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

Colorado Wild Page 6
D. WOOD CAN BE PRODUCED IN OTHER AREAS. There is no need to enter the Rio de
los Pinos project area to produce wood. As discussed above, demand is currently very low, so
any sales might not sell, or if they did sell, the wood might not get to the mill before it
deteriorates to a point where it cannot be made into any salable wood product. Also, there are
three active or prepared sales that can provide a volume of 16 MMBF in the vicinity of the
proposed project area. DEIS at 3-87.
III. PROTECT SOILS. The project area receives a considerable amount of snowfall and a
moderate amount of rain in the summer. In many years, snow does not melt until well into July,
thus the area is frequently wet. Soil impacts from the use of heavy equipment during periods
when soils are wet can be severe, as natural healing of soil compaction and displacement would
take a very long time at this cold location, which has a short growing season.
A design criterion addresses this:
Operate heavy equipment for land treatments only when soils are dry, soil moisture
is below the plastic limit, or protected by at least 1 foot of packed snow or 2 inches
of frozen soil. Wet weather operations shall be monitored and if soils become
excessively wet (as defined in the Forest Plan as exceeding the plastic limit), then
operations will be suspended until such time as soils become operable again.
DEIS at 2-11.
However, it is clear that this criterion has not been followed in operations in the adjacent County
Line Sale. See exhibits 1 and 2, attached to these comments. These photos were taken October
16, 2008 in the County Line project area, after some snowfall had occurred, followed by warm
weather which melted much of the snow.
The R-2 Supplement to the Soil Management Handbook prohibits more than 15 percent of any
area to be “detrimentally compacted, displaced, puddled, severely burned, and/or eroded
condition”. FSM 2509.18, section 2.2 (3). 3
Detrimental compaction is defined as “[a] 15%
increase in bulk density from the average undisturbed density”. Id. at section 2.05 (10 a).
Ensuring compliance with soil standards and design criteria is likely to be difficult, given the late
snowmelt and frequent summer rains. Operating on snow is not likely to be practical for more
than a few weeks each year, as frequent, and often heavy, snowplowing would have to be done to
maintain roads for access. (See also discussion in section I above.) Machinery, especially that
used for cutting trees, is not easy to safely operate in cold temperatures.
Before approving any logging in the Rio de los Pinos project area, the Forest Service must prove
that soils will be protected and that standards and design criteria will be met. The FEIS must
discuss the possibility of soil damage occurring if operations are not suspended during wet
periods. The latter is likely to occur because: a) it has already occurred in adjacent area, and b)
3 This is also a Forest Plan standard. Plan at III-10.
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