Final Environmental Impact Statement Rio de los Pinos Vegetation ...

Colorado Wild Page 2
R-2 Fen Policy, March 19, 2002. It is clear the damage to fens is essentially irreversible. See
USDA Forest Service, 1998 at 31.
The DEIS claims that there would be only minimal impacts to watersheds if Forest Plan
standards and guidelines and project design criteria are followed. DEIS at 3-23. One important
criterion is to keep activity 100 feet away from the WIZ. See DEIS at 2-11, 3-24. However, if
more than 50 percent of the 7 th level watershed is in the WIZ, it would be impossible to log more
than 50 percent of it as proposed and still stay 100 feet way from the WIZ.
In unit 4, there is riparian vegetation in “wet seepage” areas more than 100 feet from the nearest
stream. DEIS at 3-18. A such, these and other parts of the project area may be classifiable as
wetlands. We find no discussion of this in the DEIS. The Forest Service must ensure that
qualified experts carefully check to see if any parts of the project area are wetlands. Any such
areas must be avoided. The Clean Water Act’s allowance of wetland modification for normal
silvicultural activities without 404(b)(1) permits (33 U. S. C 1344(f)(1)(E)) does not apply if
“modifications of the hydrological regime are necessary to resume operations”. 33 U. S. C.
1344(f)(2) and 33 CFR 323.4(a)(1)(ii).
With death of overstory spruce, less soil moisture would be taken up by trees. Though existing
trees would grow faster and use more water, there still might be an overall increase in soil
moisture, meaning the area would be even more wet than it now is, making it even more difficult
to avoid wet areas during operations. This condition occurred on the Flattops after the spruce
beetle epidemic of the 1940s.
Another measure suggested to reduce impacts is to log over snow or frozen soils. DEIS at 3-31.
However, a design criterion prohibits operations from December 15 to April 1 to minimize
conflicts with recreation. Id. at 2-12. This would not leave much time each season for logging
over snow or frozen soils, as such logging could be done only with at least two inches of frozen
soil or one foot of packed snow. Id. at 2-11. In some winters, there would not be a foot of packed
snow before December 15. And in spring, heavy snow plowing would be required, and plowed
roads would be very wet and get damaged from vehicle use creating deep ruts. The DEIS states
that logging from April to June is unlikely due to wet soil conditions. DEIS at 3-37.
Under the Forest Service’s Watershed Conservation Practices Handbook (WCPH) actions are
limited in wet areas:
In the water influence zone next to perennial and intermittent streams, lakes, and
wetlands, allow only those actions that maintain or improve long-term stream health
and riparian ecosystem condition.
WCPH, FSH 2509.25, section 11.2.
It is hard to imagine how the proposed action could improve stream health, with operations in the
WIZ. Notably, design criterion 1a3 under this management measure prohibits the use of heavy
equipment in “streams, swales, and lakes”, except to cross streams at “designated points”. See
also WCPH design criterion 1a in section 12.4.
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