APPENDIX A

MAPS

 

APPENDIX A

An index of the maps included in this appendix is listed below. Maps A5 and A6 have been added since 

the publication of the DEIS in order to provide additional clarity for reviewers. 

Index of Maps

Map A1: Tollgate Project Planning Area Location and Vicinity 

Map A2: Tollgate Project Planning Area, Land Ownership, and Values at Risk 

Map A3: Tollgate Project Planning Area- Alternative B, Treatment Units

Map A4: Tollgate Project Planning Area- Alternative C, Treatment Units

Map A5: Tollgate Project Planning Area- Forest Plan Management Areas

Map A6: Tollgate Project Planning Area- Subwatersheds 
OR-11

US-12

US-12

Clarkston 29 Miles

[

US-12

TROY

WASHINGTON

OREGON

ASO-128

GAR-201

Peola-Iron

Springs Road

GAR-128

GAR-118

Tucannon River

COL-9233

WA-126

Road

COL-1931

COL-9115

Kendall-Skyline Road

ASO-110

ASO-105

Asotin-Cloverland Road

ASO-181

ASO-175

ASO-105

ASO

ASO-235

COL-9124

40

42

46

64

47

4304

ASO-127

ASO-100

Grande Ronde River Road

WAO-569

ASO-116

4039000

WAO-194

111

ASO-121

WAO-570

43

41

44

OR-204

OR-204

Union

Wenaha-Tucannon

Wilderness

North Fork Umatilla

Wilderness

Eagle Cap Wilderness

3109

4200

3113

6308

4302

4305

3200

6500

4030

4039

6300

4000

4400

4300

6400

4625

6401

6415

6234

4018

4610

3102

4620

4038

6212

6235

3150

4713

3100

4206

3128

6200

4022 3728

4027

6206

4608

6219

4016

6208

6236

6217

3715

4600

6232

4100

6406

6307

4700

3725

3738

4712

3719

6231

6214

6306

6437

4304

6413

DAYTON

WAITSBURG

DIXIE

WALLA

WALLA

TROY

MILTON-FREEWATER

FLORA

WESTON

WALLOWA

ELGIN

MEACHAM LOSTINE

SUMMERVILLE

IMBLER

ENTERPRISE

JOSEPH

ISLANDCITY

LAGRANDE

COVE

UNION

G A R F I E L D G A R F I E L D

C O L U M B I A C O L U M B I A

W A L L A W A L L A

W A L L A W A L L A

U M A T I L L A U M A T I L L A

U N I O N U N I O N

A S O T I N A S O T I N

W H I T M A N W H I T M A N

W A L L O W A W A L L O W A

-

WASHINGTON

OREGON

IDAHO

Tollgate Project Planning Area

Vicinity Map

Legend

Tollgate Project Planning Area

Walla Walla Ranger District

Pomeroy Ranger District

Other Forests

Wilderness

Cities

County

Forest Service Road

County Roads

Tollgate Project

Planning Area

A-1
Tollgate

Langdon Lake

Jubilee Lake

OR-204

OR-204

64

030

64

050

020

070

025

040

051

051

150

300

022

0 3 6

083

070

020

140

035

015 032

035

060

050

020

100

900 030

200

120

010

110

3725

155

040

033

080

030

041

060

3715

034

6401

3718

020

100

6406

3719

T. 5 N T. 4 N T. 3 N T. 2 N

R. 36 E R. 37 E R. 38 E R. 39 E

 ́ 1 0.5 0 1 Miles

1:83,000

Legend

Tollgate Project Planning Area

Walla Walla Ranger District Boundary

Tollgate WUI

Private Residences

Wenaha-Tucannon Wilderness

Inventoried Roadless Area

Other Ownership

Closed

Open

Overhead Electrical Line

Tollgate Project Planning Area

Land Ownership and 

Values at Risk

ATTENTION

This product is reproduced from geospatial information

prepared by the U.S. Department of Agriculture Forest

Service. GIS data and product accuracy may vary. They

may be: developed from sources of differing accuracy,

accurate only at certain scales, based on modeling or

interpretation, incomplete while being created or

revised. etc... Using GIS products for purposes other

than those for which they were created may yield

inaccurate or misleading results. The Forest Service

reserves the right to correct,update,modify,or replace

GIS products without notification. For more information

contact the The Umatilla National Forest Supervisors office.

Walla Walla River IRA

Lookingglass IRA

North Fork Umatilla Wilderness

A-2
1

79

46

41

10

68

42

4

83

50

18

84

31

77 47

48

78

43

87

15

45

26

38

85

76

44

54

64

69

49

53

34

89

62

51

104

75 25

95

86

56

20

66

35

82

5

61

103

62

97

9

52

37

3

33

99

100

67

62

36

81

90

23

72

19 94

12

62

73

71

27

102

21

55

96 98

32

70

101

29

105

7

6

7

6

6 5

3

7

4

9

2 1

5 4

8

9

2

1 5

1

2

8

9

4

9

4

6

8

3

3

1

5

2

8

3

8 9

6

8 9

7

7

7

2 1

2 1

5 4 2

1

1

1

3

2 5 4 3

3 2

6

4

19

31

30

31

19

18

30

5

18

6

6

1

7

3 2

11

11

4

11

11

11

5

12

11

10

18

15

11

11

21

14

33

34

10

32

14

28

24

14

20

16

34

22

14

32

23

23

27

26 29 27

13

20

34

21

28

25

36

12

35 32

22

13

33

33

36

28

23

12

12

26

10

15

24

29

21

14

29

17

20

24

25

25 30

28

35

30

25

15

17

16

16

13

27

27 26

27

30

16

34

10

22

13

29

17

13

31

17

36

35

26

31

21

22

26

17 15

26

29

19

34

33

27

24

18

35

32

13

15 14

20

33

17

32 36

21

35

34

28

35

22 23

36

6

24

33

28

32

25

14

26

25

13

16

30 29

12

31

10

35

12

24

25

18

31

36

19

23

19

26

23

36

15

20

14

16

25

18

23

13

35

36

10

23

12

22 24

24 19

1

20 21

12

7

6

6

5 4 3 2

3

3

2 1

6

18

19

35

30

31

34

36

27

31

22

3

32

18

15

19

33

30

34

31

10

35

10

36 31 32

15

34

34

22

33

27

34 35 36 31 32 33 34 35 36 31

R. 36 E R. 37 E R. 38 E R. 39 E R. 39 E R. 40 E R. 39 E

T. 5 N T. 4 N T. 3 N T. 2 N

Tollgate Project Planning Area

Alternative B

Treatment Units

1 0.5 0 1 Miles  ́

ATTENTION

This product is reproduced from geospatial information

prepared by the U.S. Department of Agriculture Forest

Service. GIS data and product accuracy may vary. They

may be: developed from sources of differing accuracy,

accurate only at certain scales, based on modeling or

interpretation, incomplete while being created or

revised. etc... Using GIS products for purposes other

than those for which they were created may yield

inaccurate or misleading results. The Forest Service

reserves the right to correct,update,modify,or replace

GIS products without notification. For more information

contact the The Umatilla National Forest Supervisors office.

1:83,000

Legend

Tollgate Project Planning Area

Walla Walla Ranger District Boundary

Wenaha-Tucannon Wilderness

Inventoried Roadless Area

Closed

Open

Road Realignment

Commercial Thin, Ladder Fuel Reduction, Down & Dead Removal

Commercial Thin

Commercial Thin, Ladder Fuel Reduction

Commercial Thin, Non Commercial Thin

Ladder Fuel Reduction

Ladder Fuel Reduction, Dead & Down Removal

Non Commercial Thin

Walla Walla River IRA

Lookingglass IRA

North Fork Umatilla Wilderness

A-3
1

79

46

41

68

10

4

42

83

50

18

84

31

77 47

48

78

43

87

15

45

85

76

44

54

49

64

69

53

34

62

89

51

25

95

86

56

20

66

35

75

82

5

61

103

62

97

52

37

3

9

99

100

67

62

36

81

90

23

72

19

62

73

71

94

27

102

12

21

55

33

98

32

104

101

96

70

29

105

104

104

7

6

7

6

6 5

3

7

4

9

2 1

5 4

8

9

2

1 5

1

2

8

9

4

9

4

6

8

3

3

1

5

2

8

3

8 9

6

8 9

7

7

7

2 1

2 1

5 4 2

1

1

1

3

2 5 4 3

3 2

6

4

19

31

30

31

19

18

30

5

18

6

6

1

7

3 2

11

11

4

11

11

11

5

12

11

10

18

15

11

11

21

14

33

34

10

32

14

28

24

14

20

16

34

22

14

32

23

23

27

26 29 27

13

20

34

21

28

25

36

12

35 32

22

13

33

33

36

28

23

12

12

26

10

15

24

29

21

14

29

17

20

24

25

25 30

28

35

30

25

15

17

16

16

13

27

27 26

27

30

16

34

10

22

13

29

17

13

31

17

36

35

26

31

21

22

26

17 15

26

29

19

34

33

27

24

18

35

32

13

15 14

20

33

17

32 36

21

35

34

28

35

22 23

36

6

24

33

28

32

25

14

26

25

13

16

30 29

12

31

10

35

12

24

25

18

31

36

19

23

19

26

23

36

15

20

14

16

25

18

23

13

35

36

10

23

12

22 24

24 19

1

20 21

12

7

6

6

5 4 3 2

3

3

2 1

6

18

19

35

30

31

34

36

27

31

22

3

32

18

15

19

33

30

34

31

10

35

10

36 31 32

15

34

34

22

33

27

34 35 36 31 32 33 34 35 36 31

R. 36 E R. 37 E R. 38 E R. 39 E R. 39 E R. 40 E R. 39 E

T. 5 N T. 4 N T. 3 N T. 2 N

Tollgate Project Planning Area

Alternative C

Treatment Units

1 0.5 0 1 Miles  ́

ATTENTION

This product is reproduced from geospatial information

prepared by the U.S. Department of Agriculture Forest

Service. GIS data and product accuracy may vary. They

may be: developed from sources of differing accuracy,

accurate only at certain scales, based on modeling or

interpretation, incomplete while being created or

revised. etc... Using GIS products for purposes other

than those for which they were created may yield

inaccurate or misleading results. The Forest Service

reserves the right to correct,update,modify,or replace

GIS products without notification. For more information

contact the The Umatilla National Forest Supervisors office.

1:83,000

Legend

Tollgate Project Planning Area

Walla Walla Ranger District Boundary

Wenaha-Tucannon Wilderness

Inventoried Roadless Area

Closed

Open

Road Realignment

Commercial Thin, Ladder Fuel Reduction, Down & Dead Removal

Commercial Thin, Dead & Down Removal

Commercial Thin

Commercial Thin, Ladder Fuel Reduction

Commercial Thin, Non Commercial Thin

Ladder Fuel Reduction, Dead & Down Removal

Ladder Fuel Reduction

Non Commercial Thin

Walla Walla River IRA

Lookingglass IRA

North Fork Umatilla Wilderness

A-4
Walla Walla River

Lookingglass

Tollgate Project Planning Area

Management Areas

1 0.5 0 1 Miles  ́

ATTENTION

This product is reproduced from geospatial information

prepared by the U.S. Department of Agriculture Forest

Service. GIS data and product accuracy may vary. They

may be: developed from sources of differing accuracy,

accurate only at certain scales, based on modeling or

interpretation, incomplete while being created or

revised. etc... Using GIS products for purposes other

than those for which they were created may yield

inaccurate or misleading results. The Forest Service

reserves the right to correct,update,modify,or replace

GIS products without notification. For more information

contact the The Umatilla National Forest Supervisors office.

1:83,000

Legend

Tollgate Project Planning Area

Inventoried Roadless Area

Wenaha-Tucannon Wilderness

Closed

Open

MAS

A2 OHV Recreation

A3 Viewshed 1

A4 Viewshed 2

A5 Roaded Natural

A6 Developed Recreation

A9 Special Interest Area

B1 Wilderness

C1 Dedicated Old Growth Forest Habitat 

C4 Wildlife Habitat

C5 Riparian and Wildlife

E2 Timber/Big Game

F4 Walla Walla River Watershed

P Private

Walla Walla River IRA

Lookingglass IRA

North Fork Umatilla Wilderness

A-5
Walla Walla River

Lookingglass

Little Lookingglass Creek

170601041002

Cabin Creek

170601041104

North Fork Umatilla River

170701030104

Bear Creek-Umatilla River

170701030106

Couse Creek

170701020105

Upper Lookingglass Creek

170601041001

Middle South Fork Walla Walla River

170701020102

Lower Lookingglass Creek

170601041004

Lower South Fork Walla Walla River

170701020103

Buck Creek-South Fork Umatilla River

170701030103

Little Dry Creek-Dry Creek

170701020902

Upper Pine Creek

170701020901

Gordon Creek

170601041102

Phillips Creek

170601041101

Ryan Creek

170701030105

Upper South Fork Walla Walla River

170701020101

Jarboe Creek

170601041003

Moses Creek-Grande Ronde River

170601041106

Eagle Creek-Wildhorse Creek

170701030301

Thomas Creek

170701030101

South Fork Umatilla River

170701030102

North Fork Walla Walla River

170701020104

Cash Hollow-Walla Walla River

170701020106

Thomas Creek

170701030101

North Fork Walla Walla River

170701020104 Tollgate Project Planning Area

Subwatershed Area Map

1 0.5 0 1 Miles  ́

ATTENTION

This product is reproduced from geospatial information

prepared by the U.S. Department of Agriculture Forest

Service. GIS data and product accuracy may vary. They

may be: developed from sources of differing accuracy,

accurate only at certain scales, based on modeling or

interpretation, incomplete while being created or

revised. etc... Using GIS products for purposes other

than those for which they were created may yield

inaccurate or misleading results. The Forest Service

reserves the right to correct,update,modify,or replace

GIS products without notification. For more information

contact the The Umatilla National Forest Supervisors office.

1:83,000

Legend

Tollgate Project Planning Area

Walla Walla Ranger District Boundary

Subwatershed

Inventoried Roadless Area

Wenaha-Tucannon Wilderness

Closed

Open

Walla Walla River IRA

Lookingglass IRA

North Fork Umatilla Wilderness

A-6
APPENDIX B

PLANNED ACTIVITIES BY UNIT AND 

ALTERNATIVE 

 

Tollgate Fuels Reduction Project FEIS

B-1 

APPENDIX B

Table B1: Planning Unit Treatments for Alternative B

Unit # Alt. B Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

1 134 CT, NCT Tractor none

3 17 CT, NCT Tractor none

4 72 CT, NCT Tractor none

5 22 CT, NCT Tractor none

9 17 CT, LFR Tractor none

10 148 CT Tractor none

12 17 CT Tractor None

15 109 NCT n/a Mechanical

18 86 NCT n/a Mechanical

19 17 CT, LFR Forwarder Hand Piling/ Burn

20 41 LFR n/a Hand Piling/ Burn

21 13 LFR, DDR n/a Hand Piling/ Burn

23 20 CT Tractor none

25 48 CT Forwarder Mechanical

26 104 LFR n/a Hand Piling/ Burn

27 14 LFR n/a Hand Piling/ Burn

29 5 CT Tractor none

31 78 NCT n/a Mechanical

32 11 NCT n/a Mechanical

33 27 CT, LFR Tractor Hand Piling/Burn

34 59 CT, LFR, DDR Forwarder Mechanical

35 38 CT, LFR Tractor none

36 23 LFR n/a Mechanical

37 29 NCT n/a Hand Piling/Burn

38 87 CT, LFR Tractor none

41 172 CT, LFR Tractor none

42 122 CT, LFR Tractor none

43 49 CT, LFR Tractor none

44 69 CT, LFR Tractor none
Tollgate Fuels Reduction Project FEIS

B-2 

Unit # Alt. B Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

45 105 CT, LFR Tractor none

46 177 CT, LFR Tractor none

47 70 CT, LFR Tractor none

48 50 CT, LFR Forwarder Mechanical

49 62 CT, LFR Tractor none

50 89 CT, LFR Tractor none

51 54 CT, LFR, DDR Tractor none

52 29 CT, LFR Tractor none

53 60 CT, LFR Tractor none

54 66 CT, LFR Tractor none

55 13 CT, LFR Tractor none

56 41 CT, LFR Tractor none

61 36 CT, LFR Tractor none

62 132 CT, LFR Forwarder Mechanical

64 64 CT, LFR Forwarder Mechanical

66 40 CT, LFR, DDR Forwarder Hand Piling/ Burn

67 26 CT, LFR Tractor none

68 148 CT, LFR Tractor none

69 63 CT, LFR Tractor none

70 11 CT, LFR Tractor none

71 15 CT, LFR Tractor none

72 18 CT, LFR Tractor none

73 15 CT, LFR Tractor none

75 52 CT, LFR, DDR Forwarder Mechanical

76 70 CT, LFR, DDR Tractor none

77 77 CT, LFR Tractor none

78 50 CT, LFR Tractor none

79 206 NCT n/a Mechanical

81 22 CT Tractor none

82 38 CT, LFR Tractor none

83 102 CT, LFR Forwarder Mechanical 

84 85 CT, LFR Forwarder Mechanical

85 78 CT, LFR Forwarder Mechanical
Tollgate Fuels Reduction Project FEIS

B-3 

Unit # Alt. B Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

86 47 LFR n/a Hand Piling/Burn

87 47 CT, LFR Tractor none

89 57 CT, LFR Tractor none

90 21 CT, LFR Tractor none

94 17 CT, LFR Tractor none

95 47 CT, LFR Forwarder Mechanical

96 13 CT, LFR, DDR Forwarder Mechanical

97 32 CT Tractor none

98 12 CT Tractor none

99 27 CT, LFR Tractor none

100 37 CT, LFR Tractor none

101 14 CT Tractor none

102 19 CT, LFR Tractor none

103 49 NCT n/a Hand Piling/Burn

104 75 LFR n/a Hand Piling/Burn

105 7 CT, LFR Tractor none

Totals 4333

Table B2: Planning Unit Treatments for Alternative C

Unit # Alt. C Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

1 134 CT, NCT Tractor none

3 17 CT, NCT Tractor none

4 72 CT, NCT Tractor none

5 22 CT, NCT Tractor none

9 16 CT, LFR Tractor none

10 127 CT Tractor none

12 14 CT Tractor None

15 109 NCT n/a Mechanical
Tollgate Fuels Reduction Project FEIS

B-4 

Unit # Alt. C Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

18 86 NCT n/a Mechanical

19 17 CT, LFR Forwarder Hand Piling/ Burn

20 41 LFR n/a Hand Piling/ Burn

21 13 LFR, DDR n/a Hand Piling/ Burn

23 20 CT Tractor none

25 48 CT Forwarder Mechanical

26 0 LFR n/a Hand Piling/ Burn

27 14 LFR n/a Hand Piling/ Burn

29 5 CT Tractor none

31 77 NCT n/a Mechanical

32 12 NCT n/a Mechanical

33 12 CT, LFR Tractor Hand Piling/Burn

34 59 CT, LFR, DDR Forwarder Mechanical

35 38 CT, LFR Tractor none

36 23 LFR n/a Mechanical

37 29 NCT n/a Hand Piling/Burn

38 0 CT, LFR Tractor none

41 172 CT, LFR Tractor none

42 121 CT, LFR Tractor none

43 49 CT, LFR Tractor none

44 69 CT, LFR Tractor none

45 104 CT, LFR Tractor none

46 177 CT, LFR Tractor none

47 70 CT, LFR Tractor none

48 50 CT, LFR Forwarder Mechanical

49 62 CT, LFR Tractor none

50 89 CT, LFR Tractor none

51 54 CT, LFR, DDR Tractor none

52 29 CT, LFR Tractor none

53 60 CT, LFR Tractor none

54 66 CT, LFR Tractor none

55 13 CT, LFR Tractor none

56 41 CT, LFR Tractor none
Tollgate Fuels Reduction Project FEIS

B-5 

Unit # Alt. C Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

61 36 CT, LFR Tractor none

62 132 CT, LFR Forwarder Mechanical

64 61 CT, LFR Forwarder Mechanical

66 0 CT, LFR, DDR Forwarder Hand Piling/ Burn

67 26 CT, LFR Tractor none

68 148 CT, LFR Tractor none

69 60 CT, LFR Tractor none

70 7 CT, LFR Tractor none

71 15 CT, LFR Tractor none

72 18 CT, LFR Tractor none

73 15 CT, LFR Tractor none

75 38 CT, LFR, DDR Forwarder Mechanical

76 70 CT, LFR, DDR Tractor none

77 77 CT, LFR Tractor none

78 50 CT, LFR Tractor none

79 206 NCT n/a Mechanical

81 22 CT Tractor none

82 38 CT, LFR Tractor none

83 102 CT, LFR Forwarder Mechanical 

84 85 CT, LFR Forwarder Mechanical

85 78 CT, LFR Forwarder Mechanical

86 47 LFR n/a Hand Piling/Burn

87 47 CT, LFR Tractor none

89 56 CT, LFR Tractor none

90 21 CT, LFR Tractor none

94 15 CT, LFR Tractor none

95 47 CT, LFR Forwarder Mechanical

96 10 CT, LFR, DDR Forwarder Mechanical

97 32 CT Tractor none

98 12 CT Tractor none

99 27 CT, LFR Tractor none

100 37 CT, LFR Tractor none

101 14 CT Tractor none
Tollgate Fuels Reduction Project FEIS

B-6 

Unit # Alt. C Acres Silvicultural 

Prescription Harvest Method Fuel Treatment

102 19 CT, LFR Tractor none

103 49 NCT n/a Hand Piling/Burn

104 19 LFR n/a Hand Piling/Burn

105 7 CT, LFR Tractor none

Totals 4010
APPENDIX C

ROADS 

 

Tollgate Fuels Reduction Project FEIS

C-1 

Appendix C 

Table C-1 - Roads used in Alternative B and C

Road Number Length - Miles Access and Travel Management

Category

6400 6.04 Seasonal

3700050 0.10 Seasonal

3700051 0.19 Seasonal

3719 4.68 Seasonal

3725 0.69 Seasonal

6401 3.14 Seasonal

3700070 0.10 Seasonal

3715030 0.54 Open

3718 3.15 Seasonal

3718150 0.20 Seasonal

3719025 0.11 Seasonal

3719080 0.85 Seasonal

6400030 1.59 Seasonal

6400100 2.07 Seasonal

6401000 1.54 Seasonal

6401020 2.04 Seasonal

6406 2.95 Seasonal

6406050 0.05 Seasonal

3700040 0.76 Closed

3700040 2.21 Closed

3700041 1.05 Closed

3700060 0.43 Closed

3715020 0.33 Closed

3715034 1.30 Closed

3715035 0.41 Closed

3715036 0.27 Closed

3718150 2.46 Closed

3718155 0.70 Closed

3718200 0.59 Closed

3718300 0.21 Closed

3719020 0.46 Closed

3719025 0.79 Closed

3719030 0.91 Closed

3719050 0.44 Closed

3719060 1.06 Closed

3719070 0.64 Closed

3719083 0.31 Closed

3725020 0.08 Closed
Tollgate Fuels Reduction Project FEIS

C-2 

Road Number Length - Miles Access and Travel Management

Category

3725022 0.25 Closed

6400032 0.37 Closed

6400033 0.83 Closed

6400035 0.36 Closed

6401010 0.62 Closed

6401015 0.36 Closed

6401040 0.11 Closed

6401041 0.20 Closed

6401110 0.64 Closed

6401120 0.60 Closed

6401140 0.34 Closed

6406051 0.12 Closed

6406100 0.47 Closed

3715 3.06 Closed

6401900 0.52 Seasonal

Total 52
APPENDIX D

SELECTED NATIONAL 

BEST MANAGEMENT PRACTICES

 

Tollgate Fuels Reduction Project FEIS

D-1 

Appendix D

Selected National Best Management Practices (BMPs) 

for Tollgate Fuels Reduction Project

Specific resource protection measures and mitigation's listed below would be implemented in any action 

alternative. These resource protection measures and mitigation's are consistent with the Umatilla 

National Forest LRMP standards and guidelines. BMP's and resource protection measures are identified 

below. A general discussion of Best Management Practices (BMP’s) and these specific BMPs are found 

in the document referenced below. 

National Best Management Practices for Water quality Management on National Forest System 

Lands, Volume 1: National Core BMP Technical Guide FS-990a, April 2012 

Plan-2. Project Planning and Analysis

Objective: Use the project planning, environmental analysis, and decision making processes to 

incorporate water quality management BMPs into project design and implementation.

Practices: Include watershed specialists (hydrologist, soil scientist, geologist, and fish biologist) and other 

trained and qualified individuals on the interdisciplinary team for project planning, environmental 

analysis, and decision making to evaluate onsite watershed characteristics and the potential environmental 

consequences of the proposed activity(s). 

• Determine potential or likely direct and indirect impacts to chemical, physical, and biological 

water quality, and watershed condition from the proposed activity. 

Develop site-specific BMP prescriptions, design criteria, and mitigation measures to 

achieve water quality management objectives. Consult local, regional, State, or other 

agency’s required or recommended BMPs that are applicable to the activity.

• Document site-specific BMP prescriptions, design criteria, mitigation measures, and restoration, 

rehabilitation, and monitoring needs in the applicable National Environmental Policy Act (NEPA) 

documents, design plans, contracts, permits, authorizations, and operation and maintenance plans. 

Plan-3 Aquatic Management Zone Planning

Objective: To maintain and improve or restore the condition of land around and adjacent to waterbodies 

in the context of the environment in which they are located, recognizing their unique values and 

importance to water quality while implementing land and resource management activities.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment. 

• Design and implement project activities within the AMZ to:

Avoid or minimize unacceptable impacts to riparian vegetation, groundwater recharge 

areas, steep slopes, highly erodible soils, or unstable areas.
Tollgate Fuels Reduction Project FEIS

D-2 

Road-4 Road Operations and Maintenance

Objective: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by 

controlling road use and operations and providing adequate and appropriate maintenance to minimize 

sediment production and other pollutants during the useful life of the road. 

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment. 

Operations 

• Designate season of use to avoid or restrict road use during periods when use would likely damage 

the roadway surface or road drainage features.

o Upgrade drainage structures to avoid, to the extent practicable, or minimize direct 

discharges into nearby waterbodies.

• Ensure that drainage features are fully functional on completion of seasonal operations.

o Shape road surfaces to drain as designed.

o Construct or reconstruct drainage control structures as needed.

o Ensure that ditches and culverts are clean and functioning.

Maintenance Activities

• Maintain the road surface drainage system to intercept, collect, and remove water from the road 

surface and surrounding slopes in a manner that reduces concentrated flow in ditches, culverts, and 

over fill slopes and road surfaces.

o Clean ditches and catch basins only as needed to keep them functioning. 

o Do not undercut the toe of the cut slope when cleaning ditches or catch basins. 

o Use suitable measures to avoid, to the extent practicable, or minimize direct discharges from road 

drainage structures to nearby waterbodies.

• Ensure the necessary specifications concerning prehaul maintenance, maintenance during haul, and 

posthaul maintenance (putting the road back in storage) are in place when maintenance level 1 roads 

are opened for use on commercial resource management projects or other permitted activities.

o Require the commercial operator or responsible party to leave roads in a satisfactory condition 

when project is completed. 

Road-5. Temporary Roads 

Objective: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources from 

the construction and use of temporary roads. 

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment. 

• Use applicable practices of BMP Road-2 (Road Location and Design) to locate temporary roads. 
Tollgate Fuels Reduction Project FEIS

D-3 

Road-2. Road Location and Design 

Objective: Locate and design roads to avoid, minimize, or mitigate adverse effects to soil, water quality, 

and riparian resources.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment. 

Location 

• Locate roads to fit the terrain, follow natural contours, and limit the need for excavation.

• Locate roads as far from waterbodies as is practicable to achieve access objectives, with a minimum 

number of crossings and connections between the road and the waterbody. 

Road-7. Stream Crossings

Manual or Handbook Reference: FSM 7722 and FSH 7709.56b 

Objective: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources when 

constructing, reconstructing, or maintaining temporary and permanent waterbody crossings. 

• Use crossing structures suitable for the site conditions and the RMOs.

• Culverts

Align the culvert with the natural stream channel.

Cover culvert with sufficient fill to avoid or minimize damage by traffic.

Construct at or near natural elevation of the streambed to avoid or minimize potential flooding 

upstream of the crossing and erosion below the outlet 

Veg-1. Vegetation Management Planning 

Objectives: Use the applicable vegetation management planning processes to develop measures to avoid, 

minimize, or mitigate adverse effects to soil, water quality, and riparian resources during mechanical 

vegetation treatment activities.

• Evaluate and field verify site conditions in the project area to design mechanical vegetation treatment 

prescriptions that avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian 

resources.

o Design mechanical vegetation treatment prescriptions to limit site disturbance, soil exposure, and 

displacement to acceptable levels as determined from the land management plan desired 

conditions, standards, and guidelines or other local direction or requirements. 

o Evaluate direct, indirect, and cumulative effects of vegetation alteration on streamflow regimes 

and consequent channel responses at suitable watershed scales.

o Use local direction or requirements for slope, erosion potential, mass wasting potential, and other 

soil or site properties to determine areas suitable for ground-based, cable, and aerial yarding 

systems (see BMP Veg-4 [Ground-Based Skidding and Yarding Operations] and BMP Veg-5 

[Cable and Aerial Yarding Operations]).

o Consider site preparation and fuel treatment needs and options. 
Tollgate Fuels Reduction Project FEIS

D-4 

o Use applicable practices of BMP Veg-8 (Mechanical Site Treatment) to determine areas suitable 

for mechanical treatments for site preparation, fuels treatment, habitat improvements, or other 

vegetation management purposes.

• Evaluate and field verify site conditions in the project area to design a transportation plan associated 

with the mechanical vegetation treatments to avoid, minimize, or mitigate adverse effects to soil, 

water quality, and riparian resources. 

o Use the logging system that best fits the topography, soil types, and season, while minimizing soil 

disturbance and road densities and that economically achieves silvicultural objectives.

o Evaluate the condition of system roads, including roads in storage, and unauthorized roads in the 

project area to determine their suitability for use in the project and any reconstruction or prehaul 

maintenance needs.

• Identify sources of rock for roadwork, riprapping, and borrow materials (see BMP Min-6 [Mineral 

Materials Resource Sites]).

• Identify water sources available for purchasers’ use (see BMP Uses-3 [Administrative Water 

Developments]).

• Ensure the timber sale contract, stewardship contract, or other implementing document includes 

BMPs from the decision document to avoid, minimize, or mitigate adverse effects to soil, water 

quality, and riparian resources.

o Use appropriate standard B and C provisions and regional or local provisions to address measures 

and responsibilities consistent with the BMPs in the decision document in the timber sale or 

stewardship contract. 

o Delineate all protected or excluded areas, including AMZs and waterbodies, on the sale area map 

or project map. 

o Delineate approved water locations, staging areas, and borrow areas on the sale area map or 

project map.

o Ensure that the final unit location, layout, acreage, and logging system or mechanical treatment 

and Knutson-Vandenberg Act plans are consistent with the decision document.

Veg-2. Erosion Prevention and Control

Objective: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by 

implementing measures to control surface erosion, gully formation, mass slope failure, and resulting 

sediment movement before, during, and after mechanical vegetation treatments.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment 

1. Develop erosion control and sediment plan that covers all disturbed areas including skid trails and 

roads, landings, cable corridors, temporary road fills, water source sites, borrow sites, or other areas 

disturbed during mechanical vegetation treatments. 

• Refer to State or local forestry or silviculture BMP manuals, guidebooks, and trade publications for 

effective structural and nonstructural measures to:

o Apply soil protective cover on disturbed areas where natural revegetation is inadequate to prevent 

accelerated erosion before the next growing season. 
Tollgate Fuels Reduction Project FEIS

D-5 

o Maintain the natural drainage pattern of the area wherever practicable.

o Control, collect, detain, treat, and disperse stormwater runoff from disturbed areas. 

o Divert surface runoff around bare areas with appropriate energy dissipation and sediment filters.

o Stabilize steep excavated slopes.

• Use suitable species and establishment techniques to cover or revegetate disturbed areas in 

compliance with local direction and requirements per FSM 2070 and FSM 2080 for vegetation 

ecology and prevention and control of invasive species.

• Use suitable measures in compliance with local direction to prevent and control invasive species.

• Install sediment and stormwater controls before initiating surface disturbing activities to the extent 

practicable.

• Operate equipment when soil compaction, displacement, erosion, and sediment runoff would be 

minimized.

o Avoid ground equipment operations on unstable, wet, or easily compacted soils and on steep 

slopes unless operation can be conducted without causing excessive rutting, soil puddling, or 

runoff of sediments directly into waterbodies. 

o Evaluate site conditions frequently to assess changing conditions. 

o Adjust equipment operations as necessary to protect the site while maintaining efficient project 

operations. 

• Install suitable stormwater and erosion control measures to stabilize disturbed areas and waterways on 

incomplete projects before seasonal shutdown of operations or when severe storm or cumulative 

precipitation events that could result in sediment mobilization to streams are expected.

• Routinely inspect disturbed areas to verify that erosion and stormwater controls are implemented and 

functioning as designed and are suitably maintained.

• Maintain erosion and stormwater controls as necessary to ensure proper and effective functioning. 

o Prepare for unexpected failures of erosion control measures.

• Implement mechanical treatments on the contour of sloping ground to avoid or minimize water 

concentration and subsequent accelerated erosion. 

Veg-3. Aquatic Management Zones 

Objectives: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources 

when conducting mechanical vegetation treatment activities in the AMZ.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment. 

• Clearly delineate AMZ locations and boundaries in the project area using suitable markings and 

structures.

o Maintain or reestablish these boundaries as necessary during project implementation or operation.

o Specify AMZ layout, maintenance, and operating requirements in contracts, design plans, and 

other necessary project documentation. 
Tollgate Fuels Reduction Project FEIS

D-6 

Veg-4. Ground-Based Skidding and Yarding Operations

Objectives: Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources 

during ground-based skidding and yarding operations by minimizing site disturbance and controlling the 

introduction of sediment, nutrients, and chemical pollutants to waterbodies.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using State BMPs, Forest Service regional guidance, land management plan direction, BMP 

monitoring information, and professional judgment.

• Use ground-based yarding systems only where physical site characteristics are suitable to avoid, 

minimize, or mitigate adverse effects to soil, water quality, and riparian resources.

o Use local direction or requirements for slope, erosion potential, mass wasting potential, and other 

soil or site properties to determine areas suitable for ground-based yarding systems.

• Use existing roads and skid trails networks to the extent practicable.

o Create new roads and skid trails where re-use of existing ones would exacerbate soil, water 

quality, and riparian resource impacts.

• Design and locate skid trails and skidding operations to minimize soil disturbance to the extent 

practicable.

o Designate skid trails to the extent practicable to limit site disturbance.

• Use suitable measures during felling and skidding operations to avoid or minimize disturbance to 

soils and waterbodies to the extent practicable.

o Perform skidding or yarding operations when soil conditions are such that soil compaction, 

displacement, and erosion would be minimized. 

o Suspend skidding or yarding operations when soil moisture levels could result in unacceptable 

soil damage.

o Directionally fell trees to facilitate efficient removal along predetermined yarding patterns with 

the least number of passes and least amount of disturbed area (e.g., felling-to-the-lead).

o Directionally fell trees away from streambanks, shorelines, and other waterbody edges.

o Remove logs from wet meadows or AMZs using suitable techniques to minimize equipment 

operations in the sensitive area and minimize dragging the logs on the ground. 

o Use low ground pressure equipment when practicable, particularly on equipment traveling over 

large portions of units with sensitive soils or site conditions. 

• Use suitable measures to stabilize and restore skid trails after use.

o Reshape the surface to promote dispersed drainage.

o Install suitable drainage features.

o Mitigate soil compaction to improve infiltration and revegetation conditions. 

o Apply soil protective cover on disturbed areas where natural revegetation is inadequate to prevent 

accelerated erosion before the next growing season.

o Use suitable measures to promote rapid revegetation.

o Use suitable measures in compliance with local direction to prevent and control invasive species.
APPENDIX E

SOILS

 

Tollgate Fuels Reduction Project FEIS

E-1

Appendix E

Table E-1: Cumulative effects to Detrimental Soil Condition (DSC) by Alternative and recommendation 

of mitigation for DSC. Units with combined existing and proposed DSC that exceed forest S&Gs are in 

bold. Unit 3 is the only proposed unit currently exceeding forest S&Gs. 

 

1 Unit 33 exceeds S&Gs only in Alternative C. Unit ID

Alt 

A

Alternative B Proposal Effects & 

Recommendations Alternative C Proposal Effects & Recommendations

Existing DSC 

(%)

Alt B (ac)

Total 

Detrimental (%)

Detrimental 

(ac)

Prescribed 

overlap of 

legacy & 

proposed 

DSC ac (%)

Skid trail 

overlap 

for DSC 

mitigation 

(ft)

Alt C (ac)

Total 

Detrimental (%)

Detrimental 

(ac)

Prescribed 

overlap of legacy 

& proposed DSC 

ac (%)

Skid trail 

overlap 

for DSC 

mitigation 

(ft)

1 8% 133.8 20% 26.8 20% 11658 133.7 20% 26.7 20% 11650

3 23% 16.9 35% 5.9 70% 5164 16.9 35% 5.9 70% 5164

4 0% 71.8 12% 8.6 0% 0 71.8 12% 8.6 0% 0

5 8% 21.9 20% 4.4 10% 955 21.9 20% 4.4 10% 955

9 0% 17.4 18% 3.1 0% 0 16.0 18% 2.9 0% 0

10 6% 147.7 21% 31.6 20% 16501 126.7 22% 27.8 20% 14665

12 0% 16.8 18% 3.0 0% 0 13.7 19% 2.6 0% 0

15 0% 109.2 0% 0.0 0% 0 109.2 0% 0.0 0% 0

18 4% 85.5 4% 3.4 0% 0 85.5 4% 3.4 0% 0

19 0% 17.4 12% 2.0 0% 0 17.4 12% 2.0 0% 0

20 0% 41.0 0% 0.0 0% 0 41.0 0% 0.0 0% 0

21 0% 13.4 0% 0.0 0% 0 13.4 0% 0.0 0% 0

23 0% 20.3 17% 3.4 0% 0 20.3 17% 3.4 0% 0

25 12% 47.9 20% 9.6 20% 2815 47.9 20% 9.6 20% 2815

26 0% 103.7 0% 0.0 0% 0 0.0 0% 0.0 0% 0

27 0% 13.9 0% 0.0 0% 0 13.9 0% 0.0 0% 0

29 0% 5.2 31% 1.6 20% 1182 5.2 31% 1.6 20% 1182

31 5% 78.5 5% 3.9 0% 0 77.2 5% 3.9 0% 0

32 0% 11.5 0% 0.0 0% 0 11.5 0% 0.0 0% 0

331 0% 27.3 16% 4.3 0% 0 12.1 20% 2.5 10% 892

34 0% 59.1 9% 5.5 0% 0 59.1 9% 5.5 0% 0

35 0% 38.4 17% 6.6 0% 0 38.4 17% 6.6 0% 0

36 8% 23.3 8% 1.9 0% 0 23.3 8% 1.9 0% 0

37 0% 28.7 0% 0.0 0% 0 28.7 0% 0.0 0% 0

38 0% 87.1 14% 12.5 0% 0 0.0 0% 0.0 0% 0

41 0% 171.7 14% 24.6 0% 0 171.7 14% 24.6 0% 0
Tollgate Fuels Reduction Project FEIS

E-2

42 0% 121.7 15% 18.6 0% 0 120.8 15% 18.5 0% 0

43 0% 49.0 16% 7.9 0% 0 49.0 16% 7.9 0% 0

44 0% 68.9 16% 11.3 0% 0 68.9 16% 11.3 0% 0

45 0% 104.1 16% 16.5 0% 0 104.1 16% 16.5 0% 0

46 5% 176.9 20% 36.1 20% 19766 176.9 20% 36.1 20% 19766

47 2% 70.1 17% 11.8 0% 0 70.1 17% 11.8 0% 0

48 0% 50.2 10% 5.0 0% 0 50.2 10% 5.0 0% 0

49 0% 61.8 15% 9.4 0% 0 61.8 15% 9.4 0% 0

50 0% 88.8 15% 13.7 0% 0 88.8 15% 13.7 0% 0

51 0% 53.6 16% 8.4 0% 0 53.6 16% 8.4 0% 0

52 3% 29.4 18% 5.4 0% 0 29.4 18% 5.4 0% 0

53 0% 59.5 15% 9.1 0% 0 59.5 15% 9.1 0% 0

54 0% 66.4 15% 10.0 0% 0 66.4 15% 10.0 0% 0

55 0% 13.3 20% 2.6 20% 1881 13.3 20% 2.6 20% 1881

56 2% 40.8 19% 7.7 0% 0 40.8 19% 7.7 0% 0

61 5% 35.8 20% 7.1 20% 3847 35.8 20% 7.1 20% 3847

62 0% 132.0 9% 11.9 0% 0 132.0 9% 11.9 0% 0

64 5% 63.9 17% 11.0 0% 0 61.0 18% 10.7 0% 0

66 5% 39.6 16% 6.4 0% 0 39.6 16% 6.4 0% 0

67 5% 25.8 25% 6.4 20% 3699 25.8 25% 6.4 20% 3699

68 5% 147.7 21% 31.1 20% 17225 147.7 21% 31.1 20% 17225

69 0% 63.1 17% 10.6 0% 0 60.1 17% 10.2 0% 0

70 8% 10.7 29% 3.1 30% 2487 7.1 34% 2.4 30% 2022

71 0% 14.5 19% 2.7 0% 0 14.5 19% 2.7 0% 0

72 0% 18.1 18% 3.2 0% 0 18.1 18% 3.2 0% 0

73 11% 15.1 30% 4.5 30% 3058 15.1 30% 4.5 30% 3058

75 0% 51.9 10% 5.1 0% 0 38.3 11% 4.3 0% 0

76 8% 69.6 24% 16.9 20% 8245 69.6 24% 16.9 20% 8245

77 13% 76.6 29% 22.2 30% 13281 76.6 29% 22.2 30% 13281

78 0% 50.0 16% 8.0 0% 0 50.0 16% 8.0 0% 0

79 0% 206.1 0% 0.0 0% 0 206.1 0% 0.0 0% 0

81 0% 22.1 17% 3.7 0% 0 22.1 17% 3.7 0% 0

82 0% 37.7 15% 5.5 0% 0 37.7 15% 5.5 0% 0

83 0% 102.1 9% 9.1 0% 0 102.1 9% 9.1 0% 0

84 3% 84.9 13% 10.6 0% 0 84.9 13% 10.6 0% 0

85 0% 78.1 9% 6.7 0% 0 78.1 9% 6.7 0% 0

86 0% 46.7 0% 0.0 0% 0 46.7 0% 0.0 0% 0

87 0% 46.6 16% 7.6 0% 0 46.6 16% 7.6 0% 0

89 0% 57.0 16% 8.8 0% 0 55.7 16% 8.7 0% 0

90 5% 21.3 22% 4.6 20% 2585 21.3 22% 4.6 20% 2585

94 0% 16.9 18% 3.0 0% 0 14.4 19% 2.7 0% 0
Tollgate Fuels Reduction Project FEIS

E-3

95 0% 47.1 10% 4.8 0% 0 47.1 10% 4.8 0% 0

96 0% 12.6 14% 1.8 0% 0 9.4 17% 1.6 0% 0

97 0% 32.2 18% 5.9 0% 0 32.2 18% 5.9 0% 0

98 0% 12.0 20% 2.4 10% 886 12.0 20% 2.4 10% 886

99 0% 26.6 16% 4.2 0% 0 26.6 16% 4.2 0% 0

100 0% 37.3 15% 5.5 0% 0 37.3 15% 5.5 0% 0

101 2% 13.5 21% 2.9 10% 950 13.5 21% 2.9 10% 950

102 0% 19.4 17% 3.3 0% 0 19.4 17% 3.3 0% 0

103 6% 48.9 6% 2.9 0% 0 48.9 6% 2.9 0% 0

104 5% 75.1 5% 3.8 0% 0 18.4 5% 0.9 0% 0

105 0% 7.0 26% 1.8 20% 1332 7.0 26% 1.8 20% 1332

Alt B Total 117518 ft Alt C Total 116102 ft
APPENDIX F

CONSISTENCY WITH EASTSIDE SCREENS

 

Tollgate Fuels Reduction Project FEIS

F-1 

APPENDIX F

Tollgate Fuels Reduction Project

Consistency with Eastside Screens

Introduction and Analysis of Ranges of Variability

This appendix presents a characterization of historical and existing vegetation conditions for a large landscape called the Tollgate Fuels Reduction Project Planning Area (“planning area”). Four indicators were 

used for the upland-forest characterization: potential vegetation, species composition, forest structure, and 

tree density.

The vegetation information summarized in this appendix was developed using the Most Similar Neighbor 

(MSN) imputation process (Crookston et al. 2002, Moeur and Stage 1995). The MSN algorithm uses 

canonical correlation analysis to derive a similarity function, and then chooses the most similar stand as a 

proxy from the global set of stands by comparing detailed design attributes (local variables) and lowerresolution indicator attributes (global variables). The most similar stand is selected by using the similarity 

function to maintain multivariate relationships between the global variables and the local variables.

The planning area contains approximately 46,460 acres of National Forest System lands and includes 

portions of the upper Umatilla, upper Walla Walla, and Lookingglass creek watersheds. This Appendix 

Considers all 46,460 acres located in the planning area; acreages are rounded to nearest 10 acres. 

Potential Vegetation

In the Tollgate planning area, 39 potential vegetation types (PVTs) were identified (Table F1). Twentyfive of the PVTs are forest types, comprising 81% of the analysis-area acreage, and the other 14 PVTs are 

nonforest types (19% of the planning area). 

PVTs representing equivalent temperature and moisture environments have been aggregated into higherlevel hierarchical units called plant association groups (PAG) and potential vegetation groups (PVG) 

(Powell et al. 2007). The 39 forest PVTs in the planning area were aggregated into 8 PAGs and 4 PVGs 

(Table F1) by using the information from Powell et al. (2007). 

The upland forest PVGs are dry forest (3% of total acreage), moist forest (77%), and cold forest (<1%). 

This appendix uses upland forest PVGs when reporting vegetation conditions for the planning area. Table 

F2 presents certain biophysical characteristics of the forest PVGs. 

When performing analysis of vegetation Historic Ranges of Variability (HRVs), existing vegetation was 

stratified into PVGs (Martin 2010). Since the cold upland forest PVG included less than 1,000 acres 

within the Tollgate planning area, it was largely ignored during HRV analysis because a full complement 

of cover types, structural stages, or tree density classes would not be expected for such a small amount of 

acreage (Martin 2010 and Powell 2010b). 
Tollgate Fuels Reduction Project FEIS

F-2 

Table F1 – Potential vegetation types (PVT) of the Tollgate planning area 

PVG PVT and PAG PVT Acronym Acres Percent

of Total

Percent

of Forest

Dry Upland Forest

(1,574 acres; 3%)

grand fir/elk sedge ABGR/CAGE2 675 1 2

grand fir/birchleaf spiraea ABGR/SPBE2 900 2 2

Warm dry upland forestland PAG 1574 3 4

Moist Upland Forest

(35,715 acres; 77%)

grand fir/queencup beadlily ABGR/CLUN2 7309 16 19

grand fir/twinflower ABGR/LIBO3 1247 3 3

grand fir/big huckleberry ABGR/VAME 4561 10 12

subalpine fir/queencup beadlily ABLA/CLUN2 6620 14 18

subalpine fir/twinflower ABLA/LIBO3 289 1 1

subalpine fir/false bugbane ABLA/TRCA 1095 2 3

subalpine fir/big huckleberry ABLA/VAME 2916 6 8

lodgepole pine(grand fir)/twinflower PICO(ABGR)/LIBO3* 433 1 1

lodgepole pine(grand fir)/big 

huckleberry/twinflower PICO(ABGR)/VAME-LIBO3* 409 1 1 

lodgepole pine(subalpine fir)/big 

huckleberry PICO(ABLA)/VAME* < 1 < 1 < 1

Cool moist upland forestland PAG 24882 54 66

grand fir/swordfern-ginger ABGR/POMU-ASCA2 73 < 1 < 1

grand fir/false bugbane ABGR/TRCA 34 < 1 < 1

Cool very moist upland forestland PAG 107 < 1 < 1

grand fir/Pacific yew/queencup beadlily ABGR/TABR2/CLUN2 2385 5 6

grand fir/Pacific yew/twinflower ABGR/TABR2/LIBO3 808 2 2

subalpine fir/claspleaf twistedstalk ABLA/STAM2 9 < 1 < 1

Cool wet upland forestland PAG 3203 7 9

grand fir/Rocky Mountain maple-mallow 

ninebark ABGR/ACGL-PHMA5 672 1 2 

grand fir/Columbia brome ABGR/BRVU 88 0 0

Douglas-fir/Rocky Mountain maplemallow ninebark PSME/ACGL-PHMA5 1460 3 4 

Douglas-fir/oceanspray PSME/HODI 2753 6 7

Warm moist upland forestland PAG 4973 11 13

grand fir/Rocky Mountain maple ABGR/ACGL 2551 5 7

Warm very moist upland forestland PAG 2551 5 7

Cold UF (277 

acres,1%)

subalpine fir/elk sedge ABLA/CAGE2 51 < 1 < 1

subalpine fir/grouse huckleberry ABLA/VASC 213 < 1 < 1

subalpine fir/grouse huckleberry/Jacob’s 

ladder ABLA/VASC/POPU3 12 < 1 < 1

Cold dry upland forestland PAG 277 < 1 < 1

Nonforest

(8,892 acres; 19%)

bluebunch wheatgrass-Sandberg’s 

bluegrass AGSP-POSA12 3537 8 

bluebunch wheatgrass-Sandberg’s 

bluegrass-onespike oatgrass AGSP-POSA12-DAUN 4 0 

alder snow slides ALSI3 251 1

mountain big sagebrush/elk sedge 

(montane) ARTRV/CAGE2 59 0 
Tollgate Fuels Reduction Project FEIS

F-3 

mountain big sagebrush/Idaho fescuebluebunch wheatgrass ARTRV/FEID-AGSP 262 1 

mountain big sagebrush-mountain 

snowberry/mountain brome ARTRV-SYOR2/BRCA5 186 0 

tufted hairgrass DECE 41 0

Idaho fescue-bluebunch wheatgrass FEID-AGSP 3280 7

mallow ninebark-common snowberry PHMA5-SYAL* 306 1

Kentucky bluegrass (dry meadow) POPR 29 0

Sandberg’s bluegrass-onespike oatgrass POSA12-DAUN 66 0

western needlegrass STOC* 549 1

mountain snowberry SYOR2 17 0

common cattail TYLA 5 0

Nonforest PVTs 8892 19

Sources/Notes: Summarized from the Tollgate vegetation database (NFS lands only). Powell et al. (2007) describes how 

PVTs were assigned to potential vegetation groups (PVG) and plant association groups (PAG). PVTs and PVGs are 

characterized generally in Powell (2000).

* These PVTs are plant community types or plant communities; all others are plant associations.

Table F2 – Biophysical characteristics for upland forest potential vegetation groups 

(PVG) 

PVG

Area

(acres) Disturbances

Fire

Regime

Patch

Size (acres)

Dry

Upland

Forest

1,574

Fire

Insects

Harvest

Frequent

Surface

1-252

Moist

Upland

Forest

35,715

Insects

Fire

Diseases

Infrequent

Mixed

1-583

Cold

Upland

Forest

277

Wind

Insects

Fire

Replacement 1-51

Sources/Notes: Area and patch size were derived from the Tollgate vegetation database (NFS lands only). 

Fire regime names correspond to Schmidt et al. (2002). Disturbances and fire regimes were supplied by the 

author and described in Appendix D and Agee (1996a, 2008).

Table F3 – Existing species composition (cover types) for the Tollgate planning area 

Code Cover Type Description Acres

Pct. of 

Total

Pct. of 

Forested

Non-forest Non-forest cover types (rocky, water, administrative sites, etc.) 

lacking extensive vegetation cover. 301 <1

Herb-shrub Non-forest cover types dominated by herbaceous and shrub 

species 8591 18

Ponderosa pine Forest with ponderosa pine as the majority or plurality species 2465 5 7

Douglas-fir Forest with Douglas-fir as the majority or plurality species 9885 21 26

Western larch Forest with western larch as the majority or plurality species 1045 2 3

Lodgepole pine Forest with lodgepole pine as the majority or plurality species 3269 7 9

Broadleaved species Forest with various broadleaved trees as the majority or plurality 578 1 2
Tollgate Fuels Reduction Project FEIS

F-4 

species

Grand fir Forest with grand fir as the majority or plurality species 10416 22 28

Subalpine firEngelmann spruce

Forest with subalpine fir and/or Engelmann spruce as the 

majority or plurality species 9907 21 26

Sources/Notes: Summarized from the Tollgate vegetation database (NFS lands only). The subalpine firEngelmann spruce cover type contains either a majority or plurality of either species, alone or in combination.

Species Composition

Plant species occur in either pure or mixed communities called cover types. Tree species occurrence in 

the planning area was categorized by forest cover type, a classification of existing vegetation composition 

(Eyre 1980). Forest cover types reflect current tree species amounts in the Tollgate planning area.

Forest cover types are based on a predominance of tree stocking and are seldom pure – the grand fir type, 

for example, has a majority (50% or more) or plurality of grand fir trees but could also contain Douglasfir and other tree species (Eyre 1980). 

Table F3 summarizes existing species composition for the Tollgate planning area. It shows that the 

predominant forest cover type is grand fir (28% of the forest environment has grand fir as the majority or 

plurality tree species), followed by spruce-fir (26%) and Douglas-fir (26%), and lodgepole pine (9%). 

About 19% of the Tollgate planning area supports non-forest vegetation (Table F1), much of which 

consists of dry meadows and bunchgrass communities dominated by Idaho fescue or bluebunch wheatgrass. 

HRV Analysis for Species Composition

An historical range of variability (HRV) analysis was used to evaluate species composition for the 

Tollgate planning area; HRV results are presented in Table F4. It summarizes the current amount of each 

forest cover type by potential vegetation group (PVG), as well as the estimated historical range.

An HRV analysis was completed for species composition of the forest vegetation Affected Environment. 

Because species composition varies by biophysical environment, the HRV analysis was stratified by 

potential vegetation group: dry upland forest and moist upland forest. The cold upland forest PVG was 

not included because it has too few acres (277 acres) for a credible HRV analysis. Species composition 

HRV results are presented in Tables F4a, F4b, and F4c.

The information presented in Table F4a, F4b, and F4c suggests that dry forestland currently supports too 

much of the grand fir and Douglas-fir forest cover types, and too little of the ponderosa pine forest cover 

type. Moist forestland supports too much of the grand fir and spruce-fir forest cover types, and too little of 

the western larch, ponderosa pine, and lodgepole pine forest cover types.

Table F4a – HRV analysis for species composition on the dry upland forest PVG 

Historical Range Current Amount

Cover Type Percent Acres Percent Acres HRV Interpretation

Western juniper 0-5 0-1786 0 0 At low end of historical range

Ponderosa pine 50-80 787-1259 51 800 At low end historical range

Douglas-fir 5-20 79-315 21 326 Above historical range
Tollgate Fuels Reduction Project FEIS

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Western larch 1-10 16-157 0 0 Below historical range

Broadleaved trees 0-5 0-79 0 0 At low end of historical range

Western white pine 0-5 0-79 0 0 At low end of historical range

Grand fir 1-10 16-157 28 448 Well above the historical range

Table F4b – HRV analysis for species composition on the moist upland forest PVG 

Historical Range Current Amount

Cover Type Percent Acres Percent Acres HRV Interpretation

Ponderosa pine 5-15 1786-5357 5 1665 At low end of historical range

Douglas-fir 15-30 5357-10715 27 9559 Within the historical range

Western larch 10-30 3572-10715 3 1045 Well below the historical range

Broadleaved trees 1-10 357-3572 2 578 Within the historical range

Lodgepole pine 25-45 8929-16072 9 3196 Well below the historical range

Western white pine 0-5 0-1786 0 0 At low end of historical range

Grand fir 15-30 5357-10715 28 9968 Within historical range

Spruce-fir 1-10 357-3572 27 9704 Well above the historical range

Table F4c – HRV analysis for species composition on the cold upland forest PVG 

Historical Range Current Amount

Cover Type Percent Acres Percent Acres HRV Interpretation

Ponderosa pine 0-5 0-14 0 0 This PVG contains too few acres 

(only 277) for an HRV analysis, 

which should not be completed 

for PVGs having less than 1,000 

acres in a planning area. It is 

also not appropriate to add the 

cold PVG acreage to another 

PVG for analysis purposes 

because each PVG represents a 

unique biophysical environment.

Douglas-fir 0-15 0-42 0 0

Western larch 5-15 14-42 42 110

Broadleaved trees 5-15 14-42 0 0

Lodgepole pine 25-45 69-125 26 73

Grand fir 5-15 14-42 0 0

Whitebark pine 0-10 0-28 0 0

Spruce-fir 15-35 42-97 73 204

Sources/Notes for tables F4a to AFc: Current amounts are summarized from the Tollgate planning

area vegetation database (NFS lands only). Historical ranges were adapted by Dave Powell from 

Morgan and Parsons (2001); they were based on multiple 1200-year simulations representing 

landscapes in a dynamic equilibrium with their disturbance regimes and summarized in Martin (2010) 

and Powell (2010b).

Forest Structure

Oliver and Larson (1996) developed a forest structure classification system incorporating four structural 

stages. Oliver and Larson’s (1996) system works well for conifer forests west of the Cascade Mountains, 

but it does not adequately characterize the diverse structural conditions of the interior Pacific Northwest. 

Therefore, the Oliver and Larson (1996) system was expanded to eight classes to include a wider 

spectrum of structural variation (O’Hara et al. 1996). 

Table F5 uses a modified version of the 8-class system developed by O’Hara et al. (1996) to summarize 

the acreages and percentages of forest structural stages for the Tollgate planning area. It shows that the 
Tollgate Fuels Reduction Project FEIS

F-6 

predominant forest structural stage is Old Forest Single Stratum (34% of the Affected Environment, 

OFSS), followed by Old Forest Multi Strata (31%, OFMS), Stand Initiation (21%, SI), Stem Exclusion 

(8%, SE), and Understory Reinitiation (6%, UR). OF structure classes, by definition, contain 10 or more 

live conifer trees per acre greater than or equal to 21” diameter at breast height (DBH).

Table F5 – Existing forest structural stages for the Tollgate planning area 

Code Forest Structural Stage Name Acres

Percent

of Total

Percent

of Forested

SI Stand Initiation 2176 5 6

SE Stem Exclusion 3184 7 8

UR Understory Reinitiation 7746 17 21

OFMS Old Forest Multi Strata 11600 25 31

OFSS Old Forest Single Stratum 12859 28 34

NF Nonforest 8892 19

Sources/Notes: Summarized from the Tollgate vegetation database (NFS lands only). 

Forest structural stages are described in O’Hara et al. (1996). 

HRV Analysis for Forest Structure

An HRV analysis was completed for forest structural stages of the forest vegetation Affected 

Environment. Because forest structure varies by biophysical environment, the HRV analysis was stratified 

by potential vegetation group: dry upland forest and moist upland forest. Note that the cold upland forest 

PVG is not included because it has too few acres (277 acres) for a credible HRV analysis. Forest 

structural stage HRV results are presented in Tables F6a, F6b, and F6c. 

The information presented in Tables F6a, F6b, and F6c suggest that the SE and OFMS structural stages 

are outside of their historical ranges for the dry upland forest PVG, and that all structural stages are 

outside of respective historical ranges for the moist upland forest PVG.

The wildlife standard from the Eastside Screens (Forest Plan amendment #11; USDA Forest Service 

1995) has two possible scenarios to follow as based on HRV results for late-old structural stages (LOS), 

with LOS defined as the old forest multi strata and old forest single stratum structural stages.

The wildlife standard directs that one of two scenarios is to be used: 

1. Scenario A is to be used whenever either one of the LOS stages is below HRV. If both LOS 

stages occur within a single PVG and one is within or above HRV and one below, scenario A is 

to be used. 

2. Scenario B is only to be used when both LOS stages for a particular PVG are within or above 

HRV.

For the dry and moist PVGs, results of the Eastside Screens wildlife standard are presented in the Screens 

Interpretation columns of tables F8a and F8b. 

Table F6a – HRV analysis for forest structural stages on the dry upland forest PVG 

Historical Range Current Amount HRV Screens

Structural Stage Percent Acres Percent Acres Interpretation Interpretation

Stand Initiation 15-25 236-394 17 260 Within HRV

Stem Exclusion 10-20 157-315 <1 7 Below HRV

Understory Reinitiation 5-10 79-157 9 141 Within HRV

Old Forest MS 5-15 79-236 31 487 Above HRV Scenario B
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F-7 

Old Forest SS 40-60 630-944 43 678 Within HRV

Table F6b – HRV analysis for forest structural stages on the moist upland forest PVG 

Historical Range Current Amount HRV Screens

Structural Stage Percent Acres Percent Acres Interpretation Interpretation

Stand Initiation 20-30 7143-10715 5 1894 Below HRV

Stem Exclusion 20-30 7143-10715 9 3177 Below HRV

Understory Reinitiation 10-20 3572-7143 21 7477 Above HRV

Old Forest MS 15-20 5357-7143 31 11095 Above HRV

Scenario B Old Forest SS 10-20 3572-7143 34 12072 Above HRV

Table F6c – HRV analysis for forest structural stages on the cold upland forest PVG 

Historical Range Current Amount HRV Screens

Structural Stage Percent Acres Percent Acres Interpretation Interpretation

Stand Initiation 20-45 55-125 8 22 This PVG contains too few acres (only 

277) for an HRV analysis, which should 

not be completed for PVGs having less 

than 1,000 acres in a planning area. It is 

also not appropriate to add the cold 

PVG acreage to another PVG for 

analysis purposes because each PVG 

represents a unique biophysical 

environment.

Stem Exclusion 10-30 28-83 <1 <1

Understory Reinitiation 10-25 28-69 46 128

Old Forest MS 10-25 28-69 6 18

Old Forest SS 5-20 14-55 39 109

Sources/Notes for tables F8a to F8c: Current amounts are summarized from the Tollgate vegetation database 

(NFS lands only).MS refers to multi strata and SS to single stratum. Upland forest potential vegetation groups 

(PVG) are described in Table F1 and Powell et al. (2007). Historical percentages (H%) were derived from Hall 

(1993), Johnson (1993), and USDA Forest Service (1995), as summarized in Martin (2010) and Powell (2010b). 

Forest structural stages are enumerated in Table F7. For the purposes of an HRV analysis, the bare ground 

structural stage is combined with the stand initiation stage.

Tree Density

Suggested stocking guidelines (Cochran et al. 1994, Powell 1999) were used to analyze existing tree 

density levels for the Tollgate planning area. By using the stocking guidelines in conjunction with PVGs, 

it was possible to estimate how much forest acreage is currently overstocked (Table F12); the tree density 

analysis protocol is described in Powell (2009c). 

Table 11 summarizes existing tree density classes for the forest vegetation Affected Environment. It 

shows that the predominant tree density class is High (76%), followed Moderate (15%) and then by Low 

(9%). 

Table F7 – Existing tree density for the Tollgate planning area 

Tree Density Category Acres

Percent

of Total

Percent

of Forested

Low 3356 7 9

Moderate 5548 12 15

High 28662 62 76
Tollgate Fuels Reduction Project FEIS

F-8 

None (nonforest polygons) 8798 19

Sources/Notes: Summarized from the Tollgate vegetation 

database (NFS lands only). Queries for assigning polygons to the 

tree density categories are provided in Powell (2009c).

HRV Analysis for Tree Density

An HRV analysis was completed for tree density classes of the forest vegetation Affected Environment. 

Because tree density varies by biophysical environment, the HRV analysis was stratified by potential 

vegetation group: dry upland forest and moist upland forest. Note that the cold upland forest PVG is not 

included because it has too few acres (277 acres) for a credible HRV analysis. Tree density HRV results 

are presented in Tables F8a, F8b, and F8c. 

The information presented in Tables F8a, F8b, and F8c suggest that the dry upland forest PVG portion of 

the forest vegetation Affected Environment has too little of the Low density class and too much of the 

High density condition. For the Moist upland forest portion of the Affected Environment, all three density 

classes are outside their historical ranges of variability. 

Table F8a – HRV analysis for tree density on the dry upland forest PVG 

Historical Range Current Amount

Tree Density Class Percent Acres Percent Acres HRV Interpretation

Low (<45% CC) 40-85 630-1338 5 83 Well below historical range

Moderate (45-55%) 15-30 236-472 30 466 At upper end of historical range

High (>55% CC) 5-15 79-236 65 1025 Well above historical range

Table F8b – HRV analysis for tree density on the moist upland forest PVG 

Historical Range Current Amount

Tree Density Class Percent Acres Percent Acres HRV Interpretation

Low (<65% CC) 20-40 7143-14286 9 3221 Below historical range

Moderate (65-75%) 25-60 8929-21429 14 5077 Below historical range

High (>75% CC) 15-30 5357-10715 77 27417 Well above historical range

Table F8c – HRV analysis for tree density on the cold upland forest PVG 

Historical Range Current Amount

Tree Density Class Percent Acres Percent Acres HRV Interpretation

Low (<55% CC) 15-30 40-80 19 52

No interpretation because this 

PVG contains too few acres. Moderate (55-65%) 20-40 50-100 2 5

High (>65% CC) 25-60 60-160 79 220

Sources/Notes for tables F13a to F13c: Current amounts are derived from the Tollgate vegetation 

database (NFS lands only). Upland forest potential vegetation groups (PVG) are described in Table 

F1 and Powell et al. (2007). Historical ranges were taken from Schmitt and Powell (2008).
Tollgate Fuels Reduction Project FEIS

F-9 

In March 1993, the Natural Resources Defense Council (NRDC) petitioned the U.S. Forest Service 

(Pacific Northwest Region) to halt all timber harvest activity in old growth forest occurring on national 

forest lands located east of the Cascade Mountain crest in Oregon and Washington (this geographical area 

is also known as the Eastside).

A month later in April 1993, a group of university and U.S. Forest Service research scientists released an 

“Eastside Forest Ecosystem Health Assessment” in draft form; this assessment is known as the “Everett 

Report” because it was directed by Dr. Richard Everett, a scientist located at the Wenatchee Forestry 

Sciences Laboratory (Everett et al. 1994).

In response to both the NRDC petition and the Everett report, the Pacific Northwest Region of the U.S. 

Forest Service issued interim direction in August 1993 requiring that timber sales prepared and offered by 

Eastside national forests be evaluated to determine their potential impact on riparian habitat, historical 

vegetation patterns, and wildlife fragmentation and connectivity. 

This interim direction, known as the Eastside Screens, was used to amend Eastside forest plans when 

Regional Forester John Lowe signed a Decision Notice on May 20, 1994 to implement Regional 

Forester’s Forest Plan Amendment #1 (USDA Forest Service 1994). Regional Forester’s Forest Plan 

Amendment #1 is amendment #8 to the Umatilla National Forest Land and Resource Management Plan.

A slightly revised version of the Eastside Screens was issued as Regional Forester’s Forest Plan 

Amendment #2 when Regional Forester John Lowe signed a Decision Notice on June 12, 1995 (USDA 

Forest Service 1995). Regional Forester’s Forest Plan Amendment #2 is amendment #11 to the Umatilla 

National Forest Land and Resource Management Plan.

The Eastside Screens consist of six items: three general items (items 1 to 3), a riparian standard (item 4), 

an ecosystem standard (item 5), and a wildlife standard (item 6). This section describes how proposed 

silvicultural activities for the Tollgate Vegetation Management Project would comply with the Eastside 

Screens.

1. General Standards (items 1-3 in FP Amendment #11) 

Item 1 defines the scope of the Eastside Screens to be timber sales only.

Finding: The Proposed Action includes intermediate harvest silvicultural activities. In some portions of 

the planning area, these activities would be implemented using a commercial timber sale contract. Since 

item 1 defines the scope of the Eastside Screens to be timber sales only, and because a timber sale 

contract would be used to implement some of the silvicultural activities, this means that the Tollgate 

Vegetation Management Project must comply with the Eastside Screens.

Item 2 exempts personal-use firewood sales, post and pole sales, sales to protect health and safety, and 

sales within recreation special use areas from the amendment.

Finding: It is not anticipated that personal-use firewood sales, post and pole sales, sales to protect health 

and safety, or sales within recreation special use areas would be used to implement any of the thinning or 

regeneration cutting silvicultural activities, so item 2 does not apply to the Tollgate Vegetation 

Management Project.

Item 3 exempts five categories of timber sales from the ecosystem standard (but not from the riparian and 

wildlife standards):

• Precommercial thinning;

• Material sold as fiber;

• Dead material less than 7 inches in diameter, with incidental green volume;
Tollgate Fuels Reduction Project FEIS

F-10

• Salvage sales located outside mapped old growth, with incidental green volume; and 

• Commercial thinning and understory removal sales located outside mapped old growth. 

Finding: Both of the intermediate silvicultural activities (improvement cutting and low thinning) qualify 

for an exemption from the ecosystem standard because they are “commercial thinning and understory 

removal sales located outside mapped old growth” (the fifth category of timber sales included in item 3). 

“Mapped old growth” is defined to include both of the Forest Plan allocations for old growth (C1 and 

C2) and as depicted on published maps distributed with the Forest Plan (USDA Forest Service 1990), as 

amended. This definition for mapped old growth follows written guidance and direction from the Pacific 

Northwest Region “Eastside Screens Oversight Team” (Lowe 1995). 

However, direction from the Pacific Northwest Regional Office states that it is not mandatory to exempt 

“commercial thinning and understory removal sales” from the ecosystem standard and it further notes that 

in some circumstances, it may be advantageous to project viability to not exempt them (Lowe 1995). 

The intermediate silvicultural activities described in the Proposed Action (improvement cutting, low 

thinning) are contained in the land base used for the historical range of variability (HRV) analysis for the 

Tollgate Vegetation Management Project, so there is no need to exempt them from the ecosystem 

standard, and an exemption is not claimed. 

2. Riparian Standard (item 4 in Forest Plan Amendment #11) 

Item 4 of the Eastside Screens directs that timber sales (green and salvage) will not be planned or located 

in riparian areas.

Umatilla National Forest policy is that amendment #10 (USDA Forest Service and USDI Bureau of Land 

Management 1994) to the Land and Resource Management Plan will be applied in lieu of the riparian 

standard from the Eastside Screens.

Forest Plan amendment #10, commonly referred to as PACFISH, is interim direction designed to “arrest 

the degradation and begin the restoration of aquatic habitat and riparian areas on lands administered by 

the Forest Service and BLM; it applies to watersheds outside the range of the northern spotted owl that 

provide habitat for Pacific salmon, steelhead, and sea-run cutthroat trout.” This policy means that 

applying PACFISH also meets the Eastside Screens riparian standard. 

PACFISH uses a buffer concept to establish riparian habitat conservation areas (RHCA) along both sides 

of streams, rivers, lakes and other wetlands. RHCA widths extend from the edge of the active stream 

channel and they vary with stream class and whether a stream is fish bearing or not. RHCAs can be 

established using specified feet of slope distance (such as 300 feet on either side of perennial, fish-bearing 

streams) or in numbers of “site potential tree heights” (such as 2 site-potential tree heights for perennial,

fish-bearing streams). The interim RHCA widths established by the PACFISH environmental assessment 

could be adjusted during watershed analysis or after site-specific analysis presenting a rationale for 

RHCA modifications.

Timber harvest activities are prohibited by the PACFISH amendment except in the following situations 

(see timber management standards, page C-9, in USDA Forest Service and USDI Bureau of Land 

Management 1994): 

1. For catastrophic events such as fire, flooding, volcanic, wind or insect damage (when salvage harvest 

and fuelwood cutting is then allowed if compatible with riparian management objectives); and

2. When applying silvicultural practices to control stocking, reestablish and culture stands, and acquire 

desired vegetation characteristics in a manner that also meets riparian management objectives.
Tollgate Fuels Reduction Project FEIS

F-11

Finding: None of the proposed silvicultural activities will occur in any of the riparian habitat 

conservation areas established by PACFISH (FP amendment #10) not covered by exception authorities 

under item #2 above, and/or a Forest Plan amendment. The project will include a site specific Forest Plan 

amendment for the fuels treatments within RHCA of units 19, 38, 66, and 75 (unit 19 only, under 

Alternative C), described in Appendix B. The amendment will modify applicable PACFISH standards 

and guides regarding treatment within RHCAs. The amendment is site specific to the Tollgate Fuels 

Reduction project and will remain valid only during implementation of this project. The intention of the 

treatment is to control stocking by reducing stand density to within management zones recommended by 

Powell (1999, 2009c), and would result in desirable vegetation characteristics because post-treatment 

stands would be relatively resistant to passive or active crown fire, as described in the fire and fuels 

specialist report in the Tollgate Fuels Reduction project record. The desired vegetation characteristics 

would also meet riparian management objectives by reducing future wildfire intensity and severity 

(references), maintaining high levels of canopy cover and stream shade, and maintain moderate to high 

levels of woody structure to maintain hydrologic form and function (refer to the hydrology and fisheries 

reports in the Tollgate Fuels Reduction project record for a description of sufficient riparian canopy cover 

and woody debris/structure) 

3. Ecosystem Standard (item 5 in Forest Plan Amendment #11) 

The ecosystem standard requires a landscape-level assessment of the historical range of variability (HRV) 

for structural stages, including a comparison of existing structural stage amounts with their historical 

ranges.

Item 5 (a) requires that the Forest Service “characterize the proposed timber sale and its associated 

watershed for patterns of stand structure by biophysical environment and compare to the Historic Range 

of Variability (HRV).”

Item 5 (c) requires that the Forest Service “characterize the difference in percent composition of structural 

stages between HRV and current conditions.” 

Finding: Structural stages for the planning area were determined and then compared with their historical 

ranges (e.g., HRV) by biophysical environment. Results of the analysis results are included in Tables 10 

and A6a, A6b, and A6c. 

Item 5(b) requires that the Forest Service (1) “describe the dominant historical disturbance regime, i.e. the 

disturbance types and their magnitudes and frequencies. (2) Characterize the landscape pattern and 

abundance of structural stages maintained by the disturbance regime. Consider biophysical environmental 

setting across the landscape to make this determination. (3) Describe spatial pattern and distribution of 

structural stages under the HRV disturbance regime, and (4) Map the current pattern of structural stages 

and calculate their abundance by biophysical environmental setting” (USDA Forest Service 1995). 

Finding: The analyses and map required by item 5(b) above are included within this analysis as follows:

• 5(b)(1): Table F2 and associated references

• 5(b)(2) and (3): Tables F6a-c and associated references

• 5(b)(4): Figure F6 below, Tables F6a-c and associated references

Item 5 (c) also requires that the Forest Service “identify structural conditions and biophysical 

environment combinations that are outside HRV conditions to determine potential treatment areas” 

(USDA Forest Service 1995).

Finding: Results from the structural stage HRV analysis were used when determining potential treatment 

areas for the Tollgate Vegetation Management Project. However, HRV analyses were also completed for 

species composition and tree density in addition to structural stages, so potential treatment areas may 
Tollgate Fuels Reduction Project FEIS

F-12

reflect HRV results for more than one of these indicators: species composition, structural stage, and tree 

density. 

4. Wildlife Standard (item 6 in Forest Plan Amendment #11) 

Item 6 (a) states that the wildlife standard has two possible scenarios to follow as based on HRV results 

for late-old structural stages (LOS), and it defines LOS to be the “multi-stratum with large trees” and 

“single stratum with large trees” structural stages.

Item 6 (b) directs that: 

1. Scenario A (item 6 d) is to be used whenever either one of the LOS stages is below HRV. If both 

LOS stages occur within a single biophysical environment and one is above HRV and one below, 

scenario A is to be used.

2. Scenario B (item 6 e) is to be used only when both LOS stages for a particular biophysical 

environment are within or above HRV. 

Finding: Tables F6a-b in Appendix A show that both LOS stages are within or above HRV for both 

dry and the moist upland forest biophysical environments. According to item 6 (b) of the wildlife 

standard and the HRV results presented in Appendix Tables F6a-b, this means that forest vegetation 

silvicultural activities for the Tollgate Vegetation Management Project must comply with

Scenario B for the Dry and Moist Upland Forest biophysical environments. 

When performing analysis of vegetation Historic Ranges of Variability (HRVs), existing vegetation was 

stratified into PVGs (Martin 2010). Since the cold upland forest PVG included less than 1,000 acres 

within the Tollgate planning area, it was largely excluded during HRV analysis because a full 

complement of cover types, structural stages, or tree density classes would not be expected for such a 

small amount of acreage (Martin 2010 and Powell 2010b). 

 Item 6(e), which is scenario B of the wildlife standard, has the four requirements described below. Since 

the Dry and Moist Upland Forest biophysical environments must comply with Scenario B, all findings 

will be reported in the context of these biophysical environments. 

1. Item 1 of scenario B establishes a priority for timber harvest activities, ranging from non-LOS 

stands (first priority) to smaller, isolated LOS stands (second priority) and finally to the interior of 

large LOS stands as a third priority (large LOS is defined as stands occupying 100 acres or more). 

Regeneration and group selection treatments are not allowed in the interior of large LOS stands 

(item 6(e)(1)(c)).
Tollgate Fuels Reduction Project FEIS

F-13

5. Figure F1 – Map depicting the current pattern of structural stages for the entire Tollgate 

analysis area (app. 37,566 acres). 1

 

Finding: The underlying assumption of this item is that if timber sale activities were allowed to 

occur within LOS stands, they could cause significant reduction in LOS suitability, particularly if 

the silvicultural activities being applied involved regeneration cutting methods; however, all 

silvicultural activity proposed for LOS stands involves intermediate (non-regeneration) 

silvicultural activities that would maintain LOS characteristics after treatment. Since intermediate 

harvest is the only harvest activity proposed for LOS stands, regardless of which biophysical 

environment activities occur in or which of the wildlife screen scenarios they fall under, there is 

no regeneration cutting proposed (including group selection) for any portion of the LOS stands, 

including their interiors. 

2. Item 2 of scenario B requires that connectivity be maintained between LOS stands and Forest 

Plan-designated old-growth areas, and that fragmentation of existing LOS stands be avoided by 

 

1 Structural stage names in the map legend correspond to the Eastside Screens names (see Table 9), and are 

synonymous with the old forest names or acronyms used for structural stages elsewhere in this report.
Tollgate Fuels Reduction Project FEIS

F-14

limiting silvicultural treatments to non-regeneration and single-tree selection prescriptions (this 

requirement is derived from item 6(d)(3) of scenario A).

Finding: Because only intermediate thinning treatments are included under Alternatives B and C 

(see Description of Alternatives section), connectivity would be maintained between LOS stands 

and Forest Plan-designated old-growth areas, and that fragmentation of existing LOS stands 

would be avoided by limiting silvicultural treatments to non-regeneration and single-tree 

selection prescriptions.

3. Item 3 of scenario B is a non-fragmentation standard that limits silvicultural treatments within the 

interior of large LOS stands to “non-fragmenting prescriptions such as thinning, single-tree 

selection (UEAM), salvage, understory removal, and other non-regeneration activities.” Group 

selection is allowed when openings mimic the natural forest pattern and do not exceed 1⁄2 acre in 

size.

Finding: As described above for item 1, all silvicultural activity proposed for LOS stands 

involves improvement cutting, an intermediate silvicultural activity (and a “non-fragmenting 

prescription”) that would maintain LOS characteristics after treatment. Since improvement 

cutting is the only activity proposed for LOS stands, regardless of the biophysical environment in 

which it occurs or which of the wildlife screen scenarios under which it falls, there are no 

proposals to use group selection or other regeneration cutting methods for LOS stands. 

4. Item 4 of scenario B requires that the snag, green-tree replacement, and down log standards from 

scenario A be followed (this is item 6(d)(4)(a) of scenario A), and that the goshawk standards 

from scenario A also be met (this is item 6(d)(4)(b) of scenario A), although item 4 does modify 

certain aspects of the post-fledging goshawk requirement from scenario A. 

Finding: The project’s design features and management requirements stipulate that snags and 

replacement tree numbers will meet or exceed Forest Plan standards. For specific details about 

the snags, replacement trees, and down logs items, see the wildlife specialist report. According to 

the wildlife specialist report, there are no known goshawk nests in the Tollgate planning area. If a 

nest is discovered during project preparation or implementation, most-suitable nesting habitat and 

post-fledging area standards from portion 6(d) of the Wildlife Standard would be applied at that 

time.
APPENDIX G 

DECEMBER 2012 DEIS

RESPONSE TO PUBLIC COMMENTS 

 

Tollgate Fuels Reduction Project FEIS

G-1

INTRODUCTION

A 45-day comment period for Tollgate Fuels Reduction Project Draft Environmental Impact Statement 

(DEIS) was provided for interested and affected publics, including appropriate local, state, and federal 

government agencies, and Tribes. Letters requesting comments were sent to the mailing list of interested 

parties maintained at the Umatilla National Forest Supervisor’s Office on December 17, 2012. They 

included federal, state and local agencies, Confederated Tribes of the Umatilla Indian Reservation, Nez 

Perce Indian Tribe, various environmental organizations, and interested individuals (see project file for 

mailing list). 

A notice of availability (NOA) was published in the Federal Register on December 31, 2012. A legal 

notice was also published in the East Oregonian (newspaper of record) requesting public comment on 

December 28, 2012. The 45-day comment period was scheduled to conclude on February 13, 2013. 

During the comment period, an error in the email address for the submission of electronic comments was 

identified in the December 28, 2012 legal notice (published in the East Oregonian). This error may have 

resulted in rejection notices for members of the public that attempted to submit comments to this address. 

In order to correct this error a second notice appeared in the Federal Register on February 22, 2013, 

announcing that the comment period had been extended to March 15, 2013. In addition to the notice in the 

federal register, a second legal notice was published in the East Oregonian (February 20, 2013) and letters 

(dated February 15, 2013) were sent to the project mailing list, notifying the public of the extended 

comment period. 

Shortly after mailing of the letters, an error with the email address was identified in the second legal 

notice and letters. Once this error was identified, a third legal notice was published in the East Oregonian 

(dated February 27, 2013) which provided the correct email address for submission of electronic 

comments and reaffirmed that the comment period had been extended to March 15th. In addition to the 

above described legal notice, letters (dated February 25, 2013) were mailed to the project mailing list 

identifying this error and providing corrected information. No additional Federal Register notice was 

posted, because the comment period’s duration had not changed since the February 22nd publication. 

The Forest Service received comments from different sectors of the public, with a range of concerns and 

comments. The responsible official will be considering the comments made on the DEIS in the decisionmaking process.

The Forest Service received eighteen (18) responses during the comment period. Some responses were 

received electronically, some were sent by U. S. Mail, and others were faxed. All correspondence was 

reviewed and our responses to these comments are located on the following pages. All correspondence 

received is kept in the project file and is available for review at the district office in Walla Walla, 

Washington. 

The following table is a summary of letters received. Comments are listed in chronological order. 
Tollgate Fuels Reduction Project FEIS

G-2

Letters Received During the Comment Period for Tollgate DEIS

Letter Identification 

Number and

Date Received

Author(s)

Individual,

Organization or Agency

Letter #1

December 21, 2012 Bernard Chapman Individual

Letter #2

December 22, 2012 Rod and Marcella Morrow Individual

Letter #3

December 26, 2012 Richard Artley Individual

Letter #4

December 31, 2012 Norm Kralman Individual

Letter #5

January 2, 2013 Jean Public Individual

Letter #6

February 11, 2013 Allison O’Brien U. S. Department of Interior

Letter #7

February 11, 2013 Chris Howard Blue Mountain Audubon Society

Letter #8

February 12, 2013 Lindsay Warness Boise Cascade 

Letter #9

February 12, 2013 Doug Heiken Oregon Wild

Letter #10

February 12, 2013 Christine B. Reichgott, Mgr. U. S. EPA, Region 10, Seattle, WA

Letter # 11

February 13, 2013 Irene Jerome American Forest Resource Council 

Letter #12

February 13, 2013 Veronica Warnock Hells Canyon Preservation Council

Letter #13

February 13, 2013 Karen Coulter Blue Mountains Biodiversity Project

Letter #14

February 15, 2013 Thomas Insko Individual

Letter #15

February 21, 2013 Richard Artley Individual

Letter #16

February 22, 2013

Mark Davidson

Steve McClure

William Rosholt

Union County Board of 

Commissioners

Letter #17

February 25, 2013 Jean Public Individual

Letter #18

March 11, 2013 Rick Isaacson Individual
Tollgate Fuels Reduction Project FEIS

G-3

Comments and Forest Service Response to 

Comments

Tollgate DEIS - 2012 

Letter #1

Bernard Chapman (BC)

Comment 

Number Comment and Response

BC-1

p-1 

Comment:

Alternative B is the best way to go. There is so many little areas that need clean up 

the wind damage of 20 years ago is still there in many places

Response:

Your comment has been noted.

BC-2

p-1 

Comment:

This project is needed and would benefit the area in many ways 

Response:

Your comment has been noted.

Letter #2 

Rod & Marcella Morrow (RMM)

Comment 

Number Comment and Response

RMM-1

p-1 

Comment: 

Alternative B or Alternative C if necessary would be productive choices. Over the 

years due to wind and insect damage it would be nice to see some of the trees 

removed and debris cleaned up. It would be good for the health of the forest plus 

make the vista of the Blue Mountains more attractive.

Response:

Your comment has been noted.

RMM-2 

p-1 

Comment: 

One aspect that was not real clear was which roads would be used for this project. 

Since some of the treatment areas are near or abutting where our property is (section 

36 Union county) we assume road US 64 030 (our access road to our property) 
Tollgate Fuels Reduction Project FEIS

G-4

Letter #2 

Rod & Marcella Morrow (RMM)

Comment 

Number Comment and Response

would be used and that it would be left in good condition. It also would be nice to 

know when this is going to happen so that we can plan accordingly. 

Response:

As identified in Appendix C of this FEIS, approximately 1.6 miles of Forest 

Road 6400030 would be used during the implementation of this project. All 

roads used for harvest activities will receive the appropriate maintenance 

activities from those identified in Chapter 2. Project activities are anticipated 

to begin implementation sometime between late Fall 2013 or Spring 2014. Once 

begun project activities will likely take five (5) or more years to complete. 

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

RA2012-1

p-2 

Comment: 

Please remember, by definition viewpoints are opinions. 

 

This member of the public has provided the electronic links to the source 

documents for each opposing view. 

Response:

Your comment has been noted. 

RA2012-2 

p-2 

Comment: 

Please include the source documents for the opposing views contained in the 

attachments to these comments in the Bibliography section of the final DEIS. 

When describing the environmental effects of the timber sale activities to the 

countless natural resources in the project area please cite the resource damage 

described in the source documents contained in the attachments. 

Response:

Opposing views, submitted by commenters, were reviewed by the IDT and 

their conclusions concerning the relevance of submitted articles and/or citation

can be found in the Tollgate Fuels Reduction Project record. See document 
Tollgate Fuels Reduction Project FEIS

G-5

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

entitled: “Tollgate Fuels Reduction Project Review of Citations Submitted during 

Comment Period of DEIS” 

RA2012-3

p-2 

Comment: 

It violates the law to give the public a skewed (one sided) description of the 

environmental effects of a proposed project as you have done in this DEIS. I 

suggest you become familiar with the legal definition of “hard look.” You 

should also read the Administrative Procedures Act to determine how your 

actions that reject best science. One must know a United States law to comply 

with the law.

Response:

We disagree. Please see Chapter 4 for the disclosure of environmental effects 

associated with the alternatives analyzed in detail. 

RA2012-4

P-3 

Comment: 

I have checked each of the 146 documents listed below that appear in the 

Bibliography section of this DEIS. I examined some documents that were 

located in the library at the Nez Perce National Forest Supervisor’s Office. The 

rest I examined online to determine if they had been peer reviewed using:

 

The following link explains the peer review process for government documents: 

http://en.wikipedia.org/wiki/U.S._Government_peer_review_policies 

 

The following link explains how to tell if a book/article has been peer reviewed:

http://ask.metafilter.com/75419/how-do-I-know-if-a-bookarticle-ispeerreviewed 

 

The following link explains the peer review verification procedures: 

http://en.wikiversity.org/wiki/Wikiversity:Peer_review_verification 

 

The following link provides the definition of a peer review: 

http://www.ehow.com/about_4702830_peer-review-definition.html 

 

Using this information I have determined that none of the following references 

cited have been peer reviewed. See Mr. Artley’s list on pages 3-13.

Response:

The references were determined to represent the best available science for 

this project by the members of the IDT based on their professional 
Tollgate Fuels Reduction Project FEIS

G-6

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

judgment and experience based on their knowledge of the local lands under 

consideration in the Tollgate Fuels Reduction Project. 

RA2012-5

p-13 

Comment: 

Literature authored by employees of the Federal Government must be peerreviewed to be valid. See USFS document review direction below. 

 

“US Forest Service R&D provides research information to the public that is 

reliable, accurate, and presented clearly. We require all scientific manuscripts to 

be reviewed by qualified personnel, including written reviews by at least two 

peers, competent in the subject matter and with demonstrable objectivity. FS 

R&D scientists are further required to incorporate review comments, and when 

appropriate obtain statistical review before submitting a manuscript to the 

publications control officer. A set of standard guidelines is made available to 

reviewers containing review criteria including, but not limited to factual 

accuracy, quality of information, clarity, consistency, references, effectiveness, 

and overall merit. For manuscripts containing influential information and highly 

influential assessments, we adhere to additional applicable requirements 

embodied in USDA Research Guidelines/Peer Review, based on OMB’s 

Information Quality Bulletin for Peer Review.” 

Source: http://www.fs.fed.us/qoi/peerreview.shtml 

Response:

Your comment has been noted.

RA2012-6

p-13 

Comment: 

None of the 146 documents that are identified above must appear in or be cited 

in the final EIS because none have been peer reviewed. Also please delete the 

text the body of the final EA EIS that cites the removed documents above. 

Response:

We disagree. Based on the professional judgment and experience of the IDT 

members the literature identified represents the best available science.

RA2012-7

p-14 

Comment: 

The Terms Chosen by the Responsible Official to Describe the Project in this 
Tollgate Fuels Reduction Project FEIS

G-7

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

DEIS are Euphemisms Intended to Hide the Real Actions from the Public that 

are being Proposed. 

Response:

We disagree. The proposed actions are described in the Chapters 1 and 2 

and the effects associated with those actions are disclosed in Chapter 4. A 

glossary of commonly used terms is also provided within the document. 

Please see the Glossary.

RA2012-8

p-14 

Comment: 

The vast majority of the public does not want their national forests logged for 

any reason. The USFS has predicted a “timber famine” for decades. There is no 

timber famine nor is there a shortage of timber being harvested in the United 

States to meet domestic needs. Indeed, some of the timber cut from private land 

is being exported. If this timber were needed in the United States it would be 

purchased by domestic corporations. There is no reason to defy the will of the 

public by logging their land. 

Response:

Please refer to the Purpose and Need in Chapter 1. To summarize the objective 

of this project is to reduce fuels within the Tollgate Wildland Urban Interface 

(WUI) in order to provide protection to the numerous private residences that 

occur there as well as provide protection to local and regional infrastructure as 

well as provide for safer fire suppression efforts should a wildfire occur. 

RA2012-9

p-14 

Comment:

The public understands the term logging. Most of them do not equate 

“mechanical treatment” with logging.

 

In the final EIS please either:

1) Define “mechanical treatment” as logging in the Glossary, or 

2) Replace the term “mechanical treatment” with logging everywhere in the 

NEPA document. 

Response:

The term ‘mechanical treatments’ is defined in the Glossary on page 11. 
Tollgate Fuels Reduction Project FEIS

G-8

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

RA2012-10

p-14 

Comment: 

 

When Congress Promulgated the NFMA they did not Intend for Forest Plan 

Direction to be Violated on a One Time Basis by Amending the Forest Plan. 

This is especially true of a lunatic USFS line-officer who does so in order to 

make it easier to sell timber.

Response:

Your comment has been noted. The procedures for amending the Forest Plan 

(found at FSM 1926.5) were followed. The Responsible Official will decide 

whether or not to amend the Forest Plan based, in part, on the disclosures 

contained in this FEIS.

RA2012-11

p-16 

Comment: 

The Umatilla National Forest must not propose to use or use any herbicides 

containing the chemical glyphosate. Exposure to the chemical causes immediate 

death to aquatic species. Exposure to the chemical causes cancer in mammals 

(including humans) and birds several years after exposure. 

Response:

Herbicide use is not proposed by the Tollgate Fuels Reduction Project and thus 

is beyond the scope of this decision. Use of herbicides is authorized by the 

Umatilla Invasive Plant EIS and ROD (July 2010). 

RA2012-12

p-23 

Comment: 

I will expect the fact that bee colony collapse disorder is caused by herbicides 

applied in the project area to be disclosed and discussed in Chapter 3 of the final 

EIS. I will also expect the ROD to specifically state that no chemicals that might 

cause CCD will be used for any reason. 

Response:

Please see the response to RA2012-11. As such there will be no discussion of 

any possible effects associated with herbicides. 

RA2012-13

p-24 

Comment: 

Supervisor Lawrence the USFS claims glyphosate containing herbicides 

(specifically Roundup®) are safe. This 2002 article in a Monsanto authored 
Tollgate Fuels Reduction Project FEIS

G-9

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

article called “Backgrounder – Glyphosate and Wildlife” (link below) claims 

glyphosate-containing herbicides will not harm: wild mammals, birds, aquatic 

animals, amphibians, insects and other terrestrial arthropods, earthworms and 

soil microorganisms. If this were true there would not be hundreds of 

independent scientists’ research showing otherwise. 

Response:

See response to RA2012-11.

RA2012-14

p-24 

Comment: 

Supervisor Lawrence if you still insist on killing noxious weeds with herbicides 

containing glyphosate rather than the alternatives, the people paid to apply the 

chemical should be wearing complete hazmat suits and should be given a copy 

of Attachment #9a before they are allowed t apply the herbicide. Any 

responsible employer would take measures to protect their employees. 

Response:

See response to RA2012-11.

RA2012-15

p-24 

Comment: 

Supervisor Lawrence many plants in the forest have flowers that must be 

pollinated by bees to produce seeds and regenerate. When you kill bees by 

applying herbicides you interrupt and eradicate this natural process. Clearly, 

this is a significant adverse impact on the human environment. Thus, a EIS 

must be completed.

Response:

See response to RA2012-11.

RA2012-16

p-26 

Comment: 

If the Responsible Official really wants to eliminate the sediment originating from 

temporary roads he will obliterate all temporary roads after use and say this will be 

done in the DEIS. 

Response:

Your comment has been noted. 
Tollgate Fuels Reduction Project FEIS

G-10

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

RA2012-17

p-26 

Comment: 

An obliterated road contains no running surface, because the natural sideslope 

that existed before the road was constructed is reestablished. Not obliterating a 

road because the line-officer will use it again to haul logs from the area means 

the road is not temporary. Therefore the road should be constructed to system 

road standards or not at all. 

 

Decommissioning these roads will not remove the running surface, therefore 

sediment will be generated during precipitation events, find its way to streams 

and harm the aquatic resources ... for decades until the next timber sale. 

 

You have conveniently not included the term “obliteration” in the Glossary. 

Keeping the public in the dark is easier isn’t it? 

 

This is precisely how private industrial tree farm managers treat their land. 

Response:

Road obliteration is not proposed for this project and thus is not defined in the 

Glossary. 

RA2012-18

p-26 

Comment: 

Since the 9th Circuit opinion requires a NPDES permit for temporary roads, 

Responsible Official must obtain a NPDES permit from EPA before any activity 

may commence on this timber sale, the Decision Document must state that the 

permit will be obtained immediately after the decision document has been 

signed. 

Response:

On March 20, 2013 the U.S. Supreme Court reversed the 9th Circuit’s decision 

on roads associated with timber harvest on the basis of EPA’s interpretation of 

the stormwater rule. Logging roads are therefore not considered to produce 

pollutant discharge that require point-source discharge permits because they 

are not associated with categories of industrial activities directly related to 

industrial plants. 

RA2012-19

p-27

Comment: 
Tollgate Fuels Reduction Project FEIS

G-11

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

Supervisor Lawrence, you have not chosen to analyze a Dr. Cohen alternative in 

detail. A Cohen alternative would propose to spend earmarked fire funding to: 

 

· educate the public with by providing each homeowner in the WUI written 

material that summarizes Dr. Cohen’s findings. 

 

· educate the public using USFS organized public meetings to answer 

questions about the types of fine fuels that Dr. Cohen recommends should be 

removed. 

 

· and most importantly offer USFS labor to help elderly and disabled 

people living in the WUI (with their written permission) to remove the fine fuels 

near their home as Dr. Cohen suggests. 

Response:

An alternative, similar to the one described in the comment above, was 

considered but not analyzed in detail. As such, this alternative was not 

developed for the same reasons identified in Chapter 2 under the heading 

“Alternatives Considered, but Eliminated from Detailed Study”- see number 

#2. 

RA2012-20

p-28 

Comment: 

Supervisor Lawrence, your DEIS doesn’t even mention the importance of 

removing fine fuels near a home at risk. 

Response:

The Tollgate project is focused on increasing wildfire defensibility of National 

Forest System lands within the Tollgate WUI as outlined in the Umatilla 

County CWPP. While FIREWISE concepts are important for private 

landowners to incorporate, such activities lie outside of the stated purpose and 

need of this project. 

Additionally, investigations into home losses clearly show that most structures 

in the wildland-urban interface are ignited by embers, not radiant heating. In 

essence the structure is already burning before the radiant heat from the main 

fire has an “opportunity” to ignite it. Burning structures are typically what 

ignite other structures through spotting or, if close enough, radiant heating. 

Spotting distances of typical torching events are 1⁄2 mile or less; but distance 

and number of embers increases as the extent of active crown fire increases. 

Plume-dominated crown fires and major crowning runs typically produce 

profuse spotting with most spotting up to 1 mile; however plume-dominated 
Tollgate Fuels Reduction Project FEIS

G-12

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

fires can readily spot up to 2 miles.

Consequently, the Tollgate project seeks to minimize the potential for the 

initiation and propagation of crown fire and thus provide protection for 

identified “Values at Risk” experience less exposure to the conditions noted 

above.

RA2012-21

p-28 

Comment: 

Supervisor Lawrence, your DEIS doesn’t even mention actions which best 

reduce the home ignitability. Certainly logging merchantable trees miles away 

from a home at risk is not as effective as reducing fine, flash fuels near the 

home. Keep in mind Dr. Cohen repeatedly states fuels reduction logging does 

not reduce fire intensity or rate of spread. 

Response:

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To achieve that desired condition, reductions in 

ladder fuels and canopy bulk density need to occur, and can only be 

accomplished through removal of selected crowns in selected areas.

Reduction in active crown fire reduces spotting potential, and the adverse fire 

effects associated therein. Moreover, since we cannot effectively fight crown 

fires, we need to create fuel conditions that will cause the fire to remain on, or 

drop to the surface, preferably at some distance from Values at Risk. This 

allows for contingency actions in the event the fire operations. Firefighters 

need to have fuel conditions that allow for rapid and successful burnout 

operations that will deprive the wildfire of energy needed to support crowning 

and extensive torching or that provide for more effective use of retardant, 

foam, or water. The Tollgate project seeks to create these conditions in 

strategic areas across the analysis area, increasing the defensibility of Values at 

Risk.

RA2012-22

p-28 

Comment: 

Supervisor Lawrence, your DEIS doesn’t mention “wildland fuel characteristics 

beyond the home site have little if any significance to WUI home fire losses.” If 

protecting the public had meant as much to you as volume accumulation this 

fact would have been emphasized in your DEIS. 
Tollgate Fuels Reduction Project FEIS

G-13

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

Response:

As stated on pg. 1-3 of the FEIS, the Tollgate project is consistent with the 

goals and objectives of the Umatilla County CWPP which calls for the Tollgate 

WUI to have fuel profiles with a low likelihood of active crown fire which 

allows for direct wildfire control and suppression, ingress and egress of the 

public and fire personnel, and protection of the Values at Risk identified in the 

DEIS.

Moreover, John Cohen’s work (cited in the comment) and the treatment 

distances he recommends are based solely on ignition from radiant heating. 

Cohen’s own investigations in home losses, however, clearly show that most 

structures in the wildland-urban interface are ignited by embers, not radiant 

heating. In essence the structure is already burning before the radiant heat 

from the main fire has an “opportunity” to ignite it. In addition, burning 

structures are typically what ignite other structures through spotting or, if 

close enough, radiant heating. Spotting distances of typical torching events are 

1⁄2 mile or less, but distance and number of embers increases as the extent of 

active crown fire increases. Plume-dominated crown fires and major crowning 

runs typically produce profuse spotting with most spotting within 1 mile; but 

plume-dominated fires can readily spot up to 2 miles.

RA2012-23

p-29 

Comment: 

Supervisor Lawrence, your DEIS doesn’t mention “vegetation management 

away from the structure would not affect ignition from flame exposure and 

would not significantly reduce ignitions from firebrands.” If protecting the 

public had meant as much to you as volume accumulation this fact would have 

been emphasized in your DEIS. 

Response:

Please see response to comment RA2012-22. 

RA2012-24

p-29 

Comment: 

Supervisor Lawrence, your DEIS doesn’t mention that W-UI fire-loss mitigation 

should concentrate on the residence and its immediate surroundings.

Response:

Please see response to comment RA2012-20. 
Tollgate Fuels Reduction Project FEIS

G-14

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

RA2012-25

p-29 

Comment: 

Dr. Cohen states: “Wildland fuel reduction beyond the home ignition zone does 

not necessarily change home ignitability; therefore, wildland fuel reduction does 

not necessarily mitigate the W-UI fire loss problem.” (Pg. 9) 

Supervisor Lawrence, your DEIS doesn’t tell the public this important fact. 

Clearly you think it’s more important to please your supervisor with volume 

than saving homes. 

Response:

Please see response to comment RA2012-20. 

RA2012-26

p-30 

Comment: 

Supervisor Lawrence, your DEIS doesn’t tell the public this important fact. Clearly 

you think it’s more important to please your supervisor with volume than saving 

homes. You should be indicted 

Response:

We disagree. The FEIS discloses the effects associated with the proposed 

actions for each alternative. 

RA2012-27

p-30 

Comment: 

Supervisor Lawrence, your DEIS doesn’t tell the public the truth about fuels 

reduction 

Response:

We disagree, but your comment has been noted. 

RA2012-28

p-30 

Comment: 

 

Supervisor Lawrence, your refusal to acknowledge Dr. Cohen’s methods is 

because the volume 40 meters from a home is on private land. 

Response:

Please see the response to RA2012-22. 
Tollgate Fuels Reduction Project FEIS

G-15

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

RA2012-29

p-30 

Comment: 

Supervisor Lawrence, your DEIS directly contradicts the content of a GAO 

investigation.

Response:

Your comment has been noted. This GAO report was conducted and published 

approximately 15 years ago and several changes have been occurred in agency 

operations since then.

RA2012-30

p-31 

Comment: 

Supervisor Lawrence, your DEIS doesn’t explain the truth about home ignitions 

to the public.

Response:

Please see response to comment RA2012-20. 

RA2012-31

p-31 

Comment: 

Dr. Cohen states: “Bessie and Johnson (1995) show weather (fuel moisture and 

wind) is far more important than fuels in determining fire behavior; reducing 

fuels may have a limited impact on fire occurrence.” (Pg.1999) 

Source for quote above: Objectives and considerations for wildland fuel 

treatment in forested ecosystems of the interior western United States 

Published in Forest Ecology and Management 256, 2008

http://www.firewise.org/Information/Research-and-Guidance/WUI-HomeIgnitionResearch/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

Supervisor Lawrence, your DEIS should explain why you assume it will rain 

each day during the summer with no wind. 

Response:

Please see page 3-52, fire weather parameters used to model fire behavior in 

untreated and treated stands and states, in part:

Weather used to estimate fire behavior was taken from Case RAWS. 
Tollgate Fuels Reduction Project FEIS

G-16

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

Approximated 90th percentile conditions were used for modeling.

RA2012-32

p-31 

Comment: 

Dr. Cohen states: “Treating fuels to reduce fire occurrence, fire size, or amount 

of burned area is ultimately both futile and counter-productive.” (Pg.1999) 

 

Source for quote above: Objectives and considerations for wildland fuel 

treatment in forested ecosystems of the interior western United States 

Published in Forest Ecology and Management 256, 2008

http://www.firewise.org/Information/Research-and-Guidance/WUI-HomeIgnitionResearch/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

 

Supervisor Lawrence, your DEIS doesn’t explain why you choose to waste their 

money on ineffective treatments during times when agency budgets are 

decreasing.

Response:

See response to RA2012-28

RA2012-33

p-32 

Comment: 

Dr. Cohen states: “Thinning to reduce crown fire potential requires careful 

evaluation of the tradeoffs in treatment effects on potential surface fire behavior 

and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result 

in increased potential surface fire behavior, for several reasons. First, thinning 

reduces the moderating effects of the canopy on windspeed, so surface 

windspeed will increase (Graham et al., 2004). It also results in increased solar 

radiation on the forest floor, causing drier surface fuels. It may also cause an 

increase in flammable grassy and shrub fuels over time, due to the reduced tree 

competition.” (Pg.2000) 

 

Source for quote above: Objectives and considerations for wildland fuel 

treatment in forested ecosystems of the interior western United States 

Published in Forest Ecology and Management 256, 2008

http://www.firewise.org/Information/Research-and-Guidance/WUI-HomeIgnitionResearch/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf

 

Supervisor Lawrence, your DEIS doesn’t tell the public that removing 
Tollgate Fuels Reduction Project FEIS

G-17

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

merchantable-sized fuels will exacerbate the risk of fire damage.

Response:

Fires may have an increase in spread rate in thinned stands, but with reduced 

intensities (flame lengths) and severity (crown fire) within the stands after 

treatment. 20 foot windspeeds will not be affected by any treatments proposed 

for the project. Post treatment, forb and shrub growth will increase which 

retain moisture until later in the season and thus can reduce fire behavior 

(Agee et. Al. 2002). 

RA2012-34

p-33 

Comment: 

Supervisor Lawrence, your fuels reduction timber sale in contradictory to the 

facts ... the facts told to the public by Chief Dombeck

Response:

We disagree, but your comment has been noted. 

RA2012-35

p-33 

Comment: 

Dr. Ingalsbee and Dr. Fox state: “We cite evidence that logging-induced 

changes in fuel composition, vegetation, and microclimate can result in 

increased rate of fire spread, higher fireline intensity, and more severe fire 

effects.” (Abstract-2nd paragraph) 

 

Source for quote above: Fuel Reduction for Firefighter Safety 

Published in Proceedings of the International Wildland Fire Safety Summit 

Winthrop, WA, Oct. 26-29, 1998 

http://www.fusee.org/docs/fuelbreaks/fuel_reduction_copy.htm 

 

Supervisor Lawrence, once again an unbiased, independent scientist says 

“logging-induced changes in fuel composition, vegetation, and microclimate can 

result in increased rate of fire spread, higher fireline intensity, and more severe 

fire effects” and you reject his observations. 

Response:

Contrary to the assertions of this comment, we do not reject the observations 

and assertions of the above quotation from Dr. Ingalsbee and Dr. Fox, in a 

general sense. We argree that it is certainly possible, in theory, for tree removal 

operations to result in characteristics of fuel composition, vegetation, and 
Tollgate Fuels Reduction Project FEIS

G-18

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

microclimate that amplify fire behavior. However, with respect to the likely 

effects of implementing activities under Alternatives B or C of the Tollgate 

project specifically, we have included many design features and other 

components of the Alternatives to effectively mitigate against any potential 

activity-related effects which might have exacerbate fire behavior. In addition 

to the high expected efficacy of mitigation measures (such as treatment of 

activity fuels and harvest prescriptions), the reductions in overall fuel loading 

and continuity would be so large as to dramatically reduce wildfire behavior 

overall, particularly relative to the no-action Alternative. For further

elaboration on these points, see responses to comments HCPC-12 and HCPC13, below. 

RA2012-36

p-33 

Comment: 

Supervisor Lawrence, you know how the public detests commercial logging in 

their national forest land, yet in your zeal to accumulate your precious volume 

you ignore all other facts ... including the fact that you refuse to administer the 

national forest the way the public wants. 

Response:

Your comment has been noted. 

RA2012-37

p-33 

Comment: 

Supervisor Lawrence, your fuels reduction proposal is an assault on the public. 

Response:

We disagree, but your comment has been noted. 

RA2012-38

p-34 

Comment: 

Supervisor Lawrence, why do you ignore the scientific fact that weather controls 

fire behavior ... even in areas where large trees and so-called ladder fuels have 

been removed.

Response:

Please see response to comment RA2012-3. 

RA2012-39

p-34

Comment: 
Tollgate Fuels Reduction Project FEIS

G-19

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

Supervisor Lawrence, you apparently cannot comprehend how weather affects 

wildfire behavior. 

Response:

Please see response to comment RA2012-3. 

RA2012-40

p-34 

Comment: 

Supervisor Lawrence, how will you replicate the fire benefits to the natural 

resources that exist in your timber sale area? 

Response:

Please see review the Purpose and Need for this project in Chapter 1.

RA2012-41

p-35 

Comment: 

Supervisor Lawrence, you must think you know more than the many fire 

scientists who say fuels reduction logging is a waster of time & money.

Response:

Your comment has been noted.

RA2012-42

p-35 

Comment: 

Supervisor Lawrence, your final NEPA document must tell the public why Dr. 

Schoennagel, Dr. Veblen and Dr. Rommie are wrong when they all agree that “once 

fuels reached critical moisture levels later in the season, the spatial pattern of the 

large, severe stand replacing fires was controlled by weather (wind direction and 

velocity), not by fuels or stand age.” 

Response:

Proposed treatment units are positioned on the landscape to protect specific 

Values at Risk from crown fire and are not intended to influence the spatial 

pattern of large fires on the landscape. Treatments are situated and designed 

to moderate fire intensities and severities, allowing for direct suppression 

adjacent to the Values at Risk described. 

RA2012-43

p-35

Comment: 
Tollgate Fuels Reduction Project FEIS

G-20

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

If the final EIS for the Tollgate Project does not analyze a Dr. Cohen alternative 

in detail it will be necessary to inform the public in your area about Dr. Cohen’s 

superior fire risk reduction methods myself.

 

Response:

Your comment has been noted. 

RA2012-44

p-36 

Comment: 

The Purpose & Need of the DEIS describes the need to reduce hazardous fuels 

near the WUI, and various needs to manipulate the trees in the area with 

commercial timber harvest. Supervisor Lawrence, a responsible public servant 

would have had only one Purpose & Need statement: “Take action to reduce the 

risk of wildfire damage to homes located in the WUI.” Had this been the P&N, 

hazardous fuels reduction would have been one action alternative. This would 

have left the door open to analyze other action alternatives.

 

Obviously, you would rather see peoples houses burn and people harmed so you 

can create industrial tree farm conditions ion the Umatilla National Forest and 

accumulate volume simultaneously.

Response:

We disagree, but your comment has been noted. 

RA2012-45

p-37 

Comment: 

The quote below from the USFS survey discussed above proves that the 

Proposed Action in the Tollgate DEIS is the antithesis of what the American 

public want done to their precious national forest land: 

 

“The public sees the restriction of mineral development and of timber harvest 

and grazing as being more important than the provision of natural resources to 

dependent communities (although this is still seen as somewhat important).” 

(Pg. 28) 

Response:

Your comment has been noted. 

RA2012-46

p-37

Comment: 
Tollgate Fuels Reduction Project FEIS

G-21

Letter #3 

Richard Artley’s 12/26/2012 comment (RA2012)

Comment 

Number Comment and Response

The public is very concerned about the adverse ecological effects of logging and 

road construction in their national forests. They expect to see literature 

explaining these adverse effects and they expect the Responsible Official to 

honestly weigh the trade-off of this short and long term natural resource 

degradation against the perceived positive outcome of logging and roading the 

landscape. Most members of the public will clearly explain why logging their 

forests for any reason is not worth the ecosystem damage. 

Response:

Your comment has been noted. 

RA2012-47

p-38 

Comment: 

The United States population is expected to reach 400 million in 27 years (2039). 

Children born at that time will find undeveloped public land to be a precious asset 

that must (emphasis added) never be manipulated by humans now with logging and 

road construction for short-term corporate profits.

 

Please notify this member of the public when the ROD and final EIS are first posted 

online and the legal notice of decision is published in your newspaper of record and 

the 45-day appeal period begins.

Response:

All commenters will be notified when the Final EIS is published. The Tollgate 

Fuels Reduction project is a HFRA authorized project, as detailed in the legal 

notices for the initiation of the 45-day comment period. As such, this Final EIS 

will be subject to a 30-day objection process as detailed in 36 CFR 218. 

Letter #4 

Norm Kralman (NK)

Comment 

Number Comment and Response

NK-1

p-1 

Comment:

Because of your Fuels Reduction plans which I participated in at the beginning, I 

just completed a 4 year project which included logging dead and dying trees, slash 

and under growth cleanup and burning as well as hiring a private logger from 

Pendleton who utilized a state cost share program to complete the worst of my 

property as it could be described as needing fuels reduction totaling 25 acres. 

Response:
Tollgate Fuels Reduction Project FEIS

G-22

Letter #4 

Norm Kralman (NK)

Comment 

Number Comment and Response

We thank you for your interest and participation in the collaborative process 

and for your efforts to create defensible space around your property.

NK-2 

p-1 

Comment:

Because of my senior age my primary goal when I purchased this property was that 

of habitat restoration and I did accomplish that however it became obvious in the 

past 5 years that I was not able to manage my private lands for only habitat and 

wildlife activities but that I need to take steps to allow for tree growth and keeping 

that in balance against potential fire dangers and that was completed this past 

October of 2012 through some thinning by cutting certain sized trees as well as 

beating/mulching brush, smaller trees as well as braking up the undergrowth.

Response:

Your comment has been noted and mirrors our efforts to balance multiple 

resource management needs across the landscape as we’ve strived to do in this 

project.

NK-3

p-1 

Comment:

If for just habitat it would be too much however I do believe the larger picture 

requires management of the forest for all considerations as human enjoyment, 

wildlife, forest restoration and relations with my neighbors so I am glad the work is 

done now and I look forward to a new birth come spring. 

Response:

Your comment has been noted.

NK-4

P-1 

Comment: 

All that being said I encourage your ALTERNATIVE B PLAN as the option of 

choice. 

Response:

Your comment has been noted.

Letter #5 

Jean Public (1/2/13) (JP_01_2013)
Tollgate Fuels Reduction Project FEIS

G-23

Comment 

Number Comment and Response

JP_01_2013-1

p-2 

Comment:

this is a make money logging program, not a fuel reducation program. it is 

time to stop this movement of cutting down all of ournationally owned trees 

so tha the forest service can make money. this is about money and greed, not 

fuel reduction. the plan stinks to high heaven. you are decimating the birds 

and wildlife, where you are destroying their homes and their food soiurces, 

so that you destroy the eiwllife and birds. thsis inexcusable and depraved. 

Response:

Your comment has been noted.

JP_01_2013 -2

p-2 

Comment:

you are not saving anuything in this site. you are decimating it all. 

1, entire site should be changed to wilderness site and wilderness 

designation. 

 

2. the area being logged for money and greed is not an area that would block 

wildfire. 

 

3. all snags need to be left on the site. 

vii wildfire is not and should not be a paranoiac hysteria so that all life is 

destroyed by the forest service. there IS NO WILDLIFE BUT YOU ARE 

DESTROYING IT ANYWAY. THAT MAKES NO SENSE. THIS IS A 

HYSTERICAL PLAN (OR IS IT AMONEY MAKING PLAN?)

Response:

Your comment has been noted. 

JP_01_2013 -3 

p-2 

Comment:

1-6 THE PUBLIC REJECTS ALL TIMBER ROADS. THERE IS NO 

JUSTIFICATION FOR "DANGER TREE REMOVAL". 

Response:

We disagree. Danger Tree removal is conducted in order to provide for public 

safety associated with travel routes. 

JP_01_2013 -4

p-2 

Comment:

303 STOP ALLOWING RANCHING OF SHEEP AND GOATS ON 

132,000 ACRES. THE AMOUNTS PAID TO THE TREASURY BY 

THESE CHEAP RANCHERS IS SO SMALL AND THEY LEAVE THE 

LAND SO DESTROYED THAT THE PUBLIC SAYS LET THEM GO 

RENT LAND FROM PRIVATE OWNERS.YOU WILL SEE THAT THEY 
Tollgate Fuels Reduction Project FEIS

G-24

Letter #5 

Jean Public (1/2/13) (JP_01_2013)

Comment 

Number Comment and Response

PAY ONE THOUSAND TIMES AS MUCH AS THE CHEAP BUY THEY 

ARE GETTING FROM THE FS, WHICH IS LETTING THESE 

RANCHERS DESTROY OUR LAND THAT BELONGS TO 315 

MILLION PEOPLE AND RENTING IT OUT AS IF IT BELONGED 

SOLELY TO THESE CATTLE RANCH PROFITEERS. THEWRITING 

OF THE CONTRACT IS NOT COVERED BY THE MONIES PAID AS 

LAND LEASING BY THESE CHEAP CATTLE RANCHERS WHO 

LEACH ON THE PUBLIC TRUST LAND. 

Response:

Grazing within the project area is beyond the scope of this decision. 

Environmental effects of sheep and goat grazing was conducted for the North 

End Sheep & Goat Allotment in a FEIS and was documented in a Record of 

Decision (ROD) dated 2010. Additionally, the effects of grazing, when relevant, 

were discussed in the cumulative effects sections of various resource headings 

in Chapter 4. Also see document entitled: “Considerations of Livestock Grazing 

and Rationale for not including a Range Effects Sections within the Tollgate 

Fuels Reduction Project FEIS” contained in the Tollgate project record.

JP_01_2013 -5

P-2 

Comment: 

3-18 FISH WILL BE NEGATIVELY AFFECTED BY THE LARGE SCALE EROSION FROM 

THE LOGGING. NOTHING CAN "RESTORE" THESE FISH BECAUSE THE CATCH 

ALLOWED ARE HUYGE AND DO NOT ALLOW ANY REGENERATION. 

Response:

We disagree. Please see the environmental effects disclosures related to 

fisheries resources on pages 4-16 to 4-25 of this FEIS. 

JP_01_2013- 6

p-2 

Comment:

4-53 - THIS PLAN IS DETRIMENTAL TO CLIMATE AND 

ENCOURAGES CLIMATE CHANGE.

Response:

Current understanding of climate science suggests it is difficult, if not 

impossible, to establish a cause-and-effect relationship between silvicultural 

activities and climate change at a project scale. Therefore, climate change 

effects were not used or evaluated as issues during the NEPA process, and no 

indicators were established for comparing climate change or carbon cycle 
Tollgate Fuels Reduction Project FEIS

G-25

Letter #5 

Jean Public (1/2/13) (JP_01_2013)

Comment 

Number Comment and Response

effects between Alternatives.

The FEIS goes on to summarize some scientific understanding of climate 

change effects in ways that may be pertinent to the project and benefit the 

general public’s understanding of forest management projects in the context of 

climate change: 

At the same time, large and increasing levels of interest among the 

general public in how large forest management projects interact with 

climate change and carbon cycling nonetheless suggest there is some 

value in disclosure of existing understanding, particularly to identify 

key areas of uncertainty and demonstrate consistency with national and 

international strategies and objectives. To that end, a science overview 

is provided in this section.

JP_01_2013-7

p-2 

Comment:

4-57 - THE POTENTIAL TO STORE CARBON IN OREGON FORESTS 

IS AMONG HIGHEST IN THE WORLD (HUDIBERG ET AL 2009) 

THEREFORE THIS LOGGING IS A CARBON SOURCE AND 

DETRIMENTAL TO THE ENTIRE AMERICAN ENVIRONMENT.

Response:

Please see the environmental effects disclosure for Climate Change in the FEIS 

located in Chapter 4. 

JP_01_2013-8

p-2 

Comment:

4-37 TABLE 4-34 IS INACCURATE AS TO THE REALISTIC STAUTS 

OF THESE ANIMALS WHICH ARE VIRTUALLY WIPED OUT BY 

GUN WACKO WILDLIFE MURDERERES AND HABITAT GRABBING 

BY GREEDY CATTLE RANCHERS, ETC. AL

Response:

Your comment has been noted.

JP_01_2013 -9

p-3 

Comment:

the bibliography for your deis is ancient. nothing future directed or realistic 

about present conditions has been studied in this bibliography. tracts from 50 

years and more ago are totally unrealistic in planning for a future 20 years 

out. these old documents help us not at all for 2035. they are totally not 

cogent.
Tollgate Fuels Reduction Project FEIS

G-26

Letter #5 

Jean Public (1/2/13) (JP_01_2013)

Comment 

Number Comment and Response

Response:

We disagree. The bibliography for this project represents the best available 

science as determined by the respective members of the interdisciplinary team 

(IDT). Furthermore, the IDT has reviewed submissions of science by 

commenters and determined the citations relevance as it relates to this project. 

The conclusions of the IDT’s review can be found in the Tollgate Fuels 

Reduction project record. 

JP_01_2013 -10

p-3 

Comment:

h-1 i believe entire area should be wilderness. greedy managers shoudl be fired. 

the land should be left lnatural. the managers of fs are hurting all life on earth. 

their focus is money and greed, not life for americans.

Response:

Your comment has been noted. 

Letter #6

Allison O’Brien – U. S. Department Of Interior- Office of Environmental Policy and Compliance 

(DOI)

Comment 

Number Comment and Response

DOI-1

p-1 

Comment:

The Department of the Interior has reviewed the Draft Environmental Impact 

Statement for the Tollgate Fuels Reduction Project. The Department does not have 

any comments to offer. 

Response:

Your comment has been noted. 
Tollgate Fuels Reduction Project FEIS

G-27

Letter #7 

Chris Howard- Blue Mountain Audubon Society (BMAS)

Comment 

Number Comment and Response

BMAS-1

p-1 

Comment:

BMAS has an understanding of the need for forest management in regards to fire 

threats in and around developed areas located on the Tollgate plateau. The project 

DEIS was studied by the preparers of this comment as well as visits to the Walla 

Walla Forest Service office to ask questions and discuss issues included in the 

DEIS.

Response:

Thank you for your interest in the project and are hopeful that our 

conversation in February 2013 provided additional understanding of the 

project.

BMAS -2

p-1 

Comment:

While it is understandable that home owners and business owners are 

concerned with protecting their property in the event of fire, it is also 

important that we advocate for the habitat of other species in regards to the 

proposed project. After studying the DEIS, BMAS would like to encourage 

the Forest Service to adopt Alternative C as the plan to govern the 

implementation of the Fuels Reduction Project. As it is pointed out in the 

DEIS, there is little difference between Alternative B and Alternative C, but 

from the standpoint of habitat protection, the difference is important.

Alternative B would allow treatment into the Lookingglass Inventoried 

Roadless Area (IRA) in units 26, 38, and part of 75. Since treatments in these 

units would result in their not qualifying as potential wilderness area 

designation, BMAS would prefer the choice of Alternative C. 

Response:

Your comment has been noted.

BMAS-3 

p-1 

Comment:

There is a similar situation with Unit 104, just north of the North Fork of the 

Umatilla Wilderness. It appears from Maps H-7 and H-8 that Alternative B 

would provide treatment in Unit 104 which would disconnect a fairly large 

strip of Potential Wilderness Area that previously was contiguous to the N.F. 

of the Umatilla Wilderness Area. Hence, the disconnected strip would no 

longer be eligible for wilderness designation. This would not happen if 

Alternative C were adopted. It is hoped that even if Alternative B were 

adopted, that consideration could be made regarding the impact of treatment 
Tollgate Fuels Reduction Project FEIS

G-28

Letter #7 

Chris Howard- Blue Mountain Audubon Society (BMAS)

Comment 

Number Comment and Response

in Unit 104.

Response:

Your comment has been noted. 

BMAS-4

p-1 

Comment:

Another matter of concern to BMAS is the intention of cutting of trees 

greater than 21” DBH. The larger trees make good habitat and large snags 

are utilized by a number of forest species. Page 3-69 in the DEIS indicates 

that snags are under represented in some areas of the project. It would be 

preferable in the BMAS viewpoint to treat Fuel Model 10 by removing dead 

and downed materials and decreasing the understory rather than taking out 

larger trees where ever feasible . Of similar concern is the intention for 

taking out trees greater than 21”DBH in both Alternatives B and C if they are 

viewed as having safety concerns or because of operational needs. 

Response:

Your comment has been noted. 

BMAS-5

P-2 

Comment: 

It is important to BMAS that the trees selected for removal are evaluated on an 

individual basis by a qualified evaluator and that trees selected for removal present 

an eminent danger. In the view of BMAS it would be a poor choice to remove a tree 

that has a possible chance of falling in 10 years on a closed road that is only being 

temporarily opened for treatment then closed again.

Response:

Your comment has been noted. Danger tree identification is conducted by 

qualified Forest Service personnel. Likely danger trees, those that would be 

expected to fall within 5-10 years, are targeted for removal based on the safety 

concern associated with having operators moving in and out of an area for 

multiple years as project implementation occurs. Additionally, there is an 

efficiency available in having trees that are likely to fail removed in order to 

allow for easier use of a closed road should it be needed (for instance in the 

event of a wildfire situation) versus having to log out the road should it be need 

for wildland fire suppression efforts or other resource management access 

needs. 

BMAS- 6 Comment:
Tollgate Fuels Reduction Project FEIS

G-29

Letter #7 

Chris Howard- Blue Mountain Audubon Society (BMAS)

Comment 

Number Comment and Response

p-2

Another reason for selecting Alternative C is that only one RHCA (Unit 19) 

is listed for treatment. In reading the DEIS it was gratifying to see the very 

strict guidelines regarding treatment and timber harvest in the sensitive 

RHCA’s for which the Forest Plan Amendments were obtained. The concern 

for BMAS is how these sensitive sites are monitored when the actual work is 

going on? Are there Forest Service monitors on site observing the contractors 

as they work? 

Response:

Timber harvest activities are overseen by the Timber Sale Administrator 

(TSA) whom is responsible for ensuring that harvest operators follow the 

specification of the timber sale contract which is the legal vehicle for the 

implementation of not only the timber sale activity but also the project design 

criteria identified in this document. Additionally, it is likely that members of 

the IDT (hydrologist and fisheries) biologist will be on site during the activity 

and will conduct follow up site monitoring visits. 

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

BC-1

p-1 

Comment:

Thanks you for the opportunity to provide comments on the upcoming Tollgate 

Fuels Reduction project. I am in general agreement with the purpose and need for 

the action described in this document. Below are my additional comments on the 

project. Of the alternatives analyzed, I am in favor of the proposed action (alt. B) as 

it will do more to protect the WUI.

Response:

Your comment has been noted. 

BC -2

p-1 

Comment:

There are 21,000 acres in the WUI outside of the IRA and yet the proposal is 

only to treat 4,330 acres with only 3,445 acres slated for commercial 

treatment. How did the Forest Service identify only 4,330 acres for 

treatment? What were the reasons behind not treating a larger portion of the 

WUI? What happens to the economic analysis if the acreage slated for 
Tollgate Fuels Reduction Project FEIS

G-30

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

treatment is increased?

Response:

Treatment areas were selected based on protecting identified Values at Risk 

within the planning area. Treatment extent and specific prescriptions were 

based on reducing crown fire susceptibility and fire intensities to levels that 

meet the stated purpose and need of the project and that allow for direct 

suppression opportunities in the event of wildfire occurrences. The total 

acreage slated for treatment as well as the specific prescriptions were borne out 

of this process and reflects the analysis stated above.

BC-3 

p-1 

Comment:

Table 1-1 states that 26% (10,772) of the project area acres are in the E2-

Timber and Big Game designation and yet the Forest is only treating 2,819 

acres. Why did the Forest analyze these acres if they did not plan to treat any 

of these acres?

Response:

The larger analysis area was chosen because it overlaps with the established 

WUI as identified in the Umatilla County Community Wildfire Protection Plan 

(CWPP) as amended. Additionally, the analysis was conducted on the 

landscape scale in order to provide context to the effects of the proposed 

treatments. As detailed in Chapters 1 and 2 of this FEIS, the treatment areas 

(and resulting treatment acreages) were designed based on a consideration of 

input provided by the collaborating public during project development in 

addition with the strategic locations identified during model runs and based on 

scientific literature and professional judgment and experience. 

BC-4

p-1 

Comment:

Please incorporate an alternative that maximizes the economic return for the 

project. This will provide the maximum amount of jobs and economic benefit 

for the local communities and timber industry infrastructure.

Response:

An alternative that would treat more acres within the project planning area 

was considered, but eliminated for detailed study. The rationale for the 

elimination of this alternative is disclosed in Chapter 2 of the FEIS under the 

heading “Alternatives Considered, but Eliminated from Detailed Study” – see 

#7. 
Tollgate Fuels Reduction Project FEIS

G-31

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

BC-5

P-1 

Comment: 

Why was economics not identified as a key issue for this project? Economics should 

always be a key issue identified in the purpose and need of every project. Currently, 

Northeast Oregon is suffering from high unemployment and a lack of viable job 

opportunities for young people mainly due to the decline of the timber industry. It is 

increasingly important that the Forest Service work to ensure that this infrastructure 

remain viable in order to maintain management on the national forests. Without a 

sustainable supply of wood, the infrastructure will continue to decline and Northeast 

Oregon will face the same situation that New Mexico and Arizona face, 

uncharacteristic wildfires and not timber infrastructure. 

Response:

The effect of our actions on the local communities is always a consideration in 

the projects undertaken on the Umatilla National Forest. However, given the 

nature of this HFRA project, the issues that were identified were based on 

unresolved conflicts that existed around the proposed action. The effects 

associated with economics did not represent an unresolved conflict for the 

project since under any action alternative some level of wood fiber would be 

provided to local community. The difference between alternatives on project 

economics is disclosed on pages 4-121 to 4-122 of chapter 4. 

BC- 6

p-2 

Comment:

Please expand the economic analysis to include the different effects on the 

local economies for each alternative. The local economies depend on a 

sustainable timber supply from the Federal Forest and this project will 

provide some of that sustainability. 

Response:

Please see the economics section of Chapter 4. Additionally, the Umatilla 

National Forest Plan FEIS (1990) provides additional context about Forest’s 

impact on local communities.

BC-7

P-2 

Comment:

On page 2-2 of the EIS, it states that all harvests will leave at least 80 square 

feet/acre. This is unacceptable for stands in a WUI. Why leave the basal area at the 

high end when the rest of the project area is still susceptible to crown fire? 
Tollgate Fuels Reduction Project FEIS

G-32

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

Response:

We disagree that 80ft2 per acre is “at the high end” of residual density for 

purposes of decreasing the probability of active or passive crown fire. For 

many stands in the cold and moist upland forest biophysical environments 

found in the Tollgate planning area—particularly those forests with very high 

canopy base heights—fuel conditions associated with 40 to 120ft2 per acre are 

strongly associated with low or moderate fire behavior, and very weakly 

associated with high-intensity active crown fire (Powell 2010, as cited in the 

fuels analysis section of the Tollgate FEIS). The Tollgate project carefully 

selected residual density targets based on the biophysical site-specific 

conditions of the particular treatment unit, relying upon professional judgment 

and experience, standard fire model predictions, and published scientific 

literature pertaining to analogous conditions. In addition, the residual density 

targets are, according to Forest Service technical guidelines pertinent to the 

site-specific biophysical conditions of the Tollgate activity units, actually in the 

low-to-mid range of maximum recommended density/stocking (Powell 1999, as 

cited in the silviculture analysis section of the Tollgate FEIS). 

The comment on the “acceptability” of the residual basal area has been noted. 

Although 80ft2 per acre residual basal area does not represent the bottom of 

the range described above, and as the silviculture analysis section of chapter 4 

in the FEIS makes clear, a balance must be struck in the activity prescriptions 

between fuels reduction through tree-cutting and the retention of an overstory 

canopy for protection on the one hand, and on the other hand, against windthrow, which is a very common occurrence in the Tollgate plateau and a 

disturbance to which thinned stands are susceptible. In addition to wind-throw 

risks described in the silviculture analysis, canopy fuels reduction must also be 

balanced against the retention of canopy cover for wildlife habitat, aesthetic 

concerns related to Forest Plan and other legal requirements, and the retention 

of moderate levels of overstory shade to maintain fuel moisture on the forest 

floor (and reduce surface wind speeds) during some portions of the fire season. 

In this sense, the overstory retention guidelines described in the FEIS create 

what we believe would be an effective “shaded fuel break” extremely resistant 

to passive and/or active crown fire, and offering opportunities for direct 

wildfire suppression and control. 

We agree that the rest of the project area is susceptible to active or passive 

crown fire to some degree, but some areas (approximately 20% of the Tollgate 

planning area as described in Table F7, Appendix F of the Tollgate FEIS) is 

susceptible to a relatively low degree, because fuel loading and forest density is 

at low or moderate levels.
Tollgate Fuels Reduction Project FEIS

G-33

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

BC-8

p-2 

Comment:

Table 4-12 states that the treatments will only bring one structural stage into the 

historical range for Moist Upland Forest. That structural stage is Understory 

Reinitiation, with everything else remaining out of balance with regards to structural 

class. Can you please look at including more treatments to return other structural 

classes to their HRV? Returning areas to the Stand Initiation phase would be 

relatively easy.

Response:

As described in Chapter 1 of the FEIS (especially page 1-4), activities designed 

for the Tollgate Fuels Reduction Project were not primarily intended to restore 

structural classes such that their extent would fall within Historic Ranges of 

Variability (HRV); rather, the activities were designed to meet the project 

purpose and need to implement actions which reduce the probability and 

potential extent of active crown fire within the Tollgate WUI, by reducing the 

amount and continuity of surface and canopy fuel loading. 

While the activities described in Chapter 2 may in many cases be consistent 

with restoration of structural class HRV within the project area, this was not 

always the case, because the project used the purpose and need (which related 

to fuels/fire hazard) as the primary driver for activity design. As a result, 

activities were designed to be consistent with basic hazardous fuels reduction 

principles recommended by Agee and Skinner (2005), which involves, in part, 

the retention of the largest (and often most fire-resistant) trees of the treated 

stand. Because large fire-resistant trees were, to the extent possible and 

consistent with fuels reduction needs, prioritized for retention across the 

activity units, some structural stages (such as the Stand Initiation stage) would 

not be restored to within HRV as a result of implementing the proposed 

activities.

BC-9

p-3 

Comment:

Cutting trees larger than 21” should be an option for all stands because the 

biophysical environments for OFSS and OFMS are within HRV. Since the OF is 

within HRV in the project area, why does the project only remove 21” trees on 338 

acres? The prescriptions for the stands should allow for removal of 21” trees in all 

of the acreage treated if the goal is fuels reduction.

Response:

This option was considered for the Tollgate project, but not included in an 

action Alternative for two reasons: 

1. The removal of trees >21” DBH was considered an important and effective 
Tollgate Fuels Reduction Project FEIS

G-34

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

means to accomplish the project purpose and need for portions of 338 

acres; outside of those areas, we believe that other old forests in the 

Tollgate analysis area have trees with sufficiently low density and size to 

allow accomplishment of fuels reduction objectives to meet the project 

purpose and need by only removing trees less than 21” DBH. 

2. In many areas on the Tollgate plateau that are not dominated by 

exceptionally large, dense trees (or large clusters of such trees), removing 

trees >21” DBH would result in unacceptably low residual stand densities. 

As stated above in response to comment BC-7 and in the silviculture 

analysis in Chapter 4 of the FEIS, a careful balance must be struck in the 

activity prescriptions between fuels reduction through tree-cutting on the 

one hand, and on the other hand, the retention of an overstory canopy for 

protection against wind-throw, and the retention of aesthetic, wildlife 

habitat, fuel moisture retention, surface windspeed reduction, and other 

values. 

BC-10

p-3 

Comment:

Table 3-24 states that OFMS and OFSS are both above the HRV in the Moist 

Upland Forest PVG while the SI and SE are both well below the HRV. Why is the 

forest not moving the forest towards a more balanced HRV in the Moist Upland 

Forest PVG?

Response:

See response to comment BC-8. Moving the Moist Upland Forest PVG closer to 

HRV was not the primary driver of activity design because it was not a part of 

the project Purpose and Need. However, a secondary benefit of project 

treatments (which are placed in strategically important locations) is that some 

treatments may help move associated PVGs closer toward HRV.

BC-11

p-3 

Comment:

What differentiates the LFR units from the commercial logging units? Is there an 

opportunity to take some sawlogs out of these units to offset the potential 

biomass/pulp proposed? If these units must stay in the LFR category where only 

material 4-9” is removed, please ensure that it is optional for the purchaser 

depending on the market. 

Response:

LFR units target smaller diameter material (4-9” dbh) acting as fire ladders 

within appropriate units. Your comment is noted regarding the economics of 
Tollgate Fuels Reduction Project FEIS

G-35

Letter #8 

Lindsay Warness- Boise Cascade (BC)

Comment 

Number Comment and Response

biomass material.

BC-12

p-3 

Comment:

It is unfortunate that the Forest Service analyzed such a large area and only took 

into account the cover associated with the HEI. The Forest Service would increase 

forage for the Elk by implementing skips and gaps, or shaded fuel breaks. It appears 

that there are multiple opportunities that were missed in the project area to improve 

habitat, decrease density and increase recreational opportunities. 

Response:

A mistake was made in the DEIS on page 3-66. The correction is that 

satisfactory elk cover is within desired conditions identified in the forest plan. 

Cover for big game was not emphasized in this project.

BC-13

p-3 

Comment:

Please define what best management practices you will use when building/using the 

temporary roads. Please also indicate if these temporary roads will be built on the 

top of old roadbeds or if they will be completely new. Please look to see if there are 

old road beds that could be used in these circumstances.

Response:

Design Criteria and Best Management Practices for temporary road 

construction and decommissioning are found in FEIS Table 2-7, pages2-17, 2-

18. The project description in Chapter 2 of the FEIS (see Temporary Road 

Construction section) discusses locations of these roads and also includes 

information that about half, 1.3 of 2.6 miles, of temporary road location is on 

an existing template.

BC-14

p-4 

Comment:

I am pleased that management is proposed for the RHCAs. These are very sensitive 

areas that can be detrimentally altered in the event of a wildfire as they have higher 

than normal fuel loads. It is acceptable to have short term effects in these areas in 

order to meet the long-term fuels reduction objectives. 

Response:

Thank you for your supportive comment. It has been noted. 
Tollgate Fuels Reduction Project FEIS

G-36

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

OW-1

p-1 

Comment:

Please note: In the Dec 17, 2012 "Dear Interested Party" letter, The Forest Service 

listed an incorrect email address for submission of public comments (commentspacificnorthwestumatilla@fs.fed.us). This means that the Forest Service might not 

receive (and be informed by) all of the public comments, and members of the 

public may be inadvertently denied standing due to the agency’s error. 

Response:

Please see the introduction to this appendix for a discussion of the steps undertaken to 

rectify this error and to allow for the interested public to provide their input. 

OW-2

p-2 

Comment:

Oregon Wild continues to have many of the same concerns discussed in our 

scoping letter, including: 

• The inappropriate focus on fuels instead of ecological restoration;

• the need to develop restoration treatments appropriate for moist forest types; 

less logging and greater retention of dense forests is desirable in moist 

upland forests; 

• commercial logging in 206 acres of inventoried roadless areas (and many 

additional acres of logging in adjacent and nearby uninventoried roadless 

areas that were arbitrarily left out of the RARE II inventory);

• commercial logging in RHCAs in violation of PACFISH;

• commercial removal of large trees on 340 acres;

• use of plan amendments in an HFRA project when the law requires forest 

plan compliance.

• long-term effects of 2.6 miles of road construction, and reopening large 

mileage of closed roads;

Response:

Your comment has been noted. 

OW-3 

p-2 

Comment:

Some, but not all, of the adverse effects we are concerned about are avoided or 

minimized in Alternative C, so we find Alt C less objectionable than Alternative B. 
Tollgate Fuels Reduction Project FEIS

G-37

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Some of our comments make specific suggestions to improve ecological outcomes 

(in addition to the suggestions already made in our scoping letter). 

Response:

Your comment has been noted. 

OW-4

p-2 

Comment:

The FS should reduce the scale of treatments in moist forests dominated by species 

like Douglas fir. Use objective methods to find an optimal mix of treated and 

untreated areas. Figure 3-6 shows that most of the project area is characterized as 

"moist upland forest." Such forests tend to have intermediate to long fire return 

intervals and mixed severity fire regimes. Forests influenced by these disturbance 

regimes are highly variable with a mix of higher and lower density conditions. 

Wildlife evolved with this variable pattern of forest conditions, but wildlife 

populations are now stressed by excessive road density, and altered forest structure 

as a result of past logging. Areas of dense forest with large trees may still be in 

short supply from a wildlife population standpoint (regionally, if not in this project 

area), and logging in such forests needs to be carefully scrutinized. It is often not 

necessary to conduct extensive efforts to reduce stand density in forests like these. 

Response:

Your comment has been noted. 

OW- 5

p-2,3 

Comment:

There is little ecological need for fuel reduction in moist forests with intermediate 

fire regimes. Fuel model 10 can be viewed as wonderfully complex forest habitat 

suitable for marten, pileated woodpeckers, goshawk, and big game cover, rather 

than as a threat of some kind. 

Response:

We disagree that there is no need for fuel reduction within the Tollgate project 

planning area. Please see the project’s stated purpose and need which identifies why

and how treatments were identified.
Tollgate Fuels Reduction Project FEIS

G-38

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

OW-6

P-2 

Comment:

We urge the Forest Service to forgo road construction. Areas inaccessible from 

roads should be allocated to untreated skips (or non-commercial fall-and-leave 

treatments) which provide their own set of ecological benefits, such as dense forest 

cover, abundant dead wood, soil conservation, carbon storage, etc. 

Response:

Your comment has been noted.

OW-7

p-2 

Comment:

Commercial logging should be avoided in inventoried roadless areas and 

uninventoried roadless areas >1,000 acres. Where public safety along roads and 

near home is a concern, the FS should emphasis fuel reduction on the non-roadless 

side of the road or the private side of the property boundary. Also, the focus should 

not be on fuels, but on natural ecological structures and processes. When absolutely 

necessary to conduct treatments in unroaded areas, the FS should conduct noncommercial ecological restoration efforts that restore natural fire regimes, not 

impose an unnatural low severity fire regime in ecosystems where that would be 

atypical.

Response:

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction Project is 

to reduce the probability and potential extent of active crown fire within the Tollgate 

WUI. To achieve the desired condition, reductions in ladder fuels and canopy bulk 

density need to occur, and can only be accomplished through removal of selected 

crowns in selected areas. 

Reduction in active crown fire reduces spotting potential, and the adverse fire effects 

associated therein. Moreover, since we cannot effectively fight crown fires, we need to 

create fuel conditions that will cause the fire to surface, preferably at some distance 

from Values at Risk that also allow for contingency actions in the event the main 

firefighting strategy fails. Firefighters need to have fuel conditions that allow for 

rapid and successful burnout operations that will rob the wildfire of energy needed to 

support crowning and extensive torching or that provide for more effective use of 

retardant, foam, or water. The Tollgate project seeks to create these conditions in 

strategic areas across the analysis area, increasing the defensibility of Values at Risk.

In several instances across the Tollgate planning area, hazardous fuels conditions 

situated within inventoried roadless areas (as well as Potential Wilderness and Other 

Undeveloped Lands) abut identified Values at Risk. These areas have thusly been 

prescribed for treatment in order to meet the intent described above. 
Tollgate Fuels Reduction Project FEIS

G-39

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

OW-8

p-3 

Comment:

The private land adjacent to the eastern IRA unit exhibits relatively dense forest. 

Apparently that landowner is risk tolerant and chooses not to aggressively modify fuels on 

their private land. In that case, why should we sacrifice ecological values and roadless 

values on public land, in order to protect a private landowner who is risk tolerant and 

unwilling to take the those same steps toward fuel reduction? 

Response:

Please see response to comment RA2012-20. 

OW-9

p-4 

Comment:

Also, nearby portions of the Lookingglass IRA (just to the south of the private parcel 

shown in Figure 2) are already composed of a heterogeneous mosaic of forest and 

grassland which is naturally less prone to running crown fire. The FS should just consider 

this area to provide a natural buffer for the nearby private land. Additional fuel 

modification is unnecessary. 

Response:

Ladder fuel reduction of small diameter material, to be accomplished through hand 

thinning in Unit 26, is the prescription for this area and reflects the reduced capacity 

for the area to initiate or sustain crown fire. Ladder fuel reduction is necessary 

however to adequately protect the private parcel in question from crown fire that 

initiates in the Lookingglass IRA.

OW-10

p-5 

Comment:

Also, this is not a typical wildland urban interface. These are isolated private parcels with 

very low housing density. When people choose to build in wild areas like this, they should 

not expect the same level of fuel modification fire protection as those that choose to live in 

and near urban areas.

Response:

Your comment has been noted. 

OW-11

p-5 

Comment:

The FS should not apply a buffer along roads when identifying potential wilderness areas. 

The 300 foot buffers used in the Tollgate analysis are exceedingly large and unsupported 

by logic and evidence. The FS must remember that they are looking for “potential” 
Tollgate Fuels Reduction Project FEIS

G-40

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

wilderness, so they should be inclusive. Congress has established wilderness boundaries 

much closer than 300 feet from roads in many instances. 

Response:

The logic and rational for applying a 300 foot buffer along roads is described in 

appendix H. Forest roads have associated permitted uses and maintenance. Road 

maintenance and many permitted uses have removed trees and created visible stumps 

within the corridor. These activities are expected to continue into the future. Road 

maintenance occurs to varying degrees along each road according to an assigned 

maintenance level and available funding. Road maintenance includes the periodic 

clearing of brush and the falling of danger trees that present a hazard to forest 

visitors, employees, and contractors as defined by the Region 6 Danger Tree Policy 

(2008). The distance of the hazard removal away from a road varies by tree height, 

topographic slope, and other factors. Past removal of danger trees along forest roads 

created stumps that are evident and recognizable.

We recognize stumps are not present along every mile of forest road; for example, 

roads adjacent to a meadow, talus or lake. The judgment we applied in setting a 

PWA boundary balanced inventory criteria regarding past activities and facilitating 

easy on-the-ground identification. This boundary is fully consistent with and 

supported by FSH 1909.12 inventory criteria. 

OW-12

p-5 

Comment:

The FS seems to rely on the fact that firewood cutting is allowed within 300 feet of roads; 

however, this does not justify eliminating huge swaths of otherwise roadless forests from 

the PWA analysis. Many roads are closed and not accessible to firewood cutters. Many 

open roads are not typically used for firewood access. Some areas adjacent to roads are too 

steep. There are conditions on firewood permits that limit that effects of firewood cutting. 

And most importantly, a few stumps visible within an unroaded area does not render the 

area ineligible for wilderness. 

Response:

Harvest of trees for personal use firewood within 300 feet of a road is only one of 

several reasons for selecting a 300 foot buffer along roads. The logic and rational for 

applying a 300 foot buffer along roads is described in appendix H, pgs. H-4 & H-5. 

Also see response to comment OW-11. 

OW-13

p-5 

Comment:

In its Sept 2012 appeal of the Umatilla NF’s South George Project, The Lands 

Council explained the problems with the purity doctrine that underpins the 300 foot 

buffer:
Tollgate Fuels Reduction Project FEIS

G-41

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Moreover, the FEIS states at H-3 that a 300 ft. boundary was set on each 

side of forest roads, further eliminating potential wilderness lands (Map H3), despite acknowledging that this criteria is inaccurate at H-3. This rigid 

application by the Forest Service has become known as the “purity 

doctrine,” in which any remote sign of past logging or road building will 

unequivocally preclude consideration of or recommendation for wilderness 

designation. There is, however, no foundation for such a rigid doctrine. 

First, the FSH uses the permissive “may” when it states that “[a]reas may 

qualify for the inventory of potential wilderness even though they include 

the following types of areas or features: (9) Timber harvest areas where 

logging and prior road construction are not evident ....” Forest Service 

Handbook, 1909.12, 71.11(9). The Forest Service, however, failed to 

include any area that has been subject to logging as mapped in the District’s 

GIS harvest layer and systematically applied a 300 ft. buffer around all 

roads. Second, the Wilderness Act does not contain language that 

unequivocally requires no past management activities: “with the imprint of 

man’s work substantially unnoticeable” an “area of underdeveloped Federal 

Land” (as opposed to undeveloped). 16 U.S.C. § 1131(c). Third, numerous 

wilderness areas have been designated where past logging and other 

management activities are present. Finally, and perhaps most importantly, 

Congress has expressly asked the Forest Service to abandon the “purity 

doctrine.” In a Senate Report from the Committee on Energy and Natural 

Resources regarding the Endangered American Wilderness Act of 1977, the 

Committee stated: “Generally, the committee believes that the so-called 

‘purity’ concept of wilderness long adhered to by the Forest Service, is 

unnecessarily restrictive and should be abandoned.” S. Rept. 95-490 on 

H.R. 3454. 95th Cong. 1st sess. October 11, 1977. As a result of the Forest 

Service’s rigid application of PWA criteria, 12,815 acres are not assessed 

under the Ninth Circuit’s requirement that roadless expanses are analyzed 

because of either “past timber harvest” or because “the boundary was set as 

300 feet each side of the forest roads” (FEIS at 3-183 and Table 3-82). 

Response:

The Forest Service considered all lands in the project area when following the 

established procedures for what areas qualify for inclusion in the inventory of PWAs. 

Procedures for identifying areas that qualify for inclusion in the inventory of PWAs 

comes from the National Forest Service Handbook (FSH) 1909.12, Chapter 70, 

Section 71, which are established by the Forest Service Washington Office, and apply 

to all national forest managed lands throughout the entire country. The procedures 

in Section 71 were followed (FEIS, Appendix H).
Tollgate Fuels Reduction Project FEIS

G-42

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

OW-14

p-6 

Comment:

The Forest Service should strive to be more consistent with it’s prior policies dating back 

to 1960 relating to identification of roadless and potential wilderness areas. Application of 

a 300 foot buffer is an unprecedented and divergent policy that demands great explanation. 

Region 6 needs to justify why is chooses to apply a 300 foot buffer, when other regions use 

much smaller buffers that basically extend just to the edge of the road or the road prism. 

Region 1’s Roadless Area Inventory Protocol (11/20/96) applies a 50’ buffer from the 

centerline of roads. Region 4’s Protocol for Identifying and Evaluating Areas for Potential 

Wilderness (10/28/2004) recommends a 33 foot buffer from the centerline of roads. The 

Tollgate DEIS must eliminate the large 300 foot buffers, and disclose how much logging is 

proposed in those areas.

Response:

The logic and rational for applying a 300 foot buffer along roads is described in 

appendix H, pgs. H-4 & H-5. This boundary is fully consistent with and supported by 

FSH 1909.12 inventory criteria. Also see response to comment OW-11. 

OW-15

p-6,7 

Comment:

Large trees are still rare and under-represented across the eastside. Removing large trees 

>21” dbh will reduce future recruitment of large trees and large snags and down wood. 

The FS should retain all large trees (except in infrequent cases where a shade-tolerant tree 

(21-26" dbh) is in direct competition (within the dripline) of an even larger shade-intolerant 

tree in dry forest types). 

Logging trees >21" dbh is also a violation of the forest plan as amended by the Eastside 

Screens and not allowed by plan-consistency clause of HFRA.

Response:

Your comment has been noted. However, we disagree with the claim that the project 

is in violation of HFRA. The Tollgate Fuels Reduction Project has been determined to 

be within or above HRV (Historic Range of Variability) for Moist Upland Forest and 

Dry Upland Forest. As such, there is no need for the development of a Forest Plan 

amendment to remove trees equal to or greater than 21 inches within the units 

identified in Chapter 1 of this FEIS. 

Additionally, we assert that the Tollgate project is consistent with the HFRA’s planconsistency clause because should the Responsible Official choose to implement the 

proposed Forest Plan amendments (Alternative B and C) the treatments proposed 

within RHCAs will be in compliance with the Umatilla NF LRMP, as amended, and 

as such meet the HFRA’s plan-consistency clause. 
Tollgate Fuels Reduction Project FEIS

G-43

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Should the Responsible Official choose not to implement the Forest Plan amendment 

with the selected alternative and thus the RHCA treatments would not occur and the 

project would still be in compliance with the Umatilla NF LRMP as detailed 

throughout Chapter 4 of the FEIS.

OW-16

p-7 

Comment:

In addition to protecting all large trees, we urge the FS to identify and retain all trees with 

old-growth characteristics even if they are less than 21” dbh. Old growth characteristics 

include thick bark, colored bark, flat top, asymmetric crown, broken top, forked top, 

relatively large branches, etc.

Response:

Your comment has been noted. 

OW-17

p-7 

Comment:

Logging in RHCAs is problematic for several reasons. Logging is not designed to protect 

and restore aquatic objectives as required by the forest plan as amended by PACFISH. The 

Forest Service can substantially meet fuel reduction objectives without logging in RHCAs. 

Any reduction in attainment of fuel reduction objectives by not logging 25 out of 4330 

acres is minor and insignificant. Furthermore, HFRA offers certain procedural shortcuts for 

fuel reduction projects, but Congress decided it is only appropriate to take those shortcuts 

when fuel reduction can be accomplish in compliance with the applicable forest plan, and it 

is not appropriate to take those shortcuts when fuel reduction is in conflict with forest plan 

requirements.

Response:

We agree that treatment of roughly 25 acres within RHCA buffer poses an 

insignificant effect, based on the disclosure of effects located in Chapter 4 this FEIS. 

Please see Purpose and Need located in Chapter 1 for the rationale for these proposed 

treatments.

OW-18

p-7 

Comment:

The DEIS admits that logging will be adverse to small streams but then minimizes this by 

saying that fish-bearing streams would not be affected. This is inconsistent with an 

ecosystem approach (which applies equal emphasis to fish as well as other organisms) and 

it is inconsistent with a watershed approach (which applies equal emphasis to both fish 

bearing streams and all headwater streams that flow into fish-bearing streams).
Tollgate Fuels Reduction Project FEIS

G-44

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Response:

Hydrologic effects analysis finds no affect to water temperature and an immeasurably 

small effect to sediment at the harvest unit, site specific scale. See FEIS pages 4-7to 4-

11 

OW-19

p-8 

Comment:

We urge the Forest Service to consider the restoration concepts, vision, priorities, and 

recommended prescriptions described in Tim Lillebo and Oregon Wild's Practical Guide 

for Ecological Restoration of Eastern Oregon's Dry Forests, available here: 

http://www.oregonwild.org/oregon_forests/old_growth_protection/eastsideforests/green%20book_online_lores.pdf including the lessons for successful restoration and 

recommendations for minimizing unintended consequences.

Response:

We are grateful for the reference and has taken it into consideration – particularly for 

Dry Upland Forest areas which may be directly or indirectly affected by the proposed 

activities. To put the reference in perspective, it may be helpful to note that the 

reference focuses on Dry Forest restoration, and only 141 acres, or 3.3% of the acres 

associated with activities proposed under Alternative B are classified as the Dry 

Upland Forest PVG (the values are 102 acres and 2.7%, respectively, for activities 

proposed under Alternative C) (page 4-26 of the Tollgate FEIS). As the reference 

itself states, it is not pertinent to fuels reduction activities occurring in moist or cold 

upland forest biophysical environments, which dominate the Tollgate planning area. 

As a result, this reference was not utilized in detail for most areas affected by 

activities proposed under Alternatives B and C, although, again, many of its general 

principles were incorporated to some degree in the proposed activities, to the extent 

that they were applicable and appropriate for site-specific conditions.

OW-20

p-8 

Comment:

The Forest Service should be creative in establishing diversity and complexity both within 

and between stands. “Patchy, gappy, and clumpy” is often use to describe the distribution 

of trees in dry forests. Use skips and gaps within units to help achieve diversity. Gaps 

should be small, while skips should be a little larger. Landings do not make good gaps 

because they are clearcut, highly compacted and disturbed, more likely subject to repeated 

disturbance, and directly associated with roads. Gaps should be located away from roads 

and should not be clearcut but rather should retain some residual structure in the form of 

live or dead trees.

Response:

This comment has been noted. 
Tollgate Fuels Reduction Project FEIS

G-45

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

In general, the current structural arrangement of trees and stands within and among 

the activity units already contain some gaps, as well as clumps of trees which would be 

retained for a variety of potential reasons (safety concerns, habitat mitigation 

measures, wind firmness, etc.). As a result, some activity units will lend themselves to 

a clumpy look after treatment simply because of the existing distribution of largediameter trees. Furthermore, existing disturbances (such as root rot infection and 

endemic levels of insect damage) will create and maintain small openings. In other 

cases, exceptionally dense stands affected by Non-Commercial Thinning (NCT) 

activities do not contain pre-existing skips and gaps to be utilized in a marking 

prescription. More conscious and deliberate efforts to create “skips and gaps” using 

variable-retention marking may be included within the marking guidelines at the 

discretion of a certified silviculturist and District Ranger. 

The possible direct and indirect effects of landings on soils is described within the 

FEIS on pages 4-1 through 4-6. 

OW-21

p-8 

Comment:

The prescription to remove dead-and-down wood (and the loss of dead wood recruitment 

from thinning in general, and the removal of trees >21" dbh in particular) raises some 

concerns because snags and down wood are critical components of old growth forests 

which are supposed to be restored in HFRA projects. The concern is heightened here 

because the Forest Service's current standards for dead wood are based on the outdated and 

discredited "potential population" methodology. 

Response:

The Tollgate project has its own standards for dead wood that go beyond the forest 

that meets and exceeds Forest Plan standards. No large snags will be removed unless 

they pose a hazard to workers. Occasionally dead trees 7-12 inches DBH will be 

removed in order to meet fuel objectives. Future snag recruitment will be retarded in 

thinned units, but snag density in the watershed analysis area and forest wide are 

similar to historic range of variability. The area will likely remain highly susceptible 

to insect and disease disturbance (page 4-36 2nd paragraph) with 67 % of the area tree 

density classed as “high density” (Table 4-13), which is well above HRV (Table 4-14). 

OW-22

p-8,9 

Comment:

The FS has previously admitted that --

Forest Plan standards were based on a model that did not account for snags required for 

foraging (EA p. 68 and Appendix K p. 45). There is general consensus in the scientific and 

professional community that using the biological potential model (which was used in 

developing the Forest Plan standard) is flawed and does not provide adequate nesting, 
Tollgate Fuels Reduction Project FEIS

G-46

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

roosting, or foraging structure for cavity excavating birds ...

North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project DN. 

http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/w

ww/nepa/53012_FSPLT2_055455.pdf 

Response:

The NEPA document repeatedly mentions that snag retention will exceed forest plan 

standards. No large snags will be removed by the project unless they pose a safety 

hazard. 

OW-23

p-9 

Comment:

Bull et al. (1997) states current direction for providing wildlife habitat on public forest 

lands does not reflect the new information available, which suggests that to fully meet the 

needs of wildlife, additional snags and habitat are required for foraging, denning, nesting, 

and roosting. Rose et al. (2001) suggests that calculation of numbers of snags required by 

woodpeckers based on assessing their “biological (population) potential” is a flawed 

technique (Rose et al. 2001) due to the fact that empirical studies are suggesting that snag 

numbers in areas used and selected by some wildlife species are far higher than those 

calculated by this technique. There is general consensus that the biological potential model 

does not provide adequate nesting, roosting, or foraging structure for cavity excavating 

birds (Bull et al. 1997, Johnson and O’Neil 2001). This suggests the current direction of 

managing for 100 percent population levels of primary excavators may not represent the 

most current knowledge of managing for cavity nesters. 

North Fork John Day RD, Umatilla NF. 2011. Mirage Vegetation Management Project EA, 

Appendix K – Terrestrial Wildlife Specialist Report. p K-45. 

Response:

See response to OW-21 and OW-22 

OW-24

p-9 

Comment:

The FS cannot "rely" on the outdated forest plan standards. By that we mean, the DEIS 

cannot include any language suggesting that meeting the old outdated snag standards will 

meet the needs of wildlife, because there is compelling evidence that it won't. DEIS pp 4-

79, 4-80, 4-82 repeatedly asserts that meeting forest plan standards for snags and green tree 

replacements will ensure population viability for pileated woodpecker and other primary 

cavity excavators. This is simply not supported by the best available science. Current 

science tells us that healthy forest ecosystems (and especially wildlife that depend on dead 

wood) need more snags dead wood than previously thought.
Tollgate Fuels Reduction Project FEIS

G-47

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Response:

It appears that you are confusing the forest plan consistency statement, which is 

different than forest plan standards for dead wood. Population viability is assessed at 

the forest scale, not the stand scale, and is based on the total amount of source habitat 

available. Harvested areas are assumed to no longer be source habitat for a period of 

time. See response to OW-21 and OW-22 

OW-25

p-9 

Comment:

The Eastside Screens require application of "best available science" with respect to dead 

wood. Failure to provide updated standards effecting amends the "best science" 

requirement right out of the Eastside Screens. Use of outdated standards for dead wood is 

therefore not allowed under HFRA. 

Response:

See response to OW-21 and OW-22 

OW-26

p-10 

Comment:

The FS must also refrain from excessive reliance on DecAID until it has been subject to 

NEPA review, and until it's many caveats are disclosed and considered, and until it is 

translated from mere information to actual policy. The FS cannot say that any particular 

DecAID tolerance level is adequate to support wildlife populations and legal requirements 

until the FS makes a policy decision pursuant to NEPA. The DEIS compares snag levels to 

"reference conditions" instead of comparing to the biological needs of wildlife. DecAID 

cautions that its reference conditions do not adequately represent areas of abundant snags 

such as post-fire conditions which are often important to wildlife. Even the DEIS analysis 

of effects on pileated woodpecker (p 4-79) does not disclose the effects of logging relative 

to DecAID tolerance levels or any other indicator of biological need. 

Eight large snags per acre supports only the 50% tolerance level of pileated woodpecker 

and less than a third of the project area currently provides that level of snags. The 

prescription is to retain only 3 large snags per acre and only 16 green tree replacements in 

most treated areas. This is not enough to support even the 50% tolerance level let alone the 

higher expectations implicit in the Eastside Screens' 100% potential population standard. 

Response:

All large snags will be retained wherever possible. This has been clarified in the final 

EIS. See page 2-4 and 2-19. 

DecAID does not recommend snag retention levels and makes no decisions. DecAID is 
Tollgate Fuels Reduction Project FEIS

G-48

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

used solely as a data information source. The viability of pileated woodpecker 

populations is addressed in the FEIS on page 4-79 to 4-82. 

OW-27

p-10 

Comment:

The DEIS (p 4-52) inappropriately minimizes the “infinitesimal” effects of logging on 

carbon storage and climate change. This is not appropriate. Our current problems with 

carbon and climate are not a problem brought upon us by an single actor or any single 

event at a specific location. It is instead the result of the cumulative effects of millions of 

decision by millions of people in millions of places around the world. This timber sale will 

transfer carbon from the forest to the atmosphere and it will contribute as much or more to 

the problem than other decisions like driving a pas-powered car or using electricity 

produced from coal to power our refrigerator. 

Response:

In response to this comment and other similar comments, the Forest Service took an 

additional very hard look at the climate change and carbon cycling discussion in the 

DEIS. We respectfully disagree with this comment in several ways. Contrary to the 

assertion of this comment, we do not assert that logging per se has minimal effects on 

carbon storage. In fact, because we recognize the growing interest among the general 

public in these topics, the DEIS includes an extensive summary of science findings 

with respect to the various Alternatives of the Tollgate project in the context of 

carbon cycling/climate change. Furthermore, on pages 4-52 and 4-53, the FEIS

analysis also places forest management (which includes timber harvest in addition to 

other forest disturbances such as land use conversion) in the context of all global 

emissions. 

With respect to the possible effects of the activities of this project in particular, the 

analysis in the DEIS is considered sufficient because the extent to which Alternatives 

A, B, or C of the Tollgate project may result in carbon emissions or sequestration 

(which has been recommended as a surrogate indicator for possible effects on global 

climate cycles by the Council on Environmental Quality) is analyzed in qualitative 

terms on pages 4-57 through 4-60. Again, following CEQ recommendations, the 

extent and detail of the analysis in the DEIS is intended to sufficiently inform decision 

makers and the public regarding the potentially significant effects in the context of 

the proposal for agency action. As the CEQ stated in a 2010 memorandum for the 

heads of federal departments and agencies: “CEQ expects agencies to ensure that 

such description is commensurate with the importance of GHG emissions of the 

proposed action, avoiding useless bulk and boilerplate documentation, so that the 

NEPA document may concentrate attention on important issues” (40 CFR 1502.5, 

1502.24). Because the precise direct and indirect effects of intermediate thinning 

treatments such as those proposed by the Tollgate project on carbon cycles are highly 

uncertain, but would have an almost imperceptibly small impact relative to global 

carbon emissions under even the most pessimistic scenarios, the Tollgate DEIS 
Tollgate Fuels Reduction Project FEIS

G-49

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

included a succinct but comprehensive discussion of the carbon-related effects 

relevant to the project and of interest to the public and decision maker.

Although the combined effects of millions of decisions by millions of people in millions 

of places around the world may have measureable and predictable effects on global 

climate, the Forest Service stands by its assertion that the direct and indirect effects of 

one single project such as the Tollgate Fuels Reduction project on global climate 

change or carbon emissions writ large are infinitesimal. And while the possible 

transfer of carbon from terrestrial to atmospheric pools over time can be described 

(and is qualitatively discussed on pages (4-57 through 4-60), the likely effects of this 

transfer on global climate change over the source of many decades or centuries is not 

predictable with any reasonable amount of accuracy, highly speculative, and 

essentially un-measureable. Furthermore, the extent to which the analyzed activities 

will likely tend to directly or indirectly emit or sequester greenhouse gases from both 

fossil deposits and the biosphere is, as was noted on page 4-60 of the DEIS, extremely 

uncertain and dependent upon a host of unpredictable, highly stochastic variables 

such as forest fires, insect outbreaks, and the alternative uses of building materials. 

The ranges of possible effects are discussed in qualitative terms useful to the project 

decision maker and the general public, but precise quantified emissions of metric tons 

of carbon indirectly resulting from the activities proposed under different alternatives 

is highly speculative, not commensurate with the importance of greenhouse gas 

emissions to the proposed action, and unnecessary to the application of the “rule of 

reason” to the decision-making process. The comment on the appropriateness of this 

determination has been noted. The use of “infinitesimal” is considered appropriate 

because while the value of possible carbon emissions associated with the Tollgate 

project is not zero, it is extremely small relative to global pools and fluxes. 

OW-28

p-10 

Comment:

The agency may argue that logging a few small patches of forest won’t make a difference 

in the global scheme of the climate problem, but as Voltaire said, "No snowflake in an 

avalanche ever feels responsible.” The NEPA analysis must recognize the global warming 

will not be solved by one miraculous technological fix or by changing one behavior or one 

economic activity. The whole global carbon cycle must be managed to reduce carbon 

emissions and increase carbon uptake. Recent evidence supports the conclusions that all net 

emissions of greenhouse gases are adverse to the climate. None can be considered de 

minimus. 

Response:

Your comment has been noted. We could not agree more with most these comments. 

The Forest Service deeply appreciates the need for attention to all sources of emitted 

greenhouse gases from a broad perspective of federal policy toward climate change, 

and is committed to overall reductions of greenhouse gas emissions over time through 

a variety of policy measures. However, in contrast to broad national climate change-
Tollgate Fuels Reduction Project FEIS

G-50

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

related policies and regulations, the agency is also committed at the project scale to 

following Council on Environmental Quality (CEQ) guidance to develop NEPA 

analysis at a depth and breadth commensurate with the expected effects of the project, 

in a manner that provides meaningful information to decision makers and the public. 

To that end, the Tollgate analysis provides (on pages 4-52 through 4-60) what we 

believe is a reasonable level of detailed analysis to inform public perceptions and 

allow reasoned decisions as listed on page 1-25 of the DEIS. 

At the same, we disagree that the DEIS states the analyzed activities “won’t make a 

difference in the global scheme of the climate problem.” To the contrary, the DEIS 

analyzes the likely effects of each alternative on carbon emissions (which is utilized as 

a surrogate for effects on climate change writ large, per CEQ direction), because 

carbon emissions, to the extent they may or may not occur as an effect, are recognized 

to contribute to the larger problem of climate change. We recognize the term 

“negligible” as used in the DEIS may give the mistaken impression that no such 

contribution could exist, and have improved the clarity of the terminology of this 

analysis for the FEIS. To the extent that scientific understanding allows, the analysis 

of the Tollgate DEIS on pages 4-52 through 4-60 identifies the likely effects of the 

project on greenhouse gas emissions as a reasonable surrogate for effects on global 

climate, places the intensity of expected emissions in the appropriate spatial and 

temporal context, and identifies key areas of uncertainty—which, in the case of the 

Tollgate project, are considerable.

OW-29

p-12 

Comment:

Every decision subject to NEPA should recognize climate change as a reasonably 

foreseeable event and should carefully consider and analyze the issue of climate change 

from two perspectives: first, the cumulative effects of the proposed action plus the 

anticipated effects of climate change on the resources directly and indirectly affected the 

proposal, and second the extent to which the proposed action will tend to mitigate or 

exacerbate climate change by directly or indirectly emitting or sequestering greenhouse 

gases from both fossil deposits and the biosphere. This will help meet the objectives of 

NEPA by leading to more informed decision-making at all levels of government.

Response:

The DEIS analyzes climate change from both perspectives suggested in this comment, 

with the first perspective (anticipated effects of climate change on the resources 

directly or indirectly affected by the proposal) addressed in the section titled 

“Compatibility with climate change mitigation and adaptation”(4-53) and the section 

titled “Climate change and HRV” (4-56). The second perspective is discussed in the 

section titled “Carbon cycling,” beginning page 4-57.

The Tollgate DEIS describes the likely cumulative impact (effects) of the project on 

past, present, and reasonably foreseeable future activities that overlap in space and
Tollgate Fuels Reduction Project FEIS

G-51

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

time with the expected direct and indirect of the project. Following guidance provided 

by CEQ’s NEPA regulations,1 the DEIS defines “cumulative impacts” as those that 

result from the incremental impact of the action when added to other past, present, 

and reasonably foreseeable future actions. In a memorandum for Heads of Federal 

Departments and Agencies, the CEQ interprets this regulation as “referring only to 

the cumulative impact of the direct and indirect effects of the proposed action or its 

alternatives when added to the aggregate effects of past, present, and reasonably 

foreseeable future actions (emphasis added). 

(www.nepa.gov/nepa/regs/Guidance_on_CE.pdf). 

The Tollgate FEIS accomplishes this by including a careful discussion of the 

incremental impact of the analyzed activities, added to the effects of climate change. 

OW-30

p-12 

Comment:

The Carbon Value of Wood Products Substitution is Over-estimated. The DEIS (p4-59 -

60) cites flawed science on the benefits of “substitution,” that is, using logging and wood 

instead of growing forests. The agency should avoid arguments that support logging and 

the alleged climate benefit of using wood as a substitute for alternative building materials. 

There may be some slight benefit from wood as a substitute but most of the analysis that 

tout this effect are produced by the timber industry with unreasonable assumptions that 

don’t stand up to scrutiny. 

o Substitution is speculative because the alleged benefits are in the distant future, and 

it takes more than a century to off-set the carbon emissions caused by logging 

forests. 

o Also, carbon benefits from substitution are typically realized in the distant future 

and must be discounted. 

o Many analyses start with bare ground instead of an existing forest, which biases the 

analysis because the carbon loss from logging are not accounted for. 

o Many analyses forget that wood already dominates the building material markets, 

and climate benefits would only be realized to the extent wood actually displaces 

other building materials, which is very difficult to show. People have a strong 

preference for wood houses, so less logging does not necessarily translate into 

more steel and cement houses. It’s virtually impossible to verify that a given wood 

product from a given harvest activity actually being used to substitute for steel and 

concrete.

 

1 40 C.F.R. §1508.7
Tollgate Fuels Reduction Project FEIS

G-52

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

o Using wood may delay, but does not prevent, fossil fuel use. 

o Carbon credits require “additionality.” Credit can only be given if the market share 

of wood increases relative to steel and concrete. This is unlikely. 

o A credible analysis of substitution must account for the time it takes to reabsorb the 

carbon after forests are logged, differences in the useful lifespan of different 

building materials, the improving carbon efficiency of the energy input used to 

make alternative building materials, the possibility of demand-side policies such as 

recycling and “demand reduction.” 

The agency should avoid bringing unsupported information into the NEPA process. The 

agency must give fair treatment to the merits of the competing ideas by disclosing the flaws 

and caveats associated with the substitution argument. 

Response:

These comments alleging flaws in the references cited describing possible effects of 

substituting wood products for other materials(such as steel or concrete) have been 

noted. Furthermore, the Forest Service agrees with some of the bullet points included 

in this comment, but does not agree that the points negate the technical accuracy of 

the points made regarding carbon substitution, or of the scientific claims suggested by 

the studies cited in the DEIS. The main point of the “substitution” paragraphs in the 

FEIS on pages 4-59 through 4-60 were to merely state that IF wood products are 

utilized for construction materials instead of other products with far higher 

associated greenhouse gas emissions (such as concrete or steel), the substitution could 

result in avoided emissions that would partially (if not completely, relative to an 

equivalent un-harvested forest with density-related mortality and decomposition) 

offset the emissions associated with decaying or burned activity residues (branches, 

limbs, etc.). 

Because the actual substitution effect is unpredictable (for many of the reasons 

suggested by this comment), it was merely described as a possible important variable 

influencing expected direct and indirect effects, and not used to justify any particular 

analysis alternative. Carbon emissions was not used in the analysis as an indicator of 

the extent to which any given alternative meets the project purpose and need or is 

consistent with applicable laws and regulations (Chapter 1 of the FEIS), and therefore 

it had no role in any kind of justification of activities. The Forest Service does not 

attempt to “support” logging using the possible carbon implications of materials 

substitution; rather, it is merely assessing the likely implications of building-material 

substitution (to the extent that it may or may not occur) on any possible effects of the 

alternatives under consideration on greenhouse gas emissions. Because this is done, in 

part, to assist the decision-maker with identification of any measures needed to 

mitigate adverse impacts on the quality of the human environment, this comment was 
Tollgate Fuels Reduction Project FEIS

G-53

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

utilized to add an additional statement for the FEIS that puts the likelihood of 

possible substitution in context. 

OW-31

p-15 

Comment:

Mastication should be minimized because can actually increase adverse fire effects as a 

result of concentrating fuels close to the ground. When masticated fuels do burn, the 

radiant heat can damage soil and kill trees via damage to crowns and roots.

Response:

Your comment is noted, and the Forest Service agrees that the residence time of 

burned masticated fuels can be harmful to the crowns and roots of trees. Mastication 

will be limited to areas where surface fuel loadings exceed Forest Plan standards, and 

where other means of fuel reduction are not feasible. Moreover, prescribed fire will 

not occur in areas that have been masticated.

Additionally, the assumption of this comment does not consider the ability of 

masticated fuels to collect and hold moisture, reducing the window for these fuels to 

burn in the manner described.

OW-32

Transmittal

Message

Comment:

Follow all HFRA requirements including collaboration, document compliance with the 

forest plan (including viewshed and big game requirements), fully restore and maintain old 

growth structure (including snags), retain all large trees, focus on the WUI (not miles 

away), focus on small hazardous fuels (recognizing that large wood is generally not a 

hazard, and canopy fuels are do not present a net hazard because any hazard presented by 

the canopy fuels is off-set by the fact that they help maintain a cool-moist-less-windy 

microclimate and help suppress future ladder fuels), etc.

Response:

Your comment has been noted. The procedures and policies established for HFRA 

authorized projects have been and continue to be followed. Compliance with the 

Umatilla National Forest Plan has been documented throughout Chapter 4 (and with 

discussions about proposed Forest Plan Amendment). Additionally, environmental 

effects on vegetative resources and fuels are identified throughout Chapter 4. 

OW-33

Transmittal 

Message

Comment:

Please consider an alternative that avoids commercial logging in unroaded areas 

and RHCAs, and applies a smaller diameter limit on fire tolerant species, and 

avoids impacts from road construction.
Tollgate Fuels Reduction Project FEIS

G-54

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

Response:

Per direction found within the Healthy Forest Restoration Act (HFRA) (Section 

104(d)(1)) areas that occur within the wildland-urban interface, but further than 1 1⁄2 

miles from the boundary of an at risk community, only the proposed action and an 

additional action alternative are required to be analyzed. 

The Tollgate project meets this requirement by analyzing two action alternatives 

(Alternatives B & C). As such, and in accordance with HFRA, no further alternatives 

were required and thus none were fully developed.

OW-34

Transmittal

Message

Comment:

We urge you to convert unit 38 in the Lookingglass IRA from commercial to noncommercial treatment.

Response:

Your comment has been noted. 

OW-35

Transmittal 

Message

Comment:

Non-commercial treatments should retain variability and clumps of trees, not just uniform 

20-foot spacing. 

Response:

Your comment has been noted. 

OW-36

Transmittal 

Message

Comment:

The EIS should carefully document the effects of reopening and using closed roads. Be 

sure to disclose the current condition of existing closed roads.

Response:

Your comment has been noted. Please see the environmental effects contained in 

Chapter 4 of this FEIS.

OW-37

Transmittal 

Message

Comment:

Avoid commercial logging in the inventoried roadless areas. In the IRA, consider using 

non-commercial methods to remove surface and ladder fuels as part of a comprehensive 
Tollgate Fuels Reduction Project FEIS

G-55

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

ecological restoration effort. Document compliance with the requirements of the roadless 

rule.

Response:

Compliance with the 2001 Roadless Area Conservation Rule (RACR) is disclosed on 

pages 4-125 to 4-129 of this FEIS. Your comment concerning the use of noncommercial methods for treatments within the inventoried roadless area (IRA) have 

been noted.

OW-38

Transmittal 

Message

Comment:

Avoid impacts to RHCAs. Concerns about fuel hazard should not trump the need to protect 

and restore riparian and aquatic conditions. 

Response:

Your comment has been noted. Environmental effects associated with proposed 

treatments within RHCAs are located in Chapter 3 of this FEIS (Hydrology section 

pages 4-6 to 4-16, Fisheries section pages 4-16 to 4-26, Fuels section pages 4-61 to 4-

67).

OW-39

Transmittal 

Message

Comment:

Consider impacts of logging on the unique and special characteristics of uninventoried 

unroaded areas that are greater than 1,000 acres or unroaded areas that area directly 

adjacent and contiguous with the IRAs and North Fork Umatilla wilderness area. 

Response:

Environmental effects of proposed actions for both alternatives B and C relating to 

wilderness, inventoried roadless areas (IRA), potential wilderness areas (PWA), and 

other undeveloped lands are disclosed on pages 4-102 to 4-120 of the FEIS.

OW-40

Transmittal 

Message

Comment:

GENERAL RECOMMENDATIONS FOR FUELS REDUCTION 

THINNING/RESTORATION

1. When conducting commercial thinning projects take the opportunity to implement other 

critical aspects of watershed restoration especially reducing the impacts of the road system 

and livestock grazing and establishing the ecological processes that foster recovery of 

hydrologic systems and fire regimes. See FEMAT 1993. Appendix V-J: Guidelines for 

Restoration Projects (unnumbered pages between V-96 and VI-1). Bradbury, Nehlsen et al 
Tollgate Fuels Reduction Project FEIS

G-56

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

1995. Handbook for Prioritizing Salmon & Watershed Restoration. 

http://www.salmonhabitat.org/library/bradbury_et_al.pdf 

2. Use scarce resources efficiently by striving to restore ecological processes that can be 

self-sustaining; don’t waste too much effort restoring forest structure which requires 

continuous expenditure of money and effort to maintain. Reed F Noss, Jerry F Franklin, 

William L Baker, Tania Schoennagel, and Peter B Moyle. 2006. Managing fire-prone 

forests in the western United States. Front Ecol Environ 2006; 4(9): 481–487. 

http://spot.colorado.edu/~schoenna/images/Nossetal2006Frontiers.pdf Crist, M.R., T.H. 

DeLuca, B. Wilmer, and G.H. Aplet. 2009 Restoration of Low-Elevation Dry Forests of the 

Northern Rocky Mountains: A Holistic Approach. Washington, D.C.:The Wilderness 

Society.

3. Use projects as an opportunity to conduct monitoring and research on the effects of 

thinning. There are many information gaps that need filling. Every project should generate 

useful information to inform future projects.

4. Treated stands do not existing in isolation, so be sure to consider the effects of thinning 

on adjacent areas which may provide habitat for species of concern. Prepare a “risk map” 

based on proximity to different habitat types from high quality to non-habitat.

5. Only a small subset of needed restoration activities are “profitable,” so we can’t let 

logging economics determine restoration priorities. If we restore primarily those areas that 

have commercial sized logs and fail to treat the thousands of acres of areas that need 

restoration but lack economic return, we will not be accomplishing real restoration which 

requires carefully and strategically choosing the subset of the landscape that can be treated 

to provide the greatest gain (both ecological and fire hazard reduction) for the least 

ecological “cost” in terms of soil, water, wildlife, carbon, and weeds. “Hoping to boost 

their economies and also restore these forests, local leaders are interested in the economic 

value of timber that might be available from thinning treatments on these lands. ... [W]e 

found that on lands where active forestry is allowable, thinning of most densely stocked 

stands would not be economically viable.” Rainville, Robert; White, Rachel; Barbour, 

Jamie, tech. eds. 2008. Assessment of timber availability from forest restoration within the 

Blue Mountains of Oregon. Gen. Tech. Rep. PNW-GTR-752. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 65 p. 

http://www.fs.fed.us/pnw/pubs/pnw_gtr752.pdf Allowing economics to drive these choices 

will result in greater ecological impacts and lower ecological gains. The NEPA analysis 

must honestly disclose what optimum restoration treatments would look like versus what is 

actually being proposed, so the public can see what’s being sacrificed.

6. Thinning should focus on areas accessible from existing roads. Building new roads will 

cause degradation that typically erases any any alleged benefit of treatments.

7. Use the historic range of variability as a guide, but don’t just focus on seral stage. 

Consider also the historic abundance of ecological attributes like large trees, large snags, 

roadless areas, etc. all of which have been severely reduced from historic norms. Also, 
Tollgate Fuels Reduction Project FEIS

G-57

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

consider the natural range of variability, which is the historic range of variability as 

modified by future climate change. James A. Harris, Richard J. Hobbs, Eric Higgs, and 

James Aronson. 2006. Ecological Restoration and Global Climate Change. Restoration 

Ecology Vol. 14, No. 2, pp. 170–176 JUNE 2006. 

http://www.globalrestorationnetwork.org/uploads/files/LiteratureAttachments/353_underlyi

ngprinciples-of-restoration.pdf 

8. Develop restoration treatments appropriate to each forest type or plant association group 

(PAG). Dry Ponderosa pine forests that have significant ingrowth due to fire exclusion are 

good candidates for thinning. Mixed-conifer forest types often included some dense forest 

patches, so they should be retained at appropriate scales. Lodgepole pine and subalpine 

forests have stand replacing fire regimes and generally do not need to be thinned. 

9. Prioritize treating stands that are already degraded by past logging, and place less 

priority on treating unlogged forests. See Naficy, Cameron, Anna Sala, Eric G. Keeling, 

Jon Graham, and Thomas H. DeLuca. 2010. Interactive effects of historical logging and 

fire exclusion on ponderosa pine forest structure in the northern Rockies. Ecological 

Applications 20:1851-1864. 

http://rintintin.colorado.edu/~cana4848/papers/Naficy_et_al_2010_Ecol_App.pdf (“We 

document that fire-excluded ponderosa pine forests of the northern Rocky Mountains 

logged prior to 1960 have much higher average stand density, greater homogeneity of stand 

structure, more standing dead trees and increased abundance of fire-intolerant trees than 

paired fire-excluded, unlogged counterparts. Notably, the magnitude of the interactive 

effect of fire exclusion and historical logging substantially exceeds the effects of fire 

exclusion alone. These differences suggest that historically logged sites are more prone to

severe wildfires and insect outbreaks than unlogged, fire-excluded forests and should be 

considered a high priority for fuels reduction treatments.”) 

10. Prioritize treating dry forest types at low elevation and on south slopes. Treatments in 

forests with naturally mixed-severity fire regimes should be carefully scrutinized to ensure 

those areas (i) are in fact outside of the HRV, and (ii) treatment will not remove scarce 

habitat for focal species that depend on dense forests, and (iii) treatments are in fact needed 

and (iv) proposed treatments will be effective. Treatments in mixed severity fire regimes 

should be more patchy and leave behind more structure, more snags and large dead wood. 

11. New evidence indicates that far more of the “dry” forests, rather than being typified low 

severity fire regimes, were in fact dominated by mixed severity fire regimes (including 

significant areas of stand replacing fire), so mixed severity fire is an important part of the 

historic range of variability that should be restored. The goal should not be a uniform low 

severity fire regime, but rather a wide mix of tree densities in patches of varying sizes. This 

objective can often be met by allowing natural fire regimes to operate, or by leaving 

significant areas untreated when planning fuel reduction projects. Hessburg, Paul. 

Evidence for the Extent of Mixed Severity Fires in Pre-Management Era Dry Forests of the 

Inland Northwest. Proceedings: Mixed Severity Fire Regimes: Ecology and Management. 

November 17–19, 2004. Spokane, Washington.
Tollgate Fuels Reduction Project FEIS

G-58

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

http://emmps.wsu.edu/fire/secondary/PROCEEDINGS.html#Abstracts/Hessburg.html; 

Baker, W.L., T.T. Veblen and R.L. Sherriff (2006). Fire, fuels, and restoration of 

ponderosa pine-Douglas-fir forests in the Rocky Mountains, USA. Journal of 

Biogeography. 2006. 

12. Treatments in the wildland urban interface may also be a priority, but don’t define the 

WUI too broadly, because fire hazard can be reduced by treating the area immediately 

adjacent to structures and this home ignition zone is usually on non-federal lands. The WUI 

fire problem should be framed as a home ignition problem and the solution for that lies 

with the private property owners. Cohen 2008. The Wildland-Urban Interface Fire Problem 

– A Consequence Of The Fire Exclusion Paradigm. Forest History Today. Fall 2008. 

http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf Fuel treatments in 

the WUI should be coupled with efforts to make communities fire resilient, not just to 

facilitate fire suppression.

13. Prioritize treatment of the dense young stands that are most "plastic" and amenable to 

restoration. Another priority is to carefully plan and narrowly target treatments to protect 

specific groves of fireresistant, old-growth trees that are threatened by ingrowth of small 

fuels, but don’t focus on rigid density reduction targets. Leave all medium and large trees 

that show old-growth characteristics.

14. Thin from below, retaining the largest trees, or use “free thinning” with a diameter cap 

so that some trees of all size classes are retained. Retain all large trees and most medium 

sized trees so they can recruit into the larger classes of trees and snags.

15. Identify and retain all trees with old-growth characteristics even if they are less than 

21” dbh. Old growth characteristics include thick bark, colored bark, flat top, asymmetric 

crown, broken top, forked top, relatively large branches, etc. These trees have important 

habitat value and human values regardless whether they are 21” dbh. Allow natural 

processes of succession and mortality turn some of these medium and large trees into 

ecologically valuable snags and down wood. The agencies often use this technique to 

identify and retain old-growth juniper trees and the same can be used to protect old growth 

pine, larch, Douglas fir and other species. Van Pelt, R. 2008. Identifying Old Trees and 

Forests In Eastern Washington. Washington DNR. 

http://www.dnr.wa.gov/Publications/lm_ess_eastside_oldgrowth_guide.pdf. A recent study 

supports the retention of slow growing old trees because they are relatively more resilient. 

Thestudy found that slower-growing older trees tend to channel their energy into structural 

support and defense compounds to “maximize durability while minimizing ... damage”. 

Colbert & Pederson. 2008. Relationship between radial growth rates and lifespan within 

North American tree species. Ecoscience 15(3), 349-357 (2008). 

http://www.ecoscience.ulaval.ca/catalogue/FA3149-black.pdf 

16. Remember that diameter limits are a tool in the tool box. Don’t reject the tool out of 

hand. The public supports the use of diameter limits because it provides a means to prevent 

economic values from trumping ecological values. It is often appropriate to use lower 
Tollgate Fuels Reduction Project FEIS

G-59

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

diameter limits for fire tolerant species like Ponderosa pine and Douglas fir, while using 

higher limits for fire intolerant species like grand fir/white fir. The exceptional 

circumstances in which diameter limits allegedly don’t work, are more rare than the 

circumstances in which refusing to use diameter limits will lead to unintended 

consequences, including removal of ecologically valuable trees and lack of public trust.[1] 

17. Recognize that thinning affects fire hazard in complex ways, including some tendencies 

to make fire hazard worse. The agency must address the fact that thinning creates slash; 

moves fine fuels from the canopy to the ground (increasing their availability for 

combustion); thinning increases ignition risk (by increasing human access and human 

activities, including spark-generating machine); thinning makes the forest hotter-dryerwindier; and makes site resources available to stimulate the growth of future surface

and ladder fuels. Amy E.M. Waltz, Peter Z. Fulé, W. Wallace Covington, and Margaret M. 

Moore. 2003. Diversity in Ponderosa Pine Forest Structure Following Ecological 

Restoration Treatments. Forest Science 49(6) 2003. 

http://www.globalrestorationnetwork.org/uploads/files/LiteratureAttachments/91_diversityin-ponderosa-pine-foreststructure-following-ecological-restoration-treatments.pdf; 

Kaufmann M.R., G.H. Aplet, M. Babler, W.L. Baker, B. Bentz, M. Harrington, B.C. 

Hawkes, L. Stroh Huckaby, M.J. Jenkins, D.M. Kashian, R.E. Keane, D. Kulakowski, C. 

McHugh, J. Negron, J. Popp, W.H. Romme, T. Schoennagel, W. Shepperd, F.W. Smith, E. 

Kennedy Sutherland, D. Tinker, and T.T. Veblen. 2008. The status of our scientific 

understanding of lodgepole pine and mountain pine beetles – a focus on forest ecology and 

fire behavior. The Nature Conservancy, Arlington, VA. GFI technical report 2008-2. 

http://www.fs.fed.us/r6/umpqua/projects/projectdocs/d-bug-ts/lpp-mpb-fire-2008-status-ofscience-unillustrated-versionkaufmann-et-al.pdf. Fuel reduction must find the “sweet spot,” 

by removing enough of the small surface and ladder fuels while retaining enough of the 

medium and large trees to maintain canopy cover for purposes of microclimate, habitat, 

hydrology, suppression of ingrowth, etc.

18. Fire-regime condition-class may not be an accurate predictor fire hazard, because it 

assumes incorrectly that time-since-fire is an accurate indicator of fire hazard. There is 

compelling evidence that time-sincefire has exactly the opposite of the assumed effect, that 

is, fires may burn more severely in early seral vegetation, and burn less severely in closed 

canopy forests. This may be related to the fact that closed canopy forests maintain a coolmoist microclimate that helps retain higher fuel moisture and more favorable fire behavior. 

Odion, D.C., E.J. Frost, J.R. Strittholt, H. Jiang, D.A. DellaSala and M.A. 

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

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

http://nature.berkeley.edu/moritzlab/docs/Odion_etal_2004.pdf Canopy cover also helps 

suppress the growth of ladder fuels. The practical significance of this is that the agency 

when thinning should retain more canopy variably across the stand and should not focus on 

treatment of canopy fuels except to provide some well-spaced “escape hatches” for hot 

gases generated by surface fires. Credible models of post-thinning fire behavior, must 

account for both fuel structure and microclimate effects of thinning. 
Tollgate Fuels Reduction Project FEIS

G-60

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

19. Fuel treatments without regular follow-up treatments might be worse than doing 

nothing at all because thinning can be expected to stimulate the growth of future surface 

and ladder fuels. Crystal L. Raymond. 2004. The Effects of Fuel Treatments on Fire 

Severity in a Mixed-Evergreen Forest of Southwestern Oregon. MS Thesis. 

http://depts.washington.edu/nwfire/publication/Raymond_2004.pdf; Jonathan R. 

Thompson, Thomas A. Spies 2009. Vegetation and weather explain variation in crown 

damage within a large mixed-severity wildfire. Forest Ecology and Management 258 

(2009) 1684–1694. Therefore retain plenty of canopy cover to suppress the growth of those 

future fuels and as insurance against the very real possibility that follow-up fuel treatments 

may not be adequately funded and implemented. 

20. There is growing evidence that in order to be effective, mechanical treatments must be 

followed by prescribed fire. But the effects of such fires must also be carefully considered.

21. Don’t thin to uniform spacing. Use variable density thinning techniques to establish a 

variety of microhabitats, break up fuel continuity, create discontinuities to disrupt the 

spread of other contagious disturbances such as disease, bugs, weeds, fire, etc. Retain 

patchy clumps of trees which is the natural pattern for many species.

22. Use your creativity to establish diversity and complexity both within and between 

stands. “Gappy and clumpy” is often use to describe the distribution of trees in dry forests. 

Use skips and gaps within units to help achieve diversity. Gaps should be small, while 

skips should be a little larger. Landings do not make good gaps because they are clearcut,

highly compacted and disturbed, more likely subject to repeated disturbance, and directly 

associated with roads. Gaps should be located away from roads and should not be clearcut 

but rather should retain some residual structure in the form of live or dead trees.

23. Thin heavy enough to stimulate development of some patches of understory vegetation, 

but don’t thin so heavy that future development of the understory becomes a more 

significant fuel problem than the one being addressed by the current project. 15-20 years 

after thinning and prescribed fire, the Umpqua NF found “considerable development of less 

fire tolerant understory vegetation .... Continued stand development ... will result in 

increased understory density and and fuel laddering into the dominant fire tolerant 

overstory...” Umqua NF, Dimaond Lake RD, Lemolo Pine Health Maintenance Burn 

Project, June 1, 2010 scoping notice. 

24. The scale of patches in variable density thinning regimes is important. Ideally 

variability should be implemented at numerous scales ranging from small to large, 

including: the scale of tree fall events; pockets of variably contagious disturbance from 

insects, disease, and mixed-severity fire; soil-property heterogeneity; topographic 

discontinuities; the imprint of natural historical events; etc.

25. Retain and protect under-represented species of conifer and non-conifer trees and 

shrubs. Retain patches of dense young stands as wildlife cover and pools for recruitment of 

future forests.
Tollgate Fuels Reduction Project FEIS

G-61

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

26. Recognize that thinning captures mortality and that most stands (especially plantations) 

are already lacking critical values from dead wood due to the unnatural stand history of 

logging, planting, and disrupted natural processes.[2] To inform the decision, please 

conduct a stand simulation model showing that long term snag recruitment (after logging) 

will still meet DecAID 50-80% tolerance levels.

27. Retain abundant snags and course wood and green trees for future recruitment of snags 

and wood. Retention should be both distributed and in clumps so that thinning mimics 

natural disturbance. Retention of dead wood should generally be proportional to the 

intensity of the thinning, e.g., heavy thinning should leave behind more snags not less. 

Retain wildlife trees such as hollows, forked tops, broken tops, leaning trees, etc. Think not 

only about existing snags but more importantly about the processes the recruit snags, 

including: a large pool of green trees from which to recruit snags and the existence of 

competition and other mortality processes. Logging will significantly harm both of these

snag recruitment factors. Recognize that thinning captures mortality. To inform the NEPA 

decision, please conduct a stand simulation model to fully disclose the adverse effects of 

logging on dead wood, especially long-term recruitment of large snags >20” dbh, and then 

mitigate for these adverse effects by identifying areas within treated stands and across the 

landscape that will remain permanently untreated so they can recruit adequate large snags 

and dead wood to meet DecAID 50-80% tolerance levels as soon as possible and over the 

long-term.

28. If using techniques such as whole tree yarding or yarding with tops attached to control 

fuels, the agency should top a portion of the trees and leave the greens in the forest in order 

to retain nutrients on site. 

29. Avoid impacts to raptor nests and enhance habitat for diverse prey species. Train 

marking crews and cutting crews to look up and avoid cutting trees with nests of any sort 

and trees with defects.

30. Take proactive steps to avoid the spread of weeds. Avoid and minimize soil 

disturbance. Retain canopy cover and native ground cover to suppress weeds. 

31. Buffer streams from the effects of heavy equipment and loss of bank trees and trees that 

shade streams. Mitigate for the loss of LWD input by retaining extra snags and wood in 

riparian areas. Recognize that thinning captures mortality that is not necessarily 

compensated by future growth.[3] 

32. Protect soils by avoiding road construction, minimizing ground-based logging, and 

avoiding numerous large burn piles. Rank new road segments according to their relative 

costs (e.g. length, slope position, soil type, ease of rehabilitation, weed risk, native 

vegetation impacts, etc.) and benefits (e.g. acres of restoration facilitated), then use that 

ranking to consider dropping the roads with the lowest ratio of benefits to costs. Once you 

have determined the relative acres accessed per mile of road construction, you can take the 
Tollgate Fuels Reduction Project FEIS

G-62

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

analysis one step further, to determine the “effective road density” of each segment? In 

other words, extrapolate as if that much road were required to reach each acre of the 

planning area, then compare the resulting road density to standards for big game, 

cumulative hydrological impact, etc? For example, if a new spur road accesses thinning 

opportunities at a rate of 200 acres of forest per mile of road, then divide 640 acres per 

section by 200 acres per mile to determine the effective road density of 3.2 mi/mi2. Where 

road building is deemed necessary, ensure that the realized restoration benefits far 

outweigh the adverse impacts of the road, build the roads to the absolute minimum 

standard necessary to accomplish the job, and remove the road as soon as possible to avoid 

firewood theft, OHV trespass, and certainly before the next rainy season to avoid 

stormwater pollution. Do not allow log hauling during the wet season. 

33. There is a carbon cost associated with thinning that must be disclosed and considered. 

As stands develop from young to mature to old, they continuously recruit carbon-rich 

material from the live tree pool to the dead wood pool. Some of that wood gets 

incorporated into the soil or falls in fire refugia where it can accumulate. Logging, even 

thinning, can dramatically affect the accumulation of carbon in the dead wood pool by 

capturing mortality, diverting it from the forest, and accelerating the transfer of carbon to 

the atmosphere. Carbon stays out of the atmosphere much longer if it remains in the forest 

as live and/or dead trees, instead of being converted to wood products and industrial and 

consumer waste.

34. If this project involves biomass utilization, the impacts need to be clearly disclosed. 

How will the biomass be moved from the remote corners of the treatment areas to the 

landings? Will there be extra passes made by heavy equipment? Will the landings be 

enlarged to make room for grinders, chip vans, and other equipment? Can the local forest 

roads accommodate chip vans? Will the roads be modified to make them passable by chip 

vans? What are the impacts of that? What are the direct, indirect, and cumulative impacts 

on soil, water, wildlife, and weeds? 

35. Acknowledge and consider the following potentially significant issues in the NEPA 

analysis:

a. Removing commercial sized logs, and associated roads and slash disposal, often 

conflicts with other resource values such as soil, water, weeds, wildlife habitat, fire hazard, 

and carbon storage;

b. Removal of commercial sized logs can make the stand hotter, dryer, and windier, making 

fire hazard worse instead of better;

c. Commercial logging tends to present significant risks of weed infestations because of 

soil disturbance and canopy reduction; 

d. Removal of commercial logs necessitates road related impacts on soil and water 

resources. Machine piling and pile burning tend to cause significant adverse impacts on soil 
Tollgate Fuels Reduction Project FEIS

G-63

Letter #9 

Doug Heiken- Oregon Wild (OW)

Comment 

Number Comment and Response

and water, especially when combined with road impacts and other logging disturbances.

e. “Capturing mortality” reduces future snag habitat that is already deficient. Increasing 

vigor via thinning delays recruitment of snag habitat that is already deficient;

f. The unavoidable adverse impacts of logging and roads must be balanced against the 

rather uncertain benefits of fuel reduction. Fuel reduction has little or no beneficial effect 

on low severity fires (controlled by favorable weather conditions) or on high severity fires 

(controlled by unfavorable weather conditions). There is actually a very low probability 

that moderate intensity fire will affect any given stand during the relatively brief time 

period that fuel hazard is alleged to be reduced. Please disclose the realistic probability that 

desired outcomes will occur based on (1) 

whether fire is likely to occur when the fuel treatments are likely to be effective, and (2) if 

fire does occur, whether there will be a good match between (A) the actual forest type and 

fuel treatment type, and (B) the actual probability of favorable weather conditions and fire 

conditions for that forest type and treatment type. Depending on these variables, fuel 

treatments may have little influence on both low intensity fire and extreme high intensity 

fire, leaving only a small subset of well-matched fuel treatments and fires, and a low 

probability that the proposed treatments will have ecological benefit s that exceed 

ecological impacts.

g. The effects of forest health thinning are very complex with many feedback loops. There 

is still a fair amount of scientific uncertainty about several critical factors relevant to a 

decision about fuel reduction, including: (A) uncertain rates of tree mortality and how 

many young trees need to be retained to ensure proper recruitment of future stands of old 

trees and large snags; (B) uncertainty about how much the canopy can be reduced without 

making the stand hotter, dryer, and windier (and exacerbating fire hazard); (C) uncertainty 

whether logging has any significant beneficial effect on controlling insects and diseases 

like mistletoe.

Response:

Your comment has been noted. 

Letter #10 

Christine B. Reichgott- U.S. Environmental Protection Agency Region 10 (EPA)

Comment 

Number Comment and Response

EPA-1

p-1 

Comment:

This review was conducted in accordance with our responsibilities under the 

National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act. 

Under our policies and procedures, we evaluate the environmental impacts, and the 
Tollgate Fuels Reduction Project FEIS

G-64

Letter #10 

Christine B. Reichgott- U.S. Environmental Protection Agency Region 10 (EPA)

Comment 

Number Comment and Response

adequacy of the EIS in meeting procedural and public disclosure requirements of 

NEPA.

Response:

Thank you for your review.

EPA-2

p-1 

Comment:

The overall message in our November 18, 2010 scoping comments was that the Project’s 

environmental consequences would be closely aligned with the extent to which wildlife 

risk reduction activities would enhance or degrade ecosystem functions. We have been 

especially interested in effects- particularly to water temperature-of fuels treatment in 

Riparian Habitat Conservation Areas. The DEIS’s effects analysis for water temperature is 

fully responsive to our interest and we agree with the Forest’s conclusion that, “The 

combination of local ground water influence, limited removal of streamside shade, and low 

volume of flow would protect downstream water temperature from any effects of thinning 

in the RHCAs of these units.” (p. 4-9)

Response:

Thank you for your supportive comment.

EPA-3 

p-1 

Comment:

While our review has not identified any potential environmental impacts requiring 

substantive changes to the proposal, we recommend that the Forest continue to 

explore incorporating principles of ecological forestry into project harvest 

prescriptions. 

Response:

Your comment has been noted.

EPA-4

p-2 

Comment:

To address uncertainty regarding whether a Clean Water Act National Pollution Discharge 

Elimination System permit may be required for stormwater discharges from logging roads 

we offer the following:

On December 23, 2012, Congress passed a temporary prohibitation against the 

EPA’s ability to require NPDES permits for discharges from logging roads, until 

September 30, 2012. 125 Stat. 1046, Pub. L. 112-74 (December 23, 2011). The 

Fiscal Year 2013 Continuing Resolution extended the prohibition until March 27, 
Tollgate Fuels Reduction Project FEIS

G-65

Letter #10 

Christine B. Reichgott- U.S. Environmental Protection Agency Region 10 (EPA)

Comment 

Number Comment and Response

2013. Pub. L. No. 112-175 (Sept. 28. 2012).

The EPA issued a final rule in the Federal Register on December 7, 2012, revising 

its Phase I stormwater regulations at 40 C.F.R 122.26 to clarify that stormwater 

discharges from logging roads do not constitute stormwater discharges associated 

with industrial activity and that NDPES permits are not required for these 

stormwater discharges (77 FR 72920) 

Forthcoming litigation and court decisions, including the Supreme Court’s opinion 

in Decker v. Northwest Environmental Defence Center and Georgia Pacific v. 

NEDC (nos. 11-347 and 11-338), expected in June 2013; and possible challenges 

to EPA’s December 2012 rule; could affect future permit requirments for logging 

roads. 

Response:

Thank you for your suggestion. At the time of the publication of the DEIS the 

Supreme Court had not issued a decision in this case. On March 20, 2013 the U.S. 

Supreme Court reversed the 9th circuit court’s decision on roads associated with 

timber harvest on the basis of EPA’s interpretation of the stormwater rule. Logging 

roads are therefore not considered to produce pollutant discharge that require pointsource discharge permits because they are not associated with categories of industrial 

activities directly related to industrial plants 

EPA-5

p-2 

Comment: 

Based on our review we have assigned the DEIS a rating of LO (Lack of Objections). 

Response:

Thank you for your review.

Letter #11 

Irene Jerome- American Forest Resource Council (AFRC)

Comment 

Number Comment and Response

AFRC-1

p-1 

Comment:

AFRC supports the Purpose and Need for this project and endorses the use of 

HFRA authorities- Tollgate is exactly the type of project these authorities were 

designed for. 
Tollgate Fuels Reduction Project FEIS

G-66

Letter #11 

Irene Jerome- American Forest Resource Council (AFRC)

Comment 

Number Comment and Response

Response:

Your comment has been noted. 

AFRC-2

p-1 

Comment:

Recognizing that the “purpose” of Tollgate is to implement actions that reduce the 

probability and potential extent of active crown fire within the Tollgate WUI and the 

“needs” consist of unsafe conditions for fire fighters in the Tollgate area as well as 

vegetation and fuels that are extremely heavy and departed from historical conditions, there 

is also a critical need in this region to maintain the current existing forest products 

infrastructure. The forest products infrastructure is essential to implementation of projects 

such as Tollgate, which is not a unique situation on the Umatilla National Forest. 

Maintenance of the current existing forest products infrastructure is a key issue since there 

will be no forest restoration without it.

Response:

Please see response to BC-5 above. 

AFRC-3 

p-2 

Comment:

The size and scope of the planning and analysis area is 46,000 acres with 21,000 of 

those acres that are in the WUI. Recognizing there are different management areas 

with various associated standards and guidelines within those 21,000 acres it is still 

inconceivable that only 4330 acres will receive on the ground treatment.

Response: 

Thank you for your comment. Please see response to comment BC -2. 

AFRC-4

p-2 

Comment:

Conditions in the planning area meet or exceed HRV conditions in the Dry Forest and Cool 

Moist Forest vegetation groups which provide significant opportunity for treating various 

areas, especially those where the condition class is at the moderate or extreme level. Tree 

stocking density tables in the DEIS also indicate that current densities meet or exceed 

historical conditions. How did the forest arrive at the specific areas to be treated as a part 

of the Tollgate project?

Response:

Thank you for your comment. Please see response to comment BC -2. 
Tollgate Fuels Reduction Project FEIS

G-67

Letter #11 

Irene Jerome- American Forest Resource Council (AFRC)

Comment 

Number Comment and Response

AFRC-5

p-2 

Comment: 

The economic analysis presented on Tollgate is not adequate. Alternative C has a slightly 

higher net present value than Alternative B because “Alternative B treats more acres and 

removes trees larger than 21 inches and uses more expensive logging systems”. However, 

there is no more clarification on the details of this statement. In my experience more acres 

and larger trees generally lead to a better economic recovery. Please clarify this section.

Response:

The additional acres treated in Alternative B require additional landings to be built, 

resulting in more cost. The volume per acre in these additional acres is less, thus 

resulting in more cost to treat these additional acres.

AFRC-6

p-2 

Comment:

AFRC supports the proposed treatment in the RHCAs as this is the key to creating 

ecological complexity in these areas and nothing is well served if these areas burn. Often 

riparian areas act as “chimneys” or “fuses” due to the excessive heavy fuel loads left in 

these areas if fire comes through. Obviously not all stand replacing fire is “bad” as 

described in the DEIS, however the “template” and “one-size fits all” approach that the 

forest service is directed to use. I would suggest that this treatment in the RHCAs provides 

a good opportunity for some monitoring that would provide information for better informed 

site specific decisions in the future. The Umatilla collaborative group would be ideal to 

sponsor both pre-implementation and post-implementation monitoring projects on Tollgate.

Response:

Your comment has been noted. 

AFRC-7

p-2 

Comment:

A chart provided in the documentation indicates that participants in the collaboration 

process as a part of the Community Wildfire Protection Plan (CWPP) plan evaluating 

issues in the WUI ranked 1) Fuel treatments in mature stands, 2) Access/Egress route 

protection and hazard tree treatment, and 3) Treatment in stands adjacent to private lands as 

High Priority. As a result of this support, I would ask that the forest clarify how and why 

each area was identified for treatment.

Response:

The areas proposed for treatment were identified based on professional judgment, 

computer modeling, and guidance for implementation of HFRA authorized actions.
Tollgate Fuels Reduction Project FEIS

G-68

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

HCPC-1

p-1 

Comment: 

The aim of this project – to reduce the probability and potential extent of a 

wildfire within the Tollgate Wildland Urban Interface (WUI) – is one that 

HCPC strongly supports. However, the fuel reduction activities undertaken to 

achieve that goal must be scientifically based and tailored to the specific ecology 

of the project area and surrounding forest. 

Response:

Your comment has been noted. 

HCPC-2

p-1 

Comment:

The selected alternative is not scientifically based or tailed to the unique ecology 

of the project area. Rather, it proposes commercial logging activities that will 

fail to improve protection of public and private infrastructure within the Tollgate 

WUI while destroying many of the ecological critical resources exist in the area. 

Therefore, HCPC continues to have many of the same concerns discussed in 

previous comments submitted on this project. These concerns include the 

inappropriate application of dry forest restoration science to moist forest types; 

lack of analysis of proposed activities on wildlife connectivity corridors; logging 

in inventoried roadless areas (IRA), areas adjacent to IRAs, and uninventoried 

roadless areas; logging adjacent to wilderness areas; logging of RHCAs in 

violation of Pacfish; the effects of road construction and the reopening of closed 

roads, unlawful application of Healthy Forest Restoration Act (HFRA); and the 

logging of large and old trees. 

Response:

Your comment has been noted. However, we disagree with the assertion that 

the project activities are not appropriate and will not meet (to some degree 

dependant on the alternative selected) the stated purpose and need. We also 

disagree with the assertion that the project will destroy critical resources. The 

environmental effects of proposed activities for wildlife, vegetation, IRA, PWA, 

other undeveloped lands, Wilderness, RHCAs and other resources are 

disclosed in Chapter 4 of this FEIS. 

HCPC-3

p-3 

Comment: 

Roadless areas generally entail four categories, wilderness areas, IRAs, 

uninventoried roadless areas, and roadless expanses. 
Tollgate Fuels Reduction Project FEIS

G-69

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

Response:

The Forest Service acknowledges there are many terms used to describe 

roadless issues. The terms used to disclose impacts to this topic are Wilderness, 

Inventoried Roadless Area, Potential Wilderness Area, and Other Undeveloped 

Lands. See the FEIS, Chapter 3, pages 3-95 for Forest Service agency 

definitions of terms and agency procedures for the inventory of resources. The 

term uninventoried roadless areas and roadless expanses have no meaning 

because all lands relevant to Tollgate project planning area were considered 

and inventoried (FEIS, Appendix H).

HCPC-4

p-5 

Comment: 

In addition to the areas identified in the proposed action that overlap IRA’s, 

HCPC is concerned that several more of the proposed units overlap the 

Lookingglass Roadless Area, the Walla Walla River Inventoried Roadless Area, 

and roadless lands contiguous with the North Fork Umatilla Wilderness Area. 

The Forest Service’s GIS based Roadless Area boundaries dataset has serious 

uncertainties and human error. Alternative datasets that map Roadless Areas 

based on the same criteria have serious discrepancies and illustrate among other 

things that the Forest Service derived Roadless Area dataset chronically 

underestimates the actual size of Roadless Area’s and completely omits others. 

Response:

The sets of maps that accompanied the 2001 Roadless Area Conservation 

Rule (RACR) which established the Lookingglass and Walla Walla River 

IRAs is the sole mapping inventory of the boundary for IRAs (per 36 CFR 

294). Based on this regulation, as disclosed in the FEIS treatments are 

proposed within the Lookingglass IRA (units 26, 38, and X). There are no 

activities proposed within the Walla Walla River IRA. Treatments are 

proposed within PWA adjacent to the North Fork Umatilla Wilderness. No 

project activities occur within the Wilderness. PWA is determined using the 

inventory criteria at FSH 1909.12 Chapter 71. See appendix H for 

additional information. 

HCPC-5

p-5,6 

Comment: 

The proposed action contains numerous units proposed directly adjacent to the 

perimeter of the Forest Service derived GIS Roadless Areas boundaries. The 

Forest Service has failed in its duty to protect these areas by not verifying that 

these units do not overlap areas of contiguous roadless forests.
Tollgate Fuels Reduction Project FEIS

G-70

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

Response:

The commenter does not define their terms “Roadless Area” and ”contiguous 

roadless forests” in their comment, so it is not possible to analyze an 

ambiguous, undefined term. 

For the PWA inventory the project planning area was expanded to include 

additional lands surrounding the Lookingglass IRA (PWA analysis area). The 

Forest Service considered all lands in the PWA analysis area when following 

the established procedures for what areas qualify for inclusion in the inventory 

of PWAs. Procedures for identifying areas that qualify for inclusion in the 

inventory of PWAs come from Forest Service Handbook 1909.12, Chapter 70, 

Section 71. The procedures in Section 71 were followed (FEIS, Appendix H). 

The effects of fuels reduction activities on IRAs, PWAs and other undeveloped 

lands are described in chapter 4, pages 4-102 to 4-120. 

HCPC-6

p-6 

Comment: 

This proposal could also damage or disqualify possibly eligible wilderness. NEPA 

analysis must be completed in light of other governing statutes and regulations, 

including whether the proposed actions will impinge upon Congress’s prerogative to 

designate wilderness.

Response:

The effects of fuels reduction activities on IRAs, PWAs and other undeveloped 

lands are described in chapter 4, pages 4-102 to 4-120. 

There is an irretrievable effect associated with timber removal within areas 

that have been identified, using the PWA inventory criteria found at FSH 

1902.12, Chapter 70, as Potential Wilderness within the project planning area. 

These acres would result in visibly detectible signs of timber harvest (such as 

stumps and skid trails) which would preclude the areas inclusion as part of the 

inventory until such a future time as the signs of past harvest are no longer 

visible. Although these area would not be included as part of the Forest 

Service’s Potential Wilderness inventory, they would not necessarily eliminate 

the possibility of the areas inclusion as wilderness at some point by Congress. 

(FEIS, p. 4-130)

HCPC-7

p-6 

Comment: 

Finally, the treatments proposed in the roadless areas do not meet the purpose 

and need of the Tollgate project. 
Tollgate Fuels Reduction Project FEIS

G-71

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

Response:

We disagree. The proposed treatments within the Lookingglass IRA are 

consistent with the stated Purpose and Need on page 1-4 of Chapter 1. The 

treatments within the IRA are strategically located in “pinch points” at the 

headwaters of the Lookingglass Creek as well as around the boundary of a 

private inholding. These treatments, along with other proposed fuels reduction 

treatments across the planning area, are designed to provide for protection of 

private property, private/public infrastructure, ingress/egress routes, and fire 

suppression activities. 

HCPC-8

p-6 

Comment:

In sum, the Tollgate DEIS fails to adequately consider the project’s irretrievable 

impacts to potential wilderness areas, uninventoried roadless areas and roadless 

expanses that are spatially and functionally contiguous with existing IRA’s; fails 

to adequately analyze impacts to both listed species and regionally sensitive 

species from development in unroaded areas; and fails to disclose the scientific 

research recommendations relevant to the importance of all roadless areas and 

their connective habitat, inventoried or not. 

Response:

The commenter does not define their terms “uninventoried roadless areas” and 

”roadless expanses” in their comment, so it is not possible to analyze an 

ambiguous, undefined term. 

The effects of fuels reduction activities on IRAs, PWAs and other undeveloped 

lands are described in chapter 4, pages 4-102 to 4-120. 

The effects of fuels reduction activities within IRAs, PWAs and other 

undeveloped lands on listed and regionally sensitive species are described in 

chapter 4 of the FEIS.

HCPC-9

p-8 

Comment:

In HCPC’s scoping comments it was recommended that the Forest Service 

analyze wildlife movement throughout the project area and alters the proposed 

action to best accommodate wildlife needs in the project/critical linkage area. 

Specifically, it was recommended that the Forest Service determine what the 

current major migration routes between the North Fork John Day Wilderness 

and the Walla Walla River IRA are; how the treatments will impact the ability of 

species to migrate and disperse across the landscape; the corridors that need to 

be maintained in order to guarantee long-term landscape connectivity. The DEIS 

states that connectivity corridors within the project area would be maintained. 
Tollgate Fuels Reduction Project FEIS

G-72

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

This conclusion is reached without any analysis. The DEIS does not analyze 

where these linkages occur, what the major migration routes through the project 

area are, whether these linkages will be impacted by the proposed activities, or 

how the proposed activities could be modified to achieve public safety goals 

while protecting connectivity. 

Response:

We disagree that treatment units form a contiguous barrier between core 

wildland areas. Thinning trees generally does not create barriers to animal 

movement. The statement in the DEIS that connectivity corridors would be 

maintained was based on the old forest connectivity analysis. Data and maps 

for this analysis are available in the Tollgate project record. In addition, 

habitat connectivity in relation to Highway 204 was considered during the 

planning stages of this project. Some potential treatment areas were dropped 

from consideration in order to maintain some areas with maximum forest 

cover. See page 4-75 of the FEIS.

HCPC-10

p-9 

Comment:

 

Recommendations to limit impacts to wildlife connectivity: 

• Pull units back from the Wilderness and IRA boundaries in order to 

buffer these existing wildlife migratory routes from treatment activities. 

• Apply larger buffer zones along streams than are required to maintain 

populations of species adapted to less disturbed conditions. These areas 

are least likely to burn or to become drought-stressed and best provide 

corridors for flora and fauna to adjust to on-going climatic change. 

• Leave large blocks of mixed conifer and most of the subalpine forests 

untreated. In this way, benchmarks will be available for comparing 

response to wildfires and insect and disease outbreaks. The reserved 

blocks will also offer refuges to flora and fauna not adapted to frequent 

disturbance. 

• In areas where fuels reduction will be relatively contiguous, such as 

along major roads, leave embedded skips and use variable density 

thinning in order to maintain connectivity corridors across areas that are 

already difficult for wildlife to cross. 

• Consider the functionality of riparian areas as wildlife corridors. 

While not all species would be covered by this approach, the project area 

does have a complex aquatic system. These areas are likely natural 

wildlife corridors where extra large buffers or some other approach 
Tollgate Fuels Reduction Project FEIS

G-73

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

would help plan for day-to-day wildlife movement and dispersal needs. 

Response:

The Eastside Screens were designed to maintain connectivity and were applied 

to this project. See Response to comment HCPC-9. 

HCPC-11

p-11 

Comment:

The fundamental flaw of the Tollgate DEIS is fuels reduction treatments that 

contradict the biophysical environments, plant association groups, elevational 

and aspect driven differences in plant communities, precipitation gradients, and 

historical disturbance regimes. The Forest Service cannot apply dry forest 

science to moist forests and expect the same results. 

Response:

We are unsure how any DEIS, which includes analysis of a wide array of 

analysis issues, measures, and indicators to support multiple decision 

reasoning, can have a single “fundamental flaw.” We are unsure from this 

comment exactly what specifically constitutes “dry forest science,” and to what 

we expect the results would be “the same.” 

With respect to published scientific literature, the Forest Service disagrees that 

collective scientific understanding of the biophysical processes underlying 

vegetation growth, succession, mortality, regeneration, and disturbance 

processes associated with Dry Upland Forest vegetation Potential Vegetation 

Groups (PVGs) have been applied to the analysis of activity effects on Moist 

Upland Forest PVGs with an expectation of “the same results.” Indeed, the 

characteristic high productivity, unique disturbance processes, and fire 

resistance/resilience of the Moist Upland Forest PVGs was specifically 

considered throughout the silviculture analysis and thoroughly described in the 

silviculture specialist report. To take just one example, the precise fire 

resistance and wind resistance of the constituent species associated with the 

moist upland forest PVGs in the Tollgate area was explicitly considered during 

effects analysis of the proposed activities. 

Beyond the science underlying effects analysis, some activities were deliberately 

proposed/avoided in moist forest areas relative to other activities more 

commonly associated with dry forest fuels reduction. Fuels reduction activities 

that are known to be effective in dry forest PVGs were not necessarily or 

inappropriately applied to moist forest PVGs, even though many of the project 

objectives (the creation and/or development of a shaded fuel break) are similar. 

For example, prescribed broadcast burning (known to be an important and 

effective fuels reduction activity in dry forests) was not included in the action 
Tollgate Fuels Reduction Project FEIS

G-74

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

alternatives, while in many moist forest areas mechanical mastication was 

analyzed as a more effective option to re-distribute and/or reduce fuels while 

maintaining a healthy overstory canopy. These considerations occurred in 

light of (not in spite of) the project objectives and the unique moist forest 

ecosystem characteristics described above.

HCPC-12

p-12 

Comment:

Additionally, due to the substantial evidence that thinning can increase the risk 

of wildfire, the Forest Service needs to design prescriptions in Tollgate project 

area that recognize that logging can exacerbate fire risk (Hanson and Odion, 

2006; Raymond and Peterson, 2005). 

Response:

The Forest Service has indeed designed the activities proposed under 

Alternatives B and C to take into account that tree cutting activities can 

exacerbate fire risk if activity fuels are not treated and other basic principles of 

fuels reduction are not followed. As described in Chapter 2 of the FEIS (page 

2-4), the activities include slash piling, pile burning, and mastication as means 

to mitigate the fire hazard associated with activity fuels. In addition, a thinfrom-below general prescription and retention of an overstory to provide some 

surface shade and wind protection were also utilized for all cutting activities 

proposed under both action Alternatives. We believe these measures 

collectively and effectively mitigate fire risks associated with tree cutting and 

removal. 

Also see response to comment RA2012-33.

HCPC-13

p-12 

Comment:

The Tollgate Fuels Reduction project has a very high likelihood of increasing 

fire risk because the commercial treatments will allow more solar radiation to 

penetrate into the otherwise shaded, mesic forest understory environment. 

Logging will also increase fine fuels both though felling large trees and by 

subsequent growth of the understory. 

Response:

We agree that solar radiation, broadly conceived, has the potential under some 

circumstances to increase fire intensity by lowering fuel moisture content, and 

that the growth of understory “fine” fuels is also positively associated with fire 

intensity. 
Tollgate Fuels Reduction Project FEIS

G-75

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

We do not agree that the Tollgate project itself has a very high likelihood of 

increasing fire risk in the short and medium-term (1-20 years) because the 

activities proposed under both action Alternatives are expected to actually 

lower potential wildfire intensity in many areas and result in the increased 

ability to conduct direct control and suppression activities. The basis for these 

expectations is thoroughly explained (with supporting scientific justification) 

on pages 4-61 through 4-67 in the FEIS. Although increases of incoming solar 

radiation may reduce fine fuel moisture to some degree, this effect is expected 

to be mitigated by increases in soil moisture and plant water availability 

resulting from decreased overall plant transpiration, moderate levels of 

retained overstory shade, and drastic reductions in overall surface fuel loading, 

particularly in mid and large-sized fuel classes. These expectations are 

reflected in the fire behavior model outputs described in the fire and fuels 

analysis of chapter 4 of the Tollgate FEIS. 

Indeed, it must be emphasized that existing surface fuel loading is extremely 

high in many areas affected by activities proposed under both action 

Alternatives. Although minor accumulation of fine activity fuels (needles and 

small branches) is expected to result from the proposed activities, and both 

shrubs and tree saplings are expected to grow following activity 

implementation in some areas, the surface and canopy fuel levels of these 

components would far less than existing levels for the next 20 years or more. 

In the medium to long-term (20-30 years, and beyond), the FEIS points out on 

pages 4-28, 4-29, 4-63, and 4-66 that understory thinning and other fuels 

maintenance activities (such as mastication) would be required in some areas to 

maintain fuels characteristics conducive to direct wildfire suppression. 

Professional experience in the area with understory shrub growth in the 

specific biophysical environments of the activity units suggests that understory 

growth would not impede direct fire suppression efforts for at least 20 years. 

In summary, the scientific basis for fuels-reduction activities (such as those 

proposed under the Tollgate project action Alternatives) to moderate potential 

crown fire behavior is well-established, widely accepted, and thoroughly 

summarized in Graham et al. (2004), which is cited in the Tollgate FEIS on 

page 4-63. 

HCPC-14

p-12 

Comment:

The Forest Service should analyze all proposed logging activities based on these 

principals in order to not increase wildfire risk in the Tollgate area. 

Response:

See responses to comments HCPC-12 and HCPC-13 above. 
Tollgate Fuels Reduction Project FEIS

G-76

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

HCPC-15

p-12, 13 

Comment: 

Removing an areas fire resistant maturing tree forest stand structure actually 

increases the risk of fire severity and extent of spread, due to greater solar 

drying, higher wind speeds, and greater prevalence of fire prone brush, 

vegetation and small diameter trees that soon replace the more fire-resistant 

shade providing/moisture-retaining trees removed. Additionally, logging slash 

that remains in the forest increases the risk and extent of severe fires far above 

the pre-project implementation risks. Slash piles and scattered fuels from past 

and recent logging can be found throughout the project area already. Yet this 

“fuels reduction” project fails to disclose or address these very significant issues 

and conditions. The DEIS fail to consider the majority of credible peer-reviewed 

scientific research that clearly indicates the removing old trees will not its stated 

goals, and instead would increase the risk and extent of severe fires in the 

project area.

Response:

Fires may have an increase in spread rate in thinned stands, but with reduced 

intensities (flame lengths) and severity (crown fire) within the stands after 

treatment. 20 foot windspeeds will not be affected by any treatments proposed 

for the project. Post treatment, forb and shrub growth will increase which 

retain moisture until later in the season and thus can reduce fire behavior 

(Agee et. Al. 2002). Additionally, the logging systems designed for the project 

are structured such that most activity generated slash will be removed from 

units and piled at landings. Landings that are generated as a result of project 

activities will be disposed of either through chipping for biomass utilization or 

burned on site. Surface fuel loading within the analysis area, including legacy 

activity slash, was analyzed and is scheduled for treatment if needed to meet 

the stated purpose and need of the Tollgate DEIS.

HCPC-16

p-13 

Comment:

Logging old growth trees does not achieve fuels reduction objectives. Therefore, 

the proposed action to cut trees over 21 inches dbh violates the purpose and need 

for this project. 

Response:

As stated on pg. 1-4 of the DEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To that end, reductions in ladder fuels and canopy 
Tollgate Fuels Reduction Project FEIS

G-77

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

bulk density must be accomplished, and can only be accomplished through 

removal of selected crowns in selected areas; in some instances removal of trees 

over 21” dbh is necessary in order to achieve crown spacing that will result in 

adequate reductions of crown fire potential in strategic areas across the 

planning area.

HCPC-17

p-14 

Comment:

The Tollgate Fuels Reduction project is not consistent with either the 

requirement that HFRA projects be “consistent with the resource management 

plan and other relevant administrative policies or decisions applicable to the 

Federal land covered by the project” or that projects limit activities to hazardous 

fuel removal. This project calls for forest plan amendments to remove trees in 

RHCAs and therefore does not follow “the resource management plan”. In 

addition, this project proposes removing trees over 15 inches dbh – e.g. those 

that do not pose a fuels hazard. Both actions are in violation of the requirements 

of HFRA. 

Response:

We disagree. The Tollgate Fuels Reduction project is consistent with the 

requirements of HFRA because if selected the Forest Plan will be amended for 

this site specific activity and thus the treatment of identified RHCAs will be in 

compliance with the Forest Plan as amended. 

HCPC-18

p-14 

Comment: 

In order to minimize adverse impacts of temporary road construction/road 

reconstruction and to make this a viable timber sale-offering HCPC strongly 

urges that no temporary roads are constructed or that any roads are 

reconstructed. Because the adverse impacts of building these temporary roads 

areas inaccessible from roads should be allocated to untreated skips (or noncommercial fall-and-leave treatments) which provide their own set of ecological 

benefits. 

Response:

Your comment has been noted. 

HCPC-19

p-16 

Comment: 

The DEIS discloses that under the proposed action the recruitment of large 

wood, water temperature, surface-groundwater interactions, erosion potential 
Tollgate Fuels Reduction Project FEIS

G-78

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

have the potential to be adversely affected. This reduction of Pacfish RHCAs 

and the associated adverse impacts on the streams within the project area are 

justified by the proposition that some instances smaller buffers then required by 

the Forest Plan can protect riparian condition and function. The DEIS however 

does not show that the steams in the project areas fit into these narrow 

environmental conditions where reduced RHCAs may be warranted. 

Response:

Hydrologic effects analysis finds no effect to water temperature and an 

immeasurably small effect to sediment at the harvest unit, site specific scale. 

See FEIS pages 4-7to 4-11 No effects to surface-groundwater interactions were 

identified, and none would be expected.

HCPC-20

p-16 

Comment:

HCPC requests that the proposed action be amended to incorporate the wellestablished science surrounding the protection of riparian conditions and 

functions and that the alternative selected not treat within RHCA’s. 

Response:

A large body of established science has been incorporated into the analysis and 

discussion of proposed RHCA treatments. See the FEIS pages 4-7 to 4-11 and 

FEIS bibliography.

HCPC-21

p-16 

Comment: 

It is possible to reduce potential wildfire behavior, and related risks to public 

health and safety while maintaining protections of riparian areas. Furthermore, 

these riparian areas are important connectivity corridors (see above). This role of 

riparian areas and the effects of logging within RHCAs is not analyzed in the 

DEIS. 

Response:

Analysis and modeling within the Tollgate planning areas showed that several 

RHCAs pose a threat to some Values at Risk identified within the Tollgate 

project area. The geographic positioning and vegetative structure of the four 

RHCAs proposed for treatment display a high level of risk in terms of 

“funneling” wildland fire towards identified Values at Risk and vegetative 

structure that can lead to the initiation and propagation of crown fire. As 
Tollgate Fuels Reduction Project FEIS

G-79

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

such, these areas are recommended for treatment.

The specific treatments prescribed for these areas are garnered through 

modeling and field verification with an objective of reducing crown fire and 

fire intensities. Each prescription is designed towards the reduction of these 

metrics and the concepts stated above. 

Other riparian areas within the planning area and not prescribed for 

treatment failed to display a clear need based on the purpose and need, fire 

modeling, and professional judgment.

HCPC-22

p-18 

Comment: 

The current proposed action is for 4,330 acres of logging of which the 

overwhelming majority is commercial thinning. In addition, under the proposed 

action dead and down wood removal will on 300 of those acres. This widespread 

landscape-level commercial thinning captures future mortality and due to the 

safety concerns with working in areas with snags, it is likely that snags will be 

significantly reduced across most of the treated landscape. This is inadequate for 

wildlife needs. 

Response:

Minimal long term impacts to snags are expected because the project is leaving 

fully stocked stands. Insect and other natural disturbances will continue to 

create snags. See page 4-82 to 4-84 of the FEIS. See also Response to Comment 

OW-21. 

HCPC-23

p-18 

Comment: 

Additionally, the entire project should incorporate significant unthinned “skips” 

embedded within treatments areas, so that the different habitat elements needed 

by wildlife, such as large trees, snags, and understory vegetation diversity are all 

available within close proximity, or at least within a fine scale mosaic. 

Response:

Variable density thinning will be utilized wherever appropriate and consistent 

with the purpose and need. See also Response to Comment OW-20. 

HCPC-24

p-18 

Comment: 

All unroaded areas larger than 1,000 acres should be identified for conservation 
Tollgate Fuels Reduction Project FEIS

G-80

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

in order to maintain natural levels of snag recruitment that can help mitigate for 

the lack of snags in areas that are actively managed with an emphasis on healthy 

vigorous trees. 

Response:

An inventory of potential wilderness areas was conducted for all lands within 

the project planning area. The inventory criteria used and the results of the 

inventory can be found in appendix H of the FEIS. The inventory process 

resulted in the identification of lands that met the criteria set forth in FSH 

1909.12 Chapter 71 and thus were added to the PWA inventory. Other lands 

within the project planning area did not meet the inventory criteria for 

potential wilderness areas, but also did not have a history of past development 

(i.e. signs of past harvest and/or roads). These lands are identified as other 

undeveloped lands. The environmental effects of proposed project activities on 

PWA and other undeveloped lands is disclosed in chapter 4. 

HCPC-25

p-18 

Comment: 

The DEIS indicates that the direct effects of the proposed project could be a 

reduction of levels of snags and coarse wood in harvest units reducing both short 

and long term soil productivity. This is justified as a necessary tradeoff to reduce 

the fuel loading. Due to the “necessary” changes to soil productivity, in order to 

meet the goals laid out in the LRMP the Forest Service must mitigate or restore 

degraded soils to a pre-activity condition if preventative measures cannot be 

applied during the project. 

Response:

The loss of organic matter will be a loss in general to soil development, from a 

reduction to available organic matter. However the amounts removed will not 

fall below levels required in the LRMP for various resources like wildlife, thus 

it is expected that the overall available organic matter for soil development will 

be reduced, but not eliminated. When considering the effects of a high intensity 

long duration fire would have on down wood; that organic matter would be at 

a higher risk of loss since wildfire would likely eliminate available organic 

matter from the site

HCPC-26

p-19 

Comment: 

Many units overlap areas that have extensive marshes where machinery will cause 

long-term damage to soils. The project units contain headwater systems to 

Lookingglass IRA where important fisheries are sustained. The DEIS does not 

address how these wet areas and associated hydrologic functions, plant communities 

and soils will be protected during implementation of project activities. 
Tollgate Fuels Reduction Project FEIS

G-81

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

Response:

No equipment will operate on or in wet areas and no material will be removed 

from wet areas. See the project description FEIS page 2-10 and the Design 

Criteria and Best Management Practices FEIS Table 2-7 page 2-14

HCPC-27

p-19 

Comment: 

The NEPA analysis for this project does not adequately discuss the impacts of 

proposed activities on the hydrological relationships of the streams, standing 

water areas, marshes, and very wet plant communities intermixed within the 

project area. 

Response:

Project description FEIS page 2-2 to 2-14 and the Design Criteria and Best 

Management Practices FEIS Table 2-7 page 2-14 describe the project. 

Hydrologic effects analysis finds no effect to water temperature and an 

immeasurably small effect to sediment at the harvest unit, site specific scale. 

No effect to channel stability of hydrologic function would occur. FEIS pages 

4-6 to 4-10.

HCPC-28

p-19 

Comment: 

 

The use of OHVs away from designated roads and trails can also act as wideranging seed dispersal vectors, potentially introducing weed infestations into 

remote and seldom-frequented sites. Further opening up of the forest, building 

temporary roads, and skid trails will encourage more illegal OHV trespass. This 

issue was not addressed by the DEIS. In the final EIS the issue of unauthorized 

cross county OHV must be analyzed. 

Response:

OHV travel is restricted to designated roads, trails and areas on the Umatilla 

National Forest. As with anywhere else on the forest, unauthorized OHV 

travel within the project area is a possibility. However, it is not possible or 

meaningful to speculate on where, when and to what degree illegal OHV travel 

might occur or to speculate on what the associated effects might be. 

Illegal OHV travel is a law enforcement issue. The Forest Service will continue 

to pursue individuals who engage in illegal activities on the forest.
Tollgate Fuels Reduction Project FEIS

G-82

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

HCPC-29

p-19, 20 

Comment:

Here, the DEIS fails to describe the quantity and quality of habitat necessary to 

sustain the viability of the species in question and it does not explain its 

methodology for measuring this habitat. The DEIS fails to demonstrate sensitive 

and management indicator wildlife species reasonably expected to be found in 

the project area are a part of viable populations. Please disclose the scientific 

research and other documents that the UNF used to support its habitat 

management strategies for old growth and mature forest wildlife.

Response:

Habitat for management indicator wildlife species is described on pages 3-66 to 

3-71 of the FEIS. Relevant references are cited.

HCPC-30

p-20 

Comment: 

Roads and trails serve as corridors for non-native invasions, and logging 

equipment is frequently cited as the key link in the transport and spread of 

invasive or noxious plants. HCPC suggests monitoring of the project area after 

completion so that weeds infestation sites can be identified and treated before 

spreading into adjacent areas. We also strongly recommend dropping all 

temporary road building and road re-construction as it creates disturbed soil 

conditions ideal for invasive weed spread. 

Response:

The potential impacts of the activities proposed under the action alternatives 

on non-native plant invasion are disclosed in the Tollgate FEIS on pages 4-69 

through 4-73. The analysis specifically incorporates the potential impacts of 

ground-disturbing activities and equipment on risk of invasion.

Monitoring of the project area during and after implementation of activities is 

planned and described on page 2-22. 

Regarding the comment on dropping all temporary road and road reconstruction activities from the proposed action: we have incorporated this 

comment by including a “No-Action” alternative in the project EIS. 

Consideration was made of including an action alternative with no temporary 

road construction, but this was not deemed necessary, given the anticipated 

effectiveness of applicable design features described in on page 2-19 of the 

FEIS.
Tollgate Fuels Reduction Project FEIS

G-83

Letter #12

Veronica Warnock – Hells Canyon Preservation Council (HCPC)

Comment 

Number Comment and Response

HCPC-31

p-20 

Comment: 

To best meet the stated purpose and need of the Tollgate Fuels Reduction 

project , the Forest Service should drop unit in and adjacent to areas with 

roadless and wilderness characteristics; minimize fuels reduction in the moist 

forest environments; protect all old growth and previously unlogged forests from 

any fuels reduction treatments; eliminate temporary road or landing construction 

and re-opening of closed roads; protect wildlife habitat and wildlife corridors; 

eliminate logging within RHCAs; and consciously plan to minimize OHV 

trespass and the spread of invasive weeds. 

Response:

Your comment has been noted. 

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

FUELS –

PAGES S-iii, S-iv, S-viii, 1-3, 1-6, 1-13, 1-22, 2-2, 2-9, 2-10, 2-13, 2-23, 3-1, 3-2, 3-39, 3-40, 3-43, 4-61

Comments that provide general statements or opposition in this section have been noted.

p- S-iii Response:

The Tollgate project is focused on increasing wildfire defensibility of National 

Forest System lands within the Tollgate WUI as outlined in the Umatilla 

County CWPP. While FIREWISE concepts are important for private 

landowners to incorporate, such activities lie outside of the stated purpose and 

need of this project. 

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To that end, reductions in ladder fuels and canopy 
Tollgate Fuels Reduction Project FEIS

G-84

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

bulk density must be accomplished, and can only be accomplished through 

removal of selected crowns in selected areas; in some instances removal of trees 

over 21” dbh is necessary in order to achieve crown spacing resulting in 

reduced crown fire potential across the planning area.

Analysis and modeling within the Tollgate planning areas showed that several 

RHCAs pose a threat to some Values at Risk identified within the Tollgate 

DEIS. The geographic positioning and vegetative structure of the four RHCAs 

proposed for treatment display a high level of risk in terms of “funneling” 

wildland fire towards identified Values at Risk, and are vegetatively structured 

such that crown fire can initiate and propagate in these areas. As such, these 

areas are recommended for treatment.

p. s-iii Response:

In reference to comment that private land owners adjacent to IRA need to be 

responsible for any fire risk reduction on their own lands.

The Tollgate project is focused on increasing wildfire defensibility of National 

Forest System lands within the Tollgate WUI as outlined in the Umatilla 

County CWPP. While FIREWISE concepts are important for private 

landowners to incorporate, such activities lie outside of the stated purpose and 

need of this project. 

Additionally, investigations into home losses clearly show that most structures 

in the wildland-urban interface are ignited by embers, not radiant heating. In 

essence the structure is already burning before the radiant heat from the main 

fire has an “opportunity” to ignite it. Burning structures are typically what 

ignite other structures through spotting or, if close enough, radiant heating. 

Spotting distances of typical torching events are 1⁄2 mile or less; but distance 

and number of embers increases as the extent of active crown fire increases. 

Plume-dominated crown fires and major crowning runs typically produce 

profuse spotting with most spotting up to 1 mile; however plume-dominated

fires can readily spot up to 2 miles.

Consequently, the Tollgate project seeks to minimize the potential for the 

initiation and propagation of crown fire, such that identified Values at Risk 

experience less exposure to the conditions noted above.

Again, as stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels 
Tollgate Fuels Reduction Project FEIS

G-85

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

Reduction Project is to reduce the probability and potential extent of active 

crown fire within the Tollgate WUI. To achieve that desired condition, 

reductions in ladder fuels and canopy bulk density need to occur, which will be 

accomplished through removal of selected crowns in selected areas.

Reduction in active crown fire reduces spotting potential, and the adverse fire 

effects associated therein. Moreover, since we cannot effectively fight crown 

fires, we need to create fuel conditions that will cause the fire to surface, 

preferably at some distance from Values at Risk that also allow for contingency 

actions in the event the main firefighting strategy fails. Firefighters need to 

have fuel conditions that allow for rapid and successful burnout operations 

that will rob the wildfire of energy needed to support crowning and extensive 

torching or that provide for more effective use of retardant, foam, or water. 

The Tollgate project seeks to create these conditions in strategic areas across 

the analysis area, increasing the defensibility of Values at Risk.

p. s-iii Response:

In reference to comment that roadless rule prohibits commercial logging and 

roading in NRAs and is not necessary since it is not proposed in Alternative C.

Alternative C presents a different risk profile for residual fire occurances by 

treating less intensively in the Tollgate WUI. Pgs. 4-61to 4-87 of the FEIS

clearly display the differences in effects between alternatives. The alternatives 

analyzed provide decision makers a suite of options from which to choose.

Also see 2001 Roadless Rule Consistency statement at the end of Chapter 4.

p- S-iv Response:

Please see response to comment RA2012-33. 

p- S-viii Response:

As stated on pg. 1-3 of the FEIS, the Tollgate project is consistent with the 

goals and objectives of the Umatilla County CWPP which calls for the Tollgate 

WUI to have fuel profiles with a low likelihood of active crown fire which 

allows for direct wildfire control and suppression, ingress and egress of the 

public and fire personnel, and protection of the Values at Risk identified in the 

FEIS.
Tollgate Fuels Reduction Project FEIS

G-86

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

In summary, the scientific basis for fuels-reduction activities (such as those 

proposed under the Tollgate project action Alternatives) to moderate potential

crown fire behavior is well-established, widely accepted, and thoroughly 

summarized in Graham et al. (2004), which is cited in the Tollgate FEIS on 

page 4-64.

p-1-3 Response:

The characteristic high productivity, unique disturbance processes, and fire 

resistance/resilience of the Moist Upland Forest PVGs was specifically 

considered throughout the analysis. To take just one example, the precise fire 

resistance and wind resistance of the constituent species associated with the 

moist upland forest PVGs in the Tollgate area was explicitly considered during 

effects analysis of the proposed activities. 

Beyond the science underlying effects analysis, some activities were 

deliberately proposed/avoided in moist forest areas relative to other activities 

more commonly associated with dry forest fuels reduction. Fuels reduction 

activities that are known to be effective in dry forest PVGs were not necessarily 

or inappropriately applied to moist forest PVGs, even though many of the 

project objectives (the creation and/or development of a shaded fuel break) are 

similar. For example, prescribed broadcast burning (known to be an important 

and effective fuels reduction activity in dry forests) was not included in the 

action alternatives, while in many moist forest areas mechanical mastication 

was analyzed as a more effective option to re-distribute and/or reduce fuels 

while maintaining a healthy overstory canopy. These considerations occurred 

in light of (not in spite of) the project objectives and the unique moist forest 

ecosystem characteristics described above.

The desired condition can be maintained over time through periodic entries in 

which hand thinning of understory components occurs. It is reasonable to 

expect that an activity of this type would need to occur every fifteen to twenty 

years to maintain defensible conditions across the plateau.

p-1-6 Response:
Tollgate Fuels Reduction Project FEIS

G-87

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

Analysis and modeling within the Tollgate planning areas showed that several 

RHCAs pose a threat to some Values at Risk identified within the Tollgate 

DEIS. The geographic positioning and vegetative structure of the four RHCAs 

proposed for treatment display a high level of risk in terms of “funneling” 

wildland fire towards identified Values at Risk and the vegetative structure 

that can result in the initiation and propagation of crown fire. As such, these 

areas are recommended for treatment.

p-1-13 Response:

Please see response to comment BMBP p- 1-6. 

p-1-22 Response:

Our initial attack records show that we can easily deal with fires burning 

under 70th and lower 80th percentile conditions. Initial attack success rates 

start to fall somewhere between the 80th and 90th percentile conditions, often in 

fairly specific fuel beds that hinder line-building rates, promote spotting, and 

prolong mop-up. Around the 90th percentile conditions, initial attack success 

rates tend to fall rapidly in nearly all fuel beds. We simply lack the capability 

of dealing with fires burning at >97th percentile conditions in any fuel bed.

p-2-2 Response:

Thank you for your comment. Please see response to comment RA2012-20. 

p- 2-9 Response:

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To achieve that desired condition, reductions in 

ladder fuels and canopy bulk density need to occur, and can only be 

accomplished through removal of selected crowns in selected areas.

Reduction in active crown fire reduces spotting potential, and the adverse fire 

effects associated therein. Moreover, since we cannot effectively fight crown 

fires, we need to create fuel conditions that will cause the fire to surface, 

preferably at some distance from Values at Risk that also allow for contingency 

actions in the event the main firefighting strategy fails. Firefighters need to 

have fuel conditions that allow for rapid and successful burnout operations 
Tollgate Fuels Reduction Project FEIS

G-88

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

that will rob the wildfire of energy needed to support crowning and extensive 

torching or that provide for more effective use of retardant, foam, or water. 

The Tollgate project seeks to create these conditions in strategic areas across 

the analysis area, increasing the defensibility of Values at Risk.

p-2-10 Response:

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To achieve that desired condition, reductions in 

ladder fuels and canopy bulk density need to occur, and can only be 

accomplished through removal of selected crowns in selected areas.

Reduction in active crown fire reduces spotting potential, and the adverse fire 

effects associated therein. Moreover, since we cannot effectively fight crown 

fires, we need to create fuel conditions that will cause the fire to surface, 

preferably at some distance from Values at Risk that also allow for contingency 

actions in the event the main firefighting strategy fails. Firefighters need to 

have fuel conditions that allow for rapid and successful burnout operations 

that will rob the wildfire of energy needed to support crowning and extensive 

torching or that provide for more effective use of retardant, foam, or water. 

The Tollgate project seeks to create these conditions in strategic areas across 

the analysis area, increasing the defensibility of Values at Risk.

Several of these strategic areas lie within the Lookingglass IRA, and warrant 

treatment such that adverse wildland fire behavior is minimized, and Values at 

Risk are more effectively protected.

p. 2-13 Response:

Analysis and modeling within the Tollgate planning area showed that several 

RHCAs pose a threat to some Values at Risk identified within the Tollgate 

DEIS. The geographic positioning and vegetative structure of the four RHCAs 

proposed for treatment display a high level of risk in terms of “funneling” 

wildland fire towards identified Values at Risk and vegetative structure that 

can lead to the initiation and propagation of crown fire. As such, these areas 

are recommended for treatment.
Tollgate Fuels Reduction Project FEIS

G-89

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

The specific treatments prescribed for these areas are garnered through 

modeling and field verification with an objective of reducing crown fire and 

fire intensities. Each prescription is designed towards the reduction of these 

metrics.

p.2-23 Response:

Please see response to comment BMBP p- 1-3. 

p. 3-1 Response:

Fires may have an increase in spread rate in thinned stands, but with reduced 

intensities (flame lengths) and severity (crown fire) within the stands after 

treatment. 20 foot windspeeds will not be affected by any treatments proposed 

for the project. Post treatment, forb and shrub growth will increase which 

retain moisture until later in the season and thus can reduce fire behavior

(Agee et. Al. 2002). Additionally, the logging systems designed for the project 

are structured such that most activity generated slash will be removed from 

units and piled at landings. Landings that are generated as a result of project 

activities will be disposed of either through chipping for biomass utilization or 

burned on site. 

p. 3-2 Response:

The Tollgate project is focused on increasing wildfire defensibility of National 

Forest System lands within the Tollgate WUI as outlined in the Umatilla 

County CWPP. 

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To that end, reductions in ladder fuels and canopy 

bulk density are proposed for the project.

As stated on pg. 3-39 of the Tollgate FEIS, the Burnt Cabin Fire of 2005 

demonstrates that wildfires can and will originate in wilderness and roadless 

areas, emerging on the plateau and threatening the infrastructure therein.

p.3-39 Response:

Please see response to comment BMBP p- 1-3. 

p.3-40 Response:
Tollgate Fuels Reduction Project FEIS

G-90

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

As stated on pg. 1-4 of the FEIS the purpose of the Tollgate Fuels Reduction 

Project is to reduce the probability and potential extent of active crown fire 

within the Tollgate WUI. To achieve that desired condition, reductions in 

ladder fuels and canopy bulk density need to occur, and can only be 

accomplished through removal of selected crowns in selected areas.

Fire modeling and professional judgment demonstrate that stands selected for 

treatment currently display structural characteristics associated with elevated 

risk of crown fire and adverse fire intensity.

p. 3-43 Response:

The preponderance of published scientific literature (much of which is cited 

within the fuels analysis section of Chapter 4 in the Tollgate FEIS) clearly 

shows that, regardless of fire regime, the reduction of surface and canopy fuels 

resulting from implementing the proposed action Alternatives would indeed 

likely reduce the probability of active crown fire for some period of time 

relative to a no-action Alternative. The reasons that many (but certainly not 

all) of the fire regimes that historically occurred within the Tollgate analysis 

area were less frequent and higher severity are driven by the frequency, 

amount, and timing of ignitions, fuel moisture during the fire season, and—

perhaps most importantly—the amount and continuity of surface and canopy 

fuels that tend to occur in these biophysical environments. It is these last 

variables that the Tollgate project action Alternatives would affect, and 

thereby alter the potential occurrence and behavior of wildfire in strategic 

locations in the planning area in ways that reduce “risks” to values identified in 

Chapter 1. 

p. 4-61 Response:

As displayed on p. 4-61, surface fire increases from the no action alternative to 

alternatives A and B while passive and active crown fire decreases. Surface 

fire is fire that involves surface fuels only and not components of the crowns. 

The narrative then that is displayed in the table shows post-treatment shifts in 

crown fire to surface fire.
Tollgate Fuels Reduction Project FEIS

G-91

VEGETATION –

PAGES: 1-5, 2-11, 3-1, 3-39, 3-42, 3-44, 3-48, 3-49, 3-50, 3-51, 3-65, 4-28, 4-29, 4-46, 4-47, 4-49, 4-53, 

4-56 

Comments that provide general statements or opposition in this section have been noted.

p. 1-5 

Interpreted comment: Re-opening closed roads increases spread of invasive 

plants and forestalls passive vegetation recovery

Response: 

See the Forest Service response to comment HCPC-30, above. 

p. 2-11 

Interpreted comment: No quantification of how many trees > 21” DBH would be 

removed or discussion of impacts of this, or rationale for it, given that larger trees 

should be retained with fire risk-reduction activities

Response:

All cutting activities proposed in the Tollgate project would prioritize the 

largest trees for retention at the prescribed residual density. In order to meet 

fuels reduction objectives, some trees which may be considered “large” may be 

cut under either action alternative, but the remaining stand would generally be 

composed of trees that are even larger yet. 

The precise count of trees >21” DBH would be removed as a result of 

implementing activities proposed under Alternative B was not identified during 

scoping as an issue for detailed analysis. Instead, the number of acres with 10 

or more trees per acre >21” DBH was chosen, which is considered an 

acceptable surrogate. As a measure and indicator for analysis, the total 

estimated number of >21” DBH trees is not needed to show consistency with 

applicable rules and regulations, does not enable or enhance evaluation of 

alternatives with respect to the project purpose and need, and does not enable 

evaluation of Alternatives with respect to addressing unresolved conflicts over 

alternative uses of available resources (see Issue Identification section in the 

Tollgate FEIS, pages 1-16 through 1-19). However, several other measures and 

indicators were deemed useful to address Issues related to trees >21” DBH, 

were utilized during the analysis process, and these are described in Table 1-3 

of the FEIS. 
Tollgate Fuels Reduction Project FEIS

G-92

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 3-39 

Interpreted comment: 

...without fire suppression the natural fire regime in the middle south fork walla 

walla subwatershed (in the project area) would be mixed to high-severity fires with 

long return intervals – so not an appropriate situation for fuel reduction, nor is fuel 

reduction likely to be a successful and sustainable fire risk reduction strategy over 

the mid to long-term

Response: 

We are unclear, based on this comment and its context, what constitutes an 

“appropriate” situation for fuels reduction. Our conception of—and 

justification for—the “appropriateness” of fuels reduction activities in the 

Tollgate planning area is thoroughly described in Chapter 1 (Purpose and 

Need) of the Tollgate FEIS. As is described and justified in Chapter 1 based on 

a thorough and extended scoping process, we strongly believe that this is the 

“right place, and right time” for the activities proposed under the Tollgate 

action Alternatives. 

For further response to this comment, see also the third paragraph of the 

response to comment HCPC-13 above, relating to the duration of activity 

effectiveness and need for follow-up maintenance. 
Tollgate Fuels Reduction Project FEIS

G-93

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 3-42 

Interpreted comment: 

timber “management” in upper cool moist elevations – There is no scientific 

consensus supporting logging and fuel reduction for fire risk reduction in coolmoist PAGs which are naturally subject to less frequent, higher-severity fires

Response:

The Forest Service generally disagrees with this comment, but we are unclear 

what the terms “consensus,” “risk,” and “naturally” are intended to mean in 

the context of this comment (comment p. 3-42). 

The preponderance of published scientific literature (much of which is cited 

within the fuels analysis section of Chapter 4 in the Tollgate FEIS) clearly 

shows that, regardless of fire regime, the reduction of surface and canopy fuels 

resulting from implementing the proposed action Alternatives would indeed 

likely reduce the probability of active crown fire for some period of time 

relative to a no-action Alternative. The reasons that many (but certainly not 

all) of the fire regimes that historically occurred within the Tollgate analysis 

area were less frequent and higher severity are driven by the frequency, 

amount, and timing of ignitions, fuel moisture during the fire season, and—

perhaps most importantly—the amount and continuity of surface and canopy 

fuels that tend to occur in these biophysical environments. It is these last 

variables that the Tollgate project action Alternatives would affect, and 

thereby alter the potential occurrence and behavior of wildfire in strategic 

locations in the planning area in ways that reduce “risks” to values identified in 

Chapter 1. 
Tollgate Fuels Reduction Project FEIS

G-94

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p- 3-44 

Interpreted comment: 

only a 5-year timeframe for considering cumulative effects artificially minimize the 

scale & intensity (and long-term impact) of cumulative effects that can be expected 

and roughly predicted, such as future timber sales. The Forest Service has no plans 

to stop having regularly scheduled timber sales as far as we can tell – in fact their 

budget depends on them!

Response:

The Forest Service respectfully disagrees that future vegetation management 

activities (such as timber sales) are “reasonably foreseeable” beyond 

approximately five years. As stated in the FEIS, any activities that might occur 

at some point in the future beyond all existing agency plans are highly 

speculative. 

Irrespective of funding considerations, the Forest Service currently has no 

plans to conduct activities with possible direct and indirect effects occurring 

within the Tollgate analysis area more than 5 years from now. Because no 

plans exist that include the occurrence of activities more than five years from 

present, no reasonably foreseeable activities exist that would have expected or 

likely direct or indirect effects; therefore, beyond approximately 5 years, there 

is no overlap of effects on forest vegetation which would suggest the presence of 

cumulative effects. 
Tollgate Fuels Reduction Project FEIS

G-95

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p- 3-48 

Interpreted comment: 

a) How can you claim that moist forest type supports “too much” subalpine fir 

and Engelmann spruce? These are the epitome of moist forest species. How did 

you get here then? 

b) In other words, no field data went into the HRV ranges – it’s all academic 

speculation. 

c) Why would you even want to grow more lodgepole pine? It’s not like there’s not 

enough of it elsewhere! 

d) Most NF Districts would be so happy to have so much of the old forest still. 

Natural succession is just that, and should be left alone, not artificially 

converted to some other species composition or structure

Response: 

a) The Forest Service recognizes that the phrase “too much” as used in the 

Tollgate FEIS is a value-laden and relative term. In the case of the Tollgate 

FEIS, the term was used to suggest that existing levels of a particular cover 

type, structural stage are currently outside of ranges of variability 

occurring in similar landscapes in “dynamic equilibrium” with their 

disturbance regimes. The terms “too much” have been replaced in the 

FEIS with more clear, objective terminology to convey the same ideas. 

b) The Forest Service respectfully disagrees that “no field data went into the 

HRV ranges” utilized in the Tollgate silviculture report. While the ranges 

themselves were partially derived from model simulations incorporating 

processes of vegetation succession and disturbance, the models were 

parameterized with field data. Furthermore, the validity of model results 

were frequently evaluated and deemed satisfactory by Forest Service 

personnel and independent scientists relying upon extensive professional 

expertise and experience in the field.

c) The increase of lodgepole pine occurrence and/or density, per se, is not an 

explicit objective of the Tollgate Fuels Reduction Project. The purpose of 

the project, as described on page 1-4 of Chapter 1 of the FEIS, is to 

implement actions which reduce the probability of and potential extent of 

active crown fire within the Tollgate WUI. 

d) This comment represents a general opinion and position statement, and has 

been noted. 
Tollgate Fuels Reduction Project FEIS

G-96

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p- 3-49 

Interpreted comments:

a) Old forest structure is priceless and increasingly rare across the region do to 

over-logging. Old forest should not be seen as outside of its historical range, as 

there used to be much more of it. There’s a well-documented (ICBEMP science) 

deficit in trees >21” DBH across the region. 

b) Too much old growth? Probably due to fire suppression 

c) This is not a problem that should be corrected by logging out old forest

d) Since there was a lot of clearcutting in the Tollgate area, are the acreage and 

percentage numbers for old forest being inflated by including Wilderness and 

Roadless areas in the estimates/calculations? 

Response:

a) We disagree with this comment with respect to the specific forest 

vegetation types and associated disturbance regimes within the Tollgate 

planning area. The Tollgate FEIS and associated silviculture resource 

report clearly describes and references why the Forest Service believes the 

extent of some old forests as defined in the FEIS are, for some potential 

vegetation groups within the Tollgate planning area, outside of estimated 

historic ranges. Finally, while the Forest Service does not necessarily 

dispute the claim that there may be a “well-documented....deficit in trees 

>21” DBH across the region,” we argue that such a claim is not accurate 

with respect to the Tollgate forest vegetation affected environment, and the 

structural stages and potential vegetation groups therein as defined in the 

Tollgate FEIS. 

b) The relationship of fire suppression activities and extent of old forest 

structural stages is discussed on pages 4-26 and 4-27 of the Tollgate FEIS. 

c) This comment represents a general opinion and position statement, and has 

been noted. 

d) The term “inflated” inaccurately implies a conscious effort to include 

Wilderness and Roadless areas within the Tollgate planning area merely to 

increase the estimated relative abundance of old forest within the planning 

area. This was not the case. The geographic area for the Tollgate vegetation 
Tollgate Fuels Reduction Project FEIS

G-97

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

analysis was chosen for several reasons as follows:

Rather than “inflate” estimates of old forest acres, the analysis within the 

Tollgate FEIS utilized the geographic boundaries it did in order to perform 

a reasonable HRV analysis over a scale commensurate with—and 

appropriate relative to—the disturbance and successional 

processes/regimes operating in the northern Blue Mountains in and around 

the project area. This was done to remain consistent with the intent of the 

Ecosystem Standard of the Eastside Screens Forest Plan Amendment, and 

appropriately represent biophysical environments which existing in a state 

of “dynamic equilibrium” with their constituent disturbance regimes. For 

the northern Blue mountains in which the Tollgate project is situated, these 

processes operate at watershed scales roughly analogous to the 46,000-acre 

Tollgate planning area. 

As stated in a Umatilla National Forest series of guidelines for HRV 

analysis (cited as Powell 2010b in the Tollgate FEIS): 

a. It is recommended that an RV analysis be conducted for land areas no 

smaller than 15,000 to 35,000 acres (this recommended size range was 

taken from the May 1994 Environmental Assessment for the Eastside 

Screens). 

b. Areas larger than 35,000 acres are appropriate and preferable for an 

RV analysis; areas smaller than 15,000 acres should be avoided since 

vegeta-tion patterns might not be consistent with those created by the 

historical disturbance regimes of the analysis area. 

The Tollgate Forest Vegetation Affected Environment, as analyzed in the 

Tollgate FEIS, is approximately 37,566 acres in size, which is consistent 

with standard Umatilla National Forest recommendations for HRV 

analysis. 

Additionally, the Tollgate forest vegetation affected environment (and 

other planning areas frequently utilized by the Forest Service to analyze 

vegetation effects) routinely and typically tend to be based on biophysical 

delineations such as watershed boundaries and forest types, not political 

boundaries (such as Congressionally designated Wilderness, Inventoried 

Roadless Areas, or Potential Wilderness Area inventory boundaries). In 

fact, the Eastside Screens Amendment specifically states that the Forest 

Service “characterize the proposed timber sale and its associated 

watershed,” which, in the case of the Tollgate project, encompasses 
Tollgate Fuels Reduction Project FEIS

G-98

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

multiple watersheds (and happens to include some watersheds within some 

Roadless and Wilderness areas). Rather than encompass those entire 

subbasin watersheds (or, for that matter, the entire Columbia River 

watershed in which the project also occurs), the Tollgate project area 

incorporates substantial portions of surrounding watersheds, and in so 

doing strikes a balance between being extremely large (and inappropriate 

for project-level analysis), while still remaining expansive enough to 

encompass the expected likely effects of the project. Again, this balance is 

also struck while remaining consistent with the intent of the Eastside 

Screens amendment to incorporate ecologically meaningful and 

appropriate land areas. 

Furthermore, the Tollgate project vegetation analysis area was utilized at 

the scale described in the FEIS because it was designed to be coordinated 

and integrated with the geographic scale of the project wildlife habitat 

analysis incorporating old forest structure—particularly to demonstrate 

compliance with the Wildlife Standard of the Eastside Screens Forest Plan 

Amendment.

Finally, because the Forest Service can find no rational justification, legal 

requirement, nor agency precedent to restrict the landscape-scale 

vegetation and wildlife habitat analysis of project-level effects to nonWilderness and non-Roadless areas for its own sake (and in contradiction to 

established agency protocols), such an approach runs the risk of becoming 

unlawfully arbitrary and capricious. 
Tollgate Fuels Reduction Project FEIS

G-99

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p- 3-50 

Interpreted comment: 

a) Historical percentages are based on what field data, from where and when? 

This “excess” old forest calculations is highly suspect unless it is inflated by 

including the Wilderness, Roadless, PWA, and undeveloped lands. 

b) Re: Table 3-25: High density does not automatically translate into 

uncharacteristic fire risk – especially not when its in cool moist forest (95% of 

the project area!) thus it also doesn’t translate into the “need” for fuel 

reduction 

c) Is it possible that table 3-26 reflects missing forest acreage from past logging 

compared to historic conditions for the moist PVG – the high range of acres 

historically is higher than the total acreage now. 

Response:

a) With respect to the “inflation” component of this comment, this has been 

noted, and see response (d) of comment 3-49 above. 

b) We generally agree with the comment that high density, per se, does not 

automatically translate into uncharacteristic fire risk. However, we 

disagree with the interpretation of “need” implied by this comment. The 

purpose and need of the Tollgate project, as described in Chapter 1 of the 

FEIS, is not to lesson “uncharacteristic” fire risk, for its own stake. Indeed, 

as stated on page 1-3, “the (Tollgate) plateau is generally characterized by 

mixed to high-severity fire regimes,” and the project purpose and need is 

not to change current conditions because fire risks are “uncharacteristic,” 

but instead because current crown fire risks are, in some locations, 

“characteristically” and unacceptably high for these fire regimes. 

At the same time, this comment is also well-taken in the sense that the 

terms “too much” as utilized on page 3-50 of the FEIS are unclear, and 

were replaced with more objective, clear, descriptive terminology for the 

FEIS within the silviculture analysis section of Chapter 3.

c) We respectfully disagree with this comment. The predicted high range of 

acres for low and moderate (but not high) density classes is indeed higher 

than the current low and moderate classes, but for each of the three density 

classes, the high historic range was not higher than the current total acres. 
Tollgate Fuels Reduction Project FEIS

G-100

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 3-51 

Interpreted comment: What was the field evidence from the project area – for the 

historical ranges projected by Schmitt and Powell? These are likely to be general 

estimates not necessarily applicable to the project area. 

Response:

The RV ranges estimated by Schmitt and Powell were provided for three 

groups based on biophysical environment (cold, dry, and moist upland forest). 

The density classes associated with each group were delineated using a process 

described in Powell (2009a). The actual RV ranges estimated by Schmitt and 

Powell (2008) and assigned to biophysical environments and density class were 

based on a variety of published and unpublished sources, including the draft 

Umatilla Land and Resource Management Plan (Forest Plan) Revision. Please 

note that the full reference information for Schmitt and Powell (2008) was not 

included in the Tollgate DEIS bibliography, but will be included in the FEIS. 

The Forest Plan Revision and other efforts contributing an awareness of 

reference conditions is best accomplished by consulting historical data sources, 

particularly maps depicting species composition, forest structure, and stand 

density. As Powell (2010b) describes and as utilized Schmitt and Powell (2008), 

the Umatilla National Forest has made considerable investments over the last 

20 years to locate and digitize relevant historical mapping, including maps 

derived from General Land Office survey notes collected in the 1880s, thematic 

maps depicting forest conditions in 1900, 1914-16, 1935-36, 1953-60, and 1987-

88; and topical maps portraying wildfires, insect outbreaks, and other 

disturbance processes. Many, if not most of these maps, were based on 

enormous amounts of field observations, many of which occurred in the 

Tollgate analysis area. 
Tollgate Fuels Reduction Project FEIS

G-101

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 3-65 

Interpreted comments: 

a) This is a unique and odd interpretation of Eastside Screens. Actually Eastside 

Screens require very specific protections, such as Pacfish & Infish buffers, no 

logging of trees >21” dbh except snags and OSHA hazard trees, and protective 

measures for N. goshawks

b) How can old forest be over representative in the area given historic higher 

amounts of old forest across the region and the forest past& ongoing logging 

has & is eliminating old forest structure. 

Response:

a) We respectfully disagree with this interpretation of Eastside Screens. 

While the Screens amendment may prescribe certain restrictions such 

prescriptions are not universal, if proposed activities fall under certain 

categories. Indeed, the Screens amendment specifically and explicitly 

allows exceptions to these restrictions under specific circumstances, such as 

those that have been found to exist for the activities proposed under both 

action alternatives for the Tollgate project in the DEIS.

b) The reasons that old forest structural stages described within the Tollgate 

DEIS currently exist above predicted historic ranges are numerous, and 

include the influence of fire suppression, a lack of historic timber harvest in 

some areas of the Tollgate analysis area, and the generally high 

productivity of many moist upland forest biophysical environments. These 

reasons are also described within the discussion of historic and ongoing 

trends of “no-action” in the DEIS on pages 4-26 and 4-27. 
Tollgate Fuels Reduction Project FEIS

G-102

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-28 

Interpreted comment: 

a) .... “late seral” tree species dominance as true firs and Engelmann spruce is 

natural for this area as fire is infrequent due to moist conditions. 

b) We are opposed to artificially converting natural “late seral” spruce-fir forest 

to timber industry preferred “early or mid-seral” species such as western larch 

& Douglas-fir. 

c) Likewise, we are opposed to converting OFMS to OFSS when OFMS is 

naturally there due to moist habitat conditions. 

Response:

a) The extent to which true firs and Engelmann spruce existed within the Tollgate 

analysis area under pre-settlement fire (and other) disturbance regimes is 

described within the Tollgate DEIS on page 3-48, in Table 3-22. 

b) This comment has been noted. As is described in Chapter 3 of the Tollgate DEIS, 

the longstanding practice of fire suppression within an around the Tollgate 

analysis area has affected forest vegetation species composition, perhaps to a 

greater degree than is suggested by the use of the term “natural” in this comment. 

c) This comment has been noted. The Tollgate FEIS describes, similar to response (b) 

above, that the “natural” preponderance of old forest multi-story structure classes 

is due, in part, to “unnatural” fire suppression activities occurring over a 50+ year 

period. 

Additionally, on page 4-30 of the FEIS (Figure 4-1 in particular) the Tollgate DEIS 

also states that in many moist upland forest locations, an old forest single-story 

structure class may develop and persist, enabled (perhaps in part) by the 

development of a shrub understory dominated by big huckleberry (Vaccinium 

membranaceum) or other fern and forb species which out-compete regenerating 

conifer seedlings for light, water, and/or other resources. 

In aggregate, we are somewhat confused by the content of these comments. While 

some (such as comment 3-49) suggest that the abundance of old forest structural 

stages (including old forest multi-story classes) is related to fire suppression, others 

(such as comment 4-28 (b)), deny any such connection, and that existing 

structural conditions are “natural” (to the extent that fire suppression 

activities are not “natural”). 
Tollgate Fuels Reduction Project FEIS

G-103

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-29 

Interpreted comments: 

a) Not analyzed is the controversial primary effect of removing trees >21” dbh in 

increasing the regional deficit in trees >21” dbh due to past and ongoing 

logging and setting back goals of returning needed large structure to the 

landscape – live, snags, and down wood 

b) ....all trees >21” dbh should be retained as their removal does not assist 

meeting the project’s purpose and need, violates the Eastside screens, and 

degrades wildlife habitat. 

c) Further, removing trees >21” dbh removes larger, more fire-resistant trees. 

Response:

a) In response to the “regional” element of the above comment, the 

geographic scope of the vegetation analysis of the Tollgate fuels reduction 

project is described on page 3-44 of the FEIS. The geographic analysis area 

was chosen for reasons described in response to comment 3-49 (d) above. In 

addition to these reasons, a larger geographic area was not analyzed 

because such analysis was not necessary to meet the purposes of issue 

analysis as described on page 1-17 of the FEIS. 

b) The extent to which adopting Alternative B (which includes the removal of 

some trees >21” DBH) is expected to meet the project purpose and need in 

contrast to Alternative C (which includes a 21” diameter limit) is discussed 

on pages 4-61 through 4-64 of the Tollgate DEIS. This analysis clearly 

shows that removing some trees >21” DBH, in combination with other 

differences between Alternatives B and C, contributes toward moderating 

fire behavior in a manner that meets the project purpose and need to a 

greater degree and extent than Alternative C. For large, patchy areas 

within stands and activity units dominated by large, dense, trees >21” 

DBH, the ability to conduct surface and canopy fuels reduction activities is 

expected to clearly contribute to toward meeting the project purpose and 

need by raising canopy base height, decreasing canopy bulk density, and 

reducing the amount and continuity of surface fuels. 

In the silviculture section of Chapter 4, differences of stand structure 

resulting from the diameter limit in Alternative C were noted on pages 4-29 

and 4-40 of the FEIS: 

The primary difference between the effects of removing trees >21” 
Tollgate Fuels Reduction Project FEIS

G-104

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

DBH in several units under Alternative B relative to Alternative C is 

that more sub-dominant trees in the canopy would be removed under 

Alternative B in order to attain final residual fuels and tree density 

objectives, but at the stand and unit scale, this would generally not 

affect the distribution of structural classifications described in this 

chapter.

The consistency of the alternative B, which includes the proposed removal 

of trees >21” DBH, with eastside screens, is described on page 4-44 through 

4-50 of the DEIS. As noted on page 4-48, the activities which include 

harvest of trees >21” DBH would occur in either dry upland forest or moist 

upland forest biophysical environments, and thus fall under Scenario B of 

Eastside Screens, which, contrary to the assertions of this comment, does 

not prohibit all cutting of trees, >21” DBH. 

c) We agree that trees >21” DBH are more fire-resistant than smaller trees of 

the same species. Despite what the p.4-29 comment suggests, however, we 

also note that a 22” DBH subalpine fir with a crown base height of 2 feet is 

generally less fire-resistant than a 20” DBH ponderosa pine with a crown 

base height of 30 feet. As noted throughout the Tollgate DEIS, the 

silvicultural prescription for all cutting units is to prioritize the largest, 

most fire-resistant trees for retention, while also meeting surface, ladder, 

and canopy fuels reduction objectives. 
Tollgate Fuels Reduction Project FEIS

G-105

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-46 

Interpreted comment: 

a) Yet alt B jettisons Pacfish requirements & thus violates the Eastside screens 

riparian standard. 

b) A Forest plan amendment does not ensure consistency with the Forest Plan, 

Pacfish, or the Eastside Screens, but is instead being used to violate all three 

c) How can the Forest Service use a site-specific temporary Forest Plan 

amendment? 

d) A “stocking” recommendation should not trump a legal requirement to protect 

federally listed species

Response:

a) As described on page 4-46 of the Tollgate DEIS, Umatilla National Forest 

Policy is that Amendment #10 to the Umatilla National Forest Land and 

Resource Management Plan would be applied in lieu of the riparian 

standard from Eastside screens. It is Amendment #10 which is commonly 

referred to as Pacfish. As stated on page 4-46 of the Tollgate DEIS, “(This) 

policy means that applying Pacfish also meets the Eastside Screens riparian 

standard.” 

b) We disagree. As described in the FEIS the Forest Plan amendment would 

amend the PACFISH standards. Once the standard has been amended 

associated RHCA activities would thus be in compliance with PACFISH 

and the Forest Plan, as amended. The project is consistent with Eastside 

Screens as described in the Vegetation section of Chapter 4, and 

consistency findings for other resources elsewhere in Chapter 4 of the 

FEIS. 

c) The establishment of a Forest Plan amendment is authorized utilizing 

criteria set forth at Forest Service M 1926.5. 

d) This comment has been noted. We agree that a stocking recommendation 

should not trump a legal requirement, and the exception provided by the 

Pacfish amendment makes no such assertion. 
Tollgate Fuels Reduction Project FEIS

G-106

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

 p. 4-49 

Interpreted comment: 

a) These would degrade and reduce LOS structure needed by LOS-associated 

wildlife, not “maintain” LOS characteristics (structure) that define LOS and 

contribute to its quality and habitat 

b) Logging of trees > 21” dbh under Alt. B could violate item 2, scenario B 

requirements to maintain connectivity between LOS and DOG stands, as acres 

left with less than 10 trees >21” dbh could result in isolated groves of stands 

defined as old forest. Acres can be identified differently on the ground, resulting 

in this effect. 

Response:

a) Although removal of trees will change the character of some LOS stands 

for a period of time, the planned harvest meets with the intent of the 

Eastside Screens to maintain adequate amounts of old forest. See 

vegetation response below. 

b) As the silviculture section of Chapter 4 in the Tollgate DEIS makes clear, 

no Late Structure (LOS, or Old Forest structural stage) stands would be 

removed or diminished as a result of implementing either action 

alternative. If there are any stands with mean tree-per-acre values “left” 

with less than 10 trees >21” DBH, it is because they are currently in this 

condition. We agree that there may be isolated stands of old forest 

structural stages following activity implementation under either action 

alternative, but this is only because they are currently isolated; as stated on 

page 4-50 of the Tollgate FEIS, neither action alternative is expected to 

increase old forest isolation or fragmentation. 

The Forest Service is aware from its understanding of basic statistics that 

sampling location and spatial scale can result in different trees per acre 

values, and even different estimates of mean trees per acre for an entire 

stand. We understand that it is theoretically possible for a person to go out 

into the forest and find an acre that has more, or less large trees than the 

mean trees per acre estimated for a stand as a whole. Our estimates of trees 

per acre for entire stands are based on standard sampling methodologies, 

are unbiased, are widely utilized and accepted in the field of forestry, and 

are referenced within the DEIS and silviculture resource report. 

We are aware that implementation of the activities proposed under 
Tollgate Fuels Reduction Project FEIS

G-107

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

Alternatives B and C could result in a somewhat patchy arrangement of 

residual trees across an entire stand (indeed, many comments received 

during project analysis suggested this as a desired outcome); however, 

within the activity units, marking crews would be directed to maintain an 

average of 10 or more trees per acre >21” DBH. We are confident in the 

professionalism and skill of experienced Forest Service personnel to follow 

the instructions given by the NEPA Decision documents and marking 

guides. Because existing stands are generally homogeneous in tree 

distribution, we believe that in nearly all areas the residual stand as a whole

will be fully stocked with large, vigorous trees, even if the distribution of 

trees is slightly patchy. 

As is stated in the wildlife report, these slightly patchy, but fully-stocked 

stands would remain suitable as connectivity corridors between LOS and 

DOG stands. Additionally, within Old Forest/LOS stands, it is our 

expectation that the residual stands will be somewhat patchy, but not 

enough to further isolate such stands, and certainly not enough make the 

activities inconsistent with Eastside Screens requirements to maintain 

connectivity. Again, this is because existing stands are dense and 

homogeneous enough to allow for a well-stocked residual stand using a 

thin-from-below prescription. Detailed discussion of how the activities 

proposed under Alternatives B and C are consistent with Scenario B and/or 

A requirements to maintain connectivity between LOS and DOG stands 

are included in both the silviculture and wildlife analysis and consistency 

findings sections of Chapter 4. 

p. 4-53 

Interpreted comments: 

a) Yet there’s an overall reduction in carbon storage and a net release of CO2. 

This is not “mitigation” but exacerbation of climate change. 

b) Moist mixed conifer forests with adequate precipitation as in the Tollgate 

project area do not experience “chronic stress” from tree density. Trying to 

artificially convert one naturally occurring forest type to another does not 

improve “adaptability.” 

c) Yet mid to high-severity wildfire is not “uncharacteristic” for this forest PVG 

and thus there is no stand “vulnerability” issue. 

Response:
Tollgate Fuels Reduction Project FEIS

G-108

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

a) We disagree. Nowhere in the Tollgate DEIS do we state an expectation of 

likely overall reduction of carbon storage and net release of CO2 as a result 

of implementation of the Tollgate DEIS over the long term. As stated on 4-

60, the overall effect of the activities proposed under either action 

alternative is dependent upon a host of extremely uncertain and highly 

unpredictable variables, and is thus itself uncertain. Instead, we state on 

page 4-53 of the DEIS that maintaining productive, crown fire-resistant, 

fully-stocked forest cover contributes to a “maintain forest area” climate 

change mitigation objective, particularly relative to high-severity 

disturbance events. 

To the extent that planned activities may result in carbon emissions, they 

may be considered to contribute to global carbon emissions and indirectly 

contribute to related climatic variability; however, again, the extent to 

which the proposed activities maintain productive, healthy, large trees and 

forest relative to fire-killed decomposing forests suggests the possibility for 

substantial C sequestration and mitigation effects.

b) The effects of high density levels such as those seen in the Tollgate area on 

tree susceptibility to physiological stress and resistance to disturbances are 

widely accepted within the professional and scientific forest management 

community, and thoroughly documented in the scientific literature. 

Pertinent findings from this body of literature are disclosed in the Tollgate 

DEIS on pages 3-51, and 4-35 through 4-37, 4-53, and 4-56. Furthermore, 

the conversion of one structural class, species assemblage, or density class 

to another is indeed expected (based on abundant support in the scientific 

literature and professional experience) to improve forest adaptability to 

climate change-related stresses. Tree physiological vigor would be elevated 

relative to conditions resulting from the “no-action” Alternative, which 

improves the capacity to survive and/or regenerate following increasingly 

severe and widespread drought, wildfires, insect outbreaks, or wind events. 

c) The DEIS describes how “silvicultural activities addressing stand 

vulnerability to uncharacteristic levels of wildfire...could meet multiple 

goals of near-term mitigation and mid-term adaptation even as practices 

also reflect goals for other ecosystem services such as late-old structure and 

water quality (Joyce et al. 2009).” The intent of this statement was to 

describe the effects of such activities with respect to climate change 

mitigation and adaptation strategies, and not to suggest that such strategies 

form the basis of the purpose and need of the Tollgate project. The 

wording for this paragraph will be modified slightly for the Tollgate FEIS 
Tollgate Fuels Reduction Project FEIS

G-109

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

to further avoid such suggestion. 

Indeed, the primary “vulnerability” issue related to the Tollgate project 

Purpose and Need is the vulnerability of the Values at Risk identified in 

Chapter 1 to active crown fire, and the proclivity of nearby stands to 

support active crown fire under existing climate conditions. As stated 

earlier, we understand that the biophysical environment on the Tollgate 

plateau historically supported mixed to high-severity fire regimes (although 

we also maintain that in areas characterized by Fire Regime Condition 

Class 2 and 3, existing conditions are still moderately to severely departed 

from historic conditions associated with even these regimes). 
Tollgate Fuels Reduction Project FEIS

G-110

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-56 

Interpreted comment: 

a) Logging also impairs forest vigor and integrity by damaging soils, removing 

moisture retention from tree canopy removed, potentially increasing fire risk, 

and suppressing natural disturbances that create niches for increased 

biodiversity. 

b) Preemptively removing forest in order to save it is contradictory and releases 

more carbon than wildfire 

Response:

a) The effects of activities proposed under both action alternatives on soil 

productivity and associated tree vigor, hydrologic cycles, fire risk, and 

biodiversity are all discussed in chapter 4 of the Tollgate DEIS. Although 

activity effects may result in short-term and/or localized detrimental 

impacts (all of which are thoroughly identified and discussed in Chapter 4), 

on balance, the activities are expected to improve tree physiological vigor 

and productivity, as well as understory vegetative diversity. Natural 

disturbances are not expected to be “suppressed” as a result of 

implementing the proposed activities; rather, disturbances are expected to 

continue at levels and severity more consistent with ranges of variability, 

and lower than what would be expected under a no-action alternative and 

climatic change scenarios. 

b) The activities proposed under both action alternatives do not constitute 

“forest removal” or deforestation—they are intermediate treatments and 

will result in the retention of well-stocked forest cover. The likely expected 

effects of the project with respect to carbon emissions and climate change 

and in comparison to wildfire disturbances are described on pages 4-53 

through 4-60. 

BOTANY

PAGES: 4-67 

Comments that provide general statements or opposition in this section have been noted.
Tollgate Fuels Reduction Project FEIS

G-111

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-67 

Interpreted comment: 

a) So drop units 73 & 49 to avoid these impacts to sensitive listed Gray and 

Mountain moonworts 

b) Why aren’t the effects of the Tollgate project analyzed in combination with 

other cumulative effects to sensitive listed plants such as invasive plant spread? 

c) There is no analysis supporting the conclusion that the action alternatives won’t 

contribute to uplisting or loss of viability for gray & mountain woonworts. 

Response:

a) Given the finding that the proposed activities would not contribute to trend toward s federal 

listing or cause a loss of viability to the Botrychium population or species, dropping units 73 

and 49 to avoid indirect impacts to listed was not deemed necessary to remain consistent 

with applicable laws and regulations, was not productive with respect to the project purpose 

and need, and thus was not chosen as a component of an action Alternative. Furthermore, 

the R6 Special Status Species list was changed in December of 2011 and gray moonwort no 

longer has sensitive status. This change in status was not reflected in the Tollgate DEIS, but 

will be reflected in the FEIS. 

b) The paragraph and sentence in the Tollgate DEIS associated with this comment, in 

combination with the invasive plant analysis beginning on page 4-68, do exactly as the 

comment suggests: it analyzes the direct and indirect effects of the Tollgate project (such as 

the changes in risk of exotic plant invasion resulting from the Tollgate project) in 

combination with the direct and indirect effects to listed plants (such as the existing and 

reasonably foreseeable future risks of exotic plant invasion resulting from past/ongoing 

weed infestations) that overlap in space and time. 

c) As stated above in part (a), the R6 Special Status Species list was changed in December of 

2011 and gray moonwort is no longer has sensitive status. The sensitive mountain moonwort 

plants are not in unit 49, but approximately 0.1 mile to the north. Design criteria in 

Chapter 2, table 2-7, item 91 protects these plants from direct disturbance by creation of a 

‘no activity zone’ with no ground disturbance, trees directionally felled away, no slash 

piling, no equipment allowed. The indirect impacts considered from the risk of invasive 

plant spread and changes to site characteristics such as hydrology and microclimate are 

expected to be minimal. Indirect effects on the mountain moonwort, which are already 

minimal, are further minimized by multiple design features to prevent the spread of 

invasives in the project area and the creation of a ‘no activity zone’ where the plants are 

growing. Finally, the majority of Botrychium sites discussed in Chapter 3 affected 

environment are greater than 0.5 miles from proposed project activities—well outside zones 

of indirect or cumulative effects resulting from implementing activities described under 

either action Alternative of the DEIS. 
Tollgate Fuels Reduction Project FEIS

G-112

WILDLIFE –

PAGES: S-ix, 1-20, 1-21, 2-19, 4-29, 4-46, 4-73, 4-74, 4-78, 4-80, 4-82, 4-88

Comments that provide general statements or opposition in this section have been noted.

Pages:

iv, 1-8, 

3-49, 3-58, 

4-29, 4-47, 4-49 

Comment:

Disagrees that the amount of old forest is above HRV, therefore taking trees > 21 

inches DBH trees violates the Eastside Screens.

Does not agree that old forest is over represented and well connected; reference to 

ICBEMP old growth trend; project will contribute to regional deficit of old forest, 

snags and down wood. 

Response: see response to page 3-49 and 4-49 under Vegetation Heading

p-ix Comment:

Not likely to adversely affect statements for TES fish and wildlife species is not 

supported by surveys to determine viability thresholds. 

Response:

Chapter 3 provides information about surveys and habitat analysis methods 

used to determine effects to TES species. Chapter 4 wildlife section has been 

modified to better explain the context and intensity of effects.

p-1-20 Comment:

Scale of analysis for cumulative effects to wildlife is too small. District and forest 

scale should be included.

Response:

Larger scales are considered in cumulative effects for many species where 

appropriate. See Chapters 3 and 4. 

p-2-19, 4-5 Comment:

Snag retention is lower than expected under natural conditions. Retain all large 

down and all snags > 15 inches DBH. 

Response:

Actually under natural conditions, there would be more areas that would have 

3 large snags per acre. See Figure 3-9. Regardless, all large snags will be 

retained except for the occasional hazard tree. This will be clarified in the final 

EIS (page 2-4). 

P- 4-49 Comment:

Logging trees > 21” dbh would degrade and reduce LOS structure needed by LOSassociated wildlife, not “maintain” LOS characteristics (structure) that define LOS 

and contribute to its quality and habitat. 

Response: 

Although removal of trees will change the character of some LOS stands for a 

period of time, the planned harvest meets with the intent of the Eastside 
Tollgate Fuels Reduction Project FEIS

G-113

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

Screens to maintain adequate amounts of old forest. 

ROADLESS/PWA/OTHER UNDEVELOPED LANDS –

PAGES: S-iii, S-ix, S-x, 1-14, 3-93, 3-98

Comments that provide general statements or opposition in this section have been noted.

p-S-x Response;

In reference to comment asserting that logging in Lookingglass IRA is in violation 

of prohibition of logging in IRAs. 

Fuels reductions activities proposed in the Lookingglass IRA has been 

determined to be consistent with the 2001 Roadless Area Conservation Rule 

(RACR) 36 CFR 294. The rationale for this determination can be found in the 

FEIS on page 4-125.

p-S-x Response:

Commenter states they are strongly opposed to logging in IRAs PWAs and Other 

Undeveloped Lands. Stated concerns re; impacts to other undeveloped lands. 

Your comment has been noted.

p-1-14 Response:

In reference to stated assertion that logging within IRA does not meet the allowed 

exception #1-ii, 2 and 4 

Please see the consistency finding for the 2001 Roadless Area Conservation 

Rule (RACR) at the end of Chapter 4.

p-3-93 Response:

In reference to stated assertion that logging and roading in IRAs is not disclosed and 

honored. 

The effects of fuels reduction activities are disclosed in the FEIS, pages 4-52 

through 4-59. 

p-3-93 Response:

In reference to stated assertion that PWA inventory conducted by the FS with the 

purpose of identifying potential wilderness areas in the National Forest System is 

direct contradiction to the statement in the DEIS that PWAs are not a land 

designation decision, not an evaluation of potential wilderness (FSH 1909.12 

Chapter 72) and not preliminary administrative recommendations for wilderness 
Tollgate Fuels Reduction Project FEIS

G-114

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

designation (FSH 1909.12 Chapter 73). 

Commenter asks why they are called ‘potential Wilderness area’. The 

statements are not contradictory. Areas of potential wilderness are an 

inventory.... Not a land management designation.

p-3-96 Response:

Commenter states they are strongly opposed to and management activities in PWAs. 

Your comment has been noted.

p-3-96 Response:

In reference to stated assertion that the Forest Plans is dated and direction for IRAs 

is superseded by the RACR prohibitions against logging and raods in IRA’s.

The Umatilla National Forest LRMP is the management direction for the 

Umatilla National Forest until such time as the Forest Plan is revised. 

Management of Inventoried Roadless Area is managed in accordance with the 

rulemaking in the 2001 Roadless Area Conservation Rule (RACR). As is 

clearly identified throughout the FEIS and specifically in the RACR 

consistency finding on page 4-125.

p-3-98 Response:

In reference to stated assertion that Forest Plan management area allocations have 

been superseded by more recent Congressional and Court decisions establishing 

IRAs as a management area category with prohibitions against logging and roading 

within them. Asks why the Walla Walla Ranger District is pretending this is not the 

case.

We disagree. In some locations Forest Plan management direction has been 

augmented by such rulemaking (i.e. 2001 RACR). See RACR consistency 

finding on page 4-125 as well as Forest Plan consistency findings throughout 

Chapter 4.

p-3-98 Response:

Commenter stated that fire is a natural disturbance, not a threat to “naturalness”.

The activities associated with fires (e.g. fire suppression) may have effects that 

are a threat to naturalness; for example fire related activities may introduce or 

spread of noxious weeds.

p-3-98 Response:

Commenter states the use of motorcycles and any other motor vehicles within IRAs 

should be prohibited. 

Your comment has been noted.
Tollgate Fuels Reduction Project FEIS

G-115

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

HYDROLOGY –

PAGES: S-vii, 1-5, 1-10, 2-10, 2-13, 3-11, 3-15, 3-16, 4-8, 4-9, 4-13 

Comments that provide general statements or opposition in this section have been noted.

p-S-vii

comments on FM1a amendment 

Response: Project description FEIS page 2-10 and the Design Criteria and Best 

Management Practices FEIS Table 2-7 page 2-14 describe the protections 

which protect channel stability; avoidance by equipment and no-vegetation or 

down wood removal buffers.

p-1-5

comments on 

cleaning ponds 

Response: Project description for pond cleaning and design criteria to protect 

water quality are found in the FEIS page 2-5 and Table 2-7 page 2-14

p-1-10

comments on 

MOA with DEQ 

and F Plan 

Monitoring

Response: The MOA with ODEQ identifies implementation of BMPs as the 

method of meeting State water quality regulations. Forest Plan monitoring, as 

well as other monitoring evaluates the implementation and effectiveness and is 

the feedback loop to improve practices. 

p-2-10

comment on FM1a Forest Plan 

amendment; as 

above 

Response: Project description FEIS page 2-10 and the Design Criteria and Best 

Management Practices FEIS Table 2-7 page 2-14 describe the protections 

which protect channel stability; avoidance by equipment and no-vegetation or 

down wood removal buffers. 

p-2-13

question about 

effects in U-19 

Response: No treatment buffer would protect. See FEIS Table 2-6 pg 2-13 and 

see water temperature and erosion/sedimentation effects discussion for U-19 in 

the FEIS pages 4-7 to 4-9. 

p-3-11

road 3718155 

Response: This road is proposed for decommissioning and 2 culverts would be 

replaced. See project description FEIS page 2-6 and Table 2-7 page 2-16.

p-3-15 &16

CWA comments

Response: Design Criteria and Best Management Practices have been 

identified to protect water quality and effects have been analyzed and found to 

be unmeasurably small or not to exist. See FEIS Table 2-3 and Table 2-7 pages 

and pages 4-6 to 4-16. State of Oregon has completed evaluations of water 

temperature during the Total Maximum Daily Load (TMDL) process. See 

FEIS pg. 3-15. There are no 303d category 5 listings in the Tollgate project 

area. Listings have been moved from the 303d category 5 list (water quality 
Tollgate Fuels Reduction Project FEIS

G-116

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

impairments requiring development of a TMDL) to 303d category 4a, b, or c’ 

impariments not requiring TMDL. Implementation monitoring has occurred 

see FEIS pages 4-14, 15. 

p-4-8 water

temperature

Response: Local springs are the origin of the streams in these units; ground 

water contributes the whole flow and controls water temperature in them. 

FEIS page 4-8.

p-4-9 Response: Buffer widths are described in the FEIS see Table 2-3 page 2-10. 

Sedimentation would be immeasurably small, based on design criteria FEIS 

Table 2-7 page 2-14.

p-4-13

sedimentation 

from roads 

Response: Maintenance of roads is primarily focused on correcting problems 

with drainage; culvert cleanout, necessary ditch clean out and public safety. 

Regarding the importance of drainage maintenance see references: Luce, 1999; 

Moore, 2005; and Reid, 1984; FEIS Bibliography

Direct and indirect effects to water quality from RHCA thinning are analyzed 

and found to be negligible or not to occur; see FEIS pages 4-6 to 4-10.

SOILS –

PAGES: 3-6, 4-5, 4-9 

Comments that provide general statements or opposition in this section have been noted.

p3-6 Response: In reference dropping units with moderate to high detrimental soil 

conditions. To follow the recommendations of the commenter would not allow 

the Forest to do restorative projects to reduce existing detrimental soil 

conditions. The timber sale contract will offer both equipment and opportunity 

to do restoration without additional cost to the Forest Service. It is expected 

that this restoration will aid in the stand development toward a healthier stand.

P3-6 Response: In reference to dropping units 31, 67, 104 and 105. While we do not 

have completed information on the cumulative detrimental soil conditions 

within those units, we do know the effects seen in harvested in the same 

manner and era, which allows us to estimate the expected detrimental soil 

conditions likely to be found. Given the high percentage of units that were 

evaluated, there is high confidence that assumptions are accurate.

P 4-5 Response: In reference to a missing table. Please see Appendix E

P 4-5 Response: In reference to the concern that the proposed project could reduce 

levels of snags and course wood in harvest units. While an assumed loss may 

occur; levels will be maintained by needs for other resource areas and are not 
Tollgate Fuels Reduction Project FEIS

G-117

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

expected to fall below amounts defined within the LRMP.

P 4-5 Response: In reference to false conclusion on soil impacts. The intended 

information shows that outside of road surfaces the resilience of the soil allows 

for recovery within 1 to 5 years.

P 4-5 Response: In reference to proposed mitigation. Decompaction has been shown 

by a variety of authors and empirical evidence to allow soil conditions to be 

considered restored. Three examples of this information are 

Froehlich, et al. 1985. Soil bulk density recovery on compacted skid trails in 

central Idaho. Soil Science Society of America Journal. 49: 1015-1017. 

Heninger, et al. 2002. Soil disturbance and 10-year growth response of coast 

Douglasfir on nontilled and tilled skid trails in the Oregon Cascades. Can. J. 

For. Res. 32: 233–246. 

Luce, C.H. 1997. Effectiveness of Road Ripping in Restoring Infiltration 

Capacity of Forest Roads. Restoration Ecology Vol. 5 No 3. pp.266-270. 

The Froehlich paper reports a recovery in physical terms. The Heninger paper 

reports the difference to vegetation between tilled and non-tilled trails. The 

Luce paper recommends the use of organic matter on treated soil to prevent 

soil crusting and potential erosion.

P 4-9 Response: In reference to quantity of sediment. When working at close 

proximity to culverts it is expected that some measure of sediment will be 

created. However this amount will tend to be a single input and is not likely to 

be a chronic or measurable source of sediment.

FISHERIES –

PAGES S-vii, 3-17, 3-18, 3-22, 4-23, 4-24 

Comments that provide general statements or opposition in this section have been noted.

p- vii Comment: ‘and what is “the manner that avoids adverse effects on ESA-listed 

anadromous fish”? How is it possible to avoid impacts without Pacfish buffers? 

What guarantee do we have that these impacts will not occur.’

Response: See page 1-6.

p- 3-17 Comment: “What about downstream effects to fish of raising water temperatures & 

increased sedimentation?”

Response: As stated on pages 3-16 & 3-17 and explained later in the document 

(pages 4-18 & 4-19), the design of the project (buffer widths and distance to 

fish-bearing streams) water temperatures would not be affected anywhere, and 

changes in stream sedimentation are very unlikely.

p- 3-18 Comment: “Yet this is not accounting for long term loss of tree canopy, large live 

& snag tree structure, reduction in down wood & hiding cover, sedimentation of 
Tollgate Fuels Reduction Project FEIS

G-118

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

streams and increased stream temperature, exacerbated flooding, depletion of soil 

nutrients, etc. likely to persist longer than 10 years. 

Response: Here the commenter mixes components of fish and aquatic habitat 

with other, non-aquatic, features (tree canopy, large live trees and snags, soil 

nutrients). The section that is referenced on page 3-18 addresses only to fish 

and aquatic habitat. No reason for the assertion that effects to stream 

temperature, sedimentation, flooding, or down wood (in streams) would persist 

for longer than 10 years, and we have explained elsewhere (in Chapter 4) that 

effects are either not expected at all or are very unlikely.

p- 3-18 Comment: “we are very concerned by potential impacts to Columbia river bull 

trout, which are at risk throughout most of their range and have lost a lot of their 

historic habitat.”

Response: Your concern is noted. The Tollgate project is designed to avoid 

effects to bull trout or their habitat. 

p- 3-19 Comment: We are concerned by potential negative effects of the Tollgate project 

to ESA Threatened Columbia River bull trout, snake River spring/summer Chinook 

salmon, Snake River steelhead trout, Mid-Columbia steelhead trout, and R6 

Sensitive redband trout (also MIS) and margined sculpin, particularly through 

logging in RHCAs and through stream crossings/log hauling. 

Response: Your concern is noted. The Tollgate project is designed to avoid 

effects to these species or their habitat. 

p- 3-22 Comment: “Why is this obstacle to steelhead spawning not removed?” [referring to 

the ODFW fish hatchery weir]

Response: The fish hatchery and weir are outside of the National Forest, and 

are not under the jurisdiction of the Forest Service.

p- 4-23 Comment: “Yet you can’t prevent large high intensity fires from occurring where 

they would naturally occur – the Tollgate project certainly won’t prevent such fires 

and logging often impairs habitat conditions needed by bull trout (witness the 

judge’s favorable ruling to protect fish from logging effects in the Tower Fire case).

Response: 1) The object of the project is not to prevent wildfires – we know 

that is not realistic – the object is to reduce the size and intensity of future 

wildfires and this is feasible. 

2) The Tower Fire case was about salvage logging after wildfire and the 

Tollgate project deals with fuels reduction ahead of potential future wildfires. 

p- 4-23 Comment: What about longer term residual effects of log hauling? These are 

cumulative effects that should have been analyzed... 

Response: As explained on pages 4-18 and 4-19, because Tollgate Project log 

haul routes are not near streams, sediment delivery to streams from log haul is 

not expected, and hence log haul would not contribute to cumulative effects. 

That is why log haul is not included in the cumulative effects discussion. 
Tollgate Fuels Reduction Project FEIS

G-119

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p- 4-24 Comment: Yet these conclusions [USFWS letter of concurrence regarding grazing 

allotments] were in 1998.

Response: The DEIS mistakenly identified the date of a previous letter of 

concurrence from USFWS. A new, more conservative, grazing allotment 

management plan, has been prepared, and the USFWS has once again 

concurred with a not likely to adversely affect determination for the allotment. 

So the same conclusion still holds. This new consultation was completed on 

February 23, 2011.

p- Comment: “This is still a cumulative effect stressing bull trout in combination 

with any other effects that could stress them” [referring to brook trout in Langdon 

Lake and Lost Creek].

Response: Agreed -- brook trout are a potential cumulative effect. That is why 

their presence is discussed in the cumulative effects analysis.

VISUALS –

PAGES 3-87, 3-88

Comments that provide general statements or opposition in this section have been noted.

p-3-87 Response:

In reference to stated concern and assertion that scenery stability criteria is biased 

toward activities favored by the Forest Service that cause significant impairment to 

scenic values: 

Scenic Stability is used in conjunction with Scenic Integrity which addresses 

impacts associated with logging activities. 

p-3-87 Response:

In reference to stated concern about maintaining scenery in a static condition:

Scenic Stability addresses the dynamic nature of landscapes. That is why 

Historic range of Variability (HRV) is used to determine what is beyond the 

historic range for size and frequency of stand replacement fire.

p-3-87 Response:

In reference to stated concern about the scenic degradation of logging:

Scenic degradation from logging is addressed with Scenic Integrity.
Tollgate Fuels Reduction Project FEIS

G-120

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p-3-87 Response:

In reference to stated concern that stand replacement fires are natural 

disturbances for this forest PVG, whereas logging causes unnatural scenic 

degradation: 

Stand replacement fire may be natural for the PVG but not to the scale that is 

probable due to previous fire suppression.

p-3-88 Response:

In reference to stated concern and assertion that equating scenic stability with 

fire regime condition class is fallacious reasoning:

Scenic Stability is designed to evaluate fire or other events by how they affect 

the scenic attributes. A question we address is, if there a loss, will valued scenic 

attributes remain and be expressed? Fire is not all bad, but when it rages at 

severities and scales that are beyond natural occurring events, scenic attributes 

can be negatively affected. Also associated with fire events are the fire control 

or suppression efforts. Many times these efforts cause more scenic impact.

p-3-88 Response:

In reference to stated concerns and assertion that equating stand density and 

species composition with fire regime condition class regardless of PVG is 

bogus:

Not regardless of PVG, it relates to stand data.

p-3-88 Response;

In reference to a question asking why known scenery attributes only identified 

as open stands of ponderosa pine and larch and those who appreciate denser 

mixed conifer: 

Denser mixed conifer is a scenic attribute if it can be managed in safe manner 

within the range or HRV. When it is a hazard or becomes denser than the 

natural range to past suppression, then it is no longer a scenic attribute.

p-3-88 Response:

In reference to statement that mixed high severity fire is the natural regime for 

the Tollgate planning area and moist cool forest types, in various places, are 

not uncharacteristic fire or more severe than historic range for cool moist 
Tollgate Fuels Reduction Project FEIS

G-121

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

forest;

Your comment has been noted. 

p-3-89 Response:

In reference to stated concern and assertion that most people do not judge 

scenic values as described through desired scenic stability; that the desired 

scenic stability condition stated in the DEIS reflects a lack of scientific 

accuracy and professional integrity. 

Most people judge scenic values the way scenic integrity addresses impacts. 

Scenic Stability addresses stressors and risks to scenic attributes that most 

people are not aware of. It is professionally responsible to consider impacts to 

scenery that are related to events that will cause the loss of scenic attributes as 

well as address the direct impacts of logging activities.

p-3-90 Response

In reference to the stated assertion that the forest service scenic values are conflated 

with unrelated forest service dogmatic determination to reduce fuels and prevent 

stand replacement fire no matter what....

Scenic values are not conflated. It is one resource of many being considered in 

the project effects analysis. Reducing fuels in areas where fuel loads are 

excessively high are known to reduce impacts to scenic attributes. 

CLIMATE CHANGE –

PAGES: 4-52, 4-58 

Comments that provide general statements or opposition in this section have been noted.

p. 4-52 Interpreted comment: 

a) It is by defining every project as too small for a direct evaluation of potential 

effects that no steps are taken to address these projects contribution to climate 

change cumulatively. 

b) This is a “de minimus” argument used to repeatedly avoid considering 

alternatives to exacerbating climate change.
Tollgate Fuels Reduction Project FEIS

G-122

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

c) The Tollgate & similar projects contribute to both cumulative deforestation 

(some areas don’t grow back) and fossil fuel combustion as well as to loss of 

carbon storage through removal of live trees, snags, & down wood which 

cumulatively becomes significant.

Response:

a) See responses to comments OW-27 and OW-28 above. We agree that 

national policy for climate change should carefully consider and take into 

account the collective emissions of numerous small sources; however, at the 

scale of project-level effects analysis, the likely effects of the project on 

carbon emissions are considered within the Tollgate DEIS to an 

appropriate level of depth and detail, commensurate with the context, 

intensity, likelihood, and duration of effects—and resulting importance on 

the decision being made.

b) See responses to comments OW-27 and OW-28 above. The description of 

project-level effects of possible carbon emissions in a context of global 

climate change is provided not to avoid considerations of alternatives, but 

rather, is consistent with CEQ guidance to clearly characterize the context 

and intensity of effects so that Decisions can apply the “Rule of Reason” 

and consider possible carbon/climate impacts to an appropriate degree 

commensurate with the likely impacts of the project. In addition, the 

Tollgate DEIS considers multiple alternatives (a no-action alternative and 

two action alternatives) to highlight differences of effects on carbon 

emissions for the Deciding Official to consider. 

c) We disagree that the Tollgate and “similar” projects contribute to 

deforestation. In fact, the intermediate treatments designed for the project 

are explicitly designed to retain forest cover in the context of expected 

climate change and the existing fire regimes associated with the Tollgate 

plateau. The extent to which the Tollgate project may result in fossil fuel 

combustion (through tree harvest activities) is described in the DEIS on 

page 4-59. The likely effects of the Tollgate project on carbon cycling 

through the utilization of live and dead trees as forest products, and 

mastication of down woody debris is placed in the context of mixed to highseverity fire regimes and described on pages 4-57 through 4-60. 
Tollgate Fuels Reduction Project FEIS

G-123

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-58 Interpreted comment: 

a) Logging trees considered vulnerable to climate change equals unnatural 

elimination of forest that could otherwise store carbon & survive wildfire – an 

additional stress more likely to cause forests to disappear. 

b) Logging is not carbon neutral, but a carbon source, yet this is not analyzed. 

Also not disclosed is science finding that logging releases more CO2 than 

wildfire. 

c) This science contradicts Alt B plans to log trees > 21” dbh & both alts. 

Emphasis on removing mature sawlogs 

d) Which is why it makes sense to log trees >21 inches? 

Response:

a) See response to comment 4-52 (c) above. Additionally, the Tollgate project 

is expected to retain forest cover, particularly in the context of climate 

change and expected changes in fire disturbance regimes. We are unaware 

how, as this comment suggests, removal of some (primarily understory) 

trees considered vulnerable to climate change and retention of other trees 

considered resilient and resistant to climate change would “eliminate 

forest” that could otherwise “survive wildfire,” or how the retention of all 

trees would alleviate stresses that threaten forest persistence. On pages 4-

52 through 4-60, the Tollgate DEIS describes in detail and extensively 

references the widely accepted understanding of the role of activities such 

as those proposed under the action alternatives in enabling forests to 

persist and adapt to changing climate and related stresses. 

b) The likely effects of proposed tree-cutting activities on carbon pools and 

fluxes are indeed analyzed, on pages 4-57 through 4-60 of the Tollgate 

DEIS. The relevant scientific research examining possible effects of 

intermediate thin-from-below tree harvest on fire regimes and carbon 

cycling is referenced and discussed with respect to the Tollgate project on 

pages 4-58 through 4-59 of the Tollgate DEIS. Included within this 

discussion is consideration of how harvest activities of the Tollgate project 

may result in higher, lower, or roughly equal CO2 emissions as wildfire 

occurring in the absence of implementation of project activities. 

c) Neither action alternative “emphasizes” the removal of “large sawlogs” –
Tollgate Fuels Reduction Project FEIS

G-124

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

rather, the thin-from-below prescription for most activity units instead 

prioritizes smaller trees for removal and larger trees for retention until a 

residual density is achieved which is expected to be resistant to active or 

passive crown fire under most conditions. This is consistent with the 

recommendations provided by Hurteau and North (2009) and North et al. 

(2009) as cited on page 4-58 of the Tollgate DEIS. Indeed, the activities 

proposed under both action alternatives are generally consistent with the 

statement in the DEIS citing the finding of these studies that “significant 

increases in fire resistance can be achieved by removing only smaller 

ladder fuels and fire-sensitive intermediate trees without reducing the 

majority of live-tree carbon pool associated with intermediate pines and 

large trees of all species. In some areas of the Tollgate project, additional

increases of fire resistance were desired in order to meet the project 

purpose and need, and which resulted in the proposed removal of some 

overstory trees, but in a manner consistent with the thin-from-below 

approach (which prioritizes the smaller trees for removal until a desired 

residual density is achieved) described above. 

d) See response to comment (c) above. Again, a thin-from-below prescription 

prioritizes smaller trees for removal, but when existing forest stands are 

very dense and dominated by very large trees much larger than 21” DBH, 

achieving a desired residual density consistent with fuels reduction 

objectives may occasionally involve the incidental removal of some trees 

approximately 21” DBH or slightly larger. Even these mid and large-sized 

trees are smaller than the residual overstory trees. 

It is worth keeping in mind that the primary purpose of the Tollgate 

project is not to retain all trees >21” DBH per se, but to reduce surface, 

ladder, and canopy fuels to the point where strategically located forest 

stands are resistant to active and/or passive crown fire under most 

conditions. Where the retention of all trees >21” DBH is consistent with 

this primary objective, such trees are retained. Under action Alternative B, 

where the retention of all trees >21” DBH would preclude attainment of 

primary fuels reduction objectives throughout the activity unit, harvest of 

some trees >21” DBH is allowed in pursuit of the project’s primary fuels 

reduction priorities, while still adhering to the basic approach of retaining 

the largest overstory trees in the stand. 
Tollgate Fuels Reduction Project FEIS

G-125

ROADS –

PAGES: 1-5 

Comments that provide general statements or opposition in this section have been noted.

p- Response:

Closed roads were generally closed for wildlife concerns between management 

activity cycles. Though closed to minimize wildlife disturbance, these roads 

remain available for management activities. After the activities these roads 

would again be closed. None of the roads present any “hydrologic flaw”. The 

disturbed areas along these reopened roads will be seeded with native seed, 

blocked and subsequently monitored for invasive species and effectiveness of 

the closure. 

PLANNING (MISC) –

PAGES: S-iii, S-iv, S-viii, 1-6 thru 1-9, 1-16, 2-8, 2-9, 2-11, 2-23, 3-2, 3-10, 3-16, 

4-14, 4-24, 4-26, 4-124, 4-125 

Comments that provide general statements or opposition in this section have been noted.

p. S-iii Response:

In regards to comments that treatments in the Lookingglass IRA and RHCAs 

are not necessary because they are excluded (or mostly excluded in the case of 

RHCA treatments) from alternative C, prove that they are unnecessary, we 

disagree. Alternative C was developed in response to public concerns and 

reflect an assessment by the IDT that these reduction of treatments would still 

meet the overall intention of the strategic placements just to a different degree 

(in this case likely less) than the proposed action.

This provides the Responsible Official with a range of alternatives which may 

be weighed during the deliberative process prior to making a decision.

p. S-iv Response:

In regards to assertion that removal of 21 inch trees requires a Forest Plan 

amendment, we disagree. Please see the Eastside Screens Consistency section in 

appendix F and discussion in Chapter 3. 

p. S-viii Response:

Please see the footnote #9 on page 2-8 of Chapter 2 of the FEIS which discusses 

the collaborative process associated with a HFRA project. This collaborative 

process was open to the public and the input received helped to develop the 

project’s Purpose and Need and develop the proposed action.
Tollgate Fuels Reduction Project FEIS

G-126

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 1-6 Response:

Should the Responsible Official decide to implement the proposed Forest Plan 

amendment then associated project activities will be in compliance with the 

Forest Plan. Should the Responsible Official choose not to implement the 

Forest Plan amendments then the associated project activities would be 

dropped and the project would still be in compliance with the Forest Plan.

p. 1-7 Response:

We disagree with the assertion that the EIS does not analyze and disclose the 

impacts of proposed actions on recreation within the project planning area. 

Please see page 3-82 to 3-86 in Chapter 3 of the FEIS as well as pages 4-92 to 4-

94 in Chapter 4.

p- 1-8 Response:

We disagree that the purpose and need is too narrowly defined. Please see 

chapter 1 of this FEIS.

p. 1-9 Response:

In regards to comment that RHCAs are currently degraded and will continue 

to be so and isn’t discussed in the EIS, we direct the commenter Chapter 3 for 

discussion of Existing Condition and then see Chapter 4 for discussion of 

project activity effects. 

p. 1-16 Response:

We disagree with the assertion that there was no collaborative process. We 

direct the commenter to footnote #9 on page 2-8 of Chapter 2. A brief 

description of the collaborative process used is also provided at this footnote.

p. 2-8 Response:

We concede that the exemptions listed are not met, as discussed on page 2-8. 

For this reason a Forest Plan amendment was developed. Please see the 

description of the Forest Plan amendment in Chapter 2 and the consistency 

finding for the Non-Significant Forest Plan Amendment at the end of Chapter 

4.
Tollgate Fuels Reduction Project FEIS

G-127

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 2-9 Response:

In regards to the assertion that ‘site specific Forest Plan amendments’ do not 

exist, we direct the commenter to the Forest Service Manual (FSM) 1926.5. 

p. 2-11 Response:

We disagree that actions proposed in Alternative B are “red herrings”, due 

to their elimination in order to be responsive to comments received during 

public scoping. These activities were eliminated and remaining actions were 

determined to still meet the intent of the project objectives although to a 

different degree than the proposed action (Alternative B). 

p. 2-23 Response:

The discussion that the Tollgate project is an authorized HFRA project is 

disclosed on page 1-1 of Chapter 1. 

p. 2-23 Response:

We disagree that the project will significantly degrade other resources as 

asserted by commenter. Please see disclosures of effects in Chapter 4. 

p. 3-2 Response:

In response to commenters question about analysis of cumulative effects, 

they are disclosed throughout Chapter 4 (Environmental Effects).

p. 3-2 Response:

In response to commenters comments that Tollgate Plateau is not being 

threatened by ecological processes (such as fire), this may be true for the 

vegetation, but the community located on the plateau could be threatened 

by fire. Much as it was during the 2005 Burnt Cabin Fire.

p. 3-10 Response:

We direct the commenter to the project description which describes that 

the road depicted in Figure 3-2 is being relocated upslope (out of the 

RHCA) prior to use for log haul and the existing roadbed (depicted in the 

photo) will be decommissioned. The road will be reclosed after project 
Tollgate Fuels Reduction Project FEIS

G-128

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

activities are completed and will remain ‘closed’ in accordance with its 

Access and Travel Management Plan designation. 

p. 3-16 Response:

The text on this page has been corrected and the proper reference has been 

included. 

p. 4-14 Response:

There is no discussion of grazing because this project is not expected to 

have any effects on grazing operations associated with NE Sheep Allotment. 

The cumulative effects of grazing on various resources is disclosed through 

cumulative effects discussions in Chapter 4. 

For further information on the consideration of range effects see the 

document entitled: “Consideration of Livestock Grazing and Rationale for 

Not Including a Range Effects Section within the Tollgate Fuels Reduction 

Project FEIS” located in the Tollgate project record.

p. 4-24 Response:

The DEIS mistakenly identified an earlier consultation with USFWS in 

chapter 4 (dated 1998). Chapter 4 has been revised in the FEIS to identify 

the more recent consultation. This consultation with USFWS for the North 

End Sheep Allotment was completed in 2011 with a letter of concurrence 

dated February 23, 2011. 

p. 4-26 Response: 

The Forest Plan is proposed for amendment in order to facilitate proposed 

activities within strategically important RHCAs in order to meet the P &N. 

The paragraph in question has been re-written to be more clear.

p. 4-26 Response:

The environmental effects for vegetation are displayed utilizing three 

indicators as displayed on the page. Other environment effects that the 

commenter mentioned as needing to be disclosed are disclosed in the 

document snags (pg. 4-82 to 4-84), downwood (pg. 4-79 to 4-82), CO2 (pg. 4-

53 to 4-61) of this FEIS. 
Tollgate Fuels Reduction Project FEIS

G-129

Letter #13 

Karen Coulter – Blue Mountain Biodiversity Project (BMBP)

*The following letter and handwritten comments, which were made in the margins of pages of the 

DEIS, are located in the project record. These handwritten comments were not typed into this table 

but they are referenced by DEIS page number on which they were written. Please see the project 

record to review the full body of the comments.*

Comment 

Number Comment and Response

p. 4-124 Response:

As stated elsewhere in these responses, the elimination of proposed 

activities doesn’t mean that there is “no” need for the treatments in order 

to meet the purpose and need. The inclusion (or exclusion) of these activities 

meets the Purpose and Need to varying degrees. 

p. 4-124 Response:

Please see RACR consistency finding on page 4-125. All Tollgate Project 

activitity units, with the exception of those specifically identified in Chapter 

2, have a diameter limit of 20.9 inches unless trees of a larger size pose a 

safety or operational concern. This project wide diameter limit applies to 

those units located in the IRA as well. 

p. 4-124 Response:

We disagree that the actions within IRA are not consistent with the P&N 

and that the consistency finding doesn’t agree with the breath of effects 

disclosures throughout the document.

p. 4-125 Response:

We disagree that harvest within PWA is an irreversible effect. As disclosed 

on page 4-130 of the FEIS that although signs of harvest will be visible for a 

period of time (several decades) this is not an irreversible 

effect/commitment of resources because signs of harvest are significantly 

unrecognizable the acres can be included in the inventory. Additionally, we 

disagree with the commenter’s speculation concerning the prerogative of 

Congress. Congress is not bound by any recommendation made by the 

USFS concerning Wilderness as it is Congresses determined and 

prerogative to exercise. 
Tollgate Fuels Reduction Project FEIS

G-130

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

TI-1

p-1 

Comment:

I am in general agreement with the purpose and need for action described in this 

EIS and I support Alternative B as it will treat the most acreage and have the largest 

benefit to the local communities and long-term health of the forest. However, I am 

disappointed with the limited amount of acres treated and refer you to my original 

scoping comments and collaborative team meeting minutes where priority was 

placed upon aggressively managing the treatment area to meaningfully reduce fire 

risk.

Response:

Your comment has been noted. 

TI-2

p-1 

Comment:

I support and understand the need to prioritize treatments within the WUI but not the lack 

of treatment of thousands of acres within this area that should and can be effectively and 

economically treated. In addition to not fully addressing the forest health issues and fire 

risk the proposed plan reduces the economic viability of the project such that less can be 

accomplished in areas that will not produce products of economic value. In the final EIS, 

please explain why the additional acreage within the WUI is not treated as well as the 

acreage outside of the established WUI.

Response:

Thank you for your comment. Please see response to comment BC -2. 

TI-3 

p-1 

Comment:

The EIS states that the proposed treatments will reduce the spread of crown fires to 

the local private ownerships as well as structure within the Umatilla National 

Forest. While this may be partially true, the proposal unnecessarily limits reduction 

of wildfire risk. With a significant amount of untreated areas it will remain likely 

that the area will experience crown fire.

Response:

Thank you for your comment. Please see response to comment BC -2. 

TI-4

p-1 

Comment:

Given the historic wildfire patterns and recognizing the frequent high wind conditions that 

exist in the area it is imperative that more acres within the WUI are treated to meaningfully 
Tollgate Fuels Reduction Project FEIS

G-131

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

reduce crown fire risk. As stated in the EIS, this area is home to 370 residences, 43 

privately owned cabins with FS special permits and the Spout Springs Ski Area. Even with 

the proposed fuels reductions around the structure, wildfire would still do extensive 

damage to other values within the project area.

Response:

Your comment has been noted. We direct the commenter to the Fuels effects section 

in Chapter 4 (see page 4-61 to 4-67) were a disclosure of expected effects on fuel 

loadings and fire behavior as the result of project activities in alternatives B and C. 

TI-5

p-2 

Comment: 

In the Tollgate EIS, it states that if there was a fire in the area, given the high amount of 

recreational use and threat to public safety, fire managers expect to use a significant 

amount of resources (personnel and financial) to suppress the fire. I suggest that the forest 

look at additional investment and opportunities for additional treatments within the project 

area as this will save on fire expenses in the long run.

Response:

Your comment has been noted. 

TI-6

p-2 

Comment:

In my previous scoping comments, I mentioned that there were only a few units where 

trees larger than 21” could be removed. In the EIS, the Forest acknowledged that the old 

forest structural class was within HRV for both multi-storied and single-storied classes 

which allow the Forest Service to harvest trees of this size. I question, again, the ability of 

the Forest Service to fully and appropriately treat the area without removing more large 

(21” and greater) trees. Please allow harvest of 21” trees in all proposed treatment areas as 

this will not only further reduce fuels in the area but also provide a higher economic return 

for the forest.

Response:

The Tollgate FEIS shows in Table 3-24 that the existing amount of old forest singlestory and old forest multi-story structure classes are within or above HRV. Where the 

removal of trees >21” has been deemed necessary to accomplish residual tree density 

and fuels objectives, such removal would be authorized under alternative B. In most 

(but not all) areas in the Tollgate planning area, however, such authorization is not 

seen as necessary to meet the project purpose and need. 

The suggestion to allow harvest of trees >21” in all proposed harvest units has been 

noted.
Tollgate Fuels Reduction Project FEIS

G-132

Letter #15 

Richard Artley’s 2/21/2013 comments (RA2013)

*Only comment that differ from those in Mr. Artley’s 12/26/2012 (RA2012, see responses to letter 3

Above) have been included below.*

Comment 

Number Comment and Response

RA2013-1

p-3 

Comment:

Supervisor Martin, you and Ranger Rassbach are bending over backwards to limit 

public feedback on your tragic Tollgate Fuels Reduction project. 

You published a legal notice in the East Oregonian newspaper on December 28, 2012 

announcing the start of the 45-day public comment period on the Tollgate project. The 

email address shown in the legal notice was incorrect: comments-pacificnorthwestumatilla@fs.fed.us. 

 

You had achieved your goal because the members of the public who submitted 

electronic comments were rejected and these folks did not know what to do. 

 

Yesterday I received a hardcopy letter dated February 15, 2013 from Ranger Rassbach 

announcing that the email address shown in the legal notice was incorrect and the 

comment period for the Tollgate project had been extended until March 15, 2013.: 

 

Incredibly, this letter showed the public 2 other incorrect email addresses for their new 

comments: 

 

FS-comments-pacificnorthwest-umatilla@fs.fed.us and FS-commentspacificnorthwest-umatilla-wallawalla@fs.fed.us 

 

On February 20 I emailed Ranger Rassbach alerting him of the 2nd email address error. 

Given the past deception inflicted on the public by Supervisor Martin I have no 

assurance that the letter discussed above will be sent to everyone on the mailing list, 

nor do I know if the letter will contain the correct email address for electronic 

comments. 

 

I suggest you prepare another legal notice announcing that the proposed Tollgate Fuels 

project has been dropped. This will save you the embarrassment of having the ROD 

overturned in court.

Response:

We disagree with the assertion that we have attempted to limit public input on the 

Tollgate Fuels Reduction project. In fact, we believe that the record bears out the 

opposite. Please review the introduction to this appendix and the ‘Public Involvement’ 

section in Chapter 2 for a detailed disclosure of our efforts to ensure that interested 

members of the public were able to participate and provide input into the project.
Tollgate Fuels Reduction Project FEIS

G-133

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

RA2013-2

p-5 

Comment:

The HFRA is a joke and you know it. Do you really expect something that would 

improve forest ecosystems at the expense of corporate profit to come from the Bush 

Administration?

Response:

Your comment has been noted. However, HFRA represents the law of the land and 

thus is a legitimate authority to utilize. 

RA2013-3 

p-5 

Comment:

Real science shows your claim is untrue:

 

“Although it may be relatively easy to ascertain whether an individual tree is healthy 

or not, the concept of “forest health" is very ambiguous. The presence of unhealthy 

trees does not necessarily imply that the forest as a whole is unhealthy. On the 

contrary, standing dead trees and fallen logs (coarse wood) play important roles in 

wildlife habitat, soil development, and nutrient cycling, and are a defining 

characteristic of old-growth forests.”

 

From: 2006 “Recent Forest Insect Outbreaks and Fire Risk in Colorado Forests: 

A Brief Synthesis of Relevant Research”

Authors: Romme, W.H. Ph.D., Clement, J. Ph.D., J. Hicke, P. Ph.D., Kulakowski, 

D. Ph.D., MacDonald, L.H. Ph.D., Schoennagel, T.L. Ph.D., and Veblen, T.T. 

Ph.D.

Link to complete report: 

http://spot.colorado.edu/~schoenna/images/RommeEtAl2006CFRI%20.pdf 

 

The real science that I have quoted above shows your claim that dead and dying 

trees if left in the woods will create unhealthy forests is ridiculous. Looking the 

other way to assure your personal gain is not the trait of a public servant. 

Supervisor Martin you have chosen to believe your TMA by rejecting facts 

supplied by experts who (unlike you) have nothing to gain. 

Response:

The Tollgate DEIS does not make the claim that dead and dying trees, if left in the 

woods, would create “unhealthy” forests. To the extent that dead and dying trees 

represent undesired levels and arrangements of hazardous fuels, and are contrary to 

the project purpose and need as described in Chapter 1 of the DEIS, they are 

prioritized for removal, with the appropriate amount of snags and woody debris 

retained for habitat, site productivity, and other reasons. We completely agree with 

the above quotation from Romme et al. (2006), and the Tollgate DEIS describes many 
Tollgate Fuels Reduction Project FEIS

G-134

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

design features in Chapter 2 to retain some standing dead trees and replacement 

snags, as well as fallen logs. The benefits of these features are widely acknowledged 

and understood, and these features will be retained to an appropriate degree guided 

by existing policy (Umatilla Forest Plan) and regulations pertaining to snags, and 

agency recommendations (Graham et al. 1994, cited in the DEIS) for retention of 

down woody debris for soil development, habitat, and nutrient cycling. The retention 

of these features and their ecological benefits will be balanced in the project against 

the needs of fuels reduction to accomplish project objectives. We believe the Tollgate 

project strikes a reasonable and appropriate balance.

RA2013-4

p-6 

Comment:

The vast majority of the public does not want their national forests logged for any 

reason. The USFS has predicted a “timber famine” for decades. There is no timber 

famine nor is there a shortage of timber being harvested in the United States to meet 

domestic needs. Indeed, some of the timber cut from private land is being exported. If 

this timber were needed in the United States it would be purchased by domestic 

corporations. There is no reason to defy the will of the public by logging their land. 

Response:

Please see the Purpose and Need in Chapter 1. There is no mention of timber famine 

in the Purpose and Need.

RA2013-5

p-6 

Comment: 

Supervisor Martin, the Forest Plan is a Contract with the Public. NFMA contains a 

process to amend the forest plan for individual projects to maximize ecological 

integrity project options. Amending the Forest Plan to allow resource damage to occur 

as you propose here in order to make it possible to implement a commodity output 

project with no ecological benefits is unacceptable to the vast majority of Americans.

Response:

Your comment has been noted, but we disagree with the assertion that the Forest Plan 

amendment will result in resource damage. The effects of proposed activities within 

RHCAs is disclosed in Chapter 4. 

RA2013-6

p-8 

Comment:

Supervisor Martin you willfully and consciously minimize, lessen and play-down the 

predicted adverse environmental effects of implementing the Tollgate timber sale.

Response:

We disagree. Please see Chapter 4 for the disclosure of environmental effects as 
Tollgate Fuels Reduction Project FEIS

G-135

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

determined by resource professionals on the IDT utilizing best available science and 

professional judgment/experience. 

RA2013-7

p-8 

Comment:

Unidentified USFS employees with unknown credentials make deceptive, 

unsubstantiated, and untrue statements in Chapter 3 trying to diminish the magnitude of 

the real resource damage to ALL natural resources predicted to be harmed by this 

timber sale. They do not provide credible evidence that the adverse effects will be 

“short-term,” “temporary,” minor,” and/or “unmeasureable.” 

Response:

We disagree. Please see the Chapters 3 & 4 of the FEIS for not only the disclosure of 

effects as well as the context in which IDT members arrived at their conclusions. 

RA2013-8

p-16 

Comment:

Dr. Mike Dombeck states: “The priority for fuels management should be the wildlandurban interface (WUI) and municipal watersheds, not fire-burned trees in the 

backcountry.

 

Source for quote above: “Wildfire Policy and Public Lands: Integrating Scientific 

Understanding with Social Concerns across Landscapes” 

Published in: Conservation Biology Volume 18, No. 4, August 2004, page 887 

http://www.sierraforestlegacy.org/Resources/Conservation/FireForestEcology/FireScie

nceResearch/FireEcology/FireEcology-Dombeck04.pdf

 

Supervisor Martin, your fuels reduction timber sale is precisely what USFS Chief says 

should not occur because the cost is high and it does not reduce the fire damage risk for 

people living in the WUI. What’s going on here? I don’t want my tax dollars spent to 

prepare projects that only benefit the corporation that does the logging. 

Response:

Your comment has been noted. 

RA2013-9

p-17 

Comment:

Dr. Schoennagel and her research team conclude: “We assessed the extent to which 

these treatments were conducted in and near the wildland–urban interface (WUI), 

where they would have the greatest potential to reduce fire risk in neighboring homes 

and communities. Although federal policies stipulate that significant resources should 

be invested in the WUI, we found that only 3% of the area treated was within the WUI, 
Tollgate Fuels Reduction Project FEIS

G-136

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

and another 8% was in an additional 2.5-km buffer around the WUI, totaling 11%.”

 

Source for quote above: “Implementation of National Fire Plan treatments near

the wildland–urban interface in the western United States” 

from Proceedings of the National Academy of Sciences, May 1, 2009 

http://spot.colorado.edu/~schoenna/images/Schoennagel_2009_PNAS_NFP.pdf 

 

Dr. Schoennagel is a research scientist in CU-Boulder's geography department. Her 

research team included Dr. Cara R. Nelson, Dr. David M. Theobaldc, Dr Gunnar C. 

Carnwathb, and Dr. Teresa B. Chapmana. Supervisor Martin, you ignore information 

published by the respected National Academy of Sciences and instead rely on biased 

USFS research. You use “fuels reduction” as an excuse to log far from the area where 

it will actually protect the public.

Response:

Please see response to comment RA2012-20. 

RA2013-10

p-17 

Comment:

Supervisor Martin once again you are blinded by the truth so you can obtain volume 

under false pretenses. 

Response:

We disagree. Please see Chapter 1 of the Purpose and Need. 

RA2013-11

p-17, 18 

Comment:

The Mother Jones magazine concludes: “While most environmentalists do not argue 

with the basic approach, they charge that too many old, large trees are being cut down 

under this rubric of "fuels reduction," and that federal land managers are allowing 

commercial logging operations to cut too many large trees too far from cities or towns, 

where the clearing has no real impact on human safety.” 

 

“ "It's a classic bait-and-switch," says Timothy Ingalsbee, director of the Western Fire 

Ecology Center, an Oregon-based advocacy group. "They want to do commercial 

logging and call it fuels reduction." “ 

 

Source for quotes above: “Fight Fire With Logging?

Published in Mother Jones, July 31, 2002
Tollgate Fuels Reduction Project FEIS

G-137

Letter #14

Thomas Insko (TI)

Comment 

Number Comment and Response

http://www.motherjones.com/politics/2002/08/fight-fire-logging

 

Supervisor Martin your project directly contradicts the truths stated by a person with a 

Ph.D. who specializes in fire and protection from fire damage, 

Response:

Your comment has been noted, but we encourage your review of the purpose and

need as well as the proposed activities (and their locations) within both Alternatives B 

and C. 

Letter #16 

Mark Davidson, Steve McClure, William RosholtUnion County Board of Commissioners (UCBC)

Comment 

Number Comment and Response

UCBC-1

p-1 

Comment:

We value the jobs that this project will bring and maintain in the area as Union 

County has consistently experienced double digit unemployment since 2008. As 

Union County Commissioners, we are concerned with the management of the 

National Forests in and near Union County as it pertains to the economic, 

ecological, and social aspects of Union County.

Response:

We thank you for your interest and active collaboration in the management of

national forest lands within Union County. 

UCBC-2

p-1 

Comment:

We support the proposed alternative, Alternative B. However, we request that the forest 

look at maximizing the project to have the highest economic impact for local counties with 

regards to jobs and potential economic impacts from the forest.

Response:

Thank you for your supportive comment. We believe that proposed treatment 

configurations within alternatives B and C represent a strategic approach toward fuel 

reduction efforts that is consistent with the stated purpose and need as well as 

provides economic output to local communities.

Comment:
Tollgate Fuels Reduction Project FEIS

G-138

Letter #16 

Mark Davidson, Steve McClure, William RosholtUnion County Board of Commissioners (UCBC)

Comment 

Number Comment and Response

UCBC-3

p-1 

Please discuss the economic analysis further, as there was no discussion regarding 

how this project will supply the local infrastructure, what types of jobs will be 

created/maintained, what this will do for local schools/county governments. Please 

include a better economic analysis for this project. 

Response:

This project is projected to supply the affected area or economic impact zone (DEIS 

3-109) some 29,589 ccf of sawtimber and biomass. The project is expected to create 

some 87 jobs directly related to the reduction of hazardous fuels and some 52 jobs 

indirectly related or induced. Details are contained in the project analysis file at the 

Walla Walla Ranger District. 

UCBC-4

p-1 

Comment:

Industry infrastructure should be a key issue for this project.

Response:

Your comment has been noted. 

UCBC-5

p-2 

Comment: 

We’d like to see the Forest Service focus on the economic analysis and make this a priority 

in the current EIS. We agree that restoration should be ecological, but it should also 

contribute to the socio-economic status of the local communities.

Response:

Your comment has been noted. Please see Chapter 4 (pages 4-121 to 4-122) for a 

discussion of the effects of each alternative on the local economy. 

UCBC-6

p-2 

Comment:

Please review the area for additional opportunities to increase the harvest and acreage 

treated.

Response:

An alternative targeted at additional acreage was considered, but was eliminated 

from detailed study. Please see the discussion on pages 2-24 of Chapter 2 for the 

rationale supporting the decision to eliminate said alternative. 

UCBC-7 Comment:
Tollgate Fuels Reduction Project FEIS

G-139

Letter #16 

Mark Davidson, Steve McClure, William RosholtUnion County Board of Commissioners (UCBC)

Comment 

Number Comment and Response

p-2

This is an appropriate HFRA project to reduce the fire danger to the Tollgate community. 

However, we believe that the analysis has to be more robust regarding crown fire. It 

appears that the Forest Service only analyzed how the fire would affect the treated acreage, 

not how fire would affect the project area as a whole... 

Only analyzing crown fire potential for the treated acreage is not adequate. The Forest 

Service needs to analyze the entire area to determine the effects of crown fire on the 

recreational community as well as the timber in the area. Allowing a stand-replacing fire in 

that area without working to proactively prevent it would be detrimental to the property 

owners as well as the value of the land as a whole. While we understand that there are areas 

that the Forest Service is legally unable to touch, it appears that there is a great deal of land 

in the area that could be treated.

Response:

Thank you for your comment. Please see response to comment BC -2. 

UCBC-8

p-2 

Comment:

Climate Change should be a large factor in all projects. We are concerned that the Forest 

Service’s project does not adequately account for climate change. The climate change 

projection is that these forests will become drier and more susceptible to insects, disease, 

and wildfire. The Forest Service needs to analyze how climate change will affect the area 

and identify areas where more work can be done to mitigate the threat. 

Response:

We agree and share the concerns expressed by this comment, and believe our 

discussion of how climate change is expected to affect the Tollgate planning area 

(pages 4-53 through 4-56, and particularly page 4-55 of the FEIS) offers sufficient 

breadth and depth to adequately and reasonably present likely project effects in the 

context of climate change for consideration by the general public and Deciding 

Official. In addition, the claims and statements made in the FEIS are thoroughly 

supported by rigorous, pertinent, and informative scientific literature, which are 

referenced throughout the section on climate change. The identification of where 

more work (in addition to the activities already proposed under Alternatives B and C) 

can be done to mitigate climate threats is outside the scope of the Tollgate project 

analysis, particularly since the project purpose and need does not include a focus on 

climate threat mitigation; however, the role of the Tollgate project with respect to 

climate change threat mitigation in general is briefly discussed on page 4-53. 

UCBC-9

p-2 

Comment:

We support the removal of 21” trees in all of the stands slated for treatment. The 21” rule is 
Tollgate Fuels Reduction Project FEIS

G-140

Letter #16 

Mark Davidson, Steve McClure, William RosholtUnion County Board of Commissioners (UCBC)

Comment 

Number Comment and Response

an arbitrary diameter limit that does not allow for the silviculturist to properly treat stands. 

These decisions should be made within the stand prescriptions and not in the NEPA 

document. 

Response:

Your comment has been noted. 

UCBC-10

p-2 

Comment:

Hunting and tourism are major draws for the local area. We are concerned about the 

emphasis on cover for big game in the area. The forest should focus on creating more 

forage for the large ungulates within the area.

Response:

A mistake was made in the DEIS on page 3-66. The correction is that satisfactory elk 

cover is within desired conditions identified in the forest plan. Cover for big game was 

not emphasized in this project.

UCBC-11

p-3 

Comment:

Under Activity Description on page 2-2, the EIS states that all sites would exceed 80 

square foot/acre. Please make sure that you are taking as much as possible and complying 

with NEPA. Sometimes, taking one more tree per acre will make the sale economically 

viable. 

Response:

See response to comment TI-6. The Forest Service considers a residual stocking 

density of 80 ft2 per acre (and higher in some cases) sufficient to meet project 

objectives for hazardous fuels reduction and wildfire risk mitigation.
Tollgate Fuels Reduction Project FEIS

G-141

Letter #17

Jean Public’s 02/25/2013 comment (JP_02_2013)

Comment 

Number Comment and Response

JP_02_2013

-1 

p-1 

Comment:

I DONOT AGREE WITH ANY ASPECT OF THIS PLAN. THIS PLAN IS 

ABOUT PURE GREED MONEYMAKING AND SHOULD NOT BE 

IMPLEMENTED. THE NATIONAL CITIZENS OF THIS COUNTRY OWN 

THIS LAND. THIS IS NOT LOCAL LAND THAT CAN BE RAPED. 

Response:

Your comment has been noted. 

Letter #18

Rick Isaacson (RI)

Comment 

Number Comment and Response

RI-1

p-1 

Comment:

Generally I am in agreement with the purpose and need for action described in this 

document. I suggest increasing the size/area of this project to make it a much larger, 

landscape scale type of project. 

Response:

Your comment has been noted. 

RI-2

p-1 

Comment:

I believe that hazard trees will be targeted for removal along roads. We have had 

too many of this type of sale where too much of what would be good-quality 

firewood was taken (Douglas fir, Western Larch, Lodgepole Pine especially). In 

those cases, the areas along the sides of forest roads become barren of firewood for 

far too long. 

Response:

Your comment has been noted. It should be noted that opportunities for collecting 

fuelwood exist across not only the district, but also across the forest.

RI-3

p-1 

Comment:

The forest service is presently attempting to close roads and thus, is negatively affecting 

the woodcutting public by reducing the available firewood. I suggest that more area be 

open along forest roads; at least a 1⁄4 mile buffer, however a 1⁄2 mile buffer along each side 
Tollgate Fuels Reduction Project FEIS

G-142

Letter #18

Rick Isaacson (RI)

Comment 

Number Comment and Response

of all open roads is suggested. The availability of good-quality firewood would be greatly 

enhanced by increasing the buffer along forest roads and by leaving quality species hazard 

trees for firewood gatherers. Any restriction beyond roadsides creates the effect of that area 

being pseudo-wilderness when that area should be true multiple-use forest.

Response:

Your comment has been noted. 

RI-4

p-1 

Comment: 

I suggest that NO roads be decommissioned and that all open roads remain open to the 

public now and after the project is completed. 

Response:

Your comment has been noted. However, as stated in the FEIS, this project does not 

propose to change access across the project area. Thus the status of roads in the 

project planning area, as determined by the Walla Walla RD Access & Travel 

Management Plan (ATM), will be maintained. Therefore, roads that were closed 

before project activities will be again be closed once project implementation actitivies 

are completed. 

RI-5

p-1 

Comment:

I suggest that the forest service cease and desist in the protection of diseased and overripe 

trees in this area. I do not believe that the forest service can scientifically support decisions 

to protect trees that have mistletoe, root rot, broken tops, etc based merely on the basal 

circumference or diameter of those trees.

Response:

The Tollgate FEIS does not attempt to offer scientific support for decisions to protect 

mistletoe-infested or disease-infected trees based only on the basal area and/or 

diameter of the trees. In some cases, a residual overstory is prescribed following 

proposed activities to create and/or maintain a shaded fuelbreak which may be 

affected by parasites or pathogens, but the Tollgate FEIS does not attempt to justify 

this prescription based only on the “basal circumference or diameter” of harvested or 

residual trees within the stand. 

Instead, scientific findings are cited in the FEIS to support analysis of likely project 

environmental effects, and specifically, in part, how the retention of such 

infected/infested trees could mitigate or minimize possible adverse effects on a variety 

of resources. For example, the treatments were designed to retain some forests which 

are in the old forest structural stage (and also infected by parasites or pathogens) 

specifically to avoid or minimize adverse effects on fish and wildlife habitat (pages 4-
Tollgate Fuels Reduction Project FEIS

G-143

Letter #18

Rick Isaacson (RI)

Comment 

Number Comment and Response

16 through 4-25 of the FEIS, and 4-73 through 4-92, respectively), carbon stocks in 

live biomass pools (4-57 through 4-61), aesthetic values (4-92 through 4-101), water 

quality (4-6 through 4-16), and understory vegetation diversity (page 4-29).

RI-6

p-2 

Comment:

Please review all riparian areas for management opportunities. Large buffer zones around 

these areas can be detrimental to the overall health of them by allowing high fuel loads to 

accumulate within. It is essential that these areas are managed properly in order to reduce 

the effects of wildfire or prescribed burns that could harm them. 

Response:

Analysis and modeling within the Tollgate planning areas showed that several 

RHCAs pose a threat to some Values at Risk identified within the Tollgate DEIS. The 

geographic positioning and vegetative structure of the four RHCAs proposed for 

treatment display a high level of risk in terms of “funneling” wildland fire towards 

identified Values at Risk and vegetative structure that can lead to the initiation and 

propagation of crown fire. As such, these areas are recommended for treatment.

The specific treatments prescribed for these areas are garnered through modeling 

and field verification with an objective of reducing crown fire and fire intensities. 

Each prescription is designed towards the reduction of these metrics and the concepts 

stated above. 

Other riparian areas within the planning area and not prescribed for treatment failed 

to display a clear need based on the purpose and need, fire modeling, and professional 

judgment.

RI-7

p-2 

Comment:

Rather than merely burning the units designated to be burned, harvest available saw logs 

from the burn units before burning. 

Response:

Only burning of piled, non-merchantable material will occur with the Tollgate 

project.

RI-8

p-2 

Comment:

Taking susceptible trees before the burn is smart business as it increases the dollars derived 

from timber harvest and reduces unnecessary loss from the burn. It also provides for more 

volume to local mills that very much need the additional volume of saw logs. 
Tollgate Fuels Reduction Project FEIS

G-144

Letter #18

Rick Isaacson (RI)

Comment 

Number Comment and Response

Response:

Your comment has been noted. 
APPENDIX H

POTENTIAL WILDERNESS INVENTORY

 

Tollgate Fuels Reduction Project FEIS

H-1 

APPENDIX H

POTENTIAL WILDERNESS INVENTORY

METHODOLOGY and RESULTS

For 

Tollgate Fuels Reduction Project

Index of Appendix H Maps

Map H-0.......................................Roadless Context Map for Northern Portion of 

 Umatilla National Forest

Map H-2.........................................Removal of Past Timber Harvest Area 

Map H-3....................................... Forest Roads

Map H-4........................................ Acres not containing Past Timber Harvest or Forest

 Roads 

Map H-5......................................... Forest Service Inventory of Potential Wilderness

 Areas

Map H-6.........................................5 panel map; Summary of the inventory process 

Map H-7..........................................Interaction between Potential Wilderness Areas and

 Alternative B Treatment Units

Map H-8...........................................Interaction between Potential Wilderness Areas and

 Alternative C Treatment Units

Map H-9..........................................Interaction between Other Undeveloped Lands and

 Alternative B Treatment Units

Map H-10........................................Interaction between Other Undeveloped Lands 

 and Alternative C Treatment Units
Tollgate Fuels Reduction Project FEIS

H-2 

Background:

This document describes the process and rationale used to inventory for and identify potential 

wilderness areas within the Tollgate Fuels Reduction project, Walla Walla Ranger District, 

Umatilla National Forest. The inventory is based on, and consistent with criteria found at Forest 

Service Handbook (FSH) 1909.12 Ch. 71. 

Each step of the inventory process is visually documented as a map (see map discussion below). 

These maps are displayed in this appendix. The Forest Service used professional judgment and 

local knowledge regarding unique, site-specific conditions of each area being considered for 

placement in the inventory of potential wilderness areas.

Potential Wilderness Areas (PWA): Areas of potential wilderness identified using inventory 

procedures found in Forest Service Handbook (FSH) 1909.12 Chapter 71 are called potential 

wilderness areas. The inventory is conducted with the express purpose of identifying all lands 

that meet the criteria for being evaluated for wilderness suitability. 

Potential wilderness areas are not a land designation decision, they do not imply or impart any 

particular level of management direction or protection, they are not an evaluation of potential 

wilderness (FSH 1909.12, Chapter 72), and lastly they are not preliminary administrative 

recommendations for wilderness designation (FSH 1909.12, Chapter 73). The inventory of 

potential wilderness does not change the administrative boundary of any inventoried roadless 

areas (IRAs), any congressionally established wilderness, or any forest plan management areas.

Typically, PWAs substantially overlap and/or are contiguous with inventoried roadless areas. 

PWAs may also be contiguous with designated wilderness. Some newly inventoried PWAs may 

be stand alone areas that were not identified as ‘roadless areas’ in Appendix C of the 1990 

Umatilla Forest Plan and ‘inventoried roadless areas’ as identified in a set of maps in the 2001 

Roadless Area Conservation Rule (RACR). PWAs overlap inventoried roadless areas only where 

those acres of land are consistent with the inventory criteria (FSH 1909.12 Chapter 71) and may 

extend beyond IRA and wilderness boundaries consistent with inventory criteria. 

The scope of this potential wilderness analysis inventory includes all acres contained within the 

Tollgate Fuels Reduction project boundary and lands outside the boundary sufficient to consider 

the potential wilderness area criteria found at FSH 1909.12 Chapter 71.1. The portion of the 

Walla Walla River IRA that is located outside the project boundary was not considered because 

there would be no effects from the project in this area. 

Methodology: 

The inventory process was conducted through a sequence of GIS analyses and application of 

professional judgment. The judgment applied was situational and instance by instance. Each 

map (Appendix map H-1, H-2, H-3, H-4, and H-5) documents the outcome of the application of 

specific inventory criteria. Inventory criteria were applied in a different order than appears in 

Chapter 71 but all criteria were considered and accounted for as described below under the Map 

H-1 – H-5 headings. Map H-6 is a summary map that depicts all five maps to aid the reader’s 

understanding of this inventory process. Map H-0 is a roadless context map for the northern 

portion of the Umatilla National Forest. 

Examples of typical situations that required applications of professional judgment included, but 

are not limited to:
Tollgate Fuels Reduction Project FEIS

H-3 

1. placement of PWA boundaries along permanent natural or semi-permanent human-made 

features such as ridges, streams, topographic breaks, past harvest, or forest roads to facilitate 

easy on the ground identification. 

2. whether to proceed through an isthmus (or pinch point) created between two roads or two 

harvest areas or place a PWA boundary across the isthmus;

3. whether to locate a PWA boundary around a peninsula or place the boundary through the 

peninsula. 

Table H-1A is a summary of acres evaluated in the inventory process. Table H-1B was used to 

account for and display all polygons as described in Map H-4. Table H-1C is a summary of the 

areas that meet inventory criteria as potential wilderness areas. Table H-1D is a summary of all 

inventoried lands in the project area. 

Map by Map Description

Table H-1A Potential Wilderness Area Inventory Summary

Approximate Acres

Tollgate Project Planning 

Area

Approximate Acres

PWA Analysis Area

Map H-1; Total Acres 

Inventoried. Tollgate Project 

Planning area and PWA analysis 

area).

46,464 52,284

Map H-2; Acres Removed from 

inventory due to past harvest.

14,878 16,894 

Map H-3; Acres removed from 

inventory due to activities related 

to roads

10,364* 11,690*

Map H-4; Resulting lands that 

remain after past harvest and 

activities related to roads are 

removed from inventory. 

(undeveloped lands)

15,712** 19,110**

Map H-5; Acres of Potential 

Wilderness Areas (PWAs) 13,129**

 

15,403**

 

Acres of undeveloped lands that 

did not meet PWA inventory 

criteria at FSH 1909.12 Chapter 

71.1 (other undeveloped lands)

2,584**

 

3,709**

Lookingglass PWA (consists of 

the Lookingglass IRA and PWA 

contiguous to the IRA)

3,660** 5,917 **

Walla Walla River PWA(consists 

of portions of the Walla Walla 

River IRA and PWA contiguous 

to the IRA)

7,248** 7,248**
Tollgate Fuels Reduction Project FEIS

H-4 

The largest single PWA in this analysis is the Walla Walla River IRA/PWA at 7,248 acres 

followed by the Lookingglass PWA/IRA at 5,917 acres. There are numerous smaller PWAs 

contiguous with the North Fork Umatilla Wilderness totaling about 1,151 acres and one isolated 

PWA at 1,087 acres for a total of 15,403 acres of PWA within the PWA analysis area.

Map H-0 (Context)

Map H-0 is a roadless context map for the northern portion of the Umatilla National Forest.

Map H-1 (Analysis Area)

Map H-1 displays the Tollgate Fuels Reduction project planning area and PWA analysis area, 

forest roads, North Fork Umatilla Wilderness and Lookingglass and Walla Walla River 

inventoried roadless areas (IRAs). The project planning area for Tollgate Fuels Reduction is 

approximately 46,464 acres. A portion of the Lookingglass IRA is located outside the project 

planning area. The PWA analysis area extends beyond the project planning area to account for 

potential wilderness areas that are contingent with the whole of the Lookingglass IRA. The PWA 

analysis area is 52,284 acres.

Map H-1A 

Map H-1A is an imagery photo representation of Map H-1. 

Map H-2 (Past Harvest)

Map H-2 displays Tollgate Fuels Reduction project planning area and PWA analysis area, forest 

roads, past harvest, North Fork Umatilla Wilderness and Lookingglass Creek and Walla Walla 

Creek IRAs. The PWA analysis area was overlain with Walla Walla district's GIS harvest layer 

which displays locations of timber harvest over the past 50 years. Past timber harvest included 

clear-cuts to thinning units. The past timber harvest layer also includes lands where local 

knowledge and field visits were utilized to verify past timber harvest. Notes from field 

verification can be found in the Tollgate Fuels Reduction project record). In all cases, past timber 

harvest resulted in features such as stumps, skid trails etc. which are evident; therefore, all acres 

(approximately 16,894 acres) depicted on the map do not meet FSH 1909.12 Ch 71.11(9) 

inventory criteria and were removed from the inventory in Map H-3. 

Map H-3 (Roads)

Map H-3 displays Tollgate Fuels Reduction project planning area and PWA analysis area, forest 

roads, acres with evidence of recognizable stumps, skid trails, uneven canopy closure, North Fork 

Umatilla Wilderness and Lookingglass Creek and Walla Walla Creek IRAs. The entire analysis 

area was overlain with Walla Walla district's GIS forest roads layer. Forest roads have associated 

permitted uses and maintenance. Road maintenance and many permitted uses have removed trees 

PWA contiguous with North Fork 

Umatilla Wilderness 1,151** 1,151**

Isolated PWA (polygon 362)

1,070** 1,087**

Total PWA

13,129** 15,403**

*Some of these acres may overlap with acres of past harvest. 

** This number does not include polygons less than one acre in size.
Tollgate Fuels Reduction Project FEIS

H-5 

and created visible stumps in the corridor. These activities are expected to continue into the 

future.

During initial road construction trees were felled within a clearing limit to provide for safe and 

efficient construction and future operational safety of road users. Clearing distances away from 

the edge of a road varied by many factors including tree height, topographic slope, and other 

factors. Past clearing of trees along forest roads created stumps that are evident and recognizable. 

Road maintenance occurs to varying degrees along each road according to an assigned 

maintenance level and available funding. Road maintenance includes the periodic clearing of 

brush and the falling of danger trees that present a hazard to forest visitors, employees, and 

contractors as defined by the Region 6 Danger Tree Policy (2008). The distance of the hazard 

removal away from a road varies by tree height, topographic slope, and other factors. Past 

removal of danger trees along forest roads created stumps that are evident and recognizable.

Harvest of trees for personal-use firewood is permitted within 300 feet of open forest roads 

consistent with project NEPA decisions and travel and access management plan decisions. Past 

firewood gathering along open forest roads created stumps that are evident and recognizable.

We recognize stumps are not present along every mile of forest road; for example roads adjacent 

to a meadow, talus, or a lake. The judgment we applied in setting a PWA boundary balanced 

inventory criteria regarding excluding past harvest and facilitating easy on-the-ground 

identification.

Based on local knowledge, and professional judgment regarding the evidence of recognizable 

stumps, skid trails, etc. which occur to varying degrees adjacent to forest roads (as described 

above) and to facilitate easy on-the-ground identification of a uniform, measurable boundary 

along a semi-permanent, human-made feature; the boundary was set as 300 feet each side of the 

forest road. 

This boundary is fully consistent with and supported by the following inventory criteria. 

• FSH 1909.12 at 71.1(3); potential wilderness areas do not contain forest roads therefore 

all acres that are a forest road will be removed from the inventory in Map H-4. 

• FSH 1909.12 at 71.1(9); acres with evidence of past logging and roads will be removed 

from the inventory in Map H-4. 

• FSH 1909.12, at 71; locate potential wilderness area boundaries at semi-permanent, 

human-made features to facilitate easy on-the-ground identification of a boundary. 

Therefore, highlighted acres along forest roads (approximately 11,690 acres) in Map H-3 were 

removed from the inventory in Map H-4. Note some of the highlighted acres overlap with acres 

removed due to past harvest activities.

Map H-4 ((Acres not containing Past Timber Harvest or Forest Roads)

Map H-4 displays Tollgate Fuels Reduction project planning area and PWA analysis area, forest 

roads, acres that do not contain evidence of past harvest or forest roads (undeveloped lands) and 

Lookingglass Creek and Walla Walla Creek IRAs. Approximately 363 individual polygons of 

undeveloped lands were evaluated in the PWA analysis area. Two hundred thirty two (232)

individual polygons less than 1 acre in size (totaling 39 acres) were eliminated from further study. 

The removal of these polygons resulted in 131 individual polygons, ranging in size from 1 acre to 

approximately 7,140 acres, covering approximately 19,110 acres.
Tollgate Fuels Reduction Project FEIS

H-6 

Map H-4 displays the remaining 131 polygons of undeveloped lands, each with its own unique, 

numeric identifier. These polygons do not have substantially recognizable stumps, do not contain 

forest roads, and each polygon boundary is greater than or equal to 300 feet from a forest road. 

Map H-5 (Potential Wilderness Areas and Other Undeveloped Lands)

Map H-5 displays the North Fork Umatilla Wilderness, Walla Walla River and Lookingglass 

IRAs, and Forest Service’s completed inventory of PWAs within Tollgate Fuels Reduction 

project planning area and PWA analysis area. Map H-5 also displays the remaining other 

undeveloped lands. 

The acres of the Walla Walla River and Lookingglass IRAs and each of the other undeveloped 

polygons in Map H-4 were considered individually and compared to inventory criteria found at 

FSH 1909.12 at 71.1 (1, 2a, 2b, 2c). This process and the results are documented in Table H-1B 

below and displayed in Map H-5. Acres of any polygon need only meet one of the four found at 

FSH 1909.12 71.1 criteria 1, 2a, 2b, or 2c to be retained and displayed on Map H-5 as PWA.

Of the 131 polygons (19,110 acres) evaluated in the PWA analysis area, 93 polygons, totaling 

3,709 acres (2,584 acres within the project planning area), are not contiguous with wilderness, 

primitive areas, Administration-endorsed wilderness, or potential wilderness in other Federal 

ownership due to the presence of forest roads and/or past timber harvest activity. Based on 

review of a site-specific orthophoto (project record) and local knowledge, each of these individual 

polygons is a part of a larger ecosystem and not a separate, self-contained ecosystem, such as 

found on an island surrounded by water. These polygons cannot be separately preserved due to 

physical terrain or a natural condition in part because of their small size and in part because they 

are each part of the larger, continuous ecosystem distributed throughout the project area. Based 

on the discussion above, local knowledge and professional judgment, none of these individual 

polygons met inventory criteria, and therefore were removed from the inventory. They will be 

evaluated as “other undeveloped lands” and discussed in Chapter 3 of the EIS. 

One isolated polygon, #362 (1,087acres) meets PWA criteria 71.1 (2a). It is less than 5,000 acres 

but can be preserved due to physical and natural features. This polygon is retained in the 

inventory. 

Approximately 2,317 acres are contiguous with either the North Fork Umatilla wilderness area or 

the Walla Walla River or Lookingglass IRAs. These polygon acres generally met criteria 71.1 

(2c) however, some contiguous acres were removed from the inventory based on professional 

judgment when locating a boundary at a prominent natural or semi-permanent human-made 

feature to facilitate easy on-the-ground identification. The Forest Service interpreted ‘prominent 

natural or semi-permanent human-made’ to include features such as, but not limited to, 

topographic breaks, streams, ridges, and the existing administrative boundaries of wilderness 

and/or inventoried roadless areas. These judgments are documented in Table H-1B and 

associated maps/documents in the Wilderness Potential portion of the Tollgate Fuels Reduction 

project file. The remaining contiguous acres are retained in the inventory. These areas are 

displayed in Map H-5 and in Table H-1C.

The Walla Walla River IRA (polygon # 363) and Lookingglass IRA (polygon # 364) were 

examined as independent units, separate from the polygons discussed above. The IRAs were 

examined with the same techniques as each of the other individual polygons. 

All of the Walla Walla River IRA acres located within the Tollgate project planning area meet 

potential wilderness criteria. The entire Lookingglass IRA, both inside and outside the project 

area, meet potential wilderness criteria. Regardless of the outcome, this inventory does not 
Tollgate Fuels Reduction Project FEIS

H-7 

change the administrative boundary for either IRA, which was established in the Roadless Area 

Conservation Rule (2001). Both IRAs/PWAs are displayed on map H-5. 

Map H-6 (Inventory Process Summary)

Map H-6 is a summary map that displays all five maps described above.

Maps H-7 and H-8 

Maps display interaction between Potential Wilderness and Alternatives B and C treatment units.

Map H-9 and H-10 

Maps display interaction between Other Undeveloped Lands and Alternative B and C treatment 

units. 
Tollgate Fuels Reduction Project FEIS

H-8 

Table H-1B: Tollgate Fuels Reduction Potential Wilderness Inventory

The following inventory for the Tollgate Fuels Reduction project planning area was created using the inventory criteria 

found in Forest Service Handbook (FSH) 1909.12 Chapter 71.1. Each polygon and IRA from Map H-4 (described 

above) were examined against the following criteria from FSH 1909.12 Chapter 71.1:

(1) Area is more than 5,000 acres in size

(2) Area contains less than 5,000 acres, but can meet one or more of the following criteria:

2a. Area can be preserved due to physical terrain and natural conditions.

2b. Areas are self-contained ecosystems, such as an island, that can be effectively managed as a separate unit of 

the National Wilderness Preservation System.

2c. Areas are contiguous to existing wilderness, primitive areas, Administration-endorsed wilderness, or potential 

wilderness in other Federal ownership, regardless of their size.

The Forest Service relied on local knowledge and judgment regarding unique, site specific conditions of each area being 

considered for placement on the inventory of potential wilderness. Delineation of areas for potential wilderness 

inventory; locate boundaries at prominent natural or semi-permanent human-made features to facilitate easy on-theground identification.

Note: In general, the scope of this potential wilderness inventory analysis was limited to acreage contained within the 

project planning area boundary. However, the Forest Service’s inventory crossed the project planning area boundary to 

include all of the Lookingglass IRA and acres immediately adjacent to the east end of the Lookingglass IRA. Polygons 

were examined as an entire unit (both portions that occur inside and outside of planning area) against the potential 

wilderness area criteria. 

Polygons less than 1 acre in size were dropped from the inventory. The inventory was conducted in January of 2012. 

Polygon ID Acres

Meets one or 

more criteria

FSH1909.12 

71.1(1) Is 

area greater 

than 5000 acres 

in size? 

FSH1909.12 

71.1(2a) 

Can be 

preserved due 

to terrain?

FSH1909.12 

71.1(2b) Is 

it a selfcontained 

ecosystem?

FSH1909.12 

71.1(2c) 

Is area 

contiguous?

1 3.91 N N N N N

4 16.80 N N N N N

8 89.32 Y N N N Y

9 21.86 N N N N N

12 1.32 N N N N N

13 7.71 Y N N N Y

14 21.71 Y N Y N Y

15 4.92 N N N N N

16 6.41 N N N N N

17 19.55 N N N N N
Tollgate Fuels Reduction Project FEIS

H-9 

Poly ID Acres

Meets one or 

more criteria

FSH1909.12 

71.1(1) Is 

area greater 

than 5000 acres 

in size? 

FSH1909.12 

71.1(2a) 

Can be 

preserved due 

to terrain?

FSH1909.12 

71.1(2b) Is 

it a selfcontained 

ecosystem?

FSH1909.12 

71.1(2c) 

Is area 

contiguous?

21 194.50 Y N N N Y

23 36.29 Y N Y N Y

42 7.16 Y N Y N Y

46 69.11 Y N Y N Y

49 56.12 N N N N N

50 12.00 Y N Y N Y

52 50.92 Y N Y N Y

54 11.01 N N N N N

56 6.31 N N N N N

57 8.92 Y N N N Y

60 7.02 Y N Y N Y

64 2.38 N N N N N

66 1.17 N N N N N

67 1.13 N N N N N

70 8.02 Y N N N N

71 4.07 Y N Y N Y

75 82.09 Y N Y N Y

78 6.19 N N N N N

80 1.20 N N N N N

83 2.06 N N N N N

84 132.07 Y N N N Y

86 4.10 N N N N N

89 21.31 N N N N N

92 15.37 Y N Y N Y

94 70.03 Y N Y N Y

97 14.25 Y N Y N Y

101 8.17 N N N N N

103 3.07 Y N N N Y

105 62.21 Y N Y N Y

110 40.86 Y N Y N Y

111 211.17 Y N Y N Y

117 3.63 N N N N N

119 11.62 N N N N N

122 12.06 Y N Y N Y

125 3.64 N N N N N

127 38.59 Y N Y N Y

128 3.57 N N N N N
Tollgate Fuels Reduction Project FEIS

H-10

Poly ID Acres

Meets one or 

more criteria

FSH1909.12 

71.1(1) Is 

area greater 

than 5000 acres 

in size? 

FSH1909.12 

71.1(2a) 

Can be 

preserved due 

to terrain?

FSH1909.12 

71.1(2b) Is 

it a selfcontained 

ecosystem?

FSH1909.12 

71.1(2c) 

Is area 

contiguous?

129 1.87 Y N Y N Y

133 17.26 N N N N N

134 195.13 N N N N N

135 11.05 N N N N N

138 1.54 N N N N N

142 1.35 N N N N N

143 17.14 Y N N N Y

147 4.37 N N N N N

159 39.01 N N N N N

160 1.64 N N N N N

165 66.94 N N N N N

167 100.67 N N N N N

168 4.37 N N N N N

171 3.57 N N N N N

173 1.12 N N N N N

175 2.69 N N N N N

179 93.76 N N N N N

180 1.08 N N N N N

183 4.89 N N N N N

185 2.32 N N N N N

186 2.41 Y N Y N Y

187 11.43 N N N N N

191 1.46 N N N N N

193 4.81 N N N N N

198 1.76 N N N N N

199 2.14 N N N N N

208 11.17 N N N N N

209 24.03 N N N N N

212 12.31 N N N N N

213 10.22 Y N Y N Y

227 9.80 N N N N N

235 1.55 N N N N N

240 9.83 N N N N N

241 1.08 N N N N N

242 53.46 N N N N N

246 7.00 N N N N N

247 5.54 N N N N N

254 26.59 Y N N N Y
Tollgate Fuels Reduction Project FEIS

H-11

Poly ID Acres

Meets one or 

more criteria

FSH1909.12 

71.1(1) Is 

area greater 

than 5000 acres 

in size? 

FSH1909.12 

71.1(2a) 

Can be 

preserved due 

to terrain?

FSH1909.12 

71.1(2b) Is 

it a selfcontained 

ecosystem?

FSH1909.12 

71.1(2c) 

Is area 

contiguous?

257 1.20 N N N N N

259 9.72 N N N N N

263 68.59 Y N Y N Y

266 6.41 N N N N N

269 135.94 N N Y N N

272 16.37 N N N N N

278 34.07 N N N N N

279 2.63 N N N N N

280 6.24 N N N N N

281 90.01 N N N N N

282 19.89 N N N N N

283 28.14 N N N N N

284 186.26 N N N N N

285 22.88 N N N N N

290 22.10 N N Y N

293 245.74 N N N N N

294 91.77 N N N N N

295 514.75 N N N N N

310 9.38 N N N N N

311 17.79 N N N N N

320 6.45 N N N N N

324 10.46 N N N N N

325 8.18 N N N N N

340 639.25 Y N N N Y

341 3.35 N N N N N

342 3.03 N N N N N

343 98.90 Y N N N Y

345 111.24 Y N N N Y

346 20.15 N N N N N

347 22.56 N N N N N

348 7.34 N N N N N

349 8.94 N N N N N

350 33.86 N N N N N

351 59.65 Y N N N Y

352 973.54 N N N N N

353 140.95 N N N N N

354 37.49 N N N N N

355 11.98 N N N N N
Tollgate Fuels Reduction Project FEIS

H-12

Poly ID Acres

Meets one or 

more criteria

FSH1909.12 

71.1(1) Is 

area greater 

than 5000 acres 

in size? 

FSH1909.12 

71.1(2a) 

Can be 

preserved due 

to terrain?

FSH1909.12 

71.1(2b) Is 

it a selfcontained 

ecosystem?

FSH1909.12 

71.1(2c) 

Is area 

contiguous?

357 4.54 N N N N N

358 15.00 N N N N N

359 2.02 N N N N N

362 1086.64 Y N Y N N

363 7139.74 Y Y Y Y Y

364 4858.92 Y Y Y Y

Total Acres 19,110

 

Inventory Results

In summary the following areas meet inventory criteria as potential wilderness areas and are 

displayed in Map H-5. 

Table H-1C; Final Inventory of Potential Wilderness Areas for the Tollgate Fuels Reduction Project

Potential Wilderness Area 

Identifier

(Polygon ID)

Planning Project Area 

Acreage

(rounded)

PWA Analysis Area

Acreage 

(rounded)

Lookingglass PWA (consists 

of the Lookingglass IRA and 

PWA contiguous to the IRA)

3,660** 5,917 **

Walla Walla River 

PWA(consists of portions of 

the Walla Walla River IRA 

and PWA contiguous to the 

IRA)

7,248** 7,248**

PWA contiguous with North 

Fork Umatilla Wilderness

1,151** 1,151**

Isolated PWA (polygon 362) 1,070** 1,087**

Total PWA 13,129** 15,403**

** This number does not include polygons less than one acre in size.

 

Table H-1D; Summary of inventoried lands for the Tollage Fuels Reduction Project

NF 

Umatilla 

Wilderness

PWA 

contiguous 

with NF 

Umatilla

Lookingglass 

PWA 

Walla 

Walla 

River 

PWA

Isolated

PWA 

polygons

Other 

Undeveloped 

Lands

Developed 

Lands 

(evidence of 

past harvest 

and/or roads)

Total 

(Acres)

Tollgate 

Project 

Planning 

Area

12,571 1,151 3,660 7,248 1,070 2,584 18,180 46,464

PWA 

Analysis 

Area

12,571 1,151 5,917 7,248 1,087 3,709 20,601 52,284
Tollgate Fuels Reduction Project FEIS

H-13
OR-11

US-12

US-12

Clarkston 29 Miles

[

US-12

TROY

WASHINGTON

OREGON

ASO-128

GAR-201

Peola-Iron

Springs Road

GAR-128

GAR-118

Tucannon River

COL-9233

WA-126

Road

COL-1931

COL-9115

Kendall-Skyline Road

ASO-110

ASO-105

Asotin-Cloverland Road

ASO-181

ASO-175

ASO-105

ASO

ASO-235

COL-9124

40

42

46

64

47

4304

ASO-127

ASO-100

Grande Ronde River Road

WAO-569

ASO-116

4039000

WAO-194

111

ASO-121

WAO-570

43

41

44

Union

Wenaha-Tucannon

Wilderness

North Fork Umatilla

Wilderness

Eagle Cap Wilderness

3109

4200

3113

6308

4302

4305

3200

6500

4030

4039

6300

4000

4400

4300

6400

4625

6401

6415

6234

4018

4610

3102

4620

4038

6212

6235

3150

4713

3100

4206

3128

6200

4022 3728

4027

6206

4608

6219

4016

620

8

6236

6217

3715

4600

6232

4100

6406

6307

4700

3725

3738

4712

3719

6231

6214

6306

6437

4304

6413

DAYTON

WAITSBURG

DIXIE

WALLA

WALLA

TROY

MILTON-FREEWATER

FLORA

WESTON

WALLOWA

ELGIN

MEACHAM LOSTINE

SUMMERVILLE

IMBLER

ENTERPRISE

JOSEPH

ISLANDCITY

LAGRANDE

COVE

UNION

G A R F I E L D G A R F I E L D

C O L U M B I A C O L U M B I A

W A L L A W A L L A

W A L L A W A L L A

U M A T I L L A U M A T I L L A

U N I O N U N I O N

A S O T I N A S O T I N

W H I T M A N W H I T M A N

W A L L O W A W A L L O W A

-

Tollgate Project

Planning Area

WASHINGTON

OREGON

IDAHO

Walla Walla Ranger District

Umatilla National Forest

Tollgate Fuels Reduction Project

Tollgate Fuels Reduction Project - Inventory of Potential Wilderness Areas

Map H-0: Roadless Context Map for Northern portion of Umatilla National Forest

Legend

Tollgate Project Planning Area

Walla Walla Ranger District

Pomeroy Ranger District

Other Forests

Inventoried Roadless Areas(IRA)

Wilderness

Cities

County

Forest Service Road

State Road

County Roads

Robin Harris

GIS Specialist

06/21/2011

Tollgate Project

Planning Area
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-2: Removal of Past Timber Harvest Area

H-2

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Past Timber Harvest

Wilderness

Inventoried Roadless Areas

Depicts Walla Walla Ranger District's

Past timber harvest as well as

 Walla Walla River and Lookingglass IRA's.

Past timber harvest areas where logging and

roads are evident will be removed from further 

examination per (FSH 1909.12 71.11(9)).

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-3: Forest Roads

H-3

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

300' each side of Forest Road

Wilderness

Inventoried Roadless Areas

Depicts forest roads. Acres highlighted around 

forest roads have evidence of stumps due to 

road maintenance, public safety efforts,

 and approved personal use activities which 

all occur within 300’ each side of forest roads. 

These activities result in evidence of substantially 

recognizable stumps due to removal of danger 

trees, firewood, etc. (FSH 1909.12 71.11(9)).

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-4: Acres not containing Past Timber Harvest or Forest Roads

H-4

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Acres not containing past timber harvest

or forest roads

Wilderness

Inventoried Roadless Areas

Depicts acres that remain following the 

removal of past timber harvest and forest roads. 

The remaining polygons are examined using 

inventory criteria at FSH 1909.12 ch 71. Details 

of the examination can be found in Potential 

Wilderness Inventory methodology and Results 

document (appendix H- Tollgate EIS).

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-5: Forest Service Inventory of Potential Wilderness Areas 

H-5

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Potential Wilderness Areas

Other Undeveloped Lands

Wilderness

Inventoried Roadless Areas

Map displays potential wilderness areas and

other undeveloped lands.

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Walla Walla River

Lookingglass

Walla Walla River

Lookingglass

Walla Walla River

Lookingglass

This product is reproduced from geospatial information prepared by the U.S. Department of 

Agriculture, Forest Service. GIS data and product accuracy may vary. They may be: developed from 

sources of differing accuracy, interpretation, incomplete while being created or revised, etc. 

Using GIS products for purposes other than those for which they were created may yield inaccurate 

or misleading results. The Forest Service reserves the right ot correct, update, modify, or replace GIS 

products without notification. For more information contact the Umatilla National Forest Supervisors Office. 

Depicts forest roads. Acres highlighted around 

forest roads have evidence of stumps due to 

road maintenanc e, public s afety efforts,

 and approved personal us e activities which 

all occur within 300’ each side of forest roads. 

These activities result in evidence of substantially 

recognizable stumps due to removal of danger 

trees, firewood, etc. (FSH 1909.12 71.11(9)).

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Forest Roads

District Boundary

300' each side of Forest Road

Wilderness

Inventoried Roadless Areas

Walla Walla RD, Tollgate P roject Planning Area

Existing Forest Plan Inventoried Roadle ss Areas

Appendix C - 2001 Roadless Rule

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Forest Roads

District Boundary

Wilderness

Inventoried Roadless Areas

Depicts Walla Walla Ranger Distr ict's

Past timbe r harvest and Walla Walla River

and Lookingglass IRA's.

Past timbe r harvest areas where logging and

roads are evident will be removed from further 

examination per (FSH 1909.12 71.11(9)).

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Forest Roads

District Boundary

Past Timber Harvest

Wilderness

Inventoried Roadless Areas

Map reflects FS inventory of a reas with 

wilderness potentia l within the To llgate 

project planning boundary.

Tollgate Fuels Reduction Project

Potential Wilderness Inventory

 ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Forest Roads

District Boundary

Wilderness

Inventoried Roadless Areas

Areas Meeting PWA Criteria

Other Undeveloped Lands

5 2.5 0 5 Miles

H-1 H-2 H-3

H-5

H-6

Walla Walla River

Lookingglass

Depicts acres that remain following the 

removal of past timber harvest and forest roads. 

The remaining polygons are examined using 

inventory criteria at FSH 1909.12 ch 71. Details 

of the examination can be found in Potential 

Wilderness Inventory Methodology and Results 

document (appendi x H- Tollgate EIS).

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Forest Roads

District Boundary

Wilderness

Inventoried Roadless Areas

Acres not containing past timber harvest

or forest roads

H-4

North Fork Umatilla Wilderness North Fork Umatilla Wilderness North Fork Umatilla Wilderness

North Fork Umatilla Wilderness North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-7: Interaction between PWA and Alternative B Units

H-7

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Potential Wilderness Areas

Wilderness

Inventoried Roadless Area

Alt B Treatment Units

Map displays interaction between Forest Service 

Potential Wilderness inventory and Alternative B Units.

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-8: Interaction between PWA and Alternative C Units

H-8

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Potential Wilderness Areas

Wilderness

Inventoried Roadless Areas

Map displays interaction between Forest Service 

Potential Wilderness inventory and Alternative C Units.

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-9: Interaction between Other Undeveloped Lands and Alternative B Units

H-9

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Other Undeveloped Lands

Wilderness

Inventoried Roadless Area

Alt B Treatment Units

Map displays interaction between Alternative B Units

and other undeveloped Lands

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas

Map H-10: Interaction between Other Undeveloped Lands and Alternative C Units

H-10

1.5 0.75 0 1.5 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Other Undeveloped Lands

Wilderness

Inventoried Roadless Areas

Alt C Treatment Units

Map displays interaction between Alternative C Units

and other undeveloped lands.

North Fork Umatilla Wilderness
APPENDIX I 

CONSIDERATION OF MAPS 

SUBMITTED BY 

Hells Canyon Preservation Council (HCPC)

 

Tollgate Fuels Reduction Project Final Environmental Impact Statement

I-1 

Appendix I

Consideration of Roadless Maps submitted by the Public

This appendix displays how the Forest Service considered the maps presented by interested parties which 

reported to show acres within the planning area that contained ‘roadless’ characteristics. During project 

scoping Hells Canyon Preservation Council (HCPC) supplied GIS information showing their 

determinations of acres showing ‘roadless’ characteristics. To date, only HCPC has provided such 

information for the Tollgate project. An index of maps included in this appendix are listed below: 

Index of Maps

Map I-0................................... Roadless Expanses as identified by HCPC’s inventory method 

Map I-1....................................HCPC polygons in relation to Inventoried Roadless Areas, 

Potential Wilderness Areas, Other Undeveloped Lands and Forest Roads

Map I-2....................................HCPC polygons in relation to Inventoried Roadless Areas, 

Potential Wilderness Areas, Other Undeveloped Lands, Forest Roads and Alternative B activities

Map I-3.................................... HCPC polygons in relation to Inventoried Roadless Areas, 

Potential Wilderness Areas, Other Undeveloped Lands, Forest Roads and Alternative C activities

Background:

HCPC submitted written comments (project file) about the ‘roadless issue’ in response to our scoping 

letter on the Tollgate Fuels Reduction project. Their letter included maps with polygons they present as 

roadless using inventory criteria and methods they developed for their purposes. They asked the Forest 

Service to consider the impacts to roadless characteristics within the polygons they inventoried and 

submitted as roadless.

The HCPC map and comment letter describe their polygons using many different terms including, but 

not limited to, inventoried roadless areas, roadless, unroaded, roadless expanse, and un-inventoried 

roadless. Some acres on both maps agree and overlap. Portions of the polygons submitted do not 

coincide with polygons on Forest Service maps (Appendix H). HCPC did not provide the forest service 

with inventory criteria they used to develop their maps submitted during public comment. 

Confusion surrounds this issue because there are conflicts between Forest Service maps and the map 

presented by HCPC. Each map has its own history of genesis; these maps appear to use similar terms 

with different definitions; use different terms altogether; and, based on different map products, and 

appear to have different methodology and criteria used to inventory the land. Confusion continues 

when HCPC asks the Forest Service to disclose impacts to ‘roadless characteristics’ on lands the Forest 

Service determined do not meet agency inventory criteria. 
Tollgate Fuels Reduction Project Final Environmental Impact Statement

I-2 

In a related example, this EIS discloses impacts to a number of resources sensitive to the construction of 

new forest roads or from our system of existing roads. A road is defined and criteria and methods for 

inventorying a road conform to agency policy. Definitions and inventory criteria do not change project 

to project, Forest to Forest; they are common agency-wide. It would not be reasonable for a single 

individual or group to assert their own definition of a road or how to inventory a road system and then 

ask the Forest Service to disclose the impacts of ‘their road system’ on resources present such as elk 

habitat, fish habitat, or potential wilderness areas. Further, it is unreasonable to consider one version of 

inventoried forest roads to analyze impacts to elk and fish habitat and then apply a second, different 

version of roads in another analysis (PWA, other undeveloped lands) within the same EIS. Inventories 

of resources and facilities in support of the Tollgate Fuels Reduction project have been predicated on 

agency policy and procedures. 

These situations described above confound our ability to conduct a clear and meaningful effects 

analysis for the topic in the Tollgate Fuels Reduction project. 

To resolve this confusion the Forest Service uses its discretion to rely on agency policy, agency 

definitions of terms, and agency procedures for the inventory of resources and facilities. Inventory 

criteria and procedures for potential wilderness areas are found in Forest Service Handbook 1909.12, Ch 

71. Definitions and criteria used by the Umatilla National Forest to inventory potential wilderness areas 

are used by other national forests across the county. The application of these procedures to the Tollgate 

Fuels Reduction project is found in Appendix H of this EIS. The effects to inventoried roadless areas 

(IRAs), potential wilderness areas (PWAs), and other undeveloped lands were based on maps and 

polygons created using agency inventory procedures (Appendix H) and are considered and disclosed in 

Chapter 3 of the EIS titled ‘Wilderness and Undeveloped Lands’.
Tollgate Fuels Reduction Project Final Environmental Impact Statement

I-3 

Methodology and Discussion:

The following narrative describes how HCPC maps were considered in the Tollgate Fuels Reduction 

EIS NEPA process. 

1. HCPC polygons were mapped from their digital files identified as Blues_rdls1.20.2010. Map I-0. 

Approximately 15,067 acres are represented within the Tollgate Fuels Reduction Project planning 

area.
Tollgate Fuels Reduction Project Final Environmental Impact Statement

I-4 

Table I-1 Comparison of HCPC’s polygons and Forest Service inventory of PWAs, Other Undeveloped Lands 

and Forest Plan Management Area Allocations within Tollgate Fuels Reduction Project Planning Area

Management 

Area

Acres of 

PWA 

located in 

each MA

Percent of 

PWA in 

each MA

Acres of Other 

Undeveloped 

Lands located in 

each MA

Percent of 

Other 

Undeveloped 

Land in each 

MA

Acres of 

HCPC 

inventory 

located in 

each MA

Percent 

of HCPC 

Inventory 

in each 

MA

A2 3,061 23.3 0 0 3,080 20.4

A3 635 4.8 960 37.1 927 6.2

A4 76 <1 0 0 77 <1

A5 9 <1 1 <1 231 1.5

A6 157 1.1 384 14.9 266 1.7

A9 62 <1 32 <1 73 <1

B1 0 0 0 0 10 <1

C1 1,466 11.1 18 <1 1,560 10.4

C4 547 4.1 488 18.9 509 3.4

C5 76 >1 60 2.3 86 <1

E2 1,626 12.4 641 24.8 2,756 18.3

F4 5,411 41.2 0 5,410 36

Total 13,126 2,584 15,066

Rounded 13,128 100 100 15,067 100

 

2. Map I-1 was created that compared HCPC’s polygons to locations of other undeveloped lands, 

IRA’s, PWAs, and forest roads.

Table I-2 displays the acres of overlap of HCPC’s polygons with IRA’s, PWAs, other 

undeveloped lands, forest roads and past harvest on National Forest System Lands within the 

project planning area. 

Table I-2 Overlap of HCPC’s Polygons with PWAs, Other Undeveloped Lands, Roads, And Past Harvest 

PWAs

(acres)

Other 

Undeveloped 

Lands*

(acres)

Forest Roads 

within 

Polygon 

(miles)

Areas with evidence of 

stumps and Past 

Harvest 

(acres)

HCPC 12,871 286 1.45 1,527 

 

The affected environment of other undeveloped lands is disclosed in the EIS, Chapter 3 in the 

section titled Wilderness and Undeveloped Lands. The affected environment of other 

undeveloped lands is based on maps and acres described in Chapter 3, and Appendix H. 
Tollgate Fuels Reduction Project Final Environmental Impact Statement

I-5 

Descriptions for the affected environment of other undeveloped lands applies to the acres of 

HCPC’s polygons that overlap with other undeveloped lands polygons displayed in Map I-2, and 

Table I-2. 

3. Maps listed below were created that compared HCPC’s polygons to the locations of project 

activities proposed in Alternatives B and C, of the Tollgate Fuels Reduction project. 

a. Map I-2: Consideration of HCPC polygons and Alternative B units 

b. Map I-3: Consideration of HCPC polygons and Alternative C units 

 

Table I-3 displays the acres of HCPC’s polygons in comparison to the fuels reduction treatments 

proposed in Alternatives B and C. 

Table I-3 Proposed Activities within

HCPC’s Polygons by Action Alternative

Treatment 

(acres)

Alt. B Alt. C

HCPC 837 529 

No activities are proposed in the Walla Walla River IRA, Walla Walla River PWA or in the 

isolated PWA polygon 362 (1,087 acres). 

Under Alternative B approximately 220 acres in the Lookingglass PWA will be directly affected 

by fuels treatments (113 acres are in the Lookingglass IRA).

Under Alternative C approximately 11 acres in the Lookingglass PWA will be directly affected 

by fuels treatments (0 acres are in the Lookingglass IRA).

The descriptions of environmental effects to the ‘intrinsic physical and social values’ of other 

undeveloped lands applies to the acres of the HCPC’s polygons that overlap with other 

undeveloped lands polygons displayed in maps I-3 and I-4, and Table I-2 and I-3. Fuels 

treatments proposed within other undeveloped lands and environmental effects are described in 

the Chapter 3. 

4. Lastly, about 1,528 acres of HCPC’s polygons within the Tollgate Fuels Reduction project 

planning boundary do not overlap other undeveloped lands or PWAs. These remaining acres are 

essentially developed because they contain evidence of stumps along forest roads and evidence of 

past timber harvest. 

Activities in these remaining essentially developed acres of land applies to the acres of the 

HCPC’s polygons that do not overlap with other undeveloped lands polygons or PWAs as 

displayed in maps I-HCPC-Alt B and I-HCPC-Alt C. The environmental effects to the remaining 

essentially developed acres of land are disclosed throughout all other resource sections of Chapter 

4. 
Hwy 204

Hwy 204

FS 64

FS 63

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

Main Road

Existing Inventoried Roadless Area (IRA)

North Fork Umatilla Wilderness

HCPC unroaded polygons

 ́

Consideration of

Hells Canyon Preservation

Council (HCPC) inventory

Map I-0

I-0

Walla Walla River IRA

Jaussaud Corral IRA

Lookingglass IRA

Hellhole

IRA

North Fork Umatilla Wilderness

Map displays HCPC's identification

of unroaded polygons. The GIS data 

used to produce these maps was 

developed by HCPC and provided to

Forest Serive during public scoping. 

The polygons were developed by HCPC 

using their own inventory process.
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas and consideration of HCPC polygons

Map I-1: HCPC's Polygon in relation to Inventoried Roadless Areas, Potential Wilderness Areas, Other Undeveloped Lands, and Forest Roads.

I-1

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Wilderness

Inventoried Roadless Areas

HCPC Polygon

Potential Wilderness Areas

Other Undeveloped Lands

Map displays Forest Service potential wilderness

inventory and other undeveloped lands and their 

relation to HCPC's polygons.

North Fork Umatilla Wilderness
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas and consideration of HCPC polygons

Map I-2: HCPC's Polygon in relation to Inventoried Roadless Areas, Potential Wilderness Areas, Other Undeveloped Lands, Forest Roads and Alternative B activities

I-2

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Wilderness

Inventoried Roadless Areas

HCPC Polygon

Potential Wilderness Areas

Other Undeveloped Lands

Alt B Treatment Units

North Fork Umatilla Wilderness

Map depicts Forest Service Potential Wilderness Inventory,

other undeveloped lands, and Alternative B Units in relation

to HCPC polygons
Walla Walla River

Lookingglass

Tollgate Project Planning Area - Inventory of Potential Wilderness Areas and consideration of HCPC polygons

Map I-3: HCPC's Polygon in relation to Inventoried Roadless Areas, Potential Wilderness Areas, Other Undeveloped Lands, Forest Roads and Alternative C activities

I-3

2 1 0 2 Miles  ́

Legend

Tollgate Project Planning Area

Tollgate PWA Analysis Area Boundary

District Boundary

Forest Roads

Wilderness

Inventoried Roadless Areas

HCPC Polygon

Potential Wilderness Areas

Other Undeveloped Lands

Alt C Treatment Units

North Fork Umatilla Wilderness

Map depicts Forest Service Potential Wilderness Inventory,

other undeveloped lands, and Alternative C Units in relation

to HCPC polygons
APPENDIX J 

CORRESPONDENCE FROM OTHER FEDERAL 

AGENCIES ON THE DECEMBER 2012 DEIS

 

APPENDIX J 

Index of Letters submitted by other Federal Agencies during the 45-day comment period 

for the Tollgate Fuels Reduction Project Draft EIS.

1. US Department of Interior........................Dated February 11, 2013

2. US Environmental Protection Agency.........Dated February 12, 2013
United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance 

620 SW Main Street, Suite 201 

Portland, Oregon 97205-3026 

9043.1 

IN REPLY REFER TO

ER12/926 

Electronically Filed

 February 11, 2013 

John Laurence 

Forest Supervisor 

Umatilla National Forest

72510 Coyote Road 

Pendleton, OR 97801 

Dear Mr. Laurence: 

The Department of the Interior has reviewed the Draft Environmental Impact Statement for the

Tollgate Fuels Reduction Project. The Department does not have any comments to offer. 

We appreciate the opportunity to comment. 

 Sincerely,

 

 Allison O’Brien

 Regional Environmental Officer