PUBLIC COMMENT
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PUBLIC COMMENT

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CLEAR CREEK FOREST HEALTH IMPROVEMENT AND FUEL REDUCTION PROJECT Response to Comments GENERAL PUBLIC COMMENT FOREST SERVICE RESPONSE COMMENT #1 Thank you for this recommendation. The EA [There is no definition on what constitutes “forest health” or the has been edited to clarify this point. intent of the project until page 34 of the EA. This information needs to be put in the front of the document.] (C-1) Thank you for this recommendation. The EA COMMENT #2 [There are no definitions or explanations of the terms: activity has been edited to clarify these terms. fuels, jackpot burning, or whole tree yarding. These terms need to be explained in the document.] (C-1) COMMENT #3 A table showing design feature implementation [Is there really follow-up on the monitoring plans outlined in the and monitoring has been added to the EA EA? Is there a progress-report on the monitoring that can be Appendices. Past monitoring results are reviewed by the interested public?] (C-1) available upon request. This comment is outside the scope of the COMMENT #4 [For trails that would not be planned for use within the next two proposed action. This concern can be better years.] “…trails on steep slopes and those crossing sensitive areas addressed through the Forest’s Travel be closed to off highway vehicles and stabilized to prevent further Management decision process. soil erosion and sedimentation of watercourses.” (C-4) This comment is irrelevant ...

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CLEAR CREEK FOREST HEALTH IMPROVEMENT AND
FUEL REDUCTION PROJECT

Response to Comments


GENERAL
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #1 Thank you for this recommendation. The EA
[There is no definition on what constitutes “forest health” or the has been edited to clarify this point.
intent of the project until page 34 of the EA. This information
needs to be put in the front of the document.] (C-1)
Thank you for this recommendation. The EA COMMENT #2
[There are no definitions or explanations of the terms: activity has been edited to clarify these terms.
fuels, jackpot burning, or whole tree yarding. These terms need to
be explained in the document.] (C-1)
COMMENT #3 A table showing design feature implementation
[Is there really follow-up on the monitoring plans outlined in the and monitoring has been added to the EA
EA? Is there a progress-report on the monitoring that can be Appendices. Past monitoring results are
reviewed by the interested public?] (C-1) available upon request.
This comment is outside the scope of the COMMENT #4
[For trails that would not be planned for use within the next two proposed action. This concern can be better
years.] “…trails on steep slopes and those crossing sensitive areas addressed through the Forest’s Travel
be closed to off highway vehicles and stabilized to prevent further Management decision process.
soil erosion and sedimentation of watercourses.” (C-4)
This comment is irrelevant to the proposed COMMENT #5
“The private property areas near the Project area are not in any action. Wildland Urban Intermix (WUI)
great threat from wildfires. It appears that the residents have Defense Zone treatments are addressed in the
adequately cleared around their property to provide maximum Valley View Fuels Reduction Project decision
protection.” (C-5) process.
As noted in the Proposed Action and throughout COMMENT #6
“Most trees I saw which are marked for killing (blue paint), the EA, thinning occurs for more than fire alone.
especially the larger ones, are not very vulnerable to fire.” (C-5)
This comment is a general expression of opinion COMMENT #7
“…I find the Project proposal to be unnecessary and ineffective for for which we have no technical reply.
fire prevention and, in fact, detrimental to the forest ecosystem.”
(C-5)
COMMENT #8 Comments that state a position for or against a
“Thinning to a maximum of 19.9 inches dbh [in Alternative A] will specific alternative are appreciated as this gives
not accomplish the residual spacing desired for forest health and the Forest Service a sense of the public’s feeling
fuel reduction. The requirement of helicopter logging on part of and beliefs about a proposed course of action.
the sale is not economically feasible”. (C-6, C-8) Alternative B was developed to respond to these
significant issues.
As noted in the EA (pg 41) natural wildfires in COMMENT #9
“You propose to reduce the forest cover by [to] a minimum of the southern Sierra thin trees and reduce fuels on
40%, to control the location and proportion of forest species, and to a 10-25 year cycle. One of the objectives of the
simulate the natural burn cycles in a hopefully modified form. The project is to begin the process of restoring fire to
implications of this are that this would be the first of an ongoing its natural role in the ecology. The project is
series of such projects to be continued for as long as the forest and anticipated to take 15 years to complete at which
the funding endure.” (C-9) time naturally caused fires could be allowed to
burn under certain conditions (Wildland Use
Fire).

Clear Creek Forest Health Improvement and Fuels Reduction Project Page 1 of 22
Appendix C: Response to Public Comments GENERAL
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #10 No new roads are to be constructed or
“Your proposal also sadly includes the building of additional reconstructed Preliminary EA (pg 8). Some
temporary roads in the area. There are already far too many roads temporary roads will be constructed as
in the forest and unless the new roads were completely obliterated necessary but will be obliterated and returned to
after use, they would likely become yet more user-created pre-existing condition after use.
motorcycle routes.” Any new roads need to be identified in the
EA. (C-7, C-9)
COMMENT #11 While trail use may be mostly by motorcyclists,
“I would also take exception to your observation (p. 48) that trails the trails in the project area are available to all
in the area serve a “diverse group of recreation users.” … “In truth, single-track trail users.
over 90% of trail use is by motorcyclists.” (C-9)
COMMENT #12 This comment is outside scope of this analysis,
“If you really want to know how people feel, why not ask the thank you for your concern.
homeowners in Alta Sierra where your fuels reduction project is
now complete? I understand that some of them are planning on
selling their homes and moving out because of the deforestation.”
(C-9)
COMMENT #13 Flight distance may be the primary factor
“… helicopter logging of the steep slopes might not be influencing cost for aerial logging systems.
‘economically feasible,’ and that you might not keep these in the Distance is directly proportional to cost.
final decision. … the north-facing white fir forests are in desperate Therefore you need to locate landings as close to
need of thinning. I would propose even 11-29 inch logs be the harvest unit as possible. A medium-sized
included… … would it not make more sense to allow the helicopter has an operating cost of $4,300/hour,
helicopters to take those logs down the west-facing slopes to a so minimizing flight time and maximizing
landing somewhere on the Bodfish-Havilah road… This is one productivity is crucial. A general rule is that the
place where cutting up to 29” trees would benefit the groves and center of your harvest unit must be less than 0.5
‘sweeten the pot’ for the logging contract. Let the lumber mill miles from your landing with a vertical flight
decide whether they want the trees – make that a separate bid, but grade less than 28%. Power lines, roads,
give them a chance.” (C-7) railroads, and structures also affect the flight
path of a loaded helicopter. The Bodfish-
Havilah road is approximately 7-8 miles from
the south end of the project area (Piute Peak).
Locating a landing there would be too far, too
steep, and too costly.
COMMENT #14 The Preliminary EA page 5, describes the
“You mention protecting communities – yet the project area really project area including a portion of the Valley
isn’t very near Claraville at all, and really not that close to Valley View Wildland-Urban Intermix Threat Zone.
View. How does this project protect them”? (C-7) Treatments in the Threat Zone are designed to
provide a buffer and augment the proposed
treatments in the Defense Zone adjacent to the
homes at Valley View.
Claraville is too far removed from the Clear
Creek Project area to be affected by fuels
treatments.
COMMENT #15 The FlamMap fire prediction model was used to
“The Clear Creek Forest Health Fuels Reduction Project EA fails predict fire behavior in the project area
to provide scientific evidence to prove that implementing the (Preliminary EA, pages 41-47). The
project would contribute to human safety.” (C-11) relationship between fire behavior and human
safety is discussed in the EA and Fuels Analysis
Working Paper (Chambers 2006).



Clear Creek Forest Health Improvement and Fuels Reduction Project Page 2 of 22
Appendix C: Response to Public Comments GENERAL
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #16 See Preliminary working document pages 21-23
“The Clear Creek Forest Health Fuels Reduction Project EA fails & 49-67; final BA/BE.
to protect wildlife habitat and could cost taxpayers millions to
damage forest habitat so that trees could be shipped to the
sawmill.” (C-11)
COMMENT #17 The purpose and need for this project is two-fold
The analysis should “consider the effectiveness of achieving the as described on pages 5-7 of the EA. The
desired fuels reduction outcome of the lowest impact treatments alternative suggested does not meet both the
first, before considering the use of treatments with a higher impact fuels reduction ad the forest health objectives.
on the ecosystem. For example, if removing only the brush, lower As described on pages 15-16 of the EA, only
limbs, and some small diameter trees less than 4 inches in diameter thinning small trees would not provide enough
would achieve the required live crown base height and flame growing space for residual trees to remain
length, while retaining the most crown cover, then this treatment healthy into the future. Thinning some of the
should be implemented. If this treatment is insufficient …then larger live trees is needed to do this.
removing more limbs should be implemented before considering
removing larger trees and their canopy cover.” (C-11)


FOREST HEALTH/SILVICULTURE
PUBLIC COMMENT FOREST SERVICE RESPONSE
Fifty percent overstory and fifty percent COMMENT #18
“…riparian vegetation should be protected by no-operation understory does not currently exist in most
buffers…” “Fifty percent overstory and fifty percent understory riparian areas within the project.
canopy closure should be left in a well distributed multi-storied
stand within the buffer zones for protection of fish and wildlife The intent of the Clear Creek Project is to
values.” (C-4) provide a multiple storied stand with a mosaic of
dense and open conditions in understory and
overstory; but not continuous dense canopies in
either the understory or overstory. Uniformly
dense canopy is a prescription that would likely
contribute to catastrophic loss of all canopy
cover under wildfire conditions. The
Streamside Management Zone (riparian buffer)
would be treated by manual thinning and
prescribed fire.

Riparian Buffers
Riparian vegetation is protected by limited
equipment buffers along stream channels as
described in the final EA on:
• pages 25-26;
• page 98;
• Appendix B-3, pages 22 and 23; and
• Appendix B-4, pages 50 and 65-77.

COMMENT #19 The preliminary EA pages 34-35 describes the
[Perry et al., 2004 found that thinning trees <8” dbh and controlled necessity of removing some of the existing
burning to reduce logging slash would prevent fire moving into larger live trees to allow the remaining trees to
tree crowns even under extreme fires conditions.] have enough space, water, and nutrients to
“Why is it necessary to remove trees up to 19” dbh…in light of remain healthy and vigorous.
this?” (C-10)

Clear Creek Forest Health Improvement and Fuels Reduction Project Page 3 of 22
Appendix C: Response to Public Comments FOREST HEALTH/SILVICULTURE
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #20 Snag data has been added to the EA, page 76.
“You have provided no evidence in the EA to indicate that morality High snag levels were pointed out and readily
levels of LARGE SNAGS (>15” dbh) are excessively high, much visible during the field trip and noted on page 33
less even minimally adequate.” of the preliminary papers. The preliminary EA,
“The EA does not divulge how many large snags per acre are in page 22 also noted that snags would be
each unit proposed for treatment currently, and thus has no basis maintained at a minimum of 4 large snags
for the conclusion that there is too much mortality.” greater than 15”dbh per acre within treated units
[Recommend leaving the standing snags except for safety reasons.] and higher levels in untreated stands.
(C-6, C-7, C-10)
COMMENT #21 In the preliminary EA, Forest Health/
“Table 16 of the EA states that, in unit 9, there are 6 trees per acre Silviculture section on page 36, states “One
currently in the 20-29” dbh range (see No action column), but stand falls within the Eastside Pine vegetation
would be only 2/acre after Alt. A. This seems to contradict the type. Within this stand trees 11 to 29 inches dbh
description of alt. A, which states that live trees over 19” dbh will would be thinned to remove mostly unhealthy
not be removed. Which is it?” (C-10) and dying trees.” Unit 9 is the stand referred to.
This harvest follows the direction of the 2004
Sierra Nevada Forest Plan Amendment ROD (p.
51) which modifies canopy cover requirements
for Eastside Pine vegetation types This Eastside
Pine unit is the only exception to the 19”
diameter limit for live trees in Alternative A.
COMMENT #22 Tables 6, 7, and 8 in the Preliminary EA display
“The EA states, on p. 37, that Alt. A would reduce basal area to the basal area per acre for each unit proposed for
‘less than 150 square feet per acre’, and ‘less than 70 percent of thinning of intermediated sized trees. Values
normal’. Without a far more detailed description of existing basal include both the current and the estimated post-
area in each unit and the post-logging basal area in each unit, treatment (thinning and underburning) basal
including current and post-logging numbers of live trees and snags area per acre.
in each size class in each unit, the EA utterly fails to divulge the
extent and intensity of impacts”. (C-10)
COMMENT #23 Publications by the California Pest Council,
“…neither on p. 35 nor on p. 37 (nor anywhere else) does the EA Sartwell, and Oliver that are cited on page 35 of
cite any scientific authority or hard data to support these specific the preliminary EA support the stand densities
prescriptions [reduction of basal area to less than 150 sq.ft./ac and prescribed by Alternatives A, B, and C.
less than 70% of normal]. …no data is presented to explain or
justify the ‘less than 150 square feet per acre’ prescription”. (C-
10)
COMMENT #24 SNFPA did not give basal area
“On p. 35, the EA mentions the SNFPA 2003 review team recommendations for tree stocking. The Clear
recommended certain canopy cover levels, but it is not clear that Creek project silviculturist used the density
the review team recommended “less than 150 square feet” of basal guidelines from the California Pest Council,
area per acre in these forest types. More importantly, the SNFPA Startwell, and Oliver cited on page 35 of the
2003 review team’s recommendations are not scientific document preliminary EA, along with the 2005 Forest
and cannot serve as a proxy for actual data.” … “Moreover, you Inventory Analysis data cited on page 32, and
do not describe the methodology that you used to derive these field observations to develop the stand specific
prescriptions. As such, the EA violates NEPA’s requirement to prescriptions.
ensure scientific accuracy and integrity, and divulge methodology
and hard data.” (C-10)


Clear Creek Forest Health Improvement and Fuels Reduction Project Page 4 of 22
Appendix C: Response to Public Comments FOREST HEALTH/SILVICULTURE
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #25 The environmental analysis done for Clear
“As crown cover is reduced, there will be increased solar radiation Creek concurs with this comment.
falling on the ground surface and increased drying of the ground.
… at 40% crown cover these effects should be minimal, given that
solar radiation always strikes the earth’s surface obliquely at our
latitude, even in summer. My measurements also show that the
conifers found there [Kern Plateau] and in the Clear Creek area
extract soil moisture from depth of many feet, so drying of the soil
surface is of little consequence to them”. (C-6)
COMMENT #26 It is true that oaks are susceptible to death or
“Mature conifers of the species found in the project area all have damage from fires. However, underburning on
relatively thick bark that will protect the bole from damage to the Clear Creek is planned for relatively cool,
cambial layer from the burning of a surface fire a their base. This manageable conditions (preliminary EA p. 19).
is not the case with the oaks, and it is not clear that this strategy Few large oaks should be destroyed. Smaller
will protect them from the passage of even a benign surface fire.” oaks (< 10” diameter) are more susceptible, but
(C-6) any killed by underburning are likely to quickly
regenerate by sprouting.
COMMENT #27 An alternative involving underburning and
“…the health of forest stands such as …unit 52…of mostly white girdling would help achieve some desired stand
fir, canopy cover …reportedly 54% and basal area 194 square feet structure, density, species composition, and
per acre, both excessively high for these arid mountains. From a fuels conditions, but at higher monetary cost
fuel reduction standpoint, this stand needs thinning of trees of all than the proposed alternatives. The girdled
sizes up to 10 inches or so. … Additionally some even larger trees standing trees could attract bark beetles into the
need to be eliminated to reduce competition with other trees. … On treated stands and result in additional,
units with stands similar to what we saw on unit 52, I recommend uncontrolled tree mortality. Additionally, large
hand thinning trees up to 10 inches or so to reduce ladder fuels and trees girdled now would contribute to future fuel
girdling some larger trees [up to 29” dbh] for stand health to bring loadings as they rot and fall to the ground. This
crown cover down to 40%. … This should be undertaken in may be an acceptable solution where snags are
addition to the proposed underburning”. (C-6, C-7)) deficient. Stand exams within the project area
indicate that all areas will meet or exceed
desired snag levels, so this alternative was not
analyzed in detail.
COMMENT #28 Alternatives B and C prescribe a larger range of
“…the proposed thinning of trees between 19.5 and 29.5 inches intermediate size trees (10-29”) to be harvested
dbh, …and any other thinning of trees between 10 and 29.5 inches to reduce stand densities. This allows more
dbh…careless marking could result in [the] almost complete flexibility in removing unhealthy trees and
elimination [of large trees] from a stand – precisely the opposite of leaving desired trees to make up the future
the intended preservation of a balanced size distribution. … I stands. Marking prescriptions are based on
recommend that Larry add to his marking prescriptions a limit leaving desired amounts of canopy cover, and
along the line of taking no more than one third of the trees in the larger trees have larger canopies. This bias
size categories 19.5 to 29.5 inches and 10 to 19.5 inches”. favors leaving large trees over small trees, and
“…don’t use the removal of [Jeffrey pine and white fir greater than should adequately prevent over cutting of the
16”dbh] as an excuse to ‘fire proof’ a forest” – “they ARE large trees that typically contribute most to old
fireproof already”. (C-6, C-7) forest conditions.
COMMENT #29 This comment is a general expression of opinion
“To me, the forest in this area appears to be quite healthy. Only for which we have no technical reply.
about 10% of the trees appear to be affected by bark beetles and in
your report you state that such infestation appears to be decreasing
(p. 33). Can the forest possibly be healing itself?” (C-9)

Clear Creek Forest Health Improvement and Fuels Reduction Project Page 5 of 22
Appendix C: Response to Public Comments FOREST HEALTH/SILVICULTURE
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #30 Under-burning only in Units 9 and 34 is
Suggest under burning only in Units 9 and 34, both Jeffrey pine analyzed in Alternative C.
stands. Unit 9 “is now pretty thin and… you propose to reduce the The reason so many trees are removed in unit 34
canopy from 29% to 15%....” In Unit 34, the removal of “trees is because the tree counts shows about 305
from 388/ acre to 65/acre seems a bit excessive”. (C-7) saplings per acre less than 4” in diameter. These
are the fire ladder trees that will be mostly
removed by under burning. Less than about 20
trees per acre should be logged.
COMMENT #31 This subject is addressed in the silviculture
“It is disturbing to me that the EA fails to mention different species working papers for the project. There it states
of trees at all – they are not all created equal, nor should they be that one of the silviculture objectives is to
considered under one blanket. White fir are a different factor in the increase the percentage of shade intolerant pines
ecosystem than are Jeffrey. … I would urge that you cut out more and hardwoods (by harvesting and/or
white fir than Jeffrey… Oaks thrive after being burned, and at underburning). Timber marking instructions
least you mention them”. (C-7) will favor leaving Jeffrey and sugar pines over
white firs. All oaks and other hardwoods will be
left to grow.
COMMENT #32 References cited in the EA and silviculture
The EA fails to provide the science to prove that managing stand working papers by Fiddler, et al, Oliver, Schmid
density with the proposed actions could be effective in achieving & Mata, Sartwell, and Stephens & Fule indicate
the purpose and need. (C-11) forest health and bark beetle resistance can
benefit from stand thinning.
COMMENT #33 See response to Comment #32.
“The EA fails to provide the science to prove that managing stand
density by killing 11 to 19.9 inch diameter trees with the proposed
action could be effective in achieving the purpose and need”. (C-
11)
COMMENT #34 Cited references by Bulaon, et al, and Oliver
“Since the upper limit on stand density is not defined, the EA address this issue. Bulaon points out “In the
cannot conclude that the existing stand density is causing a absence of fire or thinning, the prognosis for the
problem. The EA fails to provide scientific evidence to prove that Piutes is thickets of smaller size-class trees that
the current stand density is causing a problem and therefore this experience waves of mortality during droughts.”
project has not justification for implementation.” (C-11)
This project did not target a desired number of COMMENT #35
“…EA fails to provide scientific evidence that machine piled and residual seedlings and saplings because no
burned surface fuels will insure the survival of an adequate number regeneration harvesting to replace existing stands
of tree seedlings and saplings.” (C-11) is proposed.
EA page 21: Under-burning will be done to
mimic natural fire behavior and leave
approximately 30 percent of the areas unburned,
to leave smaller trees for stand structural
diversity.
COMMENT #36 The project does not propose to eradicate all
Beetles are a natural part of the forest and they are a natural part of beetles by thinning. It does propose thinning to
the forest process that maintains this ecosystem. This project is create healthy, vigorous trees that are more
proposing to log 20 to 95 percent of the trees between 11 and 19 resistant to heavy beetle losses like those that
inches to attempt to thin away the beetles, which cannot be thinned occurred in the Piute Mountains over the past
away. The EA fails to provide scientific proof that this project can decade. This strategy is supported by cited
achieve the stated purpose and need for this project. (C-11) papers by Bulaon, et al, Fiddler, et al, Sartwell,
and Schmid & Mata.


Clear Creek Forest Health Improvement and Fuels Reduction Project Page 6 of 22
Appendix C: Response to Public Comments FUELS MANAGEMENT
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #37 The preliminary EA, pages 41-42 and the Fuels
“There is very little fuel accumulation on the forest floor in the Analysis (Chambers 2006) describe the current
Project area. There are only a few locations where this could fuel loading in the project area and the resulting
become a fire hazard and those are very limited in size.” (C-5) predicted fire behavior.
COMMENT #38 The preliminary EA, pages 41 & 43 describe the
“The greatest fire threats in the Project area are associated with current condition of the plantations and the
former clear-cuts and the accompanying lack of forest canopy.” effects of proposed treatments within those
[Timber activities create brushy areas and crowded plantations; this plantations on fire behavior. The proposed
creates a serious fire threat.] thinning of intermediate size trees is not
“Reducing canopy cover…by killing larger trees will only expected to effect fire behavior or potential fire
exacerbate this type of problem.” (C-5) risk due to drying of the site (see preliminary
EA, page 43).
COMMENT #39 Preliminary EA, pages 41-42 describe current
“Efforts to burn understory vegetation for fire protection are not fuel loading, predicted fire behavior levels, and
needed and will only contribute to more air pollution and climate the need for treatment of surface fuels to protect
changing gasses. Chipping of vegetation will help protect the valuable resources.
forest soils from erosion and contribute to healthy soil A light underburn, similar to what is believed to
development.” (C-5) be the natural pattern of extensive low intensity
fires that frequented forests of the Sierra Nevada
on a 10-25 year cycle, releases nutrients to
stimulate growth of native plants. Many of the
plants require fire for germination. Low
intensity fire generally stimulates greater
abundance and diversity of wildlife and reduces
fuel loading so the next cycle remains low
intensity. Chipping is a possibility and is
proposed where appropriate in the proposed
action and alternatives. Chipping is not feasible
on all areas due to slopes; lack of access, size of
material, cost, and even chipping contributes
hydrocarbon emissions and dust (PM-10) to the
air.
COMMENT #40 Both studies describe thinning and burning to be
“…analyze the following studies, which found that severe fire the best method to guarantee reduction in fire
could be prevented with an 8-10” dbh limit….severe fire can be mortality during wildfire events. In Perry, D.A
effectively mitigated by felling only very small trees…or explain et al.2004, only addresses reducing torching by
in detail why these studies do not apply.” thinning less than 20cm diameter trees, but does
* Perry, D.A. et al., 2004. “Forest Structure and Fire Susceptibility not discuss crown fires; the study does suggest
in Volcanic Landscapes of the Eastern High Cascades, Oregon.” reducing crown fire to be a more difficult task
rdConservation Biology 18: 913-926. (3 paragraph) but thinning and burning is the recommendation.
* Omi, P. N., and E. J. Martinson, 2002. “Effects of fuels The Clear Creek project proposes to implement
treatments on wildfire severity. Final Report.” Joint fire Science just what this study is recommending.
Program Governing board, Western Forest Fire Research Center.
Available from
http://www.cnr.colostate.edu/frws/research/westfire/finalreport.pdf.
(C-10)


Clear Creek Forest Health Improvement and Fuels Reduction Project Page 7 of 22
Appendix C: Response to Public Comments FUELS MANAGEMENT
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #41 These two studies, as well as the studies listed in
“Your EA assumes that mechanical thinning…will reduce, rather Comment #40, recommend thinning followed by
than increase, potential for severe fire. There is ample evidence to burning as the best methods to reduce potential
contradict this.” [such as]: tree mortality during a wildfire. Other studies
* Raymond and Peterson, 2005. Canadian Journal of Forest have shown that stands that have been thinned
Research 35: 2,981-2,995. and under-burned are less likely to have
* Hanson and Odion, 2006. (abstract attached) significant mortality as a result of wildfire and
“You have not analyzed, or adequately analyzed, this type of are less likely to support crown fire.
evidence from actual wildland fires burning through areas Note that most published literature supports the
mechanically thinned.” [The modeling results cited in the EA may Sierra Nevada burned on a frequent cycle
not reflect actual real-world fire behavior.] (C-10) (Sierra Nevada Ecosystem Project). Because
the fires were frequent and the forests were
generally open, the fires generally remain low
intensity. There likely were patches of dense
habitat and reports by John Muir as well as other
reports indicate that there were patches of high
intensity fire, generally 1-2 acres in size. This is
further supported by studies in the Sierra San
Pedro de Matir in Mexico, which has many
similarities to the Sierra Nevada, Much more
similarity than the northwest coast or Canada.
In the Sierra San Matir, frequent low intensity
fires occur in open forests with very little
mortality in medium and larger trees. The
Sierra San Matir suffered similar drought
conditions during the same period that resulted
in severe drought related tree mortality in
southern California and contributed to the severe
2003 fire season. Fires in the Sierra San Matir
in 2003 resulted in very low mortality of trees
compared to southern California (Skinner et al.
2005).
These studies corroborate what has been
proposed in the action alternatives for the Clear
Creek project to be the best treatments for the
project and surrounding areas.
COMMENT #42 Preliminary EA, page 6 describes the vegetative
“Your EA states that the project area is prone to high severity fire and fuel attributes that serve as indicators of the
because it is classified as Condition Class 2 and 3. The Condition amount of departure from the natural fire regime
Class rating system was found to have no predictive value in recent that has occurred in the project area. These
large fires in the Sierra Nevada, including the McNally and Manter vegetative and fuel attributes also contribute to
Fires, in a study that I co-authored. Odion and Hanson (in press in fire behavior characteristics that would be lethal
Ecosystems).” (C-10) or mixed-lethal.

Unfortunately, the study referenced has not been
provided for our review.
COMMENT #43 Preliminary EA, pages 15-16, 19-22 describe the
“And speaking of underburning, your proposals offer us no real measures to be taken and standards to be met
assurance that the fires you set might not escape and cause when prescribed burning. Burning within a
“unintended results” (p.53). Your only solution to this risk prescription gives the Forest Service a better
involves yet another layer of deforestation in the form of fire chance of maintaining control as well as
lines.” (C-9) providing contingency forces to handle escapes.

Clear Creek Forest Health Improvement and Fuels Reduction Project Page 8 of 22
Appendix C: Response to Public Comments FUELS MANAGEMENT
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #44 The project area is within and adjacent to
Jack Cohen, “the California Department of Forestry and the Wildland Urban Intermix Threat and Defense
Government Accountability Office agree that treating the 200 feet Zones for the Valley View community.
immediately adjacent to and surrounding structures is the proper Preliminary EA pages 2, 5, 6, and 38 describe
way to protect communities – not logging miles from communities. this project’s relationship with the Valley View
This project would log miles from the community of Valley View Defense Zone Hazardous Fuel Reduction project
in contradiction of fire science”. immediately surrounding the community.
The Clear Creek Forest Health Fuels Reduction Project EA uses As described in the preliminary EA pages 7, 23,
‘selective science’ and fails to provide a fuels reduction project that and 33-38 thinning intermediate size trees is
could protect the communities it purports to protect. The EA fails proposed improve growing conditions for the
to uses Forest Service fire Science by Jack Cohn in order to justify remaining trees into the future.
logging more than 200 feet from structures.” (C-11)
COMMENT #45 The Chief of the Forest Service granted the
“The EA fails to provide a Fire and Fuels Management Plan to Sequoia National Forest a waiver of the
guide the decision making process as required by the national Fire requirement that each National Forest have such
Plan and the Sequoia LMP and Mediated Settlement Agreement. a fire plan by letter dated 06/02/2006.
Please provide a copy of the new Sequoia National Forest Fire and
Fuels Management Plan and the analysis of how this project meets
the objectives of the Fire Plan”. (C-11)
COMMENT #46 Past logging has had some effect on potential
“The EA fails to mention the past high-grade logging that removed fire hazard and effects. This issue is addressed
canopy cover in this area that caused this area to become hotter and on page 43 of the preliminary EA. In general, as
dryer and more susceptible to surface winds all of which would can be seen from table 19, page 65 of the
increase the fire danger, which this project would exacerbate.” preliminary EA, past harvest has been a very
(C-11) small proportion of the project area and is
unlikely to have widespread landscape level
effects on fire behavior.
COMMENT #47 An alternative that only removes brush, lower
“The EA fails to disclose if the modeling method [FlamMap fire branches, and trees up to 6 inches diameter was
prediction model] predicted what the conditions would be if an not studied in detail as it does not address the
alternative that only removes brush, lower branches, and trees up to need to treat beetle mortality and create healthy,
6-inch diameter. The EA did not disclose how the model for this growing forests. This type of treatment was
alternative compared to the current alternatives.” (C-11) analyzed over portions of the project area under
all of the action alternatives. This treatment is
proposed in the owl PAC and HRCA and the
goshawk PAC, as well as a pre-treatment to
under-burning on other non-thinned acres. Flam
Map was used for this evaluation and is
displayed in the Fuels Analysis Clear Creek
Project (Chambers, 2006).


Clear Creek Forest Health Improvement and Fuels Reduction Project Page 9 of 22
Appendix C: Response to Public Comments FUELS MANAGEMENT
PUBLIC COMMENT FOREST SERVICE RESPONSE
COMMENT #48 See responses to Comments #37 and 47.
“Since [the EA supports] that ‘reduced surface fuels and stand
density after thinning small trees up to six inches dbh in ladder fuel
positions and under burning would help to slow the spread of fires
and reduce the potential for fire to spread into surrounding
dominant and co-dominant trees’, proposing to log larger trees in
unnecessary, damaging to the forest resources, and should not be
implemented.”
“On the-ground observations in the project area [indicate] there is
very little surface fuel that would require implementation of this
project. The surface fuels could easily be taken care of with
prescribed fire following removal of ladder fuel trees up to 6-inch
diameter and brush. Goats could do a reasonable job of removing
much of this fuel.” (C-11)
COMMENT #49 The EA, page 59 states that less aerial fuel
“The EA fails to discuss winds faster than seven miles per hour. continuity in the larger trees would lessen the
The removal of canopy cover increase surface winds to exacerbate chances of crown fire in the early stages of a
the flames, wildfire intensity, and fire risk.” (C-11) wildfire event with winds less than seven miles
per hour.
The wind speed used for the FlamMap Model
was 12 mph at eye level. This is interpolated
from the average wind speed measured at 20
feet by the local weather station.
COMMENT #50 The preliminary EA pages 14-17, displays the
“The Clear Creek Forest Health Fuels Reduction Project EA fails schedule of the smaller prescribed burn blocks
to adequately analyze the full impacts of prescribed burning large over a fifteen year period. Preliminary EA
areas at one time and fails to prescribe resting allotments following pages 77-88 describe the effects of prescribed
fire.” (C-11) burning on the watershed.
The need to defer grazing after prescribed burns
is based on range readiness general guidelines in
the MSA, page 35.
COMMENT #51 See response to Comment #41.
“The Clear Creek Forest Health Fuels Reduction Project EA fails
to provide the scientific basis to claim logging more canopy cover
will reduce the high fire risk currently perceived by the Forest
Service.” (C-11)
COMMENT #52 Hand lines may vary from .5 foot to 6 feet
“The EA fails to provide a definition of the ‘hand line’ width that scraped to bare mineral soil with hand tools with
would be constructed in the California spotted owl Protected associated removal of brush and small trees for a
Activity Center (PAC).” (C-11) width of 6 to 10 feet or may consist only of a
wet line with water from a hose. Hand lines on
average will be 3 feet wide or less but size and
technique will vary based on fuel type,
topography and special features such as down
logs or accumulations of heavier fuels.

Clear Creek Forest Health Improvement and Fuels Reduction Project Page 10 of 22
Appendix C: Response to Public Comments