We thank everyone who commented on this project. It has been a long involved process that has brought many individuals, groups and agencies together of widely differing opinions and values. In numerous responses we have indicated sections in the Environmental Assessment (EA) where there are already existing discussions that respond to the comment. Rather than repeat the text, we have just indicated where the commenter could read the response in a document they already have. For other responses, the commenter did not supply adequate information for us to respond in detail. We have done our best to respond to those comments. Again we want to thank you for your comments throughout this adaptive and lengthy process. Without them we could not have ended up with such a well-crafted set of potential treatments.

36 CFR Part 215.6 Response to comments received on proposed actions.

(a) Comment Period. The Responsible official shall accept comments on a proposed action subject to 215.3 for 30 days following the date of publication of the notice for public comment. Both oral and written comments shall be accepted. The 30-day period for comment begins on the first day after publication of notice. Saturdays, Sundays, and Federal holidays are included in computing all time periods in this section; however, when the comment period ends on a Saturday, Sunday, or Federal holiday the comment period shall be extended to the close of business of the next Federal working day.

The Comment Period for the Fort Valley Ecosystem Restoration Project began with publication on the notice in the Arizona Daily Sun on July 19, 2000. The Public comment period ended on August 18, 2000.

(b) Submission. Persons expressing an interest or submitting comments to the Responsible Official in response to a notice published or provided pursuant to 215.5 shall provide the following information which become a matter of public record:

(1) Name, address, an (if possible) telephone number;
(2) Title of the document(s) on which comment is being submitted; and
(3) Specific facts or comments along with supporting reasons that the person believes the Responsible Official should consider in reaching a decision.

One comment received has not provided an address (Charles Frickel, Durango is all that is provided, however the document was faxed from SWFA and a copy of this document will be sent to SWFA).

(c) Timeliness. It is the responsibility of persons providing comments to submit them by the close of the comment period.

A single comment from Lea Parker emailed on 8/21/2000 missed the deadline for comments.

(1) When comments are received, the Responsible Official shall clearly identify the date of receipt.
(2) The Responsible Official must consider all written comments post marked or facsimile imprinted by the close of business on the 30th day following publication of the notice and all oral comments received by the close of business on the 30th day following publication of the notice.

(d) The Responsible Official shall address comments received from the public during the comment period in an appendix to the environmental assessment.

(e) Notes of oral comments received in response to a notice for public comment pursuant to 215.5 shall be placed in the files and addressed pursuant to paragraph (d) of this section.

This appendix addresses all comments received within the 30-day comment period provided for the public. No oral comments were received. The following table lists the comments received. Click a Project Record number to veiw responses:

In total 31 groups or persons commented on the Environmental Assessment for the Fort Valley Ecosystem Restoration Project.

The following table and narrative summarizes information from the demonstration plots at Fort Valley that can be used to predict tree numbers, diameters and basal areas for areas within the Fort Valley Project. It is provided to further the understanding of thinning effects which several individuals commenting on the EA, requested additional clarification.

A summary of tree numbers, diameters, and basal areas for the nine research and demo units (300 acres) are summarized in the following table. These units are representative of the conditions at Fort Valley, and can be used to predict the outcomes for Fort Valley. The "2/4" prescription is the dominant presettlement thinning density selected in Alternative B. A "1.5/3" thinning density will occur in areas of 5 yellow pine or more (compare to unit #10). The data is from NAU's grid of research plots at the demo units.

Units 1, 2, and 4 are in a "blackjack" setting, which has few if any yellow pines remaining, has been precommercially (0-6 inches dbh) and commercially thinned (6+) several times over the past 30 years.

Units 5, 6, and 7 are in a relatively unthinned area which has had most of the yellow pines removed in the last 50 years. These stands contained the classic "doghair" thickets. They are in the Fort Valley Experimental Forest.

Units 10, 11, and 12 have large numbers of remaining yellow pines. Little if any thinning of small trees has occurred in the past. These stands contained the classic "doghair" thickets. They are in the Fort Valley Experimental Forest.

95% of the trees removed were 12 inches diameter or less. 2.6 trees per acre over 16 inches diameter were cut (Fort Valley has a 16 inch cap).

Comments and Responses for 342a, b, c, d, e, f, g, h, j, q, and bb
A total of ten groups and or individuals as stated in Project Record Documents (PRD#342) 342a, b, c, d, e, f, g, h, j, q and bb supported the project and selection of Alternative B.

Comment: PRD #342b asked the question "why don't you get on with the project"?

Response: The project must first address public comments and then we'll have a 45-day appeal period after a decision is signed. Past appeals and a lawsuit have prevented us from taking action thus far.

Comment: PRD #342f asked if we had to burn and could we look at chipping?

Response: Burning is an important aspect in the recovery of the ecosystem. Chipping is very costly and chips laid on the ground would lessen recovery of the understory vegetation.

Comments and Responses to PRD#342bb

Comment: The letter requested that revised thinning prescriptions that might be considered be included in Appendix (8.0).

Response: All revised thinning prescriptions are attached to this document.

Comment: Table of page 115 is confusing. Does no change apply to all of the empty cells?

Response: Yes, there is no treatment in mixed conifer and therefore no change to VSS.

Comment: "Further emphasis be placed on the value of having a credible, thorough and documented multi-party evaluation and monitoring process." " Fire effects on leave tree mortality and snag retention be more explicitly addressed."

Response: Phoned Taylor and asked him to get with the Southwest Forest Alliance, who have the same concern and asked for them to come up with specifics and get back with me on their ideas.

Comments for 342i, m, n, o, p, r, s, t, u, v, w, x, y and gg
A total of fourteen groups and or individuals as written in PRD#'s 342i, m, n, o, p, r, s, t, u, v, w, x, y and gg voiced similar concerns about the project. All fourteen letters were similar in content and include information found in an Action Alert found on the Southwest Forest Alliance web site. We have summarized the various points from these letters and respond to them by point rather than by individual letter to reduce the duplication.

Comment: ".this picture fails to take into account natural ecological events and dynamics that might have naturally altered the forest structure since the 1870's."

Response: Based on previous comments to the EA, we believe you mean the effects of the 1919 seed crop and other regeneration events. These are discussed on pages 70-76 of the EA. Without detailed listing of natural events and dynamics, we cannot further address this comment.

Comment: "Furthermore, recreating this frozen-in-time structure does not necessarily restore the natural processes within the ecosystem."

Response: We do not state that we are recreating a "frozen-in-time structure".

The Flagstaff urban interface will not be returned to conditions present in 1876. Rather, the urban interface will be returned to more normal natural conditions (see pages 11-14 and 29-30 of the EA), under which native biological diversity has the greatest chance of being sustained given the continuing impacts of urban populations, global atmospheric changes, and other modern conditions.

Comment: The wildlife species that have proliferated in the dense forest conditions will be severely impacted."

Response: Direct, indirect and cumulative effects of the restoration treatments on wildlife are found on pages 85-120 of the EA. Without listing specific species and effects, we cannot further respond to your comment.

Comment: "presettlement model, is much too aggressive in thinning, drastically reducing structural diversity in the forest."

Response: The EA addresses the resulting forest structure after the various presettlement model treatments on pages 18-19 and 72-76. Without details about your concerns over forest structure, we cannot further respond to your comment.

Comment: "The project fails to consider the impacts of such a drastic timber harvest on forest-dependent wildlife."

Response: Direct, indirect and cumulative effects of the restoration treatments on wildlife are found on pages 85-120 of the EA. Without listing specific species and effects, we cannot further respond to your comment.

Comment: "The Forest Service needs to define a strict Wildland-Urban Interface and to differentiate such areas from forests that need a general reduction in fire risk.

Response: The EA has defined the Wildland-Urban Interface (EA pages 3, 5-6 and 153) and is further defined in the Cooperative Agreement (PRD#3). This item is further discussed in the Flagstaff Urban Interface Area Fire Risk Assessment (PRD#292).

Comment: "I support a less extreme approach to forest restoration, such as the Natural Processes Restoration approach supported by the Southwest Forest Alliance".

Response: We have included this approach as part of Alternatives B and D (pages 42-44), and documented why it cannot be used for the entire project area (page 27).

Comment: ".remove economic incentive to harvest the maximum amount of timber and largest trees possible."

Response: This is not a timber sale. Trees thinned are the byproducts of restoration goals and objectives (EA pages 11-14, 29-30). It is estimated that 90% of the trees removed are 12 inches diameter or less (EA Page 32, 38 and Project Record #311). This is not an effort to harvest the "largest trees possible". Two of the alternatives studied had a 16 inch cap. The economic impact of this small tree material and the 16 inch cap is discussed (page 164, EA).

Comment: "I fully support the restriction on cutting trees greater than 16".re-evaluate this limit in light of the proposal by Forest Service Chief Dombeck for a region-wide restriction on cutting trees over 12" diameter."

Response: There is no policy from the Washington Office placing restrictions on cutting trees over 12" diameter.

Comment: "longer monitoring period between the two phases of the Fort Valley project."

Response: The adaptive management strategies applied in this project will allow for a longer monitoring period if those developing the monitoring criteria believe this is necessary. We encourage you to participate in developing monitoring criteria.

The following letters were received with various issues and concerns about the project PRD# 342ff, dd, ee, cc, z, k, aa, and hh.

Comments and Responses to PRD#342ff

Comment: "The proposed project fails to address the affects of livestock grazing that results in high tree densities in Ponderosa Pine and invasion of juniper into overgrazed grasslands".

Response: Please see pages 7-8, 9 and 14 of the EA. The area has not been grazed in over 10 years. Most of the project area is administratively withdrawn from grazing.

There are no juniper trees or pinyon/juniper habitat types described in your letter within the project area.

Comment: "Population survey data needed to determine the maintenance of minimum viable populations of wildlife is not disclosed."

Response: Please see pages 20 and 85 of the EA. All of the 36 C.F.R regulations pertain to Forest Level Planning and do not apply to preparation of an EA. Enclosed is a copy of the BA&E for this project.

Comment: "The proposed project fails to disclose the uncertainty and risk of 'Forest Health' logging treatments designed to reduce fire hazard. The proposed treatments may not result in a reduction of fire hazard."

Response: The concerns you raise with not treating slash are concerns we share. Please see slash treatment proposals on pages 147-157 and pages 22-28 of the EA. All slash will be treated. We have read and included most all of the scientific literature you have provided in our EA, in addition you might want to look at some of the work of Folliott et. al (1977), Weaver (1947), Sweezy and Agee (1991), and the work of Harrington and Sackett whom have several papers. The complete literature citations are located in the EA in the references section pages 172-177.

In addition, The Flagstaff Area Fire Risk Assessment (Project Record #292) contains numerous discussions and references about effective thinning to reduce fire risk. Much of the research that concludes that thinning was ineffective in reducing fire risk revolves around leaving slash, removing large fire-resistant trees, or leaving densities too great to achieve fire reduction goals. For Fort Valley, slash is treated, large trees are left, and treatments designed to reduce fire risk remove small diameter trees (the subject of much criticism).

The EA discloses the effects of proposed treatments on pages 56-168. Without specific details about which effect is not disclosed, we cannot further address your comment.

Comment: "We recommend that thinning treatments be planned that will remove suppressed and intermediate trees, reducing crown bulk density and increasing crown base height".

Response: We agree with your recommendations and encourage further dialogue on specific alternatives described on pages 29-48 of the EA. As several of the alternatives and the various thinning treatments proposed in these alternatives are designed to do exactly what you have recommended.

Comments and Responses to PRD#342dd

Comment: "Professional Integrity of the Environmental Analysis. Regrettably, the Fort Valley EA is replete with conclusion that are foolhardy, at best, and made without any reference to scientific or other sources relied upon."

Response: We reviewed each of the examples provided in your letter and find that in all instances the sentences have been taken out of context. We recommend a more thorough reading of previous and subsequent paragraphs to better understand the effects. The author of the letter attempts to rebut statements, yet provide no scientific data or research to support the opposing statements.

In regard to references and scientific literature please see pages 172-177 of the EA, there are over 90 references provided which have been used in the preparation of this document. We have noted that your letter provides four scientific references; all of these have been previously read by Forest Service staff and are documented references in the EA. It would be in your benefit to provide scientific analysis or references in support of your statements as required by 36 CFR Part 215.6(b)(3).

Comment: "An environmental impact statement must be prepared".

Response: Please see page 19 of the EA. Your comments on this matter will be reviewed as we move forward toward a decision for this project. Please see the Decision Notice for this project.

Comment: "The Forest Service has acted in an arbitrary and capricious manner by rejecting a no commercial harvest alternative".

Response: Please see page 17, and Section 2.2 pages 22-48 of the EA. We have analyzed the no action alternative, a prescribed fire without thinning alternative, a prescribed fire in combination with thinning by non-commercial logging methods alternative and leaving a higher residual tree density, as proposed by the Southwest Forest Alliance alternative. It would be helpful for your organization to provide a clear definition for (non-commercial) as many times you state no harvest as being synonymous with non-commercial. We developed the noncommercial alternative with the best information available to us, as demonstrated in the Project Record.

In your initial comments to the Fort Valley project (Project Record #25c) you and the various organizations you have represented defined a vague definition of noncommercial. "This project should be designed exclusively as a restoration program, and not include any commercial timber sale component. By thinning small diameter trees, lopping, scattering, and burning the slash on site."

There is no further input from your organizations until the first appeal of Fort Valley, which makes absolutely no mention of noncommercial alternatives or its definition.

Subsequent response to Fort Valley from your organizations was appeal #2 (Project Record #264), which simply states without further definition, "the Forest Service must formulate a no-harvest alternative that addresses the restoration needs of the Fort Valley area."

Furthermore, Project Record #264a documents a phone conversation between John Gerritsma of the Coconino NF and yourself in which you again failed to provide details of a noncommercial alternative.

While "give-aways" might deal with some of this material, our experience (and the Flagstaff Fire Department) is that only material next to roads and easily accessible is taken. There is also a limit to the amount of such material that is wanted (see Project Record # 264a).

The citations you state are the same as appeal point #5 in your second appeal of Fort Valley (Project Record #264). The Reviewing Officer responded to those comments (Project Record #271) and subsequently denied your appeal point.

The projects you have listed on page 6 of your comments simply reflect that there are conditions under which noncommercial thinning will meet project objectives. However, these projects do not demonstrate that noncommercial thinning is the only tool required for forest health restoration. For example, both the Happy Jack Urban Interface and the Townsend-Winona projects on the Coconino fit noncommercial methods, because the trees needing treatment are generally less than 6 inches in diameter, and removal of trees was for fuels reduction purposes only, not restoration. This is not the case for most of Fort Valley (EA, page 32 and Project Record #311). Goals for Fort Valley include both fuels reduction and restoration (EA page 15). Still, we have identified approximately 780 acres to be treated noncommercially (Minimal Restoration--EA Page, 39).

Comment: "Cumulative impacts of treatments planned for the entire urban/wildland interface have not been disclosed."

Response: Please see pages 3, 57-58 and cumulative effects section for various resources pages 56-167. The Table of Contents will assist you in locating the cumulative effects documentation for the various resources. There are approximately 30 references to cumulative effects. We have articulated as concisely and accurately as possible on page 57 the status of future projects in the urban/wildland interface.

Comment: "The management prescriptions for allocated old growth are inconsistent with retention and development of old growth ecosystems".

Response: Please see page 85 where it is stated that the Fort Valley project meets all standards and guidelines in the Forest Plan and meets all monitoring requirements. See Pages 94-97 of the EA where old growth management is described and effects of treatments are addressed by alternative.

Comment: "Incomplete economic analysis".

Response: The economic analysis is located on pages 164-167 of the EA. This project is not a timber sale, therefore many of the handbook and manual regulations you cite do not apply to this project.

Page 166-167 of the EA discusses the effects on non-market goods and services. Comments regarding economic analysis requirements were the subject of appeal point #9 in your second Fort Valley appeal (Project Record #264). The Reviewing Officer responded to those comments (Project Record #271) and subsequently denied your appeal point.

Without giving us specific details about which mitigation/monitoring cost you believe is not included, we cannot further address your comment.

We did not include research costs because these activities are ongoing whether they occur on the Fort Valley site or other restoration sites around the Southwest. This project is benefiting from this research, but does not require it in the mitigation of effects.

The economics results table on page 164 displays project costs and benefits in present net value.

Comment: "The Fort Valley Project will not insure the viability of species dependent upon closed canopy forests".

Response: Please see page 20 and 85-120 of the EA.

Comments and Responses to PRD#342ee

Comment: "Need to prepare an Environmental Impact Statement".

Response: Please see pages 19 and 57-58 of the EA.

Comment: ". as noted above, however, the defining element in the Blue Mountains case was the presence of a 'strategy'."

Response: In the case of the Blue Mountains it appears future salvage sale areas were already designed . treatments had been planned, stands delineated, volumes were known and the future salvage sales had been named. Some type of comprehensive fire plan had been developed.

Our situation is very different. As stated in the EA future projects in the wildland/urban interface have no names, no prescriptions have been developed for stands, and we have no idea of where we are treating next or how. What if the rest of the urban interface is treated with clearcutting and paving, as has been recommended by some. This would have differenct affects than using the Forest Alliance Prescription. Using unevenaged management across the entire area would have different affects. It is very possible that future projects will include some new types of treatments, as we learn from other projects around the region. We may use some of the same treatments but at much different proportions and this would lead to different effects. We will continue to address cumulative effects, as future treatments for the rest of the interface are known. Could you please offer up your suggestion for how to predict the future and how to conduct a meaningful effects analysis? An extensive cumulative effects analysis was conducted for the Coconino Forest Plan and Amendments. The Fort Valley Project meets all standards and guidelines in the Forest Plan.

Comment: " Presettlement Model - It is also extremely troubling that the Forest Service's has taken a "fast track" approach to this project, and is now analyzing the entire Fort Valley 10K rather than the 1,700 acres which was analyzed during the original NEPA."

Response: Please see the EA dated December of 1998. The EA analyzed the same area as analyzed in the July 2000 EA. The Decision Notice's for the December 1998 EA decided to implement only Phase 1, or the 1,700 acres.

Comment: "Presettlement Model - The difference between the "modified" and "full restoration proposals, however, is minimal. In fact, this different amounts to, at most, a few more trees remaining per acre after logging."

Response: The difference between "full" and "modified" restoration is substantial. The number of trees is doubled. Table 4 on page 72 predicts the differences in trees per acre, basal area, and average diameter between full and modified, and in 20 years and 50 years. Preliminary information (Project Record #309, #311) clearly indicates substantial differences in economics and in stand structure. Note with no action trees reduced by ½ over a 40-year period. This is from mortality caused by stressed growing conditions. Over ½ of the trees would die and result in much higher dead fuel loading which is the reason for the worsening fire effects described in the EA. See the table at beginning of document for data from demonstration plots.

Comment: "Presettlement Model - .stands undergoing "full" restoration on Mount Trumbell have still crowned out in subsequent prescribed burns (such occurrences call into serious question the Forest Service's rejection of suggestions to consider a prescribed burn only alternative. Despite the fact that these experiments have been the most extensive presettlement logging undertaken to date, these questionable results are not addressed."

Response: Correspondence with Pete Fule' of Northern Arizona University involved in the Mount Trumbel project explained the following. There has been one crowning event, which occurred this spring. A prescribed fire within one of the treatment units, became a wildfire when it jumped a control line and entered a control or untreated block. The untreated block, which was very dense, similar to stands at Fort Valley became a crown fire of approximately 10 to 12 acres. Within the areas treated at Mount Trumbel there have been isolated trees, which have torched, mainly within oak thickets. Also, there have been a few old growth trees killed as a result of scorch. There have been no crown fires within the treated units.

The 10 to 12 acre crown fire in the control block is an example of why we are not looking at prescribed burning only for all of the Fort Valley area. Note that there is a 700 acre stand at Fort Valley where the only treatment is prescribed burning. Please see EA pages 23-28.

You may be confusing the effects of burning slash with the effects that a wildfire would have after the slash has been treated. Even prescribed burns after thinning in absence of thinning slash (Fort Valley demo units 1 and 2) may result in some mortality from fire.

Comment: ". Response to the public comments and concerns must be in the EA or in a appendix to the EA."

Response: Please see page of 1 of the EA.

Comment: "16 Inch cap and "Wildland-Urban" Interface - .The 16 inch cap which is proposed must also be evaluated in light of recent statements by Chief Dombeck that fire reduction treatments be limited to trees under 12 inches and that priority be given to high risk areas within the urban interface."

Response: Please see page 5 for a list of project objectives, which are much broader than fire risk reduction. This is an ecological restoration project and fire reduction project. There is no direction from our Washington Office to limit this project with a 12 inch cap.

Discussions about the 16-inch cap is found on pages 17-18, 46, 54, 89, 96-97, and 164-165. There are no statements on those pages portraying the 16 inch cap as "political".

Comment: "Northern goshawk - . within the highly active Orion and Fort Valley PFAs, the Forest Service should completely defer any actions."

Response: Please see pages 7-8 of the EA. The Management Guidelines for the Northern Goshawk in the Southwestern United States, recommend treating within foraging areas, PFAs, and nest stands to meet criteria recommended for habitat within these areas.

Comment: "Please address each of the provisions contained in the enclosed document relating to goshawk requirements."

Response: A review of the information requested found that all of the answers to your questions are located in the EA. Please see pages 85-88, 88-92, and 112-118. We are making you a map. It is not common policy to disclose the nesting stands, as goshawk young are taken for falconry purposes, as you may be aware. Also, keeping these areas confidential is in the best interest of the birds to avoid excessive human disturbance.

Comment: "Management Indicator Species".

Response: Please see pages 85 and 98-103. The models also give population trend data. All species showed an increase, except Abert Squirrels when compared to the no action alternative.

Comment: "Roads".

Response: Pages 158-159 describe the short-term, transient nature of temporary roads, and the overall goal of reaching the guideline (not standard) in the Forest Plan for road density. Page 98-99 discusses roads and their potential impacts to various wildlife species. The effects of roads/trails and road closures to various wildlife species are discussed on pages 101, 104, 109, 110, 116, and 119. Pages 127-131 discuss the impacts of roads and other actions on soil and water quality, and the use of Best Management Practices that limits the amount of sedimentation.

Comments and Responses to PRD#342l

Comment: "Since retaining smaller trees has been demonstrated to be crucial for wildlife, and was almost certainly a part of the structural range of variability, why has it been relegated to a mere 100 acres in the preferred Alternative B?."

Response: Small trees and areas of clumps/stands of smaller trees will be retained within 4,100 acres of the project. There are 700 acres of Modified Restoration with 20% Deferral for Wildlife Management; 780 acres of Minimal Restoration which will maintain cover within an important wildlife movement corridor; 530 acres of Dense Tree Canopy Thinning to promote structure described in the Management Recommendations for the Northern Goshawk in the Southwestern United States; 2,090 acres of Deferral (these are all dense areas with a lot of small trees in drainages, wildlife cover areas, Mexican spotted owls PACs). There are also 130 acres of Forest Forever Prescription and another 130 acres of unevenaged management. Within all the treatment areas dense clumps of small trees are grouped adjacent to snags, which have potential for flammulated owl nesting. Please see pages 37-45 for a detailed description of Alternative B.

Comment: "There is simply no basis for the successor multiplier values. Why 1.5 or 2 successor trees? Why not 5, 8 or 10?"

Response: We are sending some literature from Northern Arizona University regarding the selection for the multiplier (PRD #112). We have several demonstrations of various multipliers completed. The demonstration plots will study the effects of 1.5/3, 2/4, and 3/6. Research planned for phase 1 will look at the effects of unevenaged management, the Forests Forever treatment, a modified version of the Presettlement 2-4 (different clumping method), and a "Blend" treatment which has not yet been developed. There is a team working on the "Blend" and your experience and opinions about this could be incorporated.

Comment: "Why isn't the grazing planned for the restoration more explicitly discussed?"

Response: Please see pages 14 and 30 of the EA. Very little of the project area is grazed, most of the area is administratively withdrawn from grazing. No grazing has occurred in the area for over 10 years. Future use is expected to be minimal.

Comments and Responses to PRD#342k

Comment: "The 16 inch restriction is a political issue more than an issue of forest health and should be removed."

Response: Please see pages 17, 46, and 94-97.

Comment: ".road 9002W to remain open."

Response: You are correct that road 9002W will remain open. Please see page 160.

Comments and Responses to PRD#342aa

Comment: ."the Forest Service needs to re-evaluate the cutting cap for Fort Valley."

Response: There is no direction or policy from the Washington Office that limits thinning to 12 inches.

Comment: Currently, the EA does not specify a 16" cutting cap in Aspen Restoration.

Response: We regret the omission. The 16 inch cap includes aspen units.

Comment: The EA does not explain why this project was so greatly expanded from a 1700 acre project in 1998 to the current 9100 acre project.

Response: Please see the EA dated December of 1998. The EA analyzed the same area as analyzed in the July 2000 EA. The Decision Notice's for the December 1998 EA decided to implement only Phase 1, or the 1,700 acres.

Comment: "Therefore, the application of this treatment prescription fails to provide areas, groups, or stands that are structurally dominated by the younger tree component."

Response: A discussion of the effects of regeneration pulses and small trees is found on pages 70-78, including studies that show a lack of small trees in undisturbed pine forests (page 73). It is also important to realize that much of Fort Valley has been thinned in the past, with many of the small trees occurring "unnaturally" as somewhat evenly spaced, even-sized, and even-aged.

Small trees and areas of clumps/stands of smaller trees will be retained within 4,100 acres of the project. There are 700 acres of "Modified Restoration with 20% Deferral for Wildlife Management; 780 acres of Minimal Restoration which will maintain cover within an important wildlife movement corridor; 530 acres of Dense Tree Canopy Thinning to promote structure described in the Management Recommendations for the Northern Goshawk in the Southwestern United States; 2,090 acres of Deferral (these are all dense areas with a lot of small trees in drainages, wildlife cover areas, Mexican spotted owls PACs). There are also 130 acres of Forest Forever Prescription and additional 130 acres of unevenaged management. Within all the treatment areas dense clumps of small trees are grouped adjacent to snags, which have potential for flammulated owl nesting. Please see pages 37-45 for a detailed description of Alternative B.

Comment: The EA and the model itself fail to show that restoring a particular spatial structure to the forest stands will restore presettlement functions in today's forests.

Response: We are not recreating a frozen-in-time structure. The foundation for ecological restoration at Fort Valley lies in a primary tenet of conservation biology: that organisms, communities, and ecological systems have adapted over evolutionary time to the structures and processes that they have encountered.

As one might expect, information derived from past environments is most easily obtained for the most recent periods of time. Our understanding of ponderosa pine forests prior to disturbance is most thorough for the time period immediately predating Euro-American arrival in Arizona. Ecosystem conditions and dynamics prior to disturbance serve as "reference conditions", providing the foundation upon which restoration goals and objectives are established.

Still the Flagstaff urban interface will not be returned to conditions present in 1876. Rather, the urban interface will be returned to more normal natural conditions (see pages 11-14, 29-30 and 67-84 of the EA), under which native biological diversity has the greatest chance of being sustained given the continuing impacts of urban populations, global atmospheric changes, and other modern conditions. Restoration is not really about the past; it's about the future.

Comment: ".the model itself does not sufficiently take into account mortality of trees due to harvesting practices, prescribed fire, or natural mortality."

Response: Please see pages 68-69 and 76-77 about expected mortality. Without specific details that you have regarding mortality in this model, we cannot further address your comment.

Comment: "The Southwest Forest Alliance questions the appropriateness of applying these extreme restoration measures."

Response: See project objectives (EA page 15). This is one of a number of approaches being tested with substantial research/monitoring and adaptive management. The merits or faults of this approach can only be tested on the ground. The presettlement model is being applied to about 4,000 acres, not 104,000 acres as you state. Please see pages 3, 16, 18, and 22-48 of the EA.

You label the presettlement model as "extreme", yet you do not mention the various results that are obtained depending on existing stand conditions. Blocks 2, 5, and 12 of the Fort Valley demo sites were all thinned with the 2/4 prescriptions that is proposed for Alternative B. The visual difference is quite great. While block 2 is decidedly open, block 5 is not. Block 12, with its component of yellow pines, nowhere near resembles block 2 or block 5.

The continued exploitation of blocks 1 and 2 in the various media as the resulting consequence of the presettlement model is misleading to the public. Preliminary data from the demonstration blocks show a big difference in residual basal areas. For example, the residual basal area ranged from an average 48 in block 2 to an average 102 in block 5 (Project Record #311). The latter is high even for intermediate thinning as described in the Coconino Forest Plan.

Comment: "This treatment does not provide for interim habitat for the wildlife".

Response: Direct, indirect and cumulative effects of restoration treatments on wildlife are found on pages 85-120 of the EA. Without listing specific species and effects, we cannot further respond to your comment.

Comment: "The treatments of the presettlement model drastically decrease the age diversity within the forest. The treatment may also drastically decrease the range of genetic variation found in the stands."

Response: There is no data to support either of those contentions. In fact, results of the Fort Valley demo blocks show substantial increases in diameter distributions of trees (diameter relates to age) (Project Record #311). In addition, the greatest biodiversity is not between ages of trees, or their sizes, but in the more than 600 species of understory plants, shrubs, and grasses. The presettlement model showed significant increases in forest openings.

Comment: "The minimal restoration treatment.is simply another prescription of the full restoration treatment."

Response: The minimal restoration treatment has a 9-inch cap, is done noncommercially, and is done only around yellow pines (EA pages 33 and 39). This is significantly different than the full restoration cut and is much less aggressive than the Forest Forever prescription.

Comment: "None of the treatments were successful in achieving a sufficient degree of groupiness/clumpiness in the leave trees.

Response: Please see pages 22 (reference conditions) and page 44(monitoring). Adaptations have been made to achieve a greater clumpiness since the demo blocks were cut, EA page 43.

Comment: "Such trees will not develop full canopies and are probably much more susceptible to wind-throw".

Response: It would be very beneficial for you to provide data to support this statement. Our experience with 40 years of thinning experiments adjacent to Fort Valley at Taylor Woods Study site does not support this contention. We have not experienced any wind throw events at Fort Valley, which would support your claim.

Comment: "The EA fails to provide a convincing scientific explanation of the impacts of such a drastic timber harvest on forest-dependent wildlife".

Response: The effects of all the proposed activities are found in pages 85-120, including the effects on Abert squirrels.

Comment: "The EA does not provide an adequate analysis of potential impacts to the Northern Goshawk."

Response: Pages 112-120 describe the direct, indirect and cumulative effects to the northern goshawk. Without any description of the inadequacy of the analysis it is difficult to further address your comment.

Comment #15: "However, the EA itself contains inadequate discussion of how the proposed action impacts replacement nests, reserve trees, and canopy requirements for each PFA and Foraging Area."

Response: Replacement nests are discussed on page 114. We are unclear what your concern is over reserve trees, but they are discussed on page 114 as well. Canopy requirements are discussed on pages 117-118.

Comment: "The project as it is presented in the EA currently violates the MRNG that provides minimal protection for the northern goshawk."

Response: The Coconino National Forest Plan provides us with standards and guidelines for management of northern goshawk habitat. We have met all standards and guidelines as stated on page 85 of the EA. The Forest Plan (page 65-68) asks us only to refer to the Management Recommendations for the Northern Goshawk in the Southwestern United States (MRNG) for scientific information, not for management direction. Therefore, we cannot violate the MRNG. Pages 112-120 of the EA explain how we meet the various standards and guidelines in the Forest Plan and state all canopy guidelines are met for nesting, foraging and PFA areas.

Comment: "The EA is incomplete and confusing in its discussion of the impacts to old growth."

Response: We have sent you a compartment map and list of old growth stands as you requested. Page 94 of the EA clearly defines old growth and its various components. Pages 95-97 explain the acres being treated (page 95), and the effects about logging in existing and recruitment old growth (pages 96-97).

Comment 18: "The project needs to be implemented in such a way that will remove economic incentives to harvest the maximum timber and largest trees possible."

Response: This is not a timber sale. Trees thinned are the byproducts of restoration goals and objectives (EA pages 11-14, 29-30). It is estimated that 90% of the trees are 12 inches diameter or less (EA page 32, 38, and Project Record #311), indicating that this is not an effort to remove the "largest trees possible". Two of the alternatives studied had a 16-inch cap. The economic impact of this small tree material and the 16-inch cap is discussed (page 164, EA and Project Record #56a and #309).

Comment: "The economic analysis of the EA is inadequate."

Response: See EA, page 164, and Project Record #56a and #309 for details on trees that could have been available for harvest above 16 inches diameter. We are unclear how projected volumes in various diameter ranges improves the economic analysis. Project record #311 provides estimates of diameter ranges that can be projected over the Fort Valley Project.

Comment: "The EA does not discuss or consider the relationship of this 9100 acre planning effort to the other nine projects that are planned for the Flagstaff urban-wildland interface area, and the 104,000 acres designated around Flagstaff."

Response: The relationship between Fort Valley and the Flagstaff Urban Interface is explained on page 3 of the EA. Cumulative effects are explained on pages 56-58 of the EA.

Comment: "The Forest Service needs to explicitly designate an adequately long monitoring period between the two phases of the Fort Valley project, and before implementing the next project".

Response: We agree that not all the answers will be available to us after just one growing season between phases. This is acknowledged in the EA (page 49-55). Adaptive management strategies will allow for additional monitoring time if those participating in the monitoring feel more time is needed. Since you did not provide specific monitoring time frames based on specific concerns, we cannot further address a longer implementation break.

Forest health conditions are worsening, the forest continues to grow at high rates worsening fuel loading and impacts to old growth and the understory, and predictions for a drier climate are important factors that tempers our ability to wait with forest restoration. Currently, the Coconino National Forest burns more than 3,000 acres annually, much of it catastrophically. The 2000 fire season is a taste of things to come, and follows only 4 years after 1996, another extreme fire season. That is why we have a thoughtful monitoring plan associated with this project as well as adaptive management provisions (EA, pages 42-45).