1. My name is Jonathan J. Rhodes. I am a hydrologist with more than 30 years of experience, with a B.S. in hydrology from University of Arizona, a M.S. in hydrology and hydrogeology from University of Nevada-Reno and I finished all required academic work toward a Ph.D. in forest hydrology at the University of Washington. Since 2001, I have worked as a consulting hydrologist for a variety of clients, including county and tribal governments in Oregon, Washington, and Idaho. Prior to that I worked for more than 12.5 years at the Columbia River Inter-Tribal Fish Commission (CRITFC), where I served as Senior Scientist-Hydrologist. My professional experience includes work with tribal, federal, state, county, and city governments, universities, and non-profit groups in eight western states. 2. Most of my work has focused on the effects of current and proposed uses of land and water on water quality, streams and habitats for native trout and salmon. I am quite familiar with the watershed and aquatic management direction in the 1994 Record of Decision for Northwest Forest Plan (NFP) and Forest Ecosystem Management: An Ecological, Economic, and Social Assessment (USFS et al., 1993), which provided the scientific bases for the Aquatic Conservation Strategy (ACS) in the NFP. I authored a peer-reviewed report that comprehensively compared and evaluated the efficacy of aquatic protection measures in the NFP: A Comparison and Evaluation of Existing Land Management Plans Affecting Spawning and Rearing Habitat of Snake River Basin Salmon Species Listed Under the Endangered Species Act (Rhodes, 1995), prepared under contract with NMFS at its behest. 3. I am familiar with watersheds and streams on the Mt. Hood National Forest (MHNF). I have reviewed these conditions on the MHNF regularly since 1989. 4. I have co-authored numerous papers on the effects of logging (including thinning), roads, and related activities on watersheds and aquatic systems published in peer- reviewed scholarly journals, including Postfire Management on Forested Public Lands of the Western USA (Beschta et al., 2004), published in Conservation Biology, The Effects of Postfire Salvage Logging on Aquatic Ecosystems in the American West (Karr et al., 2004) published in BioScience, and The Failure Of Existing Plans To Protect Salmon Habitat On The Clearwater National Forest In Idaho (Espinosa et al., 1997), published in the Journal of Environmental Management. 5. I have published many other reports related to the effects of land and water use on salmon habitat, stream sedimentation, and water quality. I have served as a peer-reviewer for the Open Forest Science journal, North American Journal of Fisheries and an international symposium on the effects of forest management and streams for papers related to soil erosion and stream sedimentation of salmonid habitats. Information Reviewed 6. I reviewed the Environmental Assessment Jazz Thinning (EA), including its appendices, and the Decision Notice and Finding of No Significant Impact Jazz Thinning (DN) for the proposed timber harvest, road, and landing activities on the Mt. Hood National Forest (MHNF) within the Collawash watershed. I also reviewed the portions of USFS et al. (1993) related to the Aquatic Conservation Strategy (ACS), the Aquatic Conservation Strategy Objectives (ACSOs) and the impacts of logging and roads on aquatic and watershed resources. I also reviewed portions of the NFP related to the ACS, ACSOs, Riparian Reserves (RR) and Late- Successional Reserves (LSR). I also reviewed the National Marine Fisheries Service’s Endangered Species Act Section Concurrence Letter and Magnuson-Stevens Essential Fish Habitat Response for the Jazz Thin Timber Sale, Collawash River (LOC). 7. I personally reviewed field conditions in the Jazz Timber Sale area on July 5 and July 7, 2012. During my field review, I evaluated the existing conditions of some streams, riparian areas slated for logging, and many open, decommissioned, and closed roads that the selected alternative for the Jazz Thinning Project (Project) proposes to re-open, reconstruct and/or subject to elevated use. I also evaluated how Project activities were likely to affect streams, soils, watershed processes, the attainment of ACSOs, and Riparian Reserves. During my field evaluation, I personally took all the photos attached to this comment as Exhibit A. The photos are a true and accurate depiction of the conditions I evaluated during my field review on July 5, 2012. 8. I also reviewed other pertinent scientific literature. The list of this literature is too lengthy to list here, so I have listed it separately and attached it to this comment. I also drew on my professional judgment and experience. Scope of Review 9. I submit this information to explain how the EA failed to reasonably assess the Jazz Timber Sale’s effects consistency with the NFP ACS and ACSOs and how many aspects of the Jazz Timber Sale, especially those in Riparian Reserves, conflict with the NFP, particularly ACS and ACSO attainment. I also describe some of the many ways that EA failed to properly analyze and disclose these impacts because the EA failed to reasonably incorporate available scientific information on the nature, intensity, and duration of the likely direct, indirect, and cumulative effects of the Jazz Timber Sale on large woody debris (LWD), soils, peakflows, salmonid habitats, and water quality, all of which conflict with ACSO attainment and NFP requirements for RR and LSR. Discussion A. The EA’s fails to adequately assess and make known the Jazz Timber Sale’s impacts on downed large woody debris and resulting effects on soils, RR, LSR, and NFP requirements. 10. The EA provides no reasonable estimate of the amount of large woody debris (LWD) that will be lost due to the Jazz Timber Sale, although the Jazz Timber Sale will clearly remove copious amounts of trees on 2,053 acres within the Collawash watershed. While not made known in the EA, the LOC (p. 4) indicates that the Jazz Timber Sale will remove about 182 trees per acre logged. This equates to the removal of 373,646 trees from the ecosystem. 11. This irretrievable loss of trees from the ecosystem will greatly reduces future levels of LWD that would otherwise be ultimately recruited to the forest floor or to streams. The loss of LWD from the ecosystem is significant due to the persistence and magnitude of the LWD removal under the Jazz Timber Sale, and the importance of LWD to a variety of critical ecosystem functions, including soil productivity, aquatic conditions, the functionality of RR and LSR, and to compliance with NFP requirements affected by downed wood, including those for, RR, LSR, and ACSOs. As we noted in Karr et al., (2004): “…large trees …provide habitat for many species, reduce soil erosion, aid soil formation, and nourish streams as their leaves fall or their trunks decay (Henjum et al.1994)….there is no debate about the key role that large trees play in aquatic systems and many ecological processes…” (emph. added). 12. Although the EA’s (p. 11) estimates that the Jazz Timber Sale will take 15 million board feet of timber1 from the ecosystem, this estimate does not provide a reasonable estimate of the amount of LWD lost from the logged areas. The USFS’s own research has noted that the 1 A board foot of timber is equivalent to 144 cubic inches of timber. volume of timber produced from tree removal is typically 35 to 50% lower than the total volume wood in trees that are removed, due to a number of factors (Steele, 1984), including the length of the trees removed and production techniques. For these reasons, the EA’s estimate of timber volume amply indicates that the volume of LWD loss because of the Jazz Timber Sale is highly significant, but it is not a surrogate for a reasonable estimate of the volume of LWD loss from the Jazz Timber Sale. 13. The Jazz Timber Sale will also reduce LWD recruitment by reducing the mortality of remaining trees after logging, as the EA repeatedly acknowledges. This reduction in mortality inexorably reduces future levels of LWD recruitment to soils and streams. The EA also states that in the absence of the Jazz Timber Sale, tree mortality will be high in the near future, which indicates that the Jazz Timber Sale will not only reduce LWD levels via tree removal but also additively by delaying and reducing tree mortality, a critical process for recruiting downed LWD for vital ecosystem functions. 14. The EA’s failure to reasonably assess and make known the amount of LWD lost due to the Jazz Timber Sale from both tree removal and reduction in tree mortality rates is a severe defect due to the importance of LWD to soils, streams, the functionality of RR and LSR, and related NFP requirements. i) The Jazz Timber Sale’s adverse effects to soils from LWD loss 15. LWD provides important sources of organic matter and nutrients in soils, which are vital to the long-term maintenance and protection of soil productivity (USFS and USBLM, 1997a; Graham et al., 2004; Beschta et al., 2004; Karr et al., 2004). The EA (e.g., p. 74) acknowledges that if trees were not logged, they would eventually die and become downed LWD. The EA also acknowledges that past logging in the Jazz Timber Sale area has reduced levels of LWD and organic matter in soils, resulting in diminished soil productivity (EA, p. 112). 16. But, despite these acknowledgements of the well-known importance of LWD, associated nutrients and organic matter to soil productivity and the persistent impacts of its loss within the Jazz Timber Sale area due to past logging, the EA fails to assess the magnitude of loss of LWD and organic matter and this effect soils because of the Jazz Timber Sale. Instead, it only assesses the Jazz Timber Sale effects on organic matter by assessing the amount of area where the soil organic layer is removed under the Jazz Timber Sale (EA, p. 112), which in no way addresses the effects of tree removal and reduced tree mortality on LWD and resulting effects on soil functions and productivity. Therefore, the EA’s assessment does not assess the well-known persistent effect of tree-removal and reduced tree mortality on long-term soil productivity under the Jazz Timber Sale. 17. The EA also fails to disclose that scientific information, including that of USFS researchers, has repeatedly noted that one of the most effective, efficient and important ways to restore degraded soil productivity is to retain all sources of LWD and organic matter and prevent additional soil disturbances in degraded areas such as a the Jazz Timber Sale (Kattlemann, 1996; USFS and USBLM, 1997a; Beschta et al., 2004). The EA fails to disclose that the Jazz Timber Sale conflicts with the steps that are necessary for restoration of the degraded soil productivity in the Jazz Timber Sale area caused by previous logging. 18. The EA’s failure to properly analyze and disclose the Jazz Timber Sales effects on LWD and organic matter is a severe defect because soil and soil productivity are fundamental aspects of forested ecosystems that influence the composition and condition of vegetation, rates of vegetative recovery after disturbance, sediment flux, and the quantity, timing, and quality of water produced by watersheds, which, in turn, affect aquatic populations and habitats (Beschta et al., 2004). Organic matter is vital to the protection and maintenance of a variety of important soil processes, besides productivity, including the capture, storage, and release of water (Maidment, 1993; USFS and USBLM, 1997a; Beschta et al., 2004). 19. The EA also fails to properly make known that the loss of soil productivity caused by loss of LWD and related organic matter due to tree removal is both irretrievable and irreversible. In so doing, the EA also fails to reasonably differentiate between the Jazz Timber Sale and the No Action alternative with respect to the irreversible and irretrievable effects of logging on LWD, organic matter, and soil productivity. ii) The Jazz Timber Sale’s reduction in LWD levels and soil productivity prevent compliance with LSR requirements 20. The Jazz Timber Sale would cause significant reductions in LWD in Late Successional Reserves (LSRs) by logging about 726 acres (over one square mile) allocated as LSR under the NFP. However, the EA is devoid of a reasonably thorough assessment of the magnitude and persistence of loss of wood and decreased soil productivity and the resulting effects on meeting LSR objectives under the NFP. 21. The NFP objective for LSR is to maintain and enhance late-successional forests (NFP, p. B-4, C-9). Persistent losses of soil productivity, such as those that will be caused by the Jazz Timber Sale’s removal of trees and reductions in tree mortality are inconsistent with this objective, because losses in soil productivity thwart or impede the growth of vegetation that comprises a primary aspect of late-successional forests. However, as previously described, the EA fails to properly assess and divulge the extent and degree of soil productivity loss under the Jazz Timber Sale in all land allocations, including LSR, and, therefore fails to reasonably assess consistency with LSR requirements under the NFP. iii) The Jazz Timber Sale’s reduction in LWD levels and soil productivity decreases Riparian Reserve functionality and prevents compliance with RR requirements, and ACSO attainment 22. The Jazz Timber Sale will also harm Riparian Reserves (RR) of LWD by removing trees and reducing tree mortality by logging about 734 acres (more than one square mile) allocated as RR under the NFP (EA, p. 12). Logging in RR contributes to the impairment of the functionality of the RR in several ways that conflict with several ACSOs. 23. First, the loss of LWD via tree removal and reduced tree mortality caused by logging within one tree height reduces LWD recruitment to streams. A significant amount of the Jazz Timber Sale is closer than one tree height to streams. Although undisclosed in the EA, the LOC (p. 22) states that the logging in RR would reduce LWD recruitment to streams by 15% to 75%. NMFS (1996) assessment of aquatic habitat elements and ACSOs noted that LWD levels affect the attainment of four ACSOs including the NFP ACSOs #3, #6, #8, and #9. Not only does the EA fail to properly determine, analyze, and make known the quantitative loss of in- stream LWD caused by logging in RR2, these impacts conflict with the NFP standards for attainment for ACSOs #3, #6, #8, and #9. 2 Such an analysis is eminently tractable, although available models for instream LWD recruitment tend to underestimate the impacts of tree removal (Gregory et al., 1991). Nonetheless, the EA is devoid of any quantitative assessment of reduced LWD recruitment to streams. 24. As previously discussed, the removal of LWD and reductions in tree mortality due to logging in RR also causes significant and irretrievable losses in soil productivity in RR areas logged under the Jazz Timber Sale. Although this is not adequately assessed and discussed in the EA, this persistent loss of soil productivity degrades RR functionality and typically results in retarded plant growth. This is a significant impact because many of the attainment of ACSOs are affected by vegetation conditions within RR, including ACSOs #1, #3, #4, #5, #8, and #9. Thus, the EA fails to reasonably assess compliance with required attainment of these ACSOs because it did not properly examine and divulge the magnitude and persistence of the losses of LWD, organic matter, and soil productivity in RR under the Jazz Timber Sale and their effects on ACSO attainment. 25. The loss of LWD caused by logging in RR also degrades RR functionality by reducing LWD within RR. This downed wood is important to the RR function of detaining sediment from both natural and management-induced upslope disturbances and thereby limiting increases in sediment supply to streams from such disturbances (Rhodes et al., 1994), as the USFS has acknowledged (USFS et al., 1993; USFS and USBLM, 1997a; b). Therefore, the EA fails to reasonably assess and divulge the impact of LWD loss on this important RR function which strongly affects attainment of ACSOs #3 and #5. 26. The EA does not make known that these Project impacts on LWD, organic matter, soil productivity, and associated impacts on RR functionality are irreversible and irretrievable. B. The EA’s fails to adequately assess and make known the Jazz Timber Sale’s total impacts on soil productivity, and how these conflict with NFP requirements for RR and LSR. 27. Despite its importance, the EA fails in many ways to provide the total significant impacts to soil productivity because of the Jazz Timber Sale and their effect on LSRs and RR. For instance, the EA is devoid of a summary of the number, location, and total area of landings that will be used, constructed, or reconstructed. Although the LOC (p. 21) indicates that 20 new landings will be constructed, this information does not obviate the EA’s failure to make known the total number and area of landings, their location, particularly in RR and LSR, and level of construction and reconstruction. 28. The EA’s failure to assess and divulge the total number, area, and location of landings that will be re-used, reconstructed, and constructed under the Jazz Timber Sale is significant for many reasons. First, landings have impacts on vegetation, soils, and erosion similar to roads in their persistence and severity (Karr et al., 2004), as USFS cumulative effects models also indicate (Menning et al., 1996). Landings essentially “zero-out” soil productivity in an irretrievable manner, although this is not disclosed in the EA. As we noted in Karr et al. (2004), “Construction and reconstruction of roads and landings damage soils, destroy or alter vegetation, and accelerate the runoff and erosion harmful to aquatic systems…Logging, landings, and roads in riparian zones degrade aquatic environments by lessening the amount of large wood in streams, elevating water temperature, altering near-stream hydrology, and increasing sedimentation.” 29. Second, the failure to assess and divulge the magnitude of the loss of soil productivity due to landings is a significant defect because of the amount of landings needed for the Jazz Timber Sale. Although the EA does not make known the number and area of landings needed for the Jazz Timber Sale, it is likely to be significant. Typically at least one landing is needed per logging unit and there are 154 logging units under the Jazz Timber Sale (EA, App. A). Therefore, it is likely that at about 154 landings that will be re-used, reconstructed, or constructed under the Jazz Timber Sale. 30. The total area of these landings is also likely to be highly significant. Analyses of numerous thinning projects indicate that area of landings typically comprises 1-2% of the area logged. Using the median value in this range (1.5%), it is likely that the area of landings in the Jazz Timber Sale will be about 30.8 acres, most of which will be either constructed or significantly reconstructed. Therefore, is likely that this level of landings will have soil impacts that are akin to the reconstruction and construction of about 12.7 miles of road with mean width of 20 feet, which is extremely significant, yet undisclosed in the EA. 31. Using this same estimation method, it is likely that the Jazz Timber Sale’s logging in about 726 acres of LSR [EA, p. 12], would result in the reconstruction or construction of about 10.9 acres of landings in LSR, which would have an area and impacts equivalent to the reconstruction or construction of more than 4.5 miles of road with a mean width of 20 feet in LSR. This is a highly significant level of landing area in LSR due to severe and irretrievable impacts of landings on soil productivity, soil hydrology, vegetation, and their conflicts with LSR objectives. 32. Again, using this same estimation method, it is likely that the Jazz Timber Sale’s logging of about 734 acres of RR (EA, p. 12) would result in the reconstruction or construction of about 11 acres of landings in RR, which would have an soil impacts equivalent to the reconstruction or construction of about 4.5 miles of road with a mean width of 20 feet. This is a highly significant level due to severe and irretrievable impacts of landings in RR on soil productivity, soil hydrology, vegetation, and associated riparian functions, including water temperature moderation, provision of LWD, and regulation of near-stream erosion and sediment delivery. These impacts conflict with NFP requirements for the attainment of the majority of NFP ACSOs, including #2, #3, #4, #5, #6, #8, and #9 (NMFS, 1996). 33. Third, the severity of landing impacts partly depends on whether they are re-used, reconstructed, or constructed. While re-use and reconstruction elevate soil impacts, irretrievably reverse all soil recovery that has accrued during the period of non-use, and persistently degrade all soil functions, new landing construction causes immediate, persistent, and especially severe losses of soil productivity and losses of soil functions. 34. Fourth, although the EA is devoid of a discussion of the number and area of landings from past logging that will be significantly reconstructed, rather than re-used, it is likely that most of the older landings used by the Jazz Timber Sale will require significant reconstruction, because several decades have past since logging occurred. Reconstruction has far greater negative impacts on soils than re-use of landings due to the clearing of vegetation, additional disturbance to soils, elevation of erosion, and irretrievable reversal all soil, vegetation, and hydrological recovery on the landings that has accrued during the period of non-use. 35. Fifth, the EA’s failure to provide the total area of the soil impacts from Project landings, including the area within LSR and RR allocations, is a severe defect due to the irretrievability the effects of landings on soils. Soil productivity on landings can never be completely or rapidly regained on areas afflicted by logging landings even with remediation treatments, as USFS environmental assessments have repeatedly acknowledged (Bitterroot National Forest, 2001, Rogue River and Siskiyou National Forests, 2003; Gifford Pinchot National Forest, 2009). Notably, the EA completely fails to make known the irretrievable loss of soil productivity associated with landings. 36. The failure to make known the number and area of landings under the Jazz Timber Sale in LSR and RR is a severe defect, because landing impacts conflict with the objectives for these allocations. Landing construction, use, and reconstruction in RR persistently impair their functions, including microclimate regulation and provision of LWD. The permanent and irretrievable loss of soil productivity caused by landings, and especially with landing construction is in direct conflict with LSR objectives. 37. The EA does not divulge the total area of roads3 that will be constructed under the Jazz Timber Sale. This defect is exacerbated because the EA fails to properly disclose that available scientific information has consistently noted that road construction and major reconstruction severely reduce soil productivity in a persistent fashion due to the removal and displacement of topsoil, the loss of organic matter and future organic matter sources, soil compaction, and persistent and severe loss of soil via erosion. The EA further compounds these defects by failing to properly acknowledge that these impacts of road reconstruction on soil conditions in LSR are in conflict with LSR objectives and that these activities in RR degrade their functionality and are not in compliance with ACS standards for ACSO attainment. 3 The EA provides the length of roads that will be constructed or reconstructed (EA, p. 21), but never provides the area of these roads, or their width from which the area of the roads can be determined. This includes so-called “temporary” roads, which have extremely persistent impacts on soil productivity that are not temporary (Beschta et al., 2004). 38. All of these impacts of road reconstruction and construction are persistent, even with remediation, whether the roads’ use is temporary or not (Beschta et al., 2004; Karr et al., 2004). As with landings, the severely negative effects of road reconstruction and construction on soil productivity cannot be completely or readily reversed, even with remediation. Soil conditions on roads are completely restored, even many decades after decommissioning (Menning et al., 1996; Beschta et al., 2004; Foltz et al., 2007). For these reasons, the loss of soil productivity due to road construction and reconstruction is permanent and irretrievable, although this is not assessed or disclosed in the EA. 39. The Jazz Timber Sale will also degrade soil productivity in other ways, including by significantly elevating soil compaction which has already been greatly elevated throughout the Jazz Timber Sale area by past logging. It is extremely well-documented that soil compaction causes long-term losses in soil productivity and is a major problem on public lands that have been subjected to logging (CWWR, 1996; Beschta et al., 2004), as the USFS has acknowledged (USFS and USBLM, 1997a). Although the EA asserts that tree growth on compacted areas is “similar” to uncompacted areas, this is contrary to a vast body on scientific information. The EA provides no data to support this assertion and fails to define what constitutes “similar” tree growth. Therefore, this assertion in the EA does not obviate compaction impacts or countermand available information indicating that soil compaction reduces soil productivity in a persistent fashion and that additional compaction caused by the Jazz Timber Sale will further degrade soil productivity. 40. Although undisclosed in the EA, the loss of soil productivity from compaction is a serious concern due to its persistence. More than 50 years in the absence of additional impacts are usually needed for compacted soils to recover (USFS and USBLM, 1997a; Beschta et al., 2004). This is corroborated by the fact that soils compacted by logging 50-60 ago within the Jazz Timber Sale area remain copiously compacted. 41. The EA fails to reasonably assess the degree of soil productivity lost under the Jazz Timber Sale to elevated topsoil erosion. The EA also fails to make known that the associated loss in soil productivity is permanent, irreversible and irretrievable (Beschta et al., 2004; Karr et al., 2004), as the USFS has also acknowledged (USFS and USBLM, 1997a). 42. This is significant because the logging proposed under the Jazz Timber Sale would significantly elevate surface erosion for several years, as the USFS has repeatedly acknowledged (e.g., USFS et al., 1993; USFS and USBLM, 1997a; b). Reconstructed and constructed landings and roads, including those that are “temporary” will vastly elevate erosion for decades (Potyondy et al., 1991; Menning et al., 1996; Beschta et al., 2004; Karr et al., 2004). Landings and skyline yarding corridors also greatly elevate soil loss in a persistent fashion, permanently reducing soil productivity. 43. Due to the combined defects described in the foregoing, the EA has failed to reasonably assess and discuss the total extent, degree, and persistence of reductions in soil productivity under the Jazz Timber Sale. The EA ignored several ways in which activities under the Jazz Timber Sale will persistently degrade soil productivity, including loss of wood and organic matter from tree removal and reduced mortality of trees, elevated soil erosion, and the zeroing out of soil productivity on constructed landings and reconstructed roads and landings that had undergone some degree of recovery in the absence of use. The EA also failed to reasonably assess and discuss how these multiple impacts caused by Project will combine to synergistically reduce soil productivity. Hence, the EA failed to properly examine the Jazz Timber Sale’s obvious cumulative effects on soil productivity, including significant losses in organic matter over time, soil compaction, soil disruption, and soil loss due to elevated erosion. The EA compounded these defects by failing to acknowledge that several of the impacts on soil productivity are irreversible and involve irretrievable effects, including the loss of LWD, organic matter, and topsoil, and associated impacts on soil productivity. These are significant defects because impacts to soils strongly influence future vegetation conditions and are critical to an assessment of the total impacts on forest ecosystems, and LSR and RR requirements. 44. The USFS has conceded that soil productivity cannot be rapidly or completely restored on roads and landings (Bitterroot National Forest, 2001; Rogue River and Siskiyou National Forests, 2003). The damage to soil productivity on reconstructed and re-opened roads will persistently retard the re-establishment and regrowth vegetation and trees on road alignments, as can be seen on many of unused roads in the Jazz Timber Sale area, even after years of non-use. This persistent effect on the regrowth of vegetation on roads at stream crossings and within a site potential tree height of streams will significantly slow the establishment and production of trees that are the sources of instream LWD, which provides numerous essential stream functions (USFS et al., 1993; NMFS, 1996). The long-term loss of in-stream LWD that will be caused by road activities near streams has adverse effects on ACSOs #3, #6, #8, and #9 (NMFS, 1996). 45. Due to these same defects, the EA does not provide a sound basis for reasonably assessing if the effects of the Jazz Timber Sale are consistent with standards for the NFP LSR and RR land allocations and the ACS and ACSOs. The NFP objective for LSR is to maintain and enhance late-successional forests (NFP, p. B-4, C-9). Persistent losses of soil productivity that the Jazz Timber Sale will trigger are inconsistent with this objective, because losses in soil productivity thwart or impede the growth of vegetation that comprises a primary aspect of late- successional forests. Therefore, soil productivity impacts in LSR must be thoroughly assessed in order to reasonably assess the consistency of activities in LSR with LSR objectives. 46. The NFP (p. C-16) states that road construction in LSR “…is generally not recommended unless potential benefits exceed the costs…” However, despite this direction in the NFP, the EA makes no sound, explicit analysis of the ecological costs and benefits of road and landing reconstruction, construction, and use in LSR because the EA fails to assess the cumulative impacts of the Jazz Timber Sale on soil productivity in LSR. 47. The EA’s defects with respect to RR are similar to those for LSR. The EA fails to divulge the area of road and landing construction and reconstruction in RR under the Jazz Timber Sale, even though these activities cause long-term negative impacts on the ability of the affected areas to grow and support riparian vegetation. This is a major defect in the EA because vegetative conditions in RR are plainly key to the functionality of RR and the ability to meet the ACSO standards (USFS et al., 1993). C. The EA fails to adequately assess cumulative effects because it does not divulge the existing condition of many aquatic and watershed attributes affected by the Jazz Timber Sale. 48. The EA (p. 52) clearly notes it existing conditions are key to assessing cumulative effects analysis: “In order to understand the contribution of past actions to the cumulative effects of the proposed action and alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects.” However, the EA completely fails to divulge the existing condition of a host watershed attributes that will affected by the Jazz Timber Sale and affect compliance with ACSOs. 49. For instance, NMFS (1996) notes that all of the following affect ACSO compliance: . Water Quality / Temperature . Water Quality/Sediment./Turbidity. . Water Quality/Chemical Concentration/Nutrients . Physical Barriers . Substrate . Large Woody Debris . Pool Frequency . Pool Quality . Off-Channel Habitat . Refugia . Width/Depth Ratio . Streambank Condition . Floodplain Connectivity. . Change in Peak/Base Flow . Increase in Drainage Network . Road Density & Location . Watershed Conditions/Riparian Reserves As previously discussed, the Jazz Timber Sale is likely to affect almost all of these conditions via affects on flows, sediment delivery, water temperature, RR, and LWD. However, the EA does not divulge the existing condition of any of these attributes except water temperature. Due to the failure to make known these existing conditions, the EA has clearly failed to divulge the existing cumulative effects on these attributes and their effects on compliance with ACSOs. D. The EA fails to adequately assess and make known the Jazz Timber Sale’s cumulative impacts on water temperature. 50. The EA’s assessment of the water temperature effects of the Jazz Timber Sale is flawed in many ways. The EA failed to make known the total amount of stream shade removed, quantitatively assess the effects of shade removal, and reasonably assess and divulge the duration and extent of temperature impacts from shade removal. The EA also failed to assess the impacts on water temperatures from other activities, such as road crossings. These defects are extremely significant because several affected stream segments in the Collawash watershed already fail to meet state water quality standards for water temperature (EA, p. 67). 51. The Jazz Timber Sale will plainly elevate water temperatures in affected streams by removing shade over streams. The EA (p. 68) indicates that stream shade will be removed in 48 skyline corridors across streams. These corridors will be up to 15 feet wide (p. 68). These corridors will reduce shade on both sides of streams within the corridors, and because the EA is devoid of any required limit on the amount of stream shade removed for these corridors, stream shade may be completely eliminated within the corridors over a total stream length of up to 720 feet. This will inexorably elevate summer water temperatures because it is extremely well- established that the removal of shade over streams elevates summer water temperatures (Theurer et al., 1984; 1985; USFS et al., 1993; Rhodes et al., 1994; Murphy, 1995; Spence et al., 1996; CWWR, 1996; USFS and USBLM, 1997a; b; McCullough, 1999; Bartholow, 2000; Allen and Dietrich, 2005). 52. Although the EA asserts that shade loss over streams due to logging near streams and vegetation removal for 48 skyline corridors will involve “little” loss of shade, the EA never discloses how much stream shade would be eliminated by these activities or how much would remain. Similarly, the EA asserts there would be insignificant impacts on stream temperatures from shade removal, but does so in the absence of assessing the impact of actual shade loss on water temperatures. Such an assessment has long been eminently tractable (Theurer et al., 1984; 1985; Rhodes et al., 1994; Bartholow, 2000). Therefore, the EA has failed to provide any sound basis that water temperature increases due to shade removal will not be significant. 53. The EA’s assertions that the increased water temperatures caused by stream shade removal under the Jazz Timber Sale would not be significant is specious and without a sound basis. A sound determination of the significance of water temperature effects requires all of the three following steps: 1) Determine a scientifically-sound threshold of significance for the change in water temperature; 2) Develop a thorough quantitative estimate of the level of change in water temperature caused by the loss of stream shade under the Jazz Timber Sale.; 3) Compare the sound estimate of total change in water temperature to the threshold of significance. Notably, the EA’s assessment of water temperature impacts from the Jazz Timber Sale’s removal of stream shade lacks all three of these steps, and is, therefore, unsound. 54. The EA’s assertion that water temperature impacts might only occur at site- specific scales is also without merit and in contradiction with considerable scientific information. Scientific assessments, including those of the USFS, have repeatedly shown or noted that water temperature and other water quality impacts in headwater streams affect downstream reaches (Theurer et al., 1984; 1985; USFS et al., 1993; Rhodes et al., 1994; Allen and Dietrich, 2005). Working in two different watersheds Theurer et al. (1985) and Allen and Dietrich (2005) demonstrated that factors that influence water temperatures in headwater segments cumulatively exert a strong control on downstream water temperatures, even in a fairly large stream network. Notably, the EA is devoid of any systemic assessment of water temperature effects at the scale of the stream network, even though such assessments have long been eminently tractable (Theurer et al., 1984). Due to the absence in the EA of such a necessary approach for assessing the scale of water temperature impacts, the EA has no sound basis contention that water temperature impacts will be confined to site-specific scales, which is contrary to available scientific information. 55. The EA’s assertion that water temperature impacts might not be detectable at the scale of 5th to 6th field watersheds is not only made without any sound basis, but also spurious with respect to ACSOs related to temperature. The EA admits that water temperatures may be elevated by Project activities at some smaller scales, albeit to a degree that is never made known. The ACS requires that water temperatures be maintained or improved. The degradation of water temperature at scales smaller than 5th to 6th watershed cannot be conflated with maintaining or improving water temperatures and therefore conflicts with ACS direction. 56. Additionally, the negative effects on water temperature from vegetation removal are persistent. In the absence of soil damage, about 25-40 years are needed for the full recovery of stream shade after vegetation removal (Beschta et al., 1987; Rhodes et al., 1994). However, the soil damage caused by roads and landings significantly retards the regrowth of vegetation due to their severe reductions in soil productivity, increasing the persistence of impacts on water temperatures and associated ACSOs. 57. The EA also fails to include any sort of examination of the effect of reconstructing 12 stream crossings within the Jazz Timber Sale area, although such crossings typically elevate summer water temperatures. Although undisclosed in the FEIS, road runoff that is delivered to streams at stream crossings and other points that are hydrologically connected to streams elevates stream temperatures during summer runoff events (National Research Council (NRC), 2008). This is because runoff occurs in response to even small precipitation events and this runoff is heated by warm road surfaces during summer. Notably, this thermal pollution from roads occurs when streams are already warm due to seasonal effects, elevating the adverse impacts on salmonids (Meehan, 1991; Rhodes et al., 1994; McCullough, 1999). Although undisclosed in the EA, examinations of the effects of road density and density of stream crossings in multiple watersheds have verified that stream temperatures tend to increase with increasing density of roads and stream crossings (Nelitz et al., 2005). This is likely due to the combined impacts of roads and road crossings on water temperatures, including shade loss, subsurface flow disruption, channel widening, and warmed runoff contributions. By completely ignoring this source of water temperature elevation, the EA fails to reasonably examine the total impacts of the Jazz Timber Sale on water temperatures and related ACSOs. E. The EA fails to adequately disclose that Project’s road, landing, and logging activities, especially those in Riparian Reserves, will trigger enduring adverse impacts on sediment delivery and affected ACSOs in conflict with NFP standards. i) Road rebuilding will have long term impacts on sedimentation levels 58. Regarding compliance with the ACS and ACSOs, the NFP states, “Management actions that do not maintain the existing condition or lead to improved conditions in the long term would not ‘meet’ the intent of the Aquatic conservation strategy and thus, should not be implemented.” However, the EA fails to properly discuss that several existing conditions linked to ACSOs would not be maintained or improved in either the short- or longer-term due to the impacts of the Jazz Timber Sale on sediment delivery. 59. Notably, the EA fails to provide any quantitative estimate of sediment delivery from activities known to produce greatly elevated sediment, including elevated road use, logging, and the construction and reconstruction of landings and roads. The EA also fails to provide any estimate of the total sediment delivery that will occur due to these activities. 60. The Jazz Timber Sale proposes to re-open and reconstruct about 12 miles of roads that have been abandoned and/or decommissioned and construct another 0.4 miles of new road. (EA, p. 22); The reconstruction and construction to re-open the 12 miles abandoned or decommissioned roads will involve at least nine stream crossings and the crossing of several more seeps (EA, pp. 22-25; LOC, p. 8). All of these roads would have to be reconstructed, some very heavily, for use, although the level of reconstruction for some segments is far from adequately characterized in the EA. These activities on will cause long term degradation in many ways that conflict with ACSOs. 61. All of the abandoned or unused road segments proposed for road reconstruction under the Jazz Timber Sale that I evaluated on July 5 and July 7, 2012 had undergone some degree of vegetative and soil recovery (See photos attached to this comment). During my July 5 and July 7, 2012 field review, I found one of the roads slated for re-opening and reconstruction under the Jazz Timber Sale, which would run easterly from the 6311-160 road into the proposed Unit 18 basically no longer exists as a road (hereafter, I refer to this segment proposed for construction as “U18PR”). Although it is not made known in the EA, this road has fully recovered via decades of non-use. U18PR is fully occupied by vegetation, forest litter, duff, downed wood and trees, many of which are greater than 6” diameter at breast height (dbh) (see photos of this road segment attached to this comment). Based on my evaluation, this abandoned road is no longer undergoing significantly elevated levels of erosion or runoff and has fully recovered naturally in the absence of use and maintenance. 62. Re-opening and reconstructing these unused or recovered roads will require removing of all vegetative soil cover, including in the case live trees and downed wood. This will vastly increase erosion, as repeatedly documented by research (e.g., Dunne and Leopold, 1978; USEPA, 1980). Other factors equal, bare soils erode at more than 100 times the rate on vegetated surfaces (Dunne and Leopold, 1978; USEPA, 1980; Rhodes et al., 1994). 63. Due to the level recovery on the alignment proposed as Road U18PR, reopening the fully recovered road alignment will entail the same impacts as construction of a new road, which are not disclosed in the EA. This construction will cause immediate, large, and enduring increases in erosion and sediment delivery to streams, although this is not made known in the EA. It is extremely well-documented that road construction vastly elevates erosion for many years (USEPA, 1981; Geppert et al., 1984; Potyondy et al., 1991; USFS, 1993; Rhodes et al., 1994; USFS and USBLM, 1997a; b; Beschta et al., 2004), particularly in the first two years when the construction causes more than a 200 fold increase in erosion relative to areas in a natural condition (Potyondy et al. 1991; Rhodes et al., 1994). 64. However, vegetation removal is not the only impact associated with construction, reconstruction, and opening of unused roads that greatly elevates surface erosion and sediment delivery to streams for many years. Soil compaction also greatly increases surface runoff from roads, significantly elevating surface erosion (Dunne and Leopold, 1978). 65. The unused roads slated for considerable reconstruction under the Jazz Timber Sale have clearly undergone some degree of recovery due to revegetation, which helps de- compact soils (See photos attached to this comment). This existing compaction recovery on these roads will be irretrievably and irreversibly eliminated by the Jazz Timber Sale, greatly elevating road erosion and runoff. 66. These enduring increases in erosion and runoff from Project road activities will contribute to persistent, significant increases in delivery of sediments to streams. At least nine stream crossings will be reconstructed and subject to the re-opening of roads. Hydrological connectivity is typically high at stream crossings, where little can be done to effectively reduce runoff and sediment delivery from roads to streams (Kattlemann, 1996), as the USFS has repeatedly conceded. For instance, the Plumas National Forest Travel Management FEIS (2010) noted: “Road/stream crossings are significant sources of sedimentation on [Forest Service] lands. Even well-drained roads and trails will likely deliver some amount of surface-generated sediment to stream channels at crossings.” Therefore, it is clear that the re-opening of roads under the Jazz Timber Sale will vastly elevate sediment delivery to streams these nine crossings, contrary to the statements in the EA and DN. 67. Roads also contribute sediment to streams when they are relatively close to streams. Other National Forests have noted that it is likely that roads within 300 feet of streams contribute some runoff and sediment to streams (Clearwater National Forest, 2003). Sediment detention below road runoff diversions is limited and quickly exhausted, resulting in the delivery of sediment to streams from road runoff diversions near streams, particularly in the Pacific Northwest, as noted in the USEPA’s commissioned assessment of road BMPs and the water quality impacts of roads (GLEC, 2008), although this is not assessed or divulged in the EA. 68. Many of the currently closed, decommissioned, and/or recovered roads proposed for reconstruction and use under the Jazz Timber Sale are well within 300 feet of streams, based on the Jazz Timber Sale map in the EA (Appendix A). Notably, the MHNF’s own recent impact assessment (MHNF, 2011, p. 57) noted about 350 to 750 feet of roads that cross streams contribute runoff directly to streams. In the case of reconstructed roads, this delivery of runoff to streams over these distances will also deliver vastly elevated levels of sediment to streams. For these combined reasons, it is clear that these proposed road activities would significantly elevate sediment delivery at stream crossings, contrary to the unsupported and unsound statements in the EA. 69. Available scientific information indicates that the Jazz Timber Sale’s road activities, including reconstruction of closed and abandoned roads, will persistently elevate erosion and sediment delivery, for in several ways. The recovery of soils and vegetation that has occurred on many abandoned roads and currently closed roads has accrued in the absence of use over many years to, in some cases, several decades. Reconstruction of these roads will eliminate this recovery. After the roads are reconstructed, it will take many years to decades to reach the same degree of recovery, provided that roads are effectively closed or decommissioned after the Jazz Timber Sale, which is not assured. For the Jazz Timber Sale, the LOC (p. 25) estimated that “…approximately 21% of the roads may not be decommissioned after project completion” based on the MHNF’s decommissioning track record within the Jazz Timber Sale area. But even on decommissioned “temporary” roads, the reconstruction will irretrievably eliminate existing recovery on unused roads and vastly setback future recovery on these alignments, resulting in long-term elevation of sediment delivery to streams under the Jazz Timber Sale. 70. Reconstructed roads cause elevated erosion and sediment for many years after decommissioning (Beschta et al., 2004). The USFS Region 5 method for estimating cumulative watershed effects indicates that even 10 years after road decommissioning, a mile of decommissioned road is equivalent to 0.2 miles of new road in terms of adverse cumulative effects (Menning et al., 1996).4 After 50 years, a mile of obliterated road has still has impacts equivalent to 0.1 mile of new road (Menning et al., 1996). Thus, it is apparent that decommissioning does not instantaneously eliminate the persistent impacts of roads on erosion and sediment delivery. 4 USFS and USBLM, 1997c, Chapter 3, Effects of proposed alternatives on aquatic habitats and native fishes, in Evaluation of EIS Alternatives by the Science Integration Team. Vol. I PNW-GTR-406, USFS and USBLM, Portland, OR, notes that the approach in Menning et al. (1996) regarding the sediment-related risks to watersheds from roads were consistent with the USFS’s experts’ assessments of the sediment-related risks from these activities. 71. The increases in erosion and sediment delivery from road construction are typically greatest in the first few years after reconstruction/construction, as USFS et al. (1993) acknowledges. Decommissioning a few years after reconstruction/construction does not obviate major increases in erosion and sediment delivery that occur in the first years after construction or reconstruction. 72. As we noted in Beschta et al. 2004, “Accelerated surface erosion from roads is typically greatest within the first years following construction although in most situations sediment production remains elevated over the life of a road (Furniss et al. 1991; Ketcheson & Megahan 1996). Thus, even ‘temporary’ roads can have enduring aquatic impacts. Similarly, major reconstruction of unused roads can increase erosion for several years and potentially reverse reductions in sediment yields that occurred with non-use (Potyondy et al. 1991). Where roads are unpaved or insufficiently surfaced with erosion resistant aggregate, sediment production typically increases with increased vehicular usage (Reid & Dunne 1984)…Furthermore, the assumption that road obliteration or BMPs will offset the negative impacts of new road and landing construction and use is unsound since road construction has immediate negative impacts and benefits of obliteration [or decommissioning] accrue slowly.” 73. To provide a simple analysis of the foregoing, I used erosion rates for constructed, reconstructed, and decommissioned roads from a USFS model (Potyondy et al., 1991) to provide a rough estimate of how the Jazz Timber Sale’s proposed road construction on the abandonded, closed or decommissioned roads I examined during my field review would affect longer term erosion and sediment delivery versus that likely from leaving these roads in their current state. This approach can provide a notion of the relative difference between these two alternative road treatments (Potyondy et al., 1991; King, 1993). I scaled the amount of erosion and sediment delivery to that likely to occur with from these roads in their current state.5 This tractable effort 5 My analysis also assumes: a) the major reconstruction needed to open 0.15 mi road segment U18PR is akin to new construction, since it will occur on fully recovered alignment that is revegetated with trees; b) roads undergo heavy use for two years, followed by successful decommissioning of all such roads immediately thereafter. Notably, the latter likely results in underestimation of actual decommissioning, because, as the LOC (p. 25) notes, the MHNF’s track record indicates that more than a fifth of the temporary roads slated for post-Project decommissioning will likely not be decommissioned. indicates that, on average, over five years, the Jazz Timber Sale is likely to cause erosion and sediment delivery that is four times greater than that likely to accrue from leaving these 12 miles of abandoned, decommissioned or closed roads in their existing state, as displayed in the following Figure 1a. This analysis indicates that the elevation in erosion and sediment delivery from the construction and re-opening of these 12 miles of road is even greater for the first three years after these road activities. The erosion from the roads and consequent sediment delivery over the first three years after the Jazz Timber Sale would be almost six times that from the roads in their current partially recovered and vegetated state (Figure 1b). Figure 1a and 1b: 1.04.4012345ProjectNo Action5 yr average estimated increase in erosion and sediment delivery from surface erosion due to reconstruction of 12 miles of temporary road as ratio to that from No Action 1.05.902468ProjectNo ActionThree year average estimated increase in erosion and sediment delivery from surface erosion due to reconstruction of 12 miles of temporary road as ratio to that from No Action 74. In contrast to my foregoing analysis, the EA does not include any quantitative assessment of the Jazz Timber Sale’s effects on road erosion relative to leaving roads in their current recovering state. Therefore, the EA provides no rational basis for its assertions that the Jazz Timber Sale will have insignificant and transient impacts on erosion and sediment delivery to streams. Available information on these impacts strongly countermands the EA’s assertions in this regard. My straightforward estimates of erosion and sediment delivery due to road reconstruction show that the increases in sediment delivery due solely to this activity will plainly cause significant and easily detectable6 increases in sediment delivery to streams, which is consistent with available scientific information that strongly indicates that construction and 6 Numerous studies have detected far smaller increases in erosion and sediment delivery due to logging and road activities. reconstruction of temporary roads will greatly and persistently elevate sediment delivery to the stream system within the Jazz Timber Sale area. ii) Impacts from increased sedimentation due to log hauling 75. Although it is not adequately disclosed in the EA, in addition to construction and reconstruction impacts, elevated road use for log haul under the Jazz Timber Sale will also greatly elevate erosion and sediment delivery on unpaved roads. Research on logging roads has consistently documented that roads used by more than four logging trucks per day generated more than seven times the sediment generated from roads with less use and more than 100 times the sediment from abandoned roads (Reid et al., 1981). The USFS’s own summary of scientific information on roads (Gucinski et al., 2001) concluded that “rates of sediment delivery from unpaved roads are...closely correlated to traffic volume.” 76. Even with a road surface of crushed rock aggregate, which is often used with the intent to reduce sediment production on road surfaces, Foltz (1996) documented that elevated truck traffic increased sediment production by 2 to 25 times that on unused roads in western Oregon. Foltz (1996) noted that since the processes are the same across regions, a similar range of increases was likely. Primary mechanisms for increased erosion and sediment production from road use are the production of highly mobile fine sediment on road surfaces, road prism damage, disruption of gravel or aggregate surfaces, and rutting. 77. As with constructed and reconstructed roads, the highly elevated sediment production from roads used for haul is delivered to streams at stream crossings and other points of connectivity between streams and roads, such as gullies and relief drainage features that dump elevated road runoff laden with sediment to areas in relatively close proximity (e.g., less than 300 feet) to streams. Notably, the EA fails to disclose the total miles of unpaved roads that will be used by haul, the number of stream crossings, and the level of hydrologic connectivity between these roads. However, the LOC (p. 6) indicates that at least 61 miles of unpaved roads will be used for haul under the Jazz Timber Sale. The Jazz Timber Sale maps (EA, App A), indicate that about 90 stream crossings will be affected by elevated road erosion and subsequent sediment delivery to the stream systems at these crossings caused by log haul. Using the MHNF’s (2011, p. 57) estimate that about 500 feet of graveled roads act as extensions of the stream network at crossings, delivering elevated runoff laden with sediment at these junctures, the 90 crossings by haul roads will deliver sediment elevated by log haul directly to streams from about 8.5 miles of road. This impact of log hauling at stream crossings, alone, will greatly elevate sediment delivery to the stream system, contrary to the EA’s baseless assertions that sediment delivery from the Jazz Timber Sale will not be significant. Notably, as discussed in a following section, BMPs do not effectively reduce sediment delivery at stream crossings to insignificant levels. 78. Roads deliver sediment to streams at other points of hydrologic connectivity besides stream crossings, such as gullies, ditches and other road drainage features. Studies of road drainage to streams in the Pacific Northwest have found that about 17 to 35% of the total road mileage contributes sediment to streams (GLEC, 2008). Using the median value, this data indicates that about 26% of the at least 61 miles of unpaved roads with greatly elevated sediment production from log haul will deliver this sediment to streams from at least 15.9 miles of road subject to log haul under the Jazz Timber Sale. Because log haul is likely elevate erosion and sediment delivery by about seven times the level under the No Action on at least 61 miles of road, of which around 15.9 miles will drain into streams, this impact, alone, will greatly elevate sediment delivery to streams. This and other available information, show that the unsupported conclusions in the EA regarding the significance of the Jazz Timber Sale’s impacts on sediment delivery to streams and ACSOs affected by sediment are incorrect, misleading, and without a sound basis. 79. The EA also fails to provide any estimate of the additional sediment generated by the construction and reconstruction of landings, particularly those near streams. Although it is never divulged in the EA, the LOC indicates that at least 20 new landings will be constructed. As previously discussed, many more landings will need to be reconstructed. The EA’s failure to estimate erosion from landing activities is significant because on a per unit basis, landings generate as much sediment as roads (Menning et al., 1997; Beschta et al., 2004). Landings also have considerable potential to deliver sediment to streams. In their study of sediment travel distance from forest management activities, Ketcheson and Megahan (1996) found that the longest travel distance of sediment originated from a landing. Therefore, the EA’s failure to properly assess and make known erosion and sediment delivery impacts from landing activities is highly significant and renders the EA’s assessment of sediment impacts unsound. iii) Cumulative impact of sediment delivery 80. The EA’s failure to properly assess these impacts of landings and road activities is exacerbated by the EA’s failure to assess the cumulative magnitude of all of the impacts of the Jazz Timber Sale on sediment delivery. Instead, the EA only provides qualitative and unsupported judgments about the effects of individual activities, such as road construction and log haul, without ever assessing the overall, combined magnitude of all of the impacts of the Jazz Timber Sale on sediment delivery to streams, including that all logging and yarding, landing, and road activities. This is a major defect, because it has long been known that streams, water quality, and fish habitats are cumulatively affected by the total magnitude of sediment generated by all actions that generate additional sediment to stream systems (USFS et al., 1993; USFS and USBLM, 1997a; b; GLEC, 2008). 81. These impacts of road re-opening and log haul on sediment delivery are extremely significant. USFS et al. (1993) notes that the impacts of roads can change “…streamflow regimes, sediment transport and storage, channel bank and bed configurations, substrate composition…” in ways that “…can have significant biological consequences that affect virtually all components of stream ecosystems…” and can have unavoidable effects on streams, “…no matter how well they are located, designed or maintained.” It is well-documented that increases in sediment delivery increase fine sediment levels in streams, reducing the survival and production of salmonids (Meehan, 1991; USFS et al., 1993). Elevated sediment delivery also degrades pool volume and quality (Lisle and Hilton, 1992; McIntosh et al., 2000). USFS et al. (1993) noted that elevated sediment delivery has been one of the primary causes of the loss of pool volume and frequency in streams within the aegis of the NFP. 82. Elevated sediment delivery contributes to channel widening and loss of depth (Richards, 1982; Rhodes et al., 1994). These changes can increase water temperatures significantly, even when stream shading is not removed (Bartholow, 2000). It can also impede improvement in water temperatures through the same set of mechanisms. 83. Separately, but especially in concert, these effects of the road activities proposed under the Jazz Timber Sale are plainly inconsistent with ACSOs. NMFS (1996) indicates that these impacts would also adversely affect ACSOs #2, #3, #4, #5, #6, #8 and #9. 84. The EA also mischaracterizes the Jazz Timber Sale’s cumulative impacts on sediment delivery because it fails to properly assess and divulge impacts on the stream system (such as road crossings, near-stream logging and landings) that are upstream of listed fish habitat (LFH) and, particularly non-perennial streams. This is a major defect for several reasons. 85. First, it has long been known that smaller perennial and non-perennial streams upstream of fish habitats typically comprise the overwhelming majority of the stream network on in most watersheds (Rhodes, 1994; Moyle et al., 1996). Because non-perennial streams comprise the bulk of the stream network are upstream of perennial streams, these non-perennial streams provide typically provide most of the water and sediment supplied to downstream fish habitats (Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996) as the USFS has acknowledged (USFS and USBLM, 1997a), and, thus, strongly affect downstream conditions in perennial streams. 86. Second, the fine sediments that will be delivered to streams upstream of LFH by Project impacts are highly mobile and transported downstream quite readily. Deposition of fine sediments in LFH that is cumulatively delivered from upstream segments can have major adverse impacts on water quality, fish habitats, stream conditions, and ACSOs. 87. Third, smaller streams upstream of occupied fish habitats are quite vulnerable to upslope impacts from roads, logging, and landing activities because they are often flanked by steeper slopes than downstream reaches (CWWR, 1996), as the USFS has clearly acknowledged (USFS and USBLM, 1997a; b). These elevated impacts to highly sensitive headwater streams are translated downstream and significantly affect occupied fish habitats. As the USEPA’s commissioned report on road BMPs, GLEC (2008), noted, “Downstream deposition areas involving cumulative effects are particularly vulnerable to the negative impacts of forest practices.” 88. Available information, including that from the USFS, amply indicates that upstream impacts of the Jazz Timber Sale on sediment delivery have cumulatively significant impacts on downstream fish habitats. This, in turn, indicates that the EA has properly failed to assess the total sediment impacts on water quality, occupied fish habitats, and related ACSOs because the EA failed to properly assess the cumulative impacts of sediment throughout the stream network. For these reasons, the EA’s dismissal of the cumulative impacts of the Jazz Timber Sale on smaller streams that are well upstream of occupied fish habitats renders the EA’s conclusory assessment of the Jazz Timber Sales impacts on LFH, water quality, and sediment- related ACSOs as unsound and misleading. 89. The EA also fails to properly describe the duration of the elevated erosion and sediment delivery under Project and incorporate it into an adequate analysis of the total impacts on erosion and sediment delivery. Road reconstruction and construction increases erosion and sediment delivery for many years, even if some of the constructed roads are decommissioned and/or subsoiled subsequent to construction (Potyondy et al., 1991; Menning et al., 1996; Beschta et al., 2004; Foltz et al., 2007). However, the EA fails to divulge or account for these persistent increases in erosion and sediment delivery.7 Road decommissioning’s beneficial effects on erosion and runoff accrue slowly (Beschta et al., 2004) and decommissioning can cause additional increases in erosion and sediment delivery in the shorter term. Landings also erode at greatly elevated levels for more than a decade, even if landings are decommissioned subsequent to use, as the USFS’s own models of cumulative effects indicate (Menning et al., 1996). However, the EA fails to properly assess, divulge, and incorporate the duration of 7 The primary causes of elevated erosion on landings and roads are the severe reductions in infiltration rates and cover by vegetation. Studies have repeatedly documented that the subsoiling proposed under the Jazz Timber Sale does not rapidly or completely restore infiltration rates or forest floor vegetation, even many years after roads have been subsoiled or “ripped,” as documented by USFS research (Foltz et al., 2007), although the EA fails to consider this or incorporate it into its analysis. elevated erosion from reconstructed and constructed landings and roads into estimates of the total impact of the Jazz Timber Sale on erosion and sediment delivery. 90. The EA’s repeated assertions that the increases in erosion and sediment delivery caused by Project would not be “significant” are without a sound basis. As previously discussed, a sound determination of the significance of impacts requires all of the three following steps: 1) Determine a scientifically-sound threshold for the significance of the impact; 2) Develop a thorough and complete quantitative estimate of the impact; 3) Compare the sound estimate of the magnitude of the impact to the threshold of significance. Notably, the EA lacks all three of these steps with respect to the analysis of sediment impacts. 91. The increases in sediment delivery will degrade rather than maintain the existing condition of water quality and habitat conditions affected by sediment delivery, contrary to the clear direction in the NFP with respect to the ACS. Elevated levels of sediment delivery conflict with the maintenance and improvement in affected conditions, including water quality and habitat conditions affected by sediment in the longer term. Therefore, these impacts are plainly inconsistent with the NFP direction regarding the ACS, although the EA fails to properly acknowledge this inconsistency. F. The EA fails to make known that Project activities in RR conflict with ACSOs by degrading the reserves and that the Jazz Timber Sale’s “no-cut” buffers will not eliminate these impacts. 92. Along streams within 1,000 feet of LFH, logging is allowed to occur up to a distance of 100 feet from streams under the Jazz Timber Sale (LOC, p. 22), which is inadequate for maintenance of sediment detention, LWD recruitment, and microclimate functions in RR which are vital to ACSO attainment (USFS, 1993; Rhodes et al., 1994: USFS and USBLM, 1997a). The Jazz Timber Sale’s logging in RR is allowed in even closer proximity to streams that are without fish and more than one mile upstream from LFH will only have paltry 50-foot no cut buffer (LOC, p. 22), which is inadequate to maintain most RR functions (USFS, 1993; Rhodes et al., 1994; Menning et al., 1996; USFS and USBLM, 1997a). Non-perennial streams, which comprise the vast majority of the stream network and strongly affect downstream conditions will only have no-cut buffers of 30 to 50 feet (LOC, p. 22), which available scientific information indicates is inadequate to maintain almost all vital RR functions (USFS, 1993; Rhodes et al., 1994; Menning et al., 1996; USFS and USBLM, 1997a). Therefore, the widths of the no-cut buffers under the Jazz Timber Sale are clearly not adequate to meet the ACSOs and maintain and restore vital RR functions as required by the NFP. 93. Although it is never disclosed in the EA, several scientific assessments, including those of the USFS, have noted the need for far wider stream protection widths than those afforded under the Jazz Timber Sale are necessary to protect streams from the adverse impacts of logging, landings, and roads. USFS et al. (1993), USFS and USBLM (1995a; b) indicate that a protected area with a width of at least about 300 feet from each side of a stream is needed to protect aquatic resources from the impacts of upslope disturbance, although this is not disclosed in the EA. Because of their importance and sensitivity, smaller non-perennial and headwater streams need to receive as much or more protection than larger streams if aquatic resources are to be protected (Rhodes et al., 1994; Moyle et al., 1996; USFS and USBLM, 1997a). Scientific information amply indicates that there is a high degree of certainty that the lack of adequate riparian protection under the Jazz Timber Sale and its logging, landing, and road activities in RR will appreciably degrade RR functionality and several ACSOs in conflict with the direction in the NFP, contrary to the cursory statements in the EA regarding the adequacy of the Jazz Timber Sale’s no cut buffers. 94. The Jazz Timber Sale’s no-cut widths are inadequate to eliminate the impacts of road activities within Riparian Reserves. Impacts at or near stream crossings are not affected by the Jazz Timber Sale’s no-cut buffers because the roads and skyline yarding corridors pierce these buffers. A no-cut buffer does not exist between roads and streams at stream crossings. Therefore, a no-cut buffer has no significant effect on the persistent impacts caused by roads activities at and near stream crossings, including the impacts on sediment delivery, runoff, LWD, stream shading, and water temperatures. 95. The Jazz Timber Sale’s no-cut buffers will curtail the recruitment of large woody debris (LWD). Although the EA asserts that the no-cut buffers will preserve “most” of in- channel LWD recruitment, “most” is not the same as “all,” which is what is necessary to meet the “maintain and restore” requirements for RR and LWD in the ACS. Notably, the LOC (p. 22) clearly notes that the no-cut buffers under the Jazz Timber Sale are inadequate to maintain existing LWD recruitment levels: “Assuming the buffers are fully stocked, the no-cut buffers would capture approximately 25 to 85% of the existing wood recruitment from the adjacent stands…” Because LWD is absolutely vital to stream functions, this loss of 15 to 75% of LWD recruitment due to inadequate widths of no-cut buffers on streams under Project clearly does not maintain or restore LWD levels as required by the NFP. This is especially significant because the loss of LWD is extremely persistent, requiring many decades for full recovery (Rhodes et al., 1994). NMFS (1996) notes that LWD affects ACSOs #3, #6, #8, and #9. G. The EA fails to properly acknowledge that the Jazz Timber Sale’s BMPs have limited effectiveness and cannot obviate the negative impacts of the Jazz Timber Sale on soils, RR, LSR, and ACSOs. 96. The EA compound the defects described in the foregoing by failing to reasonably disclose that Best Management Practices (BMPs) for roads have very limited effectiveness. Although it is undisclosed in the EA, there are no reliable data indicating that BMPs consistently reduce the adverse effects of roads on aquatic resources to ecologically negligible levels, especially within the context of currently pervasive watershed and aquatic degradation (Ziemer and Lisle, 1993; Espinosa et al., 1997; USFS and USBLM, 1997; Beschta et al., 2004; GLEC, 2008). 97. The nationwide assessment of BMP effectiveness commissioned by the USEPA (GLEC, 2008) specifically noted that BMPs aimed at reducing road impacts are not 100% effective, and, in particular, that efforts to prevent road drainage to streams have considerable potential for failure, especially in the Pacific Northwest. However, the EA does not provide any discussion of the known limited effectiveness of road BMPs. GLEC (2008) also notes that in the Pacific Northwest that “conventional BMPs for road construction may not be sufficient to prevent adverse effects on stream channels and fish habitat.” 98. BMPs do not eliminate the adverse impacts of roads on sediment delivery. For instance, BMPs cannot eliminate sediment delivery from roads to streams at stream crossings (Kattlemann et al., 1996; Beschta et al., 2004; Rhodes and Baker, 2008). Megahan et al. (1992) and USFS and USBLM (1997c) noted that it is not possible to log areas without increasing erosion and sediment delivery, regardless of BMPs involved or care in implementation, especially when roads are involved. Based on review of available data, MacDonald and Ritland (1989) concluded that roads typically double suspended sediment yield even with state-of-the-art construction and erosion control and that suspended sediment contributions from surface erosion, alone, from roads in the absence of mass failure, are typically in the range of 5 to 20 percent above background and remain at elevated levels for as long as roads are in use. Notably, this would, in many cases, violate water quality standards for turbidity. 99. Activities implemented with somewhat effective BMPs still often contribute to negative cumulative effects on aquatic systems (Ziemer et al., 1991; Rhodes et al., 1994; Espinosa et al. 1997; Beschta et al., 2004; GLEC, 2008). Espinosa et al. (1997) documented that aquatic habitats were severely damaged by roads and logging in several watersheds despite BMP application. Espinosa et al. (1997) noted that blind reliance on BMPs in lieu of limiting or avoiding activities that cause aquatic damage serves to increase aquatic damage. 100. Importantly, the Jazz Timber Sale fails to include the most effective BMPs, which are: . avoidance of implementing damaging logging, landing, and road activities in high hazard, sensitive, or degraded areas, such as stream crossings, RR, and unstable terrain, such as earthflows (Rhodes, 1994; Kauffman et al., 1997; Beschta et al., 2004; Karr et al., 2004; GLEC, 2008); . full protection of an adequate width of riparian areas to prevent or reduce the transmission of upslope impacts to streams (USFS, 1993; Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996; USFS and USBLM, 1997a; Beschta et al., 2004; Karr et al., 2004). This avoidance of high impact activities in sensitive terrain has long been recognized as far more effective than attempting to reduce such impacts via BMPs, which have very limited effectiveness. Avoidance of sensitive areas is critical, because as GLEC (2008) noted with respect to road impacts, “in some cases, however, control of the problem may not be feasible: location ‘trumps’ management practice.” It has long been recognized that full protection of the area of vegetation within 200 to >300 ft of the edge of all stream types is one of the most important and effective ways to limit the impacts from upslope logging-related disturbances, as numerous independent assessments have repeatedly concluded, including, to but not limited to, USFS et al. (1993), Henjum et al. (1994), Rhodes et al. (1994), NRC (1996), Erman et al. (1996), Moyle et al., 1996; USFS and USBLM (1997a; b), Beschta et al. (2004), and Karr et al. (2004). However, despite this information, the EA fails to incorporate these effective BMPs. 101. For these reasons, the EA fails to reasonably examine the Jazz Timber Sale’s likely impacts on aquatic systems, because the EA fails to reasonably assess the limited effectiveness of the Jazz Timber Sale’s BMPs. H. The EA fails to properly analyze and divulge the Jazz Timber Sale’s impacts of peakflows and consistency with NFP ACSO # 6. 102. Although the EA acknowledges that logged forests with immature forest vegetation combine with the effects of roads to elevate peakflows, the EA does not adequately assess and discuss the existing impacts on peakflows and how the Jazz Timber Sale will exacerbate those impacts. This is significant because as research in the Pacific Northwest has shown, the combined impacts of logging, roads, landings elevate peakflows, especially in areas in the “transient snow zone” (TSZ) (La Marche and Lettenmaier, 2001; Jones and Grant, 1996; Grant et al., 2008), in which almost the entire Project would occur (EA, p. 81). 103. The EA failed to divulge or discuss the findings of the USFS’s PNW research station regarding recent synthesis on the effects of logging and roads on peakflows (Grant et al., 2008). This omission clearly indicates that the EA failed to thoroughly examine impacts on peakflows based on the USFS’s own recent research. 104. This is also a significant failing because the findings of Grant et al. (2008) indicate that existing levels of immature forests from past logging within the Jazz Timber Sale area have likely elevated peakflows in a detectable fashion. Although undisclosed in the EA, Grant et al., found that in the TSZ watersheds that have had 15 to 19% or more of the area logged have detectable peakflow increases. The EA (p. 89, Table ) indicates that several smaller watersheds within the Jazz Timber Sale area have more than 15% of their watershed area in a logged over condition that has not completely hydrologically recovered from previous logging, including the watersheds of Dutch, Lower Nohorn, Farm, and Skin. Therefore, the EA fails to disclose that the USFS’s own state-of-the-art assessment indicates peakflows have already been elevated in these watersheds. Thus, existing conditions within the Jazz Timber Sale in these watersheds do not comply with ACSO #6, of the ACS in the NFP which requires the following: “Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected.” This is a critical defect because the Jazz Timber Sale will incrementally exacerbate existing conditions in the drainages (EA, p. 90) that already have elevated peakflows by removing forest canopy via logging, landing, and road activities, which contributes to additional elevation of peakflows. 105. The EA also fails to reasonably assess flow alteration and compliance with ACSO # 6 in other ways. The EA includes no assessment of the existing hydrologic connectivity between roads and the stream system. This is a key defect. As Grant et al. (2008, p. 39) noted regarding peakflow impact assessment: “Determining where the proposed treatment falls within this range requires an assessment of the intrinsic basin condition and intensity of proposed management action…For example, the existing and proposed road network should be evaluated with respect to its degree of connectivity with the stream network…” (emphasis added) 106. The EA also completely ignored available scientific information which indicates that logging, landing, and road activities also alter the timing (frequency) of peakflows (Alila et al., 2009). This is a significant defect because this alteration in peakflow timing affects compliance with ACSO #6. 107. These defects have ecological significance. Although it is not made known in the EA, peakflow elevation by logging and roads is an important concern because even minor changes in peakflow magnitude and frequency can have major effects on salmonids by triggering significant changes in channel erosion and sediment transport (Dunne et al., 2001). 108. The EA also fails to include any assessment of the accuracy of the MHNF’s methods for estimating peakflow impacts. This is a significant flaw because it critical to assess model accuracy, reliability, and sensitivity in order to asses the accuracy of model results. Such assessments of model accuracy have long been requisite for assessing model results in natural resource science. 109. Due to the numerous defects and deficiencies in the EA’s analysis of project effects on streamflows, the EA has failed to reasonably analyze and properly discuss the Jazz Timber Sale’s impacts on peakflows and affected resources. For the same reasons, the EA has failed to properly determine the consistency of this alternative with the ACSO #6 and the NFP ACS. Summary and Conclusions 110. The EA has many severe defects which render its conclusions regarding compliance with NFP, effects on ACSOs, and environmental impacts as baseless, misleading, and in direct conflict with available information related to the Jazz Timber Sale’s impacts. The EA failed to reasonably assess and make known the Jazz Timber Sale’s cumulative impacts on LWD and soil productivity. 111. The EA did not properly assess the Jazz Timber Sale’s effect on water temperature. As a result, the EA’s assessment of these impacts and effects on related ACSOs is unsound and misleading. 112. The EA failed to adequately assess and divulge the Jazz Timber Sale’s cumulative effects on erosion and sediment delivery in many ways. Due to these defects, the EA’s conclusory assessment of these impacts and effects on water quality, streams, related ACSOs is not valid. 113. The EA failed to properly evaluate and make known that the Jazz Timber Sale’s BMPs are inadequate to reduce the Jazz Timber Sale’s impacts to insignificant levels. These defects are exacerbated by the Jazz Timber Sale’s failure to incorporate highly effective BMPs such as avoidance of high impact activities in high hazard areas and protection of an ample width of riparian areas, although this is never made known in the EA. Due to these flaws, the EA’s assessment of the Jazz Timber Sale’s effects on water quality, streams, related ACSOs is not unsound and misleading. 114. The EA also failed to properly assess and make known the existing cumulative impacts in the Jazz Timber Sale area. This is because the EA did not make known the existing condition of a wide variety of watershed attributes that affect ACSOs and will be affected by the Jazz Timber Sale. 115. The EA also failed to identify numerous irretrievable and irreparable effects that the Jazz Timber Sale will cause. These irretrievable and irreparable Project effects ignored in the EA include the loss of LWD, loss of soil productivity, the elimination of accrued recovery on unused landings and roads subject to re-opening, and topsoil erosion ____________________________ JONATHAN J. RHODES Literature Cited Allen, D.M. and Dietrich, W.E., 2005. Application of a process-based, basin-scale stream temperature model to cumulative watershed effects issues: limitations of Forest Practice Rules. Eos Trans. AGU, 86(52), Fall Meet. Suppl., Abstract H13B-1333, http://www.agu.org/meetings/fm05/fm05-sessions/fm05_H13B.html Alila, Y., P. K. Kuras, M. Schnorbus, and R. Hudson, 2009. Forests and floods: A new paradigm sheds light on age-old controversies. Water Resour. Res., 45, W08416, doi:10.1029/2008WR007207. Bartholow, J.M., 2000, Estimating cumulative effects of clearcutting on stream temperatures, Rivers, 7: 284-297. Beschta, R.L., Rhodes, J.J., Kauffman, J.B., Gresswell, R.E, Minshall, G.W., Karr, J.R, Perry, D.A., Hauer, F.R., and Frissell, C.A., 2004. Postfire Management on Forested Public Lands of the Western USA. Cons. Bio., 18: 957-967. Bitterroot National Forest, 2001. FEIS for the Burned Area Recovery Project. Bitterroot National Forest, MT. Clearwater National Forest (CNF), 2003. Roads analysis report. Clearwater National Forest, Orofino, ID. Dunne, T. and Leopold, L., 1978. Water in Environmental Planning. W.H. Freeman and Co., NY. Dunne, T., Agee, J., Beissinger, S., Dietrich, W., Gray, D., Power, M., Resh, V., Rodrigues, K., 2001. A scientific basis for the prediction of cumulative watershed effects. University of California Wildland Resource Center Report No. 46. Erman, D.C., Erman, N.A., Costick, L., and Beckwitt, S. 1996. Appendix 3. Management and land use buffers. Sierra Nevada Ecosystem Project Final Report to Congress, Vol. III, pp. 270- 273. Wildland Resources Center Report No. 39, University of California, Davis. Espinosa, F.A., Rhodes, J.J. and McCullough, D.A. 1997. The failure of existing plans to protect salmon habitat on the Clearwater National Forest in Idaho. J. Env. Management 49(2):205-230. Foltz, R.B. and Burroughs, E.R., Jr. 1990. Sediment production from forest roads with wheel ruts. In: Proceedings from Watershed Planning and Analysis in Action. Symposium Proceedings of IR Conference, Watershed Mgt, IR Div, American Society of Civil Engineers, Durango, CO, July 9-11, 1990. pp. 266-275. Foltz, R.B., 1996. Traffic and no-traffic on an aggregate surfaced road: sediment production differences. Presented at the FAO Seminar on Environmentally Sound Forest Roads, June 1996, Sinaia, Romania. 13 p. Foltz, R.B., Rhee, H., Yanosek, K.A., 2007. Inltration, erosion, and vegetation recovery following road obliteration. Trans. ASABE 50: 1937-1943. Geppert, R.R., Lorenz, C.W., and Larson, A.G., 1984. Cumulative effects of forest practices on the environment: a state of the knowledge. Wash. For. Practices Board Proj. No. 0130, Dept. of Natural Resources, Olympia, Wash. Gifford Pinchot National Forest, 2009. Wildcat Environmental Assessment. Gifford Pinchot National Forest, Vancouver WA. Grant, G.E., S.L. Lewis, F.J. Swanson, J.H. Cissel, and J.J. McDonnell. 2008. Effects of forest practices on peak flows and consequent channel response: a state-of-science report for western Oregon and Washington. General Technical Report PNW-GTR-760. Pacific Northwest Research Station, Forest Service, USDA, Portland, OR. (GLEC) Great Lakes Environmental Center, 2008. National Level Assessment of Water Quality Impairments Related to Forest Roads and Their Prevention by Best Management Practices. Final Report. Report prepared for US Environmental Protection Agency, Office of Water, Contract No. EP-C-05-066, Task Order 002, 250 p. Gregory S.V., Swanson F.J., McKee W.A., Cummins K.W. 1991. An ecosystem perspective of riparian zones. BioScience, 41:540–51 Gucinski, H., Furniss, M.J, Ziemer, R.R and Brookes, M.H., 2001. Forest roads: a synthesis of scientific information. Gen. Tech. Rep. PNW GTR-509. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. Henjum, M.G., Karr, J.R., Bottom, D.L., Perry, D.A., Bednarz, J.C., Wright, S.G., Beckwitt, S.A., and Beckwitt, E., 1994. Interim Protection For Late Successional Forests, Fisheries, And Watersheds: National Forests East Of The Cascade Crest, Oregon And Washington. The Wildlife Soc., Bethesda, Md. Jones J.A. and Grant. G.E., 1996. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon. Water Resour. Res. 32: 959-974. Karr, J.R., Rhodes, J.J., Minshall, G.W., Hauer, F.R., Beschta, R.L., Frissell,C.A., and Perry, D.A, 2004. Postfire salvage logging's effects on aquatic ecosystems in the American West. BioScience, 54: 1029-1033. Kattelmann, R., 1996. Hydrology and water resources. Sierra Nevada Ecosystem Project Final Report to Congress, Vol. II: pp. 855-920. Kauffman, J.B., R.L. Beschta, N. Otting, and D. Lytjen, 1997. An ecological perspective of riparian and stream restoration in the western United States. Fisheries 22:12-24. Ketcheson, G. L. and Megahan, W. F., 1996. Sediment production and downslope sediment transport from forest roads in granitic watersheds, USFS INT-RP-486. USFS Intermountain Research Station, Ogden, UT. King, J.G., 1993. Sediment production and transport in forested watersheds in the northern rocky mountains. Proceedings Technical Workshop on Sediments, pp. 13-18, Terrene Inst., Washington, D.C. La Marche, J.L. and Lettenmaier, D.P., 2001. Effects of forest roads on flood flows in the Deschutes River, Washington. Earth Surf. Process. Landforms, 26: 115-134. Lisle, T. and Hilton, S., 1992. The volume of fine sediment in pools: An index of sediment supply in gravel-bed streams. Water Resour. Bull., 28: 371-383. MacDonald, A. and Ritland, K.W., 1989. Sediment Dynamics in Type 4 and 5 Waters: A Review and Synthesis. TFW-012-89-002. Wash. Dept. of Natural Resour., Olympia, Wash. MacDonald, A. and Ritland, K.W., 1989. Sediment Dynamics in Type 4 and 5 Waters: A Review and Synthesis. TFW-012-89-002. Wash. Dept. of Natural Resour., Olympia, Wash. McCullough, D.A., 1999. A Review and Synthesis of Effects of Alterations to the Water Temperature Regime on Freshwater Life Stages of Salmonids, with Special Reference to Chinook Salmon. USEPA Technical Report EPA 910-R-99-010, USEPA, Seattle, Wa. McIntosh, B.A. and four others, 2000. Historical changes in pool habitats in the Columbia River Basin. Ecological Applications, 10: 1478-1496. Maidment, D.R. [ed], 1993. Handbook of Hydrology. McGraw-Hill, New York. Meehan, W.R. (ed.), 1991. Influences of Forest and Rangeland Management on Salmonid Fishes and Their Habitats. Am. Fish. Soc. Special Publication 19. Menning, K.M., Erman, D.C., Johnson, K.N., and Sessions, J., 1997. Modeling aquatic and riparian systems, assessing cumulative watershed effects, and limiting watershed disturbance. Sierra Nevada Ecosystem Project Report, Summary and Final Report to Congess, Addendum pp. 33-52. Wildland Resources Center Report No. 38, University of California, Davis. Moyle, P. B., Zomer, R., Kattelmann, R., and Randall, P., 1996. Management of riparian areas in the Sierra Nevada. Sierra Nevada Ecosystem Project: Final Report to Congress, vol. III, report 1. Wildland Resources Center Report No. 39, University of California, Davis. Murphy, M.L., 1995. Forestry Impacts on Freshwater Habitat of Anadromous Salmonids In the Pacific Northwest and Alaska--Requirements for Protection and Restoration. NOAA Coastal Ocean Program Decision Analysis Series No. 7. NOAA Coastal Ocean Office, Silver Spring, MD. 156 pp. (MHNF) Mt. Hood National Forest, 2011. Timberline Ski Area Mountain Bike Trails and Skills Park Preliminary Assessment (PA), Mt. Hood National Forest, Clackamas County, OR. (NMFS) National Marine Fisheries Service, 1996. Making ESA determinations of the effect of individual or grouped actions at the watershed scale. NOAA Fisheries ETS Division, Portland, OR. (NMFS) National Marine Fisheries Service, 2012. Endangered Species Act Section Concurrence Letter and Magnuson-Stevens Essential Fish Habitat Response for the Jazz Thin Timber Sale, Collawash River. NMFS, Seattle WA. Nelitz, M.A, MacIsaac, E.A., Peterman, R.M., 2007. A science-based approach for identifying temperature-sensitive streams for rainbow trout. N. Amer. J. of Fish. Manage., 27: 405–424. NRC (National Research Council), 1996. Upstream: salmon and society in the Pacific Northwest. National Academy Press, Washington, D.C. (NRC) National Research Council, 2008. Urban Stormwater Management in the United States, National Academies Press, Washington, D.C. Plumas National Forest, 2010. Final Environmental Impact Statement Plumas National Forest Public Motorized Travel Management. Pacific Southwest Region, Plumas National Forest, Quincy, CA. Potyondy, J.P., Cole, G.F., Megahan, W.F., 1991. A procedure for estimating sediment yields from forested watersheds. Proceedings: Fifth Federal Interagency Sedimentation Conf., pp. 12-46 to 12-54, Federal Energy Regulatory Comm., Washington, D.C. Reid, L.M., Dunne, T., and C.J. Cederholm, 1981. Application of sediment budget studies to the evaluation of logging road impact. J. Hydrol (NZ), 29: 49-62. Rhodes, J.J., McCullough, D.A., and Espinosa Jr., F.A., 1994. A Coarse Screening Process for Evaluation of the Effects of Land Management Activities on Salmon Spawning and Rearing Habitat in ESA Consultations. CRITFC Tech. Rept. 94-4, Portland, Or. Rhodes, J.J. and Baker, W.L., 2008. Fire probability, fuel treatment effectiveness and ecological tradeoffs in western U.S. public forests. Open Forest Science Journal, 1: 1-7. http://www.bentham.org/open/tofscij/openaccess2.htm Richards, K., 1982. Rivers: Form and Process in Alluvial Channels. Methuen & Co., New York. Rogue River and Siskiyou National Forests, 2003. Biscuit Fire Recovery Project DEIS. Rogue River and Siskiyou National Forests, Medford, OR. Santa Fe National Forest (2010). Draft Environmental Impact Statement (DEIS) for Motorized Travel Management Santa Fe National Forest. USFS, Southwestern Region, Santa Fe, NM. Spence, Brian C.; Lomnicky, Gregg A.; Hughes, Robert M.; Novitzki, Richard P. 1996. An ecosystem approach to salmonid conservation. Management Technology report TR-4501-96-6057. Steele, P.H., 1984. Factors determining lumber recovery in sawmilling. Gen. Tech. Rep. FPL-39. Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory, 1984. 8 p. Theurer, F.D., Voos, K.A., and Miller, W.J., 1984. Instream Water Temperature Model. Instream Flow Information Paper No. 16, FS/OBS-84-15, USFWS, Washington, D.C. Theurer, F.D., Lines, I., and Nelson, T., 1985. Interaction between riparian vegetation, water temperature and salmonid habitat in the Tucannon River. Water Res. Bull., 21:53-64 USEPA, 1980. An Approach to Water Resource Evaluation of Non-Point Silvicultural Sources (A procedural handbook). EPA-600/8-80-012, USEPA Office of Res. and Dev., Washington, D.C. USFS, NMFS, USBLM, USFWS, USNPS, USEPA, 1993. Forest Ecosystem Management: An Ecological, Economic, and Social Assessment. USFS PNW Region, Portland, Or. USFS and USBLM, 1997a. The Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins, Volumes I-IV. PNW-GTR-405, USFS, Walla Walla Washington. USFS and USBLM (Bureau of Land Management), 1997b. The DEIS for the "Eastside" Planning Area. USDA Forest Service, Walla Walla, Washington. Wemple, B.C., Jones, J.A., and Grant, G.E., 1996. Channel network extension by logging roads in two basins, Western Cascades, Oregon. Water Resour. Bull., 32: 1195-1679. Ziemer, R.R., Lewis, J., Lisle, T.E., and Rice, R.M., 1991. Long-term sedimentation effects of different patterns of timber harvesting. In: Proceedings Symposium on Sediment and Stream Water Quality in a Changing Environment: Trends and Explanation, pp. 143-150. Inter. Assoc. Hydrological Sciences Publication no. 203. Wallingford, UK. Ziemer, R.R., and Lisle, T.E., 1993. Evaluating sediment production by activities related to forest uses--A Northwest Perspective. Proceedings: Technical Workshop on Sediments, Feb., 1992, Corvallis, Oregon. pp. 71-74. Terrene Inst., Washington, D.C.