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Kondolf: Cumulative Effects in the Sequoia National Forest 3 



Sequoia National Forest, I have concluded that the failure of 

 this method to accurately model the true cumulative effects is 

 probably deliberate. The voluminous and unscientific paperwork 

 generated by this procedure serves only to create a "paper trail" 

 of ostensible compliance with NEPA and NFMA. In reality, the 

 "analyses" are rigged so that the procedure virtually always 

 indicates a watershed can accommodate more timber harvesting and 

 road building. The analyses are rigged by failure to adequately 

 account for the effects of past management activities, by using 

 "fudge factors" that reduce the computed effect of past or 

 anticipated actions, by deliberate alteration of information used 

 as input to the analysis, by failing to analyze cumulative 

 effects on receiving waters downstream, and by failing to test 

 the method against actual field conditions. I briefly discuss 

 these problems below. 



FailuTB to Adequately Account for Past Impacts 



The Sequoia National Forest claims that its procedure 

 accounts for the impacts all past activities by adding up the 

 area of roads and past timber cuts. However, the area covered by 

 existing logging roads is grossly underestimated by use of 

 official transportation maps, which fail to include many smaller 

 roads that are important sources of sediment and increased 

 runoff. The procedure also assumes that after clear-cutting, 

 sites regenerate at such a rate that they are "fully recovered" 

 after 30 years. This assumption is contradicted by field 

 conditions at a number of sites throughout the forest as observed 

 and measured by myself and other scientists. Many plantations 

 have failed to regenerate despite repeated attempts over many 

 years. The Forest Service has not systematically and objectively 

 documented revegetation rates to support its assertions of 

 successful revegetation in environmental assessments. 



Use of Fudge Factors to Guarantee the 'Analysis' Sbotfs No Impacts 



The procedure used by the Sequoia National Forest is an 

 adaptation of a method developed on other National Forests in 

 California. In this method, the expected effects of past 

 management are added: clearcuts are expected to regenerate and 

 thus contribute progressively fewer effects over time, but roads 

 do not recover because they remain bare, eroding surfaces that 

 concentrate runoff. Thus the watershed acreage covered by roads 

 should not be reduced in calculating past impacts. This 

 principle is explicitly acknowledged in the Forest Service's 1987 

 guidance document, which states, "Roads do not recover." 

 However, in subsequent revisions of the guidance documents and in 

 implementation, the Forest Service has assigned so-called 

 "sediment delivery" and "slope" factors that reduce the computed 



