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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 10b. Cumulative Effects Analysis Is Still InsufficientFurthermore, the Cumulative Effects analysis is lacking in a number of other ways:• There is no cumulative effects analysis with regard to possible new projects emerging from the Hoosier National Forest Plan. For example, not too far away from german Ridge is Management area 3.3., which gives authorization for the most rigorous “treatments” (up to 40 acre clearcuts) on the HNF. Plus there are various areas in the vicinity to the above projects that are designated Management Areas 2.8., which have the second most intense management prescriptions with regard to logging and burning on the HNF. • The map on p. 23 of the DSFEIS does not indicate whether there is any State Forest land that may have overlapping impact boundaries with HNF projects like German Ridge, Mogan Ridge, Tell City and Buzzard Roost, or management Areas 3.3. and 2.8. The State of Indiana is planning to intensify logging on State Forests (3-5 times as much logging than previously). Even if the State lands are not that close by, still, the effects of these large increase in logging on State lands needs to be considered in the cumulative impact analysis, since these are public lands where the “resources” such as birds are most likely to go when pushed out of the German Ridge area during logging and burning. The Forest Service and the State could be logging, mining, burning, building or reconstructing roads, spraying herbicides at the same time in adjacent management/project areas. The DSFEIS does not properly explain the interaction, accumulation, and synergy of these multiple, cumulative impacts on the environmental resources at the Hoosier National Forest. As the guiding regulations state, cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.” 40 C.F.R. § 1508.7. As mentioned above, 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. " The DSFEIS does not even come close to addressing all environmental effects, nor is that analysis provided in the HNF Plan, to which the German Ridge Project is tiered: • No attempt is made to include overlapping impact areas regarding air pollution from burning (See also below Section 17. Prescribed Burning). It is not admissible to pretend that the smoke from prescribed burns can just be dealt with by waiting for a windy enough day, so that the smoke is carried out of the project area, which is the approach taken by the Forest Service. There is simply no away, and the smoke certainly cannot be contained within Perry County, which is used as analysis area. This same faulty approach has been used with industrial pollutants, which were disbursed (solving heavy pollution problems in highly populated areas) by simply building high smoke stacks, that would allow for the pollution to be carried into far away places. Our planet doesn’t have any “away” any more. Several counties in Southern Indiana already do have pollution issues. • There is a vicinity map on page 1-4 of the HNF LRMP that shows the counties that overlap with the HNF area. Some of these counties are non-attainment areas with regard to particulate matter. Burning thousands of acres within German Ridge alone and other current and future burning projects on HNF and State Forests may well lead to a worsening of the air pollution situation in the non-attainment areas. The DSFEIS should address those issues. • The Hoosier is proposing to significantly increase prescribed burning. When large landscape fires are done, there are no pollution controls. There are no baghouses or electrostatic precipitators. There is nothing to stop all of the pollution from going straight into the atmosphere. There is a tremendous range of sizes and tremendous volume of particulate matter that goes into the air with this burning. In addition, areas which have been or will be treated with chemical herbicides and pesticides could be burned, creating a chemical toxicity issue. We do not believe that the EIS properly assesses the potential health effects, either individually or in combination. According the American Lung Association, particulate pollution can cause aggravated asthma, increased respiratory symptoms, chronic bronchitis, increased respiratory and cardiovascular hospitalizations, decreased lung function in children, lung cancer, and premature deaths. With the increases in burning proposed on the Hoosier and other forests in our region, all of which are proposing to implement extreme increases in prescribed burning, there could and likely will be a very significant cumulative effect on the health of residents in the region. It is no secret that there already is a serious problem with respiratory diseases in the Ohio Valley, and we are very concerned about the health effects of the pollution. By only considering the individual impacts of burning on the Hoosier, the Hoosier is bypassing having to look at the obvious cumulative impacts to our air quality from particulate pollution from all the forests in the region. And it isn’t just federal forests doing this – it is state also, and sometimes they are doing more than the federal forests. We don’t believe that a proper cumulative effects analysis on all of the burning increase in the region on the health effects of the people has been done. • The DSFEIS does not address the effects of sedimentation outside or the analysis area, which is the subwatersheds (the HUC 6th level). It seems the rationale for keeping the analysis within these boundaries is that sediment will settle and travel only as far as these subwatersheds (page 45 of the DSFEIS). However, why did the Forest Service assume this? “This area was chosen because any sediment that might potentially be introduced by the actions of the alternative would settle out before reaching larger order streams. Any sediment that might be produced would remain within these watersheds, and any potential increase in sediment would be temporary. The timeframe considered is 10 years, since any sediment produced by the proposed actions would have settled out before that.” Isn’t it general knowledge that sediments from the Midwest end up in the Mississippi? How is the Ohio River going to be affected by this, being only a few miles from the project area? How is it possible that sedimentation caused by the German Ridge project would stay put when other sediments travel far distances? For example, sediments from logging over a hundred years ago in the Yellowwood Watershed in Brown County are still accumulating in Yellowwood Lake. How is it that German Ridge project sediments will somehow stop migrating after ten years? What is the rationale for coming up with this number? • While there purports to be cumulative impact analysis contained in the EIS, they only address one impact at a time. This is flawed. For example, cutting the trees and skidding them out would cause an impact to the environment. Soil would end up in the stream and become increasingly compacted, temperatures will change, airflows change, that could affect the insect population which will affect the natural community present on the site. If that site is burned while that transition is taking place, it will have to go through a secondary recovery process, which will impact the natural community again. If a road is placed through the area, that will bring more access and disturbance and divide the area for smaller creatures and plant distribution. Minerals activity could add further soil impacts and air pollution. All of this occurring at once would have additional impacts than just one impact, even if you were looking at the one impact across the entire forest. • In addition, a hard look at cumulative impacts includes a look at “past” actions. But, there isn’t an adequate assessment of past timber harvesting in and around the Hoosier, and even the flawed Hoosier-Shawnee Assessment admits that the forest doesn’t have data on past harvesting in the Assessment area, which includes the Hoosier. “…A complete database of harvest removals for the study area does not exist at this time…” • Suffice to say that the flawed Assessment admits that there has been significant disturbance across the region since European settlement, which has had some very significant effects on the environment. This includes widespread uncontrolled burning, clearing, conversion to other uses, high grading, you name it. So much so, that, as was indicated earlier, only a small percent of the forest that was in Indiana remains, and that which remains is very much altered and now in an altered climate and environment. • Some of the obvious effects include the elimination of virtually all of the old growth forest that dominated the region, the elimination of some species, population shifts of other species from what were historical levels, and changes in watersheds. The cumulative effects analysis in the DSFEIS doesn’t mention how much of these areas have been disturbed by farming, logging, roads, and other management in the recent past, and how that might affect their ability to function as large forest ecosystems. There doesn’t appear to be any information in the record which shows how many and how large continuous forest areas are, even though the record shows that the Assessment process indicates that there is very little continuous forest habitat in the area. There is no information as to the average distance from one edge to another. Yet, without that analysis, the Respondents claim that fragmentation won’t be much of a problem, even though their plan is going to increase the effect. This does not comply with NEPA. • The practical effect of this lack of information is that the public and agency doesn’t know what size of continuous forest blocks will remain after the plan is implemented, and to what degree currently unfragmented areas will be fragmented or currently unfragmented areas will become less fragmented. Without this information, no one can tell how the forest interior ecology is going to react and how viability of species ranging from the black and white warbler to the red shouldered hawk will be maintained. In addition, there is little or no information in the HNF FEIS, GR FEIS or DSFEIS, about how connected larger forest blocks are with other blocks, and what percent of the landscape in various areas is forested vs. other habitat types. The connectivity of forest blocks is critical in knowing the impact of management activities, as it can affect genetic diversity among forest species. There are no standards and guidelines in any of the management prescriptions to insure that areas stay connected. This is a huge violation of NEPA and the plan cannot insure viability of sensitive forest interior species like the wood thrush without this information. • We are not told whether or not there is a source/sink dynamic occurring on the Hoosier, which there probably is, and which there is evidence that there is, and what kind of cumulative impacts might occur to other areas, like the Shawnee, if source areas on the Hoosier are degraded. A proper cumulative effects analysis would have such information. • But there are other cumulative impact issues that the EIS doesn’t address. For example, fragmentation effects could ultimately lead to an overabundance of leaf eating insects attacking the forest. Nature is remarkable in that the timing of the migration of the wood warblers and other species is such that it is timed almost perfectly (or at least until recently, when global climate warming seems to be dangerous altering this, as explained elsewhere in this appeal) with the hatching of leaf consuming insects in the forest. It is the flush of birds moving through our forests which help control this. Research by Marquis and others found that reduction in bird populations could become problematic in relation to the health of the forest. We have raised this issue before the agency repeatedly over the years, but the agency continues to fragment the forest. Here is what Marquis says. “Our results imply that declining populations of many neotropical migrant insectivorous bird species may result in decreased forest productivity. Where such population declines in certain bird species have been documented, they have not been offset by increases in populations of other insectivorous bird species. . . . Our research suggests that forest management practices that promote the conservation of insectivorous birds are imperative to maintain forest productivity. Such management practices would emphasizes strategies that maximize bird species diversity and the viability of their populations.” Marquis, Robert J. and Christopher J. Whelan, “Insectivorous Birds Increase Growth of White Oak Through Consumption of Leaf-Chewing Insects” Ecology, 75(7), 1994, pp. 2007-2014. • Other fragmentation impacts that aren’t considered are related to the richness of the soil, the extent of soil fauna, affecting food supplies for birds like the ovenbird. According to Dr. Scott Robinson, due to work by researchers Burke and Nol, “we now have good evidence that fragmentation can reduce insect availability for some birds and indirect evidence of food-based habitat selection by females.” This could have a huge cumulative impact on the viability of ovenbirds. Click here for Cumulative Effects Analysis Is Still Insufficient Part 3 of 4Protect Our Woods
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