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ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National ForestPart 10a. Cumulative Effects Analysis Is Still InsufficientThe new DSFEIS still does not adequately address the cumulative effects or costs of logging and burning over all the different project areas combined. Nor does the DSFEIS provide the public with adequate maps showing overlapping impacts.In the German Ridge FEIS appeal decision, issued May 4th, 2006, the appealing officer writes: "After reviewing the project record for the German Ridge Restoration Project and considering each issue raised by the Appellant, I recommend that Acting Forest Supervisor James Lowe's Record of Decision of January 24, 2006, be reversed on the narrow issue of cumulative effects as defined in Issue 7. More specifically, as mentioned in my response the Record did not sufficiently show the rationale for selecting the cumulative effects analysis area.” The Forest Service is planning a number of projects close to the German Ridge project, including the Mogan Ridge, Buzzard Roost, Goosetown and Tell City Windthrow projects. The German Ridge FEIS shows German Ridge, Mogan Ridge, and Buzzard Roost project areas on p. 89. in Figure 4-1. On p. 91, the Tell City Windthrow project is shown as it overlaps with the German Ridge project. Other relevant information for assessing cumulative effects can be found in the Hoosier National Forest Map for Alternative 5 (the preferred alternative) http://www.fs.fed.us/r9/hoosier/images/maps/forest_plan/alternative5.pdf. This map shows the Management areas for the Hoosier National Forest. In other words it shows what “treatments” have been authorized in different parts of the HNF. The Forest Service Handbook requires every EIS to identify and consider cumulative effects: “For each alternative, estimate the direct, indirect, and cumulative environmental effects, including the effectiveness of the mitigation measures, that would result from implementing each of the alternatives, including the no action alternative. Also, identify any additional mitigation measures that may be required, such as measures common to all alternatives.” 1909.15 FSH § 15. The CEQ Regulations define “Cumulative impact” as: “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.” 40 C.F.R. § 1508.7. The CEQ Regulations also state: “‘Effects’ include: . . . (b) Indirect effects, which are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems.” 40 C.F.R. § 1508.8. The map provided on page 23 of the SDFEIS supposedly provides information on “Cumulative effects analysis areas for various resources”. This map is anything but user friendly. Nor does it provide information on cumulative impacts for the limited effects it claims to address. • While the map on p. 23 shows the German Ridge project area, it does not show the boundaries of the Mogan Ridge, Tell City and Buzzard Roost projects. • The legend is not very helpful without reading into the text. It lists a two mile buffer (red), HUC 5th level (black), and HUC 6th level (orange), but none of these give the reader any information about what resources these boundaries refer to. • Only after tedious reading of the associated texts, which are sometimes confusing, is it possible to make out what “resources” (birds, amphibians, water and soil, air, etc.) the different borders refer to. • The map displays a black border which, according to the text, has no relevance for the analysis. DSFEIS, p. 22: “Figure 4-5a shows the boundaries of three of the cumulative effects analysis areas used in this Supplement. The area for this analysis of cumulative effects on birds, like the analyses for some other resources, is the 6th level subwatersheds (HUC 6th Level) (see the map). The map also displays the HUC 5th Level, since the 6th level subwatersheds are not all in the same in 5th level watershed.” • While this map shows possible impact boundaries associated with the German Ridge project, it is not at all helpful in assessing cumulative effects that could result from ALL the planned projects (Mogan Ridge, Tell City and Buzzard Roost) • For the map to show cumulative impacts on birds, bats and reptiles, air, water etc. from all four of these projects, this map would have to show impact areas for each of the projects for those same “resources”, and show how they overlap. In other words, the map would have to show red, orange and black boundary lines for all the different projects in one map. This is not happening in this map. It therefore does not really show what it says it is showing. It is showing the effects of one project, the German Ridge Project, without regard for the overlapping, cumulative effects of the other projects. • The other thing missing is what is happening on other lands. In the text, we are given information about how much logging we can expect on private lands over the next decade. Where will this most likely be happening? Will it be within the project boundary or analysis areas or outside of them? How will this affect all the above named “resources?” This is not a cumulative analysis. Protect Our Woods
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