The DEIS is available at http://www.fs.fed.us/r6/w-w

Click here to view a PDF file (large download) of a recent field visit to Joseph Creek Wild and Scenic River.

      The Preferred Alternative will not be consistent with the Wild and Scenic Rivers Act or the Wallowa-Whitman Forest                             Plan in terms of protecting riparian areas within the project area, and particularly within the Joseph Creek Wild and Scenic                            Rivers corridor.  Removal of streamside vegetation reduces shade, and causes stream temperatures to increase.  This and                               other livestock impacts on riparian areas affect the Fisheries and Water Quality ORVs (outstandingly remarkable values)                                  of Joseph Creek.  Furthermore, the DEIS states that reduction of riparian corridor vegetation diminishes both forage and                              cover for wildlife species.  This impact is crucially important because Wildlife is another ORV for which Joseph Creek was                        designated Wild and Scenic.  The utilization standards (10-20 percent) on riparian areas are arbitrary, particularly as there is                                no developed protocol for shrub utilization surveys.  Simply put, they do not ensure the public that riparian areas are being                         adequately protected, nor do the utilization standards give any assurance of protection for wildlife species outside of a vague                    monitoring program. With respect to riparian areas, there protection is particularly important where the streams may be limited                         in quality by high temperatures and sedimentation, factors which can be mitigated by healthy riparian vegetation.

Management Indicator Species

       The DEIS fails to integrate consideration of Management Indicator Species (MIS).  The USFS is required to present the                    public with quantitative information on how they establish the health of indicator populations within their analysis area.                             Throughout the DEIS, the USFS uses “habitat improvement” as a proxy for the health of important species, which unfortunately                  does not necessarily correspond to the health of the crucial management species in this area.  There is no way for the public to                     judge whether the area is actually “improving,” or simply being degraded less severely.  The problem is marked in the WWNF’s                    treatment of wildlife and big game species, for which elk are a MIS.  Though elk are failing to meet management objectives, the                     DEIS proposed to expand the grazing season in elk winter habitat, and it does little to ameliorate conflicts between cattle and                           wild ungulates in riparian areas.  Hence, the Forest Service is failing to adequately describe and incorporate MIS information.

      Consumption of native vegetation and soil disturbance by cattle have caused noxious weed infestations throughout the                      planning area. The primary cause of noxious weed problems in the Deadwood area is cattle grazing.  Clearly the best alternative                       for noxious weed infestation is Alt. 1. The DEIS asserts that grazing may benefit the control of these weeds by promoting                       recognition by cow handlers.  While this may be  \true, there is no basis for quantitatively assessing this effect, as stated in the                       DEIS.  Livestock grazing is a known vector for noxious weeds, and particularly in areas where sensitive species may be affected                       by weed spread, grazing should be excluded or limited.

      The DEIS generally states that livestock grazing impacts are “local” or “isolated.”  Soils impacts are an example of an                              impact that is acute in many places, but also very widespread.  Soil productivity is lost when livestock hoof action compacts                            the soil, disturbing the microbial community and the physical structure of the soil.  In so doing, the compaction can limit the                     productivity of the soil with respect to vegetation. The DEIS correctly states that “continued livestock grazing will cause soil                       compaction and displacement within allotments to persist.  The areas most susceptible to compaction and erosion are those                          where livestock use is concentrated or season long,” areas that often include stream bottoms (DEIS p. 112).  Yet, the Preferred                 Alternative continues the current grazing regime, yet suggests that there is the possibility of improvement in the system.  No                      rationale is offered as to why a continuation of the current grazing regime will enhance soil productivity, nor is it immediately                       clear why “any increase in detrimental soil conditions is expected to be limited in aerial extent and size” (p. 112).  Indeed, impacts                  within the Wild and Scenic Corridor (already documented by FLOW field observations) on a local or widespread scale are                         inconsistent with the “protect and enhance” standard.  The DEIS later states that “any adverse impacts to ORVs, water quality,                      or free flow, even within Forest Plan standards and guidelines, will be corrected immediately” (p. 175).  It is counterproductive                       for the WWNF, with this goal in mind, to put forth a Preferred Alternative that, by its design, encourages impacts to soils that                             threaten ORVs.  We would encourage the WWNF to expand its alternatives to include stricter exclusions of livestock grazing,                   particularly in the Wild and Scenic River Corridor.        

            The EIS fails to explain how increased monitoring will avoid damage to riparian areas.  The riparian concerns are not                       just occurring in the key areas identified by WWNF.  Those areas are subjected to ongoing violations but so do many other sites                 along numerous streams, springs and wet meadows throughout the planning area allotments.  The Preferred Alternative states                       that monitoring will establish trends in order to document the need for adjustments in capacity, numbers of head, or season of                          use.  WWNF has documented livestock damage in many areas, including the Wild and Scenic River Corridor of Joseph Creek.                  There are no assurances, or a specific plan, for how cows will be kept out of riparian areas and avoid violations of the Wild and                  Scenic Rivers Act.