SERAL 2.0 DEIR Comments
April 1, 2024
Ebbetts Pass Forest Watch
PO Box 501
San Andreas, CA 95249
www.ebbetts passforestwatch.org
Non-Profit ID# 680466959
Stanislaus National Forest
19777 Greenley Road
Sonora, CA 95370
RE: SERAL 2.0 DEIS
Stanislaus National Forest staff,
The following comments are being submitted in response to the SERAL 2.0 DEIS on behalf of Ebbetts Pass Forest Watch (EPFW), a 501(c)3 based in Calaveras County. The mission of Ebbetts Pass Forest Watch is to protect, promote, and restore healthy forests and watersheds to maintain the quality of life in the Sierra Nevada. Ebbetts Pass Forest Watch supports responsible forest management and logging methods. EPFW is grateful for the Stanislaus National Forest’s efforts to return fire to the landscape and restore wildfire resiliency to our forests. While we do understand that the more controversial aspects of the project proposal will be in a subsequent decision, we are still using this opportunity to provide feedback.
Herbicide Use
Ebbetts Pass Forest Watch is opposed to herbicide use in the SERAL 2.0 project. Herbicide use does not enhance biodiversity, nor does it restore the forest ecosystem and its natural processes. There are many other tools in the USFS toolbox that more closely mimic natural processes with fewer detrimental impacts to native flora and fauna. The cumulative impact of the total herbicide load in the watersheds within the SERAL 2.0 footprint is understated in the DEIS, and there are many inconsistencies between the various documents about the number of acres treated and for what purpose, as well as inconsistency when describing exceedances of the hazard quotients for the five proposed herbicides and their potential to adversely affect aquatic organisms.
Fuel Break creation and maintenance
EPFW appreciates that in response to scoping comments the STF chose to eliminate the use of herbicides for fuel breaks in the Herring Creek loop. We are still opposed to the use of herbicides for fuel break creation and maintenance in other areas of the forest. It is especially concerning to see the many miles of roadside spraying planned that overlaps with popular dispersed recreation areas along the North Fork Tuolumne River for example. Other methods for fuel breaks such as mastication and prescribed burning actually remove the fuel from the forest, whereas herbicides just knock the vegetation down and keep it from continuing to grow that season. Leaving areas of exposed soil along roadways maintains the degraded habitats where invasive species thrive.
Treating Invasive plant infestations
EPFW’s major concern related to using herbicides to treat invasive plants is, once again, related to areas along the Herring Creek loop. Both Upper Three Meadow and Groundhog meadow have areas marked on the map for herbicide use to treat invasive plants. It is unclear how these riparian habitats that provide critical habitats for listed amphibians can even be candidates for herbicide use. What invasive species exist in these meadows and why are herbicides necessary to remove them? How would BMP’s even allow for herbicide use in these high elevation meadows? EPFW opposes the use of herbicides on the Herring Creek loop.
Cumulative Impacts
EPFW continues to assert that cumulative impact assessments of herbicides need to consider the quantity and frequency of herbicide spraying that occurs on privately managed lands in the same watersheds SERAL 2.0 intends to treat. An assessment that only looks at the impacts of the herbicide use proposed by the SERAL 2.0 project ignores the existing herbicide load in the watershed, in particular from SPI lands. This is especially concerning given that the DEIS found all 5 proposed herbicides exceeded the Hazard Quotient(HQ), to varying degrees, for water quality and aquatic species. It is also concerning that the DEIS does not expect significant impacts, but the Aquatic Biological Evaluation repeatedly states that there may be and/or are likely to be negative impacts to aquatic species, including federally listed amphibians.
Hazard Quotients
When analyzing the hazard quotients for the 5 herbicides and the three categories, there were multiple combinations that lead to HQ’s being exceeded, at times by over 4,000. The explanation as to why these exceedances aren’t likely to occur is unclear. “The range of HQs reflects the range of conditions used in the modeling to estimate runoff and glyphosate concentrations in surface water under the most extreme scenarios which are unlikely” (DEIS p 109). There is no evidence to show that the modeling scenarios which resulted in the HQ’s being exceeded were the most extreme scenarios. This statement seems to assert without support that having a wide range of HQ values is a result of the wide range of modeling.
Consistency across documents
The Aquatics Biological Evaluation document contradicts itself within the same page when describing the Determination of Effect for both Yosemite Toad and Sierra Nevada Yellow-legged Frog. The paragraph under “Determination of Effect” describes the “potentially long-term beneficial effects” but concludes with a bolded sentence stating “The proposed action is therefore likely to adversely affect the Yosemite toad and designated critical habitat.”
Please clarify the determination of effect for the listed amphibians in the project area.
Table 8 in the Aquatics BE shows 318 acres of herbicide treatments for fuel break maintenance in habitat for YOTO with unknown occupancy.
The DEIS states on page 27 that the project has reduced the acreage of herbicide treatments by “eliminating the use of herbicides in fuelbreaks in the Herring Creek loop…”
Will there be herbicides used in fuel breaks on the Herring Creek loop or not?
Inventoried Roadless Areas
Fuel reduction using heavy equipment in Inventoried Roadless Areas threatens the areas’ eligibility for Wilderness designation. IRA’s tend to be far from resources that would be threatened by a wildfire. EPFW supports the intention of Inventoried Roadless Areas and opposes the need to perform fuel treatments other than prescribed burning, and the preparation associated with burning, in these areas.
Trees Over 30” DBH
EPFW opposes the cutting of trees over 30” DBH. All of the references supporting the need to cut trees over 30” DBH emphasize that there are specific and limited circumstances where cutting trees over 30” DBH may be beneficial. There is not conclusive, peer reviewed evidence to support the need to cut trees over 30” DBH.
Thank you for working to enhance forest resiliency and restore natural processes to the forest. We appreciate you considering our comments.
Megan Fiske, Wildlife Biologist, on behalf of Ebbetts Pass Forest Watch
admin2024@ebbettspassforestwatch.org
Ebbettspassforestwatch.org
