State Department of Wildlife (which is responsible for managing the species), indicated goat populations in the Cascade Mountains of Washington were declining. The State concluded that the decline was due to several factors: too much hunting pressure; loss of winter range cover due to timber harvest; and an above-average loading of intestinal parasites. These deliberations, in concert with the State, indicated to us that significant cover reduction on National Forest land could jeopardize viability of the species. We could not under law take the risk that our management activities might contribute to threatening the viability of this species. We then needed to establish a management requirement (MR) for assuring a viable population level, while we gathered additional knowledge of habitat needs, and located and inventoried those winter ranges being used by mountain goats. In DEIS Appendix J (page J-12), we indicated that specific locations of occupied goat winter range are not well known. The areas identified in the DEIS represent the best information available, gathered in conjunction with the State agencies and others. This information will continue to be up dated. Likewise, the required acres to maintain a goat through the winter are not perfectly established. However, because of the viability issue, establishing a management requirement (MR) that dictated constraints and other management activities was deemed appropriate; it is included in the Forest Plan. As discussed in Appendix I, DEIS, mountain goat MR's have been revised to include a dispersal requirement and the size of the winter range modified to maintain a viable population. In the FEIS, see Appendix H. DEDICATING ACRES TO MOUNTAIN GOATS IS EXCESSIVE AND UNSUBSTANTIATED The recommendation of the MBS to have 33,568 acres of timber land dedicated to mountain goats is excessive and unsubstantiated. Response: We are unable to determine the source of your acre figure. PRATT RIVER AREA HAS IMPORTANT MOUNTAIN GOAT HABITAT A specific example of goat winter range that could be impacted by logging and road construction is the lower end of the Pratt Valley (Sections 31 and 32 T.24.N., R.10.E). Mountain goats are regularly seen here during the winter months, on the low elevation ledges of Preacher Mountain. A State Department of Wildlife biologist rated this area as excellent goat winter habitat. The area is also a very important elk and deer winter range. The wildlife productivity of this area is very high and as such, should be managed not for timber, but for big game. This data was not known in 1981, when the Alpine Lakes Management Plan was implemented. Response: There are 4 mountain goat MR's designated in the Pratt River drainage. One is located on the south/southwest sides of Preacher Mountain. These areas will be monitored for adequacy of the size and locations once the Plan is implemented. The lower elevations of the Pratt River drainage have been identified as Deer/Elk winter range and allocated to MA 14 (which was 14B in the DEIS the MR for deer and elk has been dropped, as discussed in Appendix J in the DEIS.) Refer to the map for Alternative J (Preferred). The Pratt River drainage will be managed for big game as well as a variety of other resources, including timber and recreation. The prescriptions and Management Areas for Mountain Goats and Deer/Elk will ensure viability of the wildlife populations that occur in this area. MOUNTAIN GOAT PROTECTION NEEDED IN LONESOME LAKE AREA The Lonesome Lake Roadless Area parcel is sort of a way-station for both elk and mountain goats in their annual migrations to and from higher ranges in Mt. Rainier National Park and the lower ranges on Huckleberry Ridge. The goats winter predominately in Section 14, T.18 N., R.9 E. and Section 10. A pileated woodpecker MMR is proposed for Section 14 in most alternatives; this will be of value for many species. The maintenance or preservation of an old-growth timber "migration corridor" in this area is of vital importance for mountain goats. Response: The Lonesome Lake area is allocated to the following Management Areas in the Preferred Alternative: Scenic Foreground and middleground for the area within Huckleberry drainage, from the ridge in Sections 34, 27, 22, and 15 to the east; MA 1B, Semi-primitive nonmotorized dispersed recreation surrounds Lonesome Lake and Mule Lake. There is a mountain goat MR (MA 15A) in portions of Section 32 and 33. Within the Lonesome Lake area, there is a small portion of MA 12, mature and old growth habitat. We recognize the value of the migration route and have been able to avoid it in the past five year-period. No sales are planned in the Huckleberry drainage that affects this area in the next five years. As noted in the Forest-wide Standards and Guidelines for mountain goats, Item 9., we intend to survey to determine the presence or absence of mountain goat winter range as part of project design. Refer to Chapter 4, Plan. ALTERNATIVES UNNECESSARILY RESTRICT BOTH TIMBER HARVEST AND DEER AND ELK The DEIS Preferred Alternative and the other alternatives unnecessarily restrict timber harvest and deer and elk production, when both could be increased by harvesting more timber. It appears that the Forest Service has purposely left out any habitat improvement in Alternative D, which is unfortunate. Overall outputs can be better if the land base is maintained at a high level where harvest occurs and habitat improvement on winter range is done. Response: In the FEIS, we developed and evaluated a new alternative, Alternative I. It replaces Alternative D, from the DEIS. The goal of Alternative I is similar to D, but it better responds to public support for an alternative with a high timber harvest, more emphasis on big game, and access for recreation. The goals for Alternative I include: emphasize resources with an established market price, such as timber production, developed recreation, and minerals; and emphasize enhancement of big game habitat and the development and maintenance of an extensive trail system. The outputs and effects of Alternative I are displayed in the tables in Chapter II, FEIS. HOW WERE WILDLIFE POPULATION NUMBERS DETERMINED? Your current level estimates for deer and elk are approximately half what the Department of Wildlife would estimate. Do your figures include the effects on habitat usability due to roads? Is your model forage based? Your figures bear little relationship to harvest level; is this due to investments in habitat improvement? The Forest should put the same effort into developing realistic wildlife and fish population and habitat estimates as you do for timber. We understand the State Department of Wildlife has data available on elk, goats, deer, and elk on Forest lands that is not being utilized in this planning process. Response: The population estimates used in the DEIS were obtained through consultation between Forest Service and Washington Department of Wildlife biologists. The State has made population estimates for only a few of the species for which we have attempted to show populations. State population estimates are made for species an a State-wide basis. Using State estimates and pro-rating them to National Forest lands results in a gross estimate, at best. Even though we have indicated these are population estimates for certain species based on individuals, the numbers are really more of an "index" not actual populations - and should be interpreted that way. They are valid, however, for showing relative changes in population - up or down due to different management proposed in a particular alternative, and for comparing alternatives. In the FEIS, Chapter II output tables, we have clarified the text to make interpreting these tables easier. QUESTION THERMAL COVER REQUIREMENTS FOR DEER AND ELK WINTER RANGE The proposed prescriptions have no consideration for the forage/cover interrelationships - they are very questionable technically and wasteful in terms of timber productivity. Research information does not support the hypothesis that deer and elk require thermal cover for survival. (cites L.L. Irwin and Merril et al) New data found in the Mount St. Helens blast area make the standards and guidelines for big game too restrictive. It has been proven and used on other Forests that a 20-foot tall, closed canopy stand is all that is needed for deer and elk winter range. We do not agree that "thermal cover is considered to be the most critical component of big game winter range." Later research studies have shown that the quality of available forage is an equal, if not more, critical component. The MBS doesn't have the heavy snowfalls on low elevation lands that were anticipated when the optimal elk habitat definition was written. The distribution of cover/forage in the DEIS, that is 10% forage and as much as 90% cover, is a sure prescription for starvation of wild unglates. It seems intended to save old growth, not deer and elk. The DEIS would have us conclude that only the "Winter Range" of deer and elk is critical in the selection of a management plan alternative. There is no evidence presented in the DEIS that establishes the necessary habitat requirements for any forms of wildlife. It is imperative the Final EIS does so. Response: Habitat requirements and relationships for deer and elk on the Nt. Baker-Snoqualmie N.F. are based on Management of Wildlife and Fish Habitats in Forests of Western Oregon and Washington, USDA, Forest Service, Pacific Northwest Region, June 1935. Those areas that have been mapped as deer and elk winter range are identified as the most critical and necessary areas to assure maintenance of viability of both species within the planning areas. Brown et al, in Management of Wildlife and Fish Habitats in Forests of Western Oregon and Washington, find that deer would usually leave foraging areas for thermal cover when temperature dropped below 20 degrees F or rise above 60 degrees F. Additionally, elk were observed in the Cedar River leaving clearcuts for thermal cover when solar radiation exceeded 50% of maximum, or about 10:A.M. on clear days, especially during the hot summer months. In these conditions, the elk sought out the thermal protection offered by old growth stands over that of second growth stands. In order to provide the best opportunity for deer and elk on their winter range, the Forest inventoried areas of optimal thermal cover. "Optimal thermal cover is defined as a forest stand with: 1) Four layers (overstory canopy, sub-canopy, shrub layer, and 2) An Overstory canopy which can intercept and hold a substantive |