Jeff, we have received your comments on the District's proposed small timber sales. I would like to clear up some possible misunderstanding on what goes into the NEPA folder, even if we use the new categorical exclusion authority. We are still involving the full compliment of ID team members. We are looking at the cumulative effects, and the CE will include a brief discussion of these findings. I agree with you in that if we have had much recent activity in the area (regardless of whose land it occurred on), the cumulative effects issue would require us to perform a more detailed analysis. For the projects mentioned in this scoping letter, we specifically selected these areas (among other reasons) because there has been no timber sales in the last 20+ years on National Forest or other owners lands. Some of the sites may have had small scale prescribed burns in the mid-1980s to address conifer encroachment in brush/grasslands. These Rx burns will be shown in the CE. The areas we are looking at for cumulative effects are several subwatersheds, so we are looking out 5+ miles. The CE will most definitely address how the project meets the Forest Plan direction. This was probably one of our first things we looked at; Is the proposal consistent w/ the Forest Plan? Concerning old growth timber, the 3 Douglas-fir areas will be dealing with only second-growth (80-100 years old) fir. These stands do not meet the definition of old growth criteria. These areas were logged about 25-30 years ago & the logging at that time removed most of the "mature" trees. The only old trees remaining are the few that were not merchantable and/or were stuck in rocks piles. I have provided preliminary instructions that these trees would not be cut, as our interest and need is to thin the second growth stands. We recognize these old trees have a much higher value on the ground for wildlife, visuals, etc. The Boulder River campgrounds are dealing with 80-100 year old lodgepole pine. The proposed cutting areas were old logged in the late 1800s to support he mining industry. The LP stands we have today are a result of the historic cuts. I am working w/the silviculturist on a cutting Rx; I am looking at thinning from below (the area has a lot of pole sized stands), favoring to leave the best and largest trees. The mountain pine beetle is just moving into the area & we are finalizing the Rx on how best to deal w/MPB in such stands. I favor thinning down to maintain the full tree stocking, but an epidemic MPB problem may force us to a heavier cut. I am not going to the heavier cut willingly, & will use it only as a last resort. Our Rx for all cuts will include leaving snags, leaving a prescribed amount of large woody debris on forest floor, etc. The detailed silvicultural Rx will not become part of CE, but the CE will spell out some of the general stand/ground objectives we are seeking. We are currently preparing biological evaluations for fish, wildlife and botany. I will incorporate the BE findings in the CE. The TES will be addressed here. Concerning soils productivity, we have on the ID team a soils scientist & hydrologist, who will assess this concern & make recommendations. These will be displayed in the CE. We are not addressing the access issue (road management) here. This is beyond the scope of these projects. We did look at the road network here & did not see much need for change. In the case of the Boulder R campgrounds, they are on a main road under state or county jurisdiction. Fish Creek has the main Fish Creek road, the only access into that part of the Highlands. The Forest has no plans or desire to remove this road from our system. South State and Rocky Canyon are accessed by local roads. South State is a graveled road & would likely stay on the system. There are a couple "jeep" roads leading into the proposed cutting unit that we could consider for removal. Rocky Canyon provides local access, but is probably not a critical access need. We have decided to include the roads analysis in the upcoming Pipestone/Whitetail travel & access analysis, which we will be working in next month & for next year or two. South State & Rocky Canyon are both in this large travel analysis area & we will look at these roads then. I will send you the final NEPA document, which I still believe will be the CE. I don't have too exact a timeline as to when I'll get thru this planning, but hope to by end of Oct. Terry J. Sexton District Ranger Jefferson Ranger District 3 Whitetail Road Whitehall, MT 59759 Phone: (406) 287-3223 or 1-800-433-9206 Fax: (406) 287-3368 Jeff Juel cc: jeffjuel@wildrockies.org, Michael Garrity Subject: BDNF timber CE comments 09/25/2003 05:42 PM The Ecology Center, Inc. 801 Sherwood Street, Suite B Missoula, MT 59802 (406) 728-5733 (406) 728-9432 fax ecocenter@wildrockies.org September 25, 2003 Terry Sexton, District Ranger Jefferson Ranger District 3 Whitetail Road Whitehall, Montana 59759 Transmitted via email--please acknowledge receipt! Mr. Sexton: These are comments on the South State, Rocky Canyon, and Fish Creek timber sale categorical exclusion proposals (your 9/9/03 scoping letter), on behalf of the Ecology Center and the Alliance for the Wild Rockies. First of all, it is not clear that you are giving the proper legal notice, nor allowing a long enough comment period. Cumulative effects simply cannot be assessed in the context of a Categorical Exclusion (CE). Please disclose the name of any past logging projects (implemented during the life of the Forest Plan) whose analysis area(s) encompass the areas to be logged under this proposal. Please disclose if the Forest Service has performed all of the monitoring and mitigation required or recommended in those NEPA documents, and the results of the monitoring. Lacking such knowledge, justification for use of a CE is missing. How the areas to be logged contribute to the integrity of the ecosystem, its wildlife habitats, its watersheds, and its aquatic species’ habitats cannot be determined given the level of non-analysis with a CE. Likewise, the proposal’s consistency with the Forest Plan cannot be demonstrated with a CE. Whether the area is habitat for any threatened, endangered, proposed, Sensitive, or management indicator species has not been determined, nor if it is proposed critical habitat. For the proposal to be consistent with the Forest Plan, enough habitat for viable populations of old-growth dependent wildlife species is needed over the landscape. The Beaverhead-Deerlodge National Forest has failed to insure viability of MIS and TES species to date. Please disclose how stands to be logged compare to Forest Plan or Region One old-growth criteria. In order to disclose such information, please provide all the details, in plain language, of these areas’ forest characteristics (the various tree components’ species, age and diameter of the various tree components, canopy closure, snag density by size class, amounts of down logs, understory composition, etc.). We ask that the Forest Service utilize the Roads Analysis Process and consider road obliteration in the analysis area. We are concerned that mechanical treatments will adversely affect soil productivity. NFMA requires the Forest Service to “not allow significant or permanent impairment of the productivity of the land.” [36 C.F.R. § 219.27 (a)(1).] NFMA requires the Forest Service to “ensure that timber will be harvested from National Forest System lands only where soil, slope, or other watershed conditions will not be irreversibly damaged.” [16 U.S.C. 1604 (g)(3)(E).] In sum, we are not convinced that the actions can be legally categorically excluded from more detailed NEPA analysis. Thank you for considering out comments. Sincerely, /s/ Jeff Juel And for: Michael Garrity Alliance for the Wild Rockies P.O. Box 505 Helena, Montana 59624 406-459-5936