references - a123.g.akamai.neta123.g.akamai.net › 7 › 123 › 11558 › abc123 ›...

Cowlitz Valley Ranger District

180

References ABR, Inc. 2009. Radar Surveys for Marbled Murrelets in Mt. Rainier National Park,

Washington, 2009. Unpub. Report prepared for Mt. Rainier National Park, Ashford,

Washington, by ABR, Inc., Forest Grove, OR. 17 pp.

Aguilar, A.M. 2013. Forest Plan Soils Guidelines Regarding Mechanical Harvesters on Gifford

Pinchot National Forest (Draft White Paper). Gifford Pinchot National Forest, Vancouver,

WA.

Akins, Jocelyn. 2009. Cascades Carnivore Project, Forest Carnivore Monitoring on the Gifford

Pinchot National Forest: Year 1 and 2 Progress Report. Unpublished Report prepared for

Washington Department of Fish and Wildlife and Gifford Pinchot National Forest. 21 pp.

Altman, B. and J. Alexander. 2008. Habitat conservation plan for landbirds in the coniferous

forests of western Washington and Oregon. Oregon-Washington Partners in Flight.

www.orwapif.org

Aubry et al, 2011. Wolverine Distribution and Ecology in the North Cascades Ecosystem 2011

Annual Report.

Aubry, K.B., C.M. Senger, R.L. Crawford. 1987. Discovery of Larch Mountain Salamanders

Plethodon larsilli in the Central Cascade Range of Washington. Biological Conservation 42:

147-152.

Banci, V. 1994. Wolverine. Pages 99-127 in L.F. Ruggiero, K.B. Aubry, S.W. Buskirk, L.J.

Lyon, and W.J. Zielinski, tech. eds. The scientific basis for conserving forest carnivores: American marten, fisher, lynx and wolverine in the western United States. USDA

Forest Service. General Technical Report RM-254, Fort Collins, CO.

Beechie, T.J.; Pess G.; Kennard P.; Bilby R.E.; Bolton S. 2000. Modeling Recovery Rates and

Pathways for Woody Debris Recruitment in Northwestern Washington Streams. North

American Journal of Fisheries Management 20:436–452.

Bilby, R.E., Sullivan, K., Duncan, S.H., 1989, The generation and fate of road-surface sediment

in forested watersheds in southwestern Washington: Forest Science, v. 35, p. 453-468.

Bjornn, T.C.; Reiser, D.W.. 1991. “Habitat requirements of salmonids in streams.” In: Meehan,

W.R.. Influences of forest and rangeland management of salmonid fishes and their habitats.

Bethesda, MD: American Fisheries Society: 83-138.

Boyd, Diane. 1999. Carnivores-wolves, Chapter 7 in G. Joslin and H. Youmans, coords., Effects

of recreation on Rocky Mountain wildlife: a review for Montana. Committee on effects of

recreation on wildlife, Montana Chapter of The Wildlife Society. 307pp.

Brockway, D., Topik, C., Hemstrom, M., Emmingham, W.H., 1983. Plant Association and

Management Guide for the Pacific Silver Fir Zone. Gifford Pinchot National Forest, USDA

Forest Service, R6-Ecol-130a-1983. Portland, OR.

Brosofske, Kimberly D.; Chen, Jiquan, Naiman, Robert J., and Franklin, Jerry F. 1997.

Harvesting Effects on Microclimate Gradients From Small Streams to Uplands in Western

Washington. Ecological Applications. 7:1188-1200.

http://www.orwapif.org/

Niqually Thin EA/FONSI

181

Brown, G. W. 1985. Landslide Damage to the Forest Environment. In: Swanston, Doug ed.

Proceedings of a Workshop on Slope Stability: Problems and Solutions in Forest

Management. U.S. Department of Agriculture, Forest Service, Pacific Northwest Forest and

Range Experiment Station, Government Technical Report PNW-180.

Busskohl, C. B. 2009. Email Comm. Forest Soils Scientist. Umatilla National Forest. 2517 S.W.

Hailey Avenue, Pendleton, Oregon 97801.

Carroll, C., M.K. Phillips, N.H. Schumaker, and D.W. Smith. 2003. Impacts of landscape change

on wolf restoration: a reintroduction program based on static and dynamic spatial models.

Conservation Biology 17(2):536-548.

Chan, S.S.; Larsen D.J.; Maas-Hebner K.G.; Emmingham W.H.; Johnston S.R.; Mikowski D.A.

2006. Overstory and understory development in thinned and underplanted Oregon Coast

Range Douglas-fir stands. Canadian Journal of Forest Resources 36: 2696-2711.

Comfort, E.J.; Roberts, S.D.; Harrington C.A.; Davis, L. R. 2010. Midcanopy growth following

thinning in young-growth conifer forests on the Olympic Peninsula western Washington.

Forest Ecology and Management 259: 1606-1614.

Crandell, D. R. 1971. Postglacial lahars from Mount Rainier Volcano, Washington. U.S.

Geological Survey Professional Paper , 677, 75 p. Available:

http://pubs.er.usgs.gov/publication/pp677. [July 2, 2013]

Current Vegetation Survey (CVS), Random Grid Surveys. Data available at

www.or.blm.gov/surveyandmanage .

Curtis, Robert O. 1982. A Simple Index of Stand Density for Douglas-fir. Forest Science. Vol.

28, No. 1, pp 92-94.

Davis, L.R., Puettmann K. J.; Tucker, G.F. 2007. Overstory response to alternative thinning

treatments in young Douglas-fir forests of western Oregon. Northwest Science. 81(1):1-14.

Delaney, D.K., and T.G. Grubb. 2003. Effects of off-highway vehicles on northern spotted owls:

2002 results. A report to the State of California Department of Parks and Recreation, Off-

Highway Motor Vehicle Recreation Division under Contract No. 439129-0-0055. USDA

Forest Service Rocky Mountain Research Station. May 2003. 38 pages.

Delaney, D.K., T.G. Grubb, P. Beier, L.L. Pater, and M.H. Reiser. 1999. Effects of helicopter

noise on Mexican spotted owls. Journal of Wildlife Management 63:60-76.

Dixon, G. E. 2002. Essential FVS: A User’s Guide to the Forest Vegetation Simulator. Internal

Rep. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Forest Management

Service Center. 219 p.

Dobkin, D. S. 1994. Conservation and management of Neotropical migrant landbirds in the

northern Rockies and Great Plains. University of Idaho Press, Moscow, ID.

Dugger, K.M., R.G. Anthony, and L.S. Andrews. 2011. Transient dynamics of invasive

competition: barred owls, spotted owls, habitat, and the demons of competition present.

Ecological Applications 21(7) pp. 2459-2468.


182

Evans Mack, D., W. P. Ritchie, S. K. Nelson, E. Kuo-Harrison, P. Harrison, and T. E. Hamer.

2003. Methods for surveying Marbled Murrelets in forests: a revised protocol for land

management and research. Pacific Seabird Group Technical Publication Number 2. Available

from http://www.pacificseabirdgroup.org. 81 pp.

Foltz, R.B., Copeland, N.S., and Elliot, W.J. 2009. “Reopening abandoned forest roads in

northern Idaho, USA: Quantification of runoff, sediment concentration, infiltration, and

interrill erosion parameters.” Journal of Environmental Management: pp 2542-2550.

Food and Agriculture Organization of the United Nations (FAO). 2007. Roles of forests in climate

change. Available at www.fao.org/forestry/site/climatechange/en .

Forsman, E.D., R.G. Anthony, J.A. Reid, P.J. Loschl, S.G. Sovern, M. Taylor, B.L. Biswell, A.

Ellingson, E.C. Meslow, G.S. Miller, K.A. Swindle, J.A. Thrailkill, F.F. Wagner, and D. E.

Seaman. 2002. Natal and breeding dispersal of northern spotted owls. Wildlife Monographs

149:1-35.

Forsman, Eric D.; Meslow, E. Charles; Wight, Howard M. 1984. Distribution and biology of the

spotted owl in Oregon. Wildlife Monographs No. 87. Bethesda, MD: The Wildlife Society

Franklin, J.F. and C.T. Dyrness. 1973. Natural Vegetation of Oregon and Washington. USDA FS

General Technical Report PNW-8. Pacific Northwest Forest Range Experimental Station,

Portland, OR. 417pp.

Franklin, J.F.; Moir W. H.; Hemstrom, M.A.;Greene, S.E.; Smith, B.G. 1988. The Forest

Communities of Mount Rainier National Park. U.S. Department of Interior, National Park

Service.

Froehlich, H. A.; Miles, D. W. R.; Robbins, R. W. 1985. Soil bulk density recovery on compacted

skid trails in central Idaho. Soil Science Society of America Journal. 49:1015-1017.

Garland, J.J. 1997. Designated Skid Trails Minimize Soil Compaction. The Woodland Workbook,

EC 1110. Oregon State Univ. Extension Service.

Garman, S.L.; Cissel J.H.; Mayo J.H. 2003. Accelerating Development of Late-Successional

Conditions in Young Managed Douglas-Fir Stands: A Simulation Study. General Technical

Report PNW-GTR-557.

GEOBOB database. 2006. GEOBOB database replaced the ISMS database in 2005.Interagency

Special Status/Sensitive Species Program (ISSSSP). 2007. Species Fact sheet for Peltigera

pacifica. http://www.fs.fed.us/r6/sfpnw/issssp/species-index/flora-lichens.shtml

Gomez, D.M., R.G. Anthony, and J.P. Hayes. 2005. Influence of thinning of Douglas-fir forests

on population parameters and diet of northern flying squirrels. Journal of Wildlife

Management 69(4):1670-1682.

Haggerty, S. 2008. Pers. Comm. Forest Soil Scientist. Olympic National Forest. 295142 Highway

101 S., Quilcene, Washington 98376.

Hamer, T.E., and S.K. Nelson. 1995. Characteristics of marbled murrelet nest trees and nesting

stands. Pages 69-82 in C.J. Ralph et al. (Tech. eds.). Ecology and conservation of the marbled

http://www.pacificseabirdgroup.org/

http://www.fao.org/forestry/site/climatechange/en

http://www.fs.fed.us/r6/sfpnw/issssp/species-index/flora-lichens.shtml


183

murrelet. United States Department. Of Agriculture Forest Service Pacific Southwest General

Techincal Report -152. Albany, CA.

Hamer, Thomas and S. Kim Nelson. 1998. Effects of disturbance on Nesting Marbled Murrelets:

Summary of Preliminary Results. Prepared for Paul Henson, US Fish and Wildlife Service,

Portland, Oregon. January 1998. 24 pp.

Hanson, E., D. Hays, L.L. Hicks, L. Young, and J.R Buchanan. 1993. Spotted owl habitat I

Washington: A report to the Washington Forest Practices Board. Washington Forest Practices

Board Spotted Owl Scientific Advisory Group, Olympia, W A, December 20, 1993.

Herrington, R.E. and J.H. Larson. 1985. Current status, habitat requirements and management of

the Larch Mountain Salamander Plethodon larsilli (Burns). Biological Conservation 34: 169-

179.

Hicks, L.L., H.C. Stabins, and D.R. Herter. 1999. Designing spotted owl habitat in a managed

forest. Journal of Forestry, July 1999. pp. 20-25.

Hoblitt, R.P., Walder, J.S., Driedger, C.L., Scott, K.M., Pringle, P.T., and Vallance, J.W. 1995.

Volcano Hazards from Mount Rainier, Washington. U.S. Geological Survey.

Littell, J.S., M. McGuire Elsner, L.C. Whitely Binder, and A.K. Snover(eds). 2009. The

Washington Climate Change Impacts Assessment: Evaluating Washington’s Future in a

Changing Climate – Executive Summary. In The Washington Climate Change Impacts

Assessment: Evaluating Washington’s Future in a Changing Climate, Climate Impacts Group,

University of Washington, Seattle, WA. Available at:

www.cses.washington.edu/db/pdf/wacciaexecsummary638.pdf

Livezy, K.B. 2007. Barred Owl Habitat & Prey: A Review and Synthesis of the Literature.

Journal of Raptor Research, Vol. 4, No. 3.

Mahoney, R. 1992. Silvicultural Decisions II: Mechanized vs. Conventional Logging. UI

Extension Forestry Information Series I, FM12. [online]. Available:

http://www.uidaho.edu/extension/forestry/content/products/harvesting. [July 1, 2013].

Mech, L. David and Luigi Boitani. 2003. Wolves: behavior, ecology, and conservation.

University of Chicago Press, 448pp.

Mech, L.D. 2000. Leadership in wolf, Canis lupus, packs. Canadian Field-Naturalist 114(2):259-

263.

Mieman, S., R. Anthony, E. Glenn, T. Bayless, A. Ellingson, M.C. Hansen, and C. Smith. 2003.

Effects of commericial thinning on home-range and habitat-use patterns of a male northern

spotted owl: a case study. Wildlife Society Bulletin 2003, 31(4):1254-1262.

Millar, C., N.L. Stephenson, S.L. Stephens. 2007. Climate change and forests of the future:

Managing in the face of uncertainty. Ecological Applications 17(8): 2145-2151.

Miller, G.S. 1989. Dispersal of juvenile spotted owls in western Oregon. M.S. Thesis. Oregon

State University, Corvallis, Oregon.

http://www.cses.washington.edu/db/pdf/wacciaexecsummary638.pdf

http://www.uidaho.edu/extension/forestry/content/products/harvesting


184

Napper, C.; Page-Dumroese, D.; Howes, S. 2009. Soil-Disturbance Field Guide. 0819 1815P. San

Dimas, CA: U.S. Department of Agriculture, Forest Service, San Dimas Technology and

Development Center. 112 p.

Oakleaf, J.K., D.L. Murray, J.R. Oakleaf (and others), 2006. Habitat selection by recolonizing

wolves in the northern Rocky Mountains of the United States. J. Wildl. Manage. 70(2):554-

563.

Oliver, Chad and Bruce Larson. 1996. Forest Stand Dynamics. McGraw-Hill Inc. NY, NY.

Olson, D.H.; Chan S.S. 2004. Riparian buffer widths and thinning: effects on headwater

microclimates and aquatic dependent vertebrates. Northwestern Naturalist 85:84.

Olson, D.H.; Rugger, C. 2007. Preliminary study of the effects of headwater riparian reserves

with upslope thinning on stream habitats and amphibians in western Oregon. Forest Science.

53(2): 331-342.

Oregon Department of Agriculture Plant Division, Noxious Weed Control, Scotch Broom. Web

site accessed 2/8/2010. http://oregon.gov/ODA/PLANT/WEEDS/profile_scotchbroom.shtml.

Pearson, R.R., and K.B. Livezey. 2003. Distribution, numbers, and site characteristics of spotted

owls and barred owls in the Cascade Mountains of Washington. Journal of Raptor Research.

37: 265-276.

Peterson, A. 2008. Gravel inspection, history and standards. In Proceedings, 2008 Weeds across

borders conference, eds. Darbyshire and Prasad, available at

https://www.invasiveplants.ab.ca/WABProceedings/Acrobatfiles/WAB2008Complete.pdf#pa

ge=133.

Peterson, James, J. Dunham, P. Howell, S. Bonar, and R. Thurow, 2000. Interim Protocol for

Determining Bull Trout Presence. (Draft Copy).

Pollock, Michael M., Beechie, Timothy J., Liermann, Martin, and Bigley, Richard E., 2009.

Stream Temperature Relationships to Forest Harvest in Western Washington. Journal of the

American Water Resources Association.

Raley, Catherine M., and Keith B. Aubry. 2006b. Density of potential foraging structures and

pileated woodpecker foraging activity on Sun Pass State Forest, Oregon. Update to Final

Report. U.S. Forest Service, Pacific Northwest Research Station, Olympia, WA. 12 pp.

Ralph, C.J., G.L. Hunt, Jr., M.G. Raphael, and J.F. Piatt. 1995. Ecology and conservation of the

marbled murrelet in North America: an Overview. Pages 3-22 in C.J. Ralph, G.L. Hunt, M.G.

Raphael, and J.F. Piatt (eds.). Ecology and conservation of the marbled murrelet. General

Technical Report. PSW-GTW-152. Pacific Southwest Experimental Station, U.S. Forest

Service, Albany, California. 420 pp.

Rich, T. D., C. J. Beardmore, H. Berlanga, P. J. Blancher, M. S. W. Bradstreet, G. S. Butcher, D.

W. Demarest, E. H. Dunn, W. C. Hunter, E. E. Iñigo-Elias, J. A. Kennedy, A. M. Martell, A.

O. Panjabi, D. N. Pashley, K. V. Rosenberg, C. M. Rustay, J. S. Wendt, T. C. Will. 2004.

Partners in Flight North American Landbird Conservation Plan. Cornell Lab of Ornithology.

Ithaca, NY.

http://oregon.gov/ODA/PLANT/WEEDS/profile_scotchbroom.shtml

https://www.invasiveplants.ab.ca/WABProceedings/Acrobatfiles/WAB2008Complete.pdf#page=133

https://www.invasiveplants.ab.ca/WABProceedings/Acrobatfiles/WAB2008Complete.pdf#page=133


185

Roberts, S.D.; Harrington C.A. 2008. Individual tree growth response to variable-density thinning

in coastal Pacific Northwest forests.

Saab, V.A., R.E. Russell, and J.G. Dudley. 2009. Nest-site selection by cavity-nesting birds in

relation to postfire salvage logging. Forest Ecology and Management 257:151-159.

Senderak, K. 2013. Nisqually Timber Sale Silviculture Resource Report. Zone Silviculturist.

Gifford Pinchot National Forest, Cowlitz Valley Ranger District, Randle, Washington.

Sidle, R. C. 1985. Factors Influencing the Stability of Slopes. In: Swanston, Doug ed.

Proceedings of a Workshop on Slope Stability: Problems and Solutions in Forest

Management. UDA Forest Service, Pacific Northwest Forest and Range Experiment Station,

GTR PNW-180.

Singleton, P.H., J.K. Lehmkuhl, W.L. Gaines, S.A. Graham. 2010. Barred Owl Use and Habitat

Selection in Eastern Cascades, Washington. Journal of Wildlife Management 74(2): 285-294.

Sutherland, S., and C. Nelson. 2010. Nonnative plant response to silvicultural treatments: a

model based on disturbance, propagules pressure, and competitive abilities. Western Journal

of Applied Forestry. 25(1) 27-33.

Swanston, D. N. 1974. Slope Stability Problems Associated with Timber Harvesting in

Mountainous Regions of the Western United States. USDA Forest Service, Pacific Northwest

Forest and Range Experiment Station, Government Technical Report PNW-21.

Tappeiner, J.C.; Huffman, D.; Marshall D.; Spies T.A.; Bailey J.D. 1997. Density, ages, and

growth rates in old-growth and young-growth forests in coastal Oregon. Can. J. For. Res.

27:638-648.

Taylor, K., J. Mangold, L. Rew. 2011. Weed species dispersal by vehicles. Montana State

Univesity Extension. Available at

http://weedeco.msu.montana.edu/publications/agricultural.html.

Thomas, J.W., D.A. Leckenby, M. Henjum, R.J. Pederson, L.D. Bryant. 1988. Habitat

effectiveness index on Blue Mountain winter ranges. USFS. General Technical Report PNW-

GTR-218. 28 pp.

Thomas, J.W., E.D. Forsman, J.B. Lint, E.C. Meslow, B.R. Noon, and J. Verner. 1990. A

conservation strategy for the northern spotted owl; report of the interagency Scientific

Committee to address the conservation of the northern spotted owl. U.S. Department of the

Interior, Bureau of Land Management, Fish and Wildlife Service, and National Park Service,

Portland, Oregon, May 1990. 427 pp.

Thomas, J.W., H. Black, R.J. Scherzinger, R.J. Pederson. 1979. Deer and Elk. In J.W. Thomas,

ed. Wildlife habitats in managed forests: The Blue Mountains of Oregon and Washington.

Handbook 533. USDA. Portland, OR. 512 pp.

Thomas, J.W.; Raphael, M.G.; Anthony, R.G.; Forsman, E.D.; Gunderson, A.G.; Holthausen,

R.S.; Marcot, B.G.; Reeves, G.H.; Sedell, J.R.; Solis, D.M. 1993. Viability assessments and

management considerations for species associated with late-successional and old-growth

forests of the Pacific Northwest. USDA Forest Service, Washington, DC: 530 p.


186

Topik, C., Halverson, N.M., Brockway, D.G., 1986. Plant Association and Management Guide for

the Western Hemlock Zone. Gifford Pinchot National Forest, USDA Forest Service, Pacific

Northwest Region, R6-ECOL-230A-1986. Portland, OR.

Urgenson, L. 2006. The ecological consequences of knotweed invasion into riparian forests.

Unpublished thesis, University of Washington.

U.S. Department of Commerce. 2012. Bureau of Economic Analysis, Regional Economic

Information System, Washington, D.C. Tables CA05N, CA25N;

U.S. Department of Commerce. 2013. Census Bureau, County Business Patterns, Washington,

D.C.

US Environmental Protection Agency. 2007. Climate Change – Health and Environmental Effects

– Forests [online]. Available: http://www.epa.gov/climatechange/effects/forests.html#tree.

[November 8, 2012]

US Fish and Wildlife Service. 1997. Recovery Plan for the Threatened Marbled Murrelet

(Brachyramphus marmoratus) in Washington, Oregon, and California. Portland, Oregon. 203

pp.

US Fish and Wildlife Service. 2007. National Bald Eagle Management Guidelines. U.S. Fish and

Wildlife Service (USFWS), Arlington, VA. 24 pp.

US Fish and Wildlife Service. 2011. Revised Recovery Plan for the Northern Spotted Owl (Strix

occidentalis caurina). U.S. Fish and Wildlife Service, Portland, Oregon. xvi +258 pp.

USDA Forest Service 1971. Soil Resource Inventory. Gifford Pinchot National Forest. Pacific

Northwest Region. Vancouver, WA.

USDA Forest Service and USDI Bureau of Land Management, 1994. Record of Decision for

Amendments to Forest Service and Bureau of Land Management Planning Documents Within

the Range of the Northern Spotted Owl and Standard and Guidelines for Management of

Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of

the Northern Spotted Owl. Pacific Northwest Region. Portland, OR.

USDA Forest Service. 1990. Land and Resource Management Plan. Gifford Pinchot National

Forest. Pacific Northwest Region, Vancouver, WA.

USDA Forest Service. 1998. Forest Service Manual, Chapter 2520, R-6 Supplement No.

2500.98-1. Pacific Northwest Region. Portland, OR.

USDA Forest Service. 1999. Nisqually Watershed Analysis. Cowlitz Valley Ranger District,

Randle, WA.

USDA Forest Service. 1999. Unpublished GIS layer. Geologic hazards (gpghz). Gifford Pinchot

National Forest. Vancouver, WA.

USDA Forest Service. 1999b. Landtype Association (gplta). Gifford Pinchot National Forest.

Vancouver, WA.

http://www.epa.gov/climatechange/effects/forests.html#tree


187

USDA Forest Service. 1999c. Potential natural vegetation zones (gppvg). [online]. Available:

http://www.fs.fed.us/r6/data-library/gis/gifford-pinchot/. [July 1, 2013]. Gifford Pinchot

National Forest.

USDA Forest Service. 2001. Wind River Watershed Analysis. 2nd

Iteration. Gifford Pinchot


USDA Forest Service. 2004c. Likelihood of Occurrence Key.

http://www.fs.fed.us/r6/sfpnw/issssp/planning-tools/

USDA Forest Service. 2005. Invasive Plant Program: Preventing and Managing Invasive Plants,

Final Environmental Impact Statement Record of Decision. Pacific Northwest Region. R6-

NR-FHP-PR-02-05 Portland, OR. Available at http://www.fs.fed.us/r6/invasiveplant-eis/

USDA Forest Service. 2008. Record of decision and final environmental impact statement and

forest plan amendment #20, Gifford Pinchot National Forest and Columbia River Gorge

National Scenic Area (Washington portion): site-specific invasive plant treatment project and

forest plan amendment. Pacific Northwest Region. Available at

http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/GIP/.

USDA Forest Service. GUIDE TO NOXIOUS WEED PREVENTION PRACTICES, Version 1.0,

Dated July 5, 2001, available at http://www.fs.fed.us/invasivespecies/prevention/index.shtml

USDA Natural Resources Conservation Service. 1997. Introduction to Microbiotic Crusts. Soil

Quality Institute; Grazing Lands Technology Institute.

USDA, Forest Service. 2001b. Bull Trout Survey (unpublished report). Gifford Pinchot National

Forest. Vancouver, Washington.

U.S. Geological Survey, Gap Analysis Program. 2012. Protected Areas Database of the United

States (PADUS) version 1.3. Rasker, R. 2006. "An Exploration Into the Economic Impact of

Industrial Development Versus Conservation on Western Public Lands." Society and Natural

Resources. 19(3): 191-207; U.S. Department of Commerce. 2009. Census Bureau,

Governments Division, Washington, D.C.; U.S. Department of Interior. 2009. Payments in

Lieu of Taxes (PILT), Washington D.C.; U.S. Department of Agriculture. 2009. Forest

Service, Washington, D.C.; U.S. Department of Interior. 2009. Bureau of Land Management,

Washington, D.C.; U.S. Department of Interior. 2007. U.S. Fish and Wildlife Service,

Washington, D.C.; U.S. Department of Interior. 2012. Office of Natural Resources Revenue.

Washington, D.C.; Additional sources and methods available at

www.headwaterseconomics.org/eps-hdt.

Von der Lippe, M., and I. Kowarik. 2008. Long distance dispersal of plants as a driver of plant

invasions. Conservation Biology 21(4): 986-996.

WA State Noxious Weed Control Board. 2006. Written findings: Class B-designate weed: herb

Robert. http://www.nwcb.wa.gov/weed_info/Written_findings/Geranium _robertianum.html.

Accessed 2/9/2007.

Wade, J.; Herman, L.; High, C. T.; Couche, D. 1992. Soil Resource Inventory. Gifford Pinchot


http://www.fs.fed.us/r6/data-library/gis/gifford-pinchot/

http://www.fs.fed.us/r6/sfpnw/issssp/planning-tools/

http://www.fs.fed.us/r6/invasiveplant-eis/

http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/GIP/

http://www.fs.fed.us/invasivespecies/prevention/index.shtml

http://www.nwcb.wa.gov/weed_info/Written_findings/Geranium%20_robertianum.html.%20Accessed%202/9/2007

http://www.nwcb.wa.gov/weed_info/Written_findings/Geranium%20_robertianum.html.%20Accessed%202/9/2007


188

Wade, J.; High, C. T. 1992b. NEPA Assistance for the Soil Resource. Gifford Pinchot National

Forest. Vancouver, WA.

Washington Department of Fish and Wildlife. 2002. North Rainier Elk Herd Plan. Wildlife

Program, Washington Dept. of Fish and Wildlife, Olympia. 63pp.

Weins, J.D. 2012. Competitive interactions and resource partitioning between northern spotted

owls and barred owls in western Oregon. Dissertation submitted to Oregon State University,

Corvalis, OR. 156 pp.

Williams, R.E.; Shaw, III, E.G.; Wargo, P.M.; Sites, W.H. 1986. Armillaria Root Disease. Forest

Insect and Pest Leaflet 78, USDA Forest Service.

Wilson, Todd M.; Forsman, Eric D. 2013. Thinning effects on spotted owl prey and other forest-

dwelling small mammals. In: Anderson, Paul D.; Ronnenberg, Kathryn L., eds. Density

management for the 21st Century: west side story. Gen.Tech. Rep. PNW-GTR-880. Portland,

OR: USDA Forest Service, Pacific Northwest Research Station: 79–90.

Zielinski, W. J., K. M. Slauson, C. R. Carroll, C. J. Kent, and D. G. Kudma. 2001. Status of

American martens in coastal forests of the Pacific states. Journal of Mammalogy 82:478-490.

Zika, P., and A. Jacobson. 2003. An overlooked hybrid Japanese knotweed (Polygonum

cuspidatum x sachalinense; Polygonaceae) in North America. Rhodora 105 (922): 143-152.


189

Appendix A: Issues Raised During Scoping

Scoping Comment Received Interdisciplinary Team Response Theme

Treat hazard trees along haul routes The Forest Service cannot require a timber purchaser to treat hazard

trees besides those that pose an imminent threat to thinning

operations and haul.

Roads

Use temporary and spur roads to make timber harvest

economical

The interdisciplinary team is seeking access management solutions

for efficient harvest of timber while still minimizing the extent of new

disturbance in the project area.

Roads

Do not decommission any roads Currently the Forest Service is unable to fully fund the maintenance

of all existing roads on the Forest. Lack of road maintenance poses

environmental and safety risks. It is important to address these

issues through decommissioning or closure and stabilization, where

appropriate, such as where future management activities are not

expected to occur. The line officer has asked the team to consider

only closure and stabilization, not decommissioning, based on public

and interdisciplinary input. A preliminary list of road to propose for

closure is being derived from a variety of criteria based on known

future management needs, aquatic and terrestrial risk posed by the

road, and feasibility to analyze within the scope of this project.

Roads

Create 1-3 acre openings in stands to stimulate early

seral habitat for wildlife/big game; explore “linear

meadow” and Franklin/Johnson Moist Forest Strategy

The Nisqually Thin project area does not contain suitable conditions

to create early-seral openings, given that the area is predominantly in

the LSR land allocation. In addition, adjacent state and private lands

currently offer ample opportunity for big game forage, as they are

generally in an earlier state of forest regeneration along much of the

FS boundary.

Thinning prescription /

Wildlife

Consider winter logging/ easing timing restrictions to Winter closures and timing restrictions will be required for this project

to limit disturbance to endangered species (northern spotted owl,

Economics / Timing


190


make for a more economical thinning project marbled murrelet) and other wildlife, in addition to preventing damage

to soil and water resources during the wet season, as required by

law. Economics are only one facet of the purpose and need of the

project, and a variety of resource concerns must be considered in

implementation.

restrictions

Use smaller (25-50 ft) no-cut buffers in riparian zones

to increase harvest volume and improve riparian

structure

The thinning prescriptions proposed are consistent with direction

provided in the NWFP and Forest Plan for Late Successional

Reserve and Matrix, are consistent with the National Forest

Management Act, and are based on a synthesis of established

silvicultural science. Timber production for economic benefit is only

one goal of the Nisqually Thin project; ultimately the purpose in LSR

is to help stands develop more quickly into “old growth” stands.

Riparian Buffers /

Economics / Thinning

prescription

Thin more heavily overall than what is in proposed

action








Thinning prescription/

Economics

Close roads (but do not decommission) Currently the Forest Service is unable to fully fund the maintenance









Roads


191




Look for as many opportunities to decommission roads

as possible

Currently the Forest Service is unable to fully fund the maintenance











Roads

Supportive of pre-commercial thinning to improve

health and vigor of younger stands

Pre-commercial treatments will be included in the proposed action Thinning prescription

Supportive of variable density prescription, gaps and

skips, in LSR. Supportive of timber-production oriented

prescription in Matrix. Supportive of leaving quality

down wood and snags in all units.








Thinning prescription

Consider closure of trails that receive little use in

project area (Cave Creek #225, Big Creek trail #252

from #251 to Rd 8440 and redesignate remaining

portion of #252 as part of #251, Greenwood Lake

#253, Allen Mountain #269)

The team developed a purpose and need that focused around

thinning and restoration treatments to achieve primarily ecological

objectives. Specific resource concerns were not cited in this

comment.

Recreation


192


Consider improvements to certain trails (#251 trailhead

on FR 8410, trailhead for Cora Lake on FR 8420).

The IDT and line officer see the value of making recreation

improvements in the area of the Nisqually Thin proposal. However,

we felt that these types of projects are somewhat outside the scope

of the goals of this project and would not be practical to analyze.

Recreation

Evaluate safety , access, and use of High Rock

Lookout

The IDT and line officer see the value of making recreation

improvements in the area of the Nisqually Thin proposal. However,

we felt that these types of projects are somewhat outside the scope

of the goals of this project and would not be practical to analyze.

Recreation/Heritage

Revisit watershed prioritization process and evaluate

all needed watershed restoration work for this project

area

The watershed analysis from 2002 is a key reference tool the team is

using to build a list of potential restoration projects. “All” restoration

work needed in this project area cannot not be surveyed and

analyzed for practical reasons, but the team is seeking a suite of

projects that would balance various resource objectives and

restoration concerns.

Restoration

Close/Stabilize and Decommission more roads Currently the Forest Service is unable to fully fund the maintenance







and interdisciplinary input. A preliminary list of roads to propose for


future management /access needs, aquatic and terrestrial risk posed

by the road, and feasibility to analyze within the scope of this project.

Roads

Evaluate selection/creating gaps around potential

marbled murrelet nest trees; fully evaluate impacts to

Marbled murrelet is an important wildlife concern in the Nisqually Thin

area, and effects on the murrelet will be evaluated.

Wildlife/Endangered Species

Act


193


murrelet

Thoroughly evaluate thinning effects on Northern

Spotted Owl and Critical Habitat, and potential

interaction with Barred Owl

NSO, critical habitat, and barred owl interactions will all be

considered through this analysis process.

Wildlife/Endangered Species

Act

Use Variable Density Thinning framework for stand

prescriptions in LSR and Matrix; use skips and gaps,

retain down wood and snags, etc.

The thinning prescriptions proposed will be consistent with direction







Thinning prescription

Do not thin in Riparian Reserves unless treatments will

benefit aquatic and riparian resources








Aquatic/thinning prescription

Minimize construction of temp roads The interdisciplinary team is seeking access management solutions

for efficient harvest of timber while still minimizing the extent of new

disturbance in the project area.

Roads

Seriously consider climate change in project analysis;

especially re: increased stream temps and earlier peak

flows effect on fish; how to create a more resilient

ecosystem with this project; disclose effects of natural

disturbance versus harvest regarding release of

The analysis will not attempt to quantify carbon emissions or

sequestration. However, the proposal will seek to create resilience in

forest and riparian ecosystems to a variety of climatic conditions and

potential future scenarios.

Climate change


194


carbon

Evaluate cumulative effects. Cumulative effects of the proposed action will be evaluated at the

appropriate temporal and spatial scales for the resources analyzed.

NEPA/Cumulative effects

Evaluate an adequate range of alternatives The IDT is discussing the need for additional alternatives. NEPA/Alternatives

Eliminate all harvest within 0.7 miles of historic or

existing Northern Spotted Owl site centers to

ameliorate potential adverse impacts to NSO

NSO, critical habitat, and barred owl interactions will all be

considered through this analysis process. Harvest buffers/restrictions

based on NSO sites will be evaluated and consulted with FWS, and

will rely on the best available science.

ESA/Wildlife

Consider an alternative that eliminates construction of

temporary roads entirely, or at least removes units 1,

29, and 34 from the unit pool due to high percentage of

temp roads within.

The team is investigating ways to minimize new temporary road

construction wherever possible. After discussing this comment, the

team reviewed units 1, 29, and 34 and others to identify possible

ways to reduce the need to use temporary roads to accomplish the

purpose and need.

Roads

Establish a minimum 75-ft buffer between 52 road and

unit boundary to mitigate visual impacts

This suggestion will be included as design criteria to protect visual

quality.

Recreation/Visual

Creation/preservation of snags and down wood should

only be in Purpose and Need if there is certainty that

these activities will occur – since these activities are

dependent on uncertain funding, they should not be

displayed as a positive benefit or mitigation for sale-

related impacts

The planning and NEPA for any project does not ensure its

implementation on the ground, given the vagaries of federal

appropriations and how and which operations on the National Forest

are funded every year. It is reasonable to expect that creation of

snags and down wood will occur as proposed, based on the

expectation that timber harvest in the Nisqually Thin area would be

As of this writing, snags and down wood are not being viewed a

“mitigation” for sale-related impacts, but as a separate component of

the proposed action.

Proposed Action / Effects

analysis


195


EA should include consideration and protection of

species and habitat occurrences in nearby area (same

townships), as mapped by Washington Dept of Fish

and Wildlife, particularly for elk forage

The wildlife analysis will include the best data available at the scale

relevant to the species for which we manage. If other agency data is

available and relevant, we will do our best to integrate it into the

analysis.

Wildlife data / analysis

Encourages practices that will maintain habitat and set

forest stands on a trajectory toward contributing to

NSO and marbled murrelet habitat where possible and

appropriate

A majority of the vegetation prescription must be consistent with

developing late-successional characteristics given that much of the

project lies in LSR. Project design criteria for improving wildlife

habitat where possible will be included.

Wildlife

Commercial thinning harms “countless natural

resources… especially aquatic resources” –

(numerous views and citations opposing timber

harvest are attached to this assertion)

The thinning prescriptions proposed will be consistent with direction




silvicultural science. We understand that public perception of timber

harvest is controversial; however, there is a solid scientific foundation

for use of thinning in this region to enhance ecological values and

provide economic benefit.

Thinning (effects)

Roads damage the proper ecological functioning of the

natural resources in a forest (numerous views and

citations opposing forest road construction are

attached to this assertion); temp roads should be

obliterated after use

We acknowledge that roads can cause impacts to natural resources,

and these will be analyzed and disclosed in the EA. Any temporary

roads needed for the proposed action would be closed and stabilized

following use for harvest. The team is also looking at additional roads

to close and stabilize in the project area to reduce risk to natural

resources.

Roads (effects)

Scoping was conducted improperly / Comment period

is required for pre-decisional EAs

Scoping was conducted through a legal notice at the discretion of the

line officer, and was not intended to limit the time frame for providing

scoping input. The EA had not been drafted, and the proposed action

was not refined. The public has the option of providing input up until

the point at which a decision is made, but we requested scoping

NEPA/ Scoping process


196


responses be provided within a timeframe that would allow them to

be most helpful to integrate into the analysis.

Law requires that USFS obtain a NPDES permit and

disclose that the permit has been obtained

National Pollutant Discharge Elimination System (NPDES) is a permit

program that helps control water pollution by regulating point sources

that discharge pollutants into waters of the United States. The EPA

has revised 40 CFR 122.26(b)(14), its Phase I storm water

regulations, to clarify that storm water discharges from logging roads

do not constitute storm water discharges associated with industrial

activity and that a NPDES permit is not required for these storm

water discharges.

NPDES/ Water quality

Convert roads to trails (RT) suited for OHV (off-

highway vehicle) use rather than closing or

decommissioning.

Currently the Forest Service is unable to fully fund the maintenance




appropriate. The line officer has asked the team to consider only

closure and stabilization, not decommissioning, based on public and

interdisciplinary input. A preliminary list of road to propose for closure

is being derived from a variety of criteria based on known future

management needs, aquatic and terrestrial risk posed by the road,

and feasibility to analyze within the scope of this project. The

purpose and need for this project is focused around thinning and

restoration treatments to achieve primarily ecological objectives.

Addition of new recreation opportunities, such as the suggested

conversion of routes to recreational OHV use, are not connected to

ecological restoration and beyond the scope of this project.

Roads

Allow motorized vehicle access for recreation. Roads

Convert currently closed and/or decommissioned

roads to OH (off-highway vehicle) trail

Roads

Seed timber harvest landings for wildlife This analysis will include provision for seeding of temporary roads,

landings, and other areas of heavy disturbance.

Roads/Wildlife


197

Appendix B: No Commercial Harvest Buffers No commercial harvest buffers for stream and wetlands by harvest unit (Note: stream buffers of

“0*” are stream channels that fall within a larger stream buffer of a fish bearing channel).

Harvest Unit Nbr

Harvest Unit Size (ac)

Stream or waterbody

Stream Type

Interim Riparian Reserve width (ft)

No Commercial

Harvest Buffer

Width (ft)

No Commercial

Harvest Buffer in Unit (ac)

Percent Buffer

in Harvest

Unit

Total % of Buffer area in Harvest

Unit

1 125 Big Creek Perennial 360 180 1.2 0.96

125 Wetlands Wetlands 180 60 38.44 30.75 31.71

2 16.9 Big Creek Perennial 360 180 7.3 43.20 43.20

3 17.6 None None 180 0* 0 0.00 0.00

4 108.7 Stream 1 Perennial 120 15.3 14.08

108.7 Stream 1a Perennial 180 30 0.56 0.52

108.7 Stream 1b Intermittent 180 30 0.14 0.13

108.7 Berry Creek

Perennial 360

180 1.2 1.10

108.7 Wetlands Wetlands 180 60 4.4 4.05

108.7 Nisqually

River Perennial

360 180 6.4 5.89 25.76

5 19.9 Stream 1 Intermittent 180 30 0.85 4.27

19.9 Stream 2 Intermittent 180 30 0.14 0.70

19.9 Berry Creek

Perennial 360

180 1.87 9.40 14.37



40.3 Big Creek Perennial 360 180 3.08 7.64 14.54


13.7 Big Creek Perennial 360 180 5 36.50 36.64


4.78 Stream 7 Intermittent 180 30 0.21 4.39 30.54

9 52.85 Stream 1 Intermittent 180 30 0 0.00

52.85 Mesatchee Intermittent 180 180 4.19 7.93 7.93

10 114.52 Stream 1 Perennial 180 30 1.32 1.15




198

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit




114.52 Stream 7 Perennial 180 60 2.46 2.15





114.52 Stream 9a Intermittent 180 60 1.45 1.27


114.52 Stream 9c Intermittent 180 60 0.33 0.29



114.52 Wetland 1 Perennial 180 60 1.6 1.40 9.93




17.35 Mesatchee Perennial 360

180 2.69 15.50

17.35 Wetland 1 Perennial 180 60 0 0.00 27.49


113.6 Stream2 Perennial 180 0* 0 0.00

113.6 Stream 3 Perennial 180 0* 0 0.00






113.6 Stream 9 Intermittent 180 0* 0 0.00


113.6 Stream

10a Intermittent 180 30 0.16 0.14


199

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit





113.6 Mesatchee Perennial 360

180 24.73 21.77

113.6 Wetland 1 Perennial 180 60 0 0.00 23.71















316.03 Stream 1d Intermittent 180 30 0.4 0.13






316.03 Stream

3c1 Intermittent 180 30 0.29 0.09

316.03 Stream

3c2 Intermittent 180 30 0.31 0.10


316.03 Stream 3e Intermittent 180 60 0.62 0.20





200

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit


316.03 Wetland 1 Perennial 180 60 5.7 1.80



316.03 Big Creek Perennial 360 180 14.8 4.68 26.82






16 100.43 Stream 1a Perennial 180 30 1.43 1.42

100.43 Stream

1a1 Perennial 180 60 2.12 2.11

100.43 Stream

1a2 Perennial 180 60 1.18 1.17

100.43 Stream

1a3 Intermittent 180 30 0.11 0.11

100.43 Stream 1a1a

Intermittent 180 30 0.07 0.07


100.43 Stream 1c Intermittent 180 0* 0 0.00




100.43 Big Creek Perennial 360 180 6.25 6.22







80.01 Berry Creek

Intermittent 180 180 1.74 2.17 17.66

18 15.48 None - 180 - 0 0.00 0.00

19 59.79 Stream 3 Perennial 180 60 5 8.36


59.79 Stream

3a1 Intermittent 180 30 0.24 0.40



201

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit

59.79 Stream 5 Perennial 180 60 4.13 6.91 17.68



56.57 Berry Creek

Perennial 360

180 0.78 1.38 3.04









256.77 Stream 5d Perennial 180 60 2.3 0.90



256.77 Stream

6a1 Intermittent 180 30 0.11 0.04

256.77 Stream

6a2 Intermittent 180 30 0.03 0.01



256.77 Stream 7b Perennial 180 30 1.36 0.53

256.77 Stream

7b1 Intermittent 180 30 0.24 0.09

256.77 Stream

7b2 Intermittent 180 60 1.43 0.56





256.77 Stream

10a Intermittent 180 30 0.13 0.05

256.77 Stream

10b Intermittent 180 60 1.04 0.41


256.77 Stream

11a Intermittent 180 30 0.56 0.22


256.77 Stream

12a Intermittent 180 30 0.59 0.23


202

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit


256.77 Berry Creek

Perennial 360

180 2.53 0.99









47.21 Stream 1a Perennial 180 30 1.32 2.80 4.32





35.94 Stream 3b Perennial 180 60 0.85 2.37

35.94 Stream 4 Perennial 180 30 0.32 0.89 21.01

25 13.73 Stream 1 Intermittent 180 30 0.11 0.80 0.8



41.56 Rocky Creek

Perennial 180 120 0.13 0.31 9.79



35.18 Wetlands Wetlands 180 60 1.22 3.47

35.18 Berry Creek

Perennial 360

180 0.1 0.28 8.24








95.13 Stream 4 Intermittent 180 60 4 4.20





203

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit

95.13 Berry Creek

Perennial 360

180 7.88 8.28




446.27 Stream

10a Perennial 180 60 0.35 0.08

446.27 Stream

Complexes

Intermittent and

Perennial 180 30/60 152 34.06

446.27 Wetlands Wetlands 180 60 1.2 0.27 34.41



92.13 Stream

13a Intermittent 180 30 1.63 1.77

92.13 Stream

13b Intermittent 180 30 0.25 0.27


92.13 Stream

14a Intermittent 180 60 0.98 1.06


92.13 Wetlands Wetlands 180 60 12.3 13.35 20.00



80.97 Stream

1a1 Intermittent 180 60 1.58 1.95 5.56







118.79 South Fork Catt Creek

Perennial 360

180 14.13 11.89 17.02





Perennial 360

180 21.55 30.88

69.79 Catt Creek Perennial 360 180 3.63 5.20



204

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit




106.43 Stream 8a Intermittent 180 30 0 0.00 10.21









52.27 Catt Creek Perennial 360 180 22.6 43.24 58.01













37 30.79 Stream2 Intermittent 180 30 0 0.00




30.79 Stream 4d Intermittent 180 60 0 0.00





205

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit











Perennial 360

180 3.38 3.10 15.55




82.78 Stream

5a1 Intermittent 180 60 1.5 1.81

82.78 Stream


82.78 Stream














70.75 Stream

5a4 Intermittent 180 30 0.16 0.23

70.75 Stream

5a5 Intermittent 180 30 0.08 0.11

70.75 Stream

5a6 Intermittent 180 30 0.22 0.31


206

Harvest Unit Nbr


Stream or waterbody

Stream Type


No Commercial

Harvest Buffer

Width (ft)

No Commercial


Percent Buffer

in Harvest

Unit


Unit

70.75 Stream

5a7 Intermittent 180 30 0 0.00






207

Appendix C: Interdisciplinary Team Members

Name Specialty

Aldo Aguilar Soil Resources

Kevin Flores Heritage and Cultural Resources

Steve Hansen Logging systems

Jennifer Harris Fire and Fuels

John Jakubowski Wildlife Biology

Mike McConnell Hydrology

Sarah Rockey Roads and Engineering

Kevin Senderak Silviculture and IDT leader

Linda Swartz Botany and Invasive Species

Erica Taecker NEPA

Jack Thorne Recreation

Ken Wieman Fish Biology

Additional participation and review by:

Adam Dailey – Engineering

Carol Chandler –Wildlife

Jessica Hudec – Fire Ecology

Dave Olson – Natural Resources

Jamie Tolfree – Pinchot Partners

Joe Gates – Silviculture

John Squires – Pinchot Partners

Marie Tompkins – Wildlife

Paul Smale – Hydrology/Aquatics

Ruth Tracy – Water Resources


208

Appendix D: Response to Comments Received on the Draft EA

Number Theme Comment Response

Dick Artley

1-1 Omission IDT members are not listed in draft EA. Team list was inadvertently omitted, but added to EA and

posted online immediately upon receipt of comment.

1-2 Effects

analysis

The biologists, ecologist and soils scientist… use the

following unsubstantiated terms in Chapter 3 to minimize or

eliminate the near-certain damage that timber sale

implementation will inflict on their resource: Short-term, Not

measurable, Temporary, and

Minor… they must have data to support their claims that

the impacts are trivial

Given the experience and professional background of the

scientists on the team, we believe the analysis of effects

disclosed in the EA was based upon appropriate scientific

literature, valid data, and professional judgment.

The EA discloses the measurable effects to resources

from pages 35 through 179, including data and

summaries from which effects determinations were drawn.

Resources in which data or surveys are lacking were

disclosed in the EA, and the potential effects were

estimated based on peer-reviewed science and

representative data sets.

1-3 Effects

analysis

Please assure that the biologists, archaeologist, recreation

specialist, ecologist and soils scientist rewrite their effects

analysis in Chapter 3 of the final EA so the effects are

honest and accurate. Please ask them to describe the

effects to their resource rather than the length and

magnitude of the impact. Indeed, impacts that are short-

term can inflict major, long-term adverse effects.

1-4 Public

involvement

The Responsible Official has loaded her collaborative

group with people who support public land development at

a much higher ration than the public at large support forest

The opportunity to provide input during scoping and

comment periods was offered to the general public via

mail, email, and website, not exclusively to the


209


development…

Request for final NEPA document modifications :

1) Please include the names of the group members and

who they represent.

2) Please explain to the public why a USFS hand picked

collaborative group was needed when the public scoping

comments as required by NEPA serve the same purpose

as Supervisor Clayton says she relied on the collaborative

group to provide.

3) Please explain to the public why the collaborative group

members were not chosen at random and explain why

people chosen randomly would not represent the public

better than the collaborative group members chosen by the

USFS.

collaborative group. The proposed action was developed

from scoping feedback received, in writing, from a variety

of sources and interests, including citizens and entities

based outside the local area. The public meeting held

during scoping was open to the general public, as were

field trips to the project area. Collaborative group

concerns were not given more weight than those

expressed by any other member of the public who chose

to provide input.

1-5 Best Science The Attachments contain the statement by over 600 well

respected Ph.D. scientists who describe the damage to the

forest ecosystem caused by logging and road construction

activities. Why do you reject best science and instead act

on the advice of 4 to 5 of your timber employees who will

benefit financially if the Nisqually Thin timber sale is offered

and sold?

Request for final NEPA document modifications:

Please review this project in light of the best science

attached to the objector’s comments and acknowledge the

The collection of quotes provided by the commenter is not

referenced to any particular finding or statement within

this document. This makes it impossible to determine the

intent and context of each quote as it relates to our

detailed analysis. Given the experience and professional

background of the scientists on the analysis team, we

believe the specific references to scientific, professional

and other literature found throughout this document

demonstrate an appropriate and unbiased analysis.


210


science conclusions of 421 independent, unbiased

scientists regarding the impacts of timber sale activities.

The attachments deal with one issue. The scientists

quoted in each attachment provided their viewpoints on the

issue. When acknowledging the science conclusions

please organize them by issue (i.e. timber, roads,

insects/disease & fire etc.).

1-6 Public

comments

Please assure that the Responsible Official’s responses to

public comments are posted online as well as hardcopy in

the Project File.

Comments and responses will be added to the EA as an

appendix and posted online, in addition to kept in a

hardcopy project file.

1-7 Alternatives /

Roads

The pre-decisional EA does not analyze an alternative in

detail that does not construct any new roads (temp or

system)… Please analyze an alternative in detail that does

not construct any new roads (temp or system). The no

new roads alternative stands out among the infinite number

of alternatives because it reduces the adverse

environmental effects of the proposed action while still

meeting the purpose and need for the project even though

slightly less output would be generated.

Section 102 [42 USC § 4332] (2) of the National

Environmental Policy Act states “all agencies of the

Federal Government shall—…(E) study, develop, and

describe appropriate alternatives to recommended

courses of action in any proposal which involves

unresolved conflicts concerning alternative uses of

competing available resources.” (bold italics added for

emphasis).

Issues brought up during public and internal scoping and

review, including a proposed alternative to eliminate any

construction or reconstruction of non-system roads, were

resolved through revising the silvicultural prescriptions

and project design criteria, or through dropping units or

portions of units, resulting in the one proposed action

alternative rather than multiple alternatives to meet the

purpose and need of this project. Any roads constructed


211


or reconstructed for the project will be returned to a closed

and stable condition following timber harvest.

1-8 Aquatics /

Streams

There were not an adequate number of stream surveys to

predict whether the streams were subject to major adverse

effects when they are monitored after the sale is

completed. Before and after data is essential.


Before activities start, please conduct stream surveys for

all perennial streams in the project area which will include

measured values for 1) stream temperature, 2) turbidity,

and 3) stream flow.

Given the experience and professional background of the

scientists on the team, we believe the analysis is not

biased and uses appropriate scientific literature and

professional judgment. A channel inventory and stability

assessment was conducted on all channels within unit

boundaries based on field review. Detailed notes are

available in the project record. Data was also used from

the official Forest fish distribution map which combines

WDFW and USFS fish presence data including migration

barrier details.

1-9 Economics Most American recreationists will avoid areas that have

been logged. U.S. Undersecretary of Agriculture Jim

Lyons states that recreation revenues from national forests

significantly exceed timber revenues (sources cited in

attachments).

There are more businesses in communities near the

Gifford Pinchot National Forest that depend on recreation

revenues than there are businesses that depend on timber

revenues.

Please omit the Purpose & Need statement that tells the

public this project is needed to “create a sustainable supply

of timber and other forest products that will help maintain

The Gifford Pinchot National Forest provides many

recreation opportunities. Please visit

http://www.fs.usda.gov/recmain/giffordpinchot/recreation

for more information.

Logging and employment in other timber related jobs are

10-12% of the local economy (Census Bureau, 2011),

considerably greater than the importance of this sector on

employment nationally (Figure 19). While travel and

tourism related employment accounts for around 15% of

local employment, this is similar to the national average,

and is likely due primarily to the presence of Mt. Rainier

National Park in Lewis County. The timber industry

provides stability to the local workforce as a source of jobs

that typically pay more than the service industry jobs

http://www.fs.usda.gov/recmain/giffordpinchot/recreation


212


the stability of local and regional economies.” associated with tourism.

1-10 NEPA/

Alternatives

and

Proposed

Action

The range of alternatives in the pre-decisional EA is

inadequate and is clearly intended to make it easier for the

Responsible Official to select the Proposed Action that was

chosen as the alternative selected for implementation

before the NEPA process started. Please analyze in detail

and display the effects in Chapter 3 of another action

alternative to the Proposed Action that would really restore

the Riparian Reserves in the Catt Creek, Mesatchee

Creek, Big Creek,and Berry Creek drainages. This

alternative will meet the objectives of a legally written P&N

that’s not written to exclude reasonable alternatives to the

Proposed Action.

Section 102 [42 USC § 4332] (2) of the National

Environmental Policy Act states “all agencies of the

Federal Government shall—…(E) study, develop, and

describe appropriate alternatives to recommended

courses of action in any proposal which involves

unresolved conflicts concerning alternative uses of

competing available resources.” (bold italics added for

emphasis).


review were resolved through revising the silvicultural

prescriptions and project design criteria, or through

dropping units or portions of units, resulting in the one

proposed action alternative rather than multiple

alternatives to meet the purpose and need of this project.

The project addresses restoration priorities to restore

channel conditions to the extent possible given planning

and implementation constraints. The restoration projects

were vetted in public scoping and subject to the IDT

process

1-11 Economics Please include an economic analysis showing of Nisqually

thin is a below-cost timber sale. This will include ALL

USFS costs including Clayton’s salary when she worked

on the project.

Between 2003 and 2012, there were 36 commercial thin

timber sales across the Forest that were not part of

stewardship projects, of which half were allocated to

companies that are registered with the Small Business

Administration. None of the sales were sold below-cost.


213


Over half of the sales had 2-6 bidders and were sold for

up to 3.5 times the advertised value.

It is true that thinning trees does not provide the greatest

dollar return that could be received. It is a land

management tool to improve forest health and provide

wildlife habitat. However, this project is expected to be

harvested through several timber sales, over several

years. The purchasers will have the opportunity to

determine when the best time to bring the logs to market

would occur.

1-12 Invasives Herbicides Containing Glyphosate must Never be used on

Public Land for Any Reason. The Nisqually Thin sale area

is no exception. The pre-decisional EA at pages 24-24

discuss measures to deal with Invasive Weed

Management. This section mentions “treatment” of

infested sites several times but hides the treatment

methods from the public…


Please either:

1) treat non-native plants with alternatives to glyphosate-

containing herbicides, or

2) if these types of herbicides must be applied, analyze the

effect in Chapter 3 because scientific research indicates

Management direction regarding treatment of invasive

weeds for the Nisqually Thin project comes from the R6

Final Environmental Impact Statement for the Invasive

Plant Program, Preventing and Managing Invasive Plants

(2005) and Gifford Pinchot National Forest and Columbia

river Gorge National scenic Area (Washington portion):

Site Specific Invasive Plant Treatment Project and Forest

Plan Amendment #20 (2008). Changing Forest protocols

for addressing invasive plants is not within the scope of

this project; however, Mitigation Measures related to

noxious weeds prevention and treatment (Table 4) were

clarified to emphasize that only approved chemicals at

application rates specified in above-mentioned direction

may be used.


214


there might be a link between glyphosate-containing

herbicides and CCD [Colony Collapse Disorder]. As you

know environmental effects must be analyzed and divulged

in Chapter 3 if there might be an effect.

1-13 NEPA/

Amenity

values

Simply stating that amenity resource values have been

considered in the NEPA document is not enough. The

Responsible Official must “identify the methods and

procedures used to assure appropriate consideration.”


Please identify and discuss the methods and procedures

used by the Responsible Official to insure that presently

unquantified environmental amenities and values are given

appropriate consideration.

There were multiple methods and procedures followed for

identifying environmental amenities and values, as

presented in the Nisqually Thin EA. These included

deriving the project need from the Gifford Pinchot National

Forest Land and Resource Management Plan, Nisqually

Watershed Analysis, landscape-scale assessments, best

available science, and local resource data collected.

These sources also provided information about an array

of difficult-to-quantify environmental amenities and values,

such as recreation, visual quality, and climate change.

In addition, the Forest Service invited collaboration and

public comments, surfacing other values within the

Nisqually Thin project area. Input from the collaborative

group and public was considered during development of

the proposed action and alternatives and will be

considered in the decision.

1-14 Wildlife The pre-decisional EA does not discuss how the timber

sale’s harvest and slash/RX burning activities will affect

protected bird species or if there will be potential adverse

effects how they will be eliminated.


The EA (pp. 119-121) discloses the potential effects of the

Nisqually Thin project on migratory birds, with a list of 20

focal bird species known to occur in the Pacific Biome

Region. The focal species represent the habitat

requirements of any other migratory birds that are

assumed to exist in or near the project area where habitat


215


Please identify the birds that exist in and near the project

area that are protected under the Migratory Bird Treaty Act

and discuss how these birds will be protected during

burning and timber harvest operations.

exists. The effects are disclosed as neutral in the short

term for species associated with early and late seral

structure forests because the treatment units are in mid-

seral structure stands with high canopy closure. Species

associated with the mid-seral structure will likely have

short term detrimental effects to habitat.

In the long term, species associated with late-

successional structure stands will benefit as the beneficial

effects to stand growth are realized in the next 50 to 100

years.

The early and late season nesting restriction that applies

to the majority of the treatment units will minimize

disturbance to nesting migratory birds in the project area.

Burning occurs in late summer and early fall, after the

nesting season, so burning will not impact nesting

migratory birds.

1-15 Temporary

Roads

Since temporary roads are outsloped with no ditch,

sediment that is generated during precipitation events, find

its way to streams and harms the aquatic resources for

decades until the next timber sale reconstructs the so-

called “temporary” road. Then the riparian resource cycle

of destruction begins again. The final EA should clearly

state these roads will be obliterated after use such that the

sideslopes are as they were before construction. The

CMPs will be removed and a running surface does not

Any temporary roads constructed or reconstructed for the

project will be returned to a more natural state following

timber harvest, as asserted in the Proposed Action (EA

p.11). Refer to Project Design Criteria 5.14 (and others) in

the Nisqually Thin EA.


216


exist.


Please obliterate temporary roads to reduce sediment

generation rather than decommissioning them.

1-16 Timber Any national or regional poll or survey indicates the vast

majority of the public doesn’t want their public land

harvested for any reason. In the final EA EIS please tell

the public why this sale is an exception.

Request for final NEPA document modifications that

appeared in the objector’s comments: Please include a

discussion and supporting data in the final EA showing

either:

1) the majority of the general public approves of logging

their national forests, or

2) majority of the general public does not approve of

logging their national forests.

The issue of general public support of logging national

forest is outside the scope of this particular project, and

subject to a broad spectrum of beliefs and attitudes. The

purpose and need stated in the EA clearly provides the

legal framework and agency guidance under which the

proposed action was derived.

Respondents to scoping and comment periods of this

project represented a range of viewpoints about the

logging proposed in this project, from “thin more heavily

than what is proposed,” to “do not cut timber at all.”

1-17 NEPA Some lay members of the public will not be able to

determine if all practicable means to avoid or minimize

environmental harm to the natural resources in the forest

unless the Responsible makes this statement.

Request for final NEPA document modifications: Please

assure that the selected alternative avoids or minimizes

environmental harm and state in the EA that “all practicable

The Responsible official is only required to make a

statement as to “whether all practicable means to avoid or

minimize environmental harm from the alternative

selected have been adopted, …” in cases with a record of

decision (ROD) for environmental impact statements

(EIS), as per 40 CFR 1505.2(C). This regulation does not

apply to preparation of the decision notice prepared for an


217


means to avoid or minimize environmental harm from the

alternative selected have been adopted.”

environmental assessment.

1-18 NEPA The Purpose & Need is written so narrowly that it excludes

all reasonable alternatives to the Proposed Action. Such a

narrow Purpose & Need allows you to reject all (emphasis

added) alternatives submitted by the public in good faith in

the “Alternatives considered but eliminated from detailed

study” category.


Please write a new (expanded) Purpose & Need that

allows alternatives to the Proposed Action to be analyzed

in detail. Then reinitiate the NEPA comment and analysis

process to analyze the new reasonable alternatives,

especially those suggested by the public during the

comment period.

In an EA, Federal agencies must briefly specify the

underlying purpose and need to which the agency is

responding in proposing the alternatives including the

proposed action. Without a clear purpose and need, the

range of alternatives could be considered infinite and thus

impossible to analyze within a reasonable timeline and

budget. In the Nisqually Thin EA, the Responsible Official

determined that one of the project’s underlying purposes

is to provide wood fiber for local and regional economies.

This purpose is responding directly to the Gifford Pinchot

National Forest Land and Resource Management Plan

regarding timber output. The Forest Plan and Watershed

Analysis describe producing timber as part of a program

of activities consistent with specific direction and

standards and guidelines to achieve a desired future

condition through silvicultural activities.

Mount Rainier National Park (MRNP)

2-1 Support Proposed Action is supportive of ecological processes that

are connected to national park system lands, and the plan

has the potential to improve stand health and habitat

conditions on overstocked stands that were harvested 30-

N/A (Support).


218


70 years ago.

2-2 Information Park helibase is located at Kautz Creek near the Nisqually

River, so units harvested with helicopters that have the

potential to conflict with park operations would require

some coordination with appropriate park aviation

personnel. Helicopter activity is typically heaviest during

spring and fall for park operations, but may occur any time

of year if we have a search and rescue operation.

A mitigation measure (12.1, EA page 31) has been added

to ensure coordination with the Park in the event that

helicopter harvesting operations take place.

2-3 Information Information Statement #2: NPS is proposing to release

Pacific fishers from within the park near Longmire. This

release may occur as early as next fall, if the project is

approved. We would be concerned about timing of harvest

and log truck traffic during timber harvest if it overlaps with

fisher release. However, we believe that planned harvest

activity designed to promote stand health and late

successional conditions will benefit the fisher in the long

term.

We agree that the Nisqually treatments should benefit the

Pacific fisher in the long term by developing late

successional characteristics. We appreciate receiving

regular updates on the status of release activities. It is

unlikely that harvest activities and traffic will be occurring

until 2015.

2-4 Opportunity Information Statement #3: We are proposing to install

engineered log jams (ELJ) on the Nisqually River and

adjaced to the Nisqually to Paradise Road three to five

years from now, depending on funding. Locations would be

immediately downstream of Longmire, at one locations

approximately 1.5 miles downstream of Longmire, and at

Sunshine Point, immediately east of the Nisqually entrance

station. We would like to explore opportunities for

The timing might be right to collaborate on this

opportunity. Please keep us informed as plans to install

the ELJs develop. Note that effects of removing full trees

with intact root wads (which are often desirable in

engineered log jams) were not analyzed in this project EA,

so only logs removed above the ground could potentially

be made available to the Park based on the proposed

action.


219


collaboration (purchase of logs, use of slash if needed) if

timing of harvest aligns with construction of ELJs.

American Forest Resource Council (AFRC)

3-1 Support We are pleased to see the project allow ground based

mechanical harvesting on slopes up to 45% and we

encourage the consideration of this in future projects.

Mechanical harvesting has benefits economically,

improved ability to protect residual trees during felling

operations, and increased safety for harvesting personnel.

N/A (support).

3-2 Timing

Restrictions

We encourage the expansion of the Normal Operating

Season (NOS) in the upland areas identified in the draft EA

document, Item 5.1 (pg 19). Seasonal, recreation, and

wildlife restrictions often make timber sales extremely

difficult to complete within the contract timelines. Fire

season restrictions on top of other operating restrictions

can often limit work to 4-5 hours per day. All of these

restrictions have a cost to the purchaser and result in a

lower bid for the stumpage. Additionally these seasonal

restrictions become an even larger issue on units

scheduled for helicopter yarding. Scheduling helicopters for

logging can be difficult due to conflicting demands for

equipment during fire season…Soil compaction,

displacement, and erosion are factors cited for the timing of

the NOS. In the units identified for helicopter use, these

issues can be reduced due to the full suspension of the

Helicopter yarding does reduce soil disturbance, and is

preferable over ground based logging to protect that

resource. However, other components of helicopter

yarding would still remain as factors in soil damage and

erosion, including log landing operations, log hauling, road

maintenance, and industrial soil contaminants, all more

sensitive at times of high soil moisture. NOS restrictions

are the most reliable way to meet the protections needed,

therefore, on the ground monitoring and waivers are a

better way to expand operations when appropriate

conditions exist.


220


turn of logs during yarding activities with the helicopter. On

these units the lack of ground or cable yarding systems

should be a factor in extending the NOS.

3-3 Support We are pleased to the see the option included to potentially

allow the operator to operate under the guidelines

identified in Item 5.22 (pg 24) – “Over the Snow operation.”

Assuming the project area is accessible during winter

months, without significant snow plowing expense, winter

operation can be very beneficial to prospective bidders.

N/A (Support).

3-4 Economics /

treatment

prescription

We are hopeful the Nisqually Thin Project units will provide

adequate volumes. Light thinning of 4 -8 mbf /acre makes

units difficult to economically log. Light thinning, particularly

in the older stands (45+ years old) has the potential to

extend the time needed to achieve late successional forest

characteristics.

Thinning prescriptions vary by unit and management

allocation. See the explanation and summary of treatment

prescriptions and the anticipated effects on thinning in the

EA, pp. 56-63

3-5 Riparian

Reserves /

treatment

prescription

AFRC also would like to voice support for thinning

treatments in the riparian areas of the Nisqually Thin

Project. No-cut buffers of 25-50 feet can be prescribed to

provide shade to maintain stream temperatures and also

provide stream bank stability. By thinning the remaining

acres inside the riparian reserves it is possible to achieve

the management objectives of moving them into late

successional habitat faster. This method can also provide a

process to convert riparian areas primarily stocked with

hardwoods to conifer. The removal of hardwoods also

The no-cut buffers range from 30 to 180 feet and are

based on site-specific conditions by stream segment

(Appendix B in EA), along with other design criteria

specified in Riparian Reserves described in the PDC (EA

Table 4). Criteria used to determine buffers are consistent

with the Gifford Pinchot National Forest Land and

Resource Management Plan as amended by the

Northwest Forest Plan for Class I through IV streams.

These buffer widths are designed to protect water quality,

watershed (aquatic habitat conditions), and promote


221


helps to fill a niche market for mills that process

hardwoods, thus further aiding the local economies. By

reducing the no-cut buffers to 25-50 feet and thinning down

to that distance, the forest also harvests more volume

during the sale, thus reducing unit cost.

stability, consistent with Aquatic Conservation Strategy

objectives.

3-6 Support AFRC is also pleased to see this project will work to

improve the road infrastructure of the forest as needed for

timber haul.

N/A (Support)

3-7 Road

Closure

We are, however, concerned over the proposed closure of

7.17 miles of road as identified in Table 3 on pages 13 and

14. AFRC understands some roads within the identified

project area need to be decommissioned and/or stabilized

for the benefit of aquatic resources. The challenge and

concern lies in assuring that closure of portions or all of a

road system does not potentially foreclose future

operations within timber stands accessed by those existing

roads. The removal of roads needed for future treatment

projects may have significant negative impacts on the

viability of these prospective operations.

System roads were considered for closure following

treatments proposed under the Nisqually Thin based upon

criteria evaluated in the 2002 Roads Analysis, which were

subsequently verified by the IDT during development of

the Nisqually Thin proposed action. The column indicating

“Access Need” in Table 3 indicates the status of that road

in 2002. A column has been added to Table 3 to disclose

the present need as verified by the IDT. In addition, the

responsible official took these concerns into account when

opting for “close and stabilize,” rather than decommission

these system roads.

3-8 Wildlife We would also ask the Forest to verify the discussion

regarding spotted owl critical habitat (pgs 89-91) is aligned

with current critical habitat evaluation protocols.

Critical habitat for the spotted owl was designated by the

US Fish and Wildlife Service based upon a suite of criteria

and evaluations explained in more detail in the Federal

Rule (50 CFR 17). The discussion in the Nisqually Thin

EA explains the degree to which the 2012 critical habitat

designation is overlapped by the Nisqually Thin proposed


222


action in terms of the primary constituent elements

(PCEs). The commenter may be referring to the

methodology for estimating incidental take for spotted

owls based on Owl Estimation Methodology, which was

recently challenged in the courts, but this is not relevant to

the Nisqually Thin project because we are not asking for

any incidental take of spotted owls.

Gifford Pinchot Task Force (GPTF)* GPTF submitted comments on the draft EA after the comment period ended. While these

comments do not have standing in the objection process, the interdisciplinary team discussed and responded to them.

4-1 Watershed

restoration

There are a host of projects that are much needed in this

watershed and although we recognize the limited

resources of the Forest Service we are also keenly aware

of the need to move at a more rapid pace especially in the

face of climate change and it effect on the watersheds. We

again encourage the GPNF to revisit how the watersheds

were prioritized and incorporate many of the additional

watershed restoration work that was identified as a need.

The Forest is currently endeavoring to revisit the how

watersheds will be prioritized for a suite of management

purposes, including watershed restoration, vegetation

management, and wildlife. We appreciate your

engagement and interest as the process unfolds.

4-2 Road closure We are supportive of the Forest Service’s efforts to

increase the road restoration work in this project and

encourage the Forest Service to increase the number of

miles designated for closure and stabilization in areas such

as the Nisqually thin area that are sensitive habitats to a

wild variety of animals including potentially wolverine.

The Forest is always evaluating the need for and

economics of the existing road network, in addition to

seeking opportunities to benefit natural resources through

road restoration work. We look forward to your continued

interest and participation in the prioritization process.


223


4-3 Support We are supportive of the efforts being made to produce

snag trees for the species dependent on late successional

and old growth forest trees. We are also supportive of

leaving areas with important habitat outside of the “gap”.

N/A (Support).

4-4 Wildlife The GP Task Force is concerned about the possible

proximity of some of the plantation units to active spotted

owl sites and the impact of a large-scale timber sale within

critical habitat. Right now, with the negative impact that

barred owls are having on spotted owls, there needs to be

extra caution that timber harvest activities do not add to the

pressure on the still-active spotted owl sites.

The US Fish and Wildlife Service is in charge of recovery

for this species and we have a submitted our BA

requesting a “not likely to adversely affect” determination

for this project on spotted owls. One of the key issues for

the project is to hasten the development of late-

successional habitat that will be a beneficial effect for

spotted owls in the coming decades, should they manage

to persist with the presence of barred owls. According to

the latest northern spotted owl recovery plan, the best

hope for the future survival of spotted owls is to maintain

and develop large areas of suitable habitat, which this

project is designed to help achieve with the proposed

treatments.

Recent surveys have detected barred owls in the project

area and some occupancy by spotted owls of historic

territories. We are aware of the situation with barred owl

presence and the negative effect they are having on

northern spotted owls. The proposed thinning is a neutral

effect to competition and will enhance habitat for both

species. The EA fully addresses habitat degradation for

spotted owls and does a thorough analysis of this by

analyzing quantities of suitable nesting, roosting, foraging

and dispersal habitat by historic core area and the effects


224


of the proposed units on the different habitat type

quantities (EA pg. 54-62).

4-5 Treatment

prescription

While the Nisqually Timber Sale stands are a mix of Matrix

and Late-Successional Reserve, the GP Task Force urged

the Forest Service to apply a variable density thinning

(VDT) framework for all the units. We are disappointed that

the Forest Service is not considering use of VDT in the

matrix units and would request that the GPNF reconsider

its thinning protocols for the matrix. GP Task Force is

highly supportive of the use of VDT in the late successional

reserves.

The Forest Plan Management Area Categories for Matrix

is Timber Production (TS). The goal of the Timber

Production allocation is to optimize timber production, the

utilization of wood fiber and other commodities in a

manner which assures the future productivity of the land

(EA, p 7). Variable Density Thinning is a technique among

several used in Late Successional Reserves (LSR) that

increases horizontal and vertical heterogeneity of stands

in accelerating development of late-successional

structural characteristics and habitat (EA, pp.56, 59-60).

To use Variable Density Thinning in the Matrix portion of

the project would be squarely at odds with current

management direction.

4-6 Riparian

Reserves

The GP Task Force urges the district not to undertake

thinning of forests in riparian reserves—even “dry upland

portions”—without the scientific rationale to demonstrate

that such treatments are likely to benefit aquatic and

riparian resources. It is our view that riparian silviculture is

only authorized where there is a rational basis to find that it

promotes these goals.

Standards and guidelines for Riparian Reserves prohibit

or regulate activities in Riparian Reserves that retard or

prevent attainment of the Aquatic Conservation Strategy

objectives (ROD, p. C-31). Much of the science of riparian

thinning points to many benefits to dense stands less than

80 years old and even more so to stands less than 50

years old. Thinning in riparian stands does result in

accelerating the availability of live trees of pool-forming

size over time if the original treated stand was of small

diameter (Beechie et al. 2000). Recent studies of similar

treatments and buffer widths to Nisqually Thin contend

that headwaters are spatially compressed systems with a


225


narrow zone of cool, moist conditions where riparian

zones do not extend far upslope and aquatic vertebrate

community along channels is retained (Olson and Rugger,

2007). Additionally, Olson and Chan (2004) found in

thinning 30-70 year old plantations in western Oregon that

riparian buffers averaging as narrow as 17 meters wide

mitigated the microclimates associated with thinning and

thinning did not affect riparian buffer soil temperature and

stream temperature.

4-7 Roads We are disappointed that the Forest Service plans to open

more than a 1 mile of new temporary roads and re-open

4.81 miles of older roads for this project. We encourage the

Forest Service to reconsider units that require road building

to lessen impacts on the watershed.


review, including a proposed alternative to eliminate any

construction or reconstruction of temporary roads, were

resolved through revising the silvicultural prescriptions

and project design criteria, or through dropping units or

portions of units, resulting in the one proposed action

alternative rather than multiple alternatives to meet the

purpose and need of this project. Any temporary roads

constructed or reconstructed for the project will be

returned to a closed and stable condition following timber

harvest.