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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.
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 (9th 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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appeal
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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 (9th 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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appeal
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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 (9th. Cir. 2004).
Furthermore, the 10th 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
March 31, 2007
The purpose of Sequoia
ForestKeeper (SFK) is to protect and preserve the natural
environment of the Sequoia National Forest. We have numerous
members who enjoy recreational activities in the forest that
depend on the preservation of its healthy ecosystems and the
survival of the native wildlife. As such, we are very concerned
about the proposed amendments to the list of management
indicator species, the use of which are a key component to
monitoring the forest ecosystem.
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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
March 15, 2007
...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. In particular, we want detailed
information about which trees are to be cut down and why. Trees
only rarely will suddenly fall down out of the blue, so there
should only be a handful of trees in this project area that are
truly at risk of doing so. As such, it should not be too
difficult to list them for public feedback. We would also like
another opportunity to comment after the trees have been marked,
as we need an opportunity to inspect the marked trees to
determine whether they are really dangerous.
What sort of methods and
equipment will be used to remove these trees? Will any trees be
selected for removal that are further away from roads or
structures than their own height? Has the Forest Service
fully assessed the impact of this project on the spotted owl,
northern goshawk, and pacific fisher? Has the Forest Service
considered the cumulative impact of all the many hazard tree
removal projects in which it has engaged and intends to engage
in the future?
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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
March 10, 2007
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 North Road Hazard Tree Project.
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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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, &nbs |