Current Significant Tahoe National Forest Projects

 

 

Phoenix Project

 

The Phoenix project is basically the same as the combined Euro and Checkmate projects. The cumulative effects analysis is inadequate. Almost half of the analysis area is private lands, which is mostly being managed for timber production, yet the EIS contains very little information and analysis about the impacts of such logging. The EIS uses 1980 GIS data for habitat conditions on private lands, while conceding that substantial logging has occurred since that time. This is clearly outdated and falls short of NEPA requirements.

 

Stand Density Index used to support the intensity of proposed logging in this project has the following problems that should preclude its use:

 

The FVS model as used here with a thin-from-below prescription can be adjusted to report suitable SDI values without the taking of 30 inch dbh trees. This makes its use in support of the 30/40 rule suspect or illegal. The SDI was developed for even-aged stands, and is considered marginally suited by some experts even for that limited application. It is not considered appropriate for use in un-even aged stands as proposed in the Phoenix FEIS. Its use in support of the 30/40 rule is suspect or illegal. The SDI is a product of traditional, single-purpose, yield-oriented forestry. It does not account for stand attributes that qualify habitat, or for other values that might be considered part of the ecological forest system.

 

With respect to MIS, there is the usual failure to obtain annual monitoring data. The EIS admits that western portion of project area (fir) does not have a high risk of fire, yet still proposes intensive logging there. Project may adversely affect Mountain yellow-legged frog and Lahontan cutthroat trout, as well as other adverse cumulative watershed effects. Soil compaction in excess of 15% standard may occur.

 

Montez Project

 

This project in Sierra County is part of those projects meant to implement the Quincy Library Group pilot program to provide an extensive fuel break system. Unfortunately not only is this project far from any Wildland Urban Interface, it will take place within the Castle Peak Proposed Wilderness, and along the Perazzo Canyon Creek (eligible for Wild and Scenic) and adjacent to Willow Flycatcher habitat. It includes a Spotted Owl Home Range Core Area and Goshawk habitat. We will be providing comments on this egregious project, which completely ignores cumulative impacts from this and nearby SPI THP projects and the Phoenix project.   

 

Red Ant Project

 

We recognize the need to aggressively address the problem of fuels buildup that has resulted from previous misguided management policy. Thinning as proposed here can be done so that both fuels and ecology attributes are improved. Following the standards and guidelines of the 2001 Framework decision will accomplish this goal.

 

We are inclined to support any project, including this one, that avoids entry into spotted owl and goshawk habitat preserves. We strongly support the explicit declaration, included in this proposal, that no herbicide will be applied. The description of a diverse structure as a part of the desired condition of residual stands is encouraging.

 

But additionally, projects must pay attention to the deteriorating integrity of the Sierra Nevada Ecosystem. Continued north to south connectivity of this system will depend heavily on the Tahoe National Forest to resolve the roadblock to integrated management caused by the checkerboard pattern of ownership characteristic of this Forest. We submit that the time has come for every NEPA document that includes mixed ownership parcels to address this issue.

 

As an aid to achieving the desired condition of structural diversity we suggest the use of the “clumping” concept in thinning projects like Red Ant. This would produce residual structure closer to the kind of habitat expected by dependant species.

 

We have in the past observed a certain disconnect between the need to drop “hazard” trees and real concern for safety. We suggest that the EA include criteria for this practice as it will apply to Red Ant.

 

Alder Creek Project

 

As is true of the Phoenix project, thinning as proposed here can be done so that both fuels and ecology attributes are improved. Following the standards and guidelines of the 2001 Framework decision will accomplish this goal.

 

Again, the Stand Density Index is a product of traditional, single-purpose, yield-oriented forestry. It does not account for stand attributes that qualify habitat, or for other values that might be considered part of the ecological forest.

 

We support the concept behind the effort to re-establish Aspen stands. We recognize the ecological importance of this habitat for dependant species, and the need to facilitate expansion of the type toward an acreage that approaches the natural range of variability, or the proportion of the landscape it occupied in pre-fire-suppression days. We submit that this effort will be more likely to succeed if the following conditions are met:

 

• Establish District and Forest goals for desired condition of aspen communities including total acreage in the Aspen ecological type, and maximum acreage for any single restoration project.
• Set a maximum acreage not to exceed 10 acres per regeneration stand.
• Prescribe preparations for regeneration that include removal of competing conifers, but only up to a maximum dbh of 20 inches. Trees proposed for removal up to 30 inches may be approved as exceptions based on effectiveness in releasing Aspens. No conifers larger than 30 inches should be removed under any condition.

 

We suggest that the Aspen Regeneration issue needs to be further developed at the level of Forest wide planning. Aspects of the program as we understand it now, including the taking of very large, rare, conifers, and the apparent unlimited spatial scope proposed for stand treatment, indicate a project whose design is “in-progress”.