Sherman Bamford's Virginia Forest Watch Jan. 23, 2006 comment letter

Forest Service March 24, 2006 response letter

At the Upper Craig logging project in Montgomery County, the Forest Service allowed logging to proceed under wet and muddy conditions in violation of the Forest Plan and then stated that logging under these kind of conditions is "fairly common".

- photographs were taken on Dec. 31, 2005

How can we trust the Forest Service?

The width of the road is very wide - approximately 24 feet wide near Rush Hollow Creek, which is a perennial stream (VAFW field observations Dec. 31, '05 and Decision Notice p. 3). Unfortunately, this logging project is already estimated to increase the amount of sediment dumped into the stream by 15.8% (Environmental Assessment p. 65). In this project, roads of this type were only intended to be constructed with a travelway about half this width, with 12 feet of travelway and an additional 18 feet of right of way (Environmental Assessment p. 56).

Building a road this wide close to a perennial stream may certainly negatively affect the stream and its riparian area. The Forest Plan does in fact require the Forest Service to locate stream crossings as close to a right angle as possible, but this is to "minimize the length of streamside disturbance" (Jefferson National Forest Plan Revision p. 3-186). In this case, the Forest Service chose to locate the widest sections of the road and additional turn lanes nearest the stream (Forest Service response to Sherman Bamford's letter dated Mar. 24, '06). This turns the logic of the Forest Service Plan on its head.

Virginia Forest Watch is concerned that this kind of unwise road construction has the potential to degrade water quality.