Thanks to Nick Smith.
While roadside hazard tree removal seemed to spark much debate in Oregon, this one perhaps less so. The EA is about 200 pages for 2461 miles. There were three objections, described below. Here’s the press release:
The Eldorado National Forest is beginning the implementation of their Roadside Hazard Tree Mitigation Project. This project is designed to reduce safety hazards along the 2,461 miles of National Forest System (NFS) roads, including 116 miles of state, local, and private roads in Alpine, Amador, El Dorado, and Placer counties. The project aims to ensure the integrity of the NFS roads and improve safety for the public, Forest Service staff, firefighters, emergency response personnel, law enforcement, private landowners, contractors, special use permit holders, and others.
It is important to address the issue of hazardous trees in the aftermath of high-severity wildfires, as they can pose a significant risk to road users. Trees that have been killed or damaged by a fire, as well as those affected by insects, disease, drought, or other stressors may become unstable and more likely to fall, particularly in high winds or other adverse weather conditions. This project’s goal to identify and remove those hazardous trees within striking distance of roads is a proactive approach to reducing the risk of accidents, injuries, and damage to roads.
The project’s scope is to identify, fell, and remove hazardous trees that are at risk of striking a road within a buffer area of 200 feet from the edges of NFS maintenance level 1 through level 5 roads, as well as identified state, county, local, and private roads through NFS lands. However, not all roads within the project area will be treated, and roads within designated wilderness areas are not included in the project scope.
“The Eldorado National Forest’s Roadside Hazard Tree Mitigation Project was designed to increase the resilience of the forest to a range of environmental threats, not just wildfires. By removing hazardous trees that could pose a risk to public safety, and infrastructure, the project aims to reduce the impact of future wildfires and other natural disasters,” said
Forest Supervisor, Joseph Stout.Treatment of lower maintenance level roads will be based on various factors, including administrative needs, permittee needs, access needs for utilities, and other uses. The project will use a variety of methods to remove the hazardous trees within the designated buffer area. These methods may include mechanical removal and piling, hand removal and hand piling, mastication, towed or in-wood chipping, and pile burning.
The project is conducted in phases, and the first phase will focus on 231 miles of roads within the Caldor Fire footprint.
This phase of the project is expected to last 2 to 3 years, indicating that it is a significant undertaking. It is important to note that detailed information on each phase of the project will be shared with the public prior to work being started.
I tried to copy this discussion of objections from the DN but was stymied by the pdf and my Adobe. So apologies for the weird formatting below.
ALL of the Forest Service system roads on the Eldorado NF are used for recreation, for one activity, or another. Additionally, all of those roads within the Caldor Fire, will probably be needed in the next 20 years, Almost all of those roads had been previously under a hazard tree project or salvage sale. The Eldorado is a short drive from the Sacramento urban areas.
Those roaded areas are not “pristine”. They have all been logged in the last 35 years (and I did a lot of work there).
Even with all that “management” of both Federal and private timberlands, the Caldor Fire just burned right through it all. The Placerville RD sold 300 million board feet of bark beetle salvage during 1989 to 1992. Certainly, the “pace and scale” of Forest Service “Vegetation Management” was inadequate, but they were doing the right things. Despite all of SPI’s ‘management’, the Caldor Fire burned through all of it, anyway.
I am really curious to see the area I knew so well, and to judge how well my own specific work held up (or didn’t). I do have to think that my salvage and thinning efforts did reduce the fire’s intensities.
I’ll stick to process questions.
“It is important to note that detailed information on each phase of the project will be shared with the public prior to work being started.” It is therefore important that they comply with NEPA at that point based on this new information. Maybe this is the “site-specificity” issue that was raised, and it is like the “condition-based management” question of whether they (and the public) know enough about the proposed action to actually evaluate its environmental effects.
Then there is the missing alternative question that illustrates the problem with the objection process. There is no indication that how the deciding officer responds to the reviewing officer instructions would be reviewed, especially for compliance with NEPA. If this is an alternative that should have been fully developed, the project cannot proceed.
I don’t understand.. are you comparing objections to appeals or ??. We used to assume that forests would do what the reviewing officer instruction say…
The instruction here was “clarify the rationale,” but what if the rationale provided is not based on the facts in the record or is otherwise arbitrary and capricious? It’s not unusual to leave some discretion to the deciding officer about what to do in response, and there is no follow-up by the reviewing official that I’ve ever seen. Certainly no further opportunity for the public to object to the resolution of the issue (which sometimes could involve making changes in the decision).
I don’t remember appeals having this problem. It’s getting to be long ago, but when I wrote appeal decisions it was either go ahead or do it over. Unlike appeals, the objection process is prior to the decision, so making changes should be easier, but that’s not what I’ve seen. A small sample though, so other examples would be welcome.
I would also like to remind people that there are also road maintenance issues with Roadside Hazard Tree Projects. Ditches, culverts and waterbars can be functionally-impacted by falling snags. I’ve never understood the desire to have standing snags next to roads. What is the reasoning, there (officially, as per litigants)?