P. O. BOX 1749, QUINCY CA 95971
October 8, 1995
Dear Fellow Responder to the Cal Owl Draft EIS,
We noticed and appreciated your comments on the U.S. Forest Service draft EIS for management of the California Spotted Owl habitat.
In August a three-person subcommittee of the Quincy Library Group visited the Cal Owl EIS Team office in Sacramento in order to review the file of public comments. Our committee scanned all 4108 comments submitted, and copied 216 of them (about 5% of the total) for closer study. Virtually all the other 95% were form letters, i.e. post cards, newspaper ad coupons, or lists of canned phrases that were obviously supplied by organized groups.
A wide range of views was represented, with about equal numbers of comments on each side of the contentious issues. However, there was remarkable concurrence on at least five points:
1. One size does not fit all. There are large differences among these forests and subregional groupings of forests must be dealt with forest by forest or group by group.
2. The DEIS Alternatives do not cover the range of issues that responders desire to have covered, or that NEPA and NFMA require to be covered.
3. The DEIS fails to specify any adequate response to the threat of catastrophic fire.
4. The DEIS does not adequately address socio-economic concerns.
5. Wait for SNEP reports.
Of course a great many more than five issues were raised, sometimes objecting to broad management concepts, and sometimes objecting to narrowly focused details of implementation. Some technical issues of great concern, and the usual form of objection, seemed to be:
* Protection against catastrophic fire. -- Fuel reduction is the greatest need, but no alternative adequately addresses it. -- Prescribed fire is useful, but it is not the place to start in these particular forests, and would not be sufficient on it own. -- There was disagreement on the need for fuel treatments in reserve and roadless areas -- If fuelbreaks are used, how can they be interfaced with riparian and wildlife corridors?
* Inadequacy of the Preferred Alternative.
-- No support for three-tier zoning. Untested, can use province-wide.
-- Too little or too much harvest, depending on viewpoint.
-- Fails to provide connectivity of mature forest habitat.
* Computer modeling poorly done: Incorrect data, assumptions, methods, and/or analysis.
* On the California Spotted Owl, a sharp division exists.
-- According to one view, CSO protection is not needed, as evidenced by the DEIS quote on "abundant and well- distributed" owls.
-- According to others, the CSO (and other species) would not be adequately protected by any DEIS alternative. This includes furbearers dependent on late seral forest, aquatic and riparian-dependent species, micro- organisms in the soil, and specialized habitats.
* Deficient analysis of economic and social effects, and/or response to them.
The Quincy Library Group is sharing the main points of its DEIS comment analysis with you for two main reasons:
1. We want to make sure that the Final EIS takes proper account of what the comments actually say, not what a computerized statistical summary might suggest that they say.
2. We want to make clear that the "QLG Alternative" (Alt. F) did not in fact represent the QLG Proposal adequately or correctly. We never intended it to be applied outside the QLG area. The mixing of an incorrectly modeled "QLG" with a modified "Alt B" did not represent either concept adequately. Alternative F virtually omitted the strong QLG emphasis on fire protection (through fuels treatment in strategic network of shaded fuelbreaks),enhanced riparian standards, and watershed restoration.
Another issue we want to make you aware of is the existence of a "Confidential Forest Service Comment File". QLG has filed a Freedom of Information Act (FOIA) request to see this file. On August 31st, Regional Forester Sprague denied the FOIA request, stating that the Agency had a right to keep Forest Service comments internal, in order to foster free and open debate within the Agency. QLG says that the Forest Service had two years for internal debate while developing the DEIS. All Forest Service comments, made either to the EIS Team of directly to potential decision- makers, must be made public, because it is obvious that they will be given equal or greater weight in the Final EIS and Record of Decision than comments from the general public.
QLG is preparing a FOIA denial appeal to the Chief of the Forest Service, and would be grateful for any comments you would care to make on that issue to QLG, to the EIS Team, to the Regional Forester, or to the Chief.
Thank you for your thoughtful participation in the public process for the Cal Owl Draft EIS.
Linda L. Blum