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James Thomas
District Ranger
Greenbriar District
Monongahela National Forest
PO Box 67
Bartow, West Virginia 24920
Route 1, Box 250
Staunton, Virginia 24401
April 11, 1994

Mr. Thomas:

The following are my comments on the Burner Mountain/Mountain Lick Environmental Assessment (EA).

In many respects this is a strange document. Of course, along the way some authority figure decided that all these trees must be cut, all the roads built as the powers that be would have us believe are dictated by the long outdated and destructive Forest Land and Resource Management Plan (FLRMP). However parts of the EA seem almost like a cry for help from a more rational element, quoting the National Forest Management Act, the Council of Environmental Quality and Even Reed Noss! It seems as if they're saying "stop me before I kill again." However I recommend they help themselves with a rebellion against this corrupt agency which approaches its problems much like the tobacco industry.

As it stands the EA is dominated by the same old false logic as ever, as on page 3 where it is stated that this young forest is "skewed toward older age classes," a statement that is refuted by their own data as presented on page 49. On page 4 cutting is justified by wildlife needs without stating that most wildlife will be harmed by cutting. There is also reference to "escape cover," a buzz word recently invented to justify cutting in remote Bear habitat. On page 52 we read the ambiguous statement "Bears are also highly sensitive to road density, but again, based on the information above, road density in any of the action alternatives is not expected to significantly affect bear populations." One has only to look at the maps to see that the entire project area is riddled with roads and the fact that some of these roads would be legally closed to vehicles would help little since all roads provide easy access at least to walkers and thus pose a constant threat to Bears.

The entire treatment in the EA of the edge effects and forest interior species is self-serving distortions. There is a valid and extensive effort to calculate the amount of edge which is certainly unprecedented for the Forest Service. However the statement on page 63 that "for the action alternatives, the ratio of interior to edge areas would drop only slightly," is highly misleading because the area is already so highly fragmented by roads and openings that it isn't easy to fragment it more even under the action proposals. It is stated that of the 14 species of neotropical migrant birds showing significant decline in West Virginia the majority of these species depend on young brushy/open habitat whereas the majority showing an increase are species that require mature forest land." If this is true, it bucks the national trend and should be encouraged and not undone by timber cutting. Certainly there is no shortage of brushy and open country even in West Virginia, which at one time was almost entirely forested and at that time must have had many more interior than open-loving species. It is this original forest that we should compare with today's depauperate and mismanaged national forests. Seen in this light the decline of open-loving species is desirable.

As usual there is no mention of the enormous negative effects of logging on the forest floor with its attendant long recovery times of herbaceous vegetation as documented by Duffy and Meier (1992) and the analogous effects on salamanders by Petranka et al (1993) and Raymond and Hardy (1991). By my observation many parts of this project are very rich in herbaceous species, some not common such as Panax trifolius as well as a great variety of Trilliums, Orchids, etc. The Forest Service has not figured out yet how to obscure these documentations of the destructive effect of logging on the forest floor and its species! In the EA there are repeated references to "Bear/Turkey association" without any mention -- except by accident-- of the other members of this association. Does it, for example, include reptiles such as the Forest Rattler (Crotalus horridus), salamanders, frogs, mosses, fungi and the many herbaceous and non commercial woody plants? A conflict arises when the Forest Service touts the advantage to Bear and Turkey of even age cuts and wildlife openings without considering the effects of these openings on forest interior species --indeed most species of the "Bear/Turkey association." In addition to suffering from the pervasive fragmentation of the area there is no consideration of the effect of encouraging enhanced Turkey populations around managed openings. These greater Turkey populations could well result in increased foraging for reptiles and amphibians such as rare salamanders and even ground nesting birds such as many species of warbler. This conclusion was supported by Dr. Thomas Pauley, an authority on the Cheat Mountain salamander in a phone conversation with me. The Forest Service is seeking to discredit this proposal which I made in several appeals but they will not succeed and it eventually will have to be considered.

A species which has a special role is the Canada Yew (Taxus canadensis) which I have suggested (Mueller, 1992) be added to the official sensitive species list for the Monongahela. It reflects years of mismanagement that has increased deer numbers beyond carrying capacity . On page A-4 of Appendix A, in response to this issue, it is stated that "Yew populations are not known to occur in the project area." Since the northern hardwoods of Mountain Lick in particular are Yew habitat this statement supports my contention, namely that the Yew has been extirpated. Where I have encountered this plant on the Monongahela it is usually confined to steep rocky slopes that deer find difficult to reach.

The state of proposed, endangered, threatened and sensitive species (PETS) species on the Monongahela is a disaster! While many species are listed in the Forest Plan "for consideration as Regional Forester's sensitive species" citizens come to a rude awakening that many if not most of these FLRMP listed species did not make it to the Regional Forester's list! This deception is carried further when an attempt -- such as mine -- is made to obtain the official Regional Foresters' sensitive species list but these attempts are rebuffed even under a Freedom of Information Act request. The treatment of PETS species in this EA is pathetic and the Monongahela tradition (see my appeals) of bogus lists is continued. Here the old strategy is invoked of listing PETS species as located just beyond the project area as in the case of the Candy Darter, Kanawah Minnow and Hellbender. Or again, when the presence of species within the area can't be denied, as in the cases of the Southern Rock Vole, Long-tailed Shrew, Southern Water Shrew, and Northern Flying Squirrel, either there is miraculously no effect from the proposed project or an actual benefit accrues as in the case of the Rock Vole, which is said to take kindly to clearcutting -- all without any evidence of a comprehensive study of the effect of destruction of the forest floor.

On page 69 we see an example of erroneous and self-serving logic with respect to the Northern Flying Squirrel. They would have us believe that this endangered species can be saved by protecting only "occupied habitat" when we all know that such habitat must shift just as patch dynamics shifts forest stands. This illustrates once again that minimal protection without regard to the disturbance regime is futile.

Among the many species missing from the PETS list are all raptors. On page A-2 of Appendix A reference is made to a pair of Goshawks in the area, stating that "proposed thinning would not affect this pair since it is not located in the vicinity of the nesting site." If Goshawks are present here the protection of this federally designated C2 species would seem to require keeping all land-disturbing activities -- indeed human presence -- away from the entire area. Goshawks are shy, like to hunt in mature forest free from human disturbance and require very large territories, territories as large as virtually the entire project area. This bird as well as the Coopers and Sharpshinned Hawks are listed in the Forest Plan as proposed sensitive species. the failure to express any concern for any of these birds, which are in decline and in the case of the Goshawk, at the southern extremity of its range, is a serious failing. Proper treatment would include inventories of stick nests, kill evidence, sightings and vocalizations.

It is also curious that the PETS list omits totally any rare bats, a number of which have their nurseries and foraging areas in mature forest. In addition there is not one plant listed. What of the Glade Spurge, for example? What of the many species of orchids recommended to be included as sensitive in the FLRMP? Surely some must be making themselves known in Milwaukee as well as Elkins. Also many species such as Goldenseal and Ginseng (Panax quinquifolius) come to mind.

As usual there is only limited mention of cumulative effects and none with regard to the biological systems. Also the range of alternatives is sick with nothing but even age and thinning (for future even age?) and no restoration alternative.

With respect to old growth. On page 64 we read that "Areas managed for old growth values should be distributed to minimize fragmentation of old growth into small isolated areas, Delfs, 1993)." Yet the proposal goes on to designate small fragments of "mature habitat" mostly in riparian areas, fragments too small and not representative enough to endure long enough to develop into true interior old growth if one believes Harris (1984) Martin (1992) and others.

Finally the presentation leaves much to be desired. True North is not accurately known on some maps and mature habitat not on some.

Sincerely,

RF Mueller, PhD

Virginians For Wilderness