Kinnikinnick Chapter Of The Idaho Native Plant Society 

March 25th, 2005

 Mr. A. J. Helgenberg
South Grouse Project Leader
Sandpoint Ranger District
1500 Hwy 2, Suite 110
Sandpoint, ID 83864
Via Email

Subject: South Grouse Hazardous Fuels Reduction Project

 We would like to thank you for the opportunity to submit comments and questions regarding the South Grouse Hazardous Fuels Reduction Project.  As members of the Kinnikinnick 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 may be necessary and beneficial for both public safety and forest health, we urge that adequate measures be undertaken to ensure that loss or degradation of native plant habitat does not result from these actions, or are mitigated to the greatest possible extent.

 In their meeting of 11/08/2004 for property owners the Forest Service stated that they are concerned with effects to sensitive plants - has the Forest Service run any transects in the habitats that are to be impacted by this project?  What are the results of any botanical surveys or assessments to the area for sensitive or “watch list” plant species?

 Vegetation treatments add up to 806-acres.  The thinned trees look like they will be sent to a sawmill because the proposed new road extends beyond harvest areas into “commercial thin” areas.  Will any juvenile trees be left on site to be managed for soil enhancing, natural decomposition?

 We concur thinning does open up the forest and the regeneration harvests we presume are for dead, sick (Scolytus – Fir Engraver beetle attacked trees), and unhealthy growth characteristic trees; usually Grand and Douglas Firs. The FS is proposing to leave still-growing trees in an irregular spacing for light and the newly planted seral seedlings (western white pine, ponderosa pine, and western larch). We presume the lower branches (up to eight feet) on still growing trees are pruned to prevent fire from laddering up into the crowns (where it would be a stand replacement fire).  

 Perhaps the FS engineers looked at connecting the new permanent road to the north into the restricted road?  It looks from the FS’ topographical map it would allow the road to ride the same contour?  The proposed permanent road segment heading south-east would increase impact coming across the contours to connect to a restricted use road (we presume this is private and not a county road).  “Across-contour” is more erosive to soils and creates additional instability for a longer period and increases the probability for noxious weed seed on the equipment tires and treads to invade disturbed areas.  We are concerned that it appears 2.5 miles of new roads will remain after the half-mile of temporary roads are decommissioned.  Such new roads only foster the introduction of noxious weeds and illegal OHV use.

 The proposal indicates 560-acres for prescribed burns.  We would presume this is for all trees and shrubs removed and piled for burning purposes.  The excavator to pile woody debris on 211-acres for fall fires could be replaced by one of the machines with a whirling head that shatters tree trunk remains, stumps, and other large wood pieces into “chunks” at 3600 RPM for fungus decay and nutrient return to the soil. 

 We support the role of prescribed burns and managing the forest to allow naturally occurring fires in this area to burn. We believe that fuels reduction treatments should also be managed to encourage the return to historical conditions and site-appropriate diversity of forest types and plant habitat diversity.

The greatest threat to the native plants is loss of habitat; most of that loss in recent history results from human activity.  The many diverse areas found in Bonner County are all botanically important.  They should be closely studied and well protected.  Noxious weeds are the most pernicious thieves of native plant habitat and logging near road corridors 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. 

We recommend that the size of the project area, especially when considered cumulatively with the proposed treatment to the East Side of Grouse Mountain as well as other nearby areas in Bonner county warrants a complete EIS be developed, a first step in addressing the question of appropriate treatment methods and appropriate weed control protocols. 

Whenever possible, activities that 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.

We would be interested in a site visit(s) (both “before” and “after”) to the proposed treatment areas of this project.  We are also interested in receiving and written updates, decisions or other materials as well as notice of new information on your website.

Thank you for allowing us to comment.

Sincerely,

Molly O'Reilly

President