thanks for your comments. Jeff Juel cc: jeffjuel@wildrockies.org, Michael Garrity 09/12/2003 11:38 Subject: Daisy Creek Post and Pole AM The Ecology Center, Inc. 801 Sherwood Street, Suite B Missoula, MT 59802 (406) 728-5733 (406) 728-9432 fax ecocenter@wildrockies.org September 12, 2003 Mark Petroni, District Ranger Madison Ranger District 5 Forest Service Road Ennis, Montana 59729 Transmitted via email--please acknowledge receipt! Mr. Petroni: These are comments on the Daisy Creek Post and Pole project proposal (your 8/26/03 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. Also, your 8/26 notice has no map, and the legal description describes far more than the maximum 70 acres specified in your notice. 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. If the area 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).] 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 406-495-9436