On behalf of the members of the Kezar Lake Watershed Association, the Board of Trustees is submitting comments in response to the Draft Environmental Assessment (EA) for the Albany South Integrated Resource Project (Albany South). These comments express our position and concern for the Albany South Project and its impact on the Watershed.
Albany South is a multi-phased Integrated Resource Management Project proposed for National Forest lands in Stoneham, Lovell, Albany Township and Mason Township (Oxford County). The Project area is about 7,500 acres on the east-central edge of the White Mountain National Forest. The amount of timber harvesting associated with the Project varies with the major Project Alternatives, but would range from 397 acres to 965 acres in the Kezar Lake Watershed. The Project has a broad range of objectives, all of which are grounded in the White Mountain National Forest’s 2005 Land and Resource Management Plan. The US Forest Service derives its forestry management objectives and implementation strategies from this critical document.
The Albany South Project has been in process for more than four years, involving many stakeholders. The recent release of the Draft Environmental Assessment reflects the formal output from that process and also triggered an official 30-Day Comment Period which ends on June 6.
Officially there are five Project Alternatives, including Alternative 1, which is designated “No Action”. Alternative 1 is widely considered to be an unlikely outcome from the process and is used primarily as baseline reference for evaluating the relative differences in other Project Alternatives.
Alternative 2 is a modification of the initial proposal, changed in response to public comments to the July 2013 Scoping Report, including those made by the KLWA. In terms of acreage impacted, Alternative 2 is among the largest of the Project options. The differences between Alternatives 2, 4 and 5 can be measured in modest differences in total scale, and mainly differ in routing options relative to their use of the Hut Road. Their impacts on acreage within the Kezar Lake Watershed are fairly similar: Alternatives 2 & 5 involve 956 acres, and Alternative 4 involves 712 acres.
Alternative 3 is materially different in that it excludes from action the Caribou – Speckled Mountain Inventoried Roadless Area, which extends from Great Brook to Beaver Brook. By comparison Alternative 3 reduces the harvest to 397 acres in the Kezar Lake Watershed.
The Mission of the KLWA is to preserve, protect and maintain the ecological, scenic and recreational resources of Kezar Lake and its watershed for the benefit and enjoyment of residents and visitors, now and in future generations. As such, our preference would be for Alternative 1. But we are realistic about the prospects for that outcome and must therefore support Alternative 3, which poses measurably lower risk to the Kezar Lake Watershed.
The framework for a final decision by the Forest Service still allows for modification to the current Alternatives. The KLWA has submitted detailed comments addressing areas of concern with the expectation that some of these will be reflected in the Final Environmental Assessment and the Draft Final Decision when they are released. Even at that stage there will be continued opportunity for discussion and potential adjustments – although the scope of options narrows considerably.
KLWA’s comments on the Draft EA include these critical areas of concern:
- The mapped inventory of streams, vernal pools, wetlands, and groundwater seeps remains incomplete. Additional resources which have been identified should added to the maps.
- Wider buffers are requested for perennial streams (75’), intermittent streams (25’), and wetlands (75’); and Stream Smart management practices be employed for all stream crossings.
- Use of temporary bridges for all perennial stream skid trail crossings and harvest activity only in frozen, snow covered or dry conditions.
- More fully developed plans for increased frequency and intensity of extreme weather events.
- Minimize impact to winter recreational activity and preserve the view shed from Kezar Lake.
- Minimize the impact of logging and gravel trucks on rural roads, particularly the Hut Road with its narrow, winding nature.
- Develop ongoing project management and monitoring plans and tools; and continue to involve concerned parties.
Additional detail and an inventory of specific requests and questions for the Forest Service are included in the complete Comments document. KLWA appreciates the opportunity to comment on the Draft EA and trusts that the Forest Service will offer their careful consideration to our comments and suggestions. The 2005 Management Plan is already 11 years old and it seems reasonable to suggest that the bar may have moved both in our understanding of risk mitigation and of potential threats such as Climate Change. We simply ask that, as this Project advances, the FS employ Maine Forest Service Best Management Practices; the most advanced measures of on-the-ground supervision; and regular Project review.
How Can I Help?
There are many projects that would benefit from your support and involvement. Help us sustain this wonderful environment for many generations to come. Give to KLWA so that we might reserve the watershed for children and grandchildren the same experiences that have been so meaningful to each of us. Volunteer and share your gifts with us.