1. Roads and logging degrade aquatic ecosystems by increasing levels of fine sediment deposited in streams and by altering natural streamflow patterns. Increased fine sediment deposition in streams and altered streamflows and channel morphology result in increased adult and juvenile salmonid mortality, a decrease in aquatic amphibian and invertebrate abundance or diversity, and decreased habitat complexity. The FEIS did not present information regarding the significant effects of road construction (temporary or permanent), regeneration, thinning, and riparian activities on aquatic health. Deferring analysis to a brief, non site-specific ACS analysis is not acceptable according to the public disclosure requirements of NEPA. Furthermore, FLOW asserts that the Medford BLM is vastly underestimating the significance of the proposed regeneration, road construction activity, and thinning on various streams in the planning area.

2. The FEIS did not present scientific evidence regarding the impacts of logging and road construction (even with regeneration planned) on riparian areas. FLOW summarizes and lists a sampling of references below with applicable findings for BLM consideration.

Roads degraded stream habitat for aquatic species, including salmonids, by accelerating erosional processes and modifying natural drainage networks. Roads accelerate soil erosion rates due to surface erosion and mass soil movement such as slumps and earthflows, debris avalanches, debris flows, and debris torrents. High rates of stream sedimentation result from this increased erosion. Soil erosion rates (m3/hectare) were 30 to 300 times higher on forests with roads than undisturbed forest. Roads also altered streamflow rates and volumes, which along with increased sedimentation, resulted in altered stream channel geometry. Acting as new flowpaths for water, roads increased the channel network over watersheds, increasing the drainage density. Erosion resulted in sedimentation of streams and declines in spawning habitat when too high a proportion of fine sediment was deposited. Macroinvertebrates, the primary food source of juvenile fish, also declined when large amounts of sediment were present. (Furniss, M. J., T. D. Roelofs and C. S. Yee. 1991. Road construction and maintenance. In Influences of forest and rangeland management on salmonid fishes and their habitats. American Fisheries Society Special Publication 19: 297-323)

Logging activities degraded stream habitat by changing the amount, quality, and timing of flowing water, increasing erosion rates, and reducing stream habitat diversity. Logging altered streamflows by affecting snow accumulation rates in forests and snow melt rates. Because of vegetation removal, logging also changed evapotranspiration rates and soil water content, with resulting increases in annual runoff. Soil compaction changed infiltration rates and therefore runoff and erosion rates. Stream channel structures were also altered after logging, with a corresponding loss of the habitat diversity required by fish populations. By accelerating erosion rates, logging increased sedimentation rates of streams. In the steep and high-rainfall forests of Oregon, Washington, British Columbia, and Alaska, for example, mass movements of soil were the dominant erosional process. Many of these mass movements originated on open areas after logging, with increases in frequency ranging from two to 31 times.

(Chamberlin, T. W., R. D. Harr and F. H. Everest. 1991. Timber harvesting, silviculture, and watershed processes. In Influences of forest and rangeland management on salmonid fishes and their habitats. American Fisheries Society Special Publication 19: 181-205)

Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests. Mass erosion events were inventoried over a 20-year period in the Siskiyou National Forest in the Klamath Mountains of southwestern Oregon. Aerial photos were analyzed from 24 forest sites and erosion attributed to roads, logging, or natural events. The volume of soil mass movements was estimated from the photographs, with partial field checking to confirm accuracy. Debris slides were found to be the primary type of mass erosion, accounting for about 80% of the volume of soil moved and 90% of mass erosion events inventoried. A total of almost 1.5 million yd3 of debris slide erosion occurred. Roads, occupying 2% of the area studied, were the sites for more than half the slides and 60% of the erosion volume. Clearcut areas, occupying 10% of the area studied, were the sites for 34% of the slide events and 18% of the slide volume.

(Amaranthus, M. P., R. M. Rice, N. R. Barr and R. R. Ziemer. 1985. Logging and forest roads related to increased debris slides in southwestern Oregon. Journal of Forestry 83: 229-233)

Roads were responsible for 61% of the soil volume displaced by erosion in northwestern California. This study inventory covered 344 miles of roads in the Coast and Klamath Mountains. Roads were thinly rocked, graveled, or heavily rocked and regularly maintained logging roads. Slope, grade, aspect, cut-and-fill height, and soil volume displaced by erosion were recorded on each 1-mile road segment. Mass erosion was the predominant form of erosion occurring in the study sites. Roads caused 152 of the 171 major erosional events inventoried (events that displaced more than 20 cubic yards of soil), and 61% of the soil volume displaced by erosion was due to these road-related events. The remainder was due to natural events and some logging-caused erosion. Road-related erosion increased with the slope traversed by the road. Seasonal roads had similar erosion rates to main-haul (and regularly maintained) roads. In a separate study, erosion due to roads relative to logging areas was studied in 30,000 acres of commercial timberland in Six Rivers National Forest. The road network occupied less than 4% of the total logging area. Total erosion from the 30,000 acres was 137,800 cubic yards. Of this total, 40% came from the roads and 60% from the logged areas. The average erosion rate in the road rights-of-way (47 cubic yards per acre) was 17 times the average erosion rate in the logging areas (2.82 cubic yards per acre).

(McCashion, J. D. and R. M. Rice. 1983. Erosion on logging roads in northwestern California: How much is avoidable? Journal of Forestry 81: 23-26)

Clearcutting increased the frequency of mass soil movements from hillsides. A review of the scientific literature, including research from Alaska, Utah, California, Oregon, and Japan, demonstrated that clearcutting on slopes increased the frequency of mass soil movement events (landslides, earthflows, slips, etc.). The loss of forest cover was believed to affect slope stability in two principal ways:

During storm events in southwestern Washington, average sediment levels in runoff from forest roads ranged from 500 mg/l to 20,000 mg/l. Roads were direct sources of sediment delivery to streams, with approximately 34% of road drainage points entering stream channels. The authors studied the erosion of sediment from two kinds of forest gravel roads in southwestern Washington: heavily used, valley-bottom haul roads and midslope secondary haul roads. Sampling sites were located at the downslope of each cross-drain and at ditches draining from cut slopes. Traffic use of each road was also monitored. The sediment produced from each road segment was related to traffic rate as well as to type of road surfacing material. The majority of the sediment produced (80%) was material finer than 0.004 mm. Steeper roads produced a higher proportion of coarser material (primarily sand). Average sediment concentrations from the secondary road sites were 2,000 mg/l, with a maximum of 19,500 mg/l. Hourly concentrations from the mainline road ranged from 500-700 mg/l, occasionally exceeding 20,000 mg/l. Delivery of this sediment to streams was investigated by carrying out an inventory of road drainage sites in three watersheds. Two thousand drainage points, along 730 km of road, were identified. Of these, 34% directly entered streams rather than draining into the forest floor.

(Bilby, R. E., K. Sullivan and S. H. Duncan. 1989. The generation and fate of road-surface sediment in forested watersheds in southwestern Washington. Forest Science 35: 453-468)

Gravel forest roads generated up to 440 tons of sediment/km/year from surface erosion. A one-year field study was conducted to determine how much sediment was generated from forest road surfaces and from ditches and cutbanks. Ten road segments were investigated in the Olympic Mountains of Washington State. Of these, eight were gravel roads and two were paved roads. Traffic use was categorized as heavy (more than four logging trucks per day), moderate (one to four trucks), light, and abandoned. During rainstorms, water discharge was measured at the mouth of each culvert and from natural lips on abandoned roads. Rainfall intensities were recorded at each sampling location. Three factors - traffic intensity, road gradient, and road segment length - were investigated. Sediment loss was related to traffic intensity and was highest on heavy-use gravel roads compared to unused roads or paved roads. Sediment yield from cutbanks and ditches alongside paved roads was less than 1% of that from gravel roads. Heavily used roads were calculated to produce 440 tons of sediment/km/yr over the period of study, compared to lightly used roads with 3.8 tons/km/yr and paved roads with 2 tons/km/yr.

(Reid, L. M. and T. Dunne. 1984. Sediment production from forest road surfaces. Water Resources Research 20: 1753-1761)

Roads and clearcut logging increased peak stream discharges and advanced the timing of peak discharges in multiple paired watershed studies, most likely because of subsurface flow being converted to surface flow at road cuts. Even after many years, roads and clearcut logging, both together and separately, resulted in significant increases in stream peak discharges. The study examines paired watersheds in the western Cascades and examined road building, logging, and peak discharge records to compare streamflow peaks pre- and post-treatment. Records for two pairs of small basins extended over 34 years, and records for three adjacent large basin pairs extended over 50 to 55 years. One of the small watersheds was 100% clearcut without road construction. After clearcutting, a significant number of storms resulted in higher peak discharges and volumes, and began earlier. A higher-than-expected number of runoff events had greater peaks and volumes. Sixteen to 22 years after clear-cutting, average peak discharges were still significantly higher (almost 40%) than pre-logging levels. The second small basin provided four years of data on the impact of roads alone, before logging began. Roads occupied 6% of the watershed. After road construction, a higher-than-expected number of storm events had higher peak discharges and began earlier. After clearcutting 25% of the watershed, average peak discharge increased by 50% in the first five years, and storm discharges began an average of six hours earlier than pre-treatment. After 25 years, average peak discharges were still significantly (more than 25%) higher than pre-management levels. Similarly, in the three large basin pairs, peak discharge increased as cumulative area logged increased. Begin times were not reported. The authors note that the most likely mechanism for the increase in peak flow due to just roads was road cuts converting subsurface flow to surface flow, which was then routed directly to stream channels. Logging, they conclude, had an impact on streamflow due to changes in evapotranspiration and snow accumulation and melt rates.

(Jones, J. A. and G. E. Grant. 1996. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon. Water Resources Research 32: 959-974)

Roads formed new surface flow paths to natural channels and incised new gullies, so increasing the routing efficiency of water; thereby probably explaining some higher stream peak flows. Two fifth-order basins (Lookout Creek and Blue River), in the western Cascades of Oregon, were studied to determine the mechanism by which logging roads may alter stream peak flows by changing water routing efficiency. The road density in each basin was 1.9 km/km2, and roads occupied 3% of each basin's area. A sample of 62 km of the road network was surveyed. A total of thirty-one 2-km transects was selected, and the transects were subdivided into segments at each culvert. Study sites were distributed between valley, midslope, and ridgetop sites and among roads ranging in construction period from the 1950s to the 1990s. A subsample was also studied immediately after storm events. Road culverts delivered water to natural stream channels at stream crossings, into new gullies incised below culvert outlets, or onto hillslopes, where water reinfiltrated the soil. The first two mechanisms of surface flow linked the roads directly to the stream channel network. More than 57% of the total road length surveyed was calculated to be connected to the stream network by these two flowpaths. Of the 436 culverts examined, 33% crossed streams and 23% were ditch-relief culverts with gullies incised below. Thirty-four percent of the road length drained to stream channels and 24% drained to gullies. Of the gully-forming culverts studied immediately after storm events, approximately half directed surface runoff to a nearby channel or saturated area. The authors estimated that these new flowpaths due to roads resulted in an increased drainage density of 36% and 39% in the two basins, although they noted that these figures would probably vary by season and by the degree to which gullies were connected to streams.

(Wemple, B. C., J. A. Jones and G. E. Grant. 1996. Channel network extension by logging roads in two basins, western Cascades, Oregon. Water Resources Bulletin 32: 1195-1207)

Forest roads extended the natural channel network, initiated new channels, and increased the susceptibility of steep slopes to landsliding. Road cuts intercepted subsurface flow and diverted it to roadside ditches. Field surveys were conducted at three sites in the western United States to investigate road drainage and associated landsliding and channel network extension. The study sites were located in 1) the southern Sierra Nevada; 2) on Mettman Ridge in the Oregon Coast Range; and 3) on Huelsdonk Ridge on the Olympic Peninsula. Drainage area and slope were determined to be the key criteria contributing to slope instability (so leading to landslides) and initiation of new water channels. The author mapped all discharge points from the roads and estimated the contributing drainage area. In each area, average ground slopes were also measured. In the southern Sierra Nevada site, road drainage resulted in the road surface acting as an extension of the natural channel network. Road cuts had diverted both surface and subsurface flow into ditches. Four hollows had lost natural drainage waters due to diversion by the roads. Three different hollows received extra drainage from the road system. The overall drainage density of the area studied (1.2 km2) had increased by a factor of 1.6. Forest roads studied in Oregon and Washington were both ridgetop roads. Roads had initiated new channels. Road-associated landsliding was highest on the steepest slopes and on slopes having the greatest drainage area. Drainage density due to new water flowpaths increased by a factor of 1.23 at the Oregon study site; no figure was reported for the Washington site. Road discharge points were studied immediately after rainfall only at Oregon site. At other sites, the author estimate that mapping accuracy of drainage areas was within +/- 30%.

(Montgomery, D. R. 1994. Road surface drainage, channel initiation, and slope instability. Water Resources Research 30: 1925-1932)

Salmonid survival rates decreased after logging and road construction as fine sediment levels in streams increased and as important habitat characteristics, including the number of pools and winter cover, decreased. Studies from Oregon, Idaho, British Columbia, and Alaska, for instance, showed that salmonid abundance and fry survival decreased as fine sediment levels increased after logging. Fine sediment in deposits or suspension also reduced the availability of food in streams by reducing invertebrate abundance and primary production. Suspended sediment increases were shown to affect salmonids in various ways, including avoidance, cessation of feeding, and disrupted social behavior. The increased frequency of landslides and other mass erosion events due to logging and roads changed channel morphology, reducing pool area and depths and resulting in stream reaches that were wider, shallower, and more prone to bank erosion. Studies in British Columbia, for instance, showed that pool habitat was reduced by an average of 79% in streams affected by debris torrents and suitable winter cover was reduced by an average of 75%. Coho salmon winter survival averaged 1.8% in stream reaches affected by debris torrents compared to survival rates of 24.5% in unaffected streams.

(Hicks, B. J., J. D. Hall, P. A. Bisson and J. R. Sedell. 1991. Responses of salmonids to habitat changes. In Influences of forest and rangeland management on salmonid fishes and their habitats. American Fisheries Society Special Publication 19: 483-518)

Survival rates of Coho salmon and steelhead trout fry decreased as the proportion of fine sediment in spawning gravel increased. Laboratory experiments were conducted at the Alsea Watershed Study field station to investigate the relationship between the proportion of fine sediment in spawning gravel and the survival of coho salmon (Oncorhynchus kisutch) and steelhead trout (Salmo gairdneri) fry. Six different gravel sizes were mixed in troughs to create spawning gravel similar in composition to natural coho salmon redds in Deer Creek, in the Oregon Coast Range. The proportion of fine sediment (sand 1-3 mm in diameter) was then increased by 10% increments to create eight gravel mixtures with 0-70% sand by volume. Coho salmon and steelhead fry were buried in the gravel, and their date of emergence, survival, and weight were recorded. Six replicates were tested. As the proportion of fine sediment in the gravel mixtures increased, coho salmon fry emerged earlier and were smaller in size. Their survival rates decreased as fine sediment percentage increased, from 96% survival in the control gravel mixture to 8% survival in the mixtures containing 70% sand. Fine sediment proportions had no effect on the timing of steelhead fry emergence. However, their survival patterns were similar to those of coho salmon fry, with 99% survival for steelhead fry in the control mixture and 18% in the 70% sand mixture. The authors note that sediment sizes smaller than 1 mm were not tested in their experiment and that total emergent fry survival could be even lower under conditions that included finer sediment. They also note that if fish were exposed to high sediment levels for a longer time period, from egg fertilization through development, mortality due to indirect effects such as low oxygen concentrations could be higher.

(Phillips, R. W., R. L. Lantz, E. W. Claire and J. R. Moring. 1975. Some effects of gravel mixtures on emergence of coho salmon and steelhead trout fry. Transactions of the American Fisheries Society 3: 461-466)

Brook trout populations declined significantly after stream sedimentation levels increased. Populations of stream benthic invertebrates (the major food source of brook trout) declined significantly after stream sediment levels increased. Higher fine sediment levels in a stream resulted in a loss of pool habitat, fish cover, changes in stream velocity, and higher summer water temperatures. The effects of sedimentation on populations of brook trout (Salvelinus fontinalis) and stream channel physical characteristics were investigated over a period of 15 years in Hunt Creek in the Lower Peninsula of Michigan. Trout populations were monitored for five years prior to sand deposition, for five years during which sand was introduced into the stream, and then five more years without adding sand. The study area was divided into two 1-mile sections, with the upper section of the stream serving as a control throughout the study. For five years, sand was introduced daily into the treated section of the stream, increasing total sediment concentrations from approximately 20 ppm to 80 ppm to replicate concentrations reported for trout streams with severe streambank erosion. Cross sections were established at 100-ft intervals to document changes in stream channel characteristics. Brook trout were collected from spring through fall every year, as were samples of benthic invertebrates (their primary food source). The volume of sand deposited on the streambed gradually increased over the study period. A significant decrease occurred in brook trout populations in the treated section of the stream, a decrease particularly evident four years after the initial introduction of sand. Total trout numbers dropped by 51%, a statistically significant change. Trout of all sizes and ages declined in number in the sand-treated section compared to the control section of the stream. There was no change in growth rates. After sand introduction, populations of benthic invertebrates also dropped to less than half their pre-treatment populations. The insect orders of Ephemeroptera, Diptera, Coleoptera, Trichoptera, and Plecoptera showed the most significant declines. Fish stomach analyses revealed that the majority of these taxa were important food sources for brook trout. Stream physical characteristics also changed with increased levels of sedimentation. The stream became wider and shallower, pools disappeared, and the stream bottom lost all fish cover after becoming uniformly covered by sand. Water temperatures in the summer increased. Deeper stream depths near the banks disappeared.

(Alexander, G. R. and E. A. Hansen. 1986. Sand bed load in a brook trout stream. North American Journal of Fisheries Management 6: 9-23)

Delivery of fine sediments to streams and deposition on spawning and rearing substrate decreased after a moratorium on logging, but increased again after logging resumed. The effects of fine sediment delivery to rivers from logging and road construction were studied in habitat for chinook salmon (Oncorhynchus tschawytscha) and steelhead (O. mykiss, formerly Salmo gairdneri). Spawning and rearing areas were studied after a logging moratorium was declared in the watershed of the South Fork Salmon River, which drains part of the Idaho Batholith. Ten transects were established at each of five chinook salmon spawning areas, and substrate characteristics were measured for 20 years. After logging ceased, there was a significant decline in the percentage of fine sediment (material <4.75 mm in diameter) on the surface of 84% of the spawning area locations. Overall sediment declines over the 20 years varied at each of the five spawning areas, but ranged from a decrease by 16.7% at one area to a decrease by 76.5% at another. The percentage of gravel and rubble correspondingly increased. Within two years of resuming logging, however, surface fine sediments increased at all five spawning areas, with overall increases of 22.2% to 83.8%. In salmon rearing areas, transects were established at 15-m intervals at 47 sample stations. Data were collected from these areas for six years. The percentage of fines on the surface of rearing areas decreased by 73.5% over the study period. Overall, rearing areas had lower levels of fine sediment deposition from logging than spawning areas did.

(Platts, W. S., R. J. Torquemada, M. L. McHenry and C. K. Graham. 1989. Changes in salmon spawning and rearing habitat from increased delivery of fine sediment to the South Fork Salmon River, Idaho. Transactions of the American Fisheries Society 118: 274-283)

Adult and juvenile salmonids exposed to suspended fine sediment in streams had an increasingly negative response as concentrations and duration of exposure increased. The study reviewed 80 published studies on the response of fish to suspended sediment in streams. Data from these studies were used to develop models quantifying the response of fish to varying sediment concentrations and varying durations of exposure. This response was defined as "severity of ill effect," which included effects such as reduced growth rates, reduced fish density, reduced fish population size, and habitat damage. The data were also used to provide estimates of the onset of sublethal and lethal effects in fish. Data were grouped into six subcategories based on species, age, and sediment size. Adult and juvenile salmonids exposed to particle sizes of 0.5-250 (m showed an increasingly negative response as sediment dose increased, and sublethal and lethal effects occurred at high doses. The equations derived for the model were tested against newer data and validated.

(Newcombe, C. P. and J. O. T. Jensen. 1996. Channel suspended sediment and fisheries: a synthesis for quantitative assessment of risk and impact. North American Journal of Fisheries Management 16: 693-727)

The density of all three stream amphibian species studied was lower in streams affected by sediment due to road construction than in control streams. Two of three species had significantly lower numbers in all five stream microhabitats. The study analyzed the impact of highway construction and resulting erosion on the abundance of stream amphibians in California old-growth redwood forest. A major storm during road construction resulted in large volumes of sediment from mass wasting and surface erosion entering stream channels. Five streams affected by sediment were compared with five control streams in the same basin. The three most abundant native amphibians were sampled - larval Pacific giant salamanders (Dicamptodon tenebrosus), larval tailed frogs (Ascaphus truei), and larval and adult southern torrent salamanders (Rhycotriton variegatus). Salamander densities were surveyed in transects placed throughout more than 3 km each of affected stream habitat and control stream habitat. Different habitat types were sampled, including pools, glides/runs, riffles, step runs, and step pools. A total of 267 transects, 0.6 m wide, was sampled, with 540 individual amphibians captured. The density of Pacific giant salamanders and southern torrent salamanders was significantly lower in the sedimented than in the control streams. The density of tailed frogs was lower in their preferred riffle and step run habitat in sedimented streams as opposed to control streams, although results were not statistically significant.

(Welsh, H. and L. M. Ollivier. 1998. Stream amphibians as indicators of ecosystem stress: a case study from California's redwoods. Ecological Applications 8: 1118-1132)

terrestrial and aquatic ecosystems. A review of the scientific literature reveals seven general effects of roads of all kinds on the ecosystem. 1) Road construction resulted in the death or injury of roadside plants or slow-moving animals, compacted soils, and affected water bodies at road crossings. 2) Roadkill affected the demography of numerous species. 3) Animal behavior changed due to roads, with avoidance of roads, modification of movement patterns or home ranges, changes in reproductive success, escape behavior, or physiological state. 4) Roads disrupted the physical environment by changing soil characteristics such as density,

surface runoff, and sedimentation. They altered the hydrology of slopes and stream channels, created barriers to the movement of fish and other aquatic animals, and altered channel and shoreline development. 5) Roads affected the chemical environment by contributing pollutants such as heavy metals, salts, or nutrients to roadside plant and animal communities as well as to aquatic ecosystems through runoff. 6) Roads promoted the spread of exotic species. 7) Roads increased access by humans, and therefore increased poaching pressure, fishing, and passive harassment of animals.

(Trombulak, S. C. and C. A. Frissell. Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology)

Roads are a major cause of forest fragmentation because they divide large landscape patches into smaller patches and convert forest interior habitat into edge habitat. Clearcuts and roads affected 2.5 to 3.5 times more of the landscape than the surface area occupied by the actual clearcuts and roads themselves. Fragmentation due to roads was quantified in a 30,123-ha area of the Medicine Bow-Routt National Forest in southeastern Wyoming. A geographic information system was used to analyze landscape structure. Forest patch and edge-related landscape changes were measured using several indices: the number of patches, mean patch area, mean interior area, mean area of edge influence, mean patch perimeter, total perimeter, and mean patch shape. Roads contributed to forest fragmentation more than clearcuts in the study area since they dissected large forest patches into smaller fragments. They also converted more forest interior habitat into edge habitat. The edge habitat due to roads was 1.54 to 1.98 times the edge habitat created by clearcuts. Taking these factors into account, the authors calculated that together, clearcuts and roads affected 2.5 to 3.5 times more of the landscape than the area occupied by the actual clearcuts and roads themselves.

peak flows, debris flows, and landslides. The study looked at two key processes influencing riparian vegetation and channel morphology: peak flows (floods) and debris flows. Fifty years of research on biophysical processes on watersheds in the H. J. Andrews Experimental Forest in Oregon provided evidence for the impacts of roads. The road network was found to be hydrologically connected to the stream network and increased the frequency and/or magnitude of peak flows, particularly in small basins. Roads and logging together generally had a more severe effect. Debris slides, resulting in debris flows, were also frequently associated with roads. These debris flows affected the disturbance patterns of streams and transported sediment to segments of the stream. Both peak flows and debris flows influenced stream physical features such as channels, bars, and flood plains, which in turn are closely associated with riparian vegetation and aquatic communities. The authors review studies on native aquatic organisms, such as salmonids, for instance, that had evolved with historical disturbance patterns of their stream habitat.

(Jones, J. A., F. J. Swanson, B. C. Wemple and K. U. Snyder. A perspective on road effects on hydrology, geomorphology, and disturbance patches in stream networks. Conservation Biology)

3. The Medford BLM failed to analyze the Riparian Reserves for all streams, including intermittent streams, in terms of their ability to support the habitat needs of fish, wildlife and plant species that use the reserves as refugia. According to the Northwest Forest Plan "any analysis of Riparian Reserve widths must also consider the contribution of these reserves to other, including terrestrial, species." (ROD, p. B-13)

Analysis in the FEIS did not consider the contribution of riparian reserves to thermal ground cover; habitat connectivity; refugia for species with limited dispersal capabilities; and dispersal opportunities for species with large home ranges. A complete analysis that considers the contribution of Riparian Reserves to terrestrial habitat can produce reserves that actually exceed the widths required to protect riparian and aquatic ecosystems. According to the Northwest Forest Plan "other Riparian Reserve objectives, such as providing wildlife dispersal corridors, could lead to Riparian Reserve widths different than those necessary to protect the ecological integrity of the intermittent streams or wetlands. These other objectives could yield wider Riparian Reserves than those necessary to meet Aquatic Conservation Strategy Objectives." (ROD, p. B-14)

There were numerous intermittent and small streams that are not addressed in the FEIS. It raises the issue of whether the Medford BLM actually studied the "units" that are briefly described in the Appendices.

4. The cumulative impacts on hydrology were not explained in the FEIS. The analysis in the FEIS did not inform the public of the actual impacts of past, present, and reasonably foreseeable activities within or affecting the hydrology of the project area.

5. The FEIS proposes numerous "treatments" within riparian reserves. The Northwest Forest Plan states, "regardless of stream type, changes to Riparian Reserves must be based on scientifically sound reasoning, and be fully justified and documented." (ROD at B-16)

6. The FEIS has components that clearly propose logging near numerous intermittent streams. The Northwest Forest Plan makes it clear that protecting intermittent streams and wetlands is critical: "Including intermittent streams and wetlands within Riparian Reserves is important for successful implementation of the Aquatic Conservation Strategy. Accurate identification of these features is critical to the correct implementation of the strategy…" (ROD, p.B-14)

7. The Northwest Forest Plan explicitly states minimal standards and guidelines for protecting intermittent streams. At a minimum the Riparian Reserves must include 1) the extent of unstable and potentially unstable areas (including earthflows), 2) the stream channel and extend to the top of the inner gorge, 3) the stream channel or wetland and the area from the edges of the stream channel or wetland to the outer edges of the riparian vegetation, and 4) extension from the edges of the stream channel to a distance equal to the height of one site-potential tree, or 100 feet slope distance, whichever is greatest. (ROD, p.C-31)

8. The FEIS contends that ACS compliance will meet the needs of listed Coho Salmon. Unfortunately the project will not maintain or restore many of the objectives of the ACS and hence is not likely to meet the needs of listed fish species. Furthermore, impacts to Coho were only analyzed at the 5^th field scale. The FEIS must address potential impacts at the level of 6^th and 7^th field watersheds. Additionally, the FEIS must examine both short and long term impacts to these watersheds.

1. The FEIS did not demonstrate that project implementation would comply with state water quality standards. State water quality standards establish designated uses for a water body (or water body segment), support the uses with water quality criteria, and protect that water quality with an Antidegradation Policy. Full disclosure is required of all project related water quality impacts, along with a clear explanation of how water quality standards will be maintained. The management plan should provide a quantitative basis to judge whether the physical and chemical parameters, such as temperature, turbidity, and sediment accumulation, will be kept at levels that will protect and fully support designated uses and meet water quality standards under each of the action alternatives.

2. The FEIS did not provide a detailed description of the existing physical, chemical, and biological characteristics of streams other water bodies in the planning area. Identification of potentially affected watersheds on maps clarifies the relationships between local waters and proposed project activities. The FEIS does not adequately describe these characteristics of streams in the planning area and the public needs this important information to determine if project effects significantly alter the baseline condition of these waters.

3. The FEIS did not describe the relationship between surface water quality and biota found in affected waters. The management plan should clearly describe the effect of each alternative on designated uses for area surface waters with particular attention to fisheries spawning and rearing habitat. It should also identify which water quality parameters, if any, are limiting factors to local fisheries under each alternative. This information should show the extent to which fish habitat could be impaired by project activities, including effects on stream structure, seasonal and spawning habitats, large organic material supplies, and riparian habitats. The analysis should disclose whether the management plan would cause any reductions in habitat capability or impair designated uses, including coldwater fish habitat.

The Medford BLM, in their analysis of the K-W Project failed to include recommendations from the Watershed Analysis into their decisionmaking. For instance page 143 of the Wild Rogue North Watershed Analysis Version 2.0 states that "Stand regeneration will be more difficult due to the canopy retention levels required for habitat protection measures and because of the restrictions in prescribed burning operations. Alternate treatment prescriptions should be considered that allow for habitat protection, while allowing for proper forest management techniques…"

Further on page 79 the W.A. states, "[T]his watershed is thought to be currently providing significant source population habitat. In fact, when the surrounding landscape is assessed, it is apparent that this watershed, with an extensive mature and old-growth component, is critical to providing many source populations to adjacent areas which have been previously harvested on both public and private land."

Please note that at E-20, The Northwest Forest Plan requires that:

"[The Watershed Analysis] will serve as the basis for developing project-specific proposals, and determining monitoring and restoration needs for a watershed. Some analysis of issues or resources may be included in broader scale analyses because of their scope. The information from the watershed analyses will contribute to decision making at all levels. Project-specific NEPA planning will use information developed from watershed analysis. For example, if watershed analysis shows that restoring certain resources within a watershed could contribute to achieving landscape or ecosystem management objectives, then subsequent decisions will need to address that information."

Please also note that the B-10 of the Northwest Forest Plan states that:

"The intent is to ensure that a decision maker must find that the proposed management activity is consistent with the Aquatic Conservation Strategy objectives The decision maker will use the results of the watershed analysis to support the finding."

1. The EIS did not include an adequate analysis of the K-W Project on Wild and Scenic River values of the Rogue River. According to Section 10(a) of the Wild and Scenic Rivers Act "Each component of the National Wild and Scenic Rivers System shall be administered in such a manner as to protect and enhance the values which caused it to be included in said system without; insofar as is consistent therewith, limiting other uses that do not substantially interfere with public use and enjoyment of these values. In such administration, primary emphasis shall be given to protecting its esthetic, scenic, historic, archaeologic, and scientific features. Management plans for any such component may establish varying degrees of intensity for its protection and development, based on special attributes of the area." There should have been an analysis included in the EIS that determines what effect the proposed K-W Project will have on the outstandingly remarkable values of the Wild and Scenic Rogue River.

2. There are numerous "treatments" that are being recommended for the K-W Project that may affect the Natural Scenic Qualities (one of the three ORVs for the W&S Rogue River). They include activities within the Wild and Scenic corridor (fuels treatments) and activities that are near the corridor (pine conversion, fuels treatments, commercial density management, regeneration, and road construction). These activities should have been adequately reviewed, in the EIS for public disclosure, as to whether or not they affect Natural Scenic Qualities of the W&S Rogue River.

3. Depending on the selected alternative there may also be an effect on the Fisheries ORV of the W&S Rogue River. Effects to fisheries should be analyzed as to whether or not they "protect and enhance" the fisheries of the W&S Rogue River.

4. There should be an analysis of whether or not the proposed activities of the K-W Project will affect recreation within the area. Proposed activities could diminish recreational activities within the area and should be analyzed in the EIS.

5. The Act provides that federal agencies "having jurisdiction over any lands which include, border upon, or are adjacent to" a designated river "shall take action respecting management policies, regulations, contracts, plans, affecting such lands ... as may be necessary to protect such rivers in accordance with the purposes of this chapter." It is also stated that: "Particular attention shall be given to scheduled timber harvesting ... and similar activities which might be contrary to the purpose of this chapter. 16 USCS §1283(a).

In one court case, Judge Karlton of the Eastern District of California granted a preliminary injunction enjoining implementation of the South Fork Fire Recovery Salvage project on the Shasta-Trinity National Forest in California. The injunction was issued because the judge found a significant likelihood that the salvage project would adversely affect the river environment. The Wilderness Society v. Tyrrel, 701 F Supp (1989).

Judge Karlton "found as a matter of law that the WSRA's protection of the river is not limited to a 1/4 mile corridor ... The court has determined that defendants were wrong as a matter of law in believing that preservation of the 1/4 mile corridor fulfilled their duties." He cited the prior order:

The Medford BLM did not consider the impacts of the K-W Project on the Zane Grey Roadless Area. This is an issue that has been frequently raised by numerous individuals and organizations over the planning process. It is in the public interest to review impacts of the K-W Project on the Zane Grey. The Zane Grey includes 24 miles of the Wild and Scenic Rogue River and is contiguous with the designated Wild Rogue Wilderness Area just downriver.

The FEIS should have analyzed, in greater detail, the effects that the K-W Project will have on the visual and aesthetic qualities of the area. Users of public lands are increasingly concerned about the quality of their visual environment. A number of people use the roads in or near the planning area for aesthetic, occupational and recreational purposes. Many people use the trails and campgrounds within the project area. Many people object to the visual quality of regeneration harvests and their presence may negatively impact their outdoor experience. The FEIS gave a short, cursory analysis to Visual consequences yet this issue is very important to the large number of people who recreate within the project area, including those who raft or hike along the Wild and Scenic Rogue River. Many of the planned units are within the visual range of the Wild corridor.

To comply with NEPA, the BLM must address impacts related to soil resources on a site-specific (i.e., unit-by-unit) basis. The soil types and composites using field reconnaissance data and should have been mapped in the EIS. The BLM should include a qualified, journey-level soil scientist on the ID Team. The BLM should design the proposed action and mitigation measures after you have collected field reconnaissance data on soils at every site proposed for action.

It appears that the BLM’s only soil data comes from an order 3 recon survey at the landscape soil mapping project level. Please note that the Josephine County landscape soil data is useful for timber classifications but does not contain site-specific information regarding soil classifications, soil associations, or soil types. Has a BLM soils scientist even visited the stands targeted for harvest in the planning area?

1. Fire prevention is being used as a primary need for "treatment" of various forested stands throughout the K-W Project. Consideration of the following points and sources should help determine if treatments are consistent with the best science concerning fire and forest health. There are numerous scientific sources regarding appropriateness of logging to prevent forest fires and these should have been analyzed and presented in the FEIS for informed decisionmaking and review.

2. A primary indicator of a direct relationship between fires and roads is the high frequency of human-caused fires in comparison to fires started by lightning. According to data from the Interagency Fire Center collected between 1988 and 1998, 88.1% of all wildland fires were caused by humans, in contrast to 11.9% started by lightning (Department of Interior, 1999). The destructive potential of roads, combined with the difficulty of regulating human use and behavior on or near roads, renders prevention of unnecessary roads and the obliteration of roads in highly sensitive areas the most significant means to limiting fire risk associated with roads.

1. The "affected environment" and "environmental consequences" sections of the management plan failed to discuss what effect project activities could have on gene pools and species diversity.

2. The FEIS did not contain a detailed analysis of the cumulative effects of past projects, proposed or approved future projects on diversity stability, fragmentation, connectivity with adjacent landscapes, and disruption to ecosystem processes or functions. Merely listing past projects is not enough.

1. The wildlife information in the FEIS fails to track to the environmental consequences section in a way which helps the public understand significant impacts. A requirement of the alternatives section in the EIS is to present the significant environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public.

2. The wildlife section of the K-W FEIS provided generic relational impact information about possible wildlife responses to project activities, but there is little information in the section that informs the decisionmaker and the public with a complete and objective evaluation of possible significant environmental impacts from the alternatives.

3. FLOW strongly objects to logging late-successional forest in a spotted owl Critical Habitat Unit. The affected CHU OR-65 (and OR-67 to a lesser extent) is an essential east-west habitat link between the Coast Range, the Klamath Province Mountains and the Cascade Mountain Range. As described in the 1992 designation of critical habitat, critical habitat is intended to contribute to the recovery and eventual de-listing of the owl. Regeneration and commercial thinning to 40% canopy cover of critical habitat will prevent these forests from fulfilling their designated role in the owl recovery. It is especially disappointing that the BLM is proposing to log 1,727 acres of this CHU because it serves as an "inter-provisional link" that is essential for preventing the isolation of NSO populations in the Cascades, Klamaths and the Coast Range.

The FEIS contends (without justification or citation) that impacting 1,727 acres will not "adversely modify" the CHU because it "only" degrades 2% of the CHU. This conclusion is baseless. The BLM fails to justify its conclusions and fails to inform the reader or decision maker of its plans for the remaining matrix acreage in the CHU. The BLM also fails to reveal the ability of LSRs (which are being illegally used as a surrogate for existing critical habitat) to provide the inter-provisional connectivity values associated with OR-65 and OR-67.

Please note that page 64 of the Southwest Oregon Late-Successional Reserve Assessment states that "in general no net loss of suitable habitat for spotted owl should occur in CHUs, as a result of planned projects."

The FEIS should not tier the appropriateness of the action to the NFP, and base its estimation of effects primarily on this document. The FEIS severely lacks site-specific evidence, including USFWS consultation. Spotted owl critical habitat should be analyzed on a project-specific level, with the effects not masked by the general "matrix" label as it is in section 4.9.1.3.

The project will adversely affect the connectivity and habitat for the Northern Spotted Owl. Logging of the Kelsey-Whiskey project area will impact resident owls, as well as further restrict their movement between suitable habitats. The cursory treatment of the impacts of the removal of late-successional habitat on page 4-36, which states that the "Biological Opinion for NFP concluded that the amount of harvest expected in the Matrix would not be severe enough to alter the functions originally intended for critical habitat," expose that the rationale behind the Kelsey-Whiskey Project is grounded in previous planning documents, not site-specific analysis.

The FEIS does not adequately describe the impacts to the northern spotted owl, particularly in light of the cumulative impacts to spotted owl habitat in the area. Although the FEIS lists past projects, it does not give a detailed analysis of how these past activities could, in combination with the proposed action under the preferred alternative, degrade owl habitat in the area. Restating the NFP prediction that, in the long term, "late successional reserves would be primary support for late successionally affiliated species," does not truly analyze the actual cumulative effects of the project as it is planned.(FEIS 4-48)

4. As noted in the FEIS, the K-W Project area contains some of the highest bear populations per square mile in Oregon. Oregon State University researcher William Noble, funded by the Oregon Department of Wildlife, found that: "Huge Douglas-fir trees offer the site that most hibernating black bears select for their traditional long winter's nap ... a failure to provide at least some large trees, stumps and snags could have a long-term impact on bears in the future ... anything that disturbs the process ... increases the demand on this limited energy supply."

Noble said the problem is compounded for pregnant females. They face additional survival burdens, including nursing. A den disturbance can jeopardize both mother and cubs. 'This dependence of bears on large, old trees is something we've not really understood in the past."

The study's general conclusions suggest that policies which protected large snags, preserved mature forests or provided for road closures during October through March would directly benefit denning bears. (Snags, Fallen Log Dens of Choice for Hibernating Bears," Capitol Press, December 28, 1990)

Why did the FEIS not explain what the impacts to black bear populations would be?

5 Impacts on forest carnivores should be fully explored in the K-W FEIS. The healthy, late-successional habitat within the K-W Planning Area is rare and should be thoroughly studied (with full public disclosure) for presence of forest carnivores and for all impacts from "treatment" alternatives. According to a study of the American Marten, an important forest carnivore, "Logging is commonly regarded as the primary cause of observed distributional losses ... Fire, insects, and disease are other important causes of tree death in the western coterminous United States, but the effects of these disturbances on martens have been studied little. Because logging is unique among these disturbances in removing boles from forests, and because of the importance of boles in contributing physical structure to habitats, logging is likely more deleterious to habitat quality for martens than other disturbances. The geographical distribution of martens in (the Pacific Northwest) has been dramatically reduced. This reduction is likely attributable to loss of habitat through the cutting of late successional forest ..." (S.W. Buskirk and L.F. Ruggiero, "American Marten," in Ruggiero et al. editors, The Scientific Basis for Conserving Forest Carnivores: American Marten, Fisher, Lynx, and Wolverine in the Western United States, USDA Forest Service, GTR RM-254, Sept. 1994.)

6. There was not analysis in the FEIS regarding the impacts of the K-W Project on Migratory Birds. What will be the impact of the K-W Project on songbirds? Taking of migratory birds is a violation of the Migratory Bird Treaty Act: "[I]t shall be unlawful at any time, by any means or in any manner, to . . . kill . . . any migratory bird, any part, nest, or egg of any such bird." (16 USC 703) Because the Medford District RMP fails to address impacts of timber sales on migratory neotropical birds, the BLM must address the impacts.

7. The Kelsey-Whisky planning area is home to many survey and manage species including Del Norte salamanders, Mollusks, Red Tree voles, Fungi, Bryophytes and Lichens. It appears that the BLM prepared unit layouts and released the FEIS to the public for comment before completing the required surveys for some of these species. How can the public provide site-specific comments, and how can the BLM accurately assess the environmental impacts of the project, when we do not know the location and frequency of survey and manage species in the planning area?

8. The Medford BLM littered the project area with string around certain unit or road construction boundaries. This practice can kill various species, including birds. On a public hike on Sunday, April 20^th, 2003, we discovered the effects of this irresponsible practice. A Northern Flicker was caught in the string and killed. This is unacceptable and disturbing and upset the 15 persons who attended the hike. It gave a very clear picture of the short-sighted thinking of the Medford BLM with respect to the K-W Project Area. Below is a picture:

1. The FEIS did not discuss the economic consequences of implementing the various alternatives. This could include estimates of job additions or losses attributable to timber management. If timber harvesting activities are proposed, it is important that the management plan consider timber sale economics as a potential management concern for analysis in response to the full public disclosure intent of NEPA and in response to the controversy regarding below-cost timber sales. The management plan should provide clear descriptions of the key assumptions regarding Interdisciplinary Team costs, sale preparation, timber pricing, product valuation, discount rates, rotation lengths, road costs, and road maintenance.

2. NEPA requires a full accounting of a broad array of direct, indirect, and cumulative economic effects of the timber-sale program, including use of methods and procedures to "insure that presently unquantified environmental amenities and values may be given appropriate consideration" [40 C.F.R. 1507.2 (b)].

3. The BLM also should consider ecosystem services in their analysis and present relative values of these services to the public in the FEIS. Listed below are examples of ecosystem services:

4. At every level of decision making related to the timber sale program (program, forest and project level) the BLM fails to account for significant externalized costs of logging. Externalized costs are those costs borne by parties not associated with an economic transaction, in this case, timber sales, as well as those costs not factored into the transaction decision. Public land logging results in a wide array of externalized costs to government, business, and private parties. These include direct costs, such as the costs incurred by downstream water users forced to filter out logging sediments, as well as indirect costs such as the lost revenues to owners of recreation-oriented businesses or decreased property values adjacent to logged over areas. The quantification of such costs is essential for determining whether or not individual timber sales are in the public interest.

1. FLOW advocates for the full public disclosure of all foreseeable, direct, indirect, and cumulative environmental impacts of a given management plan. Clear, in-depth analysis of all relevant issues is a requirement for the preparation of a management plan.

Throughout the K-W FEIS there were many statements about impacts without any conclusions about the significance of the effect. Impacts that do not provide any discussion of significance do not inform decisionmakers and the public of what is important.

Conclusionary statements about significance without much or any rationale about why they were or were not significant (i.e., impacts statements without an impact methodology) was a problem. Bald conclusions without an objective evaluation of significant environmental impacts, including a logical and coherent record (impact methodology) of how they were derived do not help the decisionmakers and the public understand the trade-offs of management actions.

2. The management plan should describe how the NEPA process would be incorporated into future land management decisions for future site-specific projects. The process for developing a categorical exclusion or an environmental assessment should be discussed. If the effects of a particular activity are significant, an EIS may be warranted. The framework for public involvement in future management decisions should be made clear.

3. Since the proposed activities could affect threatened or endangered species, the FEIS must include the Biological Assessment and the associated U.S. Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS) Biological Opinion or formal concurrence for the following reasons:

The Medford BLM failed to include Biological Opinions from the U.S. Fish and Wildlife Service for threatened species (Northern Spotted Owl and Marbled Murrelet).

4. Especially concerning the impacts of regeneration, the Medford BLM is not consistently implementing the purpose of an EIS (40 C.F.R. 1502.1) as it relates to significance. An EIS shall provide full and fair discussion of significant environmental impacts and shall inform decisionmakers and the public of reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of the human environment.

5. A major problem with much of the analysis in the environmental consequences section was comparing alternatives instead of comparing impacts to the baseline in the affected environment section, or even worst repeating descriptions of alternatives elements without identifying impacts. The confusion may have resulted from two requirements of 40 CFR 1502.14 Alternatives Including the Proposed Action, and especially the second requirement. However, neither of the two requirements of developing the alternatives change the requirement of using the affected environment section as the baseline for comparing impacts in the environmental consequences section.

The first requirement of 40 CFR 1502.14, Alternatives Including the Proposed Action, is to design a range of reasonable alternatives around the significant planning issues identified during scoping. The alternatives section is the heart of the EIS. The requirement is to design the alternatives to sharply reflect the issues and provide a clear basis for choice among options by the decisionmaker and the public.

6. The NEPA evaluation and the consultation process are instrumental in analyzing the effectiveness of project alternatives. The full disclosure mandate of NEPA suggests that the consultation be instigated as soon as possible. Thus, the final management plan and Record of Decision should not be completed prior to the completion of ESA consultation.

7. NEPA requires that an agency provide a detailed analysis of the environmental impacts of the proposed action. 42 USCA §4332(C)(i). As part of this analysis, the agency must include an adequate discussion of cumulative environmental impacts. "'Cumulative impact' is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions ... " 40 CFR §1508.7. "Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time." Id. The K-W Analysis fails to adequately address the cumulative impacts "which result from the incremental impact of the action when added" to the already fragmented state of the project area.

The Ninth Circuit Court has recently remanded Forest Service decisions which did not include a detailed analysis of the cumulative effects of sales in proximity to one another. It is not enough for environmental impact analyses to make general observations about past and future harvest. Analysis of specific timber sales located near each other and a comprehensive evaluation of the environmental effects of these sales when added together must be performed in an EIS. Neighbors of Cuddy Mountain v. US Forest Service, No. 97-35654 (9th Cir., Mar. 4, 1998).

8. The issues to be covered in the FEIS, including riparian effects, forest health, fire, road construction, etc., are very controversial and have a range of scientific opinion, of varying credibility. "Where scientists disagree about possible adverse environmental effects, the EIS must inform decision-makers of 'the full-range of responsible opinion'" on the environmental effects. Citizens Against Toxic Sprays v. Bergland, 428 F.Supp. 908, 922 (D.Or 1977). An EIS that fails to disclose and respond to the opinions held by well respected scientists concerning the hazards of the proposed project is "fatally deficient." Seattle Audobon Society v. Mosely, 798 F.Supp. 1473, 1479 (W.D. Wash. 1992). And, in evaluating the reasonably foreseeable impacts of a proposed project in which information is incomplete or unavailable, "the agency shall always make clear that such information is lacking." 40 CFR §1502.22. The EIS must include:

9. Page 2-11 of the FEIS states that "The actual numbers and sizes of trees for logging is not known at this time. Acres are approximate and unit boundaries have not been finalized."

The FEIS fails to disclose the location, frequency and distribution of survey and manage species to the public before a decision is rendered on the project.

10. The proposed ACEC in Alternative 4 would enhance the BLM’s ability to manage and protect the outstanding values of the East Fork Whiskey Creek drainage. We believe that this proposed change is an appropriate and positive amendment to current land use allocations in the Resource Management Plan.