Comments to Interior Columbia Basin Ecosystem Management Project on the Eastside Draft Environmental Impact Statement of the Interior Columbia Basin Eastside Management Plan

Oregon Chapter AFS Comments on the “Eastside Draft Environmental Impact Statement” and the “Assessment of Ecosystem Components” (Quigley et al. 1997)

The science assessment for aquatic ecosystems does an excellent job of documenting the distribution and status of many fish species, their habitats, and the mechanisms associated with their declines. One area that has not been well addressed is an assessment of past and current aquatic habitat management activities, particularly those undertaken by the U.S. Forest Service (USFS) and Bureau of Land Management (BLM). Recent reviews of aquatic habitat restoration (Roper et al. 1997, Kauffman et al. 1997) and their implications relative to ICBEMP should be considered. Most of the restoration emphasized in the EDEIS appears to be on upland vegetation and reducing fire, insect, and disease risks, which may provide some long-term benefits to aquatic resources but may have some risks as well.

I. Review of Alternatives Presented

Most of our discussion of alternatives focuses on alternatives 4, 6, and 7. As discussed in the EDEIS (ch. 4, p. 154), alternative 1 is not expected to recover aquatic and riparian habitats and alternative 5 would lead to broad-scale fragmentation of those habitats. Population trends under alternative 2 would be “uncertain because many important populations are not covered.” Alternative 3 provides only “slightly greater benefits” than alternative 2. Thus, alternatives 1, 2, 3, and 5 do not adequately respond to the identified purposes and needs for action and management priorities with respect to aquatic ecosystems. Specifically these alternatives are inadequate for the restoration and maintenance of ecosystem health and for the ecological integrity, restoration, and maintenance of habitats for plant and animal species.

A fundamental strategy proposed in the aquatic science assessment for this project and other aquatic and riparian assessments (e.g., Henjum et al. 1994, Table 4.52) consists of 1) protection of existing strong or otherwise important populations (e.g., rare, fringe) and the habitats that support them, and 2) restoration of degraded habitats, migratory corridors, and depressed populations to expand the distribution of species and improve their status to help insure their long-term persistence. In other words, “protect the best and restore the rest”. Unfortunately, none of the proposed alternatives represents an adequate blend of the two. The preferred alternative (4) emphasizes restoration, but does so with increased risk to existing strongholds. Alternative 6 reduces those risks somewhat, but is still weak with respect to conservation of strongholds. Alternative 7, on the other hand, emphasizes conservation, but with apparently little restoration. The strategy that would best meet the needs of aquatic resources for both conservation and restoration would combine the restoration and adaptive management elements of alternatives 6 and 4 with alternative 7’s emphasis on protection of important areas of species distribution (i.e., strongholds) and existing habitat of high integrity.

II. Issue-Specific Comments

Adaptive Management

The aquatic assessment repeatedly stresses the need to reduce the risk to aquatic systems and uncertainty associated with restoration and the need to increase our knowledge of restoration in the process (e.g., III:1373-4). Adaptive management is a vehicle for accomplishing that, and alternative 6 is designed to take that approach. Of the two alternatives that emphasize restoration (4 and 6), we believe alternative 6 is more defensible for aquatic and other resources as well. The theme of alternative 6 (III:45-46) acknowledges the limitations of our ecosystem knowledge in some areas and the inherent uncertainty with respect to restoration activities associated with that. In this situation, it logically recommends an adaptive management approach so that we can learn from it and not create more problems at the time and in similar situations in the future. The rationale given for selecting alternative 4 as the preferred (Preferred Alternative, p. 1) includes: 1) “…it achieves, at a more accelerated rate than the other alternatives, fulfillment of the purpose and need…”, 2) “Emphasizing adaptive management over the long term”, and 3) “Helping restore and maintain habitats of plant and animal species…”. Alternative 4 does pursue restoration at a faster rate than alternative 6, but apparently only where restoration activities are not well studied or understood: “Restoration activities that are well studied and well understood are pursued as actively under alternative 6 as under Alternative 4” (EDEIS, Ch. 3, p. 46). We question why it is considered prudent to rapidly forge ahead under these circumstances, which are riskier at best, and the results may be counterproductive to fulfilling the purpose and need. How can alternative 4 be considered to emphasize adaptive management more than alternative 6, which was designed to embody it? Given the greater risk and uncertainty of alternative 4, how can it provide more help restoring and maintaining plant and animal habitats than alternative 6?

Grazing Effects

In the Evaluation of Alternatives, it is stated that grazing by livestock mimics grazing by native ungulates. This assumption is a flawed: livestock grazing and grazing by native ungulates can be substantially different in pattern, intensity, and effects.

Ecosystem Analysis

Alternatives 3-7 rely heavily on ecosystem analyses, and the Aquatic Evaluation of the EDEIS Alternatives refers to requirements for ecosystem analysis in its relative ratings of the alternatives. While ecosystem analyses at various scales from the interior Columbia Basin (ICB) to the watershed/subwatershed level may certainly contribute to better management, they do not insure that it will occur. As the rationale for EM-01 states, “Ecosystem analysis is not a decision-making process”. For example, we have pointed out some of the inconsistencies (e.g., roadless areas) between the ICB assessment and the proposed management alternatives. At a more local level, we are aware of substantially different conclusions from watershed analyses for federal lands and the management decisions following from them when dealing with similar situations. Consequently, we do not support an over-dependence on ecosystem analysis, which is a process, as a substitute for needed standards, performance measures (found lacking in the EDEIS–see Evaluation of the EIS Alternatives, I, 449-450), and critical review to insure protection and restoration of aquatic habitat as a product.

Watershed analysis seems to be emphasized in Forest Ecosystem Management Assessment Team (FEMAT) key watersheds, Category 1 watersheds, and strongholds, yet these are the areas that are probably already in good shape by definition. Watershed analysis would be valuable prior to activities in watersheds in poorer condition also, if restoration is the goal.


There should be regional and state oversight of compliance and effectiveness for progress toward DFC in the alternatives. This monitoring should not be left exclusively to the USFS or BLM local unit.

Non-Federal Lands

There needs to be a “bridge” between this effort (ICBEMP) and restoration of non-federal lands for true ecosystem restoration to occur. Ecosystems and needs for conservation and restoration of aquatic species do not follow land ownership boundaries.

PFC as a Standard or Goal

PFC is a qualitative assessment of channel health or trend, but does little to describe fish habitat values. It is a minimum condition that indicates trend, but does not indicate rate of recovery, which may be of critical importance to declining fish populations.

Population Status

The EDEIS seems to suggest (via the CFRs, Appendix 4-2, p.356) management for minimum viable populations instead of populations with harvestable surplus or optimum populations. Many physical attributes of the ecosystem have goals in terms of HRV, why not also for fish populations? Management for minimum viable populations does not provide for harvest, genetic diversity, increased distribution, restoration of declining populations, etc., nor does it incorporate any buffer or margin of error for unforeseen adverse circumstances. While management for minimum viable population may meet certain statutory responsibilities, any approach so limited that it fails to manage for a reasonable level of use also fails to meet federal-tribal trust responsibilities.


Alternative 7 emphasizes reducing risk to ecological integrity and population viability through establishing a system of reserves on federal lands. The need for a reserve system to maintain the best remaining examples of healthy populations and habitat of fishes and other species is well established in the scientific literature (e.g., Assessment, III:1356-1357; Rahr et al. 1998). Although alternative 7 is designed to accomplish this objective, it appears to be set up for failure because it fails to meet the needs for restoration both within the reserves and outside of them, since it “pursues low levels of watershed restoration” (EDEIS, Ch. 3, p. 50). Consequently, it appears it was rated somewhat lower in the aquatic evaluation of the alternatives since it was considered to have low-to-moderate benefits from riparian and watershed restoration (Evaluation of the Alternatives, I, 451). Thus, by design, it fails to adequately restore widespread degraded habitats and recover associated depressed populations. This lack of emphasis on restoration needs also appears to conflict with the AQ-05 objective: Restore watersheds and aquatic and riparian areas where natural watershed processes, functions, and conditions have been degraded.

Roads and Roadless Areas

Both the Aquatic Assessment and the EDEIS acknowledge the relationship between road densities and strong fish populations (i.e., the number of strong populations declines with increasing road densities, and 58% of the strong salmonid populations occur in roadless areas). However, the EDEIS is notably lacking in direction to protect roadless areas and areas with low road density from the direct and indirect adverse effects associated with increased roading. The effects will not be diminished by simply reducing road densities overall (i.e., reducing densities in highly roaded areas while increasing roads in areas with no or few roads). Given the importance of these areas for maintaining strong populations and as sources for rebuilding adjacent depressed populations, it is difficult to see how it can be concluded that the preferred alternative will result in maintaining viable fish populations or the recovery of the many species in decline.

It is also not clear in the standards what constitutes a “road” (only open roads [see BLM definition in Glossary, p. 19], closed roads, and/or temporary roads?). It could be possible to meet standards for increasing and decreasing road densities by just closing roads and not counting closed or temporary roads that still have impacts on aquatic habitat.

Although we agree that past and present management of roadless areas, particularly fire exclusion, has increased their level of risk and somewhat reduced their integrity, we believe that level of risk is more hypothetical than the known risks from roading and related development. What cannot be argued is that roadless areas and areas with low road densities continue to harbor most of our remaining healthy fish populations and represent much of the habitat with the highest ecological integrity.

Riparian Conservation Areas

In previous correspondence on the FEMAT report used in the development of the Northwest Forest Plan, ORAFS commented that establishing different sizes and standards for fish-bearing vs. non-fish-bearing perennial streams was not scientifically sound and that riparian areas along all perennial streams should be delineated similarly in terms of ecological processes and functions. We also recommended that stream gradient be factored into those dimensions. We are pleased to see that these considerations were included in the EDEIS and strongly supported with their inclusion in the Final EIS.


Many contradictory goals and directions exist (e.g., fire fuels vs. down wood for soil nutrients, stand type vs. big game habitat, road reduction for watershed restoration vs. recreational opportunity, risk of fire vs. risk of harvest/treatment on aquatic resources). It is not clear who will decide which way to go when tradeoffs are necessary.

III. Funding

The analyses of effects of alternatives assume full funding; partial funding will certainly affect predicted rates and outcomes. What guarantee of funding will there be for any alternative chosen? How effective will any alternative be if it is only partially or minimally funded? How can species viability be definitively evaluated given the uncertainties of funding and, therefore, uncertain levels of implementation and corresponding effects?

We feel that much of the success of the ICBEMP will depend on the extensive collaboration of the cooperating agencies — National Marine Fisheries Service, U.S. Fish and Wildlife Service, and the Environmental Protection Agency. The funding needs of these agencies must be fully met if they are to be effective collaborators in implementing the ICBEMP.

IV. Comments with References to Specific Sections or Pages

Document: EDEIS

Volume 1

AQ-S50, S51, & O12: Should not redds for all fish species be protected from livestock grazing impacts, rather than just listed species?

AQ-S15 & S16: These grazing standards should apply to any alternative chosen, not just Alternative 7.

AQ-S18-23: For alternatives 3-6, the standards for mineral management are expressed in rather lenient terms of “minimizing” impacts to aquatic resources “where practicable.” Standards for alternative 7 are considerably stricter and provide greater aquatic resource protection. We assume standards for the preferred alternative reflect the realities of the 1872 mining law. While we acknowledge the limitations on mining regulation associated with current mining law, the EDEIS is remiss in not explicitly displaying the aquatic effects of mining, which could be substantial even with implementation of the proposed standards.

AQ-S38, S39, S40, & S41: These requirements should be automatic for any USFS or BLM line officer. Instream flow requirements, State water rights, water intakes, and water conservation measures should be a part of any special use permit for water conveyance across federal land. Why do these only show up under Alternative 7?

AQ-S45: Same comment as above for transport of toxic chemicals across federal lands.

RM-S3: While conducting systematic Road Condition and Risk Assessment, high-risk roads and problem areas (drainage, fish passage, failure prone, etc.) should be identified and these should be targeted for restoration.

RM-S7: For true ecosystem restoration, design new and improve existing culverts to handle a 100-yr. flood and to facilitate fish passage, address life cycle needs for aquatic organisms, and allow for watershed function.

Chapter 4

Page 77: The statement “in alternatives 3-7, more emphasis on systematic grazing during dormant season, with monitoring of grazing more closely during the growing season” is shaky due to funding and commitment uncertainties.

Page 95–Why did the Science Integration Team not evaluate livestock grazing in forested ecosystems? Much of the grazing on national forest lands takes place in the forested environment, especially in riparian areas. Grazing allotments include forested ecosystems.

Page 133 (Summary sidebar)— The assertion is made that alternatives 3-7 will improve lakes, streams, rivers, riparian areas, and wetlands. But it is stated that alternative 5 will lead to a decline in most native fishes’ distribution and status. These statements seem contradictory.

Page 144 (Table 4-44)–Activities to reduce competition and introgression should be considered as “Ecosystem Management” and be included as part of this effort (ICBEMP/EDEIS).

Volume 2

Page 111–A major issue is identified: “In what condition should ecosystem be maintained?” Ecosystems are dynamic, not maintained in any one condition. Desired future conditions must be in terms of ranges, not one “snapshot” condition.

Page 235—A non-federal agency scientist should be appointed to the ICBEMP monitoring committee.

Page 332–Managers are encouraged to establish site-specific RMO’s, but a disincentive exists in the requirement for Watershed Analysis because of the time, effort, and money required.

Document: Evaluation of Alternatives by the Science Integration Team (Quigley et al. 1997)

Page 88 (Map)–Colors in legend are mixed-up.

Page 307 (Table 2-B.4)–For Rx-A2, under alternative 4 there is low road reduction activity projected for much of NE Region of Oregon, even though high & extremely high road densities are prevalent in the Region. In this factor, alternative 4 does not seem to address ecosystem needs.

Page 448–We agree with the SIT that all of the alternatives lack specific performance measures, and therefore will be difficult to evaluate or to implement adaptive management.

Page 455–Why no analysis of westslope cutthroat or redband trout for John Day Basin, or redband for Imnaha Basin?

Page 462–Why do the modeled effects for road densities show reductions in density, but do nothing to change the status of species from “depressed” to “strong”?

Page 492– What does the statement “…all subwatersheds that sustain wild steelhead should be considered critical habitats…” mean for management? What special protection or restoration takes place if a subwatershed is designated as critical habitat? This is not clear from the text on this page.

Page 782–“Changes in road management…do not provide for increased opportunity for hiking, hunting, fishing…dependent on a road-like trail surface.” Much of the national forest lands are heavily roaded; projected road density decreases will not severely limit road-dependent activities, just modify where such activity takes place.

Pages 851-3 (Maps)—Alternative 4 for Northeastern Oregon shows mostly “stable” (0 score), while alternative 6 shows mostly “slight improvement” (1 score). This is not a very encouraging projected long-term trend for ecosystem integrity from the more favorable alternatives.

V. References

Henjum, M.G., J.R. Karr, D.L. Bottom, and others. 1994. Interim protection for late-successional forests, fisheries, and watersheds. National forests east of the Cascade crest, Oregon and Washington, eastside forests scientific society panel. The Wildlife Society, Bethesda, MD.

Kauffman, J.B., R.L. Beschta, N. Otting, and D. Lytjen. 1997. An ecological perspective of riparian and stream restoration in the western United States. Fisheries 22(5):12-24.

Quigley, T.M., K. Lee, and S.J. Arbelbide, technical editors. 1997. Evaluation of EIS alternatives by the Science Integration Team. Gen, Tech. Rpt. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station.

Rahr G.R., J.A. Lichatowich, R. Hubley, S.M. Whidden. 1998. Sanctuaries for native salmon: a conservation strategy for the twenty-first century. Fisheries 23(4):6-7,36.

Roper, B.B., J.J. Dose, and J.E. Willliams. 1997. Stream restoration: is fisheries biology enough? Fisheries 22(5):6-11.

USDA Forest Service and USDI Bureau of Land Management, lead agencies. 1997. Eastside Draft Environmental Impact Statement, vol. 1 and 2. Interior Columbia Basin Ecosystem Management Project, Walla Walla, WA. (EDEIS)