The following are comments prepared By Hilary Lambert on behalf of the Cumberland Chapter concerning the Environmental Assessment (EA) for the 2003 Ice Storm Recovery Project. These comments were issued to James D. Manner, District Ranger, Morehead Ranger District of the Daniel Boone National Forest in December, 2004.
Mr. Manner,
Enclosed are the Sierra Club’s comments regarding the Environmental Assessment (EA) for the 2003 Ice Storm Recovery Project. Overall, we find the proposal to be vague, incomplete and in need of further refinement through an Environmental Impact Statement (EIS) as prescribed in the National Environmental Protection Act (NEPA).
The major omission in the EA is the lack of a suitable range of alternatives presented to the public. Basically we are presented a decision to accept the cutting of 12,570 acres or not cutting them. The alternatives presented in favor of cutting this acreage differs only in whether or not a portion of the project will be commercially harvested or totally non-commercially cut. Even the two alternatives considered and eliminated from detailed study only differ in the manner that commercial harvesting will be allowed.
Missing from the alternatives are options for a reduction in acreage cut and/or an option to proceed with salvage operations for visitor safety, i.e., cutting damaged trees along road and trail corridors to prevent future falls from injuring forest visitors. This type of project has been proposed in other districts on the Daniel Boone National Forest (DBNF) and could be appropriate in this instance.
However, given the lack of choice as presented in the EA, our preferred alternative would be "C - No Action".
We have also found the EA to be strikingly incomplete regarding details of the proposal. It is as if we are being asked to approve a plan which has yet to be developed. Apparently, DBNF staff have identified damaged trees in areas of the forest that they wish to see cut, but this information has not been relayed to the public through this plan. Despite the fact that we may (or may not) be able to find these sites based on the maps provided, we can not identify the specific trees alluded to that need to be cut. We would very much like to know what the specifics of cutting in each area would be so that our experts could present informed evaluations of DBNF decisions. Does the DBNF intend to allow foresters in to these areas to use their best judgment of which trees meet the criteria for harvest? Or will the DBNF be taking an active role in identifying and marking individual trees for treatment in order to achieve the 'desired future condition'? We hope it is the second and we feel we should be apprised of these decisions in order to make informed evaluation and comments. As it is, the detailed information is not present in the EA.
The same criticism applies to the use of herbicides as proposed. We are told which herbicides may be used and that it would total up to 1000 acres. We are not informed as to which acreage (or sites) will be impacted, nor are we informed of what "non-native invasive species" are being targeted for removal. On what data has the DBNF relied to make the statements in the EA? And why are we not provided with this data?
In addition to the lack of details, the sheer magnitude in terms of number of parcels identified makes this proposal difficult to understand and evaluate. We foresee additional problems in managing and monitoring it. A cursory review of Appendix E that lists the individual parcels shows that parcel 1338 (Appendix E, Table E-2, proposed non-commercial removal) contains no acreage, even though the measurements are carried to 4 decimal places (a .0001 acre would amount to at least 4 sq. ft., easily the size of a damaged tree crown). To illustrate the problem of lack of detail, we present parcel #569 (Appendix E, Table E-1, proposed commercial removal) which lists at .0035 acre, or approximately 152 sq. ft. If the Forest Service can identify a parcel as small as a 10'x15' room for treatment, why can it not identify for the public the tree(s) in that parcel that "need" treatment?
In the "Purpose of and Need for Action" narrative, the Forest Service claims that approximately 109 miles of skid and haul roads would need to be constructed. This number only applies to the commercial harvest units (EA, pg. 1-2, para.3). No indication of road building needs is provided for the much larger non-commercial tree removal acreage. Are we to assume that no roads will be built in these parcels? Given that the acreage is almost twice that as the commercial harvest areas, and the number of site are almost three times as many. It is assumed that ground disturbing activity on these parcels will have a greater impact on soil erosion and sedimentation issues. Yet, again, no details are provided. It appears from the maps that these areas will be more difficult to access because of their distance from existing roads and their location on hard-to-access terrains.
Again, just due to the lack of specifics and potential for environmental impact, we would have to say that the Forest Service should not take on this project, if only because it does not appear ready to manage a proposal of this magnitude.
We believe the lack of a range of alternatives and detail in the Environmental Assessment make it unsuitable for acceptance. Furthermore, the controversial nature of timber operations on Forest Service lands in Kentucky, as well the potential impact to the Indiana bat (an Endangered species), finds this proposal to be in need of further, detailed study through a complete Environmental Impact Statement. To do otherwise would prove to be a disservice to the public, a danger to the environment and a violation of NEPA.
The Sierra Club insists that the Daniel Boone National Forest not proceed with this proposal until a full and complete NEPA process be carried out.
Sincerely,
Hilary Lambert Top
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