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June 5, 2007: EXECUTIVE SUMMARY - Hoosier National Forest German Ridge Restoration Project Appeal of Record of Decision

(15) Cumulative Impacts With Regard to Bats Have Been Disregarded

With regard to bats, the German Ridge Final Environmental Impact Statement (FEIS) and Supplemental still fall short of considering cumulative impacts.

The Forest Service Manual requires every Environmental Impact Statement to identify and consider cumulative effects, and 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 cumulative analysis for bats is incomplete because it does not consider the following: 
  • Additional clearcuts called for by the Hoosier National Forest Plan.
  • Impacts from “treatments” on Mogan Ridge, Oriole Project and part of the Tell City Windthrow, which are close to the German Ridge project area. 
  • Changes in climate that could further diminish bat habitat.
  • Increased cuts on Indiana state forest.
  • Salvage of timber products in the event of natural catastrophes, such as insect and disease outbreaks, tornadoes, or wildfire.
  • Likely developments on private forest land.
  • Diminishing bat habitat in surrounding state and national forests.
  • A forest that is already greatly diminished and highly fragmented because of centuries of farming, logging, road-building, and development. Residential development encroaching on forested areas will only increase in the future. 

(16) Incomplete Cumulative Effects Analysis Regarding Birds

In the German Ridge Final Environmental Impact Statement 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.”

As a result of this determination the Forest Service provided a Supplemental Final Environmental Impact Statement. This was supposed to remedy the shortcomings identified in the decision by the appealing officer.

While the Final Supplemental Environmental Impact Statement and Response to Comment now have some wording justifying the cumulative effects boundaries that were chosen for German Ridge, the main purpose of establishing the boundaries, which is to actually analyse cumulative impacts resulting from other projects, is lacking.

The Forest Service is planning a number of projects close to the German Ridge project, including the Mogan Ridge, Oriole Project, Goosetown, and Tell City Windthrow projects.

The new map on p. 23 of the Draft Supplemental Environmental Impact Statement (same as p. 27 of Final Supplemental Environmental Impact Statement) only shows cumulative effects boundaries for the German Ridge project, not for the other projects close by. That means the map doesn’t identify potential areas of overlap, the first step in a cumulative effects analysis.  There is also no analysis in the text of what effects may result from possible overlaps of impact areas.

Therefore, it cannot be concluded from what the Forest Service has presented so far, what overlapping and mutually re-enforcing negative effects on either migratory or domestic birds may result from these different projects.

There is, in effect, no cumulative effects analysis on birds, except for the pine warbler. 

What is especially important, and missing in the Draft Environmental Impact Statement and Final Supplemental Environmental Impact Statement with regard to migratory birds, is the issue of forest fragmentation. See also (10).  The backdrop of the German Ridge project is a forest and a region that are already greatly diminished and highly fragmented because of centuries of farming, logging, road-building, and development.  What is the cumulative effect on fragmentation, and therefore on forest interior birds, of the German Ridge project and of all the other projects already in the works, planned or foreseeable?
  • The Hoosier National Forest Plan calls for extensive clearcutting that is not included in a cumulative effects analysis.
  • Additional “treatments” on Mogan Ridge, Oriole Project and part of the Tell City Windthrow project are mentioned, but not analysed.
  • Increased cuts and fragmentation on Indiana state forest are also ignored.
  • Likely developments on private forest are mentioned but not analysed in their cumulative effects on different birds.
  • Salvage logging is not considered.
  • Ignored are also actions taken in surrounding state and national forests that may add to fragmentation on a regional scale, and have effects on the survival of interior forest birds. 
  • Housing developments encroaching forested areas around the Hoosier National Forest also do not seem to weigh in when analysing cumulative effects on birds requiring large tracts of unfragmented forests.
The Forest Service tries not to touch the issue of fragmentation and instead insists on repeating over an over again that birds of all kinds will benefit from the restoration of native hardwoods. Pines are painted as fragmenting the forest. The Forest Service disregards that:
  • By cutting the pines, clearly the amount of edge habitat will increase, and this will negatively affect forest interior birds.
  • These negative effects will last for many years (how long will it take to establish forest cover that overcomes the negative effects of edge habitat for these birds?)
  • The negative effects from creating more edge habitat could have been avoided by letting the natural process unfold during which native forests are gradually taking over the pine plantations.
The purpose of  a cumulative impact analysis is therefore not accomplished, which is to show whether projects that happen in the vicinity, and/or over time, have impacts on birds that would not be detected if one would only look at the project area itself and the impacts resulting from that.

(17) Site Specific Information on Birds in the German Ridge Project Area Knowingly Withheld From the Public

Information we received from a Forest Service contracted biologist gives evidence that the Forest Service knowingly withheld site specific information from the public.

In an e-mail dated May 31st, 2007, from Dr. Donald Winslow to Mark Donham, we read:

                   Mark,

                    We have done a lot of bird counts in the Hoosier National Forest, both for
                    our own research on fragmentation and to help with the Forest Service's Long
                   Term Monitoring Points for breeding birds. In 2000, I supervised counts at
                    the 200 long term monitoring points, including 25 at German Ridge. Many of
                    the points in German Ridge are in pine plantations. The Forest Service
                   issues contracts for counts at these points every few years.

                    Let me know if you have any other questions.
                   Donald Winslow

Yet not one of the German Ridge Environmental Impact Statement documents contains information about the data collected by Dr. Winslow, which counter some of the assumptions underlying the Forest Service rationale for the German Ridge project.

Click here to continue to comment sections 18-21
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