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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 10d. Cumulative Effects Analysis Is Still InsufficientRATIONALE FOR THE CUMULATIVE EFFECTS BOUNDARY FOR BIRDS IS STILL VAGUEThe rationale for the cumulative effects boundaries, especially as it pertains to birds, is still vague, lacking an adequate rationale. This was the “narrow” point that the appeal of the project was based on. Cumulative Effects – Alt. A – Birds An important criteria in setting the geographic limits for the cumulative effects analysis is a sufficient land area (habitat) for multiple breeding ranges of the species occurring in the project area. Several species of Neotropical migrant songbirds may occur in the project area, species associated with riparian habitats. These include the Acadian flycatcher and the Louisiana waterthrush. Because activities in the larger watershed areas may affect riparian habitat and thus perhaps these bird species, the 6th-level watersheds in which the project area occurs represent—for all alternatives--the appropriate analysis area for cumulative effects on birds. The watersheds are Deer Creek Headwaters, Middle Deer Creek, Big Poison Creek, East Deer Creek, Deer Creek Main Stem, Millstone Creek, Ohio River-Fanny Creek/Adams Run, and Ohio River-Bear Creek (see Figures 3-3 and 4-5a). Because of the scale of this area (about 47,000 acres) and the habitat within it, activities outside of the analysis area are unlikely to affect wildlife that might be affected by the actions of this alternative Breeding range, feeding range… 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. The DSFEIS only mention birds that prefer water; the Forest Service has therefore extrapolated that since some birds like water, then they must chose riparian areas as the new cumulative effects boundary. To us, this seems arbitrary and capricious. There is also NO justification for why the HUC 6th level boundary was chosen, even for waterbirds. A justification of a boundary for birds would have to consider the needs of the birds, in terms of foraging, nesting, and breeding. And it would have to include not just migratory, but also local birds. And since the Forest Service has chosen two species of migratory birds as the MIS’s for this cumulative effects analysis, then they should have also included information about how these migratory birds utilize this project area. Who stops off here and for how long? What other stops may be available nearby? How might other Forest Service projects impact those sites? How are the cumulative impacts of ALL logging on lands in southern Indiana affecting these birds, and their successful flights to and from their summer and winter destinations? For example, what is the rationale for picking nine riparian areas as the boundary for impacts of the project on birds? Are all birds going to be located within this boundary or only birds associated with water? How do we know “birds” are only going to stay within these boundaries? The DSFEIS mentions that “several” species of Neotropical migrant songbirds “may” occur in the project area. What several? And why “may?” Why hasn’t an area that the Forest Service is proposing to log and burn been surveyed for neotropical migrant songbirds, a very economically and environmentally important species? So, the Forest Service chose “several” species that “may” occur in riparian habitat, and then arbitrarily chose nine watersheds “several” “may” occur in as a cumulative effects boundary? This is arbitrary and capricious. What about migratory birds that are not associated with water as much as they are associated with the forest interior? Where will these birds be found and how will they be affected by projects going on around the German Ridge area, like those in the 40-acre clearcut zone, Management Area 3.3? The other thing missing is an analysis of the different effects that logging and burning can have on different aspects of bird behavior. For example, how will all of these Forest Service projects cumulatively affect the different birds’ breeding habits? Foraging habits? Nesting habits? We are told that “many bird species inhabiting the analysis area may use this maturing forest to meet some habitat need.” However, where will they forage, nest and breed during the 15 years while they wait for the hardwoods to grow? When birds from one territory enter another, there is often competition for resources. How then will the German Ridge Project and other area projects effect the competition among these birds? For the pine warblers, we are told that the “treatments” would affect them “incrementally” and “adversely.” Then we are told that since the pine trees would be lost in the coming decades, the pine warblers would then go to other pine trees in southern Indiana. Will these other pine trees have the carrying capacity for these additional pine warblers? Who is living in these other areas? The other arbitrary and capricious decision has to do with pine warblers versus grouse and other ESH MIS’s. The Forest Service seems so concerned that the grouse will be lost if we don’t create openings in the forest for them. We are also told that other species that are not native to Indiana hardwood forests need to be protected, even if they are not native. Why then doesn’t the Forest Service care for the pine warbler? Why is it that ruffed grouse can’t possibly survive without logging, yet pine warblers are expected to survive with logging, with no real concern for their future? Could it be that that ruffed grouse society was invited to the H-S EA secret meetings and people interested in pine warblers were not? In other words, are all of these decisions scientific or are they merely political? Our Hoosier LRMP appeal points to the fact that the decision to include the MIS’s, such as grouse and woodcock, and do surveys for them, is arbitrary and capricious. This has induced circular reasoning such as “we want to log, so we will chose the species that survive after we log.” And then, “we need to log to bring back species that don’t exist when we don’t log.” In the cumulative effects analysis of the DSFEIS on Page 26, in relation to the “no-action” alternative, we are told that it would hurt the birds due to “fragmentation” of the forest by pine trees. What about the effect of fragmentation on birds after logging? Rationale for Selecting the Cumulative Effects Analysis Boundaries Still Inadequate. The Appealing Officer told the Hoosier that the rationale for selecting the cumulative effects analysis boundary was inadequate. We conclude that the rationale for the cumulative effects boundary for all resources is still inadequate. It seems as if the Forest Service did not take this order seriously, but only gave a very half-hearted attempt to meet it. Some of the boundaries seem to be the same, for example with the birds and watershed impacts. The analysis area for forest vegetation is the project area This seems to be for the ease of the Forest Service analysis, and not for any conclusive scientific reason.. We write about the boundary for birds above. However, we also include amphibians, reptiles, endangered species like the Indiana bat, rare plants, NNIS, insects, aquatic species like fish and mussels, and mammals. For example: • NNIS: The Forest Service chose the vegetative management boundary for NNIS. This is arbitrary and capricious. NNIS can and probably will migrate beyond this artificial boundary due to the proposed logging and burning. They can even migrate on hikers’ shoes. How does the NNIS get carried into and out of an area that is opened up by road building, logging, and burning? Why is it supposed that the cumulative impact boundary is only the “project area?” From the DSFEIS, page 18: “The cumulative effects analysis area and the temporal scale for nonnative invasive plant species are the same as for other components of vegetation.” • The analysis area for blowdown is also the project area. When an area is opened up by logging, don’t microclimates and air flows change? And could that not lead to changes in areas outside the project area? Especially considering the cumulative effects of increased logging and burning on state, private, and Hoosier National Forest lands and other national forest. And what about the cumulative effects of blowdowns in combination with logging and burning? • Rare and sensitive plants From DSFEIS, page 18: “This analysis was limited to plant species either known to occur in the analysis area or known to have potential habitat in it. The effects of past activities were considered in the existing conditions and the environmental consequences.” • What is the incremental effect of logging and burning in the project area on the population of rare and sensitive plants on the Hoosier NF, in Indiana, in the region or in the country? Similar to the NNIS, how do seeds for these plants get carried into or out of a logged or burned area? If for example seeds are carried by birds, diminishing sensitive plants in the project area will also affect those areas into which the seeds might have been carried. Also, how will the birds who may have eaten and/or spread the seeds be affected? • Amphibians/reptiles: The DSFEIS tells us that amphibians and reptiles will suffer in the short-term, since they do not travel very far and may be negatively impacted by changes in their environment through logging and burning. How many of these will likely die? How will their deaths affect other wildlife who prey on them, or that they prey on? Ecologists tell us that if one part of the food web is altered, it may have drastic effects on the ecosystem. How will the deaths of these amphibians and reptiles affect the health of the ecosystem? How many will be left after 15 years to inhabit this new, superior, hardwood forest? • Indiana bat: The project area plus the 2 mile buffer for the cumulative effects on the Indiana bat is inadequate. The Forest Service knows this is an endangered species and that the species needs to be studied across their entire range in order to ensure survival and recovery. More information on the Indiana bat can be found in section 20. of these comments. • RFSS: The analysis area is the project area plus a 2 mile buffer. What was the rationale for this boundary? • Fisheries and Aquatics: The analysis area chosen is the HUC 6th level subwatersheds. This was chosen because supposedly sediment settles out before reaching larger streams. We address this above. Furthermore, the FEIS states that there may be effects from temperature changes. There is no analysis of how the sedimentation and the temperature changes might affect fish species and other aquatic species and how this may play out in the food chain. • Water quality and soils: The analysis area chosen is the subwatersheds. This was chosen because sediments supposedly settle before reaching larger streams. How will this sedimentation affect water quality in area wells, and springs? The FEIS states that water flow rates may increase. How will this increase and other increases in water flow from other logging in the area affect flooding? Click here for Standards and GuidelinesProtect Our Woods
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