Sequoia ForestKeeper  works to effectively participate in the planning of our national monument and to help guide the Forest Service into creating a management plan that truly protects the Monument's resources; and to ensure that logging conducted in the Sequoia National Forest and National Monument (read the Proclamation) does not continue to destroy ecosystems, including logging under the guise of forest health, fuels reduction and resource management. Commenting and appealing on proposed projects affecting the Sequoia National Forest and Giant Sequoia National Monument is one of the key ways we participate in this process.

Ponderosa Urban Interface Project Appeal

April 6, 2009

Appellant respectfully requests that the Forest Service withdraw the decision being appealed and prepare an EIS to more fully investigate and disclose the environmental impacts and tradeoffs associated with this project. Other changes that we support include queuing the project until an acceptable Monument Management Plan has completed the NEPA process, non-removal hazard tree prescriptions, and prescriptions that protect communities by treating areas within 200 to 300 feet of structures per Forest Service fire science by Jack Cohen.  As discussed further below in this appeal, our primary proposal for this and future hazard tree projects is to cut down the hazard tree, thus rendering it harmless, then leave it behind to serve as habitat.  This is not only more environmentally sound, but also removes the conflict of interest in tree selection.

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Sequoia National Forest Travel Management DEIS Comment #2

April 1, 2009

Please accept, on behalf of Sequoia ForestKeeper, the following additional comments on the Draft Environmental Impact Statement (DEIS) associated with motorized travel management in the Sequoia National Forest. We appreciate the opportunity to work with the Forest Service to create a travel management plan that protects natural resources, minimizes user conflicts, and establishes an affordable, safe, ecologically sustainable, and enforceable motorized route system.

We find the DEIS to be inadequate in following all of the regulations established for travel management and in addressing the environmental impacts associated with the current and proposed transportation systems. We request that these deficiencies be addressed and resolved in a revised DEIS or that route designations be strictly limited, by choosing Alternative 5, with modifications described in the “Remedy” section below...

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Giant Sequoia National Monument Management Scoping Comment

May 4, 2009

Dear Ms. Emmendorfer; 

Thank you for providing the opportunity to comment on the Notice of Intent to develop a Giant Sequoia National Monument Management Plan and the Proposed Action.   

All of our previous comments, submitted to both the Forest Service or the Scientific Advisory Board, on how the Giant Sequoia National Monument should be managed and our previous appeal of the FEIS and Decision on the Management Plan for the Giant Sequoia National Monument are included herein, in their entirety, by reference. Since new scientific research has been published on many topics, our comments, the past work by the Forest Service, and the work of the previously assembled Scientific Advisory Board (SAB) may be superseded by new science. We recommend that an entirely new SAB be assembled to inform the Monument planning process.

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Bearskin Meadow Camp Renovation EA Comment

March 18, 2009

Dear Mr. Exline;

Thank you for the opportunity to comment on the Bearskin Meadow Camp Renovation Project.  In general, we support providing public facilities in the Monument, if they will protect the objects listed in the Proclamation, which is the overriding purpose of the Proclamation.  But decisions on proposed projects in the Monument should be deferred until a Monument Management Plan is in place.

Concerns about the Bearskin Meadow Camp Renovation Project EA

The project EA says,” new construction is required to harmonize with the landscape, utilize wood materials and muted colors, and landscape with native plant communities.” How will constructing with flammable wood materials in a fire adapted ecosystem protect public safety?

The EA says. “Presently, utilities are above ground, but with the replacement of the sewer lines, it is desirable to also route utility lines underground to increase safety and to improve the appearance of the Camp.” How will trenching four feet deep utility trenches through the root systems of the trees in the forest ecosystem further “the protective purposes of the monument?” Since the trees and the forest ecosystem are objects protected by the presidential proclamation, the potential impacts of the project must be analyzed in a full EIS. 

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Montecito Resort EA Comment

March 18, 2009

Dear Mr. Exline and Ms. Emmendorfer: 

Thank you for the opportunity to comment on the Montecito Lake Resort Expansion Project EA.  To begin with, and as we have commented in the past, decisions on proposed projects in the Monument should be deferred until a Monument Management Plan is completed.

Concerns about the Montecito Lake Resort Expansion Project EA

The project EA says, “The purpose of this project is to replace and/or upgrade the infrastructure including bathroom facilities, septic system, recreational facilities and visitor and staff accommodations to better meet current health and safety standards. To better accommodate the demand of people traveling from throughout the States and other parts of the world, the Resort needs to expand and offer additional rooms.”

How does the project “better meet current health and safety standards?”

This need for this project appears to be based in part on the demand of the international traveler. The world-wide demand for travel accommodations has drastically declined and this project should be analyzed in light of the economic down turn and collapse of international travel market...

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Second Joint Comment Letter about Piute Fire Restoration Project

March 16, 2009

On behalf of the John Muir Project of Earth Island Institute and Sequoia ForestKeeper, we are submitting this 2nd set of scoping comments for use in the proposed Piute Fire Restoration Project. We offer these comments in the interests of promoting greater scientific accuracy and ecological integrity in management decisions. The scientific comments herein relate to impacts to soil and hydrologic function from logging roads, landings, and removal of small diameter trees and related impacts such as grazing following restoration...

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Espinosa et. al. 1997.pdf

Baker fire, fuels, and restoration of Ponderosa Pine-Douglas Fir Forests.pdf

Bestcha et. al. 2004 Con Bio.pdf

Joint Comment Letter about Proposed Piute Fire Restoration Project

February 23, 2009

On behalf of the John Muir Project of Earth Island Institute and Sequoia ForestKeeper, we are submitting these scoping comments for use in the proposed Piute Fire Restoration Project. We offer these comments in the interests of promoting greater scientific accuracy and ecological integrity in management decisions. The scientific comments herein were provided by Dr. Chad Hanson. Dr. Hanson has a Ph.D. in Ecology from the University of California at Davis, where his research focus has been the role of fire in the ecology of Sierra Nevada forests. He has authored or co-authored several scientific studies on the subject of forest and fire ecology in the Sierra Nevada, including research into fire behavior, historic and current fire regimes, wildlife species dependent upon burned forest, and post-fire conifer survival.

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Ex. A - Clear Creek SFP Timber Sale Contract.pdf

Ex. B - Bond Declaration.pdf

Ex. C - Verner Declaration.pdf

Ex. D - Scientists Letter against Postfire Logging and Replanting.pdf

Letter in support of Halstead Meadow Restoration Project Grant

February 20 2009

Dear Ms. Demetry;

Thank you for providing the clarifying information about the Halstead Meadow restoration project and your comments about the inappropriateness of the ‘pond and plug’ method to restore Halstead Meadow, that you “are not proposing to implement the ‘pond and plug’ technique in lower Halstead meadow,” and that “Dr. David Cooper, who is designing the lower Halstead Meadow restoration, does not support the pond and plug technique either.”

All the evidence Sequoia ForestKeeper has seen from the Big Meadows experiment implemented in the Giant Sequoia National Monument indicates that applying ‘pond and plug’ to a mountain meadow produces massive sediment disturbance and water quality that does not supports life.

The historic paleontological resources found in high mountain meadow sediments should not be disturbed by ‘pond and plug,’ especially when there are proven and much less damaging and intrusive methods available. 

We have consulted with the Allen South Fork Wildlife Sanctuary and agree that the "point of origin," at the downstream limit of the meadow where sediment collection began originally, should be part of your proposed project with restoration beginning at that point in Halstead Meadow as Daniel Christensen’s letter of support states.

Sequoia ForestKeeper’s mission is to protect and restore the ecosystems of the southern Sierra Nevada and to protect all natural features. If, as we understand it, your proposal is to bring Halstead meadow back to being as close as possible to its natural condition, that you will not be digging holes in the meadow, and that you will be protecting the historical paleontological sediments, Sequoia ForestKeeper supports your project.

I would like to visit with Dr Cooper when he reviews his procedure. Please notify us when that opportunity will occur, so we can participate in Dr. Cooper’s explanation. 

I would also like to be placed on the list to receive notice and copies of scoping for all vegetation management and restoration projects proposed for implementation in Sequoia and Kings Canyon National Parks, so we can submit comments in a timely manner.  We are especially interested in commenting on projects like those that propose to remove trees, such as so-called hazard trees, or propose to restore meadows.

Thank you for your efforts in this regard. 

Respectfully submitted,

Mr. Ara Marderosian, Executive Director

DFG Plan to Move Pacific Fisher Comment

February 19, 2009

I am writing to express my concerns and opposition to your issuance on January 9, 2009 of a Notice of Intent to Adopt a Negative Declaration, signifying that there are no significant environmental impacts from the Sierra Pacific Industries (SPI) proposal to reintroduce fishers to Sierra Pacific Industries’ Stirling Management Area located between Quincy and Chico in the northern Sierra Nevada.

The proposal would release 40 Pacific fisher, captured from private and public lands in northwestern California, over a period of three years. At the same time, Sierra Pacific Industries (SPI) would be issued a permit from the U.S. Fish and Wildlife Service, assuring the company that if the fisher is listed under the Endangered Species Act, as expected, SPI will be granted immunity from any additional conservation measures resulting from the listing for a period of 20 years.

The proposal has the potential for significant long-term impacts, and should be withdrawn until a suitable site for fisher reintroduction can be determined. The SPI lands that are proposed for the transplantation are not suitable for fisher. Other lands—on national forest lands adjacent to the proposed area to the east—are much more suitable, and would not require sacrificing the requirements of the Endangered Species Act to accommodate SPI.

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Alta-Oak Creek Mojave Project; Zone Change Case No. 40, Map 197 – Comment #2

January 25, 2009

Dear Mr. James;

Below is comment number two on the Notice of Preparation for the Alta-Oak Creek Mojave Project CBM 19-08; Alta-Oak Creek Mojave Project; Zone Change Case No. 40, Map 197 Draft EIR.  PROJECT LOCATION: 3 miles west of State Route (SR) 14 (Antelope Valley Freeway) and 3 miles south of SR-58, in the Oak Creek area of eastern Kern County; Section 2, T10N, R13W; Sections 15, 19 through 23 and 27 through 35 of T11N, R13W; and Sections 5, 6, 8, 10, 15, 16, 17, 20, 25, 27, 29 and 36 of T11N, R14W, San Bernardino Base and Meridian

The applicant, Alta Windpower Development, LLC, proposes to develop the Alta-Oak Creek Mojave Project (proposed project or project) for the commercial production of up to 800 Megawatts (MW) of electricity from wind turbines. The applicant is requesting a change in zone classification to WE Combining District on approximately 2,480 acres in order to allow for the construction of up to 350 wind turbine generators (a maximum of 500 feet in height) which would generate approximately 600 to 800 MW of electricity, their ancillary facilities and supporting infrastructure.

Concern about the Potentially Significant Impact to Biological Resources

One of the cumulative impacts to be considered is the cumulative impact on biological resources from all Tehachapi area wind farms. This Alta-Oak Creek Mojave Project would further diminish, fragment, and displace the vegetation and wildlife left in the area.

Conclusion

We recommend that Kern County not approve this plan change or approve the project until all federal and state permits are obtained and, subsequently, an EIR is developed, which considers the cumulative impacts that could lead to the loss of biodiversity, the potential failure of the structure, and other possible harms to the human population and environment.

Please incorporate these comments, suggestions, concerns, and recommendations into the EIR.  Please keep me and the following individuals and organizations on the mailing list for all distributions, meetings, and actions proposed for this plan change and project. Thank you for considering these issues of greatest concern.

Western Divide Recreation Site Improvement Project Comment

January 20, 2009

This action must not occur except pursuant to an EIS that has been written. There is no GSNM Plan and EIS to provide standards and guidelines and the desired future condition for the Monument or to address where and when improvements to recreational facilities may be made inside the monument particularly inside a sequoia grove.  There is no published, peer-reviewed scientifically determined definition of a giant sequoia grove or the definition of the grove boundary, which would be required before knowing how a project that would trench through a grove or pave in a grove might impact the grove. There must be a full disclosure of exactly what and where such activities will occur. Please provide a site map showing the engineering, the proximity to riparian areas, the permeability of the soils, the drainage patterns, what specimen or other sequoias are involved, the impacts of toxics and trenching, the increased use such 'improvement's might incur and the impacts of that effect.    

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80's Mining Plan of Operations Comment

January 15, 2009

The 80’s Mining Plan of Operations (PoO) lacks any detailed explanation of the current resources in the project area and the watershed in which the project proposes to be implemented and lacks any detailed explanation of how it would comply with the requirements for protecting public lands and resources. The PoO is vague and unspecific about how it would function and mentions some operational steps that could lead to resource damage. Because this PoO fails to demonstrate or elaborate on how it would protect public lands and resources, there is a possibility that public lands and resources could be damaged by implementation of this project, and for the reasons set forth below, we believe a full EIS must be developed to analyze a full range of feasible alternatives for protecting public lands and resources and complying with federal and state laws, regulations, and requirements.

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JMP-SFK Piute Roadside Hazard Scoping Comments

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December 19, 2008

I am submitting these scoping comments for the proposed Piute Fire Roadside Hazard Removal Project on behalf of the John Muir Project of Earth Island Institute (JMP) and Sequoia ForestKeeper (SFK), in the interests of promoting greater scientific accuracy, ecological integrity, and public oversight in management decisions.

Many of the scientific publications cited herein have been posted on the Forest Service’s FTP site at ftp://ftp2.fs.fed.us/incoming/r5/Sequoia/Piute_Hazard_Tree_Scoping/Scientific_Reports and should be included in the project record...

Ex. A - Final_ReforSalvRpt_08-29-08.pdf

Ex. B - Moonlight Joint Stipulation.pdf

Ex. C - Moonlight Hazard Felling Report.pdf

Ex. D - MD-011 Disposition of Down Wood.pdf

Ex. E - Hazard Tree Procedures - Sequoia NF (2004).pdf

Ex. F - Scientists Letter Against Postfire Logging & Replanting.pdf

Ex. G - Wilson (1999).pdf

Ara's Declaration of the logging in Trail of 100 Giants

October 30, 2008

I, Ara Marderosian, declare as follows.

1.         I am a resident of Weldon, California 93283-0988 and have been involved in monitoring forest management on the Sequoia National Forest for 12 years.  In 2000, I founded a conservation organization, Sequoia ForestKeeper, and have been its executive director for 8 years.  I have also been a member of the John Muir Project of Earth Island Institute since we jointly pursued judicial review of the Burnt Ridge timber sale in 2003.

2.         President Clinton signed the Presidential Proclamation creating the Giant Sequoia National Monument (GSNM) out of the Sequoia National Forest on April 15, 2000.  The signing ceremony was held in the premier tourist area within the GSNM, the Trail of 100 Giants, which is within a giant sequoia grove.  The Proclamation stated that the purpose of the newly designated monument is to protect the Sequoia forests and end logging for timber.

3.         The Fresno Bee of April 25, 2004 announced that there will be a meeting with professional foresters held in the parking lot at the Trail of 100 Giants on Thursday April 29, 2004 to discuss hazard trees.  At the April 29, 2004 Forest Service meeting in the parking lot of the Trail of 100 Giants, the Forest Service stated their intention to fell “hazard” trees along the Trail of 100 Giants.  They also announced that they intend to close the Trail of 100 Giants throughout the summer of 2004. I asked for data and documentation on the project, but received nothing. The Order to close the trail was posted on April 30, 2004.

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Comment Letter on Tule River Reservation Protection Project

September 24, 2008

The Forest Service should not conduct fuel reduction within the Black Mountain Grove, or any other grove, without first preparing a Monument Management Plan.  The Mediated Settlement Agreement (MSA) contains strong language regarding preparation of a grove specific management plan and fuel load reduction plan.  These plans must employ the most environmentally sensitive methods available to preserve, protect, restore and regenerate the Giant Sequoia Groves, without damage to trees in the Grove.  The Forest Service must disclose, in detail, existing and future conditions of the Black Mountain Grove in light of the proposed action.  This analysis should address the cumulative impacts of the proposed action as well as all past, present, and foreseeable future actions on all other groves in the monument. 

The NOI scoping document says “The proposed project area is approximately 1,574 acres on National Forest lands and is located along the northern boundary between the Sequoia National Forest, Giant Sequoia National Monument, and the Tule River Indian Reservation. The project is bounded by Forest Service Roads (FS) 21S12 on the west and north, FS 21S94 on the east, and the boundary between the Sequoia National Forest and the Tule River Indian Reservation on the south (see enclosed map). The legal description for the project area is T215, R3OE, Sections 1, 12, 13, 14,15, 16; andT2lS, R31E, Sections 3,4,6,7,8,9,10, 15, 16, 17 and 18. Elevations in the area range from 4,800 to 7,000 feet, The project area encompasses portions of the Black Mountain Giant Sequoia Grove, planted conifer stands, mixed conifer forest, Montane chaparral, and private lands.” This statement fails to disclose that implementation of the project would extend beyond 21S12 to the west and north.

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Comment Letter on Ponderosa Urban Interface Project EA

July 26, 2008

Thank you for the opportunity to comment, again, on the Ponderosa Project as proposed in the July 15, 2008 Preliminary EA (PEA). 

The purpose of Sequoia ForestKeeper (SFK) is to protect and preserve the natural environment of the Sequoia National Forest, and especially to prevent any excessive or unnecessary logging.  As such, we are very concerned about the Ponderosa Urban Interface Project (formerly titled Ponderosa Fuels Reduction WUI Project).  While we thank you for the effort to respond to some of the issues we raised in our scoping comments, we herein reiterate those concerns.  As described below, some of the responses were inadequate and there are others with which we disagree, a number of concerns that need to be addressed, and a number of questions that need to be answered.

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Comment Letter on Fox Meadow Plantation Thinning Project scoping

June 23, 2008

Thank you for the opportunity to comment on the Fox Meadow Plantation Thinning Project scoping.  We support projects that would prevent catastrophic wildfire.  We support projects that protect wildlife habitat.  As set forth below, we suggest the Fox Meadow Plantation Thinning Project scoping be modified to reduce the compaction that would result from implementation, as proposed.

On May 23, 2008, the Forest Service disclosed the scoping document for the Fox Meadow Plantation Thinning Project, which is included herein in its entirety, by reference. The Forest Service disclosed in the scoping document that the Fox Meadow Plantation Thinning Project would reduce fuels with heavy equipment known as a masticator on 290 acres of plantations in the vicinity of Fox Meadow.

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Comment Letter on Clear Creek Revised EA

May 30, 2008

Thank you for the opportunity to comment on the Revised EA for the Clear Creek Forest Health Fuels Reduction Project.  We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately surrounding structures.  As set forth below, we oppose the Clear Creek Forest Health Fuels Reduction Project on a number of bases and ask that the project be withdrawn as written.  

We are concerned with the Revised EA for the Clear Creek Forest Health Fuels Reduction Project because the language, as cited below, indicates that the EA fails to adequately consider the cumulative impacts to the forest ecosystem, the wildlife habitat, and the human environment. The Forest Service many times claims it does not have to obey the law, because there were no comments indicating the law should be followed.  Therefore, we wish to raise the issue that all laws that apply to the project need to be followed whether mentioned in this letter or not. 

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Comment Letter on Coy Flat Land Exchange Scoping

April 15, 2008

Please address the following concerns and information in the environmental assessment for this project:

 1.      Please provide clear maps—this is truly critical to our understanding many aspects of the proposed exchange. These should clearly show the location and configuration of the federal and non-federal lands and, in particular, their relationship to other ownerships (state, private, federal) and other major features such as roads. Including topographic characteristics in the maps would also be helpful to our understanding of the project.

2.      Please provide a thorough description of the environmental characteristics of all the lands involved.

 3.      Please provide some characterizations or evaluations of the potential for development to occur on the private inholdings in or adjacent to the groves if they are not traded to the public.

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Comment Letter on Vista Fire Restoration Salvage and Hazard Tree Project

February 29, 2008

We are concerned about removing trees, because for all times of day, except at high noon in mid summer, when the sun is at an angle to true vertical, burned trees provide a tremendous amount of shade for the ground and for bodies of water. Shadows that cover 30 percent of the ground between 2:00 and 4:00 PM, in the Vista Fire area of the burned forest, would provide protection from the sun for natural and planted seedlings.

We believe that this project would increase the temperature of the forest, for the particular areas where natural and planted seedlings will exist, and for water flowing through the forest by removing the burned trees that currently provide some shade for the project area, including streams, springs, fens, and bogs and riparian areas. The EIS for this project must present evidence that such an increase in ground, air, and water temperature would not adversely affect the beneficial uses. 

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Comment Letter on Revised Ponderosa Fuels Reduction Project Scoping

February 26, 2008

Thank you for the opportunity to comment, again, on the Ponderosa Project as proposed in the December 19, 2007 scoping document and revised on February 7, 2008.  Your revised scoping document indicates that “comments received from the March 1, 2006 and the December 19, 2007 letter will still be maintained and considered.” We submitted comments then and we expect that appropriate comments from those letters to be considered in addition to those comments and questions found below.  

The proposed revised Ponderosa Project has one component that we can support, a number of concerns that need to be addressed, and a number of questions that need to be answered.  The information provided in the Ponderosa Project scoping documents is inadequate and insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the revised Ponderosa Project scoping documentation provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information.  In addition, we request that all laws applicable to this project be followed whether mentioned in this letter or not.

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Comment Letter on Ponderosa Fuels Reduction Project Scoping

January 25, 2008

The proposed Ponderosa Project has one component that we can support, a number of concerns that need to be addressed, and a number of questions that need to be answered.  The information provided in the Ponderosa Project scoping documents is inadequate and insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the Ponderosa Project scoping documentation provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information.  In addition, we request that all laws applicable to this project be followed whether mentioned in this letter or not. 

We are concerned because similar projects in the Camp Nelson area were very damaging, no standards were established, the EA/Decision Notice was not followed, and an outside fire crew carried it out even though they didn't understand what was wanted.  We have concerns regarding the potential effects of the actions proposed, as described below.

            We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately adjacent to and surrounding structures.  (Wildland Fire Threat to Homes; Where and How Much” by J. Cohen)   As set forth below, we oppose the Ponderosa Project on a number of bases and suggest that the project be postponed or severely narrowed.

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GSNM Proclamation Statement on the Primacy of Protection and Ecological Resoration in Future Monument Management Decisions

January 9, 2008

To: Carie Fox, Fox Mediation

In preparation for the next public meeting on recreation use in the Giant Sequoia National Monument, we are writing to ask your help in assuring that the essential requirements of the monument proclamation be kept firmly in mind by all participants.  Recreation, of course, receives special attention in the proclamation.  We agree with and support that.  Most monument visitors, often including us and our groups’ members, come at least in part for recreation.  You, of course, are aware that the proclamation also places important, mandatory, qualifications on recreational use.  Because, however, some meeting participants may not be so well-versed in the proclamation’s terms, we think it will be important to help communicate to them this background for their discussions. 

Most fundamentally, while it directs, appropriately, that management “provide for and encourage continued public and recreational access and use,” the proclamation requires that all such use be “consistent with the purposes of the monument.”  The purposes of the monument, by statute, are the care and management of “objects of historic or scientific interest.”  Thus recreational uses must be thoroughly examined in light of the monument’s over-riding purposes of protection, preservation, and restoration.  To meet this standard, decisions to allow recreational activity need to show clearly that they do not, in any way, set back these fundamental goals.

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Shirley Meadows Snowmaking Appeal

Nov. 11, 2007

Pursuant to 36 C.F.R. § 215.14, Sequoia ForestKeeper hereby appeals the decision to proceed with the Shirley Meadows Snowmaking Project because the Decision Memo neglects important issues described below and jeopardizes the ecological health and integrity of the Sequoia National Forest. See also Earth Island Institute v. Ruthenbeck, 490 F.3d 687 (9^th Cir. 2007) (invalidating the 36 C.F.R. § 215.12(f) exemption of categorically excluded projects from appeal).

Appellant respectfully requests that the Forest Service withdraw the decision being appealed and prepare an EIS to more fully investigate and disclose the environmental impacts and tradeoffs associated with this project. Another change that we strongly support (and argue below is required) is analyzing the entire Shirley Meadows Ski Area Master Development Plan in one EIS, rather that considering the snowmaking separately from related impacts.

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Hume Lake Roadside Hazard Tree Salvage Project Appeal

Nov. 2, 2007

Pursuant to 36 C.F.R. § 215.14, Sequoia ForestKeeper hereby appeals the decision to proceed with the Hume Lake Roadside Hazard Tree Salvage Project because the Decision Memo neglects important issues described below and jeopardizes the ecological health and integrity of the Sequoia National Forest. See also Earth Island Institute v. Ruthenbeck, 490 F.3d 687 (9^th Cir. 2007) (invalidating the 36 C.F.R. § 215.12(f) exemption of categorically excluded projects from appeal).

Appellant respectfully requests that the Forest Service withdraw the decision being appealed and prepare an EIS to more fully investigate and disclose the environmental impacts and tradeoffs associated with this project. Other changes that we support include queuing the project until an acceptable Monument Management Plan has completed the NEPA process, non-removal hazard tree prescriptions, and prescriptions that do not include a timber sale component.  As discussed further on page 6 of this appeal, our primary proposal for this and future hazard tree projects is to cut down the hazard tree, thus rendering it harmless, then leave it behind to serve as habitat.  This is not only more environmentally sound, but also removes the conflict of interest in tree-selection.

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Comment Letter on Montecito Lake Resort Expansion Project

October 20, 2007

Thank you for the opportunity to comment on the Montecito Lake Resort Expansion Project.  To begin with, and as we have commented in the past, decisions on proposed projects in the Monument should be deferred until a Monument Management Plan is completed.

In general, we support providing public facilities in the Monument, if they will protect the objects listed in the Proclamation, which is the overriding purpose of the Proclamation.  The Giant Sequoia National Monument was created “for the purpose of protecting the objects” identified in the Proclamation, and “all lands and interests in lands. . . within the boundaries of the . . . Giant Sequoia National Monument.”  The Presidential Proclamation also states that, “The Secretary of Agriculture shall prepare, within 3 years of this date, a management plan for this monument, and shall promulgate such regulations for its management as deemed appropriate.”

 The purpose of having a management plan in place is to provide us with guidance in dealing with decisions such as the one before us here.  It seems unwise to allow development in the Monument while such a plan is not yet in place.  We recommend that no expansions of facilities or increases of lands under special use permit on the Giant Sequoia National Monument should occur until after a Final GSNM Plan is in place; this Plan should spell out the standards and guidelines for the types of uses that are compatible with the Monument’s purposes as set forth in the Proclamation.

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Letter on Logging in Golden Trout Wilderness

Sept. 25, 2007

I am writing to inform you of an unfortunate series of events that has taken place in the Sequoia National Forest and Inyo National Forest this year, specifically in the Golden Trout Wilderness area (GTW).  One error has built upon another, leading to extensive damage along the trails in the wilderness.  Although this damage has already been done, my hope in sending you this letter is that we may shed some light on how this happened and thereby prevent any reoccurrence.  I will share with you in this letter the information that I have, and would greatly appreciate a written response advising us regarding what steps you have taken and/or will take to prevent this from happening again.  I realize that you are going to retire next week, so I would greatly appreciate it if you would pass this on to Randy Moore when you do, but am directing it to you in the hope that you will have an opportunity to respond sooner. 

            On May 14, 2007, Forest Supervisor Tina Terrell signed an authorization to use motorized equipment, specifically chainsaws, to clear trails in the GTW.  Her authorization letter is attached to the same email as this letter.  In late summer of this year this chainsaw work was done, and trees were cut down to great distances off either side of the trail, ranging from ten to twenty feet, which was not necessary to serve any of the values set forth in the Wilderness Act.

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Proposed PSW MIS Amendment Comment Letter

July 23, 2007

In general we are concerned that the proposed changes to MIS monitoring will erode the significant impacts analysis for future projects by emphasizing the broad, forest-wide scale over project level monitoring. This is a problem the courts have identified as plaguing NEPA analysis. The Forest Service must consider the impacts of future projects at the project level and may not downplay the affects of a project on a species simply by looking at the effects from the forest-wide scale. See Klamath-Siskiyou Wildlands Center v. Bureau of Land Management 387 F. 3d 989, 994 (9^th. Cir. 2004).  Furthermore, the 10^th Circuit reads MIS regulations to require project level monitoring. See Utah Environmental Congress v. Bosworth, 372 F.3d 1219, 1225 (10th Cir. 2004).  These decisions call into question the propriety of this amendment, which is largely motivated by a desire to conduct generalized forest-wide monitoring.  

The dangers of over-broad monitoring are already evident in the proposed action, such as the elimination of monitoring of peripheral critical habitat (e.g. bald eagle habitat,) state protected species (e.g. Tule elk) and entire habitat types such as lodgepole pine forests. Project level data is valuable and in our experience, often the only scale at which species data is actually gathered.

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Scodie Mountain North Grazing Comment Letter

June 18, 2007

Thank you for this opportunity for Western Watersheds Project and Sequoia ForestKeeper to provide scoping comments as the Kern River Ranger District of the Sequoia National Forest considers whether to authorize continued livestock grazing on these allotments under current management or to defer any action at this time.

 We have reviewed the proposal and accompanying maps for the Scodie Mountains North Grazing project.  We have the following information relating to this project that indicates that the proposed action may cause significant environmental effects.  Please incorporate our comments in planning for the proposed grazing activities on the Smith Canyon and the Jack's Creek Allotments.

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Blackrock Hazard Tree Comment Letter

June 14, 2007

Although we would prefer that the Forest Service forgo the cutting of hazard trees entirely, leaving nature in its natural state and warning the public of the dangers inherent in a wilderness environment, we recognize that there is a value to the public in eliminating any truly imminent dangers.  That said, our primary concern with hazard tree removal projects is that they are not narrowly tailored to cause the minimum amount of harm to the forest necessary to protect the public from realistic dangers.  Indeed, to do so would require the focus to be entirely on that protection, without regard to providing timber to logging interests.

             Because our concern is based on prior experience observing far more trees cut than necessary, we would like to be as informed as possible throughout the implementation of this project.  During our visit to the site we were unable to locate 350 marked trees, leaving us uncertain as to all of the trees to be cut.  Worse, however, was the fact that many of those trees that were marked did not appear to be hazard trees at all.  In some cases, only the very tops of the trees (about 8 feet or so) were dead, and those were very weathered to suggest they had been that way for some time and posed no imminent danger.  One of the trees we observed had a black-back woodpecker living in a hole in the top of the tree - it took a long time for this bird to create a nest in that tree.

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Big Meadows Improvement Project Draft Memorandum Comment Letter

June 1, 2007

We have read your draft memorandum describing the proposed pond and plug project at Big Meadows, and we do not believe that this project is necessary or natural as it is presently planned.  We recognize that there is a desire to repair damage in the area, but submit that there are better and more natural methods for doing so.  Because we agree with the comments filed by Richard Kangas, we are including portions of them herein, along with some additional comment of our own. 

            Pond and plug methods are extremely invasive no matter your expressed expected outcome.  Heavy tractor work along more than a mile (6,100 feet) of streambed and building a dam at the lower end of the meadow are not “normal practices” as you imply in your cover letter.  Since this project would be within the Giant Sequoia National Monument (GSNM) and because it would dig ponds, fill other areas, install downed trees in waterways, plant trees in the meadow where none exist, alter flows in a major meadow and stream (both within and beyond the meadow), and affect the fauna and flora within and beyond the meadow, you must write a full Environmental Impact Statement (EIS) and not simply assume the Forest Service Handbook concepts of “normal practices” covers this extraordinary case under categorical exclusion.

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Greeley Pasture Grazing Allotment Project Comment Letter

May 29, 2007

Thank you for providing the opportunity for the public to comment on the Greeley Pasture Grazing Allotment Project.  This comment letter contains general comments on the Greeley Pasture Grazing Allotment Project since the scoping document provided few details about the project.  In general, we are in favor of projects that would return damaged forest, oak woodland, and pasture areas to natural conditions.   

The information provided in the Greeley Pasture Grazing Allotment Project scoping letter (Greeley Pasture Grazing document) is insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the Greeley Pasture Grazing document provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information and toured the project area.  The Forest Service many times claims it does not have to obey the law, because there were no comments indicating the law should be followed.  Therefore, we wish to raise the issue that all laws that apply to the project need to be followed whether mentioned in this comment letter or not. 

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Hume Lake Roadside Salvage Project Comment Letter

May 3, 2007

...We are very concerned about the Hume Lake Roadside Salvage Project (formerly titled Hume Lake Roadside Hazard Tree Removal).  While we thank you for the effort to respond to some of the issues we raised in our scoping comments, we herein reiterate those concerns.  As described below, some of the responses were inadequate and there are others with which we disagree. 

            Although we would prefer that the Forest Service forgo the cutting of hazard trees entirely, leaving nature in its natural state and warning the public of the dangers inherent in a wilderness environment, we recognize that there is a value to the public in eliminating any truly imminent dangers.  That said, our primary concern with hazard tree removal projects is that they are not narrowly tailored to cause the minimum amount of harm to the forest necessary to protect the public from realistic dangers.  Indeed, to do so would require the focus to be entirely on that protection, without regard to providing timber to logging interests.

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Proposed Changes to Management Indicator Species Comment Letter

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Shirley Meadows Ski Area Master Plan Snowmaking Project Comment Letter

March 23, 2007

...We are concerned about the Shirley Meadows Ski Area Master Development Plan and the associated Snowmaking Project for two main reasons. First, we were not sent scoping for the issuance of a Winter Recreation Resort Special Use Permit to Shirley Meadows Incorporated and we found no record of the publication of scoping in the file for this project even though we found a record of the Decision that approved the Winter Recreation Resort Special Use Permit to Shirley Meadows Incorporated.  Second, the Forest Service is ANALYZING AND APPROVING each separate stage separately and not looking at the entire Shirley Meadows Ski Area Master Development Plan in one NEPA document. There is this Shirley Meadows Ski Area Master Development Plan that the lessee wants to eventually carry out, so the impacts of that master plan need to be addressed. The Forest Service can't pretend the full build out plans do not exist. By separating the project into components, the Forest Service never addresses the real impacts to the affected environment. NEPA insists that a project not be subdivided for purposes of analysis of impacts.

Also, by allowing the developer to proceed with beginning steps to full build out, the Forest Service is implying that the developer will be allowed to continue because the agency is allowing the developer to put his money into what amounts to the foundation for the full project. The Forest Service will believe it is compelled to approve subsequent requests for further build-out of the master plan, because the agency has let the developer start or let the developer go further...

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Clear Creek Forest Health Improvement and Fuels Reduction Project APPEAL

 March 21, 2007

  ...Appellant respectfully requests that the Forest Service withdraw the decision being appealed and prepare an EIS to more fully investigate and disclose the environmental impacts and tradeoffs associated with this project. Other changes that we support include applying a 9 inch diameter cap for fire resilient species, and a 12-14 inch diameter cap for fire intolerant tree species; retaining all large snags; implementing the project as a variable density treatment, with skips and small gaps...

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Hume Lake Roadside Hazard Tree Project Scoping Comment Letter

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Johnsondale Reforestation Project Comment Letter

March 15, 2007

Dear Ms. Summers;

Thank you for the opportunity to comment on the proposed Johnsondale Reforestation Project.  To assist the Forest Service in identifying and considering issues and concerns on the proposed action, we are providing comments that are as specific as possible given the lack of data and specific information provided in the scoping document.   

We support projects that would restore forest health. As set forth below, we oppose the Johnsondale Reforestation Project on a number of bases.

The information provided in the Johnsondale Reforestation Project scoping letter is inadequate and insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the Johnsondale Reforestation Project scoping documentation provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the additional and missing information from the Forest Service. 

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North Road Hazard Tree Project Scoping Comment Letter

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Recreation Site Facility Master Planning 5 Year Work Project Comment Letter

February 27, 2007

Dear Mr. Handley: 

            The purpose of Sequoia ForestKeeper (SFK) is to protect and preserve the natural environment of the Sequoia National Forest, as well as to encourage public appreciation and enjoyment of its natural beauty.  As such, we are very concerned about the proposed 5-year program of work affecting recreational use of the forest.

             The proposal to decommission or reduce more than half of all the campgrounds is of great concern to us.  Recreational use is one of the purposes of the forest and brings in significant revenue.  While it may be possible to maximize the economic benefit from the ratio between revenues and expenses by having fewer campgrounds, to do so is to treat the forest as a business purely for profit.  It ignores the need for facilities in a greater number of locations and seeks to concentrate concessions into fewer locations to save money, while still spending significantly more on logging and other projects.

             We write primarily to oppose the mass closing of campgrounds, as explained below, but would like to express special concern over one in particular: Redwood Meadow.  This campground is one of the two closest to the extremely popular Trail of 100 Giants (the other is Long Meadow, which we are also concerned about though it is less-frequented).  Redwood Meadow is a very popular site, and we cannot understand why it would be reduced to a mere parking lot.  Our organization promotes public awareness of giant sequoias, and the Trail of 100 Giants is an important contributor to that goal.  Not only would this conversion result in the loss of a very important campground, but the $5 parking fees are also a deterrent to visitors, who should be welcomed to the Trail.

             There are two most significant reasons for our concern regarding the environmental impact of the proposed reduction in campgrounds.  First, this will lead to even further privatization of camping concessions, thus placing more forest land in the hands of less accountable decision-makers (indeed, some such hand-overs are even described in the proposal).  Second, fewer developed campgrounds will lead to more offsite camping, which creates both environmental and public safety problems.

             Privatization of campgrounds will lead to fewer campgrounds, each larger and more densely packed, as opposed to the environmentally preferable scattering of smaller campgrounds.  This is because private campgrounds will be planned solely based on potential for profit rather than respect for the forest environment.  It will also lead to higher prices for consumers, thereby excluding those from lower socioeconomic classes (whose children might best benefit from experiencing nature).  Privatization allows the Forest Service to pass on a very important responsibility to private corporate interests, which is not in the best interests of either the forest or the public.

             With regard to the second concern – an increase in people camping offsite – there are many reasons why this is problematic.  There is simply no way to ensure that people will restrict themselves to environmentally safe behaviors outside the rule-oriented structure of official campgrounds.  People will drive further off-road, causing damage to the flora and potentially killing wildlife.  They will clear away areas to set up camp, thereby altering the ecosystem.  Without toilets human fecal matter will be introduced into the watershed in greater quantity, causing both environmental harm and health risks to people and wildlife.  The lack of fire rings will not prevent people from building campfires, creating a significant risk of wildfire.

             Not only do diverse and plentiful campgrounds encourage recreational use of the forest, which is one of the purposes of public land, but they also discourage irresponsible behaviors by recreational users.  We believe that the significant funds that have been earmarked for maintenance of recreational facilities be used for this purpose, allowing most (if not all) of these campgrounds to stay open.  The Giant Sequoia National Monument was created, in part, to protect and enhance recreational opportunity.

             In making the decision to close or modify so many campgrounds, were the cumulative impacts of doing so considered?  This should be taken into account during the upcoming NEPA process (clearly such a major action as this will require an EIS). Because the Sequoia National Forest Land and Resource Management Plan is the plan by which forest resources, including recreation, are to be managed, how does the RSFMP comply with this forest management requirement?

              Finally, we would like to ask whether any trees will need to be cut during the process of converting campgrounds into concentrated use areas.  This question should be addressed in any future documents discussing these plans, especially any NEPA documents.

McKenzie WUI Fuels Reduction Project Comment Letter

Dear Mr. Exline,

Thank you for the opportunity to comment on the McKenzie WUI Fuels Reduction Project.  In general, we support fuels reduction projects implemented within 200 feet of structures, because scientific research indicates that such projects would protect communities. But decisions on proposed projects in the Monument that propose fuels treatments, including tree removal, beyond 200 feet from structures should be deferred until a Monument Management Plan is in place. The court that declared the Monument management plan to be illegal agrees that hand thinning of trees less than ten inches in diameter adjacent to communities pursuant to a service contract would be acceptable for the court until a legal management plan is approved...

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Bearskin Meadow Camp Renovation Project Comment Letter

Dear Mr. Exline,

Thank you for the opportunity to comment on the Bearskin Meadow Camp Renovation Project.  In general, I support providing public facilities in the Monument, if they will protect the objects listed in the Proclamation, which is the overriding purpose of the Proclamation.  But decisions on proposed projects in the Monument should be deferred until a Monument Management Plan is in place...

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Tule River Grazing West Comment Letter

Dear Ms. Summers: 

Thank you for the opportunity to comment on the revised Environmental Assessment (revised EA) for the Tule River West Grazing Project that includes management proposals for the North Grouse, South Grouse, Grouse Valley, Rancheria, East Bear, West Bear, Middle Tule, Cow Mountain, and Black Mountain grazing allotments, on the Tule River Ranger District of Sequoia National Forest.

The following comments are submitted on behalf of Sequoia ForestKeeper, the Center for Biological Diversity, the Sequoia Forest Alliance, the Tule River Conservancy, the Kerncrest Audubon Society, Forest Forever, the Sequoia Task Force of the Sierra Club, Western Watershed Project, Forest Guardians, and Ronald J. and Carol Holmes Wermuth, and our members nationwide and in California who are affected by public lands management. Our members use our National Forests and the Giant Sequoia National Monument for a variety of recreational, spiritual, scientific, and aesthetic purposes and are impacted by livestock grazing and the degradation of the resources that results from this use. We are commenting on procedural and substantive issues that the EA failed to consider and address.

We are pleased that the EA addresses two of the problem areas where livestock grazing has drastically impacted the habitat and one area where a species requires protection from grazing in order to survive. We appreciate the fact that the District Ranger has chosen to address those areas of concern and to specify remedies in this revised EA that could address those specific impacts in these allotments that require attention.

However, our concerns are for protecting the entire Giant Sequoia National Monument and the failure of the EA to address the overwhelming scientific research cited in our previous submissions and appeal for this project, which are included herein in their entirety, by reference, which confirms that livestock grazing is harmful to the ecosystem in which it has been implemented. This revised EA fails to provide evidence to prove that every other location except for the three that are identified as being out of compliance in these allotments is in compliance.

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Blackrock Hazard Tree Removal Project Scoping Comment Letter

Dear Mr. Freeland;

 Thank you for the opportunity to comment on the Blackrock Hazard Tree Removal Project proposed for implementation on the Kern Plateau of Sequoia National Forest.  An eighteen-day comment period for the public review period is insufficient for an adequate review.  Fifteen days is insufficient time for receiving comprehensive public input. Your letter indicates that public comments and input into this process are very important, but 15 days is insufficient time to have a letter delivered by US Postal Service and still give sufficient time for a comprehensive comment.

“The Forest Service is seeking comments on this proposed action and to be informed of any unusual situations or extraordinary circumstances that may lead this proposed action to cause significant environmental effects.”

Unless the Forest Service is not interested in receiving public comments, a minimum of 30 days must be provided for the public to submit input.  We request that this comment period be reopened and 30 more days be given for public comment.

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Big Meadows Creek Watershed Improvement Project Scoping Comment Letter

Dear Mr. Exline:

 Thank you for the opportunity to comment on the Big Meadow Creek Watershed Improvement Project scoping.  We support projects that would restore creeks and meadows damaged by past livestock grazing and logging.  As set forth below, we suggest the Big Meadow Creek Watershed Improvement Project scoping be adjusted to reduce the compaction that would result from implementation, as proposed. We would like more complete information and a tour of the project area to understand the scope of the project.

 On March 22, 2006, the Forest Service disclosed the scoping document for the Big Meadow Creek Watershed Improvement Project, which would “cut and fill . . . approximately 13,150 cubic yards of existing gullies to eliminate the downcutting, 16 lodgepole pines (< 30 inches diameter) would be uprooted from a designated 23-acre area along the southern margin of Big Meadows, uprooting and hauling would be accomplished mainly using crawler type, machinery with the haul route approximately 0.3 miles, or 200 feet, across the upper dry terrace in the southern part of the meadow to restore 6,100 feet of degraded stream within the meadow to enhance aquatic species habitat while maintaining existing land uses including recreation and grazing.” The project proposes to use a method called "pond and plug".

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Frandy Park Expansion Conditional Use Permit Request Comment Letter

Dear Mr. James:

...This property is of particular interest because it is in the view shed of Riverside Park in the center of Kernville and along the sensitive Wild and Scenic Kern River. This property is one of the first view sheds that visitors see upon entering the town of Kernville. Since the Kern River has been designated as a Wild and Scenic River, it is deserving of greater protection. How does the designation effect this expansion – is it honoring this designation?

A number of questions still remain unanswered due to the lack of clarity of the information provided for this project, including the following questions.

 1.  Are the three rafting companies in question currently operating out of this location?

2. How many additional persons will this project bring, due to the 64 tent sites,30 RV sites, and parking spaces for 176 vehicles?

3. Will this project pave the parking spaces or just the roads?

4. How can a Conditional Use Permit allow the permanent retention of a whitewater rafting landing site for three rafting companies; will this make the permit no longer conditional?

5. How can a conditional use permit be permanent?

We reserve the right to submit additional comments as additional information is provided.

We recommend that Kern County not approve this Conditional Use Permit; to do so would lead to the loss of biodiversity, viewshed, open space, and agricultural uses.

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Red Mountain Thinning Efficacy Research Project Comment Letter

Dear Mr. Freeland,

...We support projects that would “determine better ways of treating fuels layers within plantations.”  However, if heavy equipment is to be used, the Red Mountain and Bradshaw Thinning Research Project proposes to implement treatments that could cause sediment flows into a habitat that is already heavily impacted by sediment flows form past logging projects. For instance, one of the streams that would receive more intense sediment flows due to this project is the Bradshaw Creek which flows through the Bradshaw Spotted Owl PAC.

Most of this project is on the west side of Poso Creek, an area that has been damaged by up-stream logging and grazing. The project description fails to mention that the project map shows that the project would also be implemented in Section 31 of Township 27 South, Range 32 East, which is on the slope above the Bradshaw Spotted Owl PAC.

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Ponderosa Fuels Reduction Scoping Comment Letter

Dear Ms. Summers:

Thank you for the opportunity to comment on the Ponderosa Project as proposed.  We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately adjacent to and surrounding structures.  As set forth below, we oppose the Ponderosa Project on a number of bases and suggest that the project be postponed or severely narrowed.

On March 1, 2006 the Tule River Ranger District started the scoping process for the Ponderosa Fuels Reduction Project (Ponderosa Project). The Ponderosa project area encompasses approximately 1,079 acres, and is located in Township 21 South, Range 31 East, Sections 7, 8, 9, 15, 16, 17, 20, 21, and 22 of Mount Diablo Meridian. The elevation ranges from 7,100 to 7,200 feet. The Ponderosa Project area is adjacent to private land that contains the community of Ponderosa and two camps with special use permits; Quaker Meadow camp and Camp COTYAC. Also in the project area is Quaking Aspen Campground. The project area consists of old forest, stands of planted pines, stands of quaking aspen, and meadows. Nineteen acres of the old forest is part of the Wheel Meadow Giant Sequoia Grove.

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Tule River Reservation Protection Fuels Reduction Pre-Scoping Comment Letter

Dear Ms. Summers:

 Thank you for the opportunity to comment on the Tule River Reservation Protection Fuels Reduction Project pre-scoping (TRRP Fuels Reduction Project) proposed for implementation in the Giant Sequoia National Monument (Monument).  We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities, based on sound science, by thinning the trees in the 200 foot-wide areas immediately adjacent to and surrounding structures.

Due to multiple past failures of the Forest Service to be honest with the public and to follow forest management laws and regulations, in regard to other projects and planning in the Giant Sequoia National Monument, the public requires copies of all proposed agreements and project specifics. The public must make sure that the Forest Service follows all laws and regulations and especially that the Forest Service complies with the protective intent of the Proclamation that created the Monument.

The Forest Service’s environmental analysis of the proposed project must show that Forest Service managed land bordering on or adjacent to the Indian forest land poses a fire, disease, or other threat to the Indian forest land or to a tribal community; or that the land is in need of land restoration activities and that the proposed project is based on sound science and could achieve the goals of the project.

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Tule River Reservation Protection Fuels Reduction Pre-Scoping Comment Letter #2  March 24, 2006

Dear Ms. Summers:

 The Monument lands do not need the type of treatment suggested by the Forest Service’s Tule River Reservation Protection Project.  We question the methods used to determine the condition of the forest near the reservation. We also suggest that the Forest Service logging of the past has caused the flammable conditions that exist, including all of the clearcuts, plantations, and brush in the Black Mountain, Peyrone-Red Hill area.  The treatment suggested by the Forest Service would cause more brush and dryer, more flammable conditions than already exist. 

The scope of the analysis and the issues to consider for the Tule River Reservation Protection Project must include a comprehensive evaluation of the current conditions and how and why these conditions exist, including the impacts that all past logging and plantations have had on forest conditions. This analysis by the Forest Service must include the impacts on fire weather conditions as described in the Forest Service Handbook 360 titled “Fire Weather.”

We want the Forest Service to complete an analysis of the area including the existing condition of the lands/plantations, failed or otherwise, original vegetative cover, alternatives for restoration that are consistent with the Proclamation and with scientific data showing that the strategies proposed for implementation have been successful elsewhere. The Forest Service has responsibilities under NEPA to be thorough in the evaluation.  

Respectfully Submitted,                                                                                                Ara Marderosian,                                                                                            Executive Director                                                                                                 ara@sequoiaforestkeeper.org

Valley View Hazardous Fuels Reduction WUI Project Comment Letter

Dear Mr. Freeland;

On February 6, 2006 the Kern River District opened the public scoping period for a hazardous fuels reduction project known as the Valley View Hazardous Fuels Reduction (WUI) Project (Valley View Project) on National Forest System managed lands (Forest lands) adjacent to the community of Valley View in the Piute Mountain south of Lake Isabella. “The project is located in Section 3, Township 28 South, Range 33 East of the Mount Diablo base and meridian. The project area is approximately 73 acres at an average elevation of 6140 feet. The project area consists of a 200 to 400 foot wide strip of NFS lands around the community. The community straddles the ridgeline between Bodfish and Clear creeks consisting of about 28 parcels with 25 mountain cabin homes and outbuildings and 5 full time residents.”  The scoping document states under “Need For Change” that “On the southwest side of the ridgeline there is a need to reduce the density and continuity of the chaparral brush and reduce canopy cover formed by brush and trees species to about 25 to 50 percent and about 50 to 75 percent ground cover formed by herbaceous species or open, naturally barren areas. Within tree stands on both the northeast and southwest sides, there is a need for less surface fuels (up to 15 tons per acre less) and ladder fuels.” The scoping document states that the project “would be implemented to reduce the risk of potentially spreading noxious weeds.”  

We would like to join you in the meeting with property owners immediately adjacent to Forest lands to discuss how the project would be designed near their property.

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Draft Kern River Valley Specific Plan Comment Letter

Dear Mr. James, 

Sequoia ForestKeeper is pleased with the concept of controlling growth in the Kern River Valley, so the natural environment is preserved, which the Kern County Planning Department is attempting to build in to the Specific Plan for the Kern River Valley.  We also like the progress that the Planning Department has made in developing the Draft Kern River Valley Specific Plan (The Specific Plan).  We are delighted to read that the Planning Department has adopted the community’s desire to protect the Kern River Valley’s dark skies by including a Dark Sky Goal and policy in the Specific Plan.   We are very happy to see Implementation 6.1.2, which requires all existing and future development to be in compliance with Public Resources Code 4291 and Government Code 51182. We wish that all other references cited in the Specific Plan were provided for the public in an Appendix to the Specific Plan, as these codes were provided. Some objectives of the draft Specific Plan, including the objectives to protect the natural environment, to maintain and enhance the health of the Valley’s natural systems and resources, retain the rural character of the Valley, and improve visual qualities of the built environment are precisely the language that residents of the community have requested. 

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Addendum to Appeal: Tule River-West Grazing Project: North Grouse, South Grouse, Grouse Valley, Rancheria, East Bear, West Bear, Middle Tule, Cow Mountain, and Black Mountain allotments

Dear Appeal Deciding Officer,

On November 19, 2005 we submitted an appeal of the Decisions for the North Grouse, South Grouse, Grouse Creek, Rancheria, East Bear, West Bear, Middle Tule, Cow Mountain, and Black Mountain allotments, collectively known as the Tule River-West Grazing Project. This appeal was filed pursuant to 36 C.F.R. § 215.14. Sequoia ForestKeeper, the Center for Biological Diversity, Sequoia Forest Alliance, the Tule River Conservancy, the Kerncrest Audubon Society, the Sequoia Task Force of the Sierra Club, California Trout, RangeWatch, Western Watersheds Project, and Forest Guardians appeal to the Forest Supervisor to overturn the DN and FONSI for the Tule River-West grazing project, because the DN neglects important issues and jeopardizes the ecological health and integrity of the Giant Sequoia National Monument of the Sequoia National Forest. 

We wish to file this addendum to that appeal, because one of our appeal points (# 3. “This project fails to show how the impacts to ecological resources will be monitored and mitigated, in violation of NEPA”) merits further explanation. We request that this be added to the appeal and the project record.

In regard to the monitoring and mitigation that is planned to protect already degraded areas of Rancheria Creek, we have already expressed our concern that the language, “If cattle breach the natural exclosures over three consecutive grazing seasons, a fence would be installed,” from page 6 of the EA does not provide hard and fast protection for this resource. We are concerned about the inclusion of the term “consecutive” and we requested that livestock be fenced out of this portion of the creek immediately in order to allow recovery. The resource damage to the riparian vegetation in this area has already been demonstrated. We objected to the unproven plan to use of natural barriers and allow three more seasons of degradation to this stretch of trout habitat before acting to prevent further damage. We asserted that the lack of firm mitigation parameters and lack of proven methods effectively undermined the purpose and need of the project: to improve the health of the riparian vegetation along approximately ¾ mile of Rancheria Creek and along an unspecified section of Long Canyon Creek.

 What we did not express in our appeal but wish to add now is that Sequoia NF plan for the lower section of Rancheria Creek is not likely to provide sufficient protection for the 1,100 ft. section of lower Rancheria Creek where the creek reach contains decadent stands of white alder and sycamore with little regeneration and other areas devoid of alder with little regeneration.

 The proposal also conflicts with the recommendations of the Forest botanist, Fletcher Linton. The vegetation report for this project argued that a small amount of livestock browsing could significantly impede alder regeneration in this section. The vegetation report states clearly that complete removal of livestock impact is what is required to promote alder regeneration. Yet the SNF has apparently ignored the strong recommendation coming from its own botanical specialist and chosen an option of “livestock impact reduction” that is not likely to be sufficient to revive the non-regenerative alder community in the lower Rancheria Creek reach.            

We thank you for your consideration of this addendum to our appeal and we look forward to moving towards a resolution.

Tule River - West Grazing Project Appeal

Pursuant to 36 C.F.R. § 215.14, Sequoia ForestKeeper, the Center for Biological Diversity, Sequoia Forest Alliance, the Tule River Conservancy, the Kerncrest Audubon Society, the Sequoia Task Force of the Sierra Club, California Trout, RangeWatch, Western Watersheds Project, and Forest Guardians appeal the Forest Supervisor to overturn the DN and FONSI for the Tule River-West grazing project, because the DN neglects important issues described below and jeopardizes the ecological health and integrity of the Giant Sequoia National Monument of the Sequoia National Forest.

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Grouse Lake Land for Timber Exchange Comment Letter

Thank you for the opportunity to comment on the Grouse Lake Land for Timber Exchange Project.  Unfortunately, we find that the scoping document, dated October 17, 2005, (publication date 19 October 2005) fails to conform to the National Environmental Policy Act (NEPA) requirement for sufficient, clear information on the project. 

We support projects that would protect additional land by including it in the Giant Sequoia National Monument (Monument), but the scoping document fails to convince us that this project would not harm portions of the Sierra Nevada that require protection.  As set forth below, we require additional information on the Grouse Lake Land for Timber Exchange Project before we can support the project as inadequately described in the scoping document.

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Biomass Production Comments to Energy Commission

14 October 2005

RE: CALIFORNIA ENERGY COMMISSION 2005 INTEGRATED ENERGY POLICY REPORT COMMITTEE DRAFT Report SEPTEMBER 2005 CEC-100-2005-007-CTD

Dear Commission Members;

We are unalterably opposed to the proposal contained in the Committee Draft Report that says “California, however has tremendous potential to produce ethanol with biomass material such as municipal, agricultural, and forestry wastes.”  The biomass in our forests is not a waste product; biomass is habitat for species, shade for retaining soil moisture and cool temperatures that are nature’s way to prevent catastrophic fires, and a source of future soil nutrients needed to grow future trees and forests. Our forests should not be used as a source for creating ethanol fuel because this would establish a structure to strip forests of essential forest components.

Also, burning any fuel, even biodiesel ethanol, still contributes Carbon Dioxide and Carbon Monoxide to the atmosphere, which exacerbates Global Warming/Climate Change. California should concentrate on acquiring energy through other sources like financing a solar photovoltaic production facility in the San Joaquin Valley to employ Californians to produce the solar photovoltaic panels that would be built into the roof of every structure in the state. While California would most likely be able to supply all of its energy needs with solar photovoltaic roof panels, the state could also encourage wind generators, only where appropriate, and where they are not a danger to migrating birds.  

Thank you for your time in this regard.

Respectfully submitted,

Ara Marderosian, Executive Director

Sequoia Guard Station Project Comments

13 October 2005

Dear Mr. Exline:

It has come to my attention that the historic Sequoia Guard Station along the Whitaker Road (M 465) between Eshom Campground and Whitaker Forest is being neglected and is in need of repair.  The main cabin has had a boarded door reopened, and windows have been broken.  The structure has a damaged roof from a tree that hit the edge of the roof on the right side in back of the outbuilding.   A tree has also fallen through a corner of the adjacent storage building.   Simple repairs need to be made before the onset of winter weather to avoid other structural problems prior to restoration. 

Other guard stations and lookouts in the Sequoia National Forest are being rented for use as recreational cabins.  I request that the Sequoia Guard Station at its scenic site in the Giant Sequoia National Monument be repaired for that purpose.  The host at the nearby Eshom Campground could easily oversee operation of this cabin as a dispersed recreational facility.

 Thank you for your time in this regard.

 Respectfully,

Ara Marderosian, Executive Director

Sequoia National Forest OHV Trail System Mapping of User-created Trails 

Thank you for providing the opportunity for us to comment on the OHV Route Designation and Mapping Project.  This project proposes to collect, identify, and GPS locate all trails, including all indiscriminate OHV user-created trails, to include them on the Sequoia National Forest trail map and, at a later date, decide which trails will be retained in the Sequoia National Forest Trail System. This project has a number of problems and concerns that must be addressed. 

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Osborne Ranch Interface Project Scoping Comments

Thank you for the opportunity to comment on the Osborne Ranch Interface Project, on the Tule River/Hot Springs Ranger District of Sequoia National Forest. We appreciate the opportunity provide our comments. Sequoia ForestKeeper supports projects that would reduce the risk for residents and structures, but the Osborne Ranch Interface Project scoping letter fails to provide any scientific research to support the claim that the proposed treatment would achieve the purported fire risk reduction.

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Stormy Black Oak Habitat Improvement Project Scoping Comments

The Stormy Black Oak Habitat Improvement Project scoping letter indicates that the project would be implemented east of the Monument approximately 3 miles northeast of Portuguese Pass and would treat 225 acres in the area of the 1990 Stormy Fire. The scoping document indicates that “[t]here is a need for the reduction in the number of leaders sprouting from existing black oak stumps. The reduction in leaders will increase growth of those leaders retained, by decreasing competition for resources.” The scoping document indicates that the project is being done so wildlife will more quickly benefit from the production of acorns. The scoping document also indicates that that the leaders would be removed by hand over a two year period. The project would be carried out in cooperation with the volunteer organization, Wild Places (Mehmet McMillan) whose care for trees is well known. 

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Tule River West Grazing Project Comments

Thank you for the opportunity to comment on the Tule River West Grazing Project Environmental Assessment (EA) that includes management proposals for the North Grouse, South Grouse, Grouse Valley, Rancheria, East Bear, West Bear, Middle Tule, Cow Mountain, and Black Mountain grazing allotments, on the Tule River Ranger District of Sequoia National Forest. We realize that this is a singular, unique occurrence in the history of the Giant Sequoia National Monument and we appreciate the opportunity.

 The project proposes renewing ten-year grazing permits that have expired on 17,737 acres in the Giant Sequoia National Monument. Our primary concern is that the renewal of these grazing permits without complying with the need to restore the Monument could be in conflict the Presidential Proclamation and the Monument Management Plan. 

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McNally Reforestation Project Comments

On May 27, 2005, ARTHUR L. GAFFREY Forest Supervisor Sequoia National Forest issued a scoping document for the McNally Reforestation Project in preparation for initiating the formal planning process by publishing a Notice of Intent (NOI) in the Federal Register to prepare an environmental impact statement (EIS) supposedly to re-establish conifers and hardwoods in “key areas” burned during the McNally and Manter Fires on the Sequoia National Forest. Please send us the “link” to the NOI for the project published in the Federal Register.

The McNally Reforestation Project scoping letter claims consistency with the Sequoia LRMP as amended by the Sierra Nevada Forest Plan Amendment, 2004 (SNFPA) and the Giant Sequoia National Monument Management Plan, 2004 (GSNMMP). The project also claims that “[a] forest plan amendment will not be required” even though the forest plan is 17 years old and the forest has failed to provide an adequate reforestation success rate by the methods applied in past projects and proposed for implementation with this project.

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Kern River Valley Preliminary Specific Plan Comments

We are concerned about the accuracy, credibility, intent, and validity of The Kern River Valley Specific Plan Opportunities and Constraints Report (The Plan) for a number of reasons. The Kern County letter that accompanied the Opportunities and Constraints Report, dated December 29, 2004, from Ted James, states that the purpose of this workshop is to: “Seek solutions from the community members on the identified issues.” According to this statement, the county sees problems regarding development of the Kern River Valley, which indicates to residents of the Kern River Valley that Kern County has failed to hear the wishes of most residents, which is that we do not want development - there is no problem if you leave the valley as it is.

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Logger Point Fuelbreak WUI Comments

Thank you for the opportunity to comment on the proposed Logger Point Fuelbreak WUI Project.  On February 4, 2005, you announced the Logger Point Fuelbreak WUI Project, which outlined a number of issues that are being considered for implementation in the Giant Sequoia National Monument based on the guidelines as described in the 2001 Sierra Nevada Forest Plan Amendment (2001 SNFPA), which amended the 1988 Sequoia National Forest Land and Resource Management Plan.

 We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately surrounding structures.  As set forth below, we oppose the Logger Point Fuelbreak WUI Project on a number of bases and suggest that the project be postponed or severely narrowed.

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Dry-Converse Fuel Reduction Project Scoping Comments

Thank you for the opportunity to comment on the Dry-Converse Fuels Reduction Project.  We support projects that would prevent catastrophic wildfire by reducing brush and ladder fuels to protect the objects to be protected in the Giant Sequoia National Monument. As set forth below, we suggest the Dry-Converse Fuels Reduction Project be modified to reduce the compaction that would result from implementation, as proposed.

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Woodward Fuel Reduction Scoping Comments

Thank you for the opportunity to comment on the Woodward Fuels Reduction Project.  This project proposes to “use a masticator to precommercially thin approximately 165 acres of plantations to reduce inter-tree competition.”  The letter says this is being done “to protect several plantations from bark beetle attacks in the short-term, while beginning to restore mixed conifer stands in the project area in the long-term.”  This project is purported to be a need to “protect and restore under the GSNM Management Plan.” We support projects that would protect the objects in the Giant Sequoia National Monument (Monument) by reducing the smaller trees (less than 10 inches dbh) and brush. As set forth below, we suggest the Woodward Project be modified to reduce the compaction that would result from implementation, as proposed.

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Sawmill Fuels Reduction Project EA Comment Letter

Thank you for the opportunity to comment on the Sawmill Fuels Reduction Project Environmental Assessment (EA).  Unfortunately, we find that this EA fails to conform to the conditions and criteria set in the scoping document provided for this project, including, but not limited to the upper diameter limit on trees to be removed and all of the criteria changed from the 2001 Sierra Nevada Forest Plan Amendment (2001 SNFPA) by the less protective, more extraction-oriented 2004 Sierra Nevada Forest Plan Amendment (2004 SNFPA) revisions. 

We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately surrounding structures.  As set forth below, we oppose the Sawmill Fuels Reduction Project on a number of bases and ask that the project be withdrawn as written.  

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Sequoia National Forest Trail System Mapping of User-Created OHV Trails  Comment Letter

Thank you for providing the opportunity for us to comment on the OHV Route Designation and Mapping Project.  This project proposes to collect, identify, and GPS locate all trails, including all indiscriminate OHV user-created trails, to include them on the Sequoia National Forest trail map and, at a later date, decide which trails will be retained in the Sequoia National Forest Trail System. This project has a number of problems and concerns that must be addressed. 

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The Red Mountain Thinning and Fuels Reduction Project Comment Letter

Thank you for the opportunity to comment on the Red Mountain Thinning and Fuels Reduction Project.  We support projects that would prevent catastrophic wildfire.  We support projects that protect wildlife habitat.  As set forth below, we suggest the Red Mountain Thinning and Fuels Reduction Project be modified to reduce the compaction that would result from implementation, as proposed.

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Camp Nelson Interface Project Comment Letter

Thank you for the opportunity to comment on the Camp Nelson Interface Project as proposed.  We support projects that would protect the health and safety of the residents in forest communities.  We support projects that protect communities by thinning the trees in the 200 foot-wide areas immediately adjacent to and surrounding structures.  As set forth below, we oppose the Camp Nelson Interface Project on a number of bases and suggest that the project be postponed or severely narrowed.

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Tule River Hot Springs Hazard Tree Abatement Projects Comment Letter

Thank you for the opportunity to comment on the hazard tree projects of the Tule River and Hot Springs Ranger District.  The proposed Tule River Hot Springs Ranger District Hazard Tree Projects (The Projects), as we understand them, have a number of problems that need to be addressed and a number of questions that need to be answered.  The information verbally provided is inadequate and insufficient to meet NEPA standards.  

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Verbal Scoping for Hazard Tree Abatement Projects is Inadequate

         We have received a telephone message, on 20 September 2004, from the Forest Service about three projects in the Monument that were begun without any written scoping documents provided to the public. This is not adequate scoping for these projects that propose to log 1,068 trees from the Monument.  These projects were segments of the Tule River Hot Springs Ranger District Hazard Tree Project which was cancelled.  These segmented projects fail to adequately implement the requirements of the National Environmental Policy Act (NEPA). 

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Stony Creek Lodge Expansion Plan Comment Letter

Thank you for the opportunity to comment on the Stony Creek Lodge Expansion Plan Project EA.  First, decisions on proposed projects in the Monument should be deferred until a Monument Management Plan is in place.  In general, I support providing public facilities in the Monument, if they will protect the objects listed in the Proclamation, which is the overriding purpose of the Proclamation

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Trail of 100 Giants Fuels Reduction Project Comment Letter

Thank you for providing the opportunity for the public to comment on the Trail of 100 Giants Hazard Tree Fuels Reduction Project.  This comment letter contains general comments on the Trail of 100 Giants Hazard Tree Fuels Reduction Project, since there was no scoping document and the telephone call I received from you on 5 August 2004 provided few details about the project.  In general, we are in favor of projects that would retain natural forest conditions, so we are not in favor of this project as understood. 

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Greenhorn West Grazing EA Comment Letter

Thank you for providing the opportunity for the public to comment on the Greenhorn West Grazing EA Project.  This comment letter contains general comments on the Greenhorn West Grazing EA Project since the scoping document provided few details about the project.  In general, we are in favor of projects that would return damaged forest areas to natural conditions. 

The information provided in the Greenhorn West Grazing EA Project scoping letter (Greenhorn West Grazing document) is insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the Greenhorn West Grazing document provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information and toured the project area.  The Forest Service many times claims it does not have to obey the law, because there were no comments indicating the law should be followed.  Therefore, we wish to raise the issue that all laws that apply to the project need to be followed whether mentioned in this comment letter or not. 

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Clicks Creek Meadow Restoration Comment Letter

Thank you for providing the opportunity for the public to comment on the Clicks Creek Meadow Restoration Project.  This comment letter contains general comments on the Clicks Creek Meadow Restoration Project since the scoping document provided few details about the project.  In general, we are in favor of restoration projects that would return damaged forest areas to natural conditions. 

The information provided in the Clicks Creek Meadow Restoration Project scoping letter (Clicks Creek document) is insufficient for a proper and thorough response that would include all of the issues that could possibly be involved in this project.  Due to the inadequacy of the Clicks Creek document provided to us by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information and toured the project area.  The Forest Service many times claims it does not have to obey the law, because there were no comments indicating the law should be followed.  Therefore, we wish to raise the issue that all laws that apply to the project need to be followed whether mentioned in this comment letter or not.

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Sierra Nevada Forest Plan Amendment (Forests with a Future) Appeal .

On January 21, 2004,  JACK BLACKWELL, Regional Forester, Pacific Southwest Region and  JACK D. TROYER, Regional Forester, Intermountain Region, published a Record of Decision for the Sierra Nevada Forest Plan Amendment (FRAMEWORK) Final Supplemental Environmental Impact Statement (FSEIS), which proposes to amend the Pacific Southwest Regional Guide, the Intermountain Regional Guide and Land and Resource Management Plans (LRMPs) for national forests in the Sierra Nevada and Modoc Plateau.  Covered are the Humboldt-Toiyabe, Modoc, Lassen, Plumas, Tahoe, Eldorado, Stanislaus, Sierra, Inyo, and Sequoia National Forests and the Lake Tahoe Basin Management Unit.  This decision proposes, among other things, to implement this plan with the "with the primary objective to conserve rare and likely important components of the landscape such as stands of mid- and late-seral forests with large trees, structural diversity and complexity, and moderate to high canopy cover”.

The Framework plan would implement logging to achieve this objective. 

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Yellow Starthistle Comment Letter

Thank you for the opportunity to comment on the Yellow Starthistle Project (YST Project).  In general, we approve of removing Yellow Starthistle (YST) from the Monument, if the objects of concern, wildlife, and visitors to the Monument will be protected. We consider YST to be a great threat to both plant and animal biotic communities and support projects to control of the plant and protect the Monument.   

While our evaluation is positive regarding the considerable thought that went into deciding to continue hand pulling and bagging YST in many areas of the YST Reduction Project, we request that botanic surveys for species that might be impacted be performed under the California Environmental Quality Act at all proposed treatment sites. This would include species listed as sensitive by the California Natural Diversity Database and also those in the California Native Plant Society Inventory of Rare and Endangered Plants of California.

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Delilah Terrace Fuels Reduction Comment Letter

Thank you for the opportunity to comment on the Delilah Terrace Fuels Reduction Project (DTFR Project) proposed on March 24, 2004.  In general, we approve of projects making the forest more resistant to future wildfires and re-establishing the native pine and oak type forest in the area, as long as the projects are capable of achieving their purposes without violating laws and regulations.

 Sequoia contains millions of pine seedlings (1/2 to one million annually planted on Sequoia NF, also some white fir, cedar, and sequoia) planted on Sequoia since the 1960's.  So, 40 year old trees are in over-supply.  Plantations are conventionally over-planted with as many as 600 trees per acre, as these DTFR Project plantations appear to be.  This project proposes to reduce the flammable thicket of brush and trees that has resulted from over-planting, to remove brush and trees to disconnect the remaining trees from each other and from the flammable brush, to make the remaining trees more resistant to future wildfires.  We agree that plantations need to be the focus of fuel reduction projects in the forest because plantations were intentionally over-planted and have become flammable thickets of brush and trees.  Over-planting is not the only problem with plantations.  Another problem with plantation management is intentionally killing native species with herbicides and poisons to prevent them from competing with the unnatural, planted seedlings. While we agree that the intentional high density of trees in plantations makes them highly flammable, we also want no more herbicides and poisons to be used to kill natural species in the forest. 

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Delilah Davis Shredding Comment Letter

Thank you for the opportunity to comment on the Delilah Davis Shredding Project (DDS Project) proposed on March 24, 2004.  In general, we approve of reducing the risk of a stand-replacing wildfire and obliterating user-created roads in the Monument, if the objects of concern, wildlife, and visitors to the Monument will be protected by the project.  We are concerned, however, about the lack of information and scientific evidence provided to prove that the proposed removal of large trees and their associated canopy cover will achieve the alleged purpose for the project of “reducing the risk of a stand-replacing wildfire”. 

 The fuels that create the risk of a stand replacing wildfire are the brush and lower branches of trees, not the trees and their canopy cover, which is what keeps the forest moist and cool and is the natural fire-prevention characteristic of the forest. We are opposed to fuel reduction treatments that remove trees larger than 3 to 4 inches in diameter.  On 10 August 2000, Denny Truesdale, Fire Specialist, Washington, D.C. USDA Forest Service, stated that, “Old Growth is not the problem.  What is needed is to take care of the underbrush and dry twigs.  The majority of the material that we need to take out is not commercial timber.  It is up to 3 and 4 inches in diameter.”

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Giant Sequoia National Monument Management Plan Appeal .

In 2000, President Clinton re-designated almost one third of the Sequoia National Forest as the newly created Sequoia National Monument. By doing so, the President recognized the unparalleled nature of the Giant Sequoias and related ecosystem, and dramatically altered the management principles for the area. Unfortunately, the Forest Services proposed
management plan for the Monument fails to comply with the promise and requirements of the Monument Proclamation and the 1992 Presidential Proclamation exempting the Groves from commercial logging, violates the spirit and words of the 1990 Sequoia Mediated Settlement Agreement, and does not met the standards of the National Environmental Policy Act ("NEPA"), 42 U.S.C. 4321 et seq. As a long time participants in the Sequoia National Forest, and now Monument, planning process, we are dismayed by the proposed management plan (which is not actually described or set forth as a plan in any discernable form) and related environmental review, and fear that the Forest Service is placing a national treasure at unnecessary risk. Most strikingly, the Forest Service ignores the prescriptions on timber harvesting and road building that are centerpieces of both Presidential Proclamations.

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View Exhibit B

McNally/Sherman Pass Restoration Project  Comment Letter #1 .

Dear Mr. Simonson;

Thank you for providing the opportunity for us to comment on this project.  The proposed McNally Fire / Sherman Pass Restoration Project salvage timber sale has a number of problems that need to be addressed and a number of questions that need to be answered.  The information provided in the McNally Fire / Sherman Pass Restoration Project Timber Sale Draft Environmental Impact Statement (DEIS) is inadequate and insufficient to meet NEPA standards.   Due to the lack of response, to date, to our request for additional information on the McNally Fire / Sherman Pass Restoration Project salvage timber sale DEIS by the Forest Service, we reserve the right to introduce additional issues of concern, which should be analyzed for this project, after we have received the missing information and toured all of the roads listed in the McNally Fire / Sherman Pass Restoration Project DEIS. The Forest Service many times claims it does not have to obey the law, because there were no comments indicating the law should be followed.  Therefore, at the outset, we wish to raise the issue that all laws that apply to the project need to be followed whether mentioned in this letter or not. 

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Tule River Urban Intermix Human Health and Safety Project  

Dear Mr. Pengilly;

Thank you for the opportunity to comment on the Tule River Urban Intermix Human Health and Safety Project (“Intermix logging project”) as proposed for the Giant Sequoia National Monument (“GSNM” or “Monument”).  As set forth below, we oppose the Intermix Logging Project on a number of bases and suggest that the project be postponed or severely narrowed until after the Monument Management Plan is in place...

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West Trimmer & Oat Mountain/LeFever Livestock Grazing Allotments 
comment #1 

Dear Mr. Exline;

There cannot be a purpose or need to continue to permit grazing on public lands since the growing body of scientific research on the effects of livestock grazing shows that grazing is harmful to the ecosystem in many ways, including the fact that grazing introduces non-native species into the National Forest; decreases soil productivity, water quality, and available browse for deer; negatively impacts riparian and meadow habitats, which decreases viability of fish, amphibians, frogs, and toads; and increases wildfire intensity. Grazing should not be continued on public lands. We recommend that Sequoia National Forest no longer authorize grazing permits on Sequoia National Forest lands. We therefore recommend that the grazing allotments in question in this project no longer be permitted. We recommend the selection of the No Action Alternative that would abandon the allotments in question and permit no grazing...

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Applications for Off Highway Vehicle (OHV) cooperative funds 2001-2002 cycle 

Dear Mr. Gaffrey,

The Sequoia National Forest has asked for comments on its developing applications for Off Highway Vehicle (OHV) cooperative funds from the State of California for the upcoming 2001-2002 cycle. Applications include a forestwide summer operation and maintenance (O&M) application for funding OHV trail maintenance, resource protection, signing, patrols and law enforcement, public information and assistance, and ongoing resource monitoring. While these funds have played an important part in helping Sequoia National Forest to provide a recreational opportunity to OHV users, the Forest Service has not provided adequate monitoring or enforcement of the regulations for OHV use sufficient for resource protection associated with OHV use...

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