Economic feasibility of biomass utilization not well addressed. ERA methodologies inadequate. Impacts of proposed buffers on commodities understated. Guidance for watershed analysis is vague. No ecological performance standards.
Preferred alternative has highest impact on soils due to road and silviculture.
Dependency of preferred alternative on small material market is unfounded. Cumulative effects analysis and consideration is inadequate. EIS emphasizes size, not structure and age. EIS does not adequately address the role of LSOG as part of the overall forest mosaic. LSOG can not be displayed spatially.