APPENDIX F

Consideration of Public Comments on Draft EIS

Consideration of Public Content

EXF Final EIS Appendix F Page 1 of 88

Appendix F – Consideration of Public Comment

During the public comment period (September 15, 2009 – November 2, 2009), responses were 

received from individuals, agencies or organizations listed in the table below. 

Consistent with the National Environmental Policy Act, 40 CFR 1503.4(b), this volume focuses on 

addressing substantive comments on the DEIS. Substantive comments include those which 

challenge the information in the DEIS as being inadequate or inaccurate, or which offer specific 

information that may have a bearing on the decision. Non-substantive comments are those that 

express opinions or position statements without any accompanying factual basis or rationale to 

support the opinion. Some comments have been summarized or paraphrased. 

All comments and response are part of the administrative record for this EIS, and have been 

considered during the decision-making process. Full text of the comment letters are on file at the 

Bend/Ft. Rock Ranger District. Letters received from federal agencies are included in full at the end 

of the appendix.

Table F-1. Agencies and organizations that submitted comments during the 45-day comment 

period:

1. Jean Public 16. Hannah Goldberg

2. Nathan Holst 17. Steven Belzer

3. Chuck Burley, Consultant 18. Lauri Solomon

4. unsigned 19. Shawn Carroll (+ 39 signatories) 

5. Kathy Ging 20. Shauna Bishop

6. Serge Vrabec 21. Theresa Mitchell

7. Steffi Lippel 22. Allie Hotra

8. Sarah Eastman 23. Dr. Richard Waring

9. Alex 24. Laurie Cross & Dave Thies

10. unsigned 25. Suzanne Pardee

11. Kingman Lim 26. Sierra Club, LOWD-BMBP, Cascadia Wildlands

12. Joanna Levy 27. Oregon Wild

13. Christopher Logan 28. U.S. Environmental Protection Agency (full letter 

included at end of appendix)

14. Matthew Haskins 29. Joe Stutler, Deschutes County Forester

15. Daniel Sinderson

Comments and Responses: The following comments, arranged by topic, are followed by the Forest 

Service response. Similar comments are grouped and given one response. The number following the 

comment indicates the commenter as listed above. 

EXISTING CONDITION

The EIS offers no documentation that the Lookout Mountain area did not support the current density of trees 

pre-European settlement. Re: statement that resulting structure will move the LOS ponderosa pine closer to 

pre-Euro-American conditions that could develop old-growth structural characteristics with trees able to 

survive for centuries. (#26)

Response: Neither the EIS nor the study plan make a claim to what structure existed at Lookout 

Mountain prior to the wildfire of about 1845. In addition, the EIS and the study plan do not suggest any 

reference condition for pre-Euro-American condition as the target for any of the treatments. The FEIS 

provides information on fire regimes for the types of plant associations that are present in the project area 

(pp. 99-101). The study plan does indicate that the few remaining examples of dry ponderosa pine oldgrowth forests in central Oregon are predominantly multi-cohort forests, in contrast to the single-cohort 
Appendix F Response to Public Comment

EXF Final EIS Page 2 of 88

stands at Lookout Mountain. Therefore, one of the treatments is designed to begin the slow process of 

transitioning from single-cohort to multi-cohort. Other treatments retain the single-cohort structure. 

Therefore, there is no inference to what may have existed at the time of settlement, except recognition that 

in the late 1800s and early 1900s, Lookout Mountain was covered with dense small saplings and poles. 

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Proposed actions fail to address the rarity of the proposed project area’s relatively intact old growth forest 

ecosystem. (#26)

Response: The Forest Service acknowledges the importance of this unit of the Experimental Forest (FEIS 

p. 1-3). The Forest Service is particularly concerned about this forest as it is at risk of major disturbance 

(FEIS pp. 3-4, 76-77, 85-87, Appendix B p. 11-14, 36); however it is not an intact old growth forest 

ecosystem (see FEIS p. 70 describing past activities; Appendix A maps of research locations and 

vegetation management).

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The area clearly has experienced additional fires beyond those disclosed in the DEIS, given the preponderance 

of relatively recent fire scars on snags, downed logs, and woody debris throughout the project area forests. 

Evidence indicates that the area is likely not outside its natural range of fire patterns. (#26)

Abundant contemporary scientific research evidences that the EXF project area mixed fire pattern transition 

zone forests are not outside the natural range of variability for their historical pre-fire suppression conditions 

for species composition, structural diversity, stocking densities, fuel loads, soil communities, and biodiversity. 

(#26)

These areas appear to be within their historic range of variability for p. pine and mixed conifer transition zone 

forests that would be naturally susceptible to mixed severity to high severity fire with greater stand structural 

complexity and variability and irregular longer fire return intervals. Evidence of past and recent fire scars 

exists throughout the project area. (#26)

Given the abundant evidence of recent fires over the past few decades found in the forest in addition to the 

documented fires disclosed in the DEIS, the contemporary research on mixed fire pattern forest fire intervals, 

and the documented mixed severity range of natural variability of the area’s fires from low to stand replacing 

high severity; there is little credible evidence supporting the DEIS premise that the stands’ fire regimes have 

been unduly altered. (#26)

Surveys of project units have documented evidence of relatively recent fires, contrary to the agency’s claims 

within the DEIS. It is highly likely that the area’s mixed fire severity forests are well within their historical 

range of variability in fire cycles, vegetative growth, stand densities, and insect and pathogen levels, as 

verified by surveys of units throughout the project. (#26)

The DEIS fails to present verifiable compelling evidence that the area’s forests are outside of the range of 

natural variability for insect, disease, and other natural pathogens and disturbances. (#26)

Response: The Experimental Forest has been the subject of extensive study since 1937. The Forest 

Service believes the charred stumps the respondents have seen in the project area are the remnants of the 

stand replacement fire that led to establishment of the single-cohort stand that exists today. The FEIS 

discusses fire return information for the plant associations present on Lookout Mt. (pp. 99-101). In 

addition, we know that portions of Lookout Mountain were underburned in the past under research efforts

(see Table 11 in the FEIS and Appendix B). The historic fire information (since records were kept) in the 

project area is based on Forest Service records that date to about 1904, and show that only one large fire 

has occurred inside the project area in the last century (FEIS p. 3, 39-40, 62, 82-84).

Commenters referenced work by Baker to support claims that the actual fire interval in the project area is 

far greater than the intervals claimed in the DEIS. The referenced work is incomplete, but has been 

reviewed (see p. 51 of this appendix). Although Baker’s research into reconstructing historic forest 

structure could add to the body of science, the EXF project does not intend to return the area to a particular 

condition based on any reconstruction. And while the fire cycle may enter into consideration in the 
Appendix F Response to Public Comments

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management of the Lookout Mountain Unit, it is not the sole basis for planned management nor is it the 

basis for the research outlined in the study plan.

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Spotted owl surveys by the USFS apparently did not begin until less than 2 years ago, and have identified a 

spotted owl pair within 2.5 miles of the project area, and found a spotted owl within the EXF Lookout 

Mountain Unit. Surveys by the East Cascades Bird Conservancy (ECBC) have documented spotted owls in the 

greater area since at least 2002. (#26)

As noted above, the East Cascade Bird Conservancy has documented spotted owl pair presence in the area 

since 2002, indicating that the owls are an established and likely breeding pair. (#26)

Response: Spotted owl surveys were conducted according to the “Protocol for surveying spotted owls in 

proposed management activity areas and habitat conservation areas.” (USDA 1993). The FEIS discloses 

spotted owl detections during surveys in 2007, 2008 and 2009 (FEIS p. 62).

The referenced documentation of a located threatened species has not been provided to the U.S. Fish and 

Wildlife Service or the Forest Service1

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. The East Cascade Bird Conservancy was contacted to acquire the 

documentation; they advised the Forest Service that they do not conduct official surveys (Steve Dougill, 

ECBC President, personal communication Nov. 6, 2009), nor have they sought a permit from the U.S. Fish 

and Wildlife Service to conduct such a survey.

The EXF DEIS fails to sufficiently disclose the methodology used to determine which forest stands in the 

project area or logging units function as current nesting, roosting, and foraging (NRF) habitat. The DEIS fails 

to disclose the criteria and site-specific methods used to determine whether the project actions would degrade 

NRF, dispersal, and connective habitat, or to adequately address scientific controversy and cumulative 

impacts issues in relation to these determinations. (#26)

Response: The Biological Assessment and FEIS Appendix E include information on how nesting, 

roosting, and foraging habitat is field-verified and mapped. Definitions are based on the 2006-2009 

Programmatic Biological Assessment (USFS 006). This information has been added to the FEIS (pp. 47-

49 and displayed in Figure 10 p. 50). The FEIS also describes how the activities will impact habitat (pp. 

63-75). 

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The area’s interfacing mixed conifer and ponderosa pine forests have evolved with and adapted over time to 

the area’s natural cyclic patterns. These species transition interface areas fluctuate in ongoing dynamic cycles 

of natural variability. However, the EIS fails to disclose or address research pertinent to these patterns and 

issues. (#26)

Response: The historic disturbance regimes and natural fluctuations over time are included in the 

description of the existing condition for forested vegetation (FEIS pp. 75-76, 81 and Appendix B p. 4-5). 

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STUDY PLAN / RESEARCH DESIGN

The DEIS proposes logging projects that include road building, landing building, pile burning, log truck 

hauling and other related management in medium high elevation interior old growth forests across two thirds 

of the lands set aside for environmental scientific research without adequately considering issues of paramount 

scientific importance given the regional and global imperatives of ongoing exponential climate change, 

including forest and soil carbon sequestration and ecological balance provided by the relatively intact 

functioning project area forests; the comparative carbon emissions release and diminished carbon 

sequestration capacity of the project if it is logged, mowed, and burned as proposed; and the carbon balance 

from no action, which includes wildfire (#26)

 1 Lauri Turner, Deschutes National Forest Wildlife Biologist, personal communication November 2009; 

Jennifer O’Reilly, U.S. Fish and Wildlife Service, personal communication November 2009.
Appendix F Response to Public Comment

EXF Final EIS Page 4 of 88

Response: There are several issues of scientific importance that will be addressed through the Study Plan. 

The Study Plan (Appendix B of the FEIS) describes the mission of the Managing Disturbance Regimes 

Research, Development, and Application Program (MDR). All research conducted within the MDR 

Program is focused on five issues. One of the issues is understanding and addressing climate 

change/atmospheric influences on ecosystems; the current Study Plan specifically will evaluate the effects 

of thinning and fuel reduction treatments on long-term sustainability to fire, insects, wind, climate change, 

and other forest disturbances (Appendix B pp. 14 and 22-23). 

Other programs within the research station are also addressing issues of climate change. Descriptions of 

all of these programs can be found at http://www.fs.fed.us/pnw/about/programs/index.html.

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This is not a legitimate scientific experiment in that it starts with unproven assumptions by logging up to the 

Upper Management Zone (UMZ) or cutting healthy understory and mature trees and only leaving a few big 

trees. This “scientific experiment” replicates current Forest Service widespread logging practices without 

learning anything new. The EXF project is a large profit timber sale disguised as a scientific experiment. (#2, 

4, 6, 7, 9, 11, 12, 14-20, 22)

Response: The experimental design does not replicate widespread practices. It consists of treatment 

structure and design structure. For an explanation of the experimental design, see pages 15 through 25 of 

the Study Plan. The upper management zone (UMZ) is explained in the FEIS pp. 17 and 85-86, and in the 

Study Plan pp. 7 and 12. The potential for learning is described in the Study Plan (pp. 14-25). 

As stated in the FEIS and Study Plan, there are six distinct research questions to be addressed with this 

project. These research questions focus on effects of forest vegetation manipulations, specifically 

treatments that potentially affect overstory and understory vegetation over time. Land managers need this 

kind of information on the response dynamics of vegetation composition and pattern at multiple scales 

because restoring resiliency of degraded forest ecosystems has become an important national priority and 

this research will help to define options for management that promote development of desired ecosystems 

attributes and values over time.

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There is no point in studying logging practices that go beyond the 21” diameter limits in the Eastside Screens 

because the screens are not going away. There is still a shortage of large and old trees. (#27)

Response: The study includes answering questions about growth rates of large trees and their resiliency 

to multiple, interacting forest stresses of fire, insects, and climate change (Appendix B p. 22). Diameter 

limits and Eastside Screens are addressed in the FEIS p. 37. Plot data was used to show the size of trees 

that are removed and that will be retained (FEIS pp. 90-91). Most trees to be removed during thinning are 

< 21” DBH. Additionally, although guidelines in the Eastside Screens are intended to promote retention 

of large trees, the Regional Forester in 2003 acknowledged that the Eastside Screens can limit our ability 

to meet the objectives of providing LOS stands, particularly single-story ponderosa pine LOS; she 

encouraged managers to amend the Eastside Screens where necessary to meet site-specific objectives. The 

FEIS shows that thinning in the EXF project will increase growth of the residual stands and retain the 

largest trees on site so that they can continue to grow.

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There is no reason to study the effects of logging in relatively rare forest type (dense mature Ponderosa pine 

forest) because the research results will not be widely applicable to other areas because there are few such 

areas in existence. (#27)

Response: The applicability of the research results is discussed in the FEIS p. 5 and Study Plan, p. 11).

Forest Service policy requires that the Research and Development program ensures coordination of R&D 

activities at the field unit level to meet regional and national R&D goals and objectives and that there is 

coordination among stations and other agencies and organizations to solve forest and range problems of 

regional and national importance (FSM 4070.2, 4070.3).

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Appendix F Response to Public Comments

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There are no real controls: By definition a control is a standard of comparison for checking or verifying the 

results of an experiment. The control areas in the EXF are scheduled to be logged 10 years later. This is not 

enough time to let the natural processes of this already healthy and mature to develop, change, and grow. The 

EXF project is limited itself to data that has been collected; what would happen to a natural mature Ponderosa 

pine forest if left to natural processes? (#2, 4, 6, 7, 9, 11, 12, 14-20, 22)

Response: There is no schedule for logging in the control units (FEIS p. 19). Data collection will occur 

immediately following treatments and again at intervals described in the study plan.

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The EXF area is rare and worth protection as it is in that it has not had significant natural or human 

disturbance (fire or logging) since about 1865, making it extremely valuable for the scientific study of natural 

processes. The Deschutes National Forest and the forests around Bend, OR have been heavily logged for the 

last hundred years. Most of the return growth has been compact, spindly, same-age lodge pole pines. These 

would be perfect areas to do scientific research in fuel reduction and pine park beetle prevention. The EXF 

area is a natural forest that was allowed to mature through natural processes and should allow perfect 

scientific research as a forest that can provide for itself. (#2, 4, 6, 7, 9, 11, 12, 14-20, 22)

The study plan reveals that the new research could be very easily accomplished by doing careful monitoring of 

timber sales that are part of the Forest Service normal logging program. We sure don’t need to log 2500 acres 

of forest to see if retained trees grow faster. Doesn’t the existing “levels of growing stock” study answer these 

questions? (#27)

Response: Some of the scoping comments suggested that research should focus on natural processes. This 

was addressed as an alternative considered, but was not analyzed in detail because the Pringle Falls 

Experimental Forest was established for silvicultural studies (FEIS p. 35). The FEIS points out that most of 

the Lookout Mountain Unit has undergone recent active management (FEIS pp. 43-44, 85, Appendix A). 

The Levels of Growing Stock study is described in Appendix B, p. 13. The research questions to be 

addressed in the current study plan are not limited to growing trees faster – see Purpose and Need, FEIS pp. 

4-5 and Appendix B.

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As reviewers have pointed out, this study plan has no built-in means for long-term data collection and no 

particular focus on climate change that could not be achieved through use of the EXF area as a naturallyevolving central plot while observing changes from management elsewhere....(#26)

As reviewers pointed out, longer term trends are not incorporated for monitoring within the project design, so 

expansion of existing knowledge claims for climate change and other long-term issues beyond five years are 

overstated and unsubstantiated. (#26)

Response: Theses comments raise two unrelated issues: the first deals with funding while the second deals 

with relevancy of climate change research. The study plan reveals the need to monitor structural changes 

and processes associated with stand dynamics in these ponderosa pine stands over the long term because 

few if any empirical comparisons of even-aged and uneven-aged systems exist across any suite of 

treatments. The proposed work will provide the opportunity to begin making these comparisons, 

recognizing that it will take decades before trends may be revealed. Agency policy is to design study to 

address current and future needs, incorporate these studies into 5-year action plans, and fund actual work 

under annual appropriations. Therefore, the study plan indicates that there is no commitment beyond the 

current effort to establish the study.

The study plan reveals that climate change is an additional form of disturbance that has not been adequately 

addressed in thinning and fuel reduction research. The Lookout Mountain portion of central Oregon has 

gone through at least five distinct periods of warming climate over the past 110 years. In the Western 

United States and at the continental scale (1 km), long-term satellite data show consistently earlier onsets of 

spring greening and corresponding increases in length of growing season (Climate Change Resource Center 

(http://www.fs.fed.us/ccrc, 10 Sept. 2009). US Department of Agriculture, Forest Service, Climate Change 

Resource Center. Washington, D.C., USA.). Small changes in growing season duration may result in 

expansion of species that have relatively narrow habitat requirements. Lookout Mountain provides a 

unique opportunity to explore vegetation dynamics under a changing climate regime because it is 

topographically simplistic, it contains essentially uniform or homogenous soils, and it contains several 

relatively clear and distinct ecotones in easily recognized plant assemblages. Early indications of 
Appendix F Response to Public Comment

EXF Final EIS Page 6 of 88

vegetation dynamics may become first apparent in the shrub and herbaceous strata with expansion of 

species from drier sites into those areas that are currently moister as conditions become increasingly 

stressed. For example, antelope bitterbrush may expand upward in elevation under increasing moisture 

stress. Understanding these dynamics will provide insights into the effects of climate change at the 

community scale, and provide managers much needed information on any restructuring of plant 

composition as a result of regional climate interacting with legacies of past management. While it may be 

possible to monitor understory community dynamics for shifts that result from climate change without any 

change in overstory structure, it is unlikely that relevant questions could be addressed through use of the 

EXF area as a naturally-evolving central plot while observing changes from management elsewhere 

because of differences and uncertainties in past disturbances that may occur elsewhere. 

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How will avoiding the LOS patches interfere with the ability to answer research questions posed in the study 

plan?

Response: This issue is addressed in the FEIS (p. 93, 97) and is based on research design, including the 

random assignment of treatment to units and the need for unbiased results. The EIS fully reveals the age 

structure of ponderosa stands within the units proposed for treatment. This relatively large block of closedcanopy forest has undergone little major disturbance, other than fire exclusion and thinning (described in 

Appendix B), since about 1845 when a single stand-replacement fire resulted in the establishment of dense 

ponderosa pine at lower elevations and mixed conifer at higher elevations. Therefore, these stands are 165 

years in age. This is in strong contrast to nearby old-growth ponderosa pine stands that exceed 600 years in 

age. Avoiding patches of assumed late- and old- structure would likely interject an unnecessary bias for 

large trees and prevent the analysis of treatment responses across the unit. 

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PURPOSE AND NEED

The Reason for Fuel Reduction or Beetle Infestation: The EXF area is a healthy and beautiful forest. There 

are no signs of pine bark beetle or competition stress in the mature and old growth Ponderosa pine stands. 

Fuel loading in the pine stands is already low, with few ladder fuels and well-spaced trees with thicker, more 

fire resistant bark. There is currently low risk of fire or insect epidemic that would justify logging. (#2, 4, 6, 7, 

9, 11, 12, 14-20, 22)

Due to past logging in the area, what “overstocking” actually exists occurs only within limited lower elevation 

dry ponderosa pine dominant stands in surrounding forests below the base of Lookout Mountain, not on p. pine 

transition forests upslope of 4,000 or more feet. (#26)

Response: Researchers, silviculturists, entomologists, and fuels specialists disagree. Signs of stress are 

evident in the trees at the Experimental Forest, as measured and studied by scientists with the PNW Research 

Station (FEIS Appendix B, p. 12-13). Bark beetle hazard is based on stocking density guidelines using the 

work of P.H. Cochran (1992, 1994) which takes into consideration the site potential (FEIS p. 85-87). Stands in 

the project area exceed density guidelines developed specifically for Central Oregon (FEIS p. 87, Table 35). 

There are two additional measurements that show the risk to bark beetles. First, tree radial growth rates in the 

project area are slower than 13 rings per inch, and second, low tree vigor as evidenced by live crown ratio 

within the project area.

In addition to the beetle risk, fuels pose a risk of damaging wildfire. The expected fire behavior is described 

on pp. 102-105 of the FEIS. Modeling with Flammap shows that current fuel conditions will create moderate 

to high flame lengths across about half of the area. Photos submitted by the respondent evidence a high fuel 

loading in many places, including ladder fuels. 

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AFRC agrees with the Purpose and Need for Action and believes the Proposed Action (Alternative 2) best 

meets this. Furthermore, AFRC would like to see well thought out scientific investigation into these 

contemporary issues of how best to reduce the risk of insect, disease, and fire while providing for the 

development of large trees and spotted owl habitat. (#3)
Appendix F Response to Public Comments

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Response: The Study Plan (FEIS Appendix B) does not directly address dynamics in forest structure that 

may contribute to northern spotted owl habitat. Much of the information developed from monitoring 

changes in forest structure may indirectly aid in our understanding of dynamics within more narrowlydefined northern spotted owl habitat. Additional study could be added to the framework provided by the 

proposed actions as resources are made available.

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I support the overarching justification for the project because it is a well replicated experiment across the 

Lookout Mountain Unit. The size of the area is adequate to test critically a number of assumptions in current 

land management, and the results are sure to be published. (#29)

Response: No response necessary.

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The DEIS must substantiate the claimed needs and actions. (#26)

The purpose and need of the EXF timber sale is too narrow. The Forest Service has limited possible actions to 

only scientifically controversial and largely insupportable logging actions that are incongruous with the 

project’s stated ecological objectives. (#26)

As presented, the DEIS proposed action alternatives significantly diverge from scientifically credible research 

and appropriate management methods for this rare ecologically functioning ponderosa pine-mixed conifer old 

growth and spotted owl LSR forest area. (#26)

There appears to be no valid ecological rationale to log this rare ecologically relatively intact old growth 

forest ecosystem. (#26)

Scientific research indicates that the purpose and need goals of the project are largely already being met by 

the area’s relatively intact natural recovery and resilience processes. (#26)

The EIS fails to assess, and needs to disclose and analyze, the consequences of disrupting natural disturbance 

processes in complex p. pine and mixed conifer forest ecosystems. (#26)

This land has been set aside to facilitate better scientific understanding of natural forest processes and 

functioning. Its highest and best purpose as part of the Pringle Falls Experimental Forest, consistent with 

Pacific Northwest Science Research Station goals and objectives, is its rare, locally unequalled capacity to 

serve as a natural template of relatively intact dynamic natural forest ecological processes, cycles, adaptation 

and functioning. (#26)

Response: The purpose and need is based on site-specific data gathered at the Lookout Mountain 

experimental forest. Researchers gathered data at reconnaissance plots in 2005 and 2007 and found stands 

that range from 132 to 224% of the Upper Management Zone in stand density index (SDI) (FEIS, 

Appendix B p. 12). SDI is explained on page 17, 85-86, and Appendix B p. 7. Forest stand conditions 

throughout the EXF planning area can best be described as being overly dense and at risk of beetle-caused 

mortality (FEIS p. 85). The risk of mortality from bark beetles that this level of stand density poses is 

well-established in the scientific literature (Cochran 1992; Cochran et al 1994). Also, see page 83-84 of 

the FEIS for a description of research findings made at the Lookout Mountain Unit.

The analysis shows that with no thinning, tree growth rates would remain low or continue to decrease, tree 

vigor would remain poor and continue to decline, the risk of insect and disease mortality would remain 

high and beyond 10 years the beetle-caused mortality is likely to reach epidemic levels (FEIS p. 88). 

Under those conditions, current and future research opportunities would be lost.

Because the area is an Experimental Forest, established as a center for silviculture, forest management, 

and insect and disease research in ponderosa pine forest, it provides the opportunity to conduct research 

while addressing the management issues (FEIS pp. 1, 4-5, 85-86, and Appendix B). The commenter’s 

suggestion that the Experimental Forest should serve as a natural template of “relatively intact dynamic 

natural forest ecological process” is not in line with the goals of the Pacific Northwest Research Station or 

the establishment record of the Experimental Forest.

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Note that the majority of sale units in Table 13 are not in dry ponderosa pine PAGs, as would be inferred from 

the purpose and need re: use of UMZ theory and fire risk/pine beetle rationales. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 8 of 88

Response: The comment is not supported by actual text in the EIS. Table 13 (now Table 29 in the FEIS, 

p. 78) clearly indicates a majority of proposed treatment units are “Mixed Conifer-Dry” or are ponderosa 

pine plant association groups and depicted in Figure 17. Existing conditions of the proposed treatment 

units, revealed through the collection of field data and numerous field trips, shows they are strongly 

dominated by ponderosa pine. The proposed treatments are designed to maintain and protect the 

ponderosa pine because this tree has the greatest probability for persistence for several centuries.

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...the purpose and need drive to produce timber volume by logging old growth is not only scientifically 

insupportable, it is economically unfounded as well. (#26)

Issuing EISes such as this one, wherein undisclosed quotas and/or unspoken timber volume objectives set the 

parameters limiting the development and focus of alternatives, and the decision-maker’s ability to modify a 

project, violates the NEPA, violates agency compliance with environmental policy laws, and violates agency 

accountability to the nation’s public.

Analysis and alternative development fail to disclose the existence or influence of timber volume quotas and/or 

pressures.

The agency’s blanket requirement of the region’s forests to meet arbitrary timber targets violates federal 

environmental policy laws. Failure to disclose and analyze the impacts of this additional timber directive 

violates the NEPA. (#26)

Response: The project’s purpose and need does not include the production of timber volume (FEIS p. 4). 

The expected output of timber and associated jobs is disclosed in the FEIS (pp. 241-242).

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The DEIS stated purpose and need objectives are not consistent with the action alternatives which propose to 

log many of the larger, more fire-resistant trees in moderate- to higher-elevation forests that instead need to be 

kept to effectively retain and restore more resilient conditions. (#26)

Response: Thinning is from below, where the largest and healthiest trees are retained (FEIS pp. 19, 89-

90). This will result in an increase in the average tree diameter in the residual stand (p. 91).

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Objective scientific research recognizes the importance of rare areas as EXF to inform and guide research 

based restoration objectives and methods elsewhere, across the regions landscape of severely management 

altered and degraded forest habitat. (#26)

The EXF project is neither unique nor is it needed to advance scientific study of forest management affecting 

ecological functioning and disturbance response. (#26)

Response: These two statements, from the same commenter, appear to be in contradiction to each other. 

The Pacific Northwest Research Station does recognize the importance of the project area to inform future 

management in ponderosa pine ecosystems – it is the purpose of the Experimental Forest, and reason that 

the proposed thinning and fuels reduction work is designed to answer important research questions. 

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The DEIS Appendix B Response to External Reviewer Comments fails to scientifically justify the purported 

purpose and need for the project, and insufficiently adheres to the foundational objective tenets of science 

research, instead obfuscating critical issues of scientific controversy and uncertainty while avoiding disclosing 

and addressing the growing evidence of environmental harms from similarly premised projects across the 

region’s forests. (#26)

Response: The commenter does not identify which “objective tenets of science research” are not being 

adhered to. The Forest Service Research and Development Code of Scientific Ethics (Forest Service 

Manual 4086) describes ethical conduct expectations and norms of behavior for scientific research and 

development activities. 

The Study Plan was developed following FSM 4072.3. In addition to a peer-review, the Study Plan was 

the subject of a double-blind external review process with seven reviewers external to the PNW Research 
Appendix F Response to Public Comments

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Station. This double-blind external review led to documented changes in the Study Plan (see Appendix B 

of the FEIS).

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Scientific research addressing complex forest ecosystems, and the role of insects has been ignored by the EIS, 

though such information is critical to the stated purpose and need ecological objectives. (#26)

Response: The FEIS discusses the role of insects in the forest ecosystem on page 75-76 and describes 

scientific research on insects conducted within the Experimental Forest on page 84.

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The EIS does not adequately explain the mixed purposes (conducting new research and protecting existing 

research). Can these two purposes be separated and accomplished in a more appropriate manner, such as by 

doing the new research in other areas, and by protecting existing research with more focused treatments in the 

immediate vicinity of the study plots. (#27)

Response: The FEIS discusses the mixed purpose on pp. 4-5. The Alternatives suggested were 

considered and dismissed from detailed analysis because they do not meet the purpose and need for action;

see pp. 35-37. 

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Most federal forest management efforts in dry forests in eastern Oregon in recent years have focused on trying 

to convert multi-cohort forests (which are over-represented) into single cohort forests (which are underrepresented). Why is the study plan here involve converting a single cohort forest into a multi-cohort forest? 

Is this study plan relevant to what managers are trying to do? Is it ecologically appropriate to convert an 

under-represented forest type into a over-represented forest type? (#27)

Response: The terms “cohort” and “stratum” were defined in the DEIS glossary. These terms have also 

been clarified in the body of the FEIS (p. 19). These questions are addressed in the study plan: see 

Appendix B, p. 23 for the rationale behind this research question. 

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The Forest Service does not disclose the scientific controversy surrounding the use of FRCC. (#26)

FRCC critique – not a sound basis for describing and prioritizing fuel treatments....Dense canopy cover might 

actually help suppress fire rather than spread it. See Odion, D.C., E.J. Frost, J.R. Strittholt, H. Jiang, D.A. 

DellaSala and M.A. Moritz. 2004. Patterns of fire severity and forest conditions in the western Klamath 

Mountains, California. Conservation Biology 18(4): 927-936. 

http://nature.berkeley.edu/moritzlab/docs/Odion_etal_2004.pdf

Response: Fire Regime and Condition Class were used in the analysis area to determine reference 

conditions (FEIS p. 99-101). Because of the controversy and simplicity of using FRCC (Morrison and 

Smith 2005; Veblen 2003), FRCC was not used as the primary basis for decision making. It also was not 

used as a measurement in the analysis; only fire behavior measurements were used to describe the effects 

of the alternatives.

-------------------------------------------------------------------------------------------------------------------

P. pine transition zone and mixed-conifer forests are questionable candidates for fire restoration through 

thinning, as attempts to restore the fire regime in these types of forests will often negatively affect habitat that 

these forests provide. (#26)

Response: The purpose of thinning and fuels reduction is not to restore the fire regime. The action 

alternatives will improve fire resilience (FEIS p. 107, 112-122).

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The Forest Service’s use of questionable fire models fails to provide adequate support for either their 

conclusion that tree canopy and stand density must be reduced in order to reduce fire risk or their conclusion 

that there is a high risk of fire and insects in the EXF Project area. Furthermore, the fire models that are 

relied on by the Forest Service in the DEIS do not adequately represent the situation on the ground in the 

forest. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 10 of 88

Response: See FEIS p. 108 for a thorough discussion of the effects of thinning on fire behavior. 

FlamMap is a state of the art tool used by many researchers and modelers (Finney 2006; Gercke & Stewart 

2006; Opperman, Gould, Finney, Tymstra 2006). FlamMap output lends itself well to landscape 

comparisons (e.g. pre- and post-treatment effectiveness) and for identifying hazardous fuels and 

topographic combinations, thus aiding in prioritization and assessments (Stratton 2004). The FlamMap 

model was used to produce maps and to compute fire behavior characteristics. Input into the model 

includes site-specific data about the situation on the ground (pp. 108-109). Although the modeling 

approach has limitations, model outputs yield useful information for planning, assessing, and prioritizing 

fuel treatments (Stratton 2004).

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Before embarking on an aggressive strategy of crown fuel reduction, the agency must address the responsible 

opposing viewpoints regarding the manifold values of retaining more canopy to retain cooler temperatures 

and moisture. Responsible opposing experts say that reducing ground fuels and ladder fuels should be the first 

priority and reducing canopy fuels a lesser priority. The agencies must also recognize that most large fires are 

climate driven, not fuel driven. “Our analyses indicate that year-of-fire climate is the strongest influence on 

area burned in forested ecosystems, but fire size may be limited secondarily by fuel continuity between or 

within forest stands (Rollins et al. 2002). For example, continuity may be less limiting for fire regimes in which 

crown fires are the dominant mechanism than in lower-elevation forests characterized by surface fires, ...” 

JEREMY S. LITTELL, DONALD MCKENZIE, DAVID L. PETERSON, AND ANTHONY L. WESTERLING. 

2009. Climate and wildfire area burned in western U.S. ecoprovinces, 1916–2003. Ecological Applications, 

19(4), 2009, pp. 1003–1021.(#27)

Response: The Forest Service agrees with the comment that reducing ground fuels and ladder fuels is a 

high priority. Fuel reduction in the EXF project follows principles of fire-resilient forests by reducing 

surface fuels, removing ladder fuels, leaving large fire-resistant trees, and spacing tree crowns (FEIS p. 

107). The Study Plan established different levels of reducing fuels for the purpose of comparing and 

contrasting the consequences of different levels.

We agree that large areas in the West have burned in fires that are climate-driven, and these 

characteristically are higher elevation forests that support stand-replacement fires. Fuel-driven fires, 

characteristically at lower elevations, do not support stand-replacement fires. Lookout Mountain was the 

site of a stand-replacement fire, the more typical fire is limited by fuel. Proposed treatments would reduce

ground fuels and fuel ladders (fuel continuity) and thus address fuel-driven fires. In general, fuel 

treatments can help produce forest structures and fuel characteristics that then reduce the likelihood that 

wildfire will cause large, rapid changes in biophysical conditions. Fuel treatments thus are designed to 

shift fires from high severity to low severity. Empirical evidence for this shift is in the literature; see, for 

example, recent work in ponderosa pine forests at Black Mountain in northeastern California, similar to 

Lookout Mountain, where tree survival after wildfire was greatest in those areas that had both thinning and 

prescribed fire prior to the wildfire event. Survival was near zero for the untreated areas. Survival in 

thinned-only areas was greater than untreated areas but substantially less than the areas with both 

treatments. Ritchie et al. 2007. Probability of tree survival after wildfire in an interior pine forest of 

northern California: Effects of thinning and prescribed fire. Forest Ecology and Management 247: 200-

208.

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Crown fire is usually a passive crown fire which relies on the preheating of canopy fuels by burning from 

below. When surface and ladder fuels are adequately treated active crown fire becomes an unlikely outcome 

except on very steep slopes where preheating is driven by the other crowns burning below. Active crown fire is 

such a rare event that it should not drive forest management objectives, and the agencies should instead focus 

on reducing surface and ladder fuels and retaining canopy to help create a cool moist microclimate and to 

help suppress the growth of surface and ladder fuels. (#27)

Response: The FEIS discusses potential for passive crown fire pp. 103-104. Active crown fire is not 

driving the project objectives, but modeling shows that treatments will potentially reduce any active and 

passive crown fire.
Appendix F Response to Public Comments

 EXF Final EIS Page 11 of 88

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Models shows that maintaining canopy cover is a useful way to reduced fire hazard, while removing canopy 

increases fire hazard...“Reduce Crown Density • Important to address once surface fire and torching are 

addressed. (“DON’T START HERE!!!!! ... Treatments that reduced surface fuels, treated ladder fuels, and 

kept the big trees fared best.” ) An EIS is needed to respond to opposing viewpoints and consider the 

consequences of alternative approaches to fuel reduction..

http://www.fws.gov/oregonfwo/ExternalAffairs/Topics/DryForestWorkshop/Documents/2005/PowerPoints/Age

e%20NSO-Bend-Agee.ppt

(#27)

Response: Fuel reduction in the EXF project follows principles of fire-resilient forests by reducing 

surface fuels, removing ladder fuels, leaving large fire-resistant trees, and spacing tree crowns (FEIS p. 

107) and is documented in an EIS. The primary objective for density reduction is to avoid large-scale 

mortality from bark beetles in addition to studying stand dynamics in the various thinning types. The 

referenced Powerpoint discusses proposed research that is designed to evaluate (test) the assumptions on 

which the quoted statement is based.

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Consider the recommendations for dry forest landscapes found in the final spotted owl recovery 

plan. Even though this forest is outside the range of the spotted owl, there are places on the eastside 

of the Cascades that do have owls and the recovery plan makes some nice recommendations for 

restoring ecological process (as opposed to specific habitat conditions just for the spotted owl). 

There are a number of species other than the spotted owl that prefer complex forests (e.g. goshawk, 

pileated woodpecker, marten, fisher, flammulated owl, three-toed woodpecker) so there is no reason 

that these recommendations should not be relevant here. (#27)

Response: The 2008 Recovery Plan and its associated recommendations for dry forest landscapes was 

considered in the EIS (see pp. 62 of the EIS and the associated conclusions in the project’s Biological 

Assessment, Biological Evaluation, and Biological Opinion).

The approved study plan attends to the original design and purpose of the Lookout Mt. Unit of the Pringle 

Falls Experimental Forest, i.e. “...to evaluate the effects of silvicultural practices on growth and yield of 

ponderosa and lodgepole pine...” (p. 4-152 of the LRMP). The study plan, because of its focus on 

ponderosa pine, was not developed to incorporate the Douglas-fir and dry grand fir components of 

Recovery Action #6 “identify, maintain, and restore 30-35% of the total dry forest (ponderosa pine, 

Douglas-fir, and dry grand fir plant association group) habitat-capable areas as spatially dynamic highquality spotted owl habitat patches...” (p. 21). The study plan and the associated EIS do potentially 

support Recovery Action #7 which states “manage lands...outside of high-quality habitat patches to 

restore ecological processes and functions, and to reduce the potential for significant losses by standreplacement fires, insects, and disease. This Recovery Action includes three elements: (1) active 

management of dry forests, (2) development of large tree structure, and (3) long-term management of dry 

forests to reduce the potential for future high-severity fires and hasten the recovery of structurally diverse 

forests.” (page 22). 

The Cultus Mt. and Sheridan Mt LSRA addressed similar recommended actions for species such as 

goshawk, pileated woodpeckers, and flammulated owls. These have been addressed within the EIS and 

the associated Biological Evaluation and Biological Assessment specific to the LSR. Each of the species 

listed in the comment have been addressed in the FEIS (respectively: pp. 150-152, 182-183, 156-158, 131-

134, 167-168, 180).

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How do you log to 75% UMZ when the upper part or majority of the unit is already less than that for its type?

Re: Unit 11 – mixed conifer on east to northeast facing slope...these units are anything but homogenous or 

well-defined. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 12 of 88

Response: The study plan reveals that UMZ targets were developed for an entire block, with each block 

consisting of 5 relatively homogeneous treatment units. The units are homogeneous with respect to 

aspect, elevation, overstory composition, and key aspects of stand structure. Treatments were then 

assigned at random to each of the 5 treatment units within a block. The EIS and study plan indicate that 

Unit 11 currently has a basal area of about 140 feet2

acre-1 and the target is about 76 feet2acre-1 across the 

whole unit. Naturally-occurring gaps and openings with less than the target density will be less affected 

by treatments compared to areas within the treatment unit where currently the basal area may exceed 140 

feet2

acre-1. Figure 6, page 21 of Appendix B (the Study Plan) shows a simulated 75% UMZ treatment in 

Block 1.

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The artificially narrowed purpose and need is used to artificially narrow and limit the range of alternatives to 

only the proposed two alternatives....This extremely narrow purpose and need assumes the necessity of both 

density reduction and this particular study plan at the expense of others.

Response: The purpose and need is based on the need for density reduction (established through 

measurements of tree growth) and the mission of this particular Experimental Forest (which is to conduct 

field research on ponderosa pine silviculture).

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A missing critical purpose and need for this project is to protect existing spotted owl habitat quality and the 

spotted owls themselves. The EXF project appears to fail to follow the northern spotted owl recovery plan 

actions #6 and #7 by not maintaining 30-35% of total dry forest and 50-75% of total moist forest for spotted 

owl within the project area west of the owl line. High quality NRF habitat is not just supposed to be identified, 

but maintained.

The project area is moister, more highly productive ponderosa pine forest with an estimated 77 year fire return 

interval, not a 5-10 year fire return interval...is more uniquely suitable as it stands to serve as spotted owl 

NRF and foraging habitat.

Response: Fire regimes for the project area is discussed on pages 99-100 of the FEIS. The FEIS 

acknowledges highly-productive ponderosa-dominated plant associations in the project area. The Spotted 

Owl Recovery Plan is addressed in the FEIS p. 62. 

-----------------------------------------------------------------------------------------------------------------------

ROLE OF SCIENCE

The DEIS for the EXF Project claims its purpose and need and proposed actions are scientifically founded, 

however it fails to objectively and adequately address issues of scientific controversy and opposition, or to 

provide the public and decision-maker with a reasonable range of scientifically founded action alternatives 

representative of differing scientific research and ecological management possibilities that have evidenced 

better capability of achieving the projects purported purpose and need goals. (#26)

The DEIS never objectively discloses the wealth of scientific research across multiple science disciplines that 

readily disproves the foundational premise of the “study plan,” nor does the DEIS objectively establish a 

credible scientific foundation for the “study plan.” (#26)

Response: The comment is not specific as to which research disproves the foundation for the Study Plan. 

The Study Plan was peer-reviewed and approved by the Pacific Northwest Research Station following 

established methods. The basis for the study plan is presented within the text (Appendix B). 

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The project as proposed would sacrifice the naturally functioning forests of EXF, precluding current and 

future research into the myriad lessons and inherent guidance that can be garnered from an ecologically intact 

system. As such, the EXF project lacks not only in humility, in its attempt to recreate a natural forest system to 

fit select hypothetical studies and contrived judgments, it fails the foundational objective tenets of science 

itself. (#26)
Appendix F Response to Public Comments

 EXF Final EIS Page 13 of 88

Response: The largest threat to current and future research is the threat of losing the existing research 

sites and future research opportunities to an insect epidemic and/or a wildfire (FEIS pp. 3-5, 85-87, 110). 

The project does not attempt to recreate a natural forest system; rather the project is intended to meet the 

purpose and need described on pages 4-5 of the FEIS. It is not clear what foundational objective tenet of 

science the project has failed. 

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The Forest Service’s Failure to Ensure Scientific Integrity of Its Analysis and Developed Alternatives Violates 

NEPA and is Arbitrary and Capricious. (#26)

The DEIS does not identify what the “best available science” is or entails, with respect to the Forest Service’s 

decision to log LOS NRF forest habitat. (#26)

The DEIS fails to reasonably address the scientific controversy surrounding the developed alternatives and 

their lack of scientific support, instead hiding behind the cloak of one set of highly suspect, largely disproven 

pretentious pseudo-science that substitutes irreparable logging harms for responsible scientific objectivity.

(#26)

Response: These comments lack specificity. However, the Forest Service has shown consideration of 

best available science in NEPA when we insure scientific integrity of the discussions and analysis. This 

means identifying methods used, referencing scientific sources relied upon, discussing responsible 

opposing views, and disclosing incomplete or unavailable information. And as stated earlier, the Study 

Plan itself was developed, reviewed, and approved through the Research and Development program 

outlined in FSM 4072.3. 

--------------------------------------------------------------------------------------------------------------------

The FEIS never “disclose[s] the extent to which the impact of the proposed action is scientifically 

controversial,” regarding the Forest Service’s proposal to reduce fire risk by commercially logging old and 

mature stands of transition zone p. pine and mixed-conifer forest. 40 C.F.R. 1507.27(b)(4). (#26)

Response: The 40 CFR reference could not be found; the Forest Service assumes the commenter is 

referring to 1508.27(b)(4), which states that when considering significance of effects, one should include 

an evaluation of the intensity of effects, including the degree to which effects are likely to be highly 

controversial. The Council on Environmental Quality defines “scientifically controversial” as when 

experts disagree over the effects to a specific resource on a site-specific area. The scientific references 

provided by the commenter have been reviewed by the interdisciplinary team and also do not support the 

comments that the effects are scientifically controversial. The concerns expressed about increasing fire 

risk through commercial logging have been readily acknowledged and thoroughly addressed in the FEIS 

(pp. 107, 108, 1009, 114, 117), in part because thinning is followed by slash treatment, mowing, and 

prescribed fire; in part because thinning starts with the smallest trees first; and finally because thinning is 

not proposed solely to reduce fire risk, but as stated throughout the FEIS, thinning will reduce stand 

density in stands that are not sustainable at the current density. 

--------------------------------------------------------------------------------------------------------------------

How is logging LOS and trees > 21” dbh putting these on a trajectory towards resiliency when both LOS and 

trees > 21” are at a deficit and both contribute to resilience? (#26)

Response: The role that trees over 21” dbh play in LOS and LSOG definitions is discussed in the FEIS 

pp. 65-67 and the predicted changes are disclosed on pp. 90-92, 95-96. The EIS reveals the age structure 

of ponderosa stands within the units proposed for treatment. Thinning from below of the smaller trees will 

provide more resources and space for the larger residual trees, and thus increase their resiliency.

--------------------------------------------------------------------------------------------------------------------

PROPOSED ACTION

The EIS appropriately defines the objective of thinning is to favor the largest diameter ponderosa pine and 

Douglas-fir and to remove the surrounding smaller diameter trees. This is a critical decision because without 
Appendix F Response to Public Comment

EXF Final EIS Page 14 of 88

reducing competition around dominant trees the intensity of thinning is likely to be insufficient, even with a 

50% reduction in stand basal area to protect residual trees against attack from mountain pine beetles....As a 

forest grows, the amount of leaf area that can be stacked above the ground reaches a maximum, which varies 

with productivity. Competition among trees increases as the carrying capacity of a site approaches its 

maximum. Unless the forest is heavily thinned, most trees become highly susceptible to bark beetle attack. To 

reduce tree mortality during a beetle outbreak requires a reduction in leaf area (and basal area) of at least 

60%. Such a reduction reduces competition and provides residual trees a chance to increase their resistance 

to beetle attack (Coops et al 2009), assuming that there is no extended drought (Kolb et al 2007). (#23)

Response: We agree with the comment that it is critical after thinning to manage fuels surrounding the 

residual trees. The FEIS states that this will occur by a combination of mowing and underburning. We 

agree with the comment that stands of ponderosa pine at Lookout Mountain likely exceed ideal levels of

leaf area index, and that as the proportion of maximum leaf area index increases there is a curvilinear 

decrease in vigor index defined as grams of wood production per year. While this relation has been 

documented for lodgepole pine, there is as yet little empirical data to construct similar curves for ponderosa 

pine of the size and age as found at Lookout Mountain. Nevertheless, we agree with Kolb at al. 2007 that 

resource uptake and growth of old trees can be increased by careful thinning; radial growth responses likely 

are slower than that of younger trees, often requiring years or decades for crowns to develop sufficient 

photosynthetic capability; and a small but growing number of experiments showing that resource uptake and 

growth of old trees of various species respond positively to a reduction of stand leaf area by management 

treatments suggests that similar responses can be expected from ponderosa pine. Finally, no direct measure 

of leaf area indices are available for stands at Lookout Mountain, precluding a direct linkage between the 

prescribed reduction in basal area and the anticipated reduction in proportion of maximum leaf area index.

-------------------------------------------------------------------------------------------------------------------------

RANGE OF ALTERNATIVES

Proposed actions appear to far exceed that scientifically necessary and capable of achieving fire risk reduction 

and ecological purpose and need goals. (#26)

Response: The commenter suggests that the purpose and need stated on page 4 of the FEIS could be 

achieved with either fewer acres treated or less intense treatments. These ideas are discussed in the section 

on Alternatives Considered but not Analyzed in Detail (p. 35-37).

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The purpose and need of the EXF timber sale is too narrow. The Forest Service has limited possible actions to 

only scientifically controversial and largely insupportable logging actions that are incongruous with the 

project’s stated ecological objectives. (#26)

The DEIS claims that 5 other possible alternatives were considered and dismissed, leaving only the 2 logging 

action alternatives that were developed. However, the two action alternatives are virtually identical in premise 

and methodology, both featuring widespread commercial logging across most all of the project area units. 

(#26)

Response: Alternative 3 was developed because of the issue of spotted owl habitat. There are 211 acres 

of spotted owl habitat and 161 acres of Late Successional Reserve within units; by avoiding those, 

Alternative 3 treats 372 fewer acres than Alternative 2. There are substantial differences in the 

alternatives’ ability to meet the purpose and need and in the difference of effects to spotted owl habitat.

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Overall, a scientifically supported reasonable alternative would have been to implement a maximum 8” to 10” 

(at most 14” to 16”) diameter limit in appropriate PAG areas as a scientifically feasible developed alternative 

for consideration. (#26)

The Forest Service must consider an alternative in its analysis which consists of utilizing only non-commercial 

limited small diameter thinning in only ecologically appropriate forest locations (lower elevation ponderosa 

pine dominant – frequent low intensity fire plant association group forests) to reduce fire risk – outside of 

spotted owl NRF, and ecologically functioning old growth transition zone and mixed conifer forest areas. 

(#26)
Appendix F Response to Public Comments

 EXF Final EIS Page 15 of 88

An alternative which would limit actions to non-commercial thinning and natural research studies would 

sufficiently address the actual rather than perceived risk of fire and could best meet the project’s ecological 

objectives. (#26)

This project allows the logging of mature and old growth trees without diameter limits. (#26)

The Forest Service does not need to cut trees above 10” to 12” dbh or for that matter to cut any trees in mixedconifer mixed-fire severity mid to high elevation forests –especially trees that evidence fire resistant mature 

and old characteristics. (#26)

Yet the agency failed to consider other reasonable alternative options, including limiting felling to trees 10, 12, 

or even 14” dbh in appropriate PAG and fire pattern areas only. (#26)

The argument for failing to analyze in detail an alternative setting diameter limits represents an even more 

narrow purpose and need – to reach an arbitrary basal area no matter what it takes to do so. (#26)

Response: Thinning only the smallest trees would not reduce stand density enough to reduce the risk of 

insect and disease-caused mortality. The FEIS points out that the average size of trees in the project area 

is 17.5” DBH, and thinning from below will retain the largest trees on site.

-------------------------------------------------------------------------------------------------------------------------

None of the action alternatives focus on scientifically supported restoration of the area’s mixed fire pattern 

forest ecosystem, even though restoration is the best approach for maintaining the wholeness of the forest and 

its habitat and reducing fire risk in the both the short and long-term. (#26)

The DEIS does not contain an action alternative that is based upon the preponderance of credible peer 

reviewed ecological science. Lastly, the DEIS fails to credibly substantiate a sound scientific foundation for 

the two similarly founded developed action alternatives, in violation of the NEPA.

Response: The alternatives are designed to meet the purpose and need described on pages 4-5 of the 

FEIS. The actions proposed in each alternative are based on current knowledge of ponderosa pine 

management and designed in such a way as to provide the platform for the research questions posed in the 

Study Plan.

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The DEIS fails to meaningfully incorporate utilizing scientifically recommended strategically placed land area 

treatments – SPLATS (or SPOTS, etc.). Without fully analyzing an alternative that minimizes the extent of 

acreage manipulated by management actions, and thereby save limited resources while protecting natural 

habitat, the Forest Service and the public will never fully know how the ecological objectives of the project 

actions could be attained without widespread commercial logging. (#26)

Response: The use of SPOTs (Treatment Optimization) is discussed in the FEIS p. 36. Strategicallyplaced fuels reduction units would serve to provide limited protection to portions of the experimental 

forest that fall outside the study area and would not address issues of bark beetle-caused mortality. 

However, the purpose of the EXF project is to reduce competition within the Experimental Forest across 

large areas. There are limitations to the concept of SPOTS, particularly as it relates to smaller pieces of 

the overall landscape. It is more appropriate when attempting to limit large fire growth and in areas where 

treatment opportunities are limited to a relatively low percent of the landscape. 

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The DEIS should consider more alternatives such as: 

doing this research in stands that are more representative of the type of stands that are over-representative 

compared to the historic range and more in need of treatment to reduce fuels.

focusing fuels treatments here on surface and small ladder fuels;

alternative methods of break up fuel continuity such as by isolating groups of 3-50 trees, instead of individual 

tree canopies. This would retain more benefits of mature forest cover for wildlife, carbon storage, and 

favorable microclimate.
Appendix F Response to Public Comment

EXF Final EIS Page 16 of 88

There are also alternative ways to “protect existing research” other than logging 2500 acres of surrounding 

forest. The EIS should have considered treatments in the immediate vicinity of the existing research plots. 

(#27)

Response: These comments have been addressed in previous responses regarding alternatives not 

considered in detail.

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EFFECTS ANALYSIS 

Basal area may be a weak measure of resource demand (and potential tree stress) in mature forests, because a 

lot of the basal area is non-conducting, non-living wood. A better measure might be surface area of live 

cambium. (#27) 

Response: There are many potential surrogates for resource demand. The Study Plan and the FEIS state 

that actual stand dynamics will be emphasized.

Basal area, discussed on p. 74, is used to convey the idea that with increasing reductions in basal area, the 

amount of water and nutrients available to trees will increase. In general terms, tree vigor can be expected 

to improve as the number of trees per acre is reduced. Measures used in the EXF analysis to measure 

resource demand and potential tree stress are: tree diameter growth rates (discussed on pp. 70-71), Stand 

Density Index (discussed p. 71), and live crown ratio (discussed p. 71). As pointed out in the EIS, current 

conditions as measured by these factors indicate overstocked, low vigor stands which are not sustainable.

Basal area and SDI are used in the analysis to measure tree density; live crown ratios and diameter growth 

are used in the analysis to measure tree vigor.

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The effects of beetle outbreaks are over-stated. (#27)

Response: The role of beetles and insects is discussed on pp. 75-76, 86-87. It’s not clear how the 

predicted effects of a bark beetle outbreak have been over-stated.

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The DEIS does not adequately disclose both direct and cumulative effects. Direct effects along with 

widespread cumulative impacts from past, recent, and ongoing logging and other management projects 

throughout the forest, need to be assessed at a landscape-scale to provide any meaningful assessment of the 

relationship of these proposed “treatments” to accomplish the purpose and need, and the likely impact of 

direct and cumulative actions upon the environment. (#26)

Response: Cumulative effects are discussed in the FEIS pp. 41-44 and throughout Chapter 3. For most 

resources, the landscape-scale is defined as the two sixth-field or fifth-field watersheds within which the 

project area lies (Figure 9, p. 445).

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The DEIS Fails to Disclose Readily Available Science That Counters the Claim that the Developed Action 

Alternatives Will Meet the Stated Purpose and Need. (#26)

Response: This comment lacks specificity. The respondent has not provided science that specifically 

counters the project’s predicted effects as disclosed in the FEIS. The IDT has reviewed and addressed 

claims of scientific controversy (see below).

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The requirements of the NEPA mandate projects such as EXF are well-founded on expert advice, scientific 

research, and accurate site-specific conditions. The EXF Project DEIS significantly fails the requirements of a 

legally compliant forest resiliency and fire risk/severity reduction project. (#26)

Response: Site-specific conditions have been assessed across the project area by surveying for habitat 

and species, utilizing high-quality satellite data and aerial photography, and gathering extensive plot data 

on the ground. The scientific basis for thinning and reducing fuels is described in the FEIS (see pp. 4, 85-

87, 102-103). The disclosure of anticipated environmental effects is based on existing knowledge built
Appendix F Response to Public Comments

 EXF Final EIS Page 17 of 88

through scientific research and the project itself will be the basis for scientific research and further 

building of knowledge. 

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The DEIS fails to reasonably substantiate its premise that it will somehow modify the chances that fire, insects, 

and disease will negatively alter the mid- to high-elevation ponderosa pine and mixed conifer forests, or to 

provide scientifically credible objective evidence of other projects that have accomplished this goal, despite the 

abundance of such projects across the interior Columbia Basin forest landscape. (#26)

Response: Conclusions are based on the best available science. See, for examples, p. 76, “Thinning has 

been shown to reduce the amount of ponderosa pine mortality caused by mountain pine beetle unless 

surrounding areas are allowed to develop epidemic population levels (Fettig et al. 2007);” p. 86, “In 

central Oregon, the most widely used standard for gauging bark beetle hazard is derived from the work of 

P.H. Cochran (1992, 1994). Cochran (1992) and Cochran and others (1994) have developed stocking 

density guidelines from which we can generally predict the risk of bark beetle attack for a number of tree 

species in central Oregon;” and p. 108, “Treatments that reduce surface fuel loads have been shown to 

decrease fire behavior and severity (Graham et al. 1999; Pollet and Omi 1999).” 

-------------------------------------------------------------------------------------------------------------------------

The DEIS fails to objectively disclose the actual results and impacts of similarly premised and 

located logging projects, both within the Deschutes National Forest, and elsewhere in the interior 

Northwest. (#26)

Response: NEPA requires the analysis and disclosure of the expected effects of the proposed action and 

alternatives. The FEIS provides this and the conclusions are based on scientific literature, expertise, and 

experience gained with similar projects that have been implemented in the area. Additionally, the Study 

Plan presents expected results in the form of hypotheses that will be evaluated through the research 

because the effects of similarly-premised actions are not precisely known.

-------------------------------------------------------------------------------------------------------------------------

The purported positive effect to the forest will happen over time, which given the time required for 

forest structure and cycles to return to natural range levels could be greater than two or more 

decades.

The analysis does not discuss how this project will facilitate a return of the area’s forests to a range 

of natural variability that is self-resilient over the long-term of time.

Response: For the stands that are thinned the heaviest, it may be 150 years before the stand density 

reaches a point where there is the threat of widespread bark beetle mortality (FEIS p. 93); however, 

facilitating “a return of the area’s forests to a range of natural variability that is self-resilient over the longterm” was not identified as a purpose and need in the EIS. The proposed study is designed to answer 

several research questions and the results can then be used to determine appropriate methods to achieve 

this in other areas where the management goals and objectives include restoration to long-term resilience 

within the range of natural variability. 

-------------------------------------------------------------------------------------------------------------------------

The Forest Service never presents credible science showing that wildlife habitat and biodiversity is 

benefited in the future by destroying habitat in the present. (#26)

Response: The FEIS discloses effects to forested vegetation and the habitat it provides to wildlife. Some 

species’ habitat benefits, for other species its habitat is degraded. Some species will likely benefit because 

the quality of the habitat improves or more is available while some species will likely experience at least 

short-term declines in habitat quality or availability. Scientific references are included in the text 

throughout the wildlife analyses.

-------------------------------------------------------------------------------------------------------------------------

Part of the inferred purpose and need of the project is to meet the land designation for the area 

which is set aside as forest that will provide for LOS NRF and focal species wildlife habitat. 

However, the project does the exact opposite.
Appendix F Response to Public Comment

EXF Final EIS Page 18 of 88

Response: The project area management allocation is Experimental Forest, which is an area for field 

research activities (FEIS p. 11). The portion of the Experimental Forest that is overlain by the Late 

Successional Reserve allocation also does not currently provide NRF (FEIS pp. 8, 46, 57-61).

-------------------------------------------------------------------------------------------------------------------------

The DEIS fails to acknowledge and discuss the high level of uncertainty with respect to the long-term 

ecological consequences of this management prescription for LOS stands, particularly given that 

most surrounding forest areas are deficient in multi-story old growth. (#26)

What remains unconvincing is whether logging in LOS stands is the appropriate solution, 

particularly when such forest types are lacking throughout the area forests. However, this 

conclusion lacks substantiation in the DEIS. (#26)

Response: The HRV for the watersheds shows that the mid-seral structural stages are above HRV and 

most thinning will occur in these stages. Thinning from below removes the smallest trees first, and leaves 

the largest trees to make up the basal area. For the EXF project area, this means that the largest trees 

remain and are better able to survive for centuries. This large tree structure is what is limiting and takes 

the longest time to create. Effects from thinning are described for the areas that currently meet criteria for 

LOS or LSOG (FEIS pp. 95-96). 

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The DEIS does not disclose the adverse consequences of doing a more ecologically motivated project that 

focused on retaining all large trees, and use of variable density thinning techniques with skips and gaps 

instead of a uniform basal area target across large homogenous harvest units. This homogenization is shown 

in Figure 16 on page 92, but the ecological effects of this is not discussed in the DEIS. (#27)

Response: Figure 16 of the DEIS is now Figure 24, p. 116 of the FEIS. It does not show the variability 

within stands in the project area. As stated on pages 102-103and shown in Figure 22, there currently 

exists a potential for passive crown fire across nearly half of the area. Figure 24 displays the resulting 

reduction in crown fire potential after thinning through a reduction in canopy base height, crown bulk 

density, crown class, and change in surface fuel model. Thinning prescriptions were developed to provide 

different levels of fuel reduction. A single prescription will be applied across each treatment unit. 

Existing gaps will be fully incorporated into the marking by focusing on tree size and species rather than 

spacing. Thus the natural distribution of the large trees will be fully retained. 

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The DEIS fails to adequately disclose the abundant scientific research that recommends strongly against the 

proposed logging in mixed conifer, mixed fire severity forest ecosystems for “resiliency” or “fuels reduction” 

rationales, nor does the DEIS present credible scientific research supporting such logging. (#26)

Response: The Forest Service acknowledges that there is on-going scientific debate about the nature of 

“mixed conifer” and “mixed severity” terms. The FEIS (p. 77-78) indicates that various portions of the 

study area differ with respect to the presence of tree species other than ponderosa pine. Plant association 

groups, based on tree and undergrowth species, all indicate a dominance of ponderosa pine. Field work 

leading to study plan development indicated a dominance of ponderosa pine. The proposed treatments 

were designed to feature for retention ponderosa pine. Mixed severity fire regimes are defined as those in 

which fire kills between 30 and 70% of the overstory. This fire regime is transition between low severity 

fire regimes where fuel reduction actions can effectively reduce fire hazard, and high severity fire regimes 

where climate-driven fires occur regardless of any fuel reduction treatments. Further, characterization of a 

site as “mixed severity” does not necessarily indicate if fuel treatments would affect fire behavior.

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EFFECTS ANALYSIS – FUEL REDUCTION / FIRE BEHAVIOR

Human activity in the area, including thinning and fuels reduction is likely to increase fire occurrence, if 

anything. (#25)

Response: Thinning, mowing, and underburning are expected to reduce fire behavior (FEIS pp. 107-124)

and slash will be treated as necessary. Certain precautions are taken when there is a fire occurrence 
Appendix F Response to Public Comments

 EXF Final EIS Page 19 of 88

concern during operations, such as fire watches, on-site suppression equipment, and operation shutdowns. 

Closing the primary access road into the Experimental Forest with a gate is likely to actually reduce the 

risk of human-caused fire occurrence in the area.

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In the East/West CWPP we identified major travel routes from recreation areas along the Cascade Lakes 

Highway that would serve as evacuation routes in the case of a major wildland fire event. Roads 4240, 4040 

and 4250 were specifically identified in the CWPP to conduct fuels reduction along each road to provide a 

margin of safety for both public and wildland responders. The proposed treatments will satisfy this 

recommendation. (#29)

Response: It should be noted that the intersection of 4240 and 4040 lies within Unit 35 which is a control 

unit – no treatment will occur there at this time. However, Unit 40 does include fuels reduction along the 

4040 road. 

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The proposed project is either inside or in the close proximity of three Community Wildfire Protection Plans 

(East/West, Upper Deschutes River, and Greater La Pine). In each case emphasis was placed on treatment of 

public lands either near evacuation routes or communities. In this particular case the community of Fall River 

Estates is immediately north west from the project area and based on previous large fire growth projections 

would certainly be adversely impacted by a large fire either originating from or burning through the project 

area, the proposed actions meet the standards identified in the CWPPs. (#29)

Response: The fire/fuels analysis indicates that lower flame lengths and reduced potential for passive 

crown fire will improve suppression capabilities in the event of a wildfire and reduction in fuels will lower 

susceptibility to uncharacteristic wildfire across the landscape.

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I object to prescribed burning which can cause lung cancer, heart attacks, strokes, asthma, allergies, and 

pneumonia among other fatal issues for Americans. (#1)

Response: Although smoke can pose a health hazard (FEIS pp. 244-245), prescribed burning operations in 

the Forest Service adhere to strict regulations to achieve compliance with all aspects of the Clean Air Act. 

Burning is only conducted when prevailing and predicted wind patterns would result in negligible effects to 

LaPine, Sunriver, Bend, and the Three Sisters Wilderness Class 1 airshed.

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The EXF DEIS does not adequately reveal the scientific uncertainty and controversy surrounding the idea that 

commercial logging can reduce the risk of fire. (#26)

It is small trees and brush – when present in excess of the natural range of variability due to past loggingcreated openings - not large trees, which contribute to fire spread, intensity, and severity. Thus, large, old and 

mature characteristic trees, regardless of diameter or condition, should be protected when efforts are made to 

decrease wildland fire risk. (#26)

Cutting large, old-growth and mature trees will not make this area more “fire-safe” – in fact, cutting large 

trees will increase fire risk in this area, as the large, old trees are the most fire-resistant component of the 

forest. (#26)

Openings resulting from commercial logging would grow in with dense fire prone brush and young trees 

within a relatively short period of time. Each time old fire resistant trees are removed, the additional openings 

fill in with more fire prone small trees, increasing fire risk throughout the area’s forests. (#26)

Oregon Wild supports use of prescribed fire, and, if necessary, careful thinning and removal of small diameter 

material and flammable brush in ecologically appropriate locations in order to help restore fire regimes. We 

urge the agency to avoid road building and prioritize such activities in the wildland-urban interface. (#27)

The fire/fuels analysis starts with an admonition from Agee (p 83) to retain large trees, but the DEIS does not 

reconcile this with the fact that here the plan is to remove 1/3 of the large trees. (#27)

Response: The trees that will be retained are the largest on site. Approximately two-thirds of the trees 

greater than or equal to 21” DBH are retained to meet the study objectives. Given that the forest is not a 
Appendix F Response to Public Comment

EXF Final EIS Page 20 of 88

static environment, brush and tree seedlings can be expected to become established over time following 

treatment. The FEIS predicts that brush will again reach its present level of site occupancy in 8 to 10 

years. In fact, one of the research questions as stated in the study plan is “How does the dominant shrub, 

giant chinquapin (Chrysolepis chrysolphylla), respond in the near-term to a set of fuel reduction 

treatments?” Young trees on these sites will grow an estimated 6” to 12” in height per year and can be 

expected to attain 10 to 20 feet in height within two decades. Additional future vegetation treatments to 

meet future objectives and the impacts of those treatments would need to be analyzed through NEPA.

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There is ample scientific controversy about whether mechanical fuels treatment reduces fire risk in the mid- to 

higher-elevation forests targeted by the EXF Project. Mature, old-growth stands have dense, moist interiors 

and little wind, which inhibit the spread of wildfire. (Morrison and Smith, 2005; Rhodes, 2007) (#26)

At the very least, the Forest Service must disclose and respond to the very lively scientific controversy about 

the role of mechanical fuels treatment in reducing the risk of fire in an EIS for this proposed project. See 

Declaration of Richard H. Waring, Declaration of Jonathan J. Rhodes. (#26)

Response: See the previous response on page 13. Thinned stands may have increases in surface winds 

relative to more closed stands and take longer to reach low fuel moistures than open sites. However, 

during summer months, fuel moistures in closed stands reach equilibrium with open sites relatively 

quickly and crown=driven wildfire are much easier initiated in closed stands. Small tree thinning, brush 

mowing, and underburning will reduce surface and ladder fuels enough to change fire behavior to 

substantially change fire behavior.

The declarations of Jonathan Rhodes and Richard Waring submitted by the Sierra Club are not comments 

specific to the EXF Project or the Experimental Forest. The Forest Service received comments from Dr. 

Richard Waring specific to the EXF Project (see comments #23).

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While Round Mountain Remote Access Weather fuel and weather conditions were used from nearby the project 

area, the conditions addressed are different than those found in the ecologically intact functioning old growth 

forests on Lookout Mountain. Additionally, the fire models employed do not utilize accurate site-specific data 

collected from sufficient on-the-ground field sampling. Instead, the models use remote sensing (satellite and 

aerial photo interpretation) of canopy closure as a proxy. (#26) 

The Forest Service fails to objectively and adequately disclose the short-comings of its fire models. (#26)

Response: The Round Mountain Remote Access Weather station is within 3 miles so it is actually a very 

good representative of the summer weather and fuel conditions for the project area (FEIS p. 102, 109). 

The FlamMap model is described in the FEIS, including assumptions and data used (FEIS pp. 102, 106, 

108-109).

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Loss of canopy cover will make the stand hotter, dryer, windier and could actually exacerbate fire effects and 

increase the level of damage to the forest canopy in the event of a fire. (#27)

The DEIS does not disclose the inadequacies of the science behind canopy fuel treatments. Most of the science 

was developed in boreal forest types with very difference canopy structure (tighter branch/needle architecture, 

and branches near the ground). (#27)

The DEIS is misleading in its analysis of canopy fuels. Treating canopy fuels is not necessary nor is it effective. 

Canopy fuels are help high above the ground where the are not at high risk of ignition. Canopy fuels help 

maintain a favorable microclimate that is more cool and moist, and less windy. Removing canopy fuels makes 

the stand hotter, dryer, and windier and increases fuel dryness, and is associated with increased canopy 

damage in subsequent wildfires. (#27)

Modeling shows that canopy fuel reduction is accomplished at the expense of increasing surface fire intensity. 

(#27) Scott, Joe. 2003. Canopy Fuel Treatment Standards for the Wildland-Urban Interface. USDA Forest 

Service Proceedings RMRS-P-29. 2003. http://www.fs.fed.us/rm/pubs/rmrs_p029/rmrs_p029_029_038.pdf

Calculations of crown bulk density (CBD) are oversimplified. Typical calculations of CBD “carries the 

implicit assumption that canopy biomass is distributed uniformly within the stand canopy, which is unlikely to 
Appendix F Response to Public Comments

 EXF Final EIS Page 21 of 88

be true even in stands with very simple structures; multi-storied stands are probably even more poorly 

represented by this procedure.” (NEXUS software help files). Canopy fuels are not uniform horizontally or 

vertically, so the risk of spreading crown fire may be over-estimated by these methods. Countryman, C.M. 

1955. Old-growth conversion also converts fire climate. Fire Control Notes 17(4): 15-19. (#27)

Studies have shown that thinned stands are warmer and windier than unthinned stands. Trevor D. 

Hindmarch and Mary L. Reid. Effects of Commercial Thinning on Bark Beetle Diversity and Abundance. 

PROJECT REPORT 1999-13. May 1999. http://sfm-1.biology.ualberta.ca/english/pubs/PDF/PR_1999-

13.pdf

We support efforts to limit the initiation and spread of crown fires through the reduction of fine surface fuels 

and (partial) treatment of ladder fuels to increase the crown base height, but we oppose efforts to heavily thin 

the overstory canopy in an effort control crown-to-crown fire spread. The most significant effect of this type of 

heavy thinning is to increase the warming and drying of ground fuels and to increase the growth of ladder 

fuels, both of which significantly detract of the risk reduction objectives and are expensive to treat. The NEPA 

analysis must address the complex effects of thinning including tendencies to reduce and increase fire hazard. 

(#27)

The NEPA document must address the fact that there is very little scientific support for aggressive thinning to 

reduce fire hazard. In fact, there is building scientific evidence that thinning can make the fuel hazard worse 

instead of better. (#27)

The NEPA document must acknowledge the paucity of scientific support for commercial logging to reduce 

fuels and reduce fire effects and fails to recognize that logging often increases fine fuel loads while removing 

the large logs that are relatively less prone to burn. Thinning also increases wind and light penetration of the 

canopy and causes fuels to dry out which make them more prone to burn and increases the time it takes woody 

material to decompose. Removing medium and large trees also removes shade and resource competition that 

helps suppress the growth of small trees and brush known as “ladder fuels.” (#27)

The NEPA document must acknowledge the paucity of scientific support for commercial logging to reduce 

fuels and reduce fire effects and fails to recognize that logging often increases fine fuel loads while removing 

the large logs that are relatively less prone to burn. (#27)

Logging very likely will have little effect on the severity or controllability of large intense canopy fires that are 

of most concern both environmentally and economically. If proposed logging has any effect it will likely lead to 

increased controllability of low intensity surface fires, but these lower intensity fires are precisely the fires that 

are beneficial ecologically and should probably not be controlled. So logging will help control fires which 

should remain wild and free, while logging will fail to control that which is most destructive. (#27)

It would be better to just do a controlled prescribed burn at the right time of year without logging. The EA 

should have considered such an alternative. (#27)

Response: Density reduction will reduce potential for passive crown fire. Proposed treatment emphasis 

is on a low thinning or thinning from below by starting with the smallest trees and accumulating basal area 

in the smallest trees first. This differs from treatments designed to create gaps in the canopy. The Study 

Plans calls for leaving basal area at 50, 75, or 100% upper management zone SDI. This reduction in basal 

area to at or below the upper management zone will reduce the risk of bark beetle mortality. The FEIS 

acknowledges the potential for changes in fire weather factors (p. 107), and these are accounted for in the 

Flammap model (FEIS p. 102).

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Based on Table 9, there have been fires in the EXF project area 165, 95, and 14 years ago. As Baker (2009) 

points out, not all of a given area is usually covered by each fire, so mean fire interval and fire rotation have to 

be calculated accordingly. These fires indicate that the EXF project area may not be outside its mean fire 

interval of 77 years. These cycles between fires are also well within historic fire intervals for the eastern 

Cascades calculated by Hanson et al (2009)....Fire risk is greatly overstated. (#26)

Response: The project area is primarily made up of ponderosa pine plant associations that generally fall 

within Fire Regime I where low-severity fires occur most frequently (FEIS pp. 87-88). Mixed severity 

fires also occur on occasion and large stand-replacing events are rare but do happen (as evidenced by the 
Appendix F Response to Public Comment

EXF Final EIS Page 22 of 88

stand-replacing fire that initiated the current stand structure at Lookout Mountain (FEIS p. 87-88). The

FEIS cites Bork (1984) for fire frequency information specific to the Lookout Mountain area of about 7 to 

38 years. The project area also falls within plant associations that (without human influence or 

intervention) were established and maintained with fire return interval of about 35-100 years and where 

stand-replacing fires also occurred but would be rare.

The cited paper by Hanson et al (2009) has been countered by Spies and 12 other authors, 2009. 

Underestimating risks to the Northern Spotted Owl in fire-prone forests: response to Hanson et al. Cons. 

Bio. 24: 330-333. The group of 13 authors shows that Hanson et al. 2009 conducted an analysis that was 

erroneous and deficient and did not support their conclusions. Furthermore, Hanson et al. 2009 showed a 

bias against active management by ignoring recent science and risk factors in dry forests that do not 

support their opinions.

Regardless, expected fire behavior is based on current stand conditions and the proposed thinning and 

fuels reductions are not meant to return the area to an historic fire interval, but to prevent a loss of the of 

the Experimental Forest to insects or severe fire and to provide an opportunity for learning through 

operational scale scientific research. 

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FFECTS ANALYSIS – ACTIVITY FUELS

At the time of the Davis Fire, large amounts of fuels from previous commercial thinning projects remained on 

the ground, escalating the severity of the fire in those areas. 

Response: It is not clear how this information is pertinent to this project. It should be noted that 

approximately 98 percent of the successful placement of control lines that ultimately determined the Davis 

wildfire perimeter consisted of areas that were thinned.

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The EXF project area is currently surrounded by a number of logging thinning projects that have left 

considerable quantities of fuels throughout the greater area. EXF proposes to add to these fire risk fuel levels, 

at least for the project’s duration and a number of years post project, dependent upon the timing and funding 

for fuel removal and/or burning completion. Burning itself also represents a very real risk of uncontrolled fire. 

(#26)

The DEIS projected timeline for the clean-up of slash created by logging may not be realized, resulting in 

increased fire risk for an indefinite period of time. The Forest Service fails to adequately analyze how slash 

can increase the risk of fire, or assess the potential for delays and deficiencies in slash and fuel treatments. 

(#26)

The DEIS also failed to address the increased fire risk to the area from thinning and logging slash and debris 

left in the forest post-project, or to provide for a reasonable removal timeline that ensures such slash is 

addressed within the short timeline this project would have limited affect on reducing fuels and fire risk. (#26)

Response: The FEIS discloses that because of whole tree yarding, there will be little activity slash (p. 19, 

114). Slash from small-tree thinning will be utilized when possible; but the potential for a lag time 

(typically 3 to 12 months) between small tree thinning and fuel treatments is disclosed in the FEIS (p. 

114).

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EFFECTS ANALYSIS - RECREATION

The EXF groves are located relatively close to Bend, and provide great value to individuals who seek solitude 

and quiet recreation. I have enjoyed the forests and rivers of the Deschutes National Forest several times, and 

logging in the EXF area would impact my enjoyment of the forest. (#25)

The EXF Project NEPA documentation failed completely to address issues of natural quiet, disclose this as a 

resource worth protecting, and modify alternatives or assess how planned logging and associated actions will 
Appendix F Response to Public Comments

 EXF Final EIS Page 23 of 88

affect natural quiet throughout the project area during the extensive duration of the EXF project 

implementation. (#26)

The new SEIS for the EXF Project must disclose the full extent and cumulative impacts to natural quiet and 

natural resources and amenities from the sequential spread of logging projects across nearly the entirety of the 

District’s forests. (#26)

Response: There are no developed recreation sites or trails in the project area (FEIS p. 10). The 

Experimental Forest is not managed for wilderness values but for field research activities (FEIS p. 11). 

There will be noise during operations, particularly from logging machinery and trucks. The impacts will 

be limited to the project area and haul routes and to the implementation timeframe which is expected to be 

take from 2 to 5 years. Access to these areas will be restricted during operations.

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EFFECTS ANALYSIS - WILDLIFE

The Forest Service fails to address cumulative impacts properly, and fails to provide any science showing that 

destroying viable mature and old mixed conifer and pine forest habitat in the present benefits the area’s many 

diverse forest species of concern in the future. (#26)

It is extremely important that project analysis address scientific research that indicates affected species of 

concern are not extirpated from forest habitat from natural wildfire – and comparatively assess scientific 

research that indicates these species are extirpated from forest habitat from commercial logging and thinning. 

(#26)

Response: The proposed activities are designed to protect and retain stands that currently contain trees 

that are about 160 years old. These stands, if managed for increased resiliency, have the potential to 

persist for another 400 years. The effects to wildlife from the thinning, mowing, and underburning are 

disclosed in the FEIS, including references to scientific research (NSO pp. 46-75, other wildlife pp. 124-

200).

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The USFS should have adequately addressed how further fragmentation of the planning area will affect lynx. 

(#26) 

The DEIS fails to adequately address potential impacts this project may have on squirrels, and ignores an 

important component of lynx diet. (#26)

The developed action alternatives would log connective mature and old forest habitat, resulting in significantly 

further reducing needed cover for wildlife, jeopardizing both lynx and their prey species viability across the 

area—in violation of the NEPA, NFMA, and the ESA. (#26)

Response: Prey is discussed for many species and connectivity is also addressed, but the Deschutes 

National Forest does not have habitat for lynx based on current habitat definitions. 

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Failing to adequately and accurately address the likely impacts to wolverine by the EXF project actions, given 

the large home ranges of these animals, and the possibility of wolverines in the project area, violates both 

NEPA and NFMA. (#26)

Response: The Biological Evaluation concluded that there would be no impact to wolverine, as there is 

very little wolverine habitat present (FEIS pp. 136-137) 

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The DEIS does not adequately consider the effects of the proposed project on American marten and Pacific 

fisher in the planning area...In this case, the Forest Service failed to accurately and adequately assess how the 

proposed timber sale(s) and road construction into mature and old forests, into connective and dispersal NRF 

old forest habitat will impact marten and fisher. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 24 of 88

Response: Pacific fisher and American marten are thoroughly addressed and impacts disclosed in the 

FEIS pp. 131-135 and 156-159, respectively. 

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The DEIS violates the NEPA by the lack of meaningful and accurate analysis, and requisite meaningful 

scientific disclosures and conclusions regarding eagles. (#26)

Response: The FEIS discloses that because of a lack of bald eagle habitat, prey, known territories, and 

distance to foraging, there would be no impact to bald eagle or their habitat (FEIS p. 126).

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...agency surveys must be conducted seasonally each year to determine the rotational patterns of Goshawks 

for the project and adjacent area forests. (#26)

Response: Goshawk surveys are described in the FEIS p. 150.

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The DEIS fails to adequately address impacts to [goshawk] such as how logging removal of forest canopy 

cover, and further fragmentation of the area’s forests, will affect adult and juvenile goshawks and other 

raptors, or other direct, indirect, or cumulative effects to goshawks and other raptor species. The EIS fails to 

adequately address impacts to Goshawk nesting areas, including sufficiently assessing historic nesting areas, 

within or adjacent to the proposed logging project. Similarly, the EIS fails to adequately address potential 

direct and cumulative impacts harms to existing raptor nests of other species in the area. (#26)

Response: Effects to goshawk are thoroughly discussed and impacts disclosed in the FEIS pp. 150-152.

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The EIS for this planned project fails to fully and adequately disclose the current population status and trends 

of native forest dependent Neotropical migrant and native avian species within the analysis area and adjacent 

forest. The project’s commercial old growth and mature forest logging would likely directly kill nesting and 

fledgling migratory birds. The project logging units would irreparably fragment migratory bird habitat. (#26)

Response: Migratory birds are addressed in the FEIS (white-headed woodpecker discussion begins on 

page 137 and other focal species starting on page 162). Depending on the priority habitat features 

associated with the focal species, the effects can be positive or negative.

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Among the many avian species experiencing population declines due to Forest Service logging projects are: 

band-tailed pigeon, rufous hummingbird, olive-sided flycatcher, winter wren, song sparrow, golden-crowned 

kinglet, pine siskin, solitary vireo, willow flycatcher, tree swallow, red-eyed vireo, yellow warbler, yellowbreasted chat, and others as well. This information was not adequately addressed in the EIS. (#26)

Response: Decline of some avian species is due to many factors, not solely “Forest Service logging 

projects.” The word “migratory” implies some species do not fulfill all their life cycle requirements in one 

place. Further, some impacts from thinning and underburning will benefit one species but not be good for 

another. The birds of conservation concerns are address in the FEIS on beginning on p. 143 including 

many of the species listed by the respondent.

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The USFS has on record a study by Brian Sharp (“Avian Population Trends in the Pacific Northwest” as cited 

above), which concludes that commercial logging in public forest lands in Oregon plays a significant role in 

the continuing population declines of several neotropical migrant bird species. The failure to disclose the full 

conclusions and implications of this study in the EIS is particularly egregious in that the study was done for 

Region 6 of the Forest Service specifically on Central and Eastern Oregon forests. (#26)

Response: See previous responses regarding migratory birds. The 1992 Brian Sharp citation has been 

reviewed by the Wildlife Biologist assigned to the EXF project. The research used empirical data from 

harvest practices in the 1960s on and concluded: “In summary, it is difficult to assess the relative 
Appendix F Response to Public Comments

 EXF Final EIS Page 25 of 88

importance of habitat alterations on breeding and wintering grounds to observed bird population changes 

in the region. At this stage, however, it appears safe to say that habitat changes on the fragmented forests 

of the Pacific Northwest are implicated in the observed population changes as much as, if not more so, 

than tropical reforestation.” The EXF project maintains connectivity between LOS and Old Growth MAs 

as required by the Eastside Screens (p. 196-198).

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The multiple mandates in NFMA and its implementing regulations requiring [MIS] population monitoring and 

surveying are not being even minimally met for the EXF project. (#26)

If the Forest Service is not monitoring MIS populations directly, please explain in detail the model the Forest 

Service is using to correlate populations and habitat. (#26)

Response: Management Indicator Species (MIS) are addressed according to the Deschutes Forest Plan as 

described on pp. 143-144.

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The DEIS fails to indicate substantive ongoing surveys, or comprehensive science, upon which it could 

reasonably base claims that the planning area is meeting 100% of the potential population for Pileated and 

other cavity excavators, as required by the amended Deschutes LRMP. (#26)

The DEIS fails to adequately address or fully disclose the project’s likely adverse impacts to cavity excavator 

species. (#26)

The DEIS fails to address and disclose the full habitat requirements of cavity excavator species dependent 

upon the project area. (#26)

Response: Habitat for cavity excavators are addressed in snag and GTR sections of the FEIS beginning on p. 

184; individual species are addressed throughout the wildlife section as Sensitive Species, Management 

Indicator Species, or Landbird Focal Species beginning on p. 124.

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The DEIS does not accurately disclose the adverse effects of the proposal:

The EIS misleadingly claims logging will benefit goshawk habitat, but logging will in fact reduce habitat 

complexity and dense forests favored by goshawks. (#27)

Response: Impacts to northern goshawk are disclosed in the FEIS pp. 150-154. It is disclosed that northern 

goshawk habitat will be reduced by both action alternatives.

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A recent review of the most accurate information on goshawk habitat selection confirms that goshawks select 

late successional forest structure (e.g. high canopy closure, large tree for forest type, canopy layering, 

abundant course woody debris). This review continues to support Reynolds’ 1992 recommendations to manage 

nest core areas and post-fledging areas for late successional forest characteristics.

This review also does not find support for a few of the assumptions underlying Reynolds’ 1992 management 

recommendations. 

(1) Goshawks are habitat generalists only in the sense of using forests with a variety of tree species, but they 

are not habitat generalists in terms of selecting forest structure. They disproportionately select for late 

successional forest. 

(2) Goshawks are not opportunistic foragers. Rather they appear to select for prey availability as determined 

by late successional forest structure.

(3) Goshawk are not limited by prey abundance. They select for prey availability, with absolute prey 

abundance being only a component of availability, late successional forest structure being an important 

determining factor.

Some relevant excerpts from this review include:
Appendix F Response to Public Comment

EXF Final EIS Page 26 of 88

Boal et al (2001) found that stands used by goshawks contained 1.6 to 2.4 km of down woody debris per 

hectare with an average diameter of 17-19 cm, depending on forest type, and Bloxton (2002) documented 

that goshawk kill sites has greater numbers of snags >12.5 cm dbh/ha (u=77) than random sites.

... the consistency of results in demonstrates goshawk selection for late successional forest structures (e.g. 

high canopy closure, large tree for forest type, canopy layering, abundant course woody debris) when using 

areas within their studies home ranges. ...

...A majority of studies found selection for stands with >40% canopy closure and greater densities of trees 

over 40 cm dbh. ...

... goshawks may be broad habitat generalists in terms of tree species but are habitat specialists with respect 

to forest structure. ...

... prey abundance is not the most important factor is selecting foraging sites 

Several studies determined that goshawks select foraging habitat based not on prey abundance but rather prey 

availability as determined by habitat structure. ... [Recommendations focusing on increasing prey abundance 

at the expense of forest structure within occupied home ranges are not likely to improve goshawk occupancy 

rates.

goshawks avoided open areas, particularly logged open areas, and none found selection for openings. ... 

current information does not conclusively support a contention that creating openings through logging will 

benefit the goshawk. Given the history of clearcutting in much of the western United States range of the 

goshawk, we very much doubt that forest clearing are a limiting factor for the species.

Occupancy rates were reduced by removing forest cover in the home range...

We have no way of knowing assessing whether 40% of the landscape in mature and old-growth forests is 

sufficient to sustain goshawks. ... we recommend protecting existing mature and old-growth forest 

characteristics and ensuring that such forests are allowed to develop in proportions similar to pre-settlement 

conditions. This can be accomplished by restricting cutting to small trees and prohibiting large reductions in 

canopy closure. A similar proposal was recently adopted by Region 5 of the United States Forest Service for 

the Sierra Nevada.

Greenwald, Crocker-Bedford, Broberg, Suckling, and Tibbitts. 2005. A review of Northern 

goshawk habitat selection in the home range and implications for forest management in the 

western United States. Wildlife Society Bulletin 33(1):120-129.

Response: The FEIS acknowledges that goshawk tend to select mature or old-growth stands of confers 

for nesting (p. 150). Impacts to goshawk habitat are disclosed in the FEIS beginning on page 130. The 

analysis concludes that heavier thinning will remove potential nesting, fledging, and foraging habitat on 

381 acres and that goshawk may use thinned areas for fledging and foraging. The cited article by 

Greenwald et al article was fully addressed & many of the claims refuted by Reynolds et al 2008 -- Full 

citation: Richard T. Reynolds, Russell T. Graham, Douglas A. Boyce Jr. 2008 Northern Goshawk 

Habitat: an Intersection of Science, Management, and Conservation. Journal of Wildlife Management, 

72(4), pg(s) 1047–1055 http://www.bioone.org/doi/full/10.2193/2007-131.

In response to each point made in reference to Greenwald et al:

1) Ponderosa Pine Forest is the major forest type at Pringle Falls. Those trees grow in groups with 

openings between the groups. The 40% canopy cover is measured for the group (don't include openings) 

as specified in Reynolds et al. 1992. Also, the measurement is made using vertical crown projection and 

not made with a spherical densiometer. The terminology below refers to stands which typically includes 

many groups of trees. Measuring canopy cover for a stand would be inappropriate. Canopy cover 

requirements are designed to provide for squirrel habitat so that trees within the group have interlocking 

crowns allowing squirrels to move through the canopy.

2) Goshawks are habitat generalists, but they do select older trees with greater canopy cover for nest site 

locations--when available. North of the tree line in Alaska, however they nest in willows because trees are 

not available. I've also visited nests placed on small trees with 1 inch limbs supporting the nest, but the 

area surrounding the nest site was crawling with ground squirrels.
Appendix F Response to Public Comments

 EXF Final EIS Page 27 of 88

3) Goshawk nest sites and post-fledgling areas (PFA) should be managed according to Reynolds et al. 

1992. The foraging areas surrounding the nest sites are ecologically variable. That is why the canopy 

cover recommendation is relaxed for the foraging area.

4) Reynolds et al. (2008) responded to Greenwald et al. who were in error. Full citation: Richard T. 

Reynolds, Russell T. Graham, Douglas A. Boyce Jr. 2008 Northern Goshawk Habitat: an Intersection of 

Science, Management, and Conservation. Journal of Wildlife Management, 72(4), pg(s) 1047–1055 

http://www.bioone.org/doi/full/10.2193/2007-131

5) Goshawks are opportunistic short flight--short sit and wait hunters moving through the forest. They 

select medium-sized prey usually squirrels, rabbits and birds. As the abundance of any one prey species 

increases so does its presence in goshawk food remains. Growth of young trees (resulting from fire 

control) creates structure that obscures prey. Removing young trees improves forest health by reducing 

competition, protects older trees from catastrophic loss to fire by preventing the creation of fuel ladders, 

and makes prey more visible to hunting goshawks because the forest floor is opened up making squirrels 

and birds easier to detect. Landscapes are variable and prey production responds to the variation across 

the landscape. The suite of prey goshawks consume have forest structural habitat requirements that span 

the entire spectrum from openings to old forest character. Providing for a sustainable food web means 

having a mixture of structural conditions and habitat characteristics in the foraging area across the 

landscape. Managing for too much of one forest structural type may provide for short-term improvement 

of prey production (emphasizing old growth for example), but leads to long-term cyclic prey production 

(when old growth dies) that hurts creates a period of prey poverty for goshawks (large clear cuts are a 

management strategy that hurts goshawks and leads to this problem).

6) Goshawks are extremely limited by prey abundance. When prey are not abundant, goshawks do not 

nest. The adults will occupy the territory though feeding themselves. Late successional forest is very 

important for prey production, but must be present in proportion to the other structural stages to maintain a 

sustainable stable prey base.

7) Reynolds et al. 1992 habitat recommendations call for down woody debris and snags. These are 

important habitat elements for prey in the food web of goshawks.

8) Opening size recommended by Reynolds et al. 1992 is small. The clear-cuts referred to most likely are 

the very large cuts created during the latter half of the last century and is not what is being recommended 

by Reynolds et al. 1992. Small openings are beneficial to some of the prey typically captured by 

goshawks.

9) Reductions of large trees should be done with considerable attention to knowledge about the existing 

spatial pattern of structural stages within the foraging area. Developing this knowledge provides context 

for determining if there is a need to cut large trees or not. Restoring the spatial pattern of trees, that 

naturally occurs in a fire-prone ponderosa pine ecosystem, is an important goal to achieve. If old structure 

is limited across the landscape, removing it may be detrimental to goshawks or it could be beneficial 

depending on its spatial distribution in relationship to goshawk foraging areas, PFAs and nest sites.

10) Reducing canopy cover by cutting older trees generally doesn't achieve the goal of providing habitat 

for tree squirrels. Canopy cover reduction would be better achieved by removing younger trees and trees 

creating fuel ladders for ground fires to escape into the forest canopy.

-----------------------------------------------------------------------------------------------------------------------

The DEIS does not adequately disclose or address likely project impacts to focal species that also nest and 

fledge during the period that proposed implementation would occur, or to native and neotropical avian species 

in the vulnerable nesting and fledgling seasons. Similarly, the DEIS fails to address impacts to the prey species 

and foraging availability of affected avian and wildlife species during this vulnerable spring through early 

summer period. (#26)

Response: Implementation may impact nesting birds as disclosed throughout the wildlife section of the 

FEIS (pp. 124-199).

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Appendix F Response to Public Comment

EXF Final EIS Page 28 of 88

Without disclosing upon what scientific research its claim is based, the DEIS audaciously portends that its 

proposed logging and related actions would “protect existing habitat as well as aid in the development of 

new habitat” for pileated and white-headed woodpeckers, goshawk, and flammulated owls. (#26).

Response: The quoted text refers to thinning and fuels reduction within the Sheridan LSR (FEIS p. 66-

67). Protection of existing habitat because thinning and fuels reduction will reduce risk of a severe 

wildfire destroying habitat and (see fire/fuels discussion), and development of habitat for some of the focal 

indicator species in the area is expected because tree density will be reduced while the large ponderosa 

pine and co-dominant Douglas-fir will be retained and stand health improved. The FEIS discloses that 

treatment will not aid the development of new habitat for other species such as spotted owl and blackbacked woodpeckers.

-------------------------------------------------------------------------------------------------------------------------

Have there been any population studies for these MIS indicator species across the Sheridan LSR Management 

Strategy Areas, as required by NFMA? Ensuring species viability per NFMA requires population surveys 

identifying existing population, genders, reproductive success, and viability thresholds.

Response: The Forest Service has followed the Deschutes Management Plan direction, essentially using 

habitat as a proxy. Also, Management Indicator Species are used to represent the habitat requirements of 

all fish and wildlife species found within the analysis area. By managing habitat of indicator species, the 

other species associated with the same habitat would also benefit. The FEIS lists which species are 

analyzed and which are not because of a lack of habitat (Table 62, p. 145). In addition, species 

observations, nests, den sites, etc. are noted in the existing condition section regardless of whether surveys 

have been conducted or not, which contributes to the knowledge base. When surveying for a particular 

species it is quite common to have non-target species respond or fly in (i.e. other raptors) which are 

entered into the wildlife observation databases.

The Sheridan LSR was assessed following Northwest Forest Plan guidelines. Management Strategy Areas 

(MSA) were delineated based on habitat and focal species (see FEIS pp. 56-61 for a description of the 

habitat available in this portion of the LSR and the common indicator species).

EFFECTS ANALYSIS – NORTHERN SPOTTED OWL HABITAT

There should be no logging in: Spotted Owl nesting, roosting, and foraging habitat, or Late and Old

successional forest (LOS) that is currently below historic range of variability, or any trees over 21” in 

diameter (dbh). There is already a male Spotted Owl living in the EXF, and the entire EXF is prime habitat for 

future Spotted Owl nesting. This is because of the large amount of evenly spaced mature and old growth 

Ponderosa pine in the entire EXF area. (#2, 4, 6, 7, 9, 11, 12, 14-20, 22)

Response: The project area is not considered “prime habitat” for future spotted owl nesting. Spotted owl 

habitat quantity and quality are described in the FEIS pp. 48-49. No activities are proposed within any 

spotted owl territories; the majority of the existing territory lies entirely outside of the project area. The 

project area does not provide prime future habitat for spotted owl nesting because as discussed in the FEIS 

p. 62:

“Recovery Actions #6 and #7 include: “Identify, maintain, and restore dry forest (ponderosa pine, 

Douglas-fir, and dry grand fir plant association group) moist forests (moist grand fir, western hemlock, 

and Pacific silver fir) habitat-capable areas as spatially dynamic high-quality spotted owl habitat patches.” 

“Manage lands outside of high-quality habitat patches to restore ecological processes and functions and to 

reduce the potential for significant losses by stand replacement fires, insects, and disease.” Therefore, 

there is a need to balance the management for the spotted owl with other habitat conditions on the 

landscape. Where development of suitable spotted owl habitat best fits the landscape, additional measures 

will be incorporated to ensure that components of habitat are being managed for (i.e. prey species habitat 

requirements, dispersal, large trees, etc.). The proposed treatments are focused within plant associations 

not likely to produce high quality habitat and placing treatments that will help reduce the risk to existing 

patches of habitat outside of the experimental forest.”

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Appendix F Response to Public Comments

 EXF Final EIS Page 29 of 88

A recent Forest Service study on the populations and trends of the Spotted Owl shows that the decline of the 

spotted owl is largely due to the destruction of its habitat. Lint (2005). In light of this study, the Forest Service 

has an obligation to protect remaining habitat, especially within land allocations that are intended to provide 

such habitat. 

Response: The Biological Opinion states that the spotted owl was listed because of loss and adverse 

modification of suitable habitat as a result of timber harvesting and exacerbated by catastrophic events 

such as fire, volcanic eruption, and wind storms. The Administratively Withdrawn allocation may provide 

demographic support for spotted owls and provide for connectivity and dispersal between larger blocks of 

habitat in LSRs. The EXF project will have no impact to spotted owl suitable habitat within Late 

Successional Reserves or Critical Habitat.

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The 2008 Final Spotted Owl Recovery Plan is very clear that the nature of the fire-dominated eastside forests 

preclude “long-term persistence of any static habitat management areas.” (Page 14) 

Response: full quote from recovery plan: No MOCAs are identified in these Provinces [dry-forest 

landscape-management approach], given the assumption that the severe natural disturbance regime 

precludes long-term persistence of any static habitat management areas.

 In addition, the loss of owl habitat in the recent past to wildfires has been relatively high. “If recent trends 

persist, the area of older dense forests available to the spotted owl could decline dramatically over the next 

several decades...Thus, it is unlikely that designating spotted owl habitat reserves within fire-prone landscapes 

will be effective...” (Page 20). 

Response: This is the rationale for not identifying MOCAs in the dry forests.

Under “Restoration of fire tolerance,” the recovery plan states that the science panel recommends Agee’s 

summary of Fire Safe fuel treatment principles that include reducing surface fuels, increasing the height to live 

crowns, and decreasing crown density (Page 109).

Alternative 2 proposes treatments consistent with the recovery plan though some are in nesting, roosting, and 

foraging habitat. However, AFRC does not believe this is in contradiction to the recovery plan. What is 

proposed in Alternative 2 is consistent with the emphasis on “a combination of spotted owl habitat concerns 

and other ecological and management objectives including fuel reduction and modifying fire behavior.” (Page 

22) The recovery plan recommends that such treatments “should be strategically managed to reduce the risk 

of habitat loss due to high severity fire, diseases, and insects and to increase the resiliency and sustainability 

of spotted owl habitat. These treatments would be the most intensive fuel treatments at the stand scale. Some 

of these treatments could include owl habitat if it is deemed necessary.” (Page 20, emphasis added).

(#3)

Indeed one could make the case that without sound scientific research such as what is proposed with 

Alternative 2, we may never know how tolerant the spotted owl is to short-term and long-term changes in its 

habitat. (#3)

Response: Alternative 2 reflects the approved study. Although the Recovery Plan, as quoted by the 

commenter, alludes to a need to “know how tolerant the spotted owl is to short-term and long-term 

changes in its habitat,” especially in regards to dry forest ecosystems, the approved study plan does not 

identify such research goals, opportunities, or opportunities. That sort of study is not precluded, however. 

Part XV of the Lookout Mountain Study Plan entitled “Ancillary or related research opportunities” does 

not list a research opportunity that looks at spotted owl responses to habitat changes; but research is not 

limited to only the items in the list. 

-------------------------------------------------------------------------------------------------------------------------

The EXF Project Would Irreparably Degrade Spotted Owl NRF and LSR Habitat. (#26)

Response: Spotted owl NRF habitat will be affected on 211 acres in the Administratively Withdrawn 

allocation. No spotted owl NRF habitat is present in the LSR portion of the project area. The FEIS also 

points out that not only is the LSR portion overlapping the project area minimally providing any spotted 

owl habitat (no NRF, and 39 acres of dispersal habitat), but also this portion of the LSR is minimally 
Appendix F Response to Public Comment

EXF Final EIS Page 30 of 88

providing habitat for other LSR indicator species (FEIS p. 58-59). The effects to spotted owl habitat and 

LSR habitat are fully disclosed on pp. 63-75 of the FEIS. 

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The DEIS also discloses that 5 miles to the north of the project area is the home range circle for the Sheridan 

Mountain pair, which was first documented in 1989, with a single female last documented in 2006 (DEIS at 3-

46). The DEIS does not disclose if these past surveys were to protocol. (#26)

Response: Surveys to protocol standards in place at the time were conducted in 1989, 1990, 1993, 1995, 

and 2006. Site visits (i.e. visits to the location where a spotted owl call or individual had been observed) 

were conducted in 1991, 1992, 1996, 2007, and 2009. 

-------------------------------------------------------------------------------------------------------------------------

The DEIS concludes by acknowledging “loss of dispersal in conjunction with treatment around NRF habitat 

may discourage new pairs of owls becoming established and being able to rear young” – which is contrary to 

population recovery and habitat protection objectives for spotted owls. (#26)

Response: This rationale leads to a determination that the project “May Affect, will Likely Adversely 

Affect” spotted owls, which required formal consultation with the U.S. Fish and Wildlife Service. A 

Biological Opinion was received from the U.S. Fish and Wildlife Service (see FEIS p. 255 and Appendix 

F). The U.S. Fish and Wildlife Service reached a no jeopardy determination for the EXF Project for the 

following reasons: 

1) The Northwest Forest Plan provides a well-distributed set of reserves which protect suitable habitat 

across the range of the spotted owl. Suitable spotted owl habitat proposed for removal in the EXF 

project area is within the Administratively Withdrawn land allocation under the NWFP, which were 

intended to provide demographic support for spotted owls and provide for connectivity and dispersal 

between larger blocks of habitat in LSRs. The NWFP recognized the need for silvicultural 

management in the Eastern Oregon Cascades Province for the purpose of reducing the risk of standreplacing fires. The EXF Project is consistent with management guidelines within the NWFP in that a 

key purpose of the project is to improve the forest resiliency to large-scale disturbance events such as 

insect, disease, and fire that will lead to loss of late-successional forest across the landscape. The 

amount and location of the nesting, roosting, foraging and dispersal habitat proposed for removal in 

the EXF project will not significantly affect connectivity between LSRs or the ability of reserves to 

support conservation and recovery of the spotted owl as planned through the NWFP.

2) All spotted owl suitable habitat within the project area has been surveyed to protocol and all sites of 

occupation have been documented. No suitable habitat will be removed within spotted owl home 

ranges or core areas within the EXF project area. (Biological Opinion, pp. 51-52).

-------------------------------------------------------------------------------------------------------------------------

The proposed logging in fact degrades the habitat by decreasing the diversity of the NRF stands. LSR and 

NRF stands that are commercially thinned may never return to late-successional forests. (#26)

Response: The FEIS discloses the effects to 211 acres of NRF habitat. The thinning within the LSR (Unit 

33) would likely promote habitat conditions, specifically larger trees, for the common indicator species: 

pileated woodpecker, northern goshawk, white-headed woodpecker, and flammulated owl.

-------------------------------------------------------------------------------------------------------------------------

The DEIS states that Nesting, Roosting and Foraging (NRF) areas will no longer be suitable habitat for 

Spotted Owl in the short-term, but that in the long-term the habitat will be more protected. This claim is 

unsubstantiated by credible evidence and scientifically controversial. (#26)

Response: The DEIS did not make that statement. The conclusions made on Page 65 of the FEIS 

regarding effects to NRF habitat as a result of Alternative 2 state: “The effects of these activities within 

NRF habitat (i.e. degradation and removal of habitat) will adversely affect northern spotted owls by 

further limiting available habitat within the watersheds... The beneficial effects to spotted owl habitat 

from the reduced fuel loadings and thinning that retains Douglas-fir are secondary to the proposed 
Appendix F Response to Public Comments

 EXF Final EIS Page 31 of 88

research within the project area. The treatments may eventually promote better foraging and dispersal 

opportunities rather than nesting due to the increased health and spacing of the trees within the stand.”

-------------------------------------------------------------------------------------------------------------------------

The Forest Service fails to address adequately how the maintenance of the re-growth of underbrush will not 

undermine the return of the area of spotted owl habitat.... the life span of the northern spotted owl is typically 

no longer than 10 years. Given that the owls’ lifespan is significantly shorter than the time allowed for the 

forest to recover to NRF habitat, it is highly suspect that any owls would remain in the vicinity to return. 

(#26)

Response: An estimate of underbrush regrowth is given in the FEIS (p. 94). With no additional 

treatments, brush will reach its present level of site occupancy in 8 to 10 years. The Study Plan is 

designed to address questions on shrub dynamics because there is a recognized gap in our knowledge for 

some species and hypothesizes that more open residual stand will have heavier shrub ingrowth. The FEIS 

acknowledges that the project is not designed to develop spotted owl NRF habitat, but that dispersal 

habitat will continue to be available in the long term.

-------------------------------------------------------------------------------------------------------------------------

The project will have significant adverse effects on spotted owls and those effects are avoidable by focusing 

fuel treatments on smaller-younger trees. 221 acres of NRF would be logged, and many more acres of foraging 

habitat would be logged adversely affecting the recruitment of dead wood and development of complex 

structure that would be expected in the absence of logging. (#27)

Response: The amount of NRF that would be thinned through is 211, not 221. Ten acres are located with 

a control unit. These dead wood habitat components are addressed in the FEIS Snag/CWD/GTR section 

beginning on p. 164.

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The DEIS has a misleading analysis of spotted owl effects by implying that owl foraging happens only in 

nesting/roosting habitat, and that dispersing owls do not seek foraging opportunities, so minimum dispersal 

habitat is good enough. The EIS needs to consider that unthinned stands will develop complex habitat that 

provides both dispersal and foraging, and that logging these stands will significantly reduce recruitment of 

complex forest structure and limit the development of high quality dispersal/foraging habitat. There is no 

bright line where foraging occurs with nesting but not with dispersal. Foraging habitat is enhanced by dead 

wood that recruits in dense stands that are experiencing mortality. Logging is adverse to this process. (#27)

Both alternatives would reduce potential foraging habitat even if NRF and LSR habitat are protected under 

Alternative 3.

Response: Foraging habitat is addressed as part of the Key Issue analysis starting on p. 46 of the FEIS. 

At the request of the USFWS, the Biological Assessment was updated to assert the foraging and dispersal 

function of stands that may not have nesting characteristics, and also display spatially the amount of 

dispersal habitat within the watersheds. The FEIS does not make the conclusion that minimum dispersal 

habitat is “good enough.” Effects of the proposed actions on dispersal habitat are disclosed on page 65-66 

and 71 of the FEIS. On page 66 of the FEIS the conclusion is that the removal of dispersal habitat as a 

result of the proposed actions would not cause a barrier to movement. The conclusion is also that the 

proposed actions “may affect, would likely adversely affect” spotted owls because of the degradation of 

dispersal habitat and the removal of nesting, roosting and foraging habitat.

-------------------------------------------------------------------------------------------------------------------------

Given the invasion of the barred owl and the increased competition faced by the spotted owl, the FS needs to 

provide more and better owl habitat in order to increase the chances that the two owls can co-exist. The DEIS 

did not disclose that capturing mortality and reducing the recruitment of complex forest habitat will eliminate 

owl habitat and reduce the chances that spotted owls and barred owls can coexist. (#27)

The book "Signs of Life: How Complexity Pervades Biology" by Sole and Goodwin has an interesting 

discussion that immediately brings to mind the barred owl/spotted owl issue.
Appendix F Response to Public Comment

EXF Final EIS Page 32 of 88

Response: Discussion of barred owls, as they relate to the proposed action effects on spotted owls, can be 

found on pages 70 and 74.

-------------------------------------------------------------------------------------------------------------------------

New information on the Threatened northern spotted owl indicates that there are significant new uncertainties 

for the owl that have not been fully considered at the regional or local scale. As recognized by the spotted owl 

status review, all existing suitable habitat could be critical to the survival of the spotted owl. U.S. FISH & 

WILDLIFE SERVICE SCIENTIFIC REVIEW PANEL FOR THE NORTHERN SPOTTED OWL. . June 22, 

2004 PUBLIC HEARING. WASHINGTON STATE UNIVERSITY, VANCOUVER CAMPUS. TRANSCRIPT OF 

PROCEEDINGS, page 121. http://www.sei.org/owl/meetings/minutes/june-meeting-transcripts.pdf

Most scientists do agree that conservation of existing suitable habitat and restoration of unsuitable habitat 

is essential for long term persistence of the owl. These topics are also covered in the Biological Opinion.

• Competition and displacement from the barred owl which is dramatically increasing in numbers 

throughout the range of the spotted owl: Barred owls have not been detected or observed in the

project area (FEIS p. 70, 74). Barred owl interaction with spotted owls in regards to habitat 

occupancy was part of the conclusion (DEIS p. 58). 

• The effects of West Nile Virus which is fatal to the spotted owl: There are no documented cases of 

west Nile virus in wild populations (Recovery Plan). Effects of the virus spreading to spotted owl 

populations is beyond the scope of the EXF project.

• Avian malaria that was recently discovered in spotted owls: The effects of avian malaria is outside 

the scope of the EXF project.

• The potential loss of habitat from Sudden Oak Death syndrome: Sudden oak death syndrome has no 

host species located in the project area that would facilitate its establishment and spread.

• The potential effect of climate change in terms of longer fire seasons; larger and more intense fires; 

increased tree mortality from fire, insects, and drought stress, consequently altered regional 

vegetation patterns and climate patterns; and uncertainty whether suitable habitat can be regrown 

from altered young stands in an altered climate regime: Ponderosa pine, the dominant species in the 

project area, is well-adapted to warm dry growing seasons. Vegetation dynamics under a changing 

climate regime will be addressed with the study plan, but not how it relates to spotted owls.

• Overly Aggressive Fuel Reduction Logging and Misapplication of the Healthy Forest Initiative and 

Healthy Forest Restoration Act: The SEI report acknowledges that fuel treatments can have impacts 

to owls. 

• Fuel reduction objectives conflict with owl habitat objectives. Where this is the case, it has been 

disclosed in the effects analysis.

• The 9th Circuit ruled in Gifford Pinchot Task Force v. USFWS, 378 F.3d at 1062, that avoiding 

jeopardy is not enough, that critical habitat is intended for recovery: The project area does not 

include any Critical Habitat.

• There has also been a continuous loss of suitable owl habitat on non-federal lands that should be 

considered as a cumulative impact on the viability of the species: There is no suitable spotted owl 

habitat on private lands within the area of cumulative effects analysis. 

• Fragmentation has gotten worse not better since the NWFP was adopted.: New counterpart 

consultation regulations allow the action agencies to bypass FWS’ regulatory oversight and selfconsult: Counterpart Regulations were not used in this project. Formal consultation, as described in 

the Endangered Species Act has been applied.

A recent presentation by the FWS to the Willamette Province Advisory Committee discussed “implications” of 

the 5-year status review. (Jim Thrailkill FWS Presentation to the Willamette PAC. December 9, 2004.) This 

information was incorporated into the BO which cited the 2008 Recovery Plan. The referenced presentation 

does not provide any science that counters that used in the EXF FEIS.

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Appendix F Response to Public Comments

 EXF Final EIS Page 33 of 88

All activity that could disturb nesting should be deferred during the spotted owl breeding season March 1st –

Sept. 30th. 

Response: This is addressed with a project design feature, FEIS p. 29.

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There should be no logging or burning in the spotted owl dispersal corridor running through the EXF project 

area as these corridors already “encompassed the best habitat currently meeting these [late seral] 

characteristics....

Response: Dispersal corridors are addressed in the FEIS pp. 53-56. Effects are disclosed p. 65

-------------------------------------------------------------------------------------------------------------------------

There should be no logging or burning degrading or eliminating northern spotted owl habitat within the 

Sheridan (or any other) LSR.

Response: This issue became a key issue that drove the development of Alternative 3 (FEIS p. 8). The 

LSR is addressed in the FEIS pp. 56-61, 66-67, 72. There is no spotted owl nesting, roosting, foraging 

habitat within the LSR portion of the Experimental Forest. There is 39 acres of dispersal habitat that will 

treated which will continue to function as dispersal habitat following treatments. Treatments under 

Alternative 2 will meet the objectives outlined in the LSR Assessment. 

-------------------------------------------------------------------------------------------------------------------------

The No Action alternative is obviously better for spotted owls because it would not only retain existing suitable 

habitat but also likely develop more suitable habitat in the mixed conifer areas. Yet the EIS fails to admit that 

true firs developing would increase canopy cover and owl security, that large Douglas-firs already exist, and 

that the Three Trappers Buttes spotted owls are using the kind of habitat that would likely develop in some 

parts of the EXF area.

Response: A comparison of the alternatives is provided on page 74. The effects of No Action state: “In 

the short-term, the current levels of NRF habitat (i.e. 221 acres within the project area which includes the 

10 acres within control units) would remain, but in the long-term there would be little to no development 

of ponderosa pine and Douglas-fir forests across the area because these are early seral species that would 

die out as true firs develop into the understory (see Silvicultural Report). The habitat currently used by the 

Three Trappers Butte owls is an inclusion of large diameter Douglas-fir and true fir surrounded by 

lodgepole pine. It is apparent that the stand is a remnant that survived wildfires in the past. With current 

fuel loadings in the area, it is uncertain whether a stand such as this would survive a future wildfire with 

the possibility that future spotted owl habitat may become even more limited. This has been illustrated on 

the Deschutes National Forest in 2003 with a loss of nearly 15,000 acres of suitable habitat (i.e. NRF 

habitat) across the forest (Programmatic BA; USFWS Biological Opinion Jan 2010).

It is not necessarily the case that spotted owl habitat within the EXF area would be difficult to sustain.

Response: The Forested Vegetation section describes the current condition of the area and the expected 

outcome of the No Action alternative; the conditions are considered unsustainable (FEIS pp. 85-87). 

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The DEIS fails to disclose the criteria and site-specific methods used to determine whether the project actions 

would degrade NRF, dispersal, and connective habitat, or to adequately address scientific controversy and 

cumulative impacts issues in relation to these determinations. (#26)

Response: The identification of spotted owl NRF is described in the FEIS pp. 48-49 and Appendix E, as 

well as within the Biological Assessment and Biological Opinion. When project activities cause stands to 

no longer meet the criteria of NRF, dispersal, or connective habitat, it has been disclosed in the effects 

analysis.

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Appendix F Response to Public Comment

EXF Final EIS Page 34 of 88

EFFECTS ANALYSIS - SOILS

The EIS provides a detailed analysis of practices proposed to reduce disturbance to the soil. The work of Dr. 

Jane Smith, presented at the [2009 Dry Forest] workshop on the implications of piling and burning slash 

should be expanded to consider the effects of mowing on below-ground microbial populations. (#23)

Response: Local monitoring has shown that the physical effects of soil disturbance from mowing activities 

do not meet the criteria for detrimental soil conditions (FEIS p. 204). 

We acknowledge the value of continued research regarding the effects of management activities on the 

biological properties of soil. Within the Forest Service, only the research branch can conduct scientific 

research. The EXF project will create opportunities for research that can be tied to or overlaid on the study 

plan “Forest Dynamics After Thinning and Fuel Reduction in Dry Forests.” 

-------------------------------------------------------------------------------------------------------------------------

The Forest Service states that this project will reduce fire risk and restore forest resiliency but the agency does 

not fairly consider the importance of protecting soils to accomplishing these project goals.... Current plans 

that permit the use of heavy logging machinery for thinning must be changed, with provisions mandating the 

use of light-on-the-land machinery instead. (#26)

...the agency should take into account how much the soil declines when trees are harvested. (#26)

Response: The combined effects of current soil disturbances and those predicted from implementation of 

the proposed management activities were addressed in the Environmental Consequences section (FEIS, 

pp. 207-223). Table 79 (Alternative 2) and Table 80 (Alternative 3) display quantitative, unit-specific 

information that shows the predicted amounts of detrimental soil conditions before and after 

implementation of the mechanical harvest and subsoiling mitigation treatments (FEIS, pp. 214-215). The 

project design features, mitigation measures, and Best Management Practices (BMPs) listed for the soil 

resource (FEIS, pp. 26-29) are all designed to minimize, avoid or reduce potentially adverse impacts from 

ground-disturbing management activities. Operational guidelines for equipment use provide options for 

limiting the amount of surface area covered by logging facilities and reducing the potential for detrimental 

soil disturbances in random locations of activity areas. 

Consequently, the overall effects to soils from the action alternatives combined with all past, present, and 

reasonably foreseeable management activities comply with Regional policy (FSM 2520, R-6 Supplement 

No. 2500-98-1) and LRMP interpretations for Standards and Guidelines SL-3 and SL-4 for planning and 

implementing management practices in previously managed areas (FEIS, p. 223). 

-------------------------------------------------------------------------------------------------------------------------

Burning large piles sterilizes forest soils beneath them, taking many years for affected areas to begin to 

recover. The DEIS failed to sufficiently address the harmful impacts of the planned burning of slash piles –

especially if economic trends do not allow the removal of logging generated slash. (#26)

Response: The effects of slash disposal and fuel reduction treatments to the soil resource are addressed in 

the FEIS on pages 211-212, 218-219. Burning large concentrations of machine-piled logging slash on 

landing decks and/or main skid trails would cause severely burned soil because heat is concentrated in a 

localized area. However, this would not result in a net increase in detrimental soil conditions because 

burning would occur on previously disturbed sites. Therefore, there would be no cumulative increase 

from the predicted amount of detrimentally disturbed soil following the mechanical harvest and yarding 

activities (FEIS, Tables 79, 80, and 81). 

-------------------------------------------------------------------------------------------------------------------------

The DEIS failed to sufficiently recognize the importance of mycorrhizal fungi on forest growth and 

productivity. The EIS failed to adequately discuss how mycorrhizae will be impacted by the planned logging 

project. The EIS failed to sufficiently assess how logging has affected mycorrhizae in areas nearby the analysis 

area. (#26)

Response: The FEIS acknowledges that mycorrhizal fungi and other soil organisms depend upon the 

continuing input of woody debris and fine organic matter for maintaining favorable biotic habitat (FEIS, 

page 206). Using mycorrhizal fungi as a bio-indicator of productive forest soils, research studies were 

used to develop conservative recommendations for leaving sufficient coarse woody debris following 
Appendix F Response to Public Comments

 EXF Final EIS Page 35 of 88

management activities (Graham et al. 1994, Brown et al. 2003). The proposed actions are expected to 

comply with project design features (FEIS, page 26-29) that ensure adequate retention of coarse woody 

debris and surface organic matter for biological activity and nutrient supplies for maintaining soil

productivity on treated sites.

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Use of low impact light equipment in appropriate areas is also not adequately addressed or incorporated in 

project actions. (#26)

Response: A discussion of the potential effects to soil properties from mechanical harvest and fuel 

reduction treatments are included in the section entitled Effects Common to Alternatives 2 and 3, 

Important Interactions (FEIS, pages 208-212). Operational guidelines for equipment use are included as 

resource protection measures to reduce the potential for detrimental soil disturbances in random locations 

of activity areas (FEIS, pages 26-29). 

Various references and Forest Service Manual direction were used as guidance to determine project design 

and mitigation needs for the EXF project. These information sources are based on the best available 

technical data, past monitoring of similar activities on representative soils, Forest Plan direction, and 

nationally and regionally approved soil quality standards and guidelines (FEIS, page 214-215).

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Whole tree yarding will remove lots of nutrients from the site because the canopy is where a lot of the nutrients 

(other than carbon) are stored. What are the implications? (#27)

Response: Commercial harvest and whole-tree yarding can affect soil productivity through the removal 

of future nutrients in the form of tree boles, limbs and branches. Existing down woody debris would be 

protected from disturbance and retained on site to the extent possible. It is expected that enough broken 

branches, unusable small-diameter trees, and other woody materials would likely be available after 

mechanical thinning activities to meet recommended guidelines for coarse woody debris retention (DEIS, 

pages 221).

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EFFECTS ANALYSIS - HYDROLOGY

At higher elevations on Lookout Mountain, where lodgepole pine is more prevalent, it may be necessary that 

more than three-quarters of the basal area and leaf area be removed to protect residual trees (Mitchell et al. 

1983, Waring and Pitman 1980 & 1985). Such an extreme thinning is likely to increase down-slope subsurface 

water flow, while at the same time reduce the duration of the snowpack. The hydrological implications of the 

proposed research deserve quantification along with the possible change in fire hazard. (#23)

Response: We agree that lodgepole pine stands at higher elevations on Lookout Mountain pose a risk of 

mortality resulting from bark beetles, and practices to protect these stands may include thinning to low 

densities. The total area supporting these lodgepole pine stands near the top of Lookout Mountain is 

relatively small, however, and is not the focus of this FEIS. Instead, the focus is on ponderosa pine. Stands 

dominated by lodgepole pine are not included within the project boundary, therefore the concern for 

downslope subsurface water flow is not considered an issue. Nevertheless, the FEIS includes a 

quantification of the potential impacts to the hydrology of the area and watershed (pp 226-228). The 

conclusion reached is that there would be no direct or indirect effects to water resources or riparian areas 

from either of the two action alternatives; and there would be no measurable changes in the flow regime of 

Fall River, including peak flows.

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DEIS failed to ensure project action provisions can effectively prevent adverse impacts to the area’s ground 

and spring water supplied aquatic systems (to which the slopes of Lookout Mountain contribute). (#26)

The EXF Project May Adversely Affect Water Flow Patterns and Downstream Redband Trout Populations and 

Habitat in Fall River. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 36 of 88

In this section, the DEIS essential claims that as the nearest riparian area is Fall River, located “over 1 mile 

away,” the project will have no effect on the ACS (DEIS at 190). However, the DEIS briefly discloses that Fall 

River is a spring fed, ground water system, and that “no measurable changes in the flow regime are 

anticipated in Fall River” (DEIS at 190). However, the DEIS fails to substantiate this claim with any evidence 

of where the source areas are for Fall River’s spring and ground water flows. (#26)

Proposed logging would open the forest to more solar exposure and wind, and compact fragment, and disturb 

soil hydrology resulting in decreased soil moisture infiltration and retention, and greater peak flow runoff. As 

Lookout Mountain is the largest closest proximity mountain to the upper reaches of Fall River, located just to 

the North-northwest of where Fall River begins its flow, it is reasonable that the mountain slopes provide a 

significant source contribution to the ground and spring water that percolates into and feeds Fall River. .... 

failed to reasonably assess potential seasonal impact fluctuations adversely affecting the available water flows 

to Fall River from the proposed logging project. (#26)

Response: A more thorough discussion of the Fall River hydrology has been added to the FEIS. The 

drainage area for Fall River is approximately 39.9 square miles. Fall River has a very stable flow regime 

because of its spring-fed, groundwater driven nature. The principle groundwater recharge zone for the 

Upper Deschutes Basin is the Cascade Range, where a large proportion of the precipitation falls. East of 

the Cascade Range there is little or no recharge from precipitation (Gannett et al. 2001). Much of the area 

between Lookout Mountain and Fall River has a history of activity, and the larger basin in which Fall 

River exists has also been heavily treated – with no evidence of changed hydrology in Fall River.

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EFFECTS ANALYSIS – ROADS

The DEIS fails to adequately address the excessive harmful extent of roads in the area already, and the 

additional harms that would be incurred by the use of these roads and extensive ground based logging across 

the area’s rare relatively intact forest soils. The project failed to sufficiently address removing excessive and 

resource damaging roads throughout the area, bringing project road density to within scientific 

recommendations for wildlife and environmental viability, as well as LRMP standards. The project failed to 

disclose if LRMP road density standards comport with recent scientific recommendations related to wildlife 

road density thresholds for the area’s species of concern, or whether these need adjustment to incorporate 

relevant new research. (#26)

Response: The current road system is considered as part of the existing condition (see FEIS p. 43, 160-

161). The road density for the project area at 2.72 miles per square mile is much closer to LRMP 

guideline than the road density for the larger Implementation Unit which averages 4 to 5 miles per square 

mile. The two action alternatives will close the main route through the Experimental Forest by placing a 

gate at the 4045/4240 road junction effectively reducing travel on about 15 miles of road within the project 

area. 

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The DEIS fails to accurately disclose the harmful ecological impacts of its so-called “temporary” new road 

construction. (#26)

Response: Temporary roads are described on page 20 of the FEIS. About 1 mile for Alternative 2 and 

0.5 mile for Alternative 3 would be needed for access to activity areas and then subsoiled following their 

use. The impacts are described in the FEIS pp. 65, 71, 160, 209.

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EFFECTS ANALYSIS – LARGE TREES, GTRs, AND SNAGS

Loss of large trees and future recruitment of large trees. There are no “excess” trees larger than about 16” 

dbh. All those trees are needed for current habitat and carbon storage, as well as for future recruitment of 

large trees and/or large snags. The expected mortality in these stands is not adverse as described in the DEIS 

but rather a natural ecological process that is net beneficial because it helps recruit rare large snags and dead 
Appendix F Response to Public Comments

 EXF Final EIS Page 37 of 88

wood while at the same time thinning the stand and making room for the continued growth of large trees. 

Logging helps grow big trees faster but at the expense of snags, habitat complexity, and carbon storage. (#27)

Logging will capture mortality and reduce and delay recruitment of large snags and exacerbate an existing 

shortage of large snags at all scales; (#27)

The DEIS needs to fully disclose the cumulative impacts of forest management across the landscape, especially 

on snags and snag recruitment processes. Site productivity diverted to the mill will never be recruited as snags. 

Forests managed for more vigorous trees will not recruit many snags. (#27)

The DEIS does not disclose how long lasting the negative effects of captured mortality are. The EIS needs to 

conduct a stand simulation model to show how long after logging it will take to attain 80% DecAID tolerance 

levels. (#27)

Loss of snags from northwest forests has long-term consequences because it takes a long time to replace large 

snags. Snags are not just nice to have; they are an essential feature of old forests. [They] provide very critical 

temporal links from one stand to the next. Under natural conditions, a forest hands down a large legacy of 

living and dead material from one stand to another even after an intense disturbance. Even non-standreplacing disturbance creates pulses of dead material that are critical for forest ecosystems Martin G. 

Raphael, Richard S. Holthausen, Bruce G. Marcot, Terrell D. Rich, Mary M. Rowland, Barbara C. Wales, 

Michael J. Wisdom, 2000. DRAFT Effects of SDEIS Alternatives on Selected Terrestrial Vertebrates of 

Conservation Concern within the Interior Columbia River Basin Ecosystem Management Project, March 2000, 

revised June 23 , 2000 and November 14, 2000. (#27).

Large snags are severely under-represented in our forests and logging will capture, reduce and delay 

recruitment of future large snags. Korol et al (2002) estimated that even if we apply enlightened forest 

management on federal lands in the Interior Columbia Basin for the next 100 years, we will still reach only 

75% of the historic large snag abundance, and most of the increase in large snags will occur in roadless and 

wilderness areas. (#27)

Response: The effect of thinning in regards to delaying the recruitment of large snags has been disclosed 

on throughout the wildlife analysis of the FEIS. Also, neither alternative will remove existing snags,

except for danger trees (which will be felled as necessary as left on site). The FEIS has disclosed that the 

effect of the improved health and vigor of the trees would be the recruitment of new, large dead wood not 

occurring for many decades.

An 80% DecAID tolerance level was not identified as the desired future condition for dead wood levels in 

the project area. DecAID is an advisory tool and was applied as such in the analysis. The commenter 

does not disclose what 80% tolerance level they are seeking. The FEIS discloses on pages 186-187 that 

the 80% tolerance level can mean different dead wood depending the species or even what data source 

(inventory data vs. wildlife data).

Commenters presented numerous research documents to support snag comments. The Decay Wood 

Advisor tool (DecAID) is the best science available to assess the effects of deadwood for a ‘natural 

disturbance,’ that is why we included an analysis using the DecAID tool and present the effects in the EIS. 

The dead wood analysis also includes evaluations based on the DecAID tool, which is considered the best 

available data on wildlife species, and their relationships with dead wood. DecAID is based on through 

review of the literature, available research, and expert judgment.

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The EIS uses 21”dbh trees as the definition of large trees, but the scientific literature usually uses 20”dbh. 

How many extra “large trees” will be removed but not disclosed under that redefinition? Please use the 

scientifically accepted definition of large tree (20” dbh). (#27)

Response: Descriptive terms like “large” cannot be compared across species, nor is there any specific 

scientific agreement that standardizes size class definitions. Region 6 Interim Old Growth Definitions for 

the Ponderosa Pine Series and for the Grand Fir/White Fir Series (USFS 1993b) uses 21” DBH as the 

minimum required diameter to define old growth for these potential vegetation series. The Status and 

Trend of Late Successional and Old-Growth Forest (Moeur et al. 2005) also cites a 21” minimum 

quadratic mean diameter in reference to “older forest with size indexed to vegetation zone” for the Oregon 
Appendix F Response to Public Comment

EXF Final EIS Page 38 of 88

Easter Cascades. Additionally, the Eastside Screens use 21 inches as a diameter size class boundary for 

management purposes. 

The FEIS provides an estimation of the average tree size retained (see p. 91). Currently the average trees 

size is 18.3” dbh; following thinning the average tree size will be 24.9” dbh for Alternative 2 and 24.7” 

dbh for Alternative 3. The average tree size increases, because thinning from below removes the smallest 

trees first, and leaves the largest trees in the stand.

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The analysis of effects on snag dependent wildlife is inadequate. The DEIS p 149 misleadingly says that higher 

quality habitat would develop due to higher growth rates on retained trees but the EIS fails to reconcile this 

with the removal of 1/3 of the large trees across 2500 acres. This project will capture and delay mortality 

which is directly adverse to the needs of these species. Any suggestion that this project benefits species 

dependent on dead wood is highly misleading. (#27)

Response: The referenced discussion is concerning hairy woodpecker habitat and the expectation that 

better habitat may develop is because not just snags, but more large snags will be created over the long 

term. The FEIS acknowledges a gap in snag recruitment, however. 

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Given that there is a regional deficit of large snags and given that the existing forest plan standards for snags 

are outdated, the FS cannot proceed to remove 20,000 large trees (i.e., future snags) until it adopts new 

standards via NFMA and NEPA procedures. (#27)

Response: The EXF area contains high snag densities and larger snags than other areas of the watersheds 

(FEIS p. 186). Implementation will not remove any existing snags except for safety reasons (FEIS p. 29, 

187), so will continue to provide an area of higher quality habitat for some species in the watershed, 

although not at optimal levels. 

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The snag/GTR analysis (p 154-161) is flawed in many ways:

a. It discloses some information about 10” dbh snags but not about larger snags that many species uniquely 

depend on.

Response: Pages 186 and 187 discloses the current amount of snags >20” dbh, and using the inventory 

data in DecAID as a reference, the amount of snags >20” dbh that had been observed on the larger 

landscape. Table 72 on page 186 of the FEIS does not separate out >20” dbh snags but instead includes 

them in the column heading “>10” dbh” in an effort to make the information in the table more easily 

compared and understood. One only has to read the disclosures of effects to pileated woodpeckers, whiteheaded woodpeckers, Lewis’ woodpeckers, hairy woodpeckers, northern flickers, Williamson sapsucker’s, 

black-backed woodpeckers, three-toed woodpeckers, pygmy nuthatch, American marten, and Pacific 

fisher to see species-specific effects.

b. It says that current snag level meet LRMP direction but does not disclose that the LRMP direction is 

outdated and scientifically discredited. 

Response: The footnote attached to Table 72 makes reference to this point. The Decay Wood Advisor 

tool (DecAID) is the best science available to assess the effects of deadwood for a ‘natural disturbance,’ 

that is why we included an analysis using the DecAID tool and presented the effects in the deadwood 

section of the EIS.

c. It discusses effects on snag habitat by discussing direct effects on existing snag, when the real effect is on 

long-term snag recruitment over time. Then when GTR is discussed, the EIS relies on outdated LRMP 

standards and the EIS provides no evidence to support the assertion that 5 tpa green tree retention is 

adequate to provide long-term snag recruitment. This would require a stand simulation model. Finally, the 

EIS claims long-term beneficial effects due to increase growth rates, without acknowledging that there are 67 

tpa (including 9 large trees) removed from the stand. The EIS never deals with the trade-off between snag 

quality (size) and snag quantity (number) caused by logging. 
Appendix F Response to Public Comments

 EXF Final EIS Page 39 of 88

Response: Green Tree Replacements (GTRs) are defined and the source of their determination is made 

on page 190 of the DEIS. An updated table was included in the FEIS (p. 190 Table 76). The Deschutes 

National Forest Wildlife Tree and Implementation Strategy (WLTL) was written in 1994. Then, as now, 

the standard and guideline for snags and subsequent GTRs is the biological population potential. 

Although this is a flawed technique, as disclosed on page 156, it remains the current direction. The 

commenter’s reference to 5 tpa is a calculation using all of the information and pertinent tables within the 

WLTL. The gap in snag recruitment as a result of the thinning and improved health of the tree vs. the, 

existing conditions is disclosed on pages 164, 174, 175, 179, 189, 191 of the FEIS.

d. Page 160 makes a completely unsubstantiated claim that logging will produce a higher density of large 

snags in the future. This is virtually impossible, given that on average 9 tpa >21” dbh will be removed 

(22,986 large trees to be removed across the project) (19 tpa >21” dbh retained, so 1/3 of the large trees will 

be removed), and the fact that many of the trees to be removed are those 15-19” dbh that are on the cusp of 

becoming “large” (>20 “ dbh) over the next couple decades. (#27) 

Response: The rationale for the “completely unsubstantiated claim” can be found within the same 

paragraph on page 191. This same paragraph acknowledges the gap in recruitment of many decades until 

the remaining trees grow larger (>20” dbh) and die.

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The Screens call for application of the following MINIMUM standards with respect to snag habitat ...100% 

potential population levels of primary cavity excavators. This should be determined using the best available 

science on species requirements as applied through current snag models or other documented procedures. 

(#27)

The bottom line is that current management at both the plan and project level does not reflect all this new 

information about the value of abundant snags and down wood. The agency must avoid any reduction of 

existing or future large snags and logs (including as part of this project) until the applicable management 

plans are rewritten to update the snag retention standards. (#27)

Unfortunately, the Eastside Screens still rely on the discredited potential population method. The Forest 

Service has numbers for meeting 100% potential population levels and strives to meet targets that are known 

to be inadequate. Even if the agency aims for a target above 100% potential population levels, the agency is 

still using an invalid reference point that does not belong in the NEPA analysis. The best available science has 

not been incorporated into the standards. The agency lacks the “documented procedures” for meeting snag 

habitat requirements called for in the Eastside Screens. (#27)

1) PNW Research Station, “Dead and Dying Trees: Essential for Life in the Forest,” Science 

Findings, Nov. 1999 (http://www.fs.fed.us/pnw/sciencef/scifi20.pdf) 

2) Jennifer M. Weikel and John P. Hayes, HABITAT USE BY SNAG-ASSOCIATED SPECIES: A 

BIBLIOGRAPHY FOR SPECIES OCCURRING IN OREGON AND WASHINGTON, Research 

Contribution 33 April 2001, http://www.fsl.orst.edu/cfer/snags/bibliography.pdf

Response: DecAID was used as a comparison with the best available science with current direction. This 

was used in species-specific discussions and the dead wood discussion. The referenced documents do not 

provide any science that counters that used in the EXF FEIS. 

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The Forest Service cannot provide any assurance that its plans and projects will assure viable populations of 

native wildlife that depend on dead trees. The Forest Service does not know how many snags are necessary to 

support viable populations of cavity associated species. The Forest Service has provided no credible link 

between DecAID tolerance levels, potential population levels, and/or viable populations. The Forest Service 

has also failed to reliably quantify existing and projected habitat for snag associated species. (#27)

Response: Using DecAID with the cumulative effects analysis and Natureserve was the best attempt to 

determine viability at the project and subwatershed scale.

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Snag guidelines are still much narrower than numerous authors have suggested they ought to be, and we 

currently run the risk of managing coarse woody debris with uniform standards across historically variable 
Appendix F Response to Public Comment

EXF Final EIS Page 40 of 88

landscapes, which is entirely inappropriate. Instead, we should be managing for levels of coarse woody debris 

that more accurately mirror levels characteristic of the natural disturbance regime (Agee 2002). Clearly, we 

need more data on what might constitute meaningful snag targets for all forest types and successional stages, 

and those targets should be set on the basis of reference conditions from natural post disturbance forests, not 

from managed forest stands and certainly not from consideration of only a single aspect of an organism’s life 

history. (#27)

Response: Changing snag standards and guidelines is outside the scope of this project.

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The agencies need to prepare a EIS to consider a replacement methodology for maintaining species and other 

values associated with dead wood. This is especially critical because adequate dead wood is recognized as an 

essential feature of healthy forests and the Forest Service has identified lots of “management indicator 

species” associated with dead wood habitat. (#27)

Response: This is outside the scope of this project.

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EFFECTS ANALYSIS – FUTURE RESEARCH 

The DEIS does not accurately disclose the adverse effects of the proposal:

the control areas are too small which will cause a shortage of reference forests for future research in this 

experimental forest; (#27):

The DEIS does not disclose that future research on unmanaged stands would be precluded by this extensive 

logging project. (#27)

Response: The reasons for the size of the control areas is discussed in the FEIS Appendix B p. 16. The 

potential for future research is maintained by treating large blocks and reducing the risk of large-scale 

disturbance . The potential for future research to occur within control units is not foregone with this 

project; however, the control units are not entirely “unmanaged” as are most Research Natural Areas.

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Doesn’t protection from wildfire and insect “outbreaks” through logging irrevocably change the baseline 

conditions of other research plots and destroy the legitimacy of future research findings by changing the site 

conditions mid-way through experiments?

Response: Existing research plots that fall within treatment units are accounted for in the FEIS. 

Protection from wildfire is an existing condition for Lookout Mountain in that the area already receives the 

highest level of suppression support. Existing studies, such as the Levels-of-Growing-Stock or spacing 

studies of mixed species were established to study the effects of density management, under the 

assumption that wildfire and insect outbreaks would not be additional factors of greater complexity. 

Therefore, protection from wildfire and insect-caused disturbances in areas surrounding these studies leads 

to greater protection of the existing studies and continues the baseline conditions under which these 

studies were established. 

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EFFECTS ANALYSIS – CARBON STORAGE AND CLIMATE CHANGE

The EIS is almost unique in its consideration that the proposed study area is likely to become warmer and 

drier in the coming decades. Trends over the last half century support this analysis for central and much of 

eastern Oregon (http://www.climatewizard.org/). If these climatic trends continue or intensify, the proposed 

study should show large differences in mortality associated with drought and bark beetle attacks. With luck, 

fire suppression may be limited to the control treatments. (#29)

Response: No response necessary.

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Appendix F Response to Public Comments

 EXF Final EIS Page 41 of 88

The DEIS does [not] accurately present the range of readily available data and information on carbon, 

climatic changes and vegetation trends, yet these data and information are central to the purpose and need. 

(#26)

While insect impacts and populations are indeed documented as moving towards higher elevations, with 

prolonged activity, these patterns too are still likely within the range of natural variability over the long-term 

of time, with many other variables influencing such impacts. Ultimately, whether climate change brings 

greater risk of severe fires or higher levels of moisture remains a field of scientific speculation and ongoing 

debate. Yet, the DEIS fails to adequately address or disclose these issues, other than to non-objectively 

misrepresent controversial scientific hypotheses as the sole facts. (#26)

Response: The climate change discussion can be found on p. 243 of the FEIS. Because climate change 

has not been adequately addressed in thinning and fuel reduction research, the Study Plan includes a 

research question aimed at long-term influence of climate change interacting with a set of fuel reduction

treatments on vegetation dynamics and forest structure. The best available science on projections for local 

climate change are disclosed in the FEIS p. 243.

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The Forest Service must consider the effect of harvest on the pool of carbon stored in the soils. The soils store 

carbon for far longer than the forest vegetation does. The analysis for the Farley logging project does not 

disclose or analyze this readily calculable parameter.... the timing of the removal is critical...

Response: The relevance of the Farley project analysis to the current EIS is not clear. The carbon / 

climate issue is discussed in the FEIS p. 243-244.

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For the EXF Project, this means that it takes years to decades for a planted forest to establish full 

photosynthetic capacity. It also takes years to decades for the dead material created by a disturbance caused 

by nature or humans to decompose away. This means that temporal lags can be expected in any projected 

gains. Thus, it may be eventually possible to gain carbon by converting an older forest to a younger biomass 

energy plantation, but it may take many decades or even centuries for this to occur. This is time we do not 

have. (#26) 

Therefore one is unlikely to gain carbon from the forest site if one converts from an older to a younger forest 

system. The analysis of the EXF logging project makes this flawed assumption and bases its management 

choice on this flawed assumption. (#26)

Response: The management of the Pringle Falls Experimental Forest is not based on carbon storage and 

the purpose and need does not involve converting older forest to a biomass energy plantation.

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To assure that forest projects in fact remove atmospheric carbon, it is essential that the actions proposed in the 

EXF project conform to rigorous scientific principles. The proposal in EXF does not provide assurance that 

that increases of carbon stores will be realized over time. (#26)

The EXF DEIS claims that due to the lack of federal standards, regulatory policy, and federal statutes it is 

impossible to determine the impacts of the EXF Project on climate change and carbon sequestration. The DEIS 

must be withdrawn, and new requisite analysis conducted that responsibly addresses the readily available 

scientific information on climate change, forest vegetation and soil carbon sequestration. (#26)

We refer you to the recently released government science report on climate change: 

http://www.globalchange.gov/publications/reports/scientificassessments/ us-impacts/. The readily available 

data on climate trends and the readily available data on actual carbon release from management disturbance 

as compared to natural disturbance must be disclosed and analyzed in the alternatives considered in the DEIS. 

(#26)

The DEIS does not accurately disclose the effects of logging carbon storage and that it will exacerbate climate 

change; (#27)
Appendix F Response to Public Comment

EXF Final EIS Page 42 of 88

The NEPA analysis should start with an accurate and up-to-date inventory of carbon storage and carbon flows 

on federal land.... The NEPA analysis should disclose and consider that logging has several adverse 

consequences on GHG pools and flows. (#27)

Before attributing carbon benefits to fuel reduction logging please consider the conclusions of Mitchell, 

Harmon, O'Connell. 2009. Forest fuel reduction alters fire severity and long-term carbon storage in three 

Pacific Northwest ecosystems. (#27)

The DEIS analysis of climate change does not discuss the effects on management on carbon storage. In 

particular the implications of Mitchell, Harmon, O'Connell. 2009. Forest fuel reduction alters fire severity and 

long-term carbon storage in three Pacific Northwest ecosystems. Ecological Applications. 19(3), 2009, pp. 

643–655 http://ecoinformatics.oregonstate.edu/new/FuelRedux_FS_CStorage_Revision2.pdf Although 

thinning can affect fire, the agencies are likely to remove more carbon by logging than will be saved by 

avoiding fire. (#27)

Response: The interdisciplinary team has reviewed the cited work by Mitchell and others; it does not 

support the comment that the EXF project is likely to remove more carbon by logging than will be saved 

by avoiding fire. The paper by Mitchell, Harmon, and O’Connell is the result of simulation exercises with 

three Pacific Northwest forest types: the east Cascades ponderosa pine forests, the west Cascades western 

hemlock-Douglas-fir forests. And the Coast Range western hemlock-Sitka spruce forests. Treatments 

simulated for the east Cascade ponderosa pine forests were similar to those proposed for Lookout 

Mountain (understory removal, prescribed fire, understory removal and prescribed fire). Based on a forest 

ecosystem simulation model, the authors suggest that fuel reduction treatments in these ecosystems 

consistently reduced fire severity. For the east Cascade ponderosa pine forests (represented by Pringle 

Falls Experimental Forest) there was little or no trade-off incurred by managing these forests for both 

fuel reduction and carbon sequestration. The authors speculate that the removal of highly flammable 

understory vegetation led to a reduction in overall fire severity that consequently lowered overall biomass 

combustion, thereby allowing increased overall carbon storage. See Chapter 3.3.11 of the FEIS for a 

discussion of carbon storage and climate change as it relates to the EXF project.

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GAO urged that all forest plans be amended to address climate change.

Climate change represents significant new information that should trigger immediate re-evaluation of forest 

plan provisions allowing carbon stored in large old forests to be removed through logging. (#27)

Response: Incorporating climate change mitigation and adaptation into the Forest Plan is outside the 

scope of this project.

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EFFECTS ANALYSIS – CUMULATIVE EFFECTS

BLM recently completed logging-thinning along Fall River downstream, though the DEIS does not disclose 

this project or whether its actions have been completed, or if there are additional actions planned on BLM or 

private lands downstream. (#26)

Response: Cumulative effects analysis addresses current and ongoing projects that have effects that will 

overlap in time and space and can therefore add to the effects of the EXF project (FEIS p. 42). The 

location of these other ownerships has been added to Figure 9 in the FEIS. The interdisciplinary team did 

not identify any effects that would be discernable at that distance, so there is no potential for effects 

accumulating with downstream. 

Hand-thinning was recently completed by the BLM on about 15 acres adjacent to Fall River in the LaPine 

State Park. No equipment was used. The piles are currently being burned. This project is outside of the 

Fall River 6th field watershed, so is not considered in the cumulative effects for most resources.

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The DEIS fails to responsibly address the ongoing concurrent landscape scale and localized impacts of the 

proposed project in conjunction with past and ongoing projects. Additionally, it fails to note the existence of 

any foreseeable future projects that may be being considered in the greater forest area. (#26)
Appendix F Response to Public Comments

 EXF Final EIS Page 43 of 88

The EXF Project fails to sufficiently identify and evaluate the cumulative impacts of the project as required by 

NEPA.

Response: The FEIS discloses ongoing and expected future projects within the subwatersheds (FEIS pp. 

43-44). The FEIS discusses where the EXF project may create cumulative effects on resources with these 

other projects (see for example pp. 68-69, 72-73, 97-98, 117-118, 134-135.)

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The Forest Service did not provide adequate data of the time, type, place, and scale of past timber harvests and 

did not explain in sufficient detail how different plans and harvest methods affected – and continue to affect –

the forest and watershed environment. ... In many cases, there is no discussion of the time, place, or scale of 

these projects, or how they specifically affected the environment. (#26)

CEQ regulation requirements for cumulative effects analysis as quoted on p. 37 of the EIS have largely not 

been met by the EXF EIS, which for most EIS topics fails to “assess the extent that the effects of the proposal 

for agency action or its alternatives will add to, modify, or mitigate those [cumulative] effects.”

Response: Table 12 (FEIS p. 44) summarizes information on the location, status, and type of projects 

considered in cumulative effects analysis. The specific environmental effects are based on the resource 

being discussed.

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How have the timber sales outlined in Table 9 restricted the amount of suitability of available habitat in the 

watershed for TES and management indicator species such? How would the EXF project further limit 

available habitat for these species and threaten their viability or contribute to a trend toward up-listing? (#26)

Response: The amount of habitat available takes into account the past activities shown in Table 11. Data 

is updated based on wildfires, harvest, and field verification (see Table 25 FEIS p. 69 for example). The 

effects analysis for the TES and MIS species analyzes the impacts to current habitat levels.

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MISCELLANEOUS

The DEIS fails to describe essential components of the project and does not look at the concept of natural 

processes that the forest is already in. (#2, 4, 6, 7, 9, 11, 12, 14-20, 22)

Response: The commenters did not specify which components of the project they felt were missing from 

the DEIS. Control units will be used to compare existing trends with effects of the treatments. See other 

responses concerning natural processes.

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Please consider our need for forested recreation near Bend. Logging destroys our shrinking areas. (#10)

Response: The goal of the Lookout Mountain unit of the experimental forest is to provide for field research 

activities while considering other resource values (see FEIS p. 11). The area does not provide any 

developed recreation opportunities such as campgrounds. There are no system trails, but the area is 

available to the public for activities such as hiking. Implementation of the project will change motor vehicle 

access because a gate will be installed on the main road entering the area (see p. FEIS p. 20). 

---------------------------------------------------------------------------------------------------------------

Johnson et al (2009) simulated thinning in a densely stocked stand of Ponderosa pine with an understory of 

Douglas-fir and grand fir. ...flame lengths increase and potential BA mortality remains above 20 percent 

regardless of surface fuel treatment.... (#27)

Response: Reference is to a newsletter, not peer-reviewed science. It is unclear what the simulated 

treatments were.

COMPLIANCE WITH THE FOREST PLAN

The proposed logging is contrary to NFP Standards and Guidelines which require management actions in LSR 

and NRF habitat “provide that “[t]he objective will be to accelerate development of late-successional 

conditions while making the future stand less susceptible to natural disturbances.” NFP S&G, C-13. (#26)
Appendix F Response to Public Comment

EXF Final EIS Page 44 of 88

The proposed action fails to focus on younger stands, which are typically under 100 years old, dominated by 

trees less than 20” dbh, and absent large old growth trees greater than 20” dbh.

The stated reasons for cutting large trees is not consistent with the NFP goal to reduce fire susceptibility by 

eliminating smaller trees, and to promote late-successional stands by allowing larger trees to enhance the 

forest’s natural resistance to fire.

Commercial thinning in the EXF Project area does not clearly result in greater assurances of long-term 

maintenance of habitat. The Forest Service admits that the action alternatives are likely to adversely affect 

spotted owl NRF habitat as well as habitat for other listed and focal species of concern.

Response: The standards and guidelines at C-13 apply to Late Successional Reserves. The FEIS 

discloses that the proposed treatment within the LSR follows recommendations in the LSR Assessment 

that was reviewed and approved by the Regional Ecosystem Office. There is no suitable spotted owl

habitat (NRF) within the LSR portion of the EXF project (FEIS pp. 8, 46). A map of the NRF habitat has 

been added to the FEIS to make this more clear (FEIS p. 50).

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Logging large fire-resistant trees is not needed to reduce fire risk, and is contrary to the Standards and 

Guidelines of the NFP to promote fire-resistant, late-successional conditions. NFP, S&G, C-13.

Response: The thinning and fuels reduction are expected to create a more fire-resilient forest.

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The Forest Service fails to show that the project’s management activities do not prevent the LSR NRF from 

playing an effective role in the objectives for which they are established. 

Response: No NRF is treated within the LSR (FEIS p. 57). The proposed management activities are 

precisely what are recommended in the LSR Assessment for that portion of the LSR. The FEIS concludes 

that the project will not prevent the LSR from playing an effective role in maintaining the objectives for 

which it was established (FEIS p. 67). 

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Alt 2 is not consistent with the Northwest Forest Plan because the DEIS does not show that there are no 

equivalent research opportunities outside the LSR. Of course there are similar (or even more relevant) 

research opportunities outside the LSR but the FS failed to consider them. (#27)

Response: The NWFP allows research activities to occur within LSRs following an assessment of 

consistency with LSR objectives (C-18). Research activities that are not consistent with the objectives 

(including those within experimental forests) may even be appropriate, “particularly if the activities will 

test critical assumptions of these standards and guidelines, will produce results important for habitat 

development, or if the activities represent continuation of long-term research.” It is only when the 

activities are not consistent with LSR objectives that equivalent opportunities be sought outside the LSR. 

In this case, however, the proposed activities are found to be consistent with the objectives of the LSR 

(FEIS pp. 31, 54), so there is no requirement to show that there are no equivalent opportunities outside of 

it (C-18). The FEIS also points out why the Experimental Forest is the appropriate place to conduct this 

kind of research (FEIS p. 33). 

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Unresolved Questions About Dry Forest Restoration

Oregon Wild stated that the NEPA document should address many of their questions about forest management 

policy regarding balancing different resource needs. These questions include: how to balance the need to thin 

dense forests while providing habitat for species that depend on dense forest; how to address the competing 

effects of canopy removal that reducing canopy bulk density while potentially making stands hotter, dryer, and 

windier; how to integrate and balance terrestrial and aquatic restoration objectives that can often be in conflict 

with each other; whether or not the Forest Service should rely on fire-regime condition-class information as a 

basis for describing and prioritizing fuel treatments; how much dead wood habitat is appropriate to leave 

through time; how many medium-sized trees are needed to achieve future old-growth structure; how much 
Appendix F Response to Public Comments

 EXF Final EIS Page 45 of 88

variability should there be within and between stands; how to balance adverse and beneficial effects to 

treatments; how do we address underlying causes of forest health problems; what is the appropriate mix of 

structural stages and is the historic range of variability different from the future range of variability that will be 

influenced by climate change; can restoration be accomplished without commercial logging; what scales and 

pace of restoration is needed to maintain viable populations of native wildlife and does federal land need to 

compensate for loss of forest on non-federal land; how do we appropriately integrate management before, 

during, and after disturbance; and how do we balance carbon storage and fuels reduction.

The commenter suggests that the EIS should consider a full range of NEPA alternatives to illuminate and 

explore these unresolved issues. Forest Service NEPA regulations state that an EIS shall document the 

examination of reasonable alternatives to the proposed action and that an alternative should meet the purpose 

and need and address one or more significant issues related to the proposed action (36 CFR 220.5(e)). The 

purpose of the EXF project has two components: 1) address insect and fire risk through stand density and fuels 

reduction, and 2) further the mission of the PNW Research Station by providing operational scale research 

opportunities. The proposed action integrates these objectives into a science-based study plan that will build 

understanding of forest dynamics, and will actually help answer some of those questions about dry forest 

management. It also provides a platform for other studies. 

OPINION / POSITION STATEMENT / ALTERNATIVE PREFERENCE

The following comments were considered by the IDT and Responsible Officials, but do not require a response: 

We also support the two proposed forest plan amendments. (#3)

I believe that Alternative 1 (No Action) is the only reasonable course of action. (#2, 4, 6, 7, 9, 11, 12, 14-20, 

22)

I urge the Deschutes National Forest to choose Alternative 1 “No Action” and allow this beautiful forest to 

grow. (#2, 4, 6, 7, 9, 11, 12, 14-20, 22)

I want to express my support for the No Action alternative regarding the Experimental Forest near Bend, 

Oregon. (#5)

If the Blue Mountain Biodiversity Project makes comment on this, we support their comments. If they do not 

make comment, we support the No Action Alternative. (#24)

I provide this declaration to support, in general, the 2nd alternative treatment proposed on the 2,554 acre 

ponderosa pine/mixed conifer forests in the Lookout Mountain Unit of the Pringle Falls Experimental Forest 

based on material presented in the Environmental Impact Statement released in September 20 9. (#23)

I do not like this plan of logging all of our trees. This area belongs to national taxpayers, not local taxpayers. 

(#1)

We feel this project will provide timely and relevant scientific data to help guide future management of these 

types of forests. (#3)

The EXF site should not be logged, because it is among the oldest forest land left in Oregon. (#13)

No Deschutes logging, please. (#21)

We have spent time in the area and would like it protected. (#24)

I urge you to support the No Action alternative for the EXF project. The EXF area is a healthy, intact forest 

that has not been marred by significant human impact since about 1865. The EXF groves of old growth 

ponderosa pine contain large, well-spaced fire resistant trees with few fuel ladders. (#25)

Most of the old growth stands of forest have already been decimated by logging, and the EXF project is just 

another poorly disguised timber sale of intact groves that are both ecologically and commercially valuable. A 

real experiment would test new assumptions and would have real control plots. The EXF “experiment” merely 

replicates the damaging activities the Forest Service has already conducted on hundreds of thousands of acres 

already, and has no real control plots. (#25)
Appendix F Response to Public Comment

EXF Final EIS Page 46 of 88

The U.S. Forest Service has excelled at giving away our natural heritage to the highest bidder, trashed water 

purity and slope stability. Thousands of species are eradicated by human activity each year, and both our 

local and global climate become more unstable each year. (#25)

As a participant on the Deschutes Provincial Advisory Committee (PAC), EPA has had the opportunity to 

survey other ongoing research efforts on the Pringle Falls Experimental Forest. This forest is an important 

natural laboratory that is serving to enhance our understanding of the role of natural and human-caused 

disturbances as agents of change in ponderosa pine, lodgepole pine and mixed conifer forests, and the degree 

to which they can be effectively managed to achieve or sustain desired ecological conditions. We are 

supportive of the proposed project, both as a means to address the risk of severe insect epidemic or 

catastrophic fire, and as an opportunity to study forest dynamics after thinning and fuels reduction in dry 

forests. Although a small component, we are appreciative that the long-term influence of climate change will 

be considered within the context of the study. As climate changes, so may the way in which fuel reduction 

treatments affect vegetation dynamics and forest structure. Research such as this can help to build our

understanding and inform future management. (#28)

Deschutes County will go on record supporting Alternative 2 as identified in the DEIS. Our comments and 

recommendations to support the proposed action is based on the thorough explanation and display of 

alternatives. (#29)

Although Alternative 2 well documents the differences from Alternative 3, the net gains from the perspective of 

research opportunities and significantly reducing the negative impacts of a stand replacement fire solidify the 

chosen alternative. We support that thesis. Frankly if we can’t protect and enhance the Region’s oldest 

Experimental Forest and return the vegetation to a normal healthy state we may be missing one of the most 

important resource opportunities in our history. (#29)

We are opposed to logging and burning in spotted owl dispersal habitat – drop units 12, 41, 23, 43, and 44. 

Professor Norm Christensen “expert advisory” : "Loss of canopy increases wind speed and air temperatures 

and decreases humidity in the forest," Christensen notes. "As a result, ground fuel fires that break out can 

spread faster and farther than they would normally." 

Duke University issued an “expert advisory” May 24, 2004 with Professor Norm Christensen saying: “...the 

practice of suppressing wildfires has allowed debris to accumulate to dangerous levels on the forest floor.” 

Indiscriminate logging aggravates the problem by thinning a fire-prone forest's canopy and littering its floor 

with sawdust and other combustible debris.

Comments that allege a scientific controversy went unaddressed in the EIS

The term “controversial” refers to cases where a substantial dispute exists as to the size, nature or effect of 

a major federal action rather than to the existence of opposition to a use.

2

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Plant association groups. 

Response: The plant associations present in the project area are described in the FEIS pp. 77-79. These 

are based on site-specific information gathered in the field. There has been no scientific evidence offered 

that these plant associations are incorrectly identified or that their identification is highly controversial.

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

 2 CEQ NEPA regulations set out factors that must be considered in determining whether an EIS must be prepared. One 

factor is: The degree to which the effects on the quality of the human environment are likely to be highly controversial. 40 

CFR 1508.27(b)(4). The courts have been clear that the controversy factor is not meant to test whether there is opposition 

to the proposal. 
Appendix F Response to Public Comments

 EXF Final EIS Page 47 of 88

Spotted owl NRF habitat, foraging and dispersal patterns and evidence, population recovery, and continued 

use of naturally burned forest habitat but extirpation from logged forest habitat.

 

Response: The impacts to spotted owl NRF are clearly displayed in the FEIS. The FEIS discloses 

that nesting habitat is not present in the project area and no spotted owls have been located within 

project units. The commenter does not provide any evidence that these disclosures are incorrect or 

highly controversial.

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Goshawk habitat needs, trends, and adverse impacts from logging, thinning, and management disturbance 

actions. 

Response: The FEIS discloses goshawk habitat needs, trends, the current condition of northern 

goshawk habitat within the project area, as well as the expected impacts from each alternative (FEIS p. 

150-152). Scientific references regarding goshawk have been reviewed and addressed in the FEIS and 

this Response to Comments (see p. 26).

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Other listed and imperiled species of concern. 

Response: This comment is not specific enough to respond to. A Biological Evaluation and Biological 

Assessment have been prepared for the project. 

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Ponderosa pine and mixed conifer transition zone forests with overall mixed severity fire patterns and cycles

at moderate to high elevations.

Response: The vegetation within the project area is described as being dominated by ponderosa pine; the 

variations in fire regime associated with the different plant associations are described (FEIS pp. 90-91). 

Recent work by Baker attempts to make the case that fires occurred less frequently in these types of 

forests. The specialists on the interidisciplinary team and the lead researcher, however, see no evidence 

of this in the Lookout Mountain Unit. 

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Direct and cumulative road density and fragmentation impacts, and the ecologically long duration of the 

impacts of erroneously termed “temporary” roads. 

Response: The impacts of roads are described for wildlife and soils. The duration of temporary road 

impacts is disclosed in the FEIS: temporary roads will be subsoiled following project activities and 

natural regeneration can be expected within about six years. Best management practices are described for 

project implementation which are based on research recommendations (FEIS p. 26).

The DEIS does not adequately disclose or objectively address the full range of scientific controversy and 

research recommendations pertinent to the following issues:

Forest soil communities, including the foundational role subsurface microbial organisms and hydrological 

functioning play in providing for the sustained resilience and vigor of forest ecosystems, capacity and 

importance of soil carbon sequestration, the relatively intact nature of unlogged forest soils throughout most 

of the EXF project area, and the irretrievable adverse impacts of mechanized ground based logging, 

thinning, mowing and burning throughout approximately two-thirds of the Lookout Mountain Unit’s now 

functioning ecologically intact forest systems. 

Response: This comment suggests that the need for action (FEIS p. 4-5) is outweighed by potential 
Appendix F Response to Public Comment

EXF Final EIS Page 48 of 88

adverse impacts. As previously discussed in this Response to Comments, evidence that trees in the project 

area are at risk of being lost to bark beetles is based on scientific research (see FEIS pp. 85-87). The 

commenter has not provided any scientific evidence to support an assertion that the current condition 

assessment is not accurate. The environmental consequences have been thoroughly discussed and 

disclosed in the FEIS, including findings for soils and hydrology. Project design features, including Best 

Management Practices will minimize potential adverse effects. 

Comments that allege a scientific controversy with the Study Plan or purpose and need

The DEIS never objectively discloses the wealth of scientific research across multiple science disciplines that 

readily disproves the foundational premise of the “study plan.”

Response: The research questions outlined in the Study Plan are intended to add to the body of science; 

the research focuses on areas where more information is needed. The “foundational premise” of the Study 

Plan is that land managers need information on the response dynamic of vegetation composition and 

pattern at multiple scales to define options for management that promote development of desired 

ecosystem attributes and values over time. No scientific evidence disproving this has been presented. We 

know from research that young ponderosa pine stands respond positively to density reduction (see 

Appendix B, p. 22); the working hypothesis for the study plan’s first research question is based on that 

premise, which has not been disproven by scientific research. Similarly, the other five research questions 

involve working hypotheses that are based in scientific research but acknowledge the need for more 

information (Appendix B, pp. 22-25).

The DEIS Appendix B Response to External Reviewer Comments fails to scientifically justify the purported 

purpose and need for the project, and insufficiently adheres to the foundational objective tenets of science 

research, instead obfuscating critical issues of scientific controversy and uncertainty while avoiding disclosing 

and addressing the growing evidence of environmental harms from similarly premised projects across the 

region’s forests.

Response: The Study Plan is not a disclosure document under NEPA. It was prepared according to Forest 

Service Manual direction (FSM 4070 Research program Formulation and Documentation). The purpose 

and need for the project have been described and similar comments previously responded to. Although 

commenters may be opposed to the Research Station’s focus on scientific research in the Experimental 

Forest, there is not a scientific controversy about the role of Experimental Forests.

There is also significant scientific controversy undermining the hypothesis that commercial thinning can 

actually reduce the risk of fire and natural disturbance cycles such as insects, and in particular, the Forest 

Service’s stated need to reduce the area’s stand density. 

Response: Thinning can reduce the risk of insects as previously discussed in other responses. Change in 

fire behavior is expected with each action alternative (FEIS pp. 112-124) that includes thinning, mowing 

of shrubs and understory, and underburning. Commercial size thinning alone does not create the desired 

change in fire behavior. The change in fire behavior is based on Principles of Fire Resilient Forests (Agee 

2002, Hessburg & Agee 2003). The Flammap model utilizes site-specific information from the project 

area to provide a quantification of the change (see FIES p. 108-109, 113). 

Comments that allege a scientific controversy regarding fire risk reduction

There is ample scientific controversy about whether mechanical fuels treatment reduces fire risk in the mid- to 

higher-elevation forests targeted by the EXF Project. Mature, old-growth stands have dense, moist interiors 

and little wind, which inhibit the spread of wildfire. (Morrison and Smith, 2005; Rhodes, 2007)

While there is limited scientific support for the removal of small diameter trees and flash fuels in frequent fireinterval low elevation ponderosa pine forests, there is significant scientific controversy and strong 

recommendations against logging-thinning relatively intact old growth forests, mixed fire pattern transition 

zone forests, mixed conifer, mixed fire-severity, and moist forest ecosystems to improve health, vigor, and 

resilience to fire, insects, and disease in forests under the erroneous rational that such are outside their 
Appendix F Response to Public Comments

 EXF Final EIS Page 49 of 88

historical pre-fire suppression conditions for species composition, structural diversity, stocking densities, and 

fuel loads. (Wilmer and Aplet, Wildland Fire Challenge, 2003).

Response: The Morrison and Smith 2005 paper is cited within the FEIS to support the explanation of why 

Fire Regime/Condition Class information is used to display a reference condition, but is not used in 

measuring the effects of the alternatives and therefore not used in the decision making.

Rhodes 2007 relates to the effects of forest fuel reduction treatments on watersheds and aquatic resources. 

The EXF project will not conduct fuels reduction activities in riparian areas. The paper provides

recommendations to reduce potential adverse effects and the EXF project appears to be consistent with 

these. The FEIS analyzes potential for hydrologic impacts and found that there would be none at the 

project or watershed level (FEIS pp. 225-229). The referenced document does not provide science that 

opposes methods proposed in the EXF project.

Wilmer and Aplet (2003) evaluates “the quality of information that feeds wildland fire policy, assess the 

challenge of identifying and protecting threatened communities from wildland fire, and outline the first 

steps in a comprehensive strategy to prioritize where fuel reduction and ecosystem restoration measures are 

needed.” Recommendations are made for homeowners and for restoring forests’ resilience. This document 

is not directly relevant to the EXF project, which does not involve urban interface. The importance of 

addressing the management issues is based on its value as an Experimental Forest.

Assessment of Additional Scientific Literature Submitted to the Forest Service

The Sierra Club, LOWD-BMBP, Cascadia Wildlands, submitted a CD attachment to their comment letter. The 

attachment included a large list of documents. Many documents were not referenced in the comments to 

substantiate any particular statement or discrete issue. Regardless, the Interidisciplinary Team, scientists from 

the Pacific Northwest Research Station and other Forest Service specialists evaluated each document for 

applicability to the project area. The results of that evaluation are displayed in the following tables. Table F-2 

lists those documents that are considered part of a substantive comment; Table F-3 lists those documents that 

are considered part of a non-substantive comment. In addition, Oregon Wild made reference to many 

documents in their comments (some scientific research and some not). Where these references were not 

directly addressed in the response to comments section above, they have also been added to one of the two 

following tables.

The CD provided by Sierra Club included over 100 individual files. Key findings about the review of the 

attachments:

• Many of the contributed documents do not report original and empirical research that has been 

subjected to an impartial review through the peer review or refereeing process; instead they are 

opinion pieces from newspapers, court documents, documents of unknown origin, presentations by 

individuals or organizations, etc.

• Some of the contributed documents are not applicable to the EXF project because they report on 

studies conducted in different forest types or regions such as western Oregon Douglas-fir forests, 

where many ecological processes are known to differ from those of central Oregon ponderosa pine 

forests, or they report on different activities such as post- fire management, clear-cutting, or other 

activities that are not part of the EXF project

• Some of the contributed documents point to areas of uncertainty and conflicting results in the science 

of ponderosa pine management; where this occurs, it is fully acknowledged.

• Some of the contributed documents relevant to the EXF project support the purpose and need for the 

project and proposed treatments; others that do not support the purpose and need or proposed 

treatments have been acknowledged.

• The overwhelming body of science that was relevant to the EXF project provides no clear evidence 

that the conclusions in the FEIS are incorrect or scientifically controversial. 
Consideration of Public Content

EXF Final EIS Appendix F Page 50 of 88

Table F-2. The following table 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 

science. Some scientific references have been addressed previously in the Response to Comments section.

Referenced Document Forest Service Consideration / Response

Science Findings Forests at Risk: Integrating Risk Science into 

Fuel Management Strategies

Correct reference: Thompson, Jonathan. 2008. Forests at risk: 

integrating risk science into fuel management strategies. Science 

Findings 102. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 5 p. 

Published research: Ager, Alan A., et. al. 2007. Modeling 

wildfire risk to northern spotted owl (Strix occidentalis caurina) 

habitat in Central Oregon, USA Forest Ecology and Management 

246: 45-56 (www.sciencedirect.com)

Science Findings publication provides an overview on fuel management and the motivation for thinning and 

then describes Western Wildlands Environmental Threat Assessment Center (WWETAC) work to build tools 

for planning fuel treatments. Executive Summary: "The threat from wildland fire continues to grow across 

many regions of the Western United States. Drought, urbanization, and a buildup of fuels over the last century 

have contributed to increasing wildfire risk to property and highly valued natural resources. Fuel treatments, 

including thinning overly dense forests to reduce fuel and lower fire risk, have become a priority for land 

managers. Planning fuel treatments on public lands is a complicated problem. Treatments must address 

multiple management objectives that are often conflicting and burdened with regulatory constraints.”

Commenters did not reference this document in comments; no distinct issue with the EIS was expressed 

concerning this publication and its use in the FEIS. The EXF FEIS does not rely on the science findings or the 

2007 study by Ager on modeling wildfire risk. Nothing in this study undermines the premise of the EXF 

project. It specifically acknowledges thinning in spotted owl habitat would decrease risk of wildfire under his 

model and it acknowledges that many scientific studies have supported thinning within owl habitat as a way to 

reduce long-term risks.

The interdisciplinary team did consider an alternative that would use the concept of strategically-placed fuels 

treatments to reduce fire risk to the experimental forest. A preliminary analysis using similar method (see

FEIS p. 36); but that would not meet the research needs or density reduction objectives.

Baker, William L. 2009. Preliminary Reconstruction of the 

Structure of Dry Mixed Conifer and Ponderosa Pine Forests in 

the Pringle Falls Area, Oregon, using the General Land Office 

Surveys

Summary report of a work in progress. Not peer-reviewed. Describes new method to reconstruct forest 

structure using GLO surveys. The preliminary report asserts that GLO data could be useful in providing 

reconstructions of forest structure. Commenters reference as evidence that the project area is not outside of 

its mean fire interval.

The cited research is not completed. The EXF project is not intended to return the area to a particular 

condition based on any reconstruction. And while the fire cycle may enter into consideration in the 

management of the Lookout Mtn. Unit, it is not the sole basis for planned management nor is it the basis for 

the research outlined in the study plan. See p. 2 of this appendix for more discussion of the issue raised by 

commenters.

Baker, William L. Why Mean Composite Fire Intervals do not 

Estimate Fire Rotation or Mean Fire Interval at a Point. 2 pp. 

Sept. 2009.

Comment from Sierra Club: “Additionally, as brought up during 

Unpublished white-paper. Not scientific research and not readily available.

The two-page statement by Baker provides information on composite fire interval and limitations for estimating 

fire rotation or point mean fire interval. Commenters reference paper as evidence that the project area is not 

outside of its mean fire interval. This paper has been reviewed by fire ecologists from the RMRS Fire 
Appendix F Response to Public Comments

 EXF Final EIS Page 51 of 88

the recent field trip by William Baker, and demonstrated in his fire 

interval research included in our comment exhibits, the actual fire 

interval in the project area is far greater than the intervals claimed 

in the DEIS.”

Sciences Laboratory, the PNRS Fire Sciences Laboratory, and the University of Arizona. Their unpublished 

response includes a basic conclusion that Baker uses the metric inappropriately: “While we acknowledge the 

limitations in reconstructing historical fire size distributions, we point out that Wright (1996) computed a fire 

rotation of 53 years for the Teanaway from reconstructed fire perimeters for the entire study period, and 26 

years for the period 1716-1890 when the fire regime was unaffected by modern fire suppression and the 

record was sufficient to adequately characterize fire extent in the study area. The correct composite fire 

interval to use in Baker’s (2009) method of calculation would have been one for the entire study area, which is 

3.2 yrs (136 fire years over the 433 year record).” 

As stated previously, the EXF project does not propose to return the area to a particular historic condition. 

Fire cycles may enter into consideration in the management of the Lookout Mtn. Unit, it is not the sole basis 

for planned management nor is it the basis for the research outlined in the study plan. The science 

concerning fire intervals in ponderosa-dominated plant associations is referenced in the FEIS pp. 99-101.

Baker & Ehle, 2001 Uncertainty in surface-fire history: the case 

of ponderosa pine forests in the western United States. Can. J. 

For. Res. 31: 1205-1226

This paper provides evidence that fire regimes in ponderosa pine forests are still unknown, because of 

inaccuracies and biases in the estimation of fire intervals. As a result, states that widespread restoration to 

low-density forest is unwarranted. From Discussion: "Since there is large uncertainty about the fire regime in 

ponderosa pine forests, caution is warranted until some uncertainty can be removed. We suggest that 

restoration of fire as a process is certainly warranted, but quantitative targets for how frequent prescribed fires 

should be, how much land area should be burned in a particular year, or how much fuel reduction is 

appropriate (Babbitt 1997; Laverty and Williams 2000) are premature because of large uncertainty about 

mean fire intervals and fire rotations. More careful study is also warranted before physical restoration of forest 

structure or fuels is undertaken on a wide scale (Covington 2000; Laverty and Williams 2000). This is 

particularly true in valuable National Parks, Research Natural Areas, and other protected areas, where a goal 

is often to maintain natural ecosystems and the species dependent upon them"

The EXF project does not prescribe a quantitative target for frequency of fire; rather the EXF project proposes 

thinning and fuels reduction to maintain the largest overstory trees and to implement the Study Plan. The goal 

is not to maintain a natural ecosystem because the Experimental Forest is a place for field research into 

ponderosa pine silviculture. As stated before, the study plan is not based on the fire interval.

Black, S.H. 2005. Logging to Control Insects: The Science and 

Myths Behind Managing Forest Insect “Pests.” A Synthesis of 

Independently Reviewed Research. The Xerces Society for 

Invertebrate Conservation, Portland, OR.

A synthesis of peer-reviewed research prepared by a special-interest group, but document is not peerreviewed. This is a literature search regarding the management of insect pests in the temperate forests of 

western North America. Citations concern the lack of effectiveness of logging to stop insect epidemics. 

Includes a limited review on the effectiveness of thinning referencing various specific studies showing 

reduced, neutral, and increased bark beetle responses to thinning. A check of the references found that most 

of the ones cited showed increased vigor of forests after thinning and a reduction in bark beetle activity. 

Research entomologists from several research stations and universities counter the arguments and opinions 

present in the Black paper. The resulting referred paper is a synthesis of existing literature and published in 
Appendix F Response to Public Comment

EXF Final EIS Page 52 of 88

Forest Ecology and Management (Fettig, et al 2007). The FEIS (and study plan) rely on Fettig et al (2007). 

Factors involving tree density are consistently associated with the occurrence and severity of bark beetle 

infestations. Management to reduce stand or landscape-level susceptibility to bark beetles must address 

factors related to tree density. Accordingly, thinning has long been advocated as a preventative measure to 

reduce the amount of bark beetle caused tree mortality and its effectiveness for this purpose is supported by 

the scientific literature. 

In addition, entomologists with the Forest Service have responded to the paper as follows: “...There are many 

statements...within the report, which are taken out of context, misleading, or simply not true... [L]iterature is 

selectively cited, and opinions are extrapolated from research that often is inappropriately used to support the 

points being made. ...Many of the cited examples of logging/bark beetle dynamics are from mixed-conifer 

coastal forests where bark beetle-caused tree mortality is often minor compared to beetle outbreaks in the 

drier eastside of interior forest of western North America....In conclusion, the Black report contains many 

examples of erroneous statements that are not even supported by the report’s cited literature.” (Forest Service 

Summary of the Logging to Control Insects: The Science and Myths Behind Managing Forest Insects “Pests.” 

Region 6, Forest Health & Protection, November 2005).

Donnegan, Joseph; Campbell, Sally; Azuma, Dave, tech. eds. 

2008. Oregon's Forest Resources, 2001–2005: five-year Forest 

Inventory and Analysis report. Gen. Tech. Rep. PNW-GTR-765. 

Portland, OR: U.S. Forest Service, Pacific Northwest Research 

Station. 186 p. http://www.fs.fed.us/pnw/publications/gtr765/pnwgtr765b.pdf

Oregon Wild comment: “...Given that spatial analyses of fuel 

treatments has demonstrated that treating a small percentage of 

the landscape can reduce landscape-scale fire hazard 

significantly and sometimes cost-effectively (Finney 2001), these 

results suggest that the fuels management challenge may be 

more tractable than has been assumed.”

Oregon Wild also provide the following from the document: “In 

general, wildlife species that use dead wood for nesting, roosting, 

or foraging prefer larger diameter logs and snags (>20 

inches).....” 

This is a general document about the state of Oregon's forests--a five year FIA report.

The FEIS identifies a purpose and need that is more varied and complex than the sole need to reduce 

landscape-scale wildfire. The document provides no science that counters that used in the EXF FEIS.

Finney and Cohen. 2003. Expectation and Evaluation of Fuel 

Management Objectives. USDA Forest Service Proceedings 

RMRS-P-29. 

http://www.fs.fed.us/rm/pubs/rmrs_p029/rmrs_p029_351_366.pdf

In the EXF project, proposed treatment emphasis is on a low thinning or thinning from below by starting with 

the smallest trees and accumulating basal area in the smallest trees first. This differs from treatments 

designed to create gaps in the canopy. See also comment/responses pages 22-23.
Appendix F Response to Public Comments

 EXF Final EIS Page 53 of 88

Oregon Wild provided a comment that references this document: 

“Mark Finney and Warren Cohen also emphasize the three step 

approach to fuel reduction that places reduced emphasis on 

canopy fuel reduction.”

Graham, Russell T.; McCaffrey, Sarah; Jain, Theresa B.(tech. 

eds.) 2004. Science basis for changing forest structure to modify 

wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. 

Fort Collins, CO: U.S. Department of Agriculture, Forest Service, 

Rocky Mountain Research Station. 43 p. 

http://www.fs.fed.us/rm/pubs/rmrs_gtr120.html

Clive M. Countryman.1972. THE FIRE ENVIRONMENT 

CONCEPT. PACIFIC SOUTHWEST. Forest and Ranger 

Experiment Station. Revised for inclusion in Intermediate 

Wildland Fire Behavior, S-290. May 1992

Comments from Oregon Wild: 

“The NEPA document must address the fact that there is very

little scientific support for aggressive thinning to reduce fire 

hazard. There is building scientific evidence that thinning can 

make the fuel hazard worse instead of better.” 

“Additionally, heavy logging slash generates the highest fireline 

intensity of any wildland fuel type when it is dry.”

Comment is incorrectly cited. Graham et al. 2004 summarize the scientific basis for changing forest structure 

to reduce fire behavior and severity. The authors list a number of methods to modify forest fuels such as 

prescribed fire, mechanical thinning, mastication and mulching. In general, fuel treatments can help produce 

forest structures and fuel characteristics that then reduce the likelihood that wildfire will cause large, rapid 

changes in biophysical conditions. Fuel treatments thus are designed to shift fires from high severity to low 

severity. Empirical evidence for this shift is in the literature; see, for example, recent work in ponderosa pine 

forests at Black Mountain in northeastern California, similar to Lookout Mountain, where tree survival after 

wildfire was greatest in those areas that had both thinning and prescribed fire prior to the wildfire event. 

Survival was near zero for the untreated areas. Survival in thinned-only areas was greater than untreated 

areas but substantially less than the areas with both treatments. Ritchie et al. 2007. Probability of tree survival 

after wildfire in an interior pine forest of northern California: Effects of thinning and prescribed fire. Forest 

Ecology and Management 247: 200-208.

Hanson, Chad T., Dennis C. Odion, et. al. 2009. Overestimation 

of Fire Risk in the Northern Spotted Owl Recovery Plan. 

Conserv. Biol. Doi:10.1111/j.1523-1739.2009.01265.x 

Sierra Club provided this reference in their comment letter: “highseverity fire risk appears to be low relative to recruitment of old 

forest, indicating there may be ample time for needed, focused 

research to understand owl response to fire and fuel treatments 

before abandoning reserves and undertaking extensive 

management action in dry-forest provinces.”

Article asserts that vegetation management in most recent recovery plan for NSO are not appropriate. From 

abstract "Fuel treatments (e.g., thinning) at regular intervals also would occur on up to 65–70% of dry forests 

in this area. Estimations of fire risk, however, were based on less than a decade of data and an anecdotal 

assessment of a single, large fire. We found that decadal data are inherently too short, given infrequent large 

fires, to accurately predict fire risk and trends. Rates of high-severity fire, based on remote-sensing data, are 

far lower than reported in the plan and in comparison with the rate of old-forest recruitment. In addition, over a 

22-year period, there has been no increase in the proportion of high-severity fire. Our findings refute the key 

conclusions of the plan that are the basis for major changes in conservation strategies for the Spotted Owl. 

The best available science is needed to address these strategies in an adaptive-management framework. 

From the standpoint of fire risk, there appears to be ample time for research on fire and proposed treatment 

effects on Spotted Owls before designing extensive management actions or eliminating reserves.”

This article has been countered by Spies and 12 other authors, 2009. Underestimating risks to the Northern 

Spotted Owl in fire-prone forests: response to Hanson et al. Cons. Bio. 24: 330-333. The group of 13 authors 
Appendix F Response to Public Comment

EXF Final EIS Page 54 of 88

show that Hanson et al. 2009 conducted an analysis that was erroneous and deficient and did not support 

their conclusions. Furthermore, Hanson et al. 2009 showed a bias against active management by ignoring 

recent science and risk factors in dry forests that do not support their opinions. Therefore this study was not 

relied on in the EXF FEIS.

Keeley, J.E.; Aplet, G.H.; Christensen, N.L.; Conard, S.C.; 

Johnson, E.A.; Omi, P.N.; Peterson, D.L.; Swetnam, T.W. 2009. 

Ecological foundations for fire management in North American 

forest and shrubland ecosystems. Gen. Tech. Rep. PNW-GTR779. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 92 p. 

http://www.fs.fed.us/pnw/pubs/pnw_gtr779.pdf

Oregon Wild provided a comment that references this document: 

“Thinning is most effective when it removes understory trees, 

because larger overstory trees are more resistant to heat injury 

(Agee and Skinner 2005). In addition, shade and competition 

from larger trees slows the recruitment of younger trees in the 

understory.”

This is a general discussion of national fire regimes. From Abstract: "This synthesis provides an ecological 

foundation for management of the diverse ecosystems and fire regimes of North America, based on scientific 

principles of fire interactions with vegetation, fuels, and biophysical processes. Although a large amount of 

scientific data on fire exists, most of those data have been collected at small spatial and temporal scales. 

Thus, it is challenging to develop consistent science-based plans for large spatial and temporal scales where 

most fire management and planning occur..."

The comment concerning removal of larger trees is addressed on page 18 of this appendix.

Odion, D.C., E.J. Frost, J.R. Strittholt, H. Jiang, D.A. DellaSala 

and M.A. Moritz. 2004. Patterns of fire severity and forest 

conditions in the western Klamath Mountains, California.

Conservation Biology 18(4): 927-936.

Oregon Wild submitted a comment that references this 

document: FRCC critique – not a sound basis for describing and 

prioritizing fuel treatments....Dense canopy cover might actually 

help suppress fire rather than spread it.

From Conclusion: "Our findings suggest that elevated risk of high severity fire due to the effects of fire 

suppression is not the pervasive, predictable ecological problem that it has often been portrayed to be in the 

Sierran forests we studied. In addition, they provide evidence that fire alone can restore its past influence as a 

patchwise and stand-thinning disturbance agent as well as a facilitator of species diversity and fire adapted 

conifers in these forests. Thus, it appears that management can shift toward process restoration by 

introducing more fire and increasing the use of wildland fire (Miller 2003). There may be no other effective 

strategy for restoring and maintaining"

Fire Regime and Condition Class were used in the analysis area to describe possible reference conditions 

(FEIS p. 82-83). Because of the controversy and simplicity of using FRCC (Morrison and Smith 2005; Veblen 

2003), FRCC was not used for prescribing treatment alternatives. It also was not used as an indicator of 

alternative outcomes; only predicted fire behavior measurements were used. 

Variously referred to as: 

Rhodes, Jonathan J. and William L. Baker. 2008. Are we 

irrationally exuberant about thinning/fuel reduction? The Open 

Forest Science Journal 1:1-7

Rhodes, Jonathan J. and William L. Baker. 2008. Fire 

Probability, Fuel Treatment Effectiveness and Ecological 

This paper presents a framework to examine the likelihood that wildfire will follow fuel treatments. The authors 

chose this research question because they felt that fuels will rebound after treatment, eventually negating 

treatment effects. From introduction: "Therefore, the necessary, but not sufficient, condition for fuel treatment 

effectiveness is that a fire affects a treated area while the fuels that contribute to high-severity fire have been 

reduced.” Authors conclude: "Even in ponderosa pine forests that burn relatively frequently, our regional 

analysis indicates that after 17 cycles of treatments, only slightly more than 50% of treated areas could 

potentially have fire severity reduced, on average. Our results indicate that high-severity fire is far from 
Appendix F Response to Public Comments

 EXF Final EIS Page 55 of 88

Tradeoffs in Western U.S. Public Forests. The Open Forest 

Science Journal 1:1-7 7 pp.

William L. Baker, Jonathan J. Rhodes. 2008. Fire Probability, 

Fuel Treatment Effectiveness and Ecological Tradeoffs in 

Western U.S. Public Forests. pp.1-7 (7). The Open Forest 

Science Journal, Volume 1. 2008. http://www.benthamopen.org/pages/gen.php?file=1TOFSCIJ.pdf

Oregon Wild provided the comment referencing this document: 

“Fuel reduction may have little or no beneficial effect on low 

severity fires (which are largely controlled by favorable weather 

conditions) or high severity fires (which are largely controlled by 

unfavorable weather conditions).”

inevitable in areas left untreated and is, instead, expected to affect only a relatively small fraction of such 

areas at the broad scale of our analysis. Factoring in the probability of fire, using our framework, can 

significantly improve the assessments of the risks posed to aquatic systems by treating or not treating forest 

fuels. Where site-specific data on fire probabilities exist, the framework can be used to help locate treatments 

where they are most likely to encounter higher severity fire, increasing the likelihood of treatment benefits. In 

fact, our results indicate that such efforts are crucial."

The authors point out that their estimate represents an initial, broad-scale first approximation of the potential of 

fire to affect areas with a given time frame, based on the assumption that fire and treatments are random. 

Further, they point out that although fire is not random, data are insufficient to accurately quantify more local 

patterns. Their analysis provides a West-side and regional first approximation of the likely upper bound of fuel 

treatment effectiveness, but is not applicable to all smaller analysis areas. 

A more appropriate empirical approach is that provided by Stephens, Scott L.; Moghaddas, Jason J.; 

Edminster, Carl; Fiedler, Carl E.; Haase, Sally; Harrington, Michael; Keeley, Jon E.; Knapp, Eric E.; McIver, 

James D.; Metlen, Kerry; Skinner, Carl N.; Youngblood, Andrew. 2009. Fire treatment effects on vegetation 

structure, fuels, and potential fire severity in western U.S. forests. Ecological Applications. 19(2): 305-320. 

Recent work in ponderosa pine forests at Black Mountain in northeastern California, similar to Lookout 

Mountain, showed that tree survival after wildfire was greatest in those areas that had both thinning and 

prescribed fire prior to the wildfire event. Survival was near zero for the untreated areas. Survival in thinnedonly areas was greater than untreated areas but substantially less than the areas with both treatments. Ritchie 

et al. 2007. Probability of tree survival after wildfire in an interior pine forest of northern California: Effects of 

thinning and prescribed fire. Forest Ecology and Management 247: 200-208.

Mark J. Schroeder & Charles C. Buck. 1977. FIRE WEATHER . . 

. A Guide For Application Of Meteorological Information To Forest 

Fire Control Operations. U.S. Government Printing Office: 0-244 

:923, first printed in May 1970. Reviewed and approved for 

reprinting August 1977. Stock No. 001-000-0193-0 / Catalog No. 

A 1.76:360.

Oregon Wild comment: “FIRE WEATHER, a joint U. S. 

Department of Commerce and U. S. Department of Agriculture 

document, is a 229 page detailed, scientific explanation, which 

explains *closed canopy forest* as one which *provides a variety 

of benefits that decrease the risk of forest fires *and states that* 

all features of the environment that affect heating and cooling are 

_significant_. *”

Moisture stress levels and ambient temperature-relative humidity during prolonged late-summer dry spells in 

low elevation ponderosa pine forests such at Lookout Mountain likely result in little reduction in fire risk despite 

"closed-canopy" structure. Proposed fuel treatments are designed to shift fires from high severity to low 

severity. Empirical evidence for this shift is in the literature; see, for example, recent work in ponderosa pine 

forests at Black Mountain in northeastern California, similar to Lookout Mountain, where tree survival after 

wildfire was greatest in those areas that had both thinning and prescribed fire prior to the wildfire event. 

Survival was near zero for the untreated areas. Survival in thinned-only areas was greater than untreated 

areas but substantially less than the areas with both treatments. Ritchie et al. 2007. Probability of tree survival 

after wildfire in an interior pine forest of northern California: Effects of thinning and prescribed fire. Forest 

Ecology and Management 247: 200-208.
Appendix F Response to Public Comment

EXF Final EIS Page 56 of 88

Stephens 1998. “Evaluation of the effects of silvicultural and fuels 

treatments on potential fire behaviour in Sierra Nevada mixedconifer forests.” Forest Ecology and Management 105(1):21-35.

Oregon Wild comments: “Stephens used FARSITE to investigate 

the interaction between slash from logging and fire behavior. 

When silvicultural treatments were conducted without reducing 

slash, the simulated fire behavior appeared more extreme than in 

the area that had not been harvested at all.

We did not find any empirical studies that evaluated commercial 

harvesting as a means of altering fire behavior. ... studies 

suggest that slash resulting from logging is a key factor in 

predicting subsequent fire risk and that removal of large diameter 

trees alone may contribute to increased fire severity.

A report prepared for Congress stated: “We do not presume that 

there is a broad scientific consensus surrounding appropriate 

methods or techniques for dealing with fuel build-up or agreement 

on the size of areas where, and the time frames when, such 

methods or techniques should be applied” (US GAO RCED-99-

65. 1999:56). A research report by Omi and Martinson (2002:1) 

stated: “Evidence of fuel treatment efficacy for reducing wildfire 

damages is largely restricted to anecdotal observations and 

simulations.””

This paper models fire behaviour in a mixed-conifer forest and investigates how silvicultural and fuels 

treatments affect potential fire behaviour. From a bstract: " The computer program FARSITE was used to 

spatially and temporally model fire growth and behaviour. Fire modelling was performed in the North Crane 

Creek watershed of Yosemite National Park. Treatments were simulated by adjusting fuel (total load, load-bysize class, depth), height-to-live crown base, tree height, and crown density parameters. Treatments modeled 

included prescribed burn, pile and burn, cut and scatter, thinning and biomass, thinning and biomass followed 

by prescribed burn, and salvage or group selection harvest with and without slash and landscape-level fuel 

treatment. The prescribed burn, thinning and biomassing followed by prescribed burn, and salvage or group 

selection with slash and landscape fuel treatments resulted in the lowest average fireline intensities, heat per 

unit area, rate of spread, area burned, and scorch heights. Cut and scatter, salvage or group selection 

treatments that do not treat slash fuels resulted in fire behaviour that is more extreme than the untreated 

forest. Restoration of mixed-conifer ecosystems must include an examination of how proposed treatments 

affect fuel structures. Combinations of prescribed fire and/or mechanical treatments can be used to reduce 

wildfire hazard."

The FEIS discloses that because of whole tree yarding, there will be little activity fuel (slash) (p. 17, 96). Slash 

from small-tree thinning will be utilized when possible; but the potential for a lag time (typically 3 to 12 months) 

between small tree thinning and fuel treatments is disclosed in the FEIS (p. 96).

Jonathan R. Thompson, Thomas A. Spies 2009. Vegetation and

weather explain variation in crown damage within a large mixedseverity wildfire. Forest Ecology and Management 258 (2009) 

1684–1694. 

Oregon Wild states: “In areas with relatively high productivity that 

can support shrubs, canopy removal via thinning is very likely to 

stimulate the proliferation of shrubs and create the very 

conditions that favor more severe crown damage during fire. This 

study also challenges the very popular notion that dense forests 

are a fire hazard.”

Reported work on the 2002 biscuit Fire in southwestern Oregon may be relevant despite large differences in 

plant associations. In a retrospective study, the authors found the most important predictors of total crown 

damage during an extensive and prolonged wildfire were the percentage of pre-fire shrub-stratum vegetation 

cover and average daily temperature. The most important predictors of conifer damage were average daily 

temperature and ‘‘burn period,’’ an index of fire weather and fire suppression effort. The median level of 

damage was 32% within large conifer cover and 62% within small conifer cover. Open tree canopies with high 

levels of shrub-stratum cover were associated with the highest levels of tree crown damage, while closed 

canopy forests with high levels of large conifer cover were associated with the lowest levels of tree crown 

damage. They conclude that weather and vegetation conditions — not topography — were the primary 

determinants of Biscuit Fire crown damage. In work proposed at Lookout Mountain, shrub layers would also 

be treated to reduce fuel ladders.

Veblen, 2003. Key issues in fire regime research for fuels 

management and ecological restoration.

This presentation from conference proceedings is a broad review of fire regime research in ponderosa pine 

systems. The author specifically examines geographical variability in fire regimes for ponderosa pine 
Appendix F Response to Public Comments

 EXF Final EIS Page 57 of 88

Sierra Club provided comment that references this document: 

“Throughout the region the Forest Service has employed dubious 

fire models to claim that commercial logging is the only way to 

serve the Forest Service’s needs. These models do not give, nor 

can they give, an adequate explanation of how mechanical fuels 

treatment can reduce the risk of fire. (Morrison and Smith, 2005; 

Veblen 2003; Carey and Schumann, 2003, and new science 

studies by Veblen, Rhodes, and others in the comment Exhibits 

C-I, II, and IV).”

dominated forests and provides research recommendations for future work. From Abstract: “The premise 

behind many projects aimed at wildfire hazard reduction and ecological restoration in forests of the western 

United States is the idea that unnatural fuel buildup has resulted from suppression of formerly frequent fires. 

This premise and its implications need to be critically evaluated by conducting area-specific research in the 

forest ecosystems targeted for fuels or ecological restoration projects.”

From Conclusion: "This essay was written to introduce some of the key limitations and issues in fire regime 

research in the context of wildfire hazard management and ecological restoration. One of the principal 

messages is that broad generalizations and premises need to be carefully examined for particular ecosystems 

and management objectives. The goal of the essay has not been to challenge the widespread consensus that 

fire exclusion has had undesirable consequences in many western forest ecosystems. Rather, it is hoped that 

critical evaluation of the premises of the fire exclusion/fuel buildup viewpoint for particular ecosystem types 

and locations will help to avoid inappropriate or ineffective management strategies."

The comment by the Sierra Club that the Forest Service uses dubious fire models and that the use of fire 

models cannot explain how mechanical fuels treatments reduce fire risk is not support by the citation. The 

EXF FEIS has relied on site-specific information gathered in the field to determine fire hazard. The FEIS 

describes how thinning, mowing, and underburning will reduce the risk of fire; and the Flammap model 

displays the changes spatially. The referenced document doesn’t provide science that opposes methods used 

in the EXF project.

USDA PNW Research. Science Findings, . 

http://www.fs.fed.us/pnw/sciencef/scifi85.pdf

Oregon Wild provided a comment that references this document: 

“There is evidence that commercial logging objectives can conflict 

with the attainment of objectives for both habitat and fire hazard.”

The comment is not supported by the reference. Instead, the research that occurred in the Gotchen LateSuccessional Reserve in Washington suggests that the potential for compatibility between fire and habitat 

objectives could be increased through landscape silviculture. Taking their cue from historical disturbance 

dynamics, researchers developed prescriptions for individual units but evaluated them collectively according to 

management objectives for the entire reserve. The places where treatments contributed most to 

accomplishing both objectives were identified by using simulation modeling. Solutions included sets of 

treatments that, when evaluated in aggregate for the entire reserve, could reduce the threat of high-severity 

fire, maintain older forest structure, and break even in costs and proceeds from timber harvest over the next 

30 years. In this scenario, trees removed were mainly in the 7- to-16-inch size classes of grand fir, a shadetolerant conifer.

White House, Office of the Press Secretary. 2009 Memorandum 

for the Heads of Executive Departments and Agencies. Subject: 

Scientific Integrity 

The Sierra Club provided comments that reference this 

document: “The EXF Project fails the expert, reasonableness, 

accuracy, and scientific requirements of the NEPA, recently 

reaffirmed in President Obama’s March 9th, 2009 Scientific 

This memo states “Science and the scientific process must inform and guide decisions of my Administration 

on a wide range of issues, including improvement of public health, protection of the environment, increased 

efficiency in the use of energy and other resources, mitigation of the threat of climate change, and protection 

of national security.” The EXF project includes an important research component that, as stated in the FEIS, 

will help to inform and guide management decision in the future. 

The memo directs specific actions to take place to ensure the highest level of integrity in all aspects of the 

executive branch's involvement with scientific and technological processes. Commenters have expressed 
Appendix F Response to Public Comment

EXF Final EIS Page 58 of 88

Integrity Memorandum (see below & comment Exhibit C, Volume 

V compilation).”

concerns about the scientific validity of the currently proposed research and cited this memo in support of their 

position. It has been noted that the Study Plan was developed, reviewed, and approved by the Research arm 

of the Forest Service following the manual direction that ensures the scientific integrity.

Whitehead, R.J. G. Russo, B.C. Hawkes, S.W. Taylor, B.N. 

Brown, H.J. Barclay, and R.A. Benton. 2006. Effect of a spaced 

thinning in mature lodgepole pine on within-stand microclimate 

and fine fuel moisture content. In P.L. Andrews and B.W. Butler 

(compilers). Fuels Management - How to Measure Success. 

USDA Forest Service, Rocky Mountain Research Station, Fort 

Collins, Colorado, Proceedings RMRS-P-41. Pp. 523-536. 

http://warehouse.pfc.forestry.ca/pfc/26362.pdf

Oregon Wild provided a comment that references this document: 

“Removing approximately half of the basal area of a mature stand 

of lodgepole pine in southeastern British Columbia, by thinning 

from below to uniform 4 m inter-tree spacing, resulted in 

decreased canopy interception of rainfall and increased withinstand solar radiation, wind speed, and near surface air 

temperature.”

The reported work is marginally relevant. Mature lodgepole pine forests differ structurally from the ponderosa 

pine forests at Lookout Mountain, and residual structure after thinning of mature lodgepole pine would share 

little structural attributes with stands at Lookout Mountain after the proposed treatments are implemented.

Table F-3. Non-substantive comments. NEPA states that comments on an EIS shall be as specific as possible (40 CFR 1503.3 Specificity of Comments). The 

following documents are considered non-substantive comments that do not warrant further response. In this case the referenced document was considered as a

“comment” and was evaluated for relevance to the project. The following table explains the Forest Service rationale for categorizing these as non-substantive 

comments. 

Referenced Document Forest Service Consideration / Why Considered Non-Substantive

Agee, 1996 Fire Regimes and Approaches for 

Determining Fire History in The use of fire in forest 

restoration Gen. Tech. Rep. INT-GTR-341. Ogden, UT. 

USDA

Two-page talk from conference proceedings. General article about fire regimes and fire history. Commenters do not 

reference this document in any comments. This paper does not provide any science that opposes methods used in the 

EXF FEIS.

Agee and Skinner [2005, For. Ecol & Mgt., vol. 211:83-

96]) 

Comment from Oregon Wild: “Agee and Skinner note 

that crown thinning alone is not likely to meaningfully 

change potential fire behavior or effects. Events on the 

American River Complex fire support these general 

Crown thinning alone is not part of the proposed treatments in the EXF project. The Agee and Skinner document does 

not provide science that opposes methods used in the EXF FEIS.
Appendix F Response to Public Comments

 EXF Final EIS Page 59 of 88

findings.”

Altman, Bob. 2000. Conservation Strategy for Landbirds

of the East-Slope of the Cascade Mountains in Oregon 

and Washington. Ver. 1.0, June 2000 121 pp.

Not peer-reviewed science. This document is used in the FEIS; it provides information on key habitat types, biological 

objectives and conservation strategies for these habitat types and focal species. Commenters did not reference this 

document in comments; no distinct issue with the EIS was expressed concerning this publication and its use in the FEIS.

Altman, Bob and Aaron Holmes. 2000. Conservation 

Strategy for Landbirds in the Columbia Plateau of Eastern 

Oregon and Washington. Ver. 1.0, March 2000 131 pp.

Not peer-reviewed science. This document is not used in the FEIS because the EXF project relies on Altman's 

Conservation Strategy specific to the East-Slope of the Cascade Mountains which is the area the EXF project falls within. 

Commenters did not reference this document in comments; no distinct issue with the EIS was expressed concerning this 

publication and its relevance to the FEIS.

E. Ampoorter, R. Goris, W.M. Cornelis, and K. Verheyen, 

Laboratory of Forestry, Ghent University, Geraardsbergse 

Steenweg 267, B-9090 Gontrode, Belgium, Inverde vzw, 

Duboislaan 2, B-1560 Hoeilaart, Belgium, Department of 

Soil Management and Soil Care, Ghent University, 

Coupure Links 653, B-9000 Ghent, Belgium, January 

2007.

This research into the impact of mechanized logging on compaction status of sandy forest soils and results are very 

similar to science cited in the EXF FEIS (Chapter 3.3.4). Namely, that the repeated travel by heavy equipment can 

increase soil bulk density and strength in coarse textured soils. The difference is that the research occurred in different 

physiographic regions and citations in the FEIS include research that occurred in Oregon or the Pacific Northwest.

Andrews & Anthony, 2004. Winter habitat use by spotted 

owls on BLM within the boundaries of the timbered rock 

fire.

Not peer-reviewed. This document is not referenced in the FEIS because research into the use of burned forest by 

spotted owls is not relevant to the EXF project or analysis. Commenters did not reference this document in comments; 

no distinct issue with the EIS was expressed concerning this publication and its relevance to the FEIS.

Andrews, Perkins, Thrailkill, Poage, Tappeneiner. 2005. 

Silvicultural Approaches to Develop Northern Spotted Owl 

Nesting Sites, Central Coast Ranges, Oregon. West. J. 

Appl. For. 20(1):13-27.

Oregon Wild comment: “Accelerating the development of 

multi-storied stands may increase the risk of wildfire.”

Document presents a simulation model to examine thinning and NSO nesting habitat. From abstract: "We used an 

individual-tree, distance-independent growth model to explore a range of management scenarios for young Douglas-fir 

stands (age class 50 years) and estimated which scenarios promoted the development of forest patches that emulate the 

species mix and diameter distributions at known spotted owl nest sites in the central Coast Ranges of Oregon. Our 

modeling indicates that without silvicultural intervention or natural disturbances, the young stands (170–247 trees/ac) 

investigated did not develop features associated with spotted owl nest sites within 160-year total stand age...”

Proposed treatments at Lookout Mountain generally are designed to prevent the development of multi-storied stands by 

thinning from below and treating fuels. Only in four units is the prescription designed to establish a new cohort as the first 

step toward a long-term goal of shifting the single-cohort, single-storied structure toward a multi-cohort, multi-storied, 

ponderosa pine forest more aligned with known old-growth structural characteristics. For a full description of these 

structural attributes, see Youngblood et al. 2004. Stand structure in eastside old-growth ponderosa pine forests of 

Oregon and northern California. Forest Ecology and Management 199: 191-217.

Baker, William, 2009 Fire Ecology in Rocky Mountain 

Landscapes Island Press. 544 pp.

Abstract of a 544-page book. Baker “argues that the most effective action is to rapidly limit and redesign people-nature 

interfaces to withstand fires” rather than re-establishing past fire regimes or focusing on fuels reduction and fire 

suppression.

Commenters did not reference this document in comments and expressed no direct relevance of this publication to the 
Appendix F Response to Public Comment

EXF Final EIS Page 60 of 88

EXF project. Risk reduction in the EXF project is focused on the role of the Experimental Forest as a place for 

silvicultural experiments. 

Baker, Veblen & Sherriff, 2006. Fire, fuels and restoration 

of ponderosa pine - Douglas-fir forests in the Rocky 

Mountains, USA.

citation was incomplete: Baker, W. L., T. T. Veblen, and 

R. L. Sherriff. 2007. Fire, fuels and restoration of 

ponderosa pine-Douglas fir forests in the Rocky 

Mountains, USA. Journal of Biogeography 34:251-269.

Provides evidence that ponderosa pine and mixed ponderosa pine–Douglas fir forests in the US Rocky Mountains has 

experienced more infrequent, high-intensity fires, in contrast to the widely disseminated model of frequent, low-severity 

surface fires developed for the ponderosa pine forests of the Southwestern USA. A restoration model, based on this lowseverity fire model, focuses on thinning and prescribed burning to restore historical forest structure. Concludes that in 

the Rocky Mountains "For the purpose of ecological restoration in Rocky Mountain ponderosa pine–Douglas fir 

landscapes, the most appropriate action at the present time is a mixture of modest passive and active approaches. 

Undisturbed mature forests require little or no restoration – a passive approach is best." 

The aim of this article is to elaborate a new variable-severity fire model and evaluate the applicability of this model, along 

with the low-severity model, for the ponderosa pine-Douglas fir forests of the Rocky Mountains. Lookout Mountain 

supports single-cohort stands that resulted from a landscape-scale, stand-replacement fire. This is an example of a nontypical low-severity disturbance and would support the authors claim of more frequent variable-severity disturbances. The 

work is not relevant from the context that the proposed research is not focused on a restoration goal derived from a lowseverity model. Rather, the goal is retention of large trees into the future. 

This document is not used in the FEIS because it has no inference for the east Cascades, and a restoration model for 

ponderosa/Douglas-fir forests in the Rocky Mountains Is not relevant to the EXF project.

Beschta et al. 2004. Postfire Management on Forested 

Public Land of the Western United States. Conservation 

Biology, Volume 18, No.4, pp. 957-967

This paper is a combination literature search and opinion piece concerning the detrimental effects of post fire salvage 

logging. The authors provide guidelines for managing post-fire landscapes.

This document is not used in the FEIS because it is not relevant to the EXF project.

BLM WOPR FEIS

http://www.blm.gov/or/plans/wopr/final_eis/index.php

Work is not relevant: reported work is outside the ecological province and addresses logging of old-growth forests. 

Proposed research is focused on treatments to retain young large trees that have the greatest potential to grow old.

Bond et al., 2002. Short-term effects of wildfires on 

spotted owl survival, site fidelity, mate fidelity, and 

reproductive success. Wildlife Society Bulletin 30:1022-

1028.

Found that wildfires did not have significant short-term impacts on NSOs: "documented minimum survival, site fidelity, 

mate fidelity, and reproductive success for 21 spotted owls after large (>540 ha) wildfires occurred within 11 owl 

territories in California, Arizona, and New Mexico" Conclude that "Wildfires may have little short-term impact on survival, 

site fidelity, mate fidelity, and reproductive success of spotted owls"

The EXF project does not propose any post-fire salvaging, nor is the project’s purpose to protect spotted owl habitat. 

This document is not used in the FEIS because it is not relevant to the EXF project.

Briggs, Christopher M. 2005. Contribution of Pinus 

Ponderosa Charcoal to Soil Chemical and Physical 

Properties. In Briggs, Breiner, Graham Pinus Ponderosa 

Charcoal.

Comment from Sierra Club: “Agency Inability to The Forest Service does not disagree that mechanical thinning can create activity slash. The EXF FEIS recognizes this, 
Appendix F Response to Public Comments

 EXF Final EIS Page 61 of 88

Accomplish Timely Ecologically Acceptable Effective 

Slash Treatment. Mechanical thinning, especially that 

focuses on reducing the canopy and stand density, 

generates large quantities of slash by relocating 

branches, twigs, and needles from the canopy to the 

ground See generally Brown et al. (2004), Stephens 

(1998), van Wagtendonk (1996) and Weatherspoon 

(1996).

No complete citations are provided, so Forest Service 

assumes Brown et al is referring to Richard T. Brown, 

James K. Agee, Jerry F. Franklin. 2004. Forest 

Restoration and Fire: Principles in the context of place. 

Conservation Biology. Vol. 18, No. 4 pp 903-912.

as well as the potential for increased fire risk during the time between thinning and slash removal. As the FEIS points 

out, however, there will be relatively low levels of slash because of whole tree yarding and thinning is followed in all units 

by mowing and underburning to reduce surface fuels. This is also addressed previously in the Response to Comments. 

The Brown et al (2004) abstract states “There is broad consensus that active management through thinning and fire is 

urgently needed in many forests of the western United States. This consensus stems from physically based models of 

fire behavior and substantial empirical evidence. But the type of thinning and fire and where they are applied are the 

subjects of much debate. We propose that low thinning is the most appropriate type of thinning practice. Treating 

surface fuels, reducing ladder fuels, and opening overstory canopies generally produce fire-safe forest conditions, but 

large, fire-resistant trees are also important components of fire-safe forest.” This document does not provide science that 

opposes methods in the EXF project. The paper also displays the factors that increase fire resilience from Agee (2002) 

and Hessburg & Agee (2003), which the EXF FEIS has relied on. 

The FEIS cites van Wagtendonk (1996) who found in fire simulations that a reduction in fuel loads decreased subsequent 

fire behavior, increased fireline control possibilities, and decreased fire suppression costs (as cited in the EXF FEIS p. 

108). 

Weatherspoon (1996) is also used in the EXF analysis (p. 96): “Where thinning is followed by sufficient treatment of 

surface fuels, the overall reduction in expected fire behavior and fire severity usually outweigh the changes in fire 

weather factors such as wind speed and fuel moisture.”

Miles A. Hemstrom, Wendel J. Hann, Rebecca A. 

Gravenmier, Jerome J. Korol. 2000. [SAG] Landscape 

Effects Analysis of the [ICBEMP] SDEIS Alternatives. 

USDA/USDI, draft March 2000

Oregon Wild comment: “The great majority (80 percent or 

more) of lands administered by the FS/BLM in the 

ICBEMP management region currently experience low 

probabilities of uncharacteristic wildfire. ... Fire 

disturbances are about equally split between low, 

moderate and high classes at present.” Also referenced 

with snag comments.

Draft EIS. Not peer-reviewed. The FEIS displays the current expected fire behavior, crown fire potential, and fire 

probability for the EXF project area. This information is based on site-specific and satellite data. The referenced 

document also does not provide any science that counters that used in the FEIS dead wood analysis.

Henry Carey and Martha Schumann. Modifying WildFire 

Behavior – The Effectiveness of Fuel Treatments — The 

Status of Our Knowledge. April 2003; 

http://www.theforesttrust.org/images/swcenter/pdf/Workin

gPaper2.pdf

This unpublished review is outdated because it does not incorporate the recent compilation of new studies designed to 

characterize the ecological effects of thinning and prescribed fire as means of fuels reduction. See for example: 

Youngblood et al. 2008. Changes in fuelbed characteristics and resulting fire potentials after fuel reduction treatments in 

dry forests of the Blue Mountains, northeastern Oregon. Forest Ecology and Management 255: 3151-3169. Also: 

Stephens et al. 2009. Fire treatment effects on vegetation structure, fuels, and potential fire severity in western U.S. 

forests. Ecological Applications 19: 305-320.

Chan et al. 2006. Overstory and understory development Study conducted on 30 year old Douglas-fir plantations in the Coast Range to test strategies to increase structural and 
Appendix F Response to Public Comment

EXF Final EIS Page 62 of 88

in thinned and underplanted Oregon Coast Range 

Douglas-fir stands. Can. J. of For. Res. 36:2696-2711

species diversity. The authors concluded that thinning can accelerate development of old growth characteristics.

The biophysical environments of the above study area and the EXF project area too dissimilar to apply thinning densities 

or planting strategies to the current project. 

Peter Chesson 2000. General Theory of Competitive 

Coexistence in Spatially-Varying Environments. 

Theoretical Population Biology 58, 211-237 (2000). 

http://eebweb.arizona.edu/Faculty/chesson/Peter/Reprint

s/2000_General_Theory.pdf

Comment from Oregon Wild concerns habitat competition between barred owls and spotted owls. This is a highly 

theoretical ecology paper that cannot be applied to the analysis in the EXF FEIS. From abstract: "A general model of 

competitive and apparent competitive interactions in a spatially-variable environment is developed and analyzed to 

extend findings on coexistence in a temporally-variable environment to the spatial case and to elucidate new principles." 

The referenced document does not provide any science that counters that used in the EXF FEIS.

Christensen, Glenn A.; Campbell, Sally J.; Fried, Jeremy 

S., tech. eds. 2008. California’s forest resources, 2001–

2005: five-year Forest Inventory and Analysis report. 

Gen. Tech. Rep. PNW-GTR-763. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 183 p.

Oregon Wild comment: “....These results suggest that 

the fuels management challenge may be more tractable 

than has been assumed.” 

This broad-scale inventory of all forested lands in California may have only marginal relevancy to the proposed 

treatments at Lookout Mountain. Based on crown fire hazard analysis using the Forest Vegetation Simulator (FVS) and 

its Fire and Fuels Extension (FFE) to calculate indices of crown fire potential and fire type under severe weather 

conditions, each inventory plot was assigned one of four classes of fire types. While about 8% of the total forested 

landbase of the north interior California was mapped as potentially supporting active crown fires, 35% was mapped as 

potentially supporting passive crown and conditional surface fires with crown fire runs continuing unless canopy gaps 

interrupt the crown fire spread. The remaining 57% of the forested landbase potentially supports surface fires. This 

analysis fails to incorporate severity of fire with respect to tree mortality. The EXF FEIS fully addresses this issue by 

using a similar modeling approach with FlamMap, 97th percentile weather from a nearby station with long-term records, 

and more detailed stand structure and fuels data.

Colbert & Pederson. 2008. Relationship between radial 

growth rates and lifespan within North American tree 

species. Ecoscience 15(3), 349-357 (2008). 

http://www.ecoscience.ulaval.ca/catalogue/FA3149-

black.pdf

This is a meta-analysis of tree-ring data to quantify relationships between growth and lifespan in 4 North American tree 

species: Tsuga canadensis, Quercus alba, Pinus ponderosa, andPseudotsuga menziesii. From Abstract: " In all 4 

species the longest-lived trees experienced slower growth rates than trees sampled at relatively young ages. 

Furthermore, long-lived trees with slow growth rates appear to mix with shorter-lived, fast-growing trees in the same 

forests. Such a relationship between growth and lifespan within species may be an important component of biodiversity 

that holds implications for old-growth forest development and long-term management." Discussion mentions a number of 

limitations with the data set. Cited in comment regarding carbon storage in suppressed trees. Carbon discussion 

included in the FEIS.

Courtney, Blakesley, Bigely, Cody, Dumbacher, Fleischer, 

Franklin, Franklin, Gutierrez, Marzuluff, Sztukowski. 

September 2004. Scientific evaluation of the status of the 

Northern Spotted Owl. Sustainable Ecosystems Institute, 

Portland, Oregon. 

http://www.sei.org/owl/finalreport/finalreport.htm

In response to comments that the agency must consider this document, it is referenced in the FEIS (p. 53) and the 

Biological Opinion. See previous responses p. 32 of this appendix.

Covington, W. Wallace, Everett, Richard L., et. al. 1994 

Historical and Anticipated Changes in Forest Ecosystems 

From Abstract " Continuation of historical trends of climate change, modified atmospheric chemistry, tree density 

increases, and catastrophic disturbances seems certain. However, ecosystem management strategies including the 
Appendix F Response to Public Comments

 EXF Final EIS Page 63 of 88

of the Inland West of the United States. Jour. Of 

Sustainable Forestry, 2:1 pp 13-63

initiation of management experiments can facilitate the adaptation of both social and ecological systems to these 

anticipated changes. A fairly narrow window of opportunity-perhaps 15-30 years-exists for land managers to implement 

ecological restoration treatments."

The Forest Service agrees that management experiments can help land managers adapt to ongoing and anticipated 

changes. The commenters provide no distinct issue with the FEIS in relation to this publication.

Raymond Davis and Joseph Lint. 2005. Chapter 3: 

Habitat Status and Trend. in Northwest Forest Plan—the 

First 10 Years (1994–2003): Status and Trends of 

Northern Spotted Owl Populations and Habitat. PNWGTR-648. 

http://www.fs.fed.us/pnw/publications/pnw_gtr648/pnwgtr648b.pdf

Comment from Oregon Wild: “The Oregon Coast Range province shows the most increase in fragmentation since 1994, 

based on the splitting index." 

This chapter describes forest to the west of the Cascades. Relevance to east-side forest fragmentation or habitat is 

unclear. Reference used in the BO. 

Curtis, Robert O.; Marshall, David D. 2009. Levels-ofgrowing-stock cooperative study in Douglas-fir: report no. 

18—Rocky Brook, 1963–2006. Res. Pap. PNW-RP-578. 

Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 91 p. 

http://www.fs.fed.us/pnw/pubs/pnw_rp578.pdf

Reported work with young Douglas-fir thinned to different stocking levels is relevant only in that the same growth-related 

principles apply in ponderosa pine. A more relevant work, because it comes from the study area, is the following: 

Cochran, P.H.; Barrett, James W. 1999. Growth of ponderosa pine thinned to different stocking levels in central Oregon: 

30-year results. Res. Pap. PNW-RP-508. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 27 p. (cited in the Study Plan). Cochran and Barrett show that thinning to wider spacing 

results in greater basal area increments per tree and a reduction in mortality, while total volume and total basal area per 

acre is not increased. This principle has been shown to occur in many tree species.

DeLuca, Thomas H. Undated. Wildfire Charcoal and 

Soil Processes. 

http://terrapreta.bioenergylists.org/delucawildfire.

Abstract. Not peer-reviewed. Commenters do not make reference to this document. This document provides 

information on charcoal and soil processes does not provide any science that opposes methods in the EXF project.

Depro, Brooks M. , Murray, Brian C., et. al. 2008 Public 

land, timber harvest, and climate mitigation: Quantifying 

carbon sequestration potential on U.S. public timberlands. 

ScienceDirct Forest Ecology and Management 255: pp 

1122-1134

This article discussed the carbon implications of timber management on public lands nationally, and compares two broad 

scenarios over a national scale, a 'no timber harvest' scenario vs a '1980s type timber harvest.’ Commenter suggested 

that the Forest carefully consider the implications of this document. 

From abstract: "To help decision makers understand the carbon implications of potential changes in public timberland 

management, we compared a baseline timber harvest scenario with two alternative harvest scenarios and estimated 

annual carbon stock changes associated with each. Our analysis found that a 'no timber harvest' scenario eliminating 

harvests on public lands would result in an annual increase of 17-29 million metric tonnes of carbon (MMTC) per year 

between 2010 and 2050--as much as a 43% increase over current sequestration levels on public timberlands and would 

offset up to 1.5% of total US GHG emissions"

Donato et al. 2006. Post-Wildfire Logging Hinders 

Regeneration and Increases Fire Risk. 

www.scienceexpress.org 5 January 

This research is not relevant to the EXF Project. It is a study of post wildfire regeneration in western Oregon, after the 

Biscuit Fire. Article presents data that salvage logging may hinder regeneration and increase fire risk.
Appendix F Response to Public Comment

EXF Final EIS Page 64 of 88

2006/page1/10.1126/science.1122855

Donovan, Geoffrey and Thomas C. Brown. 2007. Be

careful what you wish for: the legacy of Smokey Bear. 

Front Ecol Environ 2007; 5(2):73-79.

This paper discusses Forest Service wildfire suppression policy and the need to change these policies to allow the use of 

wildfire. The authors generally support fuel management. This is a policy review that does not provide science that 

counters that used in the EXF FEIS.

Dunn, David and James P. Crutchfield 2006. Insects, 

Trees, and Climate: The Bioacoustic Ecology of 

Deforestation and Entomogenic Climate Change. Santa 

Fe Institute Working Paper. December 11, 2006

Not peer-reviewed science. The commenters provided no discrete issue associated with this paper and do not cite it in 

their comments. 

Everett, R., P. Hessbur, et. al. 1994 Old Forests in 

Dynamic Landscapes Dry-site forests of eastern Oregon 

and Washington. J. Forestry Jan. 1994. Pp 22-25

This article describes old forests of eastern OR and WA, contrasting historic (for this article, 1930-50) and current (1980-

90) abundance. Describes the need to both retain old growth forest and preserve ecological processes, including 

disturbance regimes.

This reference does not provide science that opposes methods or conclusions in the EXF FEIS. The EXF project will 

retain the largest trees which could possibly develop into old growth ponderosa pine and commenters provide no 

reference to this document in their comments.

Fitzgerald, Stephen A. 2005. Fire Ecology of Ponderosa 

Pine and the Rebuilding of Fire-Resilient Ponderosa Pine. 

In: Ritchie, Martin W.; Maguire, Douglas A.; Youngblood, 

Andrew, tech. coordinators. Proceedings of the 

Symposium on Ponderosa Pine: Issues, Trends, and 

Management, 2004 October 18-21, Klamath Falls, OR. 

Gen. Tech. Rep PSW-GTR-198. Albany, CA: Pacific 

Southwest Research Station, Forest Service, U.S. 

Department of Agriculture:

From paper: “Restoration treatments (thinning, prescribed fire, mowing and other mechanical treatments) that reduce 

surface, ladder, and crown fuels can reduce fire severity and the potential for high-intensity crown fires.”

Commenters provided no discrete issue with respect to this document. The FEIS references Agee 2002, and Hessburg 

& Agee 2003 for principles of improving fire-resilience – reducing surface fuels, removing ladder fuels, leaving large fireresistant trees, and spacing tree crowns. The Fitzgerald paper supports methods proposed in the EXF project to reduce 

fire severity and potential for high-intensity crown fire.

Foster, David R. and David A. Orwig. 2006. Preemptive 

and Salvage Harvesting of New England Forests: When 

Doing Nothing Is a Viable Alternative. Conservation 

Biology Vol. 20, No. 4, August 2006

Article provides data from experiment in New England to compare impacts from disturbances vs harvest post disturbance 

OR preemptive harvesting before disturbance. From Abstract "From an ecosystem perspective there are strong 

arguments against preemptive and salvage logging or the attempt through silvicultural means to improve the resistance 

or resilience of forests to disturbance and stress. There are often valid motivations for salvage or preemptive logging 

including financial considerations, human safety, and a desire to shape the long-term composition and resourceproduction characteristics of forests. Nonetheless, there are many ecological benefits derived from leaving forests alone 

when they are affected or threatened by disturbances and pest and pathogen outbreaks." From discussion "Decisions on 

whether to salvage, cut preemptively, or leave forests after large natural disturbances depend on forest region, 

disturbance regimes, and landowner objectives. For example, New England forests do not commonly experience insect 

outbreaks that lead to large accumulations of hazardous fuels as the southern or western United States do."

The goals and objectives for the Experimental Forest are outlined in the FEIS (pp. 11) and the purpose and need for the 
Appendix F Response to Public Comments

 EXF Final EIS Page 65 of 88

project have been developed based on those goals and objectives. This article provides no scientific opposition to the 

need for action described in the FEIS or the effects analysis. Alternatives to risk reduction have been addressed in the 

No Action alternative, and alternatives not considered in detail.

Franklin AB, Anderson DR, Gutierrez RJ, Burnham KP 

(2000) Climate, habitat quality, and fitness in northern 

spotted owl populations in northwestern California. Ecol 

Monogr 70:539–590.

Comment from Oregon Wild: “...effect of climate change...Uncertainty in the weather creates uncertainty for the owl 

which can be mitigated by maintaining a larger population which is more resilient to climate variations.”

The referenced document does not provide any science that counters that used in the EXF FEIS.

Franklin, Jerry F. 2007. Letter to Ralph Bloemers, Crag 

Law Center re: Eastside Screens – Old Growth 

Protections.

Not science. This letter refers to a fire salvage project and the author provides his opinion on the Forest Service 

proposal to use a particular method of identifying trees that will succumb.

This letter provides no science that counters methods used in the EXF FEIS. The commenters provide no discrete issue 

referenced to this document.

Oscar E. Gaggiotti and Ilkka Hanski. 2004. Chapter 14 -

Mechanisms of Population Extinction. In Ecology, 

Genetics, and Evolution of Metapopulations. Elsevier. 

2004. 

http://www.eeb.cornell.edu/sdv2/Readings/Gaggiotti&Han

ski.pdf 

The Biological Opinion from the U.s. Fish and Wildlife Service includes a discussion on barred owls and more 

importantly, gives wider-range context of the project area with the spotted owl across the Deschutes National Forest and 

Oregon. The referenced document does not provide any science that counters that used in the EXF FEIS.

Gray, Andrew N.; Monleon, Vicente J.; Spies, Thomas A. 

2009. Characteristics of remnant old-growth forests in the 

northern Coast Range of Oregon and comparison to 

surrounding landscapes. Gen. Tech. Rep. PNW-GTR790. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 45 p. 

http://www.fs.fed.us/pnw/pubs/pnw_gtr790.pdf (derived 

from Table 2, page 13.)

Shaw, David C.; Franklin, Jerry F.; Bible, Ken; Klopatek, 

Jeffrey; Freeman, Elizabeth; Greene, Sarah; Parker, 

Geoffrey G. 2004. Ecological setting of the Wind River 

old-growth forest. Ecosystems. 7: 427-439. 

http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_shaw0

01.pdf 

Comment from Oregon Wild references old-growth Douglas-fir/western hemlock forests in the coast range – This type of 

forest is not found within the project area, so the information is not relevant to the analysis.

Gretchen. 2008. Letter to unknown recipient re: biochar 

references

Not science. This is a note to undisclosed recipients from someone named Gretchen concerning biochar, which is a soil 

amendment. The note concludes that it “demonstrates the amazing symmetry and wisdom of Mother Nature.” 

This letter provides no science that counters methods used in the EXF FEIS, and the commenters provided no discrete 
Appendix F Response to Public Comment

EXF Final EIS Page 66 of 88

issue referenced to this document.

Hamman, Sarah T., Ingrid C Burke, & Eric E. Knapp. 

2008. Soil nutrients and microbial activity after early and 

late season prescribed burns in a Sierra Nevada mixed 

conifer forest. Forest ecology and management 256(3): 

367-374

Abstract provided. Article describes prescribed burns conducted in southern Sierra Nevada and impacts on soil nutrients 

and microbes. Different ecosystem and it is unclear if prescribed burns are conducted with thinning.

This research effort and results are very similar to those cited in the FEIS (Chapter 3.3.4). Namely, that fire severity is 

more of a factor affecting soil nutrient and microbial status than the timing (i.e. season) of burn. The difference is that the 

research occurred in a different physiographic region; citations in the EXF FEIS include research that occurred in Oregon 

or the Pacific Northwest.

See Table 2 in Han-Sup Han and Loren D. Kellogg. 2000. 

Damage Characteristics in Young Douglas-fir Stands from 

Commercial Thinning with Four Timber Harvesting 

Systems. Western Journal of Applied Forestry. 15(1):27-

33.

http://www.reo.gov/ecoshare/ccamp/pdf/WJAF.pdf);

Comment from Oregon Wild: Projects involving partial removal should analyze and consider the following 

factors...............Thinning might help or hinder forest growth....Furthermore, thinning can damage residual trees’ roots, 

stems, and canopies which may inhibit growth rates.”

Statement taken out of context. Reported work with young Douglas-fir thinned during winter rains is marginally relevant to 

thinning 165-year-old ponderosa pine because of stand structure and bark characteristics.

Hanson, Chad, 2006. Research Proposal: Post-fire 

Management of Snag Forest Habitat in the Sierra 

Nevada.

This is a research proposal to assess whether the black-backed woodpecker may be restricted to forest recently burned 

at high severity. The proposal would also study post-fire conifer mortality.

This information is not relevant to the EXF project because the EXF project does not involve post-fire management.

Harmon, Mark E. 2009 Testimony Before the 

Subcommittee on National Parks, Forests, and Public 

Lands of the Committee of Natural Resources for an 

oversight hearing on “The Role of Federal lands in 

Combating Climate Change”, March 3, 2009 19 pp

Not Science. This testimony involves providing the speaker’s expert opinion on forests role in carbon sequestration.

Carbon policy on federal lands is outside the scope of the EXF project.

Hebblewhite, M., R.H. Munro, and E.H. Merrill. 2009. 

Trophic consequences of postfire logging in a wolfungulate system. Forest Ecology and Management 257: 

1053-1062 (doi: 10.1016/j.foreco.2008.11.009)

This article describes research from the Canadian Rockies where authors studied the effects of postfire logging on 

trophic dynamics between wolves & ungulates. Examined plant biomass and ungulate responses to two treatments 

(post- and prefire logging) compared to a burned but unlogged area (control).

This information is not relevant to the EXF project as the EXF project does not involve postfire logging in a wolf-ungulate 

system. Commenters provided no discrete issue referenced to this document.

Henjum et al. 1993. Interim Protection for lateSuccessional Forest, Fisheries and Watersheds, National 

Forests East of the Cascade Crest, Oregon and 

Washington, A Report to the United States Congress and 

the President. Eastside Forests Scientific Society Panel.

Not peer-reviewed. This panel assessed current conditions (1993) of LOS, aquatic systems, roadless areas, and other 

elements in East side forests. The panel listed recommendations to be included in the Eastside Screens. The 

recommendations concentrate on protecting remaining late-successional/old-growth forests, aquatic diversity areas, 

roadless regions, riparian corridors, and soils because these elements constitute the basic building blocks for restoring 

the eastside landscape. The EXF FEIS addresses direction contained within the Eastside Screens.

Hessburg, P. F., K. M. Reynolds, R. E. Keane, K. M. From abstract "present a decision support application that evaluates danger of severe wildland fire and prioritizes 
Appendix F Response to Public Comments

 EXF Final EIS Page 67 of 88

James, and R. B. Salter. 2007. Evaluating wildland fire 

danger and prioritizing vegetation and fuels treatments. 

Forest Ecology and Management 247:1-17.

subwatersheds for vegetation and fuels treatment. We demonstrate the use of the system with an example from the 

Rocky Mountain region in the State of Utah; a planning area of 4.8 million ha encompassing 575 subwatersheds. In a 

logic model, we evaluate fire danger as a function of three primary topics: fire hazard, fire behavior, and ignition risk. 

Each primary topic has secondary topics under which data are evaluated."

The EXF FEIS does not rely on this paper which looks at prioritizing fuels treatments across a large landscape (study 

uses a 4.8 million ha landscape). The EXF project area has already been determined a high priority for fuels reduction 

and thinning.

Tara Hudiburg, Beverly Law, David P. Turner, John 

Campbell, Dan Donato, And Maureen Duane 2009. 

Carbon dynamics of Oregon and Northern California 

forests and potential land-based carbon storage. 

Ecological Applications, 19(1), 2009, pp. 163–180 

http://terraweb.forestry.oregonstate.edu/pubs2/Hudiburg2

009EA.pdf

Reviews regional ability of forests to store carbon. Concludes that: "The potential to store additional carbon in Pacific 

Northwest forests is among the highest in the world because much of the area has forests that are long-lived (e.g., 

Douglas-fir) and maintain relatively high productivity and biomass for decades to centuries." From abstract: "Within 

ecoregions, mean live and dead biomass were usually higher on public lands, primarily because of the younger age class 

distribution on private lands. Decrease in NPP with age was not general across ecoregions, with no marked decline in old 

stands (.200 years old) in some ecoregions. In the absence of stand-replacing disturbance, total landscape carbon 

stocks could theoretically increase from 3.2 6 0.34 Pg C to 5.9 6 1.34 Pg C (a 46% increase) if forests were managed for 

maximum carbon storage. Although the theoretical limit is probably unattainable, given the timber-based economy and 

fire regimes in some ecoregions, there is still potential to significantly increase the land-based carbon storage by 

increasing rotation age and reducing harvest rates." Carbon storage and flows are outside the scope of the proposed 

research. A discussion of carbon storage is included in the FEIS.

North, Hurteau, Innes. 2009? Fire suppression and fuels 

treatment effects on mixed-conifer carbon stocks and 

emissions. In press. Ecological Applications.

Reported work is marginally relevant: it occurred in mixed-conifer forests in the Sierra Nevana on sites dominated by 

white fir (Abies concolor), red fir (A. magnifica), California black oak (Quercus kelloggii ), sugar pine (Pinus lambertiana), 

incense-cedar (Calocedrus decurrens), and Jeffrey pine (Pinus jeffreyi ) while the proposed research occurs on sites 

dominated by ponderosa pine. The elevation of the California site ranges from 1900 to 2600 m, and annual precipitation 

is 125 cm, more than twice that of Lookout Mountain. Carbon pools and flows will differ between this California site and 

the Lookout Mountain site. Lookout Mountain lacks the multi-layered forest canopy composed of different shade-tolerant 

tree species, and instead is a mostly a single-cohort stand of ponderosa pine with scattered Douglas-fir and grand fir 

saplings at the higher elevation. 

Hutto, Richard L. 2008. The Ecological Importance of 

Severe Wildfires: Some Like it Hot. Ecological 

Applications 18(8): pp. 1827-1834

Author presents data from Black-backed Woodpecker studies in western Montana to assert that some western 

ponderosa pine forests are adapted to severe fires. From abstract: "Many scientists and forest land managers concur 

that past fire suppression, grazing, and timber harvesting practices have created unnatural and unhealthy conditions in 

the dry, ponderosa pine forests of the western United States. Specifically, such forests are said to carry higher fuel loads 

and experience fires that are more severe than those that occurred historically. It remains unclear, however, how far 

these generalizations can be extrapolated in time and space, and how well they apply to the more mesic ponderosa pine 

systems and to other forest systems within the western United States. I use data on the pattern of distribution of one bird 

species (Black-backed Woodpecker, Picoides arcticus) as derived from 16 465 sample locations to show that, in western 

Montana, this bird species is extremely specialized on severely burned forests. Such specialization has profound 

implications because it suggests that the severe fires we see burning in many forests in the Intermountain West are not 
Appendix F Response to Public Comment

EXF Final EIS Page 68 of 88

entirely “unnatural” or “unhealthy.” Instead, severely burned forest conditions have probably occurred naturally across a 

broad range of forest types for millennia. "

This document presents no science that is counter to information presented in the EXF FEIS. The FEIS acknowledges 

that fires occurred at different severities (FEIS p. 99-101). The goals and objectives of the Experimental Forest, 

however, make it an inappropriate place to provide severely-burned forest habitat. 

Hutto, Richard L. and Susan M. Gallo. 2006. The Effects 

of Postfire Salvage Logging on Cavity-Nesting Birds The 

Cooper Ornithological Society. The Condor 108:817-831

A study in Montana comparing nest densities and patterns of nest reuse in logged and unlogged mixed conifer forest 

after wildfire. The authors reported lower abundances in salvage-logged plots. 

The information in this document is not relevant to the analysis in the EXF FEIS because the EXF project is not 

proposing logging after a wildfire.

Hutto, R.L., 2006. Toward Meaningful SnagManagement Guidelines for Postfire Salvage Logging in 

North American Conifer Forests. Conservation Biology 

Volume 20, No. 4, 984–993. 

http://avianscience.dbs.umt.edu/documents/hutto_conbio

_2006.pdf

Oregon Wild comment: “Newer guidelines that are 

appropriate for snag dependent species that occupy 

standing dead forests at the earliest stage of succession 

are beginning to trickle in....”

In general, the Hutto (2006) paper is clearly an “opinion” piece developed, for the “Special Section: The Ecological 

Effects of Salvage Logging after Natural Disturbances,” in the journal Conservation Biology. The paper does not present 

a study area, methods, or results from measured research but tends to focus on the need for more “scientific data” to 

assist and educate land managers dealing with post fire disturbances. The paper expresses concern for wildlife species, 

particularly black-backed woodpecker and three-toed woodpecker, with regards to salvage logging. 

In addition, the author’s call for data includes “meaningful snag targets” for “natural, post disturbance forests,” 

acknowledging the recently developed DecAID model in Washington an Oregon (Marcot et al. 2002 and ultimately Mellen 

et al. 2006) as an “important effort toward providing management guidance.” We also think that the Decay Wood Advisor 

tool (DecAID) is the best science available to assess the effects to deadwood for a “natural disturbance,” that is why we 

included an analysis using the DecAID tool and presented the effects in the Deadwood section of the EIS."

Hutto, Richard L., Courtney J. Conway, et. al. 2008 

What Constitutes a Natural Fire Regime? Insight from the 

Ecology and Distribution of Coniferous Forest Birds in 

North America. Assoc. for Fire Ecology Forum: Issues 

Management, Policy, and Opinions. Fire Ecology Special 

Issue 4(2):115-132

This paper uses ecological data from bird species to assert that patterns of habitat use by some species "indicate that 

severe fires are important components not only of higher-elevation and high-latitude conifer forest types, which are 

known to be dominated by such fires, but also of mid-elevation and even low-elevation conifer forest types that are not 

normally assumed to have had high-severity fire as an integral part of their natural fire regimes." From discussion: 

"Indeed, despite recent calls for developing restoration guidelines that are compatible with the evolutionary history of firedominated systems (Moore et al. 1999, Mitchell et al. 2006), restoration practices are not generally driven by a solid 

understanding of the evolutionary history of indigenous species. Instead, management practices tend to be focused on 

the use of mechanical treatments either to enhance wood production or to modify forest structure in a way that will 

reduce fire severity in the future."

It is disclosed that high-severity fire occurred in the project area because the current stand developed following a standreplacing fire about 165 years ago (FEIS p. 98). The EXF project does propose to modify forest structure to reduce fire 

severity and to initiate research into stand dynamics following disturbance. Commenters did not provide any direct 

comments that reference this paper.

Ingerson, A. 2009 Wood Products and Carbon Storage: 

Can Increased Production Help Solve the Climate Crisis? 

Not peer-reviewed science. Carbon flows and carbon storage are outside the proposed research. A carbon discussion 
Appendix F Response to Public Comments

 EXF Final EIS Page 69 of 88

Washington, D.C.: The Wilderness Society. 

http://wilderness.org/files/Wood-Products-and-CarbonStorage.pdf 

is included in the FEIS.

Ishak HD, Dumbacher JP, Anderson NL, Keane JJ, 

Valkiūnas G, et al. (2008) Blood Parasites in Owls with 

Conservation Implications for the Spotted Owl (Strix 

occidentalis). PLoS ONE 3(5): e2304. 

doi:10.1371/journal.pone.0002304 

http://www.plosone.org/article/info%3Adoi%2F10.1371%2

Fjournal.pone.0002304

The authors suggest the potential for a competitive advantage for barred owls over spotted owls where their range 

overlap. However, they also suggest that more study needs to be done in relation to the historical presence of some of 

the pathogens discussed in the article. The article provides evidence of another way barred owls may be interacting with 

spotted owls. The effects of avian malaria is outside the scope of the EXF project, although the threat of barred owls is 

referenced in the Biological Opinion.

Jenness et al., 2004, Associations between forest fire and 

Mexican spotted owls. Forest Science 50 (6) 765-772

Article discusses the impacts of forest fire on the Mexican spotted owl in mixed-conifer and pine-oak forests in the 

southwestern United States and Mexico, so not relevant to the EXF project. This reference states: “We recommend 

proactive fuels-management treatments in areas not currently occupied by owls as a means of reducing fire risk in areas 

occupied by owls. Within areas occupied by owls, judicious treatments may be appropriate after case-by-case 

evaluations of potential benefits and risks within those sites,” so reference does not provide recommendations contrary to 

the actions proposed in the EXF project.

Johnson, Morris C. 2008. Analyzing fuel treatments and 

fire in the Pacific Northwest. Seattle, WA: University of 

Washington. Ph.D. dissertation. 

http://www.fs.fed.us/pnw/fera/publications/abstracts/johns

on2008.shtml

Comment from Oregon Wild: “[S]lash generated from 

thinning treatments may increase potential area burned.”

As addressed previously, the FEIS discloses the potential for activity fuel to increase with thinning, this activity fuel may

increase fire behavior conditions such as rate of spread and flame length, and identifies plans to mitigate this through a 

combination of mowing and burning (page 90), and cites Omi and Martinson 2002.

Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., 

Waddell, K.L., Lindely, D.L., and B. Schrieber. 2001. 

Decaying Wood in Pacific Northwest Forests: Concepts 

and Tools for Habitat Management, Chapter 24 in

Wildlife-Habitat Relationships in Oregon and Washington

(Johnson, D. H. and T. A. O'Neil. OSU Press. 2001)

This document is cited within a restoration project from another National Forest in comments related to new information 

on snags. Complete citation not provided by commenter. The referenced text (discussing biological population potential 

for calculating snag requirements) has been previously responded to. Rose et al. 2001 in Johnson and O’Neil 2001 is 

referenced in the FEIS. DecAID provides the best science available to assess the effects of deadwood for a ‘natural 

disturbance,’ and is therefore included in the FEIS analysis. DecAID provides the best available data on wildlife species, 

and their relationships with dead wood. It is based on a thorough review of the literature, available research and 

inventory data, and expert judgment.

1. USFWS. 2008 Final Recovery Plan for the Northern 

Spotted Owl. 

http://www.fws.gov/pacific/ecoservices/endangered/recov

ery/NSORecoveryplanning.htm 

Comment from Oregon Wild asks “...how many medium-sized trees do we need to retain in order to achieve desired 

levels of old growth structure. The final recovery plan for the spotted owl recommends retention of large populations of 

medium-sized trees for recruitment as future large trees, both live and dead.” The Recovery Plan has previously been 

addressed. The Klamath Tribes’ Forest Management Plan does not provide any science that is relevant to the EXF 

project. 
Appendix F Response to Public Comment

EXF Final EIS Page 70 of 88

2. K. Norm Johnson, Jerry Franklin, Debora Johnson. The 

Klamath Tribes’ Forest Management Plan. Dec 2003. 

http://www.klamathtribes.org/forestplan.htm

It can be noted that new studies underway in support of the effectiveness monitoring plan should shed light on some of 

the forest structure variables associated with occurrence of spotted owls (see Davis and Lint 2006 for an earlier analysis 

that will be updated by current work).

Jonášová, Magda and Karel Prach 2004. CentralEuropean mountain spruce (Picea abies (L.) Karst) 

forests: regeneration of tree species after a bark beetle 

outbreak. Ecological Engineering 23: 15-27

Authors conclude that bark beetle outbreaks are a natural part of forest functioning. From conclusion: "Five years after 

the bark beetle outbreak, it is obvious that regeneration processes under the dead canopy proceed quite well.” "Thus, 

the bark beetle should be considered as a natural tool for restoration of a natural character of the mountain spruce 

forests which were altered by human activities in the past."

This reference is not relevant because the EXF project does not propose restoration of mountain spruce forest. The 

expectation that regeneration would occur following a bark beetle outbreak is not disputed; however, the purpose of the 

project is to avoid widespread loss to the overstory from a bark beetle outbreak.

Jurgensen, M.F., A.E. Harvey, et. al. 1997. Impacts of 

Timber Harvesting on Soil Organic Matter, Nitrogen, 

Productivity, and Health of Inland Northwest Forests. 

Forest Science 43(2): 234-251

This paper describes impacts of timber harvest and 'severe' prescribed burn on soil. Describes some negative impacts of 

timber harvesting and fire, while describing some of the positive benefits of forest diseases and insects. From Abstract: 

"Soil organic components are important factors in the health and productivity of Inland Northwest forests. Timber 

harvesting and extensive site preparation (piling, windrowing, or scalping) reduces the amount of surface organic material 

(woody residues and forest floor layers) over large areas. Some wildfires and severe prescribed burns can have similar 

consequences". From Discussion: "Forest diseases and insects are often assumed to have only negative influences on 

stand development. However, in terms of site productivity, they are very important in the functioning of certain forest 

ecosystems. These organisms have integral roles in the trophic dynamics of carbon and N cycling, habitat development,

and landscape diversity." "The connection between forest stress and forest health is especially important in forests of 

the Inland Northwest, which are often limited by low soil moisture and nutrient levels"

The commenter did not provide any statement of concern that references this document. Impacts to soils are disclosed 

in the FEIS.

Kaufmann, Merrill R. Thomas T. Veblen, and William H. 

Romme. 2006. Historical Fire Regimes in Ponderosa 

Pine Forests of the Colorado Front Range, and 

Recommendations for Ecological Restoration and Fuels 

Management. Front Range Fuels Treatment Partnership 

Roundtable, findings of the Ecology Workgroup. 

www.frftp.org/roundtable/pipo.pdf. 19 pp.

Not peer reviewed. Scientific review. From document: "At the request of TNC and the Front Range Fuels Treatment 

Partnership, the authors of this article are developing brief summaries of the current state of our scientific understanding 

of historical fire regimes in the forested landscapes of Colorado's Front Range"

The EXF FEIS relies on more relevant information to describe the fire regimes of the Lookout Mountain area. The 

commenter did not provide any statement of concern with the EXF FEIS that references this document.

Kaufmann M.R., G.H. Aplet, M. Babler, W.L. Baker, B. 

Bentz, M. Harrington, B.C. Hawkes, L. Stroh Huckaby, 

M.J. Jenkins, D.M. Kashian, R.E. Keane, D. Kulakowski, 

C. McHugh, J. Negron, J. Popp, W.H. Romme, T. 

Schoennagel, W. Shepperd, F.W. Smith, E. Kennedy 

Sutherland, D. Tinker, and T.T. Veblen. 2008. The status 

Reported work is marginally relevant: Lodgepole pine forests on the Rocky Mountain front are fundamentally different in 

structure from ponderosa pine forests at Lookout Mountain. Comments regarding canopy fuel reduction creating fuel 

drying are addressed on pp. 22-23.
Appendix F Response to Public Comments

 EXF Final EIS Page 71 of 88

of our scientific understanding of lodgepole pine and 

mountain pine beetles – a focus on forest ecology and fire 

behavior. The Nature Conservancy, Arlington, VA. GFI 

technical report 2008-

2.http://www.fs.fed.us/r6/umpqua/projects/projectdocs/dbug-ts/lpp-mpb-fire-2008-status-of-science-unillustratedversion-kaufmann-et-al.pdf

Gail Kimball, March 2009 Testimony before House 

Committee On Natural Resources, Subcommittee On 

National Parks, Forests, And Public Lands. 

http://www.fs.fed.us/fstoday/090320/02National_News/Fin

al_USFS_Testimony.pdf

Not peer-reviewed science. Comment notes that the Forest Service chief recognizes trade-offs in management vs. 

carbon storage. See FEIS for carbon discussion.

Kotliar et al., 2002. Effects of Fire and Post-fire Salvage 

Logging on Avian Communities in Conifer-dominated 

Forests of the Western United States. Studies in Avian 

Biology No. 25:49-64.

This document is a review of how fire and post-fire salvage practices affect avian communities in conifer-dominated 

forests of the western US. Reviews past research and then concludes with some recommendations for future areas of 

research. "studies have raised more questions than they have answered. Thus, applications of management 

prescriptions involving fire and fire-related silvicultural practices should be considered experimental..." Then lays out 

many unanswered research questions about the impacts of disturbances, including fire, on birds.

The information in this paper is not relevant to the EXF analysis because the EXF project does not propose post-fire 

salvage.

Kotliar et al., 2005. Fire on the Mountain: Birds and Burns 

in the Rocky Mountains. USDA Forest Service Gen. Tech. 

Rep. PSW-GTR-191 pp 1090-1092

Kotliar presents a very cursory review of Rocky Mountain fire regimes and changes and the influence of human activity. 

A brief summary of Kotliar et al. (2002) was included. The conclusion urges caution in the implementation of recent fire 

initiatives at broad spatial scales because of the lack of information on the effects of fire on wildlife. 

Full citation: within GTR, Bird Conservation Implementation and Integration in the Americas: Proceedings of the Third 

International Partners in Flight Conference. 2002 March 20-24; Asilomar, California, Volume 1 and 2. Editors, CJ Ralph, 

RD Terrell, Gen. Tech. Rep. PSW-GTR-191. Albany, CA: U.S. Dept. of Agriculture, Forest Service, Pacific Southwest 

Research Station. 1294 p. 

From article: "The variation observed in the response of avian communities to fire, coupled with variation in, and 

uncertainty about, historic fire regimes (Baker and Ehle 2001), argues for caution in the implementation of recent fire 

initiatives to reduce fuel loads. These initiatives are based on the premise that millions of acres are susceptible to 

uncharacteristically large and severe wildland fires due to decades of fire suppression (Allen et al. 2002). However, there 

are a number of untested assumptions about historic fire regimes and forest structure that affect the validity of the firemanagement initiatives. Moreover, it is assumed that specific forest structures will ensure the integrity of natural 

communities (e.g., avian communities). These assumptions, which are unlikely to be valid across the broad spatial scales 

at which the fire initiatives are implemented, have ramifications for the ecological integrity of avian communities of the 
Appendix F Response to Public Comment

EXF Final EIS Page 72 of 88

Rocky Mountains. Because the lack of information on the effects of fire on wildlife is a major stumbling block for 

developing ecologically sound fire management policies, basic research on fire effects is urgently needed."

The EXF FEIS does not rely on this paper. The information in this document is not relevant to the proposed EXF project 

because the validity of fire-management initiatives being implemented across broad scales is not within the scope of the 

EXF FEIS which focuses on risk reduction and research within the Experimental Forest.

Kotliar, Natasha B., Patricia L. Kennedy, and Kimberly 

Ferree. 2006. Avifaunal Responses to Fire in 

Southwestern Montane Forests Along a Burn Severity 

Gradient. Ecological Applications, 17(2): 491-507.

This paper describes impacts of severe burns on birds in Southwestern ponderosa pine forest, and concludes that 

severe fires do not have negative ecological impacts.

The EXF FEIS does not rely on this paper because it is irrelevant to the analysis, which focuses on the proposed actions 

of thinning, mowing, and underburning. 

1. Krankina, O. 2008. REVIEW of Sierra Pacific Industries 

Report – “Carbon Sequestration in Californian Forests: 

Two Case Studies in Managed Watersheds” prepared for 

Defensders of Wildlife and others. 

http://savethesierra.org/downloads/SPI_Review.pdf 

2. Geisen, T. et al. 2008. Four centuries of soil carbon 

and nitrogen change after stand-replacing fire in a forest 

landscape of the western Cascade Range of Oregon. 

Canadian Journal of Forest Resources 38:2455-2464; 

also in Sierra Club

3. Thomas William Giesen. 2005. Four Centuries of Soil 

Carbon and Nitrogen Change After Severe Fire in a 

Western Cascades Forest Landscape. MS THESIS. 

Oregon State University. 

Documents are not relevant: reported work is outside the ecological province and addresses retention of dead wood that 

currently does not exist. Proposed research is focused on treatment to retain large trees rather than capturing mortality 

through aggressive management.

Langdon, Nancy. 1995. Forest Dreams, Forest 

Nightmares, University of Washington Press, Ch. 4, Place 

and Ecology.

This book provides a natural history of the eastern Blue Mountains, commenting on changes in forest density, structure 

and species composition from historic observations and comparisons to current conditions. The information in this book 

does not present any science that opposes methods used in the EXF project. The commenter did not provide any 

statement of concern that references this document.

Lawler, J. J., M. Mathias, et. al. 2008 Oregon’s 

Biodiversity in a Changing Climate. Report prepared for 

the Climate Leadership Initiative, University of Oregon. 

55pp

Not peer-reviewed science. Commenters urged the Forest Service to consider this document. From abstract: “In the 

coming century, average annual temperatures in the Pacific Northwest are projected to rise at a rate of 0.1 to 0.6 °C (0.2 

to 1.0 °F) per decade. Although there is more uncertainty in projected changes in precipitation, in general, winters are 

projected to be wetter and summers are projected to be drier. These changes will have profound effects on many 

ecological systems across the state. For example, temperature-driven reductions in snowpack will affect stream-flow 
Appendix F Response to Public Comments

 EXF Final EIS Page 73 of 88

patterns and in turn many freshwater systems. Increasing temperatures will result in drier fuels leading to more frequent, 

intense, and/or extensive wildfires and rising sea levels will inundate many low-lying coastal areas. All of these changes 

have the potential to alter habitat and other finely balanced ecological relationships. As species move in response to 

these climate-driven changes, some will leave areas in which they are currently protected and others will replace them. 

Designing a network of protected lands that adequately conserves Oregon’s biodiversity into the future will require taking 

climate change into account. Planning for climate change will require a new set of tools including state-wide and regional 

assessments to determine which species and lands are most vulnerable to climate change and which lands are most 

isolated, synthetic analyses of regional climate and climate-impact projections, and regional cooperation among state, 

federal, and private landowners. Despite the challenges inherent in addressing climate change in the conservationplanning process, it may not be possible to protect biodiversity in the coming century unless we do.”

The Forest Service considered this document. The climate change section of the FEIS addresses the uncertainty 

involved in climate change and describes the research project’s role in exploring vegetation dynamics under a changing 

climate regime.

Mendelson III, Joseph 2008 Surveying the National 

Environmental Policy Act and the Emerging Issues of 

Climate Change, Genetic Engineering and 

Nanotechnology. NEPA and Emerging Issues Update 

11pp

This is a note within the Agricultural Law Update, the monthly newsletter of the American Agricultural Law Association. 

This document is not peer-reviewed science and does not provide any scientific information that is in opposition to the 

science relied on in the EXF FEIS. The commenter did not provide any statement of concern that references this 

document.

Mitchell, Stephen R, Mark E. Harmon, & Kari E.B. 

O’Connell. 2009. Forest fuel reduction alters fire severity 

and long-term carbon storage in three Pacific Northwest 

Forests.

Oregon Wild provided comments that reference this 

paper “Although thinning can affect fire, the agencies are 

likely to remove more carbon by logging than will be 

saved by avoiding fire...Even if logging reduces fire 

hazard there is less carbon stored in the logged forest 

than is stored in a burned forest.”

Authors suggest "that forest management plans aimed solely at ameliorating increases in atmospheric CO2 should forgo 

fuel reduction treatments in these ecosystems, with the possible exception of some east Cascades ponderosa pine 

stands with uncharacteristic levels of understory fuel accumulation". From abstract:"Two forest management objectives 

being debated in the context of federally managed landscapes in the U.S. Pacific Northwest involve a perceived trade-off 

between fire restoration and carbon sequestration. ..We suggest that forest management plans aimed solely at 

ameliorating increases in atmospheric CO2 should forgo fuel reduction treatments in these ecosystems, with the possible 

exception of some east Cascades ponderosa pine stands with uncharacteristic levels of understory fuel accumulation. 

Balancing a demand for maximal landscape C storage with the demand for reduced wildfire severity will likely require 

treatments to be applied strategically throughout the landscape rather than indiscriminately treating all stands."

This paper is the result of simulation exercises with three Pacific Northwest forest types. For the east Cascade 

ponderosa pine forests (represented by Pringle Falls Experimental Forest) there was little or no trade-off incurred by 

managing these forests for both fuel reduction and carbon sequestration. The authors speculate that the removal of 

highly flammable understory vegetation led to a reduction in overall fire severity that consequently lowered overall 

biomass combustion, thereby allowing increased overall carbon storage. The EXF FEIS addresses the issue of climate 

change/carbon storage (see Chapter 3.3.11). 

MTBS: Monitoring Trends in Burn Severity: Report on the 

Pacific Northwest and Pacific Southwest Fires (1984 to 

The FEIS is not based on any assumption of shifting wildfire severity in recent years. The information is therefore not 

relevant to the EXF purpose and need or analysis.
Appendix F Response to Public Comment

EXF Final EIS Page 74 of 88

2005). http://mtbs.gov/reports/MTBS_pnw-psw_final.pdf 

Oregon Wild comment: “...MTBS data does not support 

the assumption that wildfires are burning more severely in 

recent years.”

Nonaka, E, Spies, TA, Wimberly, MC, and Ohmann, JL. 

Historical range of variability (HRV) in live and deadwood 

biomass: a simulation study in the Coast Range of 

Oregon, USA, Ecological Applications: Vol. 15, No. 5, pp. 

1727-1746.

Jerome J. Korol, Miles A. Hemstrom, Wendel J. Hann, 

and Rebecca A. Gravenmier. 2002. Snags and Down 

Wood in the Interior Columbia Basin Ecosystem 

Management Project. PNW-GTR-181. 

http://www.fs.fed.us/psw/publications/documents/gtr181/049_Korol.pdf.

Oregon Wild comment: The federal agencies need to 

compensate for the severe lack of snags on intensively 

managed forest lands, but unfortunately snags are 

lacking on federal lands as well. For snag depletion in 

westside forests, see..

The EXF project does not propose to remove any snags, except where they pose a hazard. The referenced documents 

do not provide any science that counters that used in the EXF FEIS. 

Northern Spotted Owl Five-Year Review: Summary and 

Evaluation 

http://pacific.fws.gov/ecoservices/endangered/recovery/p

df/NSO_5-yr_Summary.pdf

This report from USFWS was undertaken to complete its regulatory requirements for a 5-yr review under section 4(c) of 

the Endangered Species Act (ESA)." The Service sought to answer these questions: 1) Is the northern spotted owl a 

valid subspecies under the ESA? 2) Is there new information about the threats or population status of the northern 

spotted owl? 3) If so, does the new information suggest that a change in listing status may be warranted?" This 

document is referenced in the BO. 

Odion, Dennis C. and Chad t. Hanson. Fire Severity in 

Conifer Forests of the Sierra Nevada, California 

Ecosystems (2006) 9: 1177–1189

Comments from Oregon Wild: Similarly, Hanson and 

Odion (2006) compared wildfire behavior in seven 

previously thinned mixed-conifer forests vs. adjacent 

unthinned forest in the Sierra Nevada and found —

From Conclusion: "Our findings suggest that elevated risk of high severity fire due to the effects of fire suppression is not 

the pervasive, predictable ecological problem that it has often been portrayed to be in the Sierran forests we studied. In 

addition, they provide evidence that fire alone can restore its past influence as a patchwise and stand-thinning 

disturbance agent as well as a facilitator of species diversity and fire adapted conifers in these forests. Thus, it appears 

that management can shift toward process restoration by introducing more fire and increasing the use of wildland fire 

(Miller 2003). There may be no other effective strategy for restoring and maintaining"

Authors are critical of the use of Fire Regime Condition Class and models such as LANDFIRE that map departures from 

historic conditions. The developed case studies in the Sierra Nevada found large variability in fire severity and less 
Appendix F Response to Public Comments

 EXF Final EIS Page 75 of 88

Contrary to our hypothesis, the mechanically thinned 

areas had significantly higher fire-induced mortality (p = 

.016, df = 6) and combined mortality (p = .008, df = 6) 

than the adjacent unthinned areas. .......

Similar results were demonstrated in a review of the fuel 

treatments that preceded the American River Complex of 

fires....”...masticated units appears to have abetted 

rather than resisted fire...only one treatment succeeded 

in both forcing fire to the surface and preserving most of 

the stand.”

correlation with condition class mapping. Author suggested more fire, whether prescribed or wild, is better.

Not peer reviewed. Relevancy is marginal. The EXF project includes the use of fire across all treatment units as part of 

the study design and fuels reduction. Although fire regime/condition class are described for the vegetation type in the 

project area, actual fire behavior simulations are based on site-specific information gathered in the field and from satellite 

data.

Odion, Dennis. 2004. Declaration in NWEA v. Forest 

Service. citing Countryman, C. M. 1955. Old-growth 

conversion also converts fire climate. U.S. Forest Service 

Fire Control Notes 17: 15-19.

The concern over warmer/drier/windier conditions following thinning has been addressed previously. The cited document 

is not peer-reviewed science. 

Omi, P.N., and Martinson, E. J. 2002. Effect of fuels 

treatment on wildfire severity. Final report. Western 

Forest Fire Research Center. Submitted to the Joint Fire 

Science Program Governing Board

Comment from Oregon Wild: “Theoretically, fuel 

treatments have the potential to exacerbate fire behavior. 

Crown fuel reduction exposes surface fuels to increased 

solar radiation, which would be expected to lower fuel 

moisture content and promote production of fine 

herbaceous fuels.....treatments that reduce canopy fuels 

increase and decrease fire hazard....Still unanswered are 

questions regarding necessary treatment 

intensities...more information is clearly needed.”

In general, fuel treatments can help produce forest structures and fuel characteristics that then reduce the likelihood that 

wildfire will cause large, rapid changes in biophysical conditions. Fuel treatments thus are designed to shift fires from 

high severity to low severity. Empirical evidence for this shift is in the literature; see, for example, recent work in 

ponderosa pine forests at Black Mountain in northeastern California, similar to Lookout Mountain, where tree survival 

after wildfire was greatest in those areas that had both thinning and prescribed fire prior to the wildfire event. Survival 

was near zero for the untreated areas. Survival in thinned-only areas was greater than untreated areas but substantially 

less than the areas with both treatments. Ritchie et al. 2007. Probability of tree survival after wildfire in an interior pine 

forest of northern California: Effects of thinning and prescribed fire. Forest Ecology and Management 247: 200-208.

Partners in Flight. Undated. Executive Summary, 

Columbia Plateau.

Not peer reviewed. Commenters provide no statement that references this document. The EXF FEIS relies on the 

information in Altman (2000) which addresses key habitat types and biological objectives and conservation strategies for 

habitat types found in the east-slope of the Cascade Mountains rather than the information for the Columbia Plateau.

Peppin, Donna, 2009. The Role of seeding in post-fire 

rehabilitation and opportunities for native plant 

production. M.S. Thesis, Northern Arizona University

Not peer reviewed. The information in this document is not relevant to the analysis in the EXF FEIS because the EXF 

project does not occur in a post-fire landscape.

Platt, Rutherford V., Thomas T. Veblen, and Rosemary L. This is a study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed 
Appendix F Response to Public Comment

EXF Final EIS Page 76 of 88

Sherriff. 2006. Are Wildfire Mitigation and Restoration of 

Historic Forest Structure Compatible? A Spatial Modeling 

Assessment. Annuals of the Assoc. of Am. Geographers 

96(3): 455-470

Comment “models shows that maintaining canopy cover 

is a useful way to reduced fire hazard, while removing 

canopy increases fire hazard” previously responded to.”

in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. From Abstract: “Contrary to 

current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure 

are needed in only a small part of the study area, primarily at low elevations. Furthermore, little of this land is located on 

Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a 

means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data 

collection on past and present landscape conditions.”

Relevancy is marginal: This study evaluates where both wildfire mitigation and restoration of historic forest structure are 

potentially needed in the ponderosa pine-dominated montane forest zone of Boulder County, Colorado. Two spatial 

models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then 

aggregated by land management classes. Contrary to current assumptions, results of this study indicate that both wildfire 

mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low 

elevations. Work proposed at Lookout Mountain does not attempt to restore stands to any historic forest structure.

The EXF project does not propose to restore historic forest structure in the project area. Fuels reduction and thinning are 

for the purpose of risk reduction and research. 

PNW Research Station. 2006. Seeing The Bigger Picture: 

Landscape Silviculture May Offer Compatible Solutions 

To Conflicting Objectives. Science Findings. July 2006. 

http://www.fs.fed.us/pnw/sciencef/scifi85.pdf

Comment from Oregon Wild: “Fuel reduction objectives conflict with owl habitat objectives.”

Not necessarily. Some fuels treatment, if done in a way that maintains adequate foraging habitat, can benefit owls in 

reducing the risk of loss of nesting habitat to stand replacing fire. The referenced document does not provide any 

science that opposed methods used in the EXF FEIS.

Raphael, M.G. (2006). Conservation of listed species: the 

northern spotted owl and marbled murrelet. Chapter 7 in 

R.W. Haynes, B.T. Bormann, D.C. Lee, and J.R. Martin 

(technical editors), Northwest Forest Plan—the first 10 

Years (1994–2003): synthesis of monitoring and research 

results. Gen. Tech. Rep. PNW-GTR. USDA Forest 

Service, Pacific Northwest Research Station, Portland, 

Oregon. http://www.fs.fed.us/pnw/publications/gtr651/ p 

121

Oregon Wild comment: “According to Raphael et al (2006) 583,500 acres of owl habitat “losses” can be attributed to 

“regeneration harvest” on non-federal forest lands from 1994 to 2004.”

This summary of activities under the NWFP also states that the vegetation monitoring reported had some limitations in 

measurement of fire activity and thinning (see text for more detail). Article states: "Clearly, loss of habitat from timber 

harvest on federal land (at least those losses from stand-replacing harvest) was below the expected 2.5 percent per 

decade." and " Observed harvest rates were substantially greater on nonfederal land than on federal land...” Also from 

article: "Silvicultural treatments were assumed to be implemented to reduce fuel and manage risk of stand-replacing fire 

in dry portions of the owl’s range. Such treatments were not done to the extent that may be required and, as a result, the 

risk of catastrophic loss of habitat in affected reserves may be greater than was assumed in the Plan’s design in these 

areas"

The referenced document does not provide any science that counters that used in the EXF FEIS.

Crystal L. Raymond. 2004. The Effects of Fuel 

Treatments on Fire Severity in a Mixed-Evergreen Forest 

of Southwestern Oregon. MS Thesis. 

http://depts.washington.edu/nwfire/publication/Raymond_

2004.pdf

Oregon Wild comment: “In a mixed-conifer, mixedThe issue of activity slash and fine wood has been addressed: slash will be minimized by whole tree yarding, piled and 

burned where necessary, and mowing and underburning will be used to treat fine fuels. 
Appendix F Response to Public Comments

 EXF Final EIS Page 77 of 88

severity fire regime study area in SW Oregon, Crystal 

Raymond found that ‘Fire severity was greater in thinned 

treatments than untreated. ... The additional fine wood 

left from the thinning operation (despite whole-tree 

yarding) most likely caused higher fire intensity and 

severity in the thinned treatments.’”

Rhodes 2007. The Watershed Impacts of Forest 

Treatments to Reduce Fuels and Modify Fire Behavior. 

Report for Pacific Rivers

This paper presents the viewpoint that ecological costs of fuel treatments, especially impacts on aquatic resources,

outweigh the benefits achieved in reducing fire risks and restoring fire regimes. 

Rhodes 2007 relates to the effects of forest fuel reduction treatments on watersheds and aquatic resources. The EXF 

project will not conduct fuels reduction activities in riparian areas. The paper provides recommendations to reduce 

potential adverse effects and the EXF project appears to be consistent with these. The FEIS analyzes potential for 

hydrologic impacts and found that there would be none at the project or watershed level (FEIS pp. 225-229).

Riddle, Linda. 2009. Letter to the Community of Pines, 

NM. 2 pp.

Not peer reviewed science. This letter from a Forest Service official in New Mexico to residents in the wildland urbaninterface has no relevance to the EXF project. That National Forest’s determination that the steep, narrow canyon terrain 

would not lend itself to effective fuels treatment for the community is entirely outside the scope of the EXF project.

Robichaud, P R, MacDonald, L H, and Foltz, R B. 2010. 

Fuel management and erosion in Elliot, William J.; Miller, 

Ina Sue; Audin, Lisa, eds. Cumulative watershed effects 

of fuel management in the western United States. Gen. 

Tech. Rep. RMRS-GTR-231. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. p. 79-100.

This reference says that roads, vegetation management, and prescribed fire may cause erosion. Commenter provides 

no statement that references this document. The FEIS addresses erosion concerns with best management practices 

and project design features. The potential effects are described in the FEIS Chapter 3.3.4. 

Romme, W.H., J. Clement, et. al. Undated. Recent 

Forest Insect Outbreaks and Fire Risk in Colorado 

Forests: A Brief Synthesis of Relevant Research. 24 pp.

Not peer reviewed science. The document provides a “brief synthesis of the current state of knowledge about forest 

insects and fires in Colorado to help inform effective management options. Our emphasis is on the ecological aspects of 

the insect outbreaks now affecting thousands of acres in the state. The document does not provide any science that is in 

opposition to that used in the EXF FEIS.

Rumbaitis del Rio, Cristina M. 2006. Changes in 

understory composition following catastrophic windthrow 

and salvage logging in a subalpine forest ecosystem. 

Can. J. For. Res. 36(11): 2943-2954

This document examines salvage logging after windthrow in a CO subalpine system and therefore is not relevant to the 

analysis in the EXF FEIS.

Rumbaitis-del Rio, C.M. and C.A. Wessman. Undated. 

Biogeochemical Consequences of Wind and SalvageLogging Disturbances in a Spruce-Fir Forest Ecosystem. 

Unknown.

Not peer reviewed science. This document is not relevant to the EXF FEIS because it examines the effects of wind and 

salvage in a different forest type.
Appendix F Response to Public Comment

EXF Final EIS Page 78 of 88

Saab, Victoria et al. Changes in downed woody material 

and forest structures after prescribed fire in ponderosa 

pine forests. In: Andrews, Patricia L.; Butler, Bret 

W.,comps. 2006. Fuels Management—How to Measure 

Success: Conference Proceedings. 28-30 March 2006; 

Portland, OR. Proceedings RMRS-P-41. Fort Collins, CO: 

U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station.

Preliminary results from a study to examine the effectiveness in prescribed burning in reducing fuels, and also examine 

impacts on wildlife. “Results of this study are intended to assist managers with developing scientifically sound and legally

defensible prescribed fire projects that will reduce fuels and concurrently enhance wildlife habitat." From Conclusion: "In 

this paper we did not evaluate the influence of fire severity on changes in fuels and other vegetation after fire. ......Also, 

we recommend monitoring vegetation and wildlife populations for several years after prescribed burning because of 

changes in vegetation and wildlife responses with time since fire (Hannon and Drapeau 2005; McHugh and Kolb 2003; 

Reinhardt and Ryan 1998; Saab and others 2004). Severity information and monitoring for multiple years after fire will 

help in developing guidelines for prescribed fire projects that will reduce fuels and concurrently create wildlife habitat."

Safford, Hugh. Undated. Fire Severity in Fuel 

Treatments American River Complex fir, Tahoe National 

Forest, California June 21 – August 1, 2008. 21 pp.

Not peer-reviewed science. This report was requested by the Regional Office Fire and Aviation Management staff, and 

carried out by the Pacific Southwest Region Ecology Program. Review of burn severity in wildfire area and discussion of 

relation to treated/untreated stands. Conclusions note that crown thinning alone is not likely to reduce fire behavior, that

surface and ladder fuels need to be reduced. This paper does not provide science that opposes methods proposed in 

the EXF project.

Schoennagel, Tania, Cara R. Nelson, et. al. 2009. 

Implementation of National Fire Plan treatments near the 

wildland-urban interface in the western United States. 

PNAS Early Edition 

(www.pnas.org/cgi/doi/10.1073/pnas.0900991106) 6 pp.

This study is a spatial analysis of location of fuel reduction treatments, conducted on a national scale, although without 

explicit spatial locations for fire treatments. Authors found that (from abstract): "During the last 5 years (2004–2008), 

44,000 fuels treatments were implemented across the western United States under the National Fire Plan (NFP)." 

"Although federal policies stipulate that significant resources should be invested in the WUI, we found that only 3% of the 

area treated was within the WUI, and another 8% was in an additional 2.5-km buffer around the WUI, totaling 11%. Only 

17% of this buffered WUI is under federal ownership, which significantly limits the ability of federal agencies to implement 

fire-risk reduction treatments near communities. Although treatments far from the WUI may have some fire mitigation 

benefits, our findings suggest that greater priority must be given to locating treatments in and near the WUI, rather than 

in more remote settings, to satisfy NFP goals of reducing fire risk to communities. However, this may require shifting 

management and policy emphasis from public to private lands."

The results of this study do not hold true for Central Oregon. Regardless, information on the national distribution of fuels 

treatments relative to WUI is outside the scope of the EXF project and not relevant to the analysis.

Schoennagel, Tania, Thomas T. Veblen, et. al. 2007. 

Multidecadal Climate Variability and Climate Interactions 

Affect Subalpine Fire Occurrence, Western Colorado 

(USA). Ecology 88(11): 2891-2902

Study sampled fire history in the subalpine zone, with study sites occurring between 2700 and 3050 m in western CO, to 

determine the impacts of climate on increasing fire frequency. Authors conclude that "interactions among broadscale 

climate oscillations represented by SSTAs in the Atlantic and Pacific oceans are emerging as an important predictor of 

significant fire activity in the western United States (refs). Interactions among climatic oscillations can intensify or weaken 

teleconnected patterns. " Also in conclusion: "Hence, temporal patterns in fire occurrence, which include a recent 

increase around 1975 in our study (Fig. 2), can largely be attributed to variation in climate rather than changes in fuels. 

Westerling et al.'s (2006) analysis of a large western wildfire database shows that the greatest increase in recent wildfire 

activity has occurred in higher elevation forests, where past land-use histories have had little effect on fire behavior."

This paper does not provide science that counters the description of the need for thinning and fuels reduction in the EXF 

project area.
Appendix F Response to Public Comments

 EXF Final EIS Page 79 of 88

Science Findings Forests at Risk: Integrating Risk 

Science into Fuel Management Strategies

This publication provides an overview on fuel management and the motivation for thinning and then describes WETAC 

work to build tools for planning fuel treatments. From executive summary: "The threat from wildland fire continues to 

grow across many regions of the Western United States. Drought, urbanization, and a buildup of fuels over the last 

century have contributed to increasing wildfire risk to property and highly valued natural resources. Fuel treatments, 

including thinning overly dense forests to reduce fuel and lower fire risk, have become a priority for land managers. 

Planning fuel treatments on public lands is a complicated problem. Treatments must address multiple management 

objectives that are often conflicting and burdened with regulatory constraints. Researchers at the Western Wildland 

Environmental Threat Assessment Center are building tools to streamline the fuel treatment planning process, and 

applying concepts from the risk sciences to better measure the potential benefits of landscape fuel treatment designs."

This technical report provides no science that opposes methods used in the EXF project.

Sestrich, Clint Michael. 2005. Changes in Native and 

Nonnative Fish Assemblages and Habitat following 

Wildfire in the Bitterroot River Basin, Montana. MS 

Thesis, Montana State Univ. 93 pp.

Not peer-reviewed science. The topic of wildfire affects to fish assemblages or habitat is not relevant to the EXF project 

because the EXF project does not involve a post-fire landscape. Commenters did not provide any statements that 

reference this document.

Alyssa V. Shanks. 2008. Carbon Flux Patterns on U.S. 

Public Timberlands Under Alternative Timber Harvest 

Policies. MS Thesis. March 2008.

Not peer-reviewed science. Comment from Oregon Wild - “Allowing harvested timber to be allocated to all types of wood 

products increases carbon emissions and results in no harvest regimes sequestering more carbon.” 

See FEIS for carbon discussion.

Shirley, Diane M. and Vicky Erickson. 2001. Aspen 

Restoration in the Blue Mountains of Northeast Oregon. 

USDA Forest Service Proceedings RMRS-P-18, pp101-

115

Conference proceedings. This presentation discusses aspen restoration which is not relevant to EXF project.

Scott L. Stephens and Jason J. Moghaddas. 2005. 

Silvicultural and reserve impacts on potential fire behavior 

and forest conservation: Twenty-five years of experience 

from Sierra Nevada mixed conifer forests. Biological 

Conservation 125 (2005) 369–379.

Comment from Oregon Wild: A study in mixed-conifer 

forests in California showed that forest reserves were 

more effective than logging in terms of reducing fire 

hazard....Overall, thinning from below, and old-growth 

and young-growth reserves were more effective at 

reducing predicted tree mortality.

This paper describes an experimental thinning project. From abstract: "Most administrators and ecologists agree that 

reducing the levels of hazardous fuels on forests is essential to restore healthy watersheds and protect adjacent human 

communities. The current debate over the appropriateness, technique, and timing of treatments utilized to restore 

vegetation structure and composition is currently on-going at local, state, and national levels. To provide information for 

these forums, the efficacy of seven traditional silvicultural systems and two types of reserves used in the Sierra Nevada 

mixed conifer forests is evaluated in terms of vegetation structure, fuel bed characteristics, modeled fire behavior, and 

potential wildfire related mortality. The systems include old-growth reserve, young-growth reserve, thinning from below, 

individual tree selection, overstory removal, and four types of plantations. These are the most commonly used 

silvicultural systems and reserves on federal, state, and private lands in the western United States. Each silvicultural 

system or reserve had three replicates and varied in size from 15 to 25 ha; a systematic design of plots was used to 

collect tree and fuel information. The majority of the traditional silvicultural systems examined in this work (all plantation 

treatments, overstory removal, individual tree selection) did not effectively reduce potential fire behavior and effects, 

especially wildfire induced tree mortality at high and extreme fire weather conditions. Overall, thinning from below, and 

old-growth and young-growth reserves were more effective at reducing predicted tree mortality."
Appendix F Response to Public Comment

EXF Final EIS Page 80 of 88

The EXF project involves thinning from below, mowing, and underburning to reduce fire behavior. The project also 

involves control areas within each treatment block. The cited references does not provide any science that opposes 

methods used in the EXF project.

1. Talbert and Marshall. 2005. Plantation Productivity in 

the Douglas-fir Region Under Intensive Silvicultural 

Practices: Results From Research And Operations. 

Journal of Forestry. March 2005. pp 65-70 

2. Curtis and Marshall. 1997. LOGS: A Pioneering 

Example of Silvicultural Research in Coastal Douglas-fir.

Journal of Forestry 95(7):19-25.

These are studies of Douglas-fir plantations, so not directly relevant. The proposed research makes not claim for bonus 

wood production.

Thiffault, E., K.D. Hannam, et. al. 2008 Chemical 

composition of forest floor and consequences for nutrient 

availability after wildfire and harvest in the boreal forest. 

Plant and Soil 308(1-2): 37-53 (doi: 10.1007/s11104-008-

9604-6)

Impacts of clearcut harvesting and wildfire on biogeochemical cycles, organic matter and nutrient availability for plants, 

15– 20 years after disturbance in boreal coniferous stands.

Authors compared the impacts of both harvesting and wildfire on biogeochemical cycles, comparing the effects of stemonly harvesting (SOH), whole-tree harvesting (WTH) and wildfire on the chemical composition of forest floor organic 

matter and nutrient availability for plants, 15– 20 years after disturbance in boreal coniferous stands in Quebec (Canada). 

From conclusion: "Our study suggests that wildfire and harvesting (with either SOH or WTH) influence organic matter 

chemical constituents in distinct ways.” This paper is not relevant to the analysis in the EXF FEIS because the EXF 

project does not involve clearcut harvesting or wildfire.

Tilman, Lehman, and Thompson. 1997. Plant diversity 

and ecosystem productivity: theoretical considerations. 

Proceedings of the National Academy of Sciences. 

94:1857-1861. 

http://www.cedarcreek.umn.edu/biblio/fulltext/t1694.pdf 

See also, Tilman, D. and P. Karieva, Eds. 1997. Spatial 

Ecology: The Role of Space in Population Dynamics and 

Interspecific Interactions. Monographs in Population 

Biology, Princeton University Press. 368 pp.

The first document is a theoretical article dealing with diversity and ecosystem function, and is not directly relevant to the 

proposed project. The second citation was is also a highly theoretical work dealing with spatial and temporal issues in 

ecology. Both of these works are well-respected ecological theory but are not directly relevant to proposed project. 

Principles regarding island biogeography may hold regarding competition between spotted owl and barred owl; however, 

one additional point is that it appears the barred owl and spotted owl may have somewhat different habitat preferences. 

If these can be better understood, then managers may be able to target conservation of habitat (such as higher 

elevations on north slopes) that spotted owls prefer and that barred owls are less likely to use.

Traill, Lochran W., Barry W. Brook, et. al. 2009. 

Pragmatic population viability targets in a rapidly 

changing world. Biol. Conserv.,

This article is a critical review of minimum population size requirements for species based on empirical and theoretical 

estimates made over the past few decades. Relevance would stem from endangered spp impacts, not project 

manipulations.

This article revisits the concept of minimum population size, stating that (in Abstract): This literature collectively shows 

that thousands (not hundreds) of individuals are required for a population to have an acceptable probability of riding-out 

environmental fluctuation and catastrophic events, and ensuring the continuation of evolutionary processes...”

Where sensitive or threatened species are analyzed in the FEIS, there is no expectation that the EXF project will impact 
Appendix F Response to Public Comments

 EXF Final EIS Page 81 of 88

population viability.

Author Unknown. Area Burned in 11 Western States, 

1916-2007. Date Unknown. 1 pp.

Not peer-reviewed science. The one-page undated paper of unknown origin concludes that “beetle outbreaks and 

wildfires are example of “healthy” ecosystems, not plant communities out of whack or “unhealthy.”” This document does 

not provide any scientific information. 

Author Unknown. Biochar: A Soil Amendment that 

Combats Global Warming and Improves Agricultural 

Sustainability and Environmental Impacts. Date 

Unknown. 3 pp.

This document is undated and from an unknown origin. Not peer-reviewed science. From introduction: “Biochar and 

bioenergy co-production from urban, agricultural and forestry biomass can help combat global climate change by 

displacing fossil fuel use, by sequestering carbon in stable soil carbon pools, and by dramatically reducing emissions of 

nitrous oxides, a more potent greenhouse gas than carbon dioxide.”

It is unclear what relevance the commenters attribute to this document as it is not referenced in the comments.

Author Unknown. Black-backed woodpeckers, Draft 

USFS Guidelines for the Intermountain West, and 

research references. 37 pp.

This is an incomplete draft. From introduction: “The following guidelines and scientific research compilations concerning 

black-backed woodpeckers emphasize that mountain pine beetle populations and cyclic fluctuations are essential for this 

species viability.” This document is incomplete and does not provide science that contradicts the analysis in the FEIS 

concerning black-back woodpeckers.

Author Unknown. Climate Change – Applicable Law. 

Source Unknown. 1 pp.

This undated document from an unknown origin discusses court decisions concerning analysis of climate change. The 

relevance of this document to the EXF Project is unclear as it was not referenced in the comments. The EXF project 

presents a discussion of climate change in the EIS p. 243

Author Unknown. Fire History of Glacier National Park 

and Bob Marshall Wilderness, Montana. Date Unknown. 

1 pp.

This one page document of unknown origin displays fire history for Glacier National Park. No science is provided and 

there is no relevance to the EXF project.

Author Unknown. Fire-regime/condition class discussion. 

Date Unknown. 1 pp.

This undated document of unknown origin cites Odion et al 2004 critique of FRCC, which has been addressed earlier in 

this Response to Comments.

Author Unknown. Forest Health, Fire, Fuels, and Fire 

Ecology. Date Unknown. 68 pp.

This undated document of unknown origin is a compilation of comments, research, and other information. Relevant 

portions of the document appear in comments received from Oregon Wild and have been responded to. The commenter 

did not reference the document in comments.

Author Unknown. 2009. Forest Restoration: Impacts of 

Logging-Thinning & Roads on Hydrology & Resilience. 

Date unknown

This undated document of unknown origin states that it is “adapted from a memo summary by Jon Rhodes, Hydrologist 

2009.” The document was not referenced in comments provided on the EXF project and its relevance is unclear. 

Rhodes references have been responded to in this Response to Comments appendix. 

Author Unknown. Neotropical Migrant and Native Birds. 

Source unknown.

A complaint about the lack of analysis in the Five Buttes project concerning neotropical migrant and native birds. Not 

scientific research or professional opinion. These comments are not relevant to the EXF project. The document was not 

referenced in comments provided on the EXF project.

Author Unknown 2009 Change in Average June 

Temperature 1951-2006 PRISM Group, Oregon State 

GIS generated map not accompanied by any text and not referenced in comments; relevance to the EXF project is 

unclear. The FEIS has acknowledged the potential for future warming in the region (FEIS p. 243). 
Appendix F Response to Public Comment

EXF Final EIS Page 82 of 88

Univ.

USDA Forest Service; Influence of Forest Structure on 

Wildfire Behavior and the Severity of Its Effects, 

November 2003. 

http://www.fs.fed.us/projects/hfi/2003/november/documen

ts/forest-structure-wildfire.pdf

Comment from Oregon Wild: Thinning opens stands to 

greater solar radiation and wind movement, resulting in 

warmer temperatures and drier fuels throughout the fire 

season. [T]his openness can encourage a surface fire to 

spread, ... 

The comment is not fully quoted, and thus the actual meaning is distorted. Thinning opens stands to greater solar 

radiation and wind movement, resulting in warmer temperatures and drier fuels throughout the fire season. While this 

openness can encourage a surface fire to spread, such fires do little ecological damage. Proposed treatments at 

Lookout Mountain were designed to shift wildfire behavior from high severity to low severity. Empirical evidence for this 

shift is in the literature; see, for example, recent work in ponderosa pine forests at Black Mountain in northeastern 

California, similar to Lookout Mountain, where tree survival after wildfire was greatest in those areas that had both 

thinning and prescribed fire prior to the wildfire event. Survival was near zero for the untreated areas. Survival in thinnedonly areas was greater than untreated areas but substantially less than the areas with both treatments. Ritchie et al. 

2007. Probability of tree survival after wildfire in an interior pine forest of northern California: Effects of thinning and

prescribed fire. Forest Ecology and Management 247: 200-208.

Van Horne & Fule’, 2006 Comparing methods of 

reconstructing fire history using fire scars in the 

southwestern United States ponderosa pine forest. Can. 

J. For. Res. 36:855-867

This research examines use of fire scars to understand the historical role of fire in ponderosa pine ecosystems. This 

document was not referenced in comments provided on the EXF project and it does not provide science that opposes 

methods in the EXF project.

Van Mantgem, Phillip J., Nathan L. Stephenson, et. al. 

2009. Widespread Increase of Tree Mortality Rates in the 

Western United States. Science 323, 521-524 (doi: 

10.1126/science.1165000)

Authors reported on elevated rates of tree mortality in western US. Direct relevance to study work is unclear. This 

document was not referenced in comments provided on the EXF project and it does not provide science that opposes 

methods in the EXF project. Authors found rapid and pervasive increases in tree mortality rates in old forests of the 

western United States and authors "conclude that endogenous processes are unlikely to be major contributors to the 

observed rapid, synchronous doubling of mortality rates in our heterogeneous sample of old forests at a subcontinental 

scale. Moreover, the available evidence is inconsistent with major roles for two possible exogenous causes: forest 

fragmentation and air pollution". Instead they suggest that climate change has altered tree mortality, and could presage 

"substantial changes in forest structure, composition, and function (7, 25), and in some cases could be symptomatic of 

forests that are stressed and vulnerable to abrupt dieback.”

Waring et al. 1992. Thinning and Nitrogen Fertilization in 

a Grand Fir Stand Infested with Western Spruce 

Budworm. Forest Science, Vol. 38, No.2, pp. 275-286.

This study describes application of nitrogen to a grand fir stand during a western spruce budworm outbreak. This paper 

is not relevant to the EXF project. The document was not referenced in comments provided on the EXF project.

Waring, R. H., K. S. Milner, W. M. Jolly, L. Phillips, and D. 

McWethy. 2006. Assessment of site index and forest 

growth capacity across the Pacific and Inland Northwest 

U.S.A. with a MODIS satellite-derived vegetation index. 

Forest Ecology and Management 228:285-291.

In this paper authors combine modeling and remote sensing to produce maps of forest productivity over a large area, 

focusing on dominant and co-dominant Douglas-fir or ponderosa pine. From Abstract: "It is difficult to map forest growth 

potential across regions with different environmental conditions from limited field measurements of productivity. 

Climatically sensitive biophysical models and remotely sensed data on vegetation offer the potential to overcome this 

problem. We combine both approaches in this paper. We calibrated the midsummer value of NASA’s MODIS 

instrument’s enhanced vegetation index (EVI) against site indices (SI) mapped at 10 widely dispersed locations for 

Douglas-fir or ponderosa pine, ranging in height from 16 to 48 m at 50 years (age at breast height)."
Appendix F Response to Public Comments

 EXF Final EIS Page 83 of 88

The document was not referenced in comments provided on the EXF draft EIS. The conclusions regarding methods for 

mapping forest productivity are not relevant to the analysis in the EXF project.

Waring, R.H. 2004. Tree Physiology Stress. In: J. Burley, 

J. Evans, and J. Youngquist (eds.) pp. 1628-1632. 

Encyclopedia of Forest Sciences. Elsevier Science Ltd., 

London.

This is an entry in an encyclopedia providing a general description of stress and tree physiology. The document was not 

referenced in comments provided on the EXF draft EIS and its relevance to the project is unclear.

Waring, Richard H. 2009 Declaration of Richard H. 

Waring, September 10, 2009

This document is comments made by Waring on the FEIS for the Farley project on the Umatilla NF. It has been 

referenced by commenters but has no relevance to the EXF project. Comments specific to the EXF project were 

submitted by Dr. Waring and are included in this appendix. 

Welch, Craig. 2009. The Spotted Owl’s New Nemesis. 

Smithsonian Magazine. January 2009. 

http://www.smithsonianmag.com/science-nature/TheSpotted-Owls-New-Nemesis.html?c=y&page=2

This document was cited by Oregon Wild in comments regarding barred owl competition with spotted owls. The 

document does not provide any science that opposes methods used in the EXF FEIS.

DAVID WIENS. NewsHour interview. “Biologists Struggle 

to Save the Spotted Owl.” December 18, 2007. 

http://www.pbs.org/newshour/bb/science/julydec07/owl_12-18.html

Not peer-reviewed science. Cited in comments from Oregon Wild concerning spotted owl regarding competitive pressure 

with barred owl – “the more habitat you protect, the more you're going to alleviate the competitive pressure between the 

species.” The Forest Service does not disagree, but it appears the barred owl and spotted owl may have somewhat 

different habitat preferences. If these can be better understood, then managers may be able to target conservation of 

habitat (such as higher elevations on north slopes) that spotted owls prefer and that barred owls are less likely to use.

Wilhere, G.F. 2003. Simulations of snag dynamics in an 

industrial Douglas-fir forest. Forest Ecology and 

Management. Volume 174, Issues 1-3, 17 February 2003, 

Pages 521-539.

This study focuses on Douglas-fir plantations in western Oregon. This is not applicable to the more ponderosa pinedominated stands in the EXF project area.

Wuerthner, George 2009. Draft Testimony of George 

Wuerthner June 19, 2009 to the House Subcommittee on 

National Parks, Forests, and Public Lands House 

Subcommittee on Water and Power Joint Oversight 

Hearing on “Mountain Pine Beetle: Strategies for 

Protecting the West.”. 11 pp.

This document is comments made by Wuerthner before a House subcommittee. It has not been referenced by 

commenters and no discrete issues with the EXF project are raised in the document. The general issues Wuerthner 

raises about forest management have been previously addressed.

Xiaojun Kou & William L. Baker, 2006 a landscape model 

quantifies error in reconstructing fire history from scars 

Jour. Landscape Ecology Vol.21, No. 5 July 2006

Authors use a landscape model to quantify error in reconstructing fire history from fire scar patterns. From abstract: 

"Here, a stochastic landscape model is used to quantitatively assess the accuracy of a commonly used statistic, the 

composite fire interval (CFI), as an estimator of the population mean fire interval or fire rotation, which are the central 

parameters useful in comparing fire regimes. Seven factors, that may affect accuracy, are explored. Two control the fire 

regime, one controls the scarring process, and the other four define the sampling and analysis procedure. Results show 

that: (1) CFI can be from 0.15 to 5.0 times the population mean fire interval, a range of more than 30 times; (2) all factors, 
Appendix F Response to Public Comment

EXF Final EIS Page 84 of 88

except population mean fire interval, significantly affect accuracy; (3) accuracy shows predictable patterns that could be 

useful in designing a sound sampling scheme and choosing a proper analysis method. However, the complexity of 

effects of these factors and the need for some prior knowledge of them make it difficult to design sampling and analysis 

procedures to accurately estimate the population mean fire interval."

Yermakov, Zhanna and David E. Rothstein. 2006. 

Changes in soil carbon and nitrogen cycling along a 72-

year wildfire chronosequence in Michigan jack pine 

forests. Oecologia 149:690–700 DOI 10.1007/s00442-

006-0474-4

Paper describes nitrogen cycling in northern jack pine forests. This document was not referenced in the comments and 

the information is not relevant EXF project.

Steve Zack, T. Luke George, and William F. 

Laudenslayer, Jr. 2002. Are There Snags in the System? 

Comparing Cavity Use among Nesting Birds in “Snagrich” and “Snag-poor” Eastside Pine Forests. USDA 

Forest Service Gen. Tech. Rep. PSW-GTR-181. 

http://www.fs.fed.us/psw/publications/documents/gtr181/017_Zack.pdf 

Oregon Wild cites as evidence that retaining more than the minimum number of snags has significant benefits for cavity 

dependent species. As stated previously, snags are not targeted for removal.

1. Kevin W. Zobrist. 2005. A literature review of 

management practices to support increased biodiversity 

in intensively managed Douglas-fir plantations. Final 

Technical Report to the National Commission on Science 

for Sustainable Forestry (NCSSF). 

http://www.ncseonline.org/ewebeditpro/items/O62F7175.

pdf 

2. Poage, Nathan, J. 2005, Variability in Older Forest 

Structure in Western Oregon. U.S. Geological Survey, 

Open-file Report 2005-1385, 28 p. 

3. SÁNDOR BARTHA et al. 2004. On the Importance of 

Fine-Scale Spatial Complexity in Vegetation Restoration 

Studies. International Journal of Ecology and 

Environmental Sciences 30: 101-116, 2004 

http://www.zpok.hu/img_upload/cb39111eba7a31c9c0e4

8686fa8e3c87/IJEES2004.pdf

4. Franklin J.F.; Van Pelt R. 2004. Spatial Aspects of 

Structural Complexity in Old-Growth Forests. Journal of 

Forestry, Volume 102, Number 3, April/May 2004, pp. 22-

All documents cited with the following comment: “Variability is not only good for habitat, but is also an under-appreciated 

way to moderate fire behavior.”

Numbers 3, 4, 6, 7 & 8 are peer-reviewed science; 1, 2, 5 are not. Most of these are not relevant to the ponderosa pine 

dominated stands in the project area. The project builds in variability with its different silvicultural prescriptions and 

control units. 

3). is a theoretical paper comparing and discussing "the methodological consequences of equilibrium and nonequilibrium 

paradigms in vegetation restoration"—not directly relevant to the project.

4). is a general description of old-growth forests, comparing their structural complexity to managed stands; no direct

relevance the comment about variability and moderating fire behavior.

(6,7) summarize research on squirrel ecology conducted on the Olympic Forest--in a different habitat type, and not 

related to the comment about variability and fire behavior.

(8) is a general paper from Nature about community dynamics, discusses the relationship between diversity and 

ecological stability. Again, not related to the comment about variability and fire behavior.
Appendix F Response to Public Comments

 EXF Final EIS Page 85 of 88

28(7).

5.Lutz. J.A. 2005. The Contribution of Mortality to Early 

Coniferous Forest Development. MS Thesis. University of 

Washington. 

http://faculty.washington.edu/chalpern/Lutz_2005.pdf

6. Carey, Andrew B., Janet Kershner, Brian Biswell, and 

Laura Dominguez de Toledo. 1999. Ecological Scale and 

Forest Development: Squirrels, Dietary Fungi, and 

Vascular Plants in Managed and Unmanaged Forests. 

Wildlife Monographs, No 142, Supplement to the Journal 

of Wildlife Management, Vol. 63 No. 1, January 1999. 

http://www.fs.fed.us/pnw/pubs/journals/pnw_1999_carey0

03.pdf

7.Andrew B. Carey, Constance A. Harrington; Small 

mammals in young forests: implications for management 

for sustainability; Forest Ecology and Management (2001) 

154(1-2): 289-309; 

http://www.fs.fed.us/pnw/pubs/journals/pnw_2001_carey0

03.pdf

8.Kevin Shear Mccann, The diversity–stability debate. 

Nature 405, 228 - 233 (11 May 2000). 

http://www.nature.com/cgitaf/DynaPage.taf?file=/nature/journal/v405/n6783/full/405

228a0_fs.html

9.USFWS. 2008 Final Recovery Plan for the Northern 

Spotted Owl. 

http://www.fws.gov/pacific/ecoservices/endangered/recov

ery/NSORecoveryplanning.htm

Earth Island Inst. v. U.S. Forest Serv., 442 F.3d 1147, 

1175-76 (9th Cir. 2006) (quoting Native Ecosystems 

Council v. U.S. Forest Serv., 428 F.3d 1233, 1250 (9th 

Cir. 2005))” ONRC v. Goodman (Mt Ashland case, 9th 

Circuit Sept 24, 2007) (emphasis added). 

http://www.ca9.uscourts.gov/ca9/newopinions.nsf/499E49

C2E3B21A128825736000533BBA/$file/0735110.pdf

Court document. In relation to snag comments, the species habitat quality and quantity were determined using best 

available science and data (DecAID).
Appendix F Response to Public Comment

EXF Final EIS Page 86 of 88

ONRC Action v. US Forest Service. Civil No. 03-613-KI. 

US District Court for the District of Oregon. Opinion and 

Order; August 9, 2006.

Refer to the Biological Assessment and Biological Opinion. The Forest Service and U.S. Fish and Wildlife Service have 

worked closely together in determining the effects. The project area was subject to review by a number of regional 

biologists during a spotted owl working group (dry forest) workshop.

Friends of the Clearwater v. Dombeck, 222 F.3d 552, 557 

(9th Cir. 2000). NWEA vs. Mark Rey, W.D. Washington. 

No. C04-844P. Judge Marsha Pechman, Aug 1, 2005.

In support of statement that agency must be alert to new information that may alter the results of its original 

environmental analysis. Court document.

Salem BLM Bottleneck LSR EA

http://www.blm.gov/or/districts/salem/plans/files/sdo_080-

07-16_eafonsi.pdf)

Oregon Wild comment: “Salem BLM’s Bottleneck LSR 

Enhancement Project EA includes Table 9 which clearly 

shows that thinning will adversely affect mortality 

processes.”

Not peer-reviewed science. The referenced document does not provide any science that counters that used in the EXF 

FEIS. The BLM project occurs in a different forest type and the analysis they provide is not relevant to the EXF project 

FEIS.

Newspaper Articles 

Barnard, Jeff, AP Environmental Writer. 2007. Not science. Not related to the EXF project.

Bentz, B., C.D. Allen, et. al. 2009 See the forest. 

http://www.missoulanews.com/index.cfm?do=article.user

Opinions&nav=News

Not science. Not related to the EXF project.

Hutto, Richard L. Post-fire logging is bad for forests and 

wildlife. Editorial guest comment in the Seattle Times. 

resale@seattletimes.com

Not science. Editorial piece. Not cited by commenters; no discrete issue with EXF project expressed.

Jamison, Michael. Reporter for the Missoulian. 2005. 

Birds in the black: Through following avian wildlife, a UM 

scientist has discovered that burned forests play a critical 

role in the health and diversity of the Western landscape

Not science. Article with interview of Hutto. Not cited by commenters; no discrete issue with EXF project expressed.

Milstein, Michael. Reporter for the Oregonian. 2006. 

Scorched forests best left alone, study finds

Not science. Not cited by commenters; no discrete issue with EXF project expressed. 

Munger and Drake. The Timberman. Portland, Oregon. 

December 1926. 

1926 newspaper article. Comment from Oregon Wild asserts that there is a “war on snags” which has long-term 

consequences because it takes a long time to replace large snags. Snag comments previously responded to. 

Robbins, Jim. 2006. Studies Find Danger to Forests in 

Thinning Without Burning.

Not science. Not cited by commenters; no discrete issue with EXF project expressed. 
Appendix F Response to Public Comments

 EXF Final EIS Page 87 of 88

Robbins, Jim. 2009. Some See Beetle Attacks on 

Western Forests as a Natural Event. New York Times, 

July 6, 2009

Not science. Not cited by commenters; no discrete issue with EXF project expressed.

Rocca, Monique E. and William H. Romme. 2009. 

Beetle-infested forests are not “destroyed” Vol. 7, No. 2, 

pp. 71-72. www.frontiersinecology.org

Newspaper article. This reference is cited by Oregon Wild with the comment that the effects of beetle outbreaks are 

overstated. This document does not provide any science that opposes methods used in EXF. The need for density 

reduction in the Experimental Forest has been shown to be based on scientific research.

Sierra Club. Undated. Forest Fire Resilience & 

Restoration Oregon Sierra Club Presentation.

This is a power point presentation. Date, author and intended audience unknown. This document provides no scientific 

information and does not reference any scientific research. Commenters provide no specific comments that reference 

this presentation.

Wuerthner, George. 2008. Logging is not the answer to 

pine beetle problems. 

http://www.queencitynews.com/modules.php?op=modloa

d&name=News&file=article&sid=8663&mode=flat&order=

0&thold=0>

Newspaper editorial piece. Commenters provide no specific comments that reference this opinion piece which is a 

response to a preceding editorial piece about logging to stop pine beetle mortality in forests in Montana. This document 

provides no science relevant to the EXF project.

Wuerthner, George. 2008. Wild Forests and Landscape 

Amnesia. International Journal of Wilderness 14(2):4-6

Not peer-reviewed science. This piece in the International Journal of Wilderness discusses public perception of forests 

and the difference between the eastern and western US. Commenters provide no specific comments that reference this 

article and it is not relevant to the analysis in the EXF FEIS.

Wuerthner, George. Undated. The Myths of Forest 

Health. Source Unknown.

Undated writing of unknown source questions the revised forest plan for the Beaverhead Deerlodge National Forest and 

more generally the Forest Service assumptions of what is normal and asserts that there is no need for “intrusive 

management other than to get out of the way and allow fires, beetles, droughts, and other normal ecological processes to 

operate.” Not cited by commenters; not relevant to the EXF project.
Consideration of Public Content

EXF Final EIS Appendix F Page 88 of 88

Federal Agency Comments:

Environmental Protection Agency
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140

OFFICE OF 

ECOSYSTEMS, TRIBAL AND 

PUBLIC AFFAIRS 

 

November 2, 2009 

John Allen, Forest Supervisor 

c/o Shane Jeffries, District Ranger 

1230 N.E. 3rd St., Suite A-262 

Bend, OR 97701 

Subject: EXF Thinning, Fuels Reduction, and Research Project. 

 EPA Project Number: 08-025-AFS 

Dear Mr. Allen: 

The U.S. Environmental Protection Agency (EPA) has reviewed the Draft Environmental 

Impact Statement (DEIS) for the proposed EXF Thinning, Fuels Reduction, and Research 

Project on the Bend/Ft. Rock Ranger District of Deschutes National Forest in Deschutes 

County, Oregon. Our review was conducted in accordance with EPA responsibilities under the 

National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act (CAA). 

The DEIS analyzes the effects of implementing vegetation management and fuels 

reduction within the Lookout Mountain Unit of the Pringle Falls Experimental Forest. The layout 

of thinning, mowing, and underburning is based on the design of a research study plan written by 

the Pacific Northwest Research Station. The DEIS considers two action alternatives: Alternative 

2 is the proposed action, and treats across 2,554, and Alternative 3 avoids activities within 

spotted owl habitat and Late Successional Reserves, and treats across 2,178 acres. Our review 

focused on Alternative 2. 

 As a participant on the Deschutes Provincial Advisory Committee (PAC), EPA has had 

the opportunity to survey other ongoing research efforts on the Pringle Falls Experimental 

Forest. This forest is an important natural laboratory that is serving to enhance our 

understanding of the role of natural and human-caused disturbances as agents of change in 

ponderosa pine, lodgepole pine and mixed conifer forests, and the degree to which they can be 

effectively managed to achieve or sustain desired ecological conditions. We are supportive of 

the proposed project, both as a means to address the risk of severe insect epidemic or 

catastrophic fire, and as an opportunity to study forest dynamics after thinning and fuels 

reduction in dry forests. Although a small component, we are appreciative that the long-term 

influence of climate change will be considered within the context of the study. As climate 

changes, so may the way in which fuel reduction treatments affect vegetation dynamics and 

forest structure. Research such as this can help to build our understanding and inform future 

management. 
 2 

Based on our review, we are rating the DEIS as LO (Lack of Objections). We appreciate 

the opportunity to review and comment on the DEIS, and we look forward to furthering our 

understanding of this and other projects as we continue to participate on the PAC. If you have 

any questions about our review, please do not hesitate to contact me at (503)326-2859. 

 

 Sincerely, 

 /s/ 

 Teresa Kubo, Acting Manager 

 Environmental Review and Sediment Management Unit 
Deschutes County will go on record supporting Alternative 2 as identified 

in the DEIS. Our comments and recommendations to support the proposed 

action is based on the thorough explanation and display of alternatives, 

furthermore we offer other additional considerations:

1. In the East/West CWPP we identified major travel routes from 

recreation areas along the Cascade Lakes Highway that would serve as 

evacuation routes in the case of a major wildland fire event. Roads 

4240, 

4040 and 4250 were specifically identified in the CWPP to conduct fuels 

reduction along each road to provide a margin of safety for both public 

and wildland responders. The proposed treatments will satisfy this 

recommendation.

2. The proposed project is either inside or in the close proximity of 

three Community Wildfire Protection Plans (East/West, Upper Deschutes 

River, and Greater La Pine). In each case emphasis was placed on 

treatment of public lands either near evacuation routes or communities.

In this particular case the community of Fall River Estates is 

immediately 

north west from the project area and based on previous large fire growth 

projections would certainly be adversely impacted by a large fire either 

originating from or burning through the project area, the proposed 

actions 

meet the standards identified in the CWPP’s.

3. Although Alternative 2 well documents the differences from 

Alternative 

3, the net gains from the perspective of research opportunities and 

significantly reducing the negative impacts of a stand replacement fire 

solidify the chosen alternative. We support that thesis. Frankly if we 

can’t protect and enhance the Region’s oldest Experimental Forest and 

return the vegetation to a normal healthy state we may be missing one of 

the most important resource opportunities in our history.

Thanks for the opportunity to provide comments on the DEIS, you have our 

full support.

Joe Stutler

Deschutes County Forester

(541) 322-7117 office

(541) 388-2719 fax

61150 SE 27th St.

Bend, OR 97702

joest@co.deschutes.or.us