Talking Points:

1. A forest-wide amendment is far reaching. It is essentially a revision of the current Forest Plan which requires an Environmental Impact Statement (EIS).
2. The specific changes to the EHE standards in the forest-wide amendment are not explicitly explained in the scoping letter making it difficult to provide meaningful public comment.
3. References to science used to justify the decision were not provided on the website until January 20, 2020, giving the public only 20 days to comment on the new information. BNF failed to notify the public of this additional information and the full text of references is not provided.
4. The justification for the amendment is that elk numbers have increased on the BNF even with site specific EHE amendments on more than a dozen timber sales over the past 15 years. But the information substantiating the claim is not available to the public. BNF must consider other reasons for increased harvest and elk numbers?
5. Other species rely on EHE standards in the BNF. According to the Gold Butterfly Biological Assessment (BA) for Grizzly Bear and Lynx pg. 11, “the Forest Plan manages wildlife security based on elk habitat effectiveness.” In the Grizzly and Lynx BAs for both Gold Butterfly and Darby Lumber Lands II, the specialist states, “The EHE standard results in areas of secure habitat for a range of species including grizzly bears”. (p. 10, Gold Butterfly BA; p. 9 DLL 2 BA). What will be the effects on other species that rely on the security of EHE standards? What has been the effect of over a dozen site specific amendments for other species like wolverine, fisher, lynx, grizzly and more? Please include baseline and current wildlife surveys.
6. BNF must consider the substantive requirements for species that are directly related to the EHE standards. EIS must provide a thorough analysis of how the amendment proposed has and will affect habitat conditions, subject to the requirements of § 219.10, for “wildlife, fish, and plants commonly enjoyed and used by the public; for hunting, fishing, trapping, gathering, observing, subsistence, and other activities” 219.10(5).
7. The EHE amendment is the only limitation on road building in the current Forest Plan. The likely result of this amendment is a huge increase in road building on the forest with all the resultant damage and degradation. How will an increase in road densities affect BNF road maintenance backlog? Considering the backlog of road maintenance throughout Forest Service lands of 54 billion dollars, how will these roads be properly maintained without funding?
8. EHE is measured by 3^rdorder drainage. Changing the standard and allowing roads will adversely affect 3^rd order drainage water quality. How will the BNF mitigate the effect of higher road densities and protect the area’s valuable fisheries, water quality, water quantity, and native trout? One glaring example of lack of road maintenance and its effects on fisheries is the debris flow in the Willow Creek drainage of just a few years ago. The sediment landed in Willow Creek, home to native bull trout.
9. Increased road density and loss of cover for elk causes displacement of elk to private land creating a loss of hunter opportunity. A full analysis of hunter opportunity and its relation to road building and private lands should be provided as part of the analysis.