Stop commercial logging on Cherokee National Forest

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• The EA's own Biological Assessment summary discloses a 'May Affect, Likely to Adversely Affect' determination for the Indiana bat, with approximately 3,537 acres of preferred summer roosting habitat impacted, yet the agency dismisses further site-specific analysis by simply tiering to a prior Programmatic Biological Opinion without showing that this project's specific footprint, acreage, and timing were actually evaluated in that consultation. Given this is the most serious effects finding in the whole document for any listed species, the agency should directly analyze in the EA (not just by reference) how this project's impacts were quantified within the Programmatic BO's scope, or prepare a project-specific Biological Opinion and an EIS given the likely adverse effect finding.
• Section 3.3.5 directly contradicts itself on prescribed fire in the Queen Cove/North River bog rare community. The affected environment discussion states that approximately 98 acres of this rare, fire-intolerant wetland bog complex are proposed for burning as part of the Whigg Ridge burn unit, but the mitigation measures in the same section state that no ignition of prescribed fire is permitted within that same rare community. The agency needs to reconcile this contradiction, clarify the actual burn unit boundary relative to the rare community boundary, and disclose whether the 98 acres figure is accurate or an error, before the public can meaningfully comment on impacts to this unique, non-fire-adapted plant community.
• The document's own fire-effects analysis, drawing on Pistrang's white paper, concludes that rich cove, acid cove, and northern hardwood forest communities are fire-sensitive and states plainly that prescribed fire is not an appropriate tool there, ending with an explicit recommendation against burning. Yet Table 6 shows these same ecozones (Acidic Cove Forest, Rich Cove Forest, Northern Hardwood Slope Forest, Northern Hardwood Cove Forest) occupy thousands of acres within the project boundary and some fall within harvest unit and fire return interval acreage. The agency should explain how burn unit boundaries were drawn to exclude these community types or revise the proposed action to remove them from prescribed fire treatment as its own specialist recommended.
• Section 3.4.1 asserts that water quality in project-area streams is good and that all streams are fully supporting designated beneficial uses, while in the same breath acknowledging ongoing sediment delivery and altered stream morphology from roads near the Tellico River, North River, and their tributaries. The agency treats this acknowledged degradation as consistent with 'good' water quality without reconciling the two statements or explaining the threshold at which sediment and morphology changes would become a beneficial-use impairment. The agency should directly analyze the cumulative sediment and morphology impacts already occurring from roads before concluding new ground-disturbing activities pose only low risk.