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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 Forest27. RIPARIAN PROTECTIONS ARE INADEQUATEThe National Forest Management Act (NFMA) requires that streams, shorelines, lakes, wetlands and other bodies of water be protected. No management practices causing detrimental changes in water temperature or chemical composition, blockages of water courses, or deposits of sediment shall be permitted within these areas which seriously and adversely affect water conditions or fish habitat. Topography, vegetation type, soil, climatic conditions, management objectives, and other factors shall be considered in determining what management practices may be performed within these areas or the constraints to be placed upon their performance.The streams on the Hoosier are an important source of freshwater game and non-game fish, as well as crayfish and mussels. In fact, the Hoosier is included in an area that has been recognized for its outstanding diversity of aquatic life. However, this same diversity has been reduced because of farming, logging, sprawl, road building, and other disturbances. The initial draft of the freshwater fish paper for the illegal Hoosier-Shawnee Ecological Assessment had this to say about the need for filter strips. “The two forests should continue to maintain vegetative filter strips of varying widths adjacent to lakes, wetlands, perennial streams, and intermittent streams in which logging, road construction and recreational activities are strictly regulated to minimize any potential negative effects those practices might have on aquatic environments and their inhabitants.” Yet, this sentence was changed in the final, through the agency’s secret editing process. “Maintenance of vegetative filter strips of varying widths adjacent to lakes, wetlands, perennial streams, and intermittent streams in which logging, road construction and recreational activities occur will help minimize the potential effects those practices might have on aquatic environments and their inhabitants." The German Ridge FEIS states on p. 159:“Removal of vegetation by any of the action alternatives could adversely affect the hydrologic characteristicsand water quality in a watershed. Reducing vegetative cover could increase water yield and stream discharge. Major changes in vegetation cover could alter normal nutrient cycles in both terrestrial and aquatic systems. Use of roads and trails by heavy equipment during harvest operations could cause further soil erosion leading to sedimentation. Proper implementation of mitigation measures (such as minimized activity within riparian areas, limited instances of stream crossings, and use of erosion control structures on roads and landing sites) would limit the potential for adverse effects.” The German Ridge DSFEIS states on p. 42:“Any potential increase in sediment would be temporary. Though re-establishment of vegetation and soilstabilization is likely to occur within 2 years on a given site following disturbance, reducing sedimentation to levels prior to implementation while completing multiple timber sales and accompanying burning may not be achieved for up to 10 years. Therefore, the timeframe considered is 10 years, as any sediment produced would be undetectable at that point and effects would no longer be discernable.” The German Ridge DSFEIS states on p. 43:“If mitigation measures are implemented properly, effects to surface fines, fisheries, or aquatics from foreseeablefuture projects should not accumulate.” And: “Loss of soil, changes in riparian conditions, and reshaping of stream channels (resulting from historic land clearing and agricultural use) have led to cumulative alterations of natural stream habitats in the analysis area. Implementing Alternative A would have a positive cumulative effect, partly because it would treat some roads that are currently impairing riparian function. Past actions led to soil movement, but ongoing and reasonably foreseeable future actions are not likely to result in soil movement of any similar magnitude on NFS land. Tell City Windthrow, the burning that is still to take place as part of the Goosetown Salvage, and the projected harvesting on private land in the next 10 years have some potential to deliver sediment to watercourses, but the mitigation measures for Forest Service projects are expected to avoid accelerated erosion and sedimentation on NFS land.” The fact is that the plan guidelines for riparian zones do not strictly regulate logging, road construction, and burning, and herbicide use within riparian areas. While the DSFEIS does admit that these activities have the potential to have an adverse effect on aquatic resources, and admits that the plan will increase sediment and other impacts on the streams, it turns around and says that application of BMPs and mitigation will do away with these impacts. In fact, the “Hoosier-Shawnee Ecological Assessment ” says that there is some evidence that these activities are detrimental to the Hoosier’s aquatic community, (and mentions the heavily documented impacts of these types of activities on salmon populations out west) but that a comprehensive study has never been done to document it one way or the other on either the Hoosier or Shawnee. From the changing of the document, the failure to have strict enforceable standards and guidelines (for more details see Section 11. Standards and Guidelines) to protect riparian areas from logging, roadwork, herbicides, etc. shows that the Hoosier is not protecting the streams and other waterbodies as required by the NFMA regulations. It also calls into question how the Hoosier analyzed the relative value of water quality vs. the commercial value of the activities being allowed in riparian zones which could be provided elsewhere. The plan cannot insure the viability of fish, crayfish, or mussels, and the riparian standards and widths do not comply with NFMA. Click here for Part 28a. Soil Analysis Is Incomplete – Soils Could Be Harmed Permanently (Part 1 of 3)Protect Our Woods
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