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Old 03-10-2009, 05:27 PM   #1 (permalink)
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Post your technical comments on the proposed EA

here is a new version.

General:

On Page one of the EA you make the following statement:

“There is a need to stem the flow of sediment that is entering the Upper Tellico River and its tributaries from the OHV System, and thereby improve habitat for native brook trout.”

I disagree with this assertion. If we are truly trying to improve the habitat for the native brook trout then we need to be about the business of reducing the flow of sediment entering the Upper Tellico River period, regardless of the source. We should be considering all sources of sediment. This EA does not consider all the sediment sources. To properly evaluate the total impact to the fishery the environmental assessment, while studying the impact of the OHV system, must include the contribution of other sediment sources. You have made an assumption that the OHV activity in the watershed is the only source contributing sediment of significance.

In Chapter 3 of the EA you report data from various watersheds. You fail to evaluate each watershed for similarity to the upper Tellico watershed. You have reported data from other sub-basins but have not provided any analysis to determine if these basins as statistically similar in nature to the watershed in question. For example, you need to make a comparison of size, slope, soils, percent of private ownership vs. public, flow, management techniques, stream characteristics, rainfall amounts in each basin, etc. You should compare these factors weighted by area, by slope, by soils and combinations of each. The statistically evaluate similarities and differences to evaluate if the reference watershed is significantly similar to the watershed in question.

You indicate that you began a monitoring plan in 2008 to evaluate the impact of the OHV area and continue for 6 years. You have assumed 6 years to provide for 3 “bankful” events that you think occur every 1.5 to 2 years. It is not apparent, and you may not realize that a 2-year event can occur today and one two days from today or one may not occur for 10 years or longer. If you are serious about evaluating three 2 year events I suggest you review Hydrology and Sedimentology for Small Catchments by Barfield, et. al. 1986. Look specifically at work done by C.T. Haan on the probability of a certain storm event occurring in any given year. Dr. Haan developed a plot that will allow you to read a time period for your monitoring plan to have the highest probability that the given event will occur. I think you will be surprised at the results. As a result of this monitoring plan you have only reported two small storm events. It does not appear that your monitoring plan has been active long enough to provide enough data to develop a conclusion. Therefore, no decision should be until this monitoring plan is complete and the results properly analyzed and reported.

You have not provided a QA/QC plan or procedure document for the monitoring plan. For example, how will you verify that all the bubble tube samplers are functioning before a rain event? We do it by checking each sampler for blockage in the tube and pump function for taking the sample and flushing the tube, battery function, ice the sample bottles in the sampler, be sure the path way and access to the sampler is clear of debris and that the notification process is working such that when the sampler begins to sample your beeper is alerted. Please provide your qa/qc manual and procedures for review. You mention TVA will be doing the lab work. Are they an EPA certified lab for the pollutants you are testing? If not, the data is suspect and should not be used. You mention most of your equipment is borrowed. This makes me believe you do not know how to operate it. You only mention installation of one rain gage. This is not adequate by any means for 50 samplers. The proper procedure is to delineate subwatershed areas draining to each sampler and locate the gages using the Thiessen Polygon method for rain gage evaluation.

The manner in which you have reported the TSS and Turbidity measurements give the appearance that there is an impact due to the OHV system. This may not be the case if the data were properly analyzed. The proper reporting of the comparison between the reference watersheds is to report the values that are statistically significantly different. I suspect that when all the information is considered that none of the data from the OHV area are significantly different from any similar reference watershed. In addition, you fail to recognize the fact that turbidity is not a measure of sediment in the stream. EPA admits that turbidity is not a good measure of sediment in their proposed rules for Effluent Limit Guidelines for Construction Activities published in the Federal Register November 28, 2008. In this document they provide an example of the case where a high turbidity reading is obtained but no suspended sediment is found. EPA also recognizes that the converse can be true. In your data this is the case where you show a high TSS level for Bald River but a lower turbidity measurement. There are two data points you have reported in Table 3.1.1.4 that should make you question the conclusion you have drawn. Again the data is reported in such a manner that it is misleading and slanted to show an impact due to the OHV area. The same is true for the data presented in the appendix. All of this data should have been tested statistically to determine if there is significant difference between the sub-basins reported. This error must be corrected to reach the correct conclusion.

In Figure 3.1.1.3 you report turbidity measurements from a single storm event and appear to compare to the standard of 10 NTU. This is an incorrect application of the 10 NTU standards. This standard is not a storm event standard it is applicable to 7Q10 flows as per 15A NCAC 02B.0206 (a) (1). Please correct this error.

In Table 3.1.1.5 you report storm event data from 1999 to 2006 for the median values of TSS in mg/l. You do not include all of the reference sites. There were several large events (i.e hurricanes 2004) that will skew this information. It is important to include all the reference sites. The Citico Creek site does not appear to pass the test of similarity to the Upper Tellico site due to the ownership status. Please correct the reporting in this table. You have not reported the eroded particle size distribution of the sediment in the runoff you have sampled. I do not mean a primary particle size distribution I said an eroded particle size distribution. This is quite a difference. Soils in our region is detached by rainfall energy or runoff energy and transported by stream power. Depending on cation exchange capacity of soils (particularly highly erodible soils) they erode differently and react differently in suspension. Some soils form aggregate particles and will settle quickly in the flow path. Others will develop particles that repel one another and act as primary particles in suspension. Many times water chemistry can affect these chemical reactions and change the settling characteristics of the soils. Please report the eroded particle size distributions for the samples from all the watersheds so we can tell how the particles are reacting in suspension. This is one variable in the design of BMP measures to be sure the BMP performs properly. I doubt this information has ever been considered in design of BMP’s by the FS. This may be a factor why many of your BMP’s may not be functioning properly.

You have applied the Rosgen methodology for stream stability classification and tried to directly tie this classification to habitat improvement. Rosgen techniques were developed for western streams primarily receiving their runoff from snow melt. This is a completely different application than streams in the eastern and southeastern US. Streams like the ones in the Upper Tellico Watershed were developed to receive runoff from high intensity rainfall events with yearly totals of 50 plus inches. Many western streams where Rosgen techniques were developed only receive a fraction of the rainfall amounts that occur in the western North Carolina area. I object to the use of Rosgen methodology and recommend you use the tractive force and permissible velocity methods to determine stream stability.

Based on the results presented from the biological assessment it inconclusive at best the improvement to be achieved by selecting alternative C. You do not present compelling evidence that any improvement will occur by selecting this alternative. You indicate it is more likely that improvement may occur. This is hardly convincing enough to eliminate $4.8 million from the local economy or to assume a positive response from the trout population. Part of alternative C is to pave 5.3 miles of Trail #1. You fail to mention the drastic impact paving trail #1 will have on the trout waters. This will create impacts to the fishery from thermal pollution, increased volume and rate of runoff increasing conveyance degradation and sediment loads. By paving trail #1 you will increase traffic causing an increased loading of heavy metals, trash and fecal pollution discharging to the stream. Please include an analysis of the impacts of paving this trail as part of your EA.

You indicate that the major impact to the trout population and reproduction is the acid rain that falls on the watershed from atmospheric conditions. Based on my knowledge of monitoring we (my company) have done in urban areas of atmospheric deposition and rain water quality this should absolutely concern you by thousands of times more than the sediment deposition you claim to be destroying the trout reproduction.


Specific comments:

Section 1.1
1. Forest Plan standards for soil and water are being violated.
• Visible sediment standards are not part of the Federal Clean Water Act requirements nor part of a North Carolina standard. This is admirable as part of the Land and Resource Management Plan for Nantahala but, is not necessary for water quality compliance.
• You mention 1/3 of the 2000 visible sediment sources are reaching the Upper Tellico River. Please provide a location map of these sources and evidence that they are discharging sediment to the upper Tellico River or its tributaries. I am requesting this information as part of an FOI request.
• You mention that six miles of trails are within 25 feet of the stream. According to 15A.NCAC 02B.0104 (p) (1) this 25 foot buffer is 2.5 times the required buffer for forestry and agricultural activities.
4. North Carolina standards for turbidity are being violated.
• 15A NCAC 02B.0206 (a) (1) provides the flow criteria to apply all water quality standards for classification as 7Q10 flows. You have applied the turbidity standard to storm flows. This is in error and should be corrected. The standard of 10 NTU is a standard to be met in 7Q10 flow conditions not in storm events. No watershed in the region will meet this standard in a storm event including those without OHV activity. The data you report supports that this is the case.
5. Brook trout reproduction is being negatively affected.

• The following streams mentioned in the study are all meeting their classified uses as follows:
o Tipton Creek C,TR
o Bob Creek C,TR
o Mistletoe Creek C,TR
o Tellico River C,TR
o Peckerwood C,TR
o Round Mtn Br. C,TR
o Bearpen Br. C,TR
o Jenks Br. C,TR
• There is no indication by the NC standards that trout reproduction has been affected. Please present studies on trout reproduction numbers compared to one of the test watersheds used for comparison with no OHV areas. Without data to back up this claim please remove it from the EA. You mention in this section a number of things that can affect the trout population but provide no evidence of impact to the trout population.

2) Trail density is being exceeded.
• An allowable trail density by the Forest Plan is 25 miles for 8000 acres. I am not opposed to reducing the trail density to the required levels. However, we should be able to do this and maintain some significant challenge areas. Again, I believe a trail rotation plan will achieve this objective as well as protecting the fishery.




Section 1.4

Item1. a and b. The State Water Quality rules establish a 10 foot separation between the active disturbed area and the waterbody. You reference the NC Forest Practice Guidelines for Water Quality. These have no force and effect, they are guidelines. While these guidelines present some good ideas they are very vague and obscure. The fact is that the Tellico OHV system meets the requirement in the 15A NCAC 02B.0206. As a matter of fact and by admission in your EA exceeds the rule by 2.5 times.
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Last edited by YellowjeepCj; 03-12-2009 at 07:26 PM. Reason: new version 31209
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Old 03-10-2009, 08:22 PM   #2 (permalink)
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WOW. Good reading.
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Old 03-12-2009, 10:05 AM   #3 (permalink)
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here is one I just fired off-

I am concerned about some information that is, or shall I say that is not listed in the Environmental Assessment(EA) of the Tellico OHV system. In specific, I am talking about the paving of Tipton Creek trail(trail #1) that is in all alternatives, except for Alternative A.

According to the EA, Tipton Creek trail is 5.3 miles long. One full mile of Tipton Creek trail is within 100' of a mapped stream and over 70% of that mile is within 25' of a mapped stream. Nowhere in the EA is anything said about the process of actually paving Tipton Creek trail. Nowhere in the EA are the negative effects of what this paving will do to this area. This is blatant attempt at leaving out the full effects of all of the alternatives and needs to be changed.

Asphalt is a petroleum based product and will increase the petroleum hydrocarbons in the area. Where is the study on what direct and indirect effects this will have on the area? What are the cumulative effects the paving and the paving equipment will have on the area? How will the paving process be able to not destroy a large amount of vegetation and negatively affect the soil and water quality when almost three quaters of a mile will be paved within 25' of a mapped stream?

I demand a full study done on the effects of paving Tipton Creek trail before and Alternative is chosen.
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Old 03-12-2009, 11:00 AM   #4 (permalink)
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an earlier one-

I am in particular wanting to talk about some of the results from the Environmental Assessment(EA). I have thoroughly read the EA and have found several issues with it. One being the reporting of the impact the OHV trails have on the auquatic population. As stated from page 66 of the EA,-


Based upon the available monitoring data from the Upper Tellico River watershed and data from other fisheries research, the sediment loading that is coming from the Tellico OHV System is likely to be having a negative effect upon brook trout reproduction. These findings are consistent with studies of salmonids across the United States (Furniss et al 1991, Waters 1995).


The key word here is 'likely.' The EA is stating that this is not definitive information, but 'likely' information. And these findings are consistent with other studies across the U.S. In other words, this happened somewhere else before so it is 'likely' to have happened here also. This study was not done as thoroughly as it should have if all of this is based on information that is 'likely' to be true.

Also, on page 67 this was stated-


NCWRC monitoring indicated that the age-0 fish densities and standing crops for rainbow trout and brown trout in the Upper Tellico River were considerably lower than the reference sites (Besler et al. 2007). Although the sample size is small for each site, the Tellico River sites appear to have lower densities of age-0 rainbow trout and brown trout than any of the other North Carolina sites. No data were gathered during this monitoring to determine the factors affecting the rainbow trout or brown trout population numbers.


I have two issues with this statement-

A. According to the statement the sample sizes of the Age-0 rainbow trout and brown trout were too small. How can you make determining factors on sample sizes that the EA even admits are too small?

B. The Tellico river sites 'appear' to have lower densities of Age-0 rainbow trout and brown trout than any of the other North Carolina sites. How did this 'appear'? Where are the actual findings? The EA states that no data were gathered during this monitoring to determine the factors affecting the rainbow trout and brown trout populations. If you have no data on this, how can you determine how this affects the rainbow trout and brown trout population?

There is a lot of information in the EA that seems rushed, assumed, and vague. I cannot believe that a study like this that will have so much impact on so many people and such a big area should be this inconclusive. Please take the time and evaluate my statements above.
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Old 03-12-2009, 11:01 AM   #5 (permalink)
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and-

On page 126 there is a chart displaying perceived impacts of OHV use to certain resources. In the chart it breaks down the various types of OHV users and their input on the impacts of water quality, vegetation, soil and wildlife. Anglers were asked about the impacts on water quality only.
For a survey to be conclusive, all participants need to be asked the same questions or these findings are irrelevant. Since this survey is inconclusive, this says little about the rest of the surveys.
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Old 03-13-2009, 12:01 AM   #6 (permalink)
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Wow...nice work, guys.

As a non-biased question which will certainly be raised - how does the independent study comissioned by SFWDA stand up to this kind of review?

I've read most of it, and it seems like things are handled very competently by the group that did the study, but being that it isn't my area of expertise I'm just sorta curious.
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Old 03-13-2009, 07:23 AM   #7 (permalink)
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does anyone have a link the Forest Plan for NC National Forests?

edit: found it

http://www.cs.unca.edu/nfsnc/nepa/na..._amendment.pdf

Read #1, #2, #8 & #10

edit 2: MOAR!! Tabe III-47 (page 53/318) Insure road stability and protection of the environment, except, existing four wheel drive ways may not be in full compliance with water quality standards. Develop startegies to bring these roads into compliance unless physical conditions preclude complete correction and the road cannot be legally closed. Schedule implementation consistent with funding.

edit 3: III-54 (page 60/318) Emphasize motorized recreation use.

This plan is chalked full of good stuff for us to use. Multiple times so far I've read that ORV use is to be maintained and managed. If they close this place down they might as well bend over and get ready to take it hard. They're going against they're own Forest Use Plan!
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Old 03-13-2009, 09:26 AM   #8 (permalink)
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Quote:
Originally Posted by McCracken View Post
does anyone have a link the Forest Plan for NC National Forests?

edit: found it

http://www.cs.unca.edu/nfsnc/nepa/na..._amendment.pdf

Read #1, #2, #8 & #10

edit 2: MOAR!! Tabe III-47 (page 53/318) Insure road stability and protection of the environment, except, existing four wheel drive ways may not be in full compliance with water quality standards. Develop startegies to bring these roads into compliance unless physical conditions preclude complete correction and the road cannot be legally closed. Schedule implementation consistent with funding.

edit 3: III-54 (page 60/318) Emphasize motorized recreation use.

This plan is chalked full of good stuff for us to use. Multiple times so far I've read that ORV use is to be maintained and managed. If they close this place down they might as well bend over and get ready to take it hard. They're going against they're own Forest Use Plan!
Good stuff Nick. The Forest Plan is now in the hopper for weekend reading.
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Old 03-13-2009, 11:40 AM   #9 (permalink)
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Anybody got any brook trout population numbers for the past few years?
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Old 03-13-2009, 01:09 PM   #10 (permalink)
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Some issues with the 'Details of Other OHV Opportunities' table from page 191. This is not what I sent them, just my feelings, I am in the middle of formulating a formal letter about this.

It is stated that there are 584 miles of OHV trails within an 8 hour drive of Murphy, N.C.

This is pure bullshit! apples and oranges to me. I just got of the phone with Jim Lane at the Prentice Cooper State Forest(PCSF) in Tn. In the table on p. 191, PCSF is listed as having the second most amount of trail mileage within an eight hour drive of Murphy. Mr. Lane confirmed that the PCSF has over 100 miles of OHV trails, or as he calls them, 'jeep' roads. I specifically asked him about challenge areas and he said, 'there are no challenge areas or rock-crawling or anything like that.' Further reading on the PCSF website states that all roads that OHVs travel are also open to ATVs, motorcycles, bicycles and horses. But yet the table lists the PCSF as having 'most difficult or challenge' trails. This table is full of shit just like the rest. The information in this table is biased and obviously false! It was put together to try to show that OHVers have other options other than Tellico and it is wrong.

How many people would take days off of work, spend tons of money on gas to travel to PCSF to ride on gravel roads along with horses and bicycles?
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Old 03-13-2009, 02:06 PM   #11 (permalink)
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Good work sungoesdown!

Here's my first letter about the Forest Plan. More to come.


Quote:
The Forest Plan (amended 1994) correctly calls for protection of environmental resources, specifically water quality. But that same Forest Plan also provides an exemption for OHV trails that may not meet water quality standards. The specific text from Table III-47 is excerpted here: Insure road stability and protection of the environment, except, existing four wheel drive ways may not be in full compliance with water quality standards. Develop strategies to bring these roads into compliance unless physical conditions preclude complete correction and the road cannot be legally closed. Schedule implementation consistent with funding.
If OHV trails do not meet current water quality standards then it is incumbent upon the Forest Service to work towards the goal of a properly managed trail system according to the guidelines of their own regulatory framework. I would suggest an incremental approach to management, rather than an abandonment of all pretenses of management.

Additionally, the proposed “Alternative C” would be in direct contradiction to Table III-11 and the Forest Wide Direction which dictates that the Forest Service shall “provide recreational riding opportunities for use by vehicles commonly classified as off-road vehicles (ORVs) on designated routes within established ORV areas…includes Upper Tellico.” The trail system is already established and the Forest Service has the responsibility to manage and maintain that trail system. Any trail closures would violate this Dispersed Recreation Management Directive.

Finally, the Forest Goals represent a noble attempt by your predecessors to protect “multiple use…across interests”, to “meet the livelihood and recreation needs”, to “improve economic prosperity of local communities, the region and the nation”, to “provide for a variety of recreation activities” and to “use facilities to the highest level of access practicable”. These are all clearly spelled out in Forest Goals 1, 2 and 8 and they should be reviewed prior to making a final decision.

But most of all, Forest Goal Number 10 is to “facilitate discussion among interests and enlist them in joint problem solving”. I would like to respectfully submit that this goal has been completely eschewed following the initial threat of a lawsuit by the SELC and others. Instead, we are presented with a “preferred alternative” that satisfies the loftiest desires of one interest group (trails available only to fishermen) while criminalizing another interest group.
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Old 03-13-2009, 02:09 PM   #12 (permalink)
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SUBJECT: COMMENTS ON THE UPPER TELLICO OHV AREA

To whom it may concern,

I would like to diect your attention to this article on a study from the Smitsonian Instition:

http://www.sciencecentric.com/news/a...php?q=08013034

The article reads as follows:

"Smithsonian study: Sediment prediction tools off the mark

A recent study led by Smithsonian ecologist Kathy Boomer suggests it is time for a change in at least one area of watershed management. Boomer has been examining the tools scientists and managers use to predict how much sediment runs into the Chesapeake Bay, and by her account, they are way off the mark. The study, co-authored by SERC ecological modeller Donald Weller and ecologist Thomas Jordan, appears in the January/February issue of the Journal of Environmental Quality.

Sediment running into the bay reduces light, suffocates underwater organisms and is a significant source of phosphorous, a nutrient that essentially fertilises the water promoting algal blooms and many other problems in the bay.

'Cities and counties are under increasing pressure to meet total maximum daily loads set by state and federal agencies and to understand where sediments come from,' she said. 'So we tested the tools most widely used now to predict sediment delivery.'

Her work has led to a new tactic. 'We're moving away from focusing on upland erosion and looking more at what happens near streams and in streams during events with high levels of stream sediments.'

The new study compared actual measurement of sediments in more than 100 streams in the Chesapeake watershed with predictions from several of the most up-to-date models. All the models failed completely to identify streams with high sediment levels.

'There was no correlation at all between the model predictions and the measurements,' said Boomer. The study is among the first to directly compare predictions of the widely used models with actual observations of sediments in a large number of streams.

The problem, she said, is that the most widely used models all begin with the same tool, the Universal Sediment Loss Equation. The USLE estimates erosion from five factors: topography, soil erodibility, annual average rainfall amount and intensity, land cover, and land management practices. Boomer emphasised that the USLE was developed to help farmers limit topsoil loss from individual fields rather than to predict sediment delivery from complex watersheds to streams.

As often applied, the USLE gives an average annual erosion rate for the whole watershed draining into a stream. But not all of the eroded soil makes it into the water, so the estimates do not translate directly into sediment delivery rates. To account for the discrepancy, different models incorporate a wide variety of adjustments. According to Boomer, the adjusted models still do not work, partly because erosion rate is not the best information to start with.

During the study, Boomer and colleagues Weller and Jordan compared erosion rates and sediment yields estimated from regional application of the USLE, the automated Revised-USLE, and five widely used sediment delivery ratio algorithms to measured annual average sediment delivery in 78 catchments of the Chesapeake Bay watershed.

'We did the same comparisons for an independent set of 23 watersheds monitored by the U.S. Geological Society,' Boomer said.

Sediment delivery predictions, which were highly correlated with USLE erosion predictions, exceeded observed sediment yields by more than 100 percent. The RUSLE2 erosion estimates also were highly correlated with the USLE predictions, indicating that the method of implementing the USLE model did not greatly change the results.

'Sediment delivery is largely associated with specific rain events and stream bank erosion,' she said. 'So, USLE-based models that emphasise long-term annual average erosion from uplands provide limited information to land managers.'

With a new focus on what is happening in and near the streams themselves, Boomer and her colleagues hope to develop more reliable tools to predict sediment running into Chesapeake Bay - tools that can be used in other lakes and estuaries as well.

Source: Smithsonian Institution"

Based on this up to date study, the Universal Sediment Loss Equation exceeded observed sediment yields by more than 100 percent. Therefore the prediction of how much sediment dumped into Upper Tellico could be vastly over-exaggerated and they provide limited information.

Therefore, the entire Tellico area could be closed due to bad science. The Enviromental Assesment needs to be rewritten and the methodlogy used to measure the amount of sediment dumped into local waters needs to be re-visited and re-esablished.

At the very least, the Enviromental Assessment needs to add wording to it that the information listed on the amount of sediment COULD be greatly exaggerated.

Sincerely,

Kurt Schneider,
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Old 03-13-2009, 02:10 PM   #13 (permalink)
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great job on the research. that's what I'm working towards. finding data that has been falsely used and throwing it back in their faces. lots of time the regs are subject to interpretation and their's is not always the final say.

I'm finding some good stuff in these plans but I need a good brook trout survey to help me finish the one two punch.
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Old 03-13-2009, 02:15 PM   #14 (permalink)
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Quote:
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I'm finding some good stuff in these plans but I need a good brook trout survey to help me finish the one two punch.
There should be a few in that uh...yeah......"special place"

You gotta change the bottom of the forum though where you can see back father becuase the posts were about 3-4 months ago. All sorts of shit on brookies.
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Old 03-13-2009, 02:33 PM   #15 (permalink)
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I wrote a long winded response and forgot what I was doing and clicked a link for a reference and lost it all. What I was hoping for was a graph or chart that showed young of the year data. I remember at the open house where they showed trout populations increasing in 2008 from the past 2 years. Thus proving that populations trends are cyclical.

Also in the FS's Indicator Species list from 2005 they say brookies can be used to Help indicate the effects of management on a portion of coldwater streams. They know they aren't the end all be all and that supports the benthic study by Caliber saying the streams are healthy.

I'm just trying to fin the thread to tie it all together. My research is getting good though.
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Old 03-13-2009, 02:44 PM   #16 (permalink)
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SUBJECT: COMMENTS ON THE UPPER TELLICO OHV AREA

To whom it may concern,

Once again I would like to direct your attention to the study by Kathleen B boomer, Donald E Weller and Thomas E Jordan, entitled "Empirical Models Based on the Universal Soil Loss Equation Fail to Predict Sediment Discharges from Chesapeake Bay Catchments"

This study was from the Smithsonian Environmental Research Center, Edgewater, MD 21037-0028

Here are the conclusions from that study:

"We implemented seven variations of USLE-based models to estimate erosion and sediment delivery, but none provided a reliable tool for assessing sediment discharge from 101 catchments where stream water quality was monitored continuously for at least 1 yr. Our results reinforce previous arguments that USLE-based sediment delivery models provide an inadequate framework for managing land and water resources at the catchment scale (Kinnell, 2004a; Trimble and Crosson, 2000a, b). The USLE was not intended to predict effects on stream water quality, yet the models continue to be widely applied at the catchment scale by scientists (e.g., Boellstorff and Benito, 2005; Fu et al., 2005; Kim et al., 2005; Onyando et al., 2005; Wang et al., 2005), policymakers (e.g., Donigian and Bicknell, 2006; USEPA, 2005), and watershed modelers.
Our review of published statistical models and the poor performance of our own empirical model in a validation attempt with independent sediment yield data also suggest that many other non-USLE empirical models developed to predict annual sediment yield (Table 7) may be unreliable. First, a comparison of published statistical models revealed contradictions in the attribution of sediment delivery to land cover versus physiographic factors. Second, the disappointing performance of our model in the validation with independent data highlights the danger of relying on empirical models that have not been tested with a validation dataset.
Our findings also suggest some directions for future research on predicting sediment discharge in ungauged drainage basins: (i) Identify potential predictor variables that conceptually link landscape and stream characteristics to flow velocity, stream power, and the ability to transport sediment; (ii) incorporate metrics to indicate potential sediment sources within streams, including bank erosion and legacy sediments; and (iii) develop predictions for temporal scales finer than the long-term annual average time frame. Consistent and verifiable results from additional empirical studies will also help reduce the uncertainty in the predictions of process-based, integrated simulation models."

In that conclusion it states:

"Our results reinforce previous arguments that USLE-based sediment delivery models provide an inadequate framework for managing land and water resources at the catchment scale"

and

"The USLE was not intended to predict effects on stream water quality, yet the models continue to be widely applied at the catchment scale by scientists (e.g., Boellstorff and Benito, 2005; Fu et al., 2005; Kim et al., 2005; Onyando et al., 2005; Wang et al., 2005), policymakers (e.g., Donigian and Bicknell, 2006; USEPA, 2005), and watershed modelers."

If the USLE is NOT intended to predict the effects on stream water quality, then this entire Enviromental Assesssment is based on faulty science. How can the forest service close an area if they are not completely sure about the amount of actual sediment?

Futhermore, how can you attribute ALL sediment from OHv usage?

A new study needs to be completed. Futhermore, the Enviromental Assement needs to address the posiblity that the figures on sedimentation maybe greatly exaggerated.

Sincerely,

Kurt Schneider,
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Old 03-13-2009, 02:47 PM   #17 (permalink)
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great job on the research. that's what I'm working towards. finding data that has been falsely used and throwing it back in their faces. lots of time the regs are subject to interpretation and their's is not always the final say.

I'm finding some good stuff in these plans but I need a good brook trout survey to help me finish the one two punch.

There is a lot of good info here- http://www.easternbrooktrout.net/doc...eportfinal.pdf

Like the fact that they state that yeah, the water got bad because of logging and bad land management, and the brook trout population went down. That is when the brown trout and rainbow trout were introduced. As time went on and the water quality and environment repaired itself, the brookies had to compete with the non-native fish, i.e. brown and rainbow trout.

Most remaining highquality trout habitat is occupied by non-native fish. Rainbow trout are specifically recognized as a threat to brook trout in over 70% of the subwatersheds with brook trout data in these states.

So the decline of the brook trout is directly related to the importation of the brown trout and the rainbow trout.
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Old 03-13-2009, 05:17 PM   #18 (permalink)
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This is good stuff. Keep up the great work. We need a biologist/environmental scientist to look at the work done by Western Carolina and pick it apart. We also need a economist to review the economic data the FS presents.
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Old 03-17-2009, 08:58 AM   #19 (permalink)
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Hey folks. I have already submitted a letter focusing on the economic impact to Tellico. I'm a newb when it comes to environmental stuff, so I'm hoping to use this thread to ask some (hopefully not stupid) questions of you folks about the EA as I read through it. I also haven't been able to get to Tellico yet, so I'm not familiar with the trails. I understand I won't be able to put together a letter as nice as the ones previously posted, but I'm still trying to do my part.

My first questions deal with Table 3.1.1.1 on page 24 of the document (28 of the PDF file). It involves results from soil contamination testing of some high challenge areas.

The section only mentions that ten sites were found to have levels above NCDENR action levels, but it does not mention how many total sites in the OHV trails were tested.

I happened to notice that there are no detectable traces of gasoline, but there are very high concentrations of diesel. Are gasoline hydrocarbons sometimes detected as diesel?

Assuming "no" to the previous question and given that most OHVs are gasoline based, would it be realistic to assume that the high concentration of diesel can be attributed to the logging vehicles that passed through the area years ago? Or are these areas not close to the former logging trails?

Given the high concentrations of oil/grease, are these points even worth mentioning in a letter?

I appreciate the input given that this EA is a lot of information for an untrained person like me to take in and pick apart during a relatively short amount of time.
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Old 03-17-2009, 10:43 AM   #20 (permalink)
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Hey folks. I have already submitted a letter focusing on the economic impact to Tellico. I'm a newb when it comes to environmental stuff, so I'm hoping to use this thread to ask some (hopefully not stupid) questions of you folks about the EA as I read through it. I also haven't been able to get to Tellico yet, so I'm not familiar with the trails. I understand I won't be able to put together a letter as nice as the ones previously posted, but I'm still trying to do my part.

My first questions deal with Table 3.1.1.1 on page 24 of the document (28 of the PDF file). It involves results from soil contamination testing of some high challenge areas.

The section only mentions that ten sites were found to have levels above NCDENR action levels, but it does not mention how many total sites in the OHV trails were tested.

I happened to notice that there are no detectable traces of gasoline, but there are very high concentrations of diesel. Are gasoline hydrocarbons sometimes detected as diesel?

Assuming "no" to the previous question and given that most OHVs are gasoline based, would it be realistic to assume that the high concentration of diesel can be attributed to the logging vehicles that passed through the area years ago? Or are these areas not close to the former logging trails?

Given the high concentrations of oil/grease, are these points even worth mentioning in a letter?

I appreciate the input given that this EA is a lot of information for an untrained person like me to take in and pick apart during a relatively short amount of time.

Very good catch! Some things that I'd ask and comment about:

1) What method did they use to test? Also did they delineate the extent of the contamination to determine if the trails themselves were the only area of contamination? If they only took grab samples in the area of the trails, that does not prove that OHV use is to blame for increased levels. What about the logging trucks that were used in the past?

2) Most of the rigs up there use gasoline. Why the high diesel numbers? And, in speaking with somoene here ar work that knows a lot more than I do about this stuff, it takes a shitload of diesel to get down to 3-4 feet. It's not just about a truck breaking down.

3) How did they take these samples? All they would have had to do is look around and find stains on the ground and pick those areas to sample. It looks to me (and to the guy at work) that they biased the data to get a screaming hot result by collecting only in areas where there was visable staining.

4) How did they get these samples? I know that I have been to Trail 2, 9, and 7. I know they didn't get a drill rig up there. And, last I checked, the whole area is ROCK. That's why we like it. How did they hand dig down to 4 feet in rock.

5) The other thing we thought of is that oil and grease are not very mobile in the environment. The proability of oil and grease getting down to 3-4 feet is very slim....VERY slim. But the probablity of the yahoos who took the samples not decontaminating their augers and what not in between samples is VERY high. So we should say that we question the collection and decon methods.

I'll probably think of more...
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Old 03-17-2009, 10:47 AM   #21 (permalink)
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This is good stuff. Keep up the great work. We need a biologist/environmental scientist to look at the work done by Western Carolina and pick it apart. We also need a economist to review the economic data the FS presents.
Yep...we are on that. But, anything that folks can pull out as not making any sense is still good.
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Old 03-17-2009, 11:18 AM   #22 (permalink)
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This was my response to Page 24

On page 24 table 3.1.1.1 it shows contamination testing results. For the most part it shows diesel fuel is a lot higher then gasoline. For this table to have any merit it should also have a table that shows the % of OHV that run on diesel, % of OHV that run on gasoline, % of OHV that run on propane, % of OHV that use other alt. fuels. It should also include all the other vehicles and equipment either there fuel source. Either this needs to be done correctly or this needs to be deleted from the EA
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Old 03-17-2009, 08:24 PM   #23 (permalink)
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I really like the biology assessment presented by Caliber in the SFWDA study. It is much more powerful that the FS/Western Carolina presentation. Suggest we have the Claiber folks review the fS/Western Carolina presentation and make comments.


The table 3.1.1.1 on the hydrocarbons is interesting. I am guessing they have sampled ares that show visible stains of fluids on the surface. As far as Trail 2 I think it was recently used for a private land logging operation. We need to FOI the actual locations of sampling, chain of custody records for the samples (could be contaminated sample bottles), sampling methodology, lab sheets, field sampling equipment, field and lab qa/qc procedures and epa lab certifications and approvals, calibration records on the lab equipment. If they can't provide by the 30th ask for an extended comment period to review this data. Who knows maybe there is oil under Tellico!
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Last edited by YellowjeepCj; 03-17-2009 at 08:39 PM. Reason: added discussion on hydrocarbons
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Old 03-18-2009, 08:32 AM   #24 (permalink)
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The table 3.1.1.1 on the hydrocarbons is interesting. I am guessing they have sampled ares that show visible stains of fluids on the surface. As far as Trail 2 I think it was recently used for a private land logging operation. We need to FOI the actual locations of sampling, chain of custody records for the samples (could be contaminated sample bottles), sampling methodology, lab sheets, field sampling equipment, field and lab qa/qc procedures and epa lab certifications and approvals, calibration records on the lab equipment. If they can't provide by the 30th ask for an extended comment period to review this data. Who knows maybe there is oil under Tellico!
I requested a copy of the report yesterday. Don't know when I'll have it, but hopefully soon.
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Old 03-22-2009, 01:57 PM   #25 (permalink)
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May find some useful info resources here as well about the restoration of Brook Trout --> http://www.easternbrooktrout.org/doc...tion_FINAL.pdf
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