January 17, 2005

Priest Lake Ranger District
32203 Highway 57
Priest River , ID 83856

Attention: Luke Hixson
Re: Outlet Fuels Reduction Project

We would like to thank you for the opportunity to submit comments as well as questions regarding the Outlet Fuels Reduction Project.  As members of the Kinnickinnick Chapter of the Idaho Native Plant Society we advocate for the protection and preservation of native plants and their habitats.  While we believe that fuel reduction projects are necessary and beneficial for both public safety as well as forest health, we urge that adequate measure be undertaken to ensure that loss or degradation of native plant habitat does not result from these actions, or is mitigated to the greatest extent possible.

The letter introducing this project states that it: “falls into at least one category of action” which may qualify it for a categorical exclusion unless biological assessments indicate a need for an EA or an EIS. What is the “category of action” which provides for considering a categorical exclusion designation for this project? We feel a full assessment may be beneficial to the development of this project.  We would also like an opportunity to review the biological assessment or other evaluations for federally listed species, and sensitive plants.

The project proposal indicates that: “this project has been identified through the Bonner County Fire Hazard Risk and Mitigation Plan” and that this plan is a collaborative effort of the Bonner County Emergency Management Group to identify and mitigate fire risks on federal, state and private lands.”  Which agencies, groups or individuals comprise the Bonner County Emergency Management Group?  Does this same group or plan require fuel reduction work on adjacent or nearby private land? The nearby outlet bay housing development contains a tight cluster of houses and other private structures as well as a dense stand of trees.  The successful reduction of risk from fire would likely depend on treating both the private as well as public lands in this area.

This project anticipates eighteen units of fuel reduction and harvest generally bordering Highway 57.  Where fuel reduction follows the highway we understand its purpose. We would like to point out that roads in general break habitat continuity, and that widening this road passage or right of way will increase  division of habitat which will degrade or destroy natural corridors for native plant reproduction. This is a growing concern locally and worldwide and should be addressed thoughtfully in this proposal.

This project will include “clearing along the right of way to include mowing and chipping.”  Recently disturbed and un-replanted soil is vulnerable to noxious weeds as well as erosion.  We would encourage an aggressive program to replant this road buffer with native vegetation so that noxious weeds are not allowed to get a foothold in this area.

Many low meadows and wetlands are located adjacent to or near the proposed harvest area, and sensitive plants are often found in these habitats.  Have meadows and meadow areas adjacent to proposed cuts been included in the survey for sensitive plants?  What steps are being taken to ensure there is no erosion, sediment or mechanical damage to meadows?  What consideration has been given to increasing the buffer zones next to these sensitive areas?

Many parts of Units 13 and 17 are not located alongside the highway or within 1.5 miles of private property.  These areas may not endanger evacuation by road, the stated goal. Both units join low, wet meadows which may be prime habitat for sensitive plants.  From the map it appears these areas are not necessarily a fire hazard and provide protection for both wildlife and native plants. Leaving some of these areas unharvested, increasing buffers or treating them lightly and with care may enhance the overall health of native species and natural systems.

Unit 1  appears quite steep and we understand the need for fire protection measures along steep areas where fire danger seems extreme.   At the south-central end of this unit the meadow to the west of the highway may provide adequate fire protection to the adjoining area so that the islands of trees located near the highway might be better considered for a natural corridor. We also wonder what steps or setbacks will be employed to prevent erosion into meadow adjacent the steeper terrain?

Declaring a Wildland Urban Interface adjacent to the road makes sense.  Yet some elements of these harvest units, especially in Units 13 and 17, are one-half mile from the road and are at least 1 1/2 miles from private land.   What are the regulation guidelines defining conditions for harvest under WUI fire protection decisions?  Does WUI treatment define distances or conditions that determine what is safe and appropriate treatment; where might we find a complete definition of these?

In the detailed project map there is a grid indicating Unit #, Acres and Proposed Treatment.  This grid does not indicate where the “prescribed burns,” mentioned in the project description, will take place. Burning returns nutrients to the soil ensuring its health and vitality in ways which removal of vegetation does not.  We would want to encourage prescribed burning wherever possible as a preferred treatment method.  

The Priest Lake area is botanically unique and important.  Plants are found in this district which appear nowhere else in Idaho .  The greatest threat to the native plants is loss of habitat; most of that loss in recent history results from human activity.  The low meadows in the Priest Lake area are botanically important.  They should be closely studied and well protected.  Noxious weeds are the most pernicious thief of native plant habitat and logging near a road corridor greatly accelerates introduction of these weeds.  We are aware you have a protocol for weed control, but we also know the weeds are winning the battle.  We feel your approach in this sensitive region requires thoughtful consideration and should only proceed with the utmost of care.  An Environmental Assessment may assist in determining the full impact of proposed actions, a first step in addressing the question of appropriate treatment methods and weed control protocols.  Whenever possible, activities which induce noxious weeds should be curtailed until we learn how to successfully combat them. We encourage experimentation to prevent weed spread and a major overhaul of the noxious weed protocol.  A well-planned project now, with appropriate protective measures, and innovative weed control, could be a model for implementation of future fuel reduction projects.

Thank you for allowing us to comment.  

Sincerely,

Molly O'Reilly  
President