Magone Project Final Environmental 

Impact Statement (FEIS)

Appendix D – Public Comment Report

Blue Mountain Ranger District

Malheur National Forest
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FEIS Appendix D – Public Comment Report Magone Project

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Table of Contents

Public Involvement ..................................................................................................................... 1

Summary of Public Response.................................................................................................. 1

Specific Written Comments........................................................................................................ 2

Consideration of Science/Literature Submitted by the Public .................................................. 78

References Cited ..................................................................................................................... 140

Comments Received on the Draft EIS from Federal, State, and Local Agencies and Elected 

Officials................................................................................................................................... 143

Comment Received from Janine Belleque (Oregon State Marine Board)........................... 143

Comment Received from Scott W. Myers, Chris B. Labhart, and Boyd Britton (Grant 

County Court)...................................................................................................................... 145

Comment Received from Maralee Wernz (Confederated Tribes of the Warm Springs 

Reservation of Oregon) ....................................................................................................... 146

Comment Received from Christine B. Littleton (United States Environmental Protection 

Agency, Region 10, Environmental Review and Sediment Management Unit) ................. 147

Tables

Table D-1. List of commenters........................................................................................................ 1

Table D-2. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 1 – Purpose and Need ........... 3

Table D-3. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 2 – Alternatives, Road 

Activities ................................................................................................................................. 4

Table D-4. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 2 – Alternatives, Recreation / 

Magone Lake........................................................................................................................... 7

Table D-5. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 2 – Alternatives, Silviculture 

Treatments............................................................................................................................. 14

Table D-6. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 2 – Alternatives, Fuels 

Treatments............................................................................................................................. 21

Table D-7. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 2 – Alternatives, 

Miscellaneous........................................................................................................................ 23

Table D-8. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS Chapter 3 – Affected Environment and 

Environmental Consequences ............................................................................................... 30

Table D-9. Comment identification number, source of comment, written comment, and Forest 

Service response for comments pertaining to the EIS, Clarifications / Miscellaneous / Errata

............................................................................................................................................... 56

Table D-10. Magone project planning area fuel load summary .................................................... 57

Table D-11. Consideration of science/literature submitted during the 45-day comment period 

related to forest vegetation, fire, and fuels ............................................................................ 79

Table D-12. Consideration of science/literature submitted during the 45-day comment period 

related to watershed resources............................................................................................. 106

Table D-13. Consideration of science/literature submitted during the 45-day comment period 

related to fisheries resources ............................................................................................... 108
FEIS Appendix D – Public Comment Report Magone Project

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Table D-14. Consideration of science/literature submitted during the 45-day comment period 

related to roads .................................................................................................................... 110

Table D-15. Consideration of science/literature submitted during the 45-day comment period 

related to wildlife................................................................................................................. 121

Table D-16. Consideration of science/literature submitted during the 45-day comment period 

related to snags.................................................................................................................... 121

Table D-17. Consideration of science/literature submitted during the 45-day comment period 

related to botany / non-native invasive plants..................................................................... 122

Table D-18. Consideration of science/literature submitted during the 45-day comment period 

related to roadless areas....................................................................................................... 124

Table D-19. Consideration of science/literature submitted during the 45-day comment period 

related to climate change ..................................................................................................... 124

Table D-20. Consideration of science/literature submitted during the 45-day comment period 

related to the National Environmental Policy Act............................................................... 126

Table D-21. Consideration of science/literature submitted during the 45-day comment period 

related to socioeconomics.................................................................................................... 126

Table D-22. Consideration of science/literature submitted during the 45-day comment period 

related to miscellaneous topics............................................................................................ 129

Figures

Figure 1. Magone Lake sonar imagery 1....................................................................................... 12

Figure 2. Magone Lake sonar imagery 2....................................................................................... 12

Figure 3. Example of a mosaic underburn pattern......................................................................... 23
FEIS Appendix D – Public Comment Report Magone Project

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Public Involvement

A 45-day comment period for the Magone Project began on February 5, 2016, with publication of a 

Notice of Availability (NOA) of a draft environmental impact statement (DEIS) in the Federal Register 

(see Federal Register Vol. 81, No. 24, Friday, February 5, 2016). The Magone DEIS was made available 

on the Malheur National Forest website at 

http://www.fs.usda.gov/projects/malheur/landmanagement/projects.

Letters were sent to approximately 130 individuals or organizations summarizing the alternatives, and 

included directions to the Forest’s website for more information. A public open house was held on March 

8, 2016, where attendees had the opportunity learn more about the project and ask questions of the 

interdisciplinary team.

Summary of Public Response

Thirty (30) comments were received in the form of emails and mailed letter comments on the Magone 

DEIS before the 45-day comment period ended. Several comments were received after the 45-day 

comment period ended. Comments were received from both individuals and organizations. Each response 

letter was assigned a reference number (Table D-1).

Table D-1. List of commenters

Letter reference number Date Name and organization

C-01 2/9/2016 Lawrence Baughman

C-02 2/9/2016 Ned Ratterman (Oregon Trail Electric Cooperative)

C-03 2/12/2016 Jean Public

C-04 2/18/2016 Judy Kerr

C-05 2/19/2016 Steve Hill

C-06 3/2/2016 Dick Artley

C-07 3/3/2016 Janine Belleque (Oregon State Marine Board)

C-08 3/8/2016 Scott W. Myers (County Court of Grant County)

C-09 3/8/2016 Rick Minster

C-10 3/9/2016 George Wuerthner (Lorax Alliance)

C-11 3/9/2016 Judy Kerr

C-12 3/9/2016 Ranko Balog

C-13 3/10/2016 Brooke Downing

C-14 3/11/2016 Jason and Clair Kehrberg

C-15 3/12/2016 Timothy Swenson

C-16 3/14/2016 Bill Richardson (Rocky Mountain Elk Foundation)

C-17 3/15/2016 Melvin and Harriet Crum

C-18 3/15/2016 Frances Preston

C-19 3/18/2016 Irene Jerome (American Forest Resource Council)

C-20 3/18/2016 Maralee Wernz (Confederated Tribes of the Warm Springs 

Reservation of Oregon)

C-21 3/19/2016 Kirk Handley

C-22 3/20/2016 Steven James Silva

C-23 3/20/2016 Ken & CiCi Brooks

C-24 3/20/2016 Dusty Bloomingheart
FEIS Appendix D – Public Comment Report Magone Project

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Letter reference number Date Name and organization

C-25 3/21/2016 King Williams (King Inc)

C-26 3/21/2016 Zach Williams (Iron Triangle LLC)

C-27 3/21/2016 Bill Wilcox

C-28 3/21/2016 Brian Milchak (Department of the Interior, Office of Environmental 

Policy and Compliance, Pacific Northwest Region)

C-29 3/21/2016 Pam Hardy (Oregon Wild)

C-30 3/21/2016 Christine B. Littleton (United States Environmental Protection Agency, 

Region 10, Environmental Review and Sediment Management Unit)

Specific Written Comments

The following section (Table D-2) contains specific written comments and their disposition in the final 

environmental impact statement (FEIS) and draft record of decision (draft ROD). To minimize 

duplication, comments addressing essentially the same topic or concern have been consolidated among 

the various letters. Each comment contains a citation to the comment letter(s) where the comment 

originated. Specific written comments are defined by 36 CFR §218.2:

Written comments are those submitted to the responsible official or designee during a designated 

opportunity for public participation (§218.5(a)) provided for a proposed project. Written 

comments can include submission of transcriptions or other notes from oral statements or 

presentation. For the purposes of this rule, specific written comments should be within the scope 

of the proposed action, have a direct relationship to the proposed action, and must include 

supporting reasons for the responsible official to consider.

The responses provided here are intended to discuss all major points of view. Statements may have been 

summarized or paraphrased to reduce paperwork.
FEIS Appendix D – Public Comment Report Magone Project

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Table D-2. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 1 – Purpose and Need

Comment 

number

Source Comment Forest Service response

100 C-06, 

pages

13 and 

48

Jointly develop an accurate P&N and scope the 

project again. If an accurate P&N does not 

show the need to log the area then modify the 

Proposed Action to include actions that do not 

require commercial “mechanical treatment.”

Failure to do so will violate NEPA because the 

analysis is not site specific. Why? The Purpose 

& Need for the project is based on another 

area. Some areas where similar actions might 

occur could have similar characteristics but 

they are not the same with the Magone sale 

and the Big Mosquito timber sale. They have 

different soils, elevation, aspect, stream 

sensitivity, recreational use etc. The only 

similarity is the fact they both have 

merchantable conifer trees. Therefore, the 

Purpose & Need does not accurately “specify 

the underlying purpose and need to which the 

agency is responding in proposing the 

alternatives including the proposed action.” (40 

CFR 1502.13)

Remove the commercially log the area to 

“maintain and improve community stability and 

infrastructure” from the P&N.

Land management planning goals and objectives, as well as standards and 

guidelines for specific land management allocations are created pursuant to the 

National Forest Management Act, as amended, and the agency’s implementing 

regulations contained in 36 CFR 219. The element of the purpose and need to 

provide for a variety of wood products and forest management employment 

opportunities to help maintain and improve community stability and infrastructure is 

based in the forest goals outlined in the Malheur National Forest Land and 

Resource Management Plan (Malheur Forest Plan), which establishes the 

management direction for the Malheur National Forest (USDA Forest Service 1990). 

The Malheur Forest Plan Goals related to timber are:

24. Provide a sustained flow of timber for lumber, fiber, and/or associated wood 

products at a level that will contribute to economic stability, while providing for 

regional and national needs.

25. Provide and utilize wood fiber in the form of saw timber, fiber, and/or 

associated wood products in a manner which will minimize losses and maximize 

outputs in a cost-effective manner, consistent with the various resource objectives 

and environmental standards.

26. Provide and economic return to the public.

This element of the purpose and need is consistent with the Malheur Forest Plan, as 

amended.

101 C-06, 

page 

36 and 

38

The Purpose & Need for this project does not 

reflect the goal to save lives and homes in the 

WUI using all available methods. The current 

P&N describes an action (fuels removal) rather 

than a goal to reduce or eliminate fire damage 

risk. Broadening the P&N would open the door 

to use other fire damage risk reduction 

methods in addition to fuels logging. Fuels 

logging is an alternative ... not a primary 

purpose and goal. Indeed, the homeowners 

living close to the national forests where a fire 

might start should be given all the protection 

possible by the USFS.

Modify the P&N to reflect what should be the 

prime goal of this timber sale: reduce the 

This element of the purpose and need states:

Reduce the fuel loadings, including the density and horizontal and vertical 

connectivity of standing vegetation, surface fuels, and/or ladder fuels to restore 

characteristics of ecosystem composition and structure to reduce uncharacteristic 

wildfire effects within the project planning area including the Nipple Butte IRA and 

wildland urban interface (WUI). Reduce fuels along County Road 18, County Road 

32, Forest Service road (FSR) 36, FSR 3618, FSR 3640, FSR 3947, and FSR 

3620, which are identified as escape corridors from Magone Lake in the Grant 

County Community Fire Protection Plan.

Reducing fuel loading can be accomplished in a variety of ways including 

commercial thinning, non-commercial thinning, hand piling and burning, prescribed 

burning, etc. A variety of these and other treatments are analyzed in the Magone 

FEIS to accomplish this objective.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

chance that homes will burn in the WUI should 

a wildfire start in the area. Fuels reduction 

would then be an alternative.

102 C-16, 

page 3

One of the Magone Project’s Purposes and 

Needs is to “Maintain or improve habitat for fish

and wildlife species present in the project 

area.” RMEF cannot accept that Alternative 2 

or 3, with their acknowledged extremely 

adverse trail disturbance and displacement of 

big game from the otherwise enhanced habitat, 

can even remotely be judged to satisfy the 

“maintain or improve purpose and need criteria 

for the project.

Elk, mule deer, and other wildlife habitat would be enhanced or maintained by many 

of the proposed project activities. However, as the comment states, wildlife use of 

that habitat along developed trails and regularly traveled roads (when accessible) 

could be substantially reduced due to the disturbance.

103 C-23, 

page 1

The Social Values and Opportunities section 

(pg 14, section 1.4.1.5) ignores the role that 

ranching plays in the local economy and within 

the DEIS, there is no recognition of a desired 

future condition related to grazing in the 

Magone Project area.

Desired future condition related to grazing in the Magone Project is outside the 

scope of the analysis of the project. Desired future conditions for grazing and 

allotment management will be addressed in through allotment NEPA in the future.

Table D-3. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 2 – Alternatives, Road Activities

Comment 

number

Source Comment Forest Service response

200 C-03, 

page 7

We don’t want more roads through this 

forest.

No new permanent road construction is proposed as part of the Magone Project. 

Temporary road construction is proposed in varying amounts under the three action 

alternatives; however, these temporary roads would be rehabilitated after use to ensure 

that the area has adequate drainage and ground cover to prevent erosion, soil 

productivity is restored, the road is no longer drivable, and the road was is no longer 

visible after approximately 5 years.

201 C-04, 

page 2

1800279, a major ML 2 local road which 

ends at Trail head #346, should never 

have been designated as a trail and 

therefore requiring to be un‐designated. 

This road did not have a CFR closure and 

justification for such action.

FSR 1800-279 is currently a ML 2 road and no changes to the maintenance level are 

proposed as part of the Magone Project. The road is currently co-designated as an ML 2 

(open) road and a trail. Un-designating the road as a trail would not change current 

motorized access to this road.

202 C-04, 

page 3

1800933 is scheduled for 

decommissioning but there is no evidence 

of a road beyond the dispersed campsite. 

Any decommissioning activities, other than 

This recommendation is consistent with what is proposed under the Magone Project, as 

stated in the Magone FEIS on page 60: “FSR 1800-933 is a currently open road that is 

not needed for future management and is proposed for decommissioning. There is no 

evidence of a designed roadway past the dispersed campsite. The segment of this road 
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

simply removing a carsonite road sign, 

would be counterproductive and causing 

ground disturbance that is unnecessary.

past the dispersed campsite would be permanently removed from the Forest 

transportation system. This road would be allowed to continue to naturally re-vegetate 

itself, with no on-the-ground work proposed.”

203 C-04, 

page 3

3600162 and 3600612 are both already 

effectively closed on the ground and 

should have carsonite road signs removed 

and left to naturally continue to close 

themselves.

This recommendation is consistent with what is proposed under the Magone Project, 

these roads would be left to continue to naturally close themselves. Under alternative 2 

the maintenance level would be changed from ML 2 to ML 1, under alternatives 3 and 4 

the maintenance level would remain ML 2.

Carsonite signs are only pulled if a road is decommissioned. We are proposing closure 

(ML1) status instead of decommissioning because we anticipate future management 

needs for these road segments.

204 C-04, 

page 3

3600187 and 3940071 are on the travel 

management list, and there is no closure 

restrictions listed and therefore should be 

left open for recreational travel. Of the total 

0.46 miles of the 3600187, 0.36 miles are 

already closed and bermed (without a 

CFR); the 3600612 and 3940071 are not 

listed as a haul route and need not be 

addressed for closure without justification.

Justification for closing or decommissioning or closing these roads has been clarified in 

the Magone FEIS and Magone FEIS Appendix A – Project Activity Tables.

FSR 3600187 (0.1 miles) is proposed for decommissioning under alternative 2 and 

closure under alternatives 3 and 4 to address water quality issues. Fill is acting as a dam 

across the valley, and there is a need to connect the upper and lower valleys.

FSR 3600612 (0.4 miles) is already effectively closed on the ground, and is proposed to 

be designated as a maintenance level 1 (closed road) under alternative 2 to reflect the 

condition present on the ground.

FSR 3940071 (0.2 miles) is proposed for closure under alternatives 2, 3, and 4 to 

address water quality issues.

205 C-04, 

page 3

3947459 accesses the Nipple Butte 

trailhead and should be left open to allow 

recreationists access to that site.

FSR 3947-459 is currently an open (ML 2) road and is not proposed for closure under 

any of the action alternatives. It is proposed to be co-designated as a trail under 

alternatives 2 and 3, which would not change motorized access to this road. 

Recreationists would continue to be able to access this site.

206 C-06, 

page 3-

5

Please analyze an action alternative in 

detail that does not construct any new 

roads (temporary or system). Please don’t 

exclude a “no new road” alternative from 

analysis in detail by claiming the P&N will 

not be met. The PYN includes timber 

harvest but it does not specify a volume of 

number of acres. The “no new roads” 

alternative will reduce the acres treated, 

but will still meet the P&N since most 

harvest would still occur.

Please don’t claim the No Action 

alternative satisfies this request to analyze 

a “no new roads” alternative in detail. The 

timber sale contains some actions that will 

Please see the Magone FEIS, Chapter 2, Alternatives Considered but Eliminated from

Detailed Study section.

The Magone FEIS documents consideration of the no action alternative and three action 

alternatives, in compliance with 40 CFR 1500.2(e); and the Magone FEIS contains best 

management practices and project design criteria to minimize, avoid, reduce or eliminate 

impacts of the proposed project (Magone FEIS Appendix C – Project Design Criteria) in 

compliance with 40 CFR 1500.2(f).
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

benefit the ecosystem of the area. A “no 

new roads” alternative would include these 

actions. The P&N will still be met because 

volume will be available from existing 

roads.

Failure to analyze a timber sale with no 

new road construction will violate: 40 CFR 

1500.2(e) and (f) because the Responsible 

Official was unable to avoid or minimize 

adverse effects of the project upon the 

quality of the human environment without 

complete knowledge of all likely adverse 

effects.

207 C-08, 

page 1

The Grant County Court would like to 

discuss the possibility of the County 

assuming responsibility of the following 

roads in the Magone Project:

 36 (end of 41023-32 to the junction of 

the 18 road);

 3618000

The Grant County Court and Forest Service can discuss this proposal further.

208 C-18, 

page 1

For the Roads proposed for closure or 

decommissioning exactly what are the site 

specific surveys used?

Engineering do road condition surveys to verify existing conditions. Other resources do 

site specific analysis to determine if road should be decommissioned or closed as it 

pertains to resource issues. 

Wildlife biologists look at a peer reviewed distance banding (essentially road buffering) 

to determine if and what road activities could maintain or enhance contiguous blocks of 

wildlife security areas (i.e., areas without roads). A draft digestible dietary energy model 

is also used to determine if a particular road may be associated with areas that provide 

better forage for elk/deer. Malheur Forest Plan management areas and if roads/road 

density pose a threat to the integrity of those (i.e., old growth and big-game winter range

maintenance) or if road densities exceed Malheur Forest Plan standards.

Aquatic resources specialists review R6 stream surveys, road condition surveys, and 

roads identified during time spent in the planning area that are causing negative effects 

to threatened and endangered species and their critical habitat. Road decommissioning 

and closure is considered if the road is a fish passage barrier, is increasing fine 

sediment generation beyond background levels, is encroaching on the floodplain 9and is 

resulting in altered hydrological processes).
FEIS Appendix D – Public Comment Report Magone Project

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Table D-4. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 2 – Alternatives, Recreation / Magone Lake

Comment 

number

Source Comment Forest Service response

209 C-01, 

page 1

Take a close look at proposed trails and 

ask, would this trail give some access to 

some rather cool views or just plain ole 

unique places on the forest? Sometimes it 

might be better to be able to do a few 

things less well.

A variety of distances of trails are considered in the Magone FEIS: 0 trails under 

alternative 1, 15.4 miles of trails under alternative 4, 54.0 miles of trails under alternative 

2, and 96.3 miles of trail under alternative 3. The impacts of these trails are analyzed in 

the Magone FEIS chapter 3, and will be considered by the responsible official when 

making a decision on this project. The responsible official will also consider the 

comments received during the scoping and 45-day comment period.

210 C-05, 

page 1

I would like to suggest an improvement to 

the "beach" area most often used by locals 

and tourists alike. Can we bring in 

additional sand to refurbish that area? Also 

can we develop the north and south side 

of that beach to create additional sandy 

beach type areas? This little beach is a big 

draw to locals and tourists and its 

improvement would give increased 

dimension to Grant County's recreation 

opportunities. It is my understanding that 

there are some decent sand deposits in 

the Seneca area, and I’m sure with your 

resources, you most likely know of other 

sand deposits in our region which can be 

utilized to enhance this public project area.

The sand at the beach area could be replenished under another project, but the beach 

area could not be expanded due to potential negative impacts to a nearby marsh area.

211 C-05, 

page 1

Additionally I would like to suggest a 

localized 'cleaning of some of the downfall 

log in the water near the shore area. This 

would include only the immediate areas 

around the beach and public access areas 

and leave the remainder of the lake natural 

and as is. This would help alleviate a 

safety hazard as it is tempting for young 

children to try to walk on those slippery 

logs close to shore.

This was considered, however, some of these logs are providing species habitat, and 

are a part of the natural processes and functions of the lake.

212 C-05, 

page 1

Lastly, could a noxious weed program be 

implemented and maintained [around 

Magone Lake]. I have noticed increasing 

Bull Thistles and Canadian Thistles around 

the shore. It seems it would only take one 

staffer about a half day every 2 weeks 

Please see the 2015 Final Record of Decision for the Malheur National Forest SiteSpecific Invasive Plants Treatment Project, which includes treatment of non-native 

plants around Magone Lake.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

during the growing season to keep these 

in check.

213 C-07, 

page 1

The Marine Board is supportive of the 

proposed Alternative 2 boating 

improvements; “The boat launching dock 

would be modified and the boat mooring 

dock would be replaced, improving visitor 

boating opportunities. The boat launching 

dock would be modified for improved 

function, eliminating the inconvenient 

angle of the dock to the boat ramp. The 

boat mooring dock on the north end of the 

lake would be replaced and moved south 

so that boaters would no longer need to 

paddle through weeds to approach or 

leave the dock.” However, the issue with 

the dock at the boat ramp is not the angle 

but the gangway structure that prohibits 

utilization of the floating dock to safely 

launch and retrieve a boat. The gangway 

should be removed and an abutment 

installed with the docks running parallel to 

the boat ramp utilizing internal piling.

Thank you for your comment, we will use this recommendation when the project is 

implemented after the decision is signed.

214 C-08, 

page 1

The Court would like to encourage the 

Forest Service to allow the use of ATV’s in 

the Magone Lake Campground.

We did consider but eliminate from detailed study the alternative of allowing OHV use in 

the Magone Lake Campground. OHV use within the campground would alter the current 

rustic experience that Magone is known for and generate noise disturbance to existing 

recreational uses.

215 C-09, 

page 1

No ATV’s at Magone Lake. The Forest Service is not proposing to allow OHV use in the Magone Lake Campground.

216 C-09, 

page 1

New dock at campground – morage. Thank you for your comment; however, it does not provide enough detail to understand 

the meaning.

217 C-09, 

page 1

Gray water sumps at campground. This was not a consideration in the Magone Project, it can be looked at in another 

analysis.

218 C-10, 

page 5; 

C-27, 

pages 

1 and 

2; C29, 

We are opposed to any new trail 

construction in the roadless areas—this 

should be reserved as a refuge for wildlife.

We strenuously object to new trails within 

the Nipple Butte IRA. Roadless areas –

especially large ones over 1,000 acres –

The alternative of not constructing any new trails in the Nipple Butte Inventoried 

Roadless Area (IRA) is analyzed in alternative 1 (no action). The action alternatives 

(alternatives 2, 3, and 4) consider a range of potential new trail mileages in the Nipple 

Butte IRA, from a high of 32.7 miles with alternative 3 to a low of 7.6 miles with 

alternative 4. The Responsible Official will consider the impacts to wildlife from potential 

trail developments when making his decision.
FEIS Appendix D – Public Comment Report Magone Project

9

Comment 

number

Source Comment Forest Service response

page 

18

are critical strongholds for wildlife, 

especially large animals such as elk and 

deer. Less than 4% of the state of Oregon 

is currently designated Wilderness, and 

approximately that much again is roadless. 

The other 92% of the State is carved up 

for roads and mechanized travel. While all 

of the staff and most of the supporters of 

Oregon Wild love mountain biking, we are 

more than willing to limit ourselves to 

enjoying the 92% of land that already has 

trails and roads. Please leave the last few 

roadless areas for the wildlife.

A 2009 study in Oregon by Naylor & 

Wisdom, looked at the impact of four types 

of recreational disturbance: all‐terrain 

vehicle riding, mountain biking, hiking, and 

horseback riding. Compared to control

periods when elk spent most of their time 

feeding and resting, travel time increased 

in response to all recreational disturbance, 

but decreasing in the order listed above 

(i.e. ATV use eliciting the greatest increase

in travel time, horseback riding eliciting the 

least). Both mountain biking and hiking 

activities were found to significantly reduce 

resting time for elk. See DEIS Wildlife 

Report page 62.

219 C-11, 

page 2

Mountain bike and hiking trail construction 

in the Nipple Butte Inventoried Roadless 

Area would need to address sanitation 

issues. Regardless of honorable intent, 

individuals utilizing such facilities must 

defecate/urinate, use toilet tissue, produce 

waste paper such as candy bar wrappers, 

sandwich baggies, etc. Some of these 

items would not be “carried out”, but either 

buried or side cast after use. Involvement 

of the Central Oregon Trail Alliance does 

not guarantee provisions for human waste 

and garbage disposal that would possibly 

Thank you for your comment, however, this is outside the scope of this project and 

analysis. Sanitation issues can and do arise from all types of recreationists anywhere on 

the Forest.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

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occur along a trail such as mentioned 

above.

220 C-14, 

page 2

If any existing trails are improved or if new 

trails are constructed as part of the 

Magone Project, we request that they be 

designed in consultation with associated 

grazing permittees, be sited in 

consideration of limiting livestock 

disturbance and avoidance of existing 

stockwater locations, and that all fence 

crossings be fitted with a cattle guard 

device or spring loaded gate to reduce the 

opportunity for gates to be left open by trail 

users. These types of unique fence 

crossing devices should also become the 

maintenance responsibility of the Forest 

and not the associated grazing permittee.

Implementation of any trail construction authorized under the Magone Project Record of 

Decision would be coordinated with associated grazing permittees through the 

rangeland management and recreation specialists.

221 C-17, 

page 1

A better addition would be designate 

equestrian trails (and build a spot at 

Magone where horses can overnight) 

because it is less disturbing to wildlife and 

there is no other area in the Malheur that 

we know of that caters to equestrian 

groups.

This was considered but eliminated from detailed study in the Magone FEIS chapter 2, 

Alternatives Considered but Eliminated from Detailed Study section.

222 C-18, 

page 1

Will any roads be constructed or 

reconstructed within the Nipple Butte IRA? 

If so, how would this be following the 

Roadless Rule?

No roads would be constructed or reconstructed within the Nipple Butte IRA. Portions of 

Forest Service roads 1800760, 1800362, 3618083, and 3618295 already exist within the 

Nipple Butte IRA and would be used during implementation under alternative 3.

223 C-19, 

page 2

AFRC supports co-designating roads as 

trails for various uses in the Magone 

project planning area. Request that any 

additional trails in areas that will impact 

grazing permits be managed seasonally so 

as not to disturb livestock management. 

This will serve a dual purpose of being 

beneficial to wildlife as well.

Implementation of any trail construction authorized under the Magone Project Record of 

Decision would be coordinated with associated grazing permittees through the 

rangeland management and recreation specialists.

224 C-23, 

page 3

Delete alternative 3 proposal to designate 

FSR 36 for OHV use due to the heavy use 

that presently occurs. This is sure to result 

in a fatality.

The proposal to designate FSR 36 for OHV use in alternative 3 provides variation in the 

alternatives considered in the Magone FEIS; alternatives 1, 2, and 4 do not include a 

proposal to designate FSR 36 for OHV use.
FEIS Appendix D – Public Comment Report Magone Project

11

Comment 

number

Source Comment Forest Service response

225 C-24, 

page 3

We ask that the proposed trail construction 

through the edge of the nest stand and 

through the PFA be dropped, as there 

have been many timber sales and much 

non-commercial thinning already 

degrading and eliminating suitable 

goshawk habitat and PFAs across the 

Malheur, and as goshawks are very 

sensitive to human disturbance and may 

abandon their nest if a trail is constructed 

near it

A trail currently exists near the northern goshawk nest, a portion of which is within the 

nest stand. New trail construction near the nest stand would be limited by timing 

restrictions if the nest stand is occupied. With its close proximity to the current trail and 

Magone Lake, it is suspected that the goshawks that nest in this location are somewhat 

habituated to nearby recreation. Although increased recreation in and around the PFA 

could result in this location being abandoned by nesting goshawks, there is a significant 

amount suitable residual habitat in the PFA, MA13 network, and connectivity corridors

throughout the project planning area. Please refer to the Magone FEIS chapter 3, 

Wildlife – Featured Species section to review the anticipated effects to northern 

goshawks.

226 C-27, 

page 3

Magone Lake seems to have plenty of 

underwater structure already. The fish crib 

is unnecessary. It will only serve to disturb 

this natural lake. Trout species are not in 

need of an abundance of structure. I 

question if there has been a study of this 

water to determine the need for this. I am 

inclined to think this is an activity 

conceived in a college class room and a 

young biologist is wanting to try it out. It 

will cost $ that will not pay off. A sound 

study, with proof of resulting success in 

this type of water, structure, etc. should be 

on hand before attempting this. 

Experimenting should not be allowed here. 

I have fished this lake for many years, I 

have plenty of experience to provide a 

credible declaration by the number of 

hooks and lures I have lost, that there is 

an abundance of structure in this lake.

Thank you for your comment and we are aware that an entire forest lies under the water 

at Magone Lake. What we do not know is the condition of the wood as far as its 

effectiveness for fish cover and habitat.

Scuba diving of specific locations within Magone Lake was completed during May 2016 

by members of the Forest Service Region 6 Dive Team. In addition to diving, side scan 

sonar recordings were taken for the entire lake as part of a trial by Garmin Inc.

The deepest part of the lake was recorded as 113 feet and standing trees were present 

throughout the lake, in particular below 20 feet. Upon further inspection by divers it was 

discovered that below 20 feet water clarity and light penetration dropped to near zero. A 

layer of particles was present at this depth (20 feet) and was visible throughout the sonar 

recordings.

Wood below this depth still had limbs and had minimal decay but wood above 20 feet 

lacked limbs and was decayed much further than those portions of wood below 20 feet 

(many broken off at stump). This suggests that below 20-30 feet dissolved oxygen levels 

quickly decline. Thus due to minimal light penetration (phytoplankton) and dissolved 

oxygen levels it is highly unlikely that fish occupy depths greater than this for large 

portions of the year and also effectively minimizes food production for aquatic insects 

(fish food) at this depth.

Additionally one of the main ways dissolved oxygen is mixed within a lake column is 

through wind/wave action and temperature/water density differences. Due to the 

orientation of the lake to primary winds, shape of lake (small surface area to volume 

ratio) it is unlikely that this lake experiences complete “turn over or mixing” in the spring 

and fall.

These findings suggest that woody debris within Magone Lake at depths 20 feet or less 

plays a critical role as fish habitat and aquatic insect habitat and that the existing wood 

within this zone is partially or completely decayed with no future recruitment due to lack 

of trees on the surrounding shoreline.
FEIS Appendix D – Public Comment Report Magone Project

12

Figure 1. Magone Lake sonar imagery 1

Figure 2. Magone Lake sonar imagery 2

Trout species as well as the majority fish species in the world require cover. Wood in 

lakes is just as important as wood in rivers. Wood in lakes is a natural disturbance that 

has been altered through human activities (e.g., firewood cutting, beaches, recreation 

activities, etc.) along shorelines. Wood along a lake shoreline provides the following 
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

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Source Comment Forest Service response

benefits: 1) prevents and minimizes shoreline erosion as part of wave/wind action, 2) 

provides overhead cover and shade for juvenile and adult fish whom spend a large 

portion of their time within the shallow littoral zones of lakes, and 3) provides critical 

wildlife rearing/nesting areas for waterfowl/amphibians/ and mammals such as beaver.

This type of work has been going on for over 30 years within the states of Michigan, 

Wisconsin, and Minnesota where wood along lake shorelines has become limited due to 

development along the shorelines. In particular, a large number of these lakes have 

brook trout in them which are native for these states. The “fish sticks” handout is a how 

to guide completed by the Wisconsin Department of Natural Resources.

Newbrey et al. (2005) found increasing complexity of branching to be positively 

associated with fish species richness, diversity, and abundance, but preference for 

branching complexity varied by species. Generally, most studies conclude that fish have 

a strong preference for some degree of branching over simple, unbranched logs, and 

striving for a variety of branching densities may be an optimal strategy to benefit a wide 

range of species (Sass et al. 2011). Similarly, coarse woody habitat additions that cover 

a range of depths can be expected to be beneficial to a wider variety of species over a

greater seasonal timeframe. It should be noted that individual pieces of structure appear 

to have a ‘carrying capacity’ of fish that they are capable of supporting.

Newbrey, M.G., M.A. Bozek, M.J. Jennings, and J.A. Cook. 2005. Branching complexity 

and morphological characteristics of coarse woody structure as lacustrine fish habitat. 

Canadian Journal of Fisheries and Aquatic Sciences 62(9): 2110–2123.

Sass, G.G., S.R. Carpenter, J.W. Gaeta, J.F. Kitchell, and T.D. Ahrenstorff. 2011. Whole 

lake addition of coarse woody habitat: response of fish populations. Aquatic Sciences 

74(2): 255-266.

Kaufmann, P.R., R.M. Hughes, T.R. Whittier, S.A. Bryce, and S.G. Paulsen. 2014. 

Relevance of lake physical habitat indices to fish and riparian birds. Lake and Reservoir

Management 30(2): 177-191.

Kaufmann, P.R., D.V. Peck, S.G. Paulsen, C.W. Seeliger, R.M. Hughes, T.R. Whittier, 

and N.C. Kamman. Lakeshore and littoral physical habitat structure in a national lakes 

assessment. Lake and Reservoir Management 30(2): 192-215.

227 C-27, 

page 3

Improving the campground boat dock is 

needed. However, moving it is not. The 

weeds that are off the end of the current 

dock do not inhibit its use. Paddling, 

rowing or motoring is not a problem. This 

is the best location to launch small craft, 

because it is closes to the parking area, 

and a short pack.

As stated in the Magone FEIS, the new boat mooring location would be in deeper water. 

The purpose of this dock would be to allow campers to dock their boats overnight or 

while not in use and avoid having to pull the boat onto shore causing shoreline damage. 

This new dock would also provide campers with an alternative to repeatedly loading and 

unloading their watercraft from the boat launch (limiting congestion at boat launch).

The alternative of not moving the campground boat dock is analyzed under alternative 1.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

228 C-27, 

page 4

Fishing platform on the other side of the 

lake is objectionable for the following 

reasons.

a. Fishing is possible already with good 

success.

b. This is a picturesque lake. Already 

many man made structures clutter the 

view, except when viewing the East 

side of the lake from the west side. 

Please leave it alone. This allows for 

nice pictures and at least a feeling of 

remoteness when viewing. There is 

already two boat docks and a fishing 

platform.

The option of not constructing a fishing platform on the east side of Magone Lake is 

analyzed under alternatives 1 and 4.

Table D-5. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 2 – Alternatives, Silviculture Treatments

Comment 

number

Source Comment Forest Service response

229 C-02, 

page 2

Request that trees not be planted in 

Oregon Trail Electric Cooperative’s 

(OTEC’s) utility line right-of-ways (ROWs).

Tree planting is not proposed as part of this project. The planting that is referred to in the 

Magone FEIS is for rehabilitation of road beds and is referring to ground cover species 

such as grasses, forbs, and shrubs.

230 C-19, 

page 2

I do not see a notice that there will be a 

forest plan amendment to remove trees 

greater than 21 inches at diameter breast 

height (dbh). Without this amendment it 

will be very difficult to effectively move 

these forest stands to a more resilient 

condition since inter-tree competition is not 

adequately reduced. Further, leaving too 

many grand fir regardless of size and age 

provides a seed source that continues the 

cycle of that species continually reestablishing under the canopy.

Site-specific amendments to go above 21 

inches are needed for the project and are 

consistent with the National Forest 

Management Act, which permits the Forest 

Service to amend a Forest Plan in “any 

During project development the silviculturist for the Magone Project determined, through 

site visits of stands proposed for treatment, that a site-specific amendment to cut trees 

greater than 21 inches dbh would not be warranted to meet the purpose and need of the 

project and the silvicultural objectives of reducing density and shifting species 

composition. Although there are young grand fir over 21 inches dbh within the project 

planning area and within some of the treatment units, they were deemed to be at a low 

enough quantity to not justify a forest plan amendment.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

manner whatsoever.” 16 U.S.C. 

§1604(f)(4)

The Magone project area has unique 

characteristics, including species 

composition at the site, which justify sitespecific amendments.

231 C-23, 

page 2

Clean up the overstocked, dead& dying 

forest and make it more resilient re and 

other natural disturbances, at a rate that 

exceeds the growth and mortality rates of 

the plant association groups.

The Magone FEIS proposes to significantly reduce stocking on a large portion of the 

project planning area (depending on alternative) using a combination of mechanical 

thinning and prescribed fire (Magone FEIS, Table 14). Thinning and fire will make stands 

and the broader landscape more resilient to natural disturbances. Thinning and burning 

will have the effect of reducing overall stand growth by removing small and young trees 

and concentrating growth in older and larger residual trees. Reducing competition and 

mortality risk associated with fire, insect attack and drought stress should reduce stand 

mortality rates. The appropriate post-treatment density and associated growth and 

mortality rates for each plant association group (PAG) is determined by modeling stand 

density index (SDI) for each PAG. SDI provides a measure of intra-tree competition for 

site resources indexed by site productivity. The FEIS (Magone FEIS, Table 15 and 

pages 64, 138-139, 153-154, 160, 166-167, 173-174) and Silvicultural Report provide 

detailed information about pre- and post-treatment SDI for each PAG in the Magone

project planning area.

232 C-23, 

pages 

2 and 4

Juniper stand reduction needs to be done.

Change the amount of juniper thinning 

slash (pg. 27) that would be scattered; 

20,000 lbs. of debris to a depth of 2 ft. 

deep is just unnatural and unless the area 

is planned for a prescribed burn in the 

immediate future, this conflicts with the 

purpose of “..reduction of surface fuels, 

duff/litter depth, ladder fuels...” on pg 29. 

On slopes, it provides a continuum of fuel 

and will not break down in this climate for 

many years. The wildfire potential is too 

great if delays to the schedule occur, and 

we all know that getting the right 

conditions for a prescribed burn can make 

delays.

Slash is proposed to be left to 7-10 tons/acre because this is the level that is needed to 

produce the desired fire behavior effects during prescribed burning, moderate fire 

behavior during a wildfire event, and assist with slope stability and protect highly erodible 

soils. Prescribed burning would occur in these units and the desired effects include 

creating a mosaic condition that increases wildlife habitat and forage. This level of slash 

has been a standard for non-commercial thinning on the Malheur National Forest for 

many years. This calculation includes tree boles, limbs, and tops. Slash accumulations 

would not be left as a continuous mat of slash to 2 feet deep. This level of slash is 

expected to be intermittent throughout the non-commercial thinning areas. Similar 

juniper treatments have been completed in the Murderer’s Creek area on the Malheur 

National Forest. The pictures below illustrate a juniper unit that was cut and prescribe 

burned. Magone juniper treatments also propose piling and restrict slash accumulations 

above 2 feet. However, the slash levels illustrated below are similar to what will be 

expected for Magone post-treatment.
FEIS Appendix D – Public Comment Report Magone Project

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FEIS Appendix D – Public Comment Report Magone Project

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Comment 

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Source Comment Forest Service response

233 C-24, 

page 3

We ask that proposed commercial logging 

in the only known Northern goshawk postfledging area (PFA) be dropped, as there 

have been many timber sales and much 

non-commercial thinning already 

degrading and eliminating suitable

goshawk habitat and PFAs across the 

Malheur.

Please refer to the environmental consequences section under northern goshawk in the 

Wildlife Report. Commercial and non-commercial thinning can be beneficial for 

goshawks as treatments can enhance understory species, in turn enhancing small 

mammal populations (prey base). Although goshawks can be sensitive to disturbance 

from activities, timing restrictions would apply to those activities if the nest is determined 

to be occupied.

234 C-25, 

page 1; 

C-26, 

page 1

Reducing stand density to manage more 

within the management zone.

In section 1.4.1.1 it states that the purpose 

of the silvicultural treatments is to shift the 

forest structure, composition, and density 

toward historical conditions and to reduce 

susceptibility to insects and disease. Later 

in that section the first bullet point says the 

desired future condition of the Magone 

The Magone FEIS acknowledges that treating larger or smaller areas would have 

different effects on landscape scale restoration objectives. There is significant variation 

in the total area treated between alternatives (Magone FEIS, Table 14). Each alternative 

proposes different amounts of mechanical treatment, ranging from 20 percent of the 

project planning area in alternative 4 to 50 percent in alternative 3. The Malheur Forest 

Plan directs projects to provide for a variety of resources, including timber products, a 

variety of wildlife habitats, clean water and healthy streams, as well as manage towards 

the historical range of variability. We look forward to continued discussions on how we 

can better meet these objectives during project planning and future projects.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

project planning area is to reduce stand 

density to manage more within the 

management zone.

Later in section 3.2.1.6 there is a 

discussion about how much the proposed 

actions will change the percent below, 

within, and above the management zone 

for each PAG. While there is no doubt that 

the proposed action, as compared to the 

no action alternative, does have an effect 

on how much of the PAG is within the MZ 

it seems that our goal should be to have a 

more pronounced or more long lasting 

effect. We realize that the constraints of 

the Malheur Forest Plan in its current state 

may provide a barrier to treating enough 

acres or treating each acre to the extent 

necessary to make a more significant 

change but we would still like to comment 

that for the amount of investment this 

forest and collaborative have made 

towards these project areas, it would be 

helpful to either treat more acres or treat 

the acres we are treating more 

aggressively. With approximately 40% of 

the project acres being proposed for 

mechanical treatment and close to 100% 

of the project acres in the burn plan we 

would suggest that we continue to discuss 

ways to have a larger impact on 

movement towards HRV through 

continued refinement of our prescriptions 

on future projects. For the current project 

we request that additional acres be added 

for mechanical treatment to bring to at 

least 50% of the project acres being 

mechanically treated.

235 C-29, 

page 8

Please specify that no trees over 21” DBH 

should be cut of any species.

This project does not propose a forest plan amendment to cut trees greater than or 

equal to 21 inches dbh. For the activities authorized under the Magone decision there 

would be no trees greater than or equal to 21 inches dbh cut. Activities authorized under 

the Aquatics EA decision and discussed within the Magone FEIS may have trees greater 
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

than or equal to 21 inches dbh cut because Aquatics Restoration Decision authorized 

that activity under specific parameters.

236 C-29, 

page 8

Thank you for your inclusion and careful 

placement of leave patches. Please 

explain your criteria for the location of 

leave patches with more specificity. What 

criteria will be used to determine a good 

leave patch?

Leave patches would be designated to provide for the best habitat possible within each 

unit. These patches would range from 5 to 15 percent of each treatment unit. Leave 

patches typically include areas of existing regeneration to provide security cover, snag 

patches, old growth pockets, wet areas (RHCAs, springs, and seeps), steep slopes, 

cultural sites, and sensitive plant sites.

237 C-29, 

pages

8-9

We are confused about the apparently 

contradictory requirement to create 

openings in the noncommercial thinning 

areas that are up to 2 acres in size. What 

exactly is the purpose of this?

We understand that there have always 

naturally been places throughout the forest 

where soils do not support tree cover for 

some reason. We encourage and support 

heavy thinning in areas such as historically

wet meadows and aspen stands that have 

been encroached on by conifers. Similarly, 

rocky ridges and some scab lands have 

never been able to support a healthy 

population of conifers. We support 

openings in these areas as well. 

Additionally, some of those scab lands 

should support a stronger population of 

mahogany. We support openings around 

these important browse species. However, 

we don’t entirely understand why there 

should be openings in other places –

especially not in the middle of areas that 

could have historically supported a healthy 

population of trees.

Please don’t allow openings larger than an 

acre in areas that there is not a site‐

specific justification. Please keep openings 

under 10% of the total treatment area 

unless there is a site specific justification.

Openings up to 2 acres were chosen in the prescription to meet Malheur Forest Plan 

standards (openings up to 2 acres are allowed) and to create areas that promote browse 

species in Big-Game Winter Range. These openings would be centered around browse 

species such as mountain mahogany and bitterbrush to enhance and promote the health 

and spread of browse habitat. Openings this large would not be used in forested stands 

that support a healthy population of trees. These areas would have openings up to 1 

acre. Also, openings would be kept to less than 10 percent of each treatment unit except 

in Big-Game Winter Range where browse species would be protected. These 

clarifications will be incorporated into the silviculture prescription.

238 C-29, 

page 9

Old growth is one of our most significant 

concerns, and we completely concur with 

The Magone FEIS acknowledges the risk to old growth trees and large and old larch and 

proposes mechanical thinning and burning which would enhance the survivability of this 
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

this prescription. Thank you for taking this 

seriously.

We encourage you to leave western larch 

of all ages in all prescriptions. We have 

been alarmed by the research by James 

Johnston showing that the percentage of 

larch existing across the entire forest has

dropped precipitously.

We have also attached our more detailed 

comments on logging in old growth in the 

form of the handbook written by Tim 

Lillebo.

species (Magone FEIS, pages 31-34, 136-176, and 228-257). The silvicultural 

prescription calls for leaving early seral trees (ponderosa pine, western larch, and in 

some areas Douglas-fir) over grand fir or lodgepole pine and retaining all rare species 

within stands. The order of preference for leaving of species described in the Magone 

DEIS and silvicultural report is western larch, ponderosa pine, Douglas-fir, lodgepole 

pine, and grand fir (Draft Silviculture Prescription for Mechanical Treatments and 

Prescribed Fire, page 14).

239 C-29, 

pages 

14-15

We concur that treatments around aspen 

need to create significant openings. 

According to the research we have seen 

from Trent Seager it appears that we may 

have lost 80‐90% of the aspen that

historically existed on the Malheur. As a 

result, treatment around aspen stands 

needs to be significant enough that aspen 

doesn’t just persist, but actually expands. 

We concur with the plan to remove conifer

that does not show old growth 

characteristics up to 150 from the last 

observed aspen sucker.

Please include a discussion of the drivers 

of aspen decline, and customize each 

treatment based on that. For example, if 

herbivory is not a problem, don’t add 

fences.

Please include a requirement that felled 

trees will not be removed until there are 

sufficient downed trees to create a barrier 

to excessive elk and cattle browse.

One driver of aspen decline is herbivory from large ungulates (Seager et al. 2013, 

Seager et al. 2015). Herbivory is negatively affecting all aspen stands in the Magone 

project planning area and fencing is needed in most if not all cases (Swanson et al. 

2010; Magone FEIS, pages 144, 153-154, 160, 167, 174, and 456). This is due to the 

low abundance of aspen in the project planning area, concentrating ungulate use in just 

a few stands. In addition, loss of aspen overstory and lack of recruitment in the 

understory is being driven by: soil and light resource competition from encroaching 

conifers, decreased water availability from encroaching conifers, decreased water 

availability from dense stocking of conifers at the watershed level interrupting snowpack 

flow through the system, and fire exclusion (Seager et al. 2015). All aspen stands in the 

Magone project planning area are declining due to these causes (Magone FEIS, pages

33 and 40).

Specifically, the exclusion of fire: decreases forage for large ungulates and thus puts 

more pressure on aspen stands, increases conifer encroachment at the aspen stand and 

watershed level, and removes natural disturbance that would remove part or all of the 

aspen overstory and initiate dense root suckering (Seager et al. 2015). While conifer 

encroachment in the Magone Project may be heavier in some aspen stands than others, 

conifer removal is needed in each stand. As the commenter says, conifer removal 

around the stand (150 feet past the last live sucker) allows for aspen stand expansion 

and decreases the need for reentry in order for the stand to expand (Seager et al. 2015).

Aspen stands outside of the IRA are proposed for fencing to minimize browse on new 

and existing suckers. Aspen stands inside of the IRA are proposed for non-commercial 

thinning and the material felled would be left on site to help create a barrier to excessive 

elk and cattle browse.
FEIS Appendix D – Public Comment Report Magone Project

21

Table D-6. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 2 – Alternatives, Fuels Treatments

Comment 

number

Source Comment Forest Service response

240 C-03, 

page 7

Stop all the burning up and loading of our 

air with fine particulate matter.

A variety of amounts of prescribed burning are analyzed in the Magone FEIS, from no 

prescribed burning under alternative 1 (no action) to up to 28,500 acres of prescribed 

burning (under alternatives 2 and 3). See the Magone FEIS chapter 3, Fire, Fuels, and 

Air Quality section. Air quality standards require that impacts be minimized, especially in 

Class 1 airsheds and smoke sensitive areas. Mitigation measures should be used when 

appropriate and burning should be conducted in accordance with the state Smoke 

Management Plan (USDA Forest Service 1990, page IV-40).

Prescribed burning in Oregon is managed by the Oregon Department of Forestry (ODF) 

under the Oregon Smoke Management Plan (OSMP). The OSMP is intended to 

minimize smoke impacts by conducting forest burning under weather conditions that 

disperse and direct smoke away from populated areas. Burning on National Forest 

System lands only occurs with prior approval granted by ODF. Wildfires tend to occur at 

the driest time of the year; therefore, fuels are more completely consumed and typically 

produce three to five times more emissions than early- or late-season prescribed fires.

241 C-23, 

page 2

Create escape corridors for wildfire 

management along existing breaks on 

access roads.

The Grant County Community Wildfire Protection Plan has identified two county roads 

and the Malheur National Forest has identified four additional Forest Service roads as 

potential escape route/safety corridors.

The objective along these safety corridors is to manipulate the existing vegetation in a 

way that moderates fire behavior, allowing safe travel for the public and suppression 

forces should the need arise to escape from an emerging wildland fire.

Silviculture and fuels reduction treatments have been primarily focused along these 

identified routes and also occur along other less used access roads.

242 C-23, 

page 4

Remove statement on pg 29, last sentence 

and again on pg 41; “Unplanned ignitions 

may be used...”; we all know after the 

Canyon Creek Complex 2015 that this can 

be devastating.

Unplanned ignitions, for example, lightning caused fires, can already be managed using 

a full suite of management tools. This includes identifying pre-existing fuel breaks some 

distance from the fire and completing large scale burning operations. The intent in the 

Magone project planning area would be to only use unplanned ignitions when fuel and 

weather conditions fall within the same prescriptions traditionally used during early and 

late season prescribed burning.

243 C-27, 

page 2

I am quite concerned about the amount of 

prescribed burning that is planned. I think 

burning is a risky business, based on the 

F.S. past history of misapplied attempts, 

resulting in failure. There have been too 

many get out of control. When the burning 

is applied to harvested areas as where the 

ground vegetation and litter (duff) is 

broken up and intermittent, the success is 

much greater. However, in the case of 

Burn block boundaries in the Magone planning area were primarily designated along 

main travel routes which provide a natural fuel break.

The two burn blocks that comprise the majority of the IRA are bounded by roads and 

trails with some potential line locations identified along main ridge tops. 

Burn block size is not always indicative of how much of the area would be burned in a 

single entry. Prescribed fire managers would look closely at fuel conditions particularly in 

untreated areas to determine if applying prescribed fire across a large portion of the 

landscape is appropriate. Early in the implementation phase managers could burn 

untreated areas within a burn block under cooler conditions and treated areas under 
FEIS Appendix D – Public Comment Report Magone Project

22

Comment 

number

Source Comment Forest Service response

places like the IRA, duff in deep around 

the larger trees where they have shed 

needles and bark scales for many years, I 

fear there will be too much heat build up 

as has been the case in other similar 

areas. P.C.R.D. has great example of 

stand loss of old timber from just such an 

attempt. Prepping fairly large blocks in 

heavily managed areas of the past may be 

acceptable, but not in places such as the 

IRA. Preparing areas around the IRA 

should provide reasonable protection for it. 

Another example of burning failure 

occurred on the Emigrant R.D. a few years 

ago resulting in a catastrophic fire.

hotter conditions. Over time fuels would be reduced to a level across the entire burn 

block allowing for large scale underburning.

Within each identified burn block there would be a number of unburned acres. Examples 

include open scabby areas, wet riparian areas, and north facing slopes in general. 

Additionally, much of the area where prescribed fire would carry is expected to burn in a 

mosaic pattern for a number of reasons. Fuel moisture, shading, grazing, and lack of 

continuous fuelbeds can lead to the mosaic burn pattern often created during prescribed 

fire operations (see Figure 3 below). Another factor limiting actual burned acres is 

project design criteria limiting where active ignitions can occur within a particular burn 

block. Depending on weather conditions, fuel characteristics, and project design criteria 

(see Magone FEIS Appendix C – Project Design Criteria) the number of acres burned 

could vary from 50 to 80 percent of the proposed burn block size.

Prescribed fire managers also recognize the risk associated with burning under large 

ponderosa pine with deep duff layers. Over time needle cast and bark scale accumulate 

around the base of these trees to depths much greater than historically would have been 

present. Managers have options for addressing this issue. Burning when duff moisture is 

high, physically removing the duff by raking one year prior to implementation, or tree well 

burning are all options for reducing the impacts to large ponderosa pine with heavy duff 

accumulations.
FEIS Appendix D – Public Comment Report Magone Project

23

Comment 

number

Source Comment Forest Service response

Figure 3. Example of a mosaic underburn pattern

Table D-7. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 2 – Alternatives, Miscellaneous

Comment 

number

Source Comment Forest Service response

244 C-06, 

page 

56; C24, 

page 3

Abide by your current forest plan and 

forget your plans to amend your plan. 

Congress did not intend for Responsible 

Officials to harm resources with FP 

amendments that allow additional 

commodity output as is the case here.

Forest Plan amendments to violate 

existing Forest Plan standards must be 

dropped by not excessively logging in a 

way that would violate already weak

Forest Plan direction. We are greatly 

concerned by the cumulative effects to elk 

and deer across the Malheur National 

The regulation at 36 CFR 219.13 allows for forest plans to be amended during project 

planning in order to keep plans current or respond to changing conditions. In addition, 

the Malheur Forest Plan Forest-Wide Standard #3 states that “If it is determined during 

project analysis that the best way to meet the management area goals of the Forest Plan 

conflicts with a Forest Plan standard, the Forest Supervisor may approve a nonsignificant amendment to that standard for that project; such exceptions and the 

rationale must be described in the project’s documentation. These changes shall be 

considered an amendment to the forest plan and will be implemented only after 

appropriate public notification and satisfactory completion of all National Environmental 

Policy Act procedures” (USDA Forest Service 1990, page IV-25).

The amendment to reduce cover is being proposed to allow the non-commercial thinning 

(which would remove juniper and other conifer cover) to enhance upland shrubs, while 

still providing cover from mahogany and increasing forage. Although the habitat 
FEIS Appendix D – Public Comment Report Magone Project

24

Comment 

number

Source Comment Forest Service response

Forest from numerous timber sale/fuel 

reduction projects using Forest Plan 

amendments to violate existing standards 

for elk and deer forest cover, which is 

needed for their thermal protection from 

winter storms and summer heat and for 

hiding cover from predators, including 

human hunters. These are obviously not 

really site-specific Forest Plan 

amendments, as they are used across the 

Forest to allow for more heavy logging 

than legally allowed. These repeated 

Forest Plan amendments have significant 

cumulative effects to deer and elk 

populations across the Forest.

effectiveness index (HEI) and cover requirements are meeting or exceeding Malheur 

Forest Plan standards, cover requirements are not always compatible with the historical 

range of variability. This conflict is apparent in the Hot Dry and Warm Dry forests 

dominated by ponderosa pine in the Magone project planning area. Historical conditions 

and fire return intervals favored large blocks of trees with canopy closure too low to 

support satisfactory or marginal cover. Today, cover requirements are being met on

many ponderosa pine sites; however, stands are stocked at levels that are at a high risk 

to bark beetle attack and severe wildfires. Modeling results (FVS) suggest that cover 

levels may not be sustainable. This inherent conflict may be even more relevant in winter 

range, which is often located in low elevation, Hot Dry and Warm Dry forests dominated 

by ponderosa pine. Unfortunately, tree thinning, the treatment that most effectively 

reduces beetle and fire risk, also reduces the effectiveness of a stand as cover.

245 C-10, 

page 1; 

C-15, 

pages 

2-3

We are opposed to any commercial 

logging, noncommercial thinning, 

prescribed burning, and new trail 

construction in the Nipple Butte roadless 

area.

The alternative of not commercial logging, prescribed burning, constructing new trails in 

the Nipple Butte Inventoried Roadless Area is analyzed under alternative 1 (no action). 

Please see Magone FEIS chapter 3, Impacts to the Nipple Butte Inventoried Roadless 

Area (IRA) section.

246 C-15, 

page 1; 

C-24, 

page 1

There is an inadequate array of 

alternatives. The alternative options 

offered under the DEIS for the project are 

largely similar across the board in regards 

to what actions would take place in the 

proposed timber sale. The primary 

difference between them is that of scale, 

not that of different types of action, with 

the exception that alternative 4 does not 

allow for commercial logging and noncommercial thinning in the Nipple Butte 

roadless area. However, this alternative is 

marginally better at best. Other then that 

Alternatives 1-3 differ in the number of 

acres and million board feet. These are not 

different alternatives of actions. They are 

merely alternatives in how much of an 

action to take. Proper alternatives to an 

action should include different plans of 

forest management. In addition, there are 

The Magone FEIS documents consideration of 16 alternatives, including: the no action 

alternative, three action alternatives proposed action, and 12 alternatives considered but 

eliminated from detailed study. The alternatives considered, but eliminated from detailed 

study are rightfully considered as part of the range of alternatives considered in keeping 

with Council on Environmental Quality guidance in their document: “40 Most Asked 

Questions.” Question 1a of this document states: 1a. Range of Alternatives. What is 

meant by the “range of alternatives” as referred to in Sec. 1505.1(e)

A. The phrase “range of alternatives” refers to the alternatives discussed in 

environmental documents. It includes all reasonable alternatives, which must be 

rigorously explored and objectively evaluated, as well as those other alternatives, 

which are eliminated from detailed study with a brief discussion of the reasons for 

eliminating them. Section 1502.14. A decision maker must, in fact, consider all of the 

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

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

FSH 1909.15; Section 14:

As established in case law interpreting the NEPA, the phrase “all reasonable 

alternatives: has not been interpreted to require that an infinite or unreasonable 

number of alternatives be analyzed, but does require a range of reasonable 

alternatives be analyzed whether or not they are within the Agency jurisdiction to 

implement. (40 CFR 1502.14 (c)).
FEIS Appendix D – Public Comment Report Magone Project

25

Comment 

number

Source Comment Forest Service response

no alternatives that do not negatively 

impact the Nipple Butte roadless area.

And at FSH 1909.14.4:

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

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

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

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

technologically infeasible or illegal, or would result in unreasonable environmental 

harm.

As described in the FEIS chapter 2 the action alternatives (2, 3, and 4) vary in 

silviculture treatment type and scale, prescribed burning timing and scale, type and scale 

of recreational developments, scale of Magone Lake restoration activities, type and 

scale of road activities, and the need for forest plan amendments. Alternative 2 was 

modified in response to scoping comments; see the Magone FEIS chapter 2 alternative 

descriptions for alternatives 3 and 4 for a description of how the alternatives were

developed in response to comments.

The alternatives considered but eliminated from detailed study and the reasons for doing 

so are given in the Magone FEIS chapter 2.

247 C-15, 

page 2-

3; C24, 

page 2

I ask that all suitable habitat for Pileated 

woodpecker, Three-toed woodpecker and 

Pine marten be protected from commercial 

logging, snag felling, and prescribed 

burning—including proposed logging in 

secondary marten habitat, wildlife

corridors, Replacement Old Growth areas 

that were designated as Dedicated Old 

Growth areas before, and in general, cool 

moister mixed conifer forest and 

Lodgepole pine forest in the Magone

project area should not be commercially 

logged or prescribed burned.

The Forest Service needs to abandon its 

plans with the Magone project to “reduce 

susceptibility to fire and insect and disease 

activity” through logging and burning 

reducing naturally denser forest types (e.g. 

cool moist and “cold dry” Lodgepole pine) 

in order to protect the viability of 

Management Indicator and other species 

dependent on denser forest naturally 

subject to infrequent stand replacement 

fire, periodic insect outbreaks, and native 

tree diseases.

Habitat for pileated woodpecker, three-toed woodpecker, and pine marten were 

considered during project planning. Adequate habitat would remain on the landscape 

under the proposed action to ensure species viability at the forest scale. Please refer to 

Magone FEIS, Wildlife – Old-Growth Dependent Species section.

Please refer to comment #315 for a discussion of historic fire return intervals and the 

historical presence of naturally denser forest types in the Magone project planning area. 

Although these forest conditions would have historically only occurred in small, isolated 

patches, the Magone Project provides for denser areas in the form of wildlife corridors, 

DOGs, ROGs, PFAs, and the Nipple Butte IRA.
FEIS Appendix D – Public Comment Report Magone Project

26

Comment 

number

Source Comment Forest Service response

248 C-15, 

page 3; 

C-24, 

page 2

I also ask that if there is going to be action 

taken in near riparian areas, or actions that 

would impact riparian areas in the project

area, that these actions be specifically for 

riparian area restoration, and restoration of 

hydrologic flow.

With all these terrible stream conditions, a 

project devoted solely to stream and creek 

restoration would seem to be in order 

instead of more destructive logging and 

roading and continued livestock damage to 

these riparian areas.

Aquatic restoration activities for approximately 19 miles of Mid-Columbia River steelhead 

critical habitat have been planned for streams within the project planning area. These 

activities are covered under the Aquatic Restoration Decision and consultation which 

has already been completed. These activities include the following:

The Aquatic Restoration NEPA effort was initiated in January 2014, and the DN/FONSI 

was signed in September 2014. This decision allows activities that are consistent with 

the 17 aquatic restoration categories to be implemented following review of the activity 

with the Project Implementation Checklist to ensure the activity is consistent with the 

analysis and is within the criteria of the Aquatic Restoration Decision. The table below 

lists out the 17 Aquatic Restoration Activities covered under the Aquatics Restoration 

Decision.

Please see the following website for information on future Aquatic Restoration Projects 

on the Malheur National Forest:

http://www.fs.usda.gov/detailfull/malheur/landmanagement/?cid=STELPRD3817723&wid

th=full

Category

1) Fish Passage Restoration

2) Large Wood, Boulder, and Gravel Placement; including tree removal for large wood 

placement 

3) Dam and Legacy Structure Removal

4) Channel Reconstruction/Relocation

5) Off-and Side-Channel Habitat Restoration

6) Streambank Resoration

7) Set-back or Removal of Existing Berms, Dikes, and Levees

8) Reduction/Relocation of Recreation Impacts

9) Livestock Fencing, Stream Crossings and Off-Channel Livestock Watering

10) Piling and other Structure Removal

11) Road and Trail Erosion

12) Juniper Removal

13) Riparian Vegetation Treatment (controlled burning)

14) Riparian Vegetation Planting

15) Bull Trout Protection

16) Beaver Habitat Restoration

17) Fisheries, Hydrology, Geomorphology, Wildlife, Botany, and Cultural Surveys in 

Support of Aquatic Restoration 

249 C-17, 

page 1; 

C-23, 

page 2

We believe that there should be 

aggressive treatment of invasive weeds. 

Driving up the Beech Creek road, we see 

Invasive plant treatments are currently authorized and being implemented under the 

2015 Record of Decision for the Malheur National Forest Site-Specific Invasive Plants 

Treatment Project.
FEIS Appendix D – Public Comment Report Magone Project

27

Comment 

number

Source Comment Forest Service response

that the knapweed has become 

overbearing.

Noxious weed control-knapweed needs to 

be done.

250 C-23, 

page 3

Removal of the proposed additional Old 

Growth and Replacement Old Growth 

management area (MA13) designations. 

We find the additional MA13 designations 

unnecessary due to the extent of old 

growth and replacement old growth within 

the Riparian Habitat Conservation Area’s 

(RHCA, now called Wildlife Connectivity 

Corridors?) which, if those acres were 

counted, would meet Forest Plan 

standards for DOG, ROG and PWFA 

without needing to “designate” additional 

areas. Additionally, the planned 

silvicultural treatments will provide the 

same characteristics by moving the PAG’s 

toward and within the Management Zone 

reference communities. Therefore, an 

amendment to the Forest Plan will not be 

necessary.

The intent of the Malheur Forest Plan was that these management areas may overlap, 

but they are distinctly separate areas. Refer to the Malheur Forest Plan, Appendix G, 

Tables G6 and G7. These tables establish the designation of MA13. Often times RHCAs 

do not provide adequate habitat for old-growth dependent species for which MA13 was 

established.

251 C-24, 

page 3

Identifiable populations of cultural use 

plants and commonly used edible and 

medicinal plants should be flagged and 

buffered from ground-disturbing activities 

within sale units.

It is not feasible to identify all populations of cultural use plants and commonly used 

edible and medicinal plants within the project planning area because they are so 

widespread.

252 C-24, 

page 3

There are too many potential Magone 

project impacts to Sensitive plants and too 

many information gaps as to possible 

unknown Sensitive plant populations for 

the Forest Service to conclude that action 

alternatives would not contribute to their 

federal uplisting, especially given the long 

list of Sensitive plant species suspected to 

occur on the District and the difficulty in 

identifying or finding the Sensitive plant 

species documented to occur in the 

planning area: Bolander’s spikerush, 

Crenulate moonwort, and Least phacelia. 

Effects to sensitive plants are described in the Magone FEIS chapter 3, Botanical 

Resources section.

None of the sensitive species found in the project planning are rare throughout the 

entirety of their range or threatened on a larger scale and would not trend toward federal 

listing if affected by action alternatives as described in the effects section.

In Magone FEIS chapter 3, Botanical Resources section it is disclosed that empirical 

studies of specific sensitive plants and their local populations are not available. 

Additionally, past records of sensitive plant populations are often lacking information or 

infrequent. We rely on expert opinion and anecdotal evidence from the field to infer 

effects to sensitive species and their populations within the project planning area. 

Therefore, little specific information exists regarding changes over time in known 
FEIS Appendix D – Public Comment Report Magone Project

28

Comment 

number

Source Comment Forest Service response

There is inadequate cumulative effects 

analysis for Sensitive plants, as there is no 

information given as to changes over time 

in known Sensitive plant populations, and 

no disclosure of loss of habitat for these 

Sensitive plant species on the District or 

across the Forest. The conclusion of no 

adverse cumulative effects is unwarranted 

based on the DEIS analysis.

sensitive plant populations. Much of this information is unknown because there is a lack 

of best available science.

253 C-24, 

page 3

The effects analysis for increased potential 

introduction and dispersal of invasive 

plants is inadequate as it does not specify 

the mitigation measures used to avoid 

these impacts, the effectiveness of these 

mitigation measures, and the locations of 

known invasive plant populations relative 

to planned ground-disturbing activities.

Please refer to Magone FEIS Appendix C – Project Design Criteria for project design 

criteria relating to the introduction and dispersal of invasive plants.

254 C-29, 

pages 

13-14

We commend the Forest Service for 

looking for ways to dovetail existing 

projects such as this with the aquatic 

restoration project that is ongoing. 

However, we have significant concerns 

about the timing of these projects, as well 

as the lack of discussion of grazing 

practices.

Timing: The DEIS acknowledges that the 

aquatic restoration activities are 

“foreseeable.” In other words they will 

likely occur at some point in the future. It 

appears to us that in order to see the 

predicted long term benefit from this 

silvicultural prescription, that the aquatic 

improvements will have to already be in

place. The long term benefits arise from 

the ability of the stream to capture 

sediment behind course woody debris or 

beaver dam analogs. The highest 

sediment runoff will occur immediately 

after logging. Unless the riparian 

improvements are present, the sediment 

runoff will be nothing but loss of topsoil 

Realistically the majority of sediment generated would come from implementation of 

aquatic restoration activities such as culvert replacement, which could potentially release 

large sediment deltas built up in front of undersized culverts.

Funding for aquatic restoration activities within East Fork Beech Creek reaches 1, 3, and 

5 has already been obtained with implementation scheduled in 2017; this is well ahead

of any scheduled timber harvest.
FEIS Appendix D – Public Comment Report Magone Project

29

Comment 

number

Source Comment Forest Service response

with the potential to smother young fish. 

The DEIS acknowledges that fine 

sediment can smother Mid‐Columbia River 

steelhead redds (eggs) within the gravel 

interstitial spaces, and fill pools critical for 

juvenile rearing especially within smaller 

1st order streams. DEIS page 86.

In other words, the course woody debris, 

and beaver dam analogs need to already 

be in place, or you risk merely smothering 

Mid‐Columbia River steelhead instead of 

improving their habitat.

The impacts of the proposed actions will 

be significantly different if undertaken in 

the wrong order. Please make sure FEIS 

requires the aquatic restoration projects to 

be completed before the proposed logging 

projects can proceed. If you put a 

mechanism in place to assure the aquatic 

improvements are done first, then this is 

an appropriate analysis, and we have no 

objection.

However, if no such mechanism exists, 

you will have to analyze the impacts of 

doing the logging before the streams are 

returned to a condition in which they can 

benefit from the runoff.

NEPA requires that the impacts of the 

project be fully examined before the 

project is undertaken. This EIS only 

examines the impacts of the logging if 

done after the aquatic restoration. It does 

not even consider what the impacts might 

be if logging is done before the aquatic 

improvements are completed. Given that 

the low impact findings rely heavily on the 

existence of the aquatic restoration, it is 

imperative that the project actually be 

done in that order. If not, additional 

analysis needs to be completed.
FEIS Appendix D – Public Comment Report Magone Project

30

Table D-8. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS 

Chapter 3 – Affected Environment and Environmental Consequences

Comment 

number

Source Comment Forest Service response

300 C-03, 

page 7

Such “prescribed” burning causes 

endless air pollution which comes across 

the USA causing lung cancer, asthma, 

allergies, pneumonia, heart attacks and 

stroke.

Air quality standards require that impacts be minimized, especially in Class 1 airsheds 

and smoke sensitive areas. Mitigation measures should be used when appropriate and 

burning should be conducted in accordance with the state Smoke Management Plan 

(USDA Forest Service 1990, page IV-40).

Prescribed burning in Oregon is managed by the Oregon Department of Forestry (ODF) 

under the Oregon Smoke Management Plan (OSMP). The OSMP is intended to 

minimize smoke impacts by conducting forest burning under weather conditions that 

disperse smoke and direct smoke away from populated areas. Burning on National 

Forest System lands only occurs with prior approval granted by ODF. Wildfires tend to 

occur at the driest time of the year; therefore, fuels are more completely consumed and 

typically produce 3 to 5 times more emissions than early- or late-season prescribed fires.

Burning would follow the guidance provided by the OSMP. Emissions from pile burning 

would occur at a different time of year than the underburning. There would be short-term 

effects to communities and residences downwind and in drainages adjacent to 

prescribed fire. There would also be short-term effects along Highway 395 north, County 

roads 18 and 32, and local forest roads in the project planning area. All prescribed 

burning would comply with applicable federal, state, and local air quality regulations.

Smoke sensitive areas, including John Day (approximately 6 air miles south of the 

project planning area), Baker City (approximately 50 air miles to the northeast of the 

project planning area), and Burns (approximately 60 air miles south of the project 

planning area), may be affected by prescribed burning because of transport winds. 

However, affects are expected to be minimal because of smoke dilution over time and 

space. Weather forecasts would be obtained prior to burning to ensure these smoke 

sensitive areas would not be affected by prescribed fire smoke. Additionally, the 

Strawberry Mountain Wilderness should not be directly affected with prescribed fire 

smoke during the visibility protection periods of July 1 to September 1.

301 C-03, 

page 7; 

C-12, 

page 1

The wildlife lose their homes and their 

food sources when you burn up the place 

or log it.

A lot of wildlife will be adversely affected.

Please refer to the Wildlife Report for expected effects from proposed activities to wildlife 

species.

302 C-04, 

pages 2 

and 3

Removal of ML 2 roads that could be 

used for motorized access and changed 

to accommodate hikers and bicyclists is 

detrimental to economy boosts supplied 

by hunters, campers, and other 

recreationists who desire access to 

public lands.

There are currently 47 miles of open (ML 2 or 3) roads within the Magone project 

planning area.

Under alternative 2 approximately 2.71 miles of ML 2 road would be either closed or 

decommissioned; of that 2.71 miles, 1.4 miles (in 2 road segments) would be closed and 

co-designated as trails. One of these road segments (FSR 1800760) is located entirely 

within the Nipple Butte Inventoried Roadless Area and the other (FSR 3618125) has 

been an issue by being used to access an illegal marijuana grow site. Closure of these 

1.4 miles is unlikely to cause a detrimental economic impact; creating additional trail 
FEIS Appendix D – Public Comment Report Magone Project

31

Comment 

number

Source Comment Forest Service response

1800760 and 3618125 are ML 2 full 

length and the designation is confusing 

when closing is addressed as well as co‐

designation as a trail. Considering the 

limited number of ML2 roads remaining 

in the area, taking away access for 

motorized vehicles in order to 

accommodate a bicycle is again a 

detriment to local economy where 

hunters and other recreationists bring 

more money into the County than dirt 

bikers (per Mike Cosgrove the local 

bicycle guru).

opportunities would draw additional visitors to the area that could provide economic 

benefits.

Under alternatives 3 and 4 approximately 0.61 miles of ML 2 road would be either closed 

or decommissioned, none of which would be co-designated as trails.

303 C-06, 

page 

10-11

Modify the draft. Write believable 

environmental effects disclosures for 

wildlife based best science. Use 

reference citations not unsubstantiated 

conclusions. Explain the positive effects 

of maintaining the status quo and 

negative effects of commercial logging;

Write your effects disclosures as if you 

would be defending them in court 

knowing the plaintiff’s attorneys will 

present many science papers written by 

Ph.D. scientists with no USDA affiliation 

who are experts in the resource you are 

responsible for protecting.

Failure to do so will violate:

40 CFR § 1500.1(b) because the 

environmental information is available to 

public is not high quality and based on 

an accurate scientific analysis.

40 CFR 1500.1(b) because the analysis 

is not “accurate” and is inconsistent with 

best science.

40 CFR 1500.1(e) because without an 

accurate effects analysis the 

Responsible Official will not seek out 

other alternatives to “avoid or minimize 

adverse effects” because he/she will not 

know Townsend’s Big-Eared Bat, Pallid 

The wildlife analysis is based on over 100 peer-reviewed scientific articles; see the 

Magone Project Wildlife Report, References section.

The Magone Project does not violate 40 CFR 1500.1(b) because information was made 

available to the public and no decision has been made at this time; the EIS contains the 

necessary evidence to support the conclusions (Magone FEIS chapter 3); and 40 CFR 

1500.2(e) and (f) because the EIS contains best management practices and project 

design criteria to minimize, avoid, reduce or eliminate impacts of the proposed project.

[Note – We assume the commenter meant 40 CFR 1500.2(e) instead of 40 CFR 

1500.1(e), which does not exist.]

There are no wildlife species listed as endangered or threatened under the Endangered 

Species Act in the Magone project planning area, therefore the Endangered Species Act 

would not be violated.
FEIS Appendix D – Public Comment Report Magone Project

32

Comment 

number

Source Comment Forest Service response

Bat, and Fringed Myotis, Blue Grouse, 

Three-Toed Woodpecker, Pine Marten, 

Black-Backed Woodpecker, SilverBordered Fritillary, and Bald Eagle, and 

will be adversely affected.

40 CFR 1500.1(e) because the 

Responsible Official will not be aware 

that the quality of the human 

environment needs restoration since they 

won’t know Townsend’s Big-Eared Bat, 

Pallid Bat, and Fringed Myotis, Blue 

Grouse, Three-Toed Woodpecker, Pine 

Marten, Black-Backed Woodpecker, 

Silver-Bordered Fritillary, and Bald Eagle 

will be adversely affected.

40 CFR § 1500.1(b) and 40 CFR 

1500.2(f) because your overly optimistic 

effects disclosures would not motivate 

the Responsible Official to 1) take action 

to protect, restore, and enhance the 

environment, and/or 2) take action to 

avoid or minimize any possible adverse 

effects on the quality of the human 

environment.

Last but not least ESA will be violated.

304 C-06, 

pages 

28-33, 

40, 42-

43, and 

58

In the final NEPA document please tell 

the public why you reject the research 

conclusions of well respected Ph.D. 

scientists quoted by the commenter and 

instead accept the effects written by 

members of the interdisciplinary team 

that contradict the scientists’ findings.

Provide independent science validating 

the IDT claims that logging reduces fire 

effects or remove the IDT’s fire claims

from Chapter 3.

Failure to do so will violate 40 CFR 

1500.2(b) because no evidence is 

presented for environmental effects 

conclusions, 40 CFR 1501.2(a) because 

the environmental effects and values are 

The regulation at 40 CFR 1502.9(b), 1502.22, and 1502.24 gives direction regarding use 

of best available science. What constitutes best available science might vary over time 

and across scientific disciplines. As a general matter, the Forest Service shows 

consideration of the best available science when it insures the scientific integrity of the 

discussions and analyses in the project NEPA document. Specifically, the NEPA 

document should identify methods used, reference scientific sources relied on, discuss 

responsible opposing views, and disclose incomplete or unavailable information. Please 

see the Magone FEIS chapter 3 and the References section.

The Forest complied with 40 CFR 1500.2(b) by documenting the effects of the proposed 

project and by using appropriate references and citations throughout the document.

The regulation at 40 CFR 1501.2(a) requires the agency to “utilize a systematic, 

interdisciplinary approach which will insure the integrated use of the natural and social 

sciences and the environmental design arts in planning and in decisionmaking which 

may have an impact on man's environment.” We complied with 40 CFR 1501.2(a) by 

convening an interdisciplinary team of 17 resource specialists, and by consulting with 

other Federal, State, and local agencies.
FEIS Appendix D – Public Comment Report Magone Project

33

Comment 

number

Source Comment Forest Service response

not identified in detail, and without 

substantiating evidence for effects 

conclusions the public cannot determine 

if they are accurate and based on best 

science which violates 40 CFR 

1500.1(b).

The final NEPA document will also 

violate 40 CFR 1500.1(b) because the 

Chapter 3 environmental effects section 

written by IDT members is contrary to the 

“best science” statements written by 

hundreds of well-respected, independent 

scientists in the Opposing Views 

Attachments [provided by the 

commenter]. With this being the case, 

the agency effects disclosures are not 

“high quality” and an “accurate scientific 

analysis.”

Why do the independent scientists’ clear 

descriptions of the massive resource 

damage caused by timber sales such as 

yours not apply to the Magone sale? 

Why do you reject best science?

Opposing Views Attachment #15 

contains quotes by Hilda Diaz-Soltero, 

Dr. Ann Bartuska, Chief Dale Bosworth, 

Associate Chief Sally Collins, Chief Dr. 

Mike Dombeck, Chief F. Dale Robertson, 

Agriculture Secretary Dan Glickman, and 

USFS Chief Tom Tidwell, who all tell the 

public the USFS depends on “best 

science” as the basis for it’s projects 

How do you justify not complying?

The regulation at 40 CFR 1500.1(b) requires that “environmental information is available 

to public officials and citizens before decisions are made and before actions are taken. 

The information must be of high quality. Accurate scientific analysis, expert agency 

comments, and public scrutiny are essential to implementing NEPA. Most important, 

NEPA documents must concentrate on the issues that are truly significant to the action 

in question, rather than amassing needless detail.” The Magone Project does not violate 

40 CFR 1500.1(b) because information was made available to the public and no 

decision has been made at this time. See the Magone FEIS chapter 3 for the 

environmental effects analysis and Magone FEIS References section for the literature 

referenced in writing the effects.

305 C-06, 

page 33

The final NEPA document also violates 

40 CFR 1502.24 because the 

Responsible Official did not identify in a 

footnote the methodologies and scientific 

sources relied upon for discussions of 

effects described in Chapter 3.

The regulation at 40 CFR 1502.24 states that “Agencies shall insure the professional 

integrity, including scientific integrity, of the discussions and analyses in environmental 

impact statements. They shall identify any methodologies used and shall make explicit 

reference by footnote to the scientific and other sources relied upon for conclusions in 

the statement. An agency may place discussion of methodology in an appendix.” The 

methodologies used by each resource specialist are disclosed in a Methodology section 

under each resource section in the Magone FEIS chapter 3.
FEIS Appendix D – Public Comment Report Magone Project

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306 C-10, 

page 2

Commercial logging has many impacts 

that are not considered fully.

The effects of commercial harvest are disclosed in the Magone FEIS chapter 3.

307 C-10, 

page 2; 

C-13, 

page 1; 

C-15, 

page 2; 

C-22, 

page 1; 

C-24, 

pages 1 

and 2

We believe the timber sale will eliminate 

important habitat for snag dependent 

species like three-toed and pileated 

woodpeckers and marten.

I am also concerned about the impacts to 

management indicator species, 

specifically that of Pileated Woodpecker, 

Three-toed Woodpecker, and Pine 

Marten. Each of these species were

selected to represent the habitat needs 

of many other species. All three of these 

Management Indicator species are now 

considered vulnerable by the Oregon 

Department of Fish and Wildlife. There is 

not much suitable habitat for these 

species in the project area and yet the 

project still plans on logging, snag 

removal, and prescribed burning which is 

harmful to specific habitat needs of these 

species. In addition, the forest service's 

perspective on whether this project 

would impact these species on a region 

wide level is far too narrow. It looks only 

at this particular project. It doesn't take 

into account the cumulative impacts of all 

the other projects in the area. When 

looking solely at one project you are not 

likely to see the larger impacts if you are 

not looking at all the other projects as 

well. In this way the habitat needs of 

critical, threatened, and endangered 

species are slowly eroded with every 

project that degrades the availability of 

their specific habitat niches. Only in

looking at forest wide impacts to species 

and habitats, and in looking at historic 

availability of said habitats can one 

determine whether a practice is 

impacting a habitat or species.

Snags would not be targeted for removal unless they are identified as a safety hazard; 

hazard snags felled will be left on site and stumped as high as possible to alleviate the 

safety hazard. Many snags would be retained under this project; however, it is not 

possible to retain every tree meeting this description.

The effects to snag dependent species are analyzed with help from the DecAID Dead 

Wood advisory tool. Tolerance levels for a sample of those species are displayed in 

figures in the Primary Cavity Excavators section of the Wildlife Report. See also Magone 

FEIS chapter 3, Wildlife section.

Viability for MIS species, including those cavity excavators mentioned, is examined on a 

Forest-wide scale. Direct and indirect effects of proposed activities on those species is 

analyzed on a project-level scale. Cumulative effects of past, present and reasonably 

foreseeable future actions are also discussed in the Wildlife Report.
FEIS Appendix D – Public Comment Report Magone Project

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We are very concerned by unspecified 

acreage quantities of logging eliminating 

suitable habitat for Pileated 

woodpeckers, Three-toed woodpeckers, 

and American martens (aka “Pine 

martens”), all of whom were selected to 

represent the habitat needs of many 

other species.

308 C-10, 

page 2

Most alternatives will violate elk and deer 

summer/winter range standards.

Forest plan amendments are proposed under alternatives 2 and 3 to allow the noncommercial thinning (which would remove juniper and other conifer cover) to enhance 

upland shrubs, while still providing cover from mahogany and increasing forage. 

Although the habitat effectiveness index (HEI) and cover requirements are currently 

meeting or exceeding Malheur Forest Plan standards, cover requirements are not 

always compatible with the historical range of variability. This conflict is apparent in the 

Hot Dry and Warm Dry forests dominated by ponderosa pine in the Magone project 

planning area. Historical conditions and fire return intervals favored large blocks of trees 

with canopy closure too low to support satisfactory or marginal cover. Today, cover 

requirements are being met on many ponderosa pine sites; however, stands are stocked 

at levels that are at a high risk to bark beetle attack and severe wildfires. Modeling 

results (FVS) suggest that cover levels may not be sustainable. This inherent conflict 

may be even more relevant in winter range, which is often located in low elevation, Hot 

Dry and Warm Dry forests dominated by ponderosa pine. Unfortunately, tree thinning, 

the treatment that most effectively reduces beetle and fire risk, also reduces the 

effectiveness of a stand as cover.

309 C-10, 

page 2; 

C-13, 

page 1; 

C-22, 

page 1; 

C-24, 

page 1

Most alternatives will fragment wildlife 

habitat, including in an Inventoried 

Roadless Area and in other areas never 

logged or roaded before.

Connectivity corridors were designed to provide wildlife movement and permeability 

across the project planning area. These corridors would also connect to adjacent past, 

present, and future planning areas to provide the same connectivity across the 

landscape, and avoid fragmenting currently intact habitats. The effects of proposed 

activities under each alternative is discussed in the Wildlife Report.

310 C-10, 

page 2; 

C-11, 

page 2; 

C-14, 

page 2; 

C-15, 

page 1

Most alternatives will affect the integrity 

of an inventoried Nipple Butte roadless 

area.

Roadless areas provide a crucial and 

vital role for many species. Specifically 

roadless areas create intact blocks of 

wildlife security habitat for far-ranging 

predators and scavengers such as 

marten, wolverine, Gray wolves, Canada 

See Magone FEIS chapter 3, Impacts to the Nipple Butte Inventoried Roadless Area 

(IRA) and Wildlife sections.

The 2001 Roadless Area Conservation Rule identifies mountain biking as an acceptable 

use in the “Roadless Area Values and Characteristics” section.

See response to comment #309
FEIS Appendix D – Public Comment Report Magone Project

36

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lynx, and Pacific fisher, who are also all 

vulnerable to impacts from human

disturbance, trapping access, and/or 

logging fragmentation and removal of 

needed forest structure such as large 

snags and abundant down wood. Habitat 

fragmentation has been cited as one of 

the leading causes of species extinction 

across the globe. I am not claiming that 

this project will cause species to go 

extinct. What I am claiming is that most 

species need intact habitats. That habitat

fragmentation starts with roads. Roads 

allow industrial access to areas 

otherwise inaccessible to industry. We 

need areas that are wholly intact. We 

need stretches of forest that don't have 

roads, that aren't bisected and crossed 

continually by roads. In addition roadless 

areas play a significant though often 

overlooked social role. They allow for 

recreation opportunities where one can 

truly get lost in nature. They are an 

opportunity for humans to remember 

what an intact forest is like.

Mountain bike and hiking trail 

construction that encroaches into an 

inventoried roadless would violate the 

pristine environment and would not be a 

step to protect wildlife and restore the 

landscape. Trails such as this are no 

different from road construction and 

disturbance to wildlife and natural 

environment would not vary significantly.

311 C-10, 

page 2

Commercial logging is permitted on NF 

lands, but only if the benefits outweigh 

the negatives. The FS has failed to fully 

consider the negatives. For instance, 

logging removes biomass. All biomass is 

critical to the forest ecosystem. Green 

trees provide shade, thermal and hiding 

The impacts from commercial logging (including adverse effects) are analyzed and 

disclosed in the Magone FEIS chapter 3. In particular, see the Soils, Aquatic Species, 

and Wildlife sections.
FEIS Appendix D – Public Comment Report Magone Project

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habitat for some wildlife, etc. as well as 

store carbon.

However, even dead trees serve many 

purposes. More than half of all wildlife 

species depend on dead trees at some 

point in their life cycle. Dead trees store 

carbon. Dead trees provide structural 

component to streams when they call 

into waterways providing habitat for fish. 

Dead trees store nutrients. Dead trees 

still provide cover both hiding and 

thermal for wildlife.

312 C-10, 

page 2

The proposal fails to put into context the 

proposed timber sale with all the other 

timber sales proposed on the forest for 

cumulative effects.

Other projects with a silviculture treatment component are discussed in the cumulative 

effects section throughout the Magone FEIS chapter 3. In particular, the Galena, 

Balance, Soda Bear, 18 Road, Big Mosquito, and Camp Lick projects on the Blue 

Mountain Ranger District. In addition, the Upper Pine, Dove, Flat, and Summit projects 

on the Emigrant Creek and Prairie City ranger districts are also discussed.

313 C-10, 

pages 

2-3; C15, 

page 2

The plan ignores the on-going and past 

effects of livestock grazing on streams 

and meadows. Many of the streams have 

widen channels and many suffer from a 

loss of woody vegetation due to livestock 

grazing. Many streams exceed water 

temperature standards, and increased 

logging, as well as the on-going livestock 

grazing will continue to negatively impact 

fisheries. For instance, East Fork Beech 

Creek remains on the Clean Water Act 

303 (d) list for bio-criteria, indicating that 

the populations of macroinvertebrates 

there are not as diverse as would be 

expected.

FS acknowledges this in the DEIS. “Fish 

habitat in the analysis area generally 

does not meet Malheur Forest Plan 

desired conditions... and riparian 

management objectives...for pool 

frequency, large woody debris.., 

sediment, temperature, and width-todepth ratio....Most streams in the 

analysis area are in a highly altered 

Allotment management is outside of the scope of this project. Ongoing and past effects 

of livestock grazing can be found in the Aquatics Report. Additional information relating 

to livestock grazing within the project planning area can be found in the Range Report. 

Annual data relating to livestock grazing within the project planning area can be found in 

the Malheur National Forest’s webpage 

(http://www.fs.usda.gov/wps/portal/fsinternet/!ut/p/c4/04_SB8K8xLLM9MSSzPy8xBz9CP

0os3gDfxMDT8MwRydLA1cj72BTMwMTAwjQL8h2VAQArb-

_RA!!/?ss=110604&navtype=BROWSEBYSUBJECT&cid=STELPRDB5337894&navid=1

30120000000000&pnavid=130000000000000&position=Project*&ttype=projectdetail&pn

ame=Malheur National Forest- Resource Management).

The Magone Project would improve riparian habitat by increasing water storage for 

gradual release; changes in hillslope and upland vegetation are the primary limiting 

factors for aquatic dependent species within the Magone project planning area in 

regards to activities proposed within the Magone FEIS. In particular conifer/juniper 

reduction treatments in the Nipple Butte IRA and Wildlife Emphasis Area would benefit 

both aquatic species and wildlife. Conifer treatments would influence peak flows and 

baseflows through altering hydrologic pathways of snow redistribution, snow retention 

and depth, transpiration losses, and evaporative losses of water going from the 

branches back to the atmosphere. The largest effect of reducing juniper and conifers is 

an increase in ground cover (sedges and grasses) promoting infiltration and the change 

in transpiration. Mature junipers have been known to consume up to 35 gallons of water 

per day. This water would likely contribute to larger amounts of base flows or decrease

the days or miles of stream that goes dry per year which is a common theme for streams 

within the Magone project planning area.
FEIS Appendix D – Public Comment Report Magone Project

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state, with conditions of important habitat 

elements strongly limiting quality of fish 

habitat." (DEIS p. 299)

Despite these acknowledged problems, 

the proposal does little for improving the 

riparian habitat, nor does it consider 

removing livestock as the quickest and 

best alternative to restore these streams. 

Instead it permits the continued 

degradation of the public’s lands for 

private gain by area ranchers.

In addition, projects could be implemented under the Aquatic Restoration Decision in the 

planning area including: fish passage restoration, large woody debris placement, 

reduction of lodgepole pine encroachment into riparian areas, juniper removal, log weir 

and boulder modification, legacy structure removal, reduction of recreation impacts and 

road erosion control, off-channel livestock watering facilities, and riparian vegetation 

(hardwood) planting.

314 C-10, 

page 3

The FS is proposing to remove conifers 

around aspen while it acknowledges the 

major influence affecting aspen 

regeneration is ungulate browsing. 

Instead of removing livestock and 

reducing elk numbers, the FS proposes 

logging. Aspen, in particular, response to 

high severity fire. It is hard to take the FS 

seriously about it’s tears over aspen. 

Instead of promoting stand replacement 

high severity fires which would benefit 

aspen and reducing livestock and elk 

browsing the FS attempts to deal with 

the issue by spending tax dollars to 

manipulate aspen stands through conifer 

removal. Wildfire can do this for us and 

do it for free. But even if conifers are 

removed, if the ungulate browsing 

continues, there will be little actual 

recruitment of new aspen.

Thank you for your comment. While aspen do respond to high severity fire, most aspen 

stands in the Blue Mountains did not historically develop from this fire regime. Most 

aspen stands in the Blue Mountains historically experienced frequent, low-severity 

underburns (Swanson et al. 2010), are small, discrete stands, and only exist in wet 

areas such as seeps, springs, RHCAs, and along meadow environments. In the Magone 

project planning area the combination of fire suppression, heavy browsing, conifer 

encroachment, and lowering of the water table has reduced aspen survival. Aspen 

studies in Oregon found that the most successful treatments to restore aspen stands 

include removing competing conifers from the stands and releasing them from herbivory 

(Seager et al. 2015). Removing conifers is important to stimulate aspen suckering 

because it increases the availability of light, moisture, and nutrients. Aspen are shade 

intolerant species that need moisture late into the growing season. Release of moisture 

through removing competing conifers increases sprout density and overstory persistence 

(Seager et al. 2015). The Magone Project proposes the approach of removing 

competing conifers and releasing stands from herbivory. This would be accomplished 

through mechanical treatments, fencing, and prescribed burning.

315 C-10, 

pages 

3-4

The FS proposes to do prescribed 

burning and logging in lodgepole pine 

and mixed conifer forests. Both of these 

forest types tend to have long fire 

rotations, and when they burn, by 

definition they tend to burn at mixed to 

high severity fires.

Most of this is assumption of wide spread 

open park like forests is based on a few 

fire scar studies that covered small 

The design of the Magone Project has been informed by site-specific dendroecological 

reconstructions of forest structure, composition, and fire disturbance in the north end of 

the forest conducted by James Johnston of Oregon State University. Forest Service 

personnel also reconstructed fire histories in the Big Mosquito planning area to the north 

of the Magone project planning area. None of these investigations found any evidence 

that mixed conifer forests or lodgepole pine forests historically experienced significantly 

longer fire return intervals than other forest types on the Malheur National Forest. Mean 

fire return intervals on mixed conifer sites on the north end of the forest, including sites 

within the Magone planning area, ranged from 11.8 to 20.2 years. All stands planned for 
FEIS Appendix D – Public Comment Report Magone Project

39

Comment 

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sample areas. These study suffer from 

inherent biases including non-random 

sampling, composite fire scars, and lack 

of large scale geographical coverage. 

(See discussion on problems in sampling 

in Baker Fire Ecology in Rocky Mountain 

Landscapes 145-161) By contrast, 

Williams and Baker 2012 used GLO 

survey notes that extended over large 

landscapes that recorded the forest 

composition and structure in the years 

before wide-spread European American 

settlement (1880s) thus present a more 

reasonable review of forest composition.

The FS is supposed to use the latest and 

best science and the fact that Williams 

and Baker’s work on the Blue Mountains 

fire regimes is not even mentioned in the 

references demonstrates a bias towards 

science that seems to confirm the FS 

bias towards logging.

Applying ideas low severity/frequent fire 

regimes and arguing that fire 

suppression has led to increased tree 

density, etc. is wrong.( See Williams and 

Baker Global Ecology and Biogeography, 

(Global Ecol. Biogeogr.) (2012)

Many of these forest types have not 

missed a single fire rotation due to the 

long fire frequency and thus are not 

outside of any historic condition. Indeed, 

their normal fire response is to have high 

severity fire at least in some portion of 

these vegetation types.

Indeed Williams and Baker’s study which 

is the only EXTENSIVE fire study done in 

the Blue Mountains found that only 40% 

of the forest appeared to be 

characterized by low severity fire, while 

43.2% was mixed severity and 16.5% 

was high severity.

treatment have missed at least 3 and usually 4 to 10 fire cycles since fire was excluded 

circa 1880 to 1900.

Almost all lodgepole pine in the Magone project planning area established after fire 

exclusion at the end of the 19th century and the current extent of lodgepole exceeds 

historical or future sustainable conditions.

There is very little or no evidence of extensive high severity fire in the Magone project 

planning area. Evidence of high severity fire would include the lack of large old growth 

overstory trees, but almost all sites that have not been logged within the Magone project 

planning area have extensive cohorts of 300+ year old ponderosa pine or western larch 

that are currently threatened by uncharacteristic fire effects from fires burning through 

extensive surface and ladder fuels. Current forest structure has little or no historical 

analog.

The fire history studies conducted on the Malheur National Forest address the sampling 

issues alluded to in this comment. Johnston’s fire histories covered a large geographic 

area (1.7 million acres) in randomly selected sites. Fire return intervals calculated by 

compositing samples were little different from other methods of calculating fire return 

intervals. His results are consistent with other published fire histories on the Malheur 

National Forest studies including Heyerdahl 2008 and 2001.

Williams and Baker’s 2012 study is not the only extensive fire study of the Blue 

Mountains (see Heyerdahl 2001 and 2008). On the contrary, unlike other spatially 

extensive studies of historical fire in the Blue Mountains, Williams and Baker do not 

actually present any evidence of historical fire patterns beyond observations of the 

species of individual trees recorded by surveyors. Williams and Baker’s work has been 

severely criticized by scientists for unsupported inference about historical fire (see, for 

instance, Fulé et al. 2014). All of the assumptions about historical forest conditions made 

by the Magone FEIS are consistent with observations recorded in GLO surveyor notes, 

which are publicly available at https://www.glorecords.blm.gov/default.aspx. Williams 

and Baker’s 2012 study estimates forest structure and composition based on GLO 

survey notes recorded for sites that were primarily on the Umatilla and Wallowa 

Whitman National Forests, well north of the Magone project planning area.

DellaSalla and Hansen’s book criticizes fuel reduction treatments and suggests that 

mixed severity and high severity fire was the norm for most of the American west, but 

they present no data that is pertinent to the Magone planning area, or that calls into 

question the extensive body of science relied on to plan treatments in the Magone 

project planning area. Consequently, the Forest Service has chosen to rely instead on 

site-specific data gathered from the Malheur National Forest and the Magone planning 

area.

Fulé, P.Z., T.W. Swetnam, P.M. Brown, D.A. Falk, D.L. Peterson, C.D. Allen, and R.E. 

Keane. 2014. Unsupported inferences of high‐severity fire in historical dry forests of the 
FEIS Appendix D – Public Comment Report Magone Project

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Williams and Baker conclude.” The 

evidence concludes that forests thought 

to have been open and park-like (i.e. < 

100 trees ha-1) instead had higher 

historical mean tree densities and large 

areas of dense trees (Fig. 2). Second, 

shade-tolerant firs, considered 

historically uncommon in dry forests 

(Keane et al., 1990; Hann et al., 1997), 

were common.”

They found that only 23% of the Blue 

Mountains (which includes the area of 

this project) had open forests of less than 

100 trees per ha and that large expanses 

of higher density occurred.

Nor is Dellasalla and Hansen’s new book 

on Mixed Severity Fire in the references. 

A summary of their findings can be found 

here: Large Infrequent Fires Are 

Essential to Forest Dynamics and 

Biodiversity in Dry Forests of Western 

North America

file:///C:/Users/office/Downloads/dellasal

ahansonfire2015.pdf

western United States: response to Williams and Baker. Global Ecology and 

Biogeography 23(7): 825-830.

316 C-10, 

pages 

4-5

The DEIS says the purpose of this 

proposal is to provide for local 

employment in the timber industry. But 

the DEIS fails to analyze and disclose 

how much each of these timber jobs 

costs taxpayers directly, as well as the 

indirect costs. I.e. when logging 

degrades elk winter range or new roads 

creates sedimentation in streams or 

weeds flows along logging roads and 

disturbed habitat, or soils are compacted 

by logging equipment and/or livestock 

and thus less able to store water, and the 

loss of carbon thus reducing the ability of 

the forest to store carbon, etc.

If these costs were fully accounted, it 

quite possible that providing jobs in the 

The Malheur Forest Plan includes forest-wise management goals to:

 Provide a sustained flow of timber for lumber, fiber, and/or associated wood 

products at a level that will contribute to economic stability, while providing for 

regional and national forest management

 Contribute to the social/economic health of communities, which are significantly 

affected by national forest management. 

 Provide an economic return to the public. 

 Provide and utilize wood fiber in the form of sawtimber, fiber, and/or associated 

wood products, while minimizing losses and maximizing outputs in a costeffective manner, consistent with the various resource objectives and 

environmental standards. 

A comprehensive effects analysis on the physical, biological, social, and economic 

environments can be found in the Magone FEIS chapter 3. Project design criteria (PDC) 

can be found in Magone FEIS Appendix C – Project Design Criteria, PDCs serve to 

mitigate impacts to activities on resource areas, in addition to best management 

practices and legal requirements.
FEIS Appendix D – Public Comment Report Magone Project

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local timber industry is negatively 

impacting the overall ability of the forest 

to provide for national interests. These 

are national lands, and the resources 

there upon do not belong to John Day or 

citizens of even Oregon. The FS is 

mandated to manage these forests for 

NATIONAL interests, not local parochial 

interests, particularly private business 

interests.

In fact, it might be less expensive to 

simply give every timber worker a pay 

check than to log the forest if all costs 

were truly considered.

317 C-11, 

page 2

The economic benefit of trail construction 

would be marginal compared to the 

construction costs and benefit to local 

businesses. I quote Mr. Mike Cosgrove, 

a bicycle enthusiast in a local newspaper 

item: “Cross country cyclists spend little 

money, but touring groups spend big 

bucks....”

We plan to join a partnership with the Grant County Chapter of COTA for trail 

construction and maintenance costs.

318 C-13, 

page 1; 

C-22, 

page 1; 

C-24, 

page 1

This sale will threaten creek water flows 

for steelhead, redband, and westslope 

cutthroat trout.

Water storage for gradual release, changes in hillslope, and upland vegetation are the 

primary limiting factors for aquatic dependent species within the Magone project 

planning area in regards to activities proposed within the Magone FEIS. In particular 

conifer/juniper reduction treatments in the Nipple Butte IRA and Wildlife Emphasis Area 

would benefit both aquatic species and wildlife. Conifer treatments would influence peak 

flows and baseflows through altering hydrologic pathways of snow redistribution, snow 

retention and depth, transpiration losses, and evaporative losses of water going from the 

branches back to the atmosphere. The largest effect of reducing juniper and conifers is 

an increase in ground cover (sedges and grasses) promoting infiltration and the change 

in transpiration. Mature junipers have been known to consume up to 35 gallons of water 

per day. This water would likely contribute to larger amounts of base flows or decrease

the days or miles of stream that go dry per year which is a common theme for streams 

within the Magone project planning area.

In addition, projects would be implemented under the Aquatic Restoration Decision in 

the planning area including: fish passage restoration, large woody debris placement, 

reduction of lodgepole pine encroachment into riparian areas, juniper removal, log weir 

and boulder modification, legacy structure removal, reduction of recreation impacts and 

road erosion control, off-channel livestock watering facilities, and riparian vegetation 
FEIS Appendix D – Public Comment Report Magone Project

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(hardwood) planting. This work would occur over the next 10 years on approximately 19 

miles of stream.

319 C-14, 

page 2

The current maintenance and use levels 

of existing trails does not support the 

Forest’s proposed trail expansion offered 

in Alternative 2 or 3. The Forest has not 

examined or analyzed the existing use 

levels to make an informative decision 

regarding an elevated need to construct 

up to 96 more miles of trails. Just 

because a handful of people voice 

interest in having new mountain bike 

trails should not compel the Forest to 

make this type of large investment and 

ecological impact in disregard for 

collecting and analyzing credible data to 

support such a decision.

The existing trails outside the Magone 

Lake Recreation Area are currently in 

disrepair and full of blow down trees, 

making it difficult for foot, bicycle, or 

horseback travel. No effort to clear or 

maintain these trails has been seen by 

us in three years, so how can one expect 

Forest to adequately maintain any

additional trails when these existing 

deficiencies remain unaddressed. The 

Forest should work to maintain what they 

have before increasing the number of 

trails.

The Forest will be looking at the existing bike trails in the Forest Recreation Strategy for 

future trails, which ones to maintain and which ones that could be removed from the trail 

system. The bike trails around Magone Lake are being incorporated into the new trail 

system in alternative 2 or 3.

320 C-15, 

page 2; 

C-24, 

pages 

1-2

With the Malheur being a high desert 

forest, and Eastern Oregon in general 

being predominantly a dry environment, 

water is of paramount concern. In this 

project in particular I am concerned 

about potential impacts to hydrologic 

flows of steelhead and cutthroat trout. 

Specifically East Fork Beach Creek, 

historically a year-round flowing creek, 

now goes almost completely dry by midJuly, with only disconnected small pools 

Thank you for your comment: Commercial removal of trees within RHCAs is not 

proposed with the Magone Project. We too are concerned about hydrological flows 

within the project planning area. Aquatic restoration actions (covered under the Aquatic 

Restoration Decision) are planned for approximately 19 miles of Mid-Columbia River 

steelhead critical habitat and involve actions that enhance water storage within the 

project planning area and reconnects floodplains as well as restore beaver habitat.

Water storage for gradual release/changes in hillslope and upland vegetation are the 

primary limiting factors for aquatic dependent species within the Magone project 

planning area in regards to activities proposed within the Magone FEIS. In particular 

conifer/juniper reduction treatments in the Nipple Butte IRA and Wildlife Emphasis Area 

would benefit both aquatic species and wildlife. Conifer treatments would influence peak 
FEIS Appendix D – Public Comment Report Magone Project

43

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of water. This creek is an important 

waterway for steelhead and cutthroat

trout, who use it to access smaller 

streams to spawn in. I am concerned that 

further logging in this area, will further 

degrade the hydrologic flow by removing 

shading and moisture retention. This

could result in further drying out of major 

creeks and the loss of fish runs 

altogether in the project area, especially 

in combination with climate change.

flows and baseflows through altering hydrologic pathways of snow redistribution, snow 

retention and depth, transpiration losses, and evaporative losses of water going from the 

branches back to the atmosphere. The largest effect of reducing juniper and conifers is 

an increase in ground cover (sedges and grasses) promoting infiltration and the change 

in transpiration. Mature junipers have been known to consume up to 35 gallons of water 

per day. This water would likely contribute to larger amounts of base flows or decrease

the days or miles of stream that goes dry per year which is a common theme for streams 

within the Magone project planning area.

321 C-15, 

page 2

Due to past logging, road building and 

cattle grazing, many of these streams 

are deficient in the large woody debris 

needed to form pools for fish habitat.

Water temperatures in at least five 

perennial streams are in violation of state 

water temperature standards to protect 

fish species viability. Substrate

embededness and fine sediment 

objectives are not being met on many 

stream reaches of five major creeks. 

East Fork Beech Creek remains on the 

Clean Water Act 303 (d) list for 

biocriteria, indicating that the populations 

of macroinvertebrates there are not as 

diverse as would be expected. One

would think that with all of the hardships 

these streams and creeks have already 

endured the only projects proposed 

would be that of riparian restoration 

projects. Yet this project would further

threaten these critical riparian habitats.

Thank you for your comment: Water storage for gradual release/changes in hillslope and 

upland vegetation are the primary limiting factors for aquatic dependent species within 

the Magone project planning area in regards to activities proposed within the Magone 

FEIS. In particular conifer/juniper reduction treatments in the Nipple Butte IRA and 

Wildlife Emphasis Area would benefit both aquatic species and wildlife. Conifer 

treatments would influence peak flows and baseflows through altering hydrologic 

pathways of snow redistribution, snow retention and depth, transpiration losses, and 

evaporative losses of water going from the branches back to the atmosphere. The 

largest effect of reducing juniper and conifers is an increase in ground cover (sedges 

and grasses) promoting infiltration and the change in transpiration. Mature junipers have 

been known to consume up to 35 gallons of water per day. This water would likely 

contribute to larger amounts of base flows or decrease the days or miles of stream that 

goes dry per year which is a common theme for streams within the Magone project 

planning area.

In addition, projects would be implemented under the Aquatic Restoration Decision in 

the planning area including: fish passage restoration, large woody debris placement, 

reduction of lodgepole pine encroachment into riparian areas, juniper removal, log weir 

and boulder modification, legacy structure removal, reduction of recreation impacts and 

road erosion control, off-channel livestock watering facilities, and riparian vegetation 

(hardwood) planting. This work would occur over the next 10 years on approximately 19 

miles of stream.

322 C-15, 

page 2

Also of concern is the impacts this 

project would likely have on Goshawk 

post-fledging areas (PFA). Goshawk's 

are very susceptible to human 

disturbance, specifically in their nesting

habitat and may abandon a nest entirely 

if there is too much repeated disturbance 

by humans. In addition, goshawk's need 

Please refer to the Featured Species section of the Wildlife Report to review the 

anticipated effects to northern goshawks and their habitat in the Magone project 

planning area. Anticipated effects from increased human disturbance and vegetation and 

canopy complexity are specifically addressed.
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a multilayered canopy structure for 

hunting and foraging. I am concerned 

that this project will reduce the canopy 

complexity, and multilayered canopy 

structure in the project area, thereby 

further degrading goshawk habitat.

323 C-16, 

pages 2 

and 3

RMEF does not believe the big game 

disturbance impact of the proposed 

increase in trail development in action 

Alternative 2, 3 and 4 was analyzed 

using best science as required by NEPA.

Recent science developed and published 

by the USFS Starkey research station 

and cited in the DEIS and in the Wildlife 

Specialist’s Report clearly indicates 

extreme levels of big game displacement 

by human foot traffic, trail bikes, and off 

road vehicles. This begs the question,

why was the impact of trail disturbance 

on big game habitat utilization not 

analyzed in the DEIS? The USFS 

Starkey station has published research 

regarding the employment of a technique 

called distance band analysis to evaluate 

wildlife displace by disturbance factors. 

We strongly suggest use of the distance 

band analysis technique for the analysis 

of big game disturbance/displacement.

Starkey research was reviewed and cited in the document under the Rocky Mountain elk 

section of the Wildlife Report. Specifically, the second paragraph under “recreation 

opportunity improvements” starts with “Wisdom et al. (2005) found that mountain bikes 

caused flight responses (disturbance and displacement) in elk and mule deer.” The 

analysis of the expected effects of trails on elk relied on data gleaned from the Wisdom 

et al. 2005 research from the Starkey Experimental Forest. If other research is published 

from the Starkey research station specifically related to disturbance from mountain bike 

recreation, the team was not aware of it.

Further, a distance band analysis was conducted and reviewed as part of proposed road 

activities, however the distance band method was not modified and conducted to 

analyze the effects of the proposed mountain bike trails.

324 C-16, 

pages 2 

and 3

Unacceptable impacts to the big game 

resource will likely occur from 

disturbance resulting from new trail 

development at levels proposed in 

Alternative 2 (54 miles) or Alternative 6 

(96 miles).

The DEIS clearly indicates the entire 

Magone project area is classified as 

either winter or summer big game range, 

and that both elk and deer are present in 

the project area. Elk are designated in 

the Malheur Forest Plan as a 

management indicator species. Trail 

The proposed trail activities and their expected effects to elk are analyzed under the 

Rocky Mountain elk section of the Wildlife Report, including those specific to winter 

range, summer range, disturbance/displacement, and forage.
FEIS Appendix D – Public Comment Report Magone Project

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disturbance of big game, though not 

definitively analyzed as required by 

NEPA, is acknowledged in the DEIS’s 

Wildlife Section and in the Wildlife 

Specialist’s Report to be sufficient to 

displace big game from the project area 

and potentially impact big game 

reproduction. This is a big concern to 

RMEF as displacing elk from public land 

to adjacent private land will only make a

current problem worse. While the elk 

population is over objective, many of 

those elk are on private property causing 

damage to growing and stored crops and 

most are not available to hunters in the 

fall to help reduce the population. The 

restoration could go a long ways to help

redistribute elk to public lands but that 

simply will not happen with the proposed 

new trail development.

325 C-17, 

page 1; 

C-23, 

page 2

The building of bike trails are very 

disruptive not only to the ecosystem, but 

to the wildlife and cattle.

Recognize that the planned recreation 

bike/hiking trails will conflict with existing 

uses (IRA, wildlife security, historical 

grazing).

Impacts of building bike trails are analyzed and disclosed in the Range, Wildlife, and 

Impacts to the Nipple Butte Inventoried Roadless Area (IRA) sections of the Magone 

FEIS chapter 3. Please review individual sections to review the effects to sensitive 

species, management indicator species, featured species and landbirds.

326 C-18, 

page 1

Will there be any extending or 

construction of trails in any areas of 

sensitive soils and/or slopes? If so, how 

many are there and where are they 

located? What is being done to deal with 

these sensitive situations?

Proposed trail locations cross numerous areas of highly erodible soil. Standard trail 

construction and maintenance practices, such as grade reversals and outsloping, are 

expected to adequately control erosion and sediment production.

327 C-18, 

page 1

Do you have a history of fire in the Nipple 

Butte IRA? If so, what is that source and 

concerning origination of fires do they 

mostly start in the IRA and move outward

or do they start on the out-side of the IRA 

and burn inward? How has this been 

No recorded fire has burned across the IRA boundary since fire suppression began 

100+ years ago. Several fires have started near the boundary of the IRA, however, the 

majority of them were contained at less than 1 acre in size. The largest recorded fire 

occurring within the IRA was contained at approximately 24 acres and occurred in the 

southwest corner of the IRA. Geographic Information System (GIS) data indicates that 

fires in the planning area occur at a rate of 1.26 fires/1,000 acres/decade. This same 
FEIS Appendix D – Public Comment Report Magone Project

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considered in preparation for this 

project?

data indicates that fires occur at a rate of 1.00 fire/1,000 acres/decade within in the IRA. 

Areas that have a fire start every 1 to 10 years are considered to have a high fire risk.

The absence of a larger scale fire disturbance over the last 100 years has allowed 

surface fuels to accumulate within the IRA and the remainder of the planning area. 

Predicting where a fire may start is essentially impossible, but regardless of whether one 

starts inside or outside the IRA the potential for the area to succumb to a high severity 

wildfire is of great concern should fuels treatments not be completed.

328 C-18, 

page 3

Was an analysis of the economic and 

social impact on the small communities 

as required by “the Regulatory Flexibility 

Act” done to the extent necessary to 

make a decision? If so, please can we 

see the report and if not, why not? Was 

the data used local data? What were the 

data sources? What was the outcome?

The Regulatory Flexibility Act requires federal agencies to consider the impact of 

regulations on small entities (i.e., small businesses) in developing proposed and final 

regulations; regulations are developed at the national level and are outside the scope of 

the Magone Project.

The Magone Project does follow current applicable regulations. An Economic Report 

was prepared for the Magone Project and is located on the Forest’s website 

(http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558

/www/nepa/99358_FSPLT3_2718792.pdf). This analysis is also summarized in the 

Magone FEIS chapter 3, Level and Effects of Silviculture Treatments section. The 

preliminary value of timber removed is based on sales sold within Appraisal Zone 3 

(primarily Blue Mountain forests) within the last 12 months. As stated in the Economic 

Report, the amount of local economic activity would be determined by whether the 

purchaser of any timber sales that come out of the Magone Project are purchased by a 

local or distant purchaser, which mill(s) get the lumber, and the price of the lumber. See 

also the Magone FEIS chapter 3, Other Required Disclosures, Environmental Justice 

section. The data used in this section is from the American Community Survey data for 

Grant and Harney counties.

329 C-19, 

page 2

The forest desperately needs dedicated 

OHV trails, however they must be 

carefully located so as not to disturb and 

provide additional impacts to livestock 

and wildlife in the area. Ranchers pay to 

utilize the National Forest for grazing and 

OHV use will need to be seasonally 

managed so as not to disrupt that use.

The Forest is managed for multiple uses and acknowledges that several uses may 

overlap and interact with each other. Preclusions of and management of uses of the 

Forest is outside the scope of this project.

330 C-23, 

page 2

The Range section did not include any 

reference to the beneficial effects of 

grazing on wildlife habitat.

Please see page 10 of the Range Report: Grazing: Grazing has a beneficial effect to 

range management. Grass has evolved with grazing and is genetically designed to 

respond positively to the effects of grazing. Grass can be grazed after seed production 

as a way to increase the abundance of the species since grazing helps incorporate 

seeds into the soil through micro sites that are created by livestock hoofs. Grass can be 

grazed prior to seed emergence and, through the natural process of nutrient cycling, can 

be fertilized prior to seed production—the time in a plants maturity which take the most 

nutrients to complete.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

331 C-24, 

pages 

2-3

Inadequate cumulative effects analysis is 

used to artificially narrow the scope of 

analysis to the immediate project area, 

allowing the Forest Service to artificially 

minimize the effects to these three 

species to “negligible”, “short term” and 

“insignificant” and to “expect” populations 

of these species to still be viable after 

logging and burning. This sleight of hand 

is also facilitated by suddenly jumping 

from a local scale of analysis to the 

Forest-wide scale for determining effects 

to the species, yet without considering 

the effects of the many other similar fuel 

reduction projects/timber sales degrading 

or eliminating suitable habitat for Pileated 

and Three-toed woodpeckers and Pine 

marten across the Forest. There is a 

complete lack of population survey 

information for these species in the 

project area and across the Malheur 

National Forest, which is needed to 

determine their actual population status, 

reproductive success rate, and viability 

thresholds. Without this information, 

assurance of their continued viability in 

the project area, on the Blue Mountain 

Ranger District, and on the Malheur is 

impossible.

Regional direction requires that viability determination be made at the Forest scale for 

MIS species, including primary cavity excavators.

The direct, indirect, and cumulative impacts to PCE and Old-Growth MIS, including 

pileated woodpecker, three-toed woodpecker, and pine marten, are disclosed in the 

Magone FEIS and Wildlife Report. The area and activities considered for cumulative 

impacts analysis is also disclosed in the Magone FEIS.

As directed by the Forest Service Region 6, where population data are not available, due 

to lack of funding or feasibility of monitoring populations, the amount and quality of 

habitat can be used as a proxy for determining viability effects of projects on MIS (Lands 

Council v. McNair 2010).

332 C-24, 

page 3

We are also concerned about impacts of 

proposed logging and hazard snag 

removal to Blackbacked woodpecker, 

another Management Indicator species.

The anticipated impacts of proposed logging activities on MIS, including black-backed 

woodpecker and dead and down wood habitat (snags), are disclosed in the Magone 

FEIS and Wildlife Report.

333 C-24, 

page 3

We are also concerned by proposed 

removal of multilayered forest canopy 

and denser forest where it would 

naturally exist (e.g. in cool moist and cold 

dry forest types and on North slopes, 

high elevations, and in riparian areas), as 

such removal could contribute to 

declines in Neotropical migratory 

Please review the Silviculture Report for the expected future vegetation and canopy 

structure, and specific plant association groups.

The wildlife section of the Magone FEIS as well as the Wildlife Report discusses the 

anticipated effects to landbirds, including neotropical migrants. Flammulated owl was not 

discussed in the document as it is not on the MIS list, featured species list, or the 

Regional Foresters sensitive species list. The anticipated effect to northern goshawk 

(accipiter) is discussed in detail in the Magone FEIS and Wildlife Report.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

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songbirds adapted to such denser 

habitat, as well as harming other bird 

species adapted to denser habitat, such 

as Flammulated owls and accipiter 

hawks.

334 C-29, 

page 2

While we concur that the forest is 

currently over stocked compared to 

historical norms, and we agree that 

common sense suggests that a thicker 

forest will burn more readily. We are still 

hoping to see specific science on this 

topic. We understand that most of your

results come from models that have 

been developed internally. We 

encourage you to identify those models, 

and the scientific basis for the 

assumptions embedded in them.

The vegetation effects analysis undertaken in this project was completed using the 

Forest Service suite of FSVeg (Forest Service Vegetation) programs and the Blue 

Mountains Variant of the FVS (Forest Vegetation Simulator) growth and yield model. 

FVS is the specific model that calculates stand growth, density, fire intensity, etc. 

Extensive data sets nationwide have been collected and analyzed to develop this model, 

and data is continually collected to refine it. FVS is an individual tree, distance 

independent model that was developed through tree ring analysis, as well as other data 

collection methods. The Fire and Fuels Extension (FFE) of FVS is the model that 

evaluates the effectiveness of management activities in the context of potential fire 

effects and stand dynamics. This model was developed through integrating FVS with 

other existing fire behavior and effects models. FVS and FFE are models that are widely 

used by the federal government, as well as state and private forest companies across 

the country.

Changes in forest structure and composition over time and changes to expected fire 

pattern are consistent with changes observed in dry and mixed conifer forests 

throughout eastern Oregon which are described by a vast body of published scientific 

literature including but not limited to:

Brown, R.T., J.K. Agee, and J.F. Franklin, 2004. Forest restoration and fire: principles in 

the context of place. Conservation Biology 18: 903–912.

Franklin, J.F., and K.N. Johnson. 2012. A restoration framework for federal forests in the 

Pacific Northwest. Journal of Forestry 110(8): 429-439.

Hagmann, R.K., J.F. Franklin, and K.N. Johnson. 2014. Historical conditions in mixedconifer forests on the eastern slopes of the northern Oregon Cascade Range, 

USA. Forest Ecology and Management 330: 158-170.

Hagmann, R. K., J. F. Franklin, K. N. Johnson. 2013. Historical structure and 

composition of ponderosa pine and mixed-conifer forests in south-central 

Oregon. Forest Ecology and Management 304:492-504.

Halpern, C. 1988. Early successional pathways and the resistance and resilience of 

forest communities. Ecology 69(6): 1703-1715. 

Hemstrom, M.A., J. Salwasser, J. Halofsky, J. Kagan, and C. Comfort. 2012. The 

integrated landscape assessment project. In: Proceedings of the First 

Landscape State-and-Transition Simulation Modeling Conference, Ed: Kerns 

B.K., A.J. Shlisky, and C.J. Daniel. Portland, OR: USDA Forest Service Pacific 

Northwest Research Station, General Technical Report PNW-869.
FEIS Appendix D – Public Comment Report Magone Project

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Comment 

number

Source Comment Forest Service response

Hessburg, P.F., R.B. Salter, and K.M. James. 2007. Re-examining fire severity relations 

in pre-management era mixed conifer forests: Inferences from landscape 

patterns of forest structure. Landscape Ecology 22(1): 5-24.

Hessburg, P.F., J.K. Agee, and J.F. Franklin. 2005. Dry forests and wildland fires of the 

inland Northwest USA: contrasting the landscape ecology of the pre-settlement 

and modern eras. Forest Ecology and Management 211(1): 117-139.

Hessburg, P.F., and J.K. Agee, 2003. An environmental narrative of Inland Northwest 

United States forests, 1800–2000. Forest Ecology and Management 178: 23–

59.

Heyerdahl, E.K., R.A. Loehman, and D.A. Falk. 2014. Mixed-severity fire in lodgepoledominated forests: Are historical regimes sustainable on Oregon's Pumice 

Plateau, USA? Canadian Journal of Forest Research 44: 593-603.

Heyerdahl, E.K., P. Morgan, and J.P. Riser. 2008. Multi-season climate synchronized 

historical fires in dry forests (1650-1900), northern Rockies, USA. Ecology

89(3): 705-716.

Heyerdahl, E., L.B. Brubaker, and J.K. Agee. 2001. Spatial controls of historical fire 

regimes: a multiscale example from the interior West, USA. Ecology 82(3): 660-

678.

Merschel, A.G., T.A. Spies, and E.K. Heyerdahl. 2014. Mixed-conifer forests of central 

Oregon: effects of logging and fire exclusion vary with environment. Ecological 

Applications 24(7): 1670-1688.

Perry, D.A., H. Jing, A. Youngblood, and D.R. Oetter. 2004. Forest structure and fire 

susceptibility in volcanic landscapes of the Eastern High Cascades, Oregon. 

Conservation Biology 18: 913–926.

Spies, T.A., M.A. Hemstrom, A. Youngblood, and S. Hummel. 2006. Conserving old‐

growth forest diversity in disturbance‐prone landscapes. Conservation Biology 

20(2): 351-362.

Stine, P., P.F. Hessburg, T.A. Spies, M. Kramer, C.J. Fettig, A. Hansen, et al. 2014. The 

ecology and management of moist mixed-conifer forests in eastern Oregon and 

Washington: A synthesis of the relevant biophysical science and implications 

for future land management. General Technical Report PNW- 897. Portland, 

OR: USDA Forest Service, Pacific Northwest Research Station.

335 C-29, 

page 3

In places such as the Nipple Butte 

Roadless Area there are important social 

values associated with a place that has 

not been treated in the past. Our 

members place a very high value on

being able to visit lands that remain in 

their primeval state. Additionally, 

roadless areas that more closely 

The Roadless Area Conservation Rule of 2001 (Federal Register 66:3244–3275) 

generally prohibits silviculture in inventoried roadless areas like the Nipple Butte IRA 

except the cutting, sale and removal of generally small diameter timber to maintain and 

improve one or more of the following roadless area characteristics:

(i) To improve threatened, endangered, proposed, or sensitive species habitat; 

(ii) To maintain or restore the characteristics of ecosystem composition and structure, 

such as to reduce the risk of uncharacteristic wildfire effects, within the range of 
FEIS Appendix D – Public Comment Report Magone Project

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approximate historical conditions are 

often strong holds for wildlife.

In order to understand the trade‐offs 

between these values and the value of 

reducing fuel loadings, please explain 

the extent to which you anticipate the 

treatments will

a) impact the outcomes if a wildfire were 

to pass through this area – especially the 

impact to old growth trees, and;

b) return the area to HRV.

variability that would be expected to occur under natural disturbance regimes of the 

current climatic period;

The Magone FEIS contains an extensive analysis of the impacts of the proposed action 

to the IRA, including impacts associated with wildfires, wildlife habitat, visitor 

experiences and old growth trees (Magone FEIS, pages 153, 159, 166, 173, 192, 197, 

202-227, 288, 290, 293, 294, 297, 298, 300, 308, 344, 364, 380, 410, 439, 456, 466, 

471, 476-477, 553, 560, 564-565, and 567).

336 C-29, 

page 6

We are concerned about the extensive 

reliance on the Management Zone as the 

indicator of improvement. While we 

appreciate that the Forest Service must 

have an eye to timber production, there 

are more values at stake than the rate at 

which the forest is able to produce 

timber. For example, many people value 

old growth for old growth’s sake and 

many cavity nesting species rely on dead 

and dying trees. When planning primarily 

for tree growth and prevention of 

mortality, these other values can often be

overlooked, and even eliminated.

Instead of presenting the results of 

treatments in terms of return to the 

“Management Zone”, we encourage the 

Forest Service to focus primarily on 

moving the forest back to the Historic 

Range of Variability (HRV). For all 

practical purposes, this should 

accomplish largely the same thing. The 

MZ, and stocking levels developed by 

Powell were developed solely with an 

eye for increasing timber production. The 

Management Zone is not necessarily 

beneficial to wildlife, nor is it as likely to 

result in forests that have long term

resilience. HRV will accomplish both 

those ends as well as produce 

One of the main reasons that the management zone (MZ) concept was used as an 

indicator for forest density is that it is the recommended indicator for assessing the range 

of variation for Dry, Moist, and Cold forests in the Blue Mountains (Powell 2012). Powell 

states that by “using the stocking guidelines in conjunction with potential vegetation 

groups, it is possible to estimate how much forestland acreage is currently overstocked 

and how it compares to a range of variation for this ecosystem component.” He then 

goes on to provide a table giving the range of variation.

The concept of the MZ was developed to understand the issue of tree competition within 

a stand given a particular size and density. In short, there is an ecological maximum 

density for any given species on any given site classification. This concept has been 

highly used for timber production purposes, however, this concept has also been highly 

used to understand forest health issues such as tree mortality, susceptibility to insect 

and disease, and wildfire risk (Powell 1999). Management Zones indicate when trees 

begin competing with each other for resources (Lower Limit), when competition induced 

mortality begins (Upper Limit), and when significant mortality occurs (above Full 

Stocking). These levels help managers understand how fast trees will be growing, how 

capable trees are at producing defense chemicals to ward off insect and disease attack, 

and how quickly dead fuels are accumulating. Managing within the MZ will be beneficial 

to wildlife and will increase forest resilience to disturbance.

It is important to note that the objective is not to manage every acre within the MZ, but to 

move more acres into this zone and provide a range of stand densities below, within, 

and above this zone as to provide for a variety of stand conditions and habitats. HRV 

information for density has not been as well developed as for structure. However, rough 

estimates from Powell (2012) are provided below. Low density roughly correlates below 

the MZ, moderate density within the MZ, and high density above the MZ.

Potential Vegetation Group Range of Variation

Tree Density 

Class

Dry UF Moist UF Cold UF

Low 40-85% 20-40% 15-35%
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substantial amounts of timber for the

local mills.

Moderate 15-30% 25-60% 20-40%

High 5-15% 15-30% 25-60%

337 C-29, 

pages

6-7

We encourage the Forest Service to 

slightly alter this indicator, and add it to 

Table 22 in the main EIS. The change 

we encourage is to shift species 

composition to that which was found in 

the Historical Range of Variability. Two 

key species that need special attention 

right now are aspen and larch. Both

appear to be substantially below HRV –

possibly by as much as 90% below HRV. 

This shift in species composition is not 

entirely captured in the first objective of 

moving the structural stage to HRV. Nor 

is it entirely captured in the goal of 

moving species composition to early 

seral.

Making this small change would be 

entirely within the declared Purpose and 

Need, and would likely carry out that 

purpose and need with greater 

effectiveness.

Recent research projects on the Malheur National Forest by James Johnston and Trent 

Seager have indicated that western larch and aspen are greatly reduced from their 

historical extent. Emphasis for these species is being taken in the Magone Project to 

increase the quantity and health of these trees. Aspen would be thinned out around and 

fenced. Western larch are the number one priority leave tree within the silviculture 

prescription. However, very few aspen stands exist within the project planning area and 

most of the area is within PAGs that do not support western larch (84 percent).

Unlike structure stage, and to some degree density, the HRV for species composition 

has not been very well defined in the literature. More research on this topic would be 

useful in developing silvicultural prescriptions with the objective of moving the landscape 

towards HRV. However, managing for an increased proportion of early seral species 

most likely will move species composition closer to historical proportions, but drastically 

changing species composition would likely require more intensive management actions 

such as regeneration harvests.

338 C-29, 

page 7

None of your information about historical 

range of variability is cited, and this is a 

very controversial area of science. There 

is a list of citations at the back of the 

Silviculturalist’s Report, but it’s not clear 

what data was retrieved from what study. 

I was also surprised to see that James 

Johnston was not among the 

researchers cited.

With so much recent fine detailed work 

by James Johnston on the Malheur I 

would have expected that his work would 

be cited. What science are you using 

here to determine what the historic 

structure was or should have been? 

Where did you get these numbers for 

historical range of variability? Is any of 

Magone project IDT leaders have communicated extensively with James Johnston in the 

course of field trips and meetings with the Blue Mountains Forest Partners. His PhD 

research shows that a wide variety of forest types on the Malheur National Forest 

historically experienced frequent fire and most forest types within the Magone project 

area are currently significantly departed from historical conditions. Treatments to restore 

forest resilience to a range of forest types within the Magone project planning area are 

designed to restore forest resiliency to a wide variety of forest types where current 

regulations and agency policy permit. These actions are consistent with the Blue 

Mountains Forest Partners zones of agreement developed in part based on information 

from Johnston’s study. Assumptions about historical range of variability found in the 

Magone FEIS are supported by a wide range of published studies (see citations in 

response to comment #334). Specifically, HRV ranges reported in the Silviculture Report 

were obtained from Powell 1998 and 2012.
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this data being supported or challenged 

by James’ work?

I am curious about this because I believe 

that some of James’ work may challenge 

some of the HRV assumptions for the 

cool moist PAGs. Because of the 

frequent fire in the region, I believe he 

has found that cool moist PAGs are so 

fire‐influenced that they behave 

somewhat more like the dry forests on 

the Malheur.

However, these conclusions are highly 

controversial. Please include a thorough 

discussion of which science you have 

chosen to rely upon, and why you chose 

that science. Without such a discussion, 

how is the public to know whether you 

are relying on the best available 

science?

339 C-29, 

page 7

Table 23 on page 123. This table is very 

confusing. What exactly is it measuring? 

It suggests that OFSS was historically 0‐

5% of the Magone Project Area, but that 

doesn’t make sense. On page 111 you 

show that more than 66% of the Magone 

Project Area is in dry forest types, and on 

pages 113 and 114 you show that those 

forest types typically had about 50% 

OFSS. It appears to me that you

accidentally copied the cool moist table 

from page 114 here. Either I don’t 

understand this table, or it is in the wrong 

place.

Thank you for your comment. This table is demonstrating the change in structural stages 

through time for the entire Magone project planning area. Since structural ranges for 

HRV are based on PAG it is not appropriate to use HRV in this table and the HRV 

column will be removed.

340 C-29, 

page 10

This distribution makes no intuitive 

sense. How can you possibly have the 

same forest type occurring in two 

radically different areas? How could it be 

that the same plant associations are 

found in both:

 low elevation riparian areas, and

Warm Moist Upland Forest is generally categorized by the presence of larger shrubs. 

There are only a few plant associations within the Warm Moist PAG and these include: 

grand fir/Rocky Mountain maple-mallow ninebark, grand fir/Columbia brome, Douglasfir/Rocky Mountain maple-mallow ninebark, Douglas-fir/Rocky Mountain maple-mountain 

snowberry, and Douglas-fir/oceanspray. These shrubs are typically located where there 

is higher soil moister, which can include riparian areas as well as seeps and springs. 

The Magone FEIS states that this PAG exists on some upper elevation knobs. Upper 

elevation means the higher elevation areas of the project, which ranges from 3,520 to 
FEIS Appendix D – Public Comment Report Magone Project

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 high elevation knobs.

These are the two most different types of 

physical environments that exist on the 

forest. It seems unlikely that they really 

support the same types of forest.

6,240 feet. In this context it does not mean high elevation environments. Shrubs such as 

Rocky Mountain maple and oceanspray can exist in small stands in the upper elevations 

of the project planning area where the soil is moist due to springs and seeps.

341 C-29,

pages 

10-11

Whether the proposed prescriptions are 

actually good for the forest in the long 

term depends entirely on whether a 

person accepts a few key points of 

science:

1. Does returning the forest to HRV 

actually improve forest health, and 

prepare it for the coming climate 

change? We believe that, given the 

state of the science, aiming to return 

the forest to HRV is likely to be the 

best way to prepare it for future 

conditions. It appears that this forest 

has undergone droughts as severe as 

any we are expecting in the next 100 

years already. The old growth trees 

currently existing on the forest are the 

trees that have proven their 

adaptability to sever drought 

conditions. (And they were probably 

somewhat lucky as well). They should 

be encouraged to expand their range.

2. Does the current science actually 

provide an accurate picture of HRV?

This is a significant point of contention 

within the environmental world. We 

are currently persuaded by the 

extensive site-specific science by 

James Johnson. We are aware of no 

more accurate, fine‐detailed analysis 

in the Blue Mountains. While we 

understand the potential drawbacks to 

using fire scars to understand

historical fire, there are drawbacks to 

using other methods, such as alluvial 

fan deposits or lake bed sediments, 

The historical range of variability of forest structure and composition within the Magone 

project planning area was generally characterized by lower densities, a higher proportion 

of basal area in older and larger trees, and a higher proportion of fire tolerant and shade 

intolerant species, especially western larch and ponderosa pine. Most of the basal area 

of most stands in the Magone planning area was found in trees 200-600 years old that 

have survived multiple droughts and dozens of fires and insect attacks. Restoring these 

forest conditions would improve the Magone project planning area’s resilience to future 

disturbance and climate regimes. Future climate regimes are expected to be warmer and 

drier with more variable precipitation and longer and more intense droughts. Fire and 

insect attacks are likely to be more frequent and potentially of higher severity. The 

scientific community has a high degree of confidence both in the historical range of 

variability of forest conditions on the Malheur National Forest and in predictions of future 

climate and disturbance. The Magone Project implements the recommendations of 

Franklin and Johnson (2012) and their (2013) Restoration of Dry Forests in Eastern 

Oregon field guide.
FEIS Appendix D – Public Comment Report Magone Project

54

Comment 

number

Source Comment Forest Service response

as well. Each method has its 

strengths and weaknesses. We are 

looking forward to the continuing 

scientific debate on this subject.

3. Do the currently proposed treatments 

actually move us toward HRV? We 

cannot say that we have examined all 

the science on the subject, but we are 

currently of the belief that the science 

by Jerry Franklin and Norm Johnson, 

and incorporated in the handbook 

Restoration of Dry Forest in Eastern 

Oregon is the best available science, 

and that it will move dry forests 

toward HRV while balancing other 

values in the most responsible way 

we know of.

342 C-29, 

pages 

19-20

We are always concerned by such broad 

based assumptions that do not appear to 

be based in data. However, in this case, 

we have no better assumption to 

propose. We agree that HRV is likely to 

be the best indicator of future health as 

we can see. As far as we can tell, the 

Forest Service is attempting to

accurately determine HRV for the large 

tree species. We encourage you to also 

look at the understory species that are 

likely to be significantly affected by cattle 

grazing which occurs throughout the 

project area.

The cumulative effects analysis of the 

change, DEIS pages 576‐77, list seven 

other forest plan amendments that have 

reduced forest cover, presumably for 

similar reasons. These defacto 

experiments could be used to predict the 

likely outcome of the proposed action. A 

full analysis of the likely impacts would 

include data about the change in actual 

elk numbers in these other areas in 

Elk populations are surveyed and managed by the Oregon Department of Fish and 

Wildlife within Wildlife Management Units (WMU). The Magone project planning area is 

part of the Northside WMU which is only 47 percent public land. Due to the large extent 

of the Northside WMU, the proportion of private land and the migratory nature of elk, 

site-specific population data as it relates to previous forest plan amendments is not 

available. Since 1995, there have been no other cover-related forest plan amendments 

within the Northside WMU, and only two in the Blue Mountain Ranger District; one in the 

Desolation WMU and one in the Murderers Creek WMU. Further, elk populations across 

the Northside, Desolation, and Murderers Creek WMUs are at or above the 

management objective established by the Oregon Department of Fish and Wildlife for 

those WMUs.
FEIS Appendix D – Public Comment Report Magone Project

55

Comment 

number

Source Comment Forest Service response

response to the changes in actual cover.

Simply listing other activities may not 

satisfy the cumulative impacts analysis 

requirements.

343 C-30, 

pages 

1-2

In our March 2015 comments on the 

Notice of Intent, the EPA recommended 

that the Forest undertake an analysis of 

greenhouse gas emissions consistent 

with CEQ guidance.1 The DEIS states on 

page 568 that, “As greenhouse gas 

emissions are integrated across the 

global atmosphere, it is not possible to 

determine the cumulative impact on 

global climate from emissions associated 

with any number of particular projects. 

Nor is it expected that such disclosure 

would provide a practical or meaningful 

effects analysis for the Magone Project.” 

We recommend that as the EIS is 

finalized, the Forest Service move away 

from characterizing project-related 

emissions as not being meaningful. 

Changes in climate are not attributable to 

any single action, but are exacerbated by 

a series of smaller decisions.

As the FEIS is finalized, we encourage 

the Forest Service to include a 

comparison of net GHG emissions and 

carbon stock changes that would occur 

with and without implementation of the

Magone Project. This analysis can 

incorporate by reference earlier 

programmatic studies or information 

such as management plans, inventories, 

assessments, and research that 

considers potential changes in carbon 

stocks, as well as any relevant 

programmatic NEPA reviews.

Thank you for your comment. The Magone Project analysis is following the current

USDA Forest Service Washington Office guidance for climate change and NEPA: 

http://www.fs.fed.us/emc/nepa/climate_change/index.htm

 

1 https://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghg-guidance
FEIS Appendix D – Public Comment Report Magone Project

56

Table D-9. Comment identification number, source of comment, written comment, and Forest Service response for comments pertaining to the EIS, 

Clarifications / Miscellaneous / Errata

Comment

number

Source Comment Forest Service response

400 C-01, 

page 1

How will the Forest Service be able to 

maintain the trails after they have been 

built? I have seen a lot of good things put 

into place, only to see them wither away, 

due to funding not being available.

Trail construction, maintenance, funding, and organization of such activities would be 

done primarily by the local Central Oregon Trail Alliance (COTA), Grant County Chapter 

through a formal agreement.

401 C-03, 

page 7

325 million people own this land, how 

many people have you contacted? Just 

locals?

Public involvement has included:

 Publication of the notice of intent (NOI) to prepare an environmental impact 

statement (February 2015) and the notice of availability (NOA) of the draft 

environmental impact statement (DEIS) (February 2016) in the Federal Register.

 Publication of legal notices and news articles in the Blue Mountain Eagle 

announcing the resource stories (August 2014), scoping period (February 2015) and 

45-day comment period on the DEIS (February 2016).

 Mailings on the availability of resource stories (August 2014), scoping (February 

2015), and availability of the DEIS (February 2016) to a list of approximately 150 

people that reside in a variety of locations.

 Information has also been available to the public on the Malheur National Forest’s 

webpage since August 2014: http://www.fs.usda.gov/project/?project=44907

402 C-03, 

page 7

I don’t want this Blue Mountain Forest 

Preserve which is made up of forest 

products sector to have any voice in what 

happens to a national site.

We will review and consider the comments of all interested parties who comment on the 

Magone Project.

403 C-03, 

page 7

Why don’t you use the correct English 

word for logging instead of “silviculture” to 

hide what you are doing from the general 

public?

Wikipedia defines silviculture as “the practice of controlling the establishment, growth, 

composition, health, and quality of forests to meet diverse needs and values”. 

https://en.wikipedia.org/wiki/Silviculture

Wikipedia then goes on to state that silviculture includes direct action in the forest and 

that it is the theory and practice of controlling the establishment, composition, 

constitution, and growth of forests. Silvicultural actions within the Magone project area, 

and on the Malheur National Forest, that are used to achieve the desired conditions of 

forest vegetation include planting, precommercial thinning, commercial thinning and 

commercial harvest, verbenone application, and prescribed fire. Each one of these 

actions/activities used is a tool that helps meet the desired condition through controlling 

either the establishment, composition, constitution, and/or growth of forests. Commercial 

thinning/harvest (i.e. logging) is a tool used to control the composition, density, health, 

and growth of forested stands when the trees are of commercial size/value.

404 C-04, 

page 2

I submitted handwritten comments at the 

Magone open house on September 24, 

2014, and additional remarks were sent 

Comments received during that open house, including yours, were reviewed and 

considered when developing the proposed action for the project. At that point in the 

planning process (pre-scoping) we were looking for input into development of the 
FEIS Appendix D – Public Comment Report Magone Project

57

Comment

number

Source Comment Forest Service response

to Sara Daugherty on September 26, 

2014, via email. Neither of these 

documents voicing my concerns were 

addressed in this Draft Environmental 

Impact Statement (DEIS).

proposed action and any information the public wanted to share about the existing 

conditions of the Magone planning area; your comments were primarily questions about 

the planning area. However, at your request during the 45-day comment period, here is 

a response to the questions you asked during the pre-scoping open house:

 Stream conditions presentation only addressed 2014 conditions. What are the 

historical facts? If conditions existed normally for many years because of 

normal fluctuations of yearly conditions, why are you attempting to change 

them now? – Focus for stream conditions is on the existing conditions, which 

looking at historical photos (1989, 1990, 1991) from monitoring has improved 

over the last 20 years. What is normal based on? The last 30 years? Last 50 

years? Last 100 years? Also portions of East Fork Beech Creek that have 

improved in condition over the last 20 years are also the ones that contain 

perennial flow the longest in 2014.

 Botany – If African grass is undesirable why isn’t it treated now before it 

becomes a problem? – The distribution and abundance of North Africa grass is 

not well known in the Magone planning area. Treating it would follow the Early 

Detection Rapid Response (EDRR) strategies in the 2015 Malheur National 

Forest Site-Specific Invasive Plants Treatment Project EIS and ROD.

 Decommissioning roads limits fire access/suppression – A Travel Analysis was 

conducted by the interdisciplinary team, which included and fire and fuels 

specialist. Only one 0.3 mile road segment is proposed for decommissioning 

under the Magone Project, and it is not needed for fire access/suppression.

 What are the average fuel loadings within the project area? Do they conflict 

with dead and defective habitat? Photos of the habitat appear indicative of fuel 

loadings as well. Dead and defective habitat versus fuel loading – explain why 

one is encouraged and the other discouraged. The average fuel loading for the 

planning area is approximately 8.3 tons/acre. Table D-10 shows the 

percentage of the planning area by fuel load class (light 0-8 tons/acre, 

moderate 8-15 tons/acre, heavy 15+ tons/acre).

Table D-10. Magone project planning area fuel load summary

Total fuel loading Percentage of project planning area

0–8 tons/acre 61%

8–15 tons/acre 17%

15+ tons/acre 22%

Coordination with the District Wildlife Biologist has occurred during the 

planning phase of the Magone project and will continue through 

implementation. Areas suitable for dead and defective habitat would be 
FEIS Appendix D – Public Comment Report Magone Project

58

Comment

number

Source Comment Forest Service response

retained. Fuels would be reduced in other areas where lower fuel loads would 

have been present historically.

 Presence of numerous snags seem dependent upon fires, diseased or dead 

and dying old growth trees. Fewer snags indicate a healthy forest or less fire 

activity. Appears you can’t have both ways. – Snags are created through a 

number of disturbances including fire, insects, and weather events like high 

winds and drought. Certain wildlife habitat types in the project planning area 

are deficient in snag densities and distribution as compared to reference 

conditions. Other wildlife habitat types are at or near reference conditions of 

snag densities and distribution. The existing condition as well as the expected 

effects of proposed activities are discussed in detail in the Magone FEIS and 

Wildlife Report under the MIS – Primary Cavity Excavator section.

 Range – July 1, 2014 shows more moisture but other resources claim drier 

conditions? What feeds all the ponds and water troughs if water is such a 

problem? – We are not sure what you are referring to with the July 1, 2014 

date; the amount of moisture varies spatially (throughout the year) and 

temporally (at different locations) in the project planning area. Water is present 

as spring and seeps; however, water storage and conveyance on the 

landscape in particular within floodplains and meadows across the Magone 

project planning area has been altered, resulting in a reduction in baseflow. 

Encroachment of juniper and conifers have contributed to this condition.

 Not proper signing on closures – 36 CFR 261.51 – 36 CFR 261.51 states 

“Posting is accomplished by: (a) Placing a copy of the order imposing each 

prohibition in the offices of the Forest Supervisor and District Ranger, or 

equivalent officer who have jurisdiction over the lands affected by the order, and 

(b) Displaying each prohibition imposed by an order in such locations and 

manner as to reasonably bring the prohibition to the attention of the public.”

 Recreation motto “traditional way of life” yet access to much of area is targeted 

for closure – See response to comment #302. Under alternative 2 approximately 

2.71 miles of road would be closed or decommissioned and under alternatives 3 

and 4 approximately 0.61 miles of road would be closed or decommissioned; 

there are currently 47 miles of open (ML 2 or 3) roads within the Magone project 

planning area.

 1 developed OHV trail? Why only 1? OHV use is only considered on one road in 

the planning area due to safety concerns.

 Campsites showing more use and bare ground – isn’t this preferred for 

campfires? The bare ground was addressing more than just the area for a 

campfire, which is preferred as you mention, it was an indication of many years 

of use.
FEIS Appendix D – Public Comment Report Magone Project

59

Comment

number

Source Comment Forest Service response

 The aim to close/decommission 100 ML1 roads totaling 63 miles may be 

detrimental to fire suppression activities especially if access roads are proposed 

to be made virtually impassable. “Roads closed under previous NEPA 

decisions.” Which NEPA decisions? – We are not proposing to 

close/decommission 100 ML 1 roads under the Magone Project. It will be listed 

under the comment section of the Travel Analysis which previous NEPA or 

administrative closures took place in the past.

405 C-04, 

page 2

I find that my statements contained in the 

DEIS have been misquoted, specifically 

those referenced in the Appendix D, 

Scoping Report. Page 4, comment 

number 201 – “If not used for haul, roads 

should be decommissioned.” I did not use 

that term and do not support such action.

We sometimes summarize lengthier comments; we apologize for the error.

406 C-04, 

page 2

Your response to Comment 200, Page 3, 

was that you could not identify road 

segments in the proposed action meeting 

this description. I propose that you refer 

to the original scoping package of 

February 2015 wherein these road 

segments are described.

Your comment #200 states “Roads naturally closed and grown in, listed as closed, have 

an effective natural closure and have no access due to private property posting should 

be left closed and undisturbed (no decommission disturbance activities) as they 

apparently are not showing use by public vehicles or off highway vehicles (OHV). 

Carsonite road signs should be removed and road numbers deleted from road lists/CFR 

closure documents.”

There are not any roads proposed for closure or decommissioning in the Magone 

scoping package, DEIS, or FEIS that have no access due to private property posting. In 

addition, the only road proposed for decommissioning is FSR 1800933 and this road 

would be allowed to continue to naturally re-vegetate itself, with no on-the-ground work 

proposed.

407 C-04, 

page 2

Comment 400, Page 20 – your response 

that you are not able to respond to this 

comment without specific road numbers 

and/or locations of the closed roads. I 

suggest your roads person refer to the 

road logs, current CFR closure list, 

February 2105 Scoping packet, and the 

2014 updated roads management 

section (perhaps talk to John Laliberte to 

find your roads for you). I don’t believe I 

should be required to do your work for 

you in this arena. The roads are clearly 

evident in one or all of the referenced 

locations.

Thank you for your comment. Please see the Magone FEIS chapter 2 for the road 

system changes proposed under each alternative.
FEIS Appendix D – Public Comment Report Magone Project

60

Comment

number

Source Comment Forest Service response

408 C-04, 

page 2

I find your Alternative Map #3 addressing 

temporary road construction and haul 

routes difficult to study due to 

overwhelming colored areas.

Thank you for your comment, we updated the map display between the Magone DEIS 

and FEIS.

409 C-04, 

page 2

Appendix A – Project Activity Tables, 

page 34, addresses proposed road 

system changes. Maintenance Level 2 

(ML) roads indicated to be closed or 

decommissioned but do not address the 

reason for these actions.

Thank you for your comment, we added the rationale behind proposed road system 

changes to this table.

410 C-04, 

page 2

1800243, another ML 2 road, shows 0.8 

miles to be undesignated but fails to 

address the remaining 1.8 miles.

As stated in the Magone FEIS, undesignating certain segments of road as trail is 

proposed to re-route the trails off of roads where the trail shares use with vehicular 

traffic. As stated in the comment, approximately 0.8 miles of FSR 1800243 would be 

undesignated as trail; the remaining 1.8 miles of FSR 1800243 is an ML 1 road and 

would continue to also have a trail designated on the road as shown in the Magone 

FEIS Appendix B – Maps, Maps 10, 11, 12, and 15.

411 C-04, 

page 3

Any activities scheduled for this project 

should meet the coordination guidelines 

and adhere to the attached Grant County 

Ordinance 2013‐01, as supported by the 

2015 edition of the Oregon Revised 

Statutes.

To the extent that the ordinance purports to prohibit the Forest Service from closing 

National Forest System roads and trails that are located within the county, it is 

preempted by federal law and therefore is not enforceable. First, Congress has 

evidenced its intent to occupy the field of the administration of National Forest System 

roads and trails. Second, the ordinance’s restriction of the Forest Service’s authority to 

close National Forest System roads and trails conflicts with several federal laws. Finally, 

Congress has not provided clear and express authorization for county ordinances that 

restrict the Forest Service’s ability to administer the use of National Forest System roads 

and trails, so the ordinance is presumptively invalid.

412 C-06, 

page 2

You have already selected the alternative 

you will implement. Now you are passing 

the Magone timber sale through the 

NEPA process to make it legal.

We respectfully disagree. The Magone FEIS analyzes four alternatives, including no 

action and three action alternatives. The Responsible Official will make his decision 

based on meeting the purpose and need for action, the environmental effects of the 

activities, consideration of public and other agency comments, and compliance with the 

Malheur Forest Plan and other applicable law, regulation, and policy.

413 C-06, 

pages 5

and 43

The Administrative Procedures Act 

directs judges to set aside an agency 

action if the court determines that the 

action is “arbitrary, capricious, an abuse 

of discretion, or otherwise not in 

accordance with law.” 5 U.S.C. § 

706(2)(A). A line-officer who ignores 

best-science and instead makes a 

Decision on weak, meager evidence 

provided by people with financial interest 

The project met the requirements of the Administrative Procedures APA by the 

regulation at the procedures of the NEPA and notice and comment requirements as 

outlined in 36 CFR 218.

The regulation at 40 CFR 1502.9(b), 1502.22, and 1502.24 gives direction regarding 

use of best available science. What constitutes best available science might vary over 

time and across scientific disciplines. As a general matter, the Forest Service shows 

consideration of the best available science when it insures the scientific integrity of the 

discussions and analyses in the project NEPA document. Specifically, the NEPA 

document should identify methods used, reference scientific sources relied on, discuss 

responsible opposing views, and disclose incomplete or unavailable information. The 
FEIS Appendix D – Public Comment Report Magone Project

61

Comment

number

Source Comment Forest Service response

in a sale being sold (i.e. IDT members 

that represent timber and engineering) is 

guilty of violating the APA. You have 

done this.

The discussion should explain why the 

recommendations of over 200 Ph.D. 

scientists represented in Opposing Views 

Attachments #1 and #4 aren’t applicable 

to the Magone sale area and/or why the 

information provided by several timber 

IDT members should trump these 

independent scientists’ research 

conclusions, thus establishing USFS IDT 

members’ information as “best available 

science.”

methods used can be found within each resource section in the Magone FEIS chapter 3. 

References are cited throughout the Magone FEIS and a References Cited section is 

provided at the end of the FEIS.

No interdisciplinary team member has a financial interest in any timber sales that may 

be sold within the Magone project planning area.

414 C-06, 

page 19

The decision document should say 

““herbicides that contain glyphosate will 

not be applied.”

Failure to tell the public this chemical will 

not be used leaves the door open for 

glyphosate application. This violates:

40 CFR 1501.2 (b), 40 CFR 1502.16(a) 

and (b), and 40 CFR 1508.8(b) because 

Chapter 3 omits important environmental 

effect disclosures (i.e. glyphosate 

exposure sometimes causes cancer)

The Apr. 21, 1997 Executive Order No. 

13045 because the Responsible Official 

does not ensure that this project will not 

disproportionately expose children to 

environmental health risks and safety 

risks.

The application of herbicides including glyphosate are not proposed as part of any of the 

alternatives analyzed in the Magone FEIS.

415 C-06, 

page 

37-38

Modify the proposed action to do the 

following in addition to hazardous fuels 

removal:

 Distribute Firewise handouts to WUI 

residents describing the fine fuels 

removal methods (where and how).

The Healthy Forests Restoration Act (HFRA) of 2003 provides the impetus for wildfire 

risk assessment and planning at the county and community level and specifically refers 

to communities that are at risk of fire coming off of Federal Lands. HFRA refers to this 

level of planning as Community Wildfire Protection Plans (CWPP). The purpose of a 

CWPP is for communities to take full responsibility and advantage of wildland fire and 

hazardous fuel management opportunities offered under HFRA legislation. The CWPP 

allows a community to evaluate its current situation with regards to wildfire risk and plan 

ways to reduce risk for protection of human welfare and other important economic, 
FEIS Appendix D – Public Comment Report Magone Project

62

Comment

number

Source Comment Forest Service response

 Contact the people living in the WUI 

and announce Firewise workshops 

will be held to answer questions.

 Offer to remove the fine fuels (with 

written permission) on private property 

owned by elderly and disabled 

homeowners who cannot do the work 

themselves.

If this does not occur, you will violate:

 40 CFR 1500.2(e) because the 

Responsible Official was unable to 

avoid or minimize adverse effects of 

the project upon the quality of the 

human environment without complete 

knowledge of all likely adverse effects. 

Most adverse effects of project 

activities described by scientists in the 

Opposing Views Attachment #11 was 

not mentioned in the final NEPA 

document EA.

 40 CFR 1500.2(f) because the 

Responsible Official was unable to 

avoid or minimize any possible 

adverse effects upon the quality of the 

human environment without 

knowledge of the adverse effects. Had 

the Responsible Official known about 

these effects he would have 

acknowledged the existence of some 

adverse effects described in the 

Opposing Views Attachment #11 in 

the final NEPA document EA.

 NEPA Sec. 101(b)(2) because the 

Responsible Official does not “assure 

for all Americans safe, healthful, 

productive, and esthetically and 

culturally pleasing surroundings;”

 NEPA Sec. 101(c) because “The 

Congress recognizes that each 

person should enjoy a healthful 

environment and that each person 

social or ecological values. The CWPP may address issues such as community wildfire 

risk, structure flammability, hazardous fuels and non-fuels mitigation, community 

preparedness, and emergency procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management should be engaged in the CWPP process 

as consultants. Information can be found at http://www.grantcountycwpp.com/

Firewise information is available via that program’s website at: http://www.firewise.org/

The Magone FEIS documents consideration of the no action alternative and three action 

alternatives, in compliance with 40 CFR 1500.2(e); and the Magone FEIS contains best 

management practices and project design criteria to minimize, avoid, reduce or 

eliminate impacts of the proposed project (Magone FEIS Appendix C – Project Design 

Criteria) in compliance with 40 CFR 1500.2(f).

The Magone Project complies with the NEPA by following the regulations at 40 CFR 

1500, which detail how the agency shall prepare a DEIS, FEIS, and ROD.

The Magone Project would follow Executive Order 13045 and would not 

disproportionately affect children from environmental health risks or safety risks.

The Magone Project is documented in an EIS and not an EA, so the last statement by 

the commenter does not apply.
FEIS Appendix D – Public Comment Report Magone Project

63

Comment

number

Source Comment Forest Service response

has a responsibility to contribute to 

the preservation and enhancement of 

the environment.”

 Ex. Ord. No. 13045, Apr. 21, 1997 

[section 1-101(a)] because the 

Responsible Official does not “make it 

a high priority to identify and assess 

environmental health risks and safety 

risks that may disproportionately 

affect children.”

For EAs only

 The draft FONSI violates 40 CFR 

§1508.27(b)(2) because the intensity 

discussion fails to discuss the degree 

to which the proposed action affects 

public health or safety.

416 C-06, 

page 43

Provide information and data explaining 

who the people living in Troy are different 

than the people living in and near Troy. 

Show why their beliefs that they enjoy 

recreating near or in areas that have 

been logged are different than a strong 

majority of the 7,069 Americans that 

responded to Chief Thomas’ 2002 survey 

for the RPA who felt it is important that 

the USFS: 

“preserve of natural resources through 

policies that restrict commodity uses, 

protect ecosystems and wildlife habitat, 

and preserve of the ability to enjoy a 

“wilderness” experience.”

Also, include a discussion and supporting 

data justifying why it’s appropriate to take 

action on public land that the vast 

majority of the American public does not 

want to occur. Demonstrate why you feel 

the Magone timber sale serves the 

majority of the American people, or 

explain why serving the natural resource 

extraction corporations is more important.

The Forest Service has prepared the Magone FEIS in compliance with the National 

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

regulations. The Magone FEIS tiers to the Malheur National Forest Land and Resource 

Management Plan (Malheur Forest Plan) Final Environmental Impact Statement and 

follows the Malheur Forest Plan. [Note – there is no town called Troy near the Magone 

project planning area or Malheur National Forest; there is a Troy, OR located about 200 

miles away near the Oregon/Washington border].

The project does not violate 40 CFR 1500.2(e) and (f) because the EIS contains best 

management practices and project design criteria to minimize, avoid, reduce or 

eliminate impacts of the proposed project.
FEIS Appendix D – Public Comment Report Magone Project

64

Comment

number

Source Comment Forest Service response

Failure to provide justification showing 

why the USFS can take actions that the 

vast majority of the American public do 

not want to occur violates 40 CFR 

1500.2(e) and (f) because the 

Responsible Official does not use all 

practicable means to “avoid or minimize 

any possible adverse effects of their 

actions upon the quality of the human 

environment” and does not “avoid or 

minimize adverse effects of these actions 

upon the quality of the human 

environment”, Executive Order 13563 of 

January 18, 2011, and 16 U.S.C. § 1851 

: US Code - Section 1851.

417 C-06, 

page 44

Post your responses to ALL public 

comments online so the 322 million 

Americans\ national forest owners might 

read them if they choose.

Failure to post your responses to ALL 

public comments online will violate 36 

CFR 215.6(d) because the Responsible 

Official did not “address comments 

received from the public during the 

comment period in an appendix to the 

environmental assessment.”

Ignoring public comments also violates:

40 CFR 1503.4(a) because the objector 

does not know how the Responsible 

Official responded to the objector’s 

comments, and

40 CFR 1502.9(b) because the Final 

environmental impact statement does not 

respond to comments.

The response to scoping comments was included as Magone DEIS Appendix D –

Scoping Report and is available on the Forest’s website at: 

http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/

www/nepa/99358_FSPLT3_2718758.pdf

Responses to comments received on the Magone DEIS are included in this document 

Magone FEIS Appendix D – Public Comment Report and are available on the Forest’s 

website at: http://www.fs.usda.gov/project/?project=44907

418 C-06, 

pages 

47-48

If you were really concerned about local 

community stability and local job creation 

you would offer this sale as an SBA sale 

to prevent a large timber corporation from 

logging it using their own labor. This 

would prevent the logs from being hauled 

The Forest Service does not identify the type of timber sale or other implementation 

mechanism that will be utilized to implement a project. Small business (SBA) sales are 

an option. The small business share on the Malheur National Forest is at 80 percent, the 

highest allowable.
FEIS Appendix D – Public Comment Report Magone Project

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many miles to be processed at a mill far 

removed from the small communities you 

claim need economic help. Of course 

your motivation to sell this timber sale 

has nothing to do with community 

stability. We both know “local community 

stability” and “local job creation” is part of 

the USFS dishonest script to trick the 

public into accepting tragic timber sales.

Offer the sale as an SBA sale and say so 

in the final NEPA document.

419 C-06, 

page 48

Include the text or links to the text of the 

following papers in an Appendix to the 

NEPA document. Line-officers must not 

withhold such important information from 

the public. Congress promulgated laws to 

prevent zealous federal officials from 

behaving in such a manner to feather 

their nest.

A 1998 presentation to the National 

Trails Training Partnership by U.S. 

Undersecretary of Agriculture Jim 

Lyons “The Economic Impact of TrailsForest Recreation’s Growing Impact” 

(http://www.americantrails.org/resource

s/economics/EconForestRec.html)

“Seeing Forests for their Green: 

Economic Benefits of Forest 

Protection, Recreation, and 

Restoration” (http://econw.com/ourwork/publications/seeing-forests-fortheir-green-economic-benefitsof-forestprotection-recre/)

“The Economic Impact of Preserving 

Washington’s Roadless National 

Forests” 

(http://www.kettlerange.org/power/Exec

Summary.htm)

Failure to do so will violate The final EA 

violates 40 CFR 1500.1(b) because 

Links to the text of the following papers is provided in the column to the left. In addition, 

the documents were reviewed by the Magone interdisciplinary team and responses 

provided in Table D-11.
FEIS Appendix D – Public Comment Report Magone Project

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environmental information is not available 

to citizens before decisions are made.

420 C-06, 

pages 

48-50

Please respond to the opposing views 

contained in the Opposing Views 

Attachments to these comments.

Each opposing viewpoint is different and 

is related to a unique subject, therefore a 

single response attempting to deal with 

all opposing views simultaneously does 

not respond to opposing views as 

required by law. Please respond to each 

opposing view and post the responses 

online for the public to see. Simply 

placing a hardcopy of your opposing 

views responses in the project file located 

at the district hides the information from 

the American public.

Failure to do so will violate 40 C.F.R. § 

1502.9(a) and 1502.9(b) and. 42 USC § 

4372(d)(4) because “Final environmental 

impact statements shall respond to 

comments as required in part 1503 of this 

chapter. The agency shall discuss at 

appropriate points in the final statement 

any responsible opposing view which 

was not adequately discussed in the draft 

statement and shall indicate the agency’s 

response to the issues raised.” Failure to 

respond to responsible opposing views 

(from any source) also is inconsistent 

with court precedent: Center for 

Biological Diversity v. United States 

Forest Service, Sierra Club v. Eubanks 

335 F. Supp. 2d 1070 (ED Cal. 2004), 

Seattle Audubon Society v. Lyons 871 F. 

Supp. 1291, 1318 (W.D. Wash. 1994), 

Seattle Audubon Society v. Moseley 798 

F. Supp. 1473 (WD Wash. 1992), and 

Sierra Club v. Bosworth 199 F.Supp.2d 

971, 980 (N.D. Cal. 2002)

Please see Table D-11 to Table D-22 which responds to each opposing viewpoint 

provided by the commenter. The responses are provided in this appendix to the Magone 

FEIS, which is also posted on the Forest’s website at: 

http://www.fs.usda.gov/project/?project=44907.
FEIS Appendix D – Public Comment Report Magone Project

67

Comment

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Source Comment Forest Service response

421 C-06,

pages

50-52

and 54-

55

Include the source literature for 

particularly relevant science quotes 

contained in the Opposing Viewpoint 

Attachments in the References section of 

the final EIS and cite the quotes 

contained in the attachments in the body 

of the final EIS. Indeed, it makes sense 

for a public servant to present the public 

with the whole story which includes 

benefits and drawbacks of project 

implementation.

Failure to do this will violate:

 40 CFR 1500.1(b) because important 

environmental information was not 

made available to citizens before the 

decision was made.

 40 CFR 1500.1(c) because the public 

was denied the opportunity to 

understand the adverse 

environmental consequences of the 

logging treatment.

 40 CFR 1500.2(b) because the USFS 

could not complete the necessary 

environmental analyses without all the 

effects evidence,

 40 CFR 1501.2(a) because the USFS 

did not identify environmental effects 

in adequate detail to complete a 

technical analyses of the project.

 40 CFR 1500.2(e) because the 

Responsible Official was unable to 

avoid or minimize adverse effects of 

the project upon the quality of the 

human environment without complete 

knowledge of all likely adverse effects. 

Some adverse effects of project 

activities described by scientists in the 

Attachments was not mentioned in the 

final NEPA document EA.

Please see Table D-11 to Table D-22, which responds to science/literature provided by 

commenters during the 45-day comment period, assessing the applicability to the 

project. The responses are provided in this appendix to the FEIS, which is also posted 

on the Forest’s website at: http://www.fs.usda.gov/project/?project=44907.

As described in 40 CFR 1500.2(a), compliance with applicable federal laws and 

regulations is one of the basic requirements of NEPA. The Magone Project complies 

with the NEPA by following the regulations at 40 CFR 1500, which detail how the 

agency shall prepare a DEIS, FEIS, and ROD. The Forest followed the regulation by 

conducting scoping on the proposed action (40 CFR 1501.7); using an interdisciplinary 

team to conduct and prepare the analysis document (40 CFR 1502.6); preparing a draft 

environmental impact statement (40 CFR 1502.9) using the recommended format (40 

CFR 1502.10 through 40 CFR 1502.18); and circulating the draft statement (40 CFR 

1502.19); inviting and responding to comments on the draft statement (40 CFR 

1502.9(b) and 40 CFR 1503).

The Magone EIS has fully met the requirements of 40 CFR 1500.1(b) and 40 CFR 

1500.1(c) by using best available science in analyses and engaging with the public at 

several points in the NEPA process, as described above.

The Magone EIS meets the purpose of 40 CFR 1500.2 by adhering to the NEPA and 

other relevant Federal and State laws and regulations. Section 1.5 of the Magone FEIS

(pages 47-48) lists the laws and regulations met under the decision document. The 

Magone FEIS discusses both the four alternatives considered in detail and the 12

alternatives considered but eliminated from detailed study. Alternatives and key issues 

were developed based on the purpose and need for the project, public comment, and 

the expertise of the interdisciplinary team members.

Magone FEIS chapter 3 summarizes the environmental effects of implementing three 

action alternatives and the no action alternative for a variety of resources. Effects 

analysis includes discussion of the range of effects and environmental consequences of 

the proposed alternatives, in addition to unavoidable adverse effects and irreversible 

and irretrievable commitments of resources. Magone FEIS Appendix C – Project Design 

Criteria lists project design criteria to mitigate project activities and protect resources.

The Magone FEIS fully meets the requirements of 40 CFR 1501.2 through the actions of 

the interdisciplinary team and the public outreach and involvement that was solicited, as 

mentioned above. A full list of the interdisciplinary team members and their qualifications 

can be found in the Magone FEIS chapter 4.
FEIS Appendix D – Public Comment Report Magone Project

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 40 CFR 1500.2(f) because the 

Responsible Official was unable to 

avoid or minimize any possible 

adverse effects upon the quality of the 

human environment without 

knowledge of the adverse effects. Had 

the Responsible Official known about 

these effects he would have 

acknowledged the existence of some 

adverse effects described in the 

Attachments in the final NEPA 

document EA.

Rejecting valid science because it s at 

odds with USFS timber agenda is also 

inconsistent with court precedent: Sierra 

Club v. Eubanks 335 F. Supp. 2d 1070 

(ED Cal. 2004), Seattle Audubon Society 

v. Lyons 871 F. Supp. 1291, 1318 (W.D. 

Wash. 1994), Seattle Audubon Society v. 

Moseley 798 F. Supp. 1473 (WD Wash. 

1992), Sierra Club v. Bosworth, 199 

F.Supp.2d 971, 980 (N.D. Cal. 2002).

422 C-06, 

page 52

The DEIS does not discuss the items 

shown below

(e) Energy requirements and 

conservation potential of various 

alternatives and mitigation measures.

(f) Natural or depletable resource 

requirements and conservation potential 

of various alternatives and mitigation 

measures.

(g) Urban quality, historic and cultural 

resources, and the design of the buil 

environment, including the reuse and 

conservation potential of various 

alternatives and mitigation measures.

Please comply with the law by including 

the missing information above. Failure to 

do so violates 40 CR 1502.16

When a federal agency proposes an action that will affect environmental quality, NEPA 

compels the agency to “utilize a systematic, interdisciplinary approach ... in planning 

and in decision making which may have an impact on man’s environment.” National 

Environmental Policy Act (NEPA) of 1969, PL 91-190, as amended. In the development 

of environmental impact statements, federal agencies are required to complete an 

analysis of the environmental consequences which forms the scientific and analytic 

basis of the comparisons of alternatives including the proposed action. Such analysis 

shall include discussions of direct and indirect effects and their significance, possible 

conflicts, the environmental effects of alternatives...and the means to mitigate adverse 

environmental impacts. 40 CFR 1502.16(a-h).

The Magone FEIS summarizes the environmental effects of implementing three action 

alternatives and the no action alternative for a variety of resources. Magone FEIS 

chapter 3, Affected Environment and Environmental Consequences, discusses the 

range of effects and environmental consequences of the proposed alternatives, in 

addition to unavoidable adverse effects and irreversible and irretrievable commitments 

of resources. Magone FEIS Appendix C – Project Design Criteria lists project design 

criteria to mitigate project activities and protect resources.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

423 C-06, 

page 53

The 20 page References section includes 

196 documents. Incredibly, 43 of these 

were authored by USFS employees. A 

word search of the DEIS reveals some of 

the references not written by USFS 

employees were not cited in the DEIS. 

They were included in the Literature 

Cited section for looks. Since this 

unprofessional behavior occurs here, why 

should the public believe what is 

contained in the DEIS?

The USFS uses the best available science and local research in making determinations 

not explicit in forest plan documentation and direction. Best available science and local 

research include peer-reviewed scientific literature, state and federal agency reports and 

management input, discussions with scientists and other professionals, and groundbased observations.

424 C-14, 

page 1

Proposed haul routes identified on 

private land on the enclosed silviculture 

treatment maps falsely indicate that an 

easement exists on our family’s property 

along the southern project boundary. The 

Forest holds no easement to these routes 

and they must be stricken from the maps 

in any resulting plan or future proposal.

We apologize for the error; Maps 3 and 5 have been corrected.

425 C-17, 

page 1; 

C-18, 

page 1; 

C-23, 

pages 

2, 3, 

and 4

As fisherman we strongly oppose the 

destruction of Beech Creek banks with 

the trees as was done in Camp Creek. 

That makes walking the Creekside while 

fishing impossible. Camp Creek shows 

no evidence of improving fish numbers 

and continually working in the creeks 

every 5 or 10 years also creates a 

continued disturbance to the natural 

recovery of these stream systems. Go 

look and fish Camp Creek to know what a 

mess the trees put in it has become. The 

streams in the Magone Project area 

presently have improving fish habitat as 

ODF&W fish surveys shows so why 

disrupt the improvement by putting trees 

in there?

Does the Aquatics Restoration EA apply 

to this project? If so, how would it be 

applied?

Aquatic restoration acceleration activities 

are no entirely necessary. Limit aquatic 

Actions implemented under the Aquatic Restoration Decision will be implemented 

following the procedures outlined in that document. The list and description of projects 

to be implemented each summer will be posted on this website each spring and at least 

30 days prior to planned implementation. Projects may also be posted and implemented 

at other times of the year. A Project Implementation Checklist will be used on each 

project to ensure all activities are consistent with the Malheur Forest Plan and project 

design criteria associated with the Aquatic Restoration Decision.

Please see the following website for information on future Aquatic Restoration Projects 

on the Malheur National Forest:

http://www.fs.usda.gov/detailfull/malheur/landmanagement/?cid=STELPRD3817723&wi

dth=full

Thank you for your comment: Could you provide data showing that no improvement has 

happened within Camp Creek other than not being able to walk the stream? Maybe it

has become more difficult to catch fish because of the trees in the water? The Forest 

Service is responsible for managing habitat to ensure the recovery of listed fish under 

the Endangered Species Act, and the habitat improvements within Camp Creek have 

been documented through photo monitoring over the last 5 years. Additionally juvenile 

abundance has demonstrated some annual increases depending on the water year. Lick 

Creek had 90 Mid-Columbia River steelhead redds counted last year (the most recorded 

since surveys began). Beaver have become established within the system where before 
FEIS Appendix D – Public Comment Report Magone Project

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restoration activities to removing log 

weirs and culvert replacement. There is 

not adequate need to add LWD/CWD or 

add beaver structures to accelerate the 

recovery that is already happening 

naturally. (ref.: ODF&W surveys of 

McClellan Creek already show significant 

increases in LWD/CWD-we attach copies 

of these surveys). Beaver are already 

established in the East Fork Beech Creek 

and McClellan Creek.

Many of these Aquatic Restoration 

Project Treatments are extensively 

analyzed within the DEIS, under section 

3.8 Analysis Issue-Aquatic Species. If the 

Magone Project includes the Aquatic 

Restoration activities only by reference, 

why is there a need for the Analysis 

Issue?

the work they were only transient. Beaver dams have persisted on Camp Creek for over 

2 years now.

We have photos of dead juvenile Mid-Columbia River steelhead at several locations in

East Fork Beech Creek within the last 5 years due to drying up of pools and portions of 

the stream.

At best Mid-Columbia River steelhead are maintaining lower than historical levels of 

abundance according to redd surveys within East Fork Beech Creek. Limitation for 

steelhead within East Fork Beech Creek revolve around survival of juvenile steelhead –

cobble dominated/straight channels are very effective at conveying water across the 

landscape and out of watersheds at a very fast rate resulting in low baseflows.

Thank you for providing the ODFW surveys: Shade has improved and we acknowledge 

that, percentage of pools is still below standards for the channel type according to 

PACFISH and our Forest Plan standards. However, the count of wood or log jams 

between the 1978 survey and 2008 survey could not be compared as one provided an x 

and the other was a number which did not define what they are counting as instream 

wood nor does it differentiate between instream wood and floodplain wood, therefore no 

comparison could be made. Additionally, these surveys are often ocular estimates for 

habitat while the R6 stream habitat surveys are measured physical habitat parameters 

that have been documented to be repeatable and are used for developing existing 

condition and analysis of effects for the Magone Project (2014).

Survey maps I presume include the sections of McClellan Creek and East Fork Beech 

Creek that are on your private land. We do not dispute that improvement has occurred 

on private land. We can only address conditions on federal lands which likely has had 

additional impacts from activities that did not occur to the same extent on your private 

land.

Aquatic restoration actions are reasonably foreseeable activities and therefore must be 

analyzed in the NEPA document, in particular as part of cumulative effects. Aquatic 

restoration actions address the existing condition.

Below is a graph of MCR Steelhead redd counts for East Fork Beech Creek beginning in 

1964; Camp/Lick Creek numbers look very different in particular within the last 5 years.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

426 C-18, 

page 1

You indicate that where plan information 

was not explicit, best available science 

(exactly what is this and from where did it 

come?) and local research (what is the 

local research source? PNW Research 

Station?) were utilized in a collaborative 

setting with stakeholders (exactly who 

were the contributing stakeholders?)

Best available science and local research include peer-reviewed scientific literature, 

state and federal agency reports and management input, discussions with scientists and 

other professionals, and ground-based observations. Additional local research includes 

work performed by seasonal Forest Service technicians; technicians perform in-depth 

project level surveys that include stand exams, fish habitat, stream condition, wildlife

habitat, road conditions, rare and invasive plants, and soil condition.

Those involved in the planning efforts for the Magone Project included Forest Service 

personnel, members of the public who engaged through attending public meetings or 

providing written comments, and the Blue Mountains Forest Partners collaborative 

group.

427 C-18, 

page 1

Was Coordination Invoked by the County 

Government or any other government on 

this project? If so, when and what were 

the specifics?

Under the National Forest Management Act (NFMA) and its implementing regulations, 

the Forest Service is required to coordinate land management planning for the National 

Forest System (such as the amendment and revision of forest plans) with land 

management planning conducted by State and local governments. This coordination 

allows the Forest Service to take into account and consider the State or county’s 

proposed management for lands under their jurisdiction, and vice versa. The statute 
FEIS Appendix D – Public Comment Report Magone Project

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Comment

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Source Comment Forest Service response

does not specify what actions are required to coordinate Forest Service planning with 

local government planning, and it does not in any way subordinate Federal authority to 

counties. Rather, the Forest Service must consider the objectives of State and local 

governments and Indian Tribes as expressed in their plans and policies, assess the 

interrelated impacts of these plans and policies, and determine how the forest plan 

should deal with the impacts identified.

The Magone FEIS chapter 4 lists the individuals, Federal, State, and local agencies, and 

tribes officially consulted with during the development of this environmental impact 

statement.

Letters announcing the scoping period and comment period for the DEIS were sent to 

the Grant County Commissioners, Grant County Court, Grant County Road Department, 

members of the Grant County Forest Commission, the Grant County Access Advisory 

Board and several school districts within the County. One comment was received during 

the 45-day comment period and was considered by the IDT.

Additionally, information regarding the project and public comment periods were 

available through the following sources:

 Publication of the notice of intent (NOI) to prepare an environmental impact 

statement (February 2015) and the notice of availability (NOA) of the draft 

environmental impact statement (DEIS) (February 2016) in the Federal Register.

 Publication of legal notices and news articles in the Blue Mountain Eagle 

announcing the resource stories (August 2014), scoping period (February 2015) and 

45-day comment period on the DEIS (February 2016).

 Mailings on the availability of resource stories (August 2014), scoping (February 

2015), and availability of the DEIS (February 2016) to a list of approximately 150 

(including those local officials listed above) people that reside in a variety of

locations.

Information has also been available to the public on the Malheur National Forest’s 

webpage since August 2014: http://www.fs.usda.gov/project/?project=44907

In addition, Forest Service personnel met with the Grant County Court on March 2, 

2016, and presented information about the Magone Project.

428 C-18, 

page 2

Was the Grant County Oregon Public 

Lands Natural Resources Plan dated 

September 1, 2015 received and filed in 

the Grant County Recorders office on 

September 30, 2015 by Julie Ellison for 

Brenda Percy, County clerk reviewed or 

considered in this project? If not, why not 

and if so, in what specific areas?

Referencing the Grant County Oregon 

Public lands Natural Resources Plan 

The Magone Project follows the Malheur Forest Plan and other applicable law, 

regulation, and agency policies.

The Grant County Oregon Public Lands Natural Resource Plan referenced by the 

commenter was ruled to be unconstitutional by Grant County Circuit Court Judge 

William D. Cramer Jr. on January 26, 2016.
FEIS Appendix D – Public Comment Report Magone Project

73

Comment

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Source Comment Forest Service response

please let me know specifically how the 

Magone Project addresses the following 

areas:

 Data Quality page 13

 Economy pages 14, 15, 16

 Access and Travel Management 

pages 17,18

 Livestock Production pages 19, 20, 

21

 Forest Resources pages 22,23, 24

 Recreation and Tourism pages 26, 27

 Watersheds pages 31,32

429 NEPA requires the project be coordinated 

with local government.

 Have the local governments been 

involved? Who and for how long? If 

not, why not?

 What are their positions? Have those 

positions been taken into account? If 

not, why not? If so, specifically how? 

Have those positions been discussed 

and analyzed? If so, please can we 

see the analysis? If not, why not?

 Are there items needing to be 

resolved?

 Any inconsistencies between the local 

government(s) and the federal 

agencies? What is the plan for 

discussion of any conflicts that cannot 

be resolved?

 How will those discussions be 

documented in the final document?

 When an inconsistency exists will 

there be a statement describing the 

extent to which the agency would 

reconcile its proposed action?

 Will the agency actively work to find 

ways to resolve inconsistencies and if 

The Magone Project follows the National Environmental Policy Act, which establishes 

the process for involving local and county governments. Letters announcing the scoping 

period and comment period for the DEIS were sent to the Grant County Commissioners, 

Grant County Court, Grant County Road Department, members of the Grant County 

Forest Commission, the Grant County Access Advisory Board and several school 

districts within the County. One comment from this group was received during the 45-

day comment period and was considered and responded to by the IDT.

Additionally, information regarding the project and public comment periods were 

available through the following sources:

 Publication of the notice of intent (NOI) to prepare an environmental impact 

statement (February 2015) and the notice of availability (NOA) of the draft 

environmental impact statement (DEIS) (February 2016) in the Federal Register.

 Publication of legal notices and news articles in the Blue Mountain Eagle 

announcing the resource stories (August 2014), scoping period (February 2015) and 

45-day comment period on the DEIS (February 2016).

 Mailings on the availability of resource stories (August 2014), scoping (February 

2015), and availability of the DEIS (February 2016) to a list of approximately 150 

(including those local officials listed above) people that reside in a variety of 

locations.

Information has also been available on the Malheur National Forest’s webpage since 

August 2014: http://www.fs.usda.gov/project/?project=44907

Section 1.4.1.5 Social Values and Opportunities (pages 40-41) in the FEIS discusses 

the desired conditions for wood products and local employment. Magone FEIS, Tables

15 and 49 provide further information on the effects on employment and income based 

on each action alternative.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

they cannot, explain why these could 

not be resolved in an analysis?

 Has an analyses been done or will 

one be done to show the “impact this 

proposed action will have on the 

productive use of our land and local 

economy”?

430 C-18, 

page 2

How do I obtain Data Quality (Data 

Quality Act or Information Quality Act of 

2001) information on the Magone Project 

specific to:

 Quality

 Objectivity

 Utility

 Integrity

Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 

2001 (Public Law 106-554), now commonly referred to as the Data Quality Act, directs 

the Office of Management and Budget (OMB) to issue guidelines for ensuring and 

maximizing the quality, objectivity, utility, and integrity of the data. 

USDA’s information quality guidelines and administrative mechanisms conform to the 

requirements of OMB’s information quality guidelines. The USDA’s guidelines for 

Information Quality Activities can be found at the following webpage:

http://www.ocio.usda.gov/policy-directives-records-forms/information-quality-activities

These guidelines were followed in determining the best available science and local 

research to utilize in addition to forest plan information for the Magone FEIS and 

resource specialist reports.

The project scoping package, DEIS, and specialist reports are available online at the 

forest website (http://www.fs.usda.gov/project/?project=44907). If you would like 

additional project information, you may submit a Freedom of Information Act (FOIA) 

request to obtain the project record; FOIA requests can be made through the Malheur 

National Forest Environmental Coordinator. To learn more about the FOIA process and 

how to file a request, please visit: http://www.foia.gov/about.html

431 C-23, 

page 3

We have repeatedly asked for 

documentation that certifies the 

accomplishments from the Camp Creek, 

Lick Creek and Cougar Creek projects 

that shows LWD/CWD additions at the 

rate of 80-120 stems per mile have 

benefited fish recovery (see photos 

attached to scoping comments.) What 

monitoring data has been collected and 

has adequate time passed to certify that 

these projects have been successful? 

In general, aquatic restoration actions such as large and coarse wood placement are not 

conducted solely to increase fish numbers as was done in the past with log weirs (to 

increase spawning). Actions focus on restoring processes that create quality fish habitat 

for multiple life stages (juvenile rearing, spawning, and migration) and involve a multi 

stage approach not only adding LWD/CWD which is just one step in the process. Other 

benefits associated with wood include floodplain connectivity (water storage), It also 

takes into account upland processes that may have been altered and are manifested 

within the stream network as well (e.g., drying of the stream channel).

We have a series of photos from the 2011 work demonstrating channel W:D 

improvement and vegetation. ODFW recorded its highest level ever of Mid-Columbia 

River steelhead redd counts within Lick Creek in 2015 (90 redds). ODFW has also been 

monitoring juvenile abundance within Camp Creek which had a very high number in 

2012, but has fluctuated due to drought conditions. Beaver have become established 

within Camp Creek for the past 3 years (juvenile rearing) where previously they were 

only transitory increasing water storage and residence time.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

While fish recovery is the ultimate goal it will not occur without recovery of the processes 

that create quality fish habitat and are self-maintain as well as suitable environmental 

conditions such as climate and ocean conditions.

While it is intuitive to think that fish numbers are direct indicators of aquatic restoration 

success it is imperative to realize that there are a large number of factors from ocean 

conditions, climate scenarios, etc. that also effect the number of anadromous fish 

returning each year. Because of this, gauges for success are not directly linked to fish 

numbers or pieces of large wood but to restoration of hydrological, physical, and 

vegetative processes that create complex fish habitat, channel morphometry, suitable 

water temperatures, and riparian vegetation communities that persist and are selfmaintaining long-term. Thus monitoring focuses on these variables that are measurable 

and repeatable, and not on fish numbers as indicators of success (examples may 

include width to depth ratios, willow stem plot counts, and even some of the indicators 

used for monitoring livestock grazing). In general, time frames for successful vegetative 

aspects may be realized in 2 to 5 years. But stream channel and hydrological processes 

may take decades depending on the actions.

Return of beaver to Camp Creek and more so the longevity of their dams and 

persistence within Camp Creek is a signal of vegetative and physical recovery within 

those areas (beaver habitat restoration) in particular floodplain connectivity.

80- to 120 trees/mile within a mixed conifer forest is identified as wood loading 

requirements within the Malheur Forest Plan and PACFISH (1994). These numbers 

were generated from areas within the Malheur National Forest and the Columbia Basin.

During our meeting in regards to the East Fork Beech Creek Project, I provided the 

below literature in regards to wood restoration and current knowledge gaps:

http://www.sciencedirect.com/science/article/pii/S0169555X16302082

432 C-29, 

page 3

It appears to us that the majority of the 

fish habitat improvement will take place 

as a result of the Aquatic Restoration EA, 

and not the project analyzed in this EIS. 

However, in several cases it appears to 

us that it will be very important that the 

aquatic restoration activities take place 

before the logging anticipated in this 

project. No matter how carefully the

project is designed, there will be soil 

erosion from activities in the area. You 

have clearly explained that if the course 

woody debris and beaver dam analogs 

are already in place, the fine materials 

that will likely run off could be used to 

help refill incised stream channels. 

That is correct, some soil erosion is anticipated from the activities but adequate 

maintenance of riparian habitat conservation area (RHCA) buffers would capture and 

filter the minor amount of sediment generated from project activities that would not be 

measurable beyond background levels.

The largest portion of sediment generated would occur as part of undersized/failed 

culverts and removal of roadbeds that “pinch” the valley and create sediment fans 

(alluvial fan restoration). Currently, these occur at every tributary confluence with East 

Fork Beech Creek and in specific areas of Clear Creek and Tinker Creek. Aquatic 

restoration work is planned to begin in 2017 on the lowermost reaches of East Fork

Beech Creek and progress upstream. Replacing and or removing these culverts and 

releasing the sediment deltas would not occur until after the section of East Fork Beech 

Creek immediately downstream have had aquatic activities completed. These actions 

would follow placement of large and coarse woody debris downstream. The Aquatic 

Restoration EA acknowledges there would be short-term adverse effects related to 

sediment generation and aquatic restoration activities for long-term benefit.
FEIS Appendix D – Public Comment Report Magone Project

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Source Comment Forest Service response

However, if those projects are not 

complete, the opportunity will be lost, and 

soil erosion will be just that.

433 C-29, 

page 11

On page 127 the DEIS asserts that 

“currently, the project planning area is 

within HRV for old forest structure (OFSS 

and OFMS) for all of the PAGs analyzed 

above.” This statement is not consistent 

with the information provided above.

Here is a breakdown of current OFSS and OFMS compared to HRV. Although two of 

the structural classes are below HRV (Warm Dry UF OFSS and Hot Dry UF OFSS), 

their corresponding structures (Warm Dry UF OFMS and Hot Dry UF OFMS) are well 

above HRV. The statement described in the comment was referring to old forest 

structure as a whole (OFSS and OFMS combined). However, since this statement may 

be misleading, it will be rewritten in the Magone FEIS to reflect the concern brought 

forward by this comment.

PAG Structure HRV Existing Condition

Warm Dry UF OFSS 15-55% 3%

OFMS 5-20% 30%

Hot Dry UF OFSS 20-70% 2%

OFMS 2-15% 22%

Cool Moist UF OFSS 0-5% 10%

OFMS 10-30% 48%

Cold Dry UF OFSS 10-40% 13%

OFMS 0-5% 1%

Warm Moist 

UF

OFSS 0-5% 2%

OFMS 10-30% 25%

434 C-29, 

page 14

Although this project has no authority to 

alter grazing permits, it would have the

authority to treat other impacts from 

grazing. For example it could fence 

riparian areas, jackstraw trees in riparian 

areas making creek access more difficult, 

or build troughs or guzzlers outside of 

riparian areas to attempt to draw some of 

the use away from fragile stream buffers. 

These activities should be considered

when attempting to return an area to its 

historical range of variability as outlined 

in the Purpose and Need of this 

document. If these activities are already 

Activities that are currently planned for the project planning area are disclosed in the 

cumulative effects section (Magone FEIS, Table 17).

Projects that are proposed under the Aquatic Restoration Decision will be posted to the 

Forest Service webpage and a 60 day comment period will be provided.
FEIS Appendix D – Public Comment Report Magone Project

77

Comment

number

Source Comment Forest Service response

planned in the Aquatic EA, they should 

be referenced here.

435 C-29, 

page 18

Please include a map of the current 

DOG, ROG and connectivity corridor 

boundaries (Alt 1) in the FEIS.

The current dedicated old growth and replacement old growth areas are identified in 

Magone FEIS Appendix B – Maps, Map 2. Current Malheur Forest Plan management 

areas. Connectivity corridors are not currently identified within the Magone project 

planning area; the proposed connectivity corridors are identified in Magone FEIS 

Appendix B – Maps, Maps 13 and 14.
FEIS Appendix D – Public Comment Report Magone Project

78

Consideration of Science/Literature Submitted by the Public

Members of the Magone Project interdisciplinary team are considered proficient in their field of study by 

way of academic achievement, training, years of professional experience, and in some cases, certification 

programs. In addition, team specialists have cited numerous studies and literature to support discussions 

and conclusions made in this project’s analysis (see the literature cited sections of the Magone FEIS and 

its supporting appendices).

Table D-11 to Table D-22 summarizes the Forest Service consideration of publications that were provided 

during the comment period and which were directly referenced in the comments, or determined to either 

have some relevance to the analysis or indicate there is a difference of opinion within the body of the 

science. NEPA states that comments on the EIS shall be as specific as possible (40 CFR 1503.3 

Specificity of Comments). Some of the following documents are considered non-substantive comments 

that do not warrant further response. In either case, the following table explains the consideration given 

by the Forest Service.
FEIS Appendix D – Public Comment Report Magone Project

79

Table D-11. Consideration of science/literature submitted during the 45-day comment period related to forest vegetation, fire, and fuels

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

ABC News Australia. 2014. Logging can “greatly 

increase” fire severity for 50 years, researchers say. 

August 3.

http://www.abc.net.au/news/2014-08-04/logginggreatly-increases-fires-risk-black-saturdaystudy/5646220

C-06, Opposing Views 

Attachment #3, page 28

Not 

applicable

This is not scientific peer reviewed literature. This 

is a news article from Australia.

Aber, J., N. Christensen, I. Fernandez, J. Franklin, L. 

Hidinger, M. Hunter, J. McMahon, D. Mladenhoff, J. 

Pastor, D. Perry, R. Slangen, and H. Van Miegroet. 

2000. Applying ecological principles to management 

of U.S. National Forests. Issues in Ecology 6. 20 p. 

Washington, DC: Ecological Society of America.

http://digitalcommons.usu.edu/wats_facpub/46/

C-06, Opposing Views 

Attachment #1, page 3; C-06, 

Opposing Views Attachment 

#4, page 2

Relevant to 

this project

This is a position paper in which the authors 

describe what they believe are the ecological 

considerations that should be incorporated in forest 

management policy. The paper summarizes some 

potential effects of timber harvest and roads. 

However, it is not scientific, peer-reviewed 

literature.

The effects of proposed activities, including timber 

harvest, on snags and downed wood, structural 

diversity and impact to tree and stand resiliency 

can be found in the Magone FEIS chapter 3. The 

Forest recognizes that timber harvest activities 

may have detrimental effects as well as the 

positive effects desired in proposed vegetation 

treatment activities. The deciding official will 

consider all effects when making a decision on this 

project.

Agee, J.K. 1997. The severe weather wildfire: too hot 

to handle? Northwest Science 71(1): 153-157.

http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Age

e_97.pdf

C-06, Opposing Views 

Attachment #3, page 1

Supports the 

analysis

The document is applicable and consistent with 

literature used in the analysis. Large, severe 

wildfires are more weather-dependent than fueldependent. Climate plays an important role in the 

intensity and severity of wildfire. This paper does 

not consider the significance of the fuels complex 

and the direct correlation to fire intensity/severity. 

Fuel condition also affects the intensity/severity 

and is the only function that can be manipulated in 

order to reduce future intensities.

Al-jabber, J.M. 2003. Habitat fragmentation: effects 

and implications. Clearcuts and forest fragmentation, 

Willamette NF, Oregon. Cascadia Wildland Project.

http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fra

gmentation%20Effects%20and%20Implication.pdf

C-06 Opposing Views 

Attachment #1, page 1; C-06, 

Opposing Views Attachment 

#4, page 1

Relevant to 

this project

This unpublished, non-peer reviewed paper 

summarizes the general effects of habitat 

fragmentation (including connectivity, corridors and 

buffer zones). The Magone FEIS chapter 3, Wildlife 

section and species-specific analyses in the 
FEIS Appendix D – Public Comment Report Magone Project

80

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Wildlife Report discuss and analyze the impacts of 

habitat fragmentation.

Clearcuts are not prescribed for this area and 

silviculture and wildlife are working together to 

avoid fragmentation issues.

Barry, G. 2002. Commercial logging causes wildfires. 

Portland, OR: Portland Independent Media Center. 

August.

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

SC-06, Opposing Views 

Attachment #1, page 3; C-06, 

Opposing Views Attachment 

#3, page 1

Not 

applicable

Non-peer reviewed article denounces all 

commercial timber harvest on National Forest 

System lands. This document is an opinion piece 

that has not been published in a scientifically peer 

reviewed outlet. The document and its findings 

have not been subjected to the rigors of formal 

technical or peer review.

Barry, J.B. 1999. Stop the logging, start the 

restoration. The Planet, a newsletter of the Sierra 

Club. 6(5).

http://www.sierraclub.org/planet/199905/ecl1.asp

SC-06, Opposing Views 

Attachment #1, page 4

Not 

applicable

This is not scientific peer reviewed literature. This 

is an opinion paper published in a 1999 Sierra Club 

newsletter supporting and advocating an end to the 

Forest Service timber sale program. It cites a 1998 

poll that states that 69 percent of Americans 

oppose commercial logging on federally owned 

land; and a Forest Service poll that showed 59 

percent of Americans who expressed an opinion 

oppose timber sales and other commodity 

production in national forests.

The Club supported a bipartisan National Forest 

Protection and Restoration Act that would eliminate 

money-losing commercial logging in national 

forests, promote restoration and help communities 

that receive logging revenue develop more diverse 

and stable economies. This Act did not become 

law.

Behan. R.W. 1990. Multiresource forest management: 

a paradigmatic challenge to professional forestry. 

Journal of Forestry 88(4): 12-18.

http://www.cabdirect.org/abstracts/19920663623.html

?freeview=true

C-06, page 64 Not 

applicable

This article discusses differences between 

sustained yield, multiple-use management, and 

multiresource forest management (which seeks the 

simultaneous production of several interdependent 

substances and services). The author asserts that 

the sustained yield concept does not fit 

contemporary society and a different paradigm of 

forest management is required, where the forest is 

appreciated for an array of commodity and amenity 

values.
FEIS Appendix D – Public Comment Report Magone Project

81

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

The Magone Project was not developed for the 

sustained yield of any resource. This project was 

developed by an interdisciplinary team to increase 

the ecological resiliency of the project planning 

area through restoring forest structure and pattern, 

vegetation composition and diversity, and riparian 

communities to conditions that are more resilient to 

natural disturbance processes. As well as provide 

for a variety of ecological and social values such as 

fish and wildlife habitat, increased water storage 

and availability, recreational opportunities, and a 

variety of wood products and employment 

opportunities.

Berry, A. 2007. Forest policy up in smoke: fire 

suppression in the United States. Property and 

Environment Research Center.

http://perc.org/sites/default/files/Forest%20Policy%20

Up%20in%20Smoke.pdf

C-06, Opposing Views 

Attachment #3, page 2

Not 

applicable

This paper speaks mainly to national policy that 

cannot be changed with the Magone Project. This 

is not scientific peer reviewed literature

Bessie, W.C. and E.A. Johnson. 1995. The relative 

importance of fuels and weather on fire behavior in 

subalpine forests. Ecology. 76(3): 747-762.

http://www.jstor.org/pss/1939341

C-06, Opposing Views 

Attachment #3, page 2

Not 

applicable

Paper discusses relationship between fuels and 

climate as related to fire behavior in the southern 

subalpine fir forests of Canada.

Bird, B. 2007. Fires normal part of ecology: fear of 

fires ungrounded. Mountain View Telegraph. 

December 20.

http://www.wildearthguardians.org/site/News2?page=

NewsArticle&id=5790#.VQdhxZgcSic

C-06, Opposing Views 

Attachment #3, page 2

Not used This is not scientific peer reviewed literature. This 

opinion paper discusses the direct effects of 

climate and does not consider the correlation to the 

fuels complex.

Bunnell, F.L., K.A. Squires, and I. Houde. 2004. 

Evaluating the effects of large-scale salvage logging 

for mountain pine beetle on terrestrial and aquatic 

vertebrates. Natural Resources Canada, Canadian 

Forest Service, Pacific Forestry Centre, Victoria, BC. 

Mountain Pine Beetle Initiative Working Paper 2004-

02. 57 p.

http://www.cfs.nrcan.gc.ca/publications?id=25154

C-06, Opposing Views 

Attachment #4, page 5

Not 

applicable

The article is focused on large-scale salvage 

logging in bug-killed timber in Canada and the 

effect it could have on different animal species. 

The actions proposed for the Magone project 

planning area have been in collaboration with the 

fish and wildlife biologists on the district, to ensure 

habitat is being minimally impacted, and in some 

cases, avoided altogether. No salvage logging is 

proposed in the Magone Project.

Campbell, J., D. Donato, J.B. Fontaine, J.B. 

Kauffman, B.E. Law, and D. Robinson. 2003. Biscuit 

C-06, page 31 Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.
FEIS Appendix D – Public Comment Report Magone Project

82

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Fire Study. Corvallis, OR: Oregon State University 

Department of Forest Science.

http://terraweb.forestry.oregonstate.edu/biscuit.htm

Campbell, J. 2014. Study finds logging increased 

intensity of Black Saturday fires. Herald Sun. August 

3.

http://www.heraldsun.com.au/news/victoria/studyfinds-logging-increased-intensity-of-black-saturdayfires/story-fni0fit3-1227012027799

C-06, Opposing Views 

Attachment #3, page 29

Not 

applicable

This is not scientific peer reviewed literature. This 

is a news article from Australia.

Cissel, J.H., F.J. Swanson, W.A. McKee, and A. 

Burditt. 1994. Using the past to plan the future in the 

Pacific Northwest. Journal of Forestry 92(8): 30-46.

http://www.ingentaconnect.com/search/article?option2

=author&value2=Cissel&pageSize=10&index=7

C-06, page 60 Consistent 

with project

Journal article discusses two schools of thought 

regarding landscape planning: 1) future landscape 

patterns are described in terms of desired products 

such as wood fiber or habitat, or 2) future 

landscape patterns are based on historical 

patterns. The authors believe elements of both 

approaches can be combined for successful 

ecosystem management. The Magone Project 

combines both elements for the desired future 

condition. The overall objective for the Magone 

project planning area is to increase landscape 

resiliency. This is the desired product for the future. 

However, this desired future condition is informed 

and developed from historical conditions on the 

landscape that include fire history, riparian and 

upland species composition, density, water 

storage, and wildlife habitat.

Coe, N.J. 2011. Forestry shouldn’t be an ‘industry.’ 

Durango Herald. February 12.

http://www.durangoherald.com/article/20110213/OPIN

ION03/702139987/Forestry-shouldn%E2%80%99tbe-an-%E2%80%98industry%E2%80%99

C-06, Opposing Views 

Attachment #3, page 3

Not 

applicable

This is a letter to the editor published in the 

Durango Herald and is an opinion piece that has 

not been published in a scientifically peer reviewed 

outlet. The document and its findings have not 

been subjected to the rigors of formal technical or 

peer review.

Cohen, J.D. 1999. Reducing the wildland fire threat to 

homes: Where and how much? In: Proceedings of the 

symposium on fire economics, planning, and policy: 

bottom lines. General Technical Report PSW-GTR173. Albany, CA: U.S Department of Agriculture, 

Forest Service, Pacific Southwest Research Station. 

pp. 189-195.

C-06, page 35; C-06, 

Opposing Views Attachment 

#11, page 4

Limited 

applicability

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 
FEIS Appendix D – Public Comment Report Magone Project

83

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen

_j001.pdf

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 

consultants.

Cohen, J.D. 2000. Examination of the home 

destruction in Los Alamos associated with the Cerro 

Grande Fire, July 10, 2000. Fire Sciences Laboratory. 

Missoula, MT: U.S. Department of Agriculture, Forest 

Service, Rocky Mountain Research Station. 6 p.

http://www.fs.fed.us/rm/pubs_other/rmrs_2000_cohen

_j001.pdf

C-06, Opposing Views 

Attachment #11, page 5

Limited 

applicability

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 

consultants.

Cohen, J. D. 2000. Preventing disaster: home 

ignitability in the wildland-urban interface. Journal of 

Forestry. 98(3): 15-21.

http://www.fs.fed.us/rm/pubs_other/rmrs_2000_cohen

_j002.pdf

C-06, Opposing Views 

Attachment #11, pages 9-10

Not 

applicable

Article discusses the ignitability of homes in the 

wildland-urban interface and the responsibility of 

homeowners in ensuring that their properties have 

low ignitability in the event of a wildland fire.

Cohen, J.D. 2001. Wildland-urban fire—a different 

approach. In: Proceedings of the firefighter safety 

summit, International Association of Wildland Fire, 

Missoula, MT.

http://www.angelfirenm.gov/assets/documents/CWPP

AppendixE-9ce7d27514.pdf

C-06, Opposing Views 

Attachment #11, page 3

Limited 

applicability

Fire is an intrinsic process of North American 

ecosystems. However, past activities have led to 

uncharacteristic wild fires. This article discusses 

the ignitability of homes in the wildland-urban 

interface and the responsibility of homeowners in 

ensuring that their properties have low ignitability in 

the event of a wildland fire. The Magone Project 

focuses on reducing the effects of uncharacteristic 

wildfire within the project planning area, including 

the wildland-urban interface. The Grant County 

Community Wildfire Protection Plan provides a link 

between landowners and federal officials allowing 

both parties to come together and do their part to 

minimize impacts to private land from wildland 

fires.
FEIS Appendix D – Public Comment Report Magone Project

84

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Cohen, J.D. 2008. The wildland-urban interface fire 

problem—a consequence of the fire exclusion 

paradigm. Forest History Today. Fall issue: 20-26.

http://www.foresthistory.org/Publications/FHT/FHTFall

2008/Cohen.pdf

C-06, Opposing Views 

Attachment #11, page 6

Limited 

applicability

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 

consultants.

Cohen, J.D. and B.W. Butler. 1998. Modeling 

potential structure ignitions from flame radiation 

exposure with implications for wildland/urban interface 

fire management. In: Proceedings of the 13th fire and 

forest meteorology conference. Lorne, Australia.

http://www.fs.fed.us/rm/pubs_other/rmrs_1998_cohen

_j001.pdf

C-06, Opposing Views 

Attachment #11, page 9

Limited 

applicability

See the above response to comment.

Cohen, J.D. and J. Saveland. 1997. Structure ignition 

assessment can help reduce fire damages in the 

WUI. Fire Management Notes 57(4): 19-23.

http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen

_j001.pdf

C-06, Opposing Views 

Attachment #11, page 5

Limited 

applicability

See the above response to comment.

Cushman, J.H. 1999. Audit faults Forest Service on 

logging damage in U.S. Forests. New York Times. 

February 5.

http://query.nytimes.com/gst/fullpage.html?res=9B00

E2DF163BF936A35751C0A96F958260&sec=&spon=

&pagewanted=print

C-06, Opposing Views 

Attachment #1, page 4

Not relevant 

to this project

The article is a summary of an Agriculture 

Department Inspector General’s report that 

reviewed 12 timber sales from 1995 to 1998. The 

article states the report found fault with both the 

environmental assessments for the projects and 

that “rules” were not followed when the sales were 

implemented on the ground.

The report looked at a number of timber sale 

contracts and NEPA project-level analyses to 

determine compliance with mitigations and terms of 

the decisions and contracts. The article was not 

applied by the commenter to the site-specific 

aspect of the Magone Project NEPA analysis. 

Programmatic reviews such as the one discussed 
FEIS Appendix D – Public Comment Report Magone Project

85

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

in the article are not specific to this project’s sitespecific environmental analysis.

Dombeck, M. 1998. A message on “conservation 

leadership” sent to all U.S. Forest Service employees 

on July 1.

http://www.wvhighlands.org/VoicePast/VoiceAug98/D

ombeck.Aug98.html

C-06, page 6; C-06, 

Opposing Views Attachment 

#1, page 6

Not relevant 

to this project

This is a message from then-Chief Mike Dombeck

sharing his view on what makes a “conservation 

leader” in the context of his natural resource 

agenda.

It is not specific to any laws, regulations, or policies 

that would be pertinent to the Magone Project 

analysis.

Egan, Timothy. 2000. Fires not caused by reduced 

logging, congressional report finds. New York Times. 

September 1.

http://www.nytimes.com/2000/09/01/us/fires-notcaused-by-reduced-logging-congressional-reportfinds.html

C-06, Opposing Views 

Attachment #3, page 27

Not 

applicable

This is not scientific peer reviewed literature. This 

is a newspaper article.

Ehrlich, A., D. Foster, and P. Raven. 2002. Call to end 

logging based on conservation biology. Native Forest 

Network.

http://www.nativeforest.org/campaigns/public_lands/st

b_5_30_02.htm

C-06, Opposing Views 

Attachment #1, page 6

Not relevant 

to this project

In 2003, 221 PhD-level scientists signed a letter to 

President Bush urging him to end commercial 

logging and road construction in National Forests 

and invest in forest restoration. They believed that 

protecting national forests creates more economic 

benefits than continued logging and advocate a 

shift in federal funding of the timber sale program 

into a program that pays local contractors to 

restore national forests. It represents an opinion 

that contains no sources, references, or literature 

cited and is not scientific, peer-reviewed literature.

The authors’ recommendations regarding the 

federal timber sale program are not specific to this 

project.

Engelfried, N. 2013. Stop drilling and logging on 

federal lands while the public is kept out. A petition 

targeted for Secretary of the Interior Sally Jewel and 

Secretary of Agriculture Tom Vilsack. Posted at 

FORCECHANGE.COM.

http://forcechange.com/86223/stop-drilling-andlogging-on-federal-lands-while-the-public-is-kept-out/

C-06, Opposing Views 

Attachment #1, page 52

Not 

applicable

This is a petition form letter on the 

forcechange.com website aimed at gathering 

signatures for submission to federal officials. It is 

not scientific, peer-reviewed literature and contains 

no sources, references, or literature cited.

Erman, D.C. (general editor) and the SNEP Team. 

2007. Status of the Sierra Nevada: the Sierra Nevada 

C-06, page 23 Consistent 

with analysis

This is an extensive report that was developed by 

many scientists about the status and management 

recommendations for the Sierra Nevada forest. 
FEIS Appendix D – Public Comment Report Magone Project

86

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Ecosystem Project. U.S. Department of the Interior, 

U.S. Geological Survey.

http://pubs.usgs.gov/dds/dds-43/

The quote that the commenter refers to in his 

comment about logging refers to historical logging 

practices that removed the large, old-growth trees, 

left the smaller diameter trees, and did not treat 

fuels or prescribe burn after mechanical treatment. 

This report actually recommends the use of 

thinning from below with the treatment of surface 

fuels followed by prescribed burning to help restore 

more historical fire patterns across the forest. This 

report states that thinning from below “should result 

in fairly open stands, dominated mostly by larger 

trees of fire-tolerant species.” This report indicates 

that thinning and fuels treatments would set the 

stage for prescribed burning and the future use of 

managed fire across the landscape. 

Fahnestock, G.R. 1968. Fire hazard from 

precommercial thinning of ponderosa pine. Research 

Paper PNW-RP-057. Portland, OR: U.S. Department 

of Agriculture, Forest Service, Pacific Northwest 

Research Station.

http://www.treesearch.fs.fed.us/pubs/25881

C-06, page 24 Limited 

applicability

The treatment discussed in this research paper is 

to thin non-commercial trees and leave them where 

they lie. All non-commercial treatments in the 

Magone planning area have a slash treatment 

associated with them. The Magone FEIS 

recognizes immediately following a mechanical 

treatment there is an increase in surface fuels and 

an associated fire hazard with the additional fuel 

load. All existing slash and created slash should be 

treated to a threshold that would limit the potential 

for high severity fires should an ignition occur. 

Slash treatment options of non-commercial 

material include piling and burning or 

underburning.

Firewise. Safety information for consumers.

http://www.nfpa.org/safety-information/forconsumers/outdoors/wildland-fires

C-06, page 34 Not 

applicable

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 
FEIS Appendix D – Public Comment Report Magone Project

87

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

consultants. Information can be found at 

http://www.grantcountycwpp.com/

Firewise. The basics of defensible space and the 

“home ignition zone.”

http://www.firewise.org/wildfire-preparedness/befirewise/home-and-landscape/defensiblespace.aspx?sso=0

C-06, page 34 Not 

applicable

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 

consultants. Information can be found at 

http://www.grantcountycwpp.com/

Firewise. The Jack Cohen files.

http://firewise.org/wildfire-preparedness/wui-homeignition-research/the-jack-cohen-files.aspx?sso=0

C-06, page 35 Not 

applicable

These articles primarily focus on structures in the 

WUI and what home owners can do to improve the 

chances of their home surviving a wildfire should 

one occur.

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as

consultants.

Firewise. Wildfire preparedness, home & landscape.

http://www.firewise.org/wildfire-preparedness/befirewise/home-and-landscape.aspx?sso=0

C-06, page 34 Not 

applicable

The Grant County Community Wildfire Protection 

Plan (CWPP) allows a community to evaluate its 

current situation regarding wildfire risk and plan 

ways to reduce risk for protection of human welfare 

and other important economic, social, or ecological 

values. The CWPP may address issues such as 

community wildfire risk, structure flammability, 

hazardous fuels and non-fuels mitigation, 
FEIS Appendix D – Public Comment Report Magone Project

88

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

community preparedness, and emergency 

procedures. Representatives from the U.S. Forest 

Service and the Bureau of Land Management 

should be engaged in the CWPP process as 

consultants. Information can be found at 

http://www.grantcountycwpp.com/

Forest Conservation News Today. 2002. Bush fire 

policy: clearing forests so they do not burn. August 

27.

http://forests.org/archived_site/today/recent/2002/tipor

efl.htm

C-06, Opposing Views 

Attachment #1, page 7. C-06, 

Opposing Views Attachment 

#3, page 3

Not 

applicable

The article is an opinion piece and not a peer 

reviewed scientific study on President Bush’s plan 

to “increase logging on federal lands in order to 

reduce the risk of wildfires.”

Forest Policy Research. 2008. California: too often 

thinning treatments tend to increase fire hazards.

http://forestpolicyresearch.org/2008/12/19/californiatoo-often-thinning-treatments-tend-to-increase-firehazards/

C-06, Opposing Views 

Attachment #3, page 4

Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.

Forest Policy Research. 2008. Montana: Blackfoot 

Clearwater Stewardship Proposal is all about selling 

out to Pyramid lumber.

http://forestpolicyresearch.org/2008/12/19/blackfootclearwater-stewardship-proposal-is-all-selling-out-topyramid-lumber/

C-06, Opposing Views 

Attachment #3, page 4

Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.

Forests Monitor. 2006. Environmental Impacts of 

Logging.

http://www.forestsmonitor.org/en/reports/550066/5500

83

C-06, Opposing Views 

Attachment #1, page 51

Not 

applicable

This is a news article/opinion piece discussing the 

impacts of logging operations in a number of 

countries (Papua New Guinea, Solomon Islands, 

Cameroon, etc.). It contains no sources, 

references, or literature cited and is not scientific, 

peer-reviewed literature. The logging practices 

reflected in this article do not reflect modern 

forestry practices on National Forest System lands.

Forests.org. 2002. Commercial logging causes forest 

fires. Forest Conservation News Today.

http://forests.org/archived_site/today/recent/2002/grgr

urge.htm

C-06, page 20 Not used Link provided is broken.

Franklin, J.F. and J.K. Agee. 2007. Forging a sciencebased national forest fire policy. Issues in Science 

and Technology 20: 59-66.

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

C-06, Opposing Views 

Attachment #1, page 8

Provides 

background 

info 

applicable to 

this project

This paper is applicable and consistent with other 

literature used in the analysis.
FEIS Appendix D – Public Comment Report Magone Project

89

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Franklin, J., D. Perry, R. Noss, D. Montgomery, and 

C. Frissell. 2000. Simplified forest management to 

achieve watershed and forest health: a critique.

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

C-06, Opposing Views 

Attachment #1, page 7; C-06, 

Opposing Views Attachment 

#4, page 9

Relevant to 

the project

This is a report by a non-government organization 

and is not peer-reviewed literature. It presents an 

approach to forest management to achieve 

watershed and forest health. Many of the concepts 

proposed are already in use within the Forest 

Service. This document offers a perspective on 

whether cutting trees can help protect forest 

values. It is part of an ongoing debate about the 

role of silviculture in management and restoration.

Frey, D. 2010. Logging won’t halt beetles, fire, report 

says. NewWest.net. March 3.

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

t_beetles_fire_report_says/C41/L41/

C-06, Opposing Views 

Attachment #3, page 5; C-06, 

Opposing Views Attachment 

#4, page 9

Not relevant 

to the project

The excerpt is from an article reporting on a report 

by an Oregon-based conservation group, National 

Center for Conservation Science and Policy, which 

states efforts to log beetle-killed trees will not 

reduce fire risk or beetle outbreaks. The report 

authors encourage fuels projects that are focused 

around the edges of communities. The Magone 

Project purpose and need does not include an 

objective to reduce fire risk or to reduce beetle 

outbreaks.

Gable, E. 2010. Battling beetles may not reduce fire 

risks – report. Land Letter. March 4.

http://www.xerces.org/2010/03/04/battling-beetlesmay-not-reduce-fire-risks-report/

C-06, Opposing Views 

Attachment #3, page 5; C-06, 

Opposing Views Attachment 

#4, page 10

Not 

applicable

This article discusses the mountain pine beetle 

epidemic in Colorado. The Magone Project 

purpose and need does not include an objective to 

reduce beetle outbreaks; however, the proposed 

action would make the forest more resilient to 

beetle attack.

Giuliano, J.A. 2008. Fire suppression Bush style: cut 

down the trees! Environmental News Service.

http://www.ens-newswire.com/ens/aug2002/2002-08-

23g.asp

C-06, Opposing Views 

Attachment #1, page 8

Not 

applicable

This is a news article/opinion piece discussing 

opposition to forest and wildfire risk reduction 

policies under the President Bush administration. It 

contains no sources, references, or literature cited 

and is not scientific, peer-reviewed literature.

Gorte, R.W. 1995. Forest Service timber sale 

practices and procedures: analysis of alternative 

systems. Congressional Research Service Report. 

October 30.

http://www.ncseonline.org/NLE/CRS/abstract.cfm?NL

Eid=215

C-06, Opposing Views 

Attachment #1, page 10

Not 

applicable

This report describes the Forest Service timber 

sale system circa 1995 and the major concerns 

over the consequences of the sale system. It then 

reviews the option of a complete overhaul of the 

current approach that would separate the timber 

cutting and removal from the sale of the wood, and 

analyzes the consequences of this approach. This 

is not applicable to analysis of the environmental 

effects of the proposed actions.
FEIS Appendix D – Public Comment Report Magone Project

90

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Changes to the practices and procedures of the 

Forest Service timber sale system cannot be made 

or analyzed at the project level.

Gorte, R.W. 2005. Forest fire/wildfire protection. 

Congressional Research Service Report.

http://www.coloradofirecamp.com/congressional_rese

arch/forest-fire-wildfire-effects.htm

C-06, page 31 Consistent 

with analysis

The overall purpose of this project is to restore 

forest resiliency by reestablishing and restoring 

forest structure and pattern, vegetation 

composition and diversity, and riparian 

communities to conditions that are more resilient to 

natural disturbance processes, including wildfire.

Gorte, R.W. 2008. Wildfire damages to homes and 

resources: understanding causes and reducing 

losses. Congressional Research Service Report. June 

8.

http://nationalaglawcenter.org/wpcontent/uploads/assets/crs/RL34517.pdf

C-06, Opposing Views 

Attachment #3, page 5

Not 

applicable

This is a report prepared by the Congressional 

Research Service for members and committees of 

Congress. The purpose of the Magone Project is 

not to eliminate wildfires.

Government Accounting Office.1999. Western 

national forests: a cohesive strategy is needed to 

address catastrophic wildfire threats. GAO/RCED-99-

65.

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

C-06, pages 22, 36, and 37; 

C-06, Opposing Views 

Attachment #1, page 9; C-06, 

Opposing Views Attachment 

#3, page 6

Not relevant 

to this project

The citation references the effects of thinning 

treatments to reduce wildfire risk. While the 

Magone Project does propose thinning, the 

project’s purpose and need does not include a 

reduction in risk of wildfire.

Hansen, C. 1999. Ending timber sales on national 

forests: THE FACTS (FY ’97). Published in the Earth 

Island Journal.

http://www.johnmuirproject.org/pdf/Fy-1997-

Economic-Report-Ending-Timber-Sales.pdf

C-06, Opposing Views 

Attachment #1, page 51

Not 

applicable

This is an opinion piece discussing the author’s 

opposition to timber sales on National Forests.

Hanson, C. National Forest protection. Environment 

Now.

http://www.environmentnow.org/forest.html

C-06, Opposing Views 

Attachment #1, page 11

Not 

applicable

This is a website article, it is not peer-reviewed 

literature.

Hanson, C. 2000. Commercial logging doesn’t 

prevent catastrophic fires, it causes them. New York 

Times. May 19.

http://www.commondreams.org/views/051900-

101.htm

C-06, Opposing Views 

Attachment #1, page 10; C06, Opposing Views 

Attachment #3, page 6

Not 

applicable

This is a news article/opinion piece discussing the 

author’s opposition to using vegetation 

management practices to reduce fuels and wildfire 

risk. It contains no sources, references, or literature 

cited and is not scientific, peer-reviewed literature.

Hanson, C. 2000. The big lie: logging and forest fires. 

Earth Island Journal. Spring.

http://yeoldeconsciousnessshoppe.com/art6.html

C-06, Opposing Views 

Attachment #1, page 60; C06, Opposing Views 

Attachment #3, page 28

Not 

applicable

This is not scientific peer reviewed literature. This 

writing is opinion from a private citizen advocacy 

organization doing their specific outreach and 

education.
FEIS Appendix D – Public Comment Report Magone Project

91

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Hanson, C. 2002. A burning issue: helping loggers, 

hurting forests. Los Angeles Times.

http://www.commondreams.org/views02/0715-04.htm

C-06, page 21 Not used Link provided is broken.

Hanson, C. 2008. Logging industry misleads on 

climate and forest fires. New West. July 11.

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

misleads_on_climate_and_forest_fires/C41/L41/

C-06, Opposing Views 

Attachment #1, page 11

Not 

applicable

This is a non-scientific guest commentary in which 

the author discusses his contention that forest 

management should not be used as a tool to 

reduce wildland fires and mitigate climate change. 

It contains no sources, references, or literature 

cited and is not scientific, peer-reviewed literature.

Hanson, C. 2010. New report debunks myth of 

“catastrophic wildfire.”

http://johnmuirproject.org/documents/myth%20of%20

catastrophic%20wildfire%20media%20release.pdf

C-06, page 31 Not used Unable to locate reference.

Hanson, C. and D. DellaSala. 2015. More logging 

won’t stop wildfires. New York, NY: New York Times.

http://www.nytimes.com/2015/07/23/opinion/morelogging-wont-stop-wildfires.html?_r=1

C-06, page 24; C-06, 

Opposing Views Attachment 

#3, page 30

Not 

applicable

This article describes a situation where only 

mature, large diameter trees will be removed 

during treatments and that slash created from the 

treatments will remain on the ground as surface 

fuels.

All fuels in treatment units both existing and 

created would be treated as stated in the analysis

(i.e. pile and burn or underburn).

Harvey, A.E., M.J. Larsen, and M.F. Jurgensen. 1976. 

Distribution of ectomycorrhizae in a mature Douglasfir/larch forest soil in western Montana. Forest 

Science. 22(4): 393-398.

http://www.ingentaconnect.com/content/saf/fs/1976/0

0000022/00000004/art00007;jsessionid=l2sdf2hphia2

.alexandra

C-06, Opposing Views 

Attachment #1, page 12

Limited 

applicability to 

this project

The authors conclude that soil organic matter is 

important in the formation and activity of 

mycorrhizae. This paper is of limited applicability to 

the Magone Project because 1) proposed activities 

would move soil organic matter back toward levels 

found before fire suppression (see Magone FEIS 

chapter 3, Soil section); 2) there is no evidence 

that somewhat decreased levels of organic matter 

or mycorrhizae would degrade productivity or other 

ecosystem function outside the prehistoric range of 

variability; and 3) soil parent material in the study 

area is limestone, which may affect mycorrhizae 

radically differently from parent material in Magone 

project planning area.

Hermach, T. 2007. The skinny on thinning: Should we 

save the forest from itself? Eugene Weekly Viewpoint. 

November 1.

C-06, Opposing Views 

Attachment #3, page 7

Not 

applicable

This is an opinion piece discussing the author’s 

opposition to vegetation management practices to 

reduce wildland fire risks. It contains no sources, 

references, or literature cited and is not scientific, 

peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

92

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.eugeneweekly.com/2007/11/08/views1.ht

ml

Higgins, M. 2000. National forest logging is bad 

business, study says. CNN.com-Nature. March 16.

http://edition.cnn.com/2000/NATURE/03/16/forest.log

ging.enn/index.html

C-06, Opposing Views 

Attachment #1, page 5

Not 

applicable

This is a news article/opinion piece reviewing a 

study by the National Forest Protection Alliance 

and the Forest Conservation Council. It contains no 

sources, references, or literature cited and is not 

scientific, peer-reviewed literature.

Houston, A. 1997. Why forestry is in trouble with the 

public. Evergreen Magazine. October.

http://evergreenmagazine.com/web/Why_forestry_is_i

n_trouble_with_the_public-v2.html

C-06, Opposing Views 

Attachment #1, page 12

Not relevant Magazine is not peer-reviewed, scientific literature. 

It contains no sources, references, or literature 

cited. The author suggests that the public does not 

trust those who manage forests or understand 

forest management practices. This project has 

followed NEPA procedures for public comment and 

review (see the Public Involvement section in the 

Magone FEIS chapter 1).

H.R. 1494 text. April 4, 2001.

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

m

C-06, Opposing Views 

Attachment #1, pages 12-13

Not relevant This was a bill introduced in 2001 to the House of 

Representatives and is not peer-reviewed, 

scientific literature. It contains no sources, 

references, or literature cited. The Magone Project 

was planned using current law, policy, and 

regulation as its foundation for devising the 

proposed project.

Hudak, M. 1999. From prairie dogs to oysters: how 

biodiversity sustains us. EarthTimes [Newsletter of 

Earth Day Southern Tier] February/March.

Book review of “The work of nature: how the diversity 

of life sustains us,” by Yvonne Baskin, 1997.

http://www.mikehudak.com/Articles/FromPrairieDogs9

902.html

C-06, Opposing Views 

Attachment #1, page 13

Not relevant 

to this project

The article is a book review, not a scientific study 

with peer review. Hudak states the book is written 

for the general audience and that it clearly explains 

environmental concepts and components, such as 

biodiversity, ecosystem services, and keystone 

species. He concludes that the reader can use the 

facts in the book to protect endangered species 

and other environmental components.

Huff, M.H., R.D. Ottmar, E. Alvarado, R.E. Vihnanek, 

J.F. Lehmkuhl, P.F. Hessburg, and R.L. Everett. 

1995. Historical and current forest landscapes in 

eastern Oregon and Washington. Part II: Linking 

vegetation characteristics to potential fire behavior 

and related smoke production. Gen. Tech. Rep. 

PNW-GTR-355. Portland, OR: USDA Forest Service,

Pacific Northwest Research Station.

C-06, page 24; C-06, 

Opposing Views Attachment 

#1, pages 13-14; C-06, 

Opposing Views Attachment 

#3, pages 7-8

Consistent 

with project

This study examined changes in vegetation 

structure and composition in 6 river basins in 

eastern Oregon and Washington from 1940 to 

1990, and projects the effects of vegetation 

changes on potential fire behavior and smoke 

production. The report states that prescribed fire 

along with mechanical measures can be used for 

restoration purposes to regulate stand composition, 

reduce plant competition, and modify fuels to 

achieve a desired structure. This is consistent with 
FEIS Appendix D – Public Comment Report Magone Project

93

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

the management activities proposed with the 

Magone Project.

Ingalsbee, T. 1997. Logging for firefighting: a critical 

analysis of the Quincy Library Group Fire Protection 

Plan. Unpublished research paper.

http://www.fire-ecology.org/research/logging-forfirefighting_2.htm

C-06, Opposing Views 

Attachment #1, page 15

Not 

applicable

This paper is specific to the Quincy Library Group

Fire Protection Plan. The Magone Project is not 

subject to this plan.

Ingalsbee, T. 2000. Commercial logging for wildfire 

prevention: facts vs fantasies.

http://www.fireecology.org/citizen/logging_and_wildfires.htm

C-06, page 23; C-06, 

Opposing Views Attachment 

#1, page 15; C-06, Opposing 

Views Attachment #3, page 8

Not relevant 

to this project

Opinion piece in which the author describes why 

he believes commercial logging does not prevent 

wildfires. It contains no sources, references, or 

literature cited and is not scientific, peer-reviewed 

literature.

This project does not propose commercial logging 

to prevent wildfires as part of the purpose and 

need or included in the proposed action.

Ingalsbee, T. 2000. Money to burn: the economics of 

fire and fuels management, part one: fire suppression. 

An American Lands Alliance publication.

www.fire-ecology.org/research/money_to_burn.html

C-06, Opposing Views 

Attachment #3, page 8

Not 

applicable

The paper addresses the national fuels program 

policies and suggested reform.

Ingalsbee, T. 2002. Logging without limits isn’t a 

solution to wildfires. Published in the Portland 

Oregonian, August 6.

http://www.klamathforestalliance.org/Documents/loggi

ngwithoutlimits.html

C-06, Opposing Views 

Attachment #1, page 16

Not 

applicable

Article contains no sources, references, or 

literature cited and is not scientific, peer-reviewed 

literature. The author describes those activities he 

does and does not view as appropriate to fuels 

reduction. The Magone Project does not propose 

commercial logging to prevent wildfires.

Ingalsbee, T. 2002. National fire plan implementation: 

Forest Service failing to protect forests and 

communities. American Lands Alliance, March.

http://www.fireecology.org/policy/ALA_fire_policy_2002.html

C-06, Opposing Views 

Attachment #3, page 9

Not 

applicable

This paper discusses national policies that cannot 

be changed by the Magone Project.

Ingalsbee, T. 2002. The wildland fires of 2002 

illuminate fundamental questions about our 

relationship to fire. The Oregon Quarterly, Winter.

http://www.fireecology.org/research/wildfire_paradox.pdf

C-06, page 22; C-06, 

Opposing Views Attachment 

#1, page 16; C-06, Opposing 

Views Attachment #3, page 9

Not used The link provided is broken.

Ingalsbee, T. 2003. Fanning the flames! The U.S. 

Forest Service: a fire-dependent bureaucracy. 

Missoula Independent. 14(24).

C-06, Opposing Views 

Attachment #1, page 17; CNot 

applicable

Opinion article in a newspaper in which the author 

discusses his disagreement with Forest Service 

policies related to fire and forest management. It 
FEIS Appendix D – Public Comment Report Magone Project

94

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.fireecology.org/research/USFS_fire_dependent.html06, Opposing Views 

Attachment #3, page 10

contains no sources, references, or literature cited 

and is not scientific, peer-reviewed literature. Postfire salvage logging is not part of the purpose and 

need or included in the proposed action for this 

project.

Ingalsbee, T. 2005. A reporter’s guide to wildland fire. 

Firefighters United for Safety, Ethics, and Ecology. 

January.

http://www.commondreams.org/news2005/0111-

14.htm

C-06, Opposing Views 

Attachment #1, page 17; C06, Opposing Views 

Attachment #3, page 10

Not 

applicable

Not a peer reviewed research paper. This project 

does not propose commercial logging to prevent 

wildfires. Slash created through harvest activities 

would be treated.

Ingalsbee, T. and J. Fox. 2006. Torchbearers for a 

new fire management paradigm. Firefighters United 

for Safety, Ethics, and Ecology (FUSEE). Poster 

presentation at Third International Fire Ecology and 

Management Congress, Association for Fire Ecology.

http://fusee.org/docs/AFE_FUSEE_display_abstract.p

df

C-06, Opposing Views 

Attachment #3, page 11

Not 

applicable

An article that describes an organization and its’ 

charter.

Karr, J.R., C.A. Frissell, J.J. Rhodes, D.L. Perry, and 

G.W. Minshall. 2002. Excerpt from a letter to the 

Subcommittee on Forests & Forest Health U.S. 

House of Representatives. July 3.

http://www.nativeforest.org/campaigns/wildfire_info_c

enter/letter_from_beschta.htm

C-06, Opposing Views 

Attachment #4, page 15

Not 

applicable

The excerpt is from a letter to congress, which 

states the allegations that the Forest Service may 

have adopted a policy that does not reverse the 

ecological effects of roads. This article is not peerreviewed and is a summary of the Beschta Report 

presented to Congress. Further, it states 

generalizations regarding roads and road 

management by the Forest Service that may or 

may not be applicable to this project. It does not 

contain data or analysis however, so observations 

made in this report may more broadly apply to 

roads management and other ecological effects.

Kaufmann, Merrill R. 2005 “Good Fire, Bad Fire” Mr. 

Kaufmann is the Rocky Mountain Research Station's 

team leader for ecosystem management Fort Collins, 

CO, USDA Forest Service.

http://csfs.colostate.edu/pdfs/Good_Fire_Bad_Fire.pdf

C-06, Opposing Views 

Attachment #15, page 7

Not used The website link provided does not work. Unable to 

locate reference.

Keene, R. 2011. Restorative logging? More rarity than 

reality. Guest Viewpoint, the Eugene Register Guard. 

March 10.

http://eugeneweekly.com/2011/03/03/views3.html

C-06, Opposing Views 

Attachment #1, page 19; C06, Opposing Views 

Attachment #3, page 12

Not 

applicable

This is an opinion piece not a peer reviewed 

research paper.
FEIS Appendix D – Public Comment Report Magone Project

95

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Keene, R. 2009. Logging does not prevent wildfires. 

Guest Viewpoint, the Eugene Register Guard. 

January 11.

http://www.highbeam.com/doc/1G1-192070397.html

C-06, Opposing Views 

Attachment #1, page 18; C06, Opposing Views 

Attachment #3, pages 11-12

Not 

applicable

This is an opinion piece not a peer reviewed 

research paper.

Kelly, S. 2007. Cheap chips, counterfeit wilderness: 

greenwashing logging on Montana's biggest national 

forest. World Prout Assembly.

http://www.worldproutassembly.org/archives/2007/12/

cheap_chips_cou.html

C-06, Opposing Views 

Attachment #3, page 12

Not 

applicable

This is an opinion piece not a peer reviewed 

research paper, and pertains to the Bitterroot 

National Forest Plan draft.

Kuglin, T. 2015. Researcher finds need for more 

prescribed burning. Helena, MT: Helena Independent 

Record.

http://helenair.com/news/local/researcher-finds-needfor-more-prescribed-burning/article_4a58c3c3-a7bb5905-a505-4567e8107600.html

C-06, page 26 Consistent Cram et al. (2006) observed that mechanical 

treatment followed by prescribed fire (including pile 

burning) had the greatest influence toward 

mitigating fire severity.

Laverty, L. and T. Hartzell. 2000. A report to the 

President in response to the wildfires of 2000.

http://frames.nacse.org/6000/6269.html

C-06, page 22; C-06, 

Opposing Views Attachment 

#1, page 20; C-06, Opposing 

Views Attachment #3, page 

13

Not 

applicable

This report recommends how best to respond to 

the year 2000 wildfires, reduce the impacts of 

these wildland fires on rural communities, and

ensure sufficient firefighting resources in the future. 

It contains no sources, references, or literature 

cited and is not scientific, peer-reviewed literature. 

The report goes on to clarify further that without 

adequate treatment of small woody material,

logging may exacerbate fire risk rather than 

lowering it. Slash created through harvest activities 

would be treated.

Lawrence, N. 2001. Gridlock on the National Forests. 

Testimony before the U.S. House of Representatives 

Subcommittee on Forests and Forest Health 

(Committee on Resources) December 4.

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

C-06, Opposing Views 

Attachment #1, page 21; C06, Opposing Views 

Attachment #3, pages 13-14

Not 

applicable

This non-scientific paper discusses thinning for fire 

risk reduction and post-fire salvage logging. The 

Magone Project does not propose post-fire 

salvage. The project proposes silviculture 

treatments to restore forest structure, composition, 

and density.

Leitner, B. 2003. Logging companies are responsible 

for the California wildfires. The Democratic 

Underground. October 30.

http://www.democraticunderground.com/articles/03/10

/30_logging.html

C-06, Opposing Views 

Attachment #1, page 21; C06, Opposing Views 

Attachment #3, page 14

Not 

applicable

The article contains no sources, references, or 

literature cited and is not scientific, peer-reviewed 

literature.
FEIS Appendix D – Public Comment Report Magone Project

96

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Long, R.D. 2001. U.S. Department of Agriculture 

Office of Inspector General. Western Region Audit 

Report: Forest Service National Fire Plan 

Implementation. Report No. 08601-26-SF. November.

http://www.usda.gov/oig/webdocs/08601-26-SF.pdf

C-06, Opposing Views 

Attachment #1, page 22

Not 

applicable

This report presents the results of the Inspector 

General’s 2001 review of the Forest Service’s 

implementation of the National Fire Plan.

Mann, C.C. and M.L. Plummer. 1999. Call for 

“sustainability” in forests sparks a fire. Science. 

283(5410): 1996-1998.

http://www.sciencemag.org/content/283/5410/1996.su

mmary

C-06, Opposing Views 

Attachment #1, page 22

Not 

applicable

This article summarized the process (as of 1999) 

that a committee of scientists went through to 

prepare a report with recommendations to the 

Forest Service for updating the National Forest 

Management Act by incorporating them into 

upcoming draft regulations not specific to the 

Magone Project. The Forest Service will continue 

to follow all laws as mandated, including the 

Multiple-Use Sustained-Yield Act and the National 

Forest Management Act.

McDaniel, Josh 2007 “The Zaca Fire: Bridging Fire 

Science and Management” Wildland Fire Lessons 

Learned.

http://www.wildfirelessons.net/Additional.aspx

C-06, Opposing Views 

Attachment #15, page 8

Not used The website link provided does not work. Unable to 

locate reference.

Morgan, P., E.K. Heyerdahl, and C.E. Gibson. 2008. 

Multi-season climate synchronized forest fires 

throughout the 20th century, Northern Rockies. 

Ecology 89(3): 717-728.

http://www.firelab.org/index.php?option=com_jombib&

task=showbib&id=343

C-06, Opposing Views 

Attachment #3, page 15

Not 

applicable

Paper discusses climatic effects as related to large, 

severe wildfires in the Northern Rockies.

Moyer, E. 2014. Trees are our climate saviors – so 

stop logging on public land. The Huffington Post.

http://www.huffingtonpost.com/ellen-moyer-phd/treesare-our-climate-logging_b_4775894.html

C-06, Opposing Views 

Attachment #1, page 54

Not 

applicable

This is a blog article written by Ellen Moyer, an 

independent environmental consultant. This is an 

opinion piece that discusses reducing carbon 

dioxide emissions and mitigating greenhouse 

gases by removing them from the air through 

photosynthesis of forests. This author believes that 

President Obama should stop commercial logging 

on public land. This is not scientific, peer-reviewed 

literature and only contains references from other 

news articles.
FEIS Appendix D – Public Comment Report Magone Project

97

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Naeem, S. F.S. Chapin III, R. Costanza, P.R. Ehrlich, 

F.B. Golley, D.U. Hooper, J.H. Lawton, R.V. O’Neill, 

H.A. Mooney, O.E. Sala, A.J. Symstad, and D. 

Tilman. 1999. Biodiversity and ecosystem functioning: 

maintaining natural life support processes. Issues in 

Ecology 4.

http://www.esa.org/science_resources/issues/TextIss

ues/issue4.php

C-06, Opposing Views 

Attachment #1, page 24

General 

information; 

not used

This report provides an overview of ecosystem 

functioning, reviews the distinction between 

taxonomic biodiversity and functional diversity, and 

evaluates the current status of research concerning 

ecosystem responses to changes in diversity.

The Magone FEIS analyzes potential direct, 

indirect, and cumulative effects on multiple 

resources, including wildlife species, fish species, 

and forest vegetation species. The project does not 

propose to extirpate any native species from the 

planning area.

Nappi, A., P. Drapeau, and J.F. Giroux. 2003. Snag 

use by foraging black-backed woodpeckers (Picoides 

articus) in a recently burned eastern boreal forest. 

The Auk 120(2): 505-511.

http://www.borealcanada.ca/research_arc_hot_e.cfm

C-06, page 32 Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.

Oko, D. and I. Kayatsky, D. 2002. Fight fire with 

logging? Mother Jones. Available online: 

http://www.motherjones.com/politics/2002/08/fightfire-logging.

http://motherjones.com/politics/2002/08/fight-firelogging

C-06, page 21; C-06, 

Opposing Views Attachment 

#1, page 27; C-06, Opposing 

Views Attachment #3, page 

16

Not 

applicable

This is a news article/opinion piece critical of the 

National Fire Plan of 2002. It contains no sources, 

references, or literature cited and is not scientific, 

peer-reviewed literature.

Ontario aviation and forest fire management. Fact 

sheet: understanding fire and fire behavior.

http://www.emifpa.org/pdf/factsheetunderstandingfire.

pdf

C-06, Opposing Views 

Attachment #11, page 2

Not 

applicable

This is not scientific peer reviewed literature. The 

quote the commenter uses does not appear on this 

page. This is an outreach site offering homeowners 

services regarding wildfire.
FEIS Appendix D – Public Comment Report Magone Project

98

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Oregon State University Research. 2009. Science 

Centric. July 9.

http://www.sciencecentric.com/news/article.php?q=09

070918-forest-fire-prevention-efforts-will-lessencarbon-sequestration-add-greenhouse-warming

C-06, Opposing Views 

Attachment #3, page 16

Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.

O’Toole, R. Incentives, not fuels, are the problem. 

Published by the Thoreau Institute.

http://www.ti.org/fireshort.html

C-06, Opposing Views 

Attachment #3, page 16

Not 

applicable

This is an opinion piece discussing fire 

suppression.

O’Toole, R. 2002. Reforming the fire service: an 

analysis of federal fire budgets and incentives. The 

Thoreau Institute.

www.ti.org/firesvc.pdf

C-06, Opposing Views 

Attachment #3, page 17.

Not 

applicable

This is an opinion piece discussing the National 

Fire Plan.

O’Toole, R. Money to Burn? Regulation. Winter 2002–

2003.

http://object.cato.org/sites/cato.org/files/serials/files/re

gulation/2002/12/v25n4-6.pdf

C-06, Opposing Views 

Attachment #3, page 17

Not 

applicable

This opinion piece discusses the history of the 

Forest Service spending on fuels treatments. The 

author proposes systematic reform of the Forest 

Service that would fund each national forest out of 

its own receipts; land managers would decide 

which combination of thinning, prescribed burnings, 

and fire suppression is most appropriate to local 

needs and resource values.

Partridge, A. 1998. Statement at a press conference 

with Senator Robert Torricelli about S. 977 and HR 

1376: the Act to Save America’s Forests, U.S. 

Capitol. April 28.

http://www.saveamericasforests.org/news/ScientistsSt

atement.htm

C-06, Opposing Views 

Attachment #1, page 49

Not

applicable

This document includes statements from scientists 

supporting the Act to Save America’s Forest (S. 

977, HR 1376). It contains no sources, references, 

or literature cited and is not scientific, peerreviewed literature.

Partridge, A. 2003. Testimony to the Agriculture, 

Nutrition and Forestry Committee, United State 

Senate. Hearing to Review Healthy Forests 

Restoration Act, HR 1904. June 26.

http://www.univision.co.za/offer-dayoA2A392Cr1N3B2x_2F2du3g3-music.shtml

C-06, page 25; C-06, 

Opposing Views Attachment 

#3, pages 17-18

Not 

applicable

This is a transcript from a committee hearing on 

the Healthy Forest Restoration Act (HFRA) in 

2003. It contains no sources, references, or 

literature cited and is not scientific, peer-reviewed 

literature. The Magone Project is not a HFRA 

project.

Peters, R.L., E. Frost, and F. Pace. 1996. Managing 

for forest ecosystem health: a reassessment of the 

forest health crisis. Defenders of Wildlife. April.

C-06, Opposing Views 

Attachment #3, page 18

Provides 

general 

background 

information

This publication notes that fire, insects, and 

disease are the drivers of forest diversity, structure 

and function. This project proposes activities to 

restore forest structure, composition, and density 

toward more resistant and resilient vegetative 

conditions given the historic fire regime.
FEIS Appendix D – Public Comment Report Magone Project

99

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Peterson, M. 2003. Testimony to the Senate 

Agriculture, Nutrition, and Forestry Committee 

concerning the Healthy Forests Restoration Act, HR 

1904. June 26.

C-06, Opposing Views 

Attachment #3, pages 18-19

Not 

applicable

This is a transcript from a committee hearing on 

the Healthy Forest Restoration Act (HFRA) in 

2003. It is not scientific, peer-reviewed literature. 

The Magone Project is not a HFRA project.

Platt, R.V., T.T. Veblen, R.L. Sherriff. 2006. Are 

wildfire mitigation and restoration of historic forest 

structure compatible? A spatial modeling assessment. 

Annals of the Association of American Geographers 

96(3): 455-470.

http://www.ingentaconnect.com/content/routledg/anna

/2006/00000096/00000003/art00001

C-06, Opposing Views 

Attachment #1, pages 27-28; 

C-06, Opposing Views 

Attachment #3, page 19

Consistent 

with literature 

used in this 

analysis

This study evaluates where both wildfire mitigation 

and restoration of historic forest structure are 

potentially needed in the ponderosa pinedominated montane forest zone of Boulder County, 

Colorado. This study questions the validity of 

thinning as a means both to reduce the threat of 

wildfire and to restore historic forest structure.

This paper found that in the lower elevations of this 

study, below approximately 6,900 feet where a 

frequent fire regime historically existed, thinning is 

needed to both mitigate wildfire risk and restore 

historical forest structure. This finding is consistent 

with literature used to develop the proposed action.

Pojar, J., C. Rowan, A. MacKinnon, D. Coates, and P. 

LePage. 1999. Silvicultural options in the Central 

Coast: a Report Prepared for the Central Coast Land 

and Coastal Resource Management Plan.

http://www.for.gov.bc.ca/tasb/slrp/lrmp/nanaimo/cenc

oast/docs/PojarMar.pdf

C-06, page 63 Not 

applicable

This report assesses the ecological suitability, 

sustainability, practicality, utility, and applicability of 

various silvicultural systems to the Central Coast 

forests of British Columbia. Commenter focused on 

the reports assertion that sustained yield is not the 

same thing as sustainability; nor is the concept of 

sustained yield particularly appropriate for forests 

as ecosystems.

The conditions on the Central Coast forest of 

British Columbia are very different from those of 

the Malheur National Forest in eastern Oregon. 

The Magone Project cites literature relevant to 

silvicultural systems used in the Blue Mountains of 

eastern Oregon.

Powell, D.S., J.L. Faulkner, D.R. Darr, Z. Zhu, and 

D.W. MacCleery. 1992. Forest resources of the 

United States. Gen. Tech. Rep. GTR-RM-234. Fort 

Collins, CO: USDA Forest Service, Rocky Mountain 

Forest and Range Experiment Station.

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

C-06, Opposing Views 

Attachment #1, page 28

Relevant to 

this project

This General Technical Report summarizes the 

forest resources in the United States in 1992. From 

the Introduction: “As required by the Forest and 

Rangeland Renewable Resources Planning Act of 

1974 (RPA), this report updates information on the 

Nation’s forest resource, particularly the timber 

resource.” This report is a data compilation and 

summary, and does not provide opinions or options 

for forest management.
FEIS Appendix D – Public Comment Report Magone Project

100

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Proposed units are located on lands suitable for 

timber production.

Power, T. 2000. The politics of forest fires—the abuse 

of other people’s hard times. August 15.

http://www.forwolves.org/ralph/tompower.htm

C-06, Opposing Views 

Attachment #3, page 20

Not 

applicable

This is an opinion piece discussing commercial 

logging.

Power, T. 2006. So-called healthy forests and wildfire 

control, “healthy forests” and wildfire control: 

accumulating scientific evidence. Native Forest 

Council.

http://forestcouncil.org/so-called-healthy-forests-andwildfire-control/

C-06, page 26 Consistent Cram et al. (2006) observed that mechanical 

treatment followed by prescribed fire (including pile 

burning) had the greatest influence toward 

mitigating fire severity.

Raven, P. 2001. February 9 letter to Senator Jean 

Carnahan.

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

C-06, Opposing Views 

Attachment #1, page 29

Not 

applicable

This citation is from a letter that supported the 

2001 proposed Act to Save America's Forests 

Legislation. According to the letter, the Act would 

have ended logging in all the remaining Northwest 

Ancient Forests, ended logging in all remaining 

roadless forests, and ended logging in “special” 

forest areas throughout the federal forest system, 

such as the giant Sequoia forests in California. In 

addition, the Act would have banned clearcutting in 

the national forests. The proposed legislation did 

not become law. Thus, this article is not relevant to 

the site-specific Magone Project analysis.

Raven, P., J. Goodall, E.O. Wilson, and over 600 

leading biologists, ecologists, foresters, and scientists 

from other forest specialties. From a 1998 letter to 

congress.

http://www.saveamericasforests.org/resources/Scienti

sts.htm

C-06, Opposing Views 

Attachment #1, page 29

Not 

applicable

This was from a letter to Congress signed by over 

600 scientists urging passage of the Act to Save 

America's Forests, not directly referencing the 

Magone Project. They state that clearcutting and 

other even-aged silvicultural practices and timber 

road construction have caused widespread forest 

ecosystem fragmentation and degradation. This 

proposed legislation did not become law. Thus, this 

article is not relevant to the site-specific Magone 

Project analysis.

Reice, S. 1998. Press conference with Senator 

Robert Torricelli. April 28.

http://www.saveamericasforests.org/news/ScientistsSt

atement.htm

C-06, Opposing Views 

Attachment #4, page 4

Not 

applicable

This is not scientific peer reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

101

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Reinhardt, E.D., R.E. Keane, D.E. Calkin, and J.D. 

Cohen. 2008. Objectives and considerations for 

wildland fuel treatment in forested ecosystems of the 

interior western United States. Forest Ecology and

Management 256(12): 1997-2006.

http://www.firewise.org/infomration/research-andguidance/WUI-HOME-IgnitionResearch/~/media/firewise/files/pdfs/research/cohenf

ueltreatment.pdf

C-06, pages 25-26 and 35; C06, Opposing Views 

Attachment #11, pages 10-13

Consistent 

with analysis

The overall purpose of this project is to restore 

forest resiliency by reestablishing and restoring 

forest structure and pattern, vegetation 

composition and diversity, and riparian 

communities to conditions that are more resilient to 

natural disturbance processes, including wildfire. 

Some of the opposing views focus on home 

ignitability, which is outside the scope of this 

project.

Rey, M. and R. Watson. 2003. Statement of Mark 

Rey, Under Secretary, Natural Resources and the 

Environment, United States Department of Agriculture 

and Rebecca Watson, Assistant Secretary, Land and 

Minerals Management, Department of the Interior 

before the United States House of Representatives, 

Committee on resources concerning containing the 

threat of wildland fire to the environment and 

communities, Flagstaff, Arizona.

http://www.wildlandfire.com/docs/2003_n_before/rey_

testimony_2003.htm

C-06, page 20 Not 

applicable

This is a transcript of a speech and is not scientific 

peer-reviewed literature.

Roberson, E.B. Excerpt from a letter to Chief Dale 

Bosworth and 5 members of congress.

http://www.plantsocieties.org/PDFs/Fire%20letter%20

CNPS%208.02%20letterhead.pdf

C-06, Opposing Views 

Attachment #1, page 30; C06, Opposing Views 

Attachment #3, page 20

Not 

applicable

Historical logging practices were based on entirely 

different management objectives and are a poor 

indicator of the effects of modern federal forestry 

practices focused on current, science-based 

restoration principles. Magone FEIS chapter 3 

describes impacts to individual resources.

Seymour, R. and M. Hunter. 1999. Principles of 

Ecological Forestry [Chapter 2]. In: Maintaining 

Biodiversity in Forest Ecosystems. Cambridge 

University Press.

http://dx.doi.org/10.1017/CBO9780511613029

C-06, pages 59-60 Consistent 

with the 

project

This book is focused on maintaining biodiversity in 

forested ecosystems, particularly in those forests 

that are subject to timber harvesting. The authors 

claim “Ecological forestry that maintains an 

effective coarse filter differs markedly from the 

‘engineering’ approach common under sustainedyield timber management.” Treatments within the 

Magone Project focus on ecological forestry 

through variable density thinning, wildlife leave 

patches, thinning to mimic historic forest patterns, 

generally thinning the smallest trees, 

predominately removing grand fir, and prescribed 

burning to restore fire back on the landscape. 

Trees thinned will be used for wood products, as 
FEIS Appendix D – Public Comment Report Magone Project

102

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

well as placement into stream channels and 

meadows for riparian restoration purposes. Snags 

and large down logs will be left on site. Units were 

designated for treatment based on the need to 

meet the ecological objective of increasing 

resiliency, not to provide for sustained yield timber 

management.

Short, B. and D.C. Hardy-Short. 2003. Physicians of 

the forest: a rhetorical critique of the Bush Healthy 

Forest Initiative. Electronic Green Journal. Issue 19.

http://escholarship.org/uc/item/4288f8j5

C-06, Opposing Views 

Attachment #1, page 32

Not 

applicable

This opinion piece discusses the federal fire policy 

known as the Healthy Forest Initiative that 

emerged out of the 2002 fire season. The Magone 

Project is not a part of the Healthy Forest Initiative.

Sierra Club. 2005. Ending commercial logging on 

public lands.

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

/ecl.html

C-06, Opposing Views 

Attachment #1, page 33

Not 

applicable

This is a statement from a non-profit advocacy 

website. It is not scientific, peer-reviewed literature 

and contains no sources, references, or literature 

cited. The Magone Project implements Malheur 

Forest Plan direction.

Sonner, S. 2012. Study challenges views about 

western forest fires. The Daily World.

http://thedailyworld.com/sections/newswire/northwest/

study-challenges-views-about-western-forestfires.html

C-06, pages 25 and 27; C-06, 

Opposing Views Attachment 

#3, page 30

Science is in 

dispute / out 

of scope

A great deal of science has stated that dry forest 

burned frequently at lower intensities. The article 

referenced here depicts that dry forest may have 

burned less frequently and at higher levels of 

severity. Additionally, the article suggest we should 

not be managing just for low-density stands. The 

Magone FEIS allows for a variety of stand densities 

to be maintained, including high-density stands.

Stahl, A. 2003. Reducing the threat of catastrophic 

wildfire to central Oregon communities and the 

surrounding environment. Testimony before the 

House Committee on Resources, August 25.

http://www.propertyrightsresearch.org/2004/articles6/t

estimony_of_andy_stahl.htm

C-06, Opposing Views 

Attachment #1, page 34

Not 

applicable

This is a transcript of testimony provided during a 

hearing before the House Committee on 

Resources in 2003. It contains no sources, 

references, or literature cited and is not scientific, 

peer-reviewed literature.

Stahl, A. 2015. Timber industry fails to convince 

judges that logging levels inked to wildfires. A New 

Century of Forest Planning.

http://forestpolicypub.com/2015/09/29/timber-industryfails-to-convince-judges-that-logging-levels-linked-towildfires/

C-06, page 23 Not 

applicable

This is a post to a blog. It is an opinion piece that is 

reporting the results of a lawsuit filed by AFRC to 

increase logging on Northwest Forest Plan lands in 

western Oregon. This is not scientific, peerreviewed literature and contains no sources, 

references, or literature cited. The Magone project 

is located in the Blue Mountains of eastern Oregon, 

not on Northwest Forest Plan lands in western 

Oregon.
FEIS Appendix D – Public Comment Report Magone Project

103

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Strickler, K. and T.G. Hermach. 2003. Liar, liar, 

forests on fire: why forest management exacerbates 

loss of lives and property. CommonDreams.org. 

October 31.

http://www.commondreams.org/scriptfiles/views03/10

31-10.htm

C-06, Opposing Views 

Attachment #1, page 35; C06, Opposing Views 

Attachment #3, page 21

Not 

applicable

This is from a non-profit advocacy website 

discussing the author’s opposition to the Healthy 

Forest Restoration Act (HFRA). It is not scientific, 

peer-reviewed literature and contains no sources, 

references, or literature cited. The Magone Project 

is not a HFRA project.

Taxpayers for Common Sense. 2000. From the 

ashes: reducing the harmful effects and rising costs of 

western wildfires. Washington DC. December.

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

C-06, Opposing Views 

Attachment #1, page 36; C06, Opposing Views 

Attachment #3, page 22

Not 

applicable

This report discusses Forest Service use of tax 

dollars to fight wildfires and Congressional funding 

of the Forest Service. It contains no sources, 

references, or literature cited and is not scientific, 

peer-reviewed literature.

Thomas, C. 2007. Living with risk: homeowners face 

the responsibility and challenge of developing 

defenses against wildfires. Sacramento Bee. July 1.

http://www.sierraforestlegacy.org/NR_InTheNews/SF

LIP_2007-07-01_SacramentoBee.php

C-06, Opposing Views 

Attachment #1, page 36; C06, Opposing Views 

Attachment #3, page 22

Not 

applicable

This is an opinion piece focusing on protecting 

homes from wildfire near Lake Tahoe and 

encourages residents to implement defensible 

space around their homes. It is not scientific, peerreviewed literature and contains no sources, 

references, or literature cited.

Thompson Memorial Lecture. What is the wildland fire 

threat to homes? April 10. 2000.

http://www.fs.fed.us/rm/pubs_other/rmrs_2000_cohen

_j003.pdf

C-06, Opposing Views 

Attachment #11, page 8

Not 

applicable

This article discusses the ignitability of homes.

Thoughts on the wildland-urban interface fire problem. 

June 2003.

http://firewise.org/~/media/Firewise/Files/Pdfs/Resear

ch/CohenThoughtsOnWUI.pdf

C-06, Opposing Views 

Attachment #11, page 6

Not 

applicable

This letter talks about home ignitability and home 

ignition zones.

University of Arizona. More large forest fires linked to 

climate change. 2006. Adapted from materials 

provided by the University of Arizona. ScienceDaily. 

July 10.

http://www.sciencedaily.com/releases/2006/07/06071

0084004.htm

C-06, Opposing Views 

Attachment #3, page 14

Provides 

background 

information

Article discusses the relationship between climate 

and large, severe wildfires and fire exclusion. The 

Magone Project would reduce fuel loading by 

reducing the density of standing vegetation, 

surface fuels, and ladder fuels. Fuel is the only 

element of fire behavior that is manageable as 

climate and topography are beyond our control.

University of Michigan. 2010. Global deforestation.

http://www.globalchange.umich.edu/globalchange2/cu

rrent/lectures/deforest/deforest.html

C-06, Opposing Views 

Attachment #1, page 56

Supports the 

analysis

This reference includes lecture notes on the topic 

of global deforestation from the University of 

Michigan. It talks about the importance of forests, 

tropical deforestation, Amazon forests, causes of 

deforestation, and forest management and 

recovery. It defines deforestation as “the 

conversion of forest to another land use or the 
FEIS Appendix D – Public Comment Report Magone Project

104

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

long-term reduction of the tree canopy cover below 

a 10% threshold. Deforestation implies the longterm or permanent loss of forest cover and its 

transformation into another land use.” Fortunately, 

federal lands are governed by the Multiple-Use 

Sustained Yield Act and the National Forest 

Management Act which requires the Forest Service 

to manage for multiple uses and to reforest any 

forested stand that is brought below these 

thresholds through management activity. This 

reference also states that “forests on federal and 

state lands are usually managed according to 

multiple use doctrine. This means that in addition 

to forest harvest, the land is available for recreation 

and maintains a healthy forest ecosystem....Forest 

restoration may seek to restore the system to a 

near-natural or completely natural state or to 

restore many aspects of the structure and function 

of an undisturbed forest.” The latter statement of 

restoring structure and function is in alignment with 

the purpose and need of the Magone project.

Voss, R. 2002. Getting burned by logging. The 

Baltimore Chronicle. July.

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

C-06, Opposing Views 

Attachment #1, page 37; C06, Opposing Views 

Attachment #3, page 24

Not 

applicable

This is from a 2003 opinion piece in a newspaper 

promoting to end commercial logging on national 

forests through HR1494, the National Forest 

Protection and Restoration Act. It is not scientific, 

peer-reviewed literature and contains no sources, 

references, or literature cited.

Walsh, J. 2010. Scientist: money to fight beetles as 

fire mitigation not productive. Durango Herald. April 

23.

http://durangoherald.com/sections/News/2010/04/23/

Scientist_Money_to_fight_beetles_as_fire_mitigation_

not_productive/

C-06, Opposing Views 

Attachment #3, page 24

Unable to 

locate 

reference

The website link provided does not work. Unable to 

locate reference.

Wuerthner, G. 2008. Ecological differences between 

logging and wildfire.

http://wuerthner.blogspot.com/2008/12/ecologicaldifferences-between-logging.html

C-06, Opposing Views 

Attachment #4, page 31

Not 

applicable

This blog is an opinion piece about the differences 

between logging and wildfire. We agree that there 

are differences between the effects of logging and 

wildfire. However, the Magone Project does not 

claim to reduce the potential for large wildfires.
FEIS Appendix D – Public Comment Report Magone Project

105

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Wuerthner, G. 2008. Logging, thinning would not 

curtail wildfires. The Eugene Register Guard. 

December 26.

http://wuerthner.blogspot.com/2008/12/loggingthinning-would-not-curtail.html

C-06, Opposing Views 

Attachment #1, page 38; C06, Opposing Views 

Attachment #3, page 25

Not 

applicable

This is an opinion blog discussing the author’s view 

that logging and thinning does not limit wildfires. It 

is not scientific, peer-reviewed literature and 

contains no sources, references, or literature cited.

Wuerthner, G. 2009. Who will speak for the forests? 

NewWest. January 27.

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

or_the_forests/C564/L564/

C-06, Opposing Views 

Attachment #1, page 38

Not 

applicable

This is an opinion blog discussing the author’s 

opposition to the Blackfoot Clearwater Stewardship 

Proposal and its proposed logging. It is not 

scientific, peer-reviewed literature and contains no 

sources, references, or literature cited. The 

Magone Project contains design criteria to

minimize potential impacts.

Wuerthner, G. 2010. Forest Service misses education 

opportunity. NewWest. June.

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

yet_another_example_of_forest_service_malfeasanc

e/C564/L564/

C-06, Opposing Views 

Attachment #3, page 26

Not 

applicable

This is an opinion blog discussing the author’s 

opposition to the Elliston Face project in Montana 

and its proposed logging. It is not scientific, peerreviewed literature and contains no sources, 

references, or literature cited.

Wuerthner, G. 2010. Pine beetle fears misplaced. 

Helena Independent Record. March 25.

http://helenair.com/news/opinion/article_f3d671f0-

37c9-11df-921d-001cc4c002e0.html

C-06, Opposing Views 

Attachment #3, pages 26-27

Not 

applicable

This is an opinion piece on the relationship 

between dead trees and the risk of large fires. The 

Magone Project purpose and need does not 

include a reduction in the risk of wildfire.

Wuerthner, G. 2012. Why are conservation groups 

advocating logging public forests? Counterpunch. 

September 27.

http://www.counterpunch.org/2012/09/27/why-areconservation-groups-advocating-logging-publicforests/

C-06, Opposing Views 

Attachment #1, page 52

Not 

applicable

This is an opinion piece discussing the author’s 

thoughts on conservation groups advocating for 

logging on public lands.

Wuerthner, G. 2014. Why thinning forests is poor 

wildfire strategy. Wildlife News. January 27.

http://www.thewildlifenews.com/2014/01/27/whythinning-forests-is-poor-wildfire-strategy/

C-06, Opposing Views 

Attachment #3, page 27

Not 

applicable

This is an opinion piece discussing the author’s 

view that logging and thinning does not limit 

wildfires. It is not scientific, peer-reviewed literature 

and contains no sources, references, or literature 

cited.

Zimmerman, E.A. and P.F. Wilbur. 2004. A forest 

divided. New Roxbury Land Trust newsletter.

http://www.ourbetternature.org/forestfrag.htm

C-06, Opposing Views 

Attachment #4, page 31

Not relevant 

to this project

This is not a peer-reviewed article. The excerpt 

provides a generic description of forest 

fragmentation. The focus of the article is on forest 

lands divided into smaller parcels for development, 

including housing and how this “poses a serious 

and growing threat to the ability of forests to 

support wildlife, and provide clean air and water, 
FEIS Appendix D – Public Comment Report Magone Project

106

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

recreational opportunities, and an economically 

viable source of wood product.” The Magone 

Project is within the boundaries of the Malheur 

National Forest and does not fragment forest lands 

for the purpose of development.

Zoning News. Saving homes from wildfires: regulating 

the home ignition zone. May 2001. 

http://www.battle-creek.net/docs/fire/zoning.pdf

C-06, Opposing Views 

Attachment #11, page 6

Not 

applicable

This is not scientific peer reviewed literature. This 

is an organization representing the field of city and 

regional planning in the United States. The article 

is focused on private citizen home owners.

Table D-12. Consideration of science/literature submitted during the 45-day comment period related to watershed resources

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Anderson, P.G. 1996. Sediment 

generation from forestry operations 

and associated effects on aquatic 

ecosystems. In: Proceedings of the 

Forest-Fish Conference: Land 

Management Practices Affecting 

Aquatic Ecosystems, Calgary, Alberta.

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

Anderson_PG1998.pdf

C-06 Opposing Views 

Attachment #1, page 2

Not used; 

consistent 

with other 

science used

Consistent with other science used to develop design features to 

minimize sediment. This article discusses the effects of logging and 

roads on aquatic habitats, particularly in relation to sediment delivery to 

streams. The article recommends measures to limit effects. These are 

similar to measures used for the project, including: PACFISH buffers 

that avoid timber harvest in riparian areas and provide a vegetated 

buffer to filter any sediment mobilized from harvest activities in uplands, 

installation of additional culverts to drain roadside ditches away from 

streams, the decommissioning of roads causing sediment inputs and 

riparian degradation, and using appropriate yarding systems to 

minimize soil disturbance. Actions proposed in the Magone Project 

include aquatic restoration work to speed recovery of riparian 

processes and functions affected by past land management activities 

including past delivery of fine sediment to streams.

Brown, G.W. The impacts of timber 

harvest on soil and water resources. 

Corvallis, OR: Oregon State University, 

School of Forestry.

http://andrewsforest.oregonstate.edu/p

ubs/pdf/pub1695.pdf

C-06, Opposing Views 

Attachment #4, page 6

Not 

applicable

This undated publication references no article after 1972 suggesting 

that it was written well before the development and application of 

Watershed Best Management Practices included in General Water 

Quality Best Management Practices” 1988. Pacific Northwest Region 

(and later publications) when logging practices were vastly different.

Keppeler, E.T., R.R. Ziemer, and P.H. 

Cafferata. 1994. Effects of humaninduced changes on hydrologic 

systems. An American Water 

Resources Association publication, 

June.

C-06, Opposing Views 

Attachment #1, page 19

Limited 

applicability

This is not the proper reference; the authors did not write this 

publication; they prepared an article for inclusion in it. Other people are 

the editors of the cited publication. The authors investigated and 

reported on how a zero-order swale was hydrologically affected by 

timber harvesting. Following timber harvests, increases in soil moisture 

were attributed to reduced evapotranspiration rates in the northwestern 

California topography and climate.
FEIS Appendix D – Public Comment Report Magone Project

107

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.fs.fed.us/psw/publications/zi

emer/Ziemer94a.PDF

The geology, soils, and climate of the Magone project planning area is 

very different from the area studied in northwestern California, 10 

kilometers from the Pacific Ocean. Water is the limiting growth factor in 

the Magone project planning area. Also the proposed actions in the 

Magone area include thinning trees, not clearcutting stands. When 

trees are thinned, it is to allow greater amounts of the most limiting 

factor (water) to be made available to and used by the remaining trees 

to enhance growth much as the redwood sprouts used shallow water in 

the study area. Surplus water is not usually available as fine roots are 

responsive to the changed conditions and optimize use of water. In 

addition the analogous mechanism in the Magone planning area is that 

the its shallow and clayey soils infiltrate limited amounts of runoff, 

naturally resulting in higher rates of overland flow, rather than piping. 

The project hydrologist (with over 20 years’ experience on the Malheur 

National Forest) has not observed piping to be a common mechanism 

associated with the root zone on the clay to clayey soils of the northern 

portion of the Blue Mountain Ranger District with the local climate; 

dominant mechanisms are described in the existing condition. Rare 

examples of piping have been observed under particular conditions 

related to soil displacement such as those associated with construction.

Roelofs, T.D. 2003. Testimony for the 

California State Water Board and 

Regional Water Quality Control Board 

regarding waivers of waste discharge 

requirements on timber harvest plans. 

August.

http://webcache.googleusercontent.co

m/search?q=cache:QNy_aih1RxEJ:ed

ennapa.org/thp/roelofstestimony.doc+

%22timber+harvest%22+ph.d.+advers

e&hl=en&ct=clnk&cd=5&gl=us

C-06, Opposing Views 

Attachment #1, page 31

Not 

applicable

This is an individual’s testimony. It is not a peer-reviewed scientific 

article.

Scott, M.G. 2001. Forest clearing in the 

Gray’s River Watershed 1905-1996. 

Research paper submitted in partial 

fulfillment of the requirements for the 

degree of Master of Science in 

Geography. Portland State University.

http://www.markscott.biz/papers/grays/

chapter1.htm

C-06, Opposing Views 

Attachment #1, page 32

Limited 

applicability 

and 

consistent 

with 

professional 

judgment 

used in the 

analysis

This is not a peer reviewed scientific article. It pertains to a 

geographical area that has climate and soils that are different from the 

project planning area. However, we believe the developments of the 

proposed actions are consistent with this information. Treatments are 

designed to emulate natural disturbance events and create more 

structure across the landscape. Past timber management and fire 

suppression have simplified the structure of the upland and riparian 

forests. In addition, the species composition has changed due to 

alterations in canopy cover and microclimates.
FEIS Appendix D – Public Comment Report Magone Project

108

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Ziemer, R.R. 1992. Effect of logging on 

subsurface pipeflow and erosion: 

coastal northern California, USA. 

Proceedings of the Chengdu 

Symposium. IAHS Publication. No. 

209.

http://www.fs.fed.us/psw/publications/zi

emer/Ziemer92.PDF

C-06, Opposing Views 

Attachment #1, page 39

Limited 

applicability

This article represents a U.S. Forest Service research study from the 

Erosion, Debris Flow, and Environment Symposium and is not peerreviewed. It discusses how macropores from clearcut logging practices 

increase the movement of suspended sediment in these belowground 

pipes. See response to other article by Ziemer.

Table D-13. Consideration of science/literature submitted during the 45-day comment period related to fisheries resources

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Klein, A. 2004. Logging effects on 

amphibian larvae populations in 

Ottawa National Forest.

http://www.nd.edu/~underc/east/educat

ion/documents/AKlein2004Preloggingsurveyofamphibianlarvaeinvern

alpools.pdf

C-06, Opposing Views 

Attachment #1, page 20

Limited 

applicability

Commenter references this article in relation to the effects of logging on 

the spotted salamander and vernal ponds, attempting to correlate this 

research to a general adverse effect to all amphibians everywhere. 

However, a correlation of 0.50 does not equate to causation as stated 

in the reference, but merely implies a relationship that could include a 

whole host of other variables unrelated to the stated action (timber 

harvest) that could vary annually or even be related to climatic variation 

in snowpack and precipitation. Additionally, this reference is not from a 

peer-reviewed journal; it is a paper written for a graduate course BIOS 

569.

The spotted salamander Ambystoma maculatum is only found in the 

eastern United States, from Ontario east to Nova Scotia and south to 

Georgia and Texas. There are no identified vernal pools located within 

the Magone project planning area. While we agree that landscape 

changes can alter how water flows and collects, we have designed and 

located our timber harvest units to avoid and minimize impacts to 

hydrological features on the landscape such as seasonal ponds, fens, 

and wetlands. The primary focus of aquatic activities associated with 

the Magone Project timber harvest activities include retention of water 

on the landscape for storage and gradual release into drier summer 

months. While there are no designated vernal pools in the area, we 

have established best management practices that will protect riparian 

habitat conservation areas and waterways from the project as planned. 

Various aquatic restoration components accompany this timber plan, 

which will benefit the landscape moving into the future.

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

R.C. Wissmar, S.E. Clarke, G.H. 

Reeves, and L.A. Brown. 1994. 

C-06, Opposing Views 

Attachment #1, page 23

Limited 

applicability

Commenter cites this article in relation to past logging practices and 

damage to aquatic habitats through siltation, reduction in stream 

complexity, and increased water temperatures. This article was 
FEIS Appendix D – Public Comment Report Magone Project

109

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Management history of eastside 

ecosystems: changes in fish habitat 

over 50 years, 1935-1992. PNW-GTR321. Portland, OR: USDA Forest 

Service, Pacific Northwest Research 

Station. 93-181.

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

nw_gtr321/

produced in 1994 from surveys that were done in 1934 to 1942 in the 

Grande Ronde, Yakima, Wenatchee, and Methow river basins; portions 

of those initial streams were re-surveyed from 1990 to 1992. The 

information supplied in this article is outdated. While historic land-use 

management practices degraded aquatic and wildlife habitat in the 

surveyed areas as well as the project planning area, management 

actions have changed since the early to mid-1900s. Eastern Oregon 

aquatic habitat is no longer declining. Strategies to protect, restore, and 

rehabilitate aquatic habitat and populations is now a priority while 

planning and implementing timber harvest plans. The watershed 

approach to protect and restore aquatic habitats recommended in the 

article is currently being implemented in the proposed action. Being that 

this literature outdates our land-use management by 30 years, it has 

limited applicability to the Magone Project.

Moring, J.R. 1975. The Alsea 

watershed study: effects of logging on 

the aquatic resources of three 

headwater streams of the Alsea River, 

Oregon – Part III. Fishery Report 

Number 9. Oregon Department of Fish 

and Wildlife.

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

Moring_JR1975b.pdf

C-06, Opposing Views 

Attachment #1, page 24

Not 

applicable

Commenter cites this article in relation to logging practices causing 

environmental changes to streams, including siltation, logging debris, 

gravel scouring, destruction of developing embryos and alevins, 

blockage of streamflow, decrease in surface and intragravel dissolved 

oxygen, increase in maximum and diel water temperatures, changes in 

pool/riffle ratios and cover, redistribution of fishes, reduction in fish 

numbers, and reduction in total biomass. This article is nearly 40 years 

old and is outdated. Timber harvesting practices described in the article 

no longer occur on public lands and are not proposed in the Magone 

Project. Project design criteria and best management practices are 

applied to all proposed actions in the Magone Project and are effective 

at preventing or minimizing the effects of logging described in the 

article.

Pacific Salmonids: Major Threats and 

Impacts. Published by NOAA fisheries 

Office of Protected Resources, May 15, 

2014.

http://www.nmfs.noaa.gov/pr/species/fi

sh/salmon.htm

C-06, Opposing Views 

Attachment #1, page 56

Limited 

applicability

This website paper provides a general overview of threats/impacts to 

salmonids from human activities.

Salmonid species on the west coast of the United States have 

experienced dramatic declines in abundance during the past several 

decades as a result of human-induced and natural factors. There is no 

single factor solely responsible for this decline. Given the complexity of 

the salmon species life history and the ecosystem in which they reside, 

it is difficult to precisely quantify the relative contribution of any one 

factor to the decline of a given species. Rather, given the available 

data, it is only possible to highlight factors which have significantly 

affected the status of a particular species. Effects analysis within the 

Magone FEIS analyze for those threats associated with logging on 

primary habitat elements associated with Mid-Columbia River steelhead 

as identified by the National Marine Fisheries Service. Project design 
FEIS Appendix D – Public Comment Report Magone Project

110

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

criteria and best management practices address these threats and 

aquatic restoration activities address the legacy effects of these 

activities on the landscape.

The effects of logging activities on Mid-Columbia River steelhead 

Critical Habitat are also analyzed within a biological assessment which 

is reviewed by the National Marine Fisheries Service for consistency.

The National Marine Fisheries Service compiled the document cited.

Table D-14. Consideration of science/literature submitted during the 45-day comment period related to roads

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Amaranthus, M.P., R.M. Rice, N.R. 

Barr, and R.R. Ziemer. 1985. Logging 

and forest roads related to increased 

debris slides in southwestern Oregon. 

Journal of Forestry 83(4).

06, Opposing Views 

Attachment #4, page 2

Limited 

applicability

This paper reviews landslide frequency as affected by forest 

management in the coastal mountains of southwest Oregon. The 

authors found a six-fold increase in landslide volume in Forest Servicelogged areas compared with unharvested areas, as well as erosion 

rates that were 100 times greater on roads and landings compared with 

undeveloped areas.

The study area geomorphology and climate are different from that of 

the Magone project planning area. The Magone FEIS acknowledges 

the effects of roads on erosion (sedimentation). These effects are 

disclosed in the FEIS in the aquatics and hydrology sections. 

Additionally, mitigation measures to address erosion from roads is 

prescribed and discussed in the FEIS and its appendices.

Aust, M., K. McGuire, M.C. Bolding, 

and S. Barrett. 2011. Forest roads and 

sediment project, project duration:

January 2011 to November 2019.

http://hydro.vwrrc.vt.edu/research/proje

cts/forest-roads-and-sediment-project/

C-06, Opposing Views 

Attachment #4, page 6

Not 

applicable

This is a summary of a work plan for an on-going study and does not 

include results. In addition the study area is in the temperate 

hardwoods with different climate, geology, and soils and consequently 

is likely to have different road issues than the project area in a semiarid to continental climate.

Borga, M., F. Tonelli, G. Dalla Fontana, 

and F. Cazorzi. 2003. Evaluating the 

effects of forest roads on shallow 

landsliding. Geophysical Research 

Abstracts, Vol. 5, 13312.

http://www.cosis.net/abstracts/EAE03/1

3312/EAE03-J-13312.pdf

C-06, Opposing Views 

Attachment #4, page 3

Not relevant 

to this project

This reference has little relevance to the proposed project. This study 

was conducted in northeastern Italy where the landscape, climate, 

soils, and geology are so different that almost no correlation could be 

reached in regards to the proposed project.

Bowling, L.C., D.P. Lettenmaier, M.S. 

Wigmosta, and W.A. Perkins. 1996. 

Predicting the effects of forest roads on 

C-06, Opposing Views 

Attachment #4, pages 

3-4

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.
FEIS Appendix D – Public Comment Report Magone Project

111

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

streamflow using a distributed 

hydrological model [Poster]. Presented 

at a meeting of the American 

Geophysical Union, San Francisco, 

CA.

http://www.ce.washington.edu/~lxb/pos

ter.html

Brister, D. 1998. A review and 

comment on: Forest Service roads: a 

synthesis of scientific information, 2nd 

Draft, USDA Forest Service.

C-06, Opposing Views 

Attachment #4, page 4

Not relevant 

to this project

The article cited is an opinion paper offering review and comment on 

Forest Service Roads: A Synthesis of Scientific Information”, 2nd Draft, 

December 1998. A more recent version of this report (Forest Roads: A 

Synthesis of Scientific Information, PNW-GTR-509) was published in 

2001. The article written by Mr. Brister suggests the Forest Service 

include in the final document an assessment of socio-economic impacts 

of forest system roads. The final document includes two sections on 

this topic 1) Direct Socioeconomic and 2) Indirect Socioeconomic 

Effects.

The report published in 2001 (as did previous drafts) analyzes the 

effects of existing National Forest System roads but does not analyze 

the effects of temporary roads. The analysis of the socio-economic 

impacts of the existing National Forest System road infrastructure is 

beyond the scope of this project.

Burns, J.W. 1972. Some effects of 

logging and associated road 

construction on northern California 

streams. Transactions of the American 

Fisheries Society 1(1).

http://www.fs.fed.us/psw/publications/4

351/Burns72.pdf

C-06, Opposing Views 

Attachment #4, page 6

Limited 

applicability –

sediment 

delivery to 

streams was 

a primary 

consideration 

in project 

design, but 

this article is 

dated and 

analyzes 

treatments in 

much greater 

proximity and 

magnitude to 

streams than 

those 

proposed in 

The commenter references this article in relation to the effects of 

logging and road construction on streams and fish, suggesting, 

“Sustained logging and associated road construction over a period of 

many years do not afford either the stream of the fish population a 

chance to recover.” This article is over 40 years old, analyzing the 

effects to streams from a logging project that occurred nearly 50 years 

ago. In the project referenced, 66 kilometers of road were constructed, 

including 4 crossings, within 76 meters of the stream, plus the entire 

area between the road and stream was logged and they ran dozers 

over 41 percent of the stream length in the stream to remove slash and 

skid trees.

Commercial timber harvest practices and associated road activities 

have changed considerably over the past half century. The Magone 

Project design criteria (PDCs) include PACFISH buffers around riparian 

areas that have proven effective at avoiding or minimizing sediment 

delivery to streams from timber harvest. Thoughtful project design and 

PDCs are in place to minimize potential sediment delivery to streams 

from all proposed actions. The Magone Project also includes many 

aquatic restoration actions aimed at contributing to recovery of 

Endangered Species Act listed fish that occur within the project 
FEIS Appendix D – Public Comment Report Magone Project

112

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

the Magone 

Project.

planning area, including restoration of floodplain connectivity, restoring 

stream and floodplain roughness elements such as large wood that 

provide quality fish habitat, removal of fish passage barriers, and 

riparian enhancement thinning to restore meadows, and reinvigorate 

hardwood shrub communities.

Coghlan, G. and R. Sowa (compiled 

by). 1998 [draft]. National Forest road 

system and use. Washington, DC: U.S. 

Department of Agriculture, Forest 

Service, Engineering Staff.

http://www.fs.fed.us/eng/road_mgt/road

summary.pdf

C-06, page 4 Relevant to 

this project

This is a Forest Service report on the national forest road system and 

use. It provides information similar to what is provided in the existing 

condition of the Road Report.

Dombeck, M., U.S. Forest Service 

Chief, 1997-2001. Remarks made to 

Forest Service employees and retirees 

at the University of Montana. February 

1998.

C-06, page 4; C-06, 

Opposing Views 

Attachment #4, page 7

Relevant to 

this project

In his speech, Chief Dombeck shares the core principles of his 

forthcoming natural resource agenda, which addresses watershed 

health and restoration, sustainable forest ecosystem management, 

forest roads and recreation; and shares highlights of the President's 

proposed FY99 budget. With respect to roads, Chief Dombeck states 

that forest roads are an essential part of the transportation system, 

providing benefits as well as causing serious ecological impacts. Thus, 

he proposed a new long-term forest road policy with four primary 

objectives: 1) More carefully consider decisions to build new roads, 2) 

Eliminate old unneeded roads, 3) Upgrade and maintain the roads 

important to public access, and 4) Develop new and dependable 

funding for forest road management.

The haul routes that would be used to haul timber from the Magone 

Project would receive needed maintenance work prior to any log 

hauling to reduce sediment delivery to adjacent streams.

EPA entry into the Federal Register: 

March 3, 2000 (Volume 65, Number 

43) page 11675, National Forest 

System Road Management.

C-06, page 7; C-06, 

Opposing Views 

Attachment #4, page 7

Not relevant 

to this project

Excerpt from a March 3, 2000 Federal Register Notice posted by the 

Forest Service. The Forest Service concluded that it needed to review 

its forest road system policy, one of four emphasis items in the 

agency's National Resource Agenda. The Agency proposed to revise 

36 CFR Part 212 to shift the emphasis from transportation development 

to managing environmentally sound access.

The Magone Project follows current law, regulation, and policy.

Forman, R.T. and L.E. Alexander. 

1998. Roads and their major ecological 

effects. Annual Review of Ecology and 

Systematics 29: 207-231.

C-06, Opposing Views 

Attachment #4, page 8

Relevant to 

this project

Many of the effects discussed in this paper are those associated with 

paved, well-maintained, high-speed roads. However, it is recognized 

that lower-standard, unpaved Forest roads have effects as well. See 

the Magone FEIS chapter 3, Wildlife section and the Wildlife Report 

regarding the effects of roads on wildlife species present in the project 

planning area.
FEIS Appendix D – Public Comment Report Magone Project

113

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Furniss, M.J., M. Love, and S.A. 

Flanagan. 1997. Diversion potential at 

road-stream crossings. USDA Forest 

Service, Technology and Development 

Program. 9777 1814—SDTDC.

http://www.stream.fs.fed.us/waterroad/w-r-pdf/diversionpntl.pdf

C-06, Opposing Views 

Attachment #4, page 10

Relevant to 

this project

This comment is a quotation from an article in the water/road interaction 

technology series produced by San Dimas Technology and 

Development Center and does not refer to specific conditions in the 

Magone project planning area. The article discusses the potential 

effects of water being diverted out of road/stream crossings. These 

concerns about the existing road system were included in the existing 

condition discussion for hydrology and aquatics; new stream crossings 

on authorized roads are not proposed in the alternatives in the Magone 

Project. Also, re-designing road crossings to improve aquatic conditions 

is beyond the scope of the Magone Project. The article makes specific 

recommendations for designing stream crossings; these (or similar 

practices) are incorporated into the Malheur National Forest’s Aquatic 

Restoration Decision under which the expected replacement of culverts

in the Magone project planning area is considered to be foreseeable 

activities (see Magone FEIS chapter 3) and discussed under 

cumulative effects.

Grace, J.M., III. 2003. Minimizing the 

impacts of the forest road system. In: 

Proceedings of the conference 34 

international erosion control 

association; ISSN 1092-2806. [Place of 

publication unknown]: International 

Erosion Control Association: 301-310.

http://www.srs.fs.usda.gov/pubs/ja/ja_g

race011.pdf

C-06, Opposing Views 

Attachment #4, page 11

Relevant to 

this project

This study evaluates alternative means (vegetation, riprap, sediment 

fences, and settling basins) of filtering sediment laden road runoff 

before it reaches the forest floor on the Tuskegee National Forest in 

Alabama.

The Magone Project includes a variety of project design criteria and 

best management practices designed to minimize sediment runoff from 

roads. See Magone FEIS Appendix C – Project Design Criteria.

Gucinski, H., M.J. Furniss, R.R. 

Ziemer, and M.H. Brookes (eds.). 

2001. Forest roads: a synthesis of 

scientific information. Gen. Tech. Rep. 

PNW-GTR-509. Portland, OR: USDA 

Forest Service, Pacific Northwest 

Research Station.

http://www.fs.fed.us/pnw/pubs/gtr509.p

df

C-06, Opposing Views 

Attachment #4, page 11

Reviewed for 

background 

information; 

consistent 

with literature 

used in 

analysis

Discusses the connection of roads to community economic and 

resource impacts.

Hann, W.J. [et al.]. 1997. Landscape 

dynamics of the Basin. In: An 

assessment of ecosystem components 

in the Interior Columbia Basin and 

portions of the Klamath and Great 

C-06, Opposing Views 

Attachment #4, page 12

Relevant to 

this project; 

provides 

background 

information

This document is part of An Assessment of Ecosystem Components in 

the Interior Columbia Basin and Portions of the Klamath and Great 

Basins, an effort to provide detailed information about current 

conditions and trends for the biophysical and social systems within the 

Basin. The abstract states that this information can be used by land 
FEIS Appendix D – Public Comment Report Magone Project

114

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Basins, Volume II. PNW-GTR-405. 

USDA Forest Service: 337-1,055.

http://www.fs.fed.us/pnw/pubs/gtr405/p

nw_gtr405aa.pdf

managers to develop broad land management goal and priorities and 

provides the context for decisions specific to smaller geographic areas.

Hawbaker, T.J., V.C. Radeloff, M.K. 

Clayton, R.B. Hammer, and C.E. 

Gonzalez-Abraham. 2006. Road 

development, housing growth, and 

landscape fragmentation in northern 

Wisconsin: 1937–1999. Ecological

Applications 16(3): 1222-1237.

http://www.esajournals.org/doi/abs/10.

1890/1051-

0761%282006%29016%5B1222%3AR

DHGAL%5D2.0.CO%3B2?journalCode

=ecap

C-06, page 7; C-06, 

Opposing Views 

Attachment#4, page 13

Limited 

applicability

This study looked at road density, patch size, and housing density to 

evaluate the pattern of fragmentation over time. The Magone project 

planning area is National Forest System land, and will not be developed 

for housing.

See the Magone FEIS chapter 3, Wildlife section and the Wildlife 

Report regarding the effects of roads and road density on wildlife 

species present in the project planning area.

Haskell, D.G. 1999. Effects of forest 

roads on macroinvertebrate soil fauna 

of the southern Appalachian 

Mountains. Conservation Biology 

14(1): 57-63.

http://www.jstor.org/stable/2641904

C-06, Opposing Views 

Attachment #4, page 13

Relevant to 

this project

This study looks at the effect of roads on macroinvertebrate fauna of 

the soil, depth of the leaf-litter layer.

See the Magone FEIS chapter 3, Soils section and the Soils Report 

regarding the impacts of existing and proposed roads to soils.

Ivins, M. 1997. Opinion article posted 

to creators.com. August 3.

http://www.creators.com/opinion/mollyivins/molly-ivins-august-3-1997-08-

03.html

C-06, Opposing Views 

Attachment #4, page 14

Not 

applicable

This is an opinion pieces discussing the author’s opinion on a variety of 

topics, including logging roads. It is not scientific, peer-reviewed 

literature and contains no sources, references, or literature cited.

Jones, J.A., F.J. Swanson, B.C. 

Wemple, and K.U. Snyder. 2000. 

Effects of roads on hydrology, 

geomorphology, and disturbance 

patches in stream networks. 

Conservation Biology 14(1): 76-85.

http://www.jstor.org/stable/2641906

C-06, Opposing Views 

Attachment #4, page 14

Consistent 

with 

professional 

judgment 

used in the 

analysis

This peer-reviewed scientific article developed a conceptual model for 

evaluating how road networks interact with stream networks at a 

landscape scale. Of particular interest is how road networks interact 

with streams for peak flows and debris flows. They used observations 

from a number of studies from the H.J. Andrews Experimental Forest 

and established a framework for illustrating how road-stream 

interactions involve peak flows and debris flows.

Kahklen, K. 2001. A method for 

measuring sediment production from 

forest roads. Res. Note. PNW-RN-529. 

Portland, OR: USDA Forest Service, 

Pacific Northwest Research Station.

C-06, Opposing Views 

Attachment #4, pages 

14-15

Out of scope 

of project

This is a U.S. Forest Service Research Note on a method to measure 

sediment production from forest roads. It provides examples on 

measuring sediment that have been used in southeast Alaska.

Measuring sediment in this analysis is out of the scope of the project. 

Data collection efforts focused on finding road-stream connections and 
FEIS Appendix D – Public Comment Report Magone Project

115

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.fs.fed.us/pnw/pubs/rn529.p

df

moving those road segments forward to eliminate the connectivity. 

Road-stream connectivity was used as a surrogate for understanding 

the sediment.

Lawren, B. 1992. Singing the blues for 

songbirds: bird lovers lament as 

experts ponder the decline of dozens 

of forest species. National Wildlife.

http://www.nwf.org/news-andmagazines/nationalwildlife/birds/archives/1992/singing-theblues-for-songbirds.aspx

C-06, Opposing Views 

Attachment #4, page 15

Not 

applicable

This is not scientific peer reviewed literature. This writing is from a 

private citizen advocacy organization doing their specific outreach.

Lowe, K. 2005. Restoring forest roads. 

A Northern Arizona University 

Ecological Restoration Institute 

publication. Working Paper 12.

http://www.eri.nau.edu/en/informationfor-practitioners/restoring-forest-roads

C-06, Opposing Views 

Attachment #4, page 16

Relevant to 

this project

This publication presents an overview of the ecological problems 

caused by forest roads and a guide to methods that can be used in 

their restoration.

Approximately 0.3 miles of road would be decommissioned as part of 

this project. Temporary roads would be rehabilitated following harvest 

activities.

Luce, C.H. 2002. Hydrological 

processes and pathways affected by 

forest roads: What do we still need to 

learn? Hydrologic Processes 16(14): 

2901–2904.

C-06, Opposing Views 

Attachment #4, page 17

Relevant to 

this project

This is a commentary article discussing the effects of roads on 

sediment generation. The publication poses several research questions 

relating to the physics of road interception and how the hillslope 

responds during rare events compared with common events.

The Magone Project would decommission approximately 0.3 miles of 

road.

Maholland, B. and T.F. Bullard. 2005. 

Sediment-related road effects on 

stream channel networks in an eastern 

Sierra Nevada watershed. Journal of 

the Nevada Water Resources 

Association 2(2).

C-06, Opposing Views 

Attachment #4, page 18

Limited 

applicability

This publication describes the results of a study on Squaw Creek in 

California identifying and characterizing sources of sediment, including 

impacts from road networks on sediment delivery to the stream 

network.

The Magone Project includes a variety of project design criteria and 

best management practices to minimize sedimentation from roads 

related to this project. See Magone FEIS Appendix C – Project Design 

Criteria.

The haul routes that would be used to haul timber would receive 

needed maintenance work prior to any log hauling to reduce sediment 

delivery to adjacent streams.

Malecki, R.W. 2006. A new way to look 

at forest roads: the road hydrologic 

impact rating system (RHIR). The

Road-RIPorter, Autumn Equinox.

C-06, Opposing Views 

Attachment #4, page 18

Limited 

applicability

This publication describes a system the author developed to provide a 

summary of forest road data and to compare forested ecosystems in 

the intermountain West. It is not scientific, peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

116

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.wildlandscpr.org/fieldnotes/new-way-look-forest-roads-roadhydrologic-impact-rating-system-rhir

McCashion, J.D. and R.M. Rice. 1983. 

Erosion on logging roads in 

northwestern California: How much is 

avoidable? Journal of Forestry 8(1): 

23-26.

http://www.fs.fed.us/psw/publications/ri

ce/McCashion.pdf

C-06, Opposing Views 

Attachment #4, page 18

Limited 

applicability

This 1983 article assessed the sources of erosion and the extent to 

which road-related erosion is avoidable on 344 miles of logging roads in 

northwestern California.

Historical logging practices, including road construction and 

maintenance, were based on entirely different management objectives 

and are a very poor indicator of effects of modern federal forestry 

practices focused on current restoration based science principles. 

Magone FEIS chapter 3 analyzes the impacts of roads and mitigation 

measures.

McFero, G.J., III. 2004. Sediment 

plume development from forest roads: 

How are they related to filter strip 

recommendations? An ASAE/CSAE 

meeting presentation, paper number 

045015.

http://www.srs.fs.usda.gov/pubs/ja/ja_g

race017.pdf

C-06, Opposing Views 

Attachment #4, page 19

Not 

applicable

This paper was presented at an international meeting in Canada. It is 

not a peer-reviewed scientific article. It looks at sediment travel 

distances downslope of forest roads and understand the factors 

affecting these distances. This study was done in Alabama and Georgia 

and makes recommendations specifically for Alabama and Georgia.

This paper is not applicable to the Magone project planning area. The 

geology, soils, and climate are too different between the project 

planning area and the cited study area.

McGarigal, K., W.H. Romme, M. Crist, 

and E. Roworth. 2001. Cumulative 

effects of roads and logging on 

landscape structure in the San Juan 

Mountains, Colorado (USA). 

Landscape Ecology 16(4).

C-06, Opposing Views 

Attachment #4, page 19

Limited 

applicability

This is a peer-reviewed scientific article that investigated the effects of 

roads and logging on disturbance regimes and landscape patterns.

They found roads to have a bigger impact on landscape structure than 

logging in their study area in the southern Rocky Mountains.

The silviculture report investigates patch size dynamics that were 

present in the 1939 aerial photo records and used those observations 

to mimic through silvicultural treatments. Treatments are also designed 

to be within the historical range of variability for any particular 

biophysical environment. Otherwise, cumulative effects do not evaluate 

changes to landscape structure. Cumulative effects to hydrology did 

evaluate peak flow and annual water yield effects due to past, present, 

and future logging activities and road networks.

Megahan, W.F. 2003. Predicting road 

surface erosion from forest roads in 

Washington State [Presentation]. 

Geological Society of America meeting.

http://gsa.confex.com/gsa/2003AM/fina

lprogram/abstract_67686.htm

C-06, Opposing Views 

Attachment #4, page 20

Not 

applicable

The author states that the model is intended for use on forest roads in 

Washington State.
FEIS Appendix D – Public Comment Report Magone Project

117

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Montgomery, D. 1998. Statement at 

press conference with Senator Robert 

Torricelli about S. 977 and HR 1376), 

the Act to Save America’s Forests. 

April 28.

http://www.saveamericasforests.org/ne

ws/ScientistsStatement.htm

C-06, Opposing Views 

Attachment #4, page 20

Not 

applicable

This document includes statements from scientists supporting the Act 

to Save America’s Forest (S. 977, HR 1376). It contains no sources, 

references, or literature cited and is not scientific, peer-reviewed 

literature.

Noss, R. 1995. The ecological effects 

of roads or the road to destruction. 

Wildlands CPR.

C-06, Opposing Views 

Attachment #4, page 21

Not 

applicable

This is an opinion pieces discussing the author’s opinion on the effects 

of roads. It is not scientific, peer-reviewed literature and contains no 

sources, references, or literature cited.

Ortega, Y.K. and D.E. Capen. 1999. 

Effects of forest roads on habitat 

quality for ovenbirds in a forested 

landscape. Auk 116(4): 937-946.

http://www.fs.fed.us/rm/pubs_other/rmr

s_1999_ortega_y001.html

C-06, Opposing Views 

Attachment #4, page 22

Not 

applicable

This article describes a study looking at the influence of forest roads on 

ovenbird density in an extensively forested region of Vermont. This 

species of bird does not occur on the Malheur National Forest.

Reed, R.A., J. Johnson-Barnard, and 

W.A. Baker. 1996. Contribution of 

roads to forest fragmentation in the 

Rocky Mountains. Conservation 

Biology 10: 1098-1106.

C-06, Opposing Views 

Attachment #4, page 23

Relevant to 

this project

This study quantified fragmentation due to roads in a section of the 

Medicine Bow-Routt National Forest in southeastern Wyoming, looking 

at number of patches, mean patch area, mean interior area, mean area 

of edge influence, mean patch perimeter, total perimeter, and mean 

patch shape identified patch- and edge-related landscape changes. 

The study found that roads added to forest fragmentation more than 

clear cuts, and that fragmentation due to roads could be minimized if 

road construction is minimized or rerouted so that its fragmentation 

effects are reduced.

Fragmentation would be reduced with the approximately 0.3 miles of 

road would be decommissioned. Temporary roads would be 

rehabilitated following harvest activities.

Reid, L.M. and T. Dunne. 1984. 

Sediment production from forest road 

surfaces. Water Resources Research 

20(11): 1753–1761.

C-06, Opposing Views 

Attachment #4, page 23

Limited 

applicability

The study described in this article looked at runoff rates and sediment 

concentrations from 10 road segments subject to a variety of traffic 

levels in the Olympic Mountains of Washington. The study showed 

roads with heavy traffic contributed more sediment.

Logging activities during this study occurred when turbidity was 

permitted in ditches associated with hauling activities. However, the 

Magone Project includes a variety of project design criteria and best 

management practices to minimize sedimentation from roads related to 

this project. See Magone FEIS Appendix C – Project Design Criteria.

Reid, L.M., R.R. Ziemer, and M.J. 

Furniss. 1994. What do we need to 

C-06, Opposing Views 

Attachment #4, page 24

Relevant to 

this project

This publication was based on the knowledge and opinions of those 

attending interdisciplinary and interagency workshops held at the 
FEIS Appendix D – Public Comment Report Magone Project

118

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

know about roads? USDA Forest 

Service, Pacific Southwest Research 

Station.

http://www.fs.fed.us/psw/publications/r

eid/4Roads.htm

Humboldt Interagency Watershed Analysis Center in 1994. The 

document inventories methods and information requirements for 

looking at a road system for transportation planning and land 

management decisions.

These recommendations are consistent with the process used in 

selecting roads to close and decommission as part of the Magone 

Project.

Reynolds [et al.]. 1992. C-06, Opposing Views 

Attachment #4, page 30

Unable to 

locate 

reference

Unable to located article based on citation given.

Rice, R.M., F.B. Tilley, and P.A. 

Datzman. 1979. A watershed’s 

response to logging and roads: South 

Fork of Caspar Creek, California, 1967-

1976. Res. Paper. PSW-146. USDA 

Forest Service.

http://www.fs.fed.us/psw/publications/ri

ce/Rice79.pdf

C-06, Opposing Views 

Attachment #4, page 24

Not 

applicable

This 1979 publication describes the effects of logging and road 

construction. Historical logging practices, including road construction 

and maintenance, were based on entirely different management 

objectives and are a very poor indicator of effects of modern federal 

forestry practices focused on current restoration based science 

principles.

Riedel, M.S. and J.M. Vose. 2002. 

Forest road erosion, sediment 

transport and model validation in the 

southern Appalachians [Presentation]. 

Second Federal Interagency 

Hydrologic Modeling Conference.

http://www.srs.fs.usda.gov/pubs/ja/ja_ri

edel002.pdf

C-06, Opposing Views 

Attachment #4, pages 

24-25

Not 

applicable

The purpose of the study described in this publication is to determine 

the ability of a watershed-scale erosion model to assess sediment 

production, delivery to streams, and predict restoration effectiveness in 

the Conasauga River Watershed in northern Georgia and southern 

Tennessee.

Data was collected in the Magone project planning area on road 

condition to identify where roads may be degrading water quality. This 

information was used to make changes to the road network as part of 

the proposed actions. Maintenance is planned for roads where they 

could not be decommissioned.

Robinson [et al.]. 1995. C-06, Opposing Views 

Attachment #4, page 1

Unable to 

locate 

reference

Unable to locate reference based on citation given.

Rowland, M.M., M.J. Wisdom, B.K. 

Johnson, and M.A. Penninger. 2004. 

Effects of roads on elk: implications for 

management in forested ecosystems. 

In: Rahm, J. ed. Transactions of the 

69th North American Wildlife and 

Natural Resources Conference, 

Spokane WA: 491-508.

C-06, Opposing Views 

Attachment #4, page 25

Applicable This paper’s goals are to describe current knowledge about effects of 

roads on elk, an example in which a distance-band approach was used 

to evaluate habitat effectiveness for elk in relation to roads, and broader 

implications of road-related policies and land management with regard 

to elk.

The impacts of roads and road density on elk are discussed in the 

Wildlife Report and Magone FEIS chapter 3.
FEIS Appendix D – Public Comment Report Magone Project

119

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

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

pnw_2004_rowland001.pdf

Schwartz, C. 1998 Wildlife and roads. 

The Interagency Forest Ecology Study 

Team (INFEST) March newsletter.

http://www.sf.adfg.state.ak.us/sarr/fore

stecology/fsroads.cfm

C-06, Opposing Views 

Attachment #4, page 26

Not 

applicable

The link provided goes to a State of Alaska webpage about Sport 

Fisheries in Alaska.

Shanley, J.B. and B. Wemple. 2002. 

Water quantity and quality in the 

mountain environment. Vermont Law 

Review. 26: 717.

http://www.uvm.edu/~bwemple/pubs/sh

anley_wemple_law.pdf

C-06, Opposing Views 

Attachment #4, page 26

Not 

applicable

This document focuses on the data gap around ski area and mountain 

resort effects on streams, especially in the northeastern United States 

and Canada. The paper concludes that lawmakers, policy makers, and 

land managers need a greater scientific foundation on which to base 

their decisions on development in the mountain environment. The 

Magone Project does not propose any ski area or resort development.

Swift, L.W., Jr.1984. Soil losses from 

roadbeds and cut and fill slopes in the 

Southern Appalachian Mountains. 

Southern Journal of Applied Forestry. 

8: 209-216.

http://cwt33.ecology.uga.edu/publicatio

ns/403.pdf

C-06, Opposing Views 

Attachment #4, page 27

Not 

applicable

No new authorized road construction is proposed in the Magone 

Project. This article discusses soil loss from roads and their cut/fill 

slopes in their study area in the Southern Appalachian Mountains. Soil 

losses were measured off forest roads. Cut and fill slopes were found to 

be the biggest contributors of soil loss. Grass cover can mitigate these 

losses. The rainfall described for the study area is nearly three times 

that in the Magone project planning area and falls primarily as rain 

compared to the majority of precipitation in the project planning area 

falls as snow. Erosion processes resulting from runoff from rain differ 

from those resulting from snowmelt, especially in the local nearcontinental climate where night time temperatures below freezing are 

common during snowmelt season and control the rate of snowmelt and 

associated runoff.

Switalski, A. 2003. Where have all the 

songbirds gone? Roads, 

fragmentation, and the decline of 

neotropical migratory songbirds. 

Wildlands CPR. September 8.

http://www.wildlandscpr.org/node/213

C-06, Opposing Views 

Attachment #4, page 27

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.

Trombulak, S.C. and C.A. Frissell. 

2000. Review of ecological effects of 

roads on terrestrial and aquatic 

communities. Conservation Biology 

14(1): 18–30.

C-06, Opposing Views 

Attachment #4, page 28

Consistent 

with project

This document discusses the effects of roads on terrestrial and aquatic 

resources. It recommends building no roads in sparsely or unroaded 

areas and encourages removal of unneeded roads. No new authorized 

road construction is proposed in the Magone Project. Temporary roads 

would be located in previously generally roaded areas as they would 

intersect with existing roads. The Magone Project would decommission 

0.3 miles of road.
FEIS Appendix D – Public Comment Report Magone Project

120

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

USDA Forest Service. Forest 

fragmentation and roads [Webpage]. 

Southern Research Station, Eastern 

Forest Environmental Threat 

Assessment Center.

http://www.forestthreats.org/publication

s/su-srs-018/fragmentation

C-06, Opposing Views 

Attachment #4, page 8

Consistent 

with analysis

This is a section from the “Forest Health Monitoring National Technical 

Reports: Examples of Analyses and Results from 2001-2004.” The 

information is consistent with analysis in the Magone FEIS chapter 3, 

Wildlife section.

Watson, M.L. 2005. Habitat 

fragmentation and the effects of roads 

on wildlife and habitats. Background 

and literature review.

http://www.wildlife.state.nm.us/conserv

ation/habitat_handbook/documents/20

04EffectsofRoadsonWil 

dlifeandHabitats.pdf

C-06, Opposing Views 

Attachment #4, page 29

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.

Winslow [et al.]. 2000. C-06, Opposing Views 

Attachment #4, page 1

Unable to 

locate 

reference

Unable to locate reference based on citation given.

Wright, B. 2009. Excerpt from a May 

11, 2009 letter to the Rogue RiverSiskiyou National Forest Travel 

Management Team.

http://www.pacificrivers.org/protectiondefense/commentletters/Rogue%20River%20Siskiyou%2

0TMP%20DEIS.pdf

C-06, Opposing Views 

Attachment #4, pages 

30-31

Not 

applicable

This is a letter from the Pacific Rivers Council to the Rogue RiverSiskiyou National Forest commenting on the Rogue River-Siskiyou 

Motorized Vehicle Use Draft Environmental Impact Statement. This 

does not apply to the Magone Project.

Yahner, R.H. 1988. Changes in wildlife 

communities near edges. Conservation 

Biology. 2(4): 333-339.

http://www.jstor.org/stable/2386292?se

q=1#page_scan_tab_contents

C-06, Opposing Views 

Attachment #4, page 1

Limited 

Applicability

The paper discusses potential negative consequences of edge effects 

to some wildlife species and calls for more research on the topic. The 

project planning area contains many inherent edges while action 

alternatives create even more induced edges of different types and 

dimensions. However, analysis considers multiple wildlife species and 

their relationship to treatments and habitat types, and connectivity 

corridors would be established to provide for movement and 

permeability across the landscape.
FEIS Appendix D – Public Comment Report Magone Project

121

Table D-15. Consideration of science/literature submitted during the 45-day comment period related to wildlife

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Jalkotzy, M.G., P.I. Ross, and M.D. 

Nasserden. 1997. The effects of linear 

developments on wildlife: a review of 

selected scientific literature. Calgary, 

CA: Arc Wildlife Services Ltd: 115 p.

http://www.ceaa.gc.ca/050/documents/

p59540/83236E.pdf

C-06, Opposing Views 

Attachment #1, page 18

Limited 

applicability

A summary of scientific literature compiled for species and habitats not 

applicable to the Malheur National Forest. However, discussions of 

road density, road construction and connectivity are consistent with 

project planning.

McLellan, B.N. 1989. Relationships 

between human industrial activity and 

grizzly bears. In: Bears: their biology 

and management, Vol. 8. International 

Conference on Bear Research and 

Management, Victoria, BC: 57-64.

http://www.bearbiology.com/fileadmin/t

pl/Downloads/URSUS/Vol_8/McClellan

_8.pdf

C-06, Opposing Views 

Attachment #4, page 20

Not 

applicable

Paper discusses impacts specific to species that are not of concern on 

the Malheur National Forest. Discussion regarding impacts of roads on 

grizzlies is consistent with analysis of the impacts that roads have on 

other wildlife species on the Forest.

Wisdom, M.J., R.S. Holthausen, 

B.C.Wales, C.D. Hargis, V.A. Saab, 

D.C. Lee, W.J. Hann, T.D. Rich, M.M. 

Rowland, W.J. Murphy, and M.R. 

Eames. 2000. Source habitats for 

terrestrial vertebrates of focus in the 

Interior Columbia Basin: broad-scale 

trends and management implications 

volume 2a – group level results. 

General Technical Report PNW-GTR485. Portland, OR: USDA Forest 

Service, Pacific Northwest Research 

Station.

http://www.fs.fed.us/pnw/pubs/gtr485/

C-06, Opposing Views 

Attachment #4, page 30

Considered The Wisdom et al. 2000 publication is cited throughout the Wildlife 

Specialist Report. In context of road densities, the current road density 

in the project planning area resulting from past activities makes up the 

existing condition. The proposed action would ultimately decrease open 

road densities in the project planning area and the effects of road 

densities are analyzed in the Magone FEIS and Wildlife Specialist 

Report.

Table D-16. Consideration of science/literature submitted during the 45-day comment period related to snags

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Maser, C. and J.M. Trappe. 1984. The 

seen and unseen world of the fallen 

tree. Gen. Tech Rep. GTR-PNW-164. 

C-06, Opposing Views 

Attachment #1, page 22

Consistent 

with science 

used in 

analysis

The publication discusses the importance of dead and decaying wood 

on the landscape, and that removal of defective habitat would be 

detrimental to species diversity and considered when basing 

management decisions. Dead and decaying wood was considered in 
FEIS Appendix D – Public Comment Report Magone Project

122

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

USDA Forest Service, Pacific 

Northwest Research Station.

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

nw_gtr164/

the analysis of the Magone Project by the use of DecAID – a “decayed 

wood advisory tool.”

Maser, C., R.F. Tarrant, J.M. Trappe, 

and J.F. Franklin. 1988. The forest to 

the sea: a story of fallen trees. Gen. 

Tech. Rep. GTR-PNW-GTR-229. 

USDA Forest Service, Pacific 

Northwest Research Station.

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

nw_gtr229/

C-06, Opposing Views 

Attachment #1, page 23

Consistent 

with science 

used in 

analysis

Dead and decaying and down wood was considered in the analysis of 

the Magone Project by the use of DecAID – a “decayed wood advisory 

tool.”

Table D-17. Consideration of science/literature submitted during the 45-day comment period related to botany / non-native invasive plants

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Anonymous. 2014. Roundup & 

fertilizers blamed for tens of thousands 

of deaths. Honey Colony.

http://www.honeycolony.com/article/tox

ic-combo-roundup-fertilizers-blamedtens-thousands-deaths/

C-06, page 15 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Center for Biological Diversity. 2016. 

FDA to start testing Monsanto’s 

glyphosate in food. Reader Supported 

News (RSN).

http://readersupportednews.org/newssection2/318-66/35283-fda-to-starttesting-monsantos-glyphosate-in-food

C-06, page 14 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Center for Biological Diversity. 2016. 

Lawsuit targets EPA’s failure to release 

public records on toxic herbicide.

http://www.biologicaldiversity.org/news/

press_releases/2016/enlist-duo-02-03-

2016.html

C-06, page 16 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Gale, R. and G. Null. 2015. Monsanto’s 

sealed documents reveal the truth 

behind Roundup’s toxicological 

C-06, page 19 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.
FEIS Appendix D – Public Comment Report Magone Project

123

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

dangers. Organic Consumers 

Association.

https://www.organicconsumers.org/new

s/monsantos-sealed-documentsreveal-truth-behind-roundupstoxicological-dangers

Gillam, C. 2016. The true inside story 

of how a college professor sells out to 

Monsanto. Alternet.

http://www.alternet.org/food/trueinside-story-how-college-professorsells-outmonsanto?akid=13934.303761.PFhZW&rd=1&src=newsletter1049885&t

=11

C-06, page 17 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Hanzai, E. 2016. The complete history 

of Monsanto, “the world’s most evil 

corporation.” Waking Times.

http://www.wakingtimes.com/2014/06/2

0/complete-history-monsanto-worldsevil-corporation/

C-06, page 14 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Heneghan, C. 2015. California EPA 

pushing to label glyphosate as 

carcinogenic. FoodDIVE.

http://www.fooddive.com/news/californi

a-epa-pushing-to-label-glyphosate-ascarcinogenic/405238/

C-06, page 15 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.

Samsel, A. and S. Seneff. 2013. 

Glyphosate’s suppression of 

cytochrome P450 enzymes and amino 

acid biosynthesis by the gut 

microbiome: pathways to modern 

diseases. Entropy 15(4): 1416-1463.

http://www.mdpi.com/1099-

4300/15/4/1416

C-06, page 17 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project. 

Why Don’t You Try This News. 2016. 

USDA forces Whole Foods to accept 

Monsanto. Reader Supported News 

(RSN).

C-06, page 18 Not 

applicable

This is not scientific peer reviewed literature. In addition, invasive plant 

treatments are not proposed as part of this project.
FEIS Appendix D – Public Comment Report Magone Project

124

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://readersupportednews.org/opinion

2/265-34/34968-usda-forces-wholefoods-to-accept-monsanto

Table D-18. Consideration of science/literature submitted during the 45-day comment period related to roadless areas

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Northup, J. 1999. Public wants more 

wilderness, less logging on Green 

Mountain NF. Press Release by Forest 

Watch, a Vermont-based 

environmental organization.

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

?id=10

C-06, Opposing Views 

Attachment #1, page 26

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.

Power, T.M. 2000. The economic 

impact of preserving Washington’s 

roadless national forests.

http://www.kettlerange.org/power/powe

rreport.htm

C-06, page 46 Limited 

applicability

This document reports the results of a study evaluating the likely 

economic impacts of protecting inventoried roadless areas (IRAs) from 

logging and other activities in national forests located in Washington. 

The study found that formerly timber-dependent communities in 

Washington would benefit economically if IRAs were to be protected 

from timber harvesting and new road building. This document is not 

scientific, peer-reviewed literature.

The Magone Project does not propose any new road construction in 

IRAs and proposes thinning under alternatives 2 and 3 to enhance two 

of the nine roadless characteristic in the Nipple Butte IRA. The impacts 

to the Nipple Butte IRA are analyzed in the Magone FEIS chapter 3.

Table D-19. Consideration of science/literature submitted during the 45-day comment period related to climate change

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Schoennagel, T., T.T. Veblen, and 

W.H. Rommie. 2004. The interaction of 

fire, fuels, and climate across Rocky 

Mountain forests. Bioscience 54(7): 

661-676.

http://www.colorado.edu/geography/co

urses/geog_4371_f05/readings/schoen

agel_et_al_2004.pdf

C-06, Opposing Views 

Attachment #3, page 21

Provides 

background 

information; 

supports 

analysis

This paper discusses the influence of fuels and climate on the severity 

of wildfires across the Rocky Mountains and seeks to understand the 

potential effectiveness of fuel reduction across a range of major forest 

types. Overall, their analysis reveals that fire regimes, climate, fuel type 

and abundance, and stand structure vary significantly and require 

different approaches to restoration and wildfire management. With fire 

suppression, the author’s note, young fire-intolerant trees can establish 

and these denser stands provide “ladder” fuels that carry fire into 

continuous canopy fuels, promoting large, catastrophic fires. The 
FEIS Appendix D – Public Comment Report Magone Project

125

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

author’s assert that this system presents a strong case for thinning to 

reduce the fire hazard and to restore historical stand structure. 

In the Magone project planning area it would be both ecologically 

appropriate and operationally possible to restore a low-severity fire 

regime through thinning and prescribed burning. Historically, fire was 

the dominant natural process in the Blue Mountain ecoregion. It will 

occur eventually as high- or low-severity fire, depending on the 

condition of the forest, and the environmental conditions at the time of 

the fire. Low-severity fires produce multiple benefits to the ecosystem, 

produce less smoke than high severity fire in forested ecosystems, and 

retain more carbon.

Westerling, A. 2006. Does global 

warming increase forest fires? NPR, 

Talk of the Nation, July 7.

http://www.npr.org/templates/story/stor

y.php?storyId=5541423

C-06, Opposing Views 

Attachment #3, page 24

Supports the 

purpose and 

need of this 

project

National Public Radio interview with A. Westerling regarding research 

published in the journal Science saying that global warming may be 

causing more intense wildfires in the western United States. The 

researchers found that increases in large wildfire activity in the western 

United States over the past 25 years is “strongly associated with 

increased spring and summer temperatures and an earlier spring 

snowmelt.” As a result, the forest dries out more than usual, and it is 

dry for longer so there are more opportunities for a fire to ignite and 

spread. Westerling proposed mitigation efforts that better manage 

vegetation (via thinning), and ecological restoration of forests that have 

been changed by past management efforts (fire suppression): “In some 

places forests were quite open and they became much thicker over 

time. And that has certainly increased the severity of fires, and perhaps 

also the frequency of fires in some locations.” This document is not 

scientific, peer-reviewed literature.

Historically, fire was the dominant natural process in the Blue Mountain 

ecoregion. It will occur eventually as high- or low-severity fire, 

depending on the condition of the forest, and the environmental 

conditions at the time of the fire. This project would modify the fuels 

complex in the planning area by reducing tree densities and removing 

shade tolerant, fire susceptible trees that contribute to high severity 

fires.

Wuerthner, G. 2007. The climate 

factor— forest thinning won’t deter the 

coming large fires. Eugene Weekly. 

December 6.

http://www.eugeneweekly.com/2007/12

/06/views3.html

C-06, Opposing Views 

Attachment #3, page 25

Not 

applicable

This opinion piece from the Eugene Daily discusses climate and fuels 

treatment contends that thinning may work to slow or reduce tree 

mortality under low and moderate fire conditions; however, thinning 

does not stop the largest blazes that occur under severe fire conditions. 

The author suggests that thinning can increase wildfire spread and 

severity by opening the forest to greater wind and solar penetration, 

drying fuels faster than in unlogged forests. This document is not 

scientific, peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

126

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

The Magone project proposes fuel treatments to restore a low-severity 

fire regime to the planning area that would lessen the effects of wildfire. 

Historically, fire was the dominant natural process in the Blue Mountain 

ecoregion. It will occur eventually as high- or low-severity fire, 

depending on the condition of the forest, and the environmental 

conditions at the time of the fire. Low-severity fires produce multiple 

benefits to the ecosystem, produce less smoke than high severity fire in 

forested ecosystems, and retain more carbon.

Table D-20. Consideration of science/literature submitted during the 45-day comment period related to the National Environmental Policy Act

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

National Forest System Land and 

Resource Management Planning; Use 

of Best Available Science in 

Implementing Land Management 

Plans. Federal Register Vol. 69, No. 

188, September 29, 2004, pp. 58055-

58057.

https://www.gpo.gov/fdsys/pkg/FR2004-09-29/pdf/04-21844.pdf

C-06, page 54 Applicable The science used by the Magone Project interdisciplinary team and the 

scientific methodologies used in the analysis are disclosed in the 

Magone FEIS chapter 3 and the specialist reports. The analysis relies

on site-specific studies and literature to support the proposed project.

USDA Forest Service. 2006. Bald 

Angel Vegetation Management Project 

Environmental Assessment. USDA 

Forest Service, Wallowa-Whitman 

National Forest, La Grande Ranger 

District.

https://scholarsbank.uoregon.edu/xmlui

/bitstream/handle/1794/6608/Wallowa_

Whitman_Bald_Angel_Vegetation_Man

agement_EA.pdf?sequence=1

C-06, Opposing Views 

Attachment #3, page 23

Not 

applicable

This document is an Environmental Assessment produced by another 

Forest Service unit in 2006. The analysis contained in this document 

applies to the Bald Angel Project and its corresponding planning area.

Table D-21. Consideration of science/literature submitted during the 45-day comment period related to socioeconomics

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Cortner, H, and M.A. Moote. 1999. The 

politics of ecosystem management. 

Island Press.

C-06, pages 58-59 and 

61

Limited 

applicability

This book focuses on the political challenges in ecosystem 

management, with chapters looking at politics and natural resources, 

the evolution of ecosystem management, policy challenges, 
FEIS Appendix D – Public Comment Report Magone Project

127

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

collaborative stewardship, effective governmental policies and 

structures, and the future of ecosystem management.

The Magone Project follows current law, regulation, and policy.

http://illinois.sierraclub.org/piasapalisad

es/factshee.htm

C-06, page 47 Link provided by commenter is broken, unable to locate reference.

McHugh, P. 1998. Economic impacts 

of trails: forest recreation’s growing 

impact. National Trails Training 

Partnership website.

http://www.americantrails.org/resource

s/economics/EconForestRec.html

C-06, page 47 Some 

applicability

This document is a website article, discussing current recreation trends 

on national forests. It is not peer-reviewed scientific literature.

Niemi, E. and A. Fifield. 2000. Seeing 

forests for their green: economic 

benefits of forest protection, recreation, 

and restoration. Prepared for: Sierra 

Club.

http://www.econw.com/media/ap_files/

FR2-Seeing-Forests-ForGreen_ECONorthwest.pdf

C-06, page 46 Some 

applicability

This document discusses the impacts of commercial logging, and the 

benefits of recreation, fish and wildlife, water, carbon sequestration, 

and unroaded areas.

The Magone Project would implement many of the recommendations 

for restoration made in the document: preserving and protecting 

existing aquatic resources, restoring ecological integrity, restoring 

natural functions, working within the watershed context, etc.

Niemi, E. and J. Kober. 2014. Logging 

expansion won’t help rural 

communities: guest opinion. The 

Oregonian.

http://www.oregonlive.com/opinion/inde

x.ssf/2014/06/logging_expansion_wont

_help_ru.html

C-06, page 47 Not 

applicable

Article submitted is an opinion piece in a newspaper, not peer-reviewed 

scientific literature.

Noble, I.R. and R. Dirzo. 1997. Forests 

as human-dominated ecosystems. 

Science. 277(5325): 522-525.

http://www.sciencemag.org/content/27

7/5325/522.abstract?maxtoshow=&HIT

S=10&hits=10&RESULTFORMAT=&ful

ltext=logging&searchid=113665990731

0_5043&FIRSTINDEX=0&journalcode

=sci

C-06, Opposing Views 

Attachment #1, page 25

Limited 

applicability

This article discusses the change in and loss of forested acres on a 

world-wide scale, different types of forest management practices, and 

the use of sustainable forestry.

The Magone FEIS analyzes and discloses direct, indirect, cumulative, 

adverse, and beneficial effects of the proposed action on a variety of 

resources, including diversity. This project is consistent with current and 

applicable law, regulation, and policy.

Rudzitis, G. 1999. Amenities 

increasingly draw people to the rural 

C-06, Opposing Views 

Attachment #1, page 31

Not relevant 

to this project

The paper discusses findings from survey research that assess why 

people move from counties throughout the American west and 

specifically the northwest. With respect to federal land management, 

most surveyed favored protection strategies, with an emphasis on good 
FEIS Appendix D – Public Comment Report Magone Project

128

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

west. Rural Development Perspectives 

14(2): 9-13.

stewardship; and commodity production allowed on federals lands that 

are not degraded.

The research does not provide site-specific analysis pertinent to the 

Magone Project. This project is consistent with current law, regulation, 

and policy.

Shields, D.J., I.M. Martin, W.E. Martin, 

and M.A. Haefele. 2002. Survey results 

of the American public’s values, 

objectives, beliefs, and attitudes 

regarding forests and grasslands: a 

technical document supporting the 

2000 USDA Forest Service RPA 

Assessment. General Technical Report 

RMRS GTR-95. Fort Collins, CO: U.S. 

Department of Agriculture, Forest 

Service, Rocky Mountain Research 

Station. 111 p.

http://www.treesearch.fs.fed.us/pubs/4

817

C-06, pages 39-42 Somewhat 

relevant

This document reports the results of a survey asking members of the 

American public about their values and objectives for public lands, and 

the role the agency should play in fulfilling those objectives. These 

findings were included in the 2000 Strategic Plan for the Forest Service.

The most recent USDA Forest Service Strategic Plan was published in 

2015. The Magone Project is consistent with current law, regulation, 

and policy.

Vincent, J.W., D.A. Hagen, P.G. Welle, 

and K. Swanser. 1995. Passive-use 

values of public forestlands: a survey 

of the literature. A study conducted on 

behalf of the U.S. Forest Service.

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

pdf

C-06, Opposing Views 

Attachment #1, page 37

Not relevant 

to this project

The article cited is an opinion paper offering review and comment 

regarding the state of economic research pertaining to the nonuse or 

passive values of forests. The article addresses the implication of the 

many studies relating to the management of public forestlands in the 

Columbia River Basin in particular and forests of the Pacific Northwest. 

This article illustrates that timber harvesting, for example, produces 

economic goods primarily in the form of wood products. On the other 

hand, forestlands are managed for recreation opportunities, watershed 

protection, and biodiversity, and these goods provide values, which can 

be characterized as passive-use values. The article identifies valuation 

methods for estimating the economic value of environmental goods. 

The article reviews four studies that attempt to estimate the total value 

derived from both use and passive-use values and identifies the 

strengths and weaknesses of each study. The article concludes that 

economic research should not ignore passive use values and by 

ignoring these values future studies may seriously understate the 

benefits associated with the preservation of wilderness areas, wildlife, 

old forests, and other goods associated with preservation. In the 

absence of this information, the only conclusions that one is able to 

reach would be very general in nature.

This article is not relevant to the Magone Project because it simply 

offers opinion regarding the development of future economic studies 
FEIS Appendix D – Public Comment Report Magone Project

129

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

and that the methodological estimations used in future studies should 

not ignore the importance of passive-use values.

Table D-22. Consideration of science/literature submitted during the 45-day comment period related to miscellaneous topics

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

16 U.S. C. § 1851: US Code – Section 

1851: National standards for fishery 

conservation and management.

http://codes.lp.findlaw.com/uscode/16/

38/IV/1851

C-06, page 41 Applicable Conservation measures and best management practices (BMPs) are 

included within the Magone FEIS Appendix C – Project Design Criteria.

These are based on the best available science

Dr. Ann Bartuska, Deputy Chief for 

Research and Development, USDA 

Forest Service Excerpt from testimony 

before the House Resources Forest 

and Forest Health Subcommittee July 

15, 2004

http://www.fs.fed.us/congress/108/hous

e/oversight/bartuska/071504.html

C-06, Opposing Views 

Attachment #15, page 1

Not 

applicable

This is a transcript of testimony provided during a hearing before the 

House Committee on Natural Resources; Forest and Forest Health 

Subcommittee in 2004. The statement focused on restoring forests after 

catastrophic events. It contains no sources, references, or literature 

cited and is not scientific, peer-reviewed literature.

Behan. R.W. 2001. Plundered 

Promise: Capitalism, Politics, and the 

Fate of the Federal Lands.

http://www.rockisland.com/~rwbehan/

C-06, page 61 Not 

applicable

The topic of this book is federal lands management in the American 

West. The author describes the historical development of management 

regimes and institutions that in his view favor narrow corporate interests 

at the expense of the public good. Author refers to the sustained yield 

approach to land management practiced by federal resource agencies 

after World War II; specifically the conversion of complex biological 

systems (old-growth forests) into simplified timber plantations. It is not 

scientific, peer-reviewed literature.

Bosworth, D.N. 2001. Dale N. 

Bosworth Chief USDA Forest Service 

Excerpt from a speech on Sustainable 

Management of the National Forests, 

at the Andrus Center for Public Policy, 

Boise State University December 12, 

2001

http://www.andruscenter.org/images/tra

nscripts/Sustainable_transcript.pdf

C-06, Opposing Views 

Attachment #15, page 2

Not 

considered

Link provided by commenter is broken, unable to locate reference.

Bosworth, D. 2004. Dale Bosworth 

Chief, USDA Forest Service Excerpt 

from a statement before the Committee 

C-06, Opposing Views 

Attachment #15, page 2

Not 

applicable

This is a transcript of testimony provided during a hearing before the 

Committee on Appropriations Interior and Related Agencies 

Subcommittee on the Fiscal Year 2015 budget. It contains no sources, 
FEIS Appendix D – Public Comment Report Magone Project

130

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

on Energy and Natural Resources 

United States Senate March 3, 2004

http://www.pirate4x4.com/forum/landuse-issues/232684-statement-dale-nbosworthchief-usda-forest-service.html

references, or literature cited and is not scientific, peer-reviewed 

literature.

Bravo, Aguirre Celedonio and Carlos 

Rodriguez Franco, compilers 1999. 

North American Science Symposium: 

Toward a Unified Framework for 

Inventorying and Monitoring Forest 

Ecosystem Resources. Guadalajara, 

Mexico (November 2-6, 1998). 

Proceedings RMRS-P-12. U.S. 

Department of Agriculture, Forest 

Service, Rocky Mountain Research 

Station

http://cwt33.ecology.uga.edu/publicatio

ns/pubs_martha_new_01282003/Batch

_2_@300dpi/PDF/1389.pdf

C-06, Opposing Views 

Attachment #15, page 7

Not 

applicable

This symposium proceedings of a symposium focused on 

improvements to inventorying and monitoring ecosystem resources. 

The specific manuscript provided by the commenter related to tropical 

deciduous and temperate deciduous watershed ecosystems, which are 

very different than those found in the Magone project planning area.

Britneff, A. 1997. RPForum. C-06, page 59 Not 

considered

Citation information was inadequate and source could not be located. 

Unable to speculate on relevance to the Magone Project.

Brown, Joel “Power to the People!” 

SRM Rangeland News, November 

2007

http://www.rangelands.org/RN/Nov.RN

07.pdf

C-06, Opposing Views 

Attachment #15, page 3

Not 

applicable

This is a Society for Range Management newsletter, and is not 

scientific peer-reviewed literature.

Boutillier, L. In: Canadian Forest 

Policy.

Wilson, J. In: Canadian Forest Policy.

C-06, pages 65, 66, 67, 

and 69

Not 

applicable

Unable to locate reference based on citation provided.

Cashore, B. 2001. Timber Pricing in 

British Columbia: Change as a 

Function of Stability [Chapter 7]. In: In 

Search of Sustainability: British 

Columbia Forest Policy in the 1990s.

http://www.ubcpress.com/search/title_b

ook.asp?BookID=1864

C-06, page 62 Not 

applicable

In this book, a group of political scientists examined the effects of forest 

policy initiatives launched by British Columbia’s government in the 

1990s to reduce conflict between environmentalists and the forest 

industry. The authors conclude that the government’s forest policy 

initiatives (search for sustainability) ultimately failed. Commenter 

focused on the book’s reference to the sustained yield paradigm 

established after World War II and how it set British Columbia on a path 

that continues to be costly and disruptive to reverse. The Magone 

Project follows current law, regulation and policy.
FEIS Appendix D – Public Comment Report Magone Project

131

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

CENTER FOR BIOLOGICAL 

DIVERSITY v. UNITED STATES 

FOREST SERVICE Argued and 

Submitted July 15, 2003. -- November 

18, 2003 Before: KLEINFELD, 

WARDLAW, Circuit Judges, and 

POGUE, Judge. In the United States 

Court of Appeals,Ninth Circuit

http://caselaw.findlaw.com/us-9thcircuit/1173711.html

C-06, Opposing Views 

Attachment #15, page 8

Some 

applicability

This is a court opinion related to disclosing opposing scientific 

viewpoints.

The regulation at 40 CFR 1502.9(b), 1502.22, and 1502.24 gives 

direction regarding use of best available science. What constitutes best 

available science might vary over time and across scientific disciplines. 

As a general matter, the Forest Service shows consideration of the best 

available science when it insures the scientific integrity of the 

discussions and analyses in the project NEPA document. Specifically, 

the NEPA document should identify methods used, reference scientific 

sources relied on, discuss responsible opposing views, and disclose 

incomplete or unavailable information. The methods used can be found 

within each resource section in the Magone FEIS chapter 3. 

References are cited throughout the Magone FEIS and a References 

Cited section is provided at the end of the FEIS.

Clayoquot Sound Scientific Panel. C-06, page 60 Not 

considered

Unable to locate reference based on information provided.

Collins, S. 2004. Sally Collins 

Associate Chief USDA Forest Service 

Excerpt from a speech to the Land 

Trust Alliance Rally “Protecting Open 

Spaces: Partners in a Common Cause” 

October 31, 2004

http://www.fs.fed.us/news/2004/speech

es/10/open-spaces.shtml

C-06, Opposing Views 

Attachment #15, page 3

Not 

applicable

This is a transcript of a speech and is not scientific peer-reviewed 

literature.

Collins, S. 2005. Forest Service 

Associate Chief speech: The future of 

partnering with the Forest Service. 

Meeting of the National Association of 

Conservation Districts. Atlanta, GA.

http://www.fs.fed.us/spf/coop/library/NA

CDspeech.pdf

C-06, page 3 Not 

applicable

This is a speech. It is not specific to any laws, regulations, or policies 

that would be pertinent to the Magone Project analysis.

Collins, S. 2006. Sally Collins 

Associate Chief USDA Forest Service 

Excerpt from testimony before the 

Committee on Energy and Natural 

Resources, United States Senate July 

11, 2006

http://www.fs.fed.us/congress/109/sena

te/oversight/collins/071106.html

C-06, Opposing Views 

Attachment #15, page 2

Not 

applicable

This is an excerpt of testimony before the Committee on Energy and 

Natural Resources, it is not scientific peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

132

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Committee of Scientists Third Draft 

Preliminary Report, July 98

C-06, pages 66 and 68 Not 

considered

Unable to locate reference based on citation provided.

Cushman, Jr., J.H. 1999. Audit faults 

Forest Service on logging damage in 

U.S. Forests. New York, NY: The New 

York Times.

http://www.nytimes.com/1999/02/05/us/

audit-faults-forest-service-on-loggingdamage-in-us-forests.html

C-06, page 2 Not 

applicable

This is a newspaper article reporting on an inspector general’s report, 

and is not scientific peer-reviewed literature.

Diaz-Soltero, H. 2000. Excerpts from 

an interview with Hilda Diaz-Soltero 

Associate Chief for Natural Resources, 

USDA Forest Service Women in 

Natural Resources, Vol. 21, No. 3 

August 2000

http://www.fs.fed.us/publications/2000/

00nov02-Hilda-Diaz-SolteroInterview.pdf

C-06, Opposing Views 

Attachment #15, page 1

Not 

considered

Unable to locate document using citation provided.

Dombeck, M. 1998. Statement by Chief 

Dr. Mike Dombeck. “Forest Chief Shifts 

focus to clean water” April 1998 

TRANSITIONS

http://www.waterplanet.ws/transitions/tr

9804/

C-06, Opposing Views 

Attachment #15, page 4

Not 

applicable

This is an article on a website, it is not scientific peer-reviewed 

literature.

Dombeck, M. 2006. Statements by 

retired Chief Dr. Mike Dombeck. 

“Politics vs. Science,” October 19, 

2006. Published by the University of 

Wisconsin, Board of Regents.

http://whyfiles.org/247sci_politics/index

.php?g=5.txt

C-06, Opposing Views 

Attachment #15, page 6

Not 

applicable

This is an article on a website, it is not scientific peer-reviewed 

literature.

Ford, D. Certified Forest Products 

Council in Wrong Focus of Resource 

Management

C-06, page 69 Not 

considered

Unable to locate reference based on citation provided.

Franklin, J.F. 1997. Commentary on 

Gordon Baskerville's Perspective. 

Conservation Ecology [online] 1(1): 10.

C-06, page 63 Supports 

analysis

The author of this commentary asserts that we do not know nearly as 

much about forest ecosystems as we, and especially foresters, thought 

we did. Consequently, traditional forestry approaches based on a very 

simple view of a forest have proven inadequate. This article discusses 

how scientists are learning how to synthesize and present relevant 
FEIS Appendix D – Public Comment Report Magone Project

133

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

http://www.consecol.org/vol1/iss1/art10

/

scientific information for resource managers, decision makers, and the 

involved public.

Gale, F. 1999. In: The Wealth of 

Forests: Markets, Regulations, and 

Sustainable Forestry.

C-06, page 69 Limited 

applicability

This book, written by Canadian forest policy scholars, provides analysis 

of the potential and limits of market, regulatory, and other policy 

instruments as means of achieving sustainability. The book was 

published during a period of change—moving from sustained yield 

policies and practices to implementing sustainable forestry. The text 

refers to significant changes taking place in the forestry curricula in 

many Canadian schools during the 1990s. Book primarily relates to 

Canadian forestry practices and policies.

Glickman, D. 1999. Agriculture 

Secretary Dan Glickman. From an 

Announcement of Interim Ban on 

Forest Road Construction. 

Washington, D.C., February 11, 1999.

http://www.ibiblio.org/london/permacult

ure/permaculture-list-archives-1999-

2002/msg04621.html

C-06, Opposing Views 

Attachment #15, page 5

Not 

applicable

This references an interim 18-month moratorium (from 1999) on 

building new forest roads. The Magone Project follows current law, 

regulation and policy and does not proposed building any new 

permanent roads.

Gordon, J. Yale University C-06, pages 62 and 64-

65

Not 

considered

Unable to locate reference based on information provided.

Haley, D. and M. Luckert. Managing 

Natural Resources in BC.

C-06, page 64 Not 

considered

Unable to locate reference based on citation provided.

Hirt, P. 1999. Institutional Failure in the 

U.S. Forest Service: A Historical 

Perspective. Research in Social 

Problems and Public Policy 7: 217-39.

C-06, pages 66-67 Not 

considered

Unable to locate reference.

Holling, C.S. 2000. Theories for 

sustainable futures. Conservation 

Ecology 4(2): 7.

http://www.consecol.org/vol4/iss2/art7/

C-06, page 59 Not 

applicable

This editorial discusses theories of sustainable development and 

management of global and regional resources. It is not scientific, peerreviewed literature.

Kessler, W. and H. Salwasser. 1995. 

Natural Resource Agencies: 

Transforming from Within [Chapter 10]. 

In: A New Century for Natural 

Resources Management.

http://books.google.com/books/about/A

_New_Century_for_Natural_Resources

_Mana.html?id=jEs_wnv2Go4C

C-06, page 65 Not 

applicable

This book explores changes in natural resources management and 

analyzes the forces that are propelling change. The authors discuss 

how the Forest Service approach to multiple-use management has not 

remained static, and how it is now recognized that ecosystem health 

must be a conscious and deliberate goal for multiple-use management. 

The Magone Project follows current law, regulation, and policy.
FEIS Appendix D – Public Comment Report Magone Project

134

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Kohm, K.A.; Franklin, J.F. 1997. 

Creating a Forestry for the 21st 

Century: The Science of Ecosystem 

Management. Island Press. 475 p.

Marcot, B.G. 1997. Biodiversity of Old 

Forests of the West: A lesson from Our 

Elders [Chapter 6]. In: Creating a 

Forestry for the 21st Century: The 

Science of Ecosystem Management.

Behan, R.W. 1997. Scarcity, Simplicity, 

Separatism, Science—and Systems 

[Chapter 26]. In: Creating a Forestry for 

the 21st Century: The Science of 

Ecosystem Management.

C-06, pages 61-62, 64, 

and 65

Consistent 

with project

This book combines the work of many natural resource scientists and 

presents a comprehensive view of ecosystem management – a concept 

for dealing with larger spatial scales, longer timeframes, and many 

more variables (ecological, economic, and social) than were commonly 

considered in past management approaches. The authors attempt to 

move the concept of forest ecosystem management into an operational 

context; this involves understanding and managing complexity, 

providing a wide range of ecological goods and services, and managing 

across broad landscapes. Commenter quotes short sections of text 

from different chapters in this book.

The Magone Project was developed by an interdisciplinary team 

charged with gathering information at a watershed scale, and using that 

information to develop a suite of activities to improve the resource 

resiliency, processes, and functions of the project planning area. The 

team brought forward silvicultural and fuels treatments, aquatic 

restoration activities, wildlife habitat improvements, recreation 

opportunity improvements, and road activities as potential actions that 

would move the planning area towards its desired future condition.

Leopold, A. 1949. A Sand County 

almanac: and sketches here and there. 

Oxford University Press.

C-06, pages 67-68 Consistent 

with analysis

A collection of essays that advocate Leopold’s idea of a “land ethic,” or 

a responsible relationship existing between people and the land they 

inhabit. Leopold viewed forestry as fundamentally different from 

agronomy because it employs natural species, and manages a natural 

environment rather than creating an artificial one. The author refers to a 

whole series of secondary forest functions: wildlife, recreation, 

watersheds, and wilderness areas.

Lowbagger.org. 2006. Conservation 

groups look to hold Forest Service 

accountable for Middle East Fork 

logging plan. April 25.

http://www.lowbagger.org/mideast.html

C-06, Opposing Views 

Attachment #1, page 53

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.

Maser, C. 1988. The Redesigned 

Forest.

http://www.chrismaser.com/bk-rdf.htm

C-06, page 61 Not 

applicable

The main theme of this book is the author’s belief that young-growth 

forests are not sustainable under current management practices. It is 

not scientific, peer-reviewed literature.

Melle, A.R. 2001. “The U.S. Forest 

Service Approach to Forest Law 

Enforcement.” A presentation to the 

East Asia Ministerial Conference, 

September 12, 2001. Ms. Melle is the 

C-06, Opposing Views 

Attachment #15, page 6

Not 

applicable

This is a 2001 presentation on the U.S. Forest Service approach to law 

enforcement in Indonesia. It is not scientific, peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

135

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Asst. Director of Law Enforcement and 

Investigations, USDS Forest Service

http://www.for.gov.bc.ca/hfd/library/doc

uments/bib49682.pdf

Nappier, S. 2002. Lost in the forest: 

how the Forest Service’s misdirection, 

mismanagement, and mischief 

squanders your tax dollars. Taxpayers 

for Common Sense.

http://www.ourforests.org/fact/lostinthef

orest.pdf

C-06, Opposing Views 

Attachment #1, page 25

Unable to 

locate 

reference

The website link provided does not work. Unable to locate reference.

Noss, R.F. 1993. Sustainable Forestry 

or Sustainable Forest? [Chapter 1]. In:

Defining Sustainable Forestry.

Rivlin, A.M. 1993. Values, Institutions, 

and Sustainable Forestry [Chapter 10]. 

In: Defining Sustainable Forestry.

Available online: 

http://islandpress.org/definingsustainable-forestry

C-06, pages 62 and 64 Consistent 

with project

Chapters from a book that presents the results of a national conference 

convened by The Wilderness Society, American Forests, and the World 

Resources Institute to help establish a common framework/definition of 

“sustainable forestry” based on an ecosystem approach. The authors 

assert the aim of silviculture is the “continuous production of wood,” and 

proposes forest management techniques that give “less weight to wood 

production and more to other values.”

The Magone Project silviculture treatments are proposed to “Restore 

forest structure, composition, and density toward more resistant and 

resilient vegetative conditions given the historic fire regime.” These 

treatments are not designed to maximize wood production, but to 

develop and maintain old growth structure, increase resiliency, shift 

species composition, decrease density, provide wood for placement 

into streams, maintain meadow environments, provide wildlife habitat, 

and restore fire back onto the landscape.

O’Neill, Kahn, and Russell C-06, page 62 Not 

considered

Unable to locate reference based on citation provided.

Potyondy, J.P. 2007 “The Evolution of 

Channel Maintenance Science in the 

Forest Service.” Mr. Potyondy is the 

WO Watershed, Fish, Wildlife, Air, and 

Rare Plants Staff.

http://www.stream.fs.fed.us/afsc/pdfs/P

otyondy.pdf

C-06, Opposing Views 

Attachment #15, page 6

Some 

applicability

This is in regards to establishment of the USDA Forest Service Stream 

Systems Technology center in 1992 (Potyondy 2007, page 140). This 

paper provides a chronological history of the USFS development of 

channel maintenance and instream flow hydrography. It highlights the 

use of best available science and how science by nature is dynamic 

and continually expanding in its understanding of stream channels and 

the USFS must adapt as science changes (best available science). 

Even as recent as 2014 channel evolution and maintenance in the 

discipline of geomorphology has seen significant shifts in thinking. Best 

available science in regards to channel maintenance and evolution was 

used for the Magone Project stream evaluation:

http://onlinelibrary.wiley.com/doi/10.1002/rra.2631/abstract
FEIS Appendix D – Public Comment Report Magone Project

136

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Presidential documents: Improving 

regulation and regulatory review. 

Executive Order 13563. Federal 

Register Vol. 76, No. 14, January 21, 

2011, pp. 3821-3823.

C-06, page 41 Applicable This is an executive order pertaining to improving regulation and 

regulatory review. The Magone Project follows current regulations.

Rayner, J. 1996. Implementing 

Sustainability in West Coast Forests: 

CORE and FEMAT as Experiments in 

Process. Journal of Canadian Studies 

31(1): 82-101.

http://public.wsu.edu/~susdev/Rayner9

6.html

C-06, page 62 Limited 

applicability

This article compares two attempts to introduce a new ecosystemmanagement paradigm (in place of the sustained-yield paradigm). It is 

based on the work of the Forest Ecosystem Management Assessment 

Team (FEMAT) in the “spotted owl forests” of the Pacific Northwest and 

the Commission on Resources and Environment (CORE) in British 

Columbia. The article is focused on the temperate coniferous forest that 

runs from Alaska to northern California.

The Magone Project follows current law, regulation, and science 

relevant to the project planning area.

Robertson, D. Chief F. Dale Robertson. 

From FIVE YEAFt REVIEW - B-3 # #

http://www.fs.usda.gov/Internet/FSE_D

OCUMENTS/fsbdev3_053856.pdf

C-06, Opposing Views 

Attachment #15, page 4

Not 

applicable

This document from 1993 is a 5-year review of the Lolo National Forest 

Plan, which does not apply to the Malheur National Forest.

Scott, J.C. 1998. Seeing like a State: 

how certain schemes to improve the 

human condition have failed. Yale 

University Press.

http://yalepress.yale.edu/book.asp?isb

n=9780300078152

C-06, page 59 Not 

applicable

The author of this book analyzes failed cases of large-scale 

authoritarian plans in a variety of fields. No apparent connection to the 

Magone Project.

Shlisky, A. Journal of Forestry. C-06, page 63 Not used Unable to locate reference based on citation provided.

Sierra Forest Legacy. 2012. Logging 

impacts.

http://www.sierraforestlegacy.org/FC_F

ireForestEcology/FFE_LoggingImpacts

.php

C-06, Opposing Views 

Attachment #1, page 55

Not 

applicable

This website article pertains to logging impacts in the Sierra Nevada. It 

is not scientific, peer-reviewed literature.

Smith, T. 1996. “Chief's Ecosystem 

Stewardship Conference Workshop 

Review” Eco-Watch, February 26, 

1996.

http://www.fs.fed.us/eco/ecowatch/ew960226.htm

C-06, Opposing Views 

Attachment #15, page 5

Not used Unable to locate document based on reference provided.
FEIS Appendix D – Public Comment Report Magone Project

137

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Tabish, D. 2014. Judge halts Glacier 

Loon timber sale in Swan Valley.

Flathead Beacon, September 26, 2014.

http://flatheadbeacon.com/2014/09/26/j

udge-halts-glacier-loon-timber-saleswan-valley/

C-06, Opposing Views 

Attachment #1, page 58

Not used This is a newspaper article, not scientific peer-reviewed literature.

The White House. 2009. Memorandum 

for the heads of executive departments 

and agencies, subject: scientific 

integrity.

https://www.whitehouse.gov/the-pressoffice/memorandum-heads-executivedepartments-and-agencies-3-9-09

C-06, page 41 Applicable This is a memorandum on scientific integrity from the White House.

As a general matter, the Forest Service shows consideration of the best 

available science when it insures the scientific integrity of the 

discussions and analyses in the project NEPA document. Specifically,

the NEPA document should identify methods used, reference scientific 

sources relied on, discuss responsible opposing views, and disclose 

incomplete or unavailable information. The methods used can be found 

within each resource section in the Magone FEIS chapter 3. 

References are cited throughout the Magone FEIS and a References 

Cited section is provided at the end of the FEIS.

Thompson, D. 2004. Judge blocks 

Klamath logging plan. Environmental 

Protection Information Center, October 

16, 2004.

http://www.wildcalifornia.org/media/epi

c-in-the-news/judge-blocks-klamathlogging-plan/

C-06, Opposing Views 

Attachment #1, page 59

Not used This is a website article not scientific peer-reviewed literature.

Tidwell, T. 2009. Statement by USFS 

Chief Tom Tidwell From an interview 

with Rob Chaney of the Missoulian, 

June 19, 2009.

http://westinstenv.org/sosf/2009/06/19/t

idwell-interviewed-by-the-missoulian/

C-06, Opposing Views 

Attachment #15, page 5

Not used Not able to locate document based on the reference provided; the link 

is broken.

Union of Concerned Scientists C-06, page 58 Not used Unable to locate reference based on information provided.

University of California, SNEP science 

team and special consultants. 1996. 

Sierra Nevada Ecosystem Project: final 

report to Congress. Volume 1, chapter 

4 – Fire and Fuels.

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

/v1_ch04.pdf

C-06, page 37; C-06, 

Opposing Views 

Attachment #1, page 

36; C-06, Opposing 

Views Attachment #3, 

page 23

Not 

applicable

Book describes the status of the late-successional forests, key 

watersheds, and significant natural areas on federal lands in the Sierra 

Nevada ecoregion. The Magone project planning area is not located in 

this region of the country.
FEIS Appendix D – Public Comment Report Magone Project

138

Literature cited by commenters Source How 

considered?

Forest Service rationale/comments

Valetkevitch, H. 2004. Statement by 

Heidi Valetkevitch National Media 

Officer USDA Forest Service to Joe 

Bauman, reporter for the Deseret 

Morning News December 24, 2004

http://www.deseretnews.com/article/60

0100084/New-forest-rules-focus-onholisticapproach.html

C-06, Opposing Views 

Attachment #15, page 3

Not used This is a website article not scientific peer-reviewed literature.

Volz, M. 2013. Judge stops 3 Montana 

logging projects of lynx habitat studies. 

Associated Press, June 26, 2013.

http://news.yahoo.com/judge-stops-3-

montana-logging-141919567.html

C-06, Opposing Views 

Attachment #1, page 58

Not used This is a website article not scientific peer-reviewed literature.

Walters, C., D. Ludwig, and R. Hilbor. C-06, page 67 Not 

considered

Unable to locate reference based on the citation provided.

Western Environmental Law Center. 

2012. Groups challenge industrial 

logging of pristine wildlife habitat along 

South Fork Flathead River. A Western 

Environmental Law Center Press 

Release.

http://www.westernlaw.org/article/group

s-challenge-industrial-logging-pristinewildlife-habitat-along-south-forkflathead-rive

C-06, Opposing Views 

Attachment #1, page 57

Not used This is a press release, not scientific peer-reviewed literature.

Wikipedia. 2015. Precautionary 

principle.

https://en.wikipedia.org/wiki/Precaution

ary_principle

C-06, pages 57-58 Not 

applicable

This is not scientific peer-reviewed literature

Wilder, Tegner, and Dayton C-06, page 67 Not used Unable to locate reference based on the citation provided.

Wilson, E.O. C-06, page 59 Not used Unable to locate reference based on the information provided.

World Resources 2000–2001. People 

and Ecosystems: The Fraying Web of 

Life. World Resources Institute.

http://www.wri.org/publication/worldresources-2000-2001

C-06, page 60 Not 

applicable

This report analyzes the value of goods and services provided by our 

ecosystems and their capacity to continue production. The report 

presents a comprehensive assessment of five of the world's major 

ecosystems: agroecosystems, forest ecosystems, coastal and marine 

ecosystems, freshwater systems, and grassland ecosystems. It is not 

scientific, peer-reviewed literature.
FEIS Appendix D – Public Comment Report Magone Project

139
FEIS Appendix D – Public Comment Report Magone Project

140

References Cited

Brown, R.T., J.K. Agee, and J.F. Franklin, 2004. Forest restoration and fire: principles in the context of 

place. Conservation Biology 18: 903–912.

Cram, D., T. Baker, and J. Boren. 2006. Wildland fire effects in silviculturally treated vs. untreated stands 

of New Mexico and Arizona. Research Paper RMRS-RP-55. Fort Collins, CO: U.S. Department 

of Agriculture, Forest Service, Rocky Mountain Research Station.

Franklin, J.F., and K.N. Johnson. 2012. A restoration framework for federal forests in the Pacific 

Northwest. Journal of Forestry 110(8): 429-439.

Franklin, J.F., K.N. Johnson, D.J. Churchill, K. Hagmann, D. Johnson, and J. Johnston. 2013. Restoration 

of dry forests in eastern Oregon: a field guide. The Nature Conservancy, Portland, OR.

Fulé, P.Z., T.W. Swetnam, P.M. Brown, D.A. Falk, D.L. Peterson, C.D. Allen, and R.E. Keane. 2014. 

Unsupported inferences of high‐severity fire in historical dry forests of the western United States: 

response to Williams and Baker. Global Ecology and Biogeography 23(7): 825-830.

Grant County Community Fire Protection Plan. 2005. Grant County, OR.

Hagmann, R.K., J.F. Franklin, and K.N. Johnson. 2014. Historical conditions in mixed-conifer forests on 

the eastern slopes of the northern Oregon Cascade Range, USA. Forest Ecology and Management 

330: 158-170.

Hagmann, R. K., J. F. Franklin, K. N. Johnson. 2013. Historical structure and composition of ponderosa 

pine and mixed-conifer forests in south-central Oregon. Forest Ecology and Management 

304:492-504.

Halpern, C. 1988. Early successional pathways and the resistance and resilience of forest communities. 

Ecology 69(6): 1703-1715. 

Hemstrom, M.A., J. Salwasser, J. Halofsky, J. Kagan, and C. Comfort. 2012. The integrated landscape 

assessment project. In: Proceedings of the First Landscape State-and-Transition Simulation 

Modeling Conference, Ed: Kerns B.K., A.J. Shlisky, and C.J. Daniel. Portland, OR: USDA Forest 

Service Pacific Northwest Research Station, General Technical Report PNW-869.

Hessburg, P.F., R.B. Salter, and K.M. James. 2007. Re-examining fire severity relations in premanagement era mixed conifer forests: Inferences from landscape patterns of forest structure. 

Landscape Ecology 22(1): 5-24.

Hessburg, P.F., J.K. Agee, and J.F. Franklin. 2005. Dry forests and wildland fires of the inland Northwest 

USA: contrasting the landscape ecology of the pre-settlement and modern eras. Forest Ecology 

and Management 211(1): 117-139.

Hessburg, P.F., and J.K. Agee, 2003. An environmental narrative of Inland Northwest United States 

forests, 1800–2000. Forest Ecology and Management 178: 23–59.

Heyerdahl, E., L.B. Brubaker, and J.K. Agee. 2001. Spatial controls of historical fire regimes: a multiscale 

example from the interior West, USA. Ecology 82(3): 660-678.
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Heyerdahl, E.K., R.A. Loehman, and D.A. Falk. 2014. Mixed-severity fire in lodgepole-dominated 

forests: Are historical regimes sustainable on Oregon's Pumice Plateau, USA? Canadian Journal 

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Heyerdahl, E.K., P. Morgan, and J.P. Riser. 2008. Multi-season climate synchronized historical fires in dry 

forests (1650-1900), northern Rockies, USA. Ecology 89(3): 705-716.

Kaufmann, P.R., R.M. Hughes, T.R. Whittier, S.A. Bryce, and S.G. Paulsen. 2014. Relevance of lake 

physical habitat indices to fish and riparian birds. Lake and Reservoir Management 30(2): 177-

191.

Kaufmann, P.R., D.V. Peck, S.G. Paulsen, C.W. Seeliger, R.M. Hughes, T.R. Whittier, and N.C. Kamman. 

Lakeshore and littoral physical habitat structure in a national lakes assessment. Lake and 

Reservoir Management 30(2): 192-215.

Merschel, A.G., T.A. Spies, and E.K. Heyerdahl. 2014. Mixed-conifer forests of central Oregon: effects of 

logging and fire exclusion vary with environment. Ecological Applications 24(7): 1670-1688.

Newbrey, M.G., M.A. Bozek, M.J. Jennings, and J.A. Cook. 2005. Branching complexity and 

morphological characteristics of coarse woody structure as lacustrine fish habitat. Canadian 

Journal of Fisheries and Aquatic Sciences 62(9): 2110–2123.

Perry, D.A., H. Jing, A. Youngblood, and D.R. Oetter. 2004. Forest structure and fire susceptibility in 

volcanic landscapes of the Eastern High Cascades, Oregon. Conservation Biology 18: 913–926.

Powell, D.C. 1999. Suggested stocking levels for forest stands in northeastern Oregon and southeastern 

Washington: an implementation guide for the Umatilla National Forest. F14-SO-TP-03-99. 

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Forest.

Powell, D.C. 2012. Range of variation recommendations for dry, moist, and cold forests. F14-SO-WPSilv-3. Pendleton, OR: U.S. Department of Agriculture, Pacific Northwest Region, Umatilla 

National Forest.

Sass, G.G., S.R. Carpenter, J.W. Gaeta, J.F. Kitchell, and T.D. Ahrenstorff. 2011. Whole lake addition of 

coarse woody habitat: response of fish populations. Aquatic Sciences 74(2): 255-266.

Seager, S.T., C. Eisenberg, and S.B. St Clair. 2013. Patterns and consequences of ungulate herbivory on 

aspen in western North America. Forest Ecology and Management 299: 81-90.

Seager, S.T., V. Ediger, and E.J. Davis. 2015. Aspen restoration and social agreements: an introductory 

guide for forest collaboratives in central and eastern Oregon. The Nature Conservancy.

Spies, T.A., M.A. Hemstrom, A. Youngblood, and S. Hummel. 2006. Conserving old‐growth forest 

diversity in disturbance‐prone landscapes. Conservation Biology 20(2): 351-362.

Stine, P., P.F. Hessburg, T.A. Spies, M. Kramer, C.J. Fettig, A. Hansen, et al. 2014. The ecology and 

management of moist mixed-conifer forests in eastern Oregon and Washington: A synthesis of the 

relevant biophysical science and implications for future land management. General Technical 

Report PNW- 897. Portland, OR: USDA Forest Service, Pacific Northwest Research Station.
FEIS Appendix D – Public Comment Report Magone Project

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Swanson D.K., C.L. Schmitt, D.M. Shirley, V. Erickson, K.J. Schuetz, M.L. Tatum, and D.C. Powell. 

2010. Aspen biology, community classification, and management in the Blue Mountains. PNWGTR-806, USDA Forest Service, Pacific Northwest Research Station.

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OR: U.S. Department of Agriculture, Forest Service, Malheur National Forest. Available online: 

http://www.fs.usda.gov/detail/malheur/landmanagement/?cid=fsbdev3_033814

USDA Forest Service. 2014a. Aquatic Restoration Environmental Assessment. John Day, OR: U.S. 

Department of Agriculture, Forest Service, Malheur National Forest. 203 p. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3817700.pdf

USDA Forest Service. 2014b. Decision Notice for Aquatic Restoration Project. John Day, OR: U.S. 

Department of Agriculture, Forest Service, Malheur National Forest. 47 p. Available online: 

http://www.fs.usda.gov/detailfull/malheur/landmanagement/?cid=STELPRD3817723

USDA Forest Service. 2015a. Malheur National Forest Site-Specific Invasive Plants Treatment Project 

Final Environmental Impact Statement. John Day, OR: U.S. Department of Agriculture, Forest 

Service, Malheur National Forest.

USDA Forest Service. 2015b. Record of Decision for the Malheur National Forest Site-Specific Invasive 

Plants Treatment Project. John Day, OR: U.S. Department of Agriculture, Forest Service, Malheur 

National Forest.

Williams, M.A., and W.L. Baker. 2012. Spatially extensive reconstructions show variable-severity fire 

and heterogeneous structure in historical western United States dry forests. Global Ecology and 

Biogeography 21(10): 1042-1052.

Wisdom, M.J., A.A. Ager, H.K. Preisler, N.J. Cimon, and B.K. Johnson. 2005. Effects of off-road 

recreation on mule deer and elk. In: The Starkey Project: a synthesis of long-term studies of elk 

and mule deer. Reprinted from the 2004 Transactions of the North American Wildlife and Natural 

Resources Conference, Alliance Communications Group, Lawrence, Kansas, USA. pp. 67-80.
FEIS Appendix D – Public Comment Report Magone Project

143

Comments Received on the Draft EIS from Federal, State, and 

Local Agencies and Elected Officials

Comment Received from Janine Belleque (Oregon State Marine Board)
FEIS Appendix D – Public Comment Report Magone Project

144
FEIS Appendix D – Public Comment Report Magone Project

145

Comment Received from Scott W. Myers, Chris B. Labhart, and Boyd 

Britton (Grant County Court)
FEIS Appendix D – Public Comment Report Magone Project

146

Comment Received from Maralee Wernz (Confederated Tribes of the 

Warm Springs Reservation of Oregon)
FEIS Appendix D – Public Comment Report Magone Project

147

Comment Received from Christine B. Littleton (United States 

Environmental Protection Agency, Region 10, Environmental Review 

and Sediment Management Unit)
FEIS Appendix D – Public Comment Report Magone Project

148