The Ecology Center 314 N. 1st Street Missoula, mt 59802 (406) 728-5733 (406) 728-5779 fax




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The Ecology Center
314 N. 1st Street
Missoula, MT 59802
(406) 728-5733
(406) 728-5779 fax
ecocenter@wildrockies.org

January 3, 2006

Robert M. Harper, District Ranger
Superior Ranger District
P.O. Box 460

Superior, Montana 59872


Transmitted via email—please acknowledge receipt!


Mr. Harper,


These are comments on the Canyon Creek Thinning project proposal (your December 8, 2005 letter with enclosure), on behalf of the Ecology Center and Alliance for the Wild Rockies. We incorporate our previous January 21, 2005 comments, and offer these as well.


We note that the item upon which we’re being asked to comment is essentially the same Decision Memo you signed on July 11, 2005 and never withdrew. It seems like a perfunctory exercise, us sending a letter that will be essentially ignored since a decision has already been made.


Many adverse consequences to soil, ecological processes, wildlife, and other elements of the natural environment are associated with logging, including thinning. (Ercelawn, 1999; Ercelawn, 2000.) For example: “Salvage or thinning operations that remove dead or decayed trees or coarse woody debris on the ground will reduce the availability of forest structures used by fishers and lynx.” (Bull et al., 2001.)


We believe that high intensity forest manipulation as you are proposing will not lend towards restoring functional ecosystems. Rather, logging activities will lead to accelerated erosion and soil compaction and will disrupt the natural processes. Fire is a natural and essential component of forest ecosystems. The presence of fire indicates high degrees of ecosystem function. Beschta et al., 1995 state, “Land managers should be managing for the naturally evolving ecosystems, rather than perpetuating artificial ones we have attempted to create.”


Any forest condition that is maintained through intense mechanical manipulation is not maintaining ecosystem function. We request detailed disclosure of the historical data used to arrive at any assumption of “desired conditions.” Also, are the proposed management activities designed to foster the processes that naturally shaped the ecosystem and resulted in a range of natural structural conditions, or are they merely designed to recreate structural conditions in a single point in time that you consider natural? Generally, past process regimes are better understood than past forest structure. How are you factoring in fire, insects, tree diseases, and other natural disturbances in specifying the structural conditions you assume to be representative of the historic range?


McClelland (undated) states:

The snags per acre approach is not a long-term answer because it concentrates on the products of ecosystem processes rather than the processes themselves. It does not address the most critical issue--long-term perpetuation of diverse forest habitats, a mosaic pattern which includes stands of old-growth larch. The processes that produce suitable habitat must be retained or reinstated by managers. Snags are the result of these processes (fire, insects, disease, flooding, lightning, etc.). (Emphasis added.)


And Hutto, 1995 addresses the processes topic, talking about fire in that case:

Fire is such an important creator of the ecological variety in Rocky Mountain landscapes that the conservation of biological diversity [required by NFMA] is likely to be accomplished only through the conservation of fire as a process…Efforts to meet legal mandates to maintain biodiversity should, therefore, be directed toward maintaining processes like fire, which create the variety of vegetative cover types upon which the great variety of wildlife species depend. (Emphasis added.)


Veblen (2003) questions the premises the FS often puts forth to justify “uncharacteristic vegetation patterns” discussions, that being to take management activities to alter vegetation patterns in response to fire suppression:

The premise behind many projects aimed at wildfire hazard reduction and ecological restoration in forests of the western United States is the idea that unnatural fuel buildup has resulted from suppression of formerly frequent fires. This premise and its implications need to be critically evaluated by conducting area-specific research in the forest ecosystems targeted for fuels or ecological restoration projects. Fire regime researchers need to acknowledge the limitations of fire history methodology and avoid over-reliance on summary fire statistics such as mean fire interval and rotation period. While fire regime research is vitally important for informing decisions in the areas of wildfire hazard mitigation and ecological restoration, there is much need for improving the way researchers communicate their results to managers and the way managers use this information.


Baker and Ehle, 2001 present theory and empirical results that suggest that fire-history data have uncertainties and biases when used to estimate the population mean fire interval (FI) or other parameters of the fire regime. From their Abstract:

Present understanding of fire ecology in forests subject to surface fires is based on fire-scar evidence. We present theory and empirical results that suggest that fire-history data have uncertainties and biases when used to estimate the population mean fire interval (FI) or other parameters of the fire regime. First, the population mean FI is difficult to estimate precisely because of unrecorded fires and can only be shown to lie in a broad range. Second, the interval between tree origin and first fire scar estimates a real fire-free interval that warrants inclusion in mean-FI calculations. Finally, inadequate sampling and targeting of multiple-scarred trees and high scar densities bias mean FIs toward shorter intervals. In ponderosa pine (Pinus ponderosa Dougl. ex P. & C. Laws.) forests of the western United States, these uncertainties and biases suggest that reported mean FIs of 2–25 years significantly underestimate population mean FIs, which instead may be between 22 and 308 years. We suggest that uncertainty be explicitly stated in fire-history results by bracketing the range of possible population mean FIs. Research and improved methods may narrow the range, but there is no statistical or other method that can eliminate all uncertainty. Longer mean FIs in ponderosa pine forests suggest that (i) surface fire is still important, but less so in maintaining forest structure, and (ii) some dense patches of trees may have occurred in the pre-Euro-American landscape. Creation of low-density forest structure across all parts of ponderosa pine landscapes, particularly in valuable parks and reserves, is not supported by these results.


In response to these scientific concerns, we ask that the FS disclose what fire history methodology it uses, acknowledge the limitations of the fire history methodology, and disclose what project-area data it’s relying upon.


Please consider that thinning can result in faster fire spread than in the unthinned stand. Graham, et al., 1999a point out that fire modeling indicates:

For example, the 20-foot wind speed1 must exceed 50 miles per hour for midflame wind speeds to reach 5 miles per hour within a dense Stand (0.1 adjustment factor). In contrast, in an open stand (0.3 adjustment factor), the same midflame wind speeds would occur at only a 16-mile-per-hour wind at 20 feet.


Graham, et al., 1999a also state:

Depending on the type, intensity, and extent of thinning, or other treatment applied, fire behavior can be improved (less severe and intense) or exacerbated.” … Fire intensity in thinned stands is greatly reduced if thinning is accompanied by reducing the surface fuels created by the cuttings. Fire has been successfully used to treat fuels and decrease the effects of wildfires especially in climax ponderosa pine forests (Deeming 1990; Wagel and Eakle 1979; Weaver 1955, 1957). In contrast, extensive amounts of untreated logging slash contributed to the devastating fires during the late 1800s and early 1900s in the inland and Pacific Northwest forests.


In their conclusion, Graham, et al., 1999a state:

Depending on intensity, thinning from below and possibly free thinning can most effectively alter fire behavior by reducing crown bulk density, increasing crown base height, and changing species composition to lighter crowned and fire-adapted species. Such intermediate treatments can reduce the severity and intensity of wildfires for a given set of physical and weather variables. But crown and selection thinnings would not reduce crown fire potential.


Also, Hessburg and Lemkuhl (1999) suggest that prescribed burning alone can be utilized in many cases—possibly here—where managers typically assume mechanical fuel reductions must be used.


The FS is often misplaces the threats to clean water onto vegetative conditions instead of correctly identifying the true threats to watershed health. The Western Montana Level I Bull Trout Team (Riggers et al., 2001) state:

(T)he real risk to fisheries is not the direct effects of fire itself, but rather the existing condition of our watersheds, fish communities, and stream networks, and the impacts we impart as a result of fighting fires. Therefore, attempting to reduce fire risk as a way to reduce risks to native fish populations is really subverting the issue. If we are sincere about wanting to reduce risks to fisheries associated with future fires, we ought to be removing barriers, reducing road densities, reducing exotic fish populations, and re-assessing how we fight fires. At the same time, we should recognize the vital role that fires play in stream systems, and attempt to get to a point where we can let fire play a more natural role in these ecosystems.


The biologists emphasize, “the importance of wildfire, including large-scale, intense wildfire, in creating and maintaining stream systems and stream habitat.” The biologists continue “in most cases, proposed projects that involve large-scale thinning, construction of large fuel breaks, or salvage logging as tools to reduce fuel loading with the intent of reducing negative effects to watersheds and the aquatic system are largely unsubstantiated.” The biologists point out that logging, thinning and fire suppression can have harmful effects on watersheds (Id.). We ask that the FS explicitly consider Riggers et al., 2001 in the subsequent NEPA document.


Roads often have devastating impacts on water quality and fish habitat by increasing landslides, erosion, and siltation of streams. Roads also fragment forests and degrade or eliminate habitat for species that depend on remote landscapes, such as grizzly bears, wolves, and other large, wide-ranging predators (Trombulak and Frissell 2000). The FS must utilize the Roads Analysis Process and analyze travel management, including road obliteration possibilities, in the analysis area.


The FS seems to fail to understand that dead, diseased, dying, etc. trees have a role in the forest—they are not something to be avoided in attempting to “Create healthier coniferous forest conditions…” . Please disclose the amounts of snags, recruitment snags, and down woody debris previous logging operations have left in previous similarly logged units, so that the public can tell if you’ve met Forest Plan Standards in those units. Please perform surveys to determine the amounts of snag habitat and down woody debris exist in similarly stocked unmanaged areas for comparison.


Please disclose how stands to be logged compare to old-growth criteria. In order to disclose such information, please provide all the details, in plain language, of these areas’ forest characteristics (the various tree components’ species, age and diameter of the various tree components, canopy closure, snag density by size class, amounts of down logs, understory composition, etc.).

Please disclose whether the amount of existing old growth meets standards and other required levels for old-growth habitat. The FS must consider the likelihood that the areas proposed for logging will have old-growth habitat characteristics enhanced, not destroyed by the same natural processes the FS is using as a reason for the logging proposal. Please disclose if the proposed cutting units were, still are, or will, in the foreseeable future, qualify as old growth. What criteria or definition(s) of old growth are you using? Please disclose how the project will impact the old-growth wildlife species, and mature forest associated species.


Please disclose, using tables and maps, the amounts, locations, sizes, and connectivity of all old-growth stands in the project area. Disclose whether it is actual old growth (meets all criteria) or whether it is “recruitment” old growth. Disclose whether or not you have compared all stands proposed for logging and/or burning to the old-growth criteria. Please disclose the methodology used to identify each stand as old growth, recruitment old growth, or not old growth.


The Lolo NF has failed to cite any evidence that managing for old growth habitat (i.e., logging to improve or create old growth) strategy will improve old growth species habitat over the short-term or long-term. In regards to such a position:

(T)here is the question of the appropriateness of management manipulation of old-growth stands… Opinions of well-qualified experts vary in this regard. As long term results from active management lie in the future – likely quite far in the future – considering such manipulation as appropriate and relatively certain to yield anticipated results is an informed guess at best and, therefore, encompasses some unknown level of risk. In other words, producing “old-growth” habitat through active management is an untested hypothesis.

(Pfister et al., 2000, pp. 11, 15 emphasis added).


For the proposal to be consistent with the Forest Plan, enough habitat for viable populations of old-growth dependent wildlife species is needed over the landscape. The Lolo NF has failed to insure viability of MIS and TES species to date.

The FS has acknowledged that viability is not merely a project area consideration, that the scale of analysis must be broader:

Population viability analysis is not plausible or logical at the project level such as the scale of the Dry Fork Vegetation and Recreation Restoration EA. Distributions of common wildlife species as well as species at risk encompass much larger areas than typical project areas and in most cases larger than National Forest boundaries. No wildlife species that presently occupy the project area are at such low numbers that potential effects to individuals would jeopardize species viability. No actions proposed under the preferred alternative would conceivably lead to loss of population viability. (Lewis and Clark NF, Dry Fork EA Appendix D at p. 9.)


The FS should firmly establish that the species that exist, or historically are believed to have been present in the analysis area are still part of viable populations. Since Forest Plan monitoring efforts have failed in this regard, it must be a priority for project analyses. Identification of viable populations is something that must be done at a specific geographic scale. The analysis must cover a large enough area to include a cumulative effects analysis area that would include truly viable populations. Analysis must identify viable populations of MIS, TES, at-risk, focal, and demand species of which the individuals in the analysis area are members in order to sustain viable populations.


The fact that the Lolo NF has not monitored the population trends of its old-growth management indicator species (MIS) as required by the Forest Plan bears important mention here. The Lolo NF has failed to insure viability of MIS and TES species to date.

Considering potential difficulties of using population viability analysis at the project analysis area level (Ruggiero, et. al., 1994), the cumulative effects of carrying out multiple projects simultaneously across the Lolo NF makes it imperative that population viability be assessed at least at the forestwide scale (Marcot and Murphy, 1992). Also, temporal considerations of the impacts on wildlife population viability from implementing something with such long duration as a Forest Plan must be considered (id.) but this has never been done by the Lolo NF. It is also of paramount importance to monitor population trends (as mandated by the Forest Plan) during the implementation of the Forest Plan in order to validate assumptions used about long-term species persistence i.e., population viability (Marcot and Murphy, 1992; Lacy and Clark, 1993).


Unfortunately, region-wide the FS has failed to meet Forest Plan old-growth standards, does not keep accurate old-growth inventories, and has not monitored population trends in response to management activities as required by Forest Plans and NFMA (Juel, 2003).


State-of-the-art conservation biology and the principles that underlie the agency’s policy of “ecosystem management” dictate an increasing focus on the landscape-scale concept and design of large biological reserves accompanied by buffer zones and habitat connectors as the most effective (and perhaps only) way to preserve wildlife diversity and viability (Noss, 1993).


The FS has stated: “Well distributed habitat is the amount and location of required habitat which assure that individuals from demes,2 distributed throughout the population’s existing range, can interact. Habitat should be located so that genetic exchange among all demes is possible.” (Mealey 1983.)


Please include in your analysis the possible effects of noxious weed introduction on Sensitive plant populations and other components of biodiversity. Please include in the analysis the results of monitoring of noxious weed infestations and treatment efficacy from past management actions in the Forest


One of the biggest problems with the FS’s failure to deal forthrightly with the noxious weed problem on a forestwide basis is that the long-term costs are never adequately disclosed or analyzed. The public is expected to continuously foot the bill for noxious weed treatments—the need for which increases yearly as the Lolo NF continues the large-scale propagation of weeds, and fails to monitor the effectiveness of all its noxious weed treatment plans to date. There is no guarantee that the money needed for the present management direction will be supplied by Congress, no guarantee that this amount of money will effectively stem the growing tide of noxious weed invasions, no accurate analysis of the costs of the necessary post-treatment monitoring, and certainly no genuine analysis of the long-term costs beyond those incurred by site specific weed control actions.


We request the FS adopt the Forest Restoration Assessment Principles found within the Forest Restoration Principles and Criteria (DellaSala, et al., 2003) as a screen for all proposed actions.


Our goals for the area include fully functioning stream ecosystems that include healthy, resilient populations of native trout. The highest priority management actions in the project area are those that remove impediments to natural recovery. We request the FS design a restoration/access management plan for project area streams that will achieve recovery goals. The task of management should be the reversal of artificial legacies to allow restoration of natural, self-sustaining ecosystem processes. If natural disturbance patterns are the best way to maintain or restore desired ecosystem values, then nature should be able to accomplish this task very well without human intervention (Frissell and Bayles, 1996).


Please utilize the NEPA process to clarify any roadless boundary issues. It is not adequate to merely accept previous, often arbitrary roadless inventories—unroaded areas adjacent to inventoried areas were often left out. Additionally, there is a lot of public support for adding unroaded areas as small as 1,000 acres in size to the roadless inventory.


We request a careful analysis of the impacts to fisheries and water quality, including considerations of sedimentation, increases in peak flow, channel stability, risk of rain-on-snow events, and increases in stream water temperature. Please disclose the locations of seeps, springs, bogs and other sensitive wet areas, and the effects on these areas of the project activities. Where livestock are permitted to graze, we ask that you assess the present condition and continue to monitor the impacts of grazing activities upon vegetation diversity, soil compaction, streambank stability and subsequent sedimentation.


Please disclose in the NEPA document the results of up-to-date monitoring of fish habitat and watershed conditions, as required by the Forest Plan.


The NEPA analysis should show whether or not your alternatives would comply with the Clean Water Act and all state water quality laws and regulations. Categorically excluding actions that risk further pollution in Water Quality Limited Segments is not consistent with the Clean Water Act, NFMA, or NEPA. Please note that designating BMPs is not sufficient for compliance with CWA and NFMA.


Discuss the actual effectiveness of proposed BMPs in preventing sediment from reaching water courses in or near the analysis area. What BMP failures have been noted for past projects with similar landtypes? We would like to see a thorough discussion of the BMPs and mitigation measures you would propose. Also, pleased disclose which segments of which roads in the watersheds to be affected by this proposal will not meet BMPs following project activities.


Unfortunately, the entire issue of BMPs has been repeatedly clouded by the FS. The Lolo NF and Regional Office have admitted that during even large-scale projects, not all problem sites are restored up to BMP standards (Lolo BMP Memo), thus allowing chronic, persistent watershed damage to continue indefinitely.


Please examine past logging activities, including such information as year and regeneration success level for each past activity in the analysis area and in the cumulative effects area. Please disclose the sizes and condition of manmade openings already existing in the area, and exactly where the proposed cutting units are in relation to the old logged areas.


Please fully analyze and disclose cumulative impacts on soil productivity. Disclose the areas of unstable and highly erosive soils that would result in mass movement and erosion. Include maps that show all land and soil types in the NEPA document. Please analyze how much soil compaction and surface erosion has occurred in the proposal area because of past actions and what the likely increases will be for the alternatives proposed.


The Sheep Creek Salvage FEIS (USDA Forest Service, 2005a) states at p. 173:

Noxious weed presence may lead to physical and biological changes in soil. Organic matter distribution and nutrient flux may change dramatically with noxious weed invasion. Spotted knapweed (Centaurea biebersteinii D.C.) impacts phosphorus levels at sites (LeJeune and Seastedt, 2001) and can hinder growth of other species with allelopathic mechanism. Specific to spotted knapweed, these traits can ultimately limit native species’ ability to compete and can have direct impacts on species diversity (Tyser and Key 1988, Ridenour and Callaway 2001).

Please disclose how the productivity of the land been affected in the project area and forestwide due to noxious weed infestations, and how that situation is expected to change in the coming years and decades.


Please disclose the scientific research information you have to indicate that “mitigation” measures such as helicopter yarding, winter logging, and skidding on slash mat materials will minimize damage to soils.


The FS has essentially admitted that it is in the dark as far as doing scientific research on soil productivity changes following management activities. In response to comments on the Black Ant Salvage DEIS, Lewis & Clark NF, USDA Forest Service, 2002 states:

Soil Quality Standards “provide benchmark values that indicate when changes in soil properties and soil conditions would result in significant change or impairment of soil quality based on available research and Regional experience” (Forest Service Manual 2500, Region 1 Supplement 2500-99-1, Chapter 2550 – Soil Management, Section 2554.1).


A formal research study, the “Long Term Soil Productivity Study,” is currently being conducted by the Research Branch of U.S. Department of Agriculture, Forest Service to validate these soil quality standards.


The Forest Management Handbook at FSH 2509.18 directs the FS to do validation monitoring to “Determine if coefficients, S&Gs, and requirements meet regulations, goals and policy” (2.1 – Exhibit 01). It asks what we are asking: “Are the threshold levels for soil compaction adequate for maintaining soil productivity? Is allowing 15% of an area to be impaired appropriate to meet planning goals?” The Ecology Center recently asked the Northern Region if they have ever performed this validation monitoring of its 15% Standard, in their February 26, 2002 Freedom of Information Act request to the Regional Forester, requesting:

The Forest Management Handbook at FSH 2509.18 provides the Forest Service with examples of validation monitoring to “Determine if coefficients, S&Gs, and requirements meet regulations, goals and policy.” It asks “Are the threshold levels for soil compaction adequate for maintaining soil productivity? Is allowing 15% of an area to be impaired appropriate to meet planning goals?” We request all documentation of validation monitoring by the Forest Service in the Northern Region that answers those two questions.


The Regional Office’s reply letter stated that there is no documentation that responds to this request. If the Lolo NF is aware of any new documentation that would respond to this request now, we ask that you please disclose it.


Harvey et al., 1994 state:

The ...descriptions of microbial structures and processes suggest that they are likely to provide highly critical conduits for the input and movement of materials within soil and between the soil and the plant. Nitrogen and carbon have been mentioned and are probably the most important. Although the movement and cycling of many others are mediated by microbes, sulfur phosphorus, and iron compounds are important examples.


The relation between forest soil microbes and N is striking. Virtually all N in eastside forest ecosystems is biologically fixed by microbes... Most forests, particularly in the inland West, are likely to be limited at some time during their development by supplies of plant-available N. Thus, to manage forest growth, we must manage the microbes that add most of the N and that make N available for subsequent plant uptake.

(Internal citations omitted.)


Please disclose your inventory or monitoring of indicators, including lichens, fungi, insects, etc. since these can and do define existing and probable future forest conditions, especially related to natural recovery following fire. Lichens in particular, while capturing atmospheric nitrogen for later release to higher plants and trees, are sensitive indicators of atmospheric and ground conditions and cannot be ignored in attempts at ecosystem management. Fungi and insects indicate and largely drive forest condition. Those that act as antagonists or parasites to destructive forms like root disease fungi or bark beetles should be recognized, as should tree pathogens and pests.


Lacy, 2001 examines the importance of soils for ecosystem functioning and points out the failure of most regulatory mechanisms to adequately address the soils issue. From the Abstract:

Soil is a critical component to nearly every ecosystem in the world, sustaining life in a variety of ways—from production of biomass to filtering, buffering and transformation of water and nutrients. While there are dozens of federal environmental laws protecting and addressing a wide range of natural resources and issues of environmental quality, there is a significant gap in the protection of the soil resource. Despite the critical importance of maintaining healthy and sustaining soils, conservation of the soil resource on public lands is generally relegated to a diminished land management priority. Countless activities, including livestock grazing, recreation, road building, logging, and mining, degrade soils on public lands. This article examines the roots of soil law in the United States and the handful of soil-related provisions buried in various public land and natural resource laws, finding that the lack of a public lands soil law leaves the soil resource underprotected and exposed to significant harm. To remedy this regulatory gap, this article sketches the framework for a positive public lands soil protection law. This article concludes that because soils are critically important building blocks for nearly every ecosystem on earth, an holistic approach to natural resources protection requires that soils be protected to avoid undermining much of the legal protection afforded to other natural resources.


The article goes on:

Countless activities, including livestock grazing, recreation, road building, logging, mining, and irrigation degrade soils on public lands. Because there are no laws that directly address and protect soils on the public lands, consideration of soils in land use planning is usually only in the form of vaguely conceived or discretionary guidelines and monitoring requirements. This is a major gap in the effort to provide ecosystem-level protection for natural resources.


The rise of an “ecosystem approach” in environmental and natural resources law is one of the most significant aspects of the continuing evolution of this area of law and policy. One writer has observed that there is a

fundamental change occurring in the field of environmental protection, from a narrow focus on individual sources of harm to a more holistic focus on entire ecosystems, including the multiple human sources of harm within ecosystems, and the complex social context of laws, political boundaries, and economic institutions in which those sources exist.

As federal agencies focus increasingly on addressing environmental protection from an holistic perspective under the current regime of environmental laws, a significant gap remains in the federal statutory scheme: protection of soils as a discrete and important natural resource.
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