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UPDATE: Allegheny NF Mortality II Project

  Distributed to TAP-RESOURCES, a free Internet Distribution List
  (subscription requests to listproc@tap.org) 
  (please distribute freely)
  August 21, 1996
  UPDATE - Public comment period extended for the Mortality II 
           timber sale project on the Allegheny National Forest
  	The closure of the comment period for the Mortality II
  draft Environmental Assessment (EA) has been extended to 
  Monday, September 2, 1996.  It had been scheduled to end on 
  August 19.  There is still time for you to write to the 
  project team leader, Carl Leland, and ANF Supervisor John 
  Palmer.  The Allegheny Defense Project was very fortunate to
  have successfully requested this extension.  Please help ADP 
  make the most of it by taking some time to write comments.  
  Below is a sample letter.  Following that is the original 
  TAP-Resources post of August 2, concerning the Mortality 
  II project.
  If you need more information, please contact the Allegheny 
  Defense Project:
  Jim Kleissler
  Susan Curry
  P.O. Box 245
  Clarion, PA 16214
  (814) 226-5224
  (814) 678-2404 fax
  Below is a sample letter that you can use verbatim or as a guide 
  for writing your own letter.  Whichever option you choose, DO IT 
  RIGHT AWAY.  The comment period closes on Monday, September 2.  
  Any comments the Forest Service receives that are postmarked after 
  Sept. 2 may be ignored completely.  You can also phone in your 
  comments.  If you cannot find the time to do any of these, please 
  at least send a short note saying that you "oppose the Mortality II 
  timber sale and demand further study of the sale in an 
  Environmental Impact Statement."
  Following the sample letter is a short e-mail post with background
  information and some other contact information.  If you have not 
  carefully read the original TAP-Resources post on the Mortality II 
  project, which was titled "Allegheny Nat'l. Forest Under Attack," 
  you should do so now.  The SAMPLE LETTER WILL BE MUCH EASIER TO 
  Send your letter to:
  USDA Forest Service
  Attn:  Carl Leland
  RD #1, Box 28A
  Ridgway, PA 15853
  814/776-6172 voice
  814/772-7387 fax
  If possible, send a cc: copy of your letter to:
  John Palmer
  Forest Supervisor
  P.O. Box 847
  Warren, PA 16365
  814/723-5150 voice
  814/726-1465 fax
  Your name
  Your address
  Carl Leland
  Mortality II Team Leader
  RD #1, Box 28A
  Ridgway, PA 15853
                                                    August ??, 1996
  Dear Sir:
  	I am writing to comment on the proposed timber sale known
  as "Mortality II."  Please consider my comments in your review of 
  the project draft Environmental Assessment (EA), respond to them 
  as required by law, and include these comments and your responses 
  in the public record.
  	I find the draft EA to be inadequate and the Mortality II 
  project unacceptable for the following reasons:
  1)  This sale is to yield over 30 million board feet (MMBF) of 
  timber, which is more than half the volume of timber cut on the 
  ANF in all of Fiscal Year 1995, which was approximately 55 MMBF.  
  It will directly impact over 5,000 acres of the ANF.  The 
  environmental impact of this sale will clearly be significant 
  and cannot be adequately addressed in an Environmental 
  Assessment.  The sheer size and potential impact of this project 
  demand that it be evaluated in an Environmental Impact Statement.  
  2)  Because of the size of this project and the amount of 
  important information left out of the EA (noted only as being 
  part of the project file), no member of the public can fully 
  understand and adequately comment on this project based on 
  the information contained in the draft EA.  That being the case, 
  the entire purpose of public comment under NEPA, to aid in sound 
  decision making by the agency, is subverted.
  3)  The "tiering" of the draft EA to the final Mortality I EA is
  illogical and unsound.  The stands to be cut in the Mortality II 
  project were not analyzed using on-the-ground field surveys until 
  after the analyses for the Mortality I final EA were completed.  
  Therefore, the Mortality I EA cannot be used to characterize or 
  analyze the conditions of the stands to be cut in the Mortality II 
  project.  This inappropriate tiering does not conform to the legal
  criteria for tiering in the Code of Federal Regulations at 40 CFR 
  Part 1508.28.  This legal definition of tiering explicitly requires 
  that the document to which another document is tiered be an EIS.
  4)  The EA shows that the ANF is deficient in old growth areas, yet
  previously protected old growth stands will be subject to thinning 
  and clearcutting.  While the successful implementation of the 
  landscape corridor approach to old growth management adopted in May 
  of 1995 might someday produce sufficient old growth to meet Forest 
  Plan guidlelines, much of the newly designated old growth areas are 
  not old growth stands at this time.  Until Forest Plan guidelines for 
  old growth are met for all Management Areas, logging existing old 
  growth should not even be considered. 
  5)  One thing that was made clear in the draft EA was the 
  failure of the Forest Service to respond to substantive and 
  relevant scoping comments submitted by James Bensman.  Mr. 
  Bensman raised numerous important ecological considerations.  As 
  such, the issues raised by Mr. Bensman should have been examined 
  and addressed within the context of this particular project.  The 
  evaluations of and responses to his comments submitted concerning 
  previous proposed actions cannot possibly take into consideration 
  the unique, site specific circumstances of the stands to be cut in 
  the Mortality II sale.  Responses to his comments made in the past 
  are neither relevant nor sufficient in resolving the issues he 
  raised.  In light of this, I find the contention in the EA that 
  there are "no unresolved issues" to be patently absurd.
  	In conclusion, the Mortality II project is an unacceptable 
  project which has yet to be adequately studied and evaluated.  The 
  Forest Service should opt for the no action alternative or, at an 
  absolute minimum, prepare an EIS for this project.  Thank you for 
  your time and attention in responding to my objections.
  your name
  cc:  John Palmer
  BACKGROUND INFO - originally posted to TAP-Resources on Aug. 2, 1996
  Distributed to TAP-RESOURCES, a free Internet Distribution List
  (subscription requests to listproc@tap.org) 
  (please distribute freely)
  August 2, 1996
  This post was prepared for TAP distribution by the 
  Environmental Resources Information Network on 
  behalf of Allegheny Defense Project (ADP).  Thanks 
  to Ned Daly and the folks at ADP for their assist-
  ance. -Arthur Clark, ERIN Project Coordinator
       The Allegheny National Forest is the only national forest in 
  Pennsylvania.  As such, it is of great concern to forest advocates of
  the Commonwealth.  Like other national forests, its management by the
  U.S. Forest Service is far from ecologically sound.  
       The Allegheny Defense Project (ADP) is a grassroots group of 
  forest defenders dedicated to fighting for the land and creatures of 
  the ANF.  ADP is a small, low-profile operation, so few people outside 
  of the area around the ANF have ever heard of it.  Until now, ADP has
  never sent out a call for outside assistance.  However, the situation 
  that ADP and the creatures of the ANF now face is very grave. We 
  urgently ask that everyone who can do so to help us study, challenge, 
  and defeat the monstrous timber sale proposal currently being planned 
  by the Forest Service for the ANF.  Below is a short description of 
  the sale, followed by what you can do to help defend the Alleghenies
  against this devastation.
  The "Forest Health" Scam Comes to Pennsylvania
       Under the guise of "treating" stands to counter the effects of
  "forest decline," the U.S. Forest Service is planning a massive 31 
  million board-feet (MMBF) timber sale project in Pennsylvania's 
  Allegheny National Forest.  The project is called "Mortality II."  
  It is the second phase of the ANF plan to supposedly improve 
  forest health by cutting both green and dying trees using 
  clearcutting, salvage thinning, and commercial thinning methods. 
  The first phase of this plan, the Mortality I project, is already 
  being implemented after approval in June 1995.  
       The Mortality II project calls for an initial 20.3 MMBF of 
  timber, cut from over 5,000 acres.  The cutting will occur in ten 
  delineated "Treatment Areas" throughout the Forest.  Additionally, 
  the project calls for over 10 MMBF of timber cutting on 2,000 
  acres, once regeneration is established in previously logged areas.
  Many of the Mortality II Treatment Areas are adjacent to areas to 
  be cut under the Mortality I project.  The close proximity of many 
  areas to be cut calls into question whether either the Mortality I 
  or Mortality II analysis can possibly evaluate what is essentially 
  one enormous project.  Last year's total annual cut on the ANF was 
  approximately 55 MMBF, less than twice the volume of the Mortality 
  II project alone.
       One might imagine that in planning such a massive project with
  such an obviously significant level of impact, that the Forest 
  Service might dispense with the formality of preparing an 
  Environmental Assessment (EA) to determine whether an Environmental 
  Impact Statement (EIS) or a Finding of No Significant Impact (FONSI) 
  is in order.  Not a chance.  In fact, the Mortality II EA issued by 
  the ANF was only 45 pages in length, excluding maps and appendices.  
       A preliminary examination of the EA by the ADP revealed 
  extremely serious problems with the information provided and the 
  project itself.  The following are but a small sampling of these:
     * clearcutting and salvage thinning of previously protected
       old growth stands
     * highly suspect "tiering" of the Mortality II EA to the 
       inadequate Mortality I project EA
     * project impacts on Pennsylvania-designated High Quality 
       (Tier 2) Cold Water Fishery trout streams, so designated 
       pursuant to the CWA
     * possible NEPA violations, including exclusion of scoping 
       comments submitted by ADP activist Jim Kleissler and failure 
       to respond to comments submitted by others
     * false and misleading descriptions and tables concerning 
       Present Conditions and Forest Plan-prescribed Desired Future 
       Conditions (DFCs) of the forest, used to justify the proposed 
       logging activities
       ADP urgently needs assistance in evaluating this project.  The
  COMMENT PERIOD FOR THE EA ENDS AUGUST 19.  Due to the terrible 
  inadequacy of the information provided to the public in the
  scoping letter and EA, ADP will be conducting a massive file review 
  of the Mortality I and Mortality II project files from August 12 
  through August 16.  Anyone who can travel to north-western 
  Pennsylvania to help is urged to come.  Please contact ADP as soon 
  as possible to make the necessary arrangements. (see "CONTACTS" 
  section below)
       All other people willing to help should also contact ADP 
  immediately.  We can use all the help we can get, in-person or on a
  consultation basis, with all of the following and more:
     * mailing or faxing letters about the sale:  write/fax
       and tell ANF Forest Supervisor John Palmer that an
       EIS is needed to properly study and document a 
       project of this size and potential impact; also 
       tell him there should be no logging of old growth
       areas, whether or not they are "officially"
       protected (see "CONTACTS" section below)
     * legal consultation on NEPA, FOIA, NFMA and ESA issues
     * guidance on interpretation of CIR (G R IR -> B G R) 
       1:12,000 aerial photos
     * fieldwork and consultation on locating listed or candidate
       species (both plants and animals, e.g. hellbender, n.
       goshawk, eastern small footed shrew, small-whorled 
       pogonia, etc.)
  To help:     
  Jim Kleissler
  Susan Curry
  P.O. Box 245
  Clarion, PA 16214
  (814) 226-5224
  (814) 678-2404 fax
  (scientific, legal and policy experts please contact ERIN at
   814-678-0007, 814-678-2404 fax or <aclark@essential.org> if
   you are inquiring during normal business hours Mon. - Fri.)
  To write letters to:
  John Palmer
  Forest Supervisor
  Allegheny National Forest
  P.O. Box 847
  Warren, PA 16365
  (814) 723-5150
  (814) 726-1465 fax
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