1

Appendix D – Response to Comments

Results of the Draft EIS Comment Period

The comment period for the draft EIS resulted in the receipt of 995 comment letters, including 

19 unique letters, 718 form letters, and 24 form letters that included additional information (234 

letters were duplicates). Comments were identified in these letters regarding issues and concerns 

raised by the author that are directly related to proposed project activities. These comments were 

then categorized according to the primary topics of their content. Within these topics areas, 

comments were grouped together and summarized together with similar comments. The 

interdisciplinary team then responded to these summary statements to address the issue or 

concern identified, or clarify where more information was requested. 

As you will see below, each topic area begins with this a summary “concern statement,” 

followed by the Forest Service’s response, and then a table of the quoted comments as they 

appeared in submitted letters. If a comment was unique in its subject from any other comments, 

it was addressed individually. Any comments that provided substantive new information were 

considered and necessary revisions made to the final EIS and supporting documents or addressed 

in the draft Record of Decision. Provided literature used in support of a comment that was not 

previously considered was reviewed by resource specialists and considered in their final analyses 

where applicable to the Horse Creek Project. 

A table is included below which lists the names of commenters who submitted letters with a 

unique identifying number assigned to each commenter. Form letters are included once in this 

list with one identifying number, although form plus letters are uniquely numbered. All letters 

submitted during the Draft EIS comment period are available for review in the public reading 

room on the project website: www.fs.usda.gov/project/?project=50586.

Quoted comments included in this response document are identified by unique comment number 

which is first the number of the letter submitted, and second a unique identifying number for the 

comment itself. Should commenters seek to find responses to their own specific comments, this 

letter number identifier can be used to search for where the Forest responded to their comments

in this document. Additionally, the letter table below will refer commenters to which comment 

response number their letters were included in.

Finally, a table of comment topics is provided to allow for navigation to topics a reviewer may 

be interested in reading.

Regarding the comment response topic numbers themselves, they are not intended to provide any 

prioritization for the topics discussed (the topics are randomly ordered) and are not continuous 

(some numbers are missing). These numbers were generated by the database used to process and 

analyze comments and do not represent any intention of the responders. Missing numbers do not 

mean that responses or comments are missing or not included.
2

Commenters by Name, Organizational Affiliation (if provided), Letter Number and Type, and 

Comment Response Number 

Name Organization Letter 

#

Letter 

Type

Comment Response 

Numbers

Phillip Anzo

Department of 

Forestry and 

Fire 

Protection

6 Unique 112, 124

Dick Artley WildLands 

Defense 1 Unique

7, 30, 41, 43, 44, 46, 48, 62, 

71, 74, 75, 106, 107, 109, 115, 

127, 134

Kimberly Baker

Klamath 

Forest 

Alliance

519 Unique

7, 34, 36, 59, 60, 72, 76, 82, 

84, 87, 88, 89, 92, 94, 95, 98, 

102, 103, 114, 128, 129, 131

Michael N.

Kobseff

Siskiyou 

County Board 

of Supervisors

520 Unique 1, 57, 102, 104, 105, 112, 124, 

132

Darvel Lloyd 578 Unique 107, 121

Kathleen

Martyn Goforth EPA 369 Unique 34, 101, 112, 128, 129

Deb MullaneySliney 518 Unique 33, 58, 79, 116, 118, 123

Ian Nelson

Pacific Crest 

Trail 

Association

996 Unique 53

Dean Prat Water Board 

(NCRWQCB) 591 Unique 19, 32, 89, 90, 92, 128, 129

Joseph Quinn

Umpqua 

Watersheds, 

Inc.

5 Unique 3, 24, 121

Kasra Ramez Wildearth 

Guardians 589 Unique 19, 22, 28, 54, 87, 98, 100, 112, 127, 129, 133

Cooper Rodgers

KlamathSiskiyou 

Wildland 

Center

517 Unique 26, 27

Luke Ruediger

Applegate 

Neighborhood 

Network

368 Unique

7, 12, 14, 18, 22, 23, 24, 26, 

27, 34, 35, 36, 37, 38, 41, 43, 

45, 48, 50, 52, 53, 54, 55, 61, 

64, 66, 69, 72, 77, 78, 80, 81, 

82, 87, 98, 99, 100, 106, 107, 

113, 114, 119, 121, 125, 135

Terry Salvestro

Fruit Growers 

Supply 

Company

2 Unique 1, 11, 18, 57, 85, 103, 105, 

112, 124
3

Name Organization Letter 

#

Letter 

Type

Comment Response 

Numbers

Suzie Savoie

Siskiyou 

Chapter 

Native Plant 

Society of 

Oregon

515 Unique 22, 26, 31, 38, 39, 40, 52, 54, 

61, 73, 81, 107, 119, 121

George Sexton

Klamath 

Siskiyou 

Wildlands 

Center

516 Unique

3, 14, 16, 17, 19, 20, 22, 24, 

25, 26, 38, 39, 42, 44, 47, 49, 

50, 51, 56, 59, 62, 63, 64, 66, 

68, 70, 82, 83, 84, 86, 93, 96, 

97, 98, 99, 106, 107, 108, 110, 

111, 114, 117, 122, 126, 128, 

130, 134, 136

Gerard MJ van 

Hees AFRC 7 Unique 1, 11, 29, 79, 116, 118, 120

Tom Wheeler EPIC 593 Unique 22, 60, 63, 67, 103, 106, 114, 

128

Tom Wheeler

Environmental 

Protection 

Information 

Center

997 Unique 114

Janey Whitlock Department of 

the Interior 592 Unique

348 individual 

commenters EPIC 4 Master Form 41, 62, 121

7 individual 

commenters KS Wild 155 Master Form 38, 63

386 individual 

commenters KS Wild 384 Master Form 38, 62, 63, 121

Carol Ampel KS Wild 488

Form 

Plus, 

384

38, 62, 63, 121, 131

M. Braun KS Wild 904

Form 

Plus, 

384

38, 62, 63, 121

Donna Brucker KS Wild 689

Form 

Plus, 

384

38, 62, 63, 121

George Frances 

Alderson KS Wild 798

Form 

Plus, 

384

38, 62, 63, 121

Roberta Hill KS Wild 979

Form 

Plus, 

384

38, 62, 63, 121

Trisha Lee KS Wild 501

Form 

Plus, 

384

22, 38, 62, 63, 107, 113, 121
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Name Organization Letter #

Letter 

Type

Comment Response 

Numbers

Albert Martin KS Wild 411

Form 

Plus, 

384

38, 62, 63, 113, 121

Thomas 

Mulkeen KS Wild 831

Form 

Plus, 

384

38, 62, 63, 121

Laura Ohanian KS Wild 491

Form 

Plus, 

384

38, 62, 63, 113, 121

Byron Rendar KS Wild 544

Form 

Plus, 

384

38, 62, 63, 121

Gabriel Scott KS Wild 385

Form 

Plus, 

384

38, 62, 63, 121

Ben Scott KS Wild 437

Form 

Plus, 

384

38, 62, 63, 121

A.M. Stone KS Wild 986

Form 

Plus, 

384

38, 62, 63, 121

Denise Tschann KS Wild 942

Form 

Plus, 

384

14, 38, 62, 63, 121

Matthew Witt KS Wild 635

Form 

Plus, 

384

38, 62, 63, 121

Vince Zauskey KS Wild 497

Form 

Plus, 

384

38, 62, 63, 121

Benjamin 

Zumeta KS Wild 882

Form 

Plus, 

384

38, 62, 63, 81, 121

Anonymous KS Wild 409

Form 

Plus, 

384

38, 62, 63, 121

Robin Carter EPIC 64 Form 

Plus, 4 41, 62, 121

F Hammer EPIC 75 Form 

Plus, 4 41, 62, 121

Ann

Hammond EPIC 162 Form Plus, 4 41, 62, 121

James Nelson EPIC 224 Form 

Plus, 4 41, 62, 121

Lawrence 

Thompson EPIC 107 Form Plus, 4 41, 62, 121

Karen Wilson EPIC 376 Form 

Plus, 4 41, 62, 87, 121
5

Table of Comment Response Numbers and Topics 

Comment Response #1: Increase treatment area ............................................................................ 9

Comment Response #3: LSR Salvage comments from Dr. Jerry Franklin .................................. 10

Comment Response #9: Activity fuels treatment ........................................................................ 14

Comment Response #14: Fuel loads after project implementation .............................................. 16

Comment Response #15: Characteristic nature of the Gap Fire................................................... 17

Comment Response #17: Susceptibility of plantation stands to fire ............................................ 19

Comment Response #19: Green trees removal for operations...................................................... 21

Comment Response #20: Tree mortality guidelines..................................................................... 22

Comment Response #21: Use of prescribed fire........................................................................... 23

Comment Response #22: Travel management ............................................................................. 24

Comment Response #23: LSR salvage consistency with FEMAT............................................... 27

Comment Response #25: Use, construction, and reconstruction of roads.................................... 28

Comment Response #26: Salvage and late successional forest development .............................. 30

Comment Response #27: Should not salvage LSR or Siskiyou Crest.......................................... 32

Comment Response #28: Salvage in LSR economically motivated............................................. 34

Comment Response #30: Siskiyou Crest as regional connectivity corridor................................. 36

Comment Response #31: Climate refugia in the Siskiyou Crest.................................................. 39

Comment Response #32: Site specific road proposal................................................................... 41

Comment Response #33: Temporary road construction needed .................................................. 42

Comment Response #34: Herbicide use ....................................................................................... 42

Comment Response #35: Non-native invasive species spread risk.............................................. 43

Comment Response #36: Westside project design features not included..................................... 44

Comment Response #37: Wilderness........................................................................................... 45

Comment Response #38: General suggestions and recommendations......................................... 46

Comment Response #40: Cost of planning and implementation.................................................. 46

Comment Response #41: Capacity for implementation ............................................................... 48

Comment Response #42: Firefighter safety during suppression activities................................... 49

Comment Response #43: Clearcutting.......................................................................................... 50

Comment Response #44: Surveys for protected botanical species............................................... 51

Comment Response #45: Surveys for Henderson’s triteleia ........................................................ 53

Comment Response #46: Negative effects of salvage harvest ..................................................... 53
6

Comment Response #47: Survey and manage fungi determination ............................................. 54

Comment Response #48: Beneficial effects of salvage harvest ................................................... 55

Comment Response #49: Salvage’s ability to promote forest recovery....................................... 56

Comment Response #50: Schist soils, wetlands, and wet meadows ............................................ 58

Comment Response #51: No action alternative effects to soils.................................................... 59

Comment Response #52: Soils PDF and BMP effectiveness....................................................... 59

Comment Response #53: Salvage increases fire severity............................................................. 60

Comment Response #54: Site specific soils effects analysis........................................................ 62

Comment Response #55: Soils effects analysis............................................................................ 64

Comment Response #56: Mechanical piling effects to soils........................................................ 65

Comment Response #57: Impacts to the PCT experience and economics................................... 66

Comment Response #58: Visual impacts to the PCT................................................................... 68

Comment Response #59: Salvage does not promote fire adaptability ......................................... 70

Comment Response #60: Effects to Visual Retention VQO ........................................................ 71

Comment Response #61: Analysis of Visual Quality Objectives ................................................ 72

Comment Response #62: Treatment timeline urgency................................................................. 73

Comment Response #63: Balanced alternative to meet multiple needs....................................... 74

Comment Response #64: Recommendations for activity fuels treatment.................................... 74

Comment Response #65: Logging systems and layout recommendations................................... 75

Comment Response #66: Salvage in Riparian Reserves and Special Interest Area ..................... 76

Comment Response #67: Credibility of effects analysis and project goals.................................. 77

Comment Response #69: Collaboration and public values over salvage ..................................... 79

Comment Response #70: LSR salvage, inconsistent with Forest Plan......................................... 80

Comment Response #72: Hazards in riparian reserves, retain felled trees................................... 82

Comment Response #73: Roadside hazards treatment on inaccessible roads.............................. 83

Comment Response #74: Roadside logging, economically driven .............................................. 84

Comment Response #75: Roadside hazards, “true” hazards........................................................ 84

Comment Response #76: Roadside logging, buffer distance ....................................................... 85

Comment Response #78: Matrix salvage, economically driven................................................... 86

Comment Response #79: Special Interest Area treatment support............................................... 87

Comment Response #80: SIA, should do ..................................................................................... 88

Comment Response #81: Reburn potential is a fraudulent statement .......................................... 88

Comment Response #82: Environmentally preferable alternative identification......................... 89
7

Comment Response #83: Violates NEPA, incorporated by reference ......................................... 90

Comment Response #84: Coarse woody debris retention ............................................................ 91

Comment Response #85: Salvage unit size .................................................................................. 91

Comment Response #86: Snag retention, not needed................................................................... 92

Comment Response #87: Snags provide shade ............................................................................ 92

Comment Response #88: Ecological benefits of snags ................................................................ 93

Comment Response #89: Snag retention of biological legacy trees............................................. 94

Comment Response #90: Forest plan standards and guidelines for snag retention...................... 96

Comment Response #91: Snag retention diameter limits............................................................. 97

Comment Response #92: Diameter limits, flexible ...................................................................... 98

Comment Response #93: Coho salmon determination................................................................. 98

Comment Response #94: Effects to aquatic species..................................................................... 99

Comment Response #95: Effects to aquatic resources consistency with law and policy........... 100

Comment Response #96: Water Board waiver compliance ....................................................... 103

Comment Response #97: Temporary roads PDF, support of ..................................................... 105

Comment Response #99: Effects to watershed and water quality.............................................. 105

Comment Response #100: Watershed effects, violates ACS ..................................................... 106

Comment Response #101: Watershed effects, rely on PDFs ..................................................... 110

Comment Response #102: Habitat connectivity analysis........................................................... 110

Comment Response #103: Wildlife effects analysis inadequate ................................................ 112

Comment Response #104: NSO recovery plan consistency....................................................... 115

Comment Response #106: Effects to NSO................................................................................. 116

Comment Response #107: NSO burned habitat use................................................................... 119

Comment Response #108: Climate change analysis inadequate ................................................ 122

Comment Response #109: Air quality impacts of prescribed fire.............................................. 123

Comment Response #110: Socioeconomic effects analysis inadequate..................................... 124

Comment Response #112: Logging systems recommendations................................................. 126

Comment Response #113: Needs and interests of the local community.................................... 127

Comment Response #114: Seasonal restriction and limited operating periods.......................... 128

Comment Response #115: Salvage and natural regeneration and recovery............................... 128

Comment Response #116: Natural recovery .............................................................................. 130

Comment Response #117: Literature provided during scoping ................................................. 134

Comment Response #118: Best available science ...................................................................... 135
8

Comment Response #119: Literature use in project analysis..................................................... 137

Comment Response #120: MIS analysis, request for extension to comment period.................. 138

Comment Response #121: General project support.................................................................... 139

Comment Response #122: General project opposition............................................................... 140

Comment Response #123: Cumulative effects analysis inadequate........................................... 141

Comment Response #124: Support of Alternative 1 .................................................................. 144

Comment Response #125: Against Alternative 1....................................................................... 145

Comment Response #126: Wildfire suppression as cumulative effect....................................... 146

Comment Response #127: Support of Alternative 2 .................................................................. 148

Comment Response #128: Support of Alternative 3 .................................................................. 149

Comment Response #129: Against Alternative 4....................................................................... 149

Comment Response #130: Support of the Karuk Alternative .................................................... 150

Comment Response #131: Arson, encouraging.......................................................................... 152

Comment Response #132: Against the Karuk Alternative ......................................................... 152

Comment Response #133: Roadside hazards and fuels treatment support................................. 153

Comment Response #134: Strategic treatment for firefighter safety.......................................... 154

Comment Response #135: Landslide risk................................................................................... 155

Comment Response #136: Overall project effects analysis........................................................ 156

Comment Response #137: Questions to answer......................................................................... 156

Comment Response #138: Request for information or hard copy.............................................. 163

Comment Response #139: Scoping literature............................................................................. 163

Comment Response #140: Salvage does not meet the purpose and need................................... 164

Comment Response #141: Not treating enough to meet the purpose and need.......................... 165

Comment Response #142: Alternative suggested....................................................................... 166

Comment Response #143: Alternatives should consider resource effects and ESA.................. 168

Comment Response #144: Recommendations for “Restoration of Federal Lands in the Pacific 

Northwest” have been ignored.................................................................................................... 169

Comment Response #145: Alternatives considered but eliminated from detailed study ........... 170
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Comment Response #1: Increase treatment area

Concern statement:

There is a concern that the project does not treat a large enough area of the area burned by the 

Gap Fire (5% of the burned area) and that as many acres as possible are treated in order to 

effectively meet the purpose and need, complete fire recovery and forest restoration, be 

economically feasible, contribute to the local economy, and address safety concerns.

Forest Service Response:

The statement that we are only treating five percent of the burnt area appears to come from 

references in the EIS about proportions of the project acres that have fire salvage. On page 216 

of the FEIS, it states that salvage harvest would occur on five percent of the National Forest 

lands. On page 59, it states salvage would occur on five percent of the LSR land allocation. 

These statements are intended to convey the scale of the project, not to infer that 95 percent of 

the needed work is not occurring. Most of the Horse Creek fire area burned at low intensity and 

there is no need to take action in those locations to salvage fire killed trees. Also, in many of 

those areas, trying to pick up scattered dead trees is just not economically feasible. A lot of the 

work we are doing has benefits beyond the site scale such as strategic fuel breaks, roadside 

hazard reduction and fuels reduction adjacent to private lands. We have clustered most of the 

salvage operations near or adjacent to private property to increase protections there. It is also a 

reality that other resource concerns for water quality and wildlife habitat limit how much of an 

area can be salvage harvested. On national forest lands, there are about 4,000 acres of moderate 

or high severity burn where more than 50 percent of the trees were killed. There are salvage 

operations proposed on 35 to 50 percent of those acres depending on the alternative. In addition, 

there are 103 acres of roadside hazard reduction, approximately 1,400 aces of fuels reduction 

adjacent to private property, approximately 460 acres of site preparation (which includes fuel 

reduction), approximately 700-730 acres of fuels management zones, 218 acres of site 

rehabilitation in the Horse Creek SIA and about 390-690 (depending on alternative) of roadside 

fuels reduction (Table 14, FEIS page 73). The roadside hazard removal will generate some 

commercial timber as a byproduct. All of these actions occur in, and are driven by the Gap Fire 

and direction in the Klamath Forest Plan. While there is more that could be done, we believe the 

Proposed Action and alternatives are balanced responses to the conditions created by the Gap 

Fire. The purpose and need for the Horse Creek Project includes fuel reduction and public safety 

as major components of ecosystem recovery, in addition to recovering value from deteriorating 

timber. More information is provided in the fire and fuels report and section of the FEIS that 

explains what effect the project has at reducing future risk of wildfire. The socioeconomics 

report and section of the FEIS provides an analysis of the project's contributions to the local 

economy.

Associated Comments:

Comment 

# Comments

2-14 We ask that as many acres be treated and planted as possible to promote forest health and 

further economic viability in the County.

7-11 The proposed action in the Draft EIS is proposing to treat approximately 5% of the total 

Forest Service burned area with salvage harvesting (a slightly higher percentage when other 
10

Comment 

# Comments

activities are included). All of the other Alternatives propose to treat even fewer acres. The 

selected alternative should treat as many acres as possible on all of the fire areas considered.

7-12

It is apparent that treating only 5% of the burned area does not come close to a complete fire 

recovery effort given the amount of acreage burned and the large acreage of high mortality. 

We would like to see more of the high severity burned areas treated.

7-14

Of the four alternatives, we will support the selection of Alternative 2 as better than nothing. 

We believe the majority of the taxpayers and county residents would rather see a quick 

response to the restoration efforts due to these fires by producing an economically feasible 

project that will produce some revenue. Most of the taxpayers and local citizens would prefer 

to see as many acres treated as possible within the framework of regulatory restrictions and 

short times frames required to accomplish some level of restoration.

7-15

None of the four Alternatives identified in the Draft EIS meet the purpose and need for the 

project. The following highlights a few of the reasons why we believe none of them will 

address the safety concerns, recover a substantial amount of the burnt timber or reduce the 

fuel loading in LSR's and riparian areas. In general, a majority of the burnt acres must be 

treated in order to meet the purpose and need. None of the alternatives treat more than 5% of 

the burnt area which will do little towards meeting the purpose and need.

520-3

It is imperative that the maximum number of acres are treated through implementation of this 

Project, however, as outlined through all of the alternatives discussed in the Project, 

approximately only five percent of the burned area will be treated, which leaves a significant 

number of untreated and vulnerable acres. This also does very little towards meeting the 

purpose and need of the Project, which outlines the necessity for (1) addressing safety needs 

for the public, adjacent landowners, and forest workers and firefighters, (2) recovering timber 

volume from fire killed trees, and preventing the probability for future high-severity fires, and 

improved fire resiliency, and (3) reduced fuels within late-successional and riparian reserves 

to meet desired conditions.

Comment Response #3: LSR Salvage comments from Dr. Jerry Franklin 

Concern statement:

There is a concern that the project analysis does not consider the views of Dr. Jerry Franklin that 

were provided in response to the Westside Fire Recovery project. Those views shared were that 

salvage logging in late successional reserves is incongruent with the recommendations of the 

Northwest Forest Plan.

Forest Service Response:

Thank you for your comments. Dr. Franklin, a respected forest ecologist, educator and scientist, 

submitted comments on the Westside Fire Recovery Project in 2015 that were specific to that 

project. Several commenters on the Horse Creek project have adopted and resubmitted those 

comments. While these comments from Dr. Franklin are not specific to the Horse Creek project, 

the concerns expressed are relevant and are considered here. Most of the area of the Northwest 

Forest Plan lies in the Oregon and Washington Cascades and Coast Ranges. This comment 

equates the Mediterranean climate dry forests of the Klamath Province in northern California 

with the mesic forests of western Oregon and Washington. There is often a presumption that the 

conditions described for those forests apply to forests of the Klamath Province as well. Key oldgrowth structural attributes of the Coast Range and Oregon and Washington Cascades include 
11

large live old trees, a large number of snags-of various ages, a multilayered canopy, and 

moderate to high accumulations of logs or coarse woody debris on the forest floor (Franklin, 

1981). The fire regime of the Klamath Mountains differs from the more mesic old-growth 

Douglas fir forests of Oregon and Washington (described in Franklin et al. (1981) in fire 

frequency, fire severity, and structural attributes such as amount and persistence of coarse woody 

debris (Taylor and Skinner 1997, Skinner 2002). The Klamath Province also differs from the 

"dry forests" east of the Cascades. The Recovery Plan for the Northern Spotted Owl (USDI 

2011) noted these differences observing: "Some areas, such as dry portions of the Klamath 

Province, have a different fire ecology than areas in the East Cascades and may not be subject to 

the same generalizations (Odion et al. 2004, 2010, Skinner et al.2006, Hanson et al. 2009, 2010); 

this should be evaluated at a finer scale by recovery implementation teams and interested land 

managers." (NSO Recovery Plan III-21). We agree with the importance of an appropriate level 

of snags and coarse woody debris in the post fire landscape; however because of the 

Mediterranean climate and historic fire regime of the Klamath Province, we disagree that all of 

that material must be retained for ecosystem function. Retention of all of the fire killed trees 

would result in fuel loads that would create a substantial risk of future high severity fire that 

could further impact remaining coniferous forests and other resources. Site-specific data from the 

Horse Creek fire and modeling of that data with accepted fire behavior and fuels analysis tools 

show that "No Action" would result in heavy fuel accumulation and high severity fire behavior 

in the future that would likely threaten adjacent communities and delay the reestablishment of 

coniferous forests (FEIS page 131, 214-219). We also disagree that the salvage units are 

"clearcuts" as described in the comment. See the definition of "clearcut" in the FEIS glossary. 

Historically, the vast majority of the Klamath Province was characterized by a frequent fire, low 

to mixed severity fire regime (Skinner et al, 2006). With frequent fire, surface fuels are 

maintained at low levels - too low for intensity sufficient to produce much stand-replacement 

fire, except under unusual circumstances. Snags and down logs rarely persisted on the landscape, 

and fire had a generally negative feedback loop for dead wood. In other words, fire tended to 

reduce the amount and distribution of dead wood in each fire cycle (Skinner 2002). Fire 

suppression coupled with a warming climate have altered the fire regime to an infrequent fire, 

mixed to high severity environment. That means that the proportion of high severity fire and / or 

patch size of high severity burns has likely increased over historic norms (FEIS page 114). 

Scientific literature has been consistent in the finding that where low-severity fire areas occurred 

in the past, the areas re-burned at low severity again. Conversely, areas that burned with high 

severity in the past tended to reburn with high severity but with increased patch size (Coppoletta 

et al. 2016; Odion et. al. 2004; Skinner et al. 2006; Thompson et al. 2007). Said another way, 

high severity fire creates a positive feedback loop for more high severity fire (Thompson et al. 

2007). The proportion of high severity fire, the patch sizes of high severity fire, and the 

frequency of high severity fire in the Klamath Province, all appear to be increasing when 

compared to historic norms. Patch sizes of high severity fire from the Gap Fire were 

uncharacteristically large compared to the historic fire regime of the Klamath Mountains 

described by Skinner et al. 2006 (FEIS page 114). Mixed severity fire was more common in the 

upper elevations of the Siskiyou Crest. Forests on the Siskiyou Crest have still been heavily 

influenced by fire suppression since European settlement, and forests there have been shown to 

be uncharacteristically dense, and deprived of natural mixed-severity fire. Forests on the 

Siskiyou Crest have had a substantially elevated risk of burning in large-sized fires with a greater 

probability of severe fire effects than would be expected in a pre-settlement condition influenced 
12

by an unaltered fire regime. “The Horse Creek Ecosystem Analysis identified that under 

conditions extant in 2000, the area “will burn with more intensity and higher severity than any 

vegetative condition that has existed in this area in documented history...This analysis area has a 

higher fire risk than any other analysis area on the Forest. Even with active fire suppression 

efforts, there is a high likelihood that much of the analysis area will be involved in large scale 

wildfire events in the near future” (Horse Heli FEIS, page 37) The Fire and Fuels Report 

documents the cycle of high severity fire. The contribution of heavy fuels to fire severity is 

significant. Coppoletta et al. (2016) found that "high to moderate-severity fire in the initial fires 

led to an increase in standing snags and shrub vegetation, which in combination with severe fire 

weather promoted high-severity fire effects in the subsequent reburn." When combined with the 

rapid growth of fire-adapted brush species, the heavy fuels that result from high severity fire 

creates conditions that perpetuates these areas in an early seral, high severity fire cycle that may 

last centuries. Hessburg et al. (2016) documented this reburn site conversion pattern resulting 

from high severity fire:"...with a warming climate creating conditions for more high-severity fire 

(Westerling et al., 2003; Lenihan et al., 2006), and the occurrence of larger and more frequent 

high-severity burned areas (Miller et al., 2009, 2012; Harris and Taylor, 2015), there is now a 

greater potential for severely burned patches to be converted to these alternative stable states 

(Lauvaux et al., 2016; Long et al., 2014a; Harris and Taylor, 2015; Perry et al., 2011; Savage and 

Mast, 2005). Typically this occurs where successive fires occur over the same area, especially 

when the initial fire burns with high severity effects and causes a transition to a grass or shrubdominated community (van Wagtendonk et al., 2012). Documented examples are widespread in 

the Siskiyou Mountains (Silver Fire of 1987 followed by the Biscuit Fire of 2003), the Klamath 

Mountains (King-Titus Fire of 1987 followed by the Panther Fire of 2008), the northern Sierra 

Nevada/southern Cascade Range (Storrie Fire of 2000 followed by the Chips Fire of 2012 - see 

Coppoletta et al. (in press)), and in the central Sierra Nevada (Stanislaus Complex of 1987 

followed by the Rim Fire of 2013)." Continuity and density of fuels need to be reduced if the 

future extent of high severity fire is to be reduced (Thompson et al. 2007; Peterson et al. 2015). 

In discussions about target levels of fuels, we often refer to "natural range of variability" or 

similar concepts. In most circumstances, fire suppression has resulted in fuel loads that have 

exceed the historic range of fuel loads so that even after a high severity fire, our start point is 

already well above our desired conditions for fuel. This is further complicated by climate change 

projections of warmer temperatures, longer fire seasons and more hot summer days that favor 

fire-adapted brush species. It is useful in this discussion to consider what Hessberg (2016) 

described as the "future range of variability". With a changing climate, what levels of fuel 

continuity and density are acceptable, and how do we begin a cycle to achieve that? It is unlikely 

that "No Action" in high severity burns will create sustainable, resilient coniferous forests in the 

face of changing climate (FEIS page 116-123). In the Gap Fire, the size of the high severity burn 

patches are particularly notable (FEIS page 114). Without some form of intervention, these large 

patches are likely to reburn with high severity and will likely increase in size. Post-logging fuel 

treatments, such as piling and burning or broadcast burning (jackpot burning), can rapidly reduce 

total amounts and spatial continuity of surface woody fuels, and may allow logged stands to 

serve as fuel-breaks in a landscape-level fire management strategy (Peterson & Harrod, 2010). In 

addition, Peterson, Dodson, and Harrod 2014 found that post-fire logging altered post-fire fuel 

succession by (1) greatly accelerating the deposition of surface woody fuels from logged snags, 

(2) reducing peak loading of large diameter woody fuels, and (3) initiating the woody fuel decay 

earlier. Ritchie, Knapp and Skinner (2012), evaluated salvaged units following the Cone Fire on 
13

the Lassen National Forest. They found that after four years higher levels of surface fuel 

accumulations occurred in lower intensity salvage plots. The highest surface fuel accumulations 

occurred in un-salvaged plots four to eight years after the fire. The highest levels of large woody 

debris were associated with un-salvaged areas. Ritchie et al. (2012) observed that areas that were 

salvaged to remove heavy fuels had lower fuel loading after eight years than areas that were 

unsalvaged. Activity fuel treatment following salvage harvest would reduce fuel loading even 

further within salvage units." (Fire and Fuels Report, Pg. 22). Dunn and Bailey (2014) also found 

that salvage logging significantly reduces coarse woody fuel loadings after approximately seven 

years, which is expected reduces re-burn hazard for several decades depending on available 

1000-hour fuel loadings. This is consistent with site-specific fuel modeling and with other 

literature considered in the FEIS, notably Peterson et al. (2015). We agree that logging can 

increase slash loads and hence fire risk if those activity fuels are not treated. In the Horse Creek 

Project, activity generated slash will be burned when logging is completed reducing surface fuels 

to levels consistent with low fire hazard. Finally, it is appropriate to note that the scale of 

proposed salvage operations in the Horse Creek project is very limited since salvage is focused 

on risk reduction by creating strategic fuel breaks (Forest Plan MA5-27, 28, 29) near or adjacent 

to private property, not maximizing the recovery of value and volume from dead trees. The most 

aggressive action salvages only five percent of the LSR in the Project Area (FEIS page 59) and 

only about one percent of the entire 49,000 acre Johnny O'Neil LSR. In the areas that are 

salvaged, the Forest Plan standards for snag retention will be met by leaving all snags in riparian 

reserves, designating snag retention areas within units, marking all cull trees for retention and 

marking high value wildlife trees where they occur. When these measures are combined with the 

limited scale of the salvage proposals, it is unlikely that LSR function will be compromised.

Associated Comments:

Comment 

# Comments

5-4

In the recent past, UW has submitted comments to the Klamath N.F. related to its 

unfortunate, ecologically retrograde West Side post-fire salvage. On that occasion, we 

submitted the extensive comments to your office made by renowned authority on regional 

forest related conservation/restorations issues, Dr. Jerry Franklin. (Copy submitted with this.) 

Therein, Dr. Franklin explained that post-fire salvage was directly and clearly antithetical to 

the intentions of the authors of the Northwest Forest Plan, regarding post-fire extraction in 

Late Successional Reserves. The Klamath N.F. obviously discounted this expert testimony 

and recommendation in favor of a shameful resort to outdated, retrograde post-fire 

management policies.

516-11

In his comments to the Klamath National Forest regarding the recent Westside clearcut 

salvage post-fire logging project please note that the author of the Northwest Forest Plan 

system of LSRs contends that: "Salvage logging of large snags and down boles does not 

contribute to recovery of late-successional forest habitat; in fact, the only activity more 

antithetical to the recovery process would be removal of surviving green trees from burned 

sites. Large snags and logs of decay resistant species, such as Douglas-fir and cedars, are 

critical as early and late successional wildlife habitat as well as for sustaining key ecological 

processes associated with nutrient, hydrologic, and energy cycles." -Dr. Jerry Franklin, 

4/6/15. The agency may not continue to remove large snags that are necessary for the LSR 

land use allocation to meet the function and purpose for which they were designed.

516-18 As described in our scoping comments, the primary architect of the NWFP LSR system has 

written that: "Salvage logging of large snags and down boles does not contribute to recovery 
14

Comment 

# Comments

of late-successional forest habitat; in fact, the only activity more antithetical to the recovery 

process would be removal of surviving green trees from burned sites. Large snags and logs of 

decay resistant species, such as Douglas-fir and cedars, are critical as early and late 

successional wildlife habitat as well as for sustaining key ecological processes associated 

with nutrient, hydrologic, and energy cycles." -Dr. Jerry Franklin, 1/20/04. The DEIS ignores 

the role that snags and logs play in sustaining wildlife habitat and key nutrient, hydrological 

and energy cycles that contribute to ecological (rather than economic) recovery in the 

Reserves. Franklin concluded that "salvage logging of large snags and logs is absolutely 

antithetical to rapid recovery of late-successional forest habitat." Yet such logging comprises 

the bulk of the KNF's "recovery" project.

Comment Response #9: Activity fuels treatment

Concern statement:

There is a concern that as a result of salvage treatments in the project, a large quantity of activity 

fuels (surface fuels, or slash) would be generated and if untreated increase the risk of future 

wildfire with high severity burning in the treatment units. These comments provided references 

to research regarding this issue. One commenter specifically asks "Does the Forest Service 

believe that logging will create worse fuel conditions in the short term? Does "site preparation," 

which includes the treatment of slash, act as a mitigation against the increased fuel loading 

caused by logging? What would occur if the Forest Service logged but did not treat post-logging 

slash?"

Forest Service Response:

The DEIS and the Fire and Fuels Report displays and discusses the short-term fuels conditions as 

well as mid- and long-term fuels conditions under the no action alternative and action 

alternatives. The project does not have an alternative proposed containing logging without site 

preparation and therefore this was not analyzed. The Fire and Fuels Report states "the short-term 

effect of salvage harvest is an elevated surface fuel loading from branches, cull logs, and unmerchantable tops followed by a much longer period of reduced surface fuel loading relative to 

burned stands that were not logged." (Fire and Fuels Report, page 22). The Fire and Fuels Report 

also states that for action alternatives there are "follow-up treatment of site preparation following 

salvage harvest. This treatment is aimed at reducing surface fuel loading (in all fuel size 

categories) from activity fuel generated by the salvage harvest, breaking up continuous fuel beds 

and reduction in fuel bed depth. Post-logging fuel treatments, such as piling and burning or 

broadcast burning (jackpot burning), can rapidly reduce total amounts and spatial continuity of 

surface woody fuels, and may allow logged stands to serve as fuel-breaks in a landscape-level 

fire management strategy (Peterson & Harrod, 2010). In addition, Peterson, Dodson, and Harrod 

2014 found that post-fire logging altered post-fire fuel succession by (1) greatly accelerating the 

deposition of surface woody fuels from logged snags, (2) reducing peak loading of large 

diameter woody fuels, and (3) initiating the woody fuel decay earlier. Ritche, Knapp and Skinner 

(2012), evaluated salvaged units following the Cone Fire on the Lassen National Forest. They 

found that after four years higher levels of surface fuel accumulations occurred in lower intensity 

salvage plots. The highest surface fuel accumulations occurred in un-salvaged plots four to eight 

years after the fire. Furthermore, the highest levels of large woody debris were associated with 
15

un-salvaged areas. Ritchie et al. (2012) observed that areas that were salvaged to remove heavy 

fuels had lower fuel loading after eight years than areas that were un-salvaged. Activity fuel 

treatment following salvage harvest would reduce fuel loading even further within salvage 

units." (Fire and Fuels Report, page 22). Dunn and Bailey (2014) also found that salvage logging 

significantly reduces coarse woody fuel loadings after approximately seven years, which is 

expected to reduce the risk of high severity burning for several decades depending on available 

1000-hour fuel loadings (Dunn and Bailey, page 107). This is consistent with site-specific fuel 

modeling and with other literature considered in the FEIS, notably Peterson et al. (2015). We 

agree that logging can increase slash loads and hence fire risk if those activity fuels are not 

treated. In the Horse Creek Project, activity generated slash will be burned reducing surface fuels 

to levels consistent with low fire hazard. Several comments refer to Donato et al. (2006). This 

paper posits that post fire salvage logging can result in a pulse of fine fuels that can increase fire 

intensity and severity in the short term, however the paper does not explain the results in a 

scenario where post logging slash is treated in all harvested areas. Post-harvest treatment of slash 

is proposed in all Alternatives (see Chapter 2 of the FEIS for full discussion of proposed 

Alternatives), and the predicted effects of this post-harvest treatment is a significant reduction 

both fine and coarse woody debris, as noted in Chapter 3 of the FEIS. This type of treatment for 

post-salvage fuels is called for by Donato et al. (2006) when they sate "Our study underscores 

that, after logging, the mitigation of short-term fire risk is not possible without subsequent fuel 

reduction treatments." The Horse Creek project will treat activity fuels so the findings of Donato 

et al. 2006 with respect to increased fuels from logging do not appear to be relevant. See the Fire 

and Fuels report for a complete discussion of treatment of post-salvage activity fuels (FEIS 124-

133). See also concern #49 for additional discussion of Donato et al. 2006 Mclver and Starr 

(2000) conducted a literature review of 21 studies worldwide prior to the year of 2000. Although 

Mclver and Starr (2000) "found no studies documenting a reduction in fire intensity in a stand 

that had previously burned and then been logged" Mclver and Starr (2000) is now nearly 20 

years old, and many of the cited papers are older than that. This does not reflect findings of more 

current literature that show post-fire logging followed by treatment of activity fuels (slash) can 

reduce future fire severity. Many other studies have found that areas with site preparation 

following salvage harvest, as proposed in the Horse Creek Project, have an overall reduction in 

fuel loading e.g. Ritchie, Knapp and Skinner (2012), Peterson and Harrod (2010), Peterson, 

Dodson and Harrod (2014). The site specific analysis for the Horse Creek Project clearly shows a 

reduction in future fire behavior potential and fuel loading, leading to reduced fire and fuel risk 

(see Fuels Report).

Associated Comments:

Comment 

# Comments

1-80

"Postfire logging significantly increased both fine and coarse downed woody fuel loads (Fig. 

1B). This pulse was comprised of unmerchantable material (e.g., branches), and far exceeded 

expectations for postfire logging-generated fuel loads (5, 6). In terms of short-term fire risk, a 

reburn in logged stands would likely exhibit elevated rates of fire spread, fireline intensity 

and soil heating impacts (7)."

1-82

"Recent studies have found, however, that salvage-logging can increase surface fuels 

available to fires above prelogging levels by transferring unmerchantable material to the 

forest floor, suggesting that this postfire management practice might actually increase fire 
16

Comment 

# Comments

risk for a time (3, 8). Until now, no study has quantified how recent fire history and postfire 

management actually affects the severity of a large wildfire (4)." (pg 10743)

1-83

"However, the available evidence suggests that the combined influence from a pulse input of 

surface fuels resulting from salvage-logging (3, 8) followed by the establishment of uniform 

young plantations may increase susceptibility to severe reburns in the early stages of forest 

development." (pg 10746)

368-40

A study of post fire logging in Oregon found salvage without slash treatment increased fire 

fuels by 3-13 tons per hectare. (Duncan, 2002) This is significant because it is highly unlikely 

that logging slash will be responsibly removed in a timely manner, if at all following logging 

operations. The KNF currently has a backlog of slash removal from recent massive post-fire 

logging projects including the Westside Project.

368-42

The agency must analyze fire hazards associated with logging treatments based the following 

metric. How many tons of logging slash will remain per acre on sites 1, 3, 5 and 10 years 

after treatment? How will this effect community fire safety, predicted flame length and fire 

severity? Finally how does this compare to stands that are not subjected to salvage logging 

and the subsequent pulse of highly flammable tops, limbs, and relatively fine woody fuels 

associated with salvage logging.

368-46

when salvage logging occurs a "pulse input of surface fuels resulting from salvage 

logging...may increase susceptibility to severe reburns in the early stages of forest 

development." (Spies, 2007)

368-55

post-fire logging can often lead to increased fire and fuel risks, creating higher fire severity in 

future fire events. Post-fire logging tends to increase fine fuels through the creation of 

logging slash, by altering forest succession, and hampering natural recovery.

368-144

The analysis of fuel reduction benefits in the DEIS is predicated on slash removal. If slash 

can not be removed in two years, a FEIS should re-analyze the fuel reduction and fire risk 

reduction benefits to reflect the increased fuel risk every year that slash remains in post-fire 

logging units. The scale of slash buildup in effected stands will drastically increase fire risks 

and the potential for a severe re-burn. If the flush of fine fuel/activity slash generated during 

logging operations cannot be cleanup immediately following the sale due to fiscal constraints, 

then the sale should be scaled back to compensate. To do otherwise is irresponsible and will 

put the community of Horse Creek at elevated risk in future fires.

519-47

Post-fire logging creates enormous quantities of highly flammable activity-created fuel 

("slash"). Duncan (2002) reported that woody fuels on the ground surface increased 1.2 to 5.3 

tons per acre after post-fire logging. Donato and others (2006) compared fire hazard in the 

Siskiyou National Forest of Oregon burned by wildfires in 1987 and 2002, and concluded that 

post-fire logging significantly increased the likelihood of high severity "reburn" compared to 

sites that were left to naturally recover without management due to the density and volume of 

fine woody fuels created by post-fire logging activities. Thompson and others (2007) reported 

similar results.

519-48

Please answer the following questions: Does the Forest Service believe that logging will 

create worse fuel conditions in the short term? Does "site preparation," which includes the 

treatment of slash, act as a mitigation against the increased fuel loading caused by logging? 

What would occur if the Forest Service logged but did not treat post-logging slash?

Comment Response #14: Fuel loads after project implementation

Concern statement:
17

There is a concern that not enough of the project area is proposed for fuels treatment such that 

the risk of future wildfire will still be present after the project is completed, especially if less area 

is treated than is currently proposed.

Forest Service Response:

The DEIS and the Fire and Fuels Report demonstrate that all of the analyzed action alternatives 

substantially reduce the potential for extreme fire behavior and associated potential for severe 

burn effects in the future (Fuels Report Tables 24 through 32 on pages 29, 30, and 31). Not all 

areas that can exhibit future high fire behavior potential are proposed for treatment. This would 

be impractical and would not balance potential negative effects to other resources (wildlife, soils, 

hydrology, etc.). The fuels treatment design for the action alternatives focuses on strategic 

locations (i.e. roads, ridge tops, natural barriers, and the Wildland Urban Interface) to increase 

future fire management actions, fire resiliency, and public and forest use safety (Fire and Fuels 

Report, page 21 and Chapter 2 of the FEIS). These strategic locations are in areas likely to be 

used by future fire suppression activities as well as control lines for future prescribed fire 

projects. The Fire and Fuels Report (page 26) also states that "it will be desired to introduce 

prescribed fire, to maintain low fuel loading and fire behavior conditions, in the project area once 

conditions are ripe to do so in the future." Such future projects could also maintain desired 

conditions of reducing the risk of future wildfire.

Associated Comments:

Comment 

# Comments

2-15

Fruit Growers has plans to remove dead trees along roads and treat fuels in areas that will tie 

into your proposed units. Any areas that get dropped from the project adjacent to our lands 

will result in a higher fire risk to our lands in the future and render our fuel treatments less 

effective.

7-7

The salvage treatments account of 5% of the burned areas. It is a public travesty not to treat 

95% of an area that suffered a catastrophic event on the Klamath National Forest. The 

untreated areas will burn again. Additional green forests will be consumed in the next 

catastrophic event as the untreated fuels accumulate and once again burst into flames.

Comment Response #15: Characteristic nature of the Gap Fire

Concern statement:

There is disagreement regarding whether the Gap Fire was in fact uncharacteristic for the high 

elevation areas of the Siskiyou Crest, Upper Buckhorn and Middle Creek watersheds, and for the 

red fir, white fir, and mountain hemlock forests that are located in these areas. There is a concern 

that if the fire was characteristic according to the fire regimes of this area that treatment is 

unjustified and unnecessary.

Forest Service Response:

We agree that historically, much of the area within the Siskiyou Crest burned at with mixed 

severity, and did so in the Gap Fire. “Mixed severity,” however, is a very broad description. Just 

because an area burned within a wide band of conditions does not mean the current conditions 

are aligned with the desired conditions in the Klamath Forest Plan. By not treating some of these 

locations, the project would meet neither the purpose and need for public and forest user safety, 
18

nor the Land and Resource Management Plan objectives for these land allocations. These areas 

are matrix lands that are managed to have a sustained flow of forest products. Part of the desired 

condition described for these areas in the Klamath Forest Plan is a fire-resilient coniferous forest 

(FEIS pages 13-16). The Klamath Forest Plan also notes that salvage logging is appropriate to 

recover volume in fire-killed trees in these regulated matrix land allocations (FEIS pages 8, 15-

16). Salvage logging and treatment of activity fuels followed by variable density reforestation 

with the appropriate species will reduce the probability of future high severity fire and accelerate 

the development of a fire-resilient coniferous forest (FEIS pages 216-220).

One commenter suggests that the analyzed action alternatives do not take into account the fact 

that the stands located near the Siskiyou Crest have a natural history of mixed-severity fire that 

differs from the historical fire regime of lower elevation forests within the project area. The KNF 

acknowledges that the historical fire regime is different on the Siskiyou Crest than at lower 

elevations. Forests on the Siskiyou Crest have still been heavily influenced by fire suppression 

since European settlement, and forests there have been shown to be uncharacteristically dense, 

and deprived of natural mixed-severity fire. Forests on the Siskiyou Crest have had a 

substantially elevated risk of burning in large-sized fires with a greater probability of severe fire 

effects than would be expected in a pre-settlement condition influenced by an unaltered fire 

regime. “The Horse Creek Ecosystem Analysis identified that under conditions extant in 2000, 

the area “will burn with more intensity and higher severity than any vegetative condition that has 

existed in this area in documented history...This analysis area has a higher fire risk than any 

other analysis area on the Forest. Even with active fire suppression efforts, there is a high 

likelihood that much of the analysis area will be involved in large scale wildfire events in the 

near future” (Horse Heli FEIS, page 37). The fire regime of the area, however, does not negate 

the purpose and need of the project or the Forest Plan standards and guidelines that informed it. 

Associated Comments:

Comment 

# Comments

368-5

The KNF cannot continue credibly claiming to be restoring the role of fire while at the same 

time logging fires that burn within the range of variability. The KNF can not continue to 

claim to be reducing fuels while filling the landscape with untreated logging slash and 

explosive even aged, plantation-like stands of young conifers.

368-11

The Gap Fire burned in a characteristic mosaic that is well within the range of variability. The 

Gap Fire itself was far from catastrophic and provided great benefit to the habitats in which it 

burned. The fire burned in a characteristic mosaic at 67% low severity, 26% moderate 

severity and 7% high soil burn severity.

368-24

Although the patch size is relatively large in a few locations, when considered in context of 

the entire fire area, the levels of fire severity were characteristic. They do not represent a 

novel condition outside the range of variability for mixed conifer forests in the KlamathSiskiyou Mountains.

368-85

The Fire Regime and Stand Development Patterns for High Elevation Forests on the Siskiyou 

Crest area are adapted to mixed severity fire. The DEIS provided no scientific evidence 

documenting a need for post-fire logging in high elevation forest habitats adjacent to the 

Siskiyou Crest. The actual ecology and fire regime of a site must be taken into account when 

planning land management activities. The DEIS failed to differential between high and low 

elevation forest habitats, both of which are proposed for salvage logging despite having very 
19

Comment 

# Comments

different natural histories and natural fire regimes. This failure constitutes inadequate analysis 

in the DEIS.

368-86

The high elevation red fir, white fir and mountain hemlock forests are adapted to mixed 

severity fire affects, with highly variable fire free periods. These forests are poorly adapted to 

fire in terms of fire resistance, they generally have thin bark and low canopies, the variability 

in fire regime also allows stands to grow dense and build heavy fuel loads between natural 

fire cycles leading to mixed severity fire affects. In extreme fire conditions many of these 

stands can burn with intensity, but often fire starts are moderated by the cool/moist high 

mountain conditions, further contributing to the variable fire return interval. The fire affects 

associated with the Gap Fire in these high mountain forests were well within the range of 

variability and demonstrate the ability of wildland fire to restore/rejuvenate healthy habitat 

conditions. The snag patches created by the Gap Fire do not represent novel or 

uncharacteristic conditions in need of treatment. In fact, the structural and age class diversity 

created in the Gap Fire in Upper Buckhorn and Middle Creek represents characteristic and 

intact old-growth conditions. These stands are not dominated by high severity effects and 

were restored/rejuvenated by the Gap Fire. The Gap Fire had only positive effects in high 

elevation forest types.

368-87 If fire affects for a given fire or a given area within a fire burns at characteristic fire severity 

levels no treatment is justified or necessary.

368-88

All fire affects in the Upper Buckhorn and Middle Creek watersheds, were beneficial, the 

proposed post fire logging will negate many of these benefits while creating unnecessary and 

unjustified impacts. The Gap Fire BAER Report documented only low and moderate soil 

burn severity, no high severity effects were mapped in Upper Buckhorn and Middle Creek. 

Although small patches of forest were subjected to stand replacing affects, soil burn severities 

were only low or moderate. The small patches of snag forest found within this forested area 

do not constitute uncharacteristic affects nor do they create excessive fuel hazards.

368-92

Replanting in snag forests of relatively small "patch size" will negatively impact fuel loading, 

vegetative recovery and late seral forest recovery. The plant communities affected and the 

habitat present were only enhanced and the forests natural fire regime restored in the Gap 

Fire.

368-93

Post-fire logging is not intended to be implemented in areas of characteristic fire severity and 

is being misapplied in the Upper Buckhorn and Middle Creek watershed and throughout the 

Gap Fire.

368-94

The KNF has not proven that uncharacteristic disturbance has affected these watersheds. 

Such documentation is required by NEPA if the KNF intends to move forward with post-fire 

logging in high elevation forest types. This was not adequately analyzed in the DEIS. If 

current conditions do not represent uncharacteristic conditions, then the need for immediate 

treatment is unfounded.

Comment Response #17: Susceptibility of plantation stands to fire

Concern statement:

There is a concern that the salvage harvest with site preparation and planting treatment will 

establish a plantation forest structure in units treated. This is a concern for commenters as 

research and previous fires on the Klamath National Forest have demonstrated that plantation 
20

stands, including those created as part of salvage harvest, burn and reburn at a high severity 

which is uncharacteristic.

Forest Service Response:

We agree that plantations can burn at high severity, especially when site preparation fuels 

treatments do not occur. This would not be the case for the Horse Creek Project, which proposes 

site preparation following salvage harvest and prior to planting. The majority of plantations 

within the Gap Fire footprint burned at low severity during the fire; most of these plantations had

obtained site preparation and maintenance prior to the Gap Fire. In addition, the majority of the 

plantations burned by the Westside Fires of 2014 also burned with low severity. As noted in the 

Fire and Fuels Report, page 23; "Weatherspoon and Skinner 1995 and Peterson et al. 2009 both 

found that fire intensity and damage to the overstory are much lower in plantations where slash 

has been removed following logging. A high percentage of plantations in the Gap Fire burned at 

low severity." The Horse Creek Project proposes site preparation treatments following logging, 

increasing the likelihood that the plantations will burn at low severity fire and will burn less 

severely compared to the same areas under the no action alternative.

Associated Comments:

Comment 

# Comments

368-47

At the Gap Fire After Action Review, Terry Silverstro for the Fruit Growers Supply 

Company stated that 58% of plantation stands 1-10 years old were lost due to fire, 79% of 

plantations between 11-20 years old were lost, 33% of plantations between 21-30 years old 

and 31% of plantations over 30 years old were lost. These plantation stands were affected 

with high severity fire at much higher percentages than the remaining portions of the fire. 

This means that the very nature of plantation/even-aged management as proposed by both 

FGS and the KNF following the Gap Fire will increase fire severity.

368-48 once unmanaged stands were mixed with a patchwork of plantation stands "the potential 

exists for a self reinforcing cycle of catastrophic fires." (Perry, 1995 b)

368-51

Donato (2008) who determined that residual dead wood does not influence reburn potential as 

significantly as does the structure of regenerating forest. Thus, even salvage logging with 

slash disposal disturbs natural recovery, creating dense plantation stands where fuel 

connectivity and fire severities are unnaturally high.

368-52

In the KNF, research into the 1987 fires showed that "plantations were uniformly destroyed 

with few exceptions...the vast majority suffered complete mortality." (USDA FS, 1988) This 

quote is taken from the FEIS of the KNF LRMP, created to inform and define management 

direction for the KNF.

368-53

Examination of the spatial pattern created by the 1987 KNF fires showed that tree plantations 

had twice as much crown fire as unmanaged stands. (Odion) To further support these 

findings, analysis of the 1994 Dillion Fire on the KNF found plantations burned with more 

severity than unlogged stands. Plantations also created conditions that encouraged adjacent 

unlogged stands to burn with high severity and possibly encourage fire spread into areas that 

may not have otherwise burned. (Key, 2000)

368-54

"reforestation goals should avoid establishing dense, uncharacteristic, "fully stocked" forests, 

thereby perpetuating the potential for uncharacteristic fire." (Franklin, 2009 P.68) 

Weatherspoon and Skinner came to similar conclusions in their study of the 1987 Hayfork 

Fires. (Weatherspoon/ Skinner, 1995)
21

Comment 

# Comments

368-56 Tree planting creates simplified plantation stands with excessive fuel loads and fuel 

connectivity, encouraging high severity fire effects.

368-60 The potential for high severity re burns in plantation stands are high, effecting recovery and 

forest succession, especially of late successional habitats.

368-71

clearcut/plantation style logging that is typically practiced by the KNF following fire and 

proposed in this project, will drastically increase future fire risks and encourage dangerous 

fire behavior by creating unbroken swaths of even aged conifer plantation.

368-74

Salvage logging will not address this safety concern and may make the risk of burnover more 

acute by creating increased fuel risks through salvage logging, tree planting and even aged 

plantation management.

368-76 Tree planting also creates even aged plantation-like stands that facilitate rapid fire spread and 

high severity impacts.

516-19

As stated on page 52 of the DEIS, the Karuk Tribe Alternative "holds that the pulse input of 

surface fuels resulting from salvage-logging followed by the establishment of uniform young 

plantations may increase susceptibility to severe reburns in the early stages of forest 

development." Yet the KNF appears set on conducting such activities regardless of how they 

undermine the alleged purpose and need for the project and without responding to or refuting 

the literature referenced by the Tribe.

942-2 we know through experience that replanting with more flammable tree plantations is not 

ecologically a win win situation.

Comment Response #19: Green trees removal for operations

Concern statement:

There is a concern regarding the removal of live trees to facilitate roadside logging, and salvage 

harvest proposed in the project.

Forest Service Response:

A "green" tree is defined as any tree with less than a 70 percent chance of mortality using criteria 

in Report #RO-11-01 "Marking Guidelines for Fire-Injured Trees in California" (Smith and 

Cluck 2011). (FEIS page 18). Trees with greater than 70 percent chance of mortality using these 

criteria would be cut in roadside hazard units and salvage units. All "green" (those trees with less 

than a 70 percent chance of dying as a result of damage from the Gap Fire) trees that meet this 

criteria will be retained within roadside hazard and logging operations, the only exceptions are 

green trees that pose a hazard to roadways as described in the hazard tree treatment section of 

Chapter 2 of the FEIS or the occasional green tree that needs to be removed for cable harvesting 

or landings. See Chapter 2 of the FEIS for details regarding the proposal.

Associated Comments:

Comment 

# Comments

516-49

We note that the proposed salvage logging is in no way limited to dead trees. While the 

agency is silent as to the number of live green trees to be removed (as opposed to felled) in 

roadside logging and to facilitate yarding and landing activities, the DEIS does indicate that 

the Forest Service intends to log trees that are in fact still alive.
22

Comment Response #20: Tree mortality guidelines

Concern statement:

There is a disagreement regarding the guidelines used in the Horse Creek project for judging the 

degree of tree mortality which determines how trees are marked for removal.

Forest Service Response:

The fire-injured tree marking guidelines for the Horse Creek Project are based on published 

models from the Hood et al. 2010 study (Hood, Sharon M.; Smith, Sheri L.; Cluck, Daniel R. 

2010. Predicting mortality for five California conifers following a wildfire. Forest Ecology and 

Management. 260: 750-762). These well established guidelines are based on the best available 

science documenting post-fire conifer mortality in California and their use has contributed to the 

success of many post-fire salvage and restoration projects. These models were developed after 

monitoring fire-injured trees for 5 post-fire years. Ponderosa pines were assessed for both the 

level of crown scorch and the level of crown kill, accounting for any post-fire flushing that 

occurred. From the crown scorch data, the pre-bud break (pre-needle flush) guideline for 

ponderosa pine was developed. This guideline is appropriate for marking trees after the fire and 

before bud break/needle flush the following growing season. The pre-bud break model exhibited 

a similar high degree of accuracy as the post-bud break (post-needle flush) model from the same 

study. Some post-fire flushing of individual ponderosa pine may occur throughout the project 

area at the onset of bud break by the end of June 2017. Even if pines that were marked before 

bud break flush, there is a high probability that they will ultimately die based on the high 

probability of mortality level guideline selected for this project. Data from the Hood et al. 2010 

study revealed that 84% of all yellow pines less than30" diameter breast height with greater than

90% crown length scorched died within 5 years regardless of post-fire flushing (n=1069). The 

data also revealed that 95% of all ponderosa pines between 30" and 40" diameter breast height

with greater than 60% crown length scorched died within 5 years regardless of post-fire flushing 

(n=362). All pines marked after bud break will include post-fire flushing as part of the marking 

criteria. The potential for epicormic branching from the boles of fire-injured white fir is well 

known, especially on trees that remain green for 2-3 post-fire years. However, on trees with 

higher levels of crown kill, the small amount of crown biomass that might be contributed by 

epicormic branching is not likely to contribute to long-term tree survival. For example, in the 

Hood et al. 2010 study, 90% of white fir less than 35" diameter breast height with greater than

80% crown length killed (n=787) and 94% of white fir greater than35" diameter breast height

with greater than 70% crown length killed (n=154) died within 5 years. Any effects of epicormic 

branching on white fir survival would have been accounted for by the fact that if a study tree still 

had any green foliage (which would include epicormic branching) after 5 years, it would have 

been recorded as alive for the purpose of data analysis and model development. The same is true 

for any effects of flushing on red fir survival. In the study, the mortality of red fir with greater 

than 80% crown length killed was 67% (n=9). Tree diameter was not a significant variable in the 

red fir model.

Associated Comments:

Comment 

# Comments

516-51 The proposal to log live trees raises the controversial issue of mortality models and marking 

guidelines for designating "dying" trees. There is an extensive scientific literature on the 
23

Comment 

# Comments

delayed mortality of fire-damaged conifers on forests of the western United States. (e.g. Martin 

1963, Bevins 1980, Ryan 1982, 1983, 1998, Peterson 1985, Peterson and Arbaugh 1986, 

Wyant et al. 1986, Chambers, et al. 1986, Harrington 1987, 1993, Ryan et al. 1988, Ryan and 

Reinhardt 1988, Ryan and Frandsen 1991, Regelbrugge and Conard 1993, Mutch and Parsons 

1998, Saveland and Neuenschander 1990, Flanagan 2001, Borcher and Schreiner 2002, 

Stephens and Finney 2002, McHugh and Kolb 2003, Thies et al. 2006, Hood and Bentz 2007, 

Michaletz and Johnson 2007). While none of these studies are acknowledged or addressed in 

the Horse Creek DEIS, it is clear that the translation of this science into marking guidelines for 

salvage logging has been and is still the subject of considerable scientific controversy.

516-53

Attached to these comments is a 2009 peer-reviewed article (Hanson and North 2009) 

indicating that the Forest Service Region 5 mortality guidelines may significantly overestimate 

tree mortality to the detriment of ecosystem functions (including flushing) and post-fire 

recovery. The abstract for that study concludes: With growing debate over the impacts of 

post-fire salvage logging in conifer forests of the western USA, managers need accurate 

assessments of tree survival when significant proportions of the crown have been scorched. 

The accuracy of fire severity measurements will be affected if trees that initially appear to be 

fire-killed prove to be viable after longer observation. Our goal was to quantify the extent to 

which three common Sierra Nevada conifer species may 'flush' (produce new foliage in the 

year following a fire from scorched portions of the crown) and survive after fire, and to 

identify tree or burn characteristics associated with survival. We found that, among ponderosa 

pines and Jeffery pines with 100% initial crown scorch (no green foliage following the fire), 

the majority of trees flushed, and survived. Red fir with high crown scorch (mean=90%) also 

flushed, and most large trees survived. Our results indicate that, if flushing is not taken into 

account, fire severity assessments will tend to overestimate mortality and post-fire salvage 

could remove many large trees that appear dead but are not. Additionally, following the recent 

Rim Fire in Region 5, the Forest Service elected to retain all live trees exhibiting green needles 

in order to contribute to post-fire recovery. Please 

see: http://www.fs.usda.gov/wps/portal/fsinternet/!ut/p/c5/04_SB8K8xLLM9MSSzPy8xBz9C 

P0os3gDfxMDT8MwRydLA1cj72BTUwMTAwgAykeaxRtBeY4WBv4eHmFYT4GMHkidBvgAI6EdIeDXIvfdrAJuM3388jPTdUvyA2NMMgyUQQAyrgQmg!!/dl3/ 

d3/L2dJQSEvUUt3QS9ZQnZ3LzZfS000MjZOMDcxT1RVODBJN0o2MTJQRDMwO 

DQ!/?project=43033 While the Forest Service URL above may be confusing and byzantine, 

the direction of the Stanislaus National Forest was crystal clear: Do Not "Salvage" Log Living 

Green Trees.

Comment Response #21: Use of prescribed fire

Concern statement:

There is a suggestion that prescribed fire could, or should, be used alongside, or instead of, 

proposed treatments in the project.

Forest Service Response:

Prescribed fire is not out of the question. It is just not part of this project. As stated in the Fire 

and Fuels Report, "it will be desired to introduce prescribed fire, to maintain low fuel loading 

and fire behavior conditions, in the project area once conditions are ripe to do so into the future" 

(Fire and Fuels Report, page 26). The fuels treatment design for all action alternatives is built in 

strategic locations to use prescribed fire in the future as a subsequent fuels treatment to the 
24

proposed activities of the Horse Creek Project. At the present time, prescribed fire alone would 

not meet the purpose and need of the project, and since the area just burned, it is not ready to 

introduce prescribed fire. In addition, numerous entries of prescribed fire would have to occur 

over time across the project area to reduce fuels as they begin to fall, which would be impractical 

to analyze in this NEPA document as those actions would be years in the future. Alternative B 

was developed in response to scoping comments regarding this suggestion. This alternative was 

considered but eliminated from detailed study as it did not meet the purpose and need of the 

project. For more information, please refer to the Alternatives Considered but Eliminated from 

Detailed Study section of Chapter 2 of the FEIS.

Associated Comments:

Comment 

# Comments

2-19 Prescribed fire could then follow the mechanical treatments as necessary.

368-45

"heavy logging slash" Fuel Model 13, is the most problematic fuel, with the highest potential 

fire line intensity. Yet, treating this slash in the post fire landscape has become increasingly 

difficult due to the sheer number of acres involved. It has also that treating post fire logging 

slash has been shown to affect plant succession and thus forest regeneration. (Strittholt, 2004 

P. 19) Likewise, treating logging slash in recently burned areas can increase erosion. 

(Strittholt, 2004 P. 26) The creation of slash should simply be avoided by choosing a nonsalvage alternative and utilizing prescribed fire around the community of Horse Creek when 

sufficient fuel is available.

368-75

Cyclical prescribed or wildland fire use will alleviate some of this risk if firefighters can 

benefit from fuel breaks created by recent fires. Prescription fire will significantly reduce fine 

fuels and ground fuels, the very fuels that tend to facilitate rapid fire spread, high severity 

impacts, and high fire line intensity. Salvage logging, on the other hand, focuses on removing 

large diameter fuels that tend to burn slowly and with much less intensity.

Comment Response #22: Travel management

Concern statement:

There is a concern that the Forest Service must consider the Klamath National Forest's travel 

analysis report, identify the minimum road system, minimize road contributions to watershed 

functionality, stormproof existing roads, and identify unneeded roads to prioritize for 

decommissioning or other uses.

Forest Service Response:

This is outside the scope of the proposed action, and is not related to the decision to be made. 

Travel analysis is not included in this project, and no new system roads are proposed for 

construction. Temporary roads are proposed to meet the management objectives. Best 

management practices and project design features will be used to address effects of temporary 

roads. Also, alternative 3 considered and analyzed the effects of removing temporary road 

construction from project activities.

Associated Comments:
25

Comment 

# Comments

516-89

Additionally the terrestrial and aquatic impacts of the existing transportation system will be 

amplified by roadside logging of duplicative dead-end roads to nowhere. As acknowledged 

on page 132 of the DEIS: Roads are the major contributor to excessive sedimentation to 

streams and impacts to watershed function in the Horse Creek watershed. Road density is 

high in the Horse Creek 6th Field watershed...Much of the road system in lower Horse Creek 

and throughout the Horse Creek watershed was constructed on dormant landslide deposits 

that are highly susceptible to chronic and acute surface erosion and mass wasting... Please 

note that that the Klamath Forest Plan requires that "Project-level planning should review the 

opportunities available to improve or maintain aquatic habitat. Through the interdisciplinary 

process, the cause of the problem should be identified and treated as well as the effects." 

ROD 4-33, emphasis in the original. Here the Forest Service has decided to simply ignore the 

cause of water quality problems, namely the existing transportation system- while also 

proposing to increase the negative impacts associated with its network of logging roads. WR3 of the Northwest Forest Plan prohibits this type of shell game. "Do not use mitigation or 

planned restoration as a substitute for preventing habitat degradation."

589-4

1. We support the Forest Service's efforts to create a resilient future road system. Identifying 

a resilient future road system is one of the most important endeavors the Forest Service can 

undertake to restore aquatic systems and wildlife habitat, facilitate adaptation to climate 

change, ensure reliable recreational access, and operate within budgetary constraints. And it 

is a win-win-win approach: (1) it's a win for the Forest Service's budget, closing the gap 

between large maintenance needs and inadequate (and possibly declining) funding through 

congressional appropriations; (2) it's a win for wildlife and natural resources because it 

reduces negative impacts from the forest road system; and (3) it's a win for the public because 

removing unneeded roads from the landscape allows the agency to focus its limited resources 

on the roads we all use, improving public access across the forest and helping ensure roads 

withstand strong storms.

589-5

1. As part of its analysis of the Horse Creek Community Protection and Forest Restoration 

Project under NEPA, the Forest Service must consider the Klamath National Forest's travel 

analysis report, identify the minimum road system, and identify unneeded roads to prioritize 

for decommissioning or other uses. The Forest Service faces many challenges with its 

oversized, under-maintained, and unaffordable road system. The impacts from roads to water, 

fish, wildlife, and ecosystems are tremendous and well documented in scientific literature. 

The Klamath National Forest is no exception, with 4,536 miles of system roads, the required 

maintenance of which exceeds annual maintenance costs. U.S. Dep't of Agric., Forest Serv., 

Klamath Nat'l Forest Motorized Travel Mgmt. FEIS (January 29, 2010). To address its 

unsustainable and deteriorating road system, the Forest Service promulgated the Roads Rule 

(referred to as "subpart A") in 2001. 66 Fed. Reg. 3206 (Jan. 12, 2001); 36 C.F.R. part 212, 

subpart A. Subpart A is meant to close the gap between the agency's limited resources and the 

maintenance required to keep up its oversized and deteriorating road system. It sets out two 

important obligations for the agency: 1. Identify the minimum road system needed for safe 

and efficient travel and for the protection, management, and use of National Forest system

lands; and 2. Identify unneeded roads to prioritize for decommissioning or to be considered 

for other uses. 36 C.F.R. § 212.5(b). We urge the Forest Service to carefully evaluate the 

proposed Horse Creek Community Protection and Forest Restoration Project and each of the 

alternatives through this lens. Direction from the Forest Service's Washington Office required 

all forests to submit travel analysis reports by the end of FY 2015 and then begin 

implementing the recommendations and working towards full compliance with subpart A.[2] 

The Klamath National Forest has failed to make its travel analysis report public, which was 
26

Comment 

# Comments

due to the Forest Service's Washington Office in September 2015. This report must be made 

publicly available so that we are able to fully assess projects like this that involve major road 

components. The next step is even more important under subpart A: Consider the 

recommendations and science-based analysis in the travel analysis report as it applies to the 

project area to identify the minimum road system[3] and identify unneeded roads for 

decommissioning. Given that with this project you are considering changes to a large number 

of miles of roads, and given its large geographic scale, this is precisely the type of project to 

complete the next steps under subpart A.[4] To identify the minimum road system, the 

Forest Service must consider whether each road segment the agency decides to maintain on 

the system is needed to meet certain factors outlined in the agency's own regulation.[5] 

Consider whether each road segment is needed to: 1. Meet resource and other management 

objectives adopted in the relevant land and resource management plan; 2. Meet applicable 

statutory and regulatory requirements; 3. Reflect long-term funding expectations; and 4. 

Ensure that the identified system minimizes adverse environmental impacts associated with 

road construction, reconstruction, decommissioning, and maintenance. 36 C.F.R. § 

212.5(b)(1). In assessing specific road segments, the Forest Service should also consider the 

risks and benefits of each road as analyzed in the travel analysis report, and whether the 

proposed road management measures are consistent with the recommendations from the 

travel analysis report. To the extent that the final decision in this project differs from what is 

recommended in the travel analysis report, the Forest Service must explain that inconsistency. 

See, e.g., Smiley v. Citibank, 517 U.S. 735 (1996) ("Sudden and unexplained change . . . or 

change that does not take account of legitimate reliance on prior interpretation . . . may be 

'arbitrary, capricious [or] an abuse of discretion") (internal citations omitted). Unfortunately, 

without access to the Klamath National Forest's travel analysis report we are unable to 

meaningfully comment on whether this project is consistent with the recommendations from 

that report. Finally, the Forest Service must identify unneeded roads for decommissioning or 

other uses. 36 C.F.R. § 212.5(b)(2).[6] Here, the Forest Service proposes not to close or 

decommission any roads after implementation of the Project and fails to include the necessary 

information regarding upgrades or mileage of road that will be affected. Based on current 

natural resource conditions, assessed risks from the existing road network, road densities 

across the landscape, the agency's limited resources, and long-term funding expectations, at 

least some road decommissioning or closures are warranted. Temporary roads that will be 

accessed for the Project will affect nearby vegetation and further fragment the forest. System 

roads are vulnerable to damage, and landslide events could damage riparian vegetation and 

harm aquatic species such as threatened Coho Salmon. Decommissioning can temporarily 

increase sediment to streams but has dramatic reductions in the long run. The Forest Service's 

Rocky Mountain Research Station has spent over a decade monitoring the effectiveness of 

road treatments. A 2012 report evaluating pre and post treatment of roads showed an 80% 

reduction in sediment delivery to streams when roads were decommissioned.[7] In addition, 

the 20-year monitoring report of the Northwest Forest Plan confirmed that watersheds that 

showed the most improvement in condition were those that completed road 

decommissioning.[8] Decommissioning at least some road miles is consistent with the Forest 

Service's long-standing policy to "manag[e] access within the capability of the land."[9]

589-6

Applicable statutory and regulatory requirements should shape a project's statement of 

purpose and need. When the agency takes an action "pursuant to a specific statute, the 

statutory objectives of the project serve as a guide by which to determine the reasonableness 

of objectives outlined in an EIS." Westlands Water Dist. v. U.S. Dept. of Interior, 376 F.3d 

853, 866 (9th Cir. 2004). Under subpart A of its travel rule, the Forest Service has a 
27

Comment 

# Comments

substantive duty to address its over-sized road system. See 36 C.F.R. § 212.5. This 

underlying substantive duty must inform the scope of, and be included in, the agency's NEPA 

analysis.[10] After more than 15 years since finalizing the subpart A rules, the Forest Service 

can no longer delay in addressing this duty.

589-9

The Forest Service should include it its statement of purpose and need the need to identify the 

minimum road system that will be accessed to remove the hazardous trees and decrease the 

risk of future fires harming local communities. It is imperative that the Forest Service 

complies with its duty to identify the minimum road system and identify unneeded roads that 

should be decommissioned so that the road conditions are accounted for and up to date. As 

noted above, addressing the road system is crucial to establishing a resilient future forest. The 

Forest Service must recognize unnecessary roads that need to be upgraded or repaired to 

abate threats to wildlife and wildlife habitat.

589-19

The Forest Service's current road system in the Project area is over-sized and unaffordable. 

Identifying a sustainable future road system is one of the most important endeavors the Forest 

Service can undertake to restore aquatic systems and wildlife habitat, facilitate adaptation to 

climate change, enhance recreation, lower operating expenses, and ensure a resilient future 

forest.

591-16

The 2002 Horse Creek Ecosystem analysis recommends road stormproofing and 

decommissioning in the Project area. Given the impacts from the Gap Fire and proposed 

project activities, CWE modelling in the draft hydrology specialist report identifies that 

several of the Project watersheds exceed the threshold of concern. However, as stated in the 

passage above, the DEIS does not include any proposals for addressing road stormproofing or 

decommissioning in the Project area.

Comment Response #23: LSR salvage consistency with FEMAT

Concern statement:

There is a concern that the salvage harvest proposed in late successional reserve is contradictory 

to the recommendations of the Forest Ecosystem Management Assessment Team (FEMAT) and 

the Northwest Forest Plan.

Forest Service Response:

In this comment selected phrases from the FEMAT report are cited with the suggestion that those 

citations show the proposed Horse Creek project is inconsistent with the goals and principles of 

LSR management. The commenter however did not include other FEMAT citations that are 

specific to risk reduction and salvage and also did not note that the Forest Plan of the Klamath 

National Forest, not FEMAT, is the source of management direction for projects on the Klamath 

National Forest. While the FEMAT report does not provide management direction and does not 

include recent research specific to the Klamath Province (i.e. Skinner, 2002, Taylor and 

Skinner1998, 2003) or post-salvage fuel treatments (Peterson et al. 2009, Peterson and Harrod, 

2010), it is useful for this discussion to clarify the intent of the FEMAT report and its subsequent 

incorporation into the Northwest Forest Plan. FEMAT considered salvage with three different 

prescriptions, ranging from no salvage, to salvage with minimum guidelines. Prescription 2, 

(FEMAT II-18) limited salvage in LSRs stated "Valuable trees that are dead can be used for 

commercial purposes with the attendant employment and economic benefits. ...Increased fire 

danger or risk to insect and disease resulting from large accumulations of dead trees can be 
28

reduced in an economically feasible fashion. Avoided are the perceptions of economic waste if 

patches of dead trees are not salvaged." Guidelines for salvage in LSRs were developed in the 

FEMAT Report to implement Prescription 2 (FEMAT III-36). These Guidelines were carried 

forward to the Northwest Forest Plan Record of Decision (ROD) Standards and Guidelines (C14) and subsequently to the Forest Plan of the Klamath National Forest (4-87). It is clear that the 

FEMAT report anticipated that salvage would need to be considered and that those Guidelines 

were incorporated into the Forest Plan of the Klamath National Forest. The Secretaries of 

Interior and Agriculture, the decision makers who approved the Northwest Forest Plan noted 

their logic for salvage in LSRs in the Response to Comments in the ROD for the Northwest 

Forest Plan (ROD, Page 66): "Salvage is not required to be beneficial, but is designed to permit 

recovery of a timber volume in those instances where catastrophic events clearly kill more trees 

(resulting in more snags and down logs in the short and long term) than are needed to maintain 

late successional conditions." The National Forest Management Act requires that projects or 

activities be consistent with the management direction of the national forest where the project or 

activity occurs. The Forest Plan is the document that provides guidance for management in this

project. The Forest plan incorporates guidance from the FEMAT report and the Northwest Forest 

Plan, but is more site-specific to the Klamath National Forest. The Forest Plan of the Klamath 

National Forest clearly anticipated that risk reduction salvage may be necessary and provided 

project Guidelines for both risk reduction in LSRs (Forest Plan 4-86; MA5-27 to 29) and for

salvage (Forest Plan 4-87, MA 30-1 to MA 30-11) to ensure that the objectives of the Forest Plan 

were achieved. The Forest Plan of the Klamath National Forest also required completion of an 

LSR Assessment to guide LSR management. The LSR Assessment included the guidelines for 

salvage found in the Forest Plan of the Klamath National Forest. The Horse Creek project is 

consistent with those recommendations and with the Klamath Forest Plan.

Associated Comments:

Comment 

# Comments

516-21

FEMAT directs that: Because of the important role of dead wood in late-successional and 

old-growth forest ecosystems, and because there is much to learn about the role of dead wood 

in development of forests, only limited salvage is appropriate in Late-Successional 

Reserves...The Final Draft Recovery Plan [for the NSO] would allow removal of smalldiameter snags and logs, but would also require retention of snags and logs likely to persist 

until the new stand begins to contribute significant quantities of coarse woody debris." 

(FEMAT 1993, p IV-37) In the Horse Creek Logging Project the Forest Service has taken 

the exact opposite approach recommended by the NWFP. The agency is proposing extensive 

(rather than limited) salvage logging throughout the Reserves and is proposing to remove 

large diameter snags from logging units while leaving the least valuable (for wildlife and 

mills) small diameter snags in the units.

Comment Response #25: Use, construction, and reconstruction of roads

Concern statement:

There is a concern regarding the long term impacts of use, construction, and reconstruction of 

logging roads on ecosystem health and watershed quality.

Forest Service Response:
29

Temporary roads are proposed in Alternatives 2 and 4 to meet the management objectives of the 

project. Best management practices and Project Design Features will be implemented with any 

project action alternative to direct placement of and aid in successful closure and rehabilitation of 

temporary roads (see Chapter 2 of the FEIS, PDF Geology 1, 4, Watershed 11, 12, 24, and 

Fisheries 2, and Appendix C - Best Management Practices). Effects to resources as a result of 

including temporary road construction and reconstruction (new and existing roadbeds) is detailed 

in the analysis provided in Chapter 3 of the FEIS and in supporting resource reports, such as the 

Hydrology report. In response to scoping comments regarding this issue, Alternative 3 was 

developed to consider and analyze the effects of removing temporary road construction from 

proposed project activities. This resulted in the removing of 13 units from the proposed action 

alternative where it would be infeasible to implement treatments without the construction of 

temporary roads (new and existing roadbeds). However, according to the Hydrology section of 

Chapter 3 of the FEIS (Comparison of Alternatives), all of the action alternatives (with or 

without temporary roads) would have similar effects to hydrology-related resources compared to 

no action (Alternative 1). Furthermore, the Geology section of Chapter 3 of the FEIS concludes 

that in light of the relatively small differences in model outputs for the alternatives (with or 

without temporary roads), a different way of comparing the alternatives is to simply look at the 

amount of activities with the highest potential for triggering landslides. Those alternatives 

incorporating the most new and existing roads and landings would have the highest potential for 

initiating landslides, and those with the fewest would have the lowest potential. We looked at the 

photos of the existing roadbed of the 47N90 road referenced in comment 593-6. Although we 

could not tell exactly were the photos were taken, we assume the roadbed may be used in the 

Horse Creek Project. Any temporary road or existing roadbed used in the project will be "put to 

bed" and be hydrologically stable when the project is completed (FEIS page 190; BMP 6, page

355). These effects are disclosed in the FEIS and supporting Resource Reports included in the 

project record available on the project website and will be considered by the Responsible Official 

in arriving at a decision.

Associated Comments:

Comment 

# Comments

368-2 We also oppose new temporary or permanent road construction.

501-3 Punching new logging roads into headwaters of the south side of the Siskiyou Crest does, will 

cause further landslides and other issues in the future.

515-6

We oppose all temporary or permanent road construction. Road construction has major 

impacts to botanical values, bulldozing and altering native plant habitat, while facilitating the 

introduction of invasive plant species such as yellow starthistle. Roads also have impacts to 

hydrology and sedimentation, which in turn can affect native plant communities. Salmon and 

steelhead and other important fisheries need intact native plant communities in order to 

thrive. With degraded plant habitat and altered hydrology, roads will have detrimental 

impacts to native fisheries.

516-88

The Forest Service is proposing significantly increasing the Equivalent Roaded Area (ERA) 

through road construction, landing construction and skid trail establishment despite the clear 

recommendation of the Watershed Analysis to reduce road density.

589-12

The best available science shows that roads cause significant adverse impacts to National 

Forest resources. See, e.g., 66 Fed. Reg. at 3208 ("Scientific evidence compiled to date 

[2001] suggests that roads are a significant source of erosion and sedimentation and are, in 
30

Comment 

# Comments

part, responsible for a decline in the quality of fish and wildlife habitat."). A 2014 literature 

review from The Wilderness Society surveys the extensive and best available scientific 

literature—including the Forest Service's General Technical Report synthesizing the scientific 

information on forest roads (Gucinski 2001)—on a wide range of road-related impacts to 

ecosystem processes and integrity on National Forest lands.[11] Erosion, compaction, and 

other alterations in forest geomorphology and hydrology associated with roads seriously 

impair water quality and aquatic species viability. Roads disturb and fragment wildlife 

habitat, altering species distribution, interfering with critical life functions such as feeding, 

breeding, and nesting, and resulting in loss of biodiversity. Roads facilitate increased human 

intrusion into sensitive areas, resulting in poaching of rare plants and animals, human-ignited 

wildfires, introduction of exotic species, and damage to archaeological resources.

593-6

The project says it will create temporary roads on existing roadbeds. The quality of the 

existing roadbed varied in the project. Near the entrance to the unit, off Forest Service Road 

47N90, the existing roadbed was well established. Off the northeastern "spur" near the 

northern end of the unit, the roadbed quality deteriorated the further from the main stem, with 

brush and small trees growing in the existing roadbed. Towards the southern end of the 

"main" road, before it turns to head back uphill in a northeasterly direction, the roadbed was 

improperly graded and acts as a stream. There was significant channeling. Any new 

temporary road needs to be constructed to avoid a similar future fate, perhaps through water 

bars and other engineering features.

Comment Response #26: Salvage and late successional forest 

development

Concern statement:

There is a concern that salvage harvest actions proposed are inconsistent with the development of 

late successional forest characteristics, and that adequate justification and current science has not 

been provided for salvage harvest in an LSR.

Forest Service Response:

All of the salvage harvest proposed in the LSR in the Horse Creek project is intended to reduce 

the risk of future high severity fire particularly adjacent to, or near private property, and to 

accelerate the reestablishment of coniferous forests. See the response to Concern #3, which also 

addresses fire cycles in the Klamath Province and #23, which addresses consideration of salvage 

in FEMAT and Forest Plans. The Forest Plan of the Klamath National Forest clearly anticipated 

that risk reduction salvage may be necessary in the late successional reserve land allocation, and 

provided project guidelines (Forest Plan page 4-86; MA5-27 to 29) to ensure that the objectives 

of the Forest Plan were achieved. The Forest Plan also provides general guidelines for salvage in 

late successional reserves when it is not specific to risk reduction (MA5-30-1 to MA5-30-11). 

These general salvage guidelines were considered in project design, however, the Forest Plan 

allows for some salvage operations that do not meet guidelines MA5-30 1 through 4 when the 

salvage is essential to reduce the risk of future risk of fire (MA5-30-5), as is the case in the Horse 

Creek Project. There is no question that salvage in the LSR land allocation is permitted by 

Klamath Forest Plan. Recreating late successional forests after a high severity fire depends on 

preventing future high severity reburns for at least 80-100 years after a coniferous forest has 

been reestablished. The only practical way to do that is to reduce the continuity and density of 
31

fuels so that the severity of future reburns is reduced. The purpose of risk-reduction salvage in 

the Horse Creek Project is to reduce the risk of future high severity fire (FEIS page 13) by 

reducing fuels. In the Klamath Province, areas that burn with high severity tend to reburn with 

high severity (Coppoletta et al. 2016; Odion et. al. 2004; Skinner et al. 2006; Thompson et al. 

2007). Coppoletta et al. (2016) found that "high to moderate-severity fire in the initial fires led to 

an increase in standing snags and shrub vegetation, which in combination with severe fire 

weather promoted high-severity fire effects in the subsequent reburn." Said another way, high 

severity fire creates a positive feedback loop for more high severity fire (Thompson et al. 2007). 

(See Fire and Fuels report for a complete discussion.) Hessburg et al. (2016; See Fire and Fuels 

report) documented this reburn site conversion pattern resulting from high severity fire: "...with 

a warming climate creating conditions for more high-severity fire (Westerling et al., 2003; 

Lenihan et al., 2006), and the occurrence of larger and more frequent high-severity burned areas 

(Miller et al., 2009, 2012; Harris and Taylor, 2015), there is now a greater potential for severely 

burned patches to be converted to these alternative stable states (Lauvaux et al., 2016; Long et 

al., 2014a; Harris and Taylor, 2015; Perry et al., 2011; Savage and Mast, 2005). Typically this 

occurs where successive fires occur over the same area, especially when the initial fire burns 

with high severity effects and causes a transition to a grass or shrub-dominated community (van 

Wagtendonk et al., 2012). Documented examples are widespread in the Siskiyou Mountains 

(Silver Fire of 1987 followed by the Biscuit Fire of 2003), the Klamath Mountains (King-Titus 

Fire of 1987 followed by the Panther Fire of 2008), the northern Sierra Nevada/southern Cascade 

Range (Storrie Fire of 2000 followed by the Chips Fire of 2012 - see Coppoletta et al. (in press)), 

and in the central Sierra Nevada (Stanislaus Complex of 1987 followed by the Rim Fire of 

2013)." Continuity and density of fuels need to be reduced if the future extent of high severity 

fire is to be reduced (Thompson et al. 2007; Peterson et al. 2015). That is the primary objective 

of salvage harvest in the LSR in the Horse Creek project. The FEIS is replete with site-specific 

evidence that fuel treatments would be effective and would accomplish the fuel reduction 

objectives in the Klamath Forest Plan so that future high intensity / severity fires are reduced. 

Tables 45 through 47 (FEIS pages 131-132) clearly display the contrasts between no action, and 

the action alternatives. Within treatment areas (Table 46, page 131), the potential for high 

intensity fire (flame lengths greater than eight feet) drops by 89 percent from 3,145 acres to 350 

acres. Figures 7 and 8 (FEIS page 132-133) clearly show the effects of salvage logging followed 

by treatment of activity fuels. Twenty years out, a period within the fire return interval of the 

Klamath, surface fuels greater than three inches in diameter drop from 123 tons/acre in untreated 

areas to 11 tons per acre - a reduction of over 90 percent - in areas that have been salvage logged 

with follow-up disposal of activity fuels. These outcomes are consistent with the Klamath Forest 

Plan goal (FEIS page 13) to reduce fuel buildups that could contribute to high intensity fire. 

These findings are also consistent with recent research cited in the FEIS and in the Fire and Fuels 

report. Post-logging fuel treatments, such as piling and burning or broadcast burning (jackpot 

burning), can rapidly reduce total amounts and spatial continuity of surface woody fuels, and 

may allow logged stands to serve as fuel-breaks in a landscape-level fire management strategy 

(Peterson & Harrod, 2010). In addition, Peterson, Dodson, and Harrod 2014 found that post-fire 

logging altered post-fire fuel succession by (1) greatly accelerating the deposition of surface 

woody fuels from logged snags, (2) reducing peak loading of large diameter woody fuels, and (3) 

initiating the woody fuel decay earlier (Fire and Fuels Report; FEIS page 124-125) Ritchie, 

Knapp and Skinner (2012), evaluated salvaged units following the Cone Fire on the Lassen 

National Forest. They found that after four years higher levels of surface fuel accumulations 
32

occurred in lower intensity salvage plots. The highest surface fuel accumulations occurred in unsalvaged plots four to eight years after the fire. Furthermore, the highest levels of large woody 

debris were associated with un-salvaged areas. Ritchie et al. (2012) observed that areas that were 

salvaged to remove heavy fuels had lower fuel loading after eight years than areas that were 

unsalvaged. Activity fuel treatment following salvage harvest would reduce fuel loading even 

further within salvage units." (Fire and Fuels Report, Pg. 22). Dunn and Bailey (2014) also found 

that salvage logging significantly reduces coarse woody fuel loadings after approximately seven

years, which likely reduces re-burn hazard for several decades depending on available 1000-hour 

fuel loadings (Dunn and Bailey, 2015). See FEIS Fire and Fuels Report. Reforestation, as 

described in the Silviculture chapter of the FEIS would follow treatment of activity fuels. Note 

that the planting prescription would not create dense, fire-prone plantations. Without 

reforestation it may take decades to reestablish a coniferous forest in the larger patches of high 

severity fire where seed sources are sparse. The No Action alternative is responsive to this group 

of comments. The most likely outcome of No Action is perpetuation of the cycle of high severity 

fire and the conversion of forests to semi-permanent brushfields (FEIS page 110-123, 215). This 

means that the private property in Horse Creek would likely be threatened again by high severity 

fire in the future as fire-killed trees on national forest lands break and fall to the ground and 

become surface fuels. The best hope to reduce the risk of future high severity fire and reestablish 

a fire resilient coniferous forest is to reduce the heavy fuels by salvage logging, treat the light 

activity fuels (slash) by burning, and then plant the site to a variable density with appropriate 

fire-adapted species. Finally, there are other reasons to consider salvage harvest besides reducing 

the risk of future high severity fire such as public safety, safety for firefighters and conservation 

of biodiversity (Thompson et al. 2007). Public and firefighter safety are part of the Purpose and 

Need for the Horse Creek Project (FEIS page 14). 

Associated Comments:

Comment 

# Comments

368-21

It is our contention that post fire logging within these areas is counterproductive and fails to 

meet the goals to "protect and enhance conditions of late-successional and old growth forest 

ecosystems." Thus far the KNF has not identified how salvage activities would benefit late 

successional habitats or encourage their development. Justification for salvage logging in 

LSR habitat has not been provided, nor has valid scientific data been used to support the 

claims that salvage logging will facilitate late successional forest development, adequate 

regeneration, or the reduction of fuels. The claims are instead ideologically and economically 

driven and thus inappropriate in LSR forest.

368-34

Scientists and agency management plans agree that post fire salvage logging is generally 

inconsistent with the development of late successional habitat and biodiversity. There is also 

general consensus that the process and mosaic of fire is very important in maintaining and 

encouraging late successional forest habitat, biodiversity, forest resiliency, and heterogeneity.

Comment Response #27: Should not salvage LSR or Siskiyou Crest

Concern statement:

There is a concern that salvage harvest in an LSR and along the Siskiyou Crest is inappropriate 

and should not be done.

Forest Service Response:
33

Several commenters expressed concerns about salvage harvest along the Siskiyou Crest in the 

vicinity of Condrey Mountain, citing connectivity with Elliott Creek and Cook and Green 

Creeks, which are on the Rogue River National Forest north of the Siskiyou Crest and which 

have no connectivity to the project area. In Alternatives 2 and 4, proposed salvage units near the 

Siskiyou Crest are all in the matrix land allocation where fuel reduction and recovery of volume 

of fire-killed trees are legitimate objectives in the Klamath Forest Plan (FEIS page 15). 

Alternative 3 drops salvage units along the Siskiyou Crest and was developed in response to 

issues related to habitat connectivity in this area (FEIS page 25). Project effects related to habitat 

connectivity were evaluated for all alternatives at numerous places in the Wildlife section of the 

FEIS (pages 258, 267, 278, 290, 291 etc.). Habitat connectivity was used as an analysis indicator 

for fisher, marten and wolverine (FEIS page 270). Land allocations and standards and guidelines 

in the Klamath Forest Plan and similar designations on the Rogue River National Forest are 

intended to maintain habitat connectivity (FEIS page 150). The Johnny O'Neil LSR to the west 

of Condrey Mountain lies on both sides of the Siskiyou Crest. There are no salvage units in the 

LSR land allocation along the Siskiyou Crest in any alternative. Note that no salvage harvest is 

planned in any alternative in Riparian Reserves, the land allocation that provides connectivity 

between larger reserves. Salvage harvest in the late successional reserve land allocation is 

addressed in depth in concern responses #3, 23 and 26. Several comments expressed concern

about clearcutting. No clearcut logging will occur in the Horse Creek project. See the Glossary in 

the FEIS for a definition of clearcutting as used in this FEIS.

Associated Comments:

Comment 

# Comments

5-2

UW joins its voice with that of EPIC, Klamath-Siskiyou Alliance et al. in objecting to large 

scale logging on the Siskiyou Crest, including in the Johnny O'Neil LSR. Surely the wildlife, 

botany, silvicultural science professionals of the Klamath have spoken against such outdated 

and inappropriate management. If not, then they are remiss in their obligations to the wider 

public, in whose sacred trust these precious lands are managed by the Forest Service. 

Needless to say, this particular high ground is one of the very few, largely intact east-west 

connectivity corridors extent in our region. To disrupt it further than has already occurred 

through private industrial post-fire area salvage is, in our judgment, environmentally 

indefensible.

368-15

The forests of the Condrey Mountain-Dry Lake Mountain area at the headwaters of Buckhorn 

and Middle Creek have been targeted by the KNF with many post fire logging units, despite 

sustaining predominantly low severity fire affects. The forest proposed for logging are the 

last remaining ancient forest habitat in the Buckhorn and Middle Creek watersheds. The KNF 

intentionally lit these forests ablaze between September 3 and September 8, 2016 to bolster 

fire containment. They now intend to log the natural fire mosaic, removing massive old trees 

and the building blocks of forest complexity (e.g. old snags, downed wood, old living trees, 

etc).

368-35

A significant portion of the Gap Fire Area has a history of intensive, even-aged forest 

management, making the Johnny O'Neil LSR that much more important for the connectivity

it provides. The connectivity into the between the Klamath River and Upper Applegate 

watershed in Elliott Creek and Cook and Green Creek is still functional in the Johnny O'Neil 

LSR and should not be compromised with post fire clearcut logging.
34

Comment 

# Comments

368-83

To continue logging in LSR forest and within high elevation connectivity corridors will only 

compound the fragmentation, serious watershed, and wildlife impacts associated with 

previous post-fire logging projects in this important and now heavily altered landscape.

516-13

As will be established in these comments, salvage logging decreases ecosystem sustainability 

by inhibiting natural conifer regeneration, removing structural complexity, decreasing 

nutrient cycling, and (especially when combined with plantation establishment) increasing 

future fire hazard. These are not appropriate project results for the LSR land use allocation.

Comment Response #28: Salvage in LSR economically motivated

Concern statement:

There is a concern that salvage harvest in late successional reserve (LSR) is motivated by the 

recovery of economic value and not the ecological objectives of the land use allocation. 

Furthermore, there is concern that the effects of salvage harvest in LSR is not adequately 

analyzed.

Forest Service Response:

The purpose of salvage harvest in the LSR is to reduce the risk of future high severity fire by 

removing heavy fuels and to accelerate the development fire-resilient coniferous forests by 

replanting (FEIS pages 9, 17). Nowhere in the FEIS is it stated that economic recovery is the 

objective of salvage harvest in the LSR. The courts have held that the Forest Service may 

consider economics when considering salvage in LSR. In a legal challenge of salvage in LSRs, 

the 9th Circuit Court of Appeals determined that, "the Forest Service may consider economic 

interests in choosing how it will conduct LSR salvage operations; that it may do so is not only a 

matter of common sense, but it is also something explicitly contemplated by the Northwest 

Forest Plan (ONRC v. Brong No. 05-35063; D.C. No.CV-04-00693-AA). The DEIS (page 47) 

and FEIS (page 59) disclose the effects of the proposed action and its alternatives on the LSR 

land allocation. Discussions of effects to natural resources such as late successional forest 

structure, ecological processes etc. occur within the appropriate resource section of the FEIS. For 

example, discussions of late successional forest habitat and connectivity occur throughout the 

wildlife report and the corresponding chapter in the Wildlife section of the FEIS. The question of 

LSR salvage as a "significant issue" is addressed by the design of the alternatives and the limited 

harvest planned in the LSR land allocation. Salvage harvest in the LSR is being done to reduce 

risk of future high severity fire, not recover volume. Nearly all of the proposed salvage harvest in 

the LSR is clustered along private property boundaries where it is intended to create fuel breaks 

and reduce fuels to reduce the risk of future high severity fire. The vast majority of the fire killed 

trees in the LSR will remain unharvested. As noted in Table 10 (page 59) of the FEIS, no 

alternative proposes to salvage more than 5 percent of the LSR in the project area. When 

compared to the entire Johnny O'Neil LSR (46,840 acres), salvage harvest in the Proposed 

Action will affect one percent of the designated LSR and Alternative 4 will affect less than one 

percent of Johnny O'Neil LSR area. Alternative 4 was designed to limit potential impacts to 

northern spotted owls and their habitat that is mostly found in the LSR land allocation. Standards 

and guidelines for the late successional reserve land allocation regulate or prohibit activities that 

would prevent LSR management objectives from being achieved. All of the proposed LSR 

salvage harvest in the Horse Creek project is intended to reduce the potential for severe fire 
35

effects associated with future fire events that may occur within LSR in the project area. The 

Forest Plan of the Klamath National Forest anticipated that risk reduction salvage may be 

necessary in the late successional reserve land allocation, and provided project guidelines (Forest 

Plan page 4-86; MA5-27 to 29) to ensure that the objectives of the Forest Plan were achieved. 

The Forest Plan also provides general guidelines for salvage in late successional reserves when it 

is not specific to risk reduction (MA5-30-1 to MA5-30-11). These general salvage guidelines 

were considered in project design, however, the Forest Plan allows for some salvage operations 

that do not meet guidelines MA5-30 1 through 4 when the salvage is essential to reduce the risk 

of future risk of fire (MA5-30-5), as is the case in the Horse Creek Project. The project is fully 

consistent with the Klamath Forest Plan as required by the National Forest Management Act (See 

the Forest Plan Consistency Checklist on the project website at 

http://www.fs.usda.gov/main/klamath/landmanagement/planning.) Project effects to the LSR 

land allocation and associated resources are disclosed in the FEIS as required by the regulations 

for the National Environmental Policy Act (NEPA) (40 CFR 1500) and the Forest Service NEPA 

regulations (36 CFR 220).

Associated Comments:

Comment 

# Comments

516-15

The DEIS provides no compelling rationale to support the agency's focus on commercial 

logging and road construction within protected LSRs. The DEIS fails to analyze and disclose 

the impacts of the proposal to focus logging and road construction in the Reserves. The DEIS 

limits its discussion of LSRs to a few sentences disclosing the massive acreage of Reserve 

logging that is proposed while avoiding any substantive or qualitative analysis or disclosures 

regarding the effects of such logging on late-successional forest structure, ecological 

processes or ecological recovery. Indeed, the DEIS utilizes the term "recovery" to exclusively 

refer to the desire to "recover" the maximum economic value from the Reserves by logging 

them at the soonest possible date, which is inconsistent with the NWFP. NFP SFEIS F-21 

("Salvage will not be driven by economic or timber sale program factors" in LSRs). While the 

"summary" introduction to the DEIS acknowledges impacts to LSRs from salvage logging as 

a "significant issue" necessitating analysis in the DEIS, no actual analysis of project activities 

on the LSRs is provided in the document.

516-16

The Klamath National Forest has previously acknowledged (Westside DEIS page 106) that 

an action alternative that focused on hazardous fuels treatments and roadside logging would 

"meet one part of the purpose and need for this project (to reduce safety hazards to adjacent 

landowners, the public and forest workers) by including fuels and roadside hazard 

treatments." But the Forest Service insists upon conducting unit salvage logging in LSRs in 

order to "obtain the maximum economic commodity and value from burned timber." Ibid. 

The agency also mistakenly contends that unit salvage logging will "increase the likelihood 

and speed by which burned forests are restored."

516-17

Please note the recent 2013 BLM publication entitled the Analysis of the Management 

Situation for the Resource Management Plans for Western Oregon states that: The 1995 

RMPs do not provide management direction in Riparian Reserves or Late- Successional 

Reserves to salvage after disturbance for economic reasons. Since recent science seems to 

indicate that an ecological rationale for post-disturbance timber salvage is weak, an 

opportunity exists to add an economic objective related to after- disturbance salvage activities 

to these reserved land use allocations. In other words, KNF timber planners are not alone in 

their desire to circumvent the NWFP in order to place economic objectives above ecological 
36

Comment 

# Comments

objectives within the Reserve land use allocation. However, unlike the BLM salvage logging 

proponents, rather than amend the Forest Plan to place economic considerations above all 

other resource values, here the Forest Service is instead simply proposing to ignore the 

ecological function and purpose of the LSRs that it proposes to clearcut.

Comment Response #30: Siskiyou Crest as regional connectivity corridor

Concern statement:

There is a concern for the effects actions proposed in the Horse Creek project may have on the 

biological diversity and connectivity provided by the Siskiyou Crest. Commenters share that the 

Siskiyou Crest is a unique area providing a regionally important habitat connectivity corridor for 

species which contributes to the area's high level of biodiversity.

Forest Service Response:

Several commenters expressed the need to maintain habitat connectivity along the Siskiyou Crest 

to maintain existing diversity, and allow species to migrate and adapt to changing climate. We 

agree that connectivity of habitats is important. In response to these concerns, Alternative 3 

drops salvage units along the Siskiyou Crest and was developed in response to issues related to 

habitat connectivity in this area (FEIS page 25).

Land allocations in the Klamath Forest Plan are intended to maintain habitat and connectivity for 

species dependent on late successional and old growth forests by providing large reserves (the 

Late Successional Reserves) that maintain species meta populations and dispersal corridors (the 

Riparian Reserves) to allow migration and movement. At the project scale, elements such as 

green tree retention, retention of coarse woody debris, snag retention, the Survey and Manage 

requirements to protect rare species and their habitats and consultation with regulatory agencies 

under the Endangered Species Act provide additional protections. 

We also agree that logging and road building can adversely affect habitat if these circumstances 

are not considered. By following the strategies outlined in the Klamath Forest Plan, and 

consulting with regulatory agencies we believe we are minimizing those impacts to habitat 

connectivity. Several papers were provided that spoke to the diversity of the Klamath province in 

general (Dellasala et al. 1999, Olsen et al. 2012). Olson et al. 2012, notes that most of the 

region's biodiversity, endemic species, and species vulnerable to climate change are 

invertebrates, non-vascular plants, and fungi that are largely restricted to persistently cool and 

moist late-successional forests. It is unlikely that severely burned stands where salvage units are 

located and for which commenters are concerned, are "persistently cool and moist latesuccessional forests." 

Commenters provide no evidence that the land allocations and management prescriptions in the 

Klamath Forest Plan are not consistent with the biodiversity objectives described in Dellasalla et 

al. 1999 or Olsen et al. 2012 or that the Horse Creek project is not consistent with the direction in 

the Forest Plan with respect to species conservation. Even if the Forest Plan was inconsistent 

with these papers, the place to address landscape-scale concerns for biodiversity is at the Forest 

Plan level through monitoring and at the time of Forest Plan revision, not project-level NEPA 

decisions. 
37

Several commenters expressed concerns about salvage harvest along the Siskiyou Crest in the 

vicinity of Condrey Mountain, citing connectivity as a driving issue. There are no salvage units 

in the LSR land allocation along the Siskiyou Crest in any alternative. In Alternatives 2 and 4, 

proposed salvage units near the Siskiyou Crest are all in the matrix land allocation where fuel 

reduction and recovery of volume of fire-killed trees are legitimate objectives in the Klamath 

Forest Plan (FEIS page 15). Riparian Reserves are flagged out of any salvage unit and will 

remain uncut. Snag retention areas have also been designated where needed to provide 

connectivity. Coarse woody debris will be retained in the amounts specified in the Forest Plan. 

Alternative 3 drops salvage units along the Siskiyou Crest and was developed in response to 

issues related to habitat connectivity in this area (FEIS page 25). 

Project effects related to habitat connectivity were evaluated for all alternatives at numerous 

places in the Wildlife section of the FEIS (pages 258, 267, 278, 290, 291 etc.). Habitat 

connectivity was used as an analysis indicator for fisher, marten and wolverine (FEIS page 270). 

Land allocations and standards and guidelines in the Klamath Forest Plan and similar 

designations on the Rogue River National Forest are intended to maintain habitat connectivity 

(FEIS page 150). Note that no salvage harvest is planned in any alternative in Riparian Reserves, 

the land allocation that provides connectivity between larger reserves.

See also the response to concern #31.

Associated Comments:

Comment 

# Comments

368-12

Despite the positive effects of the Gap Fire, the KNF has proposed to implement old-growth 

post fire logging at the headwaters of Buckhorn Creek and Middle Creek in a nationally 

significant connectivity corridor.

368-96

There is simply no ecological benefit and no scientific justification for salvage logging high 

elevation forest in the Siskiyou Crest connectivity corridor that burned at characteristic fire 

severities. Analysis of this issue in the DEIS is entirely inadequate and does not accurately 

reflect the regional impact of fragmentation on the Siskiyou Crest, especially given a 

changing climate and the need for migratory corridors and climate refugia.

368-97

The forests targeted for post-fire logging, new "temporary" road construction and ground 

based logging include the last old forests in Upper Buckhorn and Middle Creek below Dry 

Lake Mountain and Condrey Mountain. Logging these units would fragment the remaining 

corridor of intact habitat on the southern face of the Siskiyou Crest.

368-100

The DEIS did not accurately analyze the impact of post-fire logging on the Siskiyou Crest 

and on regional connectivity. Environmental analysis surrounding the proposed Horse Creek 

Community Protection and Forest Restoration Project should include thorough analysis and 

disclosure of the direct and cumulative impact to the Siskiyou Crest connectivity corridor in 

this important bottleneck in Upper Buckhorn and Middle Creek. The impact of logging on 

wildlife species, connectivity,

368-145

The retention of intact forest landscapes will better protect the areas biodiversity, 

connectivity, recreational opportunities, and natural resource values. The Siskiyou Crest play 

a vital role, by allowing genetic and biologic diversity to flow throughout the KlamathSiskiyou Montains and the West Coast of North America. The connectivity that this 

landscape provides is largely responsible for the areas incredible biodiversity.

515-1 SCNPSO's board and members regularly botanize on Forest Service land in the Horse Creek 

watershed, especially up higher on the Siskiyou Crest. The botany on the Siskiyou Crest is 
38

Comment 

# Comments

outstanding, and is likely even more stunning now, after the Gap Fire, as wildflowers usually 

bloom in greater profusion following wildfire. We value the habitat connectivity the Siskiyou 

Crest provides to the greater region. The Klamath-Siskiyou Mountains have world-renowned 

biodiversity that can be negatively affected by the post-fire salvage logging proposed in the 

Horse Creek Community Protection Project.

516-5

Of special concern to our organization is the proposal to implement high-elevation salvage 

logging units on the Siskiyou Crest near Condrey Mountain and Dry Lake Mountain. This 

portion of the Siskiyou Crest is crucially important for wildlife connectivity and due to the 

checkerboard land ownership pattern on the Klamath National Forest and is a pinch point for 

a regionally important wildlife habitat connectivity corridor.

516-7

The DEIS fails to address the unique regional wildlife connectivity values provided by the 

Siskiyou Crest. In particular, the DEIS does not disclose the impacts of proposed highelevation snag removal in logging units near Condrey Mountain and Dry Lake Mountain on 

the ability of Management Indicator Species, Late-Successional Associate Species, and Snag 

Associated Species to move and traverse through the landscape.

517-1

Document 1: A Global Perspective on the Biodiversity of the Klamath-Siskiyou Ecoregion 

Authors: D. DellaSala, S.B. Reid, T.J. Frest, J.R. Strittholt, D.M. Olson A Global Perspective 

on the Biodiversity of the Klamath-Siskiyou Ecoregion quantifies the regions biodiversity by 

comparing it to national and global examples. The paper ultimately ranks the KlamathSiskiyou Ecoregion as one of the worlds outstanding temperate coniferous forests, due in no 

small part to exceptional levels of wildlife diversity and endemism. This globally significant 

biodiversity is one of the key values of the Siskiyou Crest. The DEIS must consider the 

significant and unique values established by this document. The DEIS acknowledges that 

"openings" due to timber harvest and road construction will occur, reducing habitat 

connectivity. According to DelaSalla et al., the top three threats to biodiversity in the region 

are habitat fragmentation due to road construction and logging, "degradation of species- rich 

areas" due to logging, grazing, and mining, and competition from invasive species (frequently 

brought in by logging and road construction/use.)

517-2

A Science-Based Conservation Assessment for the Klamath-Siskiyou Ecoregion Authors: 

R.F. Noss, J.R. Strittholt, C. Carroll, P. Frost A Science-Based Conservation Assessment for 

the Klamath-Siskiyou Ecoregion assesses the adequacy of conservation measures in the 

region and proposes improvements. In creating the assessment, the paper establishes 

biodiversity and habitat connectivity as key values of the ecosystem. These values must be 

considered by the DEIS. The "openings" created by road construction and logging, 

acknowledged in the DEIS, will negatively impact these values. The assessment frequently 

points to road construction and logging as direct threats to biodiversity and major causes of 

habitat fragmentation.

517-3

Mt. Ashland Late Successional Reserve Assessment Author: United States Forest Service 

The Forest Service's Mt. Ashland Late Successional Reserve Assessment identifies the 

unique function of the Siskiyou Crest as a biological crossroads. The paper states this with 

extreme clarity at pages 4 and 5: The Mt. Ashland LSR links the high elevation Siskiyou 

range of the Klamath Geological Province with the Southern Oregon Cascades. This link is a 

critical node in the overall migratory patterns of the Pacific Northwest. The maintenance of 

late-successional habitat within the Mt. Ashland LSR is important for maintaining species 

migration and dispersal. The DEIS must consider these values. The "openings" created by 

road construction and logging in Alternative 2 will result in decreased habitat connectivity 

and will harm the values established by this document.
39

Comment 

# Comments

517-4

The Cascade-Siskiyou Land Bridge: Using A Collaborative Scientific Process to Develop a 

Strategic Action Plan for Enhancing Landscape-Scale Connectivity Authors: E. Frost, M. 

Black This document operates from a baseline understanding of the regions immense value to 

landscape connectivity and proposes action to enhance that value. This document establishes 

the value of the Siskiyou Crest as one of the most important habitat connectors in the Pacific 

Northwest. The DEIS must consider this unique value. The Cascade-Siskiyou Land Bridge 

identifies incompatible land use management and barriers to wildlife movement among the 

chief threats to ecological connectivity in the region. Road construction is specifically 

mentioned as barrier to wildlife movement. The "openings" the DEIS acknowledges will be 

created by intensive logging and road construction are threats to the values established in this 

document, as described in the document.

Comment Response #31: Climate refugia in the Siskiyou Crest

Concern statement:

There is a concern that the effects analysis for climate change should include consideration of the 

impact proposed project activities may have on climate refugia in the Siskiyou Crest and its role 

as a migration corridor. Commenters also share that maintaining biological complexity and 

legacies may be important as microclimates and habitat niches as species adapt to a changing 

climate.

Forest Service Response:

We agree with the importance providing for species diversity and the role that refugia play in 

maintaining diversity. The cited paper, Olson et al. 2012, notes that most of the region's 

biodiversity, endemic species, and species vulnerable to climate change are invertebrates, nonvascular plants, and fungi that are largely restricted to persistently cool and moist latesuccessional forests. It is unlikely that severely burned stands where salvage units are located 

and for which commenters are concerned, are "persistently cool and moist late-successional 

forests" after the Gap Fire. Microclimate in severely burned areas, particularly on south facing 

slopes like the Horse Creek project tend to be hot and dry because the trees no longer have 

crowns so there is little shade. Early successional brush and hardwoods typically reoccupy the 

site after a severe burn, and may dominate the site for decades to centuries. It is not clear that the 

cited paper applies to the conditions of high severity burns however the topic is relevant for other 

reasons including the recovery of these sites. Several commenters expressed the need to maintain 

habitat connectivity along the Siskiyou Crest to allow species to migrate and to adapt to 

changing climate Land allocations in the Klamath Forest Plan are intended to maintain habitat 

and connectivity for species dependent on late successional and old growth forests by providing 

large reserves (the Late Successional Reserves) to maintain species meta populations and 

dispersal corridors (the Riparian Reserves) to allow migration and movement. At the project 

scale, elements such as green tree retention, retention of coarse woody debris, snag retention, the 

Survey and Manage requirements to protect rare species and their habitats and consultation with 

regulatory agencies under the Endangered Species Act provide additional protections. These 

strategies are not inconsistent with those identified by Olson et al (2012). We also agree that 

logging and road building can adversely affect habitat if these circumstances are not considered. 

By following the strategies outlined in the Klamath Forest Plan, and consulting with regulatory 
40

agencies we believe we are minimizing those impacts to habitat connectivity. While the 

comments cite recent journal article on refugia (Olson et al, 2012) commenters provide no 

evidence that the land allocations and management prescriptions in the Klamath Forest Plan are 

incongruent with Olson et al. (2012) or that the Horse Creek project is not consistent with the 

direction in the Forest Plan with respect to species conservation. In alternatives 2 and 4, 

proposed salvage units near the Siskiyou Crest are in matrix lands in patches of high severity 

burn where most, if not all of the trees are dead. There are no salvage units along the Siskiyou 

Crest in Late Successional Reserves in any of the action alternatives. Riparian Reserves are 

flagged out of any salvage unit and will remain uncut. Snag retention areas have also been 

designated where needed to provide connectivity. Coarse woody debris will be retained in the 

amounts specified in the Forest Plan. Alternative 3 was developed to be responsive to comments 

and drops all salvage harvest near the Siskiyou Crest. Alternatives 2 and 4 have the highest 

probability of restoring habitat connectivity along the Siskiyou Crest. They will reestablish 

coniferous forests decades sooner than large severely burned areas that are not planted because 

alternatives 2 and 4 reduce the risk of future high severity fires and accelerate the development 

of late successional forests. Alternative 3 would have the same effect as "no action." In 

alternative 3, these large patches of high severity burn near the Siskiyou Crest are likely to 

become semi-permanent brushfields that are maintained by high-severity fire (FEIS page 218). 

This trajectory is not likely to provide the refugia or connectivity that is the concern of the 

commenters.

Associated Comments:

Comment 

# Comments

368-108

It is not just the release of emissions that impacts climate resilience and ecosystem resilience. 

The impact of fragmenting a regionally significant connectivity corridor (as is proposed in the 

DEIS) will also have significant impacts to climate resilience. As climate induced species 

migration becomes more necessary these corridors have an increasing importance to region 

wide species viability and climate resilience.

368-109

The intact high elevation forests on the Siskiyou Crest should be retained to provide 

connectivity and refuge in the face of a changing climate. Likewise, forests of varying 

environmental gradients should be protected. Retaining biological complexity and intact 

biological legacies such as fire killed snags will provide additional microclimates and habitat 

niches for migrating plant and animal species.

368-110

The affects of the proposed action should be considered in the context of climate change, a 

potential mass migration of plant species and the Siskiyou Mountains role in providing 

habitat connectivity and refugia for the re-distribution of species due to climate affects.

368-111

A paper published in 2012 by the Natural Areas Journal by Olson etal, identifies the Siskiyou 

Crest as a key micro-refugia and meso-refugia in the Klamath-Siskiyou region. The paper 

also identifies the removal of non-climate related stressors such as logging as an important 

step towards maintaining connectivity, complexity and resilience on the landscape scale. 

Impacts to micro-refugia, meso-refugia and key gaps in current reserve systems are proposed 

in the DEIS. (Olson etal 2012).

517-5

Climate Refugia for Biodiversity in the Klamath-Siskiyou Ecoregion Authors: D. Olson, R.F. 

Noss, J.R. Strittholt, D. DellaSala, J. Kass, M.E. Koopman. T.F. Allnut Climate Refugia for 

Biodiversity in the Klamath-Siskiyou Ecoregion highlights the unique ability of the regions 

microclimates to provide a refuge for species vulnerable to the effects of climate change. The 

paper identifies specific "Microrefugia" sites that can provide protection to biodiversity. 
41

Comment 

# Comments

Climate refugia is a significant and important wildlife value that cannot be ignored in the 

DEIS. The paper also identifies the main andromorphic threats to this value. Logging and 

road construction are specifically identified as non-climate stressors that damage the ability 

of the ecosystem to provide climate refugia. The DEIS acknowledges that "openings" will be 

created by road construction and timber harvest.

Comment Response #32: Site specific road proposal

Concern statement:

There is a concern that the DEIS does not contain a site specific analysis of proposed road 

activities, including a delineation of where roads will be constructed, road maintenance and 

improvements and the resulting impacts.

Forest Service Response:

The interdisciplinary team did a review of what units required treatment and what access roads 

were needed for the proposed treatments. Road maintenance and improvements will follow Best 

Management Practices and Project Design Features as described in Chapter 2 of the FEIS. All 

temporary roads will be closed and hydrologically stabilized according to the Project Design 

Features outlined in Chapter 2 of the FEIS. Chapter 3 of the FEIS summarizes the analysis for 

each resource area potentially impacted by the proposed project, this includes a description of the 

spatial and temporal context for each specific resource. Resources that could be affected by 

temporary road construction included this connected action within the bounds of the specific 

analysis and disclosed effects of the action within the environmental consequences discussion as 

summarized in the FEIS. This forms the scientific and analytic basis for comparison of the 

alternatives, including the proposed action and any connected actions. 

Alternative 3 dropped all new and temporary road construction. This provides an easy 

comparison of the site specific effects of road construction. Figure 9 (FEIS page 177) compares 

landslide risk ratio between alternatives. This comparison clearly shows the influence of existing 

disturbances in the project area (roads, past timber harvest, and fire), in that they significantly 

outweigh the effects of project proposals. As a result, the difference in risk ratio between 

alternatives is very small for all 7th field watersheds analyzed.

Associated Comments:

Comment 

# Comments

589-10

Site-specific analysis of the proposed road activities is crucial. We are pleased that the Forest 

Service intends to complete an Environmental Impact Statement for the Project. A project of 

this size and scope clearly contemplates significant effects that are best analyzed in an EIS. 

However, the Forest Service must conduct site-specific analysis as a part of the DEIS, which 

it has failed to do. This includes explicitly delineating where roads will be constructed, which 

roads will be maintained or improved, and the resulting impacts of such activity on important 

Forest resources.
42

Comment Response #33: Temporary road construction needed

Concern statement:

There is a concern that implementing Alternative 3 including the proposal to remove all new and 

temporary roads does not meet the purpose and need of the project.

Forest Service Response:

In response to scoping comments, Alternative 3 was developed to consider and analyze the 

effects of removing temporary road construction from proposed project activities. This resulted 

in the removal of 13 units from this proposed action alternative as they would be infeasible to 

implement without the construction of temporary roads (new and existing roadbeds). These units 

are located in General Forest and Partial Retention VQO Management Areas. The Horse Creek 

project proposes to restore these Management Areas to the desired conditions as guided by the 

goals of the Forest Plan. For General Forest, that includes the desired condition of a fire-resilient, 

multi-aged, regulated coniferous forest that provides timber and other resource values as the 

management area contributes to the forest timber base on a sustainable basis. For Partial 

Retention VQO, that includes the desired condition of a coniferous forest that is resilient to fire, 

where management actions are subordinate to the visual character of the landscape. The 

management area also contributes to the forest timber base on a sustainable but low intensity 

basis. As demonstrated in the Silviculture effects analysis in Chapter 3 of the FEIS, these 

untreated units with severely burned stands would likely be replaced by shrubs and brush and the 

regeneration of conifers and restoration of forested wildlife habitat may take decades 

(Silviculture section, Chapter 3 FEIS).

Associated Comments:

Comment 

# Comments

7-5

Alternative 3 removed all treatment units on the Siskiyou Crest and all new and existing 

temporary roads. New and existing temporary roads are much needed to perform harvest 

activities. With less treatment and higher logging costs associated with removal of roads, this 

alternative clearly fails to address the purpose and need.

Comment Response #34: Herbicide use

Concern statement:

There is a concern that herbicides will be applied to control infestation of non-native invasive 

plant species.

Forest Service Response:

Herbicide use for the treatment of non-native invasive species is not proposed as part of the 

Horse Creek Restoration Project. All treatment of non-native invasive species on KNF land as 

part of this project will consist of non-chemical hand pulling or mechanical mowing/weed 

whacking. Language has been added to the Non-Native Invasive Species Report to clarify 

treatment techniques.

Associated Comments:
43

Comment 

# Comments

1-59

the DEIS tells the public you will "treat" NNIS in the Klamath National Forest without 

identifying how you will treat the weeds. I'll bet you plan to apply Roundup and keep it secret 

because Monsanto's use of glyphosate is making front-page headline. Thus, the public knows 

even casual exposure to glyphosate is likely to kill and maim terrestrial wildlife, birds and 

human visitors later in life and will kill aquatic life with water concentrations of just a few 

parts per million.

1-60

You must have read about Monsanto in the news. Do you trust them to put safety ahead of 

profit? America has the highest cancer rate of any industrialized country in the world. Red the 

obituaries and you will learn most people died of cancer. In spite of the warnings you applied 

glyphosate in the past just because the USDA said it was safe. Perhaps in a few years you 

might be responsible for the death of the person named in the obituary. Many carefully 

designed studies link glyphosate to horrendous bodily harm. How will you be at ease with 

yourself over the rest of your life knowing you planted the cancer seed where families will 

camp or hike? If glyphosate is safe why would herbicides that contain the chemical be 

bannedDenmark, England, Italy, El Salvador, Sri Lanka, France, Holland, Austria, Bulgaria, 

Germany, Greece, Hungary, Ireland, Japan, Chile, South Africa, Luxembourg, Madeira, 

Cameroon, New Zealand, Peru, South Australia, Russia, France,Switzerland, Columbia, and 

Costa Rica?

1-71

Not telling the public they will likely be exposed to a chemical that sometimes causes cancer 

violates: 18 U.S.C. § 1001(c) because the Responsible Official relied on a single (emphasis 

added) research conclusion that glyphosate is safe made by a lab with possible ties to 

Monsanto (Syracuse Environmental Research Associates--SERA) knowing the research 

conducted by hundreds of independent scientists reveals glyphosate exposure may cause birth 

defects, miscarriages, premature births, cancer - non-Hodgkin's lymphoma and hairy cell 

leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning 

disabilities, ADHD and other neurological disorders (especially in children), mitochondrial 

damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, 

decrease in the sperm count and chromosomal damage 40 CFR 1501.2 (b), 40 CFR 

1502.16(a) and (b), and 40 CFR 1508.8(b) because Chapter 3 omits important environmental 

effect disclosures related to glyphosate research (i.e. glyphosate exposure is statistically 

correlated to birth defects, miscarriages, premature births, cancer - non-Hodgkin's lymphoma 

and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, 

infertility, learning disabilities, ADHD and other neurological disorders (especially in 

children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin 

tumors, thyroid damage, decrease in the sperm count and chromosomal damage cancer) 40 

CFR §1508.27(b)(2) because the intensity discussion fails to discuss the degree to which the 

proposed action affects public health or safety. The Apr. 21, 1997 Executive Order No. 13045 

because the Responsible Official does not ensure that this project will not disproportionately 

expose children to environmental health risks and safety risks.

Comment Response #35: Non-native invasive species spread risk

Concern statement:

There is a concern that there is an elevated risk of introduction and rapid spread of certain nonnative invasive plant species as a result of project activities and that this risk needs to be 

mitigated. There is particular concern regarding hauling along routes infested with dyer's woad 

and the risk of spread from the Klamath National Forest into Southern Oregon.
44

Forest Service Response:

The high risk of introduction and spread of non-native invasive species has been acknowledged, 

and project design features to mitigate that risk have been included in Table 9 (page 52-53, 

Project Design Features) of the FEIS. The main haul route was included in the spatial bounding 

for the non-native invasive species risk analysis. Post-project non-native invasive species survey 

and treatments will prioritize areas near the Siskiyou Crest and around the Horse Creek SIA.

Associated Comments:

Comment 

# Comments

515-12

The risk of introducing and/or spreading non-native invasive species as a result of project 

activities is high for certain species. SCNPSO asks the KNF to give this issue special 

consideration when implementing this project. Because of the mix of land ownership within 

the project boundary, and a lack of data for private land, it is important to take all 

precautionary measures to ensure non-native invasive species do not spread due to project 

activities. The natural disturbance of the fire may already be seeing an increase in some nonnative species in some areas, but compounded by road construction and logging, the problem 

will be exacerbated and a non-native invasive plant explosion could occur.

515-13

As the Draft Botanical Resources Report points out, "The effects of suppression-related seed 

dispersal will not be immediately evident for the sake of this analysis." This means that the 

DEIS does not have all the relevant or current information regarding the presence of nonnative invasive species within project area because the spread of non-natives from Gap Fire 

suppression activities is still unknown. It is assumed that yellow starthistle and spotted 

knapweed, in particular, have been introduced from outside the analysis area, "particularly 

from the incident command post and from the southern contingency area," during Gap Fire 

suppression activities.

515-14

Dyer's woad is of particular interest to the SCNPSO as the spread of Dyer's woad from 

Siskiyou County has started to affect southern Oregon as the plant has made its way over 

Siskiyou Summit. Project activities associated with salvage logging on the Siskiyou Crest 

could introduce Dyer's woad to other areas of the Siskiyou Crest, facilitating spread into other 

areas of southern Oregon.

515-15

No log hauling should occur on the probable haul route proposed under the proposed action 

where Dyer's woad occurs. If hauling is to occur in the Dyer's woad area it will likely be 

spread around and risk infestation in other locations. This will have dire consequences that 

will last into the future. It is best to avoid hauling in the Dyer's woad area.

Comment Response #36: Westside project design features not included

Concern statement:

There is a concern that the project did not employ the same set of project design features 

intended to protect water quality as the Westside Fire Recovery Project. Additionally there is 

concern of how BMP-6 will be implemented to address watercourse crossings on Maintenance 

Level 1 roads.

Forest Service Response:

The Forest is continually working on refining and improving our project design features which 

evolve over time with input from our specialists and implementers as well as from other agencies 

and the general public. No project design feature list is exactly the same from one project to 
45

another as they are specific to the needs and activities proposed in a given project and are 

tailored to the specific project area. Project design features are not intended or needed to repeat 

standards and guidelines provided in our Forest Plan, best management practices designed to 

manage water quality, direction provided in the terms and conditions included in our standard 

timber contracts, or other guidance (e.g. wet weather operating standards); project design 

features are intended to provide additional protections not already covered in other laws, 

regulations, or policies. After review of the project design features of the Westside Fire Recovery 

Project, it is apparent that those not included in the Horse Creek Project were excluded for these 

very reasons. As the Forest continues to refine and improve our project design features, we will 

continue to work with the North Coast Regional Water Quality Control Board to ensure the 

protection of watershed values.

Regarding the implementation of BMP Road-6 which states "Avoid, minimize, or mitigate 

adverse effects to soil, water quality, and riparian resources by storing closed roads not needed 

for at least 1 year (Intermittent Stored Service) and decommissioning unneeded roads in a 

hydrologically stable manner to eliminate hydrologic connectivity, restore natural flow patterns, 

and minimize soil erosion," a survey of legacy sites is ongoing at the time of the publication of 

this FEIS and a legacy site treatment plan will be completed according to the requirements of the 

waiver. There likely are legacy sites on Maintenance Level 1 roads and they will be addressed in 

the waiver through the North Coast Region Water Quality Control Board consultation process.

Associated Comments:

Comment 

# Comments

591-5

Page 107 to 116 of the Final Environmental Impact Statement (FEIS) for the Westside Fire 

Recovery Project (Westside Project) identified 36 Project Design Features (PDFs) designed 

to address watershed protection measures. Site conditions and proposed activities in the 

Horse Creek Project are very similar to the conditions in Westside Project areas. During the 

Westside Project development process we worked closely with KNF staff to develop PDFs 

that were appropriate for a large fire recovery project and were protective of water quality. 

Numerous PDFs contained in the Westside Project FEIS appear to be appropriate for 

inclusion in the Project FEIS. KNF should add the relevant PDFs for water quality protection 

developed for the Westside Project into the Project FEIS.

591-7

As the Project area experienced moderate to high severity fire across a large area, 

watercourse crossings on Maintenance Level 1 roads may be at risk from elevated water flow, 

as well as the potential for debris flows from burned areas. If any Maintenance Level 1 road 

used in the Project area currently contains culverted watercourse crossings, KNF should 

address in the FEIS how BMP Roads-6 will be implemented. If watercourse crossings will 

remain on Maintenance Level 1 roads at the conclusion of Project activities, KNF should 

identify in the FEIS and/or the Waiver application how they plan to inspect and maintain 

those crossings in the future.

Comment Response #37: Wilderness

Concern statement:

There is a concern that treatment should have different project objectives within wilderness 

areas.

Forest Service Response:
46

Thank you for your concern, however, there are no treatments proposed within designated 

wilderness areas.

Associated Comments:

Comment 

# Comments

518-3

Alternative 3-I am not certain how many residents live up on the Siskiyou Crest, however, if 

it is truly a wilderness area, perhaps plans for residential areas and wilderness areas should be 

different, based on needs.

Comment Response #38: General suggestions and recommendations

Concern statement:

Recommendations and suggestions for how the project design and implementation should occur 

to avoid concerns regarding management goals, post treatment activity fuels, beneficial uses of 

water, and air quality.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation. The effects of the 

project are disclosed in the FEIS and supporting Resource Reports, included in the project record 

available on the project website, and will be considered by the Responsible Official in arriving at 

a decision.

Associated Comments:

Comment 

# Comments

368-143

All units that cannot be cleanup in two years should be canceled. Units further from the 

community of Horse Creek should be dropped first, including those on the Siskiyou Crest. No 

logging should take place unless slash can be removed in a timely manner.

369-3 We also recommend that the FEIS discuss the potential to process residual fuels at a biomass 

energy facility to minimize air the emissions associated with pile burning.

519-45

We urge the Klamath National Forest to protect the beneficial uses of water, fulfill its tribal 

trust obligations and restore threatened species populations and habitat. The project should 

maintain and restore the Johnny O'Neil LSR and retain living trees and the largest trees, 

including all legacy trees, and provide an adequate amount of snag retention within all project 

units. Thank you for your attention and consideration.

Comment Response #40: Cost of planning and implementation

Concern statement:

There is a concern that the cost of planning and implementation including fuel reduction and 

activity slash removal was not disclosed or analyzed in the DEIS. Including a comparison of 

incoming funds associated with the timber sale with the cost of planning and implementation.
47

Forest Service Response:

While the agency remains confident here that the necessary funding will be acquired when 

needed for those activities to be implemented, there is no requirement that the receipts from the 

salvage harvest proposed here or funds from any other sources cover the costs of those future 

activities. Under current management priorities, national forest timber sales are generally 

designed to accomplish management or ecological objectives that may have multiple benefits; 

their primary purpose is not revenue generation. In this Project, salvage harvest units have been 

primarily designed with the purpose of reducing fuel loading in strategic locations and/or 

reestablishing coniferous forests, not to strictly generate revenue. Because the objectives of this 

project are broader than just to generate revenue the comparison of the timber revenue to the 

planning costs would not be sufficient to show if project objectives were met. Salvage harvest 

achieves important fuel reduction goals because it removes heavy fuels that contribute to future 

fire severity and resistance to control. In other words, the dead trees that are harvested reduce 

fuel loads and pay their own way out of the woods. Regardless of the value of timber sale 

receipts, salvage harvest projects can be highly ecologically valuable, and can provide one of the 

only economically feasible means of removing the heavy fuels. Salvage logging also reduces the 

cost of other subsequent fuel treatments such as hazard reduction in the Wildland Urban 

Interface (WUI). Pre-sale actions such as preparation of environmental analyses under the 

National Environmental Policy Act (writing the EA or EIS), salvage sale contract preparation 

and administration are generally funded by a combination of annually appropriated funds and 

salvage sale fund receipts. Other actions such as post-fire slash treatments, reforestation, WUI 

fuel reduction, roadside fuels treatments, etc., are also likely to come from a variety of funding 

sources, including congressional appropriations, grants and agreements, and to a lesser extent 

timber sale receipts. Forest Service appropriations are authorized by Congress on an annual 

basis. Because of this, the agency cannot obligate congressionally-appropriated funds for actions 

to be carried out in future years. We believe the Horse Creek Project is likely to receive the 

funding it requires for full implementation over the course of the project, and the agency is 

committed to using whatever funds it has available to accomplish the project's post-sale 

restoration goals.

Associated Comments:

Comment 

# Comments

368-139

The DEIS did not analyze the true cost to taxpayers associated with this project. The agency 

should disclose the cost of analysis, timber sale preparation, survey work and other 

implementation/planning costs for the proposed project in an FEIS.

368-140

The agency should also compare the cost of incoming funds associated with the sale of timber 

with implementation and planning costs. The sale price for the proposed timber sale should 

be based on recent salvage timber values in the Westside Project where logs were sold for 

pennies per thousand.

368-141 The DEIS also did not disclose the actual cost of fuel reduction and activity slash removal in 

post-fire logging units.

368-147

The cumulative impact of this increase in logging slash was not analyzed in the DEIS. 

Likewise, the cumulative effect of increasing numbers of untreated post fire logging units on 

agency budgets should also be considered.
48

Comment Response #41: Capacity for implementation

Concern statement:

There is concern regarding the Forest's capacity to implement the proposed activities considering 

outside demands including other projects, available funding, and the increasing number of postfire logging landscapes across the forest.

Forest Service Response:

See also response to concern #40. Project planning efforts include all areas that are feasible to 

implement that meet the purpose and need of the project regardless of the value of timber sale 

receipts. Salvage harvest projects can have desirable effects, such as long term fuels reduction, 

and can provide one of the only economically feasible means of removing the heavy fuels. 

Salvage logging also reduces the cost of other subsequent fuel treatments such as hazard 

reduction in the Wildland Urban Interface (WUI). Pre-sale actions such as preparation of 

environmental analyses under the National Environmental Policy Act (writing the EA or EIS), 

salvage sale contract preparation and administration are generally funded by a combination of 

annually appropriated funds and salvage sale fund receipts. Other actions such as post-fire slash 

treatments, reforestation, WUI fuel reduction, roadside fuels treatments, etc., are also likely to 

come from a variety of funding sources, including congressional appropriations, grants and 

agreements, and to a lesser extent timber sale receipts. Forest Service appropriations are 

authorized by Congress on an annual basis. Because of this, the agency cannot obligate 

congressionally-appropriated funds for actions to be carried out in future years. We believe the 

Horse Creek Project is likely to receive the funding it requires for full implementation over the 

course of the project, and the agency is committed to using whatever funds it has available to 

accomplish the project's post-sale restoration goals.

Associated Comments:

Comment 

# Comments

368-142

Project acres should be scaled back to reflect the actual funds available for activity slash 

removal. If funding is not available to cleanup all activity slash within two years of 

implementation, fuel reduction benefits analyzed in the EA will not be realized.

368-146

The agency must analyze the capacity of the KNF to actually implement proposed activities 

given the demands of other projects, limited available funding, and increasingly numerous 

number of post-fire logging units across the KNF that are currently in need of treatment. The 

actual number of acres realistically feasible to treat should be defined and project fuel loading 

should be based on actual ability of the KNF to treated activity slash.

368-148

In the Westside Project, funds generated from logging receipts were intended to pay for slash 

removal. Selling salvaged timber for literally pennies per thousand as the KNF did during the 

Westside Project has provided very little funding for slash removal, restoration and for 

addressing legacy sediment sites as was intend. The logs were removed and the rest will 

perhaps happen someday in the future and only with further public investment. The same will 

be true in the Horse Creek Community Protection and Restoration Project. The DEIS did not 

analyze this with this reality in mind, making the analysis faulty and inaccurate.

519-22 To what degree does the project rely upon potential timber revenue to fund this area? What 

would happen if timber revenue came up short—how would these project features be funded?
49

Comment Response #42: Firefighter safety during suppression activities

Concern statement:

There is a concern regarding the agency's fire suppression tactics relating to fire fighter safety.

Forest Service Response:

Fire suppression strategy, tactics and methods are outside the scope of the proposed action and 

are not related to the decision to be made. The objective of fire fighter safety in this project is 

about providing a safe environment for firefighters to do their jobs. Fire suppression is a part of 

the Forest Service mission where community protection, resource protection and protection of 

infrastructure is concerned. This includes access and initial attack far removed from communities 

at risk when it is desirable or necessary to suppress fires while they are small during times of 

high fire danger. Firefighter safety will be compromised by the hazards left in untreated 

landscapes where risk reduction salvage, roadside hazard tree removal, roadside fuel reduction 

and fuel reduction in fuel management zones are not accomplished. Areas where snags are not 

removed will compromise firefighter safety by increasing resistance to control of future fires, 

increasing the intensity of fireline exposure to heat and fire, and increasing exposure to falling 

and rolling material.

Associated Comments:

Comment 

# Comments

368-68

KNF managers continue to consistently utilize wildland fire fighting strategies that are the 

most dangerous to firefighters, including wilderness/backcountry firefighting that relies 

heavily on helicopter and vehicle use, two of the most dangerous firefighting activities. This 

contradicts the agency's claim to be protecting fire fighters from safety hazards by 

implementing post-fire logging.

368-70

The issue of firefighter safety is a real concern, yet should be addressed through the creation 

of a comprehensive fire plan, the use of prescribed fire, and the proper management of 

personnel in the event of a future fire. Firefighter safety depends heavily on sound forest 

management

368-72

According to the report, Wildland Fire Fatalities By Type Accident published in 2008, not a 

single firefighter has ever been killed by falling snags in the KNF ( NWCG, 2008), and only 

five firefighters have been killed by snags in the State of California since 1910. (NWCG, 

2011) In total, 324 firefighters have lost their lives while suppressing wildfires in the state of 

California, the five who were killed by falling snags amounts to .02% of the state's fatalities. 

(NWCG 2011) In addressing the risk of snags, The National Wildfire Coordinating Group 

recommends that managers "can reduce fatalities by learning to expect the unexpected 

events," one way of addressing this issue is by avoidance of such dangerous situations and 

choosing less aggressive containment strategies, especially in remote and inaccessible areas.

368-73

it appears that the agency is engaging in the most risky form of wildland fire suppression, 

through its heavy utilization of aircraft while fighting back country fires. Salvage logging will 

in no way address this safety concern or minimize the risk to life posed by aircraft accidents. 

Only reform of the current paradigm involving wilderness/roadless firefighting will alleviate 

this risk. If firefighter safety is a purpose of the project, aircraft fatalities and the risk of back 

country suppression must be addressed. To do otherwise is disrespectful to those that have 

lost their lives on the KNF.
50

Comment 

# Comments

368-79

Back country fire fighting is the most risky form of fire suppression and if a purpose of the 

project is to address safety concerns, an unbiased look and thorough analysis of the risks 

associated with such back country suppression must be included in any Environmental 

Analysis.

Comment Response #43: Clearcutting

Concern statement:

Commenters expressed concerns with the effects of clear-cut harvest methods in the project area 

on the Siskiyou Crest, watershed condition, recreation opportunities, wildlife, and habitat 

connectivity. There is a concern that this practice does not effectively restore the forest to desired 

conditions.

Forest Service Response:

As a point of clarification, we are proposing salvage harvest of dead and dying trees, with 

follow-up site preparation and reforestation. In the Horse Creek Project, we are assessing 

individual trees, on a case-by-case basis, for their ability to survive the effects of the Gap Fire, 

and salvage harvesting those trees that are dead or determined to have a 70 percent or greater 

probability of mortality in the next 5 years. "Clearcutting" is defined in the glossary of the Horse 

Creek FEIS. Clearcutting is a silvicultural system used in green, as opposed to fire-killed, stands 

of trees. Salvage harvesting dead and dying trees is not "clearcutting".

Associated Comments:

Comment 

# Comments

155-1

I urge Forest Service planners to please focus the Horse Creek project on restoring forest 

ecosystems and watershed health while protecting homes and communities from wildfire. 

High elevation backcountry clearcutting on the Siskiyou Crest will not contribute to those 

needed restoration efforts.

368-13 The KNF has proposed to clear cut 2257 acres of fire-affected forest in Buckhorn, Middle and 

Horse Creek.

368-32

the clearcut logging proposed in the ironically named Horse Creek Community Protection 

and Forest Restoration Project would be inconsistent with predisturbance management goals 

or Standards and Guidelines in the area's LSR forest, northern spotted owl habitat and in 

areas designated as for visual "retention" such as along the Siskiyou Crest in Upper Buckhorn 

Creek and Middle Creek.

384-2 The Forest Service insistence on clearcutting the Siskiyou Crest is bad for the forests and 

communities that are served by the use and enjoyment of our public lands.

409-1 Clearcutting is not the way. We've observed this over the decades. It's not the way to deal 

with our fuels problems.

437-1 It is high time that we change the business as usual with regard to so called "salvage logging", 

especially by the incredibly damaging method of clearcutting!

497-1

In addition, salvage logging and particularly clearcutting discourages cavity nesting birds 

such as woodpecker species, nuthatches and bluebirds, that seek out burned or dead trees for 

nesting and the necessary insects for feeding themselves and their young
51

Comment 

# Comments

515-20 Clearcutting is an ecological travesty, unsupported by the majority of forest scientists and 

ecologists.

516-6

The inclusion of these late-successional, backcountry, clearcut logging units is antithetical to 

the alleged community protection purpose and need for the project and ensures steadfast 

opposition to the agency's post-fire clearcutting agenda.

544-1

Would you please forward the scientific reasons for clearcutting native forests on the 

Siskiyou Crest or do you feel that anything goes in the age of Trump. And how does this 

protect the tribe, the community, and Oregonians.

635-1

As I understand it, the so-called "Horse Creek Community Protection and Forest Restoration 

Project" targets high-elevation post-fire forests on the Siskiyou Crest for salvage clearcut 

logging.

635-2

If arson becomes the trigger for clearcutting forests that shouldn't be clearcut, what is to 

prevent anyone who wants to override ecological best practices from just going up in the 

woods and setting a fire?

689-1 Clearcutting is not the way. We've observed this over the decades. It's not the way to deal 

with our fuels problems.

831-1 I do not approve of clearcutting, it is counterproductive to the environment

882-2

Clear cutting this area, which I have hiked through, would be a disaster to the human and 

natural communities downstream costing far more than the value of the timber sale. Doing so 

would be a gross violation of your duty to protect our natural resources.

942-1 We as citizens of the region know that clear cuts do not work to restore forest lands

942-3

The initial clear cut destroys the soils beneficial bacteria and nutrients. The location of the 

clear cut on the steep aspect of this proposed cut will allow rapid runoff and destroy the forest 

below it, carry extra top soil into the creeks and streams hindering the fish and wildlife habits. 

The length of time spent in the clear cutting and rehabilitating of the land will have by 

duration of time ruined the ecologically balance and create a more serious and less responsive 

system for future habitation and use.

979-2 The Forest Service's insistence on clearcutting the Siskiyou Crest is bad for the forests and 

bad for the millions of people who OWN and enjoy our public lands.

Comment Response #44: Surveys for protected botanical species

Concern statement:

The commenters expressed concern that there have not been adequate surveys for botanical 

species listed as threatened, endangered, proposed, sensitive, and survey and manage throughout 

the project area. There is concern that without survey of suitable habitat there may be impacts to 

populations, and that small buffers around any known locations may not be large enough to 

protect the habitat. Additionally, there is concern that only previously known sites are being 

evaluated in order to determine if they still exist, and that new sites are not being located for 

protection.

Forest Service Response:

Survey requirements are different depending on whether the species is listed as federally

threatened or endangered, Forest Service Sensitive, or Survey and Manage. Not all management 

categories require pre-disturbance surveys be completed at the project level. For example: the 
52

Forest Plan states that "If surveys [for Sensitive plant species] cannot be conducted, project areas 

should be assessed for the presence and condition of Sensitive species habitat" (page 4-23, S&G 

6-8). Similarly, pre-disturbance surveys are not required for Survey and Manage Categories B, 

D, E, or F (Table 20, Botanical Resources Report). When pre-disturbance surveys are required 

(threatened, endangered, and Survey and Manage A and C species), they must be completed 

prior to implementation, and not necessarily prior to release of the environmental planning 

document provided that there is adequate protection measures incorporated into the project 

design in the event that populations are discovered during pre-disturbance surveys. Botanical 

survey are currently on-going and project design feature (Bot-8) is included in the FEIS to ensure 

surveys for threatened and endangered species will be complete before project implementation. 

Similarly, in order to be in compliance with Survey and Manage guidelines as stated in the FEIS, 

surveys for Category A and C botanical species will be completed prior to project 

implementation. The use of avoidance areas surrounded by buffer zones is a common and 

effective tool used to protect rare plant populations and their surrounding habitat (CNPS 1998). 

Avoidance zones are monitored following project implementation to determine whether 

protection goals were met. Avoidance and buffer zones are established on a species and site 

specific basis using data collected from numerous years of project design feature effectiveness 

monitoring on the Forest. As a point of clarification, the FEIS does state that roadside hazard tree 

logging may affect certain Sensitive bryophytes, lichens, and fungi that have suitable habitat 

present in treatment units (Chapter 3 of the FEIS). The comment seems to confuse Forest Service 

Sensitive Species and Survey and Manage direction. For Survey and Manage categories B, D, E, 

and F we are required to protect known sites but do not need to conduct pre-disturbance surveys. 

Our large dataset of "known sites" is based on data gathered from many years of surveys across 

the Forest that included species specific, habitat specific, and random grid survey types.

Associated Comments:

Comment 

# Comments

515-10

It appears that rare plant surveys for the DEIS may not have been completed by the time the 

document was released. This could be an oversight that may result in rare plants being 

unknowingly impacted by the salvage logging activities. Because of the large area of the 

project and the changes in elevation, the possibility of impacts to rare plants, bryophytes and 

fungi are very possible. Small buffers do not protect these species enough for ongoing 

dispersal habitat. Because of their limited numbers, rare plants need habitat protection to 

ensure their long-term viability and dispersal. Small buffers are not enough. Rare plants such 

as Gentner's fritillary (Fritillaria gentneri), Henderson's fawn lily (Erythronium hendersonii), 

Clustered lady slipper (Cyprepedium fasciculatum), Mountain lady slipper (Cypripedium 

montanum), Klamath Mountain buckwheat (Eriogonum hirtellum), and Henderson's horkelia 

(Horkelia hendersonii) are found in the project area.

515-18 SCNPSO will be waiting for the final Botanical Resources Report to understand more of 

what the actual on-the-ground plant surveys document in the project area.

516-27

The DEIS paradoxically claims that there will be no effect to sensitive bryophytes, lichen and 

fungi from roadside logging of live trees because "no known sites" would be impacted. It 

would be strange indeed if any "known sites" were impacted given that the agency has 

refused to survey for these sensitive species. When one chooses not to "look" it is nearly 

impossible to "know" what is on the landscape that will be impacted by proposed logging 

activities.
53

Comment 

# Comments

516-76

While the KNF is refusing to survey previously un-surveyed suitable habitat to locate known 

sites of Sensitive species, it is re-surveying already known sites in order to remove the 

protection buffers when possible to facilitate logging. This is an interesting and unique 

interpretation of the NWFP and the KNF LRMP.

Comment Response #45: Surveys for Henderson’s triteleia

Concern statement:

There is a concern that no botanical survey was conducted for the Henderson's triteleia which 

may occur within the project area.

Forest Service Response:

Triteleia hendersonii is not listed as federally threatened or endangered, as Forest Service 

Sensitive, or as Survey and Manage and is therefore not a species we are required to manage for 

on the Klamath National Forest. No specific pre-disturbance surveys are required for this 

species, however it would be noted if it was found in a survey plot.

Associated Comments:

Comment 

# Comments

515-11

It is very possible that Henderson's triteleia (Triteleia hendersonii) also occurs within the 

project area, as a population exists in Elliott Creek, just over the ridge from the project area. 

Surveys for this species are advised.

Comment Response #46: Negative effects of salvage harvest

Concern statement:

There is concern for the negative effects of salvage harvest on multiple resources, including the 

following: habitat complexity and connectivity; habitat components including snags and coarse 

woody debris; soil stability, compaction, and schist soils; high mountain meadows and springs; 

plant communities and the spread of nonnative invasive species; hydrology and water quality; 

fish-bearing streams; and, wildlife including threatened species and snag depending birds.

Forest Service Response:

This group of comments are general expressions of concern and opposition to salvage logging. 

The Klamath Forest Plan provides land allocations, management prescriptions, and standards and 

guidelines to ensure that logging, and other land management tools, are used to create and allow 

for the desired future conditions of these areas as described in the Forest Plan. Standards and 

Guidelines regulate or prohibit actions and activities that would prevent forest plan objectives 

from being achieved. At the project level, we apply water quality best management practices, 

project design features, and site-specific project reviews by a professional interdisciplinary team. 

The FEIS provides a complete record of the analysis. There is no site-specific evidence in these 

comments other than the commenter's opinion that the Horse Creek project is inconsistent with 

the Klamath Forest Plan as amended, or failed to follow the procedures of the National 

Environmental Policy Act. Project effects to all the resources that commenters expressed concern 
54

regarding salvage harvest are disclosed in the FEIS and supporting Resource Reports, included in 

the project record available on the project website, and will be considered by the Responsible 

Official in arriving at a decision. Commenters are encouraged to review the appropriate resource 

sections and reports for their specific concern.

Associated Comments:

Comment 

# Comments

1-31

Opposing Views Attachments #1, #4, and #21 would convince any intelligent person that 

logging and roading activities always degrade and often eliminate the capacity of a resource 

to function properly. The USFS finds it convenient to hide this information from the public.

1-43 Best science clearly indicates that post-fire logging causes significant, long-term, irreversible 

harm to the natural resources in the burned landscape.

1-45 No human development action in the forest inflicts more long-term ecosystem damage than a 

post-fire timber sale.

1-78

After a fire, the new forest is particularly vulnerable to logging disturbances that can set back 

the forest renewal process for decades. Post-fire logging has been shown to eliminate habitat 

for many bird species that depend on snags, compact soils, remove biological legacies (snags 

and downed logs) that are essential in supporting new forest growth, and spread invasive 

species that outcompete native vegetation and, in some cases, increase the flammability of the 

new forest." (pages 1 and 2)

4-6

I am opposed to large scale post-fire logging because logging can make fuel conditions 

worse, cause significant impacts to nearby salmon-bearing streams, affect threatened species, 

such as the northern spotted owl, and reduce habitat connectivity by creating a more fractured 

and distressed landscape.

368-4

The impact to connectivity, wildlife habitat, hydrology, water quality, soil stability and 

habitat complexity associated with large-scale post-fire logging as proposed by the KNF is 

significant.

368-64

salvage logging, through the removal of the snag patches and especially the removal of large 

diameter snags is detrimental to forest diversity, succession, and recovery and should be 

avoided especially in LSR forest, complex old stands and landscapes adapted to mixed or 

high severity fire.

368-82 The post-fire logging proposed in the project should be canceled due to extreme cumulative 

impacts.

368-89

post fire logging followed by tree planting will negatively impact the positive effects on fuel 

loading and create novel ecosystems where biologic legacies have been removed and habitat 

complexity has been greatly reduced. There is simply no ecologic benefit to logging these 

stands.

368-112

Post-fire logging will reduce habitat complexity, damage very sensitive schist soils, impact 

adjacent high mountain meadows and springs, reduce connectivity and impact the natural 

revitalization of fire affected plant communities. These impacts will compound the affects of 

climate change.

Comment Response #47: Survey and manage fungi determination

Concern statement:
55

There is a concern that the determinations made in the botanical resources report regarding the 

Survey and Manage fungi species are in violation with the management direction set forth for 

those species in the Northwest Forest Plan and the Klamath Forest Plan.

Forest Service Response:

The effects of action alternatives on Survey and Manage ectomycorrhizal fungi species was 

clarified to more accurately address long-term population viability. The original determination of 

"long-term decline in population viability" was in reference to the loss of ectomycorrhizal host 

trees located in areas proposed for hazard tree removal. However, trees slated for removal are 

dead or dying and will not continue to support ectomycorrhizal fungi symbionts in the long-term 

regardless of whether they are felled or not. Additionally, the known locations of these 

ectomycorrhizal fungi are located in areas characterized by no- or low-severity fire and, 

therefore, it is likely that very few hazard trees will need to be felled in this area and 

subsequently adequate host tress will be sustained to support ectomycorrhizal populations. 

Furthermore, populations and surrounding habitat will be flagged and any hazard trees felled 

within the flagged buffer will be left onsite limiting disturbance. Therefore, the determination 

has been updated to "indirect effects may result in a short-term population decline as host trees 

die or are felled, however, long-term population viability will remain static as trees natural 

regenerate in this area". This is in compliance with Survey and Manage direction for managing 

known sites.

Associated Comments:

Comment 

# Comments

516-77

The analysis of project effects on S&M and Sensitive species consists of conclusions without 

data. Despite the lack of data, at page 81 of the DEIS the agency is able to conclude that the 

indirect effects of its widespread logging activities in the project area "may result in a longterm decline in population viability" for numerous survey and manage fungi species. Neither 

the NW Forest Plan or the National Forest Management Act allow for this result.

Comment Response #48: Beneficial effects of salvage harvest

Concern statement:

There is a concern that salvage harvest does not have any beneficial effects.

Forest Service Response:

Forests affected by historic fire suppression, such as those affected by the Gap Fire and 

subsequently proposed for management under this project were overly dense and exhibited fuel 

loading (dead woody material) amounts that were generally greater than those present in a presettlement natural forest influenced by a natural fire regime (FEIS, Fuels Report, Chapter 3). The 

Gap Fire killed, but did not consume, trees in high-severity burn areas resulting in large amounts 

of dead heavy fuels. Untreated heavy fuel loading represents a greater risk of severe burning 

effects to replanted areas and other resources than areas that have fuels reduced through salvage 

harvest as described in the proposed action (FEIS, Chapter 3, Fuels Report). 

The project will reduce the risk of severe fire effects to planted trees and other resources by 

reducing heavy fuel loading. This is a beneficial effect to future forest development. Individual 

snags within harvest units will not be retained unless they have high quality habitat 
56

characteristics such as signs of decay and defect, cavities, broken or multiple tops, very large 

lateral branches and flattened canopy. In order to contribute to Recovery Action 12, very large 

snags that have these characteristics and are likely to persist until the next stand is capable of 

producing large snags should be retained wherever they occur, provided safety considerations 

can be addressed (FEIS, page 31).

Associated Comments:

Comment 

# Comments

1-69 Post-fire timber sales have no beneficial natural resource effects.

368-90 The logging of old growth snags and trees the agency suspects will die has no ecological or 

stand development benefit that has been demonstrated with credible science in the DEIS.

Comment Response #49: Salvage’s ability to promote forest recovery

Concern statement:

There is a disagreement regarding the ability of salvage harvest to promote forest recovery after 

a wildlife. The commenters state that the disturbance of salvage harvest will impede forest 

recovery.

Forest Service Response:

These comments argue that post fire logging will damage natural regeneration delaying recovery, 

and that slash from logging will increase fuel loads and subsequent fire risk. A paper by Donato 

et al. 2006 is offered in support of these arguments. A peer review response to Donato et al. by 

Newton et al 2006 ( M. Newton, S. Fitzgerald, R. R. Rose, P. W. Adams, S. D. Tesch, J. 

Sessions, T. Atzet, R. F. Powers, C. Skinner) found several concerns with Donato et al. Among 

the critiques was a (1) lack of context for the data, inferences about natural regeneration 

processes, mortality from logging, and fuel accumulations without presenting key information 

regarding (i) agency post-fire management directives for reforestation or downed wood levels 

(2), (ii) implications of delays in post-fire plan implementation, or (iii) important environmental 

and disturbance descriptors such as plant associations, fire intensity, seed tree proximity, and 

weather patterns. Results from their study cannot be readily extrapolated because it was a shortterm observational study of site-specific forest operations governed by agency management 

objectives. Donato et al. also failed to consider other conifer reforestation and logging studies, 

some more than 50 years old. Donato et al. drew their findings from a study of the Biscuit Fire 

where salvage occurred two years after the fire and activity fuels were not treated. Since logging 

was delayed, there was established natural regeneration around the edges of units. In the Horse 

Creek project, salvage will occur the first year following the fire, so it is unlikely there will be 

natural regeneration in large patches of high severity fire anywhere where there are not seed 

sources (FEIS page 215-219). It is unlikely that the damage to natural regeneration observed by 

Donato et al. will occur. Donato et al. (2006) suggest that post fire salvage logging can result in a 

pulse of fine fuels that can increase fire intensity and severity in the short term, but does not 

examine a scenario where post logging slash is treated in all harvested areas. Post-harvest 

treatment of slash is proposed in all alternatives (see Chapter 2 of the FEIS for full discussion of 

proposed Alternatives), and the predicted effects of this post-harvest treatment is a significant 

reduction both fine and coarse woody debris, as noted in Chapter 3 of the FEIS. This type of 

treatment for post-salvage fuels is called for by Donato et al. (2006) when they state "Our study 
57

underscores that, after logging, the mitigation of short-term fire risk is not possible without 

subsequent fuel reduction treatments." The Horse Creek project will treat activity fuels so the 

findings of Donator et al. 2006 with respect to increased fuels from logging do not appear to be 

relevant. See the Fire and Fuels report for a complete discussion of treatment of post-salvage 

activity fuels (FEIS 124-133). Comments suggest that post-fire reforestation considerations 

relied solely on a paper by Zhang et al. 2008. That is not correct. Peterson (2015), Shatford et al. 

(2007) Knapp et al. (2012), McDonald an Fiddler (1989), Lowell et al. 1992), Skinner et al. 

(2006) and others are among the cited papers used to evaluate post-fire conditions. Finally, stand 

data was compiled from existing plots in the project area and used to simulate future stand 

conditions based on proposed treatments. The Forest Vegetation Simulator (FVS) was used to 

estimate the time needed to establish conifer-dominated stands (FEIS page 213). FVS is a stateof-the-art vegetation model that is widely used to model vegetation response after logging or 

other disturbance events such as wildfire. 

Associated Comments:

Comment 

# Comments

1-79

"Foresters commonly argue that post-fire logging removes dangerously flammable dead 

wood, and that forests recover faster when logged and replanted. But Dan Donato, a graduate 

student who conducted the new study with five colleagues, found that areas of the Siskiyou 

Mountains burned by the 2002 Biscuit Fire were bristling with naturally established conifer 

seedlings two years later. The researchers also found that subsequent salvage logging killed 

three-quarters of the new trees, and elevated fire danger by scattering tinder on the ground."

1-81

"Our data show that postfire logging, by removing naturally seeded conifers and increasing 

surface fuel loads, can be counterproductive to goals of forest regeneration and fuel 

reduction. In addition, forest regeneration is not necessarily in crisis across all burned forest 

landscapes. The results presented here suggest that postfire logging may conflict with 

ecosystem recovery goals."

516-1

As the quotations by the author of the NW Forest Plan above indicate, and as will be 

discussed in these comments, post-fire salvage logging does not contribute to the 

"restoration" of forest ecosystems. Rather, the significant impacts of commercial salvage 

logging inhibit forest recovery and increase future fire hazard. It is incontrovertible that a 

strong consensus exists among fire ecologists that post-fire salvage logging impedes and 

delays forest recovery.

516-28

While ignoring or discounting the vast body of peer-reviewed studies regarding the 

significant environmental impacts of salvage logging, the Horse Creek Salvage Logging 

DEIS repeatedly references "Zhang et al. 2008" to support the controversial contention that 

"reforestation would restore the desired forested environment faster than natural 

regeneration." Please note that the "desired forested environment" referenced by Zhang et al. 

consists of industrial forestlands in the Southern Cascade Mountain Range managed by 

Roseburg Forest Products (with herbicide application and clearcutting) to "provide 

harvestable yields in about 30 years." (Zhang, page 429). In contrast, the Horse Creek 

Salvage planning area is located in the Klamath Mountains, like the forest stands studied by 

Donato et al. Our organizations provided a copy of the Donato study to the agency during 

project scoping. Yet, curiously, the DEIS largely ignores Donato's findings regarding natural 

post-fire reforestation in the Klamath Mountains on federal lands. For instance the 

silivculture section of the DEIS simply ignores the findings of the Donato study that 

undermine the agency's clearcut logging agenda. Is the Forest Service proposing to clearcut 
58

Comment 

# Comments

the existing LSR snag forest, utilize herbicides and manage these stands on 30 year rotations? 

If not, why is the agency basing its analysis on a reforestation study conducted on private 

industrial forestlands in the Cascade Mountain Range, rather than one conducted on Forest 

Service lands regarding the effects of salvage logging on reforestation in the Klamath 

Mountains?

Comment Response #50: Schist soils, wetlands, and wet meadows

Concern statement:

There is concern regarding the effects of the proposed activities specifically within areas of 

schist soils, wetlands, and wet meadows including the risk of erosion, watershed health, soil 

productivity, natural fire recovery, and compaction.

Forest Service Response:

The parent material for the soils (Schist) was taken into consideration in analysis contained 

within the Soils Resource Report, the parent materials present and how they respond to analysis 

indicators is described in the affected environment section of this report. Rubber tired skidders 

and crawler tractors ("cats") would be restricted to designated skid trails and less than 35 percent 

slope in all alternatives (FEIS viii). This substantially reduces soil impacts from ground skidding 

logs. The erosion hazard rating for the schist soils was used in the analysis for soils effects and 

the project design features are sufficient to avoid unnecessary negative effects from taking place 

within these area (FEIS Chapter 3 Soils). The effects from the fire were discussed in the affected 

environment section of the Soils Resource Report and in the Gap Fire BAER report which was 

also referenced in and incorporated into the Soils Resource Report. The effects of ground based 

harvesting were also discussed in the Soils Resource Report and were estimated to have 

beneficial effects, such as disturbance breaking up the fire induced hydrophobic layer and the 

hydrologic stabilization of existing skid trails that are currently contributing sediment. Concerns 

for landslides and road placement are addressed in the Geology Resources Report. Any new 

temporary road or landing construction with potential to have adverse impacts will be field 

reviewed by a geologist prior to construction (FEIS 41-42). The project area has been reviewed 

by professional geologists and soil scientists. There are no known units located on active 

landslides. 

Associated Comments:

Comment 

# Comments

368-16

Live trees as well as dead trees will be logged, some units will be treated with ground based 

yarding doing severe damage to the highly erodible schist soils of the Condrey Mountain 

area.

368-91

Ground based logging and "temporary road" development on fire affected schist soils also has 

no positive result in terms of watershed health, soil productivity, natural fire 

recovery/revitalization.

368-135

ANN opposes tractor yarding on sensitive schist soils throughout the planning area. Turbidity 

and sedimentation is a problem in the Horse Creek watershed. The water quality impacts are 

effecting aquatic habitats and species including ESA listed coho salmon.
59

Comment 

# Comments

368-136

Damage to sensitive schist soils throughout the planning area is of concern, especially in 

relatively undisturbed areas at the headwaters of Buckhorn and Middle Creek. The planning 

area includes many historic landslides and the soils are highly susceptible to both compaction 

and erosion, including rill and gully erosion that disrupts hydrology. Many sensitive wetlands 

and wet meadows are located adjacent to or within logging units. These wetlands are the 

headwaters of Buckhorn Creek.

368-137

The potential impact to soils in this project is extreme, especially in ground based logging 

units. Post fire logging units on schist soils and on historic landslides or earthflows should be 

canceled.

Comment Response #51: No action alternative effects to soils

Concern statement:

There is a concern regarding the analysis of effects to soils resources under the no action 

alternative.

Forest Service Response:

This comment provided no evidence or analysis to support the opinion presented. The Gap Fire 

BAER report addressed the soil burn severity of the area and showed that there was a mosaic 

pattern of burn severity, in areas that burnt at low or no severity there still exists the risk of high 

severity wildfire effects. This project is intended to reduce those effects through the action 

alternatives. The damage the fire did to the soils was addressed in the Gap Fire BAER report and 

in the affected environment section of the Soils Resource Report. Soil burn severity is a measure 

of fires effects on soils and hydrophobicity is one of the factors. The acres of soils burn severity 

were incorporated into the analysis. Table 1 in the Soil Resource Report outlines the indicator 

conditions for soils assessment and Table 4 lists the indicators that were used in the analysis of

the area and the estimated acres not meeting desired conditions for each indicator.

Associated Comments:

Comment 

# Comments

1-86

You say there will be an increased accumulation of organic matter in terms of surface and 

ladder fuels knowing most organic matter (dead & dying trees) will be removed under the 

Proposed Action. You say "Years of fire suppression and past management activities have led 

to overly dense stands which have increased the risk of large-scale high severity wildfire. As 

fire intensity increases, the potential for soil organic matter destruction, nitrogen 

volatilization, microbial mortality, structure and porosity destruction, and inducement of 

water-repellency are greatly elevated." This is true. The Gap Fire started because of the 

"overly dense stands." The fire has already damaged the surface layer of soils by glassifying 

them (hydrophobic). You are terrified to admit this because it wouldn't portray No Action as 

a tragic option.

Comment Response #52: Soils Project Design Feature and BMP 

effectiveness

Concern statement:
60

There is a concern that the project design features and Best Management Practices are not 

sufficient to protect soils during post-fire logging operations.

Forest Service Response:

Please note that the Klamath National F 2012 Monitoring and Evaluation Report did not find 

disturbance above 15% in any unit, which is in compliance with the requirements of the Forest 

Plan. Desired soil conditions were met on 83 to 92 percent of the units monitored, Project Design 

Features and Best Management Practices have been effective in meeting desired soils conditions 

as shown through monitoring efforts on the Forest. Project design feature, Watershed-3 addresses 

the concerns raised on page 8 and 9 of the KNF 2012 Monitoring and Evaluation Report. 

Watershed 2 project design feature outlines the guidelines for soil disturbance in accordance with 

the Forest Plan.

Associated Comments:

Comment 

# Comments

516-55

Please note that the KNF FY12 Monitoring and Evaluation Report (page 8 and 9) discusses 

impacts of post-fire tractor yarding in the Panther Salvage timber and states: The majority of 

areas that did not meet desired [post project] conditions were located on primary skid trails 

and landings. Due to a lack of protective duff mat on the soil surface, and increased amount 

of disturbance was noted on secondary skid trails compared to green timber sales. 

Recommended changes to planning tractor yarding for salvage timbers sales is to reduce the 

extent of soil displacement and compaction by limiting slope steepness where skidding can 

occur or limiting the total area in the unit in primary and secondary skid trails. Alternatively, 

planners can reduce soil disturbance in fire salvage units by changing logging systems from 

tractor yarding to cable or helicopter yarding. The monitoring information above, developed 

by the Klamath National Forest, indicates that BMPs and PDFs are not sufficient to protect 

soils during KNF post-fire logging operations. KNF post-fire timber practices are not 

sufficient to meet Forest Plan soil standard 3-2.

Comment Response #53: Salvage increases fire severity

Concern statement:

There is a disagreement regarding the findings of the FEIS that salvage harvest will reduce fire 

severity in the project area. The commenters contend that fire severity and the risk of future 

wildlife increases as a result of salvage harvest, or at least does not decrease the likelihood of 

reburn in the treated stands.

Forest Service Response:

Some research suggests that fire severity and the risk of future wildfires increases as a result of 

salvage harvest (e.g. Dellasala et al. 2006, Donato et al. 2006, and Thompson et al. 2007. Donato 

et al. (2006) suggest that post fire salvage logging can result in a pulse of fine fuels that can 

increase fire intensity and severity in the short term, however the paper does not explain the 

results in a scenario where post logging slash is treated in all harvested areas. Post-harvest 

treatment of slash is proposed in all Alternatives (see Chapter 2 of the FEIS for full discussion of 

proposed Alternatives), and the predicted effects of this post-harvest treatment is a significant 

reduction both fine and coarse woody debris, as noted in Chapter 3 of the FEIS. This type of 

treatment for post-salvage fuels is called for by Donato et al. (2006) when they sate "Our study 
61

underscores that, after logging, the mitigation of short-term fire risk is not possible without 

subsequent fuel reduction treatments." The Horse Creek project will treat activity fuels so the 

findings of Donato et al. 2006 with respect to increased fuels from logging do not appear to be 

relevant. See the Fire and Fuels report for a complete discussion of treatment of post-salvage 

activity fuels (FEIS 124-133). McIver and Starr (2000) are also cited extensively but this 

literature review is now 17 years old and does not incorporate more recent studies on this topic. 

Many of these studies did not have post-salvage treatments similar to those proposed in the 

Horse Creek Project. The Fire and Fuels Report states "the short-term effect of salvage harvest is 

an elevated surface fuel loading from branches, cull logs, and un-merchantable tops followed by 

a much longer period of reduced surface fuel loading relative to burned stands that were not 

logged." (Fuels Report page 22). The Fire and Fuels Report also states that for action alternatives 

there are "follow-up treatments of site preparation following salvage harvest. This treatment is 

aimed at reducing surface fuel loading (in all fuel size categories) from activity fuels generated 

by the salvage harvest, breaking up continuous fuel beds and reduction in fuel bed depth. Postlogging fuel treatments, such as piling and burning or broadcast burning (jackpot burning), can 

rapidly reduce total amounts and spatial continuity of surface woody fuels, and may allow 

logged stands to serve as fuel-breaks in a landscape-level fire management strategy (Peterson & 

Harrod, 2010). In addition, Peterson, Dodson, and Harrod 2014 found that post-fire logging 

altered post-fire fuel succession by (1) greatly accelerating the deposition of surface woody fuels 

from logged snags, (2) reducing peak loading of large diameter woody fuels, and (3) initiating 

the woody fuel decay earlier. Ritchie, Knapp and Skinner (2012), evaluated salvaged units 

following the Cone Fire on the Lassen National Forest. They found that after four years higher 

levels of surface fuel accumulations occurred in lower intensity salvage plots. The highest 

surface fuel accumulations occurred in un-salvaged plots four to either years after the fire. 

Furthermore, the highest surface fuel accumulations were associated with un-salvaged areas. 

Ritchie et al. (2012) observed that areas that were salvaged to remove heavy fuels had lower fuel 

loading after eight years than areas that were un-salvaged. Activity fuel treatment following 

salvage harvest would reduce fuel loading even further within salvage units." (Fire and Fuels 

Report, page 22). Dunn and Bailey (2014) also found that salvage logging significantly reduces 

coarse woody fuel loadings after approximately seven years, which likely reduces re-burn hazard 

for several decades depending on available 1000-hour fuel loadings (Dunn and Bailey, P. 107). 

This is consistent with site-specific fuel modeling and with other literature considered in the final 

FEIS, notably Peterson et al. (2015). We agree that logging can increase slash loads and hence 

fire risk if those activity fuels are not treated. In the Horse Creek Project, activity generated slash 

will be burned reducing surface fuels to levels consistent with low fire hazard. The vast majority 

of plantations within the Gap Fire footprint burned at low severity during the fire. We saw this 

same pattern in the Westside Fires of 2014 where 70 percent of the burned plantations survived 

(Westside Fire Recovery EIS, page 163). As noted in the Fire and Fuels report, page 23, 

"Weatherspoon and Skinner 1995 and Peterson et al. 2009 both found that fire intensity and 

damage to the overstory are much lower in plantations where slash has been removed following 

logging. A high percentage of plantations in the Gap Fire burned at low severity." The Horse 

Creek Project proposed site preparation treatments following logging, increasing the likelihood 

that the plantations will burn at low severity fire and would burn less severe compared to the no 

action alternative.

Associated Comments:
62

Comment 

# Comments

1-53 You have already had your "high severity" fire. Even if a reburn were a possibility it would 

certainly not be "high severity" given the fact that most trees burned.

1-58 the USFS's claim that the chances of a reburn increase if the post-fire landscape is not logged 

is another USFS lie to convince the public post-fire logging is the professional thing to do.

368-38

Fuel analysis in the DEIS is inadequate and does not incorporate the best available science. 

Many studies have shown post-fire logging and reforestation (e.g. planting) is positively 

correlated to increased fire severity. In a recent literature review conducted by J.D McIver 

and L. Starr, over twentyone separate scientific papers studying the effects of salvage logging 

found these activities to contribute to fire and fuel risks.

368-39

"there is no scientific evidence that supports the claims that post fire salvage and replanting of 

conifers reduces the intensity or severity of subsequent fires. On the contrary, post fire 

salvage logging has been shown to actually increase future fire risks because of the buildup of 

fine combustible fuels in the short term." (Strittholt, 2004, P. 6)

368-44

In a study conducted in the Biscuit Fire Area researchers found the following key findings: 1) 

Salvage logging does not reduce reburn potential 2) Severe re-burn is driven by the structure 

of young vegetation and regeneration not by residual woody material from previous fire. ( 

Donato, 2008) The researcher stated that " if the management objective is to reduce the risk 

of high severity reburn, post fire management of deadwood may need to focus on nonmerchantable material, which makes up a large portion of residual deadwood and is the most 

available fuel." The KNF salvage proposal in the Gap Fire is focused on logging trees 18" 

and larger, fuels that do not significantly contribute to the spread or intensity of a fire.

368-49 areas salvage logged after the 1987 Silver Fire burned with twice as much high severity fire 

than in unsalvaged stands (Harma, 2003 P.82).

368-50

Thomas Spies found areas salvage logged burned 16%-61% higher during the Biscuit Fire 

than in unsalvaged areas. He concluded that "the hypotheses that salvage logging followed by 

planting reduces burn severity is not supported by the data." He found this to be true even in 

stands that were salvage logged and broadcast burned; this is due to the vegetative diversity 

and small gaps found in naturally recovering forests. (Spies, 2007)

368-57 To claim post fire logging will reduce future fuel risks and wildfire severity in the project 

area is unsubstantiated, unfounded, and contrary to the best available science.

Comment Response #54: Site specific soils effects analysis

Concern statement:

There are concerns regarding the effects analysis for soils resources including site specific 

analysis of landing locations, skid trails on slopes greater than 35%, cumulative impacts from 

adjacent private industrial post-fire logging, and the number of project area acres with a potential 

for accelerated erosion.

Forest Service Response:

Analysis regarding effects to soils resources from landings and skid trails is site specific and was 

evaluated at the unit level to identify conditions within which landings or skid trails may be 

placed. Project Design Features were developed to respond to the potential effects resulting from 

landing or skid trail placement within the conditions that exist within the project area and within 

units. Landings which do not require further development, such as existing roadbeds, will be 

preferentially used wherever possible. In the final EIS, Project Design Feature Geology-5 (FEIS 
63

page 43) was modified to require a field review by a geologist prior to any landing construction 

with cuts or fills greater than 5 feet or on slopes greater than 20%. The intent of this modification 

is to ensure that any landing construction is stable and will not cause excessive erosion that is

expected to contribute sediment to streamcourses within the project area. In the Soils Resource 

Report, landing locations were included in the analysis for projected disturbance for the road 

system and a summary of the analysis can be found under the section for temporary roads and 

landings. The amount of ground disturbed by potential skid trails is captured in the Soils 

Resource Report as part of the analysis of area meeting (or not meeting) Forest Plan Standards 

and Guidelines. This is evaluated as a percentage not meeting standards and guidelines with a 

threshold of fifteen percent for detrimental effect to soil productivity, and ten percent for 

compaction induced reduction of porosity. Project design feature Watershed-3 was specifically 

designed for slope limitations on skid trails and limits skidding on over 35% slopes to straight up 

and down patterns if the soil texture can tolerate this activity. Additionally, project design feature

Watershed-6 requires the placement of waterbars on skid trails and dispersal of slash over skid 

trails to preclude detrimental runoff which could cause channel formation or deliver sediment to 

streams. Cumulative impacts for soils were analyzed on a unit by unit basis as the soils analysis 

is bound by unit boundaries where effects to soils as a result of project activities are likely to take 

place. Furthermore, adjacent private operations would only have the ability to cause cumulative 

effects to sedimentation which is discussed in the Hydrology Resource Report and not included 

in the soils analysis. Table 4 in the Soils Resource Report references estimated acres not meeting 

desired conditions for soil erosion, this was measured as part of the indicator for soil stability and 

discussed in the analysis, the acres not meeting desired conditions for soil erosion was 

determined to be under the threshold of concern and is in compliance with the Forest Plan 

guidance and direction.

Associated Comments:

Comment 

# Comments

516-54

The KNF offers no explanation for why it intends to conduct actions that will result in 

undesirable soil conditions that violate forest plan standards throughout the planning area. 

While the Draft Logging Systems Supplemental Report (un-paginated) indicates that the 

Forest Service intends to construct between 70 and 100 new log landings in the naturally 

recovering post-fire watersheds, the location and impacts of these landings is not disclosed, 

analyzed or quantified in the NEPA document.

516-56

Please note that the soils analysis contained on page 215 of the DEIS assumes that tractors 

will be restricted to slopes less than 35% in areas with sandy soils. In fact skid trails will be 

authorized at the whim of the Forest Service on slopes greater than 35% as acknowledged on 

page 36 of the DEIS. Yet the location, number and impacts of skid trails on slopes greater 

than 35% is not analyzed or disclosed in the NEPA document.

516-57

Please additionally note that neither the DEIS or the Draft Soils Report even acknowledge, let 

alone quantify or analyze, the ongoing significant cumulative impacts to soils from adjacent 

private industrial ground-based post-fire clearcutting activities in the project area.

516-58

Shockingly, page 56 of the DEIS indicates that only 14 acres out of the over 2,200 acres of 

proposed post-fire logging will not increase the potential for accelerated erosion. In other 

words, nearly all of the acres proposed for clearcut salvage logging will increase the potential 

for accelerated soil erosion.
64

Comment Response #55: Soils effects analysis

Concern statement:

There are concerns that project related impacts to soils resources including compaction, 

displacement, soil porosity, productivity, stabilization, and erosion need to be analyzed and 

disclosed in the environmental documents for the project.

Forest Service Response:

The analysis indicators for determining the effects to soil resources for this project are soil 

stability, soil organic matter, and soil structure, these indicators are sufficient in demonstrating 

compliance with all applicable law, policy, and regulation regarding soil resources including 

compliance with Forest Plan Standards and Guidelines. The analysis for soil resources included 

an analysis of the current existing disturbance for each indicator within each salvage unit of the 

project area as a baseline for determining the effects. See page 7 of the KNF 2012 Monitoring 

and Evaluation Report referenced in the Soils Resource Report for tractor yarding in fire salvage 

effects on the Forest. 

Impacts to soils resources in the project area from project activities can only be analyzed after 

project activities have taken place, monitoring efforts from previous projects are used to 

determine effects in the project planning stages. It was noted in the soils report that logging slash 

from salvage harvest would increase soil cover. In accordance with the Forest Plan, up to 15% of 

a harvest unit can have detrimental disturbance before it significantly effects soil productivity. 

For compaction the Forest Plan allows for 10% or more reduction in the soil porosity of the 

surface soil. The majority of the soils in the project area are expected to have a moderate 

compaction risk rating based on texture and fragment content, this is discussed in further detail in 

the Soil Resource Report. Compaction is also more of a concern depending on the soil moisture 

when the harvesting occurs, project design feature, Watershed-14 references the Forests wet 

weather operations standards which were based on local data and designed to minimize 

compaction. 

The temporal boundary for soil strength and structure outlined in the soils report is 30 years and 

compaction has been shown to not hinder the long term productivity of the site (Conifer Root 

Proliferation after 20 Years of Soil Compaction, Matt D. Busse, Gary O. Fiddler, and Carol J. 

Shestak). Project design features have been applied to this project to ensure that detrimental 

disturbance stays under the threshold outlined in the Forest Plan (under 15%). 

Compaction will take place on the landings and skid trails. Project design features Watershed-6 

and -8 are designed to ensure hydrologic stabilization to reduce run-off from these areas. Postharvest soil cover guidelines will be addressed through project design feature Watershed-9 which 

addresses soil cover, fuels concerns, and run-off in accordance with the Forest Plan. Since this is 

a burned area there are areas of fire induced hydrophobicity and as discussed in the Soils 

Resource Report tractor disturbance can actually aid in breaking up the hydrophobic layer which

helps to increase moisture infiltration. Also, as discussed in the soils report, the existing skid 

trails are large sources of sediment and hydrologic stabilization of these areas has the potential to 

decrease the sedimentation.

Associated Comments:
65

Comment 

# Comments

368-61

Salvage logging negatively effects nutrient replenishment by damaging, compacting, and 

eroding soil resources during falling and yarding operations. Salvage logging can also cause 

"onsite impacts to early successional native plant species...where species are nitrogen fixers, 

(salvage) can significantly affect a major pathway of nutrient replenishment." (Beschta, 2004)

368-138

The agency must fully analyze the impact of compaction and soil disturbance associated with 

post fire logging and ground based yarding on soil erosion, soil compaction, soil productivity, 

water quality and water holding capacity in a FEIS.

516-50 Please note that dying trees assist in post-fire soil stabilization and restoration via needlecast.

516-82

Heavy machine use in timber sale units causes soil compaction and displacement. Soil 

compaction is an increase in bulk density with a corresponding decrease in soil porosity. 

Compaction reduces soil productivity through a reduction in root growth, tree height, and 

timber volume (Greacen and Sands 19802; Froehlich and McNabb 19843) and may be 2 

Greacen, EL and R Sands. 1980. 1980 Compaction of forest soils. A review. Australian 

Journal of Soil Research. 18(2):163-189. 3 Froehlich, HA, and DH McNabb. 1984. 

Minimizing soil compaction in Pacific Northwest forests. In EL Stone (editor) Forest Soils 

and Treatment Impacts. Proceedings of 6th North American Soils Conference, June 1983, 

University of Tennessee, Department of Forestry, Wildlife and Fisheries, Knoxville, TN. P 

159- 192. produced by a single pass of logging equipment across a site (Wronski 19844). 

Productivity losses have been documented for whole sites (West and Thomas 19815) and for 

individual trees (Froehlich 19796, Helms and Hipkin 19867). Decreases in important 

microbial populations have also been observed in compacted soils (Amaranthus et al.

516-83

Soil compaction may also increase surface runoff because of reducing infiltration (Graecen 

and Sands 1980.)9 Soil displacement from ground-based machine use occurs when the 

tracked equipment turns on its skids pushing the soil into small piles, or berms, along the skid 

trails. This displacement of the topsoil removes the organic litter layer and exposes mineral 

soil. Removal of the loose, organic surface materials promotes surface sealing and crusting 

that decreases infiltration capacity and may increase erosion (Child et. Al. 1989.)10 Soil 

displacement also results in a loss of important soil biota, such as mycorrhizal fungi, which 

facilitates nutrient uptake by plants (Amaranthus et al. 1989 and 1996.)

Comment Response #56: Mechanical piling effects to soils

Concern statement:

There is a concern regarding the direct and cumulative effects of mechanical piling on soils 

resources because of the potential for harmful impacts including increased ground disturbance, 

compaction, and soil displacement.

Forest Service Response:

The Soils Resources Report was updated to include an analysis of the effects of mechanical 

piling within ground-based units. In summary, the results of this analysis show that disturbance 

to the soil from machine piling is not expected to disturb any additional acres than those already 

disturbed by other ground based logging activities. Please refer to the Ground-based tractor 

logging section of the Alternative 2 direct and indirect effects analysis provided in the Soil 

Resource Report available in the project record and on the project website. 
66

Post-harvest soil cover guidelines will be addressed through project design feature, Watershed-9 

which addresses both soil cover and fuels concerns in accordance with the Forest Plan. Retention 

of large and coarse woody debris are addressed in project design feature Watershed-1 for large 

woody debris retention on the landscape and project design feature, Wildlife-6 for the retention 

of existing woody debris across the landscape. In response to the literature provided by the 

commenter regarding soil crusts: The majority of the area in the Horse Creek Project is steep 

timber ground with low pH soils and the BLM publication references that soil crusts form on 

flatter chaparral areas with high pH soils. The local disturbance monitoring report performed in 

2012 was referenced in the Soil Resource Report furthermore the projected disturbance was 

taken from soil monitoring data on the Forest from 1998 to 2014, local data collected on Forest is 

determined be the most relevant. In accordance with the Forest Plan, up to 15% of a harvest unit 

can have detrimental disturbance before it significantly effects soil productivity in that unit. 

Project design features have been applied to this project to make sure detrimental disturbance 

stays under 15%. project design feature, Watershed-2 defines detrimental soil disturbance 

according to the Forest Plan and limits that disturbance to 15% of the harvest unit, slope 

restrictions for ground based equipment are explained in project design feature, Watershed-3, 

and the re-use of old skid trails is covered under project design feature, Watershed-21 for 

minimizing compaction and other soil disturbances.

Associated Comments:

Comment 

# Comments

516-78

The Horse Creek salvage logging DEIS does not disclose and analyze the impacts, location, 

acreage or science surrounding the significant direct and cumulative impacts associated with 

proposed machine piling activities.

516-79

Please note that recently your colleagues in the Six Rivers National Forest 

concluded: "Machine piling/burn piles would increase ground disturbance and soil 

displacement when the machine turns." -Little Doe and Low Gulch Timber Sale DEIS p 110. 

No similar analysis or disclosure is present in the Horse Creek DEIS.

516-80

Mechanical piling is universally recognized as an outdated practice that has 

disproportionately harmful significant impacts on watershed and soil resources. Please 

see: Evelyn Bull et al. Trees and Logs Important to Wildlife in the Interior Columbia River 

Basin PNW-GTR-391 (1977). BLM, USGS, Biological Soil Crusts: Ecology and 

Management (Technical Reference 1730-2 (2001) (Available from BLM Publication 

Management Distribution Service, Bldg 41, E-16 (BC-650B) Denver, CO 80255 We further 

encourage the agency to examine the soil compaction monitoring reports from 1985 through 

1997 on the Payette National Forest. While the Payette contains different ecotypes and soil 

types than does the Horse Creek project area, the monitoring reports clearly show long-lasting 

and significant soil damage from tractor piling activities. Similar monitoring in the Idaho 

Panhandle (Jerry Niehoff) and the Kootenai National Forest (Lou Kuennen) demonstrate 

significant impacts to soils. We also encourage the agency to review the findings of Geppert, 

R.R., Lorenz, C.W., and Larson, A.G., 1984. Cumulative Effects of Forest Practices on the 

Environment: A State of the Knowledge. Wash. For. Practices Board Proj. No. 0130, Dept. of 

Natural Resources, Olympia, Wash.

Comment Response #57: Impacts to the PCT experience and economics

Concern statement:
67

There is concern that the Forest did not take an adequate "hard look" at the impacts to the Pacific 

Crest Trail in regards to both the recreational experience and the economic benefits it provides. 

There is a concern regarding the effects of the project on characteristics of the Pacific Crest Trail 

such as a healthy intact ecosystem and the use of popular campsites.

Forest Service Response:

As stated previously in response to public scoping comments: As mandated, we used the 

Klamath National Forest Land and Resource Management Plan for direction in the Recreation, 

Wild and Scenic River, and Scenic Resources Analysis. Appropriate project design features 

respond to the variety of proposed management activities and current conditions to ensure 

ongoing sustainability and restoration within the recreation/aesthetic/ecological frameworks. 

Furthermore, management goals stated in the Forest Plan for Management Area 11 (Retention 

VQO) allow for programmed, sustained harvest of wood products in areas capable, available, 

and suitable for timber management, as well as allowing for the maintenance of stand health and 

resilience to wildland fire, insect, disease, and other damage. In the Scenery chapter of the FEIS

we disclose that visual standards for partial retention may not be met in several areas (FEIS page

199). By proposing this action, and disclosing that visual standards would not be met in some 

locations, the Forest Supervisor has determined that reestablishing forest vegetation was more 

important than meeting visual standards within established time periods. To mitigate potential 

impacts on visual resources, several project design features have been incorporated into the 

Horse Creek Project (FEIS, page 55-57). Standard and Guideline 11-7 allows more time to 

accomplish visual objectives. The only proposed management activity that may directly affect 

the Pacific Crest National Scenic Trail is hazard tree removal, which would occur along an 

approximately quarter-mile segment where the trail parallels National Forest System Road 

47N81. Per the FEIS, page 204, "The Pacific Crest National Scenic Trail will be analyzed for the 

quarter mile segment alongside National Forest System Road 47N81 where roadside hazard tree 

removal is proposed; however, the remainder of the trail was unaffected by the Gap Fire, and it 

was determined through field observation that proposed treatments near the Siskiyou Crest will 

not be seen from the trail corridor due to remaining green tree vegetation." None of the 

additional proposed treatments will directly affect the Pacific Crest Trial corridor in the Project 

area that would necessitate trail closures, and therefore, would not affect any potential campsites 

along, or adjacent to the trail corridor. Also, field visits indicated no campsites along the trail 

within the quarter-mile segment included in the analysis for hazard tree removal.

Associated Comments:

Comment 

# Comments

368-17 The Pacific Crest Trail (PCT) also runs through the headwaters of Buckhorn and Middle 

Creek and would be impacted by old-growth post fire logging.

368-102

The PCT runs directly above areas targeting for old growth, post-fire logging in Upper 

Buckhorn Creek. Given the international acclaim of the PCT and the continuing popularity of 

the trail, it would be unwise to log so close to the trail. Maintaining a healthy, intact 

ecosystem along the PCT corridor is consistent with the current and expected future 

recreational use of the area and the economic vitality the PCT brings to the region.

368-103 DEIS analysis did not take a "hard look" as is required under NEPA to identify impacts to the 

PCT experience from the proposed logging project. The agency did not adequately analyze 
68

Comment 

# Comments

the impact of degrading the PCT on both the recreational experience and the economic 

benefits it provides.

368-105

Logging units will be located adjacent to the meadows at Buckhorn Spring Camp, a nice PCT 

campsite. The area should be utilized and developed for primitive PCT recreation rather than 

logged. Another popular PCT is located on the trail above Alex Hole. Logging units will be 

located on the slopes south of the PCT which are utilized by recreational hikers. The intact 

nature of the area surrounding the PCT is part of the trails appeal and should not be degraded 

for the minimal economic value that fire-salvaged timber represents. Folks utilizing the PCT 

and hunters in the fall, utilize the area around Buckhorn Spring their experience will be 

degraded if logging occurs.

368-116 The forests targeted for post fire logging on upper Buckhorn Creek are particularly important, 

as they are directly adjacent to the PCT.

515-9

Our members regularly enjoy hiking the PCT along the Siskiyou Crest in the project area. We 

are concerned about the impacts salvage logging will have along the PCT in the project area. 

As botanists do, we often leave the trail in search of botanical interests, so even if logging 

does not occur directly next to the PCT, the overall PCT experience will be negatively 

impacted if logging were to occur near the PCT within a short off-trail walk. Although visual 

impacts from the trail will occur, please don't limit your consideration of the visual effects of 

salvage logging along the PCT, but the overall wildland experience the PCT was created to 

offer.

Comment Response #58: Visual impacts to the PCT

Concern statement:

There is a concern regarding the visual impacts to the Pacific Crest Trail and the resulting effects 

to the recreational experience as a result of project activities including salvage units and hazard 

tree removal. Recommendations for cut tree marking and stump height and direction were 

proposed by commenters as means to mitigate some of these impacts.

Forest Service Response:

Per the FEIS, page 204, "The Pacific Crest National Scenic Trail will be analyzed for the quarter 

mile segment alongside National Forest System Road 47N81 where roadside hazard tree removal 

is proposed; however, the remainder of the trail was unaffected by the Gap Fire, and it was 

determined through field observation that proposed treatments near the Siskiyou Crest will not 

be seen from the trail corridor due to remaining green tree vegetation." 

As stated previously in response to public scoping comments: As mandated, we used the 

Klamath National Forest Land and Resource Management Plan for direction in the Recreation, 

Wild and Scenic Rivers, and Scenic Resources analysis. Appropriate project design features 

respond to the variety of proposed management activities and current conditions to ensure 

ongoing sustainability and restoration within the recreation/aesthetic/ecological frameworks. As 

noticed in the Scenic Resource analysis (FEIS, page 207), "Successful project design feature 

implementation would not prevent these effects from being completely unnoticeable; however, 

they would minimize the effects to fall within the Forest Plan thresholds for visual quality 

objective standards and guidelines." 
69

The following project design features were used to minimize negative effects of that either 

directly or indirectly relate to the Pacific Crest National Scenic Trail within the project area are 

described in Chapter 2 of the FEIS and include: Recreation and Scenic Resources 3, Recreation 

and Scenic Resources 5, and Recreation and Scenic Resources 9 and 10, which directly protects

the Pacific Crest National Scenic Trail from damage during the implementation of roadside 

hazard tree activities. Other possible project design features were considered, but not included, 

based on the level of proposed treatment (hazard tree removal) adjacent to the Pacific Crest 

National Scenic Trail and National Forest System Road 47N81, and professional judgment.

Associated Comments:

Comment 

# Comments

368-104

Logging treatments would be visible from the PCT and will impact the recreational 

experience of trail users on the PCT. Protecting the remaining intact forest adjacent to the 

trail is necessary to protect the internationally renowned values of the PCT. Impacts to the 

PCT and the immediate environment surrounding the PCT should be minimized by canceling 

all units adjacent to the Siskiyou Crest from Dry Lake Mountain and Windy Camp to 

Condrey Mountain and Reeves Ranch Spring.

368-106

From portions of the PCT the upper end of logging units will be visible near Condrey 

Mountain these units should be canceled. In this same location hazard tree falling will impact 

the intact nature of the trail and the forest surrounding the trail. Efforts should be made to 

minimize hazard tree removal by ensuring only trees obviously threatening to fall in the road 

are removed. Stumps could be cut low with the angle of the cut stump facing away from the 

trail.

996-1

In reviewing the DEIS documents, including project area maps for Alternative 2 and the 

associated resource reports, it appears there are three harvest units (117.15, 118.03, and 

118.06) within close proximity to the PCT immediately south of the Crest. Additionally, 

while the PCT is north of the 47N81 road in this area it does parallel the road closely in some 

areas. And, the proposed hazard tree cutting along the quarter mile of road the PCT is closest 

to could dramatically affect the viewshed of the PCT and the experience of the trail user.

996-2

Specific to hazard tree operations within site of the PCT, using cut tree marking and cutting 

stumps as low to the ground as is feasible and angling the cut faces away from the trail will 

help to minimize visual impacts to the trail in the short term. In addition, hand raking ground 

disturbance associated with the logging activity would also help maintain the scenic integrity 

of the PCT. Lastly, being thoughtful and removing as few hazard trees as possible within 150

feet of the PCT.

996-3

A project of this scale warrants a field visit with Forest staff. I can personally commit to 

making myself available in a timely manner this summer for field visits to the section of road 

between Reeves Ranch Spring and Alex Hole to review potential impacts on the PCT. I look 

forward to working together to enable appropriate removal of hazard trees along the road 

while also protecting the scenic integrity of the Pacific Crest National Scenic Trail.

996-4

I understand that none of the aforementioned harvest units will overlay the PCT and should 

be screened from view. However, in the event of future wild fires it is possible the units may 

become visible. And as a point of reference regarding harvest units within close proximity to 

the PCT, the Hat Creek Ranger District of the Lassen National Forest implemented the visual 

mitigation measures below during a similar timber operation near the PCT following the 

Reading Fire: * Protect NFS trails, including the Pacific Crest National Scenic Trail, from 

damage during implementation of the proposed activities. * Equipment crossings would be 

limited to designated crossings. The trail tread would be restored at crossings. * No leave-tree 
70

Comment 

# Comments

marking would be applied within 150 feet of NFS trails falling within Retention (R) and 

Partial Retention (PR) VQO classes. * Stumps would be cut to a maximum of 8 inches within 

50 feet of NFS trails. * To minimize soil displacement, avoid turning equipment within 50 

feet of NFS trails. * Activity-generated fuels created within 150 feet of NFS trails, 

viewpoints, and other high-use areas would be piled and burned or removed within one year 

of operations. Piles would be located a minimum of 100 feet from trails and trailheads. * In 

areas of high recreational use, some vegetation, where available, would be left along the edge 

of trails and roads. Residual vegetation can act as a visual barrier to discourage future 

unauthorized routes. I look forward to speaking with Forest staff about how similar 

mitigation measures will be implemented during the Horse Creek project implementation in 

order to meet the Visual Quality Objective of Retention for the area near the PCT as is 

identified in the DEIS documents. Additionally, I appreciate the Klamath National Forest 

being thoughtful in regards to timber operations, including both hazard tree removal and 

harvest units, within close proximity to the PCT. And to reiterate, a field visit to the affected 

section of PCT on this project is crucial to the planning process for the Horse Creek Project.

Comment Response #59: Salvage does not promote fire adaptability

Concern statement:

There is a concern that salvage harvest will not promote the ability of Klamath forests to become 

fire-adapted and fire resilient landscapes, and that such claims by the Forest Service be supported 

by analysis.

Forest Service Response:

Some research suggests that fire severity and the risk of future wildfires increases as a result of 

salvage harvest (e.g. Dellasala et al. 2006, Thompson et al. 2007). However, many of these 

studies did not have post-salvage treatments similar to those proposed in the Horse Creek 

Project. The Fire and Fuels Report states "the short-term effects of salvage harvest is an elevated 

surface fuel loading from branches, cull logs, and un-merchantable tops followed by a much 

longer period of reduced surface fuel loading relative to burned stands that were not logged." 

(Fire and Fuels Report, page 22). The Fire and Fuels Report also states that for action 

alternatives there are "follow-up treatment of site preparation following salvage harvest. This 

treatment is aimed at reducing surface fuel loading (in all fuel size categories) from activity fuels 

generated by the salvage harvest, breaking up continuous fuel beds and reduction in fuel bed 

depth. Post-logging fuel treatments, such as piling and burning or broadcast burning (jackpot 

burning), can rapidly reduce total amounts and spatial continuity of surface woody fuels, and 

may allow logged stands to serve as fuel-breaks in a landscape-level fire management strategy 

(Peterson & Harrod, 2010). The treatment strategy for the Horse Creek Project are aimed at fireadapted and fire resilient landscapes." (Fire and Fuels Report). Variable density planting and 

species are proposed to mimic a more natural stand for the site specific location. Many factors 

such as aspect, slope and historical species composition will play a role in the specifics for 

plantations. Site preparation prior to planting along with maintenance and allowing prescribed 

fire to play a role in plantations once conditions are ready will increase fire-adapted and fire 

resilient landscapes.

Associated Comments:
71

Comment 

# Comments

368-59

no scientific study to date has substantiated claims that salvage logging and tree planting 

encourages a healthy and natural recovery of forest associations. On the contrary, salvage 

logging tends to degrade soil, vegetation, and aquatic resources and decrease biodiversity, 

creating simplified plantation stands, not patchy and fire adapted native ecosystems. It does 

not facilitate forest development or reduce fuels.

515-2

The SCNPSO opposes large-scale, post-fire logging, especially on the Siskiyou Crest, in Late 

Successional Reserve (LSR) forest, and in areas that burned within the range of variability for 

wildland fire in the Klamath Mountains. How are we ever going to achieve fire resilient 

forests without allowing wildfires to recover naturally? Salvage logging sets back the goal of 

fire-adapted forests and fire resilient landscapes.

589-7

Here, the Forest Service states that the hazardous trees and fuel conditions need to be abated, 

with a higher priority near private property in burned areas caused by the Gap Fire. It states 

that this will significantly decrease the future risk of fires spreading and harming fire 

suppression crews and residents at risk. The agency states that these actions will also increase 

the resiliency of the forest so that future fires can be effectively controlled. The Forest 

Service must provide support for these claimed needs, demonstrating how removing 

vegetation will increase the resiliency of the forest.

Comment Response #60: Effects to Visual Retention VQO

Concern statement:

Commenters expressed concern regarding impacts within the Visual Retention VQO in 

Management Area 11 and the resulting effects to the Siskiyou Crest and the recreational value of 

the PCT, Buckhorn Springs Camp, Windy Camp, the Condrey Mountain Geologic Area, and the 

Condrey Mountain Back-Country Area.

Forest Service Response:

As stated previously in response to public scoping comments: As mandated, we used the 

Klamath National Forest Land and Resource Management Plan for direction in the Recreation, 

Wild and Scenic River, and Scenic Resources analysis. Appropriate project design features 

respond to the variety of proposed management activities and current conditions to ensure 

ongoing sustainability and restoration within the recreation/aesthetic/ecological frameworks. 

Furthermore, management goals stated in the Forest Plan for Management Area 11 (Retention 

VQO) allow for programmed, sustained harvest of wood products in areas capable, available, 

and suitable for timber management, as well as allowing for the maintenance of stand health and 

resilience to wildland fire, insect and disease, and other damage. In the scenery chapter of the 

FEIS we disclose that visual standards for partial retention may not be met in several areas (FEIS 

page 199). By proposing this action, and disclosing that visual standards would not be met in 

some locations, the Forest Supervisor has determined that reestablishing forest vegetation was 

more important than meeting areas within established time periods. To mitigate potential impacts 

on visual resources, several project design features have been incorporated into the Horse Creek 

Project (FEIS, page 55-57). Standard and Guideline 11-7 allows more time to accomplish visual 

objectives: 11-7: " In the case of recovery activities after extreme catastrophic events such as 

intense wildland fires, time periods to achieve the VQOs stated in Forest-wide and Management 

Area Standards and Guidelines may be extended. This would be necessary where previously 
72

unnoticed scenery alterations are exposed to view due to loss of vegetative screening, or during 

timber salvage activities where recovery of forest vegetation is determined to be of greater 

importance than achievement of VQOs within the time periods established."

Associated Comments:

Comment 

# Comments

368-113

ANN opposes post-fire logging in Visual Retention Areas on the Siskiyou Crest. Protecting 

these viewsheds and designated Visual Retention Areas will protect the recreational value of 

the PCT, Buckhorn Springs Camp, Windy Camp, the Condrey Mountain Geologic Area, and 

the Condrey Mountain Back-Country Area. 215 acres of Visual Retention VQO, management 

area 11 will be logged in Alternative 2 in the DEIS.

368-114 Logging in or adjacent to management area 11 lands will impact viewsheds, naturally 

appearing forests, and will by no means, limit the signs of management activities.

368-115 Numerous units are located within a Visual Retention VQO Area on the Siskiyou Crest. 

These units should be canceled in the Record of Decision

368-117

The post-fire logging units proposed in the project would degrade important visual resources. 

Proposed treatments would not provide "attractive scenery" or "naturally appearing 

conditions". According to Visual Retention VSO "visual considerations" should take 

precedence over aggressive timber harvest. Post-fire logging proposed in the project will 

drastically alter visual characteristics adjacent to the PCT and the Siskiyou Crest. Historic 

camping and recreation areas such as Buckhorn Springs Camp and Windy Camp along with 

Special Interest Areas such as the Condrey Mountain Blue Schist Geologic Area and Condrey 

Mountain Backcountry Area will be impacted by post fire logging. The viewshed of many 

important management designations or recreational opportunities will be significantly 

degraded.

368-118 All units in Visual Retention VSO areas should be canceled to protect important viewsheds, 

naturally appearing landscapes and attractive scenery as mandated in the Forest Plan.

Comment Response #61: Analysis of Visual Quality Objectives

Concern statement:

There is concern regarding the attainment of visual quality objectives throughout the project area 

in both retention and partial retention visual quality objective areas. There is concern over the 

use of a Forest Plan Standard and Guideline allowing project activities to forgo VQOs in the 

short term.

Forest Service Response:

Several comments suggested that the Forest Plan visual standards are not being met and that 

Standard and Guideline 11-7 was being misapplied because the Gap Fire was not catastrophic 

since only about 17 percent of the fire was a moderate or high severity burn. There is no 

definition of "catastrophic" in the Klamath Forest Plan glossary. In general terms, the word 

"catastrophic" is taken to mean a sudden and negative change in condition. It is within the 

discretion of the Forest Supervisor to determine when a fire event is catastrophic in the context 

of the Forest Plan. The Gap Fire burned over 21,000 acres of national forest land and another 

12,400 acres of private land, and demonstrated fire behavior that by all accounts was unusually 

intense. There are several large high burn severity patches in excess of 100 acres and at least one 

that is in excess of 1,000 acres. Nearly all of the Horse Creek SIA experienced high severity fire 
73

where all of the old growth riparian vegetation was killed. Within the Horse Creek Community, 

several homes and outbuildings were lost to extreme fire behavior. The Purpose and Need 

section of the FEIS in Chapter 1 describes conditions created by the Gap Fire that do not meet 

the desired condition described in the Forest Plan. The Proposed Action was developed in 

response to those conditions. A concern for visual effects was noted on scoping comments (FEIS 

page 25). In the Scenery chapter of the FEIS we disclose that visual standards for partial 

retention may not be met in several areas (FEIS page 199). By proposing this action, and 

disclosing that visual standards would not be met in some locations, the Forest Supervisor has 

determined that reestablishing forest vegetation was more important than meeting visual 

standards in those areas within time periods established by the Forest Plan. To mitigate potential 

impacts on visual resources, several Project Design Features have been incorporated into the 

Horse Creek project (FEIS page 55-57). Standard and Guideline 11-7 (printed in its entirety 

below) allows more time to accomplish visual objectives. “11-7 In the case of recovery activities 

after extreme catastrophic events such as intense wildland fires, time periods to achieve the 

VQOs stated in Forest-wide and Management Area Standards and Guidelines may be extended. 

This would be necessary where previously unnoticed scenery alterations are exposed to view due 

to loss of vegetative screening, or during timber salvage activities where recovery of forest 

vegetation is determined to be of greater importance than achievement of VQOs within the time 

periods established.”

Associated Comments:

Comment 

# Comments

516-85

The scenery analysis contained at 180 of the DEIS indicates that the KNF intends to conduct 

salvage logging activities such that "some recreational settings would be adversely affected in 

the short term from project activities not meeting visual quality objectives." Indeed, as 

discussed on page 190 due to proposed clearcutting "large openings will be created with high 

line and texture contrasts..." At 191 the DEIS indicates that in the timber sale will violate 

VQOs in retention and partial retention areas. At DEIS 191 the Forest Service claims that it 

can conduct clearcutting that violates VQOs following "extreme catastrophic events such as 

intense wildland fires." Yet no showing is made that the Gap Fire was extreme or 

catastrophic. Indeed, according to the Forest Service only 17% of the fire area burned at 

either a moderate or high severity. Additionally, the Forest Service neglects to disclose the 

impacts of proposed green tree logging throughout the project area on VQOs.

516-86 Page 227 of the DEIS indicates that the Forest Service intends to ignore its own Visual 

Quality Objectives from the Klamath River by heavily logging unit 116.49.

Comment Response #62: Treatment timeline urgency

Concern statement:

Commenters expressed concern that implementation needs to be expedited without delay in order 

to avoid future timber revenue loss and to accomplish the critical safety and restoration results 

needed to protect the Horse Creek Community.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 
74

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

2-12

However, in order for this project to accompli sh the desired safety and restoration results 

stated in the purpose it needs to be expedited without delays. Delays will result in less acres 

being treated or restored.

520-1

We would also like to express the overwhelming need to expedite this Project in order to 

avoid further timber revenue loss and to accomplish the critical safety and restoration results 

needed to protect the Horse Creek Community, and the need to complete the National 

Environmental Policy Act (NEPA) process by summer 2017, to allow work to commence at 

the earliest possible time.

Comment Response #63: Balanced alternative to meet multiple needs

Concern statement:

There is a concern regarding the division in alternatives to meet varying interests, and a 

recommendation to look for the most balanced approach that can be implemented broadly, and as 

soon as possible.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. We agree with you that project 

proposals should be tailored to the needs of individual areas, and we have tried to do this with 

the Horse Creek Project. Your suggestion aligns directly with our Forest Service mission “to 

sustain the health, diversity, and productivity of the nation’s forests and grasslands to meet the 

needs of present and future generations.” The challenge is determining how to incorporate and 

balance often competing needs and desires, as described in the draft record of decision. 

Associated Comments:

Comment 

# Comments

518-7

Is it not an option, for the Karuk lands to see their proposal enacted, the Crest wilderness 

region have theirs and the Horse Creek Residential Community have their own? Can not 

these proposals be tailored to individual areas? There may not be a "one size fits all" solution, 

however there needs to be a balance maintained in addressing the complex and varied issues; 

the potential for future severe wildfire near homes, the economic stability of the affected 

community and the private timber company, the wildlife habitat and other ecological factors. 

Whatever plan is implemented, I do believe that the priority should be that it be implemented 

broadly, and as soon as possible, without the delays that we know seem to be inherent in 

Federal government decisions.

Comment Response #64: Recommendations for activity fuels treatment

Concern statement:
75

In response to concerns about the accumulation and disposal of post treatment activity fuels 

commenters provided recommendations including manual piling or underburning rather than 

tractor piling, and to implement whole tree yarding out of commercial units.

Forest Service Response:

The intent of the project is to remove heavy fuel loading to desired levels to prevent high 

intensity and severe fire into the future. We appreciate the recommendation of manual and 

underburning, as well as whole tree yarding, over tractor piling of material. The recommendation 

to use whole tree yarding is an option to effectively reduce fuel loadings. During contract 

development the agency will require whole tree yarding in as many ground based yarding units 

as feasible. Many of the salvage harvest and roadside hazard units will be conducted using 

manual and underburning methods. In order to be cost effective and treat more acres to desired 

levels, we have analyzed for tractor piling as a means to remove heavy fuel loadings. Leaving all 

these tools available will allow the project to meet desired conditions and the purpose and need 

more readily. We will consider these recommendations as we lay out units for pre- and postsalvage harvest treatments. Thank you for your recommendation.

Associated Comments:

Comment 

# Comments

516-81

Manual piling or underburning is far preferable to tractor piling. Manual piling and 

underburning have none of the negative impacts to soils associated with tractor piling, and 

they provide an increased opportunity for local employment while significantly reducing 

long-term damage to soil health and productivity. Hence manual piling or underburning 

would better achieve the stated purpose and need for the project. Given that these practices 

can reduce fuels without the negative impacts associated with machine piling, they are 

reasonable to implement and reasonable to consider and analyze as an action alternative.

519-11

One mechanism by which the Forest Service could reduce the risk of post- logging fuel 

accumulation is to require whole tree yarding. Please consider whole tree yarding as a project 

requirement. If the Forest Service does not require whole tree yarding, please explain why.

Comment Response #65: Logging systems and layout recommendations

Concern statement:

In response to concerns regarding the layout of the commercial units, commenters provided 

recommendations including marking all cull trees before logging for snag retention, and to 

review the mark to ensure that trees that continue to persist are marked for retention.

Forest Service Response:

There is no intent to remove hardwoods or cull trees. Hardwoods are not included timber and 

would only be cut in salvage units if they pose a hazard to operations. Cull trees will be marked 

for retention before operations begin as will trees with high quality habitat characteristics such as 

signs of decay and defect, cavities, broken or multiple tops, very large lateral branches and flattened 

canopy (FEIS page 31). If these trees must be felled for safety reasons, they will be left in place. 

Standing dead trees 14 inches diameter at breast height or greater would be considered for 

salvage using the guidelines in Report #RO-11-01 "Marking Guidelines for Fire-Injured Trees in 

California" (Smith and Cluck 2011). Fire-killed and fire-injured trees with a 70 percent or greater 
76

probability of dying within the next three to five years would be considered for salvage harvest. 

The "Marking Guidelines for Fire-Injured Trees in California" also addresses the evaluation of 

trees with signs of insect activity. Trees with this evidence will be removed as described by the 

guidelines.

Associated Comments:

Comment 

# Comments

519-5

Snag retention requirements are included in the project. However, as experienced in the 

Westside Project, these snag retention requirements are difficult to interpret, implement and 

verify. The project notes that "cull" trees will be left of the landscape and that cull trees tend 

to possess characteristics consistent desirable for wildlife and will therefore benefit wildlife. 

If this is true, please mark all cull trees before logging begins. In monitoring for snag 

retention for the Westside Project, we often found trees that we thought were wildlife legacy 

trees that were not marked for retention because the marking crew believed them to be cull 

trees. This caused considerable headache and confusion for both the public and the U.S. Fish 

and Wildlife Service.

593-4

Remark Units: EPIC has some concerns with tree marking. EPIC noticed multiple trees 

which appeared to survive the fire and were well situated to continue to survive into the 

future that were not marked for retention. These trees will help to stabilize slopes and will 

provide seed source for natural regeneration only if they are allowed to stand.

593-10

Some larger trees with high amounts of green foliage were not marked, as shown below. 

EPIC volunteers did not notice any snags—trees without any sign of green limbs—being 

marked for retention. No hardwood snags were marked for retention.

Comment Response #66: Salvage in Riparian Reserves and Special 

Interest Area

Concern statement:

There is concern for the effects of salvage harvest in riparian reserves and the Horse Creek 

Special Interest Area. These comments state that such activities are inconsistent with the Forest 

Plan, especially where the standard for large in stream woody debris is not met, and should at 

least be limited to areas that burned at high severity.

Forest Service Response:

The project proposes only to treat hazardous fuels and fall hazard trees in Riparian Reserve and 

the SIA. Riparian Reserve areas are not proposed for salvage harvest. In Riparian Reserve and 

the SIA, felled trees qualifying as in-stream large woody debris (those 24 inches in diameter or 

greater) will not be removed (except as described below), and will contribute large woody debris 

to the stream channel and the associated Riparian Reserve area. Felled trees greater than 24 

inches diameter will only be removed under the following circumstances; where large woody 

debris requirements have been met and fuel loading is excessive. Removal may also take place if 

a felled tree would threaten the function of a drainage structure or cause stream diversion, or if a 

felled tree presents a safety hazard (see PDF Fisheries-3). Snags which do not represent a hazard 

will be retained. The project is consistent with the Forest Plan standards and guidelines for 

Riparian Reserves, the SIA, and ACS goals and objectives. Forest Plan standards and guidelines 

for Riparian Reserves do not limit the Forest from removing hazard trees, and state "Fell trees in 
77

RR when they pose a safety risk. Keep felled trees on-site when needed to meet CWD 

requirements" (MA 10-58).

Associated Comments:

Comment 

# Comments

368-124

Ecological processes such as wildfire, including high severity fire are essential to maintain 

complex, late seral habitat conditions on the KNF. Removing the large fire killed trees is not 

consistent with maintaining the unique features and ecological processes of the Botanical 

Area, especially within the riparian reserve of Horse Creek. Post-fire logging within a 

riparian area and botanical preserve designated for "old-growth riparian vegetation" is simply 

not supported by the best available science.

368-125

post-fire logging is not consistent with the protection of old growth characteristics or the 

development of future old growth conditions. Removing the large fire killed trees will 

diminish important biological legacies that add structural complexity to the surrounding 

terrestrial forest habitat, to the forest floor and as in stream wood to stabilize Horse Creek and 

create important pool habitat.

368-126

The KNF can not credibly contend that post fire logging of large old growth trees will 

"promote the management goals of the special interest area to protect "old-growth riparian 

vegetation."

368-127

The logging of "old growth riparian vegetation" that the area was designated to protect does 

not enhance or emphasize the unique resource for which the area was designated. Old forest 

logging is also obviously inconsistent with the recommendation that "few signs of 

management activities" should be present. Neither does the proposed action constitute "minor 

vegetative clearing."

368-130

Riparian Areas subjected to high severity fire should be treated to maintain the largest 

number of fire killed snags. In areas subjected to high severity fire, the retention of large 

snags will be especially important and will be the only wood inputs to the stream and for soil 

and habitat concerns for many decades, perhaps centuries.

368-133

According to the Horse Creek Watershed Assessment page 5-15 not a single reach in Horse 

Creek watershed including Buckhorn, Middle and Horse Creek, meet the 20 pieces/mile 

requirement in the Forest Plan. Thus post fire logging in Riparian Reserves is inconsistent 

with the Aquatic Conservation Stratedy (ACS) and MA10-54B. Surely post fire logging is 

not required to meet the ACS objectives as identified in MA10-54.

368-134

No credible science supports post fire logging in Riparian Reserves. All post fire logging 

proposed in Riparian Reserves should be canceled, especially given the deficiency in large in 

stream wood throughout the entire Horse Creek watershed.

515-4

This timber salvage project has proposed to implement old growth, post-fire logging at the 

headwaters of Buckhorn Creek and Middle Creek, in an area known for its habitat 

connectivity corridor. The Klamath National Forest (KNF) has proposed to clear-cut 2,257 

acres of fire-affected forest in Buckhorn, Middle and Horse Creeks. The project will log 

many biologically important areas, including the Johnny O'Neil LSR and the Horse Creek 

Botanical Area designated to protect complex old forest habitat. The SCNPSO does not 

support any logging in LSRs or Botanical Areas.

Comment Response #67: Credibility of effects analysis and project goals

Concern statement:
78

There is concern over the credibility of the effects analysis and ability of the project to meet its 

stated objectives in the purpose and need.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation. The Forest Service is an 

agency that strongly promotes sustainable conservation land management practices. We are 

mandated by law to achieve quality land management under the "sustainable multiple-use 

management concept" to meet the diverse needs of people while protecting the resource. The 

evaluation of all alternatives analyzed in the FEIS relies on best relevant science to the project 

area. Activities proposed under the action alternatives are feasible to implement and are expected 

to meet the objectives presented in the purpose and need statements in the FEIS. All action 

alternatives considered in detail were developed to meet the purpose and need of the project; in 

choosing a selected alternative, the Responsible Official will consider how well each alternative 

meets the purpose and need (FEIS, page 22).

Associated Comments:

Comment 

# Comments

1-33 Agency line-officers expect their IDT members to write anything to assure the Proposed 

Action will be selected for implementation. They enthusiastically comply.

1-34

Untrue No Action effects write-ups describe the disasterous effects of doing nothing. This 

scheme has been effective. Think about it. NEPA requires the Responsible Official to 

consider the No Action alternative. The No Action alternayive has not been chosen for a 

timber sale NEPA document nationwide for decades. Do you think they really considered it? 

With the help of the IDT's Chapter 3 No Action lies perhaps they did. Even a child knows it's 

better to do nothing than do something bad. Here are examples of the No Action effects 

disclosure for most resources in Chapter 3 of the Horse Creek draft EIS. Most are so untrue 

and so pathetic they are almost comical:

1-38

How is the public supposed to have confidence in the DEIS findings and conclusions after 

reading the illogical, conjured-up, untrue Chapter 3 predicted effects? The judge won't be 

fooled, especially when the plaintiff has an independent scientist testify. The judge will know 

this expert isn't motivated by pleasing his/her supervisor with volume.

1-46

Anyone (including the USFS Responsible Official and IDT members) who spends the 

American tax dollar planning and preparing a post-fire timber sale knowingly plunders public 

land for personal gain ... expanded promotion possibilities in an agency with a overriding 

timber agenda.

4-8 To simply ignore this alternative is simple dereliction of duty by a public/government 

employee and organization.

384-1

The proposal to heavily log remote backcountry native forests, and to punch new logging 

roads into headwaters of the south side of the Siskiyou Crest does not reflect the values that 

most Americans place on these public lands. By targeting remote native post-fire forests the 

Klamath National Forest loses the social license and credibility that are needed for true 

collaboration, community protection, and restoration following wildfire events.
79

Comment 

# Comments

516-93

Despite the fact that the Horse Creek watershed is currently over the Threshold of Concern 

for watershed health and contains listed fish, it is preordained and inevitable that the agency's 

salvage logging agenda will trump the conservation obligations of the NWFP, the CWA and 

the Basin Plan. Page 143 of the DEIS indicates that "it appears that Alternative 3 poses the 

lowest risk of increasing sediment delivery to streams and further degrading of aquatic 

habitats."

979-1

By cutting remote native post-fire forests, the Klamath National Forest loses the social license 

and credibility that are needed for true collaboration, community protection, and restoration 

following wildfire events.

Comment Response #69: Collaboration and public values over salvage

Concern statement:

Commenters expressed concern that additional collaboration and public involvement would build 

project objectives and outcomes that better fit with values held by the commenters.

Forest Service Response:

The Klamath National Forest agrees that public involvement is extremely important to identify 

values and issues that are important to local communities, tribes, our recreating public, and 

citizens across the country who are actively interested in the management of our federally 

managed public lands. Collaboration is also a very useful tool, but is more appropriate for 

projects that can incorporate the time needed to successfully collaborate without having 

detrimental impacts on the landscape. Throughout development of the Horse Creek Community 

Protection and Forest Restoration Project, we have reached out to our interested and affected 

public through the scoping process, public meetings and field trips, and the public review of the 

DEIS and associated comment period. We have consulted with the Karuk Tribe and met with the 

Shasta Indian Nation and Shasta Tribe, Inc., as well as with the Horse Creek Fire Safe Council, 

Seiad Fire Safe Council, and KS Wild. Throughout the planning process, we have coordinated 

with our professional peers in the US Fish and Wildlife Service, National Marine Fisheries 

Service, and the North Coast Regional Water Quality Control Board. Ten formal public meetings 

have been held between mid-November of 2016 and early June 2017, with another planned in 

July, 2017. The issues raised and comments received have assisted the Forest in developing 

robust alternatives that effectively respond to the concerns brought forward. For a full 

description of public involvement, please see the Public Involvement Section of Chapter 1 of the 

FEIS and the Scoping Outcome Summary on the project website. 

The Forest Service is an agency that strongly promotes sustainable conservation land 

management practices. We are mandated by law to achieve quality land management under the 

"sustainable multiple-use management concept" to meet the diverse needs of people while 

protecting the resource. As an additional point of clarification, we are proposing salvage harvest, 

with follow-up site preparation and reforestation. In the Horse Creek Project, we are assessing 

individual trees, on a case-by-case basis, for their ability to survive the effects of the Gap Fire, 

and salvage harvesting those trees determined likely to not survive at the 70 percent criteria. 

Additionally, we no longer conduct "clearcut" harvest; this method of regeneration harvest was 

eliminated in 1994 with the implementation of the Northwest Forest Plan, which was 

incorporated into the Klamath’s Forest Plan and FEIS. The use of the proper silvicultural system 
80

proposed is crucial. Under the Forest Plan, we may propose Green Tree Retention (GTR) as a 

regeneration treatment if found to be the "optimum" system, but we must retain 15 percent of 

each stand (the largest/oldest stand component). GTR is a stand regeneration treatment, which is 

not the silvicultural system we are proposing for Horse Creek, as discussed in the Scoping 

Outcome Summary, DEIS, and FEIS.

Associated Comments:

Comment 

# Comments

155-2

I am deeply troubled by the continuing proposal to focus on clearcutting and road building 

following wildfires. Instead of clearcutting along the Siskiyou Crest, please work with 

communities, scientists, and the Karuk Tribe to develop real restoration plans that protect our 

wild areas, help conserve salmon runs, and prepare our forests for the inevitable future 

wildfires.

155-3

These are public lands owned by all Americans and I would like the Forest Service proposals 

to reflect the values that all Americans find in our shared heritage. It is not appropriate to 

only listen to industrial logging interests while shutting out other voices.

384-4

Please consider bringing people together and healing communities and forests through real 

restoration as opposed to controversial backcountry clearcutting that does nothing to protect 

homes or public lands values.

516-2

Our organizations are hopeful that the ecological impacts of salvage logging, the science 

regarding salvage logging and the content of these comments may influence the direction of 

this project- but we are concerned that the decision to authorize salvage logging across all 

land use allocations regardless of the ecological impacts may be preordained and inevitable. 

We submit these comments to the Klamath National Forest with the hope that the science, 

concerns and information contained within them will substantively influence project design.

593-5

EPIC visited the project multiple times during the DEIS comment period. EPIC first visited 

the units on May 19, 2017 and returned the weekend of June 9-11. EPIC groundtruthed three 

units and quickly reviewed several others

798-1 We would rather see better collaboration, community project, and restoration, instead of 

salvage logging with its damaging impacts.

Comment Response #70: LSR salvage, inconsistent with Forest Plan

Concern statement:

There is a concern that salvage logging in the LSR is not appropriate following a fire, and that 

salvage logging units in the LSR do not meet the criteria in the Forest Plan.

Forest Service Response:

A number of commenters have expressed a concern that salvage is not appropriate in an LSR, or 

that standards for stands proposed for salvage activity have been misapplied. 

All salvage harvest in this project is considered to reduce the risk of future high severity fire in 

accordance with the goals of the Forest Plan for fire management (4-8) which state: "Reduce 

unacceptable fuel buildups and potential acreage of future high intensity wildfires." The Forest 

Plan of the Klamath National Forest clearly anticipated that risk reduction salvage may be 

necessary in the late successional reserve land allocation, and provided project guidelines (Forest 

Plan page 4-86; MA5-27 to 29) to ensure that the objectives of the Forest Plan were achieved. 
81

The Forest Plan also provides general guidelines for salvage in late successional reserves when it 

is not specific to risk reduction (MA5-30-1 to MA5-30-11). These general salvage guidelines 

were considered in project design, however, the Forest Plan allows for some salvage operations 

that do not meet guidelines MA5-30 1 through 4 when the salvage is essential to reduce the risk 

of future risk of fire (MA5-30-5), as is the case in the Horse Creek Project. (FEIS page 13-14, 

62) 

The Forest-wide LSR Assessment for the Forest provides criteria for risk reduction, including 

salvage, in the LSR land allocation. A review by the Regional Ecosystem Office (REO), a 

coordinating body for implementation of the Northwest Forest Plan, determined that projects 

consistent with the recommendations of the KNF LSR assessment are not subject to further 

review by the REO, and may be implemented as designed. All of the action alternatives meet the 

criteria for risk-reduction salvage in the LSR assessment, and are not subject to further review by 

the REO. (FEIS page 62).

Several commenters expressed a concern that there were islands of green trees inside salvage 

units in conflict with direction in the Forest Plan and that these trees would be cut. This comment 

misinterprets the Proposed Action and alternatives as well as the Klamath NF Forest Plan. We 

agree that green trees in high severity burn areas should not be cut. We are not proposing to cut 

trees unless they are dead or they meet mortality guidelines. Decades of experience on the 

Klamath have shown the majority of trees with a 70 percent or greater chance of mortality 

immediately after the fire are very likely to die over the next three to five years. Table 8 on page 

48 of the Draft EIS shows that there are 95 acres of stands with 0% to 25 percent tree mortality 

and 69 acres with 25 percent to 50 percent tree mortality included in salvage units in the 

Proposed Action. These are measures of stand conditions based on RAVG data, not individual 

trees. These are typically smaller clumps of lower severity burn areas that are included in units 

because they imbedded in larger clumps of fire-killed trees that form the salvage unit. That a tree 

is in a treatment unit does not mean it will be cut. Any trees that do not meet the mortality 

guidelines (70 percent chance of dying) will be left regardless of fire severity in the stand where 

they are located. Conversely, trees that meet these guidelines and are likely to die can be 

harvested if they are in a unit. At the top of page 48 in the Draft EIS, the text notes "green trees 

that meet mortality guidelines will not be cut in any alternative." This discussion is found on 

page 59 of the FEIS. This is also clearly explained on in the description of the Proposed Action 

(FEIS page 30) and alternatives.

Associated Comments:

Comment 

# Comments

368-22

Salvage logging within LSR habitat in the Horse Creek drainage will have severe impacts to 

LSR values and is inconsistent with LSR standards and guidelines. For instance, the 

Standards and Guideline identified in the KNF Forest Plan MA 5-30 "Guidelines for salvage" 

discourage salvage logging in small openings less than 10 acres "because small forest 

opening areas are an important component of old growth forest." This guideline also states 

that "The potential for benefit to species associated with latesuccessional forest conditions 

from salvage is greatest when stand-replacing events are involved." In general, the Gap Fire 

was not a stand replacing event, but a natural mixed severity fire, with little to no 

environmental damage associated with fire effects and severities.
82

Comment 

# Comments

368-27

The Standards and Guidelines also discourage post fire activities in areas retaining over 40% 

canopy closure, and the removal of green trees within LSRs, stating that "all standing trees 

should be retained." Retaining "all standing trees" is functionally very different than logging 

green trees the agency suspects may die within five years.

368-36 The post-fire logging proposed is inconsistent with the KNF Forest Plan and is not 

scientifically justified.

516-10

Page 47 of the DEIS indicates that the alleged purpose of widespread LSR logging involves 

reducing the risk of future high severity fire and providing for firefighter and public safety. 

Yet page 48 of the DEIS indicates that 97 acres of the proposed LSR salvage logging will 

occur in stands with 0% to 25% tree mortality while 69 acres of LSR salvage logging will 

occur in stands with 25% to 50% tree mortality. Both the KNF LRMP and the NW Forest 

Plan expressly prohibit the post-fire logging of LSR stands that burned at these low 

intensities. Removing snags (and green trees) from LSR forest stands that have retained the 

majority of their green trees in no way reduces fire hazard or contributes to human safety. 

Rather, it is simply a timber grab that violates two applicable forest plans. Such logging will 

inhibit the objectives of the LSR management, decrease ecosystem recovery and resiliency, 

and increase the controversy surrounding the agency's salvage logging proposal.

516-20

MA-5 of the KNF LRMP only allows post-fire logging in LSRs "if it benefits habitat." As 

acknowledged by both the Forest Service and the BLM in many projects and contexts, 

salvage logging of LSRs does not benefit habitat. This is particularly true for the silviculture 

prescription in Horse Creek that call for new road construction, clearcut logging, and removal 

of snags and down wood likely to persist over time. FEMAT 1993, p. IV-36 states that 

"[m]anagement objectives [following natural disturbances in LSRs) should focus on either 

simulating natural succession or allowing it to occur unimpeded." The DEIS refuses to 

implement this guidance and commits the agency to removing forest structure in the LSRs 

and speeding plantation establishment specifically in order to avoid and prevent natural 

succession within the Reserves.

516-24

It is clear that the Forest Service logging agenda will inhibit, rather than recover, habitat for 

rare late-successional associated species. As stated on page 263 of the DEIS: "Alternative 2 

would result in decreased habitat connectivity in the Lower Horse Creek drainage. 

Alternative 2 would create more openings in Lower Horse Creek that would result in 

reducing the habitat connectivity form low to very low habitat connectivity." Achieving the 

management objectives of the LSR land use allocation and the resultant protection of at-risk 

species is simply not a priority from the Klamath National Forest. The DEIS fails to 

demonstrate that the Horse Creek project complies with the Northwest Forest Plan's standards 

and guidelines.

Comment Response #72: Hazards in riparian reserves, retain felled trees

Concern statement:

There is a concern that trees felled in riparian reserves and in the Horse Creek Special Interest 

Area as part of the roadside hazard removal treatment be left on-site as coarse woody debris as is 

the direction of our Forest Plan standards and guidelines, or used for watershed restoration 

purposes.

Forest Service Response:
83

In Chapter 2 of the FEIS, the treatment for Roadside Hazard Tree Removal was clarified to 

include the process for determining which roadside hazard trees within stream course riparian 

reserves would be left on site and which would be removed. It states, "Within stream course 

riparian reserves, roadside hazard trees equal to or greater than 24 inches diameter at breast 

height will be felled and left on site if the following criteria are met: 1) the faller can safely fell 

the hazard tree away from the road without causing excessive damage to residual tree crowns or 

boles; 2) removal would cause excessive soil disturbance such as gouging; 3) the tree does not 

lean towards the road; 4) once fallen the tree would not disrupt flow through a drainage structure; 

5) where leaving the felled tree would not contribute to or cause excessive fuel loading (this 

threshold may be met sooner in areas identified for fuels reduction); and 6) felled trees that are 

the furthest from the road, below the road, and on steeper slopes below the road will be favored 

for leaving. Hazard trees in stream course riparian reserves where these criteria are not met, or 

that are less than 24 inches in diameter at breast height, will be felled and removed." This is 

consistent with the Forest Plan standards and guideline for Riparian Reserves (RRs) which states 

"Fell trees in RR when they pose a safety risk. Keep felled trees on-site when needed to meet 

CWD requirements" (MA 10-58).

Associated Comments:

Comment 

# Comments

368-120 All felled trees should be maintained on site or utilized in the Horse Creek watershed for 

restoration purposes. No logs should be sold as commercial timber.

368-123

the retention of coarse woody debris is essential to manage the area in a way that is consistent 

with Botanical Area Standards and Guidelines and maintains the ESA listed Coho Salmon 

found in Horse Creek.

368-129

ANN opposes all forms of commercial logging in riparian reserves including commercial 

hazard tree felling. All trees felled should be left within the riparian reserve as coarse woody 

debris. Tree yarding will cause significant impacts to riparian areas and increase turbidity by 

disturbing soils.

368-132

The DEIS also proposes 18.8 miles of roadside hazard tree removal in riparian reserves. We 

would ask the agency to consider avoiding the impact of yarding in these sensitive areas. 

Prescriptions should leave all trees cut within the riparian reserve or felled into the riparian 

reserve as coarse woody debris and retained on site rather than yarded out and risk causing 

undue amounts of damage to the riparian area or causing sedimentation downstream.

516-35 Please note that the KNF LMRP standards and guidelines for Riparian Reserves (MA 10- 58) 

direct the Forest Service to "fell" as opposed to "remove" trees where they pose a safety risk.

Comment Response #73: Roadside hazards treatment on inaccessible 

roads

Concern statement:

There is disagreement regarding the roadside hazard tree removal on roads #46N36Y and 

#46N20YA, which are adjacent to units 118.64 and 118.63. The comment states that this road 

should not be treated for hazard trees as it is landlocked by private land and inaccessible to the 

public.

Forest Service Response:
84

The purpose and need for the project (FEIS, Chapter 1) clearly describes that there is a need for 

safe conditions for forest workers, firefighters, tree planters, recreationists, and adjacent private 

landowners, including and in addition to members of the public. While open public access is not 

available to all on these road segments, as the commenter correctly identifies, these roads are 

used by adjacent landowners, forest workers, firefighters, and tree planters who are also 

members of the public or Forest Service employees that the Forest Service seeks to provide safe 

conditions for when they travel on this road.

Associated Comments:

Comment 

# Comments

593-8

Units 118.64 and 118.63 EPIC intended to groundtruth these units but were stymied because

these units are only accessible on private roads. The project proposes roadside hazard tree 

removal through these units, however there is no official Forest Service road to access the 

unit and no road is shown on the transportation network. In short, EPIC is concerned that 

there is no need for roadside hazard here, given that there is no public road.

Comment Response #74: Roadside logging, economically driven

Concern statement:

There is a concern that roadside logging is being conducted in Reserve land use allocations for 

the purpose of economic value recovery instead of ecological objectives.

Forest Service Response:

This comment reflects the opinion of the commenter, not the content of the EIS. It is unclear in 

this comment what treatment the commenter is referring to when naming "roadside logging," or 

which "Reserve land use allocation" is being referenced. 

The purpose of roadside hazard removal is to remove trees that pose a danger to roads or the use 

of roads. The only criteria that are used are those are identified on pages 18 and 19 of the FEIS. 

Trees that are a hazard to the road, or trees that will become a hazard to the road because of 

probability of mortality would be removed. Standard and Guideline MA5-23 on page 4-86 of the 

Klamath Forest Plan specifically provides for cutting hazard trees in reserves. Trees may be left 

in circumstances where down wood is inadequate.

Associated Comments:

Comment 

# Comments

516-41

The Forest Service is proposing significant roadside logging in Reserve land use allocations. 

While the DEIS attempts to justify extensive roadside Reserve logging as related to the 

"safety" element of the project purpose and need, in fact the removal of roadside trees has 

nothing to do with public safety and is solely designed to accomplish the agency's economic 

preferences. Down wood recruitment serves the management goals for these land use 

allocations by providing for wildlife habitat, nutrient cycling and needed legacy forest 

structure. Its removal serves only economic, rather than ecological, objectives.

Comment Response #75: Roadside hazards, “true” hazards

Concern statement:
85

There is a concern that the felling of roadside hazard trees be minimized to true hazards to the 

road, which one commenter defined as those which are obviously dead and leaning into the road.

Forest Service Response:

Trees that are dead and lean toward the road would generally be marked as hazards. Other 

criteria identified in the FEIS would also apply. Guidelines that will be used to mark hazard trees 

and potential hazard trees are identified on page 18 and 19 of the FEIS.

Associated Comments:

Comment 

# Comments

368-119

ANN supports the non-commercial aspect of treatments proposed in the Horse Creek 

Botanical Area, although we would like to see hazard tree felling practiced judiciously to 

allow effective ingress and egress, while maintaining ecological values.

368-128

Hazard tree removal along the roadside above Horse Creek, should be minimized to include 

only true "hazard trees" leaning into the road and obviously dead. All trees felled should 

remain on site to stabilize soils, hold moisture, provide coarse wood to the adjacent stream 

corridor on Horse Creek and to create microclimate for regeneration.

Comment Response #76: Roadside logging, buffer distance

Concern statement:

There is a concern that the project will cut trees 250' above and below roads, potentially as a 

“clearcut” and in critical habitat. There is a concern that this width is inappropriate as trees will 

not fall onto the road from such distances.

Forest Service Response:

Criteria for hazard trees are disclosed on page 27 of the FEIS. The Horse Creek Project analyzes 

the effects of the project, as proposed. The DEIS described the larger area being evaluated and 

the GIS analysis used to refine the area of evaluation. The FEIS further refined those areas 

considered for roadside hazard treatment for the purposes of analysis. In all cases, the analysis in 

the final EIS analyzes the greatest possible impacts based upon the actions proposed, including 

roadside hazard treatments. Site-specific concerns and conditions were reviewed and considered 

during development of the proposed actions and its analysis. See the Project Design Features in 

Chapter 2 for roadside hazard treatments that addressed on a unit basis where such mitigations 

will be applied. Only trees that meet the treatment guidelines for hazard trees will be felled as 

described in Hazard Tree Guidelines for Facilities and Roads in the Pacific Southwest Region

(Angwin, 2012). The roadside hazard prescription only removes hazard trees. Clearcutting or 

removal of trees which do not pose a hazard is not proposed by the project.

Associated Comments:

Comment 

# Comments

516-38

In March 2015, the Roseburg BLM signed a decision record to implement the Rabbit 

Mountain Fire Safe Cow post-fire project located in the LSR land use allocation. Unlike the 

KNF, the Roseburg BLM must adhere to the Oregon and California Land Act which the 

BLM interprets as a "timber primacy" statute. Despite this, the BLM has taken a much 
86

Comment 

# Comments

different approach to LSR roadside logging then have KNF timber planners. Unlike the KNF, 

the BLM is limiting roadside "hazard tree" logging to a distance of "1.5 tree heights below 

roads, 1.5 tree heights above roads on slopes less than 35 percent, and 2.5 tree heights above 

roads on slopes greater than 35 percent." Further, "[o]nly trees that are dead will be felled" 

and "[w]here physically and operationally practicable, topping of dead hazard trees will be 

considered as an alternative to felling." The KNF roadside LSR and RR timber grab contains 

none of these sideboards. Instead, trees up to 250' feet above and below roads will be 

removed regardless of slope and live trees contributing to NSO suitable and critical habitat 

will be felled and removed.

516-39

When the Klamath National Forest signed the 2010 decision to log the Panther Salvage 

timber sale (a cumulative impact that is not fully disclosed and analyzed in the Horse Creek 

DEIS) the KNF authorized removal of alleged "hazard" trees up to 200' feet above and below 

logging roads. See Panther EA page 24. The KNF 2014 decision to log the Salmon Salvage 

timber also authorized removal of roadside trees up to 200' feet above and below roads. No 

explanation is provided in the Horse Creek DEIS of why KNF timber planners have now 

increased the size of post-fire roadside clearcuts by an additional 100' to a total of 250' feet 

above and 250' feet below roads in the Horse Creek timber sale. Inexplicably the KNF will 

now create a 500' foot wide post-fire clearcut along some roads rather than the previous 400' 

wide swath.

516-40

The DEIS indicates that the Forest Service intends to remove (and in some cases clearcut) 

dead and live trees up to 250' feet below roads and that some snags and trees located further 

than 250' feet above roads will be removed due to "slope." This can be contrasted with the 

Riparian buffer for non-fish bearing streams which is considerably smaller than 250'. The 

agency offers no rational explanation for why trees may travel further downhill to reach roads 

than to reach streams or how snags that are 150' in height will jump up hill for several 

hundred feet to reach logging roads.

Comment Response #78: Matrix salvage, economically driven

Concern statement:

There is a concern that the purpose of project treatments is economically driven and focused on 

the production of timber volume.

Forest Service Response:

The Forest Plan gives us overall objectives, standards, and guidelines for managing resources 

within specific areas of the Klamath National Forest. Timber management objectives in the 

Forest Plan direct the Forest to provide a maximum supply of wood products on regulated (also 

described as “matrix” lands) commercial forest land consistent with other resource values (Forest

Plan, page 3-18). As shown in Table 4 of the FEIS, there are 9,601 acres of regulated lands 

within the 40,834-acre project area (FEIS, pages 11-13). Of those, a maximum of 3,349 acres, or 

8.2 percent of the project area, are proposed for treatment following the standards and guidelines 

for regulated commercial forest lands. This includes, depending on the alternative, about 800-

1,400 acres (FEIS Tables 8 and 9) of proposed salvage harvest on matrix lands where timber 

production is an objective in the Forest Plan. The vast majority (31,233 acres, or 76.5 percent) of 

the project area falls within unregulated lands where other objectives such as reducing risks of 

stand replacement fire may apply. The scoping proposal (pages 4-7), DEIS (pages 10-14), and 
87

FEIS (14-18) clearly describe the Forest Plan direction that applies to these areas. In addition, 

meeting the local and national demand for wood fiber does not mean that other resource 

protections are not in place. Please see Chapter 3 of the FEIS for a full analysis of all impacts to 

resources, as well as the project design features (FEIS, pages 39-57), best management practices 

(FEIS, Appendix C), and other Forest Plan standards and guidelines (Forest Plan Consistency 

Checklist, available on the project website) that have been applied to ensure resource protection.

Associated Comments:

Comment 

# Comments

1-44 These dead and dying trees are orders of magnitude more important to the proper functioning 

of the ecosystem in a post-fire landscape than money.

1-85

The notion that corporate profit is more important than maintaining unique post-fire wildlife 

habitat clearly reveals you are willing to destroy a healthy forest ecosystem to increase the 

chances you will be promoted to a higher paying job by proving your ability to generate 

volume. This is criminal Supervisor Grantham. Here's one of your corporate-friendly 

purposes for this timber sale listed in the P&N at page 11: "Regulated (Matrix) Lands 

(Management Areas 13, 15 and 17) Harvests would be carried out for the following purposes: 

...... 3) to meet local and national demand for wood fiber" Supervisor Grantham, you excel 

at acting out the corporate lap-dog role as the USFS teaches you. No wonder you have been 

promoted to Supervisor.

Comment Response #79: Special Interest Area treatment support

Concern statement:

There is support for the treatments proposed for the Horse Creek Special Interest Area, including 

the decision to remove the building of temporary roads in the area from the proposed action 

between DEIS and FEIS. However, there is concern for the safety of forest workers using 

explosives to fell trees with intact rootwads.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation. All necessary steps will 

be taken to ensure the safety of project workers regarding the use of explosives or any other of 

the proposed activities.

Associated Comments:

Comment

# Comments

368-121

We support experimental felling with dynamite or by pulling trees over root wad and all, but 

we also believe safety for the workers should come first and only truly hazardous trees that 

would be most likely to fall directly into the road should be removed.

519-2 On our May 17, 2017 field visit with District Ranger Jeff Marzal and members of the ID 

Team it was stated that all "temporary" roads in the Horse Creek Special Interest Area have 
88

Comment

# Comments

been dropped from the project. We agree and appreciate this judgment and hope that it still 

stands. This is in sync with the management direction for this special area.

Comment Response #80: SIA, should do

Concern statement:

There is a concern for the project design of treatments in the Horse Creek Special Interest Area.

Forest Service Response:

The Horse Creek Special Interest Area treatments were designed to restore ecological functions 

to reflect the unique characteristics for which the Horse Creek Botanical area was designated. As 

described in Chapter 2 of the FEIS, hazard trees will be abated according to the same standards 

and guidelines as the treatment for Roadside Hazard Tree Removal except that, in addition to 

trees equal to or larger than 40 inches diameter at breast height being subjected to a 90 percent 

probability of mortality standard, any tree exhibiting high quality wildlife habitat characteristics 

(as defined in the FEIS) will also be subjected to the 90 percent standard. These marked hazards 

will be reviewed by resource specialists and identified to be used as 1) in-stream large woody 

debris; 2) forest coarse woody debris; or 3) stockpiled for future restoration work. Excess hazard 

trees less than 24 inches in diameter at breast height not meeting these needs would either be 

removed as a forest product or moved to a cull deck to be used as firewood or burned. Finally, as 

part of the restoration effort, portions of the Botanical Area would be planted or seeded with 

native, locally-sourced vegetation. 

For more information regarding the treatments proposed in the Horse Creek Special Interest 

Area, please see the "Restoration Activities in the Horse Creek Special Interest Area" section of 

Alternative 2 included in Chapter 2 of the FEIS.

Associated Comments:

Comment 

# Comments

515-5

Only necessary hazard trees should be cut in the Horse Creek Botanical Area. No commercial 

logging should take place in this special area. No artificial reforestation with nursery stock 

should be planted in the Horse Creek Botanical Area. Please minimize yarding impacts by 

leaving downed wood. Consider leaving as much woody debris and downed wood in the 

riparian area as possible. No trees from the botanical area should be sold. If hazard trees are 

cut they should only be used on site for riparian restoration work.

Comment Response #81: Reburn potential is a fraudulent statement

Concern statement:

There is a concern that the Forest Service is in violation of regulations regarding making 

fraudulent statements by claiming that the Horse Creek project area has the potential for reburn.

Forest Service Response:

One commenter asserted that the Klamath National Forest is in violation of Title 18, United 

States Code. To clarify, Title 18 of the United States Code deals with federal crimes and criminal 
89

procedure; it does not cover environmental analyses. 18 USC § 1519 applies to Federal 

investigations and bankruptcy, not to environmental impact statements. Even if 18 USC § 

1001(a)(2) were a relevant standard for this project, we have not knowingly and willfully made 

any materially false, fictitious, or fraudulent statement or representation. As stated in the Fire and 

Fuels Report, best available science describes that "Fire historically played a major role in 

shaping vegetation composition and structure in the project area (Agee 2007, Skinner et al. 2006, 

Taylor and Skinner 1998).” Further, "The historical fire regime of the Horse Creek Project area 

consists of frequent (about every 8 to 15 years) low to moderate intensity and severity fire; and is 

not stand replacing (Skinner 2006)." Additional relevant science, described in the Fire and Fuels 

Report, shows that "the proportion of high severity fire has increased substantially over historic 

norms. Areas that burn with high severity are likely to reburn with high severity, but with 

increased patch size. Said another way, high severity fire creates a positive feedback loop for 

more high severity fire (Thompson et al. 2007). The proportion of high severity fire, the patch 

sizes of high severity fire, and the frequency of high severity fire in the Klamath Province, all 

appear to be increasing when compared to historic norms" (Fire and Fuels Report, Affected 

Environment Section, page 14).

Associated Comments:

Comment 

# Comments

1-72

Telling the public untrue information that a "reburn" is possible violates: 18 USC § 1519 

and because you have "knowingly concealed, covered up, and falsified" a document with the 

intent to "impede, obstruct, or influence" the "proper administration of any matter within the 

jurisdiction of" the United States Forest Service. 18 USC § 1001(a)(2): "(a) Except as 

otherwise provided in this section, whoever, in any matter within the jurisdiction of the 

executive, legislative, or judicial branch of the Government of the United States, knowingly 

and willfully- (2) makes any materially false, fictitious, or fraudulent statement or 

representation"

Comment Response #82: Environmentally preferable alternative 

identification

Concern statement:

There is a concern that the National Environmental Policy Act was violated as the DEIS did not 

identify an environmentally preferable alternative.

Forest Service Response:

The commenter has confused the requirements of the record of decision with those of the 

environmental impact statement. 40 CFR 1505.2(b) requires that "At the time of its decision ... 

each agency shall prepare a concise public record of decision. The record ... shall: (b) Identify all 

alternatives considered by the agency in reaching its decision, specifying the alternative or 

alternatives which were considered to be environmentally preferable" (emphasis added). The 

environmentally preferable alternative was identified in the draft record of decision, as 

appropriate under 40 CFR 1505.2(b). There is no such requirement to disclose an 

environmentally preferable alternative in a draft or final environmental impact statement.

Associated Comments:
90

Comment 

# Comments

1-84

NEPA requires EISs to specify the alternative or alternatives that you consider to be 

"environmentally preferable." You have failed. The words "environmentally preferable" don't 

exist in your DEIS. Keeping the "environmentally preferable" alternative(s) secret from the 

public violates 40 CFR 1505.2(b).

Comment Response #83: Violates NEPA, incorporated by reference

Concern statement:

There is a concern that the National Environmental Policy Act was violated as the Biological 

Assessment was incorporated in the DEIS by reference and was not readily available for public 

review during the Notice of Availability comment period.

Forest Service Response:

The commenter correctly states that 40 C.F.R. § 1502.21 requires that information incorporated 

by reference must be "readily available" for review by the public. However, all information 

necessary to form "the scientific and analytic basis for the comparisons under §1502.14," as 

required by § 1502.16 (environmental consequences) was directly included in the draft EIS and 

applicable draft resource reports which were readily available. The biological assessment is not a 

NEPA requirement. Rather, a biological assessment is used to determine whether formal 

consultation or conference for species protected by the Endangered Species Act is required under 

50 CFR § 402.14 or §402.10, respectively (50 CFR §402.12 (k)). The Wildlife biological 

assessment was not incorporated by reference in either the draft EIS or the final EIS, and was 

therefore not required to be readily available.

Associated Comments:

Comment 

# Comments

519-4

Information incorporated by reference must be "readily available" for review by the public. 

40 C.F.R. § 1502.21; see also Save Our Ecosystems v. Clark, 747 F.2d 1240, 1247 (9th Cir. 

1984); State of Cal. v. Block, 690 F.2d 753, 765 (9th Cir. 1982); League of Wilderness 

Defenders/Blue Mountains Biodiversity Project v. Connaughton, No. 3:12-CV-02271-HZ, 

2014 WL 6977611, at *15 (D. Or. Dec. 9, 2014). The comment period must not start until all 

information incorporated by reference is available. See Forty Most Asked Questions 

Concerning CEQ's National Environmental Policy Act Regulations, 46 FR 18026-01 (25(b)) 

("Care must be taken in all cases to ensure that material incorporated by reference, and the 

occasional appendix that does not accompany the EIS, are in fact available for the full 

minimum public comment period."); 40 C.F.R. § 1502.21 ("No material may be incorporated 

by reference unless it is reasonably available for inspection by potentially interested persons 

within the time allowed for comment." (emphasis added)); League of Wilderness Defenders, 

2014 WL 6977611, at *20 ("[T]he Forest Service violated NEPA by . . . failing to make the 

draft Specialist Reports publicly available during the comment period."). The DEIS states: A 

stand-alone [Biological Assessment] will be prepared for Coho salmon and Coho salmon 

Critical Habitat. This document will be the Biological Evaluation for Forest Service sensitive 

species and the Management Indicator Species analysis for management indicator species. 

The Biological Assessment will analyze project effects relative to the full suite of habitat 

indicators included in the Analytical Process: water temperature; turbidity; chemical and 
91

Comment 

# Comments

nutrient contamination; physical barriers; substrate character; large woody debris; pool 

frequency and quality; off-channel habitat; refugia; width to depth ratio; streambank 

condition; floodplain connectivity; change in peak and base flows; increase in drainage 

network; road density and location; disturbance history; disturbance regime; and riparian 

reserves. The Biological Assessment for Coho salmon and Coho salmon Critical Habitat has 

not been released to the public. The Forest Service cannot slough off environmental review to 

a Biological Assessment that is not part of the NEPA process. Here, the DEIS is utilizing the 

Biological Assessment to perform the analysis otherwise required by the DEIS. In short, to 

meaningfully evaluate the conclusions in the DEIS, it is necessary to examine the BA. 

However, the BA is unavailable to the public. Because the BA is unavailable for review, the 

Forest Service may not begin the comment period until the BA is readily available for public 

review.

Comment Response #84: Coarse woody debris retention

Concern statement:

There is a concern that coarse woody debris is retained in accordance with Forest Plan standards 

and guidelines to support seedling growth.

Forest Service Response:

Coarse woody debris standards will be met by retaining any coarse woody debris now on-site, all 

cull trees, snags in snag retention areas and riparian reserves, and green trees that are in units. 

See the snag and coarse wood analysis in the appendix to the Management Indicator Species 

Report for a complete discussion. Although the project will reduce the number of snags as a 

result of implementing the project, the Horse Creek Project will still retain enough snags to 

exceed the snag levels and coarse woody debris described in the Forest Plan (MIS Appendix, 

page 18).

Associated Comments:

Comment 

# Comments

368-28 The recommendations also include the retention of Coarse Woody Debris.

368-63

downed woody debris is essential for "seedling growth after clearcutting and intense fire on 

droughty sites" and "a requisite for maintaining long term forest growth." The author explains 

that "in the Klamath Mountains conifer seedling performance can depend on the ability of the 

soil to retain moisture and support nitrogen fixing and ectomycorhizal organisms. Removal of 

large amounts of organic material may result in difficult reforestation of these thin, droughty, 

and infertile sites." (Amaranthus, 1990 SNF)

Comment Response #85: Salvage unit size

Concern statement:

There is a concern that salvage harvest should not be conducted in units smaller than 10 acres.

Forest Service Response:
92

As demonstrated in the "Salvage Harvest with Site Preparation and Planting" section of 

Alternative 2 in Chapter 2 of the FEIS (Table 7), no units are included in the project which are 

less than 10 acres in size. The smallest unit proposed in the project is unit 118.12, which is in 

Alternative 2, and is 13 acres in gross area.

Associated Comments:

Comment 

# Comments

368-23 The majority of the snag patches targeted for logging are relatively small and characteristic 

of mixed severity fire, some may be less than 10 acres and should not be logged.

Comment Response #86: Snag retention, not needed

Concern statement:

There is a concern that snag retention is unnecessary as 95% of the burned area will not be 

treated and will provide a large number of snags.

Forest Service Response:

Thank you for your comment. We agree that there are a lot of snags on the landscape; however,

removing snags can have local effects on species that are snag-dependent. The National Forest 

Management Act (NFMA) requires that projects be consistent with the forest plan of the national 

forest where the project occurs. The Klamath Forest Plan provides metrics for snag retention that 

must be met in any project to ensure that habitat requirements of various species are met (Forest 

Plan Table 4-4, page 4-30). An analysis of snag retention compliance can be found on page 14 of 

the Appendix to the Management Indicator Species (MIS) report. The project meets the snag 

retention requirements in the Forest Plan.

Please refer to Comment Response #1 for more information on this topic.

Associated Comments:

Comment 

# Comments

7-2

Since such a small proportion of the burnt timber is being removed, requiring snags to be left 

within the treatment units is nonsensical. There will be more than enough snags left in the 

95% of the landscape that will not be treated to meet any wildlife need. That's 2,043 acres out 

of 40,824 acres being harvested or leaving 38,781 acres covered with snags.

518-4

Alternative 4-With only 5% of total area considered for treatment, I should think that with the 

95% remaining undisturbed, there would be adequate snags for wildlife habitats to be 

minimally affected.

Comment Response #87: Snags provide shade

Concern statement:

There is a concern for the amount of shade snags provide in riparian areas and that salvage 

should not remove this stream shade.

Forest Service Response:
93

The Horse Creek Project was designed to conserve stream shade to the greatest extent possible 

while allowing for worker and public safety. Where proposed roadside fuels treatments and fuel 

management zones cross riparian reserves, no vegetation that provides effective shade to the 

stream channel or floodplain will be cut (FEIS pages 29-30). Further, no salvage harvest is 

occurring in riparian reserves as those areas are set aside for snag retention. Only snags that 

constitute a hazard to the public or workers would be removed. We believe, because of these 

project design parameters, that our project will not impact stream shade.

Associated Comments:

Comment 

# Comments

368-131

Standing snags have been shown to provide significant post-fire shade in riparian areas. In 

research conducted after the 1987 Silver Fire it was shown that "57% of post fire shade was 

provided by dead vegetation, removal of dead vegetation from riparian reserves by timber 

salvage or other post fire activities should be carefully considered where water temperatures 

reach critical levels for fish," (Amaranthus, 1990) as they do each summer in the Klamath 

River.

Comment Response #88: Ecological benefits of snags

Concern statement:

There is concern for the ecological benefits of snag retention, including snags' ability to retain 

hillside soils and soil moisture, provide for regeneration, protect against temperature and climate 

extremes as a microclimate, and provide habitat for birds, mammals, beetles, and pollinators.

Forest Service Response:

The Klamath National Forest recognizes that snags are ecologically beneficial and includes 

standards and guidelines for management and retention of snags and associated coarse woody 

debris. The project is consistent with all Forest Plan standards and guidelines regarding snag and 

coarse woody debris retention and management. Additionally, much of the project area has been 

influenced by historic fire suppression activities which have reduced stand diversity, which 

includes forest openings without snags or large amounts of coarse woody debris. "Within the 

Horse Creek 6th field watershed...as a consequence of the lack of mixed severity fires, the forest 

vegetation has changed from a heterogeneous pattern to a more homogeneous pattern of smaller 

openings in a matrix of denser forests (Skinner et al 2006). Therefore, one of the most extensive 

problems related to health of this watershed is the over-accumulation of vegetation and fuel 

loading...This has resulted in uncharacteristically dense vegetation and high fuel loading" 

(Johnny O'Neil FEIS, page 5) "Fires have been suppressed in this area since the early part of the 

century. Without fire, many young trees that would have died from heat or scorching have lived, 

resulting in very dense conifer stands" (Horse Heli FEIS, page 2). The Johnny O'Neil and Horse 

Heli projects overlap the proposed Horse Creek project and the pre-Gap Fire conditions 

described for those projects are highly relevant. The forests in the Horse Creek watershed has

been substantially affected by historic fire suppression, and display stand densities and a 

reduction in stand diversity that is not characteristic of the natural, fire-influenced forest 

condition. Snag habitat and recruitment of coarse woody debris resulting from the Gap Fire and 

retained by the Horse Creek project will be present at levels that are consistent with, or greater 

than those that would be expected from a natural fire event prior to the fire suppression era." The 
94

amount of dead wood would have been much less under the historical fire regime than exists 

today and is consistent with other research in similar dry forest fire regimes (Knapp 2015, 

Stephens 2004)" (Horse Creek Community Protection and Forest Restoration Project, page 111).

Associated Comments:

Comment 

# Comments

368-62

Perhaps the most obvious impact of salvage logging is the removal of large standing snags. 

These snags and the large downed wood they provide have been identified as "keystone 

species" providing habitat, building soil, holding moisture, stabilizing soils, harboring 

regeneration, providing microclimate, and protecting against temperature and climate 

extremes. (Perry 1997) "Large dead wood is one of the most obvious structural legacies of a 

natural disturbance, and a major reason why clearcuts are not the ecological equivalent of 

natural disturbance." (Perry 1997) Likewise, salvage logging will reduce this natural process 

and the desirable fire mosaic, reducing the rich post fire landscape to the ecological 

equivalent of a clearcut.

515-8

Although the SCNPSO focuses on native plant conservation, we recognize that, in nature, 

everything is connected. It is important for native plants to have robust pollinator populations, 

and other insect and bird populations that help disperse plants seeds as part of the biotic 

community. Fungi and other forest organisms are also important to native plant conservation. 

For this reason, keeping snags on the landscape is truly important. Snags provide habitat for 

wood nesting pollinators such as carpenter bees, cavities for bird nests, beetle habitat, as well 

as for many species of wildlife such as Pacific fisher, bats, etc. Snags represent a 

concentration of biological wealth, that when removed have major repercussions throughout 

the biological community. The preservation of snags and downed logs within the burned area 

adds habitat complexity that is unmatched in an unburned forest.

882-1

Snags left after burns are some of the best mammal and bird habitat on Earth. Remaining tres 

and woody debris literally hold up the hillside by retaining and building soil for the verdant 

wildflowers that arise after burns.

Comment Response #89: Snag retention of biological legacy trees

Concern statement: There is a concern that large snags, considered biological legacies, will be 

removed in salvage units. Commenters state that snags should be retained that are likely to 

persist until the new stand is again producing large snags.

Forest Service Response:

See the response to concern #70 which also speaks to salvage in Late Successional Reserves.

Questions concerning the interpretation of ONRC v. Brong are matters of law that are beyond the 

scope of response to comments on a draft EIS. 

Several commenters questioned whether salvage was permitted in an LSR. The Klamath Forest 

Plan (and the Northwest Forest Plan) provided two groups of standards and guidelines for 

salvage in an LSR. The first group are "Guidelines to Reduce Risks of Large Scale Disturbance" 

where salvage is done to reduce the risk of large-scale future disturbance (Klamath Forest Plan, 

page 4-86). The second group are "Guidelines for Salvage" (Klamath Forest Plan, page 4-87) 

where salvage is done to recover value and timber volume. Both are legitimate objectives, but 

the distinction between salvage to reduce the risk of future disturbance (Klamath Forest Plan 

MA5-27, 28, 29) and salvage for the purpose of recovering value and timber volume (Klamath 
95

Forest Plan MA5-30, 1-11) is important for the application of the appropriate Standards and 

Guidelines. The Horse Creek FEIS clearly states that the purpose of salvage in the LSR is to 

reduce the risk of future large scale disturbance (FEIS, page 17) in that land allocation. Standard 

and Guideline MA5-28 of the Klamath Forest Plan states “Salvage activities should focus on the 

reduction of catastrophic insect, disease and fire threats. Treatments should be designed to 

provide effective fuel breaks wherever possible” (emphasis added). This explains why nearly 

all of the salvage in the LSR is clustered around private property. The FEIS provides site-specific 

modeling based on project data that shows salvage harvest will reduce fuels and the risk of future 

large scale disturbance (FEIS, pages 132-133). If the purpose of the project was the recovery of 

volume and value, it would have been much more aggressive about harvesting dead trees in the 

LSR. 

Commenters state that all material that may persist for 80 years until the next stand is capable of 

producing large material must be retained. This comes from Standards and Guidelines for 

salvage MA5-30-3 (Forest Plan, page 4-87). If the purpose of the Horse Creek project was 

recovery of volume and value from fire-killed trees, the direction to retain all material that may 

persist for 80 years would be applicable. However, that is not the purpose of salvage in the LSR; 

the purpose of salvage in the LSR, as previously noted, is reduction of risk. The standards and 

guidelines for salvage in the Forest Plan (page 4-87) also include Standard and Guideline MA5-

30(5) which states: "Some salvage that does not meet the preceding guidelines will be 

allowed when salvage is essential to reduce the future risk of fire or insect damage to latesuccessional forest conditions. This circumstance is most likely to occur in the California 

Cascades Province and somewhat less likely to occur in the California Klamath Province. It is 

important to understand that some risk associated with fire and insects is acceptable because they 

are natural forces influencing late-successional forest development. Consequently, salvage to 

reduce such risks should focus only on those areas where there is high risk of large-scale 

disturbance" (emphasis added).

This Standard and Guideline is an exemption from preceding requirements in the salvage 

Standard and Guidelines (notably the requirement to retain down wood and snags that may 

persist for 80 years required in S&G 3) where salvage is done for the purposes of risk reduction 

which include effective fuel breaks. Standard and Guideline 5 is applicable to the Horse Creek 

project because the Horse Creek project is being done under the guidelines to reduce the risk of 

future large scale disturbance (Forest Plan, MA5 -27, 28, 29; page 4-86). Thus, the requirement 

to retain material that may persist for 80 years is not applicable where that would frustrate risk 

reduction objectives of the Horse Creek project. The record amply demonstrates that without fuel 

reduction, there is a high risk of future large scale disturbance in the Horse Creek project because 

of the large patch size and continuous heavy fuels. See FEIS Chapter 3, Fire and Fuels section.

Several comments spoke to retention of “legacy trees.” The term “legacy trees” does not appear 

in the Forest Plan. Recovery Action 12 in the Recovery Plan for northern spotted owls speaks to 

retention of legacy features, but the term is undefined in the Recovery Plan. We do however seek 

to retain very large, old snags because of their value to wildlife and biological diversity. In the 

FEIS, a description of the retention of snags for wildlife was added to the Salvage Harvest with 

Site Preparation and Planting treatment description to clarify retention of large snags (FEIS, page

31). If a wildlife snag must be felled for safety reasons, the entire tree will be left in place and 

shall not be bucked into smaller logs.

Associated Comments:
96

Comment 

# Comments

368-19

Roadside hazard on major ingress and egress routes, fuel reduction and prescribed fire would 

be advised in strategic locations, but biological legacies (e.g. snags) should be retained for 

standing snag and downed woody material. The habitat complexity associated with these 

biological legacies should be prioritized in LSR habitat.

368-29

the Standards and Guidelines recommend the retention of snags and snag fields stating that 

"Snags provide a variety of habitat benefits for a variety of wildlife species associated with 

late-successional forests. Accordingly following stand-replacing disturbance, management 

should focus on retaining snags that are likely to persist until latesuccessional conditions have 

developed and the new stand is again producing large snags providing a variety of habitat 

benefits for a variety of wildlife species associated with late-successional forests." The only 

snags capable of bridging the divide and persisting on the landscape until a new stand 

emerges are the big, old snags most likely to be targeted in post fire logging operations.

516-22

Oregon Natural Res. Council Fund v. Brong, 492 F.3d 1120, 1127 (9th Cir. 2007) Like the 

BLM in the Brong case, the Horse Creek timber sale is targeting large-diameter snags for 

removal from the LSR system in order to maximize the economic return to the agency from 

logging the Reserves. By removing large snags likely to persist until late- successional 

conditions have developed the Forest Service is violating the NW Forest Plan standards and 

guidelines concerning post-fire logging in the Reserves. Also like the BLM in Brong, the 

Forest Service is relying on "retention" of snags outside of actual logging areas in an attempt 

to circumvent substantive LSR snag retention standards. As noted on Table 5 on page 25 of 

the Horse Creek Logging DEIS, within many proposed clearcut salvage logging units either 0 

or 1 acre of snags will be retained. The DEIS indicates that snag retention for the LSRs 

logging units are being calculated by utilizing a total baseline that includes adjacent Riparian 

Reserves and other lands areas outside of actual logging areas as part of "units" in order to 

avoid retaining large snags that may persist LSR stands that are subjected to logging. As 

stated on page 198 of the DEIS "salvage harvest units (sic) boundaries may include riparian 

reserves and patches of green trees that burned with lower severity."

519-7

These large trees, referred to as "legacy trees" are the ones most likely to persist until a new 

forest regenerates. The DEIS does not specifically define or seek to protect these biological 

legacies. We urge timber planners to locate and GPS these trees on the landscape, as was 

discussed on the field visit May 17, 2017. Please include this in the Final EIS.

Comment Response #90: Forest plan standards and guidelines for snag 

retention

Concern statement:

There is a concern with the metric the Forest Service used to meet its Forest Plan standards and 

guidelines for snag retention.

Forest Service Response:

This comment asserts that the Northwest Forest Plan Standards and Guidelines at C-42 requires 

the Forest Service to retain a specific number of snags in each salvage harvest unit. This 

represents an overly narrow and incorrect reading of the Klamath Forest Plan. The comment 

quotes a single provision from the Northwest Forest Plan, but fails to consider all the applicable 

supplemental management direction in the Forest Plan for the Klamath National Forest and the 

multiple objectives of the project. 
97

The Forest Plan was signed after the Northwest Forest Plan and incorporated the applicable 

elements of the Northwest Forest Plan but the Klamath Forest Plan provides direction specific to 

the Klamath Province and the Klamath National Forest, including snag metrics. It is the Forest 

Plan that provides management direction for the Klamath National Forest, not the Northwest 

Forest Plan. The cited language on page C-42 of the Northwest Forest Plan does not appear in 

the Klamath Forest Plan. Standard and Guidelines 8-22 and 8-25 on page 4-30 of the Klamath 

Forest Plan provide snag metrics to be used in project planning on the Klamath National Forest. 

The Forest Plan direction does not require that these snag metrics be met on every acre or in 

every cutting unit; the Forest Plan requires that within any 100-acre landscape, the appropriate 

number of snags be retained. This allows Project design to mimic the natural snag distribution 

described by Skinner (2002) and Taylor and Skinner (1996) with concentration of snags in time 

and space, and intervening areas where snags would be relatively sparse or would not occur. To 

accomplish this, we retain all the snags in riparian reserves (except in roadside hazard areas), all 

of the non-merchantable cull trees and any very large trees with high value to wildlife. In 

addition, we designate snag retention areas within units where we need additional snags to 

complement habitat connectivity. 

Leaving snags in clumps as described in Klamath Forest Plan guideline 8-24 (page 4-30), is more 

effective than single isolated trees because snags in clumps are more resistant to blowdown. We 

also reduce the probability that these areas where snags are retained within units will be 

consumed by inevitable future fires by removing the adjacent heavy fuels with salvage sales and 

burning the activity fuels when salvage is completed. See the Fire and Fuels report in the FEIS 

for a more complete discussion of fire cycles and residual fuel treatments in the Klamath 

Province. An analysis of snag retention metrics in the project area is provided in the Appendix of 

the Management Indicator Species Report. The draft and final Wildlife Resource Reports (page

53-56) provide an assessment of snag metrics and effects on species associated with snags. See 

also FEIS page 31-33, 39, 57, 125, 291-293.

Associated Comments:

Comment 

# Comments

516-23

The DEIS indicates that the Forest Service is proposing to leave as few as two snags per acre 

in harvest units and those two snags may be averaged over 100 acres and the retained snags 

could be on the edges of units such that actual logging acres would remove all snags as a 

clearcut.

516-71

The NFP at C-42 clearly states: "As a minimum, snags are to be retained within the harvest 

unit at levels sufficient to support species of cavity -nesting birds at 40 percent of potential 

population levels based on published guidelines and models." Page 272 of the DEIS 

acknowledges that "units will not provide 5 snags per acre but the project will meet the Forest 

Plan standards of 5 snags per acre averaged over 100 acres." C-42 above applies to "harvest 

unit" scale and the KNF cannot avoid implementation of this substantive snag retention 

requirement by drawing units larger on maps (and not logging adjacent Riparian Reserves) 

and averaging snag retention outside of actual logging areas in order to avoid providing 

habitat for snag associated MIS species.

Comment Response #91: Snag retention diameter limits

Concern statement:
98

There is a concern that snag retention in the project is not defined by a diameter limit or sizebased retention requirement.

Forest Service Response:

There are no diameter requirements for snag retention other than the metrics shown in table 4-4 

on page 4-30 of the Klamath Forest Plan. Very large trees that provide high quality wildlife 

habitat would be retained. In the FEIS, a description of the retention of snags for wildlife was 

added to the Salvage Harvest with Site Preparation and Planting treatment description to clarify 

retention of large snags (FEIS page 31). If a wildlife snag must be felled for safety reasons, the 

entire tree will be left in place and shall not be bucked into smaller logs.

Associated Comments:

Comment 

# Comments

516-65

Please additionally note that the Forest Service has not quantified the amount of legacy tree 

removal that it intends to engage in. As discussed on the Forest Service field-tour, the agency 

cannot point to any large conifer snags greater than 30"-inches DBH that do not exhibit 

legacy tree characteristics. Yet Forest Service timber planners hope to remove this size class 

via salvage logging throughout the project area.

519-6 Please include a strict upper limit diameter limit for snag retention.

519-8

One point of confusion with the Westside Project was the snag retention requirement could 

be read—and was read by U.S. Fish and Wildlife Service and EPIC—as requiring the 

retention of the largest class of trees, which were indicative of an older forest age class. The 

snag retention requirements here have dropped the size-based retention requirement, instead 

focusing on complex tree features like cavities and broken tops.

Comment Response #92: Diameter limits, flexible

Concern statement:

There is a concern that diameter limits should remain flexible and that all hazards, regardless of 

size, should be abated.

Forest Service Response:

As described in the description of action alternatives in Chapter 2 of the FEIS, all hazards will be 

abated, regardless of size-class, in all action alternatives.

Associated Comments:

Comment 

# Comments

2-17

We ask that diameter limits be removed or flexible up or down to allow maximum volume 

removed in all diameter classes and that all dead trees along roads be felled or treated that 

pose a safety or road maintenance issue.

Comment Response #93: Coho salmon determination

Concern statement:
99

There is a concern that effects of the project to Coho salmon should be determined to be Likely 

to Adversely Affect habitat.

Forest Service Response:

As stated in the Modifications or Clarifications between Draft and Final Document section of 

Chapter 1 of the FEIS, "Upon further consideration, the determination of effects for Coho 

salmon and their critical habitat was changed to May Affect Likely to Adversely Affect from 

May Affect Not Likely to Adversely Affect due to adverse existing condition ." More 

information regarding this determination can be found in the Aquatic Resources section in 

Chapter 3 of the FEIS and in the Aquatic Resources Report available on the project website.

Associated Comments:

Comment 

# Comments

516-102

Because the Forest Service intends to conduct logging activities that it knows will harm water 

quality and trend the project area away from attainment of Aquatic Conservation Strategy 

Objectives the project is Likely to Adversely Affect Essential Fish Habitat for ESA-listed 

Coho salmon. See DEIS page 149.

Comment Response #94: Effects to aquatic species

Concern statement:

There is a concern for the effects of project activities on aquatic species and their habitat, 

including Coho salmon and redds, Chinook salmon, and refugia for these species in Horse Creek. 

There is specific concern for project activities that may increase sediment and temperature in 

streams and reduce dissolved oxygen levels, and the cumulative effects of adjacent timber 

operations and the 2016/2017 storms that have damaged roads throughout the project area.

Forest Service Response:

See the response to Concern # 95. The FEIS discloses waters that are listed as impaired because 

of low oxygen conditions (FEIS, Chapter 3, Hydrology Section, page 189).

Associated Comments:

Comment 

# Comments

368-7 the KNF can not continue claiming to be restoring salmon habitat while building new roads 

on sensitive soils and increasing stream turbidity with post-fire logging projects.

376-1

Horse Creek is a very important watershed providing wildlife corridors for threatened species 

and streams important for salmon and large scale post-fire logging impacts these beyond 

acceptability.

519-25

Project impacts to the Southern Oregon/Northern California Coastal (SONCC) Coho salmon 

evolutionary significant unit (ESU) and the Upper 2 NOAA/NMFS, Klamath River Basin, 

Report to Congress. 2010 3 True, K., Voss, A., & Foott, J. Scott (2016). Myxosporean 

Parasite (Ceratonova shasta and Parvicapsula minibicornis) Prevalence of Infection in 

Klamath River Basin Juvenile Chinook Salmon, March - August 2016. U.S. Fish & Wildlife 

Service California - Nevada Fish Health Center, Anderson, CA. 

http://www.fws.gov/canvfhc/reports.asp. 4 National Marine Fisheries Service West Coast 

Region, 2016 5-Year Review: Summary & Evaluation of Southern Oregon/Northern 
100

Comment 

# Comments

California Coast Coho Salmon 5 Brown, L., Moyle, P., Yoshiyama, R. Historical Decline and 

Current Status of Coho Salmon in California. North American Journal of Fisheries 

Management, Volume 14, 1994- Issue 2. 6 Horse Creek project, Draft Aquatic Resources 

Report. April 2017. 7 Personal communication with Toz Soto. Fisheries biologist, Karuk 

Department of Natural Resources. June 9, 2017. Klamath-Trinity Rivers (UKTR) Chinook 

salmon ESU should be considered as both salmon species are suffering and have incurred 

negative impacts, throughout the ESU. At the least a regional analysis of effects to salmon 

populations should be analyzed as the cumulative effects to water quality is apparent, 

particularly from Beaver Creek to Elk Creek, given the 2014 Wildfires, suppression actions, 

dense road systems, thousands of acres of subsequent salvage logging in Beaver Creek, 

O'Neil Creek, Walker and Grider Creeks (all thermal refugia for salmon) the 2015 July storm 

event (which turned 150 miles of the Klamath River brown all the way to the ocean), the 

2016 Gap Fire, suppression actions and 5,000 acres of private lands logging currently 

happening and the heavy rainfall and extensive road damage from the 2016/2017 

winter/spring season throughout the Klamath Mountains. To further exemplify the point 

above, the January 15, 2016 biological opinion for the Westside Fire Recovery Project was 

received from the National Marine Fisheries Service with a determination that the project was 

"Likely to Adversely Affect" coho salmon or their habitat (Westside ROD page 59). Walker 

and Grider Creeks, which serve as Coho Essential Fish Habitat/Critical Habitat and other 

thermal refugia in the Westside project, were filled with sediment and fines from extensive 

mass wasting and landslides in 2015 and 2016/2017.

519-38

Thermal refugia, such as Horse Creek, in the Klamath River basin are essential to the support 

of the coldwater fishery because they moderate the impact of naturally elevated temperatures 

in the mainstem Klamath River and also can provide a refuge from depressed mainstem 

dissolved oxygen levels. Their protection has become even more important since the Klamath 

River has become impaired for temperature.13

519-46

Although the final salmon survey report from the 2016 fall survey is not ready for 

distribution, survey results documented 20 coho redds in the first 3,300 feet of the Middle 

Creek this year (compared with four last year). For comparison, there were only had 13 redds 

in the lower six miles of Horse Creek. It is hypothesized that Horse Creek fish were utilizing 

Middle Creek due to the less than desirable post-fire water quality in Horse Creek. If that is 

the case, Middle Creek is an even more important refugia for those Horse Creek fish over the 

next few years as the mainstem recovers.

589-16

In addition, the Coho Salmon, classified as a threatened species, will have a significant 

increase in risk due to impacts on the watershed from an increase of sediment delivered to the 

streams.

Comment Response #95: Effects to aquatic resources consistency with law 

and policy

Concern statement:

There is a concern that the stream temperature and sediment increases that may result from the 

project would affect aquatic resources and beneficial uses to a level that is unacceptable 

according to the Aquatic Conservation Strategy, Basin Plan, Clean Water Act, Endangered 

Species Act, and Magnuson-Stevens Fishery Conservation and Management Act.

Forest Service Response:
101

The Summary of Cumulative Watershed Effects Process (Bell, 2012, available on the project 

website under Supporting Documents), states that: "Klamath National Forest CWE assessments 

model the disturbances and land sensitivity. Results fall on a continuum. As disturbances 

increase (and recover) over time and space, at some point, the risk of initiating or contributing to 

existing adverse cumulative watershed impacts becomes a cause for concern. These modelspecific levels are called "inference points" or Threshold of Concern and are used to inform land 

management decisions. Ecologically, a transition exists from lower to higher risk of adverse 

effects to beneficial uses - from insignificant to potentially significant. From a management 

perspective, inference points are intended to represent the center of that transition zone. 

Inference points do not represent the exact point at which cumulative watershed effects will 

occur. Rather, they serve as "yellow flag" indicators of increasing susceptibility for significant 

adverse effects occurring within a watershed." 

Appendix B - Actions Considered for Cumulative Effects (FEIS) states that "For the purpose of 

this project, it is assumed that private Timber Harvest Plans (THPs) submitted between 2012 and 

the present are still ongoing and will be analyzed under cumulative effects; THPs submitted prior 

to 2012 are considered past actions. Cumulative effects analysis will also consider recent and 

current Notice of Emergency Timber Operations for the 2014 Beaver Fire and the 2016 Gap 

Fire." Table B-4 shows all of the Emergency Timber Operations that were incorporated into the 

CWE model. Additionally, after communicating with Fruit Growers Supply Company about 

their intentions, we included evaluation of potential actions on the remainder of their property 

affected by the Gap Fire (see FEIS Appendix B). 

Our Forest engineers and hydrologists have been assessing impacts to roads after the fires and 

winter storms, and sites will be treated as necessary through road maintenance. Model results 

were carefully considered in Chapter 3 of the FEIS and in the Aquatic Resources Report, and 

help inform, but are not the only consideration for, the determination of effects on species. 

As stated in the Aquatic Resources Report and Chapter 3 of the FEIS, there will be no 

measureable increase in water temperature with any of the action alternatives. Any nonmeasureable increase in water temperature will not be expected to adversely affect aquatic 

organisms because water temperature in Horse Creek streams is well within the properly 

functioning range (based on water temperature monitoring in mainstem Horse Creek and Middle 

Creek). Vegetation on or near streambanks that is likely to provide shade will not be cut. 

Salvage and reforestation, construction of new temporary roads and landings, and re-opening 

existing landings will not occur within riparian reserves so increases in peak flows, sediment 

delivery to streams, and risk of landsliding from implementing the actions will be negligible to 

minor. 

The no action determination for listed, sensitive and management indicator species is No Effect. 

The determination for threatened SONCC Coho salmon for all action alternatives is May Affect, 

Likely to Adversely Affect. The determination for sensitive species for all action alternatives is 

may impact individuals, but not likely to cause a trend to federal listing or loss of viability. The 

determination for management indicator species for all action alternatives is may affect 

individuals, but is not likely to lead to a decreasing population trend. The determination for Coho 

and Chinook salmon essential fish habitat is May Affect, Likely to Adversely Affect. 

As the Aquatic Resources Report points out, "Impacts are expected in large part due to the 

vulnerable post fire condition of project area watersheds and streams where project disturbances 
102

will occur. Even the Karuk alternative (which was not analyzed in detail for reasons discussed in 

the FEIS) that would cause the least ground and watershed disturbance would be likely to have 

an adverse effect on aquatic species given the highly disturbed and vulnerable state of the Horse 

Creek watershed." 

Consultation with Fish and Wildlife Service is ongoing, and the final Record of Decision will 

incorporate any terms and conditions applied for the protection of aquatic species. Prior to 

implementation of the project, the Forest Service will meet all the relevant conditions for the 

Non-point Source Sediment Discharge Waiver. 

This will meet the requirements for the Clean Water Act, the Total Maximum Daily Load and 

the Basin Plan. The Standards and Guidelines in the Forest Plan are met through project design 

and analysis (see the Forest Plan Consistency Checklist in the project record and the Hydrology 

Resource Report, available on the project website).

Associated Comments:

Comment 

# Comments

519-33

On average before the Gap Fire, none of the watersheds, except Middle Creek, meet the core 

juvenile rearing life stage temperature of 16 degrees Celsius (USDA 2015b).8 After the Gap 

Fire temperatures likely increased stream temperatures. According to the ERA model used by 

the agency, Middle Creek watershed has a high risk to channel morphology and shows a high 

landslide risk.5, 6 A high risk to channel morphology means that the increase in peak flows 

would lead to undesirable changes (such as channel straightening and loss of coarse wood) 

that would require long-term recovery (greater than ten years). As noted above, Middle Creek 

had a proportionally high number of coho redds which must be protected to meet tribal trust 

responsibilities and beneficial uses. The KNF cannot continue to harm salmon and critical 

habitat as well as all other sensitive aquatic species in the project area. The project as 

proposed would increase sedimentation and water temperature.5 Contrary to the spirit and 

intent of the Klamath Basin Plan and TMDL Plan, Endangered Species Act, Clean Water Act 

and the Magnuson-Stevens Fishery Conservation and Management Act the project as 

proposed would have both long and short - term negative effects to aquatic resources which 

are entirely avoidable and preventable. The measured impacts would be worsened if the KNF 

accurately accounted for all of the private lands industrial logging currently taking place or if 

the extent of last winters' landsliding and road failures in the Horse Creek watershed were 

fully known.

519-34

The TMDL and Basin Plan were created to protect and restore beneficial uses of water in the 

Klamath River and downstream. The plan requires a zero increase in water temperature. 

Summer stream temperatures were measured near the mouth of 87 watersheds representing 

most of the major tributary streams on the Klamath National Forest. The Maximum Weekly

Maximum Stream Temperature exceeded the 16oC threshold for core juvenile salmonid 

rearing in 85% of all streams on the Forest.10 Only 2 watersheds on the Forest meet the 

shade targets in the TMDL shade curves. Both of the watersheds that met the curves are 

heavily managed (Middle Horse and Mill- Scott Creeks)11. The Gap Fire likely increased 

stream temperatures and even a slight increase in temperature, as the project would produce, 

is in violation of the Basin Plan. See also the Fisheries and Sensitive Aquatic Species section 

of these comments.

519-36

The KNF has a duty to protect the beneficial uses of our rivers and must live up to its tribal 

trust responsibilities. Commercial, recreational and sustenance salmon fishing has been 

limited or cancelled over the last few years because of the current disaster12 (see Salmon 
103

Comment 

# Comments

Crisis Articles folder attached to these comments). Any increase in sediment or temperature, 

as the project would induce, that will further harm salmon and other aquatic species is in 

violation of the Basin Plan and Magnuson-Stevens Fishery Conservation and Management 

Act, which finds that these fishery resources contribute to the food supply, economy, and 

health of the Nation and provide recreational opportunities.

Comment Response #96: Water Board waiver compliance

Concern statement:

There is a concern that the project adhere to California state laws and comply with Regional 

Water Board consultation process. These comments include concern for waste discharge 

requirements, total maximum daily load compliance, Basin Plan compliance, and potential 

coverage by a waiver which requires a legacy sediment site treatment plan to lower watershed 

risk ratios.

Forest Service Response:

The Forest Service will submit an application for coverage under the Waiver from the Regional 

Water Board prior to commencing project activities (FEIS, pages 194-195). Compliance with 

water quality objectives in the Basin Plan, including the state and federal anti-degradation policy, 

is ensured by meeting the conditions of the Waiver. Finding #50 of the Waiver states that 

activities covered by the Waiver are consistent with Resolution No. 68-16 because overall they 

will result in a net benefit to water quality by setting forth conditions that implement riparian and 

shade protections and enhancements, address legacy sediment sites, and implement Best 

Management Practices and on-the-ground prescriptions for new activities. The activities 

permitted under this Waiver have been determined to have a low potential impact to water

quality when conducted pursuant to the terms of the Waiver, resulting in compliance with 

applicable water quality control plans, including applicable water quality objectives. The Forest 

Service will obtain coverage under the Waiver from the Regional Water Board prior to 

commencing project activities. 

Finding #31 of the Waiver states that compliance with the Waiver constitutes Total Maximum 

Daily Load (TMDL) compliance for established TMDLs. Additionally, a legacy sediment site 

plan to meet the conditions of the Waiver will be submitted to the Regional Water Board as part 

of the application for coverage under Category B of the Waiver.

Associated Comments:

Comment 

# Comments

519-40

The state and federal antidegradation policies are independently enforceable requirements, 

despite being referred to as policies. The state antidegradation policy is titled the Statement of 

Policy with Respect to Maintaining High Quality Waters in California, codified in 23 CCR 

§2900, and is commonly known as "Resolution 68-16." The federal antidegradation policy is 

found at 40 CFR §131.12 and it has been incorporated into the Basin Plan. Both the state and 

federal antidegradation policies require that where surface waters are of higher quality than 

necessary to protect the designated beneficial uses, the high quality of those waters be 

maintained unless otherwise provided by the policies. The federal antidegradation policy 
104

Comment 

# Comments

applies to surface water regardless of the quality of the water and requires that water quality 

is adequate to protect and maintain existing beneficial uses fully. The Klamath River TMDL 

Action Plan does not delete or limit beneficial use designations and does not relax any water 

quality standard in the antidegradation policies. Both the state and federal antidegradation 

policies acknowledge that minor or repeated activities, even if individually small, can result 

in violation of antidegradation policies through cumulative effects, especially, for example, 

when the waste is a cumulative, persistent, or bioaccumulative 13 Staff Report for the 

Klamath River TMDLs, the Klamath River Site Specific Dissolved Oxygen Objective, and 

the Klamath and Lost River Implementation Plans North Coast RWQCB. Chapter 6. 2010. 

pollutant. Cumulative impacts to water quality have been accruing, particularly from Beaver 

Creek to Elk Creek, given the 2014 Wildfires, suppression actions, dense road systems, 

thousands of acres of subsequent salvage logging in Beaver Creek, O'Neil Creek, Walker and 

Grider Creeks (all thermal refugia for salmon) the 2015 July storm event (which turned 150 

miles of the Klamath River brown all the way to the ocean), the 2016 Gap Fire, suppression 

actions and 5,000 acres of private lands logging currently happening and the heavy rainfall 

and extensive road damage from the 2107/2017 winter/spring season throughout the Klamath 

Mountains. The cumulative impacts analysis in the DEIS shows an increase in sedimentation, 

which would be increased if the KNF accurately accounted for private lands logging, this is 

in violation to the antidegradation policies.

591-1

California state law assigns responsibility for protection of water quality within north coast 

watersheds to the Regional Water Board. The Regional Water Board implements and 

enforces the Porter-Cologne Water Quality Control Act ("Porter-Cologne Act": Wat. Code, 

§13000 et seq.) and the Water Quality Control Plan for the North Coast Region (Basin Plan). 

All KNF projects must comply with all substantive and procedural requirements of the 

Porter-Cologne Act (Water Code) and the Basin Plan.

591-2

The Basin Plan contains water quality objectives, implementation plans for meeting those 

objectives, and other policies, including State Water Resources Control Board (State Water 

Board) and federal policies, which are applicable to operations on NFS lands. Water Code 

section 13260(a) requires that any person discharging waste or proposing to discharge waste 

within any region that could affect the quality of the waters of the state, other than into a 

community sewer system, must file with the appropriate Regional Water Board, a report of 

waste discharge containing such information and data as may be required.

591-3

Pursuant to Water Code section 13260, Regional Water Boards prescribe waste discharge 

requirements (WDRs) except when it finds, pursuant to Water Code section 13269, that a 

waiver of WDRs for a specific type of discharge is in the public interest. The State Water 

Board Policy for the Implementation and Enforcement of the Nonpoint Source Pollution 

Control Program (Nonpoint Source Policy) requires that nonpoint source discharges of waste 

be regulated by WDRs, waiver of WDRs, or prohibitions to ensure compliance with the Basin 

Plan. Additionally, the Project must be in compliance with any total maximum daily load 

(TMDL) for the watersheds in which a project will occur.

591-4

The Project DEIS lacks a proposed legacy sediment site treatment plan. An acceptable legacy 

sediment site treatment plan including a schedule for treatment must be submitted and 

approved by the Executive Officer before Waiver coverage will be granted.

591-14

Implementation of legacy sediment site treatment would potentially lower the risk ratios in 

watersheds within the Project area and maintain reasonable progress towards TMDL 

compliance. We encourage KNF to identify legacy sediment site treatment in the Project 

FEIS and model the effects of treatment in CWE analysis in the Project FEIS.
105

Comment 

# Comments

591-15 Treatment of legacy sediment sites in the Project area is a requirement for enrollment of the 

Project under the Waiver.

Comment Response #97: Temporary roads project design feature, support 

of

Concern statement:

There was a comment expressing support of the project design features (PDFs) Watershed-12 

regarding treatment of temporary roads.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. The Watershed 12 project design 

feature was developed to apply the Best Management Practices (National BMP Road-5, R5 BMP 

2-1) for the decommissioning of temporary roads and states "Following use, all temporary roads 

(new or existing) will have takeoffs from system roads obliterated or blocked to avoid 

unauthorized use."

Associated Comments:

Comment 

# Comments

591-6

On page 39 of the DEIS, PDF Watershed-12 states: All temporary roads (new or existing) 

will have takeoffs from system roads obiliterated or blocked to avoid unauthorized use. All 

temporary roads will be hydrologically stabilized, including removal of temporary culverts 

and fills at stream crossings, outsloping of road surfaces where appropriate, and proper 

construction of waterbars. The language in PDF Watershed-12 regarding treatment of 

temporary roads in the Project area appears appropriate.

Comment Response #99: Effects to watershed and water quality

Concern statement:

There is a concern that proposed project activities will affect water quality.

Forest Service Response:

On page 188 of the FEIS, under the "Channel Condition" section, we acknowledge that the 

results of the Forest Sediment Monitoring Report for 2009-2015 (USDA 2016), which combines 

the 2009 through 2015 monitoring data showed that the Middle Horse Creek reach exceeded 

reference conditions for three of four sediment indices. Further, we acknowledge in that same 

section that the Monitoring Report (USDA 2016) determined that effects to water quality were 

currently adverse in Middle Horse Creek and possible adverse in the Horse Creek main stem, 

with human-related sediment sources being the likely cause in both watersheds. We also 

acknowledge from Table 58 on page 190 of the FEIS that four of the project area watersheds 

have an ERA risk ratio above 1.0. We use the above 1.0 risk ratio as a "yellow flag" indicating 

increasing susceptibility for adverse effects to beneficial uses in a watershed (Bell 2012). 

Implementation of the preferred alternative would increase the ERA risk ratio by, at most, 0.1 in 

five of the project area watersheds. 
106

Please see our analysis discussion on page 190 of the FEIS which states that a 0.1 increase in risk 

ratio is within the model error. Further, an increase in risk ratio of 0.1 could not be detected 

through pre- and post-implementation monitoring. Direct and indirect effects analysis of 

Alternative 4 (beginning on page 192 of the FEIS) indicates that increases to runoff and potential 

for impacts to stream channels from the alternative as proposed, are minimal and would keep 

conditions at current levels. Implementation of Alternative 4 with appropriate project design 

features and BMPs would not increase sediment risk to project area streams above existing 

condition and is similar to the minor effects discussed for alternatives 2 and 3. Stream 

temperatures will remain at current levels similar to the existing condition and alternatives 2 and 

3.

Associated Comments:

Comment 

# Comments

519-35

According to the Draft Hydrology Report at page 17, the results of the Forest Sediment 

Monitoring Report for 2009-2015 (USDA 2016), which combines the 2009 through 2015 

monitoring data showed that the Middle Horse Creek reach exceeded reference conditions for 

three of four sediment indices. The mainstem Horse Creek response reach exceeded reference 

conditions for V- star and mean surface fine. The Monitoring Report (USDA 2016) 

interpreted that effects to water quality were currently adverse in Middle Horse Creek and 

possibly adverse in the Horse Creek main stem, with human-related sediment sources the 

likely cause in both watersheds.

591-13

Table 13 on page 24 of the draft hydrology specialist report identifies that four of the ten 7th 

field watersheds studied as part of the Project have ERA risk ratios that are higher than 1.0. 

Additionally, implementation of the preferred alternative increases the ERA risk ratios in six 

of the ten 7th field watersheds. Our analysis of Alternative 2 raises concerns that conducting 

salvage harvest and associated activities in watersheds already exhibiting elevated risks for 

cumulative impacts could result in significant impacts to water quality, especially in 

watersheds that have burned with a moderate or high intensity.

Comment Response #100: Watershed effects, violates ACS

Concern statement:

There is a concern that effects of proposed project activities to stream sedimentation, watershed 

function, channel morphology, terrestrial connectivity, stream flow conditions, and riparian 

dependent species are inconsistent with the Aquatic Conservation Strategy objectives of the 

Northwest Forest Plan and the Clean Water Act.

Forest Service Response:

As described in the Aquatic Conservation Strategy (ACS) section of the DEIS (pages 66-70), the 

FEIS (pages 82-88), and the Aquatic Conservation Strategy Report, the Aquatic Conservation 

Strategy has four components: 1) Key Watershed, 2) Watershed or Ecosystem Analysis (Forest 

Plan, page 4-25), 3) Watershed Restoration, and 4) Riparian Reserves (Forest Plan, page 4-25). 

There are no key watersheds within the Horse Creek Project. Ecosystem analyses provide 

recommendations, not management direction, to be considered in project-level planning. 

Applicable ecosystem analyses were considered in these documents, and we found that the 

project is largely consistent with the recommendations of the Horse Creek and 

Thompson/Seiad/Grider Ecosystem Analyses, with one exception of road decommissioning, 
107

which is outside the scope of the project. Treatments within the Horse Creek Special Interest 

Area include restoration activities. Within riparian reserves, standards that prohibit and regulate 

activities that retard or prevent attainment of Aquatic Conservation Strategy objectives (Forest 

Plan, page 4-106) will be met.

The aquatic conservation strategy analysis found that proposed actions would maintain or 

restore, or at least not prevent the attainment of the nine aquatic conservation strategy objectives. 

The decrease in risk of future high-severity fire due to fuel reduction treatments would help to 

maintain and restore watershed processes identified in the aquatic conservation strategy 

objectives in the long term. Therefore, the project is consistent with the Aquatic Conservation 

Strategy and Forest Plan. 

The ACS report stated that none of the project activities will prevent the attainment of ACS 

objectives. Project design features ensure the project will not prevent the attainment of the 

objectives in the short or long term at the site and 5th-field scale. The decrease in future risk of 

high-severity fire due to reduction of heavy fuels in project salvage units will help to maintain 

and restore watershed processes identified in the aquatic conservation strategy objectives in the 

long term. Site preparation and planting will decrease the time needed to recover forests. 

Proposed fuels reduction treatments will build upon the beneficial effects produced by the Gap 

Wildfire and will further reduce fuels. There is no clear cutting proposed in any units of this 

project. 

Regarding concerns about soil compaction, Objective #5 of the ACS Report states that increases 

in soil compaction are known to cause alterations to peak flows, as well as changes to the timing 

of sediment delivery (Grant et al.). While the report discloses this information it also states that 

soil compaction will occur at the site scale, and the amount of compaction at the watershed scale 

will not be measureable. All of the temporary roads and landings proposed for the Horse Creek 

project are within the Horse Creek 5th field watershed as seen in Table 6 of the ACS report. The 

total length in miles of temporary roads is 2.9 miles on existing roadbeds and 1.7 miles of new 

roads. This small mileage is not enough to prevent attainment of aquatic conservation strategy 

objectives at the site scale. Potential increased peak flow related to timber salvage is 

indistinguishable beyond increases expected to result from the Gap Fire and the subsequent wet 

winter of 2017. Salvage harvest is not expected to affect base flow beyond influences of the 2016 

Gap Fire, and will not prevent attainment of aquatic conservation strategy objectives at the site or 

5th-field scale. To clarify the concern regarding the increased risk ratio in Middle Creek for 

channel morphology, the DEIS states that increased risk is small to negligible. \

Regarding concerns about work on unstable lands, there will be no heavy equipment used in 

stream course riparian reserves or on unstable ground except for on existing roads and landings,

and no natural, live vegetation will be removed from stream banks that will reduce stream shade 

or bank stability, as stated in the ACS report. 

Regarding concerns about large wood, the project is attempting to increase large wood within the 

special interest area in order to improve habitat. In addition all trees cut as hazards will be left in 

the riparian reserves as long as they do not cause excessive fuel loading. The effects on 

invertebrate riparian dependent species was evaluated in objective #9 of the ACS Report. 

Specific project design features were drafted to ensure the project integrates Best Management 

Practices for the protection of water quality and maintains and restores the natural processes 

described in the Aquatic Conservation Strategy Objectives. Project design features ensure the 
108

project will not prevent the attainment of the objectives in the short or long term at the site and 

5th-field scale. For more information on the methods for calculating and considering snag 

retention, please see comment response #100. A discussion of habitat connectivity is also 

available in comment response #102. The methods used and analysis conducted for both of these 

issues is consistent with our Forest Plan standard and guidelines. 

Finally, Alternative 3 was developed in response to scoping comments to consider and analyze 

the effects of removing temporary road construction and all units in the Siskiyou Crest from the 

proposed action. This resulted in the removal of 18 salvage harvest units that were located in the 

Siskiyou Crest area or where infeasible to implement without temporary roads. As demonstrated 

in the Silviculture effects analysis in Chapter 3 of the FEIS, these untreated units with severely 

burned stands would likely be replaced by shrubs and brush and the regeneration of conifers and 

restoration of forested wildlife habitat may take decades (Silviculture section of the Chapter 3 

FEIS). If these stands are not treated they would not be restored to the desired conditions 

outlined in the project's purpose and need as guided by the Forest Plan goals for these 

management areas. For this reason, Alternative 3 was not selected as the preferred alternative, as 

is discussed in the draft Record of Decision.

Associated Comments:

Comment 

# Comments

516-90

The Project Will Violate the Aquatic Conservation Strategy (ACS) The DEIS indicates that 

the Horse Creek salvage logging project will inhibit attainment of the objectives of the ACS 

in numerous ways. As stated on page 132 of the DEIS: Roads are the major contributor to 

excessive sedimentation to streams and impacts to watershed function in the Horse Creek 

watershed. Road density is high in the Horse Creek 6th Field watershed... Much of the road 

system in lower Horse Creek and throughout the Horse Creek watershed was constructed on 

dormant landslide deposits that are highly susceptible to chronic and acute surface erosion. 

Yet the DEIS calls for extensive tractor yarding, landing establishment and new logging road 

construction and proposes to close none (as in zero) of the duplicative logging roads in the 

planning area.

516-92

Page 132 of the DEIS also indicates that the Horse Creek watershed "was not properly 

functioning" for sediment prior to the Gap Fire and that the sediment risk factors have all 

been exacerbated by the fire and will be further exacerbated by logging, road construction 

and landing establishment. Page 141 of the DEIS discloses that: [Many] of the Horse Creek 

watershed areas where actions would occur are particularly vulnerable to disturbance due to 

post fire conditions, high road density, and existing cumulative effects over the Threshold of 

Concern. Therefore, ground disturbance from salvage logging and road and landing 

construction even outside stream course riparian reserves is likely to slightly elevate peak 

flows and increase sediment delivery to streams. Intentionally elevating peak flows and 

increasing sediment delivery violates the NWFP ACS, the Clean Water Act and the Basin 

Plan.

516-94

The ACS of the NWFP requires that the Forest Service decrease rather than increase risks to 

aquatic resources. The Horse Creek project inhibits attainment of the objectives of the ACS. 

As acknowledged on page 147 of the DEIS: Ground disturbance associated with all action 

alternatives would slightly increase risk of adverse effects to aquatic habitat in mainstem 

Horse, Buckhorn and Middle Creeks in the short and long term because these watersheds are 

vulnerable to disturbance due to post-fire conditions and because aquatic habitats in these 

watersheds are currently degraded due to high levels of watersheds disturbance. At 148 of the 
109

Comment 

# Comments

DEIS the Forest Service again acknowledges that "alternative 3 could pose the least risk to 

special status aquatic species..." Our organizations again contend that the Forest Service has 

no intention of implementing alternative 3 and that increased deleterious impacts to special 

status aquatic species will result from the agency's salvage logging agenda. Indeed, as 

reflected on page 149 of the DEIS, the agency intends to conduct logging activities that are 

Likely to Adversely Affect (LAA) listed Coho salmon. This is because listed species are less 

important to the Klamath National Forest than timber volume.

516-96

The Forest Service acknowledges that salvage logging may negatively impact temporal 

connectivity at the site scale but dismisses the negative impact because project design 

features that require snag retention in the salvage units will meet the standards and guidelines 

at the site scale. This contention is incorrect, the PDFs do no such thing. In fact, the logging 

PDFs call for: (1) Counting Riparian Reserves as "units" in order to double-count the 

Reserves for leave-tree purposes while clearcutting the actual harvest units; (2) Defining units 

larger than the actual harvest area in order to count trees outside of the logging zone as "leave 

trees" and (3) Averaging leave tree retention over 100-acre plots such that many "units" will 

be effectively clearcut. Hence the project will indeed negatively impact terrestrial 

connectivity at the site scale in violation of ACSO 2.

516-97

Page 175 of the DEIS clearly acknowledges that "[a]ll action alternatives increase the risk 

ratio in Middle Creek for channel morphology from Moderate to High." This represents a 

clear violation of the ACS of the NWFP.

516-98

The Forest Service is proposing numerous actions that will directly increase sediment 

production and delivery to streams in addition to the significant sediment production 

that has already occurred from the wildfire events, wildfire suppression (including dozer 

lines), and the existing road system. As stated on page 5 of the Draft ACS report, "cumulative 

watershed effects modeling has shown that the action alternatives would increase the risk 

ratios for sediment delivery..." This is a direct violation of ACSO 5. The Forest Service 

contention (on the same page) that "measures would be taken to help reduce the increase" in 

sediment production from logging activities does not release the agency from its duty to 

decrease, rather than increase sediment production in this project area. As stated on page 176 

of the DEIS, "[l]ocalized, short-term effects to water quality from sediment are anticipated" 

from implementation of all action alternatives. Simply refusing to quantify the amount of 

addition sediment delivery does not relieve the agency of its obligations under the NWFP 

ACS and the Clean Water Act. Please note that Middle Klamath is 303(d) listed for sediment.

516-99

The NEPA documents supporting the Horse Creek Fire Salvage project fail to analyze or 

disclose the role of large down wood in moderating peak flows and maintaining in-stream 

flow during low flow conditions. Klamath National Forest BMPs that allow for up to 50% of 

streamflow to be diverted by water drafting would directly inhibit attainment of ACSO 6. 

Please note that "Large clearings greater than two acres... can indirectly lead to incremental 

increases in peak flow, especially when openings are created in the rain-on- snow zone." 

(Horse Heli DEIS 3-33). The Horse Creek DEIS calls for the establishment of numerous large 

clearings through clearcut logging.

516-101

By removing large wood from non-fish bearing hydrological Riparian Reserves via roadside 

logging the Forest Service will directly negatively impact populations of invertebrate riparian 

dependent species. Log landings within hydrological Riparian Reserves will also negatively 

affect invertebrate the riparian dependent species that this ACSO is designed to protect. 

Sediment production from upslope salvage logging activities will also negatively impact 

invertebrate riparian dependent species in the project area.
110

Comment Response #101: Watershed effects, rely on project design 

features

Concern statement:

There is a concern that the effects analysis of water quality relied on the implementation and 

effectiveness of project design features and best management practices.

Forest Service Response:

The Forest concurs that even well-implemented best management practices and project design 

features may not completely eliminate all impacts to water quality. However, they are useful for 

minimizing impacts and inclusion of them makes comparisons between alternatives more 

realistic since the project will not be implemented without incorporation of these measures. As 

the annual Best Management Practices Effectiveness Program reports note, when BMP failures 

occur, corrective actions are taken and documented. Follow-up monitoring is also conducted for 

any sites that were not rated as fully effective the previous year. This monitoring evaluates the 

success of corrective actions that were implemented the previous year.

Associated Comments:

Comment 

# Comments

519-41

The Hydrology section of the DEIS relies on BMPs and PDFs to mitigate impacts of the 

proposed project to water quality. For example, the DEIS at page 175 states that with the 

implementation of PDFs and BMPs, water quality is expected to remain at existing levels. 

The KNF 2012 BMPEP Report, page 4, reported that BMPs were effective 87% of the time. 

The KNF cannot rely on the practices that are not entirely effective or implemented and must 

calculate this into project models.

Comment Response #102: Habitat connectivity analysis

Concern statement:

There is a concern that the effects of proposed project activities to habitat connectivity are not 

fully analyzed.

Forest Service Response:

Habitat connectivity is important for wildlife; to address this important factor the FEIS provides 

a habitat connectivity analysis to show the potential effects to habitat connectivity resulting from 

the project. Habitat is defined by biotic and abiotic features that are used by a particular species 

to meet the needs of survival and reproduction. Habitat connectivity and the spatial scale used to 

measure connectivity is specific to the species being evaluated. The spatial scale for evaluating 

habitat connectivity would be at a biologically relevant scale at which the particular species 

would use an area. For fisher and marten in this project, a watershed provides the spatial scale 

that is biologically relevant for the species' home range size and movements, this project is 

proposing treatment on approximately 5% of the burned area which is a relatively low 

percentage at the watershed scale. 

The habitat connectivity analysis includes the changes to habitat resulting from the Gap Fire 

along with the changes occurring in the past and the effects of the project actions. Fire can create 

dramatic changes in the habitat by altering the vegetation composition in a particular area; 
111

whether or not a particular area has changed to the point that it is considered inhospitable is 

determined by the species of interest. Like fire, salvage harvest can further change the vegetation 

structure, but without context of particular species, it is incorrect to identify salvage harvest as 

creating "inhospitable" conditions. For example, fire can remove important marten habitat 

components like tree canopy cover which is described in the Wildlife Biological Evaluation 

(pages 13 and 14). Not all salvage harvest treatments are created equally, as described in the 

Wildlife Biological Evaluation, the size of the unit and the amount of residual woody debris can 

influence the potential movements of a marten. 

The criteria used to analyze habitat connectivity is available in the Biological Evaluation (pages 

16 to 18). The Wildlife Biological Evaluation analysis indicator called "habitat connectivity" was 

developed to measure the effects of salvage harvest along with the other project actions that 

could affect habitat because snags and coarse woody debris have been described as important 

habitat components for fisher and marten to move through the home range and across the 

landscape (i.e. habitat connectivity). Further, the Horse Creek Project added snag retention areas 

in the salvage harvest units that will increase the amount of snags and coarse woody debris to 

reduce the potential effects to fisher and marten. 

As the comments point out, a region-wide assessment is available that describes and evaluates 

important corridors at a much larger spatial scale than the Horse Creek Project area. As described 

in the Biological Evaluation (page 4): "The California Department of Transportation (Caltrans) 

and California Department of Fish and Wildlife (CDFW) commissioned the California Essential 

Habitat Connectivity Project to identify a functional network of connected habitat for wildlife 

species and reduce the conflict between vehicle and wildlife collisions (Spencer et al. 2010). The 

report displays a statewide Essential Habitat Connectivity map which is a coarse scale map 

depicting the blocks of habitat important for maintaining connectivity over a large area. These 

habitat blocks were designed to inform large scale land management efforts, but these blocks 

were intended to be replaced by more detailed analyses (Spencer et al. 2010). The Horse Creek 

Project contains portions of the identified Essential Habitat Connectivity area.” As 

recommended, we have provided a site specific habitat connectivity analysis that provides a 

more sensitive analysis to scale.

Associated Comments:

Comment 

# Comments

519-12

The southwest portion of the LSR, in the Seiad Creek drainage, however, is severely lacking 

in the distribution of LSOG habitat. Much of the area is dominated by early seral vegetation. 

Overall, the distribution and connectivity of LSOG habitat, relative to other Forest LSRs is 

moderate. KNF LSR Assessment 2-82 The FEIS needs to take a hard look at habitat 

connectivity in the project area; the DEIS is not sufficient. The DEIS indicates in numerous 

places that habitat connectivity is an important value supported by the post-fire forests and 

that logging will negatively affect connectivity, however, the DEIS refuses to examine 

habitat connectivity, except for three mesocarnivores. An adequate review of the impacts of 

the project to habitat connectivity would perform a wildlife habitat connectivity analysis for a 

full suite of focal species that utilize the project area. Habitat connectivity is "the degree to 

which a landscape facilitates or impedes wildlife movements among patches of habitat" Draft 

Wildlife Biological Evaluation at 3 (citation omitted). In particular, we are concerned with 

connectivity between older forest types. Connectivity is diminished, disturbed, or broken by 

roads, logging, and other barriers. "Within the Horse Creek Analysis Area, the potential 
112

Comment 

# Comments

barriers to dispersal for late-successional forest related species would include areas that 

currently do not support late- successional or mid-successional forest." Horse Creek 

Ecosystem Analysis at 3-26.

519-13

Roads, logging units, and other barriers present different difficulties for various species. 

"Non-forested patches on the landscape would not, however, pose absolute barriers for highly 

mobile species, such as owls, goshawks, fisher, or marten. For smaller species with limited 

mobility; such as salamanders, mollusks, or even plants; non-forested areas can pose barriers 

to dispersal, as can roads and the Klamath River." Id. Looking specifically at roads: Forman 

(1995) showed how various species are affected by the width of roads. Surface arthropods, 

such as Wolf spiders and beetles, almost never cross a lightly traveled, six meter (20 feet) 

wide paved road. Small animals cross lightly traveled roads of 6- 15 meters (20-49 feet) 

width, less than 10% of what is normal for movements within the adjacent habitat. Mid-sized 

animals crossed road corridors up to 15 meters (49 feet) wide, but not 15- 30 meters (49-98 

feet). Large animals crossed most roads, but the rate of crossing is typically lower than 

movement rates in unroaded habitat. Id. at 3-27. While examining a focal species, which is 

indicative of a certain use of a habitat type, can be useful in examining habitat connective, 

examining connectivity through a one (or few) focal species is not appropriate, as different 

species can navigate connectivity barriers differently—that is, a snail is different than fisher 

which is different than an owl. It is abundantly clear that the project is within well recognized 

wildlife corridors. KNF admits as much. On page 4 of the Draft Wildlife 

Biological Evaluation, KNF wrote, "The Horse Creek Project contains portions of the 

identified Essential Habitat Connectivity area," as identified in the California Essential 

Habitat Connectivity Project, a report produced for the California Department of 

Transportation and the California Department of Fish and Wildlife. Further, the Draft 

Wildlife Biological Evaluation recognizes, "Theobald et al. (2011) found similar importance 

of the Horse Creek Project area for contributing to large scale wildlife connectivity as the 

California Essential Habitat Connectivity project." Id. KNF has further indicated that the 

Project has the potential to reduce the value or fitness of the wildlife corridor. The same the 

Draft Wildlife Biological Evaluation uses habitat connectivity as an analysis indicator for 

impacts to fisher, marten, and wolverines. Id. at 15-17. The KNF refuses, however, to 

perform any evaluation of the project's impacts to wildlife connectivity. KNF states that it is 

necessary to model connectivity at a "smaller scale (e.g. 7th field watershed)" and ultimately 

refuses to do so because no existing science provides a fine enough scale approach. This 

refusal is undercut by the Forest Service providing some habitat connectivity analysis at a 

smaller scale as an analysis indicator for martens, fishers and wolverines. In doing so, the 

Forest Service has demonstrated that this is a subject that they can evaluate. In not doing a 

larger habitat connectivity analysis for more than a small section of focal species, the Forest 

Service has admitted the issue, shown it can fill the information gap, and yet the Forest 

Service refuses to conduct the necessary analysis. This is not sufficient. To resolve this issue, 

the Forest Service should provide connectivity analysis for a range of focal species to 

demonstrate how the project, and other nearby actions that will cumulatively impact wildlife 

habitat resources, will affect wildlife connectivity.

Comment Response #103: Wildlife effects analysis inadequate

Concern statement:

There is a concern that the effects analysis for wildlife (Northern Spotted Owl, Goshawk, Pacific 

Fisher, Pallid bat, Townsend's Big-Eared bat, Fringed Myotis bat, Siskiyou Mountain 
113

Salamander, migratory birds, and snag and hardwood associated management indicator species) 

was inadequate as it is considered to rely on risk level assessments and project mitigations and 

lacks supporting data and surveys.

Forest Service Response:

Effects to the species noted in the comments are addressed in the Wildlife section of Chapter 3 of 

the FEIS. The supporting Wildlife Biological Evaluation, Wildlife Resource Report, and 

Management Indicator Species Report, referenced in the FEIS and available in the project record 

on the project website, analyze the effects of the project on wildlife habitat as described in the 

methods section of each report. The analysis indicator does present a risk assessment for some 

species while other species have other indicators but these analysis indicators are analyzed using 

real data such as goshawk survey records. Instead of presenting acres of habitat that are affected 

by the project, the analysis indicator presents the level of effects in categories such as "low" or 

"high" that are relevant to the species based on the measures presented in the best available 

science. These levels of effects are described as methods and reference the assumptions made for 

the analysis. For example, in the Biological Evaluation, the fisher analysis indicators include 

"analysis indicator 1 - habitat connectivity" and "analysis indicator 2- change in fisher home 

range;" the methods identified describe the sources of data used for the analysis, the assumptions 

made, and literature used to create these levels of effects are presented on pages 11 to 20.

Associated Comments:

Comment 

# Comments

516-64

Despite proposing road construction and post-fire clearcut logging throughout the project 

area, the DEIS fails to quantify the impacts to NSO and instead relies upon arbitrary "risk 

levels" as a surrogate for disclosing, or avoiding, the removal of spotted owl habitat. Please 

note that page 259 of the DEIS indicates that even the most "owl friendly" of the action 

alternatives would downgrade and remove 143 acres of NSO critical habitat. Such impacts do 

not contribute to the "recovery" of either the spotted owl or the project area.

516-67

The Forest Service has an affirmative duty to avoid or minimize impacts to species whose 

viability has been identified as a concern. Yet page 261 of the DEIS indicates that under all 

developed action alternatives agency timber planners intend to log within 0.25 miles of 5 out 

of 7 Goshawk nest sites located in the project area. Rather than analyze, quantify or disclose 

the impacts of such logging the Forest Service simply relies upon conclusory "risk levels" in 

which data and acres and locations do not inform the "analysis" results.

516-68

No effort to address fisher population distribution has been made in support of the proposed 

Horse Creek timber sale. What is disclosed in the DEIS (page 263) is that implementation of 

"Alternative 2 would result in decreasing habitat connectivity in the Lower Horse drainage. 

Alternative 2 would create more openings in Lower Horse Creek that would result in 

reducing the habitat connectivity from low to very low habitat connectivity." Despite the 

significant project impacts to Pacific Fisher detailed above, the DEIS contains no data or 

analysis at all regarding project activities. Indeed the Fisher "analysis" neglects to even 

mention the construction of log landings or logging roads, let alone quantify their locations 

and impacts. No data is presented to support the conclusions asserted in the DEIS.

516-69

The DEIS contains no substantive or quantified information regarding project activities on 

Pallid, Townsend's Big-Eared or Fringed Myotis bat species. Instead the DEIS offers 

conclusory statements unsupported by analysis or data of any sort.
114

Comment 

# Comments

516-70

The DEIS and its supporting documents make no attempt to quantify project impacts to snag 

associated MIS species present in the planning area. The Klamath LRMP, Standard & Guide 

8-19 (page 4-28) directs the Forest to "[c]ollect information on sensitive species to assess 

population distribution and habitat associates." Give this clear direction to "collect 

information...to assess population distribution," and given that MIS are designated by the 

KNF "because their population changes are believed to indicate the effects of management 

activities it is difficult to understand how MIS could fulfill their management function if KNF 

timber planners refuse to collect information about MIS population size, distribution and 

trends. Please note that in 2006 KNF timber planners responded to concerns about project 

impacts to MIS Species in the Horse Heli timber sale DEIS by contending that retention of 

habitat in the "Late Successional Reserve land allocation" was sufficient to "provide for latesuccessional species" and hence the KNF was somehow relieved of its duty to disclose 

project impacts to MIS Species. Yet here, in Horse Heli, the KNF is specifically proposing to 

extensively log snag associate MIS habitat locating squarely within the LSR land use 

allocation while again refusing to survey for MIS species, analyze project impacts on MIS 

species, quantify project effects to MIS species, or reveal the population data and trends for 

snag associate MIS species in the timber sale area.

516-72

As stated in the Management Indicator Species Report: The importance of recently burned 

forests to breeding cavity-nesting birds is well known. Primary cavity excavators are 

important members of forest ecosystems because the cavities they excavate may be used by 

secondary cavity nesters, including bats, American marten, many owl species, and other 

birds. Rather than disclose the impacts of LSR snag removal across thousands of acres of 

snag- associate MIS species, both the MISR and the DEIS rely entirely on the retention of 5 

snags per acre to mitigate project effects. In fact no harvest unit will actually retain 5 snags 

per acre in the unit.

516-73

Even if the KNF were to leave 5 snags per acre in logging units (which it is not) that would 

still not relieve the agency of its duty to utilize the MIS program to disclose project impacts 

to MIS populations. Reciting tree standards and guidelines does not constitute disclosure of 

project effects on MIS species. In KS Wild v. USFS, Eastern District of California 2004, 

(which is binding precedent for this project) the federal district court held that the Klamath 

National Forest violated its LRMP, and NFMA, by failing to monitor and survey for snag 

associated MIS species in the illegal Beaver old-growth timber sale. As recognized by the 

court in KS Wild v. USFS, the KLRMP (at 5-3) clearly states that "population trends of the 

management indicator species will be monitored and relationships to habitat changes 

determined." It simply doesn't get much clearer than that. Hence the court in KS Wild v. 

USFS ruled that in the Beaver Creek timber sale "because the habitat of the Snag Species 

Association MIS may be appreciably affected, use of habitat as a proxy for population 

surveys was arbitrary and capricious."

516-74

No attempt is made to analyze or disclose the impacts to Hardwood Associate populations 

from removal of a significant portion of their total habitat. Instead of analyzing or disclosing 

the impacts of removing exiting hardwood habitat on this MIS assemblage, the DEIS and the 

MISR limit discussion to the potential negative effects of hypothetical future wildfires on this 

habitat type.

516-75

The DEIS and Migratory Bird Resource Report contain no actual data or analysis to support 

the conclusions reached by the agency. The brief description of habitat types does not 

constitute a hard look and the effects of project implementation on species at the site scale or 

the regional level. Population trends are ignored and no attempt is made to link forest 
115

Comment 

# Comments

practices to population levels or reproductive success. The assumption on page 276 of the 

DEIS in the migratory bird section that "no salvage unit would be left completely devoid of 

snags" is incorrect. Within many logging units no snags are required for retention under the 

current logging prescription.

516-84

Siskiyou Mountain Salamander (SMS) The Klamath National Forest has repeatedly claimed 

that "[t]he primary goal of forest management is to avoid or minimize impacts to species 

whose viability has been identified as a concern." Yet it does not appear that pre-disturbance 

SMS surveys were conducted prior to the Horse Creek timber sale planning effort. The KNF 

has elected to ignore the survey protocols of the NWFP and rely on "mitigation" involving 

"known sites" that is not informed by a project-specific effort to determine where 

salamanders are located. The DEIS and Wildlife Report contain no survey results, population 

data, analysis or site specific analysis or information regarding project impacts on SMS.

Comment Response #104: NSO recovery plan consistency

Concern statement:

There is a concern for how the project is consistent with Northern Spotted Owl Recovery Plan 

Action 12.

Forest Service Response:

The Northern Spotted Owl Recovery Plan is not a regulatory document. The Recovery Plan 

provides many recommendations to minimize effects to the northern spotted owl. Recovery 

Action 12 speaks directly to the need for post-fire silvicultural treatments to focus on conserving 

and restoring habitat elements that take a long time to develop (e.g. large trees, medium, and 

large snags, down wood). We agree that retention of large structures as described in Recovery 

Action 12 is beneficial to NSOs and many other species, and that any material over time would 

serve an ecological function for the simple reason that there is no "excess" in nature. We also 

agree that we should strive to maintain large structures that would persist until the next stand is 

capable of producing large material. That is a requirement of the Klamath National Forest Land 

and Resource Management Plan (Forest Plan, 4-87; MA 5-30). Retention however, of all of the 

dead wood now present on the landscape from a wildfire would create an undesirable risk of 

future high severity fire. We do not agree that all fire killed trees, or all large fire killed trees 

must be retained because this would create conditions that conflict with the forest wide goals 

(which includes LSRs) of the Forest Plan for fire management (4-8) which state: "Reduce 

unacceptable fuel buildups and potential acreage of future high intensity wildfires." Retention of 

all of the dead trees now on the landscape would create fuel conditions that would likely cause 

more uncharacteristic high severity fire in the future that would actually consume snags and 

down logs, place additional late successional forest at risk from large stand replacement fire and 

delay reestablishment of late successional stand conditions (Fuels Report, page 17). This 

conflicts with the management goals for Late Successional Reserves (4-83) which state; "The 

objective of LSRs is to protect and enhance conditions of late successional and old-growth forest 

ecosystems."

Within salvage units the Horse Creek Project seeks to meet the objective of retaining large 

material until the next stand is capable of producing such material by: 
116

− Retaining snags in riparian reserves. The larger trees tend to occur in the riparian reserves, 

on average across the landscape, in locations that historically burned at lower fire severity. 

Large snags are more likely to persist than smaller snags; 

− Retaining snags in wildlife snag retention patches on lower slope positions that historically 

were more likely to burn at lower fire severity; 

− Individual snags with high quality habitat characteristics such as signs of decay and defect, 

cavities, broken or multiple tops, very large lateral branches, and flattened canopy. These 

snags tend to be in the larger size class compared across the landscape; and

− Reducing fuels around riparian reserves and snag retention patches using salvage harvest 

and follow-up fuels reduction treatment would reduce the fuel continuity thus reducing the 

risk of high severity fire that could reduce these snags or down wood.

None of the action alternatives in the Horse Creek Project are inconsistent with the 

recommendations of the Recovery Plan. It should also be noted that Alternative 4 was developed 

to reduce impacts on northern spotted owls and their habitats.

See also Concern Response #89 and 90 which speak to snag retention, and standards and 

guidelines for salvage in the LSR land allocation.

Associated Comments:

Comment 

# Comments

516-61

NSO Recovery Plan Recovery Action 12 directs: "In lands where management is focused on 

development of spotted owl habitat, post-fire silvicultural activities should concentrate on 

conserving and restoring habitat elements that take a long time to develop (e.g., large trees, 

medium and large snags, downed wood)." NSO RP, III-49. Post-fire logging particularly 

targets medium and large fire-killed trees (snags) for removal. The NEPA analysis does not 

explain how the proposed action is consistent with these (and other) provisions of the NSO 

RP, as required by law. 40 C.F.R. § 1508.27(b)(10) (consideration of a project's significance 

requires an analysis of "Whether the action threatens a violation of Federal, State, or local law 

or requirements imposed for the protection of the environment"). Similarly, the NEPA 

analysis does not explain how the Horse Creek logging project will contribute to the recovery 

of the northern spotted owl. 40 C.F.R. § 1508.27(b); 16 U.S.C. 1536.

Comment Response #106: Effects to NSO

Concern statement:

There is a concern for the effects of proposed project activities on the northern spotted owl and 

its habitat. These concerns specifically regard potential effects to habitat complexity and 

structures, home ranges, survival and reproduction, nesting and core sites, and long term impacts 

to the owls.

Forest Service Response:

The northern spotted owl (NSO) is analyzed in Chapter 3 of the FEIS and in the supporting

Wildlife Resource Report for all alternatives. The Horse Creek Project will affect northern 

spotted owl habitat and those effects are disclosed in detail in both documents. The documents 

also provide more detail on the literature reviewed and description of the project effects to NSO. 
117

Both documents include the ever growing collection of literature related to NSO use of fire 

affected habitat and this information was used to estimate effects of the Horse Creek Project to 

NSO over the short- and long-term. The Horse Creek Project is also being evaluated by the U.S. 

Fish and Wildlife Service. 

The Endangered Species Act does not allow a Federal agency to "Jeopardize" any threatened, 

endangered, or proposed species. To ensure that "Jeopardy" does not happen, the action agency 

must consult with the U.S. Fish and Wildlife Service. The Forest has been in contact with the 

Service about NSO consultation for the Horse Creek Project over the past several months. 

However, the action agency can consult on a project that may result in effects that are likely to 

adversely affect a spotted owl activity center as long as the action doesn't reach the point of 

"Jeopardy". The FEIS and the Wildlife Resource Report both analyze the effects of the proposed 

activities on northern spotted owl critical habitat and activity centers. The critical habitat and 

activity center analyses are not the same. Activity centers may or may not contain critical habitat 

but the effects to an activity center are the same regardless whether this activity center contains 

critical habitat. Critical habitat is a geographically defined area that contains varying amounts 

and quality of habitat; however, the effects to critical habitat are assessed based on the "primary 

constituent elements" that represent the important biological elements for the northern spotted 

owl habitat. The effects analysis for critical habitat estimates the effects to the primary 

constituent elements within each Critical Habitat subunit. 

The Northern Spotted Owl Recovery Plan is not a regulatory document. The Recovery Plan 

provides many recommendations to minimize effects to northern spotted owls. Recovery Action 

12 speaks directly to the need for post-fire silvicultural treatments should focus on conserving 

and restoring habitat elements that take a long time to develop (e.g. large trees, medium, and 

large snags, down wood). We agree that retention of large structures as described in Recovery 

Action 12 is beneficial for NSOs and many other species, and that any material over time would 

serve an ecological function for the simple reason that there is no "excess" in nature. We also 

agree that we should strive to maintain large structures that would persist until the next stand is 

capable of producing large material. That is a requirement of the Klamath National Forest Land 

and Resource Management Plan (Forest Plan, 4-87; MA 5-30). Retention however, of all of the 

dead wood now present on the landscape from a wildfire would create an undesirable risk of 

future high severity fire. We do not agree that all fire killed trees, or all large fire killed trees 

must be retained because this would create conditions that conflict with the forest wide goals 

(which includes LSRs) of the Forest Plan for fire management (4-8) which state: " Reduce 

unacceptable fuel buildups and potential acreage of future high intensity wildfires." Retention of 

all of the dead trees now on the landscape would create fuel conditions that would likely cause 

more uncharacteristic high severity fire in the future that would actually consume snags and 

down logs, place additional late successional forest at risk from large stand replacement fire and 

delay reestablishment of late successional stand conditions (Fuels Report, page 17). This 

conflicts with the management goals for Late Successional Reserves (4-83) which state; "The 

objective of LSRs is to protect and enhance conditions of late successional and old-growth forest 

ecosystems." 

Within salvage units the Horse Creek Project seeks to meet the objective of retaining large 

material until the next stand is capable of producing such material by: 
118

− Retaining large snags in riparian reserves. The larger trees tend to occur in riparian 

reserves, on average across the landscape, in locations that historically burned at lower fire 

severity. Large snags are most likely to persist than smaller snags; 

− Retaining snags in wildlife snag retention patches on lower slope positions that historically 

were more likely to burn at lower fire severity; 

− Individual snags with high quality habitat characteristics such as signs of decay and defect, 

cavities, broken or multiple tops, very large lateral branches and flattened canopy. These 

snags tend to be in the larger size class compared across the landscape; and

− Reducing fuels around riparian reserves and snag retention patches using salvage harvest 

and follow-up fuels reduction treatment would reduce the fuel continuity thus reducing the 

risk of high severity fire that could reduce these large snags or down wood.

See also Comment Response #104.

Associated Comments:

Comment 

# Comments

368-6

The KNF cannot continue claiming to restore northern spotted owl habitat and building 

habitat complexity in LSR forests, while denuding slopes of snags, live trees, and downed 

woody debris.

516-60

It appears that the Horse Creek project is likely to adversely affect numerous spotted owls, 

and yet the Forest Service nonetheless is proposing to move forward with post-fire logging 

activities that will not "conserve" spotted owl sites. In addition, post-fire logging will 

"diminish a home range's capability to support spotted owl occupancy, survival and 

reproduction in the long-term," the very activity the NSO RP states should not occur.

516-66

Lastly, as occurred in Westside, it is foreseeable that the Forest Service will again allow 

logging of occupied NSO nesting and core sites as owls move and relocate within the project 

area.

519-3

The DEIS generally contends that salvage logging will harm owls in the short term but will 

ultimately benefit owls by more quickly creating owl habitat in the long term. Please revisit 

this conclusion in light of the Biological Assessment issued for the Westside Project. The 

Biological Assessment first acknowledges: Little information exists on the short or long-term 

effects of salvage and fuels reduction and habitat restoration treatments on NSOs. Biological 

Assessment at 143. That said, the Biological Assessment was notably skeptical of the Forest 

Service's logic that logging will benefit the owl in the long term: The demographic rates of 

both northern and California spotted owls in post-burn environments indicate a decrease in 

spotted owl survival and occupancy, though this finding is somewhat confounded by the 

influence of salvage harvest. As described above in the prey section, the landscape condition 

as a result of the fire and then salvage harvest is likely to provide abundant edge type habitat 

for woodrats (and deer mice) that are associated with both early and late seral forests (Sakai 

and Noon 1993). Multiple studies have shown that NSOs make use of edge habitat (Folliard 

1993, Clark 2007, Irwin et al. 2013, and Comfort 2014). As proposed, treatments will remove 

habitat structures and will create large openings in the canopy that will persist and will not 

function as habitat for decades. Habitat attributes associated with these forests typically do 

not develop until 150-200 years of age (Thomas et al. 1990). Thomas et al. (1990) notes that 

intensively used areas and roosting sites on the KNF contain trees with a mean age range of 

73-367 years. Areas of salvage harvest or concentrated roadside hazard, in particular, will 
119

Comment 

# Comments

create large openings in the canopy that will persist and will not function as habitat for 

decades. The removal of habitat structures will delay the development of late-successional 

habitat, in this case the development of NRF habitat (PCEs) within treated areas that would 

otherwise occur if there were minimal intervention with post fire ecological processes. It will 

take several decades for the attainment of dispersal habitat (PCE 4) and longer for NRF 

habitat (PCEs 2 and 3). Attainment of the PCEs will be ameliorated to an extent through the 

project design features and forest replanting efforts. Commercial salvage units generally 

include the retention of large snags and down wood, green trees, and trees within riparian 

reserves (or inner gorges). Westside Project Biological Assessment at 125.

589-15

The Forest Service's proposed action would affect the habitat of the Northern Spotted Owl, 

which is classified as an endangered species. The Northern Spotted Owl's activity centers will 

increase in risk due to a downgrade of 158 acres of the nest and roosting habitat from the 

salvaging of logging areas and removal of hazardous trees.

Comment Response #107: NSO burned habitat use

Concern statement:

There is a concern that the wildlife effects analysis does not accurately account for how the 

Northern Spotted Owl uses burned forests or how their use of habitat changes post-fire.

Forest Service Response:

The comment claims that northern spotted owl analysis fails to consider "best available science." 

The "best available science" is addressed by the Council on Environmental Quality in the Code 

of Federal Regulations (40 CFR 1502.24): "Agencies shall insure the professional integrity, 

including scientific integrity, of the discussion and analyses in environmental impact statements. 

They shall identify any methodologies used and shall make explicit reference by footnote to the 

scientific and other sources relied upon for conclusions in the statement. An agency may place 

discussion of methodology in an appendix." The northern spotted owl analysis in the FEIS and 

Wildlife Resource Report provides the professional and scientific integrity throughout the 

document and it provides ample discussion of the relevant research that discusses both sides of 

the contradicting science related to the spotted owl use of fire-affected habitat in the section 

called "NSO use of the post-fire landscape." We agree that spotted owls may use fire-affected 

habitat and we have included this in estimating project effects on spotted owls. The commenters 

provide a series of citations that are also used in the FEIS and Wildlife Resource Report. To 

ensure that the northern spotted owl analysis accounts for the effects of treatment occurring in 

habitat that was affected by fire and may be used by northern spotted owl, the FEIS and Wildlife 

Resource Report analyze all habitat regardless of fire severity occurring in the analysis area. 

As it is pointed out by the commenter, sites that are currently unoccupied could be active in the 

future and vice versa; this is why we included all activity centers that could be affected by the 

project in the analysis. In order to provide an emphasis and recognition of NSO use of fireaffected habitat in the analysis, pre-fire suitable habitat that burned at moderate or high fire 

severity is identified by its own category called "post-fire foraging" or "PFF" and effects to PFF 

are part of the analysis (see Chapter 3, Wildlife Resources section in the FEIS). The commenter 

also expressed concern about NSO nesting in a burned landscape. For the NSO analysis, all 

known activity centers (areas including NSO nest sites) identified during the years of surveys 
120

were analyzed despite the amount of acres burned or fire severity resulting from the Gap Fire in 

the activity centers. The literature presented by the commenter plus others in the FEIS describe 

the fact that NSO may nest in areas where NSO may have not been recorded to nest before. To 

locate these possible new activity centers, the Forest is currently conducting NSO surveys to 

locate any nesting NSO in the project area. Surveys are covering all fire severities to locate any 

nesting owls regardless of the habitat or fire severity. If the Forest locates any nests in new 

locations, this information will be disclosed to the U.S. Fish and Wildlife Service as requested by 

the ESA consultation process. 

The potential continued use of previously suitable habitat that burned at moderate and high 

severity for foraging was fully analyzed in the FEIS (Chapter 3, page 250). The FEIS and 

Wildlife Resource Report consider the same literature presented in these comments except for 

Odion et al. 2014, that presents an argument that the long-term positive effects of thinning do not 

outweigh the short-term negative effects; since this project does not propose thinning in any 

alternative, this paper was not relevant to the choice between alternatives. The FEIS and Wildlife 

Resource Report provide a thorough analysis of short-term and long-term effects on northern

spotted owls resulting from proposed project activities.

Associated Comments:

Comment 

# Comments

368-26

Numerous recent studies have shown that northern spotted owls can and do use forests 

affected by high severity fire for foraging activities (Bond 2016). Many other scientific 

papers have documented significant northern spotted owl use in fire effected forests, 

including areas affected by high severity. The following publications should be reviewed by 

agency staff and analyzed in the Horse Creek Community Protection and Forest Restoration 

Project EA. · Bond et al. 2016. Foraging habitat selection by California spotted owls after 

fire. · Lee and Bond 2015. Previous year's reproductive state affects Spotted Owl site 

occupancy and reproduction responses to natural and anthropogenic disturbances. · Lee and 

Bond 2015. Occupancy of California Spotted Owl sites following a large fire in the Sierra 

Nevada, California. · Odion et al. 2014. Effects of fire and commercial thinning on future 

habitat of the Northern Spotted Owl. · Lee et al. 2013. Influence of fire and salvage logging 

on site occupancy of spotted owls in the mountains of Southern California. · Bond et al. 2013. 

Diet and home-range size of California Spotted Owls in a burned forest. · Lee et al. 2012. 

Dynamics of California Spotted Owl breeding-season site occupancy in burned forests. · 

Bond et al. 2010. Winter movements by California Spotted Owls in a burned landscape. · 

Bond et al. 2009. Habitat selection and use by California Spotted Owls in a post-fire 

landscape. · Bond et al. 2002. Short-term effects of wildfires on spotted owl survival, site 

fidelity, mate fidelity, and reproduction.

516-62

The DEIS also completely misrepresents the best available science on spotted owl use of 

burned forests. As the FWS has stated, the "best available information suggests that even with 

loss of forest canopy cover and other key habitat components typically found in NRF habitat, 

burned areas can provide some habitat function for spotted owls depending on fire severity. 

For example, areas that burned at low severity in some cases still provided spotted owl 

nesting, roosting, and foraging function. Areas that were burned at moderate and high 

severity may provide some limited nesting and foraging depending on burn patch size, edge 

type, and proximity to known sites (Bond et al. 2002, Bond et al. 2009, Clark 2007, Clark et 

al. 2011, and Clark et al. 2013 plus other authors per Appendix C)." United States Fish and 

Wildlife Service, Biological Opinion for the Douglas Complex Post-Fire Salvage project, 
121

Comment 

# Comments

TAILS #01EOFW00-2014-F-0161 (2014) (Douglas Complex BiOp). FWS also explains that 

"studies of spotted owls in post-fire landscapes indicate that spotted owls use forest stands 

that have been burned, but generally do not use stands that have been burned and logged." Id. 

While spotted owls prefer late-successional habitat when it is available, they have been 

observed foraging in areas burned by fires of all intensity categories. The research indicates 

that "low- to moderate-severity fires that retain adequate canopy can function for nesting or 

roosting and thus allow the continued use of spotted owl activity centers, while territories that 

burned at high-severity no longer supported nesting spotted owls. It is expected that within 

mixed severity burns, spotted owls will select the best available post-fire suitable habitat and 

Activity Centers at these locations may persist into the future." Id. "However, results of these 

and other studies are confounded because of post-fire logging that occurred within the study 

areas." Id. "While the role of this burned habitat is unclear in overall spotted owl population 

maintenance, available information suggests that in the short-term this habitat, in particular 

when it is salvage logged, likely contributes to reductions in spotted owl survival and 

occupancy." Id. Indeed, "spotted owl use of these burned areas is well documented (Bond et 

al 2002, Bond et al. 2009, Clark 2007, Clark et al. 2011, Clark et al. 2013, Gaines et al. 1995, 

Jenness et al. 2004, King et al. 1998, Lee et al. 2012, Roberts et al. 2011)." See also, NSO 

RP, III-47 - III- 49.

516-63

Similarly, the DEIS fails to discuss how spotted owls change their use of habitat post-fire. 

According to the FWS, "Where spotted owl activity centers are affected by fire (any range of 

severities) but sufficient habitat remains in the home range and immediately adjacent area, 

site fidelity may cause spotted owls to increase the size of their home ranges or shift locations 

to encompass the best available habitats rather than vacate the burned site." (King et al. 1998, 

Clark 2007, Clark et al. 2011, 2013). Thus, a shift by spotted owls may occur under 

conditions where the burned area is presumably still functional in terms of extant spotted owl 

habitat and the affected area is considered to be occupied. This shift is likely to occur within 

the pre-fire home range of the affected spotted owl(s)." Douglas Complex BiOp. Indeed, 

"Clark (2007) found that in high severity burned landscapes, and landscapes with salvage 

harvest, spotted owls are likely to increase their home ranges to compensate for the loss of 

suitable habitat and this will likely impact spotted owl habitat-fitness." Id. Clark and others 

concluded that "spotted owls may shift their habitat use patterns and/or increase their home 

range size to encompass the best available suitable habitat post-fire rather than vacate the 

affected site, unless very poor habitat conditions exist over much of their home range (King 

et al. 1998, Clark 2007)." Id. Spotted owls that shift and/or expand their home ranges in 

response to wildfire take advantage of unoccupied habitat that may be necessary for the 

species to persist in a post- fire environment. The NSO Recovery Plan states that "it is not 

uncommon for an occupied spotted owl site to be unoccupied in subsequent years, only to be 

re-occupied by the same or different spotted owls two, three or even more years later (Dugger 

et al., 2009). While temporarily unoccupied, these sites provide conservation value to the

species by providing habitat that can be used by spotted owls on nearby sites while also 

providing viable locations on which future pairs or territorial singles can establish territories." 

NSO RP, III-45. Unoccupied owl habitat is important post-fire because it represents vacant 

territory that may be recolonized by shifting or dispersing owls. In a heavily fragmented 

landscape like the planning area, these "vacant" sites may represent the best remaining 

suitable habitat. Id. The DEIS does not address this issue at all. At the very least, there is 

scientific controversy around the use of burned forests by northern spotted owls. The Forest 

Service is required by NEPA to disclose and respond to this controversy in the FEIS. 40 

C.F.R. §§ 1502.24; 1508.27(b)(4); 1502.9.
122

Comment Response #108: Climate change analysis inadequate

Concern statement:

There is concern that the climate change analysis should have included consideration of the 

effects logging activities may have on climate change, and that climate may have on roads as 

extreme weather events increase in frequency.

Forest Service Response:

We appreciate the issues related to climate change; however, climate issues raised by 

commenters can rarely be addressed in project-level NEPA decisions. In project-level NEPA 

analysis, the environmental consequence of an action is, by definition, measured from the current 

condition, which is a forest where a mixed severity fire has occurred. As noted in the Climate 

section in Chapter 3 of the FEIS (pages 105-106), effects on this project on future climate change 

are too small to measure. In general terms, we see this project as consistent with broad objectives 

to reduce greenhouse gasses since reducing fuels and reestablishing a fire-resilient coniferous 

forest is likely to reduce emissions when compared to repeated high severity fire. The specific 

effects of alternatives on greenhouse gas emissions are disclosed in the Air Quality section of 

Chapter 3 of the FEIS. This disclosure includes information on the emissions related to logging 

equipment FEIS, page 80) and a comparison of the emissions by alternative (FEIS, page 82). For 

the preferred alternative (Alternative 4), these emissions are 144,650 metric tons over a five year 

period with the highest annual emissions being 49,250 metric tons. There is also some benefit 

from sequestering carbon from fire killed trees in wood products that will likely last a century or 

more (FEIS pages 105-106). Scientific understanding of the effects of climate change has 

improved in the last decade but there is still some uncertainty in quantifying the impact of 

project-level emissions on climate (FEIS, pages 105-106) and climate change effects on local 

areas (FEIS, page 105), including the interaction of changes in climate with specific project 

activities, such as temporary roads, on wildlife, fisheries, hydrology and soils. Overall, “it is 

expected that treatments proposed in the action alternatives will benefit forests by reducing the 

amount and severity of future high intensity fire and reestablishing resilient forests” (FEIS, page 

106). 

Associated Comments:

Comment 

# Comments

368-107

The DEIS for climate change did not adequately analyze the effects of proposed logging 

activities on climate change. Actions that increase emissions such as logging must also be 

analyzed for impacts an action might have on climate resilience and vital connectivity 

corridors for migrating species.

589-14

Climate Change and Forest Roads Climate change is a major challenge for natural resource 

managers because of the magnitude of potential effects and the related uncertainty of those 

effects. A robust analysis under NEPA of the forest road system and its environmental and 

social impacts is especially critical in the context of climate change. Climate change

intensifies the impacts associated with roads. For example, as the warming climate alters 

species distribution and forces wildlife migration, landscape connectivity becomes even more 

critical to species survival and ecosystem resilience.[12] Climate change is also expected to 

lead to more extreme weather events, resulting in increased flood severity, more frequent 

landslides, altered hydrographs, and changes in erosion and sedimentation rates and delivery 
123

Comment 

# Comments

processes.[13] Many National Forest roads are poorly located and designed to be temporarily 

on the landscape, making them particularly vulnerable to these climate alterations.[14] Even 

those designed for storms and water flows typical of past decades may fail under future 

weather scenarios, further exacerbating adverse ecological impacts, public safety concerns, 

and maintenance needs.[15] At bottom, climate change predictions affect all aspects of road 

management, including planning and prioritization, operations and maintenance, and 

design.[16] The Forest Service has a substantive duty under its own Forest Service Manual 

to establish resilient ecosystems in the face of climate change.[17] More broadly, the Forest 

Service has a mission to sustain the health, diversity, and productivity of the Nation's forests 

and grasslands to meet the needs of present and future generations. The agency's own climate 

change science identified above demonstrates how climate change places ecosystems on our 

national forests at risk. Thus to fulfill its mission, the Forest Service must address the risks of 

climate change when managing road activities on our national forests.[18] Here, the Forest 

Service must analyze in detail the impact of climate change on forest roads and forest 

resources. It should start with a vulnerability assessment, to determine the project area's 

exposure and sensitivity to climate change, as well as its adaptive capacity.[19] For example, 

the agency should consider the risk of increased disturbance due to climate change when 

analyzing this proposed project. It should include existing and reasonably foreseeable climate 

change impacts as part of the affected environment, assess them as part of the agency's hard 

look at impacts, and integrate them into each of the alternatives, including the no action 

alternative. The agency should also consider the cumulative impacts likely to result from the 

proposed project, proposed road activities, and climate change.[20] In planning for climate 

change impacts and the proposed road activities, the Forest Service should consider: (1) 

protecting large, intact, natural landscapes and ecological processes; (2) identifying and 

protecting climate refugia that will provide for climate adaptation; and (3) maintaining and 

establishing ecological connectivity.[21] The Forest Service addresses climate change but 

avoids discussing the impacts of climate on roads. It must assess the climate impact on roads, 

as it is crucial to determining the roads that deteriorate or indirectly cause harm to the wildlife 

and wildlife habitat. The proposed action indicates that in the short term, it will set designated 

days to prescribe burning and anticipates 168,000 metric tons of carbon dioxide to be 

released, which will increase temperatures. The Forest Service also plans on setting up 

salvage logging treatments that require fourteen temporary roads to be in place to access the 

salvage units. The roads under the proposed action will pose the highest risk of increasing 

landslides and water temperature. The rising water temperature is not expected to be 

significant but will have at least some affect on aquatic species such as the threatened Coho 

Salmon by removing riparian vegetation and by widening and creating shallow stream 

channels.

Comment Response #109: Air quality impacts of prescribed fire

Concern statement:

There is a concern for the effects prescribed burning may have on human health by releasing fine 

particulate matter in the air. The commenter requests the Forest Service work with local and 

State officials to implement best management practices to minimize emissions.

Forest Service Response:
124

Prescribed burning for the project is focused on treatment of activity fuels or slash resulting from 

project activities. In Chapter 2 of the FEIS, project design features are included to ensure site

specific burn plans are developed prior to implementation of burning activities and used in 

implementation, see project design feature Fuels 1 and 2. Project design feature Fuels 2 

specifically states, "All burning activities would adhere to pertinent air quality regulations. 

Smoke emissions would be minimized by following Best Available Control Measures (BACM). 

A smoke permit administered by the local County Air Resource Agency would accompany burn 

plans."

Associated Comments:

Comment 

# Comments

369-2

We recognize the challenge the Forest Service faces in implementing a restoration project 

that would rely, in part, on prescribed bums to achieve project objectives. Though the Horse 

Creek Project area has good air quality and meets all federal ambient air quality standards, 

the fine particulate matter generated from prescribed fire does present a human health risk. 

We recommend that the Forest Service work with local and State of California air quality 

officials to implement best management practices to minimize emissions from prescribed 

bums to the greatest possible extent.

Comment Response #110: Socioeconomic effects analysis inadequate

Concern statement:

There is a concern that the effects analysis of proposed project activities on socioeconomic 

factors is inadequate as it lacks supporting research for some of its assumptions and does not 

include consideration for the following: jobs contributed to the local economy by the restoration 

and mitigation work or as a result of private harvest activities, the price of raw timber at the mill, 

hauling costs, long term productivity losses of untreated areas, impacts to commercial and 

recreational fishing, and the value of ecosystem services.

Forest Service Response:

Supporting research for the analysis of effects on social and economic indicators is provided in 

the Socioeconomic Resource Report, available on the project website. Some citations of 

background information on the affected environment were inadvertently omitted. For example, 

the statement that "lifestyles, attitudes and values of Siskiyou County residents are similar to 

those of rural residents in other counties in the western Unites States" is based on information 

provided in Charnley et al. 2006 (GTR-649), part of the socioeconomic monitoring of the 

Northwest Forest Plan; the general statement that "many local residents depend on natural 

resources to support the, and want the forest products to be used for the benefit of people in the 

county" comes from the Siskiyou County Comprehensive Land and Resource Management Plan 

of 1996 which is referenced in the literature cited for the Socioeconomic Resource Report and 

supplemented by comments to previous project provided by members of the Siskiyou County 

Board of Supervisors and other county residents. As noted in the analysis of effects of 

alternatives on the economic environment, in response to comments requesting more detailed 

information, the FEIS added a footnote to clarify that "differences in economic benefits are more 

meaningful when compared between alternatives rather than as absolute values. Stumpage and 

product values can fluctuate significantly with market values for burned trees and the amount of 
125

deterioration." The analysis of factors used to provide this comparative economic analysis are 

provided in Appendix A (Economic Impact Analysis) to the Socioeconomic Resource Report. 

The appendix also includes a discussion of the economic effects of restoration service contracts 

(pages 18-19) as well as logging and hauling costs (pages 16-18). The information provided is 

not intended to be a complete analysis of all economic impacts of the project, instead, it is based 

on available information that can be measured at the project scale (employment, labor income, 

economic output and fiscal effects on Siskiyou County). Cumulative effects analysis of 

Alternative 1 (that applies to all alternatives) includes a statement on the difficulty of acquiring 

information on actions on private land and the subsequent use of assumptions related to such 

actions. Cumulative effects analysis of Alternative 2 (that applies to all action alternatives) states 

that "Alternative 2 will result in noticeable social and economic cumulative effects, especially in 

the timber section." Even though, "this section is such a small part of the economy of Siskiyou 

County [that] overall cumulative effects to the county are not expected to be substantial," the 

economic effects of action alternatives, as disclosed in the FEIS, body of the Socioeconomic 

Resource Report, and Appendix A to that report will be noticeable. These effects are useful in 

comparing the relative economic value of alternatives to the County. The concept of ecosystem 

services includes the benefits people receive from healthy natural systems. However, analysis of 

ecosystem services is not required in project analysis, as indicated in the publication "Integrating 

Ecosystem Services into National Forest Service Policy and Operations" (Deal et al. 2017) that 

was cited in the public comment. Effects on resources such as water quality, fisheries, heritage 

resources and recreation are disclosed in several sections of Chapter 3 of the FEIS. Information 

on the economic benefit of these resources are becoming available at the regional or national 

scale but are not developed in a way that they can be effectively used in analysis at the project 

scale at this time. See also comment response #40 for information regarding the costs and 

funding sources for implementation of restoration activities.

Associated Comments:

Comment 

# Comments

519-18

The Socioeconomic Analysis states, "Lifestyles, attitudes and values of Siskiyou County 

residents are similar to those of rural residents in other counties in the western United States." 

Draft Socioeconomic Resource Report at 3. Please cite a source for this statement. This is a 

broad statement. For example, the Horse Creek Project is being opposed by the Karuk Tribe, 

which is largely based in Siskiyou County and has been since the beginning of time. The 

Socioeconomic Analysis states, "Many local residents depend on natural resources to support 

them, and they want forest products to be used for the benefit of the county." Id. Again, 

please cite a source for this statement. Indeed, the economic analysis shows that timber 

related employment is not as important to the county as it was in the past.

519-19

The cumulative effects analysis is particularly barren. The analysis does not mention the large 

amount of post-fire logging performed. Indeed, following the Gap Fire, CAL FIRE has 

processed 21 emergency notices totaling 4,863 acres. As noted in the Socioeconomic report, 

the timber industry is "such a small part of the economy—to what extent has this large pulse 

of logging fulfilled the county's "need" for timber and timber jobs?

519-20

The comparison of project economic effects fails to provide necessary 

information/assumptions underlying its conclusions. At what price does the Klamath National 

Forest anticipate federal timber purchasers will be able to sell their raw timber to a mill? 

What is the anticipated cost of truck hauling to the timber purchasers?
126

Comment 

# Comments

519-21

The Forest Service has done little work to quantify the economic value of the restoration and 

mitigation work of the project—the treating of post-logging slash, fuels treatments near 

communities, site preparation, etc. How many jobs are these activities likely to provide? 

Where would the money come from? How much money would it cost to implement these 

measures?

519-24

The term "ecosystem services" refers to the regulating, supporting, cultural, and provisioning 

benefits people receive from healthy natural systems. The ecosystem services concept 

describes the many benefits people receive from nature. It helps us connect with people as we 

carry out the U.S. Forest Service (USFS) mission to sustain the health, diversity, and 

productivity of the Nation's forests and grasslands to meet the needs of present and future 

generations.1 The Klamath National Forest makes no attempt to calculate the ecosystem 

services provided by the Horse Creek area nor does it factor in the current salmon fisheries 

disaster (see the Salmon Crisis Articles folder attached to these comments), which not only 

effects Siskiyou County residents but many Native American tribes, the state and the nation. 

The agency should make an attempt to calculate and consider ecosystem services as they are 

the fabric of socioeconomics and part of the beneficial uses of our rivers and watersheds, 

which would be harmed by the proposed project. 1 USDA/FS. Integrating Ecosystem 

Services Into National Forest Service Policy Operations. Gen. Tech. Rep. PNW-GTR-943. 

Portland, OR .Pacific Northwest Research Station. 87 p.

519-37

Commercial and recreational fishing constitutes a major source of employment and 

contributes significantly to the economy of the Nation. Many coastal areas are dependent 

upon fishing and related activities, and their economies have been badly damaged. The 

Klamath River is the lifeblood for many Native American Tribes, including the Karuk, Yurok 

and Hupa people. The Klamath National Forest cannot continue to fail its tribal trust 

responsibilities by persistently degrading water quality and dismissing alternatives put forth 

by the Karuk Tribe.

520-5

The County considers the loss of productive forest to be a long term economic burden to our 

viable tax base. Please include the long term loss of productivity in your economic analysis 

for those untreated acres. Your analysis must discuss and disclose to our local population the 

lands reduced ability to provide those tax receipts to our County for at least the first timber 

rotation with the subsequent loss of revenue for County roads and schools.

Comment Response #112: Logging systems recommendations

Concern statement:

There were recommendations from the commenters regarding planned logging systems for units 

in the project including to use mechanical treatment as much as possible to increase economic 

returns to the local community, to change unit 115.34 from ground-based to skyline harvest due 

to slope and natural regeneration, and to limit the number of landings created.

Forest Service Response:

We appreciate the comment and agree that mechanical treatments will result in an increased 

amount of acres treated. The project treatment units have been designed to treat as many acres 

with mechanical equipment as possible within the limitations of the Forest Plan, applicable laws, 

regulations, policies, and economics. See Chapter 2 of the FEIS for detailed descriptions of 
127

treatments proposed. The effects of construction/reconstruction of both new and existing 

landings are outlined in Chapter 3 of the FEIS. 

The draft analysis cited in the comment overestimated the number of landings by almost 100% 

because the number of new landings proposed inadvertently included skyline landings that use

the existing footprint of forest system roads. These parallel settings used for skyline logging 

typically operate within the existing road prism and require no cutbank excavation or fillslope 

widening and are not “new” landings. We expect closer to 30 new landings to be required –

about half the number in the draft analysis. Project design features require a predisturbance 

inspection by a resource geologist for any significant landing excavation (FEIS page 43). We 

acknowledge that there is complexity within individual units that may not allow for the logging 

system that was analyzed for the overall unit. Where these complexities exist the Project Design 

Features will be followed including slope restrictions for ground based equipment. The final 

layout of units will reflect treatment descriptions and project design features as described in 

Chapter 2 of the FEIS.

Associated Comments:

Comment 

# Comments

2-20 We recommend maximizing mechanical treatment that provide products to the local mills, 

provide jobs, and will result in increased acres treated.

519-42

According to Tables 5, 6 and7 in the Draft Logging Systems Supplemental Report 77 new 

lands are proposed for Alternative 2, 53 new landings for Alternative 3 and 56 for Alt. 4. 

Why are so many new landing being proposed? This is near the same amount of new landing 

construction proposed in the Westside project. Landing construction and their impacts has 

been well documented. This amount of soil disturbance would remove and harm critical 

habitat for both northern spotted owls and salmon.

593-3

We recommend changing unit 115.34 from ground-based to skyline harvest, given the 

steepness of the slope and impacts to natural regeneration. Furthermore, skyline harvest will 

be less impactful on natural regeneration. For other ground-based harvest areas, EPIC 

recommends developing additional project mitigation measures to reduce impacts.

Comment Response #113: Needs and interests of the local community

Concern statement:

There is a concern that the needs and interests of the County and those directly impacted by the 

wildfire, including adjacent landowners and range permittees, be considered in the project.

Forest Service Response:

Project scoping included adjacent landowners, grazing permittees, and Siskiyou County, among 

others. No commenter requested an industry preferred alternative that was consistent with the 

project purpose and need, which focuses primarily on community protection, as well as hazard 

tree and fuels management along public roads and access. The project does emphasize treatments 

near local, private landholdings and roads used by the local public.

Associated Comments:
128

Comment 

# Comments

520-9

The Project completed by the Klamath National Forest must consider the needs and interests 

of the County, our economics and prosperity, and those directly impacted by these wildfires, 

including adjacent landowners and our range permittees who rely on grazing these public 

lands.

Comment Response #114: Seasonal restriction and limited operating 

periods

Concern statement:

There is a recommendation that the project remove the seasonal restrictions and limited 

operating periods to allow for a longer operating season and reduce economic losses due to 

deterioration.

Forest Service Response:

We appreciate your comment as it pertains to safety and sale viability. Limited operating periods 

will not apply to imminent hazards trees that are identified. They will be fell as soon as possible 

after being identified. We recognize that limited operating restrictions will cause product 

deterioration and reduce sale viability if logging doesn't occur as soon as possible following a 

wildfire. The complete removal of limited operating periods is not feasible due to current Forest 

Plan direction, laws, and regulations regarding certain wildlife species. This is why the agency is 

making every effort to ensure most logging is completed this fall in order to avoid any delays 

that may be caused next spring due to limited operating periods.

Associated Comments:

Comment 

# Comments

2-18 We ask that limited operating periods and restrictions be removed to allow for a longer 

operating season. This will result in more material removed and more acres restored.

520-2

Limited operating periods and operating restrictions should be removed; and implementation 

of tree diameter limits has limited application when addressing salvage and safety projects. 

Leaving large accumulations of large diameter trees on the landscape leads to a greater 

resistance in controlling future wildfires in the urban landscape, and these encumbrances will 

shorten operating seasons and increase the risk of product deterioration, reduce sale viability, 

and diminish receipts to the County by suppressing contract bid values.

Comment Response #115: Salvage and natural regeneration and recovery

Concern statement:

There is a concern that post fire logging will hinder natural regeneration and recovery, and 

increase the fire risk within the proposed units.

Forest Service Response:

There is no disagreement that over time, trees will become reestablished within burned areas, 

however, research has shown that the quickest way to reestablish a coniferous forest after stand 

replacement fire is by active reforestation (Zhang et al. 2008). The effects of not salvage logging 
129

was analyzed through the no action alternative, and ultimately found not to meet the purpose and 

need of the project. This analysis showed that reforestation will slowly occur naturally but may 

take many decades to replace brush-fields (Zhang et al. 2008). In larger patches where the 

majority of the trees were killed by the fire, reestablishment of forest cover would rely on natural 

regeneration and may take decades or longer. For the larger, contiguous areas of high severity 

burn, distance from seed sources may further delay natural regeneration because of long 

distances to trees capable of producing seeds. Damage to natural regeneration as a result of 

salvage harvest increases with the amount of delay between the fire and the salvage activities. 

Proposed activities are designed to meet the management goals for each management area and 

the methods for replanting areas are designed to be consistent with their desired future 

conditions. The Fire and Fuels Report also states that for action alternatives there are "follow-up 

treatment of site preparation following salvage harvest. This treatment is aimed at reducing 

surface fuel loading (in all fuel size categories) from activity fuels generated by the salvage 

harvest, breaking up continuous fuel beds and reduction in fuel bed depth. Post-logging fuel

treatments, such as piling and burning or broadcast burning (jackpot burning), can rapidly reduce 

total amounts and spatial continuity of surface woody fuels, and may allow logged stands to 

serve as fuel-breaks in a landscape-level fire management strategy (Peterson & Harrod, 2010). In 

addition, Peterson, Dodson, and Harrod 2014 found that post-fire logging altered post-fire fuel 

succession by (1) greatly accelerating the deposition of surface woody fuels from logged snags, 

(2) reducing peak loading of large diameter woody fuels, and (3) initiating the woody fuel decay 

earlier. By treating the proposed salvage units and implementing post-logging site preparation 

and planting, both naturally regenerated and planted conifers that occur will be better suited for 

long term survival because of the reduced fuel loading and fire risk within these areas. Following 

salvage harvest natural regeneration will likely still occur in areas near patches of green trees,

which will remain on the landscape.

Associated Comments:

Comment 

# Comments

1-74

"Although logging and replanting may seem like a reasonable way to clean up and restore 

forests after disturbances like wildland fires, such activity would actually slow the natural 

recovery of forests and of streams and creatures within them.'

1-75

no substantive evidence supports the idea that fire-adapted forests might be improved by 

logging after a fire. In fact, many carefully conducted studies have concluded just the 

opposite. Most plants and animals in these forests are adapted to periodic fires and other 

natural disturbances. They have a remarkable way of recovering - literally rising from the 

ashes - because they have evolved with and even depend upon fire."

368-58

authors recommended the following approach: First and "most critically" they recommend to 

"forego those activities that either cause additional damage, or prevent the establishment of 

native species, ecosystem processes, or plant succession. The avoidance of degradation is far 

easier than trying to rehabilitate degraded lands." (Beschta, 2004) Instead they advocate for 

the restoration of fire suppression impacts to facilitate natural recovery, including the 

mitigation/ restoration of fire lines, helispots, road work to reduce sedimentation, replacement 

of culverts, spike camps, etc.

516-31

As for carbon, recent data shows that the highest biomass (and carbon) levels are maintained 

by periodic high-intensity fire, due to the combined biomass of the snags and logs from the 

previous fire and the vigorous natural tree regeneration spurred by the fire and the nutrient 
130

Comment 

# Comments

cycling resulting from the fire (See: Keith, H., B.G. Mackey, and D.B. Lindenmayer. 2009. 

Re-evaluation of forest biomass carbon stocks and lessons from the world's most carbondense forests. Proceedings of the National Academy of Sciences 106: 11635-11640). The 

Keith et al. (2009) study was conducted in fire-adapted forests in Australia, but the authors 

made clear that their results are applicable to other fire-adapted temperate forests, including 

western U.S. conifer forests. Vigorous natural conifer regeneration is the rule, not the 

exception, in high-intensity fire areas of the Klamath- Siskiyou (with no salvage logging, 

replanting, or herbicide application). See: a) Donato, D.C., J.B. Fontaine, J.L. Campbell, 

W.D. Robinson, J.B. Kauffman, and B.E. Law. 2006. Post-wildfire logging hinders 

regeneration and increases fire risk. Science 311: 352; and b) Shatford, J.P.A., D.E. Hibbs, 

and K.J. Puettmann. 2007. Conifer regeneration after forest fire in the Klamath-Siskiyous: 

how much, how soon? Journal of Forestry April/May 2007, pp. 139-146.

593-2

Impacts to Natural Regeneration: After the fire, we perceive a relatively low need for 

reforestation in the units we covered. Significant conifer and hardwood regrowth was evident 

through all units visited. Furthermore, we are confident that, given nearby seed sources, forest 

regeneration will occur. That said, salvage logging, and in particular tractor logging, has been 

shown to harm natural regeneration. Post-logging reforestation may be necessary to 

reestablish a forest on the appropriate timescale, but only a mitigation measure for logging.

Comment Response #116: Natural recovery

Concern statement:

Commenters have expressed concern that natural recovery is desirable over post-fire logging. 

This concern includes allowing trees to remain onsite to decompose and add to the soil recovery 

of the area, and leaving material standing to provide habitat for wildlife. Additionally there is 

concern that not allowing for natural recovery within the proposed units is limiting the amount of 

complex early seral forest habitat which is habitat for wildlife species and an essential stage of 

natural processes that will result in the most bio diverse and successful post-fire plant 

community. Commenters suggested that there are adequate natural seed sources adjacent to 

patches of dead trees to facilitate natural recovery. There is concern that implementing the 

project will concentrate slash at or near the ground elevating the risk of future fires

Forest Service Response:

There is no disagreement that over time, trees will become reestablished within burned areas, 

provided another high severity fire does not occur. However, research has shown that the 

quickest way to reestablish a coniferous forest after stand replacement fire is by active 

reforestation (Zhang et al. 2008). 

The effects of not salvage logging was analyzed through the no action alternative, and ultimately 

found not to meet the purpose and need of the project. This analysis showed that reforestation 

will slowly occur naturally but may take many decades to replace brush-fields (Zhang et al. 

2008). In larger patches where the majority of the trees were killed by the fire, reestablishment of 

forest cover would rely on natural regeneration and may take decades or longer. For the larger, 

contiguous areas of high severity burn, distance from seed sources may further delay natural 

regeneration because of long distances to trees capable of producing seeds. Damage to natural 
131

regeneration as a result of salvage harvest increases with the amount of delay between the fire 

and the salvage activities. 

Proposed activities are designed to meet the management goals for each management area and 

the methods for replanting areas are designed to be consistent with their desired future 

conditions. The Fire and Fuels Report also states that for action alternatives there are "follow-up 

treatment of site preparation following salvage harvest. This treatment is aimed at reducing 

surface fuel loading (in all fuel size categories) from activity fuels generated by the salvage 

harvest, breaking up continuous fuel beds and reduction in fuel bed depth. Post-logging fuel 

treatments, such as piling and burning or broadcast burning (jackpot burning), can rapidly reduce 

total amounts and spatial continuity of surface woody fuels, and may allow logged stands to 

serve as fuel-breaks in a landscape-level fire management strategy (Peterson & Harrod, 2010). In 

addition, Peterson, Dodson, and Harrod 2014 found that post-fire logging altered post-fire fuel 

succession by (1) greatly accelerating the deposition of surface woody fuels from logged snags, 

(2) reducing peak loading of large diameter woody fuels, and (3) initiating the woody fuel decay 

earlier. 

Within the proposed salvage harvest units, riparian areas are designated for no treatment and will 

serve as snag retention patches within the units, there are also retention clumps identified within 

units, these project design features will leave standing structure within units post-salvage harvest 

for wildlife habitat. 

Additionally, the total proposed treatment area is a relatively small percentage of the total area 

burned in the Gap Fire, leaving adequate acreage on the landscape that will regenerate naturally 

and likely be early seral habitat for some time. By treating the proposed salvage units and 

implementing post-logging site preparation and planting regeneration either natural or planted 

that occurs will be better suited for long term survival because of the reduced fuel loading and 

fire risk within these areas. Following salvage harvest natural regeneration may still occur in 

areas near patches of green trees which will remain on the landscape.

See also Comment Responses #1, #2, #9, #49 and #53.

Associated Comments:

Comment 

# Comments

1-29

The agency wants the public to understand that every post-fire landscape must be logged as 

quickly as possible before the timber value is lost. Trees are supposed to decompose when the 

die. The organics in the soil depend on this natural process that the USFS spend tax dollars to 

eliminate.

1-51

Comment #5: You ignore the science in Opposing Views Attachments #8 and #14. They 

contain statements by many Ph.D. scientists who provide irrefutable evidence that dead and 

dying trees in a post-fire landscape have significantly more value if left in place to function as 

Nature intended, than logging them off to provide corporate profit. To serve the public, 

comply with "best science," and protect provide important wildlife habitat you must drop this 

timber sale and seek your wood elsewhere.

1-66

Comment #7: Without exception all post-fire timber sales describe the need to "capture" trees 

before they loose economic value. Elsewhere in these comments I have described the tragic 

wildlife habitat destruction resulting from any and all post-fire timber sales. I have listed the 

names of over 600 Ph.D. biological scientists who recommend post-fire landscapes must 
132

Comment 

# Comments

never be disturbed. You propose rob the organic material that should be returned to the soil. 

You trade away wildlife habitat with this timber sale. Your Purpose and Need does not 

mention any ecological benefits from post-fire timber sales. Why? There are no ecological 

benefits ... just ecological destruction. Clearly, the real unannounced purpose for this postfire timber sale is to provide profit opportunities for resource extraction corporations at public 

expense.

1-73

Forest ecologists and some biologists know the only time a wildfire is catastrophic is when it 

burns homes in the WUI. They know Nature restores the forest with fire but they are 

frightened to acknowledge it. Why? Their jobs pay well and they don't want to harm their 

promotion possibilities.

1-76

Professor Jerry Franklin noted that logging dead trees often has greater negative impacts than 

logging of live trees. He concluded that "timber salvage is most appropriately viewed as a 

'tax' on ecological recovery." Beyond those concerns, post-disturbance logging often 

intensifies the potential severity of future fires by concentrating the slash from logging at or 

near the ground. Rather than leaving plant material standing - and providing perching, 

nesting, and feeding sites for wildlife - such logging abruptly moves the material to the 

ground. Most of this material would naturally fall to the ground, adding important supplies of 

nutrients and energy to the forest floor and structure in the form of woody debris to stream 

channels. But this naturally happens over decades, not in the relatively short time associated 

with a logging operation."

1-77

This post-fire renewal, known as "complex early seral forest," or "snag forest," is quite 

simply some of the best wildlife habitat in forests, and is an essential stage of natural 

processes that eventually become old-growth forests over time. This unique habitat is not 

mimicked by clearcutting, as the legislation incorrectly suggests. Moreover, it is the least 

protected of all forest habitat types, and is often as rare, or rarer, than old-growth forest, due 

to extensive fire suppression and damaging forest management practices such as those 

encouraged by this legislation.

368-20 ANN also opposes reforestation (e.g. site prep and planting) in LSR forest, natural 

regeneration is preferable in habitats managed for conservation values such as LSR forest.

368-25 In general seed sources are available adjacent to all "snag fields," providing for adequate 

recovery and regeneration.

368-33

during the Biscuit Fire Recovery DEIS in response to salvage logging proposals in the 

Siskiyou National Forest, Jerry Franklin provided the following comments: "Salvage logging 

of large snags and down boles does not contribute to recovery of late successional forest 

habitat; in fact, the only activity more antithetical to the recovery process would be the 

removal of surviving green trees from burned sites. Large snags and logs of decay resistant 

species, such as Douglas fir and cedars, are critical as early and late successional wildlife 

habitat as well as for sustaining key ecological processes associated with nutrient, 

hydrological, and energy cycles."

368-65

Much of the forest burned and proposed for salvage is Douglas fir, ponderosa or sugar pine 

habitat at low elevations and should be allowed to recover naturally. Professor Jerry Franklin 

seems to agree stating in his comment on the Biscuit Fire salvage project that "naturally 

disturbed habitat that is undergoing slow natural reforestation—without salvage or planting—

is the rarest of the forest habitat conditions in the Pacific Northwest. Yet it is increasingly

evident from research such as at Mount St. Helens, that such large slowly reforesting 

disturbed areas are important as hot spots for regional biodiversity."
133

Comment 

# Comments

368-84

Small patches of natural, late seral forest are rare in the planning area and all late seral 

habitat, subjected to any level of fire severity, should be maintained for habitat, to increase 

complexity and reduce fragmentation.

501-2 Give it time for forests to regenerate. Fires were part of preserving forests in ancient Native 

American knowledge, and now proven with science.

515-7

Natural Forest Regeneration is Best Study after study has shown that letting fires recover on 

their own without planting conifers will result in the most biodiverse and successful post-fire 

plant community that will thrive due to localized adaptation. Letting successional species 

return to the burn area on their own will allow for the existence of a naturally regenerating 

burn area, one of the most unique habitat types in the West. Planting conifers and 

implementing artificial reforestation will diminish the important ecological role of the postfire plant community.

516-34

Unlike the Zhang article (located in the Cascades, on private industrial forestlands, in which 

no actual research or plots were used) a 2007 article by Shatford et al. from the Journal of 

Forestry involved research in the Klamath Siskiyous regarding reforestation of public lands 

after wildfire disturbance. The article is entitled, Regeneration after Forest Fire in the 

Klamath-Siskiyous: How Much, How Soon? We provided the article to the Forest Service 

during project scoping. Quoting directly from Shatford: "[O]ur findings suggest that the 

prognosis for achieving reasonable conifer densities [from natural regeneration] are fair to 

excellent, even on sites with high cover of broad-leaved shrubs and hardwoods. Although 

conifer growth may be delayed by competition over the short term, benefits in terms of 

wildlife habitat and site fertility should be considered. Viewing ecosystem recovery as a 

variable and dynamic process highlights the limitations of short-term studies that provide an 

incomplete picture of the regeneration process. In addition, assertions that burned areas, left 

unmanaged, will remain unproductive for some indefinite period seem unwarranted." It is 

also telling that the DEIS simply omits reference to findings such as those by Noss et al. in 

2006 indicating that naturally disturbed, un-salvaged, early successional forests are often the 

most biologically diverse of all forest conditions and are both more rare and more imperiled 

than old-growth forests in many regions.1

516-52

The agency's proposal to the harvest "dying" fails to disclose the scientific controversy or 

respond to the best available science. As discussed by Lindenmayer, Noss, and others, 

(Lindenmayer et al. 2004, Beschta et al. 2004, Lindenmayer and Noss 2006, Noss and 

Lindenmayer 2006) ecosystems on sites damaged by the passage of fire are in a stressed 

condition and are the least able to withstand further disturbance. All trees that have a chance 

of surviving are needed to play critical roles in natural site regeneration. They should be 

preserved, even if some will later die. They provide site-adapted seed sources for new trees, 

shade for seedlings that is critical under the xeric conditions of most western forests, and a 

host of benefits to wildlife. If a few later succumb, they will provide snag habitat useful to 

wildlife. (Cf. e.g. Hutto 2006.) Furthermore, even dead trees can play an important role in 

natural site restoration, as outlined by the above authors. A discussion of these considerations 

was largely absent from the NEPA documentation related to the harvest selection and 

marking criteria.

516-103

Please note that there is almost universal agreement that salvage logging does not leave 

watersheds and forests in a healthier, more resilient state, and that the timber volume gained 

via salvage is neither predictable nor sustainable. We urge the Forest Service to familiarize 

itself with the growing body of literature indicating that the post-fire ecosystems have more 

to offer than simply an opportunity for salvage logging and plantation forestry. We especially 
134

Comment 

# Comments

urge Forest planners to recognize the extraordinary biological and botanical values of Forest 

Service lands on the Siskiyou Crest near Condrey Mountain and Dry Lake Mountain. Please 

emphasize natural recovery of these areas as opposed to salvage logging and plantation 

establishment.

578-2 It is common knowledge now that letting burned forests recover naturally is absolutely the 

best management alternative.

Comment Response #117: Literature provided during scoping

Concern statement:

There is a concern that literature submitted in support of comments made during the Scoping 

Period was not addressed in project design, project analysis, or the scoping responses.

Forest Service Response:

As described in 40 CFR 1501.7, "there shall be an early and open process for determining the 

scope of issues to be addressed and for identifying the significant issues related to a proposed 

action." The purpose of the scoping period is for the discovery of alternatives to a proposal or 

significant impacts that may have been overlooked. 

In the disposition of comments provided in the Scoping Outcome Summary available in the 

project record and on the project website, all comments that identified relevant new information

regarding the proposed action, provided suggestions for the development of alternatives to the 

proposed action, or were site-specific in regards to proposed project activities were addressed. 

In fact, on pages 59-64 of the Scoping Outcome Summary, topic numbers 14, 16, and 18 address 

the project-specific concerns regarding the reduction of fire hazard and the increase of fire 

resiliency that the commenter refers to including whether proposed post-fire logging will restore 

a natural fire regime and create a fire-adapted forest community, whether post fire logging will 

influence fuel loading in stands by the creation of slash, and the effect the size of fuels removed 

from the project area will have on fire spread and intensity. 

The literature provided during the scoping period was considered by the specialists of the 

interdisciplinary team. Scientific papers provide information but they are rarely site and project 

specific, nor is there a requirement in law or regulation to follow the recommendations of a 

journal article. Journal articles do not provide management direction to the Forest Service. That 

comes from the Forest Plan. Project design is based on the difference between site-specific 

existing conditions and the desired condition in the Forest Plan. Analysis is based on site-specific 

data where it exists, and where it does not, the agency must use the best information otherwise 

available. In its analysis, the Forest Service must consider the available information, and make 

that information available to all. There is however no requirement of the Forest Service to 

conduct an exhaustive literature review of every possible journal article for every proposed 

project. In its review, the Forest Service must acknowledge scientific controversy concerning the 

effects of an activity. When a decision is made, the Forest Service must show a rational 

connection between the evidence presented, the facts found and decision made. We believe the 

record for the Horse Creek Project shows these standards have been met. 
135

For a detailed response to concerns regarding the treatment of activity fuel in the project please 

refer to comment response #9; for the effect of salvage harvest in promoting fire adaptability see 

comment response #59; for the effect of salvage harvest in reducing fire severity see comment 

response #53; and for the susceptibility of plantations to fire see comment response #17.

Associated Comments:

Comment 

# Comments

516-25

Failure to Address Science that Conflicts with the Agency's Logging Agenda Our scoping 

comments of December 19, 2016 contained a number of peer-reviewed and Forest Service 

documents that contradict the agency's contention that commercial salvage logging will 

reduce fire hazard or increase fire resiliency. Indeed, a great deal of scientific literature 

indicates that the proposed salvage logging will increase fire hazard and decrease fire 

resiliency in the project area. Throughout the DEIS, Klamath National Forest timber sale 

planners ignore science that conflicts with their logging agenda and their preferred 

assumptions. NEPA does not permit this. Prior to issuing a decision to salvage log the agency 

must acknowledge and address peer-reviewed science indicating that post-fire logging will 

increase future fire hazard and decrease future fire resiliency in the project area.

516-33

Our scoping comments on proposed fire salvage logging in this planning area contained an 

extensive list of attachments and an exhaustive bibliography. Yet most of these studies are 

not relied upon or meaningfully addressed by the agency. Instead the Forest Service elected 

to cherry-pick a small handful of studies that have questionable utility to the actions being 

proposed. How did the agency select these studies? Why are they more relevant than the body 

of literature submitted previously by our organizations? Does the Forest Service contend that 

scientific controversy does not exist regarding the effects of post-salvage logging on 

firefighter safety, reforestation, and ecological health?

Comment Response #118: Best available science

Concern statement:

There is a concern that the agency will not consider multiple documents provided during the 

comment period as the best available science for the project planning and analysis.

Forest Service Response:

The "best available science" is addressed in the Code of Federal Regulations (40 CFR 1502.24) 

"Agencies shall insure the professional integrity, including scientific integrity, of the discussions

and analyses in environmental impact statements. They shall identify any methodologies used 

and shall make explicit reference by footnote to the scientific and other sources relied upon for 

conclusions in the statement. An agency may place discussion of methodology in an appendix." 

Literature that has been provided by commenters that supports a concern regarding a project 

level effect or methodology has been reviewed by the interdisciplinary and discussion of this 

literature can be found throughout this response to comments document. The interdisciplinary 

team used the best available science in preparing the project design and analysis for this project 

and the professional and scientific integrity of this best available science is documented in the 

FEIS and supporting resource reports and appendices. Literature does not become "best available 

science" until it is related to the analysis and when the findings are interpreted or adapted to site 

specific conditions. Please see also response to #117 above.
136

Associated Comments:

Comment 

# Comments

1-23

You will all reject the best science in these comments. You witlessly follow the 

recommendations of a few biased IDT members and reject the conclusions of over 600 Ph.D. 

biological scientists.

1-24

You ignore Dr. Cohen's fine fuels removal method because it doesn't produce precious 

volume. After all, how would you get-out-the-cut and serve your corporate masters without 

volume.

1-25

The opposing views attachments to these comments present the research conclusions of 

hundreds of independent scientists. Of course the USFS routinely ignores and rejects this 

science because it is inconsistent with USFS lies needed to motivate agency employees to 

embrace the agency timber agenda.

1-26 Request for changes to be made to the final NEPA document: Please respond to each 

opposing view and post the responses online for the public to see.

1-27

Comment #1: I ask the resource specialists reading these comments to remove their USFSsupplied blinders and understand the USFS has an overriding timber (produce volume) 

agenda and culture. Please assure that your Chapter III effects disclosures for No Action and 

the Proposed Action are consistent with the science I present in the Opposing Views 

Attachments. Based on the "best science" if your resource will be damaged or destroyed 

please indicate this is likely to occur in your effects.

1-35

Comment #: Mr. Hupp, Mr. Bowden, Mr. Isbell, Mr. Grunbaum, Mr. Rodriguez, Mr. Tripp 

and Mr. Bell your education and experience must be extraordinary! I quote over 600 Ph.D. 

biological scientists below who all agree a post-fire landscape must never be "treated" (a.k.a. 

logged) and would clearly prefer No Action.

1-41

Comment #2: Supervisor Grantham, you reject the advice of over 600 Ph.D. biological 

scientists who signed a letter to Congress in 2006 and a letter to the Senate and President 

Obama in 2015. Both letters contained multiple reasons why a post-fire landscape must never 

be disturbed. Why do you accept the recommendations of Mr. Paulo to "treat" the Horse 

Creek area whose job depends on selling timber sales. Might there be bias? Keep in mind 

USFS leaders have been telling the public agency projects are all grounded in "best science" 

since 1993.

1-42

Comment #3: Supervisor Grantham, you have just read 1) a 2006 letter to Congress signed by 

540 Ph.D. independent biological scientists, and 2) a letter sent to Congress and President 

Obama signed by 253 Ph.D. independent biological scientists. Each letter includes 

undisputable evidence explaining why a post-fire landscape must remain intact and unlogged. 

Here are short excerpts from each letter: Letter #1-"Many scientist-reviewed studies and 

syntheses (please see the selected citations appended to this letter) have recently come to this 

conclusion. For example, no substantive evidence supports the idea that fire-adapted forests 

might be improved by logging after a fire. In fact, many carefully conducted studies have 

concluded just the opposite. Most plants and animals in these forests are adapted to periodic 

fires and other natural disturbances. They have a remarkable way of recovering - literally 

rising from the ashes - because they have evolved with and even depend upon fire." (page 1, 

paragraph 3) Letters #2 and #3- "After a fire, the new forest is particularly vulnerable to 

logging disturbances that can set back the forest renewal process for decades. Post-fire 

logging has been shown to eliminate habitat for many bird species that depend on snags, 

compact soils, remove biological legacies (snags and downed logs) that are essential in 

supporting new forest growth, and spread invasive species that outcompete native vegetation 
137

Comment 

# Comments

and, in some cases, increase the flammability of the new forest." (page 2, paragraph 

2)) Most USFS line-officers who value healthy non-timber natural resources would allow 

the recommendations of over 600 Ph.D. independent biological scientists to override several 

biased timber IDT members.

1-47

Comment #4: Supervisor Grantham, Ms. Bousfield, Ms. McChesney, Ms. Gustavson, Mr. 

Isbell, Mr. Bell, Mr. Grunbaum, Mr. Rodriguez, Mr. Beal, Mr. delaFuente, Mr. Tripp, Mr. 

Hermandorfer, Mr. Ford, Mr. Bowden, Mr. Dietzler, Mr. Dennis, Mr. Hupp, Ms. Corbett, Ms. 

Boland, Ms. Lonergan, and Ms. Miller, clearly the conclusions of over 600 independent 

Ph.D. scientists recommending to never log a post-fire landscape represent "best science."

1-52

Comment #6: Attachment #15 contains quotes by Hilda Diaz-Soltero, Dr. Ann Bartuska, 

Chief Dale Bosworth, Associate Chief Sally Collins, Chief Dr. Mike Dombeck, Chief F. Dale 

Robertson, Agriculture Secretary Dan Glickman, and USFS Chief Tom Tidwell, who all tell 

the public the USFS depends on "best science" as the basis for it's projects. I have included 

attachments to these comments that contain quotes of the research conclusions of hundreds of 

scientists no connected with the USDA that describe major short and long term damage to the 

non-timber resources in the project area resulting from commercial logging and road 

construction ... especially temporary road construction. This represents best science. These 

Opposing Views Attachments are not contained in the References section of this draft EIS. 

Why?

1-67

Comment #8: Supervisor Grantham, when Ms. Bousfield, Ms. McChesney, Ms. Gustavson, 

Mr. Isbell, Mr. Bell, Mr. Grunbaum, Mr. Rodriguez, Mr. Beal, Mr. delaFuente, Mr. Tripp, 

Mr. Hermandorfer, Mr. Ford, Mr. Bowden, Mr. Dietzler, Mr. Dennis, Mr. Hupp, Ms. Corbett, 

Ms. Boland, Ms. Lonergan, Ms. Miller, Mr. Siemers, Mr. Dock Chastain, Mr. Bousfield and 

Mr. Paulo disagree with and reject the findings of hundreds scientists does this constitute 

"scientific consensus?" Please explain why you choose to rely on the knowledge of 20 USFS 

IDT members and reject the "best science" recommendations of over 600 Ph.D. biological 

scientists. Please don't tell the public the scientist's statements aren't applicable because they 

are not site specific unless you omit all literature in your References section that is not 

specific to this timber sale.

Comment Response #119: Literature use in project analysis

Concern statement:

Commenters expressed specific concerns regarding the use of literature in the project analysis. 

This includes the use of the Zhang et al. 2008 paper, commenters are concerned that this paper 

only compares post fire logging and replanting with post fire logging and no replanting which 

wouldn't account for the option of comparing no logging and natural recovery. There is also 

concern over the use of the Weatherspoon and Skinner 1995 paper in use for comparison 

between plantations and uncut/partially-cut stands.

Forest Service Response:

Comments suggest that post-fire reforestation considerations relied solely on a paper by Zhang et 

al. 2008. That is not correct. Peterson (2015), Shatford et al. (2007) Knapp et al. (2012), 

McDonald and Fiddler (1989), Lowell et al. (1992), Skinner et al. (2006) and others are among 

cited papers used to evaluate post-fire conditions. Finally, stand data was compiled from existing 

plots in the project area and used to simulate future stand conditions based on proposed 
138

treatments. The Forest Vegetation Simulator (FVS) was used to estimate time needed to establish 

conifer-dominated stands (FEIS, page 213). FVS is a state-of-the-art vegetation model that is 

widely used to model vegetation response after logging or other disturbance events such as 

wildfire. As noted in the Fire and Fuels Report, page 23; "Weatherspoon and Skinner 1995 and 

Peterson et al. 2009 both found that fire intensity and damage to the overstory are much lower in 

plantations where slash has been removed following logging. A high percentage of plantations in 

the Gap Fire burned at low severity." The use of this literature was not to support a position for 

or against conversion of snag patches into plantations, but rather to analyze the effects of the 

proposed project activities in regards to fuels and fire hazard. The use of this literature was for 

describing how the fire effects are reduced in plantations that received site preparation and fuels 

reduction activities as opposed to leaving post-logging debris or slash in place.

Associated Comments:

Comment 

# Comments

516-29

Zhang et al. (2008) did not compare post-fire logging/planting to no-logging/naturalregeneration. They compared post-fire logging and replanting to post-fire logging with no 

replanting--i.e., after the tractor logging had compacted the soil, removed any natural seed 

sources, and destroyed any natural regeneration that might have been coming in. Therefore, 

Zhang et al. (2008) has no relevance to the Horse Creek project. Nor does it have any 

relevance to carbon stocks after fire, including high-intensity fire, in areas that have not been 

logged or replanted.

516-30

Zhang et al. (2008) do not present any quantitative data on plant species, and instead cite to 

DiTomasso et al. (1997). The DiTomasso et al. (1997) study compared salvagelogged/replanted/herbicide-treated areas to salvage-logged/replanted/No-herbicide areas. 

Therefore, once again, the study is inapplicable to the Horse Creek logging project (wherein 

the comparison is between salvage logging/replanting/herbicides and no- logging/noplanting/no-herbicides). It is not clear whether the journal (California Agriculture) in which 

DiTomasso et al. (1997) was published is peer-reviewed, but the study concludes that salvage 

logging followed by herbicides initially reduces plant species richness relative to salvage 

logging followed by no herbicides, but that there is similar plant species richness over time, 

and possibly somewhat higher plant species diversity in some of the logged/planted/herbicide 

areas relative to logged/planted/no- herbicide. Total vegetative cover was highest in the areas 

with no herbicides. Again, though, the results of DiTomasso et al. (1997) are irrelevant to the 

proposed salvage logging project because they do not compare no-logging/no-replanting/noherbicides to logging/replanting/herbicides.

516-32

Our organizations were also surprised to see the Forest Service reference Weatherspoon and 

Skinner (1995) as supporting the conversion of snag forests into fiber plantations. The 1995 

study referenced by the Forest Service clearly states "no comparison of wildfire hazard 

between plantations and uncut/partially-cut stands is provided by this study."

Comment Response #120: MIS analysis, request for extension to comment 

period

Concern statement:

There was a request for an extension to the comment period due to the lack of availability of 

management indicator species analysis report for public review.

Forest Service Response:
139

No extension to the comment period was granted; management indicator species analysis was 

available for public review when and before the DEIS comment period began. In addition to 

management indicator species information included in the Aquatic and Wildlife Resources 

sections of Chapter 3 of the DEIS, a detailed Aquatic Resources Report was available on the 

project website and available for public review on April 27, and a two part detailed report 

regarding management indicator species was available on April 24, one and four days, 

respectively, before the DEIS comment period began on April 28, 2017.

Associated Comments:

Comment 

# Comments

516-3

We are very concerned about the direct, indirect, and cumulative environmental impacts on 

wildlife, watersheds and other resources in the area. We request an additional commenting 

period after the agency presents a detailed analysis of the project's effects prior to finalizing 

the Environmental Impact Statement. For instance, the current DEIS contains no information 

about the location, number and site-specific conditions of survey and manage habitat in the 

project area. The location, population trends, and acres of impacted Management Indicator 

Species habitat is also not available to the reader.

Comment Response #121: General project support

Concern statement:

Letters from commenters described general support of the project activities being proposed 

including the objectives for fuels reduction and reforestation, roadside hazard removal, and 

benefits to the community.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

2-11 Fruit Growers supports the proposed fuel and reforestation proposals.

2-16 The proposed 103 miles of roadside hazard and 1,243 acres of roadside fuels treatment are 

good approaches to meeting the project objectives.

6-1

The Siskiyou Unit of the California Department of Forestry and Fire Protection (CAL FIRE) 

is in support of your Horse Creek Community Protection and Forest Restoration Project 

(Horse Creek Project) which will reduce fuels along egress and ingress roads, on strategic 

ridges, and adjacent to private property.

6-4 I support this proposed project and believe its implementation will benefit the citizens of 

Siskiyou County.

369-1 Based on our review of the DEIS, we have rated each of the alternatives as Lack of 

Objections (LO) (see enclosed "Summary of EPA Rating Definitions"). We strongly support 
140

Comment 

# Comments

many of the core components proposed in the Horse Creek Project, including the restoration 

activities planned for the Horse Creek Botanical Area, as well as the prohibition on salvage 

harvest within wilderness, backcountry, research natural areas, designated or recommended 

wild rivers, inventoried roadless areas, or riparian reserves

520-7

Siskiyou County is extremely supportive of the maximum amount of treatment and 

restoration possible being achieved through completion of this Project; which would allow 

some revenue to be realized after the Gap Fire, restore severely damaged areas within the fire 

perimeter, and would increase fire resiliency throughout the Forest. As you are aware, 

catastrophic wildfire is a situation that is faced on an almost annual basis throughout Siskiyou 

County, and any efforts that reduce the chance of wildfire must be implemented throughout 

our federal forests. In addition, private industry actively treats on their property following a 

wildfire, and treatment on forest service land will assist in preventing future wildfire on these 

private properties.

589-3

We are very encouraged to see the Klamath National Forest considering ecosystem 

restoration on a large scale to address many of the factors that continue to degrade 

ecosystems. We fully support the goal of establishing a more resilient forest. The conifer 

plantation reforestation that will occur on an estimated 458 acres of high severity burn areas 

is crucial to protecting the forest from fires and disease.

Comment Response #122: General project opposition

Concern statement:

Letters from commenters expressed general opposition to the project objectives and purpose, 

with specific concern regarding the Siskiyou Crest, Late Successional Reserves, damage to 

natural resources, the Pacific Crest Trail, roads, fire resiliency, and salvage in general.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

368-1

We oppose large-scale post-fire logging especially on the Siskiyou Crest, in LSR forest and 

in areas that burned within the range of variability for wildland fire in the Klamath-Siskiyou 

Mountains.

368-8

The proposed Horse Creek Community Protection and Forest Restoration Project will 

damage many natural resources in the Middle Klamath watershed and make the communities 

of the Middle Klamath River less fire resilient and fire wise.

368-9 Alternatives 2-4 in the DEIS are all steps in the wrong direction and will continue the failed 

post-fire management policy known as "salvage" logging.

368-18 ANN opposes post-fire logging in LSR forest.
141

Comment 

# Comments

368-101 ANN opposes all 14 units located on the Siskiyou Crest and all units in upper Buckhorn and 

Middle Creek that lay below the Pacific Crest Trail (PCT).

411-1 I encourage you to not use forest fires as an excuse to further destroy and degrade the 

Siskyou back country. I endorse the position of SK Wild

491-1 NO! No so-called salvage logging, and no more new logging roads! NO!!

501-1 Stop Salvage Logging. When will truth prevail that will prove we need to save historical 

places for future generations.

Comment Response #123: Cumulative effects analysis inadequate

Concern statement:

There is a concern that the cumulative effects analysis for the project did not fully consider and 

disclose the effects of all the private timber operations and salvage harvest occurring on adjacent 

private lands, nor the effects of previous Forest Service actions such as fire suppression activities 

and the Westside Fire Recovery Project. Of specific concern were the cumulative effects to the 

northern spotted owl, wildlife habitat and its connectivity, aquatic resources, water quality and 

watershed condition, future fire severity, and local economic needs. It is recommended that the 

cumulative effects analysis should assume that all areas on private land containing merchantable 

timber which burned at moderate- to high-severity would be harvested.

Forest Service Response:

The cumulative effects analysis for the Horse Creek project was updated since publication of the 

DEIS to include private timber harvest plans received since that time. As described in Appendix 

B of the FEIS, the Westside Fire Recovery Project and other federal projects were considered as 

ongoing actions and included in the analysis of cumulative effects. Private ongoing actions 

considered in the cumulative effects analysis included two non-industrial timber harvest 

management plans (49 acres), three timber harvest plans (1,444 acres), and 45 emergency timber 

operations (8,973 acres). In addition to these known private harvest and emergency operations

plans, the cumulative effects analysis included the assumption, based on communication with 

Fruit Growers Supply Company, that all of their remaining lands affected by the 2016 Gap Fire 

would be harvested with future notices of emergency timber operations (about 4,000 acres). 

The cumulative effects of these activities and others described in Appendix B of the FEIS were 

disclosed by each resource specialist in their section of Chapter 3 of the FEIS and in their 

supporting resource reports available on the project website. For information about cumulative 

effects to the northern spotted owl and wildlife habitat and its connectivity, please see the 

Wildlife Resources section and supporting resource reports. For information about cumulative 

effects to aquatic resources and fish, refer to the Aquatic Resources (Fisheries) section of the 

FEIS and the supporting resource report. For information about cumulative effects to water 

quality and watershed condition, refer to the Hydrology section of the FEIS and the supporting 

resource report. For information about cumulative effects to future fire severity, refer to the Fire 

and Fuels section of the FEIS and the supporting resource report. For information about 

cumulative effects to local economic needs, refer to the Socio-Economics section of the FEIS 

and the supporting resource report.
142

Associated Comments:

Comment 

# Comments

368-14

FGS is preparing to log off their holdings in the Gap Fire and the KNF is proposing to 

clearcut thousands of acres of fire affected forest currently benefiting from natural fire 

revitalization. The proposed public lands logging will further exacerbating already 

significant cumulative impacts to old forest and endangered species habitat, endangered 

fisheries (coho salmon), soils and future fire hazards on the Klamath River due to recent post 

fire logging in the Beaver Fire and Happy Camp Fire footprints.

368-80

The analysis of the Horse Creek Community Protection and Forest Restoration Project in the 

DEIS did not include adequate analysis of cumulative impacts including the impacts 

associated with discretionary fire suppression activities, post fire logging on private land in 

the Beaver Fire and Gap Fire footprint, and post fire logging on federal land in the Westside 

Project.

368-81

The impact of these cumulative impacts has potentially detrimental consequences to stream 

habitats, water quality, endangered fisheries, cold water tributary streams, late seral forest 

habitat, forest complexity, future fire severity, connectivity of habitat, connectivity between 

LSR forests, and connectivity on the Siskiyou Crest..

516-91

Please note that page 132 of the DEIS indicates that cumulative effects "modeling suggests 

that watershed function may be adversely impacted by high levels of watershed disturbance" 

yet the DEIS calls for significant addition watershed disturbance through clearcut logging, 

landing establishment and new road construction on federal lands while failing to quantify or 

analyze the cumulative impacts of ongoing private industrial post- fire clearcutting.

519-14

The DEIS is insufficient in its look at cumulative impacts from private forestry. This 

deficiency affects all of the categories of environmental analysis (e.g., air quality, aquatic 

conservation strategy, fisheries, etc.) as well as all proposed alternatives. Cumulative impacts 

or effects are those "which result[] from the incremental impact of the action when added to 

other past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or non-Federal) or person undertakes such other actions." 40 C.F.R. § 1508.7. 

Furthermore, "[c]umulative impacts can result from individually minor but collectively 

significant actions taking place over a period of time." Id. In short, approximately half of the 

project area is composed of "checkerboard" lands, alternating private and public blocks of 

land. Because of weak California law regulating post-fire logging, private landowners are 

able to log as much of the burned area—including areas of low- and moderate-severity— as 

they would like. Based on previous experience, the Klamath National Forest should 

anticipate that all areas on private land containing merchantable timber would be logged. 

(Indeed, CAL Fire has already been notified that over 8,000 acres will be logged, including 

areas that burned at low-severity.) Because of this massive amount of post-fire logging on 

adjacent lands, the cumulative impact of activities on federal public land is heightened, and 

in effect, the federal lands come to bear the entirety of the "conservation burden." This was 

true for the Beaver Fire area of the Westside Fire Recovery Plan and this is true for the Horse 

Creek Project. After a fire, private landowners generally utilize two sections of the Forest 

Practice Rules: 14 Cal. Code Regs. § 1038 and § 1052. Under "exemption notices," pursuant 

to 14 Cal. Code Regs. § 1038, timber companies are allowed to remove "dead, dying, or 

diseased trees of any size" up to 10% of the "average volume per acre." Under "emergency 

notices," pursuant to 14 Cal. Code Regs. § 1052, landowners are able, after providing only 

five days notice to CAL FIRE, to log an unlimited large area of forest, provided only that the 

trees are "damaged" by fire—a term which lacks no definition and depends on the judgment 

of the registered professional forester submitting the notice. There are no snag retention 
143

Comment 

# Comments

requirements for post-fire logging. Furthermore, the Forest Practice Rules do not include any 

wildlife protection for emergency notice logging. Timber companies typically utilize both 

rules to maximize timber extraction. First, a timber company will submit § 1052 emergency 

notices for large harvest areas. The company will then submit a § 1038 exemption notice for 

a large area of land, typically an entire watershed or management unit. The timber company 

will then utilize the § 1052 emergency notice to log large contiguous units and utilize the § 

1038 to "clean up" and remove merchantable timber from other areas. As the Forest Service 

witnessed after the Beaver Fire of 2014, private landowners, including the same landowner 

as documented by the Beaver Fire (Fruit Growers Supply Co.), will use emergency notices to 

log areas that burned at low-severity. Logging of green trees will, for example, greatly 

impact the potential impact analysis for wildlife as much of the analysis presumes that areas 

that burned at low-severity will not be logged and that they will provide the same ecosystem 

function as before. For example, the wildlife biological evaluation assumes the presence of 

nesting/roosting habitat, some of which is found on private land. The Klamath National 

Forest is evidently aware of this practice. As described in the Biological Assessment 

provided for the Westside Fire Recovery Plan, "Private land harvest in the Beaver fire area 

does not appear to be based on effects from high fire severity, so that green trees (i.e. suitable 

NRF) and fire affected trees are being removed." Forest Service, Wildlife Biological 

Assessment for Westside Fire Recovery Project (July 24, 2015) at G-102. Indeed, the Forest 

Service removed salvage from the Beaver Fire area, except for roadside hazard logging, 

because of the high cumulative impact risk caused by private land salvage: "All salvage was 

dropped in the Beaver Fire area because of potential cumulative impacts on habitat 

connectivity and remaining northern spotted owl habitat from salvage harvest on 

checkerboard private land holdings." Westside Project Record of Decision at 18. As of June 

5, 2017, EPIC has identified 21 emergency notices related exclusively to the 2016 Gap Fire 

totaling 4,863 acres to be logged on private lands within the project area and often adjacent 

to proposed action. Many of these were missing from the consideration of cumulative 

impacts—some 3,723 acres—because they were filed after the DEIS was submitted. Given 

the experience with the Beaver Creek Fire, the Forest Service should assume that all timber 

that was of sufficient age to harvest that burned, at any severity, would be logged. --2-16EM037SIS: FGSC, 429 acres T47N-R10 W 35, 36. Date filed 10/3/16 --2-16EM-038SIS: 

Christian Futures, 344 acres, T46N-R10W 3,5,9. Date filed 10/3/16 --2-16EM-039SIS: 

FGSC, 198, T46N-R10W 17. Date filed 10/6/16 --2-16EM-041SIS: Trudi Rainey, 28 acres, 

T46N-R10W, 8. Date filed 11/21/16 --2-17EM-001SIS: Mannix, 31 acres, T46N-R10W, 

9,16. Date filed 1/19/17 --2-17EM-004SIS: EB Development Corporation, 113 acres, 

T46N-R10W 8,9, Date Filed 3/22/17 --2-17EM-005SIS: John M. Huston, 82 acres, T46NR10W 8, Date filed 4/7/17 --2-17EM-006SIS, Mary Schaffer Revocable Trust, 9 acres, 

T46N-R10W 8, Date Filed 4/7/17 --2-17EM-007SIS: Dennis and Carol Lawrence, 47 acres, 

T46N-R10W 8, Date filed 4/7/17 --2-17EM-008SIS: Michael and Donna Strong, 9 acres, 

T46N-R10W 5, Date filed 4/7/17 --2-17EM-009SIS: Inez Rainey, 178 acres, T46N-R10W 

15,16, Date filed 4/13/17 --2-17EM-010SIS: FGSC, 1,175 acres, T47N-R10W 27, 28, 35, 

Date filed 4/17/17 --2-17EM-011SIS: FGSC, 83 acres, T47N-R10W 29, Date filed 

4/18/17 --2-17EM-012SIS: FGSC, 609 acres, T47N-R10W 17,19, Date filed 4/18/17 --2-

17EM-013SIS: FGS, 975 acres, T47N-R10W 31, Date filed 4/17/17 --2-17EM-014SIS: 

Dennis Lang and Michele Treuscorff, 30 acres, T46N- R10W 9, Date filed 4/21/17 --2-

17EM-015SIS: Richard True and Mary Hartshorn, 120 acres, T46N-R10W 5,9, Date filed 

4/20/17 --2-17EM-016SIS: Gary Rainey and Karen Rainey, 23 acres, T46N-R10W 9, Date 

filed 4/24/17 --2-17EM-019SIS: Mike Morgan, 355 acres, T46N-R10W 7, Date filed 
144

Comment 

# Comments

5/15/17 --2-17EM-021SIS: Stephen R. and Annette M. Riede, 8 acres, T46N-R10W 8, Date 

filed 5/25/17 --2-17-022SIS: Robert A Decoursey Trustee, 17 acres, 46N-10W 8, Date filed 

5/25/17 It is likely that at least one, if not more, landowner submitted a §1032 exemption 

notice. However, given the broad landscape and the lack of specific harvesting details, EPIC 

has not attempted to locate any. EPIC believes that the Forest Service is obligated to examine 

the CAL FIRE exemption library, available at 

ftp://thp.fire.ca.gov/THPLibrary/Cascade_Region/Exemption%20Notices/, to see if any have 

been submitted. Please provide mapping showing the location of all actions considered under 

cumulative effects overlaid with the proposed project activities. Given the importance that 

adjacent lands play, a visual representation of the cumulative effects logging would be 

helpful in evaluating potential impacts.

519-15

Please answer the following questions about private lands logging: Did private lands logging 

result in the taking of any owls? How much northern spotted owl habitat, and what type, was 

removed/downgraded/degraded by actions considered under cumulative effects?

519-16 How does private logging affect habitat connectivity?

519-17

Did actions considered under cumulative effects remove/log areas that burned below highseverity? If so, how much? To what degree does this vast amount of private post-fire 

logging satisfy the community "need" to "recover timber volume from fire killed trees"? In 

reviewing the cumulative effects of private salvage, KNF claims that "private timber 

companies (e.g., Fruit Growers Supply)) within the project boundary plan to remove fuel 

through salvage harvest and reduce fuels along

519-32

As seen from the Cumulative Impacts section of these comments, the KNF grossly 

underestimated the amount (the non-inclusion of 3,723 acres) of industrial logging activities 

on private lands, which includes 15,238 acres of the 40,834 acre project area. Because of this 

blatant miscalculation the Cumulative Watershed Effects (CWE) modeling - (Equivalent

Roaded Acres (ERA) model is used to evaluate watershed disturbance; the Universal Soil 

Loss Equation model (USLE) is used to evaluate soil erosion; and the Geology model (GEO) 

used to evaluate the potential for mass wasting) - used to predict effects to aquatic species is 

highly inaccurate.

593-1

Private Salvage Cumulative Effects: Given the significant private logging, EPIC is 

concerned about the cumulative effects of the proposed logging on federal public lands. All 

units visited appear to already be impacted by private salvage, including private salvage up 

to the ownership/unit boundary.

997-1

Two more emergency notices are online to add to the cumulative effects analysis: 

ftp://thp.fire.ca.gov/THPLibrary/Cascade_Region/Emergency%20Notices/2017/20170608_2

-17EM-023SIS.pdf 

ftp://thp.fire.ca.gov/THPLibrary/Cascade_Region/Emergency%20Notices/2017/20170612_2

-17EM-024SIS.pdf As our comments states, EPIC believes that it makes the most sense to 

just assume that all areas of private land that burned at moderate- to high-severity will be 

salvage logged (instead of just waiting to see who will file an emergency notice and when, 

together with the difficulty of predicting how much will be logged under a Section 1038 

exemption).

Comment Response #124: Support of Alternative 1

Concern statement:

Comments received that supported the no action alternative.
145

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

1-36

Mr. Grunbaum, a competent, knowledgeable fisheries biologist would tell the public No 

Action is preferable to any action alternative for aquatic species protection. Why? There 

would be no skidders and tractors weighing 35,000 pounds with spinning wheels and tracks 

operating on hydrophobic soils that will increase the sediment levels in streams to levels that 

are unimaginable.

1-68 I know USFS Responsible Officials never select the No Action alternative, however based on 

the clear adverse natural resource effects here it seems this would be a prudent thing to do.

Comment Response #125: Against Alternative 1

Concern statement:

Commenters expressed that the no action alternative would not meet the purpose and need of the 

project because there would be a longer recovery time, more fuels accumulation, and species 

diversity and structure may not recover. There was specific concern regarding the no action 

alternative in areas around private property including residences and private timber companies.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

7-4

Alternative 1 - No Action This alternative will not meet the purpose and need since no 

recovery will occur. This alternative will actually create conditions for long-term adverse 

effects as the untreated landscapes will once again be consumed by catastrophic wildfire as 

down fuels accumulate, over the next 10-15 years, from all of the untreated material. This has 

been the case on all of the past wildfire areas that have not been treated. Eventually, this area 

will burn again creating environmental effects greater than those from first fire. We don't 

believe this is what the public wants and is not in the best interest of taxpayer owned public 

lands.

7-8

In a many cases, it will be a minimum of 300 years before mature forests would once again 

occupy these sites. In some cases, forested stands may never re-occupy these sites. We don't 

believe that is what a majority of the public wants. They want to see green forests that 
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provide recreational opportunities, wildlife habitats for all species, clean and healthy 

watersheds, visually pleasing landscapes, and commodity removal opportunities. Doing 

nothing within these burned areas will not allow any of these things to happen for centuries.

7-9

Secondly, species establishment through natural regeneration may not promote the desired 

species for many of these sites. Artificial regeneration can insure the right species 

composition and allow for rapid conifer re-establishment on those areas that are treated.

518-1

Alternative 1-This should be reserved strictly for wilderness areas where there exists ZERO 

Wildland Urban Interface. While it would provide a great opportunity for data collection to 

address (either the Pros or Cons of) natural forest regeneration, it does not make sense in an 

area encompassing human residents and a private timber company.

Comment Response #126: Wildfire suppression as cumulative effect

Concern statement:

There is a concern that by virtue of including the ability to suppress future fire in the Horse 

Creek project area as part of the purpose and need of the project, that the Forest Service should 

analyze fire suppression activities in its cumulative effects analysis as a connected action.

Forest Service Response:

The fire suppression activities conducted in association with the Gap Fire were included in the 

analysis of effects as part of the existing condition in the Forest as described in the affected 

environment sections for each resource in Chapter 3 of the FEIS and in supporting reports 

available in the project record on the project website. This is in accordance with 40 CFR 1508.7 

and in accordance with the Council on Environmental Quality Guidance Memorandum on 

Consideration of Past Actions in Cumulative Effects Analysis dated June 24, 2005 that directs 

the way cumulative effects analysis should be conducted: "With respect to past actions, during 

the scoping process and subsequent preparation of the analysis, the agency must determine what 

information regarding past actions is useful and relevant to the required analysis of cumulative 

effects. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list 

and analyze all individual past actions.” 

Future fire suppression activities should not be considered in a cumulative effects analysis as this 

is not a reasonably foreseeable action, nor is it a connected action. The Council on 

Environmental Quality’s (CEQ) 40 questions document gives this guidance: "The agency has the 

responsibility to make an informed judgment, and to estimate future impacts on that basis, 

especially if trends are ascertainable or potential purchasers have made themselves known. The 

agency cannot ignore these uncertain, but probable, effects of its decision." “Reasonably 

foreseeable future actions” are defined in 36 CFR 220.3 and in the Forest Service Handbook at 

1909.15 as “Those Federal or non-Federal activities not yet undertaken, for which there are 

existing decisions, funding, or identified proposals. Identified proposals for Forest Service 

actions are described in 220.4(a)(1).” In our informed judgment, unscheduled future fire 

suppression activities are an emergency response to an unplanned event and are not reasonably 

foreseeable actions that can or should be included in cumulative effects analysis.

Furthermore, the commenter is correct that a connected action which should be included in a 

cumulative effects analysis is defined in the Forest Service Handbook as actions that "cannot or 
147

will not proceed unless other actions are taken previously or simultaneously" (FSH 1909.15, zero 

code, section 5). However, in our informed judgment, project activities will not determine 

whether a wildfire can or will occur in the project area, nor does a future potential wildfire 

control whether the proposed project can or will occur. Again, fire suppression activities are an 

emergency response to an unplanned event and not a proposed action which is subject to Forest 

Service control and responsibility. 

All reasonably foreseeable future actions are included in our cumulative effects analysis, as 

shown in Appendix B of the FEIS.

Associated Comments:

Comment 

# Comments

516-42

Yet here the Forest Service has refused to disclose even the site-specific and cumulative 

impacts of fire suppression activities (including dozer line construction in Reserve land use 

allocations) associated with the Gap Fire, let alone the cumulative impacts of the future fire 

suppression that the agency hopes to facilitate via additional logging.

516-43

Throughout the DEIS the Forest Service states part of the objective of the roadside salvage 

logging is to provide ingress and egress for firefighters and that part of the objective of unit 

salvage is to affect fire behavior and the ability to suppress future fires. Given that safety is 

one of the purposes of the project, and that fire suppression effectiveness was used as a 

measure of achievement of that purpose, there is no doubt that fire suppression is a connected 

and cumulative action to the authorized logging activities.

516-45

The Council on Environmental Quality (CEQ) regulations that implement NEPA "define the 

circumstances under which multiple related actions must be covered by a single EIS." 

Thomas v. Peterson, 753 F.2d 754, 758 (9th Cir. 1985). The Ninth Circuit has determined 

that, while agencies should be given "considerable discretion" in defining the scope of an 

environmental analysis, an agency is required to consider more than one action in a single EIS 

if they are part of a single proposal or are 'connected actions,' 'cumulative actions,' or 'similar 

actions.' Native Ecosystem Council v. Dombeck, 304 F.3d 886, 893-4 (9th Cir. 2002); 40 

C.F.R §1508.25(a)(1). The combined effects of salvage logging to facilitate future fire 

suppression, along with the impacts of that fire suppression, must be analyzed together in a 

single NEPA document. Actions are connected when they "cannot or will not proceed unless 

other actions are taken previously or simultaneously" or when they are "interdependent parts 

of a larger action and depend on the larger action for their justification." 40 C.F.R 

§1508.25(a)(1)(ii, iii). Where one project will not proceed but for the completion of another, 

it is a connected action and NEPA mandates that both actions be analyzed in the same 

document. Thomas, 753 at 759.

516-46

The public has pointed out that the scoping notice and DEIS for this project repeatedly 

indicate that part of the purpose and need for the project (and alleged outcome of project 

activities) is the increased ability to suppress wildfire in the planning area. Indeed, the agency 

repeatedly frames the environmental analysis in terms of the impacts of alternatives on fire 

behavior and fire suppression and dismisses the No Action Alternative as not conducive to

connected fire suppression objectives and actions. Given that one purpose of the project is to 

facilitate additional fire suppression the agency has a duty under NEPA to disclose the 

connected and cumulative impacts of fire suppression that implementation of the project is 

designed to facilitate.

516-47 Attached to our scoping comments was a 2004 article from Conservation Biology entitled 

Impacts of Fire-Suppression Activities on Natural Communities by Backer et al. The abstract 
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of that paper reads as follows: The ecological impacts of wildland fire-suppression activities 

can be significant and may surpass the impacts of the fire itself. A recent paradigm shift from 

fire control to fire management has resulted in increased attention to minimizing the negative 

effects of suppression. While the philosophy behind minimum-impact suppression tactics has 

provided a good first step in this direction, increased attention to the ecological effects of 

suppression is needed, especially in the management of public lands. We reviewed the 

potential impacts of suppression on land, air and water resources and the impacts of using fire 

to help control fire. Effects on land resources include erosion, which is exacerbated by the 

construction of fire lines, temporary roads, and helicopter pads, and some postfire 

rehabilitation activities. Although the fire itself is the most obvious source of air pollution, the 

vehicles used in suppression activities contribute to this problem and to noise pollution. 

Water resources, including aquatic flora and fauna, may be seriously affected by suppression 

activities that can increase erosion, sedimentation, turbidity, and chemical contamination. 

Finally, the use of backburns and burnout operations contributes to the risk of soil and water 

contamination, increases the total area burned, and promotes more intense fires or more 

homogenous burned areas. Although no fire-management strategy should be applied 

uniformly, some general techniques such as use of natural clearings, natural barriers, and

appropriately sized fire lines, "leave no-trace" camping, and careful application of fuels and 

retardants can be employed to minimize the impacts of suppression. Because part of the 

purpose of the Horse Creek Salvage project is to facilitate additional fire suppression, the 

cumulative and connected impacts of such suppression must be disclosed and analyzed.

516-48

Please note that the Horse Creek logging DEIS indicates that part of the purpose of the project 

is to provide conditions to facilitate future fire suppression/exclusion. Hence continued fire 

suppression constitutes a "connected action" to the proposed salvage logging. As connected 

action, the impacts and consequences of fire suppression activities 1 Noss, R. F., J. F. 

Franklin, W. L. Baker, T. Schoennagel, and P. B. Moyle. 2006. Ecology and management of 

fire-prone forests of the Western United States. Society for Conservation Biology Scientific 

Panel on Fire in Western U.S. Forests. Society for Conservation Biology, North American 

Section, Arlington, Virginia. Also available from 

www.conbio.org/sections/namerica/napolicy.cfm. (such as fireline construction, use of 

retardant, and backburns/burnouts) must be disclosed in the NEPA document for this project.

Comment Response #127: Support of Alternative 2

Concern statement:

Commenters expressed support of Alternative 2 as the alternative that does the most to meet the 

stated purpose and need of the project. However, there is concern that this alternative, while 

including the most treatment, still does not treat a large enough percentage of the project area.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:
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7-3

While Alternative 2 still does not accomplish the purpose and need, it is the best of the four 

alternative even though it only treats about 5% of the area. Of the four alternatives, 

Alternative 2 should be selected.

518-6

Alternative 2-This seems the most feasible and rational, despite the fact that 5% still seems 

like a very low percentage of treatment area. I would have liked to see that number reflected 

more along the lines of 15-20%.

Comment Response #128: Support of Alternative 3

Concern statement:

Commenters expressed support of Alternative 3 due to concerns over salvage units along the 

Siskiyou Crest that would not be included in this alternative.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

368-95 ANN strongly opposes any form of post-fire logging on the Siskiyou Crest. We support the 

cancelation of all 14 units dropped from Alternative 3.

368-99 Post-fire logging should be canceled on the Siskiyou Crest, especially in high elevations 

where forests are well adapted to high severity fire.

515-19

We believe that all 14 timber salvage units located on the Siskiyou Crest should be canceled. 

This includes units near Condrey Mountain, Dry Lake Mountain, Windy Camp and Buckhorn 

Springs Camp at the headwaters of Buckhorn and Middle Creeks. These units in the red 

fir/hemlock zone are inappropriate for salvage logging as the impacts will be the same as 

clearcutting a green, unburned forest.

Comment Response #129: Against Alternative 4

Concern statement:

Commenters expressed opposition to Alternative 4 due to the reduction in treatment and reliance 

on natural regeneration for recovery of burned areas. There is concern that there are not enough 

seed trees adjacent to these burned areas to facilitate natural regeneration.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 
150

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

7-6

Alternative 4 This alternative was developed to further reduce the effects to the northern 

spotted owl. This alternative does nothing to recover any of the burned area. There is very 

little being done to recover forested stands lost in the wildlfire, very little in terms of creating 

worker and public safety, and nothing to ensure forests will once again thrive in the impacted 

areas.

7-10

This Alternative also drastically reduces that amount of reforestation planned. That would be 

a very big mistake. Relying on natural regeneration is not the best approach. First of all, the 

probability of natural regeneration is very low in those areas that have thousands of 

contiguous acres of high mortality. There are not enough seed trees around to provide for 

rapid conifer re-establishment.

Comment Response #130: Support of the Karuk Alternative

Concern statement:

Commenters expressed support of the Karuk Alternative because it incorporates aspects of the 

proposed action that are less controversial such as development of fuel reduction areas adjacent 

to private property, roadside hazard tree removal, and the creation of fuel management zones, 

while reducing treatment in the Siskiyou Crest area. Additionally there is support of this 

alternative as it has the backing of tribal and conservation communities.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:

Comment 

# Comments

4-5

Please consider and adopt the Karuk Alternative. The Karuk Alternative incorporates many 

aspects of the proposed project, including the development of fuel reduction areas adjacent to 

private property, roadside hazard tree removal, and the creation of fuel management zones by 

using strategic ridge-top fuel breaks. What the proposal lacks is much of the contentious and 

environmentally destructive post-fire logging.

4-7

The Karuk Alternative has the backing of tribal and conservation communities because it 

provides forest restoration jobs while protecting at-risk forests and watersheds. I ask the 

Forest Service to consider and adopt the Karuk Alternative, as it meets all of the purposes and 

needs of the project and has broad buy-in from the affected community.

5-3

UW strongly recommends adoption of the "Karuk" Alternative. Enjoying the active, 

intelligent and comprehensive support of indigenous peoples of the Karuk Tribe, as well as 

those of other concerned conservation groups and individuals, this reasonable, eco-forward 
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alternative stands to protect, restore and enhance the historic importance, ecological and 

cultural, of this priceless corridor. Surely, here in the twenty-first century, in the face of 

onrushing climate change, these long-term, existential considerations must trump either 

political or financial convenience, when the Klamath N.F. formulates its management 

proposals for Horse Creek.

64-1 You must consider the Karuk Alternative, and you will see how important it is to adopt.

162-1

Please consider and adopt the Karuk Alternative for the Horse Creek project. The Karuk 

Alternative is a science based, not profit based, program - the kind that the National Forest 

should be rigorously supporting.

368-3

We support the Karuk Alternative and believe it is of the utmost importance that all 14 

Siskiyou Crest units are canceled. This would include units near Condrey Mountain, Dry 

Lake Mountain, Windy Camp and Buckhorn Springs Camp at the headwaters of Buckhorn 

and Middle Creeks.

368-10

Only the Karuk Alternative will continue the process of adapting and becoming more fire 

resilient as a community, while at the same time encouraging a more healthy relationship to 

fire and a more characteristic fire regime. We encourage the Klamath National Forest to 

implement the Karuk Alternative and begin down a new path, towards more holistic, coherent 

and ecologically appropriate fire and post-fire management.

384-3

I am disappointed and mystified by the agency's refusal to implement the Karuk Alternative 

that draws on the best available science and 10,000 years of place-based experience to focus 

post-fire management on forest stands adjacent to homes and communities.

409-2 Too bad you didnt consider the Karuk alternatively a combination of alternatives that were 

better for forest health.

515-16

We support the Karuk Alternative because it incorporates many aspects of the proposed 

project, including the development of fuel reduction areas adjacent to private property, 

roadside hazard tree removal, and the creation of fuel management zones by using strategic 

ridge-top fuel breaks. What the proposal lacks is much of the contentious and environmentally 

destructive post-fire logging.

515-17

The Karuk Alternative has the backing of tribal and conservation communities because it 

provides forest restoration jobs while protecting at-risk forests and watersheds. The SCNPSO 

asks the Forest Service to consider and adopt the Karuk Alternative, as it meets all of the 

purposes and needs of the project and has broad buy-in from the affected community.

578-1 I agree 100% with the Karuk Tribe, K-S Wildlands Center, and other reputable organizations 

that you MUST NOT proceed with the Westside salvage sale at Horse Creek!

689-2 Too bad you didnt consider the Karuk alternatively a combination of alternatives that were 

better for forest health.

942-4

"The Karuk vision of ecosystem management is one that is adaptive, holistic, and sustainable 

for people and place. Ecosystem management should take care of the land, address people's 

need, use resources wisely, and practice ecologically balanced stewardship. " 

http://tribalclimate. uoregon. edu/files/2010/11/Karuk_profile_5_14-12_web1. pdf There are 

extensive plans researched and ready to put into place, and that are the preferred solution to 

the clear cut. http://www. karuk. 

us/images/docs/dnr/Karuk%20DNR_Strategic%20Plan_FINAL_12172015. pdf
152

Comment Response #131: Arson, encouraging

Concern statement:

There is a concern that the FEIS should include the analysis of arson which the commenter 

believes the Forest Service is encouraging by proposing salvage harvest projects.

Forest Service Response:

Thank you for your concern. Cumulative effects are defined by the Council on Environmental 

Quality (CEQ) in 40 CFR §1508.7 defines a cumulative impact as "the impact on the 

environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions." CEQ's 40 questions document gives this 

guidance: "The agency has the responsibility to make an informed judgment, and to estimate 

future impacts on that basis, especially if trends are ascertainable or potential purchasers have 

made themselves known. The agency cannot ignore these uncertain, but probable, effects of its 

decision." “Reasonably foreseeable future actions” are defined in 36 CFR 220.3 and in the Forest 

Service Handbook at 1909.15 as “Those Federal or non-Federal activities not yet undertaken, for 

which there are existing decisions, funding, or identified proposals. Identified proposals for 

Forest Service actions are described in 220.4(a)(1).” In our informed judgment, the probability of 

a project encouraging illegal behavior is not a reasonably foreseeable action that can or should be 

included in cumulative effects analysis.

Associated Comments:

Comment 

# Comments

516-14

The cumulative impacts of encouraging future human-initiated fire events by proposing 

significant post-fire logging of Late Successional Reserves and stands designated as spotted 

owl critical habitat was not fully disclosed and analyzed in the DEIS.

Comment Response #132: Against the Karuk Alternative

Concern statement:

There is concern that the Karuk Alternative further reduces treatment to less than 5% of the total 

project area with no support for reforestation.

Forest Service Response:

Thank you for your comments on the Horse Creek Project. This comment reflects the opinion of 

the commenter. Comments that state a position for or against a specific action are appreciated as 

this gives the Responsible Official a sense of views and beliefs about a proposed course of 

action. While such information can be used by the decision maker in arriving at a decision, it 

cannot be used to improve the environmental analysis or documentation.

Associated Comments:
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518-5 Karuk Alternative-In my view, it reduces even further the 5% planned for treatment, with no 

support for reforestation. I would oppose this one.

Comment Response #133: Roadside hazards and fuels treatment support

Concern statement:

Commenters expressed concern that with a delay in implementation or without roadside fuels 

reduction and hazard tree removal access to private property would not be safe for private 

employees, contractors, fire fighters, and the public. Additionally it was pointed out that this 

work is necessary in order to facilitate safe public egress during emergency evacuations.

Forest Service Response:

Thank you for your support of the project's goals. As expressed in our purpose and need (FEIS, 

Chapter 1), "the goal for all land allocations is to protect lives and properties of local 

communities." To achieve this goal, the Forest proposes to remove hazards along all public roads 

and along ingress and egress routes (including those mentioned by commenters) and reduce fuels 

and create fuel breaks adjacent to private property. The Forest is working quickly to move this 

project forward with urgency while ensuring all needed environmental analysis is completed 

thoroughly and all timelines for public input and response are given in compliance with laws and 

regulations.

Associated Comments:

Comment 

# Comments

2-13

Fruit Growers Supply Company is a cooperator on many of the public roads through the 

project. It is of most importance that these roads be open and safe for our employees, 

contractors, fire fighters and the public. This was not the case in previous roadside salva ges 

that experienced unnecessary delays. Many of the trees that had been marked for removal 

were left standing resulting in unsatisfactory results.

6-2 Further, the Horse Creek Project will reduce safety hazards along roads and in concentrated 

stands in and around the community of Horse Creek.

6-3

The proposed project will directly reduce fire danger by removing hazard fuels and improve 

firefighter safety by maintaining adequate access for emergency vehicles and facilitate safe 

public egress during emergency evacuations.

520-8

As outlined in the comment letter from Fruit Growers Supply Company, they have been 

especially impacted by the Gap Fire, with more than 8,000 of their acres within the fire 

perimeter. Fruit Growers is a cooperator on many of the public roads located throughout the 

Project area, and it is imperative that roads remain open or be opened and kept safe for Forest 

Service, private industry employees, and the public to access areas of treatment and 

restoration. Although we are sure that you share this same priority for open and safe roads, 

situations during previous projects have often times prevented this from happening. The 

County would like to draw attention to the importance of the Thompson Low Gap to Horse 

Creek Road as a primary escape route and EMS artery for Residents living downriver of the 

Horse Creek Road/Hwy 96 intersection during periods of high water and fire activity. Along 

with the Grey Back Road this is the only public access to our downriver communities during 
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emergency events. Keeping this route open by fully treating the vegetation along the route is 

the only safe responsible option this Project should implement.

Comment Response #134: Strategic treatment for firefighter safety

Concern statement:

There is a concern that the project is not strategic in meeting the stated purpose and need for fire 

fighter safety due to the location of the salvage units that occur mid-slope where fire suppression 

tactics are unlikely to be used.

Forest Service Response:

We agree, and it is stated in the Fire and Fuels report and FEIS, that prominent ridgelines, areas 

adjacent to private residences, and along major roads are strategic areas to treat and are the likely 

areas to be used in future firefighting efforts. There are also many other reasons why a salvage 

unit may be proposed. For example, in the matrix lands, recovery of volume from fire killed trees

is a legitimate objective from the Forest Plan (FEIS page 15-16) that may not be “strategic” for 

firefighter safety. That does not mean however that firefighter safety is not improved by that 

action. Firefighter safety will be compromised by the hazards left in untreated landscapes where 

risk reduction salvage, roadside hazard tree removal, roadside fuel reduction and fuel reduction 

in fuel management zones are not accomplished. 

When looking at the combined effects from all the fuels management activities proposed in the 

project, we feel that you must look at all the treatments as a whole. Almost all the proposed 

salvage units proposed in the action alternatives are adjacent to private land containing 

residences or along strategic ridges and roads. By not removing heavy fuel loading adjacent to 

these identified strategic locations through salvage and site preparation treatments, the analysis 

for Fire and Fuels shows that these areas may no longer be effective. 

To ensure treatments such as strategic roads, ridgelines, and areas adjacent to private property 

are more effective and efficient to use during future fire suppression efforts, we feel that treating 

heavy dead and downed fuel loading along with snags is necessary. Snags are both producers and 

receptors for spotting potential and heavy fuels loading increases fire behavior potential. This 

would be undesirable and unsafe for many firefighting tactics adjacent to these strategic 

locations. Lastly, during initial attack incidents or while conducting prescribed fire operations, it 

would be safer to work outside of large snag patches or within treated salvaged areas compared 

to within untreated large snag patches. Not all snags in all areas are proposed for removal, just 

those identified in meeting the purpose and need.

Associated Comments:

Comment 

# Comments

368-66

The purpose and need for the project states that firefighter safety is a major goal and positive 

result of post-fire logging. ANN believes evidence supports this claim in very limited and 

strategic locations, but not throughout the planning area. The DEIS generalizes this issue and 

claims all post-fire logging will reduces risks to firefighting personnel in future fires. This 

claim is false and demonstrates faulty analysis. In fact, firefighter safety will only benefit in 
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areas that are likely to be utilized for fires suppression activities. This would include 

prominent ridgelines, areas adjacent to private residences and along major forest roads. 

Analysis regarding firefighter safety in the DEIS is overly generalized, inadequate and 

oversold. Likewise hazard tree felling is not being contested, thus under no alternative will 

major forest roads provide unsafe conditions.

368-67

in the Gap Fire After Action Review KNF fire management officier Ed Guzman, stated that 

mid-slope firefighting in the Klamath River was not effective. The KNF post-fire logging 

strategy is unfortunately based on pure economics with unit location based on commercial 

viability rather than strategically located to facilitate fire fighter safety.

368-77

The likelihood of fire managers sending suppression crews into or making fire line within 

existing "snag concentrations" from the Gap Fire is also fairly minimal and could be entirely 

avoided if Prescribed Natural Fire, appropriate crew management or reasonable containments 

strategies where implemented allowing the fire to burn to safe, effective, and low risk 

firelines. This is especially true on mid-slope areas where fire managers, for safety reasons; 

tend not to send crews. Numerous post fire logging units are located mid slope. If "snag 

concentrations" are retained, the likelihood of fire managers sending crews into such 

conditions is very, very minimal.

368-78 Avoidance of risk is the only realistic management option. Cleansing areas of wildlife rich 

snags is not the answer.

Comment Response #135: Landslide risk

Concern statement:

There is a concern that the alternative likely to be chosen for implementation is not the 

alternative that has the lowest landslide risk.

Forest Service Response:

The commenter misrepresents the findings provided in the DEIS regarding landslide risk. While 

they are correct that the risk ratio is lowest for Alternative 3, in the referenced section titled 

"Cumulative Effects Common to Alternatives 2, 3, and 4," it is also stated in the DEIS and FEIS 

that the increase in landslide risk ratio is "too small to warrant a change in the likelihood 

category compared to existing condition" (FEIS, page 176). As there was no change in landslide 

risk likelihood for any of the action alternatives compared to the existing condition, there is no 

difference in alternatives here in the ability of project activities to meet the purpose and need of 

providing for public safety. These effects are disclosed in the FEIS and supporting Geology 

Resource Report, included in the project record available on the project website, and will be 

considered by the Responsible Official in arriving at a decision.

Associated Comments:

Comment 

# Comments

516-87

Page 155 of the DEIS discloses that alternative 3 (which the Forest Service has no intention 

of implementing) increases landslide risk the least. This is critically important because "the 

consequences of a landslide event should it occur under any action alternative are very high 

for these three watersheds due to the presence of homes and other structures in the lower 

reaches." Given that "human safety" is allegedly central to the project purpose and need it is 
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unfortunate that the Forest Service is poised to reject implementation of the alternative that 

presents the least additional risk of high consequence landsliding to downhill and 

downstream homes.

Comment Response #136: Overall project effects analysis

Concern statement:

There is a concern that the overall project effects analysis needs to consider and disclose all 

project effects before making a final decision including site specific information.

Forest Service Response:

Site-specific effects are disclosed at the appropriate scale by (by unit, by treatment, management 

area, watershed, project area) for analyzed resources throughout the FEIS. Project Design 

Features are similarly site-specific and also applied at an appropriate scale, such as by unit, by 

treatment, by management area, project wide, or in response to clearly defined conditions which 

may exist at the time of implementation. Disclosure of location, treatment, or criteria where 

PROJECT DESIGN FEATUREs are applied is disclosed in Table 9 in the FEIS (page 41). 

Requests for analysis of the entire Klamath National Forest Road system as it relates to this 

project are outside of the scope of this project. Requests for analysis of the cumulative effects of 

climate change to the Klamath National Forest Road System are likewise outside the scope of 

this project, and infeasible to measure with any degree of accuracy.

Associated Comments:

Comment 

# Comments

1-50 Indeed, the Federal Courts agree that the Responsible Official must disclose and consider 

"adverse impacts" based on best science when making the final decision.

589-11

Here, the Forest Service must provide site-specific details and analysis of what is 

contemplated by the Project and what impacts the Project will have. The DEIS talks about 

effects generally, and talks about project implementation on the ground generally, but fails to 

provide any relevant and helpful site-specific information. The Forest Service refers in 

extremely vague terms to the proposed activities. The Forest Service fails to provide sitespecific analysis for many important aspects of the Project, including: * Number of system 

road miles on the Klamath National Forest; * Length, location, and rehabilitations plans for 

temporary roads; * Climate impact on roads and cumulative climate change effects * When 

specific project design criteria apply to certain management activities.

Comment Response #137: Questions to answer

Concern statement:

Several questions were asked or clarifications requested within the comment letters. Some 

comments misrepresented proposed activities and their assumptions will also be clarified here.

Forest Service Response:
157

Below each comment, we respond to each question individually to provide direct response to the 

commenter’s inquiry or clarify the misunderstanding.

Associated Comments:

Comment # Comments

369-4

The DEIS states that the Karuk Tribe submitted an alternative in response to the scoping 

notice published for the Horse Creek Project. The Karuk Alternative is described in some 

detail, including the ways in which its proposed actions or principles conform with the 

proposed action (Alternative 2). The DEIS also includes a table that compares the acreage 

of actions proposed in the Karuk Alternative to those proposed in the action alternatives. 

The Karuk Alternative was not identified as an action alternative, so does not appear to 

have been subjected to the same level of analysis as the no action and action alternatives; 

nor was it included in the section of the DEIS devoted to alternatives considered but 

eliminated from detailed study. It is unclear, therefore, whether or not the Karuk 

Alternative was considered a reasonable alternative. We recommend that the Forest 

Service clarify this in the FEIS.

Forest 

Service 

Response:

Thank you for your comment and this opportunity to clarify. In response to comments and 

questions like this and others, the Final Environmental Impact Statement was clarified to 

include a discussion of how the Karuk Alternative was considered and why it was not 

analyzed in further detail. Please see the section of Chapter 2 called "Alternative 

Developed as a Result of Tribal Consultation with the Karuk Tribe (Karuk Alternative)" 

for more information.

516-4

Similarly, the location, number, and configuration of snag retention areas and legacy trees 

is not disclosed in the DEIS. The location and functionality of riparian reserves cannot be 

determined from the DEIS. We would like an opportunity to review and comment upon 

such information in a meaningful way prior to a decision being rendered to implement the 

project.

Forest 

Service 

Response:

Thank you for your comment. As the draft EIS noted under the section on Modifications 

to Proposed Action since Scoping, "Snag retention areas have been identified that include 

all riparian reserves with additional areas to enhance wildlife connectivity totaling 272 

acres inside salvage harvest units resulting in a net salvage harvest area equal to 1,771 

acres (Table 7)." This should have referred to Table 5, not Table 7, of the DEIS; this error 

was corrected in the FEIS. The analysis presented in the DEIS used the estimated amount 

and distribution of riparian reserves and snag retention patches using existing data and the 

acres of riparian reserves and snag retention patches are disclosed in the DEIS. The 

boundaries of these riparian reserves and snag retention patches are currently being 

marked with paint on the ground but are not complete at this time. The high valued 

wildlife snags are also currently being marked with paint to identifiy these snags as “no 

cut” wherever they occur in the salvage harvest units. Project design features for riparian 

reserves will be followed during implementation, as described in the Project Design 

Features section of Chapter 2 and the Aquatic Conservation Strategy section of the 

Chapter 3 of the FEIS.

516-95

The Forest Service mistakenly contends that the project will have "no effect" on large 

wood recruitment to streams because some (fish bearing) streams will receive a two tree 

length buffer and some (non fish-bearing) streams will receive a one tree length buffer. In 

fact the Forest Service anticipates that hazard trees will be removed more than 250' feet 

above some road locations due to "slope" considerations. The agency may not 

simultaneous claim that large wood may travel more than 250' down slopes to reach a 

road, but that it can only travel one tree length to reach a stream. The aquatic ecosystems 
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Comment # Comments

of both fish-bearing and non-fish bearing streams benefit from large wood recruitment of 

the kind that the Forest Service claims happens to roads located more than 250' downhill 

of hazard trees.

Forest 

Service 

Response:

This comment was provided in regards to the Westside Fire Recovery Project and does not 

apply to the Horse Creek Project. Within the Horse Creek DEIS and FEIS, large wood 

recruitment to streams in the Horse Creek Project is discussed in detail in the description 

of the action alternatives (Restoration Activities in the Horse Creek Special Interest Area 

section in Chapter 2) and the Aquatic Conservation Strategy section of Chapter 3. As in 

Westside, project design features are in place to retain large wood (see Chapter 2, Project 

Design Features section of the DEIS and FEIS).

516-100

The Forest Service is proposing roadside logging (and yarding) in Riparian Reserves 

throughout the project area. The agency is also proposing log landings in Riparian 

Reserves. Additionally the Forest Service is proposing to establish yarding corridors 

through and across hydrological Riparian Reserves. All of these activities will remove 

forest structure (standing live, dying and dead trees called snags, future down wood and 

canopy cover) that contribute to terrestrial and riparian plant communities and ecosystems.

Forest 

Service 

Response:

This comment was provided in regards to the Westside Fire Recovery Project and does not 

apply to the Horse Creek Project. Actual treatments proposed in riparian reserves in the 

Horse Creek Project are described in detail in the Proposed Action section of Chapter 1 

and the Aquatic Conservation Strategy section of Chapter 3 of the Horse Creek DEIS and 

FEIS. The Scoping Outcome Summary also provides a section on "Clarification on what 

is Not Proposed by the Project" and includes a "Salvage in Riparian Reserves and Special 

Interest Areas" section. As stated in the "Treatments in Riparian Reserves" section of the 

Aquatic Conservation Strategy analysis in the FEIS, "no natural, live vegetation would be 

removed from stream banks that would reduce stream shade or bank stability. There 

would be no salvage, no landing construction or re-construction, and no new road 

construction within riparian reserves." As in Westside, project design features are also in 

place to minimize effects to riparian reserves (see Chapter 2, Project Design Features 

section of the DEIS and FEIS).

519-9

The DEIS states that snag retention areas have been identified for the Project. DEIS at 17. 

The DEIS further provides information on the amount, in acres, of snag retention areas. 

DEIS at 25-26, Table 5. Notably, Unit 115.31 does not contain any snag retention areas, 

despite being in LSR. Similarly, Unit 115.32 contains on 5 acres and the table further 

indicates that the snag retention areas are in riparian reserves. Please provide 

unit specific maps that show snag retention areas. It is important to see where snags will 

be maintained to understand where on the landscape snag retention will occur. For 

example, snag retention in areas that would otherwise be retained—such as riparian areas 

or buffer zones for species—is not appropriately labeled "retention" as these areas would 

be preserved. Further, unit boundaries could be expanded to areas artificially capture more 

retention.

Forest 

Service 

Response:

The Klamath Forest Plan provides direction specific to the Klamath Province and the 

Klamath National Forest, including snag metrics. It is the Klamath Forest Plan that 

provides management direction for the Klamath National Forest, not the Northwest Forest 

Plan. The cited language on page C-42 of the NWFP does not appear in the Klamath 

Forest Plan. Standard and Guidelines 8-22 and 8-25 on page 4-30 of the Klamath Forest 

Plan provide snag metrics to be used in project planning on the Klamath National Forest. 

The Forest Plan direction does not require that these snag metrics be met on every acre or 

in every cutting unit; the Forest Plan requires that within any 100-acre landscape, the 
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Comment # Comments

appropriate number of snags be retained. This allows Project design to mimic the natural 

snag distribution described by Skinner (2002) and Taylor and Skinner (1996) with 

concentration of snags in time and space, and intervening areas where snags would be 

relatively sparse or would not occur. To accomplish this, we retain all the (non hazard 

tree) snags in riparian reserves, all of the non-merchantable cull trees and any very large 

high value wildlife trees. In addition, we designate snag retention areas within units where 

we need additional snags to complement habitat connectivity. Leaving snags in clumps as 

described in Klamath Forest Plan guideline 8-24 (p. 4-30), is more effective than single 

isolated trees because snags in clumps are more resistant to blowdown. We also reduce the 

probability that these areas where snags are retained within units will be consumed by 

inevitable future fires by removing the adjacent heavy fuels with salvage sales and 

burning the activity fuels when salvage is completed. See the Fire and Fuels report in the 

FEIS for a more complete discussion of fire cycles and residual fuel treatments in the 

Klamath Province. An analysis of snag retention metrics in the project area is provided in 

the Appendix of the Management Indicator Species Report. The draft and final Wildlife 

Resource Reports (p. 53-56) provide an assessment of snag metrics and effects on species 

associated with snags. See also FEIS p. 31-33, 39, 57, 125, 291-293.

519-23

Why was much of the economic analysis split into the "Draft Logging Systems 

Supplement Report"? It is inappropriately placed. This information should be put in a 

revised Socioeconomic Report released with the final EIS. What is this document 

supplementing? There is no other document that it seemingly supplements provided on the 

project website.

Forest 

Service 

Response:

This report provides additional information about the logging systems planned for use, 

supplementing the treatment descriptions included in the EIS. It is a different type of 

report than others as it is not an effects analysis, but a consideration of implementation, 

which is different and therefore separate from the analysis of effects the proposed project 

activities may have on socioeconomic factors.

519-44 The Final EIS should include an updated cumulative impacts report.

Forest 

Service 

Response:

Thank you for your comment. The Final Environmental Impact Statement does include an 

updated cumulative impacts report to include timber harvest plans received between draft 

environmental impact statement and final environmental impact statement. Please see 

Appendix B of the FEIS for all actions considered for cumulative effects, as incorporated 

into resource analyses in Chapter 3.

591-8

On page 148 of the DEIS, Table 50 identifies the potential for significant effects on 

sediment indicators for special status aquatic species at the 6th field watershed, 7th field 

watershed, and site scales. Please describe in the FEIS how KNF proposes to address the 

potentially significant impacts identified in Table 50.

Forest 

Service 

Response:

Thank you for your comment. To give context, the Summary of Cumulative Watershed 

Effects Process document (Bell, 2012, available on the project website under Supporting 

Documents), states that: "Klamath National Forest CWE assessments model the 

disturbances and land sensitivity. Results fall on a continuum. As disturbances increase 

(and recover) over time and space, at some point, the risk of initiating or contributing to 

existing adverse cumulative watershed impacts becomes a cause for concern. These 

model-specific levels are called "inference points" or Threshold of Concern and are used 

to inform land management decisions. Ecologically, a transition exists from lower to 

higher risk of adverse effects to beneficial uses - from insignificant to potentially 

significant. From a management perspective, inference points are intended to represent the 

center of that transition zone. Inference points do not represent the exact point at which 
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Comment # Comments

cumulative watershed effects will occur. Rather, they serve as "yellow flag" indicators of 

increasing susceptibility for significant adverse effects occurring within a watershed."

Model results were carefully considered in Chapter 3 of the FEIS and in the Aquatic 

Resources Report, and help inform, but are not the only consideration for, the 

determination of effects on species.

As stated in the Aquatic Resources Report and Chapter 3 of the FEIS, there will be no 

measureable increase in water temperature with any of the action alternatives. Any nonmeasureable increase in water temperature will not be expected to adversely affect aquatic 

organisms because water temperature in Horse Creek streams is well within the properly 

functioning range (based on water temperature monitoring in mainstem Horse Creek and 

Middle Creek). Vegetation on or near streambanks that is likely to provide shade will not 

be cut. Salvage and reforestation, construction of new temporary roads and landings, and 

re-opening existing landings will not occur within riparian reserves so increases in peak 

flows, sediment delivery to streams, and risk of landsliding from implementing the actions 

will be negligible to minor.

On page 188 of the FEIS under the "Channel Condition" section we acknowledge 

that the results of the Forest Sediment Monitoring Report for 2009-2015 (USDA 

2016), which combines the 2009 through 2015 monitoring data showed that the 

Middle Horse Creek reach exceeded reference conditions for three of four 

sediment indices. Further, we acknowledge in that same section that the 

Monitoring Report (USDA 2016) interpreted that effects to water quality were 

currently adverse in Middle Horse Creek and possible adverse in the Horse Creek 

main stem, with human-related sediment sources the likely cause in both 

watersheds. We also acknowledge in Table 58 on page 190 of the FEIS that four of 

the project area watersheds have an ERA risk ratio above 1.0. We use the above 

1.0 risk ratio as a "yellow flag" indicating increasing susceptibility for adverse effects to

beneficial uses in a watershed (Bell 2012). Implementation of the preferred alternative 

would increase the ERA risk ratio by at most 0.1 in five of the project area watersheds. 

Please see our analysis discussion on page 190 of the FEIS which states that a 0.1 increase 

in risk ratio is within the model error. Further, an increase in risk ratio of 0.1 could not be 

detected through pre- and post-implementation monitoring. Direct and indirect effects 

analysis of Alternative 4 (beginning on page 192 of the FEIS) indicates that increases to 

runoff and potential for impacts to stream channels from the alternative as proposed, are 

minimal and would keep conditions at current levels. Implementation of Alternative 4 

with appropriate project design features and BMPs would not increase sediment risk to 

project area streams above existing condition and is similar to the minor effects discussed 

for alternatives 2 and 3. Stream temperatures will remain at current levels similar to the 

existing condition and alternatives 2 and 3.

The no action determination for listed, sensitive and management indicator species is No 

Effect. The determination for threatened SONCC Coho salmon for all action alternatives 

is May Affect, Likely to Adversely Affect. The determination for sensitive species for all 

action alternatives is may impact individuals, but not likely to cause a trend to federal 

listing or loss of viability. The determination for management indicator species for all 

action alternatives is may affect individuals, but is not likely to lead to a decreasing 

population trend. The determination for Coho and Chinook salmon essential fish habitat is 

May Affect, Likely to Adversely Affect. As the Aquatic Resources Report points out, 

"Impacts are expected in large part due to the vulnerable post fire condition of project area 
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Comment # Comments

watersheds and streams where project disturbances will occur. Even the Karuk alternative 

(which was not analyzed in detail for reasons discussed in the FEIS) that would cause the 

least ground and watershed disturbance would be likely to have an adverse effect on 

aquatic species given the highly disturbed and vulnerable state of the Horse Creek 

watershed."

Consultation with Fish and Wildlife Service is ongoing, and the final Record of Decision 

will incorporate any terms and conditions applied for the protection of aquatic species.

Prior to implementation of the project, the Forest Service will meet all the relevant 

conditions for the Non-point Source Sediment Discharge Waiver. This will meet the 

requirements for the Clean Water Act, the Total Maximum Daily Load and the Basin Plan. 

The Standards and Guidelines in the Forest Plan are met through project design and 

analysis (see the Forest Plan Consistency Checklist in the project record and the 

Hydrology Resource Report, available on the project website).

591-9

Based on our review of KNF guidance documents we were unable to identify where the 

1.5 "high risk" ratio threshold is derived. The Project FEIS should include additional detail 

to explain how the "moderate risk" and "high risk" ERA threshold values were 

determined. The Waiver does not apply to specific projects on federal land when the 

project may result in impacts that cannot be mitigated to less-than- significant levels.

Forest 

Service 

Response:

Thank you for your comment. This was an error that was corrected in the FEIS and final 

Hydrology Report. They are now consistent with the Summary of Cumulative Watershed 

Effects Process document (Bell, 2012) which states that "These model-specific levels are 

called “inference points” or TOC and are used to inform land management decisions. 

Ecologically, a transition exists from lower to higher risk of adverse effects to beneficial 

uses – from insignificant to potentially significant. From a management perspective, 

inference points are intended to represent the center of that transition zone. Inference 

points do not represent the exact point at which cumulative watershed effects will occur. 

Rather, they serve as “yellow flag” indicators of increasing susceptibility for significant 

adverse effects occurring within a watershed."

591-10 Please identify in the Project FEIS how the effects of legacy sediment site treatment were 

analyzed.

Forest 

Service 

Response:

Legacy sediment site treatments were not included as part of the purpose and need of this 

project, nor were their treatments analyzed, as their treatment is a permit requirement of 

the North Coast Regional Water Quality Control Board, not the Klamath Forest Plan. We 

will continue to work with the Regional Water Board to develop an acceptable legacy site 

inventory and plan, which we will submit to the Regional Water Board after the Record of 

Decision is signed, as per requirements of the Waiver. Prior to implementation of the 

project, the Forest Service will meet all the relevant conditions for the Non-point Source 

Sediment Discharge Waiver.

591-11

Page 19 of the draft hydrology specialist report identifies three beneficial uses in the 

Project area: resident and anadromous fish, domestic and irrigation supply, and domestic

supply. The Project area is located within the Seiad Valley Hydrologic Subarea (HSA). 

The Basin Plan identifies the following beneficial uses for the Seiad Valley HSA: · 

Municipal and Domestic supply · Agricultural Supply · Industrial service supply · 

Industrial process supply · Groundwater recharge · Freshwater replenishment · Navigation 

· Water contact recreation · Non-contact water recreation · Commercial and sport fishing · 

Warm freshwater habitat · Cold freshwater habitat · Wildlife habitat · Rare, threatened, or 

endangered species · Spawning, reproduction, early development · Native American 

culture
162

Comment # Comments

Forest 

Service 

Response:

Thank you for your comment. This was an error that has been corrected in the final 

Hydrology Report.

591-12

Page 20 of the draft hydrology specialist report contains the following passage: Table 11 

shows the acres and percentage of each of the total riparian area burned at a moderate or 

high burn intensity by the 2016 Gap Fire at the 7th field and 6th field project area 

watershed scale. The Lower Horse Creek 7th field watershed is the only drainage where 

over 20 percent of the burn intensity was moderate or high. We believe this indicates that 

the Gap Fire produced localized effects to shade in certain project area 7th field 

watersheds, but not to the point where the 94 percent stream shade that existed in the 

Horse Creek watershed would be detrimentally affected. According to the values in Table 

11 a total of 998 acres of riparian reserves within the Project planning area burned at

moderate to high intensity. Prior to the Gap Fire stream shade in Horse Creek was 

measured to be 94 percent and then 998 acres of riparian reserves burned at moderate to 

high severity. How did KNF determine that the stream shade that existed prior to the Gap 

Fire was not detrimentally affected?

Forest 

Service 

Response:

To clarify, only hazard tree removal from the overstory would occur within perennial and 

late flowing intermittent reaches. Where roadside fuels treatment crosses riparian reserves, 

no vegetation that provides effective shade to the stream channel or floodplain will be cut 

and for fuels management zones, generally located on ridgetops, no vegetation that 

provides effective shade to the stream channel or floodplain will be cut (see Final 

Hydrology Report). We believe actual removal of canopy would be closer to zero thus 

meeting general condition #4 of the Water Board Waiver which requires us to retain all 

natural shade in the riparian reserve, which addresses the underlying concern about shade

in riparian reserves. Due to the need to respond quickly to conditions created by the Gap 

Fire around the community of Horse Creek, we based existing shade on historical values 

after considering how many acres of riparian reserves were impacted by moderate to high 

severity fire. There are 6,492 acres of riparian reserves in the project area (see Table 4 of 

the FEIS, Management areas found within the project area). As Table 10 of the Final 

Hydrology Report (Table 11 of the draft report) shows, 996 acres of riparian reserves 

within the 6th-field watersheds of the project area burned at moderate or high intensity. 

This means that only 15 percent of the riparian reserves within the 6th field watersheds 

burned at this intensity, which in the professional judgement of the hydrologists on the 

interdisciplinary team was not a detrimental effect to stream shade as a result of the Gap 

Fire. Vegetation burn severity data are used to assess effects of the 2016 Gap Fire on 

vegetation and related reduced shade as a baseline for the analysis of project activities. 

Riparian areas subject to moderate and high vegetation burn severity provide reduced 

shade relative to pre-fire conditions; shade protects water temperatures from solar 

insolation and warming.

The direct and indirect effects of the project on shade are estimated by the amount of 

riparian reserve that is within treatment area where live vegetation is likely to be removed. 

These areas are assumed to have the potential for shade loss. However, shade will not be 

lost over much of the treatment area because the treatments focus on dropping only hazard 

trees.

593-9

EPIC is concerned about our ability to access and "groundtruth" these units, given they 

must be accessed by a private road. EPIC requests that these units be added to the July 

12th field trip or that special accommodations be made to access these units.
163

Comment # Comments

Forest 

Service 

Response:

Thank you for your interest in visiting these units (118.64 and 118.63) as part of the July 

12th public field trip. We will take this under consideration as field trip sites will be 

selected for the agenda according to public interest, accessibility, and logistical concerns 

such as driving time.

Comment Response #138: Request for information or hard copy

Concern statement:

Requests were made by specific individuals and organizations for follow up contact.

Forest Service Response:

Thank you for your interest in the Horse Creek Project. We have you on our mailing list for the 

project and will be sending hard copies of documents for this project as requested. 

Associated Comments:

Comment 

# Comments

369-5 When the FEIS is released for public review, please send one hard copy and one CD to the 

address above (mail code: ENF-4-2).

519-1 Please send hard copies of all future NEPA documents to the EPIC office.

589-1 Please add our names and organizations to the contact list to receive any future public 

notices regarding this project.

591-17 We would appreciate receiving copies of the environmental documents and wish to remain 

on the mailing list for future KNF projects.

Comment Response #139: Scoping literature

Concern statement:

There is a concern that a few specific pieces of literature provided during scoping were not 

considered in the completion of the project analysis.

Forest Service Response:

Stritthholt et al. 1999 is a proposed strategy for a conservation evaluation process to be used for 

land management designations, and as such, is not pertinent to the choice between alternatives in 

the Horse Creek Project. For this reason it was not incorporated into the draft EIS. . We agree 

with the importance of providing for species diversity and the role that refugia play in 

maintaining diversity, which we believe is the general thrust of Strittholt et al. (1999). We also 

agree with the need to maintain habitat connectivity along the Siskiyou Crest to allow species to 

migrate and to adapt to changing climate. The Forest Plan is a science-based plan to address the 

needs of species dependent on late-successional and old growth forest habitats. The Forest Plan 

emphasizes maintenance of diversity and uses refugia as a cornerstone strategy. Land allocations 

in the Forest Plan provide large reserves (the Late Successional Reserves) to maintain species 

meta populations and dispersal corridors (the Riparian Reserves) to allow migration and 

movement. At the project scale, elements such as green tree retention, retention of coarse woody 

debris, snag retention, the Survey and Manage requirements to protect rare species and their 

habitats, and consultation with regulatory agencies under the Endangered Species Act provide 
164

additional protections. These strategies are not inconsistent with those identified in other 

comments related to conserving biodiversity in the Klamath Province. We also agree that logging 

and road building can adversely affect habitat if these circumstances are not considered. By 

following the strategies outlined in the Klamath Forest Plan, and consulting with regulatory 

agencies, we believe we are minimizing those impacts to habitat connectivity. Commenters 

provide no evidence that the land allocations and management prescriptions in the Forest Plan 

are not consistent with these objectives. Even if the Forest Plan was inconsistent with these 

objectives, the place to address landscape-scale concerns for biodiversity is at the Forest Plan 

level through monitoring and at the time of Forest Plan revision, not project-level NEPA 

decisions.

The Mt. Ashland LSR Assessment referenced in the comment is on the Rogue River National 

Forest, 15 air miles east of the Horse Creek Project on the north side of the Siskiyou Crest. The 

portion of the Mt. Ashland LSR that is on the Klamath National Forest was addressed in the 

Forest Wide LSR Assessment for the Klamath National Forest (1999). The Horse Creek Project 

is not in the Mt. Ashland LSR, it is in the Johnny O’Neil LSR. The Regional Ecosystem Office 

(REO), a coordinating body for implementation of the Northwest Forest Plan reviewed the 

Klamath LSR Assessment in 1999. The REO determined that the Klamath LSR Assessment 

provided adequate recommendations for risk reduction, including salvage, and that projects 

consistent with the assessment could go forward with no further review by the REO. The Horse 

Creek project is consistent with the recommendations of the LSR Assessment (FEIS page 59).

Please also refer to comment response #117 for more information about scoping period literature 

review.

Associated Comments:

Comment 

# Comments

516-8

Our timely Horse Creek Salvage timber sale scoping comments specifically requested that the 

agency's NEPA analysis address the locally and regionally significant issues regarding 

management of this unique resource discussed in: Strittholt J.R., R. F. Noss, P. A Frost, K. 

Van-Borland, C. Caroll, G. Heilman, Jr. 1999. A conservation assessment and science based 

plan for the Klamath-Siskiyou. Rogue River National Forest, Klamath National Forest. 1996. 

Late-Successional Reserve Assessment; Mt. Ashland Late Successional Reserve Assessment 

(#RO-284). In its rush to clearcut and salvage log backcountry, high elevation, native forests, 

miles from any home or community, agency planners simply ignored the above request to 

consider relevant documents and studies.

Comment Response #140: Salvage does not meet the purpose and need

Concern statement:

There is a concern that the proposed project activities of "back-country logging" and salvage 

harvest do not meet the purpose and need of community protections and forest restoration. 

Forest Service Response:

Community protection and forest restoration are key parts of the purpose and need for the Horse 

Creek Project; however, the purpose and need is also driven by the desired conditions for the 

landscape or management area as defined in the Forest Plan. For example, where the existing 
165

condition of the landscape does not represent the desired conditions described in the Forest Plan, 

there is a need to act to accomplish the goals and objectives or purposes described in the Forest 

Plan. A comparison of the existing and desired conditions supporting the need for change, 

including the ways in which the project seeks to address these needs, is outlined in detail in 

Chapter 1 of the FEIS, which includes salvage harvest as one of the ways the project seeks to 

address these needs. 

It is unclear from the comments what is meant by “back country logging;” however, 

“backcountry” in general terms is normally taken to mean places with Roadless or Wilderness 

character. The areas where there are salvage units proposed in the Horse Creek Project are all in 

roaded areas that have a history of timber management.

Regarding community protection, almost all the proposed salvage units proposed in the action 

alternatives are adjacent to private land containing structures or along strategic ridges and roads. 

By not removing heavy fuel loading adjacent to these identified strategic locations through 

salvage and site preparation treatments, the Fire and Fuels section of Chapter 3 of the FEIS and 

the supporting resource report show that these areas may no longer be effective. To ensure 

treatments such as strategic roads, ridgelines, and areas adjacent to private property are more 

effective and efficient to use during future fire suppression efforts, treating heavy dead and 

downed fuel loading along with snags is necessary. Snags are both producers and receptors for 

spotting potential and heavy fuels loading increases fire behavior potential. This would be undesirable and unsafe for many firefighting tactics adjacent to these strategic locations.

Regarding forest restoration, please refer to comment response #49.

Associated Comments:

Comment 

# Comments

488-1

Such back-country logging does not do anything for "community protection" and many 

studies have shown this is wasteful of resources and certainly not "restorative" of forest 

health.

519-43 The Horse Creek project as proposed, salvage logging and road and landing construction, 

will not attain community protection or forest restoration.

Comment Response #141: Not treating enough to meet the purpose and 

need

Concern statement:

There is a concern that there will be significant acres left untreated which will not achieve the 

purpose and need and not address the need to recover the greatest possible value following a 

stand replacing fire, or for protecting the public and adjacent private property.

Forest Service Response:

While the purpose and need for the project includes the recovery of timber volume from fire 

killed trees in the General Forest and Partial Retention VQO management areas because these 

areas contribute to the timber base of the Forest, the project does not seek to recover "the greatest 

possible value following a stand replacing fire." Treating all General Forest and Partial Retention 
166

VQO management areas for volume recovery is impractical and would not balance potential 

negative effects to other resources (wildlife, soils, hydrology, etc.). 

However, treatments were designed for the purpose and need of public safety and abating the 

unsafe conditions for the public and adjacent landowners that the Gap Fire created. These 

treatments include removing hazard trees from public roads, reducing fuels on lands adjacent to 

private property containing structures, and creating fuel breaks adjacent to private property. The 

Fire and Fuels Report shows a significant reduction of fire behavior potential in all action 

alternatives (Fuels Report, Tables 24 through 32 on pages 29, 30, and 31). Not all areas that have 

the potential to exhibit high severity fire are proposed for treatment. This would also be 

impractical and would not balance potential negative effects to other resources (wildlife, soils, 

hydrology, etc.). The fuels treatment design for the action alternatives focuses on strategic 

locations (i.e. roads, ridge tops, natural barriers, and the Wildland Urban Interface) to increase 

the options for future fire management actions, fire resiliency, and public and forest use safety 

(Fire and Fuels Report, page 21 and Chapter 2 of the FEIS). These strategic locations are in areas 

likely to be used by future fire suppression activities as well as control lines for future prescribed 

fire projects. The Fire and Fuels Report (page 26) also states that "it will be desired to introduce 

prescribed fire, to maintain low fuel loading and fire behavior conditions, in the project area once 

conditions are ripe to do so in the future." Such future projects could also maintain desired 

conditions of reducing the risk of future wildfire.

See also Concern Response #1. 

Associated Comments:

Comment 

# Comments

520-6

Based on the alternatives outlined in the Project, there will be significant acres left untreated 

and substantial acres where snags and other debris will remain. Treating only five percent of 

the burned area does not achieve the purpose and need and does not address the need to 

recover the greatest possible value following a stand replacing fire, or for protecting the 

public and adjacent private property. Please describe to Siskiyou County how harvest and 

reforestation on such a limited basis would meet the goal intent of productive sustained 

forests described in the Forest and Rangeland Renewable Resources Planning Act of 1974 

and those specific legal mandates of "sustained yields...achievement and maintenance in 

perpetuity of a high level annual or regular periodic output" and requirements of Forested 

Public Lands described in detail in the Multiple Use Sustained Yield Act of 1960, Section 

3(b).

Comment Response #142: Alternative suggested

Concern statement:

Commenters have suggested either alternatives, or a combination between the existing 

alternatives should be created to address a number of concerns including removal of all 

temporary roads, avoidance of northern spotted owl activity centers, and limiting the amount of 

replanting in streams.

Forest Service Response:

Thank you for the recommendations for alternative actions the Forest Service may consider, 

however, our request for information to "help the interdisciplinary team develop effective, issue-
167

driven alternatives and mitigation to the proposed action" was made with the Notice of Intent to 

prepare an environmental impact statement, as stated in the Horse Creek Project Scoping Letter 

dated November 17, 2016 and published online on November 11, 2016. This scoping period 

began on November 23, 2016 and closed after 30 days on December 23, 2016. 

However, regarding the alternative actions suggested by the commenter, removing all existing 

temporary roads from the project was considered by the Responsible Official in Alternative 3, 

where all units requiring temporary roads were removed. To avoid interfering with activity 

center for the northern spotted owl, Alternative 4 (preferred alternative) was developed to 

respond to concerns raised in scoping regarding the impacts of the project on northern spotted 

owls and their habitat. More information on this alternative and how it seeks to protect northern 

spotted owl activity centers is available in Chapter 2 of the FEIS. 

Finally, no replanting in streams is proposed in any action alternative. While planting is proposed 

for Riparian Reserves, none of this work will be conducted in streams and stands selected for site 

preparation and tree planting are predominantly plantations composed of standing dead trees 

generally under 16 inches in diameter at breast height (FEIS, Chapter 2). 

As to the impacts of climate change on the land and water, the Climate Change section in 

Chapter 3 of the FEIS and its supporting resource report noted many of the effects of a changing 

climate on forests. We recognize the issues related to climate change, however the issue of

climate change can rarely be addressed in project-level NEPA decisions. Please refer to comment 

response #108 for additional information regarding the consideration of climate change in the 

project. 

In terms of reducing the harms from road activities, travel analysis and the construction or 

decommissioning of Forest System Roads is outside the scope of the proposed action and is not 

related to the decision to be made. Travel analysis is not included in this project, and although 

temporary roads are proposed to achieve salvage harvest implementation, Alternative 3 addresses 

this issue as described above. According to 40 CFR 1501.2(c), the Agency is required to "study, 

develop, and describe appropriate alternatives to recommended courses of action in any proposal 

which involves unresolved conflicts concerning alternative uses of available resources as 

provided by section 102(2)(E) of the Act." As these comments do not provide any new 

unresolved conflicts, this newly proposed alternative provided outside the scoping period will 

not be considered further.

Associated Comments:

Comment 

# Comments

589-17

We suggest as a new alternative that the Forest Service remove all existing temporary roads 

and avoid interfering with activity centers for the Northern Spotted Owl while limiting the 

amount of replanting in the streams to minimize interference with the Coho Salmon habitat. 

As vital as it is to maintain a resilient forest, it is just as important to be attentive to the 

significant level of negative impacts on endangered species that may result from the proposed 

action and climate change.

589-18

The Forest Service presents two alternatives to its proposed action, but neither considers 

removing threat levels for at least one of the endangered species, addressing impacts from 

climate change on the land and water, or reducing the harms from road activities. We are 

delighted to see the Forest Service consider removing temporary roads in Alternative 3, 
168

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# Comments

which would decrease potential threats of road density and the volume of sediment going into 

streams and harming the Coho Salmon. However, the Forest Service seems to not have any 

alternatives in place that would protect the Northern Spotted Owl, and no analysis is 

presented for any system roads that could be removed to reduce logging and negative effects 

on wildlife. The Forest Service should look to a range of alternatives that would avoid 

interfering with the habitat of listed species and avoid adding roads.

Comment Response #143: Alternatives should consider resource effects 

and ESA

Concern statement:

There are concerns that resource specific impacts that could have been avoided through project 

design were not mitigated and that the information regarding impacts to the northern spotted owl 

was not incorporated into project design because of the order of completion of the reports.

Forest Service Response:

Project design features were developed as part of the interdisciplinary process to minimize 

effects to resources where possible. These project design features apply to all action alternatives 

and are available in Chapter 2 of the FEIS. The Responsible Official has been involved 

throughout the process of project development and effects analysis and will fully consider the 

effects disclosed by specialists of the interdisciplinary team in making her decision. The Record 

of Decision will outline the rationale of the decision made and the mitigations in place to 

minimize effects to resources. A draft version of the Record of Decision is available in the 

project record on the project website. 

The commenter correctly states that the Biological Assessment did not inform agency planning 

or alternative development; that is the role of the wildlife biologist, not a document that by 

definition is used to determine whether formal consultation or conference for species protected 

by the Endangered Species Act is required under 50 CFR § 402.14 or §402.10, respectively (50 

CFR §402.12 (k)). The wildlife biologist who completed the biological evaluation and biological 

assessment was involved in all stages of project development as a member of the 

interdisciplinary team. His expertise and analysis of effects to wildlife and threatened and 

endangered species were included in project development and all the information necessary to 

form "the scientific and analytic basis for the comparisons under §1502.14," as required by § 

1502.16 (environmental consequences) was included in the DEIS and applicable resource 

reports. 

All NEPA required analysis of effects to resources, including northern spotted owl, is available 

to the Responsible Official and to the public in advance of a decision being made.

Associated Comments:

Comment 

# Comments

1-28 Then please take the last important step. Simply disclosing your resource will be hammered 

and walking away isn't enough. Meet with the Responsible Official. Ask her to modify the 
169

Comment 

# Comments

Proposed Action and/or include mandatory mitigation so there will be no effect to your 

resource.

516-59

The Biological Evaluation (BE) and Biological Assessment (BA) for impacts to the NSO 

cannot inform agency planning or alternative development because the logging alternatives 

were developed prior to the completion of a BE or BA.

Comment Response #144: Recommendations for “Restoration of Federal 

Lands in the Pacific Northwest” have been ignored

Concern statement:

There is a concern that recommendations of Dr. K. Norman Johnson and Dr. Jack Ward Thomas 

in “Restoration of Federal Lands in the Pacific Northwest” have been ignored, and that timber 

salvage is about recovering economic value rather than enhancing ecological recovery. The 

commenter then cites the recommendations from the paper in the comments below.

Forest Service Response:

The reasons for various proposed actions are explained in Chapter 1 of the FEIS. These depend 

on land allocations, desired conditions in the Forest Plan, and the existing condition of the 

landscape. These cited recommendations are very general, but we believe the project is 

responsive to these concerns and there are many citations in the FEIS to support these arguments. 

For example, there are abundant protections for soil and aquatic resources. The Horse Creek SIA 

is a site that has been allocated to native biodiversity and there is no salvage proposed in the SIA. 

Late Successional Reserves are another land allocation where biodiversity is important and only

severely burned sites in the LSR are proposed for salvage with the intended purpose of reducing 

the risk of future high severity fire as provided by the Forest Plan. Those areas are clustered 

around private property in the community of Horse Creek to provide as much protection from 

high severity fire over time as possible. Only 5 percent of the LSR is affected, and there are 

provisions for leaving very large trees with high wildlife values so it is hard to argue that 

biological legacies will not be protected. The citation to Lindenmeyer et al. (2008) suggesting 

that “predisturbance management goals” be used as a start point is exactly what we do when we 

describe the desired condition in the Forest Plan with the existing condition on the ground. For 

example, the predisturbance management goal for an LSR is generally a late successional 

coniferous forest. The proposed action and alternatives were designed to accomplish that 

objective by reducing the risk of high severity fire and accelerating the development of 

coniferous forests. 

See Concern Responses #3, #23, #26, and #70 that also have information relative to these 

comments. 

Associated Comments:

Comment 

# Comments

368-30

They also list three recommendations under "General Post Disturbance Guidance," these 

recommendations include: 1) Do no significant additional ecological damage to the biota and 

functional capabilities of the post disturbance ecosystem, with particular consideration of soil 
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# Comments

and aquatic resources. 2) Consider the merit of potential activities in the context of the 

primary management objectives for the site. For example, salvage would appear to be 

inappropriate in areas that have been allocated primarily to maintenance of native biodiversity 

and functions and natural forest ecosystems (including old growth) and 3) Give full 

consideration to the ecological roles played by biological legacies from the post disturbance 

ecosystem including their importance and duration."

368-31 (Lindenmeyer etal., 2008), which recommends "using pre-disturbance management goals as a 

starting point in determining appropriate actions."

Comment Response #145: Alternatives considered but eliminated from 

detailed study

Concern statement:

There was a concern that an alternative proposed in scoping to remove salvage harvests from 

reserve land use allocations was not considered in the DEIS.

Forest Service Response:

Alternative A included in the Alternatives Considered but Eliminated from Detailed Study 

section of Chapter 2 of the DEIS, and of the FEIS, was developed in response to these scoping 

comments. None of the action alternatives include salvage harvest in the Horse Creek Special 

Interest Area or in riparian reserves. In addition to these reserve land use allocations, Alternative 

A considers avoiding salvage harvest within late successional reserves. This alternative was 

considered but eliminated from detailed study because it would not meet the purpose and need to 

reduce fuels near communities and private structures and to create effective fuel breaks. For 

more information about how this alternative was considered and why it was not studied in detail, 

please refer to Chapter 2 of the FEIS.

Associated Comments:

Comment 

# Comments

516-12

Despite our reasonable and timely request during project scoping, agency timber planners 

have arbitrarily refused to consider and develop an action alternative in which reserve land 

use allocations are not subject to unit salvage logging.