p. 1, para. 3 



The DEIS (p 3-38) discusses the cumulative effects of past actions on soils, considering the relative ages 

 of harvest and area of impacts across all ownerships, recognizing that older harvest methods typically 

 had greater soil impacts than recent harvest It is apparent that all ownerships considered in the 

 exchange had several harvest entries and extensive ground based skidding. We estimated that past 

 harvest effects were high with 15-25% of sites impacted, based on aerial photos and published research 

 due to the broad scale of the area. Research considered in the EA, but not directly referenced, includes 

 work by Bradshaw (1979) where he measured conventional skidding area that covered up to 22% of a 

 harvest unit, versus about 7% area for pre-planned skid trails. In more extreme cases tractor skid trails 

 may cover up to 36% of a harvest area (Dryness 1965 and Froehlich 1976, iji Bradshaw 1979). We also 

 expect that there has been some ammelioration of soil effects over time. 



The DEIS (p. 4-58) displays that there is potential for cumulative effects to long term soil productivity 

 associated with land management treatments and harvest operations over previously harvested areas. 

 We expect that all the action alternatives would have similar effects on a per acre basis considering 

 implementation of BMP's. The areas affected may change slightly by landowner based on their 

 management goals. We expect the risks of cumulative effects would be minimized if harvest plans 

 incorporate ways to minimize disturbance by using existing roads and trail systems and attempt to reduce 

 the number of roads and trails. All landowners are concerned about maintaining long-term soil 

 productivity. Forestry practices across ownerships should comply with Best Management Practices 

 (consistent with past BMP audit results) to prevent resource damage to soils and water 



Reference: 



Bradshaw, G. 1979. Preplanned skid trails and winching versus conventional harvesting on a partial cut. 

 Oregon State University, Forest Research Lab Note 62. 



Old Growth 



p. 1. para. 4 



DNRC and FWP recognize the importance of old growth, and we made a strong effort to present a clear 

 and objective analysis of the two issues considered. We agree that the old growth issue is one of much 

 public debate, and in the DEIS we acknowledged that DNRC is in the process of revising current 

 departmental policy pertaining to the old growth definition in use and old growth commitment acreage 

 (DEIS pp. 3-15, and 4-24). An analysis of how Green et al. old growth amounts shift under the various 

 alternatives at the Unit level was omitted from this analysis, because a revised DNRC commitment that 

 incorporates Green et al. old growth definitions does not exist Thus, any analysis of this nature that 

 might have been included in the DEIS would have been quite speculative. Lands with the largest patches 

 of old growth and high attribute levels (primarily found in section 10, T15N, R14W) could only be 

 exchanged to FWP, and would be afforded a high level of protection should Alternative C or D be 

 selected. 



Since publication of the DEIS, DNRC's commitment for old growth management has changed. On April 

 16, 2001, Senate Bill 354 became law. This bill requires that any set-aside of State trust lands, for 

 purposes of natural areas, open space, old growth protection, and wildlife management areas, must be 

 compensated to the trust The commitment in the SFLMP, to defer harvest of old growth in the amount of 

 one-half of historic levels, is in conflict with this law, and will be amended. Also as a result of the passing 

 of SB 354, DNRC does not now have plans to designate old grov^h retention reserves in the foreseeable 

 future. DNRC will continue to harvest and manage old grow/th to meet biodiversity objectives and efforts 

 will be made to minimize impacts. However, under SB 354, a defined retention acreage commitment will 

 not exist. DNRC is currently developing temporary procedural rules to implement SB354. Subsequent 

 DNRC activities will trigger additional individual MEPA assessments, which will address issues specific to 

 each proposed project. 



BCWMA Land Exchanges Final Environmental Impact Statement 23 



