2-SHORT. Environmental Assessment. Plains/Thompson Falls Ranger District, Lolo National Forest Sanders County, Montana

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1 United States Department of Agriculture Forest Service August SHORT Environmental Assessment Plains/Thompson Falls Ranger District, Lolo National Forest Sanders County, Montana

2 Cover Photo: Area thinned in 2014 as part of the Shorty Gulch Hazardous Fuels Reduction Project. In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA s TARGET Center at (202) (voice and TTY) or contact USDA through the Federal Relay Service at (800) Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C ; (2) fax: (202) ; or (3) program.intake@usda.gov. USDA is an equal opportunity provider, employer, and lender.

3 Contents CHAPTER 1: PURPOSE AND NEED FOR ACTION Introduction Background and Setting Purpose and Need for Action Public Involvement Issue Resolution... 6 CHAPTER 2: ALTERNATIVES Proposed Action Design Criteria Alternatives Considered in Detail Resource Protection Measures Monitoring Alternatives Considered but Eliminated from Detailed Study CHAPTER 3: ENVIRONMENTAL EFFECTS Past, Present, and Reasonably Foreseeable Future Actions Vegetation Resilient Vegetative Conditions Old Growth Botany Weeds Fire and Fuels Soils Aquatics Wildlife Transportation System Heritage Recreation Economics Appendix A - Maps Appendix B: Detailed Vegetation and Road Treatments Appendix C: Soils Appendix D: Science Basis for Restoration Treatments i

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5 CHAPTER 1: PURPOSE AND NEED FOR ACTION 1.1 Introduction The Lolo National Forest is proposing to improve the health and resiliency of forest vegetation, reduce fuels in the wildland urban interface, support the economic vitality of local rural communities, and maintain a suitable transportation system in Shorty Gulch, a tributary to Prospect Creek. The 2-Short project is proposed under the authority of the Healthy Forests Restoration Act of 2003 (HFRA), Public Law , as amended by the 2014 Farm Bill, Section The project is consistent with the following Farm Bill criteria: Within a Section 602 designated area. Designed to reduce the risk or extent of or increase resilience to insect and disease infestation. Not located within a wilderness area, wilderness study area, or an area where vegetation removal is prohibited or restricted. Developed through a collaborative process (as described below in section 1.4). Designed to retain large trees, as appropriate for the forest type, to the extent that the trees promote stands that are resilient to insects and disease (see Design Criteria below in section 1.4.1) This Environmental Assessment (EA) discloses the direct, indirect, and cumulative effects of the proposed action and alternatives to determine whether they may significantly affect the quality of the human environment and thereby require preparation of an environmental impact statement. Preparation of this EA fulfills agency policy and direction to comply with the National Environmental Policy Act (NEPA), the Lolo National Forest Plan, 40 CFR , 36 CFR 220.7, and other relevant federal and State laws and regulations. The reports cited in this EA and additional project documentation are contained within the project file located at the Plains/Thompson Falls Ranger District office in Plains, Montana. 1.2 Background and Setting The 4,200 acre project area is located about 5 miles southwest of Thompson Falls, Montana (see map in Appendix A). The project area is primarily allocated to timber management and big game winter range forage production (Management Areas 16, 18, 22, 23, 25) in the Lolo Forest Plan 1. The Forest Service recently completed the Shorty Gulch Hazardous Fuels Reduction Project in Shorty Gulch that focused on treating dry ponderosa pine sites in the wildland urban interface. No permanent road construction was considered in the project, requiring helicopters to be used to remove fuels from inaccessible areas. Because of a decline in log values between the time of planning (2008) and 1 The Forest Plan guides all natural resource management activities and establishes management standards for the Lolo National Forest. It described resource management practices, levels of resource production and management, and the availability and suitability of lands for resource management. 1

6 implementation (2011), a portion of the project was not treated due to the economic infeasibility of helicopter yarding. The original Shorty Gulch project contained approximately 260 acres of helicopter units. In total, the project included approximately 946 acres of fuel treatments about half the acres were commercial harvest and the other half were non-commercial treatments (e.g. slashing/piling and prescribed burning). The sale (200 acres) was completed in 2014 and all the non-commercial fuels work has been accomplished. Approximately 260 acres (originally identified for helicopter yarding) were left untreated and therefore not all project objectives were met. In 2015, the Forest Service re-evaluated the area to determine how to fully achieve the objectives of the original Shorty Gulch Hazardous Fuels Reduction project and to identify other vegetation needs. The fuels reduction aspect is important because nearly the entire project area (90 percent) is located within the wildland urban interface and identified within the Sanders County Community Fire Protection Plan (2005) as a high priority area for fuels reduction. Private land and residences are located immediately south and east of the project area and the Bonneville Power Administration (BPA) 500kV power line and Northwestern Energy power line cross the southern portion of the area. The Forest Service determined that it would be feasible to construct new roads to access the previously deferred helicopter units and skyline yarding could be used to complete the vegetation treatments. During the assessment, the Forest Service also identified insect and disease concerns within the Douglas-fir dominated stands that make up a large part of the project area. Root disease is prevalent within the area and Douglas-fir is very susceptible to the disease. In addition, Douglas-fir trees are at risk to insect infestation due to high tree density and disease-induced stress. 1.3 Purpose and Need for Action The purposes of the 2-Short project are to: Improve the health, resiliency, and viability of the forest vegetation o o Reduce risk of future tree mortality from root disease and insect infestation Complement past hazardous fuels reduction work within the wildland urban interface to lower the risk of uncharacteristic wildfire effects Contribute to the sustainable supply of timber from National Forest System (NFS) lands Maintain a suitable transportation system for long-term land management that is responsive to public interests and reduces adverse environmental effects Improve Resilient 2 Vegetative Conditions and Reduce Fuels within the Wildland Urban Interface The Lolo Forest Plan provides for the maintenance of a diverse mosaic of vegetational development, well-distributed across the Forest to insure ecological integrity (Forest Plan, page II-2). It also provides for a balanced Fire Management Action Plan that is commensurate with threats to life and property, public safety, values, hazards, risks, and specific resource management goals (Forest Plan, page II-17). One of the primary Forest Plan goals for the management areas within the project area is to provide for healthy stands of timber (Forest Plan, pages III-70, 83, 107, 112, and 127). 2 Forest Service Manual 2020 defines resilience as the ability of an ecological system to absorb disturbances while retaining the same basic structure and ways of functioning, the capacity for self-organization, and the capacity to adapt to stress and change. 2

7 The ponderosa pine and Douglas-fir forest types within the project area were historically affected by low to mixed severity fires (from underburns to stand replacement) of low to moderate frequency (5-50 years). However, according to District records, most of the project area last burned naturally in the early 1900s. Due to nearly 100 years of fire absence, increased stand densities and biomass accumulations have elevated the risk of stand replacement fire. The original Shorty Gulch Hazardous Fuels Reduction project focused on addressing these concerns primarily in the dry ponderosa pine forest types. However, the original project did not include Douglas-fir dominated stands. In these areas, root disease has become more aggressive and widespread because of high stand density and Douglas-fir composition. Without fire or other disturbances to modify species composition and density, root disease pockets become larger as trees become more susceptible from decreased vigor and overstocking, the trees die, and the disease centers regenerate to dense stocking of host species, continuing the cycle. To break this cycle, management actions are needed to modify the species composition to favor disease-resistant species, such as ponderosa pine and western larch. Douglas-fir beetle, a native bark beetle, tend to kill large diameter (generally greater than 14 inches) Douglas-fir trees and are attracted to trees weakened by fire, root disease, drought, or defoliation. Dense stands have higher susceptibility to beetle-induced tree mortality (Kegley 2004). As described above, the 2-Short project is proposed in part to complement past fuels reduction work within the wildland urban interface. In addition to the recently completed Shorty Gulch Hazardous Fuels Reduction project, approximately 1200 acres of prescribed burning was conducted in 2005 in both Brush and Valentine Gulches, located immediately west and east of Shorty Gulch, respectively. The prescribed burning reduced surface fuels within treated areas. Topography and wind can influence fire behavior in the Shorty Gulch and surrounding areas. The Prospect Creek drainage, to which Shorty Gulch is tributary, is oriented in a west to east direction and funnels prevailing winds down drainage toward nearby residences, the BPA power line, and the rural community of Thompson Falls. For example, the 1973 Tri-Creek Fire burned approximately 7500 acres down Prospect Creek through multiple tributaries from Cox Gulch to Brush Gulch. The combination of past and proposed vegetation treatments would provide defensible opportunities for initial attack fire resources to more quickly and safely contain a fire once it has started and before it reaches private land. More than 80 years of fire research shows that fuel, topography, and weather combine to determine wildfire intensity (the rate at which fuel is consumed and heat is generated) and severity (the damage to forest components). Of these factors, fuel (vegetation) is the only one that can be treated. Models, field observations, and experiments indicate that for a given set of weather conditions, fire behavior is strongly influenced by fuel structure and composition (Graham et al. 2004). The intent of the 2-Short project is to modify fire behavior to limit the undesirable effects of fires on the ecosystem and human development. Fuel treatments are not intended to guarantee benign fire behavior but can reduce the probability that extreme fire behavior will occur. Weather, drought, and topography are factors that humans cannot influence. The Forest Plan defines three fire management area categories for fire suppression and protection (Forest Plan, page VI-25). The project is located within two of these areas: Fire Management Unit (FMU) 1, which is the wildland urban interface containing high values at risk. About 90 percent of the project area is in FMU 1. 3

8 Fire Management Unit 2, accessible areas with moderate values at risk. Approximately 10 percent of the project area is in FMU 2. The Northern Rockies Southwest Zone Fire Danger Operation Plan identifies FMUs 1 and 2 as priority areas for fuel reduction treatments. Due to the existing conditions and the values at risk, the 2-Short project includes strategically-placed, science-based vegetation treatments to slow fire spread and reduce fire intensity, increasing options for and effectiveness of future fire suppression actions. Support Communities The 2-Short project lies within Sanders County, of which 52 percent of the land base is NFS land. Thus, the local community has significant social and economic ties to NFS lands. According to the Montana Department of Labor, Sanders County currently has one of the highest unemployment rates in the state (nearly twice the state average). Management decisions made by the Forest Service can have an impact on the economies of smaller, resource-based communities. Economic effects can include changes in local employment and income, and changes in local services and community infrastructure. Forest products resulting from management activities on NFS lands contribute to the local economy and to the sustainability of the forest products industry. Currently, Montana s forest products industry is one of the largest components of manufacturing in the state and employs roughly 7,700 workers earning about $335 million in compensation annually, with most of the industry centered in western Montana where the 2-Short project is located. (Morgan et al. 2015). Most Montana mills are operating at less than full capacity and require an adequate supply of timber to remain viable and meet market demand (ibid.) One of the goals outlined in the Lolo Forest Plan is to provide a sustained yield of timber and other outputs at a level that will help support the economic structure of local communities and provide for regional and national needs (Forest Plan, page II-1). Approximately 36 percent of the NFS land within the project area is allocated in the Lolo Forest Plan to be managed with an emphasis toward timber production. All of the remaining NFS land within the 2-Short area is identified in the Forest Plan as suitable 3 for timber harvest with objectives that include providing for healthy stands of timber. The 2-Short project includes commercial timber harvest treatments that would yield various wood products to local and regional forest industries. The nearest mill is located about 10 miles away by road. In addition, treatments would result in resilient forests which would continue to grow and maintain future opportunities for sustainable products removal. In doing so, the project would contribute to the maintenance of a forest industry infrastructure, which provides employment benefitting local communities and sustaining markets for forest products. The Forest Service recognizes the need for a strong forest industry to help accomplish vegetation management objectives now and in the future. Maintain a Suitable Transportation System The Lolo Forest Plan directs that roads be kept to the minimum number and size needed to meet user and resource needs (Forest Plan, pages II-2 and II-17). 3 The Lolo National Forest Plan defines suitable forest lands as land for which technology is available that will ensure timber production without irreversible resource damage to soils, productivity, or watershed conditions, for which there is reasonable assurance that such lands can be adequately restocked, and for which there is management direction that indicates that timber production is an appropriate use of that area (Lolo Forest Plan, page VII-40 and 36 CFR ) 4

9 Forest roads are beneficial in that they provide access for land management activities and recreation. Driving for pleasure is the single largest recreational use of Forest Service managed lands (65 FR 11676). Nationally as well as locally, there is an increasing demand for motorized recreation opportunities on NFS lands. Currently within the 2-Short area, there are about 20 miles of road open yearlong or seasonally to pubic motorized use, although none provide desired loop routes. On the downside, roads can be costly to maintain and can cause environmental harm depending on their location and condition. Within the 2-Short project area, there are approximately 24 miles of system roads under Forest Service jurisdiction that are recorded and tracked in the Agency s road atlas. In addition, during the assessment of the project area, another 7 miles of non-system 4 roads were identified on NFS lands. As described above, nearly the entire project area is allocated in the Forest Plan as suitable for timber production and thus a well-designed road system is necessary to provide access for management activities. The Forest Service conducted a project-level Travel Analysis to determine which roads are needed (e.g. access for land management activities, recreation, and power line maintenance) and to identify resource concerns. The Travel Analysis also identified the need to construct some new roads, conduct maintenance on some existing roads, as well as adopt some of the non-system roads to the National Forest road system. The 2-Short project would balance access needs and desired uses while addressing resource concerns and budgetary constraints to maintain a suitable transportation system into the future. 1.4 Public Involvement Collaboration In August 2014, a letter was sent to over 200 individuals and organizations inviting them to participate in a collaborative effort to help in the development of site-specific projects on NFS lands in Sanders County. Several people including local residents, County Commissioners, Sanders County Resource Advisory Committee (RAC) members, representatives of timber industry, Montana Department of Natural Resources and Conservation, and other organizations responded. Discussions regarding the 2- Short project began in April 2015 at a meeting held in the Sanders County Courthouse. On October 14, 2015, the Forest Service sponsored a public fieldtrip to the project area. The Forest Service used the valuable input from the collaborative participants to develop the proposed action for the project. In addition to the project s natural resource objectives, collaborative participants wanted to highlight the social and economic benefits this project would provide to the public, including enhanced recreation opportunities, employment, and income within Sanders County. Scoping On March 28, 2016, a scoping letter soliciting comments on the proposed action was mailed to 175 landowners, organizations, other agencies, and individuals who had previously requested notification 4 Non-system roads are old (relic) roads that are not recorded in the Forest Service road atlas. Most of these roads were constructed prior to 1970 to provide access for timber harvest. Although their prisms still exist on the landscape, most of these roads have since been abandoned and most are heavily vegetated with brush and/or trees and are currently impassable. Due to the capabilities of today s timber harvesting equipment, many of these roads are not needed for land management activities. 5

10 about the types of activities included in the project. The scoping letter and associated map were posted on the Lolo National Forest website. A legal notice requesting comments was published in the Missoulian newspaper on March 31, A project announcement and public meeting notice was published in the Clark Fork Valley Press and Sanders County Ledger on April 6 th and 7 th, respectively. The Forest Service held a public meeting on April 12 th to share information about the project and encourage public comment. Twelve people attended the meeting. At the completion of the scoping period, seven letters had been received. An additional comment letter was submitted nearly a year later in March Agencies and Persons Consulted The Forest Service consulted the following organizations, Federal, State, tribal, and local agencies while preparing this environmental assessment: Federal, State, and Local Agencies: U.S. Fish and Wildlife Service Montana Department of Environmental Quality Montana State Historic Preservation Office Montana Department of Fish, Wildlife, and Parks Sanders County Commissioners Tribes: Confederated Salish and Kootenai Tribes Other: Sanders County Collaborative Lolo Restoration Committee Issue Resolution Public comments were reviewed to identify concerns and issues relative to the Proposed Action. Most comments were supportive of the overall project, but there were a few concerns expressed on the project s potential effects to water quality and public motorized access. These concerns were addressed: 1) in project design; 2) by creating resource protection measures; and 3) through analysis to determine environmental effects. The issues raised during scoping and how they were addressed are briefly summarized below. Timber harvest and road-related activities could degrade water quality and aquatic habitat in project area streams as well as in Prospect Creek. Resource protection measures (Chapter 2, section 2.2.1), best management practices, and project design criteria (Chapter 2, section 2.1.1) would be applied to minimize adverse effects to aquatic resources. Chapter 3, section 3.4 discloses the potential effects of project activities on water quality and aquatic habitat. The analysis concludes that the project would not have significant adverse effects to these resources within area streams and would have no measurable effects to Prospect Creek. Although sediment delivery from road-related activities could temporarily increase in Shorty and Brush Gulches during project implementation, roadrelated sediment would be reduced below the existing condition following completion of the project due to road improvements. Road maintenance activities, particularly on the Shorty 6

11 Gulch road, and decommissioning a segment of road would address the existing sediment concerns within the project area, resulting in improved water quality within Shorty Gulch over the long term. Road closures could affect public motorized access. Travel analysis was completed to address long-term transportation needs for land management and public access. Chapter 3, sections 3.7 and 3.9 disclose the potential effects of the project on public motorized access. The analysis concludes that the project would result in a net gain of 0.5 miles of road open to public motorized use from May 15 to October 15. 7

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13 CHAPTER 2: ALTERNATIVES Section 102(2)(E) of the National Environmental Policy Act (NEPA) requires the Forest Service to study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources. 2.1 Proposed Action The proposed action was developed to address the purposes and needs for action as described in Chapter 1. The proposed action, with some modifications, was carried forward as Alternative 2 (modified proposed action), as described below and analyzed in Chapter 3 of this document. The proposed action included approximately 765 acres of timber harvest and 366 acres of noncommercial treatments. To access vegetation treatment areas, approximately 5 miles of new road (including temporary and long-term specified) was proposed for construction. The proposed action also contained several road management activities including road decommissioning (5 miles); adding existing non-system roads to the National Forest system (3 miles); road maintenance (20 miles); and establishing a seasonal motorized loop route between Shorty and Brush Gulches. Design criteria were included in the proposed action to minimize and/or avoid potential environmental impacts. These design criteria are incorporated into Alternative 2 and reflected in the resource protection measures (see section 2.2.1) Design Criteria Project-level design features were identified upfront to protect resources in the area. The design features are based on Forest Plan direction, relevant science, and site-specific evaluations. Design features include best management practices (BMPs), which minimize effects on soil and water resources. For harvest and road management activities, BMPs are designed to assure compliance with the Clean Water Act and State of Montana water quality standards. Large trees, as appropriate for the forest type, would be retained to the extent that the trees promote stands that are resilient to insects and disease. Vegetation treatments would be designed to be consistent with relevant scientific information to maintain or restore ecological integrity, including maintaining or restoring structure, function, and composition. Fire-tolerant trees, primarily larch and ponderosa pine, would be retained, but a mix of trees of all species in a stand would be represented after treatment. Machine operations would occur when soils are dry or frozen. Off-road equipment would be washed prior to entry into the project area to reduce the risk of weed establishment and spread. Wildlife features such as wallows, mineral licks, and seeps would be protected. Woody debris and snags would be left within all vegetation management treatment areas at levels outlined in the Lolo National Forest Coarse Woody Material Guide and Forest Plan to provide for soil productivity and wildlife habitat. Forestry Best Management Practices would be utilized to minimize effects to soil and water. 9

14 No harvest treatments would occur within Riparian Habitat Conservation Areas to protect streams and other aquatic features. New road construction would follow Best Management Practice standards to minimize potential environmental impacts. 2.2 Alternatives Considered in Detail Overview of the Alternatives Two alternatives were analyzed in detail. A map of the Modified Proposed Action (Alternative 2) is located in Appendix A. Alternative 1: No Action Alternative 2: Modified Proposed Action Details of the Alternatives Alternative 1 The no action alternative closely correlates with the existing condition. This alternative proposes no actions that are contained in the modified Proposed Action. It provides a baseline for comparison of the environmental consequences of the modified Proposed Action to the existing condition and is a management option that could be selected by the Responsible Official. This alternative would continue the standard resource protection and recurrent maintenance activities such as access management and routine scheduled road maintenance that are currently ongoing in the project area. Ecosystem processes such as vegetation succession would continue their current trends. Alternative 2 Alternative 2 would conduct commercial and non-commercial vegetation treatments to address disease and insect concerns and reduce fuels on approximately 1129 acres (see Table 2-1). This alternative also includes road management activities, including maintenance, decommissioning, travel restrictions, and construction (see Table 2-3). A 13-mile motorized recreation loop route would be created. Refer to Appendix A for the map and Appendix B for unit- and road-specific information. Vegetation Management Table 2-1: Vegetation Treatments Treatment Type Acres (Percent of NFS lands) Commercial Treatments Intermediate Timber Harvest 192 Regeneration Timber Harvest 536 Subtotal 728 (18%) Non-commercial Treatments Non-commercial Thin 246 Slash/burn/plant 140 Underburn 15 Subtotal 401 (10%) TOTAL 1129 (28%) 10

15 Intermediate Timber Harvest treatments (e.g. commercial thinning) would be used to enhance growth, quality, vigor, and composition of the existing stand. Generally, smaller trees would be removed from the lower and main canopy, retaining the larger trees of desired fire-tolerant and disease-resistant species with gaps between the crowns. Within some stands, prescribed fire would be applied following harvest activities. Regeneration Timber Harvest treatments would be used to replace the existing stand with a stand that has a species composition and stocking density that meets desired future conditions specified in management objectives. Regeneration harvests are proposed where stand conditions (insects, disease, blowdown, etc.) do not meet and are not projected to meet desired conditions and where intermediate harvest cannot alter stand development to a desired condition. Prescribed fire would be applied following harvest to reduce fuel and prepare the site for natural regeneration or planting. Natural regeneration is expected at various densities and species, and most of these units would be planted to ensure regeneration of western larch, ponderosa pine, and western white pine. Due to existing conditions (i.e. insects and disease), some of the regeneration harvest treatments would result in forest openings that would exceed the Regional 40-acre opening size limitation (Forest Service Manual 2470, Section , Region 1 Supplement ). To exceed this size, Regional Forester approval is required. These larger openings could range in size from 66 to about 96 acres, mimicking natural disturbance patterns (see Table 2-2). Regeneration harvest treatments proposed for the 2-Short project are not clearcuts. Varying densities of trees would be retained within these areas, from scattered individuals to groups consisting of the largest, healthiest trees. Non-commercial thinning would occur in young (20-40 years old) stands to remove smaller trees from the lower and main canopy, retaining the larger trees of desired fire-tolerant species with gaps between crowns. This would provide growing space to reduce competitive stress, resulting in trees that grow bigger faster, develop characteristics that increase fire-tolerance both at individual tree and at stand levels, and better resist some of the most damaging insects and diseases. The resulting stand densities would typically be between 110 and 170 trees per acre, but that would vary by species distribution and tree sizes. The trees cut during this process would be left on site and allowed to decompose back into the soil. Slash/Burn/Plant treatments would be used to convert root disease susceptible tree species in root disease areas to a more resistant trees species. This treatment would be used in areas that are not economically viable for commercial timber harvest because of the lack of enough merchantable timber. The treatments in these areas would consist of slashing some of the understory trees to create a fuel bed. The areas would then be burned to prepare the site for planting root disease resistant tree species (e.g. western larch, ponderosa pine, and western white pine). Table 2-2: Summary of Treatments Resulting in Forest Openings Greater than 40 Acres Units Acres Condition 13, 103 (103 is slash/burn/plant no commercial timber harvest) 80 Existing conditions: Stands are comprised primarily of lodgepole pine and grand fir with some larch and Douglas-fir components. High bark beetle-caused mortality in the lodgepole pine has created high surface fuel buildup and left intermediate and suppressed lodgepole pine crown classes. The grand fir is overstocked, suppressed, and currently at high risk of being attacked by fir engraver beetle. Desired conditions: A mixed diversity stand consisting of larch and white pine as the major component with lodgepole pine, Douglas-fir, and grand fir. Regeneration harvest would provide larch and rust-resistant white pine for longterm fire resilience, provide seed sources for recovery after major disturbances, and replace a forest floor of wood and litter with grasses and shrubs for 11

16 Units Acres Condition herbivores. An opening greater than 40 acres is desired to provide for landscape level treatment , Existing conditions: Stands consist predominantly of Douglas-fir, with some larch, ponderosa pine, and grand fir. They are located in moderately cool, moist Douglas-fir habitat types with extensive root disease. Douglas-fir and grand fir are highly susceptible to root disease. There is also a moderate amount of mortality in the Douglas-fir and grand fir from the combination of root disease and bark beetles. Desired conditions: Convert existing species composition to root diseaseresistant larch, ponderosa pine, and white pine. Regeneration harvest to a two story stand featuring larch and ponderosa pine legacy trees and plant larch, ponderosa pine, and rust-resistant white pine to restore it to a resilient stand that would provide seed sources after future disturbances. A size greater than 40 acres is desired to treat the entire root disease area. 21, 22 17, 18, Existing conditions: Stands are predominantly Douglas-fir, with some ponderosa pine and a few larch. They are located in moderately warm, dry Douglas-fir habitat types with extensive root disease. Douglas-fir is highly susceptible to root disease. Some mortality is occurring in the Douglas-fir from the combination of root disease and bark beetles. Desired conditions: Convert existing species composition to more root diseaseresistant ponderosa pine. Regeneration harvest to a two story stand featuring ponderosa pine legacy trees and plant ponderosa pine to restore them to a resilient stands that would provide seed sources after future disturbances and replace a forest floor of wood and litter with grasses and shrubs for herbivores. A size greater than 40 acres is desired to provide for landscape level treatments. 102 (slash, burn, and plant no commercial harvest) Road Management 96 Existing conditions: Stand is predominantly Douglas-fir, with some larch and grand fir. It is located in moderately warm, moist grand fir habitat types with extensive root disease. Douglas-fir and grand fir are highly susceptible to root disease. High mortality is occurring in the Douglas-fir and grand fir from the combination of root disease and bark beetles. Desired conditions: Convert existing species composition to more root diseaseresistant larch. Regeneration harvest to a two story stand featuring larch legacy trees and plant larch and rust-resistant white pine to restore it to a resilient stand that would provide seed sources after future disturbances. A size greater than 40 acres is desired to treat the entire root disease area. Table 2-3: Road Management Activities Road Management Activities Miles Maintenance 16 Reconstruction 2 Decommission (see Table 2-4 for details) Total: 5.6 System Roads (physical closure) 1* Non-system Roads 4.6 Physical closure

17 Road Management Activities Miles Administrative closure (no physical treatment would be performed on the ground) 3 Storage Total: 1.7 Non-system roads to be added to the NF road system (administrative closure) 1.7 Travel Management Changes Total: 1.6 Change from open yearlong to open seasonally (Open May 15-October 15) 1.6 (Road #18884 as part of the motorized recreation route) Add Existing Non-system Roads to the National Forest System and keep closed Total: 2.6 yearlong (includes the miles of non-system roads shown above for storage) New Construction (see Table 2-5 for details) Total: 4.3 Long-term Specified (multiple segments ranging from 0.2 to 1.0 mile in length) 4.3** *Approximately ½ mile is currently open yearlong and drivable. This segment of Road #18884 is proposed for decommissioning to address erosion and sediment delivery concerns. Alternate seasonal access would be provided as part of the motorized loop between Shorty and Brush Gulches (see below). The other ½ mile of road (end of Road #18494) is currently designated open seasonally but is undrivable due to vegetation encroachment on the roadway. This road segment is not needed for logging system access because the road above it (Road #7636) is sufficient for skyline equipment to reach the area. **Approximately 1 mile of new road construction would be kept open seasonally to public motorized use as part of a motorized loop between Shorty and Brush Gulches (see below). Closure would be controlled by the gate on the Shorty Gulch Road (#7605). The rest of the newly constructed roads would be closed yearlong to public motorized use. Conduct heavy maintenance on the Shorty Gulch Road #7605 to provide for timber haul and address aquatic concerns due to the road s close proximity to the intermittent stream in Shorty Gulch. Establish a 13-mile seasonal motorized loop route between Shorty and Brush Gulches by connecting a portion of Road #18884 to new road construction. The loop route would be open to the public from May 15 to October 15. The steep lower portion of Road #18884 would be decommissioned due to erosion and sediment delivery issues. New access to the remainder of Road #18884 would be provided by new road construction (18494ext). At the upper end, Road #18884 would then be connected to Road #16286 via new road construction (16286ext). Road #16286 ties into Road #7636 which originates in Brush Gulch at the Prospect Creek highway. If monitoring determines that travel management restrictions are not adhered to, the motorized loop would be closed to public motorized use. Maintenance activities would include surface blading, minor earth work (e.g. cut and fill shaping), road surface shaping, ditch cleaning and reshaping, roadside clearing and/or brushing, seeding disturbed areas, drain dip and cross drain cleaning and construction, culvert cleaning, armoring, and/or replacement, slash filter windrow and sediment trap construction near live water crossings. Because these roads are intended for long-term access, and in most cases would remain open to public travel, work would be performed to minimize environmental impacts and to provide a safe and stable road. Reconstruction activities would include widening the road to a 14-foot minimum travel width to accommodate log trucks. Roads to be reconstructed are non-system roads that would be used for the project and added to the National Forest road system. Decommissioning treatments would occur on roads not needed for future use. Activities could vary from full recontouring of roads found to be causing resource impacts to no treatment of roads that are fully revegetated, contain no stream crossings, and have no associated resource impacts. 13

18 Storage treatments would occur on roads that are needed for long-term access, but not in the shortterm. In this project, no physical treatments would be performed due to the roads existing condition (naturally in a stored state). Long-term Specified Road Construction would be constructed to access treatment areas and provide long-term access for future land management activities. The location, design, and construction of these roads would follow Best Management Practice standards to minimize potential environmental impacts. None of the proposed roads would cross streams. Table 2-4: Road Decommissioning and Storage Levels Road Treatments Miles Road Decommissioning 3D DN (Administrative) 3 Road Storage 3SN (Administrative) 1.7 Decommission Level 3D: Closure activities would include road surface ripping (de-compaction) where needed, placement of woody debris on the road surface, removal of structures (culverts, bridges) and reshaping of stream crossings to natural contours, installation of water bars at frequent intervals, seeding of the road prism, and recontouring the entrance of the road. On flatter terrain, boulders could be used to close the road entrance. Decommission Level 5: Closure activities would include full recontouring; replacing overburden (excavated soils) back onto the road prism to return the ground to its natural contour, removal of structures (culverts, bridges) and reshaping of stream crossings to natural contours, placing woody debris upon the disturbed area, and seeding and fertilizing the disturbed soil. Decommission Level 3DN (Administrative closure): These roads are already revegetated with brush and trees, and no physical activities would be conducted on the ground. The intent of this treatment is to administratively decommission roads without re-disturbing road surfaces that are already stable from natural processes. Storage Level 3SN: (Administrative closure): These roads are already revegetated with brush and trees, and no physical activities would be conducted on the ground. The intent of this treatment is to administratively store roads until needed in the future. Table 2-5: Summary of New Long-term Specified Road Construction Road # Length Travel Management (miles) 18884ext 0.7 Yearlong Gate Closure (A) 38358ext 0.8 Yearlong Gate Closure (A) 16818ext 1.0 Storage Level 3S 16286ext 0.6 Open Seasonally May 15 to October 15 (D) 18494ext 1.0 Open Seasonally May 15 to October 15 (D) 7605ext 0.2 Open Seasonally May 15 to October 15 (D) TOTAL

19 2.2.1 Resource Protection Measures Resource protection measures are incorporated into the action alternative to mitigate the potential for unintended harm to the environment (see Table 2-6). These measures 1) avoid impacts altogether by not taking action or parts of an action, 2) minimize impacts by limiting the degree or magnitude of the action and implementation, 3) rectify the impact by repairing, rehabilitating or restoring following action, 4) reduce or eliminate the impact over time by preservation or maintenance activities, or 5) compensate for the impact by replacing or substituting resource or environments (40 CFR ). In addition, the Lolo National Forest has developed standard operating procedures (SOPs), which include best management practices that have been determined to be effective in minimizing potential environmental effects (see Table 2-7). SOPs area applied to all projects. Table 2-6: Project-specific Resource Protection Measures Resource Description of Project-Specific Resource Protection Measure Protection Measure Soils 1 Excavator/grapple piling would be limited to time periods when dry soil conditions exist over greater than approximately 85% of the harvest unit (summer operating conditions) and to areas of high fuel concentrations. Machines would use existing skid trail corridors where available. Units/Location Units 20, 23, and 26 Excavators would be restricted from operating in areas with more than 35% average slope, unless reviewed by the Forest soil scientist. Slash would not be machine piled in sensitive areas (rocky ridges, rocky ridge shoulders, areas with high potential for weeds, or in areas of shallow soil identified by gravel pavement on the soil surface and early successional stage vegetation/weeds, etc.) unless reviewed by the Forest soil scientist. 2 For seasonally moist areas, seeps, and springs, a 50-foot no-equipment buffer would be placed around wet areas. Unit 18 3 All existing soil wood (wood in an advanced state of decay) would be retained unless it is deemed a hazard to Units 8, 9, and 11 equipment operations. Tops of harvested trees would be left within activity units following the silvicultural prescription or understory would be slashed and left in place. Slash would be left on the ground through one winter before prescribed burning activities occur to allow nutrients to release into the soil. 4 Existing landings would be re-used to the extent possible Landing site preparation to a depth of 4-6 inches would occur. Site preparation may include de-compaction and/or scarification. Weed treatments would occur as needed with seeding using Lolo Seed mixes appropriate for the site. Unit 27 15

20 Resource Protection Measure Description of Project-Specific Resource Protection Measure Slash, both fine woody material and coarse woody material (material greater than 3 inches in diameter), would be placed over the site, covering at least 60% of the landing to a depth of 2-3 inches. Most slash would be in direct contract with the soil surface. 5 By purchaser agreement, in lieu of waterbars, slash of mixed sizes (at least 50% less than 6 inches diameter) would be placed over approximately 65-70% of the constructed skid road to a depth of approximately 2-3 inches where available (approximately tons/acre). Most slash would be in direct contract with the soil surface. Heritage 6 To ensure treads of the historic pack trail (which are still in use) remain passable, slash material would be placed at least 6 feet away from centerline on either side of trail. Botany 7 The hill monkeyflower population along south edge of Unit 26 would be buffered from skyline corridors and log skidder routes. Units/Location Unit 27 Units 33, 101 and The identified hill monkeyflower population would be buffered from the construction of new Road 18494ext. Road 18494ext Unit 26 Table 2-7: Standard Operating Procedures Standard Operating Procedures Soils Harvest operations would occur during Winter Operating Conditions Ground-based operations would be limited to periods when snow depth or frozen ground is adequate to protect soils (winter operating conditions). Or, during Summer Operating Conditions Units/Location All ground-based harvest units Where they exist and are safe, existing skid trails would be re-used. New skid trail locations would be approved by the Timber Sale Administrator. Operation of skidding equipment off of designated trails would be minimized unless dispersed skidding is approved during winter periods. Harvesting and skidding operations would not occur unless specified conditions (dry soil, adequate snow depth, or frozen ground) exist over approximately 85% of the harvest unit (including landings). Soil moisture would be evaluated at the bottom of the root-tight layer if one exists or within the top 6-12 inches of the soil surface (Refer to Table B1 in the Soil report for a definition of dry soil by soil texture). Ground-based equipment would be allowed to operate on slopes averaging 35% or less, and on slopes of 40-45% less than 100 feet in 16

21 Standard Operating Procedures length as approved by the timber sale administrator. Skyline corridors would be approved by the timber sale administrator and efforts should be made to avoid sensitive areas (swales, ephemeral draws, concave landscape features, and the nose of ridges, etc.) to the greatest extent possible. Coarse woody debris would be retained for long-term soil productivity and wildlife habitat. On drier sites, harvest that would result in an open forest would retain 5 to 12 tons per acre of woody material over 3 inches in diameter and 6 feet long in both down and standing dead. Thinning treatments and prescribed burning would retain lesser amounts (3 to 6 tons per acre) because the retained overstory would provide ample recruitment over time. On moister sites, harvest that would result in an open forest and standreplacement portions of mixed severity prescribed burns would retain 12 to 20 tons per acre of woody material over 3 inches in diameter and 6 feet long in both down and standing dead. Intermediate harvests would retain less amounts (6 to 10 tons per acre) because the retained overstory would provide ample recruitment over time. Weeds Off-road equipment would be cleaned (power or high pressure cleaning) of all mud, dirt, and plant parts before moving into the area. If gravel or other material is hauled for road surfacing, it would be from a site (pit) that has been previously treated for weeds and is currently weed free. Disturbed sites would be seeded with native seed mixtures or appropriate Lolo seed mixtures. Slash would be placed on skid trail prisms after use. Refer to the Soil report for prescribed amount of slash. If temporary roads are used, they would be treated with herbicide prior to final road obliteration unless waived by the District Weed Coordinator. Any use of herbicides for weed control would follow mitigation measures outlined in the Lolo National Forest s 2007 Integrated Weed EIS and Record of Decision to protect water resources. These measures include: All application of herbicides would be performed by, or supervised by, a state licensed applicator following all current legal application procedures administered by the Montana Department of Agriculture. All herbicides would be handled following Environmental Protection Agency (EPA) label guidelines and other state and federal laws for storage, application, and disposal methods. Mixing would take place at least 150 feet from open water unless spill containment devices are readily available and an anti-back siphoning device is used when drafting water. Applicators would review stream and wetland areas to ensure that herbicides would not be applied to open water. Herbicides would be used to water s edge only when absolutely needed and provided the product label allows such use. Herbicide applications near live water or in areas with shallow water tables would follow label directions. Herbicide applicators would not initiate spraying when heavy rains are forecast that could cause offsite herbicide transport into sensitive resources such as streams. Herbicide applicators would be familiar with and carry an Herbicide Emergency Spill Plan to reduce the risk and potential severity of an accidental spill. Herbicide applicators would also carry spill containment equipment. Herbicides would not be applied if snow or ice covers the target vegetation. Low boom pressure (less than 40 pounds per square inch) would be used to reduce drift. Drift reduction products would be used as needed near sensitive resources. Units/Location All skyline units All activity units Project Area 17

22 Standard Operating Procedures Ground-based herbicide application would occur only when wind speed is 10 mph or less. If commercial applicators are used for the application of restricted use pesticides, Forest Service contract administrators would check to make sure their Montana commercial restricted use pesticide license is current. Aquatics Road surfaces and drainage would be improved as needed to protect water quality and fisheries. All roads used for haul would have BMPs installed before timber haul use. BMPs include adequate road surface and ditch drainage, functioning ditches, adequate spacing of drain dips or ditch relief culverts, leadouts or drainage structures before stream crossings, road shaping to shed water off the surface and not into streams, rock check dams in ditches, and graveling of areas where drainage treatments may not be fully effective due to stream proximity. BMPs would be maintained for their effectiveness through the life of the project. Short-term BMP actions would be implemented on an as needed basis and include silt fences, straw bales, or other temporary but effective measures to reduce turbid water from reaching streams. Implementation of road BMP treatments would occur from May 15 to October 15 during dry weather periods, unless otherwise agreed to with a watershed specialist (hydrologist or fisheries biologist). New road construction would occur from May 15 to October 15 during dry weather periods unless otherwise agreed to with a watershed specialist (hydrologist or fisheries biologist). Tree cutting and ground-based equipment would be prohibited from all RHCA buffers. However, tree cutting and removal would be allowed within ephemeral draw buffers but ground-based equipment would be prohibited. Equipment may cross ephemeral draws at designated crossings. Channel Type Buffer (feet) Perennial fish bearing stream 300 Perennial non-fish bearing stream and wetlands greater than 1 acre 150 Seasonally flowing or intermittent streams and wetlands less than 1 acre 100 Ephemeral draws 50 As needed, slash filter windrows would be placed on relief culvert outlets on all haul routes that are within 300 feet of a waterway. As needed, slash-filter windrows would be applied to all stream crossings on haul routes before blading, haul, and other project activities occur. Slash-filter windrows would be maintained during and after haul to ensure effectiveness. Following use for this project, temporary roads (if needed) and landings would be rehabilitated and seeded with approved Lolo National Forest seed mix and covered with slash or mulch. Erosion control measures (such as straw bales, wattles, silt fences, hydro mulching, seeding with approved mix, and water barring) would use only certified weed-free products and would be used where necessary and remain in place before and during grounddisturbing activities. To ensure effectiveness, erosion control measures would remain in place and functional until disturbed sites (such as roads, culverts, landings, and burn piles) were stabilized, typically for at least one growing season after ground-disturbing activities. Inspection and maintenance would occur following high rainfall events and prior to fall and spring runoff to ensure effectiveness. Heritage If previously unrecorded heritage resources are encountered during project implementation, activities would be halted and a Forest Archaeologist would be notified immediately. If necessary, additional mitigation measures would be devised in consultation with the Units/Location Haul roads Haul roads Haul roads New road construction Harvest units Haul roads Haul roads Temporary roads and landings All activity areas Project area 18

23 Standard Operating Procedures Montana State Historic Preservation Office. Wildlife Snags and snag replacements would be retained in timber harvest units consistent with the Lolo National Forest Dead and Down Habitat Components Guidelines (June 1997) and Appendix N of the Lolo Forest Plan. Unless specified for removal in the silvicultural prescription, snags would remain within treatment areas. Snags that need to be cut for safety or operational reasons would remain in the unit. Units/Location All timber harvest units 19

24 2.2.2 Monitoring Implementation and effectiveness monitoring would be conducted under this project to: (1) determine whether the original objectives of the activities are met; (2) determine the need for additional action; and (3) educate and assist in the design in future projects. Monitoring of the vegetation treatment activities would occur during and immediately following contract implementation. All preparation and subsequent project-associated operations would be monitored by Forest Service representatives to ensure compliance with specifications. Weeds In conjunction with other post-harvest monitoring or inventory activities, harvest units would be monitored for the presence of new weed infestations. In addition, roads treated with herbicide would be monitored for herbicide efficacy, the presence of new weeds, and/or the spread of existing weeds. Follow-up actions would depend on the monitoring findings. The motorized recreation route would be also monitored for weeds in conjunction with other recreation responsibilities. New infestations would be treated. Soils The Lolo National Forest Soil Monitoring Program objective is to evaluate project design standards and mitigations to ensure they were implemented so that a project complies with the Lolo Forest Plan and Region 1 soil quality standards. 2-Short units 3, 15, 22, and the rehabilitation of historic horse logging tracts in Unit 27 (see rehabilitation plan in Appendix C) would be added to the Forest soil monitoring program for post-harvest soil quality assessment. Post-harvest monitoring would be initiated 2-3 years following an activity. The soil scientist would work closely with the layout and design crews as well as the Timber Sale Administrator. When concerns or questions arise, the site would be visited and decisions documented. If any units are suspected of exceeding Region 1 soil quality standards following activities, they would be reviewed and rehabilitation measures applied. Recreation The motorized loop route would be monitored (particularly during the fall hunting season) for compliance with seasonal use restrictions. If these restrictions are not adhered to, the motorized loop would be permanently closed to the public. 2.3 Alternatives Considered but Eliminated from Detailed Study The Healthy Forests Restoration Act (HFRA) (2003) only requires the Forest Service to study, develop, and describe: The proposed agency action The alternative of no action An additional action alternative, if the additional alternative is proposed during scoping or the collaborative process and meets the purpose and need for the project. 20

25 One public comment, received nearly a year after the conclusion of the scoping period and collaborative process, requested the Forest Service to analyze an alternative that does not include any timber harvest or new road construction due to potential effects of these activities on the environment. In addition to being proposed outside the scoping and collaborative process, this alternative would not meet the purpose and need to restore resilient vegetative conditions, reduce fuels, or support communities. Therefore under the HFRA, the Forest Service is not required to analyze this alternative in detail. The Forest Service considered using only non-commercial silvicultural treatments to accomplish vegetation objectives, but determined that they would not be effective in lowering the risk of high severity fire, insect infestation, or disease without removal of some of the larger-sized trees. An alternative that does not conduct timber harvest and associated road construction is essentially represented by the No Action alternative (Alternative 1), the effects of which are described in Chapter 3. The analysis summarized in Chapter 3 concludes that proposed timber harvest and road construction would not have significant adverse effects on forest resources. The Lolo Forest Plan allows for timber harvest to achieve management objectives within the project area. To respond to the identified needs within the project area, the modified proposed action uses the range of silvicultural tools available, including timber harvest, prescribed burning, and non-commercial mechanical treatments. 21

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27 CHAPTER 3: ENVIRONMENTAL EFFECTS This section summarizes the potential effect of no action and the modified proposed action. The analysis of effects takes into consideration mitigations provided by the resource protection measures described in Chapter 2. If no direct and indirect effects are identified, no cumulative effects would occur. 3.1 Past, Present, and Reasonably Foreseeable Future Actions Consistent with 36 CFR 220.4(f) and Council on Environmental Quality (CEQ) guidance, the past, present, and reasonably foreseeable future actions were considered for analysis of cumulative effects where appropriate for each resource. Past actions considered in the cumulative effects analysis include those that contributed to establishing the baseline conditions of the project area today. Past Actions Timber Harvest Past management actions on NFS lands within the project area include timber harvest and related activities. According to Forest Service records, timber harvest has occurred on approximately 1110 acres (27 percent) of the NFS land since the 1950s. Harvest has ranged from individual tree removals to clearcuts. Regeneration-type harvests account for about 52 percent of the NFS land harvested. The remaining 48 percent of the harvest area received intermediate treatments. All of the previously harvested areas are certified as stocked. Although the Forest Service has no detailed records of harvest prior to 1950, timber cutting likely occurred in Shorty Gulch. Table 3.1-1: Summary of Past Harvest on NFS Land by Decade Type of Harvest 1950s (acres) 1960s (acres) 1970s (acres) 1980s (acres) 1990s (acres) 2000s (acres) 2010s (acres) TOTAL (acres) Regeneration Intermediate TOTAL Note: total acres of past harvest shown in the table is somewhat inflated (by approximately 17 acres) due to multiple entries on the same piece of ground. The most recent timber harvest on NFS land is described below: Shorty Gulch Hazardous Fuels Reduction (HFR) ( ): Timber sale included 200 acres of intermediate harvest using conventional yarding systems (tractor and skyline). Project was focused on fuels reduction in dry ponderosa pine forest types. Sale closed in Denver Nine (1988): Timber sale included approximately 270 acres of harvest within the project area. All but 5 acres were regeneration harvest. Pre-Commercial Thinning Approximately 345 acres has been pre-commercially thinned in the project area since

28 Prescribed Burning Prescribed burning not associated with timber harvest has occurred on approximately 740 acres (300 acres in and 440 acres in ). Fuel Break Approximately 59 acres of fuel break was completed in 2012 as part of the original Shorty Gulch HFR project. The work consisted primarily of slashing and hand piling of small diameter trees near residences and adjacent property boundaries. Road Development and Other Infrastructure There are approximately 24 miles of National Forest system roads in the project area. About 22 percent of these are open yearlong to public travel and 60 percent open seasonally. There are approximately 7 miles of non-system roads under Forest Service jurisdiction. Most of these roads are grown-in with vegetation. The most recent road construction on NFS land occurred in the mid to late 1980s. Approximately 2.8 miles of road were constructed in the Shorty Gulch drainage (Roads 16809, 16286, and 16819) and approximately 8 miles of road were constructed in the Clear Creek drainage (Roads 7635, 16818, and 16820) as part of the Denver Nine Timber Sale. Bonneville Power Administration (BPA) and Northwestern Energy power lines cross the southern edge of the project area. The power line development includes roads that access the towers and/or poles. Road Maintenance Maintenance was recently conducted on roads 7636, 16286, 17059, and a segment of used for haul in the Shorty Gulch HFR project (sale closed in 2014). Weed Treatment Herbicide has been applied to approximately 465 acres, including drivable roads and forest openings. About 93 acres of roads were treated in under the Shorty Gulch HFR project. Roads were re-treated in spring Approximately 334 acres of forest openings in Valentine Gulch were aerially treated in 2002 and 2006 under the Big Game Winter Range and Burned Area Weed Management EIS/ROD (2001). Ongoing and Reasonably Foreseeable Future Actions Ongoing and reasonably foreseeable future actions within the project area include: Shorty Gulch Road Relocation The first 0.1 miles of the Shorty Gulch Road #7605 will be relocated out of a wetland located near the mouth of Shorty Gulch in proximity to Prospect Creek. This project will decommission approximately 0.1 miles of road, remove two undersized culverts, and construct a new segment of road outside the riparian area. This project will occur in summer

29 3.2 Vegetation Resilient Vegetative Conditions Field reconnaissance by certified silviculturists and Regional entomology and pathology experts identified four primary diseases and insects of concern in the project area including root disease, Douglas-fir beetle, mountain pine beetle, and dwarf mistletoe. The science basis for conducting vegetation treatments to address these pathogens and provide for forest resilience is contained in Appendix D. Root Disease A root disease hazard map for the western portion of Region One indicates that over 70 percent of the project area has a moderate or high hazard rating, which indicates the likelihood that root diseases exist on the site and the highest possible impact that might occur to the stand (Lockman and Egan 2016). Just under 30 percent of the project area has a low hazard rating, indicating root diseases likely occur, but they have less impact than in stands with moderate or high root disease hazard. On-theground observations (Lockman and Egan 2016) validated the presence of root disease, with overstory tree losses ranging from observable to over 50 percent mortality. Armillaria was the main root disease observed, and schweinitzii root and butt rot is contributing to tree decay, decline, and mortality. Armillaria is considered a disease of the site in that the established mycelia of the fungus are essentially permanent. Douglas-fir and true firs are the most susceptible species to Armillaria root disease-caused mortality (Hagle 2008), so losses on a site are directly related to the proportion of susceptible species. Virtually all of the 2-Short project area has root disease likely present. The dominance of Douglas-fir on root disease-infected sites explains in the observed ongoing mortality. Units 2, 12 through 22, 24 through 27, and 101 through 104 have observed presence of and mortality from root disease (see map in Appendix A). Douglas-fir Beetle Stands dominated by large Douglas-fir trees infected with root disease serve as refugia for Douglas-fir beetles, and root disease exacerbates Douglas-fir beetle-caused tree mortality during outbreaks. Stands in the project area and in the immediately surrounding landscape have substantial amounts of potential Douglas-fir beetle habitat in the form of moderately and highly susceptible vegetation (Douglas-fir cover type in dense stands of large diameter trees). There is potential for Douglas-fir beetle outbreaks and related tree mortality, especially if protracted drought occurs. (Lockman and Egan 2016). Most of the project area has a moderate hazard, meaning there is potential for 10 to 30 percent loss of basal area 5. Douglas-fir beetles primarily infest Douglas-fir trees. Susceptible stands have a majority of Douglasfir, are mature or older, and have high basal area (Furniss and Kegley 2014). Under normal conditions, beetles typically inhabit individual trees with low resistance, infected with root disease, or are dying. Outbreaks of beetles are typically attributed to weather events, fires, defoliation, and drought. 5 Basal area is a measure of tree density per acre based on the total area in square feet of the cross-section of tree trunks measured 4.5 feet above the ground on an acre of land. 25

30 Units 2, 3, 4, 6, 7, 9, 12, 16, 17, 18, 20, 21, 22, and 26 have observed past and ongoing mortality from Douglas-fir beetles (see map in Appendix A). The combination of a landscape dominated by sites with root disease and Douglas-fir cover type results in on-going and foreseeable mortality from the individual agents and the interaction between Armillaria root disease and Douglas-fir beetles. Mountain Pine Beetle Mountain pine beetles are native bark beetles that spend their entire lifecycle beneath the bark of host trees, except when adults emerge and fly in search of new host trees. Mountain pine beetle outbreaks develop in dense stands (300 to 600 trees per acre) of large-diameter (over 8 inches diameter breast height (dbh)), older (over 80 years old) lodgepole pine and dense stands (over 150 square feet of basal area per acre) of mid-size (8 to 12 inches dbh) ponderosa pine, often in single-story even-aged stands. Mountain pine beetles can exist at low levels for decades with scattered and often insignificant levels of tree mortality. Outbreaks are dependent on a number of factors including favorable climatic and stand conditions and proximity to an existing beetle population. Extensive tree mortality from mountain pine beetle outbreaks can significantly alter successional pathways. Late successional, shade tolerant, fire intolerant, and insect- and disease-susceptible species such as subalpine fir or Douglas-fir often replace the pine that have been killed by mountain pine beetles in the absence of fire (Gibson et al. 2009). High amounts of past mortality caused by mountain pine beetles occur in units 13, 14, 103, and 104. Lodgepole pine units 10, 11, and 33 and ponderosa pine units 8, 30, 31, 32, 34, 35, and 36 have moderate to high hazard for mountain pine beetles due to tree size and density (see map in Appendix A). Dwarf Mistletoe Dwarf mistletoes are small, leafless, parasitic plants that require a live host to survive. They are generally host-specific. The major species affected in the Northern Rockies are larch, lodgepole pine, and Douglas-fir. Dwarf mistletoes reduce growth, wood quality, seed production, and life span of their host trees. Dwarf mistletoe infestations can increase wildfire risk, especially in Douglas-fir, by development of large brooms filled with small twigs and dead needles in the lower portion of crowns (Hoffman 2010). Larch and lodgepole pine trees are heavily infected with dwarf mistletoe in units 13, 14, 25, 103, and 104. Douglas-fir dwarf mistletoe infestations are in units 2, 15, 16, and 23 (see map in Appendix A). Alternative 1: Direct, Indirect, and Cumulative Effects Under Alternative 1, stands with low to moderate levels of root disease and dominated by root disease susceptible species would continue to suffer mortality and lose basal area over time. If there is a component of root disease tolerant species, such as western larch, then the species composition would slowly shift towards those species. Without disturbance, such as fire, these stands would continue to regenerate to root disease susceptible species and experience losses from root disease (Lockman and Egan 2016). Dense stands dominated by mid-sized Douglas-fir trees would continue to grow and increase in their susceptibility to Douglas-fir beetles. In general, Douglas-fir beetle outbreaks require: 1) a susceptible host; 2) conducive weather conditions; and 3) amplified beetle populations (typically resulting from a catalyst such as windthrow, fire-injury, migration from surrounding area, etc.). Forest conditions within the 2-Short area are currently susceptible and this susceptibility would increase through time. It is reasonable to assume that within the subsequent near-future (20-30 years) substantial and protracted 26

31 drought will occur, likely multiple times which would increase tree stress lowering resistance to insects (Lockman and Egan 2016). Similarly, dense stands dominated by lodgepole pine or ponderosa pine would continue to grow and increase in their susceptibility to mountain pine beetles. In general, mountain pine beetle outbreaks require: 1) a susceptible host; 2) conducive weather conditions; and 3) amplified beetle population within the stand or migration from the surrounding area. The 2-Short project area has forest conditions that are currently susceptible and susceptibility would increase through time. Dwarf mistletoes have been found to generally increase the rate of conversion to later-seral species and produce mature stands with relatively low stocking. Severe levels of dwarf mistletoe have been found to prevent canopy closure over time, which is commonly seen in heavily infected western larch stands. Dwarf mistletoe would increase in individual trees subsequently infecting the entire tree crown and leading to decline, topkill, and eventual mortality in mature trees. On sites with moderate to high levels of root disease, western larch with moderate to severe levels of dwarf mistletoe would become less likely to tolerate root disease and begin to decline from both diseases (Lockman and Egan 2016). Alternative 1 would not meet the project purpose to trend the area toward desired resilient vegetative conditions. It would also not meet one of the primary goals Forest Plan goals for the area, which is to provide for healthy stands and optimize timber growing potential. Alternative 2: Direct, Indirect and Cumulative Effects Root Disease Managing losses from root disease is a function of reducing susceptible host species (primarily Douglas-fir and true firs) and increasing root disease tolerant species (primarily larch, ponderosa pine, lodgepole pine, and western white pine) (See Appendix D for more information). Alternative 2 would reduce root disease hazard on approximately 680 acres (see Table 3.2-1). Treatments include regeneration harvest followed by planting of disease-tolerant species on approximately 526 acres and slashing/burning/planting on 140 acres with moderate to high levels of existing root-disease caused mortality. Stands with root disease and dominated by root disease susceptible species greatly benefit from regeneration harvest if the stand is regenerated with disease tolerant species (Lockman and Egan 2016, Lockman 2009). Approximately 14 acres (Unit 2) with existing low levels of root disease would be commercially thinned to feature disease-tolerant species. Commercial thinning can exacerbate root disease because the disease present on the roots of susceptible trees quickly colonize the entire root system following cutting. Without the natural defenses of the tree, the inoculum is able to rapidly infect neighboring residual trees that share root contact, resulting in mortality some time following harvest (Morrison 2001, Lockman 2009). However, commercial thinning stands where root disease tolerant species make up a large component of the residual stand (as in this case) can benefit if the tolerant species are retained (ibid.). Within Unit 2, retention of the larch and ponderosa pine trees would allow these trees to develop size and crowns for future seed crops of root disease tolerant species. Maintaining and perpetuating root disease-tolerant species would result in a decrease of fungus biomass on site and lower root disease severity over time (Lockman and Egan 2016). Past harvest likely had mixed effects on root disease. The extent of moderate and high root disease hazard in the project area indicates that the intermediate harvests conducted in the 1950s through 1980s (up to 342 acres) likely exacerbated root disease by some combination of removing root disease tolerant tree species and increasing fungal inoculum through increased root biomass available after 27

32 removing Douglas-fir. The 200 acres harvested in the Shorty Gulch Hazardous Fuels Reduction project in the 2010s retained mature root disease tolerant and fire tolerant trees that will contribute in the long term to stands of low risk due to the lack of susceptible host trees. The regeneration harvests of the 1950s through 1990s likely resulted in a flush of fungal inoculum. Current root disease hazard is related to the proportion of susceptible species in the regeneration. Past regeneration harvest units that were later pre-commercially thinned (345 acres) to feature root disease resistant species now have a lower root disease hazard. Cumulatively, past and proposed regeneration and intermediate harvests and non-commercial treatments would reduce root disease hazard on about a 29 percent (1225 acres) of the project area. Bark Beetles Managing bark beetle hazard is a function of altering stand conditions (primarily density and age class) and increasing the proportion of non-host species (see Appendix D for more information). Alternative 2 would reduce bark beetle hazard on approximately 886 acres (see Table 3.2-1). Treatments include 193 acres of intermediate harvest, 412 acres of regeneration harvest, 246 acres of non-commercial thinning, 16 acres of underburning, and 19 acres of slash/burn/plant activities. Intermediate harvest would reduce stand density and susceptibility to Douglas-fir beetle-attack where root disease occurrence is low. Silvicultural techniques that reduce density levels below 100 feet 2 per acre of basal area and prioritize the removal of large-diameter Douglas-fir trees can effectively reduce susceptibility to Douglas-fir beetle-attack (Lockman and Egan 2016). Regeneration harvests, whether they occur across or within smaller patches of stands, would reduce Douglas-fir beetle susceptibility to low levels until recruited Douglas-fir trees reach or exceed 10 inches dbh (ibid.). Long-term reduction of mountain pine beetle hazard through silvicultural treatments includes: (1) thinning to reduce mountain pine beetle-caused mortality by changing microclimate and wind patterns within the stand, allowing beetle-produced pheromones to dissipate, and providing more growing space, nutrients, and water for remaining trees if the thinning is performed prior to initiation of the bark beetle outbreak and (2) regeneration harvesting patches to create a mosaic of age and size classes to reduce the amount of pine that is susceptible to mountain pine beetles at any one time (Gibson et al. 2009). Past harvest in the project area has reduced the bark beetle hazard by reducing tree densities. However, the hazard is now increasing within the areas that were intermediately harvested in the 1950s through the 1980s (approximately 342 acres) due to tree growth and development of understory trees that modify the microclimate under the main tree canopy. The 200 acres harvested in the Shorty Gulch Hazardous Fuels Reduction project in the 2010s retained mature ponderosa pine and larch trees at low densities. These areas will retain a low bark beetle hazard for several decades. Cumulatively, past and proposed non-commercial thinning, regeneration harvests, intermediate harvests, and underburning would result in a low bark beetle hazard on about 33 percent (1400 acres) of the project area. Dwarf Mistletoe The project would reduce dwarf mistletoe hazard on approximately 294 acres (see Table 3.2-1). Treatments would include about 14 acres of intermediate harvest, 261 acres of regeneration harvest, and 19 acres of slash/burn/plant activities. Intermediate harvest can be used to manage dwarf mistletoe infections. However, if infected trees are retained, the mistletoe tends to spread and the infection intensifies (Hoffman 2010; Muir and Geils 2002; Schmitt and Hadfield 2009). There is a potential that intermediate harvest treatments may 28

33 overlook latent infections from dwarf mistletoe, and when a stand is opened up, these latent infections become quite visible. Therefore, intermediate harvest would reduce dwarf mistletoe, but not likely remove it if the host trees are still maintained on site (Lockman and Egan 2016). Unit 2 (14 acres) would be commercially thinned to remove Douglas-fir mistletoe infected trees, which would reduce the disease hazard in this stand. Regeneration harvest provides the best control for dwarf mistletoe through complete removal of infected trees and replacement with mistletoe-free regeneration (Hoffman 2010; Muir and Geils 2002). When the host tree dies, the dwarf mistletoe dies. Past regeneration harvest has reduced dwarf mistletoe infections on about 585 acres. Cumulatively, past regeneration harvest and the proposed activities listed above would reduce dwarf mistletoe hazard on approximately 879 acres (20 percent) of the project area. Table 3.2-1: Summary of Acres with Reduced Insect and Disease Hazard by Alternative Issue Proposed Activity Alternative 2 (acres) Root Disease Regeneration harvest on past intermediate harvest 118 reduced root disease hazard Intermediate harvest reduced root disease hazard 14 Regeneration harvest on land not previously 408 harvested reduced root disease hazard Slash/burn/plant reduced root disease hazard 140 Total reduced root disease hazard 680 Bark Beetle Intermediate harvest low hazard 193 Non-commercial thinning reduced bark beetle 246 hazard Regeneration harvest reduced bark beetle hazard 412 Underburn reduced bark beetle hazard 16 Slash/burn/plant - reduced bark beetle hazard 19 Total reduced bark beetle hazard 886 Dwarf mistletoe Intermediate harvest reduced DMT hazard 14 Regeneration harvest reduced DMT hazard 261 Slash/burn/plant - reduced DMT hazard 19 Total reduced dwarf mistletoe hazard 294 Forest Plan Consistency The 2-Short project is consistent with the Lolo Forest Plan. Reducing insect and disease concerns addresses one of the primary goals Forest Plan goals for the area, which is to provide for healthy stands. Timber harvest is proposed where the Plan allows this activity. Forest-wide standards related to vegetation management were followed in the project design (see Vegetation report in the Project File for more information) Old Growth The Lolo Forest Plan defines old growth as individual trees or stands of trees that in general are past their maximum rate in terms of the physiological processes expressed as height, diameter and volume growth (pages VII-24 to VII-25). The Lolo National Forest Plan Final Environmental Impact Statement (page II-61) (1986) states, As a strategy for meeting old growth needs, the Forest was segregated into 71 drainages. A minimum of eight percent old growth was allocated to most of these drainages where wilderness was not available. The eight percent was based on an interpretation of 29

34 literature available at the time which considered the minimum habitat needed for various old growth associated wildlife species. In 1994, the Lolo National Forest recognized a need to adjust the strategy for managing old growth (In-service memo 2070, Daniels 4/29/94). The resultant memo adopted the Region 1 old growth definitions (see below) and provided direction for consistent implementation of an old growth strategy within the Lolo Forest Plan. The strategy states that in order to conserve biological diversity, including old growth associated species, the Forest will: Retain 8 percent of the Forest land in old growth reserves Manage landscapes using ecological principles Prescribe treatments that consider the range of natural variation, age class distribution and natural processes The Northern Region (Region 1) of the Forest Service has defined old growth in Green et al. (1992, errata corrected 2011). Old growth definitions are stratified by habitat type groups that reflect similarity of disturbance response, potential productivity, stocking density, down wood accumulation, fire frequency, and tree species. The Green et al. old growth definitions are specific to forest type (the dominant tree species) and habitat type group, and are defined by a minimum number of live trees greater than a specific size and age, in stands with a minimum density. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on old growth because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects The project would have no direct, indirect, or cumulative effects on old growth. No activities are proposed within existing old growth (as defined by Green et al. 1992, errata corrected 2011) or Forest Plan management area 21 (which are areas allocated to in the Forest Plan to be managed for old growth succession). Field reviews concluded that none of the areas proposed for treatment meet minimum old growth characteristics (ibid.) Forest Plan Consistency A forest-wide old growth analysis using Forest Inventory and Analysis (FIA) data (Czaplewski, 2004) shows that the Lolo National Forest is meeting the Forest Plan old growth strategy of the Forest Plan. The estimated percentage of old growth (using the more restrictive definition provided by Green et al. (1992, errata corrected 2011) on all forested lands on the Lolo National Forest is 9.0 percent (Bush et al. 2007, updated 2012), above the 8 percent strategy. Using the Lolo Forest Plan definition of old growth, the FIA inventory data indicates that at least 14.4 percent of the Lolo National Forest forestlands are old growth, i.e., old forest stands as represented by large size and over 160 years old (Applegate and Slaughter, 2003). At least 20 percent of Lolo National Forest forestlands are old forest stands over 140 years old. The Lolo National Forest is currently meeting the Forest Plan strategy for old growth at the forestwide scale, and appears to have an abundance of old growth sufficient to continue to meet the strategy in the event of disturbance such as fire or pathogens. Alternative 2 would not affect the Forest s ability to meet its old growth strategy because no old growth would be removed, and the project s vegetation 30

35 treatments would improve the overall resiliency of the project area and reduce the potential for stand replacing fire behavior Botany The project area contains potential habitat for 6 sensitive species, including tapertip onion, bigleaf sedge, diamond clarkia, clustered lady s slipper, western pearlflower, and hill monkey flower. Botanical surveys were conducted within the project area and four populations of hill monkeyflower consisting of a total of approximately 15,400 plants were identified. This species is a small, shortlived annual herb that grows in gravelly, bare soil. No other sensitive plants species were found. No threatened and endangered species or habitat occurs within the project area. This section is focused on sensitive plants because these are species for which population viability is a concern, as evidenced by significant current or predicted downward trends in 1) population numbers or density and/or 2) habitat capability that would reduce a species existing distribution (FSM ). Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on sensitive plants or their habitat because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects Because proposed new road construction (#18494ext) would have bisected one of the hill monkeyflower populations, the road location was adjusted to avoid the entire population (see Resource Protection Measures in Chapter 2). Therefore, this activity would not impact sensitive plants. Three hill monkeyflower populations overlap portions of Units 3, 7, 22, 26, and 30. The population located within Unit 26 would be buffered from timber harvest; therefore there would be no impact to this population (see Resource Protection Measures in Chapter 2). Unit 30 is proposed for noncommercial thinning where no ground disturbance would occur. This type of treatment would maintain favorable hill monkeyflower habitat conditions such as open stand conditions and bare soil. Thus, the non-commercial thinning in Unit 30 would have no adverse impact to the species. Timber harvest in Units 3, 7, and 22 could cause a decline of approximately 9 percent of the hill monkeyflower plants within the project area if weed cover increases. However, a minimum of 14,000 plants (91 percent) would remain unaffected by project activities. There would be no significant current or predicted downward trends in population numbers or density and/or habitat capability that would reduce the existing distribution of hill monkeyflower. Cumulative Effects Historical data are lacking for hill monkeyflower in the project area because the populations were not found until Past activities likely affected hill monkeyflowers. Widespread fire suppression that began in the early 1900s has allowed conifer cover to increase in much of the project area and caused bare soil to decrease as fallen branches and conifer needles accumulated changes that could have reduced habitat for hill monkeyflower. Past ground disturbing activities such as road construction and ground-based timber harvest likely destroyed some plants. Logging also created more open stand conditions and bare soil in some areas that may have helped perpetuate monkeyflower populations. While impacts of past activities are less understood, the beneficial impacts of past logging and prescribed burning (e.g. reduced tree canopy cover and bare soil patches) may have compensated for any detrimental impacts associated with fire suppression, road construction, ground-based timber harvest, and invasive weed spread, resulting in an overall neutral impact on hill monkeyflower plant 31

36 numbers. The project area continues to support four large monkeyflower populations and 56 percent of the plants documented in Montana. The 2-Short project could reduce monkeyflowers in the project area by approximately 1,385 plants, but at least 14,000 monkeyflowers (91 percent of plants in the project area) would remain. Therefore, the project may impact individuals or habitat but would likely not contribute to a trend toward federal listing or loss of viability for the species. Forest Plan Consistency The project is consistent with the Lolo Forest Plan because sensitive plant species would be protected to maintain population viability (Forest Plan standard 27, page II-14) Weeds Weeds are capable of out-competing native vegetation. As a result of weed proliferation, native plant populations can be displaced and the total number of native plant species can decrease. Therefore, weeds may reduce the ability of natural communities to support plants and animals native to the ecosystem and reduce the ability of communities to recover from disturbance. Weed spread is exacerbated by soil disturbance that creates a suitable seed bed for weeds to germinate. Any activity that exposes soil has the potential to accelerate weed spread. Factors limiting weed spread are shade from tree canopies, higher soil moisture, needle and grass litter that provides a mulch-like covering of the ground, lack of exposed soil, and native plant competition. Surveys conducted within the 2-Short project area indicate that weeds are present on the roads to varying degrees. The drivable roads within the project have been treated for weeds since 2010 and have only occasional plants to small patches of weeds. The surveys also showed that weeds have generally not spread beyond the roads except where vulnerable habitat exists or where there is a break in the tree canopy along the road. Small (1/10th acre) to medium (1-2 acre) size patches of weeds are present in some forest openings and old harvest units in close proximity (within 500 feet) of roads. The most common weed species within the project area are spotted knapweed and St. Johnswort. Alternative 1: Direct, Indirect, and Cumulative Effects No ground disturbing activities are proposed in Alternative 1. However, the amount of weeds and weed species currently present can be expected to gradually increase within the project area. As natural disturbances such as insect and disease mortality, windthrow, fire, snow breakage, continue to occur and create gaps in the existing forest canopy or disturb the soil, weeds can be expected to spread from their current locations into these newly disturbed sites. With the exception of wildfire, these changes would occur very gradually. Under Alternative 1, fuel loads within the project would not be further reduced and thus the potential for uncharacteristic wildfire effects in some areas would not be addressed. High severity wildfires could burn large areas of duff, exposing mineral soil. These wildfires could also remove large areas of canopy cover, increasing the amount of available light to the forest floor. Exposing the mineral soil and increasing the available light would result in an increased risk of the introduction, establishment, and persistence of weeds. If existing populations of weeds are nearby, the likelihood of introduction and establishment of noxious weeds would increase. The drivable roads in the project area have been treated for weeds and will continue to be treated with herbicide into the foreseeable future. This action will reduce the existing weed populations along 32

37 these roads. Reducing the weed populations along these roads will lower the risk of weed spread into nearby susceptible habitats. Alternative 2: Direct and Indirect Effects Weed spread could be facilitated by vehicle travel in and out of the project area and by ground disturbing activities including log skidding, prescribed burning, and road maintenance and construction. Harvest methods that cause less ground disturbance such as skyline yarding would have a lower risk of weed spread than tractor skidding. Prescribed burning may kill native vegetation, temporarily exposing soil. The majority of the area affected by the project has a moderate risk for weed susceptibility, meaning that weeds may dominate interspaces of native vegetation but sites generally have a limiting factor which prevents full development of the weeds (see Weed report in the Project File for more details). All road-related activities (e.g. construction, reconstruction, maintenance, and physical decommissioning treatments) pose a high susceptibility for weed establishment and spread. This means weeds may frequently dominate native vegetation following disturbance or through invasion into a disturbed community. To minimize the risk of weed introduction and spread, several measures would be applied to project activities (see Chapter 2, section 2.2.1) including: Wash off-road equipment to remove mud, dirt, and plant parts before moving into project area. Pre-treat weeds on roads prior to conducting ground-disturbing activities on or near them. Minimize soil disturbance and revegetate bare soil as appropriate. Seed disturbed sites. Monitor for weeds after completion of project activities and treat weeds as necessary. Approximately 89 acres within units 20, 26, 27 and the upper portion of unit 15 were determined to have a high risk to weed establishment and spread due to a combination of ground disturbance (tractor skidding) and tree canopy reduction (regeneration harvest) in weed-susceptible habitat types (generally dry aspects with gravelly soils). This high risk accounts for less than 8 percent of the proposed vegetation treatments and about 2 percent of the project area. To reduce the potential for weed spread and establishment on these more vulnerable areas, the following additional resource protection measures would be applied (see Chapter 2, section 2.2.1): Place slash on skid trails after use. Where feasible, use herbicide to treat weeds in potential landing areas prior to use. The recreational motorized loop route would be on existing and newly constructed roads that are open primarily in the summer to public motorized use. To address potential weed concerns, the motorized recreation route would be monitored and new weed infestations would be treated. Cumulative Effects Past soil disturbing activities over the last sixty years, whether they were natural or man-caused, have helped spread noxious weeds into and within the 2-Short project area. Private land located in and adjacent to the project area could be a source for weed seed. Weed treatments on other lands may or may not occur depending on the landowner. Without treatments, 33

38 these areas could add to the amount of existing weeds and possibly the number of species in the project area. While it is unknown when the first noxious weeds were established in the project area, a good estimate would be in the late 1950s. The Lolo National Forest adopted preventive measures to avoid weed spread and establishment of new invasive species with the 1991 Noxious Weed Management Amendment to the Lolo Forest Plan. This authorized integrated pest management strategies including the use of certain herbicides. Timber sale contracts were modified to include washing of equipment to remove weed seeds prior to entry onto National Forest land, herbicide spraying of haul routes, and use of weed-free grass seed to re-vegetate disturbed ground. In 2007, the Lolo National Forest adopted an adaptive and integrated weed management strategy to include treatment of new weed species, new weed populations, and use of new control methods. Over the last ten years, drivable roads within the project area have been treated with herbicide; the latest treatment was applied in spring In addition, over 300 acres of big game winter range in Valentine Gulch have been sprayed to reduce weeds. Monitoring across the Lolo National Forest indicates herbicide treatments have been more than 90 percent effective in controlling and reducing weed populations. Ground-disturbing activities in Alternative 2 may contribute to weed spread in the project area. However, recent roadside herbicide treatments and project resource protection measures (e.g. washing mechanized equipment, minimizing ground disturbance, and revegetating disturbed sites) would minimize the potential for establishment and spread of weeds. Forest Plan Consistency Project activities would be consistent with the Forest Plan because all management activities would incorporate appropriate weed prevention measures. Weed prevention measures outlined in Appendix W of the Plan (amended to the Forest Plan in 1991) are incorporated in the resource protection measures for the 2-Short project (Chapter 2). 3.3 Fire and Fuels The 2-Short project is designed to complement the fuels reduction work previously completed in Shorty Gulch to slow fire spread and reduce fire severity, increasing options for and effectiveness of future fire suppression actions. Fuels work is prioritized in this area because of its proximity to private land, numerous residences, the Northwestern Energy power line, and the BPA power line that supplies power to over 13,000,000 people in the Pacific Northwest. Treatments for the 2-Short project would be consistent with the principles of fire hazard reduction summarized by Agee and Skinner (2005): Reduce surface fuels to reduce potential flame length Increase height to live crown. To avoid crown fire initiation, the height from the ground to the lowest living foliage needs to be considerably higher than the expected flame lengths from the fuel on the ground Decrease crown density to make tree-to-tree crown fire less probable Retain big trees of resistant species resulting in less mortality for the same fire intensity 34

39 Any particular wildfire s growth and behavior is unique because of the infinite combinations of weather, fuels, and physical settings that can occur over spatial and temporal scales (Graham et al. 2004). These variables make it difficult to speak to fire behavior with specificity and certainty. Given this complexity, focusing on basic scientific principles is important for decision-making and adaptive management over time (Peterson et al. 2005). Alternative 1: Direct, Indirect, and Cumulative Effects The Shorty Gulch Hazardous Fuels Reduction project (completed in 2014) reduced fuel loads on approximately 600 acres of the project area through a mix of timber harvest, prescribed burning, and non-commercial mechanical treatments. However, the original objectives of that project were not fully realized due to the infeasibility of helicopter yarding as described in Chapter 1. With no additional action occurring in the project area, fuels conditions in areas left untreated would continue to trend towards the following: In areas with relatively open canopies, there would be an increase in needle litter accumulations, conifer regeneration encroachment and crown closures, providing ideal conditions for crown fire spread. Surface fuels would increase in stands affected by insects and disease, particularly as the dead trees fall to the ground. Mixed species stands would continue to mature resulting in denser stands, high fuel loadings and large amounts of ladder fuels. Initial attack of a wildland fire (line construction, holding, and mop-up 6 ) would become more difficult when heavy fuel loadings are encountered, aerial fuels become involved with fire, and danger trees are present. Actions on large fires are only compounded by those same issues associated with initial attack. With no additional action occurring in the project area, suppression efforts would expect the following: Line construction would proceed slowly due to the amount of work required to construct an appropriate fuel break and fireline through continuous heavy surface fuels and tree regeneration. Fireline intensity would preclude the use of direct attack by hand crews. Aerial delivery of water or retardant would be less effective in cooling the fire because of heavy fuels. There would be more snags and hazard trees that need to be felled for firefighter safety. Heavy surface fuels and ladder fuels would facilitate torching and spotting. Options for backfiring or burnout would be limited. Where tree crowns are horizontally continuous, there may be crown fire runs that compromise the fireline and jeopardize personnel. Holding and burning out fireline would be difficult, and may be less successful due to the potential for spotting from torching trees and heavy fuel concentrations. Water would be less effective in supporting holding efforts. Burnout operations would be of higher risk due to increased potential for spotting from torching trees and long residency time of fire in heavy fuels. Mop-up to secure the fire from escape would take longer due to residency time of fire in the heavy fuels. 6 Mop-up means extinguishing or removing burning material near control lines, felling snags, and trenching logs to prevent rolling after an area has burned, to make a fire safe, or to reduce residual smoke. 35

40 If initial attack is unsuccessful and a fire is burning into or within the 2-Short area, there may be an increased threat to private property, homes, and regional power lines. Prevailing winds funneling down Prospect Creek would likely spread the fire to the east toward Highway 200, where more residences and community infrastructure are located. As evidenced by the path of the 1973 Tri-Creek Fire, the power lines located parallel to Prospect Creek would also be at risk. Alternative 2: Direct and Indirect Effects Fuel conditions would be manipulated using a variety of treatments. Fuel modeling 7 and scientific literature (Appendix D) indicate that these treatments would result in the area having low to moderate severity fire behavior characteristics under normal summer conditions over the next years as opposed to those that support moderate to high severity fire behavior characteristics if no action is taken. For example, the project s treatments would reduce the rate of fire spread, fireline intensity, flame length, and scorch height in treated areas (see the Fire and Fuels report in the Project File). Project treatments would reduce the amount of heavy surface fuel accumulations providing conditions that are less resistant to control efforts. In addition, they would reduce the amount of ladder fuels and break up the horizontal continuity of the crowns, allowing more heat energy to be dissipated into the air instead of to adjacent aerial fuels. This would reduce the likelihood for sustained crown fires and associated long-range spotting. Initial attack of a wildland fire (line construction, holding, and mop-up) would become less difficult with lighter fuel loadings, lower potential for aerial fuels to become involved with fire, and fewer danger trees present. Suppression actions on large fires would find tactical advantages because of the treatments and placement of treatment units. Suppression efforts would experience the following benefits for the next years: Line construction would proceed at a faster rate because less work would be required to construct an appropriate fuel break and fireline through light surface fuels. Aerial delivery of water or retardant would be more effective in cooling the fire because of lighter fuel loadings. Areas would have fewer danger trees that need to be felled for firefighter safety. The horizontal continuity of tree crowns would be reduced, so there would be less potential for crown fire runs that compromise the fireline and jeopardize personnel. Holding would be less complicated and more successful due to the reduced potential for spotting from torching trees and limited fuel concentrations. Water would be more effective in supporting holding efforts because of light fuels. Burnout operations would be lower risk due to reduced potential for spotting from torching trees and short residency time of fire in light fuels. Mop-up to secure the fire from escape would take less time due to short residency time of fire in light fuels. If a fire escapes initial attack efforts within the 2-Short area or a large fire moves into the area, fire suppression actions would be expected to be aggressive until the fire is no longer threatening high value sites. Many treatments are located along terrain features that are traditionally used in successful 7 For the 2-Short project, the Standard fire behavior fuel models: a comprehensive set for use with Rothermel s surface fire spread model developed by Scott and Burgan (2005) were be used to categorize surface fuels. These were used in conjunction with the BehavePlus (Andrews et al. 2008) fire modeling system. To provide a straightforward comparison between alternatives, constants are used as inputs for fuel moisture and air temperature that correlate to typical summer conditions when fire danger is very high. 36

41 suppression operations, which would reduce the potential for large fire growth and spread outside the area toward more populated community areas to the east. These treatments combined with those conducted a few years ago would also reduce threats to the regional power lines located on the south end of the project area. Keeping fire out of the BPA power line is s a high priority because of its national value for electricity transmission and it poses heightened risks to firefighters. There could be an increase in fire hazard during the short period of time between harvest operations and the treatment of surface fuels through prescribed burning or piling and burning (typically no longer than three years). In some units, the tops of trees would be removed when the trees are cut, which would minimize the amount of slash on the ground. Once surface fuels are treated, this temporary increase in fire hazard would be neutralized. Treatments to manage fuels and restore resilient stands are not one-time events because forest vegetation continues to grow. There are few studies evaluating the longevity of fuel treatments and their effectiveness at altering fire behavior over time. The longevity of fuel treatments varies with climate, soils, and other factors. The benefits of fuel reduction treatments likely last longer in areas where vegetation development is slower than in highly productive areas (Graham et al. 2004). Maintaining desired fuel conditions would require re-conducting some combination of fire or mechanical activities in the future. Lacking intermediate maintenance, the prescribed burn stands would likely need re-treatment in 10 to 30 years, intermediate harvested stands would likely need treatment in 20 to 50 years, and regeneration harvested stands would return in 70 to 100 years to conditions comparable to today. The analysis summarized above displays the effects of the project s treatments that are expected over the next years. Cumulative Effects The long-term trend of vegetation development in the area shows increasing amounts of fuel as biomass continues to accumulate at many times the removal rate. As described in the Vegetation section, insects and disease have killed and continue to kill trees within the project area. The resulting red-needled trees have high crown fire potential because the fine fuel is already dried out. After the needles fall, the crown fire potential is reduced. Within a few years, the trees start falling and generate heavy surface fuel loads. The understory develops due to increased light and moisture, increasing ladder fuels. Any large wildfires in the future will temporarily reduce biomass on areas burned, but any area not burned will continue to increase the already 100-plus years of growth and biomass accumulation. The project would alter this long-term trend within treated areas by reducing existing and potential fuel levels for several decades. The recently completed Shorty Gulch Hazardous Fuels Reduction project reduced fuel loads on about 600 acres of treated areas. However, since the project as designed was unable to be completed as described in Chapter 1, the strategic effectiveness of the project in reducing fuels over a larger area was compromised. In addition, approximately 1200 acres of prescribed burning was conducted in 2005 in both Brush and Valentine Gulches, located immediately west and east of Shorty Gulch, respectively. The prescribed burning reduced surface fuels within treated areas. When combined with these past fuel reduction treatments, the project would comprehensively reduce the potential for large fire growth and sustained high severity crown fire over a larger area. The combination of past and proposed vegetation treatments would provide defensible opportunities for initial attack fire resources to more quickly and safely contain a fire once it has started and before it reaches private land. 37

42 Forest Plan Consistency The project s activities would be consistent with the Lolo Forest Plan. Prescribed burning and other fuel treatments would occur within Forest Plan management areas that allow these activities. Prescribed fire objectives for smoke management would be met within the constraints established by the Montana State Airshed Group (Forest Plan standard 43, page II-17). 3.4 Soils Forest Service Soils Manual (FSM 2550; November 2010) and Region 1 Soil Quality Standards provide guidelines and methods to show compliance with the National Forest Management Act (NFMA). The objectives of the Region 1 Soil Quality Standards (R1 SQS) include managing NFS lands without permanent impairment of land productivity and to maintain or improve soil quality, similar to the NFMA. Region 1 Soil Quality Standards are based on the use of six physical and one biological attribute to assess current soil quality and project effects. These attributes include compaction, rutting, displacement, severely-burned soils, surface erosion, soil mass movement, and organic matter. The analysis standards address basic elements for the soil resource: (1) soil productivity (including soil loss, porosity; and organic matter), and (2) soil hydrologic function. The soil productivity direction identifies a value of 15 percent detrimental soil disturbance (DSD) as a guideline for maintenance or loss of soil productivity and to show compliance with the NFMA. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects to soil because no activities would occur. Indirectly, fuel loading (coarse woody debris) and organic matter would continue to build on the forest floor, creating increased risk for high burn severity in the event of fire. This may result in organic matter loss, soil nutrient loss, or soil erosion (in the short term; less than 10 years). Fire severity exceeding the historic range could have detrimental effects on soil productivity through the oxidation and loss of soil organic matter and associated soil biota as well as through accelerated rates of erosion (Harvey et al. 1987; Neary et al. 2008). Increased coarse woody debris and organic matter would also slow nutrient cycling associated with soil shading and a decrease in normal litter decomposition due to the soil priming effect 8 (Powers et al. 2004). Alternative 2: Direct and Indirect Effects Soil disturbance is an unavoidable consequence of forest management activities. Best Management Practices and standard operating procedures (described in Chapter 2, section and the Project File) would be applied to reduce disturbance and limit the effects of management activities on soil resources; however, it would not be possible to completely eliminate disturbance. Although recovery times for both physical soil properties (i.e. de-compaction and aggregate formation) and forest floor formation are long (20-40 years); the 2-Short project would retain the soil building processes within the treated areas. Recovery would occur over time as illustrated by Lolo National Forest soil monitoring studies (see Project File). Any new soil disturbance would not be substantial or cause a permanent impairment. 8 Soil priming effect is defined as a short-term change in the turnover of soil organic matter caused by treatments, usually addition of organic carbon to the soil. 38

43 Extensive research has been done on the effects of timber harvest on physical soil resources. In addition, the Lolo National Forest soil monitoring program also reviews the effects of timber harvest on soil quality and forest floor indicators (see Project File). One common theme through these studies is the interplay between the logging system, season of activity, and experience of the equipment operator in the amount and degree of soil disturbance that may occur. The susceptibility of soil to physical disturbance, compaction, displacement, rutting, or puddling is a function of soil rock content, soil texture, original bulk density, soil moisture, soil protections (frozen or snow covered ground), and soil organic matter (Page-Dumroese et al. 2006b). Equipment operations expose the soil to physical disturbance related to machine operator techniques, number of passes, type of machine applying the load, and amount of slash on the site. Most research has found that detrimental soil compaction and displacement is associated with landings, temporary roads, and main skid trails, especially near landings. It is important to note that much of the published literature uses the broad term soil disturbance. Most of this research does not define the level of soil disturbance making it difficult to equate soil disturbance cited in literature to the Region 1 Soil Quality Standards. A joint British Columbia Ministry of Forests/USDA Forest Service team of Soil Scientists emphasize that not all soil disturbance is detrimental (Curran et al. 2007). Soil disturbance may change the physical, chemical, or biological properties of the soil with no consequences to soil or site productivity. Soil Productivity Soil productivity is defined as the inherent capacity of the soil resource, including the physical, chemical, and biological components, to support resource management objectives. It includes the growth of specific plants, plant communities, or a sequence of plant communities (USDA 2010). The project would maintain soil productivity and comply with Region 1 soil quality standards (USDA Forest Service 1999) because soil properties necessary for resiliency and recovery would be left intact after management actions are complete; the project would preserve soil productivity on greater than 85 percent of an activity unit. Soil biological properties (forest floor, organic matter, and ground cover) and hydrologic function would be maintained on all but the larger log landings and heavily used skid trails. Physical soil disturbance and activity footprints would be limited through implementation of standard operating procedures and site-specific resource protection measures (Chapter 2). Chemical processes would be supported because nutrient replenishment, forest floor, coarse woody debris, and humus stores would remain on site (Busse et al. 2009, Fleming et al. 2006, Laiho and Prescott 1999). The project would not result in changes to soil resiliency or recovery potential. Powers (2002) concludes soil productivity should be preserved if the loss of biomass, organic matter, soil porosity and topsoil is limited. A 2016 study on timber harvest and fuel treatments in western Montana found that when standard operating procedures and BMPs are followed, these activities can result in subtle positive long-term effects for soil health and productivity (Ganzlin et al. 2016). Soil productivity and the processes that lead to soil productivity would be maintained within each vegetation treatment area and across the landscape. Harvest activities would avoid detrimental soil impacts on more than 15 percent of the activity area. Although all harvest units would meet Region 1 soil quality standards following implementation, the project would result in approximately 41 acres (about 6 percent of the proposed harvest acres and less than 1 percent of the NFS land in the 2-Short project area) of DSD. Detrimental soil disturbance would occur within the larger landings, in primary skid trails, and at skid trail or skyline corridor convergence. However, this soil disturbance is not considered substantial or a permanent impairment. 39

44 Soil productivity would be maintained since project-related soil disturbance would dissipate with time and DSD would remain below thresholds where long-term impairment may occur. Refer to Appendix C and the Soil report in the Project File for detailed soil effects by treatment unit. Tractor Harvest Units The project would include approximately 40 acres of tractor harvest units. Soil disturbance is typically associated with landings and wheel tracks within the main skid trails where bare soil is expected. Potential impacts from dry season harvest would be minimized by utilizing completely dry conditions when soil strength is at a maximum (NCASI 2004; Page-Dumroese et al. 2010), restricting equipment to slopes of less than 35 percent, and restricting equipment to areas where a robust root-tight layer is present to resist equipment abrasion. To offset the loss of forest floor within these areas, slash placement would be used to protect any exposed bare mineral soil against soil sealing and erosion, and to moderate soil temperatures and increase soil moisture for vegetation re-establishment. Lolo Forest Plan soil monitoring between 2006 and 2015 found that operational controls and soil moisture are key components for achieving soil objectives within harvest units. In addition, this monitoring illustrates that soil disturbance decreases over time. Most harvest units, even groundbased harvest units, meet Region 1 soil quality standards within 5 years after implementation as a result of revegetation, natural decompaction from freeze thaw cycling, and natural soil recovery processes and forest floor building. Published research reports that soil disturbance is typically found in less than 15 percent of the activity unit (Page-Dumroese et al. 2000; McIver and Starr 2000; Clayton 1990; Klock 1975). Disturbance would be generally limited to main skid trails and landings due to increased traffic. Skyline and Excaline Harvest Units The project would include approximately 687 acres of skyline and excaline harvest units. Minimum soil disturbance would occur with hand-felling and hand-processing of logs on the slope. Soil disturbance occurs when moving trees to and within the corridor. Skyline corridors are narrower than skid trails with an average spacing of about 75 feet. Skyline logging soil disturbance may be greatest at the landing where logs are no longer suspended and corridors converge. Ground cover in skyline corridors would be reduced by approximately 5-10 percent as a result of yarding logs (Clayton 1990; Klock 1975). In many cases, the displaced ground cover along the corridor occurs in small patches. These small areas (less than 100 square feet) are not considered detrimental displacement. Ground cover reduction would only occur along the corridor where log suspension is limited and numerous yarding passes occur. These effects would be minimized by ensuring good suspension of the log and avoiding wet soil conditions. In addition, standard operating procedures, which include constructing waterbars in skyline corridors where needed and covering bare soil with slash, would prevent erosion. During the field season of , monitoring occurred on six recently completed skyline units on the Lolo National Forest. Detrimental soil disturbance from skyline harvesting ranged from 0-8 percent with an average of 2 percent (USDA Forest Service 2010). Monitoring found mitigation measures employed in the corridors were effective at limiting offsite erosion. Across Region 1 (Montana and northern Idaho), soils monitoring data indicates that skyline logging systems result in significantly lower DSD than ground-based systems, at 1.9 and 8.2 percent, respectively (Reeves et al. 2011). Loss of organic matter and groundcover was minimal. 40

45 Log Landings Landings would be associated with most harvest units. Landings would generally be located on flat areas away from streams and outside or on the edge of the cutting units. Where existing landings are re-used, additional disturbance would not occur or would be minimal. Detrimental effects from landing construction could include soil compaction, litter loss, loss of coarse woody debris, increased potential for erosion, nutrient loss, loss of soil hydrologic and biologic function, and possible weed incursions. Unit-specific DSD from landings is included in the acres of soil disturbance expected from project activities calculated for ground-based units (see Appendix C). Log landings associated with tractor harvest units would generally be less than ½ acre in size. Erosion control measures would be used if needed to avoid erosion and sediment transport from landing sites during maintenance and construction. All landings would be rehabilitated. Rehabilitation measures including scarification, seeding, and slash placement would encourage expedited soil function recovery and reduced erosion potential. Specified Road Construction The continued use of system roads would not further impair the soil resource since this land has already been dedicated to the forest transportation system and is not considered as part of the productive forest landscape. The project would construct approximately 4.3 miles of long-term specified road to provide access to vegetation treatment areas. These roads would be constructed through soil types that are well-suited to road locations with proper engineering, construction, and maintenance (USDA Forest Service Land Systems Inventory 1988; field reviews in Project File). New roads would be engineered considering hydrologic function and road bed stability. Best management practices would be applied to all new road construction. These areas would be dedicated to the Forest transportation system. Road Decommissioning The project would decommission approximately 0.5 miles through slope recontouring and 2.1 miles through road surface ripping, placement of woody debris, removal of structures, reshaping of stream crossings, installation of water bars, and seeding of the road prism. Although there would be soil disturbance and an elevated risk of soil erosion in the short-term; re-establishing the soil gas and hydrologic exchange and soil biotic processes would expedite soil productivity recovery (Lloyd et al. 2013; Lolo National Forest soil monitoring reports). Soil Erosion and Geologic Risk The project would apply Best Management Practices to reduce bare surface soil, erosion, and off-site movement of soil material. No soil erosion is expected from harvest treatment areas because standard operating procedures (including Best Management Practices) and site-specific resource protection measures would be applied to minimize operational footprints, and maintain the forest floor, groundcover, and soil organic matter. Bare surface soil and loss of ground cover may occur in large landings and within the main skid trails and skyline corridors. The project would not alter landslide or mass movement risk, which is currently low. Intermediate harvest units would retain fully stocked stands and regeneration harvest units would be planted. Adequate root strength would remain to bind the soil. Prescribed fire does not generally result in intense heating of the soil and complete consumption of organic soil horizons except in isolated areas of high fuel loading. The probability of these small areas of disturbance altering slope stability is low. Mature trees are typically not affected during prescribed burning; the rooting systems would remain intact to provide hillslope stability. 41

46 Cumulative Effects For activities to be considered cumulative, their effects need to overlap in both time and space with those of the proposed actions. The appropriate geographic area for soil cumulative effects analysis has been defined as the land affected by management activity (USDA Forest Service 1999). This is because soil productivity is a site-specific attribute of the land. The productivity of one area of soil is not dependent on the productivity of another area whether that area is adjacent or not. Similarly, if one acre of land receives soil impacts from management activities and a second management activity that may affect soils is planned for that same site, then soil cumulative effects are possible on that site. Thus, cumulative effects to soil productivity are appropriately evaluated on a site-specific basis. A larger geographic area such as a watershed or project area is not considered an appropriate geographic area for soil cumulative effects analysis. This is because assessment of soil quality within too large an area can mask or dilute site-specific effects (Nesser 2001). Thus, cumulative effects to soils are evaluated for site-specific activity areas (i.e. proposed vegetation treatment units), not for the entire watershed or project area. As discussed above, the post-project detrimental soil conditions for all vegetation treatment units would be below 15 percent within each activity area and meet Region 1 soil quality standards (see Appendix C). This assessment of post-project soil conditions reflects the cumulative effects to soils because it considers existing soil conditions resulting from any previous management or natural events that affected the soil as well as the direct and indirect effects of this project s activities. There are no reasonably foreseeable future actions that overlap the activity areas; therefore there would be no additional cumulative effects than what is previously described above. Consistency with the Forest Plan and Other Direction The project is consistent with the Lolo Forest Plan, National Forest Management Act, and Forest Service directives. The project is consistent with the goals, objectives, and standards for soil resources set forth in the Lolo Forest Plan because project design criteria and Best Management Practices have been included to protect soil resources and limit the disturbance footprint; landscapes with sensitive soils would be protected; and land productivity would be maintained (Forest-wide standard 18, Forest Plan, page II-12). Large wood levels have been considered as found in the Lolo National Forest Down Woody Material Guide (2006) and Graham et al A soil scientist has been involved in project planning and would be involved with the project through implementation by coordinating with other team members including silviculture and timber specialists to ensure the maintenance and enhancement of soil resources. Forest Service Manual establishes guidelines that limit DSD to no more than 15 percent of an activity area. All units would meet Region 1 soil quality standards following project implementation; this assessment is based on a consistency review completed for each unit that included harvest methods, landings, unit access, and remediation (see Appendix C). The National Forest Management Act (NFMA) requires that all lands be managed to ensure maintenance of long-term soil productivity, hydrologic function, and ecosystem health. All proposed activities are consistent with this direction; proposed activities would not result in irreversible damage to the soil resource as described above. 42

47 3.5 Aquatics Issue Raised in Public Comment Timber harvest and road-related activities could degrade water quality and aquatic habitat in project area streams as well as in Prospect Creek. The 2-Short project area contains two primary drainages, Shorty Gulch and Valentine Gulch, which are tributary to Prospect Creek. Activities would also occur within the Brush, Foster, Prospect Creek face, and Clear Creek subwatersheds. Because all streams in the project area go subsurface for much of the year, there is limited seasonal surface connectivity between these streams and Prospect Creek. There are short segments in the middle reaches of Shorty Gulch and Valentine Gulch, that likely flow perennially (yearlong), but the upper and lower reaches are intermittent, generally flowing only during spring runoff. Stream channel intermittency in the project area is likely naturally occurring. Sando and Blasch (2015) studied stream intermittency in several stream channels in the lower Clark Fork drainage from Thompson Falls north through the Noxon Reservoir area. They found that the main predictors of stream channel intermittency were snowpack persistence, mean annual mean monthly minimum temperature, and surface geology types. The surface geology type being coarse, unconsolidated metasedimentary material creates a much lower base water table. During field observations, there were no sighting of fish in Shorty Gulch; however, the lower reach may support native species (westslope cutthroat trout 9 ) and non-native species (brown trout, brook trout, and rainbow trout) for short periods during the spring. Given the small size of Shorty Gulch and limited stream flows, fish are likely only using the area as short-term refugia during spring high flows. Upstream of this area, no fish have been observed. The channel rapidly decreases in bankfull width to about 1-4 feet and further upstream, gradients are too steep to support fish. Near the mouth of Shorty Gulch there is a perennial wetland, which is seasonally connected to Shorty Gulch and perennially connected to wetlands adjacent to Prospect Creek via a culvert under the highway. Montana Department of Fish, Wildlife and Parks indicate that there is likely a year-round resident population of westslope cutthroat trout that inhabit the perennial reach of Valentine Gulch based on professional judgement (MFISH 2005). Further upstream, gradients are generally too steep to support fish. Activities proposed in Valentine Gulch would have no effects to water resources including fish and fish habitat. Activities are generally located near ridgetops where there is no connection to waterways. Therefore, this drainage will not be discussed further. Brush Gulch, located to the west of the project area where only road use for timber haul would occur for this project, contains westslope cutthroat trout likely only in the spring (sampling conducted by Montana Department of Fish Wildlife, and Parks, MFISH 2017). This drainage is intermittent, and connectivity between Brush Gulch and Prospect Creek is limited. Culverts on the highway prohibit upstream passage. Although the project boundary also encompasses a small portion of Clear Creek, Foster Gulch, and Prospect Creek face drainages, activities proposed in these drainages would have no effects to water 9 Westslope cutthroat trout is a designated Forest Service, Region 1 sensitive species, which indicates viability of the species is a concern. 43

48 including fish and fish habitat. Activities are generally located near ridgetops where there is no connection to waterways. Therefore, these drainages will not be discussed further. Prospect Creek is listed by the State as water quality impaired due to sediment and alteration of streamside vegetation. The Montana of Department of Environmental Quality (DEQ) developed a Total Maximum Daily Load (TMDL 10 ) Plan for sediment (2009) in Prospect Creek. This TMDL Plan does not provide any specific information or recommendation for streams within the 2-Short project area. There is limited connectivity between Prospect Creek and project area streams. Prospect Creek, downstream of the project area, is used as a migratory corridor for bull trout 11 and is designated bull trout critical habitat 12. However, this species is not present within the 2-Short project area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would maintain the existing condition. There would be no direct effects to water quality because no activities would occur. The limited fish habitat and populations in the project area would likely remain near their existing conditions. The relocation of Road #7605 out of the wetland at the bottom of Shorty Gulch will improve wetlands and aquatic habitat associated with both Shorty Gulch and Prospect Creek. Although road maintenance would continue to occur on system roads, the lower segment of Road #18884 and Road #7605 where it is adjacent to the stream would continue to pose an erosion and sediment delivery risks to Shorty Gulch. Alternative 2: Direct and Indirect Effects The aquatic analysis focuses on Shorty Gulch and Brush Gulch because this is where potential effects to water resources could occur. As discussed below, there would be no adverse downstream effects to Prospect Creek. The project includes resource protection measures (see Chapter 2) to minimize or avoid potential short-term effects of project activities to water resources. The project would not create permanent or long-term unnatural stress on project area streams. It would not affect stream temperature or measurably affect water yield. Fine sediment potentially generated from road maintenance and haul would be of relatively short duration generally occurring during spring runoff over a 3-5 year period and not continuous in nature. The magnitude of projectrelated short-term sediment delivery would be low compared to existing conditions. The intensity of the sediment effects would also be low based on the relatively small amounts of sediment delivered where they would occur and the limited timing of potential delivery. Thus, the sediment generated from the implementation of project activities would not adversely affect stream stability, substrates, or channel structure (Megahan and King 2004). 10 A TMDL is the maximum amount of a particular pollutant that a water body can assimilate without causing applicable water quality standards to be exceeded. 11 Bull trout is listed as threatened under the Endangered Species Act 12 Critical habitat is defined in the Endangered Species Act as a specific geographic area(s) that contain features essential for the conservation of a threatened or endangered species and that may require special management and protection. 44

49 Temperature Stream temperature is heavily influenced by solar radiation as a primary influence (Johnson 2004; Caissie 2006). Shade from overhead riparian canopy is the most effective variable to reduce radiant heat sources (Krauskopf et al. 2010). The project would not affect stream temperature. Riparian and streamside areas would be buffered to protect riparian habitat conservation areas (RHCAs) 13 and no vegetation removal would occur in these areas (see Resource Protection Measures in Chapter 2). Water Yield Forest canopy intercepts precipitation and affects snow accumulation and melt, sublimation, evapotranspiration, and temperature moderation (Lewis and Huggard 2010). Any activity or natural event that alters the forest canopy has the potential to affect snow accumulation and ablation and subsequent stream runoff timing and magnitude (Grant et al. 2008). When stream flows are higher than those in which the stream evolved for long durations, stream channels may be altered. This creates the potential for bank scour, erosion, and subsequent increases in bedload deposition. Inchannel surveys conducted within the 2-Short project area do not indicate negative stream channel alterations from management-induced water yield. The project would not measurably affect water yield. The projected reduced forest canopy conditions resulting from the project combined with the existing condition would be below the thresholds that current research indicates would result in detrimental changes in water yield (see Hydrology report for more information). Sediment Vegetation Treatments The vegetation treatments would have no measurable effect to water resources because activities would occur outside of RHCAs (see Resource Protection Measures in Chapter 2) at distances with little to no probability of sediment delivery (Litchert and MacDonald 2009). These RHCAs were designed to protect critical riparian values, and existing and future fish habitat (USDA FS 1995). In addition, forestry best management practices would be applied to minimize ground disturbance and soil erosion, which are effective in controlling sediment generation and delivery to streams (Litchert and MacDonald 2009). Road Construction Road encroachment or proximity to water bodies is an indicator of a road s potential to deliver sediment. Roads within 300 feet of a water body are the most likely to deliver sediment (Belt et al. 1992). Monitoring conducted within a research area found that roads within 10 meters (33 feet) of streams delivered 74 percent of the road-related sediment (Cissel et al. 2013). New road construction would have no measurable effect to water resources including fish and fish habitat because of its location and use of modern construction standards. New roads would not cross any streams and construction would occur only in dry weather periods during the summer or fall (see 13 Riparian Habitat Conservation Areas (RHCAs) include traditional riparian corridors, wetlands, intermittent streams and other areas that help maintain the integrity of aquatic ecosystems by influencing the delivery of coarse sediment, organic matter, and woody debris to streams; providing root strength for channel stability; shading the stream; and protecting water quality (Naiman et al. 1992). 45

50 Resource Protection Measures in Chapter 2). Of the 4.3 miles of new road construction, approximately 0.6 miles would be within 300 feet of an ephemeral stream, which only carries water during short periods such as from snow melt or after intense rain events. This road segment (Road 18494ext) is located within the upper reach of Shorty Gulch where there are no fish present due to the steep stream gradient and lack of water. Best management practices would be applied in design and construction, which would minimize the potential for sediment delivery to the point that any effects to water resources would be discountable. If any sediment from the road construction were to be delivered to the ephemeral stream, it is highly unlikely it would reach downstream fish bearing areas. Road Decommissioning Approximately 2.6 miles of road would be physically decommissioned. The lower ½ mile of Road #18884 would be fully recontoured to reduce existing water quality impacts to Shorty Gulch and potential downstream effects to fisheries and aquatic habitat. Although decommissioning activities on this road may temporarily yield additional sediment to Shorty Gulch during the first year, the quantity would be low due to implementation during dry weather periods, lack of water in the unnamed draw where the road is located, and application of best management practices. Once the activity is completed, sediment delivery potential would be reduced below existing conditions. Several researchers have found similar results with short-term sediment pulses and long-term chronic sediment decreases from road decommissioning near streams (Hickenbottom 2001; Madej 2001; Switalski et al. 2004). Road Maintenance and Use The Shorty Gulch road (#7605) is in close proximity to Shorty Gulch for much of its length, and there are multiple locations where the road encroaches on the intermittent stream channel. Because sediment delivery from this road could be exacerbated by log haul, heavy maintenance would be conducted prior to haul to address identified drainage issues and reduce the potential for sediment contribution. Improving and maintaining drainage is an effective way to reduce road-related sediment production (Coe 2006; MacDonald and Coe 2008; USEPA 2005; NCASI 2012). Road drainage structures are used to disconnect road segments from the stream channel network (Coe 2006). Drainage structures installed at appropriate intervals remove storm water from the roadbed before the flow gains enough volume and velocity to erode the surface. Appropriately spaced structures also reduce the downslope transport distance of material off the road surface (Coe 2006, Luce and Black 1999). The proper placement of structures routes the discharge onto the forest floor so that water disperses and infiltrates before reaching a stream (Croke and Hairsine 2006, Woods et al. 2006, Sugden and Woods 2007, Packer 1967). Prior to haul, maintenance activities would ensure that all haul routes would meet BMP standards. Road maintenance and haul activities in proximity to streams could temporarily increase the potential for fine sediment delivery into Brush and Shorty Gulches to a relatively small degree compared to background loads. Project road-related activities would primarily occur during the summer and fall when area streams are dry. Therefore, the time when potential sediment yield from project activities would most likely enter live water would be in the late spring/early summer during spring runoff or after intense rain events in the summer or fall. At these times, water flows are generally high, which typically increases the fine sediment transport capability. Project-related sediment delivery could cause a short-term increase in turbidity immediately downstream of delivery points as fine sediment is entrained in the water column, which may temporarily cause fish to move to adjacent habitat (e.g. across the stream channel) as they avoid areas of increased turbidity. While temporary displacement of fish may occur, no physical harm or impact to normal behavioral patterns (e.g. feeding, spawning, or sheltering) is expected. Because the relatively low quantity of sediment potentially generated from 46

51 road-related activities would be flushed through the system during high flows, the project would not impact habitat in fish-bearing streams within or downstream of the project area. It is highly unlikely that project-generated sediment would reach Prospect Creek because of the intermittency of project area streams and the wetland located near the mouth of Shorty Gulch. Wetlands tend to filter sediment because the water velocity is low allowing fine particles settle out. The only time project-generated sediment could potentially reach Prospect Creek would be during spring runoff when stream flow is very high. If delivered, a small amount of project-generated sediment compared to background loads would be diluted by high water volumes and the potential increase over seasonally high natural sediment levels would be immeasurable and inconsequential. Therefore, the project would have no adverse effects to water quality, fish, or aquatic habitat in Prospect Creek. Once the project is completed, road-related sediment within Shorty and Brush Gulches would be reduced below existing conditions due to the decommissioning of the problematic segment of Road #18884 and improvements made to area roads, particularly the Shorty Gulch Road (#7605). Cumulative Effects There would be no additive effects from the Shorty Gulch Fuels Reduction project that was completed a few years ago because there are no ongoing effects to fisheries or water quality that would overlap with the 2-Short project. Under that project, BMPs were applied to roads in Brush Gulch prior to haul which minimized the potential for sediment delivery during project implementation. The relocation of Road #7605 out of the wetland at the bottom of Shorty Gulch prior to project implementation will improve wetland and aquatic habitat associated with Shorty Gulch and Prospect Creek. Although a short-term release of sediment from removal of the culverts and road could occur, the long-term benefits of moving the road out of the wetland and stream will result in improved water quality and aquatic habitat in Shorty Gulch and downstream of this site for approximately 0.5 miles. The short-term increase in sediment from this activity will occur prior to the 2-Short project and potential sediment effects of the two projects would not overlap in time. In the long-term both projects would improve watershed conditions by remedying existing road-related impacts on water resources. Biological Determination of Effects on Sensitive and Listed Species The project would not affect the viability of westslope cutthroat trout or result in a trend toward Federal listing of this species under the Endangered Species Act for the reasons stated above. The project would have no effect on bull trout because this species is not present in project area streams. In relation to background sediment levels, project-generated sediment quantities would be very low. As described above, if in the unlikely event, project-related sediment was delivered to Prospect Creek (a migratory corridor for bull trout), the quantity would be very low and so diluted and inconsequential that there would be no effects to the species or designated critical habitat. When the U.S. Fish and Wildlife Service designated critical habitat for bull trout, they identified nine primary constituent elements (PCEs 14 ) as essential for the conservation of bull trout and may require special 14 Primary constituent elements (PCEs) are physical or biological features essential to the conservation of a species for which its designated or proposed critical habitat is based on, such as space for individual and population growth, and for normal behavior; food, water, air, light, mineral, or other nutritional or physiological requirements; cover or shelter, sites for breeding, reproduction, rearing of offspring, germination of seed 47

52 management considerations (75 FR October 18, 2010). The project would have no effect to these PCEs in Prospect Creek because of the creek s limited surface connectivity with project area streams; there would be no measurable increase in water yield; Prospect Creek downstream of the project area is a migratory corridor and does not contain spawning or rearing habitat; and the potential to deliver the small amount of project-related sediment to Prospect Creek is very low. Since the only time project-generated sediment could potentially be delivered to Prospect Creek would be during flushing high spring flows, deposition within this water body would be extremely unlikely. Regulatory and Forest Plan Consistency The project is consistent with the Lolo Forest Plan. Best management practices have been incorporated into the project and would be applied to assure that water quality is maintained at a level that is adequate for the protection and use of the National Forest and that meets or exceeds Federal and State standards. (Forest-wide standard 15, Forest Plan, page II-12) Project-related increases in water yield would be immeasurable so channel damage would not occur as a result of land management activities (Forest-wide standard 19, Forest Plan, page II-12) The project is consistent with Endangered Species Act recovery goals. The project was designed to be compatible with the habitat needs of bull trout in Prospect Creek through resource protection measures, best management practices, and project design. (Forest-wide standard 24, Forest Plan, pages II-13 to 14) The project was designed to have minimum impacts on the aquatic ecosystem and would not cause permanent or long-term unnatural stress. (Forest-wide standard 28, Forest Plan, page II-14) o Aquatic insect density or diversity are not expected to change because the relatively small amount of sediment delivered during project implementation would most likely occur during periods of high runoff that correspond to high stream flows, which would quickly dilute the sediment. If any impacts to macroinvertebrates were to occur, they would likely be indistinguishable from natural fluctuations in population (McElravy et al. l989; Gravelle et al. 2009). o o o Fish populations would not be reduced. It is unlikely that intragravel sediment accumulations would be affected due to the stream types, the relatively short duration of the activities, and low magnitude, timing, and intensity of the project-generated sediment. Channel structure would not be adversely affected because there would be no measurable change to water yield. The relatively small quantity of fine sediment generated by roadrelated activities would not cause aggradation or changes to channel morphology (Megahan and King 2004). The project is consistent with the Inland Native Fish Strategy (amended to the Forest Plan in 1995) requirements and direction (see Fisheries report in the Project File for more detailed information). dispersal; and habitats that are protected from disturbance or are representative of the species historic geographic and ecological distribution. 48

53 Prospect Creek Watershed Sediment TMDL (2009) As described above, the project would not adversely affect water quality in Prospect Creek. Following project implementation, road-related sediment delivery in Shorty Gulch would be reduced below existing conditions. Addressing problematic road segments, as is the case with the 2-Short project, is consistent with general recommendations listed in the Prospect Creek Watershed Sediment TMDL and Framework for Water Quality Restoration plan. 3.6 Wildlife The Lolo National Forest provides habitat for many different species of wildlife, several of which occur within the 2-Short project area. The presence or absence of these species depends on the amount, distribution, and quality of each animal s preferred habitat. Some of these species are affected by hunting or trapping, which is regulated by Montana Fish, Wildlife and Parks. This analysis focuses on species listed as federally threatened or endangered on the Lolo National Forest (USDI- FWS 2016) and Forest Service sensitive species (USDA-FS 2013). The table below provides a list of species, preferred habitat, whether the habitat or species are present in the project area, and whether detailed analysis was conducted for that species. If a species or their habitat does not occur within the project area, no further analysis was conducted. Management Indicator Species (MIS) 15 including elk, northern goshawk, and pileated woodpecker are addressed to determine project compliance with Lolo Forest Plan standards and management area direction (USDA-FS 1986). Table 3.6-1: Wildlife Species Considered in the 2-Short Analysis Status on Species Present in Species Preferred Habitats Forest Analysis Area Grizzly Bear Canada Lynx Threatened Threatened Alpine/subalpine coniferous forest, lower elevation riparian areas in spring, lack of human disturbance. Subalpine fir habitat types (including cover types with pure or mixed subalpine fir, lodgepole pine, Douglasfir, grand fir, western larch, and hardwoods) above 4,000 feet in elevation, vertical structural diversity in the understory (down logs, seedling/saplings, shrubs, forbs) for foraging and denning No observations. Species is likely absent. No observations within project area, although there were historic observations within 10 miles of the project area. Habitat Present in Analysis Area Yes, habitat is present. Project area is outside the Cabinet-Yaak Grizzly Recovery Zone; is not within the current, mapped occupied distribution area for grizzly bears No suitable habitat is present. Project area contains dry ponderosa pine/douglas-fir forest types that do not provide lynx habitat (Squires et al. 2010; Koehler et al. 2008; Maletzke et al. 2008) 15 Management Indicator Species are species identified in the Lolo Forest Plan that are used to monitor the effects of planned management activities on viable populations of wildlife or fish including those that are socially or economically important (Lolo Forest Plan, page VII-15). 49

54 Species Yellow-billed Cuckoo Wolverine Gray Wolf Fisher Northern Bog Lemming Townsend s Big-Eared Bat Peregrine Falcon Bald Eagle Black-backed Woodpecker Common loon Status on Forest Threatened Proposed Sensitive Sensitive Sensitive Sensitive Sensitive Sensitive Sensitive Sensitive Preferred Habitats Riparian willow-cottonwood forests along low-gradient rivers and streams, and in open riverine valleys that provide wide floodplain conditions (greater than 325 feet). The optimal size of habitat patches are generally greater than 200 acres in extent and have dense canopy closure and high foliage volumes of willows and cottonwoods. (79 FR 48551) High elevations centered near the tree line in coniferous forests, rock alpine habitat above tree line, cirque basins, and avalanche chutes that have food sources. Deep, persistent, and reliable spring snow cover (to mid-may) is the best predictor of wolverine occurrence. Habitat generalists. Moist mixed coniferous forested types (including mature and old-growth spruce/fir forests at low- to midelevations), riparian/forest ecotones. Wet riparian sedge meadows, bog fens with extensive sphagnum moss mats. Roosts in caves, mines, rocks and buildings. Snag roosting habitat also important. Forages over tree canopy, wet meadows, riparian areas and open water. Cliff nesting (ledges); riparian foraging (small bird species prey). Nesting platforms near a large open water bodies (greater than 80 acres) or major river system; available fish and water bird species prey, secure nesting habitat. Burned forests or less typically, coniferous forests with high insect infestations (i.e. bark beetles) Lake habitat. Secure nesting and brood rearing areas. Species Present in Analysis Area No records of species presence in Sanders County No observations within or near the project area. No observations within project area, but species observed in Prospect Creek. No observations have been recorded in the project area. Snow tracking and bait station surveys did not detect the species within or in close proximity to project area. Species not present. Species not present. Species not present. Past surveys have not detected eagle nests along the Prospect Creek. Species not detected. Species not present. Habitat Present in Analysis Area No. Dropped from further review. No suitable habitat present. Yes, suitable habitat present. No. Dropped from further review. No. Dropped from further review. No. Dropped from further review. No. Dropped from further review. No. Dropped from further review. No. Dropped from further review. No. Dropped from further review. 50

55 Species Flammulated Owl Harlequin Duck Coeur d'alene Salamander Status on Forest Sensitive Sensitive Sensitive Preferred Habitats Mature (greater than 9 inches diameter breast height (dbh)) and old-growth ponderosa pine with abundant moth species prey. Secure nesting habitat (greater than 35% canopy cover). During the breeding season, found near large, fast flowing mountain streams. Wet, fractured, moss-covered rock, waterfalls Species Present in Analysis Area Species detected within project area. Species not present. Species not present. Habitat Present in Analysis Area Yes, suitable habitat present. No. Dropped from further review. No. Dropped from further review. Northern Leopard Frog Boreal Toad Bighorn Sheep Northern Goshawk Pileated Woodpecker Elk Sensitive Sensitive Sensitive MIS MIS MIS Typically in or adjacent to permanent slow moving or standing water bodies with considerable vegetation Variable including; wetlands, forests, woodlands, sagebrush, meadows and floodplains. Overwinters in caverns or Species not present. No toads detected within project area No. Dropped from further review. Yes, suitable habitat present. rodent burrows Inhabits steep, rocky open slopes Species not present No. Dropped from further review. West of Continental Divide: Stands with mean diameter of greater than 10 inches, crown closures of at least 40% and elevations below 6,200 feet. Foraging habitat is variable but typically in mature stands with dense canopies fairly open understories Moderately warm, dry Douglasfir/ponderosa pine; moderately cool, dry Douglas-fir; moist mid-elevation spruce/grand fir. Large, soft snags (greater than 21 inches diameter breast height). Habitat generalists, secure habitat during the hunting season, secure winter range. Observations within and adjacent to the project area in 1997, 2005, and No nests found. Yes, species present Yes, species present Yes, suitable habitat present. Yes, suitable habitat present. Yes, suitable habitat present Threatened Species The Endangered Species Act (ESA, PL , as amended) regulates threatened and endangered species management. Under ESA, the Forest Service shall carry out recovery programs developed by the U.S. Fish and Wildlife Service (USFWS) and must prepare a biological assessment for any action that is likely to affect a listed species or its habitat (16 USC 1536(c)). Forest Plan standard 24 (page II-13) states that all threatened and endangered species will be managed for recovery. Standard 27 (page II-14) states that management practices in essential habitat for threatened and endangered species must be compatible with the species needs. Management guidelines for project-level planning for threatened and endangered species are outlined in species-specific recovery plans and/or conservation strategies (i.e. USDI-FWS 1986, 1987, 1993; USDA-FS 2001, 2007). 51

56 In accordance with Section 7(c) of ESA, the U.S. Fish and Wildlife Service determined that the following listed threatened wildlife species may be present on the Lolo National Forest: Canada lynx and grizzly bear. There is no designated critical habitat for either species within the project area. Grizzly Bear The grizzly bear was listed as threatened under the Endangered Species Act in The Lolo National Forest encompasses portions of three grizzly bear recovery areas, the Northern Continental Divide, Cabinet-Yaak, and Bitterroot. The 2-Short project area is not located within a grizzly bear recovery area; the current mapped occupied distribution area for grizzly bears; or an identified linkage area between recovery areas (Servheen et al. 2001). The Mount Headley Bear Management Unit (#22) of the Cabinet-Yaak Grizzly Bear Recovery Zone is the nearest to the 2-Short project area. It is located about 6 miles away across the Clark Fork River, Highway 200, and a main railway. In addition, residential development lies between Bear Management Unit #22 and the 2-Short area. The project area is not within or adjacent to an area identified as a recurrent use area by grizzly bears (Allen 2001), also referred to as BORZ (bears outside recover zones). The 2-Short project area does not meet the guidelines used to delineate BORZ (ibid.), which include: Evidence of multiple bears, with females and cubs given high priority Multiple years of bear use (typically at least three observations since 1994). Radio collar documentation is given a high priority. Additional information such as credible sightings, captures, and mortality sites are also taken into consideration. There are no recorded or anecdotal observations of grizzly bears within the project area. The Forest Service, U.S. Fish and Wildlife Service, Montana Department of Fish, Wildlife, and Parks, and U.S. Geological Survey (USGS), along with many other cooperators, have been surveying for grizzly bears within and around the Cabinet-Yaak Grizzly Bear Recovery Zone. The USFWS office in Libby Montana is trapping, radio-marking, and following radio-collared bears where they travel. Surveys indicate no bears have moved into the 2-Short area. The USFWS is also collecting all grizzly bear observations known from within or surrounding the Cabinet-Yaak Recovery Zone. Forest Service wildlife biologists, technicians, and other Forest personnel working within and adjacent to the project area over the last several years have not observed grizzly bears or sign of grizzly bears (e.g. scat or tracks). The 2012 USGS-led study to determine the grizzly population of the Cabinet-Yaak ecosystem did not include the 2-Short or adjacent areas because there was no evidence or even a suspicion that bears occupied the area. Therefore, recent efforts to define where bears are present on the landscape have not indicated there are grizzly bears in the 2-Short or surrounding drainages south of the Clark Fork River. Grizzly bears are opportunistic omnivores (Schwartz et al. 2003) and feed on an array of animals and plants. Their opportunistic selection of food items has permitted bears to occupy a great variety of vegetation types in North America (Herrero 1972). In Montana, grizzly bears use meadows, seeps, riparian zones, mixed shrub fields, closed timber, open timber, snow chutes, and alpine habitats. Habitat use is highly variable between areas, seasons, local populations, and individuals (Servheen 1983, Craighead and Mitchell 1982, Aune et al. 1984). The 2-Short project area would likely provide suitable foraging habitat for grizzly bears particularly during the spring. 52

57 Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on grizzly bears or their habitat because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects The project would have no direct, indirect, or cumulative effects on grizzly bears because: The species is not present. Grizzly bears have not been observed within or near the project area (see discussion above). None of the proposed activities would preclude grizzly bear use or movement within the area. o o Vegetation treatments would maintain a mosaic of forested cover. Harvest treatments would increase grass/forb/shrub production (Zager et al. 1983; Kerns et al. 2004) and maintain forested connectivity that may provide a bear moving through the area with foraging opportunities and cover. Studies indicate that grizzly bears in Montana do well in areas with a diversity of habitat types, including those with cover and those without (Servheen 1983, Mace et al. 1997, Waller and Mace 1997). Grizzly foraging behavior is typically associated with more open habitats, but bears generally forage in areas with some type of hiding cover nearby, especially during the day (ibid.). Open road density would essentially remain the same; therefore existing security would be maintained. Food/wildlife attractant storage restrictions apply on all NFS lands on the Lolo National Forest. Forest Plan Consistency The project is consistent with the Forest Plan. The rationale for the determination of effects demonstrates project consistency with Forest Plan forest-wide standards 24 (page II-13) and 27 (page II-14) that state federally listed species will be managed for recovery, with management practices in essential habitat compatible with the species needs. Canada Lynx The U.S. Fish and Wildlife Service (USFWS) listed Canada lynx as a threatened species in March USFWS determined that the main threat to lynx was the lack of guidance for conservation of lynx and snowshoe hare habitat in National Forest Land and Resource Plans and BLM Land Use Plans (USDI -FWS 2000a). In 2001, the Forest Service signed a Lynx Conservation Agreement with the USFWS indicating that the Lynx Conservation Assessment and Strategy (LCAS) (Ruediger et al. 2000) would be used as the guiding document during project analysis. In March 2007, 18 Forest Plans (including the Lolo National Forest) were amended with the Northern Rockies Lynx Management Direction (NRLMD) Record of Decision (ROD) [USDA-FS 2007]. The NRLMD describes the habitat management considerations needed to ensure lynx recovery. The NRLMD provides standards and guidelines to apply to lynx habitat. The Lolo National Forest is considered occupied lynx habitat. However, there is no suitable habitat within the 2-Short project area. The project area contains dry ponderosa pine and Douglas-fir forest types that do not provide lynx habitat (Squires et al. 2010; Koehler et al. 2008; Maletzke et al. 2008). 53

58 Only about 60 acres in the northwest corner of the 2-Short project area overlaps a lynx analysis unit (LAU) 16. LAUs are mapped on a broader scale than lynx habitat and thus contain many areas that are not suitable for lynx use. The project area is not located within designated lynx critical habitat (79 FR 54782, September 12, 2014). The nearest critical habitat is over 50 miles away. The species is likely absent as there have been no recorded or anecdotal sightings within the project area. No lynx were detected during carnivore track surveys that were conducted near the area in Intensive track surveys conducted by the Rocky Mountain Research Station across western Montana, including portions of the Lolo National Forest, have shown that lynx are uncommon to absent in many parts of this region. The Yaak (about 90 miles northwest of the 2-Short project area) and the Clearwater Valley near Seeley Lake (about 100 miles southeast of the 2-Short project area) are the primary strongholds for lynx in northwest Montana (Squires, Lynx Research Progress Report, 2006). Squires et al. (2013) do not include the Plains/Thompson Falls Ranger District in their map of lynx habitat in the Northern Rockies. On the Plains/Thompson Falls Ranger District, sightings of lynx and/or their tracks are rare and evidence of breeding is unavailable. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on Canada lynx or its habitat because the species is likely absent, no suitable habitat is located within the project area, and no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects The project would have no direct, indirect, or cumulative effects on lynx because: The species is likely absent because there is no suitable habitat within the project area as described above. The project would maintain all of the elements necessary for lynx to move across the landscape. Vegetation treatments would maintain a mosaic of forested cover to provide for lynx travel. Regeneration harvest activities would not create large openings that are unsuitable for lynx travel (Squires et al. 2013). Forest Plan Consistency The project is consistent with the applicable standards of the NRLMD, amended to the Lolo Forest Plan in 2007 because it would have no effect on habitat or habitat connectivity (see Wildlife report in the Project File). The rationale for the determination of effects also demonstrates project consistency with Forest Plan forest-wide standards 24 (page II-13) and 27 (page II-14) that state federally listed species will be managed for recovery, with management practices in essential habitat compatible with the species needs. Wolverine In February 2013, the U.S. Fish and Wildlife Service listed wolverine as a proposed threatened species (Federal Register 78: , February 4, 2013). They concluded that while wolverines appear stable to expanding, the primary threats to the contiguous U.S. population are the risk of eventual habitat and range loss due to climate warming, with secondary threats from trapping/wolverine 16 LAUs approximate the area used by individual lynx and are the units used to analyze the effects of a project (USDA-FS 2007, FEIS Vol. I, p. 370). 54

59 harvest, with potential threats from disturbance associated with human developments [e.g. houses and ski areas] and transportation corridors [e.g. interstate highways and high volume secondary highways], and loss of genetic stochasticity due to isolation between snowy habitats caused by climate change (Federal Register 78: , 2013). The USFWS specifically mentions that forestry-related management practices are not likely a factor contributing to the decline (78 FR 7879). Timber management, winter elk security, thermal cover, or over-the-snow uses managed by the Forest Service were not identified as threats to the U.S. population (78 FR ). On August 13, 2014, after considering the best available science, the USFWS declared that listing the wolverine as a threatened species was not warranted because they determined the effects of climate change are not likely to place the wolverine in danger of extinction now or in the foreseeable future (79 FR 47522). Thus, the USFWS withdrew its proposed listing rule. The U.S. Fish and Wildlife Service s determination was challenged in Court. In April 2016, the District Court of Montana ruled that the U.S. Fish and Wildlife Service must reconsider protections for wolverines under the Endangered Species Act. Currently, the species is proposed for listing under ESA. Surveys for wolverines and other carnivore species have been conducted across the Lolo National Forest in the last several years. There were no detections (confirmed DNA) of wolverines on the Plains/Thompson Falls Ranger District (USDA FS 2012). Low detection rates are normal because wolverines naturally occur in low densities with a reported range of one animal per 25 square miles to one animal per 130 square miles (Hornocker and Hash 1981; Hash 1987; Copeland 1996; Inman et al. 2007a). This may be due to their need for large territories and their tendency to defend those territories from other wolverines (79 FR 47530). Deep, persistent, and reliable spring snow cover (April 15 to May 14) is the best overall predictor of wolverine occurrence in the contiguous United States (Copeland et al. 2010). Wolverine year-round habitat use takes place almost entirely within the area defined by deep, persistent spring snow (78 FR 7868). This is likely related to the wolverine s need for deep snow during the denning period (78 FR 7872). No records exist of wolverines denning anywhere but in snow, despite the wide availability of snow-free denning opportunities within the species range (78 FR 7867). The deep, persistent spring snow area in the Copeland et al. (2010) model captures all known wolverine dens in the contiguous United States (78 FR 7868). Additionally, except for denning females (denning habitat is not considered scarce or limiting to wolverine reproduction), wolverines are occasionally observed in areas outside the modeled deep, persistent snow zone, and factors beyond snow cover may play a role in overall wolverine distribution (79 FR 47534). In the contiguous United States, valley bottom habitat appears to be used only for dispersal movements and not for foraging or reproduction (78 FR 7868). There is no denning habitat within the project area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on wolverine because the species is likely absent, no preferred habitat is located within the project area, and no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects The project would have no direct, indirect, or cumulative effects on wolverines and would not lead to a loss of species viability or jeopardize the continued existence of the species. The 2-Short project area is located within dry south-facing drainages that do not contain areas with persistent spring snow or high elevation cirque basins. This suggests that wolverines would likely only use the project area for transitory habitat rather than for breeding and year-round use. This species is not thought to be 55

60 dependent on vegetation or habitat features that may be manipulated by land management activities. Wolverines have been documented using both recently logged areas and burned areas (78 FR 7879). It is unlikely that wolverines avoid low-use roads like those in the project area (78 FR 7878). Therefore, timber harvest and new road construction would not affect potential wolverine movement through the area. Sensitive Species The Forest Service manual and Lolo Forest Plan require the Lolo National Forest to manage for sensitive species. The Forest Service manual defines sensitive species as those plant and animal species identified by a Regional Forester for which population viability is a concern. For species identified as sensitive, the Forest Service shall avoid or minimize impacts to species whose viability has been identified as a concern (FSM ). Forest Plan standard 27 (at p. II-14) directs the Forest to manage for population viability. The project is consistent with this direction (see summary for each species below). Gray Wolf In May 2011, the U.S. Fish and Wildlife Service removed gray wolves in a portion of the Northern Rocky Mountain Distinct Population Segment (DPS) encompassing Idaho, Montana and parts of Oregon, Washington, and Utah from the Federal List of Endangered and Threatened wildlife species. The U.S. Fish and Wildlife Service and the states will monitor wolf populations in the Northern Rocky Mountains DPS and gather population data for at least five years. Wolves in Montana are now managed under the Montana FWP Gray Wolf Management Plan as a hunted and trapped game species. Since delisting, wolves are analyzed as a sensitive species by the Forest Service in the Northern Region. Population trend numbers reached about 650 wolves in 2011 (Bradley et al. 2013). Prior to delisting, populations were increasing and they appear to have stabilized since 2011 (ibid.). Radio-collared wolves are monitored by Montana Department of Fish, Wildlife, and Parks and none have been identified as using the project area specifically as a core area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on gray wolves because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects If present during project activities, wolves could be temporarily displaced as they may avoid areas with active harvest and road work. However, the effects would be inconsequential because of the wolf s wide-ranging nature (wolf pack home ranges vary from 50 to 200 square miles). The project area of approximately 7 square miles in size is considerably smaller than a home range. There are ample areas outside the project area that would provide for suitable displacement during project implementation. Therefore, the project would not affect species viability or contribute to a trend towards Federal listing. Cumulative Effects There would be no adverse cumulative effects to gray wolves resulting from this project. No other harvest activities would be ongoing within the Prospect Creek watershed during the implementation of the 2-Short project. Therefore, there would not be additional timber sale-related disturbance to the species within the 182 square mile watershed, which is roughly the size of a wolf pack home range. 56

61 The Montana Wolf Conservation Management Plan requires the State to regulate wolf harvest to maintain a minimum number of breeding pairs. Thus, it is highly unlikely that legal hunting would be allowed to lower the wolf population to a point where viability is a concern. Montana FWP also manages deer and elk populations. It is unlikely that the State would manage big game populations to levels so low that wolves would begin switching to alternative prey. Flammulated Owl Flammulated owls are small, migratory insectivores that inhabit mountainous forests throughout western North America. McCallum (1994) noted that flammulated owls are perhaps the most common raptor of the montane forests of the western United States. The species is ranked by NatureServe as globally secure with a widespread distribution (MNHP 2008). In Montana, the Natural Heritage Program ranks the species as being abundant in some areas, but potentially at risk because of limited breeding habitat or populations (Ibid.). In Montana, calling flammulated owls were correlated with the number of ponderosa pine trees greater than 15 inches diameter breast height (dbh); low live basal area, low canopy (less than 40 percent) in ponderosa pine and moderate canopy (less than 70 percent) in sites dominated by Douglas-fir (Wright 1996). They appear to avoid young, dense stands of Douglas-fir, clearcuts, and intensively cutover areas, but they will use thinned or selectively logged stands (McCallum 1994). Surveys conducted in 2006 and 2015 detected the species in suitable habitat within the project area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on flammulated owls or their habitat because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects Although suitable habitat for flammulated owls is present within the project area, treatments would not occur within it. The species uses mature, large diameter ponderosa pine forests. Often these areas have a component of Douglas-fir, but stands dominated by Douglas-fir (where 2-Short treatments would generally occur) are typically not used by flammulated owls. There is a slight possibility that the noise from harvest activities could temporarily disturb individual birds using habitat in nearby or adjacent stands. However, effects would be inconsequential because activities would be of limited duration and disturbance is not considered a risk to the owls. The completed Shorty Gulch Hazardous Fuels Reduction project improved the quality of owl foraging habitat within treated areas. It also reduced the probability of stand replacing fire within treated stands, thus increasing the likelihood that suitable owl habitat would be maintained into the future. By conducting additional fuel reduction treatments in nearby or adjacent stands, the 2-Short project would further reduce the likelihood of uncharacteristic wildfire effects that could otherwise affect habitat. Therefore, the 2-Short project would not contribute to a trend toward federal listing or a loss of species viability. Boreal Toad Boreal toads are found in a wide variety of habitats including wetlands, forests, woodlands, sagebrush, meadows, and floodplains in the mountains and mountain valleys (Reichel and Flath 1995, summarized in Maxell 2000 and Werner et al. 2004). Adult and juvenile toads are freeze-intolerant and overwinter and shelter in underground caverns, or more commonly in rodent burrows. While smaller juveniles are active almost exclusively during the day, adults are usually active at night except during the spring and at higher elevations. Adult boreal toads are largely terrestrial and are known to 57

62 travel miles from their breeding sites through coniferous forests and subalpine meadows, lakes, ponds, and marshes (Werner et al. 2004). Boreal toads generally breed in lakes, ponds, and slow streams, laying eggs one to three months after the snow melts (Reichel and Flath 1995, Werner et al., 2004). Timing of breeding is dependent on temperature, snowmelt, and/or the presence of surface water from flooding and takes place from May to July in shallow areas of large and small lakes, beaver ponds, temporary ponds, slow moving streams, and backwater channels of rivers. Adults will move up to four kilometers (about 2.5 miles) away from water after breeding and juveniles will disperse up to four kilometers from their birth place. No toads have been detected within the project area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on boreal toads because no activities would occur. Alternative 2: Direct and Indirect Effects No harvest activities would occur within Riparian Habitat Conservation Areas, which would protect streamside habitat (see Resource Protection Measures in Chapter 2). Because toads are known to travel along stream areas - especially downstream (Young and Schmetterling 2009), the stream buffer would preclude any impacts on toads within or adjacent to streams. Because the boreal toad is an upland species for the summer and early fall (before underground hibernation), its home range and daily use could overlap somewhat with project activities. Machinery use associated with harvest has the potential to directly harm individual toads (which are likely widely spaced in their upland habitats). However, potential adverse impacts from project activities in nonbreeding areas would likely affect only a few individuals, if present, and would not have populationlevel impacts. Toads are more active at night when project activities would not be occurring, which would further limit potential effects. In addition, these toads have generally high productive rates, which would likely compensate for the mortality of a few (1-2) toads from machinery use, if it were to occur. Cumulative Effects The reroute of the lower segment of the Shorty Gulch road will not measurably affect toads, if present, because activities would occur between July 1 and August 31, when most toads have completed their breeding cycle and returned to the uplands for the year. Once the road relocation is completed, suitable toad breeding habitat would be improved. The potential effects of the project combined with those of the past Shorty Gulch Hazardous Fuels Reduction project and reasonably foreseeable road reroute would not contribute appreciable cumulative effects to this species or habitat and would not affect species viability. Therefore, the project would not contribute to a trend toward Federal listing. Management Indicator Species Management indicator species, considered widespread and common animals, were designated in Forest Plans to represent species whose population changes are believed to indicate the effects of management activities on representative wildlife habitats (FSM 2621). The Lolo Forest Plan defines Indicator Species as species identified in a planning process that are used to monitor the effects of planned management activities on viable populations of wildlife and fish including those that are socially or economically important (Forest Plan, page VII-15). The Lolo Forest Plan identifies 58

63 northern goshawk (natural old growth forests), pileated woodpecker (mature old growth with limited management), and elk (big game), as Management Indicator Species (MIS) (Forest Plan standard 27, at p. II-14 and Forest Plan Final Environmental Impact Statement, pp. III-28 through III-29). The Lolo Forest Plan standard 27 states that habitat for management indicator species will be monitored. Elk population data, collected by Montana FWP will be compared against habitat data to test elk/habitat relationships. Forest Plan standards 21, 22, and 23 (page II-13) provide for the protection of elk habitat such as wallows and winter range. The Plan further states that as monitoring technology become available for northern goshawk and pileated woodpecker, population trends will be monitored. In the interim, habitat parameters including old growth acres and condition, and snag densities will be monitored as an indicator of population trend. In recent years, both population and habitat have been monitored at a Region-wide scale and a forest scale. This data indicates that population trends for northern goshawk and pileated woodpecker are stable or increasing. Information from these efforts is summarized in the individual species sections below. Northern Goshawk The northern goshawk is found throughout North America with breeding documented from Alaska to Newfoundland and south through the Rocky Mountains, Sierra Mountains, and into Mexico. In Region 1, the species breeds in mountainous or coniferous regions throughout western and southern Montana as well as north and north central Idaho. Goshawks winter throughout their breeding range with a portion of the population wintering outside breeding areas (Montana Distribution committee 1996; Squires and Reynolds 1997). According to NatureServe, the northern goshawk is globally secure common, widespread and abundant. The species is not considered a species of greatest conservation need by either the states of Montana ( or Idaho ( /CDC/cwcs_table_of_contents.cfm), and is not contained in either of the states Comprehensive Wildlife Conservation Strategies. It is no longer listed as a species of concern in Montana because of recent surveys that found them to be more abundant than previously thought (MNHP 2008). Based on recent broad-scale habitat and inventory and monitoring assessments conducted in Region 1, breeding goshawks and associated habitats appear widely distributed and relatively abundant on NFS lands, including the Lolo National Forest (Samson 2006a, errata corrected 2008; 2006b; Canfield 2006, Kowalski 2006). In a random sample of goshawks nesting in a heavily managed landscape adjacent to the Lolo National Forest, monitoring showed reproductive rates and nest success above or well within the ranges reported in studies done in less-managed landscapes throughout the western United States (Clough 2000). Results suggest goshawks do well even in managed landscapes. Goshawks have been observed within and adjacent to the 2-Short project area. The project area is about the size of a territory for one pair of goshawks. Approximately 240 acres of nesting habitat is required to support a nesting pair within a territory (Brewer et al. 2007). Currently, the project area contains about 1564 acres of nesting habitat nearly 7 times that needed to support 1 goshawk pair. Nesting habitat criteria includes a tree canopy cover of 60 percent or greater and tree diameter of 10 inches or greater. Foraging habitat is abundant within the project area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on northern goshawks because no activities would occur. However, untreated areas would be at higher risk to stand replacement wildfire, which would likely 59

64 alter the habitat composition away from the mix of vegetation age classes and forest seral stages recommended in the literature (Reynolds et al. 1992, Saw and DeStefano 2001). Alternative 2: Direct and Indirect Effects Regeneration harvest would overlap approximately 325 acres of suitable nesting habitat. This represents about 20 percent of the 1564 acres of nesting habitat within the project area. This type of harvest would reduce canopy cover below 60 percent, which would render these stands unsuitable as nesting habitat until tree crowns return to pre-treatment levels, more than 10 years out (Reynolds et al. 1992; Squires and Ruggiero 1996; McGrath et al. 2003). Post-treatment, there would still be 5 times the amount of recommended nesting habitat (Reynolds et al. 1992) in the project area, which would support more nests than the territorial nature of goshawks would tolerate. Thus effects would be minor given the abundance of nesting habitat distributed throughout the project area. Reducing the risk of high severity fire would increase the likelihood that suitable habitat would remain available over the long term. Cumulative Effects The recently completed Shorty Gulch Hazardous Fuels Reduction project had no effect on nesting habitat. Therefore, the 2-Short project would have no cumulative effects with the previous project. Although the project would alter about twenty percent of the nesting habitat, it would not individually or cumulatively lead to a loss of species viability because foraging and nesting habitat would remain abundant; and goshawk habitat is abundant and well-distributed across the Forest and Region more than sufficient to sustain a viable population. Pileated Woodpecker The pileated woodpecker is considered widespread and common in Montana (MNHP 2009). In 1990, the Northern Region designed a monitoring program to help biologists and managers better understand the habitat relationships and population trends of landbirds breeding in this region. Monitoring data indicate that the pileated woodpecker population is relatively abundant and evenly distributed across the Forest and northwest Montana (USDA-FS 2008; Numerous observations of pileated woodpecker have occurred within Prospect Creek and sign from pileated woodpecker excavations into larger dead trees is also common. Although the pileated woodpecker is most often associated with mature forests (Conner et al. 1976, Conner 1980, Shackelford and Conner 1997), it is able to do well in young and fragmented forests (Mellon et al. 1992), including forested areas with just 10 percent forest cover (Bonar 2001). The nest tree is the most important variable for predicting nesting habitat (Kirk and Naylor 1996, Giese and Cuthbert 2003). In Montana, the species selects western larch for nesting more frequently than other tree species, followed by ponderosa pine, black cottonwood, aspen, western white pine, and Douglasfir (McClelland and McClelland 1999). Nest tree diameters are generally larger than 15 inches (ibid.), and winter roost trees are generally larger than 10 inches in diameter (Bonar 2001). Pileated woodpeckers are considered non-migratory. Territory size varies from 700 to 1557 acres for breeding pairs (Bull and Holthausen 1993). Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on pileated woodpecker because no activities would occur. However, there could be some negative indirect effects to pileated woodpeckers under this alternative. Effects would be related to the persistence of dense understories and the continued exclusion of fire in some areas. Over time, these two factors would increase the risk of a stand-replacing fire (Fire and Fuels section 3.3), which could result in the loss of live and dead large diameter trees used by the 60

65 species. In addition, these conditions would not allow for the regeneration of shade-intolerant species such as western larch and ponderosa pine, species highly important to the pileated woodpecker. Alternative 2: Direct and Indirect Effects Regeneration harvest would overlap approximately 355 acres (14 percent) of the suitable pileated woodpecker nesting and foraging habitat within the project area. Some of the larger trees would be removed which could reduce the number of available nesting and feeding trees. However, after project implementation approximately 86 percent (2164 acres) of the foraging and nesting habitat would remain unaffected. Thus, suitable habitat would remain abundant following implementation of the 2-Short project. Snag management guidelines in the Forest Plan would be followed (see Resource Protection Measures in Chapter 2) and no existing old growth stands would be affected (see Section 3.2.2). Cumulative Effects The diversity of habitats used by this species would enable it to persist through a variety of influences. Pileated woodpecker habitat is abundant and well-distributed across the Region, Forest, and 2-Short project area. The project would have no measurable adverse cumulative effects on the species or its habitat at the project area, Forest, or Regional scale due to the extensive amount of available habitat, the relatively small amount being treated, the relatively small scale of effects, and the fact that the species is common and widespread. Elk The Forest Service Manual directs forests to manage for species that are in demand for hunting (FSM , 2602, and 2603). The Lolo Forest Plan contains goals, objectives, and standards for big game management that include providing and improving habitat for big game, protecting features such as wallows and mineral licks, managing winter range, providing hunting opportunities and working cooperatively with Montana FWP (USFS 1986). Big game on the Plains/Thompson Falls Ranger District primarily refers to elk, white-tailed deer, and mule deer. There are smaller numbers of moose and bighorn sheep. Managing for the requirements for elk generally fulfills the needs of other big game species. The document Coordinating Elk and Timber Management (Lyon et al. 1985), as well as the Montana elk management plan (MTFWP 2004), were considered in assessing the effects of timber harvest on elk habitat. Montana Department of Fish, Wildlife, and Parks goals for the elk population in the Lower Clark Fork Elk Management Unit (of which the 2-Short area is a portion) include maintaining elk numbers, a diverse bull age structure, and a variety hunting opportunities (MTFWP 2004). This requires controlling vulnerability from hunting and providing winter range sufficient to support elk when little forage is available. Although more recent research is now available, the Coordinating elk and timber management document (Lyon et al. 1985) is used to help balance needs for elk and management of other resources. Monitoring conducted in Prospect Creek by the Montana Department of Fish, Wildlife, and Parks indicate that there have been no noticeable up or downward trends in elk numbers over the last several years. In addition, hunting regulations have remained relatively stable. Lolo National Forest Plan Management Areas 18, 22, and 23 (elk winter range emphasis) comprise 2125 acres (53 percent of NFS land) within the project area. One of the Forest Plan goals for these winter range areas is to optimize forage production. Within these management areas, the Forest Plan directs maintaining a minimum 50:50 cover:forage ratio. Primarily due to fire exclusion, winter range areas currently have reduced forage and excessive cover (nearly 90 percent). 61

66 Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on elk because no activities would occur. However, continued forest succession would result in conifer encroachment into formerly open forest stands, which would reduce forage for wintering animals (Irwin and Peek 1983; Gibbs et al. 2004). Although, winter range forage was improved within areas treated by the recently completed Shorty Gulch Hazardous Fuels Reduction project, forage conditions on untreated areas would continue to decline. Alternative 2: Direct and Indirect Effects Vegetation treatments would improve forage production on approximately 390 acres of winter range areas, which would benefit elk. Hiding cover would be reduced for roughly 15 years on approximately 237 acres, where regeneration harvest would occur within winter range. However, because cover is currently exceeding desired conditions, treatments would move the cover:forage ratio closer to that which is outlined in the Forest Plan (see above). Harvest operations and related road work could temporarily disturb elk during implementation. However, these effects would be discountable due to the relatively small size of the project area and the availability of ample suitable areas outside the 2-Short project area for elk to temporarily displace to. Temporary displacement would not lead to mortality or long-term consequences. Security during the fall hunting season and the winter/spring periods would be maintained or slightly increased because newly constructed roads and the motorized recreation loop route would be closed during these times. In addition, the travel management status of Road would be changed from open yearlong to open seasonally (May 15 to October 15), slightly increasing security during these time periods. Cumulative Effects The fuel reduction treatments (e.g. prescribed burning, slashing/handpiling, and commercial thinning) conducted under the previously completed Shorty Gulch Hazardous Fuels Reduction project improved the quantity and quality of big game winter forage. In addition, prescribed burning and weed treatments within Valentine Gulch similarly improved forage production on winter range areas. The 2- Short project would continue this trend, which would benefit elk. Migratory Birds Numerous avian species, including those listed as Forest Service sensitive or management indicator species are protected under the Migratory Bird Treaty Act. Executive Order of 2001 outlined the responsibilities of Federal agencies regarding migratory bird conservation. In December 2008, the Forest Service entered into a Memorandum of Understanding (MOU) with the U.S. Fish and Wildlife Service on the Migratory Bird Treaty Act to further clarify agency responsibilities. Four key principles embodied in the MOU direct the Forest Service to: 1) focus on bird populations; 2) focus on habitat restoration and enhancement where actions can benefit specific ecosystems and migratory birds dependent on them; 3) recognize that actions taken to benefit some migratory bird populations may adversely affect other migratory bird populations; and, 4) recognize that actions that may provide long-term benefits to migratory birds may have short-term impacts on individual birds. The parties agreed that through the NEPA process, the Forest Service would evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors. The needs of migratory birds are addressed throughout this analysis, including the individual sections on project impacts to flammulated owl, northern goshawk, and pileated woodpeckers as well as other sections of this EA that address habitat diversity. 62

67 Migratory bird species are currently monitored by the Northern Region and through the USGS Breeding and Christmas Bird Surveys ( These larger monitoring efforts can help to detect population trends. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on migratory birds because no activities would occur. Indirectly through vegetative succession, Alternative 1 would favor species requiring older, denser forest stands (e.g. Townsend s warbler) and would reduce habitat for species using fire-maintained, open habitats (e.g. red-breasted nuthatch); unless large, high intensity fires occurred to set back forest succession and favor species requiring open habitats or burned areas (black-backed woodpeckers, kestrels, and bluebirds). Alternative 2: Direct, Indirect, and Cumulative Effects Because of the myriad of species included in the migratory bird group, any habitat modifications could have effects on some species but not others. Timber harvest activities would create disturbance that could temporarily displace birds to unaffected areas. If timber harvest occurs during spring, it could have negative effects on individual nesting birds because nests, eggs and nestlings would be unable to move away from activities. These impacts are unlikely to have population-level effects because: 1) these species are currently abundant enough that loss of some reproduction in a year is insignificant and 2) most species reproduce relatively quickly, enabling them to repopulate a small area easily. Migratory birds include such a wide range of species which use nearly every habitat available in the Northern Region. Managing landscapes to maintain a balance of vegetative conditions within reference conditions can balance the needs of many species. At the same time, avoiding adverse effects on Endangered, Threatened, and sensitive species focuses attention on species where special management may be required. According to Partners in Flight, the Intermountain West area needs restoration work to improve historic structure of ponderosa pine forests, aspen habitats, and riparian habitats to best conserve the suite of birds native to this area (Rich et al. 2004). Therefore, cumulatively, the project would not affect migratory bird populations because of the relative small scale of the timber harvest activities, the limited intensity of effects, and the widespread/secure nature of these species (note that sensitive bird species are discussed above). 3.7 Transportation System Issue Raised in Public Comment Road closures could affect public access. Within the 2-Short project area, there are approximately 37 miles of road, 84 percent (31 miles) is under Forest Service jurisdiction and the remaining 16 percent is private (2 miles) and County (4 miles). Of the roads under Forest Service jurisdiction, 24 miles are system roads and 7 miles are nonsystem or undetermined roads. Most non-system roads are narrow, brushed/treed-in roads constructed in the mid-20 th century to accommodate the logging equipment of that era. Approximately 20 miles (65 percent) of road under Forest Service jurisdiction within the project area are currently legally open yearlong or seasonally to public motorized use. Forest Service policy prescribes the travel analysis process for many purposes (FSH ). Travel management decisions are to be informed by travel analysis, as applicable (FSM ). Travel management decisions are defined at FSM 7715 and include adding a route to or removing a route 63

68 from the forest transportation system, constructing a National Forest System (NFS) road or NFS trail, acquiring an NFS route through a land purchase or exchange, decommissioning a route, approving an area for motor vehicle use, or changing allowed motor vehicle classes or time of year for motor vehicle use. In these instances the responsible official has the discretion to determine whether travel analysis at a scale smaller than a ranger district or an administrative unit is needed and the amount of detail that is appropriate and practicable for travel analysis (FSM (3)). Following the policy described above, the Forest Service completed a project-specific travel analysis for the 2-Short project area. This analysis documented the need for new specified road construction, identified some roads to be decommissioned, and found that some existing undetermined roads need to be added to the specified road system (see Chapter 2 for specific details). As part of this analysis, all roads under Forest Service jurisdiction were analyzed, including system roads, non-system (undetermined) roads, and proposed new long-term specified roads. See the Transportation report in the Project File for more detailed information regarding the Travel Analysis. Alternative 1: Direct, Indirect, and Cumulative Effects Under Alternative 1, the existing transportation system and public motorized access within the project area would remain as they currently are. Periodic road maintenance would continue at current levels based on need and priority. Alternative 2: Direct, Indirect, and Cumulative Effects Approximately 6 miles of road would be decommissioned. When combined, road construction, decommissioning, and travel management activities would result in a net gain of 0.5 miles of road open to the public during the summer (see Table 3.7-1). Most of the road segments proposed for decommissioning are non-system roads on which public motorized travel is not permitted and/or are undrivable due to vegetation growth on the roadway. Road surveys indicated that about 3 miles (50 percent) of road proposed for decommissioning would need some kind of physical treatment. The remaining roads are benign and not currently causing any identifiable environmental harm because of their location and well-vegetated condition. Natural processes have essentially decommissioned them already. Table 3.7-1: Summary of Changes to Public Motorized Access Management Action Miles Description Change from Open yearlong to Open seasonally (May 15 to October 15) (Road 18444) 1.5 Motorized recreation loop route New road construction, Open seasonally (Roads 18444ext and 16286ext) 1.6 Motorized recreation loop route NFSRs decommissioned, currently drivable 0.5 Alternate route constructed as part of motorized (lower segment of Road 18444) NRSRs decommissioned, not currently drivable (Road 18494, but designated as open seasonally May 15 to October 15) 0.6 recreation loop route. Road segment not needed for long-term management. The road above (7636) is sufficient for skyline equipment to reach the area. Cumulatively, the project would result in a net gain of 6 miles of road to the National Forest system through the adoption of 2.6 miles of non-system roads, construction of 4.3 miles of new long-term specified road, and the decommissioning of approximately 1 mile of existing system road. See Transportation report in the Project File and Appendix B of this document for more details. 64

69 Forest Plan and Regulatory Consistency The project is consistent with the Lolo Forest Plan. New roads would be built within Forest Plan management areas that allow road construction. A project-specific Travel Analysis was conducted to ensure roads within the project area would be the minimum number and meet the design standards to provide for safety and to meet user and resource needs (Standard 48, page II-17). Roads within the project area would be managed to provide for resource protection, wildlife needs, commodity removal, and a wide range of recreation opportunities (Standard 52, page II-18). The Travel Management Rule (2005) (36 CFR (c)) criteria was addressed in the designation of roads, including those to be constructed, maintained, or added to the National Forest System. Consideration was given to the speed, volume, composition and distribution of traffic; compatibility of vehicle class with road geometry and surfacing; right of access; and wilderness and primitive areas (36 CFR (c, d, and e)). The roads within the project area are primarily collector and local roads designed to accommodate lowboys, log trucks or other high-clearance vehicles traveling at low speeds. Traffic volumes are generally low (2-8 average daily trips (ADT)) with occasional increases during timber haul and other project activities. Road geometry corresponds with the intended use of these roads for forest management and recreation; curvilinear alignment with intervisible turnouts, single lane foot width with turnouts, native or aggregate surfacing. New roads constructed for the project and future land management would correspond with these general standards. No changes would be made to valid existing rights of use. No roads would be located in designated wilderness or primitive areas. Designated roads would be identified on the motor vehicle use map and recorded in the Forest Roads and Trails Atlas. 3.8 Heritage Surveys conducted within the project area identified a segment of an historic pack trail located within the north portion of the project area. Although this trail is still used (primarily by hunters in the fall), it is ineligible for listing on the National Register of Historic Places (NRHP) 17 due to lost integrity. No other heritage features were found. The historic Thompson Falls to Murray stage road lies just outside the southern boundary and is mostly overlain by the Prospect Creek highway. This site was determined eligible for listing on the NRHP. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on heritage resources because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects The project would have no direct, indirect, or cumulative effects on heritage resources. Although the historic stage road is located just outside the project area, no activities would occur near it. The unmaintained historic pack trail passes through Units 33, 101 and 102, where treatments would include slashing, burning, and planting. A resource protection measure would be applied to pull slash away from the trail so that the tread is clear of debris (see Chapter 2). Because treatments would be 17 The National Register of Historic Places is the official list of the Nation s historic places worthy of preservation. 65

70 non-ground disturbing and the trail tread would be maintained free of debris, the project would have no effect on the trail. The Montana State Historic Preservation Office has concurred that the project would have no effect on historic properties (letter dated December 22, 2016). Forest Plan Consistency The project is consistent with the Lolo Forest Plan. Cultural resources were considered during the planning process, field inventories were conducted, and the Forest has consulted with the State Historic Preservation Office (Forest Plan standard 54, page II-20). In addition, the Forest has discussed this project with the Confederated Salish and Kootenai Tribes (Forest Plan standard 55, page II-20). They expressed no concerns. 3.9 Recreation The project area is primarily used for dispersed recreation activities (e.g. hunting). There are no developed recreation sites or maintained system trails within the 2-Short area. Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on recreation because no activities would occur. Alternative 2: Direct, Indirect, and Cumulative Effects General Recreational Use Vegetation management activities would result in a short-term increase in vehicle traffic, which would include log trucks. Roadways would be appropriately signed to warn forest visitors of additional traffic in the area. Road dust, smoke from prescribed burning activities, noise from operating equipment, and increased road traffic may be a temporary inconvenience to some recreationists using the area during implementation of project activities. Mechanical operations and hauling would generally occur during daylight hours on weekdays during the summer and early fall. The Prospect watershed, to which Shorty Gulch is tributary, contains far more popular areas for recreation that offer amenities such as maintained trails, mountain lakes, and longer open roads for those who enjoy recreational driving. Therefore, there would be nearby undisturbed areas for forest visitors to enjoy during project implementation. There would unlikely be any cumulative effects on general recreation use due to the temporary and intermittent nature of the project s activities. Motorized Recreation The project would establish a seasonal (open May 15 to October 15) motorized loop route between Shorty and Brush Gulches by connecting a portion of Road #18884 to newly constructed road. The new road construction would tie into existing system roads, which are currently open seasonally and loop around into Brush Gulch. The loop would be open to all motorized vehicles, although the existing primitive condition of a portion of the retained segment of Road #18884 would likely limit use to higher clearance 4-wheel drive vehicles and ATV/motorcycles. Due to the limited length of the loop (13 miles) and its relatively close proximity to Thompson Falls, it is expected that use would be primarily by local residents. Road #18884 is currently open yearlong to public motorized traffic. The road is steep, narrow, with encroaching vegetation and is used primarily by some local residents for activities such as firewood collection. 66

71 Decommissioning the lower ½ mile of Road #18884 and changing the travel management restriction on the rest of the road from open yearlong to open seasonally (May 15 to October 15) would reduce yearlong public motorized access by 2 miles within the project area. However, seasonal motorized use from May 15 to October 15 would be allowed on 1.5 of those miles and 1 mile of the new road construction, resulting in a net gain of ½ mile of public motorized access. The change in travel management from open yearlong to open seasonally may displace a few people who use the road for firewood collection and/or hunting in the late fall but may benefit those who prefer a walk-in hunting experience. The establishment of a loop route would be an opportunity to address a frequent public request that the Forest Service provide more driving loops in an area which is suited to such use (e.g. loop is located close to Thompson Falls in a dry area with no stream crossings and where no federallylisted threatened or endangered species are present). The motorized loop route would be monitored (particularly during the fall hunting season) for compliance with seasonal use restrictions. If these restrictions are not adhered to, the motorized loop would be permanently closed to the public (see Section in Chapter 2) Economics Three factors were considered in the economic analysis: project feasibility which addresses only the timber harvest component of this project; financial efficiency, which addresses present net value (PNV) or the net monetary costs and benefits of the project; and economic impacts, which are the effects of this project on local jobs and labor income. Project feasibility is used to determine if the timber harvest would be feasible, that is, would it sell, given current market conditions. The determination of feasibility relies on a residual value analysis (price of the timber = revenues costs) that uses local delivered log prices and stump-to-mill costs. The appraised stumpage rate from this analysis is compared to the base rate. The project is considered feasible if the appraised stumpage rate exceeds the base rate. Financial efficiency provides information relevant to the future financial position of the government as the project is implemented. Financial efficiency considers anticipated Forest Service costs and revenues. PNV is the difference between the present value of the revenues and present value of the costs. PNV converts costs and revenues over the entire time frame of the project into a single figure for a selected year. A positive PNV means that the project would generate more financial revenues than financial costs. The NEPA planning is a sunk cost at the time of the decision and is not included in the PNV analysis. Financial efficiency analysis is not intended to be a comprehensive analysis that incorporates monetary expressions of all known market and non-market benefits and costs. Many of the values associated with natural resource management are best handled apart from, but in conjunction with, a more limited financial efficiency framework. These non-market benefits and costs associated with the project are discussed throughout the various resource sections of this EA. Economic impacts are used to evaluate potential direct, indirect, and cumulative effects of the project on the economy. They are measured by estimating the direct jobs and labor income generated by 1) the processing of the timber volume from the project and 2) Forest Service expenditures for contracted other activities. The direct economic and labor income benefit employees and their families and, therefore, directly affect the local economy. Additional indirect and induced multiplier effects (ripple effects) are generated by the direct activities. Indirect effects are felt by the producers of materials used by the directly affected industries. Induced effects occur when employees of the directly and 67

72 indirectly affected industries spend the wages they receive. Together the direct and multiplier effects comprise the total economic impacts to the local economy. Economic impacts are estimated using input-output analysis, which is a means of examining relationships within an economy, both between businesses and between businesses and final consumers. It captures all monetary market transactions for consumption in a given time period. The resulting mathematical representation allows one to examine the effect of a change in one or several economic activities on an entire economy, all else constant. The model used for this analysis is the 2014 IMPLAN data in conjunction with response coefficients that relate timber harvest quantity to direct jobs and income (Sorenson et al. 2016). IMPLAN translates changes in final demand for goods and services into resulting changes in economic effects, such as labor income and employment of the affected area s economy. Data used to estimate the direct effects from the timber harvesting and processing were provided by the University of Montana s Bureau of Business and Economic Research (BBER) (Sorenson et al. 2016). This national dataset is broken into multi-state regions and is considered more accurate than that which is available from IMPLAN. The Northern Rockies BBER Region (Montana and Idaho) is used for this analysis. The BBER data represents the results of mill censuses that correlate production, employment, and labor income. The economic impact area for this analysis consists of Sanders and Mineral Counties. Potential limitations of these estimates are the time lag in IMPLAN and the uncertainty of where the timber will ultimately be processed. The analysis assumes the harvested timber volume would be processed in the Sanders and Mineral County impact area. However, if some of the timber were processed outside the region, then a portion of the jobs and income would be lost by this regional economy. Table Project Feasibility and Financial Efficiency Summary (2016 dollars) Category Measure Alternative 1 Alternative 2 Timber Harvest Information Acres Harvested* Timber Harvest & Required Design Criteria Timber Harvest & All Other Resource Activities * Volume and acres are estimations CCF= hundred cubic feet Volume Harvested* (CCF) 0 14,548 Base Rates ($/CCF) 0 $32.90 Appraised Stumpage Rate ($/CCF) 0 $54.26 Predicted High Bid ($/CCF) 0 $59.91 Total Revenue 0 $877,000 PNV 0 $449,000 PNV 0 $279,000 68

73 Table : Total Employment and Labor Income over the Life of the Project* Non-Timber Harvest-related Activities Alternative 1 Alternative 2 Part and Full Time Jobs Contributed Direct 0 7 Indirect and Induced 0 3 Total 0 9 Labor Income Contributed ($) Direct 0 $295,000 Indirect and Induced 0 $89,000 Total 0 $384,000 Timber Harvest and Processing Alternative 1 Alternative 2 Part and Full Time Jobs Contributed Direct 0 45 Indirect and Induced 0 42 Total 0 87 Labor Income Contributed ($) Direct 0 $2,241,000 Indirect and Induced 0 $1,575,000 Total 0 $3,815,000 All Activities Alternative 1 Alternative 2 Part and Full Time Jobs Contributed Direct 0 52 Indirect and Induced 0 45 Total 0 97 Labor Income Contributed ($) Direct 0 $2,536,000 Indirect and Induced 0 $1,663,000 Total 0 $4,199,000 * It is important to note that these may not be new jobs or income, but rather jobs and income supported by this project. Part and Full Time Jobs Contributed is the total full and part-time wage, salaried, and self-employed jobs contributed to the economic impact area from the change in final demand associated with this project. Labor Income Contributed includes the wages, salaries and benefits of workers who are paid by employers and income paid to proprietors in the economic impact area from the change in final demand associated with this project. Direct effects represent the impacts for the expenditures and/or production values specified as direct final demand changes. Indirect effects represent the impacts caused by the iteration of industries purchasing from industries resulting from direct final demand changes. Induced effects represent the impacts of all local industries caused by the expenditures of new household income generated by the direct and indirect effects of final demand changes. Total effects are the sum of direct, indirect, and induced effects. Alternative 1: Direct and Indirect Effects Under Alternative 1, no activities would occur; therefore no financial costs would be incurred from harvest operations and associated activities. However, the NEPA planning costs will have already been incurred, representing a sunk cost with no return on the planning investment. Alternative 1 would yield a present net value of zero (Table ). This value also neglects the resulting losses in timber values and non-market benefits. In addition, since the planning costs for this project have already been incurred, there would be no return on the planning investment. Alternative 1 would support no direct, indirect, or induced employment, and no labor income contribution to local economies (Table ). This alternative has the potential to continue the 69

74 decline of timber-related employment in the rural communities of the economic impact area. Continued decline in timber harvest from NFS lands could potentially impact wood product employment and associated indirect and induced employment. A 2009 report by Spelter, McKeever, and Toth states many of the forests in the West are publicly owned, and supply from these lands has decreased. Since January of 2007, twenty six sawmills have experienced permanent closure. Most negatively affected were the states of Montana and California, whose losses in this period ( ) were 26 and 25 percent, respectively (Spelter, McKeever and Toth 2009). In 2010, the only major pulp mill in Montana closed. Permanent closures also continued to impact the state s log home industry (Morgan et al. 2011). Operations at most other facilities were curtailed in 2009 and Timber processing capacity dropped from 934 MMBF in 2004 to 606 MMBF in Capacity utilization, which normally exceeds 70 percent, dropped to 50 percent in 2009 (McIver et al. 2013). A 2015 Forest Products Outlook report stated that log supply affected milling facilities across the state in 2014 and would continue into 2015 (Morgan et al. 2015). Changes in the economic base and wood products infrastructure for the impact area would also likely continue to be influenced by fluctuations in market prices, international market conditions, changes in technology, and industry restructuring. Cumulative Effects Alternative 1 would not be without some associated cumulative economic effects. This alternative would have the potential to continue the decline of timber-related employment in the rural communities of the economic impact area. Cumulative loss in timber-related jobs could affect the remaining infrastructure and capacity of local rural communities, and could disrupt the dependent local goods and services industries. Alternative 2: Direct and Indirect Effects Project Feasibility The appraised stumpage rate from the feasibility analysis was compared to base rates. As displayed in Table , the appraised stumpage rate is greater than the base rate, indicating that the project is feasible (likely to sell). Financial Efficiency The financial efficiency analysis is specific to the timber harvest and other activities associated with the alternatives (as directed in Forest Service Manual 2400-Timber Management and guidance found in Forest Service Handbook ). Costs for sale preparation, sale administration, regeneration, and restoration activities are included. If exact costs were not known, the maximum of the cost range was used to produce the most conservative PNV result. If actual costs are lower, all else equal, PNV would be higher than the estimates in Table The expected revenue for the project is the corresponding predicted high bid from the sale feasibility analysis. The predicted high bid is used for the expected revenue (rather than the appraised stumpage rate) since the predicted high bid is the best estimate of the high bid resulting from the timber sale auction. Because not all costs of the project are related to the timber sale, two PNVs were calculated. One PNV indicates the financial efficiency of the alternative, including all costs and revenues associated with the timber harvest and required design criteria. A second PNV includes all costs for the alternative with the required design criteria and for the timber harvest and all other resource activities (e.g., non-commercial thinning; slash, burn, and plant treatments). 70

75 Results shown in Table indicate that the project is financially efficient (positive PNVs) for the timber harvest with designed criteria. When considering the timber harvest with the design criteria and other resource activities, the PNV is lower, as expected, but still positive. The decision maker takes many factors into account in making the decision. When evaluating tradeoffs, the use of efficiency measures is just one factor that is considered. Economic Impacts The project would support existing jobs through timber harvest-related and other non-commercial activities. Table displays the direct, indirect and induced, and total estimates for employment (part and full-time) and labor income that may be attributed to the project. Since the expenditures occur over time, the estimated impacts of jobs and labor income would be spread out over the life of the project. It is important to note that these may not be new jobs or income, but rather jobs and income that are supported by this project. It is anticipated that the timber harvest would occur over a five-year period, with the other resource activities spread out over four years after harvest. This means that the impact of timber harvest to jobs and labor income would occur prior to those associated with other resource activities. However, implementation could take longer than anticipated due to unforeseen circumstances. Cumulative Effects Management of the Lolo National Forest has an impact on the economies of local counties. However, there are many additional factors that influence and affect the local economies, including changes to industry technologies, management of adjacent National Forests and private lands, economic growth and international trade. The project would provide a variety of opportunities for contracts that may contribute to the local economy and have the potential to attract new business and residents and retain existing businesses and residents. In addition, there are other foreseeable future Forest Service projects within Sanders County and counties closest to the project area that are in various stages of planning that potentially may add to the Forest s annual timber offerings during the time of implementation of the project. These ongoing and foreseeable projects are expected to add cumulatively to the employment and income of the economic impact area within the life of the 2-Short project. Forest Plan Consistency Consistent with the Forest Plan, an economic analysis has been completed that includes the probable marketability (i.e. economic feasibility) of the commercial timber harvest portion of the project (Forest Plan standard 11, page II-11). The project also contributes to one of the Forest Plans primary goals to provide a sustained yield of timber and other outputs at a level that will help to support the economic structure of local communities (Forest Plan, page II-1). 71

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77 Appendix A Map NOTE: This map along with the entire Environmental Assessment are posted on the Lolo National Forest website ( where viewers can use the zoom-in function to see greater detail. A larger scale map is available at the Plains/Thompson Falls Ranger District office upon request. 73

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79 Appendix B Detailed Vegetation and Road Treatments Table B-1: Vegetation Treatment Areas Unit Acres Treatment Type Logging System 2 14 Commercial Thin Skyline 3 28 Commercial Thin Skyline 4 33 Commercial Thin Skyline 6 40 Commercial Thin Skyline 7 34 Commercial Thin Skyline 8 11 Underburn Underburn Commercial Thin Skyline/Excaline Commercial Thin Skyline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Skyline/Excaline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Excaline Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Tractor Regeneration Harvest Skyline Regeneration Harvest Skyline Regeneration Harvest Tractor Regeneration Harvest Tractor Non-commercial Thin Non-commercial Thin Non-commercial Thin Non-commercial Thin Non-commercial Thin Non-commercial Thin Non-commercial Thin Slash/Burn/Plant Slash/Burn/Plant Slash/Burn/Plant

80 Unit Acres Treatment Type Logging System Slash/Burn/Plant Acres are approximate 2 Equipment reflects the primary yarding system. Units may contain incidental areas that would require another type of equipment. Vegetation Treatment Descriptions: Commercial Thin treatments are designed to enhance growth, quality, vigor, and composition of the existing stand. Generally smaller trees are removed from the lower and main canopy, retaining the larger trees of desired fire-tolerant and disease-resistant species with gaps between the crowns. Within some stands, prescribed fire would be applied following harvest activities. Regeneration Timber Harvest treatments are designed to replace the existing stand with a stand that has a species composition and stocking density that meets desired future conditions specified in management objectives. Regeneration harvests are proposed where stand conditions (insects, disease, blowdown, etc.) do not meet and are not projected to meet desired conditions and where intermediate harvest cannot alter stand development to a desired condition. Prescribed fire would be applied following harvest to reduce fuel and prepare the site for natural regeneration or planting. Natural regeneration is expected at various densities and species, and most of these units would be planted to ensure regeneration of western larch, ponderosa pine, and blister rust-resistant western white pine. Non-commercial thinning would occur in young (20-40 years old) stands to remove smaller trees from the lower and main canopy, retaining the larger trees of desired fire-tolerant and disease-resistant species with gaps between crowns. This provides growing space to reduce competitive stress, resulting in trees that grow bigger faster, develop characteristics that increase fire-tolerance both at individual tree and at stand levels, and better resist some of the most damaging insects and diseases. The resulting stand densities are typically between 110 and 170 trees per acre, but that varies by species distribution and tree sizes. The trees cut during this process would be left on site and allowed to decompose back into the soil. Slash/Burn/Plant are treatments that would convert root disease-susceptible tree species in root disease areas to more resistant tree species. This treatment would be used in areas that are not economically viable for commercial timber harvest because of the lack of enough merchantable timber. The treatments in these areas would consist of slashing some of the understory trees to create a fuel bed. The areas would then be burned to prepare the site for planting root disease resistant tree species (e.g. western larch, ponderosa pine, and western white pine). Table B-2: Road Treatments Road # BMP EMP Length (Miles) Management Action 76

81 Road # BMP EMP Length (Miles) Management Action Decommission, Closure Level 3D. Future logging system access would be via skyline from road above (#7636) Decommission, Closure Level 5. Identified aquatic concerns on existing segment. Segment not needed due to proposed new construction Change travel management designation from Open Yearlong to Open Seasonally Map Code D Decommission, Closure Level 3D Add to System: Store Level 3S-N; Long-term access Add to System: Yearlong Closure Map Code A; Long-term access Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3D Add to System: Store Level 3S-N; Long-term access Add to System: Yearlong Closure Map Code A. Power line access road Add to System: Store Level 3S-N; Long-term access Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN Decommission, Closure Level 3DN BMP = Beginning mile point EMP = End mile point 77

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83 Appendix C Soils Tables C-1 through C-3 summarize the estimated detrimental soil disturbance (DSD) for Alternative 2 associated with harvest activities by unit for skyline, tractor, and excaline methods. Region 1 Soil Quality Standards identifies a threshold of 15 percent DSD as a guideline for maintenance or loss of soil productivity and to show compliance with the National Forest Management Act. Predictions of additional DSD from project activities are estimates based on best available science. For more information, see the Soil report and supporting documentation in the Project File. Table C-1: Skyline Harvest Soil Disturbance Estimate Potential DSD (%) Unit Current DSD (%) From Vegetation Management (including skid trails, landings, mitigations) From Post- Harvest Activity (site prep or fuels treatments) From Temp Roads Cumulative DSD without Rehabilitation (%) DSD Reduction from Rehabilitation (%) Total Estimated Post- Activity Short-term DSD (%) 2 0% 2% 0% 3% 5% 3% 2% 3 0% 2% 0% 0% 2% 0% 2% 4 1% 2% 0% 0% 3% 0% 3% 6 1% 2% 0% 0% 3% 0% 3% 7 0% 2% 0% 0% 2% 0% 2% 10 6% 2% 0% 0% 8% 0% 8% 11 0% 2% 0% 0% 2% 0% 2% 12 0% 2% 0% 0% 2% 0% 2% 13 0% 2% 0% 3% 5% 3% 2% 14 0% 2% 0% 1% 3% 1% 2% 15 8% 2% 0% 0% 10% 0% 10% 16 5% 5% 0% 0% 10% 0% 10% 17 0% 2% 0% 0% 2% 0% 2% 18 1% 2% 0% 0% 3% 0% 3% 19 2% 2% 0% 0% 4% 0% 4% 21 0% 2% 0% 0% 2% 0% 2% 22 0% 2% 0% 0% 2% 0% 2% 24 3% 2% 0% 0% 5% 0% 5% 25 0% 2% 0% 0% 2% 0% 2% 79

84 Table C-2: Tractor Harvest Soil Disturbance Estimate Potential DSD (%) Unit Current DSD (%) From Vegetation Management (including skid trails, landings, mitigations) From Post- Harvest Activity (site prep or fuels treatments) From Temp Roads Cumulative DSD without Rehabilitation (%) DSD Reduction from Rehabilitation (%) Total Estimated Post Activity Short-term DSD (%) 23 3% 9% 1% 0% 13% 0% 13% 26 1% 9% 1% 0% 11% 0% 11% 27 15% 9% 0% 0% 24% 10%* 14% *See unit-specific rehabilitation plan for Unit 27, below. Table C-3: Excaline Harvest Soil Disturbance Estimate Unit Current DSD (%) From Vegetation Management (including skid trails, landings, mitigations) Potential DSD (%) From Post- Harvest Activity (site prep or fuels treatments) From Temp Roads Cumulative DSD without Rehabilitation (%) DSD Reduction from Rehabilitation (%) Total Estimated Post Activity Short-term DSD (%) 20 0% 6% 1% 0% 7% 0% 7% Unit-Specific Rehabilitation Plan Rehabilitation of soil resources ties to direction in the Lolo Forest Plan, NFMA, and the R1 soil quality standards. The use of rehabilitation techniques in site-specific instances would move areas of soil disturbance towards improved site potential at a faster rate than if no rehabilitation techniques are used. It is estimated that rehabilitation would reduce soil and forest floor recovery to approximately years. Without rehabilitation, recovery of soil and forest floor process and function would be expected to take greater than 40 years. Work in Canada has shown that soil restoration techniques, when prescribed on a site-specific basis, will reduce the effects of equipment used on the soil resource (BC Ministry of Forestry 2000, 2002). For techniques to be effective, soil texture, soil moisture, organic matter content, and erosion potentials must be considered. Rehabilitation actions would be effective at breaking up the area extent and magnitude of detrimental soil disturbance and provide for improved aeration and hydrologic function within the soil. Rehabilitation actions start the ultimate goal of soil restoration; that is to provide the building blocks from which soil organisms and plants can continue to modify and build soil structure and chemistry. By providing these building blocks, R1 soil quality standards are met since steps have been made to move the treatment units towards improved soil and site condition. Promoting biologic activity is the best way to remediate damaged soils (Powers 1990). 80

85 Slash Placement in Units Unit 27, Slash on Skid Trails and Landings Rehabilitation techniques include: slash (less than 6 inches diameter preferred) would be placed by the harvesting contractor on main skid trails close to the landings where bare mineral soil is exposed. Slash would cover at least percent of the disturbance to a depth of 2-3 inches (approximately tons/acre). Coverage would be measured at the time of placement. Ensure contact with the soil surface. In this unit, slash would be placed by purchaser agreement in lieu of waterbars as part of timber harvest operations to control erosion as well as to provide organic matter for forest floor function (Table C-4). Slash placement is a required mitigation to meet regional and national soil policy in Unit 27. If purchaser opts to install waterbars instead of slash placement, slash would be placed using alternative funding. Table C-4: Acres of Skid Road Required for Slash Placement by Unit Unit Acres Existing Skid Road Rehabilitation and Landing Rehabilitation (Unit 27) Rehabilitation may include a combination of the following techniques: Machine scarify the soil surface to break up any hydrophobic layer. This can be accomplished by ripping or excavator scalloping of the skid trail and horse logging rut surface. Re-contour previously excavated and graded material back across the landing site to reestablish natural contours. Re-spread the surface soil back over the scarified or re-contoured landing, if topsoil has been saved. Add additional inoculate to the site by taking a hand shovel or two of surface soil and humus (gather no more than 1-2 inches of surface soil) from a nearby, undisturbed area, spread the material over the site. Work this inoculate into the burned area by hand or machine scarifying. Again, avoid turning the soil. Seed with grasses and forbs or plant shrubs/trees on the site. Place slash, both fine woody material (needles and small branches) and coarse woody material (material greater than 3 inches in diameter) over the site, cover at least 60 percent of the landing to a depth of 2-3 inches. Ensure slash contact with the soil surface. Measure coverage at the time of placement. Table C-5: Acres of Existing Skid Road Obliteration, and Landings Planned for Rehabilitation, by Unit: Unit Acres skid obliteration 2 - landing rehab Planting in Units Planting is required for rehabilitation in Unit 27, other units would be planned for planting as funding allows. The units would be planted with trees by hand after harvest and post-harvest activities are complete. 81

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87 Appendix D Science Basis for Restoration Treatments An assortment of scientific literature forms the basis for restoration activities within this project and provides guidance for managing for resilient, fire, insect and disease tolerant forests. A consensus exists in describing changes both in wildfire severity and insect and disease effects in low- and mixed-severity fire regimes resulting from past management including fire suppression. Examples are provided below: Graham et al. 2004: Millions of acres of forestland (mainly in dry forests dominated by ponderosa pine and/or Douglas-fir) contain a high accumulation of flammable fuels compared to conditions prior to the 20 th century. Low severity fires prior to the 20 th century burned regularly in most dry forest ecosystems. They controlled regeneration, promoted fire-tolerant species, maintained open forest structures, reduced forest biomass, and decreased the impacts of insects and diseases. With fire suppression, dense forest structures developed with homogeneous and continuous horizontal and vertical stand structures. These changes in structure and composition have dramatically altered how wildfires now burn in these forests from how they burned historically. Reinhardt et al. 2008: It is generally accepted that past management practices including the successful suppression of many wildland fires in some western United States ecosystems over the last 70 years have resulted in excessive accumulation of surface and canopy fuels which have, in turn, increased the potential for severe fires. Agee and Skinner 2005: A one-size-fits-all fire exclusion policy was applied to all forests. Protected forests soon had more tree regeneration, and the early fires were easy to suppress with generally light fuel loading. Selective removal of large, fire-resistant trees added to the problem, so that by the late 20 th century, we had widespread continuous forests with, on average, smaller trees and much greater fuel loads. Areas that were once forest openings became forested. Fires that once spread as surface fires were now more intense, and capable of jumping into the canopy of the forest as crown fires. This problem continues unabated into the 21 st century, not only in high elevation or wet forests where that type of behavior was characteristic, but widely across all forest types. Peterson et al. 2005: Prior to the 20 th century, low-intensity fires burned regularly in many arid to semiarid forest ecosystems, with ignitions caused by lightning and humans. Lowintensity fires controlled regeneration of fire-sensitive species (e.g., grand fir), promoted firetolerant species (e.g., ponderosa pine, Douglas-fir, western larch), and maintained a variety of forest structures including a higher proportion of low-density stands than currently exists. These fires reduced fuel loading and maintained wildlife habitat for species that require open stand structure. Lower density stands likely had higher general vigor and lesser effects from insects. In many areas, fire exclusion has caused the accumulation of understory vegetation and fuel, greater continuity in vertical and horizontal stand structure, and increased potential for crown fires. Across any particular landscape, there were probably a variety of stand structures, depending on local climate, topography, slope, aspect, and elevation. Noss et al. 2006: Topographically complex western mountain landscapes may be especially prone to mixed-severity fire, because drier south-facing slopes with lower fuel loads can burn 83

88 at low severity when adjacent, moister north-facing slopes that support higher tree densities experience high-severity fire. The inherent variability of mixed-severity fire regimes precludes easy detection and analysis of the effects of fire exclusion. Exclusion of fire may have allowed tree densities to increase in some areas but post-fire tree density is naturally high in patches killed by high-severity fire. These are often very complex landscape mosaics; hence, it is necessary to plan and conduct activities at larger spatial scales. The consequences of many human activities including fire exclusion, logging, tree planting, and livestock grazing are most serious in forest types that historically were characterized primarily by low-severity fires. These surface fires killed few large, fire-resistant trees but killed many smaller trees of all species, helping to maintain open-canopied stands of large old trees. Human activities since European settlement have dramatically modified the fuel structure in these forests. Hessburg et al. 2005: Fire prevention and suppression still persist to this day. While well intentioned, such suppression compounds problems of advancing secondary succession and the extreme fire intolerance and high contagion of large expanses of dry forest. Small fires, if they had been allowed to burn in the early 20 th century, or were intentionally lit, would have broken up the dry forest, thereby reducing the size of the area influenced by uncontrolled wildfires in the modern era. These authors and others including Baker and Williams (2015), Odion et al. (2014), Schoennagel et al. (2004), and Schoennagel et al. (2016) recommend a variety of management practices to restore resilience to stands and landscapes including providing for open stands, age class diversity, and retention of fire-tolerant trees through a variety of mechanical and prescribed burning treatments. Clarifications to the frequent low-severity fire model with its image of pre-20 th century forest with widely spaced, mature trees (often old growth) over a grassy or herbaceous forest floor are highlighted by Baker et al. (2006), Baker et al. (2001), Baker and Williams (2015), Odion et al. (2014), Sherrif et al. (2014), and Williams and Baker (2014). A variable-severity model may be more appropriate given that dry ponderosa pine forests across the western United States historically experience high-severity fire as well. In this model, natural fires vary in severity and frequency, sometimes burning at low severity in surface fuels and sometimes burning as high-severity fires in the crowns of trees, or with a mixture of surface and crown fire. (Baker et al. 2006) These descriptions of variable-severity fire are consistent with the fire regimes described in Fischer and Bradley (1987) for western Montana and the inventory-based description of historical conditions provided by Losensky (1993). Climate Change Observed climate changes over the past several decades in the western United States include increased seasonal, annual, minimum, and maximum temperatures, altered precipitation patterns, and earlier timing of peak runoff. Predicted changes include additional increases in average temperature over the next 50 years, reduced snowpack, and reductions in runoff and natural water storage (Loehman and Anderson 2009). Globally, climatic changes have a generally positive impact on forest productivity when water is not limiting, but fine-scale trends are difficult to ascertain (Boisevenue and Running 2006). The vigor and sustainability of forest ecosystems are compromised by biotic and abiotic stress complexes. In western North America, increased water deficits accelerate the stress complexes that normally involve some combination of multi-year drought, insects, and fire (McKenzie et al. 2007). Bark beetles respond to changing climatic conditions. A changing climate, including elevated temperatures (higher winter minimum and summer maximum temperatures), drought, and elevated carbon dioxide, can directly affect bark beetle development time and survival and perhaps affect hosttree allocation patterns (Raffa et al. 2008; Six et al. 2014). Responses to warming will differ among 84

89 and within bark beetle species because of differences in temperature-dependent life history strategies such as cold-induced mortality and developmental timing. Indirect effects include changes in host-tree vigor and effects on community associates (Bentz et al. 2010). Stress complexes are also regionspecific. In the northern Rockies, bark beetles are proliferating and killing millions of acres of forest, setting up the prospect of large, intense fires. The effects of stress complexes will be magnified in a warming climate, so increases in fire superimposed on increased drought and insects may have significant effects on growth, regeneration, distribution, and abundance of forest species (McKenzie et al. 2007). Climate change and bark beetle population models suggest a movement of temperatures suitable for beetles to proliferate to higher latitudes and elevations in the coming century (Bentz et al. 2010; Six et al. 2014). Tree species distribution is affected by climate. Climate change is expected to affect forests both by movement of suitable environmental conditions and by altering disturbances. Geographic ranges for many tree species are expected to shift northward (Fule 2008). Western larch forests, for example, go through natural cycles of succession, maturity, demise, wildfire, and regeneration. A changing climate will affect each process, starting with demise as plants become more poorly adapted to the climate at the site where they are growing. This demise coupled with a warmer and drier climate provides fuel for wildfire of increasing frequency and severity. The wildfire provides conditions for regeneration of seral species such as larch. Local seed sources may not be best suited for regeneration under changed and changing climatic conditions (Rehfeldt and Jaquish 2010). Variability of climate affects large wildfires in the western United States. Associations between large fire occurrence and quasi-periodic climatic patterns (e.g. El Nino Southern Oscillation, Pacific Decadal Oscillation) are evident in some regions but difficult to establish in others. While at the regional scale extreme fire weather is the dominant influence on area burned and fire severity, increased temperatures in the future likely will result in more fires occurring earlier and later than is typical and will increase the total area burned in some regions (McKenzie et al. 2004). The eleven years when annual fire extent in western Montana and Idaho exceeded the 90 th percentile were concentrated in and when warm springs were followed by warm, dry summers and the Pacific Decadal Oscillation was positive, which resulted in longer fire seasons. The long period of of lesser fire extent generally had cool springs, negative Pacific Decadal Oscillation, and a lack of extremely dry summers which contributed to successful active fire suppression. The relationship between climate and large fire extent is consistent with previous centuries in the region, suggesting a strong influence of spring and summer climate on fire activity despite major land-use change and fire suppression efforts. Pierce et al. (2004) showed that millennial-scale climate changes influenced fire behavior. Ponderosa pine forests experienced frequent low-severity fires in colder periods measured in centuries, while warmer periods resulted in severe droughts and stand-replacing fires. Climate projections for warmer springs and continued warm, dry summer suggest forests of the northern Rockies are likely to experience synchronous large fires in the future (Morgan et al. 2008), which Baker (2015) suggests will approach historical scales. Reference conditions in a broad sense are useful because they encompass the recent past and evolutionary history. A long-term functional view of reference conditions can provide insights into past forest adaptations and migrations under various climates. Restoration of patterns of burning and fuels and forest structure that reasonably emulate pre-fire exclusion historical conditions is consistent with reducing the susceptibility of these ecosystems to catastrophic loss. Priorities may include fire and thinning treatments of upper elevations to facilitate forest migration (Fule 2008). 85

90 Wildfire Behavior There is abundant literature on fire behavior, forest structure, forest fuels, fire weather, and other aspects of fuels management. For this discussion of effects, references are limited to some of the more recent publications that for the most part summarize generally accepted principles and caveats from other research study-based and peer reviewed publications. This is appropriate because short of removing all potential fuel from a site, potential fire behavior (intensity) and severity (effect) are dependent on the interaction between fuel, weather, and physical setting (Jain and Graham 2004; Graham et al. 2004). Of those three factors, the only thing humans can alter through management is fuel. Any particular wildfire s growth and behavior is unique because of the infinite combinations of weather, fuels, and physical settings that can occur over spatial and temporal scales (Graham et al. 2004). Fire behavior is typically described at the stand level, but the spatial arrangement of stands across landscapes affects the growth of large fires (Graham et al. 2004). These variables make it difficult to speak to fire behavior with specificity and certainty. Models exist to predict fire behavior under specific defined conditions, but for each modeled condition there exists infinite unmodeled conditions that may occur when a fire actually starts or spreads to an area. There are, however, useful general concepts concerning the effects of fuels on fire behavior (Agee and Skinner 2005; Graham et al. 1999; Graham et al. 2004; Peterson et al. 2005) as discussed below. Forest fuel structures typically can be classified as three strata: ground fuel, surface fuel, and crown or canopy fuel (Graham et al. 2004; Agee and Skinner 2005; Peterson et al. 2005; Graham et al. 1999). Ground fuel consists of duff, roots, buried woody material, and accumulations of needle fall and bark sloughs (Graham et al. 2004). Ground fuels typically burn by smoldering that may last many hours to months (Peterson et al. 2005), leading to soil damage and tree mortality (Graham et al. 2004; Peterson et al. 2005). Rotten ground fuel is ignitable by firebrands thrown ahead of a fire front, which increases spotting of small fires (Graham et al. 2004). Surface fuel consists of grasses, shrubs, litter, and woody material (Graham et al. 2004) such as sound and rotten logs and stumps (Peterson et al. 2005). Surface fuels release energy at highly variable rates ranging from high rates during a relatively short period when fine fuels are flaming and low rates during a longer period when smoldering and glowing combustion consumes larger fuel (Graham et al. 2004). High loadings of surface fuel resulting from blowdown, ice storms, timber harvest, or precommercial thinnings have high surface fire intensity that increases the likelihood for igniting overstory crown fuels either through direct ignition or by drying overstory fuels, which leads to torching (Graham et al. 2004). Crown fuel consists of vines, mosses, needles, branches, and so forth suspended above the ground in trees or other vegetation (Graham et al. 2004). This material is available for crown fires that can be propagated from surface fires through fuel ladders of vertically continuous surface and crown fuels or from crown to crown fire spread (Graham et al. 2004). Crown fuels separated from surface fuels by large gaps are more difficult to ignite because of the distance above surface fires (Graham et al. 2004). Crown fuels require higher intensity surface fires, long duration surface fires that dry the crown fuels, or mass spotting over a large area to ignite (Graham et al. 2004; Agee and Skinner 2005). Once ignited, high density crown fuels are more likely to spread than low density crown fuels (Graham et al. 2004; Agee and Skinner 2005; Peterson et al. 2005). The presence and density of overstory tree canopies influence surface fuel conditions and burning. Fires burning in open stands have increased rate of spread compared to fires in dense stands under similar conditions due to fine fuel moisture content, surface air temperature, and shading (Graham et 86

91 al. 2004). Open stands also develop fine fuels such as grasses, forbs and small shrubs more readily than dense stands. These fine fuels can support more rapid fire spread compared to large woody fuels in dense stands (Graham et al. 2004). The continuity and density of tree canopies combined with wind and physical setting provide conditions for rapidly moving crown fires that consume needles and branches over large areas (Graham et al. 2004). Initiation and propagation of crown fires is related to canopy base height, canopy bulk density (weight for a given volume), and canopy continuity (Graham et al. 2004). Canopy base height affects how readily fire can transition from surface fire to crown fire (Graham.et al. 2004). Patchiness of the canopy can reduce fire spread (Graham et al. 2004). Depending on weather and physical setting, surface fires can rapidly spread through dry grass and other surface fuels igniting tree crowns, especially those with low crowns. This torching can progress from individual and small clumps of trees to large groups within a few hours (Graham et al. 2004). Torching and crown fires produce firebrands that are carried by winds hundreds of feet and even miles (Graham et al. 2004). Subsequent ignitions from firebrands can occur in a process that can be repeated numerous times, producing fire fronts that move many miles in a day (Graham et al. 2004). Fuel treatments to modify fire behavior The intent of fuel reduction in restoration projects is to modify fuels to reduce fire severity so live trees and understory vegetation are retained to provide resilient recovery of the site. To accomplish this, fuels are manipulated to reduce the likelihood of crown fires and reduce the intensity (the rate fuel is consumed and the amount of heat generated) of surface fires. Agee and Skinner (2005) summarized the principles of fire hazard reduction in a table reproduced below: Table D-1: Principles of Fire Hazard Reduction Treatments Principle Effect Advantage Concerns Reduce surface fuels Reduces potential flame length Control easier; less torching Surface disturbance is less with fire than other Increase height to live crown Decrease crown density Keep big trees of resistant species Requires longer flame length to begin torching Makes tree-to-tree crown fire less probable Less mortality for the same fire intensity Less torching Reduces crown fire potential Generally restores historical structure techniques Opens understory; may allow surface wind to increase. Surface wind may increase and surface fuels become drier. Less economical; may keep trees at risk of insect attack Graham et al. (2004) adds reduce continuity of the forest canopy to the list of objective, quantifiable fuel treatment criteria (principles). Peterson et al. (2005) concurs that potentially effective techniques for reducing crown fire occurrence and severity are to reduce surface fuels, increase canopy base height, reduce canopy bulk density, and reduce forest continuity. Jain and Graham (2007) found some notable exceptions to these general concepts when studying over 900 observations in 73 wildfires in the Rocky Mountains. Trees with low canopy base heights (height to live crown) did not have high severity fires in thinned stands, plantations, and other managed stands where surface fuel was modified through slash disposal and site preparation activities. In dense subalpine fir dominated forests with high canopy base heights, burn severity was high because the crowns tend to intercept 87

92 precipitation and evapotranspiration depletes floor moisture, resulting in dry forest floor conditions. These dry conditions coupled with high surface fuel loads caused crown fires. There is a wide variety of well-documented and contrasting views on the effects of thinning on fire behavior (Graham et al. 1999; Carey and Schumann 2003). The contradictory views can be explained in part by the loose use of the term thinning. Knowing exactly what forest treatments are called thinnings can provide more precise predictive power to describe how fires would behave in the resulting stands structures, compositions, and fuels (Graham et al. 1999). This project proposes thinning from below. There are many different kinds of thinnings, thinning regimes, reserve tree regeneration harvests, and combinations that create a wide variety of stand structures or compositions to meet various objectives. Because there are so many possible stand structures and compositions, there are at least as many ways that stands would respond to fire (Graham et al. 1999). The many stand treatments that may or may not be thinnings but are similar to thinnings alter the stand characteristics that directly influence fire behavior. The crowns of trees removed may significantly contribute to surface fuels with a major impact on expected fire intensities depending on whether and how they are treated. Crown bulk density, which depends on both species composition and stand density, is the primary controlling factor of crown fire behavior (Graham et al. 1999). Crown fires are often considered the primary threat to forest types and human values, and crown fires are the primary challenge for fire management (Graham et al. 2004). Depending on the type, intensity, and extent of thinning or other treatment, fire behavior can be improved or exacerbated (Graham et al. 1999; Graham et al. 2004; Peterson et al. 2005). Thinnings in general would lower crown bulk densities and redistribute fuel loads, thus decreasing fire intensities if the surface fuels are treated. Extreme weather conditions can create fire behavior that would burn through or breach most fuel treatments (Graham et al. 2004). Realistic objectives for fuel treatments include reducing the likelihood of crown fire and other fire behavior that would lead to undesirable future conditions (Graham et al. 2004). Because surface fuels are drier due to exposure to heat and wind and wind speed is increased in thinned stands, it is critical that surface fuels be treated to minimize fire intensity (Graham et al. 1999; Agee and Skinner 2005; Graham et al. 2004; Peterson et al. 2005). There are numerous studies supporting this. More recent studies include Cram et al. (2006), which found that in ponderosa pine forests of New Mexico and Arizona, wildfire severity was reduced in all treated stands compared to untreated stands. Thinning followed by burning was most effective at reducing fire intensity, followed by piling and burning. Lopping and scattering slash had the least effect on reducing fire intensity. Omi et al. (2006) found wildfire severity was often reduced by treatments in Colorado, Arizona, California, Oregon, and Washington. Treatments that included reduction of surface fuels were generally effective, with or without treatment of canopy fuels, but thinning followed by slash treatments produced the most impressive reduction in fire intensity and severity. Thin-only treatments were generally ineffective and in some cases produced greater fire severity than untreated areas. Treatments that included reducing surface fuels were effective up to ten years. On the other hand, Raymond and Peterson (2005) studied two sites burned in the Biscuit Fire in southwest Oregon and found that thinning without treating surface fuels resulted in the highest mortality. Lower mortality was found in untreated stands, and the least mortality was found in stands that were thinned and underburned. Carey and Schumann (2003) summarize a number of studies pointing out the effectiveness of thinning with effective surface fuel treatments and the mixed results of thinning without surface fuel treatments. Thinning from below (as proposed in this project) and possibly free thinning can most effectively alter fire behavior by decreasing fire intensity (Graham et al. 1999). Low thinning (thinning from below) 88

93 removes trees from the lower canopy, leaving large trees. Free thinning (crop-tree thinning) releases selected trees while not treating the rest of the stand. Crown thinning and selection thinning would not reduce crown fire potential because they leave multiple canopy layers (Graham et al. 1999). Crown thinning (thinning from above) removes dominant and codominant trees from the canopy to favor residual trees in the same classes. Selection thinning removes dominant trees to favor smaller trees. Peterson et al. (2005) summarized the effects of thinning treatments on key components of canopy structure related to crown fire hazard in a table reproduced below: Table D-2: Effect of Thinning on Key Components of Canopy Structure Thinning Treatment Canopy Base Canopy Bulk Density Canopy Continuity Height Crown Minimal Lower in upper canopy but minimal effect in lower canopy Low Large increase Large effect in lower canopy, some effect in upper canopy depending on tree sizes removed Selection None Lower in upper canopy but minimal effect in lower canopy Free Geometric (Mechanical*) Variable Density Small to moderate increase, depending on trees removed None Increase in patches where trees are removed *Referred to as Mechanical in Graham et al Small to moderate decrease throughout canopy, depending on trees removed Small to moderate decrease throughout canopy, depending on spacing and species composition Decrease in patches where trees are removed Lower continuity in upper canopy, but minimal effect in lower canopy Large effect in lower canopy, some effect in upper canopy depending on tree sizes removed Lower continuity in upper canopy but minimal effect in lower canopy Small to moderate decrease throughout canopy, depending on trees removed Small to moderate decrease throughout canopy, depending on spacing and species composition Moderate to large decrease Overall Effectiveness May reduce crown fire spread slightly but torching unaffected Will greatly reduce crown fire initiation and torching May reduce crown fire spread slightly if many trees removed but torching unaffected May reduce crown fire spread slightly if many trees removed; torching reduced slightly Crown fire spread and initiation reduced if spacing is sufficiently wide; torching reduced Crown fire spread reduced, crown fire initiation reduced somewhat; torching reduced somewhat Prescribed burning reduces loading of fine fuels, duff, large woody fuels, rotten material, shrubs, and other live surface fuels that affect spread rate and intensity (Graham et al. 2004). Burning reduces horizontal fuel continuity and disrupts growth, intensity, and spot fire ignition probability of surface fires. Prescribed burning designed to reduce ladder fuels decreases the vertical continuity between surface and canopy fuels. It also scorches the lower branches of trees and effectively raises the live crown base height. Prescribed burning has potential challenges, too (Peterson et al. 2005). Individual and clumps of trees may be killed that were not targeted. Fallen dead branches and boles then can increase surface fuel loads. 89

94 Thinning and prescribed burning can modify understory microclimate by allowing increased solar radiation to reach the forest floor, which increases surface temperatures, decreases fine fuel moisture, and decreases relative humidity compared to untreated stands (Graham et al. 2004). These conditions can increase surface fire intensity. All fuel strata need to be managed over time and space to minimize unwanted consequences of wildfire (Graham et al. 2004). There are few studies evaluating the longevity of fuel treatments and their effectiveness at altering fire behavior over time. Various studies have shown that effectiveness of prescribed burning alone decreases significantly over 10 to 20 years (Graham et al. 2004). The longevity of fuel treatments varies with climate, soils, and other factors. The longevity of fine woody fuels from thinning slash is greater on drier sites than on moister sites. Effects likely last longer in areas where vegetation development is slower than in highly productive areas (Graham et al. 2004). There are several ways fuel treatments could exacerbate wildfire hazard (Keyes and Varner, 2006). Thinning transforms live canopy fuels to dead surface fuels that must be burned or removed. Slash generated from thinning inflates fuelbed depth unless treated. Reducing canopy cover can facilitate drying of dead surface fuels. Thinning can increase subcanopy wind speed, resulting in higher rates of spread and potentially erratic fire behavior. Thinning increases sunlight and wind on the forest floor, resulting in drier duff. Hardwoods and shrubs can stump sprout prolifically, effectively relocating elevated live fuels to the forest floor level. Soil disturbance from thinning can disturb soils and encourage seedling regeneration. Advance regeneration can be released after thinning, resulting in greater vertical continuity of fuels. Thinning increases light available to overstory trees so lower branches are retained longer, compared to lower limbs dying in denser stands and effectively raising crown base height. Fuel management treatments should be designed to minimize these adverse effects, and they should be designed with future maintenance treatments in mind (Keyes and Varner 2006). A much more thorough discussion of the benefits, opportunities, and trade-offs of fuel treatments in dry mixed-conifer forests that includes this literature and much more is in A Comprehensive Guide to Fuel Management Practices for Dry Mixed Conifer Forests in the Northwestern United States (Jain et al. 2012). Although we have a good general understanding of the factors that govern fire behavior, the interactions between the factors and the way fire behaves on a landscape are complex. Fire behavior and severity can be understood and predicted in general terms, but exact predictions are not possible (Graham et al. 2004). Given this complexity, focusing on basic scientific principles is important for decision-making and adaptive management over time (Peterson et al. 2005). Bark Beetle Susceptibility Western pine beetle populations can reach outbreak levels when ponderosa pine is moisture stressed (Randall 2004). In the first half of the twentieth century, stands of large, old, decadent ponderosa pine were killed by western pine beetles. Large, old, slow-growing ponderosa pine are very susceptible to attack. Large old ponderosa pines surrounded by second growth mixed conifer stands are susceptible. Lately western pine beetles have been aggressively attacking young second growth stands. Trees are usually killed in groups, usually in stands of dense, over-stocked, even-age ponderosa pine but also in clumps of ponderosa pine in mixed-conifer stands. Two systems to identify western pine beetle hazard have been developed: one to identify susceptible trees and one to identify susceptible stands (Randall 2004). Individual tree hazard is based on age, crown size, and dominance. Older trees with poor, thin crowns and slow growth rates are most likely to be attacked and killed by the beetle. Stand hazard is based on the average diameter of ponderosa 90

95 pine trees over 5 inches at dbh (diameter at breast height: 4.5 feet above the ground), stand structure, and the percent basal area of ponderosa pine in the stand. Even-aged stands with more than 120 square feet of basal area per acre of ponderosa pine trees averaging over 10 inches dbh are most likely to be attacked and killed by the beetle. Mountain pine beetles are attracted to pine trees. A female beetle will land on the tree, begin to tunnel, and release an aggregation pheromone to attract other beetles to the tree. If enough beetles respond, the tree can be overwhelmed in a short time. At this point, the tree will not recover and will die slowly. Outbreaks occur when multiple thresholds involving temperature, host tree abundance and defenses, and beetle brood productivity are surpassed. The primary elements for an outbreak are abundance of suitable hosts and a trigger: warm weather and drought. (Six et al. 2014) Mountain pine beetles typically attack only pines larger than 6 inches dbh (Six et al. 2014). Lodgepole pine trees over 10 inches tend to be preferred by mountain pine beetles, and they produce brood that attack trees less than 10 inches (Fettig et al. 2013). There are many hazard rating systems, and they commonly are based on the proportion of lodgepole pine over 7 to 8 inches dbh, stand density, and stand age over 80 years. Ponderosa pine trees between 5 and 13 inches tend to be preferred by mountain pine beetles (Fettig et al. 2013). Hazard rating systems for ponderosa pine vary and tend to be based on tree size, stocking levels, and stand structure. Forests comprised mainly of larger diameter pine with homogeneous structure and composition can contribute to the extent and severity of an outbreak once it is initiated. Restoration treatments focused on restoring diverse structures and age classes tend to reduce outbreak severity and extent (Fettig et al. 2013; Six et al. 2014). Douglas-fir beetles are attracted to wind-throw and trees weakened by fire, drought, defoliation, or root disease (Kegley 2004). Douglas-fir beetle populations expand rapidly in these conditions and subsequent generations attack and kill surrounding healthy green trees. As beetles are forced into increasingly healthier trees, populations decline. Outbreaks typically last from 2 to 4 years. Outbreaks are associated with dense stands, usually with trees over 120 years old. Stand-level Douglas-fir beetle hazard is based on stand density, percent of Douglas-fir, average stand age, and the average diameter of the Douglas-fir (Kegley 2004). Highest hazard stands are more than 250 square feet of basal area per acre, more than 50 percent Douglas-fir, greater than 120 years old, and greater than 14 inches average dbh (Weatherby and Their 1993). Treatments to modify bark beetle susceptibility Preventing western pine beetle-caused damage in ponderosa pine stands is accomplished by reducing the conditions considered as stand hazards (Randall, 2004). Thinning to reduce the density and increase the vigor of the residual trees results in lower losses to western pine beetles. Thinning to about 90 to 100 square feet per acre is effective, which generally results in removing enough trees so the tree crowns don t touch. Tree removal should focus on trees weakened by defoliation, root disease, lightning, fire, mechanical injury, breakage, attack by other beetles, or root damage. Creating a mosaic of age, size class and species of trees across the landscape is the best approach to long-term mountain pine beetle management (Forest Health Protection MFO-TR-11-22; Fettig et al. 2013; Six et al. 2014). Although many stands of ponderosa pine have historically grown in an uneven-aged clumpy distribution, the historical basal areas of these stands were often significantly less and kept in check with frequent ground fires. This clumpy distribution along with single tree and openings resulted in forest resiliency and reduced susceptibility to mountain pine beetles (Kolb et al. 2007). Mountain pine beetles may still attack clumps of pines throughout an area during an outbreak, but the cumulative amount of mortality in thinned areas should be less. Although some clumps of pine can be retained, the number of clumps retained is related to the amount of potential mortality in the 91

96 units. Whitehead and Russo (2005) and Whitehead (2010) showed that thinning without spacing targets can leave a clumped distribution of residual trees that remain susceptible to bark beetle-caused tree mortality. (Forest Health Protection MFO-TR-11-22) During the recent mountain pine beetle outbreak on the Helena National Forest in ponderosa pine, mountain pine beetles first became active in clumps and eventually clumps of beetle-killed trees coalesced. There was no mountain pine beetle activity in the thinned approximately 300 acre unit while significant mortality from mountain pine beetles occurred in the adjacent uncut unit. (Forest Health Protection MFO-TR-11-22) Figure D-1: Mountain pine beetle activity in a thinned and adjacent unthinned stand on the Helena National Forest. The thinning was completed two years prior to the outbreak in that drainage. In uneven-aged stands, competition from a dense understory resulting from fire suppression may stress older trees predisposing them to beetle attacks. Thinning can reduce bark beetle caused tree mortality by reducing tree competition and changing the micro-climate of a stand. Large trees are more likely to survive if moisture availability improves. Also individual trees can be protected when the microclimate is altered which can negatively affect beetle overwintering survival and reduce beetle attacks on trees (Leslie and Bradley 2001). (Forest Health Protection MFO-TR-11-22) Stand susceptibility to mountain pine beetles can also be reduced by lowering stocking densities to targets relative to site carrying capacity. During the current mountain pine beetle outbreak, Oneil (2006) found that the majority of plots attacked by mountain pine beetles were above site carrying capacity as compared to the plots not attacked which were below site carrying capacity. Carrying capacity was a significant predictor even during times of drought. Oneils work showed that thinning to a basal area target that does not consider carrying capacity would not reduce susceptibility to mountain pine beetle attack under current climate conditions. (Forest Health Protection MFO-TR-11-22) Treatments aimed at reducing the mid-story may also result in less mountain pine beetle-caused tree mortality following fire. Fire injury can sometimes predispose trees to attack by bark beetle if there is beetle pressure within the treatment unit. Larger, old growth trees often suffer more from fire effects and thinning than mature pines and therefore can be more susceptible to bark beetle following prescribed fire (Kolb et al. 2007). (Forest Health Protection MFO-TR-11-22) Likewise in lodgepole pine forests, age-class structure and species composition influence outbreak intensity and severity. Creation of age and size class mosaics ultimately reduce impacts from mountain pine beetles. Thinning reduces host availability, reduces competition between trees to increase vigor, and affects microclimate. Thinning from above reduces stand susceptibility by 92