Friends of the Bitterroot

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The letter below addresses FOB's concerns re the proposed Trapper-Bunkhouse project in the Darby Ranger District of the Bitterroot National Forest. The DEIS for the project will follow and will elicit additional comments.

Scoping comments for the Trapper-Bunkhouse Land Stewardship Project

Date: October 20, 2005

Dear Ranger Oliver:

Your notice stated the purpose/need of the Trapper-Bunkhouse Land Stewardship Project is because the "landscapes ... are not functioning as they should due to influences from many natural or human-caused factors". It appears the human-caused factors include the extensive forest road system's significant adverse impacts and the heavy-handed logging that has occurred throughout much of the roaded portions of proposed analysis area.

Under fisheries and watersheds, you state that the proposed activities "... focus on restoring aquatic passage, improving channel conditions ... and protecting the overall good stream health in the analysis area". It further states that "no streams ... are on the ... 303d ... List for sediment reasons".

While no analysis area streams are actually on the 303d List, the Bitterroot River downstream from the East Fork and West Fork is on the 303d List and the analysis area's streams are tributaries to the Bitterroot River.

Previous FS analyses appear to raise a question about the "overall good stream health" statement in your notice. The BNF's 1991 Sensitive Watershed Analysis identified Little Trapper, Trapper Tributary, BT Face, South Fork Chaffin, North Fork Chaffin, McCoy, Bunkhouse, and Waddell Creeks as being "High Risk" (Red), and Spoon Creek was listed as "Sensitive" (Yellow).

High Risk (Red) streams do not fully support their "beneficial uses" as is required by the Clean Water Act, and the "Sensitive" (Yellow) streams may not either.

The Trapper-Bunkhouse Project analysis area is approximately 34,300 acres in size, and you are proposing "vegetation treatments" over 5,785 acres within the analysis area. Of the 5,785 acres of "vegetation treatments", activities on approximately 3,075 acres will consist of commercial logging. While you apparently already have logging units laid out, your notice failed to provide the unit numbers within the shaded areas shown on your vegetation proposed action map.

We are concerned about the proposed amounts of commercial logging and potential for road construction/reconstruction and ORV loop trail construction/reconstruction because of the history of extensive logging and roading impacts to the watersheds and fisheries within this area.

Your notice states the Trapper-Bunkhouse Project will "respond to the goals and objectives of the ... [BNF] Land and Resource Management Plan". Apparently it will respond to the Plan by using "amendments" so you will not have to comply with the mandatory Plan Standards for snags, wildlife EHE, and wildlife thermal cover in the activity areas.

Your Trapper-Bunkhouse Project also proposes to create and designate extensive off-road vehicle (ORV) trail loops in the Bunkhouse and Trapper-Chaffin areas. The notice states that ORV loops in the Bunkhouse area would be approximately 24 miles in length and the six potential ORV loops in the Trapper-Chaffin area would total approximately 75 miles in length. Two parking areas would be built in the Trapper-Chaffin area and one would be constructed in the Bunkhouse area.

The Trapper-Chaffin ORV loops are in the general area where Supervisor Dave Bull in 2003 previously proposed a ORV destination play area. There was significant public concern and objections raised about the intended actions and their likely consequences and the proposal was dropped from further analysis at that time. It appears you now are using the Trapper-Bunkhouse Land Stewardship Project EIS process to resurrect and overpower the previous local non-motorized user's and local homeowner's strong objections by attaching it to logging and fire safety issues.

The NEPA implementing regulations and court decisions require that an EIS develop a reasonable range of alternatives, be a "full disclosure" document, and the proposed activities must be in full compliance with the Bitterroot LRMP. Ninth Circuit Court decisions have determined that proposed actions must be in full compliance with the controlling LRMP. BNF Plan Management Areas within these proposals include MAs 1, 2, 3a, 3b, 3c, 5 and 6. The 1987 Forest Plan sets out enforceable Standards for each of the above MAs which must be complied with in proposed actions unless they are specifically amended. Your EIS will need to disclose and discuss the applicable Plan Standards and demonstrate compliance with the Forest Plan.

Approximately two-thirds of the Bitterroot National Forest watersheds are in significantly worse shape than disclosed by the Forest Plan. The native species of fish were also in a much more precarious condition than was apparently assumed in the 1987 Forest Plan. Bull trout were not listed as a MIS or otherwise acknowledged by the Forest Plan. One of the objectives of the proposed Trapper-Bunkhouse Project's actions should be to develop site-specific actions and objectives for the most rapid recovery of the adversely affected streams and native fisheries.

The EIS for the proposed actions will need to disclose and assess the effects on the watersheds due to the cumulative actions from the past logging, road building and reconstruction, grazing, mining, or other human-induced impacts in conjunction with the present proposals. The cumulative effects of direct, indirect, and reasonably foreseeable future logging, road construction, grazing or mining activities in the analysis area need to be disclosed and assessed. The analysis will need to clearly map, disclose and discuss all the watershed riparian areas and existing conditions, including the bogs and wet areas with undefinable stream courses found within the assessment area.

The existing Forest system roads will be used by workers, log haulers, contractors, ORV users, Forest Service personnel and the general public. The analysis for the Trapper-Bunkhouse proposed projects need to evaluate and fully disclose the environmental consequences that the cumulative effects of past and reasonably foreseeable future road construction, road maintenance and logging within the assessment area and the adjacent connected riparian systems on the native fisheries.

The EIS analysis will need to clearly describe and disclose the effects of past activities on the fisheries resource within the proposed activity areas and in other streams adjacent to the general area. The descriptions and disclosures need to be site-specific.

On the existing Forest roads, stream crossings and culverts are of special concern, and many of the roads closely parallel, and cross Forest streams. The analysis for the Trapper-Bunkhouse Project's proposed actions must fully disclose and evaluate sedimentation sources on all existing roads within the assessment area and any connected riparian areas. For each stream within the project area, their connected riparian areas and along the Forest roads, the analysis must fully disclose the impacts of past, present and reasonably foreseeable future projects on the fisheries resource and on fisheries habitat.

The descriptions and disclosures need to be site-specific and should include the documented and measured sediment bedloads, embeddedness levels, spawn/fry emergence percentages, critical reaches, macroinvertebrates, biological potentials, turbidity and chemistry levels, stream bed and bank stability conditions currently found as opposed to the natural or "unaffected" conditions. The site-specific analysis needs to disclose fish numbers, species, size, condition, and locations. Of particular concern are the bull trout and the westslope cutthroat trout.

Fragmentation of wildlife habitat by road construction, leaving many system and non-system roads open to motorized vehicle use throughout much of the year, logging and other projects that remove and destroy cover needed by wildlife or cause stress or wildlife disturbance is a concern as well. The extent to which habitat fragmentation has already taken place within and immediately adjacent to the analysis area need to be fully disclosed in the Trapper-Bunkhouse EIS.

The road density (open and closed) issue is closely linked to stream sedimentation, wildlife habitat fragmentation, indiscriminate shooting of birds and animals (particularly the low density, wide ranging carnivores) and poaching of big game animals. These are significant issues of concern. Roads cannot truly be considered closed to motorized vehicle use and mitigation measures claimed if they are still open to off-road motorized vehicle uses. Closed roads still have significant effects, and site-specific road density information needs to be fully disclosed. The analysis for the Trapper-Bunkhouse Project area should clearly display on maps the locations of all roads, both open and closed (including temporary roads and other non-system roads) that exist on the developed areas of federal, state or private lands within and adjacent to the different analysis areas.

Your analysis will need to disclose which system and non-system roads are open to motorized vehicle use along with the seasons of their use. The analysis also needs to show the locations of trails, (system and non-system), that exist within the area and whether or not they are open to motorized vehicles.

The analysis will need to fully disclose and discuss the situation regarding any likely funding levels and the relationship to the Forest's continuing failures to properly maintain the existing road systems over several decades. The BNF has an extensive backlog of necessary road reconstruction and repairs that have not been funded. These deteriorating system roads are significantly impacting watershed and fisheries resources and can lead to further listings under the ESA.

Because the historical road budgets for the BNF have not been adequately funded for decades, there is good reason for the public to question that the road reconstruction and rehabilitation work proposed in the Trapper-Bunkhouse Project will actually be adequately funded or ever accomplished.

The analysis for the Trapper-Bunkhouse Project's proposed actions will need to fully disclose and discuss the cumulative adverse impacts stemming from the Forest's repeated failures to receive adequate funding to maintain the existing road systems in conjunction with the fires and the subsequent loss of funds for the roads restoration and rehabilitation that was required in the BAR ROD and court Settlement Agreement.

Due to the continuing lack of necessary funding, we maintain that your EIS needs to take a hard look at closing and removing more roads in the Trapper-Bunkhouse project area. We believe it would be arbitrary and capricious for you to further ignore this ongoing lack of adequate funding levels and the resulting significant resource impacts.

Significant portions of the Forest lands within the analysis area have been adversely impacted by previous road construction and logging. Unrecovered and unregenerated cutting units will need to be fully disclosed, in addition to the past cutting units, where vegetation and regeneration are not yet of sufficient height to provide adequate hiding cover and/or thermal cover for elk and other wildlife species.

The EIS needs to provide an indepth analysis of the cumulative effects from past, present, and reasonably foreseeable future actions on the habitat of sensitive species and species of special concern such as goshawk, great gray owl, northern saw whet owl, boreal owl, flammulated owl, pileated woodpecker, blackbacked three-toed woodpecker, northern three-toed woodpecker, fisher, marten, wolverine, lynx, bighorn sheep, gray wolf, grizzly, mountain lion, elk, mountain goat, and mule deer. A biological evaluation needs to be prepared for all threatened, endangered, and sensitive species. Direct and indirect as well as cumulative effects must be addressed.

Regulations require that habitat be so managed as to maintain viable populations of existing vertebrate species and that such species be well distributed within the forest. To ensure that this is done, the analysis for the Trapper-Bunkhouse Project's proposed actions will need to provide site-specific information concerning existing habitats, population numbers, distributions, and trends.

The population, health and stability of the numerous species of plants and animals is of concern as well. We are concerned about the situation regarding biological corridors for vertebrate species - particularly the low density, far ranging carnivores. The analysis for the Trapper-Bunkhouse proposals must fully disclose the direct and indirect effects of past, present and reasonably foreseeable future roading and logging on biological diversity potentials within and adjacent to the analysis area.

The EIS analysis for the Trapper-Bunkhouse Project's proposed actions need to identify, document, map and otherwise fully disclose habitat for all sensitive, threatened, or endangered plants, and plants of special concern. A Biological Evaluation needs to be prepared for TE&S; plants found in the analysis area.

Continuing loss of old growth trees and habitat (due to the time frames required to reproduce those conditions) is essentially an irreversible and irretrievable commitment of the resources as well as being highly controversial. Old growth needs to be broken down by species and sizes and clearly delineated on maps so as to adequately disclose the existing situation and any proposed actions affecting the old growth resource. The analysis for the Trapper-Bunkhouse Project's proposed actions need to disclose the location, species of trees, condition of trees, size, past areas of harvest and fire history of the old growth habitat.

You will need to fully disclose and discuss the cumulative effects of past, present and reasonably foreseeable roading and logging on old growth areas and their associated habitats. There is a past history of the BNF's overcutting the ponderosa pine component which needs to be disclosed and addressed in the analysis.

Ranger Oliver has indicated he was considering developing only one "action" alternative for his Trapper-Bunkhouse Land Stewardship Project EIS. We maintain that NEPA requires a reasonable range of alternatives be developed and considered.

Attached with these scoping comments is a Community Protection and Local Economy Alternative that could be considered along with other reasonable "action" alternative that might be developed.

Please continue FOB on the mailing lists for the Trapper-Bunkhouse Land Stewardship Project's EIS, and please send us the NEPA DEIS analysis documents in a timely manner when they become available.


Jim Miller,


Friends of the Bitterroot

October 20, 2005