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Erika Lovejoy said at 4:40 p.m. on 27 February 2006 ,

The Draft Workplan was not available at the web link we were originally given, and was also not released until February 21st, thus these comments will be brief.

Thank you for the opportunity to comment on the SNAMP workplan. Please consider the following questions and comments:

(1) Is an external scientific peer review proposed? A scientific peer review is critical to ensure: 1) management questions are clearly articulated, and 2) the study design is adequate to answer the management questions posed. "Adaptive management" can only work if the study designs are capable of truly answering the management questions. We recommend peer review be conducted by a panel of at least three external scientists with no connection to the USFS (i.e., not using current consultants or those with financial or other potentially conflicting interests) and be incorporated in to the workplan.

(2) Our understanding is that your on-the-ground projects will not be conducted within the Lahontan Region, however the results will be extrapolated to this Region. It would be very useful if your study design considered Lake Tahoe conditions, and those of other sensitive Sierra Nevada ecosystems. Note that the Lake Tahoe Basin is a highly sensitive area and not all management approaches may be appropriate for this area in terms of both potential negative environmental impacts and related regulatory restrictions. However, resources managers are very interested in what management strategies could be applied in the Tahoe Basin for fuels hazard reduction projects, while still protecting water quality and habitat. SPLATS can be especially problematic. While they provide for fire protection, they do not allow for wildlife habitat and have bare soils, which maximize erosion potential. They are essentially barren land. Are other methods being explored that can restore forests in a way that can be beneficial to water quality, fire protection, biodiversity, and overall forest health? The study focus on SPLATS seems to be very limiting. Given the amount of fuels hazard reduction work that is expected to occur over the next decade (playing “catch-up” for work that hasn’t been done yet), it would be very useful if the study examined other techniques that will allow for a more balanced set of “future desired conditions”, which is a stated goal mentioned in your study proposal.

(3) Models are being proposed as an evaluation tool. It will be critically important that the limitations of these models be clearly presented, so the study results do not initiate the use of inappropriate management strategies, especially in sensitive regions like the Lake Tahoe Basin.

(4) It would be useful for the study to clearly define soil types and conditions where treatments were conducted, so the study results can be appropriately extrapolated to other geographic areas in the Sierra Nevada. For example, for the portions of the project area treated with mastication, we would be interested in knowing what soil types and conditions (slope, moisture, vegetation) were present, in addition to the overall study results showing the impacts to soils, water quality, vegetation, forest health, and fire protection.

Erika Lovejoy Environmental Scientist Lahontan Regional Water Quality Control Board 2501 Lake Tahoe Blvd South Lake Tahoe, CA 96150

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