Comments to the Rogue River-Siskiyou National Forest Regarding “Appropriate Management Response”
Dubrasich, Michael E. and Gregory J. Brenner. 2008. Comments to the Rogue River-Siskiyou National Forest Regarding “Appropriate Management Response”. Western Institute for Study of the Environment.
Full text [here]
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Selected Excerpts:
Executive Summary
The purpose of this document is to request that the Rogue River–Siskiyou National Forest prepare an Environmental Impact Statement (EIS) before altering or amending their Forest Plan to include unprepared fire, known as Wildland Use Fires.
We believe unprepared fires can have significant effects upon natural resources and the human environment. The National Environmental Policy Act requires the preparation of Environmental Impact Statements before the U.S. government engages in activities that might have significant effects.
The EIS process aids in revealing, analyzing, and public discussion of the potential effects before they happen. That is a beneficial process, as well as required under federal law.
This document is a statement of our rationale for requesting an EIS process. We present this document to the Rogue River – Siskiyou National Forest so that they might understand and comply with federal law. …
Table of Contents
I. Statement of Purpose 1
II. Introduction 2
III. Wildland Fire Use 8
IV. WFU Implementation Uncertainties 13
V. Probable Significant Impacts/Effects on Flora 20
VI. Probable Significant Impacts/Effects on Fauna 35
VII. Probable Significant Impacts/Effects on Historic/Cultural
Resources and Values 60
VIII. Probable Significant Impacts/Effects on Watersheds and
Water Quality 86
IX. Probable Significant Impacts/Effects on Airsheds and
Air Quality 91
X. Probable Impacts/Effects on Recreation and Scenery 101
XI. Probable Significant Impacts/Effects on Rural Economies 104
XII. Probable Significant Impacts/Effects on Fire Costs and Losses 108
XIII. Probable Significant Impacts/Effects on Public and
Fire Fighter Safety 121
XIV. Probable Significant Cumulative Impacts/Effects 129
XV. Conclusions 133
XVI. References 137
Appendices Listing 148
II. Introduction
Who We Are
The Western Institute for Study of the Environment (W.I.S.E.) is a non-profit 501(c)(3) corporation organized exclusively for educational, and scientific purposes, including the delivery of original scientific articles, reviews of scientific articles and books, original literature, and case study reports to the public via a website on topics related to promoting the proper management of the environment. In addition, W.I.S.E. organizes special events with guest speakers, awards banquets, field tours, and symposia.
W.I.S.E. is a collaboration of environmental scientists, practitioners, and the interested public. We provides a free, on-line set of post-graduate courses in environmental studies, currently fifty Topics in eight Colloquia, each containing book and article reviews, original papers, and essays at https://westinstenv.org.
The Principal Author of this document is Michael E. Dubrasich, the Executive Director of W.I.S.E. Mr. Dubrasich is a professional consulting forester who has extensive experience in, and makes frequent use of, the Rogue River–Siskiyou National Forest for research and recreation. W.I.S.E. membership includes wildlife biologists, forest historians, retired and active US Forest Service employees, and others who also have extensive experience in, and make frequent use of, the Rogue River– Siskiyou National Forest for scientific research and outdoor recreation. We foresee serious injury to our legitimate private and economic interests within the jurisdiction of the RR-SNF should the major Federal actions described in this document occur.
The Rogue River–Siskiyou National Forest
The Rogue River-Siskiyou National Forest (RR-SNF) is a United States National Forest located on both sides of the border between the states of Oregon and California. The formerly separate Rogue River and Siskiyou National Forests were administratively combined in 2004. The Rogue River-Siskiyou National Forest ranges from the crest of the Cascade Range west into the Siskiyou Mountains, covering almost 1,800,000 acres (7,300 km²). The RR-SNF is administered by the USDA Forest Service.
The Issue At Hand
On March 5, 2008, the RR-SNF issued a Notice on their website [here]:
The Notice requested public comment “regarding a proposal to amend the Forests’ Land and Resource Management Plans to allow for the full range of Appropriate Management Response strategies for the management of wildland fires.”
This document consists of our public comments pertaining to and in fulfillment of the RR-SNF request. …
The Necessity of Preparing an EIS
We maintain that an Environmental Impact Statement is necessary in this case.
The RR-SNF is allowed under law to prepare an EA to make a preliminary determination as to whether the proposed action will have a significant effect upon the environment. If the EA establishes that the agency’s action may have a significant effect, then an EIS must be prepared (NEPA 102, 42 U.S.C. 4332.)
We maintain that the proposed modification of the fire management direction for Wildland Fire Use in the Appropriate Management Response will indeed have very significant and intense effects upon society as a whole (both human and national), the affected region, the affected interests, and the locality, both short- and long-term. The proposed major Federal action will:
- negatively affect public health and safety;
- impact the unique characteristics of the geographic area including natural, historic, and cultural resources and ecologically critical areas, including but not limited to threatened and endangered flora and fauna, historical/cultural values, water quality, air quality, climate change, public recreation, public scenery, and local, state, and national economies;
- result in highly controversial effects on the quality of the human environment;
- involve highly uncertain, unique, and unknown risks to the human environment;
- will establish a precedent for future actions with significant effects and represents a decision in principle about a future consideration;
- is related to other actions with cumulatively significant impacts;
- will adversely affect districts, sites, highways, structures, and objects listed in or eligible for listing in the National Register of Historic Places and will cause loss or destruction of significant scientific, cultural, and historical resources;
- will adversely affect endangered and threatened species and their habitats that have been determined to be critical under the Endangered Species Act of 1973; and
- threatens a violation of Federal, State, and local law and requirements imposed for the protection of the environment.
About This Document
The main body of this document, Comments to the Rogue River-Siskiyou National Forest Regarding “Appropriate Management Response” includes an explanation of what the RR-SNF is proposing and the various significant impacts and effects that will result from adoption of that proposal. Also included is a list of references and various supporting documents in the Appendices.
