Responsible Official: Monte Williams, Forest Supervisor, Arapaho and Roosevelt National Forests and Pawnee National Grassland

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1 January 9, 2017 Roosevelt National Forest Boulder Ranger District Attn: Objection Reviewing Officer: Brian Ferebee Lead Objector: Lisa Mayhew Hynek 38 Wildewood Dr. PO Box 715 Nederland, CO Objectors (physical address, address, date of last comment submission): Brian Hynek, 38 Wildewood Dr & 66 Wildewood Dr, 28 January 2016 Emory Smith, 44 Wildewood Dr, 22 January 2016 Alice Bosma, 32 Wildewood Ln, 25 January 2016 Paul Bosma, 32 Wildewood Ln, 25 January 2016 Mary Hughes, 31 Wildewood Dr, 23 January 2016 Jeremiah Fitzer, 42 Doe Trail, 29 January 2016 Jessica Fitzer, 42 Doe Trail, 28 January 2016 Tania Corvalan, 218 Alpine Dr, 19 January 2016 Pedro McMillan, 244 Big Springs Dr, 24 January 2016 Ruth Wharton, 244 Big Springs Dr, 28 January 2016 Project name: Forsythe II Responsible Official: Monte Williams, Forest Supervisor, Arapaho and Roosevelt National Forests and Pawnee National Grassland This objection to the USFS Forsythe II Project is being written to specifically address concerns about planned treatments within Unit 2 of the project, as defined in the Draft Decision released on December 8, Unit 2 is defined as a Lodgepole Pine Treatment area. This treatment area directly abuts a number of parcels of private property along Peakview Dr, Wildewood Dr, Wildewood Ln, and Doe Trail within the Big Springs neighborhood in the town of Nederland (~16 as determined by comparing the Forsythe II Draft Decision map to the Boulder County Assessor s office private property map). As a homeowner whose property boundary abuts that of the USFS, and specifically, Unit 2, I have previously commented on the Forsythe I/II project. I submitted comments on 23 January These comments are filed under Lisa Mayhew at the following url: management.org/public//readingroom?project=47358 While I believe that some treatment of the dense, predominantly lodgepole pine forest within Unit 2 is necessary, I have concerns about patch and clear cutting of the forest within Unit 2 considering its extensive boundary with private properties. I initially raised these concerns in the comments I

2 submitted on 23 January Current, specific concerns about the designated treatment plan for Unit 2, as outlined in the Draft Decision, are described below: 1) As stated in my previous comments, I am concerned about the lack of a buffer zone between Unit 2 and private property. As depicted in the Draft Decision map, there is no Defensible Space zone outlined between the private property and the Lodgepole Pine Treatment area of Unit 2*. There are a number of problems with the lack of Defensible Space around Unit 2: a. This directly contradicts one of four main objectives of the Forsythe II Project as listed on page 2 of the Draft Decision Provide private property landowners the opportunity to complete defensible space mitigation around their homes on adjacent NFS lands. I object to private properties within Big Springs being omitted from this project objective. In the Draft Decision, there was no explanation or justification for why homeowners within Big Springs are not afforded the opportunity to extend their defensible space mitigation onto USFS land. b. The removal of this Defensible Space buffer may lead to implementation of patch/clear cuts directly adjacent to private property. In the Environmental Assessment, it is stated in Appendix B. Design Criteria (pg. 190), that Unit boundaries shall be natural edges whenever possible and prevent the appearance of uniform tree spacing and straight line unit boundaries. Straight line boundaries shall be treated by feathering9 and scalloping10. Where feathering is defined as to go from a clearcut or maximum thinned density to existing stand density in 50 to 200 feet in a gradual progression and scalloping is defined as to cut curvilinear edges of varying wavelength and amplitude for example, a short one followed by two long ones, and then a medium one, etc. However, previous work done as part of Forsythe I has not always followed these guidelines (as evidenced by cuts on both East and West Magnolia Roads). I object to the implementation of clear/patchcuts within ft of private property boundaries due to the following negative effects of such a strategy: i. Planned clear/patch cuts will end feet from private property boundaries, with the trees thinned gradually such that the thickest forest is at the private property boundary. I am a participant in the Wildfire Partners Program, as are many of my neighbors. By removing the Defensible Space buffer around Unit 2, the USFS will severely limit my ability to mitigate fire risks, perform informed thinning and promote diverse and fire-resilient spacing in the forest surrounding my property. ii. Eliminate vital wind protection. Having observed the many patchcuts completed in this area over the past decade, nearly every one has experienced significant blowdown of healthy trees around the perimeter of the cut. Patch/clear cutting within 50 ft of private property boundaries will similarly lead to blowdown of the trees remaining on the perimeter of adjacent private property. iii. By drastically decreasing the width of the forest to ~50 to 200 ft around private property, there is increased risk of breaches of private property by members of the public recreating on the (extensive and soon to be official) trail network within Unit 2. Having no concealment of our structures and possessions will lead to increased security risks.

3 iv. Creation of potentially hazardous (and unsightly) slash piles near (as close as 50 ft) private property boundaries and structures. It is my understanding that slash piles adjacent to private property in the Cold Springs area may have led to the destruction of structures during the Cold Springs fire, something that is currently under investigation by the USFS. At a minimum, the minimum distance requirements between slash piles and private property boundaries and structures (#12 under Slash Piles, pg ) needs to be amended prior to cutting. Additionally, we have noticed slash piles from prior clear/patch cutting in this area to remain for years, causing significant fire hazard. v. Property value reduction. People who choose to live in Nederland often do so because they want to live in secluded, forested areas. Clear/patch cutting of the forest to within ft of private property boundaries is likely to lead to devaluation by removing this positive aspect of residing in the Big Springs neighborhood. This has been the case for residents of Magnolia Road whose property borders clear/patch cuts done as part of Forsythe I. This concern was inadequately researched and addressed in the Environmental Assessment document (pgs ). vi. Negative impacts on the quality of life of Big Springs residents who border USFS land. At the time of patch/clear cutting the impact of heavy machinery working at our property boundaries will include times of intense noise and air quality reduction. Afterwards, disturbance to the land surrounding our homes, including torn up soil, ruts, tracks, and slash piles will remain for untold periods of time. I suggest that to remedy these specific negative impacts and this objection, the Forsythe II Project be amended to include a 300 ft Defensible Space around Unit 2 such as included in Alternative 2 of the Forsythe II project. Additionally, Alternative 3 included a Defensible Space designation at the boundary of private property and USFS land. *At a meeting with the Nederland Board of Trustees held on 5 January 2017, Trustee Dallas Masters informed the public that in conversations with Sylvia Clark, USFS Boulder Ranger District, he was assured that a mistaken statement in the Forsythe II Draft Decision would be corrected so that clarification will be made to the Draft Decision to support mitigation efforts on USFS property in designated treatment areas by adjacent private landowners (as in other areas, but was miscommunicated in the Draft Decision) (Dallas Masters, Chair PROSAB, Undated Letter to the Nederland Board of Trustees). Trustee Masters clearly stated at the meeting that this would apply to Big Springs residents whose properties border USFS property slated for treatment as part of Forsythe II Project. However, it is not clear that this will actually be applied to residents whose private property borders Unit 2. The confusion arises from reading Sylvia Clark s recent but undated letter to Trustee Masters in which she states, The defensible space is especially important in this draft decision. We will correct the statement that clarifies that adjacent landowners are able to do this, with permission from the FS, within areas that have been analyzed. The correction will not change the map to create the untreated buffer along all private land boundary, but allows for defensible space work to be completed within the polygons analyzed for treatment. It is unclear which exact statement she is referring to as no specific citation of the Draft Decision was made. I request that the USFS clearly define a Defensible Space Zone between private property and Unit 2 and that this provision is made in writing in the text of the Forsythe II Project Decision, included on the map, and distributed to the public.

4 2) Much of the terrain within Unit 2, and directly abutting private property boundaries, consists of steep, north facing slopes. The one to ten acre patch and clear cuts planned for the Lodgepole Pine Treatment areas, if situated on these north facing slopes, will lead to increased soil erosion and could lead to increased overland flow and flooding into private property at the base of these slopes. I object to the planned clear/patchcuts on north-facing slopes that will lead to increased erosion and overland flow. To remedy this objection, I suggest that the USFS does not clear/patchcut on the north-facing slopes or that design criteria be included to minimize these effects. If the USFS chooses to adapt design criteria to minimize such effects, I request that an explanation of these criteria and how they will address erosion be clearly stated in the Forsythe II Project Decision. This issue was not adequately addressed in the Draft Decision. 3) While the vast majority of Unit 2 is lodgepole pine forest, there are significant areas where a diversity of other conifer species (e.g. Douglas Fir, Ponderosa Pine, Limber Pine, Englemann Spruce) and aspens are present in relatively high densities. The wording of the Draft Decision makes it unclear if these diverse areas will be spared from patch and clear cuts. Specifically, I object to the following wording included in the description of how Lodgepole Pine Stands will be treated (Draft Decision, pg. 5) Mixed conifer species may be retained in patchcuts or clearcuts if there is minimal potential for blowdown when the remainder of the stand is cut. This implies that the default position of the USFS will be to cut the mixed conifer species even though they are rare and valuable to the health (and healthy regrowth) of Unit 2. Additionally, the USFS has not defined minimal potential for blowdown or conveyed to the public how the logging contractors will be monitored to ensure that they accurately determine which trees are at minimal risk for blowdown. To remedy this objection, I suggest that the USFS change the wording of this statement from may be retained to will be retained. Further, I suggest that the USFS identifies areas of species diversity within Unit 2 (as well as Unit 1 and especially Units 3 and 4 which have extensive mixed conifer areas) and agrees not to include them within the borders of planned clear/patch cuts. I also suggest that a minimally thinned lodgepole buffer be kept around mixed conifer stands to help prevent blowdown within the mixed conifer. I further suggest that residents of the Big Springs neighborhood are invited to participate in an oversight committee that works with the USFS during the planning stages of the patch/clear cuts to ensure that diverse conifer species are not included within areas planned for cutting. At a meeting with the Nederland Board of Trustees held on 5 January 2017, Trustee Dallas Masters informed the public that Sylvia Clark, USFS Boulder Ranger District, would be encouraging and supportive of such community participation. 4) On the basis of prior, firsthand experience, I am concerned that contrary to what is written in the Draft Decision, the patchcuts/clearcuts will not be maintained. In the past, lodgepole forests that are either a part of the current Unit 2, or adjacent to Unit 2 (it s very difficult to tell accurately from the map provided in the Draft Decision) have been patch/clear cut. These areas quickly regrew into doghair stands of young lodgepole pine trees. No maintenance occurred and these treated areas are now growing back into problematic, dense lodgepole forests, as evidenced by the inclusion of many of these areas in the Draft Decision as Units 85-95, which are slatted for regeneration thinning treatment. This not only defeats the purpose of the treatment but also increases wildfire risk. As

5 many of these young lodgepoles are adjacent to the surrounding mature lodgepole forest, they now can act as ladder fuels. Furthermore, the understory in these previously cleared areas now include tall grasses and mullen, that were not present in the mature lodgepole forest prior to cutting, that quickly dry out and can act as surface fuels. There is also a significant increase in wind speeds across the cut areas. To remedy my objection to increased fire danger due to neglected clear/patchcuts, I suggest that as part of Forsythe II the USFS specifically defines and holds to a routine maintenance schedule that does not allow for the substantial regrowth of over-crowded lodgepole pines. This schedule should be made available to the public and oversight by the community should be allowed to ensure that the USFS adheres to the schedule. 5) In the description of the Lodgepole Pine Stands treatment plan (Draft Decision, pg. 6) the following statement is made: Following patchcut/clearcut treatments, reforestation treatments (tree planting of mixed conifer species) will occur in these areas. The idea of reforestation seems contradictory to the 1 st objective stated in the Draft Decision Reduce the severity and intensity of a wildfire within the wildland urban interface (WUI) and the general USFS method of choice to address this objective, which is the removal of trees through patch/clear cuts. I object to the inconsistency in the Draft Decision of the Forsythe II Project**. I suggest that the USFS clearly explain to the public how these seemingly contradictory methods benefit fire mitigation (or if they are not intended to benefit fire mitigation, why are they included?) so that these ideas can be critically considered by the public. **To be clear, I am not necessarily against reforestation with mixed conifers. I want to better understand why both cutting and reforestation are included in an area that was specifically targeted for treatment in order to benefit fire mitigation for the town of Nederland. 6) Past patch/clear cuts within the lodgepole forests that are either a part of the current Unit 2, or adjacent to Unit 2 were not maintained or reforested, as stated above. To ensure that such work will be completed in a timely manner as part of Forsythe II, I suggest that the USFS specifically defines and holds to a narrow (1 year post-cutting) window during which any clear/patch cut areas will be reforested. I further suggest that the USFS conduct 3 and 5 year follow-ups to ensure planted trees have survived and if not, are re-planted. I also request that the USFS start thinning excessive lodgepole pine regeneration at 5 and 10 years post-cutting in order to limit the development of ladder fuels and promote a healthy, resilient forest. 7) I did not address wildlife issues in my 23 January 2016 comments however, one of the objectives in the proposed action was to improve wildlife habitat and that objective has not only been removed from the draft decision, but an amendment to the plan to allow degradation of habitat has been added. Thus, I am now qualified to object on wildlife issues. I oppose this amendment, as it is likely to set a significant precedent for other WUI treatments. I further oppose the disruption of the wildlife corridor between Magnolia Road and Big Springs. On pages of the Forsythe II Project Environmental Assessment, it is stated that changes in elk movement can result in habitat degradation for elk and other species, increased vehicle collisions as elk move more at night, increased exposure of elk to disease, and increased negative interactions with landowners. The combination of habitat changes to date has created narrow areas where elk move between barriers to and from production areas and winter range. Examples of this include a narrow eastwest forested area south of the Big Springs subdivision and north of Magnolia Road. Planned patch/clear cuts in Unit 2 are likely to further disrupt this already limited elk migration route.

6 Additionally, on page 132 it is stated that Treatments to dense forest cover areas, especially northfacing slopes oriented east-west that provide forested corridors for travel, vary somewhat among the action alternatives. Loss or compromise of these corridors can result in changes in elk movement and use of available forage, which can have unpredictable results including negative effects to habitat for other species. Much of the terrain within Unit 2 is north-facing, east-west oriented slopes, which were removed from consideration in Alternative 3 in order to to leave more travel corridors for elk and other animals. Yet, they have been targeted for patch/clear cutting in the current Draft Decision. To remedy my objection, I suggest that the CPW units are eliminated from the Draft Decision and multiple wildlife corridors be kept at a minimum of 100 meters wide, to shield them from the impacts of surrounding community. I appreciate your careful consideration of the objections I have raised in this letter. I believe further discussion of these points is necessary prior to moving forward with a final decision. I would greatly appreciate a reply to this objection letter. Please feel free to contact me at and/or mayhewlisa@gmail.com. Lisa Mayhew Hynek Property Owner 38 Wildewood Dr Nederland, CO 80466