres). Nonetheless, he makes the valid point 

that early seral habitat is a low (1.15%) percentage 

of the Project Area, compared to what it was 

historically (9%). The effects analysis for 

Alternative 2 is correct, adding meadow 

restoration, quality early habitat and wildlife gaps

to arrive at about 99 acres, an increase of .31% in 

this habitat type for a total of 1.46%. However, for 

Alternative 3, the combination of early seral habitat 

creation (16 acres) and gaps (34.8) is 51 acres, not 

44. This is a .16% increase, bringing the total to 

1.31% early seral habitat. The summary figures 

should also be changed to 1.31% and 413 acres.

Wildlife / Early 

Seral Habitat

Thank you for taking such a detailed look at the 

acres involved in this analysis. This can be a 

difficult process and errors can be made in 

updating numbers as the planning process evolves 

and changes are made to proposed actions. For 

alternative 3 the spreadsheet shows 16.0 acres of 

early seral and 28.8 acres of gaps for a total of 

44.8 acres. It seems the acres were underestimated 

by 0.8 acres. Then again that 0.8 acres is two gaps 

that are 0.5 and 0.3 acres so might not be large 

enough to count toward gap acres. This is why the 

term approximate is used. Since dominant tree 

release is difficult to evaluate, acreage is often 

slightly overestimated to ensure enough acres are 

included to cover variance in prescriptions.
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Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands,

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS states that the early-seral habitat creation 

through clearcutting will benefit the western 

bumblebee. Is there any science to demonstrate that 

western bumblbees thrive is post- logging earlyseral environments? We are curious about how this 

species fares in newly creation plantations and 

whether the application of herbicides influences the 

successful entry or re-entry of this species into 

logged and sprayed areas. Is the FS spraying the 

early-seral areas? Will this impact the bee? Do 

complex early-seral habitats benefit the species 

more than clearcut? The DEIS states that there are 

no western bumblebees in the project area, how 

will this early seral habitat benefit them if they are 

not present? How close is the nearest documented 

population? Please address these questions in the 

FEIS or the republished DEIS.

Western Bumble 

Bee

Western bumblebees have experienced declines in 

populations for unknown reasons. Providing 

flowering plant habitat as an ecosystem which 

western bumblebees could utilize is one benefit of 

maintaining early seral habitat areas. Historically 

western bumblebees were documented along the 

powerline in the analysis area, although none 

were located during surveys related to the Hwy 46 

project.

Herbicide use is not proposed in the Hwy 46 

project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

In the FEIS, please include any data or studies that 

look at spotted owl recolonization or use of thinned 

stands (pre and post logging activities). We are 

concerned that there are short- term impacts 

associated with commercial logging that will 

displace spotted owls or interrupt essential 

behavioral activities. It be useful to see information 

on how quickly spotted owls re- inhabit thinned 

stands or if young stands that were thinned were 

later recolonized by the species.

Northern Spotted 

Owl

The thinning proposed in this project would not 

displace NSO or disrupt their essential behavioral 

activities. Because there would be no 

displacement, time for recolonization is not an 

issue. “The Biological Assessment for Willamette 

Planning Province of Oregon for FY 2018 LAA 

Projects Within the Willamette National Forest 

With a Potential to Modify Habitat and/or Disrupt 

Northern Spotted Owls” discusses these issues on 

page 38-40 and provides references. Other 

literature citations are located on Pages 111-116. 

These citations includes studies of prey species 

and of NSO habitat use patterns. One reference on 

page 115 discusses your concerns – USFWS (U.S. 

Fish and Wildlife Service). 2007. Draft: What are 

the Effects of Habitat Thinning on Northern 

Spotted Owls?
Hwy 46 FEIS Appendix 

400

Commenter Comment Resource Topic Response

Adverse effects of disturbance to NSO would be 

avoided in this project. Extensive surveys were 

conducted and where activity centers were located 

seasonal prohibitions on project activities are in 

place to avoid disruption of NSO ‘essential 

behavioral activities’.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

the DEIS fails to take a hard look at numerous 

elements of this issue, including the invasion of the 

barred owl, cumulative impacts of past/ongoing 

logging associated with the fire season, and the 

impact of thinning on owl prey species. Barred 

owls are simply not mentioned, this is 

inappropriate. If barred owls are in the project area, 

this is significant as the species displaces the 

spotted owl. If the proposed logging has an impact 

on the spotted owl, even a very short term impact 

(temporary displacement), this could create an 

opening for the barred owls to move into these 

areas and further contribute to the spotted owl's 

decline. We discussed the barred owl concerns in 

our scoping comments, please ensure this issue is 

addressed in the FEIS.

Northern Spotted 

Owl

This comment is more related to the consultation 

process and recovery plan objectives for NSO at a 

region wide perspective. Consultation documents 

and specifically Biological Opinion 01EOFWOO2017-F-0555 contains discussions related to 

barred owls and other factors affecting the long 

term viability of the NSO. Barred owls are present 

throughout the range of the NSO. Barred owls are 

mentioned and discussed in FEIS section 3.6.4 

Affected Environment – Northern Spotted Owl.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Regarding prey species, the DEIS simply 

concludes: "Variable density thinning adds 

diversity to the stands which also benefits owls by 

providing more diverse habitats for prey species." 

But in previous FS projects and BLM projects, 

commercial thinning has been acknowledged to 

have short-term impacts on prey species, and cause 

temporary displacement and potentially affect 

recolonization of the logged areas. This is 

significant and needs to be discussed.

Northern Spotted 

Owl

Each agency has projects in different areas and 

habitat types which can have different impacts on 

prey species. The term recolonization infers 

removal of NSO as a result of treatments which is 

not expected to occur with the protection 

measures integrated into project design and 

seasonal prohibitions on potentially disruptive 

activities.

The ‘Biological Assessment For Willamette 

Planning Province of Oregon for FY 2018 LAA 

Projects Within the Willamette National Forest 

With a Potential to Modify Habitat and/or Disrupt 

Northern Spotted Owls’ includes Hwy46. This 
Hwy 46 FEIS Appendix 

401

Commenter Comment Resource Topic Response

document was not available at the time the draft 

EIS was submitted for comments. This B.A. 

discusses specific prey species and provides 

references to papers which address impacts to 

Spotted Owl prey species on pages 38-40.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

This section in the DEIS is scant absent a 

Biological Assessment from Fish and Wildlife 

Service. Are these stands RA 32? Were RA 32 

stands logged in this year's fire season? Were owl 

activity sites impacted by the logging this past fire 

season? 

Northern Spotted 

Owl

The DEIS was published prior to the results of 

consultation being available. The biological 

evaluation and biological assessment from the 

USFS and biological opinion from the USFWS 

are now available for review. While logging did 

not occur during the 2017 fire season in the 

project area, suppression activities did result in 

log decks that were sold. The contingency fire 

line south of the Breitenbush community between 

Devil’s Creek and the South Fork of the 

Breitenbush River is located in RA 32, however, 

all cut material was left in the forest. The fire line 

constructed in this area was a hand line 

constructed by hand using existing user trails in 

order to minimize impacts on RA-32. Dead snags

that were safety hazards for firefighters were cut 

but most cutting was small brush and trees less 

than 7 inches. No large live trees were cut in the 

construction of this fire line. No commercial 

timber was cut in this area so there was none to 

sell as part of the log deck sale. The only 

commercial timber that was cut was the result of 

mastication work along roads that were being 

fortified as fire lines.

Karen Sjogren The effects analysis for the action alternatives was 

difficult to understand and I have struggled to 

come up with the author's figures. It may have been 

helpful to present the data in tabular form. For 

Alternative 2, using the author's own figures, I 

come up with 143 acres of suitable habitat removed 

Northern Spotted 

Owl

Habitat acres degraded remain in the habitat 

category they were in prior to project activities 

occurring. For suitable habitat removed 

approximately 20 acres is in gaps, 80 acres in 

sugar pine restoration, 35 acres in early seral and 

2 acres in road relocation. The 2 acres in road 
Hwy 46 FEIS Appendix 

402

Commenter Comment Resource Topic Response

(this includes the 6 acres downgraded to dispersal) 

and 84 acres of dispersal (this includes adding in 

the 6 acres downgraded from suitable). I assume 

that the 33 acres of "degraded" dispersal habitat 

would no longer function as such.

relocation were incorrectly listed as foraging 

habitat removed, the correct term should have 

been suitable habitat removed. For dispersal 

habitat approximately 28 acres will be removed in 

gaps, 10 acres in sugar pine restoration and 19 

acres in early seral. Total acres of approximately 

137 acres of suitable removed and approximately 

57 acres of dispersal removed have been revised 

in the final EIS. In habitat effects analysis, 

degraded means the habitat remains the same type 

of habitat after treatment. Downgrade means 

habitat was altered and reduced in quality, such as 

suitable to dispersal habitat or dispersal to nonhabitat.

Karen Sjogren Critical Habitat appears to be a very large subset of 

total suitable and dispersal habitat in the project 

area, at least for the thinning units and gaps. 

However, for dominant tree release 11 acres of 

suitable habitat and 55 acres of dispersal habitat is 

degraded, which is greater than the total figures 

degraded for this activity in the Project Area (6 & 

33, respectively, p.148, bottom). How can this be 

so? Also, meadow restoration is put in here as a 

factor reducing habitat along with early habitat 

creation, which is not mentioned for total habitat 

modification in the previous section. Please 

explain. I can accept that the effects on Critical 

Habitat are only slightly less than for project 

habitat overall, but the figures in this section need 

to be redone.

Northern Spotted 

Owl

You are correct. The numbers have been 

recalculated. There are 9.75 acres of suitable and 

60.5 acres of dispersal habitat listed under 

dominant tree release. Dominant tree release in 

CHU is 9.75 acres of suitable and 51 acres of 

dispersal habitat.

Karen Sjogren In the LSR's, the only prescribed treatment is 

thinning 808 acres in dense plantations under 80 

years old (p. 79). Thus, I was surprised that three 

acres of suitable habitat would be thinned in the 

Northern Spotted 

Owl 

This results from the owl habitat mapping not 

matching the silvicultural stand mapping. In 

reality when units are marked on the ground these 

stand edges are obvious and older suitable habitat 
Hwy 46 FEIS Appendix 

403

Commenter Comment Resource Topic Response

LSRs. Where are they? If dispersal habitat is 

"degraded", isn't it essentially removed?

is not included in the thinning unit. Dispersal 

habitat degraded remains dispersal habitat.

Karen Sjogren The dispersal figures for dominant tree release (59 

acres "down-graded) for Alternative 3 cannot be 

correct because they exceed the total acreage for 

this activity (58.25 acres). Also, if dispersal habitat 

is downgraded, it is lost as such; this was true in 

Alternative 2 calculations for the 33 acres lost to 

dominant tree release. It also does not make sense 

for this figure to exceed Alternative 2, which 

begins with a larger figure (72.75 acres) to begin 

with. 

For Critical Habitat lost/modified under 

Alternative 3, t number of dispersal acres 

"degraded" by DTR (i.e., lost) is still suspiciously 

large—45 acres, compared to 33 acres "degraded" 

under Alternative 2 for all owl habitat.

Northern Spotted 

Owl 

Dispersal habitat was degraded rather than downgraded and was presented as degraded. For 

alternative 2 the 33 acres of dispersal habitat 

degraded is approximately 60 acres plus 

approximately 10 acres of suitable habitat plus 

approximately 2.5 acres of non-habitat. For 

alternative 3 the 59 acres should be approximately 

61 acres.

Downgraded would be lost, degraded would 

remain the type of habitat it was before treatment.

Karen Sjogren For the LSRs, the figures should be exactly the 

same for both alternatives since only plantations 

are thinned or otherwise manipulated. However, 

the loss of dispersal acreage to DTR in Alternative 

3 is given as 32 acres rather than 2 (Alternative 2). 

The correct number is probably 2

Northern Spotted 

Owl

The numbers have been checked, alternative 3 has 

3.5 possible acres in two units and part of one unit 

is non-habitat. So rounding to a best estimate 

would yield 3 acres rather than the incorrect 32 

acres. The correct number for alternative 2 will be 

changed from 2 to 3 acres of DTR. 

Karen Sjogren If acreage "remains habitat", does that mean that 

habitat stays in the same category (suitable or 

dispersal)? 

Northern Spotted 

Owl

That is correct.

Freres Enclosed please review a study published in the 

journal Forest Ecology and Management which 

stated that cover in tall trees is the key habitat 

requirement for spotted owls not total canopy 

cover. It is also indicated that spotted owls largely 

avoid cover created by stands of shorter trees.

Northern Spotted 

Owl

Thank you for sharing the article.

Nick Cady for 

Cascadia 

Wildlands, 

The DEIS claims that deer and elk are struggling in 

the project area and that this is why additional 

clearcutting is needed. They base the struggling 

Big Game A purpose and need of the Hwy 46 project is to 

move stand structure from an overabundance of 

mid seral stands to increase both early and late 
Hwy 46 FEIS Appendix 

404

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

deer and elk status on "The current estimated elk 

population of about 3,000 for the Santiam WHU is 

well below the State Management Objective of 

5,200." Please analyze the basis for the State 

Management Objective, it is our understanding the 

these objectives are not based in any science but 

rather on numbers optimized to sell hunting tags. It 

is inappropriate for the FS to rely upon these 

artificial numbers. Please rely upon actual historic 

levels or drop this purported support for clearcut 

logging from the FEIS.

The FS includes in the DEIS a model to assess elk 

and deer foraging in the project area and concludes 

that these are poor foraging areas. However, the 

model assumes that Douglas fir/hemlock forests 

provide poor nutritional value for elk. The DEIS 

elsewhere states that the historical condition of 

these forests are fir/hemlock forests. Should the FS 

be altering the project area to provide more deer 

and elk habitat if this runs counter to the historical 

condition of these forests?

seral stand structure within the watershed. Early 

seral habitat creation will provide landscape 

heterogeneity and provide habitat for song birds, 

cavity nesters and pollinators, as well as 

providing benefits to big game species.

Karen Sjogren Elk and Deer. Even though these are indicator 

species, I felt that the DEIS spent a 

disproportionate time on them, especially since the 

effects of the project are negligible on their habitat. 

I agree with Cascadia Wildlands that the role of 

private lands in providing habitat for these species 

should be considered, as that's where I have most 

often seen them. It is true, however, that most 

hunting opportunities are on public land. Is less 

interest in hunting at all responsible for reduced 

harvest success? 

Big Game Private timber and agricultural land is not present 

in the analysis area. Your question about less 

interest in hunting possibly being responsible for 

reduced harvest success is an interesting one, and 

is beyond the scope of this project. Oregon 

Department of Fish and Wildlife maintains, on 

their website, statistics of hunter 

numbers/days/hunt types/etc. and success rates.

Karen Sjogren The "Affected Environment" description does a 

good job of describing how different forest types, 

stand stages, and hardwood component percentage 

Big Game The B&B fire created thousands of acres of early 

seral habitat on the Willamette N.F. most of it 

occurring at high elevations where forage 
Hwy 46 FEIS Appendix 

405

Commenter Comment Resource Topic Response

correlate to forage nutritional values for these 

species. The text and tables are also good in 

describing how poor forage acreage has increased, 

and good forage acreage declined, over the last 25 

years; the totals mask greater increases or 

decreases in individual BGEAs (p. 170). Will 

recent fires change the amount of acreage in these 

categories, as occurred, for example, as a result of 

the B & B fire in 2003? 

nutritional values are low. Recent fires in the 

analysis area are the Scorpion fire which resulted 

in approximately 16 acres of forest canopy being 

killed and the Little Devil fire which resulted in 

approximately 68 acres of forest canopy being 

killed. The Scorpion fire early seral habitat area 

would result in higher quality foraging habitat on 

16 acres. The Little Devil Fire was on a rocky 

ridgeline at higher elevation and would result in 

lower quality foraging habitat. Very little change 

resulted from 2017 fires in the analysis area. The 

Whitewater fire was mostly in the North Santiam 

watershed which is outside the analysis area. 

Some acres of this fire were in the Breitenbush 

watershed and outside the analysis area at high 

elevation and would not be higher quality 

foraging habitat. 

Karen Sjogren In the Effects Analysis, the author states (as he did 

in the Snags section) that the project will "remove" 

197 acres of forest, benefitting three of the above 

named species. I cannot come up with this figure 

from the tables, so please explain.

Meadow restoration 8 acres, early seral 45 acres, 

gaps 48 acres, sugar pine shelter wood 94 acres 

and road relocation 2 acres (total of 197 acres).

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS admits there is going to be snag loss 

associated with the proposed logging. Despite the 

fact that the models used by the FS show that the 

snag levels will remain above the minimum 

thresholds (although the DEIS does appear to 

disclose some recent science that went unnamed 

that invalidated these models, please elaborate in 

the FEIS), we believe that the further reduction of 

snags and habitat for cavity nesting species runs 

counter to recommendations and standards in the 

Forest Plan.

Snags The project analysis and recommendations are 

based on the best available science.

Nick Cady for 

Cascadia 

The Hwy 46 DEIS and Appendix F (DecAID) 

failed to compare the effects of logging versus not 

Snags The no action alternative, alternative 1, would be 

the condition if stand treatments were to not 
Hwy 46 FEIS Appendix 

406

Commenter Comment Resource Topic Response

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

logging on future recruitment of snags and dead 

wood. The Appendix compares current and 

reference conditions, but fails to product those 

numbers into the future as a result of logging 

versus no action.

occur. The results of treatments are discussed as 

alternatives 2 and 3.

Karen Sjogren Table 35 shows that all the planning subdrainages 

in the Project Area are currently meeting this 

requirement. Did the recent fires change these 

percentages in any of the listed subdrainages? 

Table 36 is a really nice comparison of how the 

two action alternatives would affect large snag 

density compared to the present conditions. What 

does FW-125 stand for?

Snags FW means a forest wide standard and guideline 

found in the Land and Resource Management 

Plan for the Willamette National Forest and FW125 is related to snags. An analysis of existing 

conditions was conducted after the fires which 

can be found in Appendix F DecAID Analysis. 

Basically very little changed. An analysis was 

completed for the areas where the canopy was 

visibly killed, determining that 16 acres in the 

Scorpion Fire and 68 acres in the Little Devil fire 

were killed.

Karen Sjogren In the effects analysis for snags, the author states 

that Alternative 2 proposes 197 acres of 

regeneration harvest. I have reviewed all the 

treatment prescriptions and can only come up with 

101 acres that qualify and therefore would require 

snag creation. Please clarify. The Alternative 3 

effects analysis also uses the figure of 197 acres of 

regeneration harvest, which is obviously incorrect. 

Please redo this section so the reader can 

understand where, why and to what degree 

additional snags and downed wood will be created 

as a mitigation/enhancement measure in this 

project. 

Snags Meadow restoration 8 acres, early seral 45 acres, 

gaps 48 acres and sugar pine shelter wood 94 

acres (total of 195 acres). And yes the alternative 

3 number is high and should be reduced to 54 

acres, early seral 16, gaps 29 and sugar pine 

shelter wood 9 acres.

Nick Cady for 

Cascadia 

Wildlands, 

The Forest Service cannot provide any assurance 

that its plans and projects will assure viable 

populations of native wildlife that depend on dead 

Management 

Indicator Species

This is analyzed and discussed in section 3.6.12,

Management Indicator Species.
Hwy 46 FEIS Appendix 

407

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

trees. The Forest Service does not know how many 

snags are necessary to support viable populations 

of cavity associated species. The Forest Service has 

provided no credible link between DecAID 

tolerance levels, potential population levels, and/or 

viable populations. The Forest Service has also 

failed to reliably quantify existing and projected 

habitat for snag associated species. 

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The agency's analysis of snag retention and habitat 

for cavity dependent species is faulty at both a 

programmatic level and at a project level. The 

agency must defer any decision on this project until 

it reviews all the available new information and 

amends its management plan standards to provide 

adequate snags for wildlife and all other ecosystem 

functions. 

Management 

Indicator Species

DecAID analysis integrates the most current 

scientific information for cavity dependent 

species. 

Karen Sjogren Raptors and Colonial Nesting Birds. Why weren't 

surveys done within sale units for raptors? Without 

surveys, how could it be known that the only nest 

trees are located outside of proposed harvest units?

Raptors and 

Colonial Nesting 

Birds

Surveys were conducted for only osprey nests as 

they are large, visible, ospreys are very noisy and 

they remain in the same trees for many years. 

Surveys are not done for other raptors. Raptor 

detections are included in contract language for 

timber sales with recommended procedures when 

detected. Individual trees are protected under this 

contract clause and harvest activities are 

seasonally restricted during the nesting season. 

The timber sale administrator looks for potential 

raptor nests during normal inspection activities. 

Raptors are not surveyed for as nest locations 

move yearly. During unit layout the cruisers and 

unit boundary layout crew also look for and report 

raptor nests when found.

Karen Sjogren For Alternative 3, 54 acres are "removed"; this 

figure is 44 acres on p.145, and no figure is given 

Migratory Birds The 54 acres is early seral 16 acres, gaps 29 acres 

and sugar pine shelter wood 9 acres. For the last 
Hwy 46 FEIS Appendix 

408

Commenter Comment Resource Topic Response

for the snag analysis on p. 176. If other activity 

treatments that remove habitat are added in, the 

total is 118.05 acres. The author is probably adding 

in some of the small gaps created by DTR and 

sugar pine restoration, but the methodology is not 

clear and I cannot arrive at his figures. Please 

explain. Without consistent and accurate figures 

for early seral habitat creation it is not possible to 

determine or compare effects. Please explain also 

the source of the proclamation at the top of p. 185 

that Alternative 3 would create 111 acres of gaps 

less than Alternative 2. Alternative 3 creates 13 

few acres of gaps, according t Table 9. Where does 

the other acreage come from?

sentence in Alternative 3 with 111 acres listed, 

this included dominant tree release for an 

additional 61 acres. 54 + 61 = 115 approximate 

acres. This last sentence was missed in 

Alternative 2, thank you for indirectly pointing 

that out. The acres in openings would be 268 in 

alternative 2. Gaps 48, sugar pine shelterwood 94, 

meadow 8, early seral 45 and DTR 73 acres.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service should include in its analysis an 

assessment of how the roads in the project area are 

likely to provide a vector for the spread of invasive 

species by fragmenting the landscape and creating 

buffers that are less resistant and resilient to 

stressors sed use of those roads by log hauling 

trucks and other motorists will further exacerbate 

the risk of spreading invasive species.

Invasive Weeds This is discussed in FEIS Section 3.7.9 and 

3.7.10.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The analysis states 232 total road miles exist in the 

project planning area and that 170 miles will 

remain open under Alternatives 2 and 3. See, e.g., 

DEIS at 204.

* How many of the 232 miles of road in the project 

area are system roads?

* How many miles of unauthorized, non-system 

roads exist in the project area? Where are the 

unauthorized, or non-system roads? * How does 

the Forest Service plan to manage the non-system 

roads?

Transportation We have reviewed the roads within the planning 

area, and have corrected the miles of roads 

analyzed. 216 miles of system roads are in the 

planning area.

We will be using approximately 9.12 miles of 

temporary roads to implement the Hwy 46 

project. 

Temporary roads will be decommissioned by the 

timber purchaser following timber sales activities. 

See Table 13, Design Elements, and Appendix A, 

FEIS page 277.
Hwy 46 FEIS Appendix 

409

Commenter Comment Resource Topic Response

The Forest Service does not track unauthorized, 

non-system roads. When unauthorized, nonsystem roads are located, they are closed to public 

access.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National

Monument

The total system miles analyzed on Table 63 

appears to be incorrect. DEIS at 325.

* What is the total number of system road miles in 

the project area?

Transportation There are approximately 216 miles of system 

roads in the project area. The Road Status table 

has been updated in the FEIS. (FEIS, table 64 

page 342)

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service references a travel and road 

management plan developed specifically for this 

project, that includes details regarding road status, 

conditions, stream culvert locations and conditions, 

road maintenance levels, and management 

classifications, which is located in a transportation 

analysis file. DEIS at 200. Much of this 

information is precisely the type of site- specific 

information that should be disclosed in the DEIS so 

as to inform the public and allow for meaningful 

comment.

Transportation This information is provided in the Road Status 

Table in Appendix H of the DEIS and FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service states that Alternatives 2 and 3 

meet the proposed minimum road system in the 

planning area. DEIS at 204. But the minimum road 

system for the project area has not yet been 

identified. The RIS included a recommendation, 

but was not itself an agency decision.

Therefore, the language referring to "meeting" that 

system is confusing. The agency must clarify 

whether it is proposing to determine the system 

roads identified under Alternatives 2 and 3 as the 

Transportation The (now) 150 miles is referring to the open roads 

that will remain open. The remaining miles are 

either closed or are being decommissioned. The 

minimum roads needed is what is analyzed in this 

EIS as needed for haul of the proposed units and 

also to administer for current and future 

resources.
Hwy 46 FEIS Appendix 

410

Commenter Comment Resource Topic Response

minimum road system. It must also explain in its 

analysis how the resulting road system achieves the 

factors defining a minimum road system under 

subpart A. Given that there are 232 miles of forest 

roads in the project area, and here the Forest 

Service identifies 170 miles as the minimum road 

system, did the agency determine that the 

remaining 62 miles are not needed?

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We strongly support the Forest Service's 

modification to include decommissioning of 1.99 

miles. DEIS at 200. However, this number is far 

too small given the challenges the Forest Service 

faces in maintaining its road system, the adverse 

impacts from the road system to the landscape, and 

in light of the 232 total road miles existing in the 

project area.

Road 

Decommissioning

The Forest Service has reviewed the road system 

in the planning area. Of the approximately 216 

miles of system road in the project area the Forest 

Service has included additional miles of road 

decommissioning in the FEIS, bringing the total 

to 8.88 miles of road decommissioning.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service states that storing 1.37 miles of 

roads will reduce the backlog of maintenance 

needs in the analysis area. DEIS at 204. To the 

extent the agency is storing certain roads for 

"resource protection," it should prioritize 

decommissioning these roads. See, e.g., DEIS at 

318 (identifying Forest Road 4600044 for closure 

"for resource protection" but failing to explain 

what future need the agency might have for the 

road that prevents it from being decommissioned).

We have identified the resources that needs those 

roads to remain on the system for future use. The 

Road Status Table in Appendix H has been 

updated.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

The information provided in the DEIS and Table 

63 (Appendix H) fails to provide any estimated 

timelines for the proposed road work. It also fails 

to provide any information about the aquatic risk or 

future needs of each of the roads in the project 

area. See, e.g., DEIS at 315 (stating that a road 

identified in the RIS to be analyzed for 

Roads System roads identified and cleared for 

decommissioning will be decommissioned in the 

future when funding becomes available. By 

having these roads identified and cleared for 

decommissioning through this EIS, road 

decommissioning funding sources such as Legacy 
Hwy 46 FEIS Appendix 

411

Commenter Comment Resource Topic Response

Douglas Fir 

National 

Monument

decommissioning "needs to remain on system for 

resource administration" without addressing 

whether the road presents a high aquatic risk, or 

defining what resource administration is needed 

and how far into the future).

Roads and other internal Forest Service funding 

sources will be competed for very easily. 

Road maintenance activities will occur before and 

during the associated timber sale.

Temporary roads will be constructed by the 

purchaser prior to timber sale activities, and 

would be decommissioned by the purchaser 

following timber sale activities.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Log hauling during wet weather has unacceptable 

water quality impacts and is decidedly NOT in the 

public interest. The NEPA analysis must take a 

hard look at the adverse water quality effects of log 

hauling during wet weather

Wet weather haul Wet weather haul has been analyzed in the FEIS, 

see Hydrology section 3.4.4. Roads not suitable 

for wet weather haul have been identified, FEIS 

Table 13, page 53. Further wet weather haul 

design elements are identified on page 58 of the 

FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The analysis in the DEIS mentions the Road 

Investment Strategy (RIS) (DEIS at 23, 201- 202), 

but fails to evaluate the road activities proposed for 

the Hwy 46 Project based on those 

recommendations. It makes no attempt to explain 

whether the road-related actions proposed in this 

project are consistent with the recommendations 

from that 2015 forest-wide report. It is possible this 

information is addressed in the travel and road 

management plan referenced in the analysis, but 

unfortunately as noted above the Forest Service 

fails to disclose this information to the public. 

DEIS at 200 (explaining the "travel analysis and 

plan considered such road-related items as safety, 

risk to resources, future expected use, public and 

private access, emergency access, and maintenance 

costs"). Appendix H to the DEIS lacks the 

Transportation The Road Status Table has been updated.
Hwy 46 FEIS Appendix 

412

Commenter Comment Resource Topic Response

necessary information to comply with subpart A of 

the roads rule. See 36 C.F.R. § 212.5(b)(2) 

("Responsible officials must review the road 

system on each National Forest and Grassland and 

identify the roads . . . that are no longer needed to 

meet forest resource management objections"). 

Instead, it merely lists the recommendations from 

the TAR (which as explained below are 

inadequate) but fails to explain any differences 

from those recommendations to the proposed road 

actions under this project. See DEIS, Appendix H 

at 312-333.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS should analyze the potential impacts on 

recreation new roads will have on this high use 

area. New roads not only attract illegal off road 

vehicle use but also attract trash dumping, firearm 

waste, littering, and other illegal activity. These 

activities could impact the desirability of the area 

and its appeal to recreationists. These activities and 

construction could also impact any wilderness or 

remoteness character of the area. Please address 

these issues in the DEIS.

Temporary Roads 

/ Recreation

The potential for these illegal activities are 

common across all National Forest Lands, 

especially in areas of timber harvest activity. In 

order to reduce the potential increase of these 

types of illegal activities, the Design Element for 

Action Alternative, indirectly address these 

concerns. In all units, the following criteria apply:

• Prevent off road travel and dispersed site

creation. Place natural obstacles such as down 

wood and rock in a natural arrangement to 

prevent creation of new dispersed sites where they 

don’t presently exist. Bury boulders 1/3 of the 

way in the ground where possible.

• Rehabilitate all landings to prevent site from 

becoming a new dispersed site. Place natural 

obstacles such as down wood and rock in a 

natural arrangement to prevent creation of new 

dispersed sites where they don’t presently exist. 

Bury boulders 1/3 of the way in the ground where 

possible.

• In units where proposed landings are currently 

dispersed sites, rehabilitation of sites will be 

necessary to restore site to desired condition for 
Hwy 46 FEIS Appendix 

413

Commenter Comment Resource Topic Response

continued use as a dispersed site or return to a 

naturalized state. Consultation with a recreation 

specialist will be required in the design phase for 

units in or adjacent to these areas. Rehabilitation 

may include: Placing natural obstacles such as 

down wood and rock in a natural arrangement to 

prevent expansion of dispersed sites. Burying 

boulders 1/3 of the way in the ground where 

possible.

• Purchaser will close temporary roads to traffic 

and rehabilitate to prevent new off road recreation 

use. Subsoil road surface of temporary roads to 

prevent new road creation. Place natural obstacles 

such as down wood and rock in a natural 

arrangement to prevent creation of new dispersed 

sites where they don’t presently exist. Bury 

boulders 1/3 of the way in the ground where 

possible.

We know from actively working in the field, 

when access into new areas due to any form of 

disturbance happens, dispersed sites tend to get 

created – increasing the likelihood of the other 

illegal activities mentioned in the question –

therefore our management practices try to reduce 

any new dispersed site creation.

Additionally, Design Elements regarding impacts 

to Wilderness Areas (areas designated by the 

Wilderness Act) only apply to Unit 560, as that 

was the only unit near the Mt. Jefferson 

Wilderness. The activities proposed for Unit 560 

will be limited by these Design Elements:

• Restrict activities to recreation off-season

• Accomplish treatment with non-motorized 

equipment

• Expedite activities to affect only 1 year
Hwy 46 FEIS Appendix 

414

Commenter Comment Resource Topic Response

With these criteria, we hope to mitigate any 

impacts, or potential impacts to Wilderness or 

remote areas.

AFRC also contains a restriction that prohibits the use of 

helicopter operations prior to 8am year-round. As 

you likely know, economically logging with 

helicopters comes as a challenge. Any additional 

parameters applied will only exacerbate that 

challenge. We would like the District to consider 

limiting this particular restriction to the weekend 

and holiday periods. Like most farmers, the 

logging community has a tradition of starting work 

early in the morning. It's not always easy, but it is 

necessary. We ask that you consider the strong 

work ethic that this community practices and allow 

a start time that they see necessary to get their job 

done.

Operations In order to balance the competing demands of a 

working economy of logging and a recreation 

economy for the project area, this restriction was 

decided on as a compromise between the two. 

Knowing that the Breitenbush area has a high 

demand for recreation use and knowing that 

helicopter operations can produce noise 

disturbances, we wanted to allow the use of 

helicopters as necessary for harvest operations, 

but within the constraints of the quiet hours of the 

nearby campgrounds. In previous helicopter 

harvest operations on the Detroit Ranger District, 

helicopter operations have impacted the recreation 

experience of campers in nearby campgrounds, to 

the point of lost revenue at those sites. Due to the 

lack of recreationists in the winter months, we 

will change the restriction to an 8:00 AM start 

time, from Memorial Day to Labor Day, only in 

units 24, 32, and 32a. We believe this is sufficient 

to reduce impacts to the recreating public and 

reduce the burden of additional restrictions.

AFRC Under the "Recreation" heading on page 47, Table 

13 describes a restriction aimed at reducing impact 

to the recreating public. This restriction also 

applies an 8 am start time to certain units yearround. We would ask the District to again consider 

the potential impacts to recreationalists during 

winter months when recreation is likely low.

Operations From October to May, all of the developed 

campgrounds along the Breitenbush corridor are 

closed for the season, and much of the project 

area typically receives enough snowfall to restrict 

access for several months at a time – leading to a 

lower number of recreationists. Due to this lack of 

recreationists in the winter months, we will 

change the restriction to an 8:00 AM start time, 

from Memorial Day to Labor Day, only in units 

24, 32, and 32a. We believe this is sufficient to 

reduce impacts to the recreating public.
Hwy 46 FEIS Appendix 

415

Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS states that appx. 300 acres of areas that 

are classified as "retention" are going to be 

commercially thinned. The FS states that this will 

done in such a way that it will not be evidence to a 

forest visitor. Please elaborate further in the FEIS 

how this is possible.

What are you basing the assumption that these 

treatments will not be visible to forest visitors 

upon?

Scenic Quality Based on the analysis of the proposed treatments 

and the known, local conditions (screening 

density of vegetation from roadways, trails, etc.), 

the proposed actions in the FEIS are deemed to 

not be evident to the casual forest visitor. The 

majority of forest visitors will not notice harvest 

activities as they drive the roadway (likely driving 

35-45 miles per hour) or hike trails with few 

viewpoints facing the proposed harvest units. 

There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS simply states that "Proposed treatments 

in alternatives 2 and 3 fall well within allowable 

scenic quality ranges set by the Forest Plan." DEIS 

at 215. This is not the hard look required under 

NEPA. What type of logging is going to take place 

in these areas, are there any proposed gaps, what 

type of yarding will be used?

Scenic Quality Just a bit further in the document, under the 

section labeled Scenic Viewsheds, the rationale 

for the comment "Proposed treatments in 

alternatives 2 and 3 fall well within allowable 

scenic quality ranges set by the Forest Plan." By 

looking at the numbers in Table 53, as well as the 

description and scenic quality mitigations further 

described in the section, we believe this project 

falls well within the allowable scenic quality 

ranges set by the Forest Plan. There are many 

units within the project area that will have 

proposed gaps. There are several types of logging 

and yarding methods that will be used within the 

project area: ground based; skyline; and 

helicopter. Each of those methods have their own 

type of yarding requirements and restrictions.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Are you generating view sheds from certain 

viewing points or trails?

Some analysis here is necessary, especially given 

the recreational popularity in this area and the 

Breitenbush River's Wild and Scenic eligibility. It 

is difficult to imagine that the forest visitor will not 

Scenic Quality We generated a viewshed analysis from multiple 

points across the landscape of the project area 

using Google Earth, GIS data, and on the ground 

surveys. We used computer software to look for 

high points, cut banks, and previously cleared 

artificial or natural openings, for example, and 
Hwy 46 FEIS Appendix 

416

Commenter Comment Resource Topic Response

Friends of the 

Douglas Fir 

National 

Monument

see fresh stumps, yarding damage, large stump 

fields in the gaps, or the temporary roads and 

landings constructed to facilitate the logging. We 

are very concerned about these impacts and the 

nearly 300 acres of logging proposed in these 

areas. Conclusory sentences in the DEIS are simply 

not sufficient.

then travelled to those sites in the field to visually 

inspect the effect of the unit treatments from those 

sites. In some cases, computer modeling was 

sufficient to extract an approximate analysis, but 

site visits were also used.

We will amend the conclusory statements in the 

FEIS to reflect these concerns, but as stated 

before, based on the analysis of the proposed 

treatments and the known, local conditions 

(screening density of vegetation from roadways, 

trails, etc.), the proposed actions in the FEIS are 

deemed to not be evident to the casual forest 

visitor. The majority of forest visitors will not 

notice harvest activities as they drive the roadway 

(likely driving 35-45 miles per hour) or hike trails 

with few viewpoints facing the proposed harvest 

units. There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS does included an image to simulate the 

impacts of logging adjacent to a camping site 

located in the project area at some "valued scenic 

viewpoints." What level of thinning did this image 

simulate and how was the image created?

Scenic Quality The level of thinning in the image was 

commensurate to the average level of harvest in a 

thinned unit. The caption on most of the photos 

showing the simulation states that the image was 

created with (Adobe) Photoshop. A real world 

example, of what a thinned unit would look like, 

can be found on Forest Service Road 46, at about 

1000 feet west of the entrance of Humbug 

Campground, on the south side of the road. If 

requested, images of that thinned unit can be 

provided.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

The DEIS repeatedly states that view impacts will 

be minimal and perhaps not apparent to the casual 

forest visitor. How is the FS supporting this 

statement and assumption?

Scenic Quality Based on the analysis of the proposed treatments 

and the known, local conditions (screening 

density of vegetation from roadways, trails, etc.), 

the proposed actions in the FEIS are deemed to 
Hwy 46 FEIS Appendix 

417

Commenter Comment Resource Topic Response

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

not be evident to the casual forest visitor. The 

majority of forest visitors will not notice harvest 

activities as they drive the roadway (likely driving 

35-45 miles per hour) or hike trails with few 

viewpoints facing the proposed harvest units. 

There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS discloses a myriad of effects on the 

numerous various recreational activities that are 

offered in the project area. However, the FS never 

attempts to cumulate these effects. How many 

folks will be turned away by closures?

How many folks will witness active operations?

Recreation Past and present natural and human caused 

disturbances or modifications including timber 

harvest and road construction are evident 

throughout the project area. Due to the limited 

duration of the activities within the project area, it 

is not likely that people will be turned away by a 

closure unless there is legitimate need for public 

health or safety. Visitors may choose to turn away 

and recreate in different areas due to the activities 

being presented.

We do not have accurate or available records of 

the number of visitors in the project area, but we 

do have estimated information from the National 

Visitor Use Monitoring report. We will amend the 

conclusory statements in the FIES to reflect these 

concerns.

Karen Sjogren There is a creative, subjective element in designing 

forest treatment prescriptions so they achieve their 

objectives but do not reduce the scenic attributes of 

the area. This project appears to do that. Did recent 

fires change any elements of this section?

Scenic Quality During the fire, some roads had a narrow strip 

(usually not more than 10 feet wide) of trees 

removed on one side to enhance the fire break 

created by the road. Although some of this fire 

line treatment did occur in Hwy 46 units in this 

area, the effect on vegetation within those units 

was minimal. Only trees immediately adjacent to 

the road were cut. Most of the higher intensity 

burns within the project area occurred away from 

open system roads and therefore will have 
Hwy 46 FEIS Appendix 

418

Commenter Comment Resource Topic Response

minimal effects on the scenic attributes of the 

area. From the perspective of high, open 

viewpoints, the effects of the fire may change the 

overall appearance of the project area, but those 

effects will reflect a natural process at work 

within the project landscape. We will amend the 

conclusory statements the FIES to reflect these 

concerns.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS simply admits in this section that it will 

violate the Forest Plan by leaving visible stumps, 

evidence of logging in the wild and scenic corridor. 

This is illegal. These restrictions exist for a reason, 

and these stumps could later be used to disqualify 

this area for Wild and Scenic eligibility. This is 

significant. The FS cannot simply write off these 

restrictions because they make logging in the area 

expensive. Why does any alternative simply not 

contain this illegal logging?

Wild and Scenic 

Rivers

The Forest Plan allows logging to occur within 

the 1⁄2 mile wild and scenic river corridor and 

standard and guide MA-6-12 and MA-6b-11 say 

that stumps within the corridor “should” be flush 

cut. This guideline was also developed by a forest 

plan when the common logging prescription was 

clearcutting. The thinning being proposed in these 

stands is much less visually impacting. The Forest 

Plan goes on to specify that this action is required 

unless justifiable reason exists for not taking 

action, such as an unacceptable hardship or 

expense (page IV-45). Therefore, due to the 

expense of flush cutting stumps, only the areas 

within 100’ of system roads are proposed to have 

stumps flush cut. Partial implementation of this 

measure will reduce effects to visual quality due 

to stumps in areas most often viewed by visitors 

to the forest and is consistent with Forest Plan 

direction. Visual effects from areas where stumps 

are not flush cut within the 1⁄2 mile corridor will 

be reduced with the passage of time and growth of 

surrounding vegetation. Eligibility of the rivers 

for inclusion in the national Wild and Scenic 

River System will not be jeopardized. The text in 

the Eligible Wild and Scenic Rivers section of the 

FEIS has been corrected to include this 

clarification.
Hwy 46 FEIS Appendix 

419

Commenter Comment Resource Topic Response

Karen Sjogren The McCoy 6 project for both alternatives was not 

described elsewhere in the tables or text, especially 

for Alternative 3. (DEIS page 217)

Recreation The “McCoy 6” as stated in the DEIS, may have 

been misinterpreted as a project, but is the name 

of a route in the McCoy Motorized Recreation 

Area. The complete name is the McCoy 6 Boulder 

Ridge Route. This is a loop used primarily by 

snowmobiles in the winter and some OHVs in the 

summer months. The route follows Forest Service 

Road (FSR) 2231-810 and FSR 2231. The 

majority of this loop is outside of the project area 

boundary, but a small portion of the route passes 

through Unit 73. The FEIS states “Meadow 

restoration is proposed along segments of the 

Mansfield trail in alternative 2 and the McCoy 6 

Boulder Ridge Route (used by snowmobiles and 

OHVs) in alternatives 2 and 3. Although 

treatments would be enhancing existing natural 

features and would be repeating form, line, color, 

and texture of the characteristic landscape, the 

intentions may not be evident to forest visitors. 

Restored meadows would provide trail users with 

variation in scenery and valuable views of 

alternative landscapes from dense forest.” Unit 73 

is a thinning unit. We will amend the FIES to 

clarify these concerns.

Daphne Stone we also need to retain some amount of old forests 

for recreation and wildlife habitat. Although the 

proposed sale includes a burn and a plantation, 

both are old stands. Once an old stand is cut, it is 

unlikely that it will ever be allowed to reach this 

age again

General No old stands are being proposed for harvesting 

in any alternative of this project. Hazardous fuels 

activities in units 170 and 270 around the 

Breitenbush property will be limited to cutting 

brush and thinning trees less than 7 inches dbh. 

Some stands (over 80 years old) in the project 

area are experiencing competition due to high tree 

densities. Thinning treatments in these stands are 

designed to increase tree growth and accelerate 

species diversity in the mid-story, ultimately 

moving those stands to an old-growth structure in 
Hwy 46 FEIS Appendix 

420

Commenter Comment Resource Topic Response

a shorter timeframe than if left in their current 

condition. Early seral habitat creation in these 

stands will increase structural diversity at the 

landscape level, creating habitat for a wider 

variety of plant and animal species and replicating 

natural processes, such as fire, that shaped the 

landscape historically. 

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS is proposing ground based logging in an 

IRA. Does this involve temporary road 

construction in the IRA? 

Inventoried 

Roadless Areas

No temporary roads would be built in the IRA. 

FEIS has been updated.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS should discuss potential economic 

benefits and costs, direct and indirect, of the 

logging project and discuss the contributions to the 

local economy from the timber to be logged and 

jobs provided as compared to the economic 

benefits brought by clean water, unlogged forests, 

and recreation, particularly by the Breitenbush 

community and its over 25,000 annual guests.

The Forest Service needs to consider how much 

business Breitenbush brings to the surrounding 

counties and areas, and to contact Breitenbush 

specifically to consult on revenue and numbers on 

attendees and what percentage of these attendees 

use the surrounding forest lands, including the 

project area. These figures should be weighed 

against the purported value to the community 

generated from the project's implementation.

Local Economics We recognize the role the Breitenbush Resort 

plays in the local area, and are aware the 

community will be impacted by this project. 

Many design elements have been designed to 

minimize these impacts.

The Breitenbush Resort officials shared general 

numbers with us during the planning process, but 

did not provide the information needed to 

complete the type of analysis suggested in this 

comment. The DEIS discussed the importance of 

the Breitenbush Hot Springs Resort to its’ many 

visitors, the economics and tourism it brings to 

the area. The economics section also outlined that 

the leisure and hospitality industry currently 

represents 14% of the employment in the North 

Santiam Canyon. Because of this very fact, many 

added mitigation measures are proposed in this 
Hwy 46 FEIS Appendix 

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Commenter Comment Resource Topic Response

project to ensure that impacts to recreation in the 

area are minimized.
Hwy 46 FEIS Appendix 

422

Comments from Cascadia Wildlands, Oregon Wild, WildEarth Guardians and Friends of 

the Douglas Fir National Monument on Climate Change

The FS should consider the economic benefits of keeping carbon stored in unlogged forests by 

calculating the avoided costs of global climate change. Disclose the Social Cost of Carbon Dioxide as a 

proxy for the impacts of GHG emissions.

DEIS page 255 says "a project of this magnitude makes an infinitesimal contribution to overall 

[greenhouse gas] emissions. Therefore, at the global and national scales, the proposed action's direct 

and indirect contribution to greenhouse gasses and climate change would be negligible. In addition, 

because the direct and indirect effects would be negligible, the proposed action's contribution to 

cumulative effects on greenhouse gasses and climate change would also be negligible." This is wrong on 

many levels. First, why does the FS say this about greenhouse gases but not about this project's 

contribution to jobs and wood products which are also infinitesimal at a global scale? Second, the FS 

cannot conclude that this projects GHG emissions do not contribute to cumulative impacts. If that was 

true then there would be no global warming problem at all, because every individual contribution is 

small in comparison to the global problem. The FS does not seem to understand that climate change is 

by definition a problem of cumulative effects. All GHG emissions (from logging and all other sources) are 

part of the problem, and all carbon capture (such as by growing trees that are not logged) is part of the 

solution.

The NEPA analysis in the Hwy 46 DEIS must avoid minimizing this project's contribution to carbon 

emissions and global warming by saying the effects of this project would be negligible on a global scale. 

This is not an appropriate framework.

The Hwy 46 DEIS failed to describe how many tonnes of CO2e would be emitted by this project, how big 

the carbon debt created by this project is, how long it would take to recapture that carbon, how much 

warming would occur during the time period it takes to recapture that carbon, and failed to quantify the 

forgone opportunity to capture carbon in unlogged forests under the no action alternative, etc.

Response:

The Forest Service acknowledges the trade-off between management activities and greenhouse gas 

(GHG) emissions. The intent of the project is not maximizing carbon, but to promote biodiversity by 

increasing landscape diversity through a number of actions (increasing/maintaining early seral 

vegetation, improving stand-structure characteristics, and increasing snag recruitment). The Forest 

Service recognizes carbon sequestration is one of many ecosystem services provided by forests and 

forest products now and into the future. Carbon sequestration should be considered in context with 

other ecosystem services (USDA FS, 2015). 

The EIS states its adherence to the suggested practices of reducing forest disturbance effects found in 

the National Climate Assessment for public and private forests (Joyce et al. 2014). We further describe in 

the EIS on pages 17 to 19 the need for maintenance and restoration of forestlands to promote healthy 

functional ecosystems. Improving stand conditions will improve forestland adaptive capacity and 

function better under threat of disturbances like fire. This improved resiliency to disturbance threats will 

improve chances of future forest persistence. 
Hwy 46 FEIS Appendix 

423

The Forest Service currently lacks standardized tools for estimating all GHG emissions and carbon 

associated with the implementation of the proposed project. Current CEQ guidance allows federal 

agencies flexibility in using the best available scientific information to qualitatively describe emissions 

and carbon tradeoffs between alternatives rather than quantifying them in the absence of available 

information/tools. For this project we do not have the analyses or information for quantification at the 

project level at this point in time. 

Several studies throughout western forests support the efficacy of thinning for reducing severity of 

potential wildfire (Agee and Skinner, 2005; Safford et al., 2009; Stephens et al., 2009; Safford et al., 

2012). There is also evidence to suggest that treatments such as thinning reduce burn probability in 

adjacent untreated stands (Moghaddas et al., 2010). Evidence does indicate a cost in terms of reduced 

carbon storage for this reduced burn severity (Campbell, Harmon, and Mitchell, 2012). However, over 

large areas and long periods of time, Campbell and Ager (2013) show forest carbon stocks are insensitive 

to a wide range in fuel reduction treatment effectiveness, lifespan, vegetation recovery rates, and other 

factors. These authors suggest “that the carbon costs to reduce wildfire effects through fuel treatment 

appear relatively small.”

Providing some context for the Willamette NF, a recent regional carbon assessment estimates that the 

entire forest stores 250 teragrams* of carbon (USFS, 2015). A second carbon assessment focusing on 

disturbance estimates the forest lost approximately 25 teragrams of potential carbon storage over the 

past 60 years (USDA FS, 2016 in press – Fig. 4d Appendix B) because of fire, harvest, and insects. From 

1991-2011, the assessment presents evidence (Figure 1q – see below) of more fire on the forest 

especially since 2003, which suggests increasing influence on lost carbon storage (USDA FS, 2016 in press

– Appendix A). Considering the size of the project area, the carbon trends of the forest as a whole will 

likely show little sensitivity to the carbon emissions caused by the proposed action.

The short-term release of GHG associated with the project be it removal of carbon stocks or the shortterm emissions occurring during implementation is reasonable given the improved longer-term 

ecological conditions. The project’s co-benefit of increased forest resilience is supported by science that 

projects higher levels of fire under future climate change, and the need to restore forests by increasing 

uneven-age, large tree stands that are more resistant to disturbance (Rogers et al., 2011). Of course 

there is uncertainty to how future climate will affect the extent and severity of fire in the future. The 

literature indicates the need to proactively promote resilience to fire and other disturbances under this 

0

1

Percentage of forest disturbed

Year

1q) Willamette

Insects

Harvest

Fire
Hwy 46 FEIS Appendix 

424

uncertainty by increasing spatial heterogeneity (landscape diversity) at multiple scales (Cansler and 

McKenzie, 2014), which is in line with the original intent of the proposed action. 

*

One teragram is one trillion grams.

Literature Cited:

Agee, J.K., Skinner, C.N. (2005). Basic principles of forest fuel reduction treatments. Forest Ecology and 

Management. 211:83-96. doi:10.1016/j.foreco.2005.01.034

Campbell, J. L., Harmon, M. E., & Mitchell, S. R. (2012). Can fuel-reduction treatments really increase 

forest carbon storage in the western US by reducing future fire emissions? Frontiers in Ecology and the 

Environment, 10(2), 83–90. doi:10.1890/110057

Campbell, J.L. & Ager, A.A. (2013). Forest wildfire, fuel reduction treatments, and landscape carbon 

stocks: A sensitivity analysis. Journal of Environmental Management. 121, 124-132. 

doi:10.1016/j.jenvman.2013.02.009

Cansler, C. A., & McKenzie, D. (2014). Climate, fire size, and biophysical setting control fire severity and 

spatial pattern in the northern Cascade Range, USA. Ecological Applications, 24(5), 1037–1056. 

doi:10.1890/13-1077.1

Moghaddas, J. J., Collins, B. M., Menning, K., Moghaddas, E. E. Y., & Stephens, S. L. (2010). Fuel 

treatment effects on modeled landscape-level fire behavior in the northern Sierra Nevada. Can. J. For. 

Res., 40(9), 1751–1765. doi:10.1139/x10-118

Rogers, B. M., Neilson, R. P., Drapek, R., Lenihan, J. M., Wells, J. R., Bachelet, D., & Law, B. E. (2011). 

Impacts of climate change on fire regimes and carbon stocks of the U.S. Pacific Northwest. Journal of 

Geophysical Research, 116(G3). doi:10.1029/2011jg001695

Safford, H. D., Schmidt, D. A., & Carlson, C. H. (2009). Effects of fuel treatments on fire severity in an 

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