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Comment on the Forest Service’s proposal to replace culverts and bridges using a categorical exclusion

The Forest Service has proposed culvert replacements in an area that significantly overlaps with the Lolo Insects and Disease timber sale, which the Forest Service approved last month. Some of these proposed culvert replacements are along proposed log hauling routes connected to the timber sale and some of these culvert replacements are close to or within steelhead critical habitat. The agency is trying to push this overlapping project through by skipping public comment and with no environmental analysis. We’ve provided talking points for your unique public comment.

The Forest Service has demonstrated how the new NEPA regulations might look by exclusively selecting entities to comment on several culvert replacement projects in the Nez Perce-Clearwater National Forest. Recently, the Forest Service contacted Friends of the Clearwater and just two other entities (a tribe and one other environmental organization) for scoping comments on culvert replacements in the Nez Perce-Clearwater National Forest. The Forest Service is proposing these replacements under a categorical exclusion, a category of action that requires no environmental analysis because the activity cannot possibly have an individual or cumulative effect on the environment. When we asked whether the agency was planning to issue a scoping notice to the public, the employee who reached out said, “We are not planning to issue a scoping letter through the newspaper of record as the project is straight forward and we have received little in the way of comments (other than support) on previous culvert replacement projects. The email we sent therefore constitutes the limit of our scoping process.” 

The Forest Service has excluded you, the public, from comment. Because the public owns this land and the Forest Service has cut you out of the NEPA process, we pass this information to you and encourage you to lodge your comments on being excluded as well as substantive comments on these categorical exclusions. 

The map the Forest Service emailed to us has three separate project areas. While we think the public should consider and comment on all of the areas, we highlight the alarming issues with the third culvert proposal in the Lolo Creek drainage. The approximate 22 culvert replacements planned in the Lolo Creek drainage substantially overlap with roads and threatened fish critical habitat in the Lolo Insects and Disease Project — a massive timber sale that the Forest Service approved just a month and a half ago. When the Forest Service approved that timber sale, the agency disclosed and analyzed approximately 21 culvert replacements. The Forest Service also consulted with the National Marine Fisheries Service (NFMS) on those replacements because the replacements were in critical habitat for steelhead, which is listed as a threatened species under the Endangered Species Act. With the proposed categorical exclusion, the Forest Service plans to add 22 more culvert replacements in the project boundary (doubling total culvert replacements in the area) and along roads the Forest Service plans to haul timber from the Lolo timber sale. Below are map excerpts from the Lolo Insects and Disease Project Record of Decision next to the new proposed culvert replacements. The side-by-side comparison illustrates that the new culverts were not in the original project and that some appear suspiciously close to log-hauling routes. 

Above left: Excerpt of Figure 6 (“Map of Road Decommissioning, Storage, and Culvert Replacements”) from the Lolo Insects and Disease Record of Decision, pdf p. 56. 

Above right: Excerpt of map the Forest Service emailed to us for the culvert replacements that the Forest Service has proposed as a categorical exclusion, asserting that the project cannot possibly have an impact on the environment. 

Above left: Excerpt of Figure 4 (“Map of Eldorado Creek Harvest Sites and Haul Roads”), from the Lolo Insects and Disease Record of Decision, pdf p. 52.

Above right: Excerpt of map the Forest Service emailed to us for the culvert replacements that the Forest Service has proposed as a categorical exclusion, asserting that the project cannot possibly have an impact on the environment. 

NEPA prohibits the Forest Service from breaking connected projects up to avoid environmental analysis. And, the Forest Service should have disclosed to the public and the National Marine Fisheries Service these newly proposed culvert replacements. 

Does this proposal seem fishy? Alarming? Submit a comment in your own words! Unique comments are more powerful than form letters!

Some points to raise when you comment:

* Demand a public scoping period under NEPA, and let the Forest Service know what you think the agency circumventing public comment to do these culvert replacements. 

* Demand more information on this project.

* Inform the Forest Service that the culverts are in steelhead habitat and the agency should be consulting with the National Marine Fisheries Service on these new proposed culverts.

* Emphasize that NEPA prohibits breaking up connected projects. The culverts along haul routes should have been included in the Lolo Insects and Disease environmental impact statement.

* Because these new culvert replacements were not analyzed with Lolo Insects and Disease, and they should have been, tell the Forest Service that it should be withdrawing the decision for that timber project and re-analyzing the impacts of 22 additional culvert replacements in a supplemental environmental impact statement for the Lolo Insects and Disease Project. 

Open a comment period for culvert and bridge replacements on the Nez Perce-Clearwater National Forest

Hello Supervisor Probert, Ms. Smith, and Mr. Knapton,

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