Pete Miller cc: dragain@fs.fed.us, petemiller@wildrockies.org Subject: Frozen Face Douglas-fir Beetle Salvage 11/07/2003 05:45 PM The Ecology Center, Inc. 801 Sherwood Street, Suite B Missoula, MT 59802 (406) 728-5733 (406) 728-9432 fax ecocenter@wildrockies.org November 10, 2003 Mark Petroni, District Ranger Madison Ranger District, 5 Forest Service Road, Ennis, MT 59729 Transmitted via email--please acknowledge receipt! Mr. Petroni: These are comments on the Frozen Face Douglas-fir Beetle Salvage Project proposal (your 10/10/03 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. Please disclose the name of any other 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 any 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. Categorically excluding actions that risk further pollution in Water Quality Limited Segments is not consistent with the Clean Water Act or NEPA. 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.). The Forest Service must 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).] We incorporate the Ecology Center’s October 19, 1998 letter to Forest Supervisor Deborah Austin as comments on the Beetle Trails Salvage Project proposal. For your convenience, that letter is being sent as an electronic attachment to this email letter. In sum, we are convinced that the action cannot be legally categorically excluded from a more detailed NEPA analysis. Thank you for considering out comments. Sincerely, /s/ Pete Miller And for: Michael Garrity Alliance for the Wild Rockies P.O. Box 505 Helena MT 59624 406 459-5936 (See attached file: Issues2_KNF.doc) Issues2_KNF10.doc