Preliminary Analysis of Public Concerns 2/5/99

Herger-Feinstein Quincy Library Group Forest Recovery Act
Pilot Project Notice of Intent
Prepared by:
Content Analysis Enterprise Team,
February 8, 1999
For the:
U.S Department of Agriculture, Forest Service

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1.1   Notice of Intent
1.2   Range of Alternatives
1.3   The SNFP Amendment/ Quincy Pilot Project EIS Interface
1.4   Public Involvement
1.5   Tribal Rights and Treaty Obligations
1.6   Implementation


2.1   Late Seral/ Old Growth Forests
2.2   Group Selection and other Timber Harvest
2.3    Aquatic & Riparian System Protection
2.4   Fire and Fuels Management
  2.4.1 Prescribed Fire
  2.4.2 Fuelbreak Construction
2.5   Roadless Area Disposition
2.6   Transportation System Management
2.7   Mitigating Affects on Wildlife
2.8   Grazing and Related Riparian Area Management


3.1   Socio-Economic Analysis


The following is preliminary list of public concerns derived from a review of 185 responses received with regard to the Quincy Pilot Project EIS. It is important to note that this list does not claim to be comprehensive, nor does it provide more than summary information. Decision-makers and the public are directed to the actual letters for more information.

 Public Concern statements are divided into major areas denoted by section headings and sub-headings. Each statement is supported by one or more supporting quotes from an actual comment letter fax or Email. Each quote includes a reference to the original response. With a few exceptions he number of sample statements is not intended to represent the relative importance of a public concern, rather the number reflects the need to describe of variety of perspectives on an otherwise general topic.

Public Involvement for Notice of Intent

Input has been received from many individuals; interest groups; Federal, State, and local governments and agencies; and American Indian tribes. This input, combined with science, management information and direction in the Herger - Feinstein Quincy Library Group Pilot Project EIS, will be used to construct alternatives for the DEIS.

On December 15, 1998, the Plumas National Forest Supervisor published a Notice of Intent announcing the Quincy Library Group Forest Recovery Act Pilot Project EIS in the Federal Register. Public scoping meetings were hosted by the Lassen, Plumas, and Tahoe National Forests at Loyalton, Blairsden, Quincy, Oroville, Chico, Burney, and Chester, CA between January 4th and January 16th, 1999. Two additional scoping meetings were held at Susanville and Quincy on Saturday, January 16th. The public was also invited to respond in writing.

Content Analysis Process

The process followed for analyzing is public input is called content analysis. It is a method of compiling, categorizing and organizing reviewer input by identifying areas of concern to respondents. The content analysis summary is only one of several tools available to decision-makers and project team members. The summary is intended to serve as a map to the comments. It provides readers with both a sense of major themes and public concerns, and means of tracking specific issues back to original letters

Content analysis should not in any sense be construed of as a voting process. All comments are treated equally. The goal of the analysis is not to capture how many people mentioned a specific topic, but to capture the full range of public concern. PROPOSED ACTION/  PLANNING and PROCESS

Given the complexity of planning and carrying out an Environmental Impact Statement (EIS) that combines congressional intent with the NEPA and forest planning process, members of the public express confusion with regard to many aspects of the process. Their questions and concerns center on what the Herger-Feinstein Quincy Library Group Forest Recovery Pilot Project Act mandates and how it will be carried through the EIS process. A variety of interpretations of the Act are offered. These comments deal with the intent of the act, the range of alternatives, project relationships with the Sierra Nevada Forest Plan Amendment EIS (SNFP), Tribal treaty rights and federal obligations, public involvement and collaboration, as well as implementation concerns.

1.1 Notice of Intent

Clarity of the proposal as described in the NOI is concern for many of those who responded. Several people noted the list of errata and suggested other specific and detailed grammatical corrections. In particular, they want the NOI and DEIS to clearly describe the Congressional and legal framework the Agency is operating under and how it relates to the forest planning process. All of these responses, whether from people in support of the proposal as it stands or against, suggest the NOI and DEIS should make efforts to clearly state and describe the purpose and need for action.

1.2 Range of Alternatives

Availability of scientific information, legislative history and language of the Act, and guidance from the Council on Environmental Quality are all used by respondents as rationales for including a reasonable range of alternatives other than those legislated. Comments from individuals and several local and national conservation organizations include requests for consideration of  "citizen alternatives" during preparation of the Draft EIS.  These people argue that the Forest Service has an opportunity within the process for the Quincy Pilot Project EIS to develop an alternative that is consistent with overall range-wide direction being developed for the Sierra Nevada Forest Plan Amendment EIS.

1.3 The SNFP Amendment/ Quincy Pilot Project EIS Interface

The range-wide Sierra Nevada Forest Plan Amendment EIS and its relationship to the Quincy Pilot Project EIS is an issue of importance to most people who responded to the NOI request for comment. Although most respondents are concerned by significant opportunities, as they see it, for conflicting management direction in the EISs, their comments can be characterized in two opposing perspectives.

The Quincy Pilot Project EIS should remain independent from the SFNP proposal, many people believe. Pointing to the broad range of issues the SNFP intends to address across the National Forests of the Sierra Nevada, they argue the narrower range of issues, short planning and implementation time frame embodied in the Quincy proposal and the Herger-Feinstein Act support a need to keep both efforts separate. In recognition of shared benefits from use of science contained in the Sierra Nevada Ecosystem Project (SNEP) reports and other guidance, they assert the proper relationship between the EISs is one of mutual support and coordination with exchange of information and avoidance of conflicts in planning and decision process.

In contrast, many other respondents argue for tiering the Quincy Pilot Project EIS to the broader decisions of the SNFP Amendment EIS. They note that the SNFP proposes amendments to the Regional Guides as well as Forest Plans, an observation they believe places Sierra wide efforts above those of the Quincy proposal. Further, some assert both the legal language and legislative history of the Herger-Feinstein Act make it clear that regional planning processes should take precedence over the pilot project. In particular, they cite language in the Act requiring the pilot project to comply with interim CASPO guidelines or those subsequently issued. These respondents believe the proper relationship between the two proposed actions should be one in which the pilot project is considered as one of many alternatives for analysis in the SNFP Amendment EIS.

1.4 Public Involvement

While some respondents are appreciative of the Forest Service's efforts at involving the public during the scoping period for the Notice of Intent, many are upset by what they term a lack of "full public involvement." In their view, the legislative nature of the Pilot Project EIS and the several years of close collaborative work between members of the Quincy Library Group leading up to their community stability proposal, give the proposal an air, as one put it, of  "closed-door back room negotiations." These people ask that, given the complexity of the proposal and the size of the project area, the comment period should be extended an additional 30 to 60 days. A longer comment period, in their opinion, is necessary to allow adequate time for response and for the Forest Service to hold meetings and interact with people in locations outside the project area.

The short time frame of the Quincy pilot project planning, others argue, is directly linked to the a need for immediate action towards reducing forest fuels and preventing catastrophic wildfire. They ask that the timeframe for completion of the EIS not be altered through extension of the comment period for the NOI or Draft EIS.

1.5 Tribal Rights and Treaty Obligations

Evaluation of potential effects on cultural and archaeological resources and tribal economic, cultural needs are analyses a member of the Pit River Tribal Council feels the EIS should include. This person asserts that assessing the condition and needs of the autonomous bands of the Pit River Tribe may be better accomplished through a memorandum of understanding with the Forest Service. Current efforts at consultation with affected tribal groups, in their opinion, have not been adequate. Further, the Councilperson asks that the EIS direct prescribed burning activities to areas of fire-dependent plant species with cultural uses.

1.6 Implementation

The Herger-Feinstein Act does not guarantee funding for the entirety of the five year pilot project, some respondents note. They ask that the Quincy EIS assess the ramifications of changing levels of funding. MANAGEMENT DIRECTION

Comments with regard to future management direction under the Quincy Pilot Project EIS include references to: Late Seral/ Old Growth Forests, group selection and other timber harvest, aquatic and riparian ecosystem protection, fire and fuels management, herbicide use, roadless area disposition and transportation system management, mitigating effects on wildlife, grazing and related riparian area management.

2.1 Late Seral/ Old Growth Forests

A large number of respondents clearly ask for protection of remaining Late Seral/ Old Growth (LS/OG) forests. Many others are do not specifically mention protection of specific acreage of LS/OG as an issue of concern.  The need for a clear definition of LS/OG and differing perspectives on where that definition might come from underlies and brings together these comments. Most comments suggest the Draft EIS should include a clear accounting for how, what kind, and how much LS/OG forest will be protected under different alternatives.

2.2 Group Selection and other Timber Harvest

Clear criteria for single or group tree selection in the EIS and an alternative that seeks to minimize the negative impacts associated with intensive logging are the two main concerns for those who responded on the topic of group selection and other timber harvest. These people want the EIS to give detailed guidance on single and group tree harvest, from logging techniques to how trees will be selected and, most importantly, how negative effects will be mitigated. Comments with regard to riparian buffers are included below in the Aquatic and Riparian section.

2.3 Aquatic & Riparian Ecosystem Protection

Most respondents agree that protecting and restoring aquatic and riparian systems and watersheds  is important, where they differ is on what the best approach is. As a starting point, some request a detailed evaluation of existing riparian conditions and/or watershed analyses within the area of the proposal.  Identification of aquatic systems at or above the Threshold of Concern, analysis of near-stream impacts of timber harvesting, DFPZs, roads (construction, maintenance, and obliteration) and grazing,  plans for mitigating effects, and compliance with other plans like the Lahontan Basin Management Plan are all issues these people feel the EIS should address.

While all those who commented on this topic feel the pilot project EIS should apply consistent standards for aquatic and riparian management, some question the use of those found in the Scientific Assessment Team (SAT) report. The SAT standards, they note, were developed to address species needs in the Pacific Northwest; an area some argue has significant biophysical differences from the Northern Sierra. SAT standards should be evaluated in the EIS these respondents assert.

Others suggest the aquatic conservation strategy identified in the SNEP Vol. III, Chapter 5 should be considered as a viable alternative to the SAT. Regardless of standards, some of these respondents believe the pilot project EIS should protect all riparian areas identified in the SNEP.

2.4 Fire and Fuels Management

Consistency with federal regulations and quality interagency planning are two topics respondents feel the pilot project EIS should address. These people want the project team to ensure that alternatives in the EIS incorporate the Federal Wildland Fire Policy. Further, they assert, the agency needs to better coordinate with and include interagency and state partners in future fire and fuels management planning.

For others, adequate analysis of the effects of fire suppression and exclusion are of primary concern. These respondents want the pilot project EIS to disclose the direct, indirect, and cumulative effects of fire exclusion, suppression.

Comments with reference to prescribed fire, defensible fuel profile zones and the use of herbicides appear below.

2.4.1    Prescribed Fire

Prescribed fire should, in the opinion of some respondents, be given increased attention as an alternative means of reducing fuels. Air quality compliance and coordination with public and private land managers are issues they believe any analysis of prescribed burning should also address. Towards assessing the value of  prescribed burning, some of these respondents ask that the EIS directly compare linear constructed fuelbreaks with area wide fuels treatment using prescribed fire. One person specifically requests information on prescribed fire as an alternative to logging in construction of fuelbreaks.

In contrast, other people commented on alternative means of fuel reduction.  Addressing the economic feasibility crown fuel thinning and hand reduction of surface and ladder fuels in the EIS is important to these respondents.

2.4.2     Fuelbreak Construction

Where defensible fuel profile zone (DFPZ) fuel breaks will be constructed is the primary issue for most respondents. They want to know how many acres of the land will be treated under alternative proposals, how they will be identified, the relative value of different location, and what the costs of construction and maintenance will be.

People offer several suggestions for locating DFPZs. One fire safe council recommends the use of the Technical Fuels Report, Lassen, Plumas and Tahoe National Forests, 1995 as a resource in locating DFPZs. Others assert Community Defense Zones in areas of urban-interface should be the primary location for construction of DFPZs. Still, for some, the most important aspect of DFPZs is an alternative in the EIS should optimize the number of acres treated under the act.   Others noted that locations should be based on hazard, risk, and value.

Regardless of where DFPZs are constructed, people are also concerned by the cost and labor requirements of future maintenance. Without maintenance, in the opinion of many, future fire risk will be increased in DFPZs. These respondents believe the EIS should analyze and account for necessary maintenance of DFPZs.

Suggestions for dealing with maintenance build on questions of how much canopy cover should be left in DFPZs. One respondent specifically suggests a 60% canopy cover as a means of decreasing maintenance needs. Regardless of need, others want the pilot project EIS to directly address standards for construction of DFPZs on ridgelines,  and the use of herbicide.   Still others stressed that standards and guidelines should allow for site-specific design; allowing for variation in stand charactoristics, and be compatible with wildlife needs.

2.5 Roadless Area Disposition

Whether they believe the Forest Service should protect roadless areas less than 5,000 acres or more than 1,000 acres in size, many respondents agree that protection of these areas is vital. Noting that the Quincy Act directs the Forest Service to defer logging in some roadless areas, they ask that the EIS defer logging and road building in all roadless areas.  Specifically, some request protection for the Bald Mountain and Castle Peak roadless areas.

2.6 Transportation System Management

Few respondents commented directly on transportation system management outside the context of retaining roadless areas. One respondent, however, ask that the EIS include and evaluation of the impacts of any new road construction the proposal may require.

2.7 Mitigating Affects on Wildlife

Sensitive species, especially those that appeared in the June 10, 1998 Region list, are the primary concern of people who responded to the NOI on the topic of wildlife. These people assert the pilot project EIS should include a full viability assessment for sensitive species in the area of the proposal. This assessment, some request, should include and analysis of existing habitat and future needs towards ensuring protection of these species.

 2.8 Grazing and Related Riparian Area Management

The congressional record for the Herger-Feinstein Act, some respondents note, suggests that neither congress nor the Quincy Library Group intended to impact grazing activities in the area affected by the proposal. In light of this information, some respondents, in particular those representing ranching or other grazing interests, ask that the pilot project EIS not change existing allottment management. Guidance offered in the Lassen, Plumas and Tahoe forest plans is sufficient in their view. If changes are made, these respondents ask that they be included in the planning process for development of any new grazing guidelines. SOCIAL and ECNOMIC CONSEQUENCES

Regardless of their view on how the Quincy pilot project should be implemented, respondents believe an accurate and fair assessment of the proposal's effects on the local economy are vital.

3.1 Socio-Economic Analysis

Establishing a base-line local context for analyses, using verifiable assumptions about the relationship of resource harvest and use to employment and income, and utilization of a ``broad'' economic view that recognizes the importance of non-timber employment sectors are all aspects of analysis the people feel should be clearly identified in the EIS.