appendix f: response to scoping commentsa123.g.akamai.net/7/123/11558/abc123/forestservic... · 25....

Mesabi Project Environmental Assessment

Laurentian Ranger District 1 Appendix F

APPENDIX F: RESPONSE TO SCOPING COMMENTS

1. Mark Belpedio/Paul Stanaway-Camp GRUMP P, LLC. 25. Dan McDonald

2. Tim Berrini 26. Ann Oelrich

3. Paul Borg 27. Dorothy Oie

4. Dennis Carlson 28. Richard Pakkala

5. Steve Cerkvenik 29. Donald Peterson

6. Annah Gardner-Sierra Club 30. Mark Pohto

7. Karen Hemphill 31. Mark Prchal

8. Robert Hopper 32. Carl Racchini

9. Kristian Jankofsky 33. Steve Racchini

10. Al Jarvinen 34. Kyle Rahikainen

11. Nolan Johnson 35. Rian Reed-MN DNR

12. Alex Jokela 36. Kristi Rolf

13. Steve Kamunen 37. Brad Sagan-Sierra Club

14. Steve Kernik 38. Scott Schultz

15. Mike Kochevar 39. Michael Smith

16. Allan Lambert 40. Steven Smokey

17. Mike Madden 41. Pat Snyder

18. Clay A Mariucci 42. Franklin Sterle

19. Clint Mariucci 43. Walt Sweeney

20. Mark Mariucci 44. Darren Vogt-1854 Treaty Authority

21. Richard Mariucci 45. John Vukmanich

22. Wesley Mattonen 46. Floyd Weappa

23. Jim McCarty 47. Joyce Zimmerman

24. Bob McDonald 48. Rebecca Zimmerman-Nomeland

Table F-1: People Who Submitted Comments on the Mesabi Project Scoping Report



All comments received on the Mesabi Project were reviewed by the interdisciplinary team and district ranger. The following explains how public comments were categorized and addressed. Categories of comments include:

1. Issues Considered in Alternatives: An issue is a point of debate with a proposed action based on some anticipated effect(s). Issues may drive alternatives based on extent of geographic distribution of effects, duration of effects, and intensity of interest or conflict generated. Alternatives are other reasonable courses of action or mitigation measures not included in the proposed action (40 CFR 1508.25 (b)). Alternatives may be based on key issues or may be suggested by the public during scoping. The EA describes which alternatives will be analyzed in detail or analyzed briefly and eliminated from further study.

2. Other Issues: Other issues were considered but not analyzed in an alternative. Issues that were not analyzed in an alternative may already be addressed in the existing range of alternatives, be limited in the extent of geographic distribution of effects, duration of effects, and intensity of interest or conflict generated; or may be already addressed by law, regulation, or forest plan direction. However, in many cases, effects related to issues identified in this category are analyzed in the EA.

3. Beyond the Scope: Comments that raise issues that are beyond the scope of the Mesabi Project and would not be relevant to meeting the purpose and need.

4. Non-issue Comments and Questions: Non-issues are comments that do not debate possible effects of the proposed activities. They may be questions, asking for more clarification of the proposed action.

5. Comments Noted: Some comments are statements of opinion or preference about the proposed actions. These are considered by the interdisciplinary team and provide information on individual and group values and preferences relating to this project. However the scoping process is not a vote and comments are not used in that manner.

CATEGORY #1: ISSUES CONSIDERED IN ALTERNATIVES HERBICIDE

Comment MS-006-1 (Annah Gardner-Sierra Club): “Use of Herbicides-The Sierra Club agrees with the general direction of vegetation management proposed to replace aspen with other species and to adapt to anticipated climate change. Sierra’s concerns are more specific especially the proposed use of herbicides and reliance on clearcutting. Sierra North Star’s general position is to oppose the use of herbicides in vegetation management. This is especially true when alternative treatments are available. Herbicide use is proposed to “free up funds” for other project uses (Herbicide Treatment Attachment 7, p. 1). Cost containment should not be a consideration when herbicides are involved. Alternative treatments should be analyzed in the EA and their use evaluated independent of cost considerations. 1,858 acres of herbicide treatment is far too much for 14,222 total treatment acres. The sheer scale of proposed treatments increases the probability that harmful effects will result. The potential effects of herbicides are further multiplied by their application to numerous relatively small plots (less than 100 acres) where spread to surrounding areas is likely.



The Project proposes a number of possible preventive measures to counter potential effects of herbicide use. For example, “Direct dietary exposure of fauna to the proposed herbicides would be minimized by choosing less desirable foraging sites, and season of application.” (Attachment 7, p.3) How will the project avoid “less desirable foraging sites”? The potential sites have already been selected. “If any TES species are observed during implementation of control activities (other than raptors flying by overhead or a wolf passing by), work would stop until the District Wildlife Biologist is consulted.” (Attachment 7, p.5) These measures are unlikely to be utilized effectively in a project of this scale involving widely dispersed sites. Toxic chemicals cannot be used to promote diverse, productive, healthy native forest communities. Herbicide treatments have the potential to cause damage to water resources, sensitive species, and their habitats. Proposed mitigations appear inadequate. Sierra concludes that herbicide use should be sharply curtailed in Mesabi in favor of mechanical treatment. Cost containment should not be a factor in choosing a treatment option.” Comment MS-007-1 (Karen Hemphill): “I am writing as I have received and reviewed the proposal for the Mesabi Project Area, File Code 1900. I am a property owner in the vicinity of this project. My comments are that I am opposed to the Mesabi Herbicide Proposal everywhere you are proposing to use these chemicals. I am adamantly opposed to the use of chemical herbicides. Please see the attached report from the Scientific American which labels glyphosphate as probably carcinogenic to humans. The World Health Organization also categorizes glyphosphate as probably carcinogenic to humans and as “definitely genotoxic". If you believe these chemicals are harmless to the environment, humans and animals, you are seriously delusional. I would like to go on record as being opposed to the use of these chemicals and would propose manual removal. Please reconsider the use of these chemicals: glyphosphate, triclopyr and Sulfometuron Methyl and find another method to remove the vegetation that you are trying to control. There are enough unemployed people that I would think you could come up with another solution such as manual removal using labor or machines. Cost is not the only issue to consider, but the long term effects of the carcinogens that you are using. I am appalled that you would even consider using these chemicals. Please keep me advised. I am surprised that you are more concerned with your carbon footprint and managing your mailing list than the chemicals that you propose in this project. What are you thinking??”

http://www.scientificamerican.com/article/widely-used-herbicide-linked-to-cancer/ http://www.gmwatch.org/news/latest-news/16302-glyphosate-damages-dna-says-world-health-organisation-expert Comment MS-036-4 (Kristi Rolf): “Comment 4. Although nothing was said about #292 and #293 being treated with herbicide, I would not support any current OR future herbicide treatments on #292 and #293 as this is a highly populated area with lakes and wetlands on and near #292 and #293.” Comment MS-037-2 (Brad Sagen-Sierra Club): “Magnitude of Proposed Herbicide Use As best Sierra can determine, the magnitude of proposed herbicide use in Mesabi is unparalleled in USFS, certainly in Region 9. (HERBICIDE USE SUMMARY FOR SILVICUTURE-RELATED GENERAL VEGETATION TREATMENT DURING CY 2013, US FOREST SERVICE – NATIONAL FOREST SYSTEM) In 2013 (the last year reported), only 3103 acres were treated in

http://www.scientificamerican.com/article/widely-used-herbicide-linked-to-cancer/

http://www.gmwatch.org/news/latest-news/16302-glyphosate-damages-dna-says-world-health-organisation-expert

http://www.gmwatch.org/news/latest-news/16302-glyphosate-damages-dna-says-world-health-organisation-expert



the entire Region 9. Mesabi (1858 acres proposed for herbicides) would increase that total by two thirds in a single project. This would clearly constitute a "major Federal action(s) significantly affecting the quality of the human environment." 42 U.S.C. § 4332(2)(c). Any potential environmental effects of herbicide use would be multiplied exponentially by the size of the acreage proposed for treatment. The acres scheduled for herbicide treatment should be reduced considerably. Alternative treatments should receive careful consideration as required by an EIS.”

Comment MS-037-3 (Brad Sagen-Sierra Club): “Treatment Parcel Fragmentation – Effects on Non-Treatment Lands Potential effects of herbicide use on adjacent lands in Mesabi are multiplied because treatment sites are frequently small parcels adjacent on one or more sides to non-treatment lands. Drift from large-scale sprayer applications and soil drainage thus have the potential to affect far more adjacent acres than if treatments were confined to a small number of parcels.” Comment MS-037-4 (Brad Sagen-Sierra Club): “Inadequate Information Regarding Herbicides USFS reports on three possible herbicides under consideration for Mesabi. The information regarding Sulfometuron Methyl is dated (SERA 2004) and needs to be updated. Information on Glyphosate (SERA 2011a) and Triclopyr (2011b) is more recent but should also be updated to incorporate the latest research and technical information. Sierra notes the sparse information regarding the effects of these herbicides when used with large scale boom (broadcast foliar) sprayers and the failure to identify and evaluate potential surfactants and other adjuvants.”

Comment MS-037-5 (Brad Sagen-Sierra Club): “Use of Large Motorized Sprayers The Project proposed to use boom spray (Broadcast Foliar) sprayers mounted on trailers. There are relatively few evaluations involving the use of this size of application. Spray drift to adjoining lands should be a major issue, especially because of the fragmentation into small stands. An EIS evaluation should consider alternatives to this type of sprayer equipment.” Comment MS-037-6 (Brad Sagen-Sierra Club): “Incomplete Information Regarding Alternatives The scoping document is incomplete regarding potential alternatives. USFS acknowledges, for example, “If necessary, additional design criteria could be added to further address concerns for non-target resources.” (Mesabi Herbicide Proposal, p.3) Specific mechanical and other non-herbicide treatments, including no-action, should be identified and evaluated for similar site conditions.” Comment MS-037-7 (Brad Sagen-Sierra Club): “Cost Considerations Cost considerations appear to be a driving force behind the proposed use of herbicides in the Mesabi Vegetation Project. For example, “…this financial savings could free up funds to meet Forest Plan objectives on other sites as needed.”(Mesabi Herbicide Proposal, p.1) As Sierra noted in our original scoping comments of Sept. 24), “Cost containment should not be a consideration when herbicides are. Alternative involved treatments should be analyzed in the EA (EIS) and their use evaluated independent of cost considerations.” Cost may be a legitimate secondary consideration when alternative treatments are comparable on environmental criteria.”

Comment MS-037-8 (Brad Sagen-Sierra Club): “Surfactants and Adjuvants The Mesabi Herbicide Proposal acknowledges that surfactants (adjuvants) will be used with two (Glyphosate



and Triclopyr) of the three proposed herbicides. No information is provided regarding potential surfactants. It is generally acknowledged that “…certain adjuvants or adjuvant mixes may sometimes be more toxic to certain non-target organisms than the herbicide itself.” (The Nature Conservancy 2001[3], Weed Control Handbook, p.8.4). An EIS should identify and evaluate potential surfactants and other adjuvants, the herbicides with which they may be used, the conditions of use (boom sprayer, etc.) and the potential environmental consequences of use. The complexities of interactions between the herbicide, adjuvant(s) and method(s) of application chosen, along with site conditions must be acknowledged and addressed in an EIS. Alternatives to adjuvants and to the herbicides should be presented and evaluated.” Comment MS-037-9 (Brad Sagen-Sierra Club): “Potential Effects on Wildlife Herbicides may affect plant, animal, and aquatic species in multiple ways. Regarding the potential direct effects on wildlife, the Triclopyr SERA states: “it appears that large mammals consuming contaminated vegetation are the nontarget organisms at greatest risk. The magnitude of the HQs for these exposure scenarios is similar to the magnitude of the exposure scenario involving the consumption of contaminated vegetation by a young woman, as described in the human health risk assessment (Section 3.4). As with the human health risk assessment, the high HQs suggest the potential for adverse effects in large mammals. This assessment based on HQs is consistent with the recent EPA risk assessment, U.S. EPA/OPP (2009a). The available field studies neither support nor substantially refute concerns for adverse effects in large mammals. The lack of detailed field studies involving longer-term observations in populations of large mammals following applications of triclopyr adds substantial uncertainty to the risk characterization for mammalian wildlife.” (SERA, 20lla, p.130, emphasis added) The potential direct effects to large mammals consuming contaminated vegetation (a virtual certainty if 1858 acres are treated), coupled with the absence of long-term studies require an EIS and a drastic reduction in the number and size of treatment sites.” Comment MS-006-9 (Annah Gardner-Sierra Club): “The Project proposes numerous short in-out roads with no obvious destination such as a body of water (e.g., A5, 17, 30, 52). Such roads encourage illegal cross-country travel and serve no reasonable purpose. Sierra notes the SNF road/trail system is acknowledged to be underfunded and must be reduced (see SNF Roads Project). The EA should document the quite specific need for any additional roads and trails. “Increased recreation opportunities” (motorized recreation) are not needed in Mesabi and should be rejected as a consideration.” Comment MS-010-8 (Al Jarvinen): “What is the actual risk level for humans, fish, and wildlife exposed to the proposed herbicide applications that is shown by the cited risk assessments?” Response: We acknowledge that indiscriminate herbicide use has the potential to cause negative effects to water, sensitive species, and their habitats. In recognition of the risk of negative effects of herbicides, we have analyzed two action alternatives in detail: alternative 2 includes the use of herbicide on 538 acres and alternative 3 is a non-herbicide alternative, which proposes mechanical site preparation in lieu of herbicide use. The same number of acres would be treated in both alternatives 2 and 3; however, we anticipate that alternative 3 would require an additional release to remove competing vegetation and thus take longer and cost more to achieve the same results as would occur on those acres proposed for herbicide in alternative 2. A summary of the effects analysis can be found in chapter 2 of the EA, while the full analysis for each alternative



by resource are is located in chapter 3. Additionally, acres planned for herbicide in the proposed action was reduced from 1,858 acres to 538 acres in the modified proposed action due to proximity of a water source, access, or a change of management goals for a stand.

We would inspect and monitor herbicide sites to determine effectiveness of treatments on all projects using herbicide. If herbicide does not prove to be the best tool then another method would be used to get desired results pending budget and time constraints.

Herbicide application protocols are described in appendix h of the EA and includes mitigations and design criteria such as no application of herbicide to wetlands or water and applying only when wind speeds are 10 mph or less. Using a large motorized sprayer is the most effective application tool for post-harvest site preparation units for foliar application to set back existing competing vegetation to promote natural regeneration or planting of tree species such as birch or pine. Depending on site conditions, hand application could be deemed a better tool and would be used in lieu of a boom spraying. Boom sprayer application was considered in the analysis because it potentially has greater effects than hand application and it was determined there would be minimal risk to adjacent stands when all mitigations, labels, and directions are followed especially in regards to wind speeds. Acres listed are the total stand acres and would likely exceed the actual acreage sprayed by herbicide.

The other consideration that reduces the risk of negative effects of herbicide use is selection of herbicides that have low toxicity. As proposed in the Mesabi Project, glyphosate, sulfometuron methyl, and triclopyr have relatively low toxicity and do not pose any plausible risk to people or the environment based on results of risk assessments for these herbicides (SERA 2011, SERA 2004, and SERA 2011) and on the proposed application methods. The National Pesticide Information Center, a collaboration between Oregon State University and the US Environmental Protection Agency (EPA), has classified glyphosate and tryclopyr as a group D chemical, that is, not classifiable as to human carcinogenicity. This consensus is based on studies that involve feeding laboratory animals large daily doses of the pesticide over most of the lifetime of the animal (Tryclopyr General Fact Sheer, http://npic.orst.edu/factsheets/triclogen and glyphosate general fat sheet, http://npic.orst.edu/factsheets/archive/glyphotech.html#cancer). While sulfometuron methyl has not been evaluated for its human carcinogenic potential, it still considered to have low to very low toxicity based on laboratory animal testing (Reregistration Eligibility Decision Sulfometuron methyl, https://www3.epa.gov/pesticides/chem_search/reg_actions/reregistration/red_PC-122001_18-Sep-08).

Surfactants are considered inert ingredients by EPA and hence relatively little information is available about their toxicity. We would use a non-ionic surfactant such as Liberate or Activator 90. Of the little information available on surfactant toxicity (SERA 1997 USDA Forest Service 2007), evidence suggests non-ionic surfactants have low risk associated with their use. Only formulations of these herbicides that do not contain POEA (a surfactant toxic to amphibians) would be used. There is no evidence to suggest that non-ionic surfactants would pose a hazard when applied following label directions.

Cost is one consideration for choosing what tool to utilize for each treatment proposed for the project. Costs for establishing a stand of paper birch or conifer could be lowered due to a reduced need for maintenance activities such as release in comparison to a mechanical or prescribed fire treatment. For example, following a mechanical site prep or prescribed fire

http://npic.orst.edu/factsheets/triclogen

http://npic.orst.edu/factsheets/archive/glyphotech.html#cancer



treatment without herbicide, young stands will typically need up to three releases to successfully establish themselves to a “free to grow” state. With herbicide we could see this reduced to a single site prep entry followed by minimal amounts of follow-up treatments. Other considerations include access, vegetation composition type and age, desired future conditions, and other resource considerations. Utilizing stewardship and alternative sources of funding has become important to implement more costly management actions such as conversions and plantings. A comparison of direct, indirect, and cumulative effects will be analyzed in the EA for the three alternatives. Effects of the herbicide proposal are evaluated in chapter 3 of the EA, wildlife BE, and habitat group 6 of the plant BE.

The Superior National Forest has not conducted any monitoring of herbicide use for forestry because very little forestry use of herbicides has been implemented from recent decisions where it has been approved. The Forest is currently developing a Forestwide monitoring strategy and protocol for herbicide treatments. Monitoring of herbicide use in the project would occur as described in appendix d and appendix h of the EA and would incorporate any additional monitoring protocols developed by the Forest in the future. State and county foresters are using similar herbicides on their lands within the Superior National Forest boundary; we have no reason to expect effects outside of the range of those analyzed and disclosed by the EA. Potential adverse impacts from herbicide use would be mitigated by design features described in appendix h and by following best management practices (BMPs): MFRC guidelines for herbicide application, Forest Service Manual 2150 (Pesticide Use Management and Coordination), Forest Service Handbook 2109.14 (Pesticide Use Management and Coordination Handbook), the Forest Service Health and Safety Code Handbook Chapter 22.1 and all federal, State, and local regulations.

REJECT ADDITIONAL RECREATION OPPORTUNITIES

NO NEW ROADS

Comment MS-006-10 (Annah Gardner-Sierra Club): “Roads, both temporary and permanent, affect overall forest health and contribute to the decline of certain species. Roads negatively impact lynx, wolves, moose and other sensitive species, cause fragmentation of the forest, increase potential OHV trespass, promote the spread of non-native invasive species and harm soil and water resources. How many miles of new “temporary” roads will be built? No new roads should be constructed. Focus needs to be placed on reducing the amount of roads in the Superior National Forest, not increasing it.” Response: Overall, the project would reduce the number of roads in the project area through decommissioning. Temporary roads would be needed to access harvest units that do not have existing roads to them. There would be about three miles of new temporary roads needed and they would be decommissioned when management is complete. For more information about system roads, please refer to section 2.4, alternatives considered and not carried forward for detailed analysis as well as the transportation analysis in chapter 2. For more information regarding temporary roads please see the summary of effects by resource area, including potential effects from temporary roads, in chapter 2, and further information can be found in each resource section in chapter 3.



CATEGORY #2: OTHER ISSUES Comment MS-006-2 (Annah Gardner-Sierra Club): “Clearcutting-The proposed clearcut of 6,646 acres (Scoping Document, p.10) is too great (almost half of the treatment area). Alternatives such as thinning and shelterwood cuts should receive greater consideration. Clearcutting should be reduced except where the area is being converted from aspen to a different species.” Response: The amount of even-aged treatment was proposed for Mesabi due to the purpose and need for the project area. Clearcutting is an appropriate harvest technique to regenerate (create young) species such as jack pine, red pine, spruce-fir, aspen, and paper birch (FP G-TM-2, S-TM-2). In stands 20 acres or larger five percent of the stand would remain as a legacy patch where no harvest occurs (FP G-TM-5). Type of harvest is generally dependent on species, stand age, and spatial arrangement as well as management needs to move towards the desired conditions.

The Mesabi EA explains and analyzes the need to create young forest and improve species diversity within the dominant landscape ecosystems. Efforts were made to reduce fragmentation by creating young stands adjacent to existing young stands on federal and other ownership. The management indicator habitat objectives for the Mesic Birch-Aspen-Spruce-Fir (MBA) landscape ecosystems describes that there is less jack pine and white pine and more red pine and aspen in the project area. Additionally, there is an overabundance of mature aspen and an underrepresentation of young forest (Mesabi ch. 1). Section 3.3 in the EA analyzes effects of clearcutting and all proposed vegetation activities. Interior species habitat, fragmentation, and large mature patches are discussed in section 3.6.

Comment MS-001-1 (Mark Belpedio and Paul Stanaway-Camp GRUMP P, LLC.) “In regards to the Mesabi Project, we the officers of Camp GRUMP P, LLC. would like to voice a few of our concerns with this project. As property owners in close proximity to several of the proposed sites we are very concerned about the loss of recreational use of this property during the time it will take for the forest to regenerate. There are several proposed sites that are very near to our property which will have an immediate and lasting effect upon the wildlife in and on our property as well. We are also concerned that the additional traffic and the use of heavy equipment used to accomplish these projects particularly on FS Road 256I and 256IA (upon which we have a Private Road Easement) will create undue stress and damage to the road. Under the terms of our easement, we are responsible for the maintenance and upkeep of this road and would like some assurance that the road will be returned to as-is condition after this project is completed and not just left for us to repair. We have spent much time and labor in upkeep of this road and would like to be sure that the road is returned to the state it was found prior to these projects taking place.” Response: Implementing the various vegetation management activities to create young forest and improve the health, structure, and within-stand diversity is beneficial for the forest adjacent to your land. Effects to the recreation resource have been analyzed in the EA. Please see chapter 3.11 for this analysis.

As described in A2 p. 6 of the scoping report, most wildlife habitat needs would be met by implementing actions that meet landscape ecosystem objectives. Activities include maintaining



some existing large patches of mature forest for those species requiring interior forest habitat and also creating young forest which enhances browse opportunities for moose and other species.

We understand you have a legal easement for the road past the gate, but not legal easement of FR2561 and FR2561A. Any damage to roads from vegetation management operations would be fixed prior to contract termination.

Comment MS-002-1 (Tim Berrini): “Who will be responsible for the cost and or taxes of the new roads and infrastructure or any other work described in the plan in support of the project. Will this be absorbed by the immediate area or the state as a whole” Response: Timber sold on National Forest System (NFS) land would result in measureable revenues to the U.S. Treasury and local county governments. Additionally, revenues from timber sale receipts go towards transportation, logging overhead, and road construction costs. Local taxpayers would not be contributing to improvements of NFS roads for project activities. For more information see appendix g-economics in the EA.

Comment MS-006-3 (Annah Gardner-Sierra Club): “Continued Reliance on Aspen-The project area contains too much aspen, largely as a result of past management actions. USFS acknowledges they got it wrong in the past – referencing current problems as the result of “previous management objectives” (Scoping Document, p.16). The Project should place even more emphasis on replacement of aspen with conifer species. For example, stands 90, 91, 93, 95-98, and 100-106 appear good candidates for conversion rather than simply clearcutting.” Response: This project is moving towards forest plan LE objectives for vegetation composition and age class objectives (see section 3.3-vegetation). Conversion acres were prioritized towards riparian areas and increasing sizes of existing conifer patches. Additionally the team focused on more mixed stands that would be more likely to be able to convert than pure aspen stands. The stands mentioned above do not meet the priority criteria. Some were pure aspen stands that would be difficult to convert and others have access limited to frozen ground conditions.

Comment MS-006-4 (Annah Gardner-Sierra Club): “Mature Forests-The Sierra Club supports plans to use prescribed burns to promote structural and species diversity. There is concern with the large amount of harvesting proposed that would create young age class and reduce large mature patches. The number of large mature patches should be maintained, as should their size in terms of acreage. Many sensitive species such as lynx, Northern goshawk, black-throated blue warbler, bay-breasted warbler, and boreal owl rely on mature forest for habitat. The Sierra Club favors maintaining areas of older forest or extended maturity forest, reduction of aspen forest to its historical range and percentage of coverage, and uneven aged forest generally. The Sierra Club enthusiastically supports efforts to identify, protect, and promote sensitive plants within the Superior National Forest. It is wonderful that this project proposes to improve habitat conditions at two locations where sensitive plant species are present. Timber harvesting and road building creates unfavorable conditions for many sensitive species. Focus needs to be placed on improving conditions for threatened species, not merely maintaining what is currently available. A similar project effort should be directed toward improving habitat conditions for threatened animal species. (See above comments on mature forests.)”



Response: Vegetation management treatment in mature forest patches would follow forest plan direction to emulate natural disturbances and other ecological processes. Treatments could include clearcut with reserves, shelterwood, two age cut, and selective thinning. Type of harvest is generally dependent on species, stand age, and spatial arrangement as well as management needed to move the stand to the desired condition. For more information see section 3.6-management indicator habitats in the EA. Specific objectives of the project include to maintain the acreage of mature and older upland forest patches of greater than 300 acres in spatial zone 1 (FP S-VG-6 p. 2-26). Please see table 3.6-3 in the EA for analysis of large mature patches. Even after harvest in some patches there will be more mature patches greater than 300 acres in 2020 than there is now.

Project activities would maintain habitat and improve it for a variety of species, including but not limited to, Canada lynx, northern long-eared bat, northern goshawk, and other species where opportunities and needs are present (Scoping Report p. 6).

As described in forest plan objective O-WL-30 to enhance or restore high quality habitat for sensitive plants, project activities would include habitat improvement for least moonwort (botrychium simplex) and ternate grapefern (botrychium rugulosum) within the project area.

Please see the BA and BE for more information on regional forester sensitive species and threatened species and effects with the project. Forest plan objectives for most wildlife species is included in landscape ecosystem objectives and management indicator habitat objectives.

Comment MS-006-5 (Annah Gardner-Sierra Club): “Biomass-The use of tops of trees for biomass (Scoping Document, p.9) should be considered only when a surplus of downed matter is identified and the nutrient needs of the cut area are clearly satisfied.” Response: Removal of biomass (material left over after harvest or other treatments) may be permitted on treatment units in the project area after the primary treatment is completed per forest plan operational standards and guidelines and Minnesota Forest Resources Council (MFRC) guidelines. However, there are treatment units where this would not be proposed as it would meet forest plan objectives for certain resources. Extraction of biomass is dependent also on the demand and availability of equipment to process and transport it.

Comment MS-006-6 (Annah Gardner-Sierra Club): “Transportation System-It is disconcerting that the Scoping Letter states that “Recently however, District staff identified several additional unauthorized roads” (10). Why are there so many unidentified roads the Agency is unaware of? It appears that the Travel Management Project did not successfully identify all unclassified roads. A re-evaluation should be conducted to ascertain locations of all unclassified roads within the Superior National Forest. The Mesabi Project should obliterate all unauthorized roads and should reject any consideration of currently unauthorized roads as additions to the FR system (Scoping Document, p.10). Response: All roads in the project area were analyzed for possible need for timber and recreational access. Decisions were made to either keep the road open to motorized vehicles, added to the system but closed to motorized vehicles, added a special use permit, or decommissioned. Overall there is a reduction of roads in the project area. Please see chapter 2 for a discussion of the transportation system.

Comment MS-006-7 (Annah Gardner-Sierra Club): “Climate Change-The Project proposes to consider introduction of species found further south (Scoping, Table 8 and p.19). Species



considered include, as American basswood, black cherry, northern red oak, and eastern white pine. Are any of these located so far south that introduction would not represent the natural geographic progression of species due to climate change? Assisted tree species migration may be necessary because of imposed barriers such as urbanization and large-scale agriculture. Species introduction apart from natural progression would be a significant environmental action and should require an EIS before initiation.” Response: Within the project area American basswood, northern red oak, and eastern white pine are inside their respective tree species ranges (Little, E.L., Jr. 1971), and black cherry is represented in northeastern Minnesota according to forest inventory analysis (FIA) data (Hansen, M.H., Frieswyk., T., Glover, J.F., Kelly, J.F. 1992).

All of the aforementioned species are currently found within the project area in varying degrees of abundance. Regional projections for impacts on forest types/communities found in the project show that these species are more inclined to succeed under a variety of climate change scenarios due to their current ranges that extend further to the south. This project would look at either maintaining or increasing these tree species within the project by reserving or through tree planting.”

Comment MS-006-8 (Annah Gardner-Sierra Club): “Increases in off highway vehicle (OHV) use are aggregating damage to precious natural resources on our public lands. OHV’s cause: damage to water and soil resources, erosion, sedimentation, spread of non-native invasive species (NNIS), air and noise pollution, disruption to other forest users, increases in motorized traffic and destruction of sensitive species habitat. The Scoping Letter states, “As a high use recreational area, some water and soil resources within the Mesabi Project Area have sustained impacts (such as rutting and the introduction of fine sediment contamination) associated with ATV or other recreational vehicle traffic” (8). The Sierra Club is concerned with the unregulated usage of the vehicles, and the cumulative resource damage that is the result. A large percentage of motorized recreation riders do not stay on sanctioned trails but travel into new areas. This creates a multitude of impacts to our wild lands including destruction of sensitive ecosystems and species habitat and the carrying of seeds of invasive species into previously undisturbed lands and waters. The EA should identify ways the Agency will prevent illegal OHV use that is occurring within the project.” Response: Temporary roads and roads no longer needed would be effectively decommissioned so as to not allow motorized use. Law enforcement is also aware of illegal ATV use.

Comment MS-013-1 (Steve Kamunen): “I’m concerned about the mesabi project attachment 3. The project is to log off 106-107-108-109-110. I've hunted here along with my 2 sons for many years. I just don't see that much timber in this area. By cutting this area the wildlife in this area would greatly diminish. I would like you to reconsider this project. Thank you.”

Response: A no-action alternative was analyzed in the EA. Units 106 and 110, quaking aspen stands, are proposed for clearcut with reserves under the action alternatives, 107 is paper birch so would get treated with a shelterwood harvest, and 108 and 109 are mixed stands with balsam fir and aspen. These prescriptions were chosen to restore the stands to a healthy and productive state. These stands are aging and breaking apart. Creating younger forested conditions in these stands would provide browse for a variety of game species and grow to be healthier and more diverse stands.



Comment MS-018-6 (Clay A Mariucci): “3. I am concerned that new roads or trails or recreation areas could induce trespassing of others on my property.” a. To the extent new trails, roads, reacreation areas are created, there is a significant risk that others using the Federal land will not recognize the boundaries of my land. b. I request detailed information about any new or improved roads, trails or appurtenances that would tend to attracted third parties to traverse the area. I simply want the chance that such would induce traffic onto or across my land to be evaluated.” Response: We understand your concern. Any new roads or trails would be for management activities to NFS lands. There will be no new permanent roads or trails near your property. Temporary roads would be needed to access the harvest units. Temporary roads would be constructed for vegetation management activities and decommissioned after all activities have been completed. If you have private land adjacent to public land, we recommend posting it to deter intrusion.

CATEGORY #3: BEYOND THE SCOPE Comment MS-008-1 (Robert Hopper): “Damage caused by logging trucks coming down 405 that are overloaded and violating the load restrictions in the spring. Our asphalt coating has deteriorated tremendously to the point of, the logging trucks just don’t seem to care. So I’m hoping in your forestry management program that you would take and make a new road that would go from the intersection of 405 and Forest Road 257 straight out to U.S 53. It is a very short little jaunt. It would keep these big logging trucks off of our road and the hazards associated with speeding down our road, overload conditions violating the road restrictions.” Response: The USFS is responsible for the administration of Forest roads 256 and 257 which would include the ability to enforce load restrictions on those roads that have been signed. The 405 road is administered by St. Louis County. Construction of another road off the 405 road to US 53 is not part of the project proposal as we try to build as little new miles of road as possible when existing roads are already in place. If the logging trucks are overloaded and traveling down the 405 road, please work with St. Louis County.

Comment MS-010-2 (Al Jarvinen): “The two 40 acre parcels were part of my grandfather’s original homestead in 1904 and I would like to add them back into my families holdings for future generations. I have offered to exchange two 40 acre parcels that I own in Section 29, Twp 61, Range 18 that are more valuable than those in Section 28. Ownership of the section 29 parcels would give the Forest Service access to an isolated 40 acres of Superior National Forest land that has likely never been logged (old growth) and could contain sensitive plant and animal species.” Response: We are not prepared to engage in this land exchange at this time; however, we may consider your proposal in the future and suggest contacting the local Forest Service office to follow the protocol.

Comment MS-010-4 (Al Jarvinen): “One of the purposes of the Mesabi Project is to improve water access site recreation opportunities. How about providing public access to Big Rosendahl Lake? I grew up fishing this lake when I was young and would like to do so again.”



Response: Some improvement to recreational opportunities were identified in the scoping report and included for public consideration and comment; however, we will not include a public access to Big Rosendal Lake at this time, but may consider it in the future. We would need to work with MN DNR to establish access and consider land ownerships, existing roads, and new access as needed, as well as potential impacts to the lake and adjacent lands. In addition, the 2004 forest plan standard S-RWA-1 allows a maximum of 10 new water accesses. Therefore, when evaluating new water accesses, we consider the amount of work involved and investment required based on the lake size and recreational opportunity.

Comment MS-018-3 (Clay A Mariucci): c. My attorney's office searched for easements and found nothing recorded. Would it be appropriate to formalize this access route as a part of Mesabi Project #44466? The legal claim to the access is firm as it has been in place and in use for almost 100 years (since the original homestead; in a land grant signed by Woodrow Wilson) and is the only access route to my land.” Response: To formalize this access route, we would need to review your original documentation to see if there is a legal claim to the access. Additionally, we would need to research how the federal land was acquired. If the decision is made to grant a legal easement, that would be completed outside of the project. Easement would depend upon the review of the documents and may or may not have fees involved.

Comment MS-033-1 (Steve Rachini): “Terri, after having spoken on the phone today with Ryan from your office I want to make it known that I own property in the area that needs to be maintained . I own 7.5 acres of land on hwy 73, 15 miles north of Chisholm Just north of county hwy 65 about 2 miles. this property was a Christmas tree farm full of red pine and I know the trees are old cause I sheared them in the summers of 1967 and 1968 for the man I purchased the land from. Due to the fact only about 5 acres are heavily wooded local loggers like John Rolle and Tony Zidich can't justify such a small cut I know I have asked them. I want to keep this land from being overgrown with aspen and the red pine maintained but have been unable to get it done. Ryan had said to advise that it would be available for harvesting and might interest someone doing work near by as part of this project. I want the grouse back but they don't like the hood. Thanks Steve Racchini” Response: We will make an effort to keep you informed about when we are working in that area, to take advantage of the logger that is there. We also suggest contacting the Eveleth DNR Forestry Office, and speaking to a private forest management specialist.

Comment MS-036-1 (Kristi Rolf): “Comment 1. I am writing to confirm that you are aware that you need an easement to cross over my land.” Response: The USFS is aware and had been in contact with you regarding this. Comment MS-041-1 (Pat Snyder): “We received notification of the above project. When looking at the map, I’m not sure we will be directly affected by it. We own the following parcels in St. Louis County: #330-0010-04910, #330-0010-04912. We were told that a road realignment project may be in the future and we are wondering if this is it. Can you tell us if Giants Ridge Road is being moved or in some way affected by this project? Thank you,”



Response: The nearest proposed Mesabi Project activities would be almost one mile to the south of your parcels. Giants Ridge Road is not under the jurisdiction of the Forest Service and is not part of the proposed project.

Comment MS-018-9 (Clay A Mariucci): “6. Animal Habitat, potentially protected species may exist in the area a. This area has an astonishingly diverse and healthy population of wildlife unlike most other wooded areas. Certainly the current forest supports a population of wildlife it cannot if it is simply reduced to a stand of trees awaiting future harvest. b. I do not know of specific endangered species in the location. I do know, however, I have seen animals thriving here I don't normally expect to see. Several kinds of owls and birds, wolves, and smaller mammals that I don't see anywhere else. The area also seems to act as a refuge that supports a very healthy deer population. c. Has a survey for protected species been conducted specific to this area? I think it would be worthwhile to have experts evaluate if this area should be treated differently than a typical stand of trees. d. The "wilderness" character of this area must be preserved as its value outweighs any other objective to heavier thinning, defoliating or cutting.” Response: Please see sections 3.4-3.6 for information on threatened and endangered species, regional forester sensitive species, and management indicator species. Additionally see the biological assessment and biological evaluation for direct, indirect, and cumulative effects to wildlife species. These units are miles from the federally designated wilderness areas (Boundary Waters Canoe area Wilderness) and are located within the General Forest Management Area, which emphasizes land and resource conditions that provide a wide variety of goods, uses, and service; including wood products, other commercial products, scenic quality, developed and dispersed recreation, and habitat for a diversity of terrestrial and aquatic wildlife. (FP p. 3-6).

Comment MS-024-1 (Bob McDonald): “In regards to the forest vegetation project north of virginia sections 106, 107, 108, 109, 110 I have hunted that area for 50 years and my grand parents were there years before that. Parts of that area has been logged off more than once in the past and the small patches of trees that are left has made for some good hunting for my family and our kids. Every time we get logged we have to redo our hunting places and that makes it hard to reset everything. There is not a lot of woods left by big rice and it would be nice if we could keep the little that is there. We love it up at big rice and the venison we harvest is the best. We hate to see the rest of the trees cut because what would be left would be small popples that you can hardly walk through from past logging and the new clear cut, where do we go from here. I hope you will reconsider logging sections 106 through 110 and leave the trees that are left for us and the couple of deer we take each year. Thank You” Response: These units were selected to be harvested because they were overmature, in need of treatment (greater than 75 years old), and to consolidate the forest in that area to create a future larger patch of forest. The existing mature forest was broken up by patches of younger forest and not providing quality interior habitat. Best management practices and forest plan standards and guidelines would be followed which would include leave trees and uncut reserve areas. There would still be some areas of mature forest in that area after harvest. There are certain



wildlife species, such as deer, that prefer to have edges – areas where mature forest meet young forest.

Comment MS-025-1 (Dan McDonald): “Hello, I'm Dan McDonald and I'm writing to you regarding the mesabi project attachment 3 proposed action by stand unit. This project plans to log off sections 106 through 110 near big rice lake. I have hiked all over that area hunting and see how heavily those sections and others have been clear cut. There doesn't seem to be much old growth left. I have been hunting there with my family since childhood and wish you would reconsider logging those parcels. There's not much land there and it would be a shame to cut the few remaining small patches of trees that are left. My family and I would be forever in your debt if you didn't log that off. Thanks for listening. Dan McDonald”

Response: Please see the comment to MS-024-1.

Comment MS-035-1 (Rian Reed, MN DNR): “The DNR has reviewed the Mesabi Project Scoping Report and we have one follow-up comment made from our May 19, 2014 letter in regard to the proposed treatments adjacent to DNR designated old-growth in T61N Rl 7W S4. This location was mistakenly identified as section 9 in the May 19 letter; DNR policy sets forth a Special Management Zone (SMZ) around all designated old-growth to maintain the integrity of the old-growth stand. In short, this is composed of a 330' buffer around the stand. The DNR would appreciate if the Forest Service could buffer the old-growth in a like manner. Further information on DNR designated old-growth and SMZ policy can be provided. The DNR appreciates the opportunity to comment and looks forward to continued coordination as the project proceeds.” Response: Thank you for bringing this to our attention. We have added it to the notes for that stand and will follow a 330’ buffer to the extent possible.

Comment MS-036-2 (Kristi Rolf): “Comment 2. I am concerned about the health impact of burning so close to my home (#292 less than 150" from my house) and I am requesting an appropriate buffer to protect my health, the health of my pets, and to protect my property from smoke.” Response: Several mitigations measures would be used to reduce adverse health impacts to you and your pets, and to protect your home and property. Burns would be designed to utilize wind vectors that would carry smoke (emissions) and fire away from your home. These burns would also be conducted when the dispersion index is “fair” or better. These conditions allow smoke to rise and move out more effectively reducing the smoke near to the burn site. There are four categories: poor, fair, good, and excellent. The dispersion index describes the ability of the atmosphere to disperse emissions and is a product of the mixing height and transport wind speed. People would see smoke column rapidly above tree tops before the smoke is dissipated by transport winds. Emissions would be further reduced by eliminating the amount of material available for consumption. This has been accomplished by the recent fuel reduction activities along Pine Lane. Material was either burned in piles, obliterated with a brush hog, or ran through a chipper. In addition, the proposed harvest would reduce the amount of available fuels even further by removing merchantable timber off site. These burns will be staffed with appropriate number of personnel and equipment to ensure the burns are implemented successfully. The burn perimeter would be fully secured before crews go home for the night and crews would be back early the following morning to continue mopping up the burn. The



production of heavy smoke concentrations is limited to the day of ignition. Some stumps and large logs would be seen smoldering the following day.

Comment MS-036-3 (Kristi Rolf): “Comment 3. I am also concerned about my home, my privacy, and the peaceful enjoyment of my land if ATV/OHV's are allowed to roam/travel from the heavily populated Lake 14 to FS721A (Pine Lane) through the clear cut 40 acres (#292). This 40 acres is already a common thoroughfare for ATV'OHV's. Without grown trees, the 40 acres would be opened up to increased ATV/OHV use. For this reason, I am again requesting an appropriate buffer to protect my home, my privacy, and my peaceful enjoyment. If Lake 14 was not so close, I would not be concerned with this.” Response: We understand your request and are open to working with you further regarding your property and NFS lands. Additionally as described in the following comment, most if not all large mature pine would remain in that stand buffering some OHV effects.

Comment MS-036-6 (Kristi Rolf): “To keep #292 from becoming a thoroughfare, I suggest that #292 not be clear-cut as this 40 acres is relatively healthy. I suggest that it be thinned maintaining the Pine and burning the undergrowth while regenerating the birch. If you do clear-cut, I am requesting that #292 be monitored by law enforcement for unlawful ATV/OHV use and accompanying damage to planted trees until the trees grow to an appropriate height to block ATV/OHV use. The Forest Service can expect me to call law enforcement when ATV/OHV's travel in the planted areas close to my property.” Response: We understand your desire to not have stand #292 clearcut. The main objective is to compliment the fuels reduction that has been done on the private land in the vicinity while managing forest health and fuels reduction objectives further from the private property. Currently this area is a mixed pine stand with a large component of paper birch. We are proposing to do a pine shelterwood harvest in that stand, leaving most or all of the mature pine. Following harvest, the proposed action calls for a site preparation burn and conversion to red and white pine through planting.

Unauthorized OHV use would be deferred to law enforcement.

Comment MS-044-1 (Darren Vogt-1854 Treaty Authority) “The 1854 Treaty Authority would like to provide comments on the Mesabi Project Scoping Report. Thank you for the consideration of the input we previously provided (included below) before the proposed action was completed. We have a few additional comments or points needing clarification. We remain interested in access to Sandy and Little Sandy lakes. The scoping report states: “The current access to Sandy/Little Sandy Lakes is causing some resource impacts. To accommodate current use patterns, address resource damage, and enhance water access opportunities, the Mesabi Project proposed action is to officially recognize, designate, and manage this site as water access. Improvements to this site could include converting an existing road to a trail.” “The Sandy/Little Sandy Lakes site is not currently a designated recreation site and resource damage is occurring. To accommodate current use patterns and address resource damage, the Mesabi Project proposed action is to officially recognize, designate, and manage this site as a backcountry campsite.” We are supportive of providing access to the lakes and a recreational proposal for a campsite. However, it is unclear if converting an existing road to a trail would accommodate use, and vehicle (truck) access is probably preferred. This use is necessary for



current monitoring and restoration work in the lakes, and also for resource users (hunters, rice harvesters, etc.). Roads and campsites should avoid impacts to cultural resource sites identified in the area.” Response: The “existing road” is actually a user created ATV trail down to the lake. This would be upgraded to prevent any resource damage from the current situation. All USFS projects are reviewed for impacts on heritage resources. This user trail is not located on National Forest System land, and would need an easement, prior to making it a designated water access route.

Category #4: Non-Issue Comments or Questions Comment MS-001-2 (Mark Belpedio and Paul Stanaway-Camp GRUMP P, LLC):“And finally we would appreciate being notified prior to any prescribed burns in the areas adjacent to our property. Particularly the sites marked as 117-123, 106-111, 114-115, and 175-176. We have fire suppression equipment on our property (ie. a sprinkler system) and would like to be sure that we are able to protect our property in the event of an escape during one of these burns. Two of our members are also USFS wildland fire trained and members of the Lakeland Fire Department and would like to be able to stage protection equipment at our property in the event of something happening during one of the burns to protect our property. Thank you for taking the time to read our concerns on this Mesabi Project and look forward to a continued relationship with the Forest Service.” Response: Comment noted. The Forest Service will notify the officers of the Grump P Camp prior to prescribed burning of the identified areas.

Based on your concern we would advise you to contact the fire specialist at the district office to provide your contact information. This information would get added to the burn plan for any prescribed burns adjacent to your private property and you would be notified in a timely manner of upcoming burn activity to that area. In general, public notification of prescribed burning is dependent upon many factors including size of the proposed burn, time of year, weather conditions, and adjacency to private property. Large prescribed burns are broadcast to various public information systems and include a contact name and number for questions and concerns.

Comment MS-003-1 (Paul Borg): “Cannot read unit numbers on map.”

Response: Wildlife Biologist, Dan Ryan, returned Mr. Borg’s telephone call, explaining that unit 310 would be underburned and unit 315 would be thinned and underburned. Additionally, Mr. Ryan assured Mr. Borg that nothing would be done on his land unless he wanted it.

Comment MS-005-1 (Steve Cerkvenik): “Anything you can do to improve grouse habitat and access to it will be welcomed by me and many others, I'm sure. Thank you.” Response: As described in the purpose and need for the project, young forest and a younger age class within the project area would provide habitat needs for wildlife species including moose and deer (young aspen/birch) and snowshoe hare (young conifer). Additionally, minimal amounts of large young patches on the landscape decreases habitat for olive-sided flycatcher, white tailed deer, moose, red fox, and ruffed grouse. Comment MS-006-11 (Annah Gardner-Sierra Club): “Gravel Pits-The scoping document states as a project goal, but provides no further information regarding,“Designating existing gravel pits within the project area as continuous use or administrative pits needed for



administrative and public use.” (Scoping Document, p. 2) The project area contains 35 current and potential pits. This is a high number and detracts from scenic and other forest uses. The project should include an analysis of the potential cumulative effects of current and potential pits. The Project also proposes to approve minerals prospecting around a current gravel pit. Approval should be for exploration only.” Response: Section 3.12.4 in the EA discloses and explains the need for mineral materials and effects of extraction of mineral materials. It is accurate to say that implementation of the vegetation and transportation management components of this project would require relatively small amounts of gravel. Additionally see the mineral materials section in chapter 1 regarding the proposed mineral material exploration at the Jammer Lake gravel pit by preference right contract holder Seppi Brothers Concrete Products, Inc; which is for exploration only at this point. Finally, see appendix e for cumulative effects from exploratory pits around the project area and appendix d for an example pit management plan. Agency policy requires such plans when more than 5,000 cubic yards of material is removed from a pit during a calendar year. Pit management plans are implementation direction for mineral materials permit administrators and permit holders, and consolidate required mitigations from law, policy, the forest plan, and project-level NEPA decisions such as this project. Like a timber sale contract, a pit management plan is a product of a NEPA decision, not a separate action.

The project proposes to authorize continuous use of gravel pits not just to serve the Forest’s needs, but also the needs of the general public and other State and local agencies. As described above, section 3.12.4 of the EA details the need for mineral materials in the project area. The Forest does not anticipate any large need for mineral materials on NFS lands in the project area in the foreseeable future beyond what is disclosed in the EA.

Comment MS-009-1 (Kristian Jankofsky): Owns the property at the top of road A22. He wants to know what that road will be, what type of traffic. Will it be bermed?

Response: The wildlife biologist called Mr. Jankofsky back concerning his scoping inquiry. He told Mr. Jankofsky the road to access his property is proposed to be decommissioned. It will need to be looked at to determine whether a special use permit is needed or if the road can be transferred off USFS management.

The parties also discussed the proposed OML 1 road south of his land. Mr. Jankofsky agreed with not allowing ATVs and trucks on it since they use it now and trespass on his property.

Comment MS-010-1 (Al Jarvinen): “On Attachment 2 (Transportation and Other Map) I would appreciate if you would reconsider adding A4 (Section 28, Twp 65, Range 18) to the Forest Service Road System. This road goes into the two 40 acre parcels of land that I am currently attempting to do a land swap with the U.S. Forest Service (Personal Communication, Tim Engrav, Acting District Ranger, August 15, 2015). Therefore, I would not want a designated road into them.” Response: Please see response to comment MS-010-2 regarding the land exchange. The road proposed to be added as an OML1 road would be bermed when not in use and would not allow motorized traffic. It would only be used for possible future management activities.



Comment MS-010-7 (Al Jarvinen): “The proposed road (A4) would also create more ATV and OHV usage, thereby, increasing problems with trespassing, littering, and vandalism. Things which I have experienced in the past.” Response: Comment noted.

Comment MS-010-3 (Al Jarvinen): “On Attachment 1 (Vegetation Treatment Map), Treatment area 163 also contains white cedar. How will the cedar be handled? Whitetailed deer gravitate to this area in the winter months.” Response: We are aware of the northern white cedar on this site. The forest plan gives us clear guidance to only allow harvest of white cedar when regrowth of cedar is likely to be successful or for research purposes. We do not intend on harvesting any cedar on the site you mention. The objective for this site and other black ash sites would be to increase within-stand diversity; we may seek to increase the amount of cedar on this site as part of that objective. Planted seedlings would be protected from browse with tubing or budcapping if this is the case.

Comment MS-010-5 (Al Jarvinen): “Are there any invasive plant species in the Project area? If so, how will they be controlled?” Response: Please see ch. 3.10 of the EA on non-native invasive plants and treatment methods.

Comment MS-011-1 (Nolan Johnson): Own property in T59 R21 S14. Inquired regarding general information about the project. He would be interested in areas for walking and ruffled grouse habitat.

Response: Please see the Superior National Forest webpage for information on recreational opportunities: http://www.fs.usda.gov/recmain/superior/recreation

Comment MS-012-1 (Alex Jokela): “Looking at Vegetation Map, on the east side of 73, you’ll find unit 514/515. If you go directly across (west) on 73. There is an 80 acre piece of national forest behind some privately owned land. My wife and I own a bit of that private land—73 is on the east with the 80 acres of national forest on the west. I’ve wandered around on the 80 acres—it mostly brush and fallen trees with several FS planted white pine and jack pine. Questions! Is there anything that I can do in collaboration with FS to plant more white pine or other trees on this NF land?” Response: The stand (C321S003) was cut in 2006. It was planted in 2007 with 2,000 red pine, 1,000 white spruce, 2,000 jack pine, 2,000 red oak, and 3,000 white pine. In 2009 the planted trees showed good survival rates. We also planted red pine in 2011. Our last stocking survey in that stand showed it as 67 percent stocked. At this time the silviculturists will monitor and make future decisions on the need to replant any of it or manage a mixed stand since it does have quite a bit of paper birch coming up among the planted species.

You can contact the district forester/silviculturist in Aurora, MN to find out details of plans to manage this stand.

Comment MS-014-1 (Steve Kernik): “I have reviewed the information regarding vegetation management in the Mesabi Project Area, and have one comment. I own property on Pfeiffer Lake, and I am concerned about the impact on water quality that the vegetation management plans for Areas 60, 61, and 64 will have on the lake. I don't know the exact slope of the riparian



areas but if I am interpreting the information correctly I believe that the maximum buffer strip would be 150 feet, if the slope was 40% or more. The buffer would be less if the slope is less. I believe that given the recreational value of Pfeiffer Lake, with a public campground and heavy recreational use, the buffer strip adjacent to the lake should be at least 300 feet. Thank you for consideration of my comment.” Response: Units 60 and 64 would be treated to improve conditions at and near the campground and would increase conifer in these stands. Water quality, recreation, and visual concerns would be the main drivers for these units. Appropriate mitigations would be incorporated (see appendix a). Unit 61 is proposed for a fuels treatment; limited clearing would be involved.

Comment MS-016-1 (Allan Lambert): “Regarding this Project, it would be nice to see which roads may be “Decommissioned”. I own property on Dewey Lake, address is 12008 Dewey Bay Road West, which is cross country from my residence at 7069 Barrett Rd. I am constantly using the Forest Service roads to go back and forth from both properties. Is there a list of roads which are being considered for “Decommissioning” is so please supply me with them.” Response: Please see the alternative map in the EA and also the transportation section, located in chapter 2.

Comment MS-017-1 (Mike Madden): “I have a few questions regarding part of your proposal to build a back country campsite at Sandy/Little sandy lakes. Rec. Project proposal 2. Specifically where you plan to build the camp and how you plan to access it. I would like to talk this over and ask a few other questions as well.” Response: See response to the following comment.

Comment MS-017-2 (Mike Madden): Mr. Madden was wondering how we propose to access 1) the south side of Sandy Lake for timber harvest/thinning, and 2) the proposed locations of the dispersed campsite on Sandy Lake and how we would access it.

Response: The IDT recreation specialist spoke with Mr. Madden about the route from Reid Rd which would require easement from Woods and Madden’s ownership group. Mr. Madden stated he would talk with his ownership partners about the easement idea but is not sure they want to do that. The recreation specialist stated he would check with the timber specialists to see how they proposed to access the harvest unit.

Comment MS-018-1 (Clay A Mariucci): “I am writing to share concerns and preserve my standing to object regarding the above captioned project. First, I will relate some background information to orient you to the locale of my concern. My family owns a 40 acre undeveloped and wooded plot impacted by the project. Our land is identified as: St. Louis County Parcel ID# Legally Described as" 696-0010-02010; SEl/4 of NWl/4, Section 13, Township 61, Range 17 Our property is surrounded by Federally owned land much of which is impacted by the proposed project. It also appears that Unit #70 of the project encroaches onto my land and Units# 56, 61, 68, 70, 71 and 73 surround and affect my land. Long-standing access to my property crosses Units#70 & 71 as a dirt road that runs from Highway 1 from a point roughly 2000 feet east of Pfeiffer Lake State Forest Rd and runs south to my land. Access to my property begins at a point off Highway 1 at roughly Latitude 47.7717690° and Longitude -92.4522927° and crosses Federal land to a point at roughly Latitude 47.769038°, Longitude -92.452673°.”



Response: Comment noted. All proposed treatments would take place on National Forest System lands.

Comment MS-018-2 (Clay A Mariucci): “My family has for many years utilized our land and the Federal land surrounding it for recreation including hunting, cross country skiing, dog sledding and just being in nature. The entire area, both our land and the surrounding Federal land is filled with trails and landmarks we care about. It is somewhat frightening to know this project plans to alter virtually all of this area we know and love. We wish to be involved to hopefully ensure this area isn't greatly changed in appearance or character to in such a way as to ruin our many uses of the area. I have concerns about: 1. Preservation and possibly improvement of the access road to my property. a. I recently noticed signs indicating the access was "ATV only" and have been concerned about implications for my use to access my property. b. I want to ensure my access to my property is not cut.” Response: The road is currently an operation maintenance level (OML) 2 road which allows cars and trucks. The project is not proposing to change the OML or type of access level of this road.

Comment MS-018-4 (Clay A Mariucci): “d. I would like to know, is my access road identified or impacted by in Mesabi Project #44466? e. I request maximum possible notice and detailed information about how this project may impact the access road to my land.” Response: We will make sure to involve you when the timber access plan is figured out and let you know plans for FR756. Comment MS-018-5 (Clay A Mariucci): “2. I am unclear and need clarification: Does this project intend to enter onto and/or alter my land? a. I'm looking at a blown up detail of "Mesabi Project Area Vegetation Treatment Map Attachment 1" dated August 2015 and the number "70" is actually printed directly on my land, while my land is specifically not colored in like other areas identified by the map. I am confused about what this means. b. Does this mean that this project will enter onto my land or is this "Unit 70" actually one of the colored areas? c. Please provide me with a detailed delineation of where "Unit 70 and Unit 71" are located because I want to know if property is impacted. My father and I planted the Red Pine trees at the north line of my property in the early 1970's and I very strongly want to preserve them.” Response: Units 70 and 71are located entirely within the National Forest System, which is indicated by the colored polygons where treatments are planned. Due to the size and scale of the map, the label did not fit directly inside or on top of the colored polygon. Comment MS-018-7 (Clay A Mariucci): “4. I want planners to be aware that this area (Areas identified as Units#S6, 61, 68, 70, 71 and 73) is an area with many unique and special areas that deserve a light touch. a. This area is not "typical" forest. b. There is a ravine through the land north of my land that holds an immense amount of wildlife and which would be RUINED by a heavy handed clearing.



c. If this project is intended only for purposes of preparing for eventual timber harvest, this would be a very negative use for this area and should be reconsidered. d. I have seen wolves, owls, eagles, deer, coyote, bear, flying squirrel, fox, pine martin, in this incredibly unique and lushly vegetated area. e. Many many deer find refuge and thrive in this thickly vegetated area. I believe that consideration to allow heavier than usual vegetation in this area is wise as support of wildlife and the special habitat outweighs the value of fire mitigation or forest management. f. I believe many areas should not be touched at all. I urge you to avoid any heavy handed thinning or defoliating. g. I request maximum possible notice and detailed information about specific plans for Units#56, 61, 68, 70, 71 and 73.” Response: Units 56 and 61 are not in this area. Objectives for all units is to promote diverse, productive, and healthy vegetation communities by thinning red pine in units 68, 69, and 70. Secondary treatment proposed is for a prescribed underburn in these stands. However, prescribed burning would be conducted in units 71 and 73 as part of a larger fuel project to help reduce effects in the event of a wildfire. These objectives as well as potential effects to wildlife can be found in chapter 3. Comment MS-018-8 (Clay A Mariucci): “5. We had a bad experience the last time a project like this came to this area in roughly the 1980's. We don't want to see that experience repeated. a. My father Richard Mariucci owned this property prior to myself. I spoke to him about this proposed project and he warned me about a very bad experience in roughly" the 1980's. b. My dad said the last time they came in and "improved and managed" in the area (areas now marked 68,69, & 73) they brought in equipment from the North (Hwy 1), ran a bulldozer through, destroying our main gate, directly across our property to the west line. From there they punched through our barbed wire fence hand-made rock wall bordering the property line, to access the areas now marked 68,69,& 73. My dad caught this and put a stop to it. We would definitely like for this to not happen again! c. We feel it is critical that anyone involved on the ground, especially contractors, be warned in advance not to trespass on our private property. Much of the property line is marked with either a barbed wire fence (much of it now on the ground) and/or a "rock wall" built of piled/placed field stones. d. Areas 68,69,&73 are now marked for harvest. My father said when they went in there in the 1980's, "and molested that area", they removed all the cover and significantly reduced the amount wildlife by altering a natural forest and original existing wildlife habitat. We do not want to see the same happen again. This area has far more than simply "timber" value to us and to the public. e. The access road to my property was built by Oscar Salminen back in the 20's so he could get to his home on the property we (his heirs) now own. Concurrent with the 1980's project, a forestry post and sign was placed at the entrance to our access road indicating "ATV access". Immediately after this marker was placed, 4-wheeler traffic, trespassing, theft, vandalism and tree cutting became a problem on our property. This is likely because the signage gave the impression of "open to the public" encouraging people to come down the previously unmarked



road. The original homestead buildings, that were still standing at that time (including a sauna, barn, and house) were vandalized, destroyed beyond repair, garbage and spent shotgun shells were littered about the property, trees on our property were illegally cut, no trespassing signs and buildings were shot up, and so on. My dad also thinks there are several police reports. One regarding a graduation party where the buildings were vandalized destroyed beyond repair, garbage and spent shotgun shells were littered about the property, trees on our property were illegally cut, no trespassing signs and buildings were shot up, and so on. My dad also thinks there are several police reports. One regarding a graduation party where the buildings were vandalized and items from the buildings destroyed and used for the ban fire, and another regarding illegal tree cutting. I also found "set" steel traps on our property and wouldn't have known it if one of my sled dogs hadn't alerted me. My lead dog came dangerously close to getting caught. I used to train and run a team of Siberian sled dogs out there on a regular basis. This was very disturbing because it was an every other weekend affair for many years for me, and finding a place that was safe to run a team of sled dogs, where you didn't have to worry about getting run into by snowmobiles, was always difficult. f. While we do not own the access road outright, signage on this road can and has directly affected our property. We want to ensure the impact on our property is considered for any signage, trails or roads involved with the proposed project. Response: We will make sure to involve you when the timber access plan is determined and let you know plans for FR 756. All proposed treatments would take place on National Forest System lands only.

Comment MS-026-1(Ann Oelrich):“My family owns private land potentially impacted by this project. I am writing to share concerns and preserve my standing to object regarding the above-captioned project. My family owns a 40 acre undeveloped and wooded plot impacted by the project. Our land is identified as: St. Louis County Parcel ID# 696-0010-02010; Legally Described as” SE1/4 of NW1/4, Section 13, Township 61, Range 17. I am writing to simply lend my support to the comments submitted in a letter dated September 16, 2015 by Clay Mariucci and would like you to consider these comments also my own. The letter is attached in both a Word and a PDF document. Please contact me with any available information affecting areas identified as Units# 56, 61, 68, 70, 71 and 73.” Response: Please see response to comment MS-018-7 above. Comment MS-027-1 (Dorothy Oie):“Hello, I'm contacting you re: the Mesabi Project. I live within the designated area on the East Donnywood Circle. Can I be reassured that I won't look out my backdoor and see all the big red pines down and essentially the area clear cutted to an immature forest? Response: Units 216-219 are just north of the East Donnywood Circle area. The proposal is to thin the red pine and underburn the stands to reduce the threat from a wildfire. The units would remain "mature" forest and would not be clearcut.

Comment MS-028-1 (Richard Pakkala): “How is this project being funded?”

Response: This project will be funded through many different sources including money appropriated by Congress, grants, retained receipts from timber harvest, trust funds, etc. See the economics appendix (g) for a discussion on economic factors related to the project.



Comment MS-028-2 (Richard Pakkala): “If going on private land: a. Is the value of the cut timber/pulpwood being paid to the landowner? B. Will this affect someone's SFI enrollment and payments if it changes their Forest Management Plans?” Response: All proposed treatments would take place on National Forest System lands only.

Comment MS-028-3 (Richard Pakkala): “If a SUP road is being added adjacent to someone's property, is access to the road gated and locked? If so, will the adjacent landowner be given a key for use of the road?” Response: Access that is considered special use can be gated. If the adjacent landowner uses the same route to access their property, than the special use would be issued to a road association. All parties of the association would have legal access behind the gate and would have a key to the lock. Comment MS-028-4 (Richard Pakkala): “Where new public roads are being added adjacent to a private landowner's property, has consideration for increased liabilities to the adjacent property owners been considered? Will it include the following: a. Signage for No Trespassing/Private Property posted along the private landowner's property? b. Replacement of signage on an annual basis since they will be destroyed on a regular basis? c. Trash pick-up on a regular basis?” Response: As managers of National Forest System lands, the US Forest Service would not post private landowners land. Additionally, we are adding very few new system roads open to the public; most are OML 1 roads which are closed to all motorized vehicles. Comment MS-028-5 (Richard Pakkala): “How can the public object to this project?” Response: Please see http://www.fs.usda.gov/projects/superior/landmanagement/projects for information on objection regulations. The opportunity to object will occur at a later stage in the environmental review process, when the draft decision document is published.

Comment MS-029-1 (Don Peterson): “All of your Jack Pine harvest sites are to be site prepared with a broadcast burn and seeded to Jack Pine. This is a standard prescription. I would like to suggest not seeding until three years after the cut or the burn. Jack Pine in this area has always come back naturally, even without site prep. After three years a survey could be done and any parts of the stand that is not naturally regenerated could be planted to Red or preferably White Pine. The end result would be a more diverse Jack Pine stand. The only other request I would have is ELTs be included in stand information so a reviewer could more carefully assess the correctness of the prescription. Over all the plan sounds very well thought through and I will support it.” Response: Thanks for your comments. Following the primary treatment of stands we conduct condition surveys to help us determine additional reforestation needs such as planting and seeding. If we leave seed trees on site and then conduct some prescribed burning, we may not need the artificial seeding. However, for most areas on the Forest, competition from other species, especially aspen, is abundant and the reason we prescribe site preparation. Finally, the National Forest Management Act (NFMA) requires that we have an established stand five years after harvest. The need to plant or seed is based on a site inspection and survey.

Regarding the ELT stand information, this information is included in our stand analysis files and available per request.

http://www.fs.usda.gov/projects/superior/landmanagement/projects



Comment MS-030-1 (Mark Pohto): “I’m contacting you regarding the Mesabi Project Attachment 3 Proposed action by stand unit. The project is to log off sections 106,107,108,109, and 110 north of Big Rice Lake. I have hunted these woods for 30 years with my brother-in-laws. Portions of the woods we hunt have been logged off twice already. The woods you plan on logging is the only old growth forest left in the area that we hunt. The wildlife in the old growth forest is far more abundant than you will find in the Aspen regrowth. Cutting these sections will eliminate the best possible habitat for the existing wildlife. Please reconsider your decision to cut the remaining old forest, there just doesn’t seem to be that much timber on it. Thank you for your time.” Response: Please see the comment to MS-024-1. Comment MS-031-2 (Mark Prchal): “My ? to you also is how do you plan to keep the deer from eating all of your new plants. I planted 1000 white pine and bud capped them the first year but did not get a chance to cap them the following year and now I have none. But I would love to see more of the pine, spruce. Are you going to do any projects on private land? It didn’t look like you were I was just asking. Please keep me informed.” Response: When feasible, planted seedlings would be protected from browse with tubing or by budcapping. Additionally, as described in our monitoring appendix (d) on pp. 7-8, all stands harvested and converted to conifer will be monitored during the first and third years after planting to determine survival and stocking success.

All proposed treatments would take place on National Forest System lands only. We will keep your information on the project mailing list.

Comment MS-032-1 (Carl Racchini): “Units 291 & 292, Unit 291-6 to 7 acres would that area be planted? This area has milkweed used for monarch butterflies. Aspen/birch/balsam fir – why not stand diversity? Fuels work talk about keep not hazardous to fire Scattered wetlands = buffer waterbodies Road access – cabins along lake maintain the road, damage to road during harvest Eagle nest on other side of lake. Great Gray Owls in area no nests. Three toed woodpeckers. Spruce budworm killed balsam.” Response: Both units 291 and 292 would be harvested, burned, and planted to convert to more of a white and red pine forest.

Comment MS-034-1 (Kyle Rahikainen): Mr. Rahikainen called and inquired what is the Mesabi project? He received the scoping letter.

Response: The project leader explained the various proposed actions/treatments to Mr. Rahikainen. He is ok with what we are doing … taking care of the forest.

Comment MS-039-1 (Michael Smith): “1. Will the road that was decommissioned appendix D - U125603.1 Still be made to be impassable to all motorized traffic.” Response: Yes. For more information, see response to comment 45-1 on the definition of decommissioning.

Comment MS-039-2 (Michael Smith): “2. Will there be a buffer zone on my property lines or will they log right up to it. 3. As to my concern with item # 2 . I ask this because if they log up to my property line this leaves the property more open bullets from road hunters to come flying



through my property. Also this will greatly reduce a wind break from north and northwest winds.” Response: Generally, buffers are not left along roads in the sense of a continuous strip of uncut trees of a particular width. These areas are part of the stands that would be managed. However, during harvest layout individual trees or clumps of trees are typically left for various reasons and tend to break up the temporary opening created by the harvest.

Comment MS-039-3 (Michael Smith): “4. This may not matter but this property has some historical history. It is one of the Earlier homestead sites established in this area about 1917 by otto wallta.” Response: Thank you for your comment and sharing the information. The Forest Service fully anticipates conducting heritage resource field survey’s on National Forest System (NFS) land prior to ground disturbance. FS heritage sites that are identified (on NFS land) during field surveys will receive proper site avoidance to mitigate potential damage.

Comment MS-039-4 (Michael Smith): “5. If this project does go forward I would like to know the dates and time schedules that this will happen particulary areas 115 and 107.” Response: Comment noted. We will enter your name into the database so the timber sale administrator can contact you prior to implementation.

Comment MS-040-1 (Steven Smokey): “I currently own and manage property within the Superior National Forest that will be impacted by the Mesabi Project. As referenced in Map Attachment 1 and Proposed Actions Attachment 3, the north and east property lines of my property will be impacted by forest management activities conducted in Unit #107. The activities include shelterwood management and the application of herbicides on approximately 144 acres. Please note that the eastern section of Unit #107 contains a unique bolder field geographical feature. I have shown pictures of the bolder field to several Minnesota geologists who have communicated that the size and undisturbed condition of the field make it a valuable geological resource. Also be informed that sections of the field, and its associated drainage, cross through my property. I am requesting that additional management requirements be added to the plan for Unit #107 to address preservation of the bolder field. Additionally, I am requesting that a buffer zone of healthy mature trees remain along the property lines. However, there are several dead or diseased trees along the north property line that will hopefully be harvested. I am also suggesting that the Forest Service visit with adjacent property owners along the property lines or at points of concern to address project details that would be difficult to list in a report or in writing. Thank you for giving me the opportunity to comment.” Response: Features such as boulder fields and ELT 18 areas usually have varied terrain and thin soils; so most of these areas are inoperable for logging equipment. These areas would be flagged off for reserve islands if there are merchantable trees in them during layout or the stand would be modified to exclude these areas. A note was added to this unit to make sure everyone is aware of this boulder and to mitigate properly.

Please see response to comment MS-039-2 regarding buffers. Unit 107 is typed as a paper birch stand and proposed for a shelterwood harvest. Please refer to appendix a in the EA for a complete description of this treatment type. Typically when National Forest System lands abut private land, property lines are located through survey or other means. Property lines are



typically not cut in straight lines and shelterwood harvests would include reserve areas and legacy patches that could be placed along your property line to minimize any blowdown or windthrown trees that may occur. This unit is also flagged as being adjacent to private land and will be treated accordingly.

Information on the proposed action for the project has been sent to landowners in and around the project area.

Comment MS-042-1 (Franklin Sterle): “Roads A21 & A22. I am not a fan of new roads in the area. If this is for logging, I would like to see the road closed and bermed after.the logging is done. If for other uses, no road.” Response: Temporary roads constructed for vegetation management activities would be decommissioned after all treatments have been completed. Other than any special use access roads, no new National Forest System roads used for long-term access needs would be constructed on NFS lands within the project area.

Comment MS-043-1 (Walt Sweeney): “Owns hunting land off of 73. Believe involved in this Mesabi project. Like to know what you people are proposing to do. Received letter, call me back and give me some information on what this is all about.” Response: The wildlife biologist phoned Mr. Sweeney and explained the proposed plan in unit 530; which is adjacent to this property. It is proposed to be clearcut with reserves and either site prep burned or receive mechanical site prep with seeding to jack pine.

Mr. Sweeny was satisfied with that and was just checking to make sure his property will not be affected.

Comment MS-045-1 (John Vukmanich): “I received a letter today regarding the Mesabi Project and had some questions. When an existing road is labelled to be decommissioned, what exactly does that mean? I currently hunt deer in an area accessed by an old logging road that is marked on the map for decommission. The road is not motorized use, is not designated, and is currently bermed and blocked by boulders. I access the area on foot. Will the road simply be left and considered non-designated or is the road going to be dug up and planted? Also, a paragraph in the plan references unauthorized motorized vehicle use to access Big Aspen via an old logging road and power line from Cty Rd 302. I live on 302 near the power line and am very curious about this statement and why this area is an issue. I frequent this area regularly and will likely have additional questions, too, regarding motorized access plans and trail designations. Any help would be appreciated.” Response: Decommissioning a road means it would be effectively blocked from any further motorized use (see forest plan guideline G-TS-16 p. 2-50.) It can include activities that result in restoration to a more natural state (FSM 7735). Activities are dependent on the road features but usually involve installation of a berm or rocks are at the beginning, removal of any culverts, and sometimes planting a few trees in the first 100 feet or so to try and block the view of the closed road from the main road. In most cases foot travel is remains possible since most of the road would not be changed.

The current proposal is to legally open the old logging road and the trail under the powerline to allow ATVs to access the Big Aspen trail from SC302. Currently, it is not part of the trail system



so it is considered illegal to use those trails. Adding it to the trail system would make it legal to use.

Comment MS-037-1 (Brad Sagen-Sierra Club): “EIS Requested. The National Environmental Policy Act (NEPA) requires preparation of an EIS for "major Federal actions significantly affecting the quality of the human environment." 42 U.S.C. § 4332(2)(c). Governing regulations adopted by the U.S. Forest Service direct, “If the responsible official determines, based on scoping, that the proposed action may have a significant environmental effect, prepare an EIS.” 36 C.F.R. § 220.6(c). Because of the complex issues and uncertainty regarding the proposed use of herbicides in the Mesabi Vegetation Project, Sierra requests a full EIS for the Project. The rationale for the request is presented in the comments that follow.” Response: We understand your request for an EIS; however, no significant impacts (in terms of context or intensity) have been identified warranting an EIS to be prepared by the IDT. The team has been directed to prepare an EA analyzing potential direct, indirect, and cumulative effects. Within the EA, a no herbicide alternative will be analyzed. The environmental analysis process will include identification of issues, as well as development and analysis of alternative actions and incorporation of mitigations and design criteria. If the interdisciplinary team determines that significant effects are likely, an EIS will be prepared.

Herbicide use as a timber stand improvement (TSI) tool was recommended by the silviculturist for regenerations, conversion purposes, and to prevent seedlings from being outcompeted by aspen or brush (EA section 2.3-Alternatives Analyzed in Detail). Potential direct, indirect, and cumulative effects to resources from herbicide are anticipated to be minimal because application of herbicide under alternative 2 for the project would follow Forest Service manual section 2150 concerning pesticide use, management, and coordination; the Forest Service Health and Safety Code Handbook chapter 22.1; the Minnesota Department of Natural Resources Voluntary Site-level Forest Management Guidelines for herbicide use; and all manufacturers labeled use guidelines. In following the MN DNR Voluntary Site-level Forest Management Guidelines for herbicide use, it is stated to, “avoid broadcast application methods within filter strips and riparian management zones” (p. 16-Pesticide Use MFRC). Additional mitigation measures that would be employed during operations can be found in the herbicide proposal (appendix h) and chapter’s 3.8 and 3.9.

Comment MS-009-2 (Kristian Jankofsky): Discussed road proposed to be decommissioned that access his property. It will need to be looked at and a decision whether a special use is needed or that the road can be moved over to the USFS. Also discussed proposed OML 1 south of his property. He agreed with not allowing ATVs/trucks since they use it now and trespass on his property. Response: It was determined that the road in question did not need a special use permit since it was within the county road right-of-way. Comment MS-010-6 (Al Jarvinen): “A reference section should be added to the project proposal for all the cited literature. Thank you for considering my comments.” Response: Please see ch. 4, section 4.3-References and Literature Cited in the EA. Comment MS-022-1 (Wesley Mattonen): Owns property (40 acres) in Sandy Township T60N R17W Section 13. Would like some info on what is happening in the area.



Response: The IDT wildlife biologist phoned Mr. Mattonen back and explained about the proposed harvest on NFS land to the north and that we would probably not need access across his property. Mr. Mattonen was satisfied with that response.

Comment MS-023-1 (Jim McCarty): Mr. McCarty called during scoping requesting general information about the project.

Response: The project leader spoke with him. He thinks it is a good project. He owns two parcels, one 8 miles north of Virginia and one west southwest of Cook on the Sturgeon River. The parcel north of Virginia is in the Mesabi Project Area.

Comment MS-031-1 (Mark Prchal): “I am writing you today in regards to the Mesabi Project (36 CFR 218.5). I looked over the draft plan on line and saw some of the proposals. I would like to see more pines planted (white, red, and jack. Also more spruce planted as the aspen are the norm right now and that’s all you see. Let me add in balsam fir and how about white cedar.” Response: The project would include 13,732 acres of secondary treatment (including 277 acres of diversity planting), and 3,113 acres of reforestation (with 288 acres of diversity planting and 907 acres of seeding).

Comment MS-038-1 (Scott Schultz): “My land is flanked by the proposed gravel pits 306 Pit A and HWY 53 A. I would like to get some clarification about these planned pits so I can determine if those projects would impact how I use my land or impact the resale value of my parcel. I would appreciate speaking with you to clarify the plans for these gravel pits. Until I can get some clarity to the proposal, please let this email serve as my notice of my desire to have the option to submit an objection to these projects. Thank You.” Response: After further review of the 306 pit and the Highway 53 pit, they are both being removed from consideration from further development. They were identified in the Virginia EIS because of the potential need for the Highway 53 project that was just starting up at the time. However, both sites have limited quantities of material available, potential access issues, and are located in an area in low demand for Forest Service use. They are planned to be closed (see table 3.12.4-1 in EA). Comment MS-044-2 (Darren Vogt-1854 Treaty Authority): “Moose Lake can contain good crops of wild rice utilized by harvesters. The scoping report states: “Moose Lake is a wild rice and waterfowl hunting lake that receives a moderate level of use. This site is currently not a managed recreation sites therefore resource damage is occurring. To accommodate current use patterns and to address resource damage, the Mesabi Project proposed action is to designate and manage this is a backcountry campsite.” It is important to maintain access to the lake, and it is our understanding that the proposal does not change current access (ATV trail / longer carry-down access). Little Rice Lake is also utilized by wild rice harvesters. In an effort to maintain and improve wild rice on the lake, beaver management is occasionally needed on the outlet that drains into Big Rice Lake. It is my understanding that a trail provides access for this management work. The transportation map for the Mesabi Project indicates decommissioning two roads (trails?) that I believe provide this access. These trails are necessary for management actions at Little Rice Lake. Thank you, and please contact me with any questions about our comments.”



Response: This project would not change the access to Moose Lake. This project would decommission 600 feet of trail that goes down to the creek near Little Rice Lake because of current ATV use across the creek. Walk-in access would be available in this corridor after decommissioning for management purposes.

CATEGORY #5: COMMENTS NOTED Comment MS-004-1 (Dennis Carlson): The area around/near him was logged about 18 years ago. He is pro-logging.

Response: Comment noted.

Comment MS-015-1 (Mike Kochevar): “Please keep informed of all that is going on for the Mesabi project. I am in a shack in that area by the Dark River “Dark River Haven.” Response: Comment noted. Mr. Kochevar will remain on the mailing list. Comment MS-018-10 (Clay A Mariucci): “Please be aware that Richard Mariucci, Ann Oelrich, Mark Mariucci and Clint Mariucci have all been involved in formulating these comments and will likely submit either their own echoed concerns or a letter affirming they wish my comments here to be reiterated also as their own. Please contact me with any available information. Sincerely, Clay Mariucci” Response: Please see comment and responses from MS-018. Clay A Mariucci

Mark Mariucci Response: Please see comments and responses from MS-018. Clay A Mariucci

Richard Mariucci Response: Please see comments and responses from MS-018. Clay A Mariucci

Ann Oelrich Response: Please see comment and response from MS-018. Clay A Mariucci

Comment MS-036-5 (Kristi Rolf): “Comment 5. I am in support of decommissioning (721) D41, D42, and (722) D44. Thank you” Response: Comment noted.

Comment MS-046-1 (Floyd Weappa): Property Lake 13 in Britt. All for cleaning up the forest.

Response: Comment noted.

Comment MS-047-1 (Joyce Zimmerman): They own a cabin on Long Lake. T59N R20W Sec8. They want to know if anything is being proposed on FR1842. She indicated they have the same goals for their property to make it nice for animals. They would like to stay on the mailing list.

Response: We are not proposing any changes to FR1842. Comment MS-048-1(Rebecca Zimmerman-Nomeland): “Hello- I'm writing on behalf of my mom, Joyce Zimmerman (copied here), on our concern of the decommissioning proposal for Zimmerman Road off of HWY 73.Our cabin road links in with Zimmerman Road. We will not have access to the cabin if the road is closed. Our 40 acres abuts the National Forest and Long



Lake. We want to keep this 40 acres as a wildlife and nature preserve. We are happy to work with you on your goals for the area conservation. Please reach out with any concerns/questions that you have for us.” Response: See response to the above comment. PUBLIC THAT REQUESTED TO STAY ON THE PROJECT MAILING LIST:

• John Anderson

• Dick Artley

• Walter Carlson

• William Corrigan

• Rocci Debreto

• Frank Fabish

• Leota Hanson

• Bill Jussela

• William & Inez Nelson

• William Pont

• Darrel Swenson

• Clifford Wiklund



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