This CE is particularly interesting because the scientific basis for treatment is right upfront.
The TNC analysis used a reference baseline concept referred to as Natural Range of Variability (NRV) to look at ecological departure for each ecological system on the district. The current condition of ecological systems was derived using the metric known as Unified Ecological Departure. This is a single measure that integrates concepts of: (1) ecological departure in the traditional sense, (2) high risk vegetation classes, and (3) acceptable amounts of certain unharmful or benign uncharacteristic vegetation classes. Twelve ecological systems on the
district were selected for simulations of likely future conditions under various regimes of active management.
Nine of these systems are brought forward in this analysis (Table 1 and Figure 1). A full breakdown of ecological departure by structural stage for each of the nine systems is available in Appendix 2.
How Many Acres?
320,000 acres are under review for treatments including the 250,000 acres in IRA outside of wilderness areas. Treatments would not occur in areas where vegetation is within a desired NRV or in areas where it is determined that restoration would not be successful.
Note: The TNC analysis maps show where treatments are outside NRV.
Purpose and Need
The purpose and need for the proposed project include:
Improve and/or maintain wildlife habitat across the Pine Valley Ranger District including habitat for Threatened and Endangered species, Forest sensitive species and Forest focal species and species of concern (California condor, peregrine falcon, northern goshawk, Townsend big-eared bat, spotted bat, elk, mule deer, wild turkey, flicker, grey vireo, broad-tailed humming bird, Virginia’s warbler and brewer’s sparrow).
Improve and/or maintain stand conditions in mature and old growth pinyon-juniper stands.
Restore ecosystem composition and/or structure, to reduce the risks of uncharacteristic wildfire effects, and to conditions within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period (36 CFR 294.13 (b)(1)).
Note: the last bullet is language directly from the 2001 Roadless Rule.
Based on findings from the Landscape Conservation Forecasting and project design features (Table 2) the Dixie NF proposes the following actions to improve wildlife habitat and select vegetation community conditions on the Pine Valley Ranger District:
1. Trend vegetation communities towards the Natural Range of Variability (NRV) as identified in the TNC Landscape Forecasting report (2014) using the most appropriate tool or suite of tools such as: mastication, harrow, seeding (rangeland drill and/or aerial), chipping, lop and scatter, cut/pile, and prescribed burning.
2. Modify existing conditions to improve wildlife habitat and reduce the threat of uncharacteristic wildfire across the landscape by manipulating vegetation age class and species diversity distribution across the project area.
There are 32 pages of detailed documentation, including design criteria. I didn’t see anything about later site-specific analysis on this one. Page numbers would have been helpful.
Again, here is the plain English of this category: 36 CFR 220.6(e)(6) “Timber stand and/or wildlife habitat improvement activities that do not include the use of herbicides or do not require more than 1 mile of low standard road construction”. This one seems to fit wildlife habitat improvement. Would you agree with the use of the category if they did the same activities in the same places, but had documentation and scoping separate for each site? Would you agree if they took some activities (say PB) and used a different category for PB? Based on this reading I don’t see any timber harvest (not pinyon or juniper).
Let’s go back to the way the news story was written: “Under this administration, there’s really only one goal and that’s measured in board-feet,” Rissien said. Uh..I wouldn’t go looking for board feet in PJ in Region 4, myself.
Here’s another quote: “Rissien and others question how the Forest Service can know that such large projects won’t have detrimental environmental effects. By using a CE, the Forest Service doesn’t have to conduct an environmental study, so the public has no information to know if the forest or wildlife is affected.” I’m just pointing out that the condensed info in these CE’s, that is the three we’ve looked at so far, is equivalent to that required in an EA. From CEQ’s guidance here:
While the regulations do not contain page limits for EA’s, the Council has generally advised agencies to keep the length of EAs to not more than approximately 10-15 pages. Some agencies expressly provide page guidelines (e.g., 10-15 pages in the case of the Army Corps). To avoid undue length, the EA may incorporate by reference background data to support its concise
discussion of the proposal and relevant issues.