Moonlight and Wheeler Fires Recovery and Restoration Project. Record of Decision. Revised Final Environmental Impact Statement

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1 United States Department of Agriculture Forest Service Pacific Southwest Region Plumas National Forest Plumas County California R5-MB-195 July 2009 Moonlight and Wheeler Fires Recovery and Restoration Project Revised Final Environmental Impact Statement

2 For More Information Contact: Rich Bednarski, Interdisciplinary Team Leader Plumas National Forest Mt. Hough Ranger District Highway 70 Quincy, CA (530) The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual s income is derived from any public assistance. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA s TARGET Center at (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC or call toll free (866) (voice). TDD users can contact USDA through local relay or the Federal relay at (800) (TDD) or (866) (relay voice). USDA is an equal opportunity provider and employer.

3 Table of Contents Introduction...1 Background...1 Purpose and Need...2 Purpose 1: Remove roadside safety hazards...2 Purpose 2: Recover the value of fire-killed trees...3 Purpose 3: Re-establish forested conditions...3 Decision and Rationale for Decision...4 Decision...4 Rationale for Decision...4 Findings Required by Other Laws and Regulations...14 Principle Environmental Laws...14 Executive Orders...15 Special Area Designations...16 Public Involvement...16 Alternatives Considered in Detail but Not Selected...17 Environmentally Preferable Alternative...18 Implementation Date...18 Administrative Review or Appeal Opportunities...19 Contact Person...19 i

4 Introduction The (Moonlight and Wheeler Project) is located north of Quincy, west and south of Antelope Lake in Plumas County, California, and within the Mt. Hough Ranger District of the Plumas National Forest. The area affected by the proposal includes 16,006 acres that burned primarily with high vegetation burn severity that resulted in a deforested condition characterized by relatively large areas of standing fire-killed trees on a total of 68,408 acres of public land within the Moonlight and Antelope Complex Fires. In addition, the Moonlight and Antelope Complex Fires burned 19,238 acres of private land. Background The Antelope Complex Fires began on July 5, 2007, burning approximately 23,000 acres on both the Mt. Hough and Beckwourth Ranger Districts. As a result of several lightning strikes, nine wildland fires began; the Wheeler Fire became the largest fire within the Antelope Complex. The Moonlight Fire began on September 3, 2007, burned approximately 65,000 acres, and was contained on September 15, The Moonlight Fire burned into the Antelope Complex Fires creating a contiguous burned landscape stretching across 168 square miles. Based on fire severity assessment methods and severity maps (Safford et al. 2007; Miller 2007; Miller and Thode 2007), over 41,290 of these acres burned with high vegetation burn severity (killing 75 to 100 percent of the trees). Management proposals by the Plumas National Forest (PNF) are determined by direction contained in the PNF Land and Resource Management Plan (PNF LRMP) (USDA 1988) as amended by Herger-Feinstein Quincy Library Group (HFQLG) Final Supplemental Environmental Impact Statement (FSEIS) and (ROD) (USDA 1999a, 1999b, 2003b, 2003c), and the Sierra Nevada Forest Plan Amendment (SNFPA) FSEIS and ROD (USDA 2004a, 2004b). HFQLG Management Direction in the SNFPA ROD (USDA 2004b, pages 66-68) applies to salvage activities included in this EIS. Salvage guidance is not specifically addressed in Table 2 of the SNFPA ROD (USDA 2004b, pages 68 and 69). Under the SNFPA ROD errata (USDA 2004c), guidance of the SNFPA ROD (2004b, pages 52 and 53) clarifies salvage direction (subject to HFQLG limitations). Table 2 of the SNFPA ROD (USDA 2004b) provides standards and guidelines applicable to the HFQLG Pilot Project area for the life of the pilot project. Standards and guidelines that are applicable to this project from Table 2 include those for HFQLG land allocations (Table 2, pages 68-69), Scientific Analysis Team (SAT) Guidelines (USDA 2004b, page 67; USDA 1999a, Appendix L, pages APP L 9 APP L 12), and down wood and snags (page 69). According to the HFQLG ROD (USDA 1999b), The Lassen, Plumas, and Tahoe Forest Plans are amended to prohibit scheduled timber harvest in Riparian Habitat Conservation Areas (RHCAs), except for salvage harvest, or to meet SAT guidelines for riparian management objectives. In addition, the SNFPA ROD (USDA 2004b) allows for removal of dead and dying trees regardless of diameter in salvage treatments, as long as the recommended snag guidelines are met (USDA 2004b, table 2, pages 68-69), dead and dying large trees (greater than 30 inches dbh) may be removed as salvage. 1

5 According to the SNFPA ROD (USDA 2004b, page 37) the Forest Service is to evaluate California spotted owl habitat conditions after a stand-replacing event within a 1.5-mile radius around each Protected Activity Center (PAC) to identify opportunities for re-mapping the PAC. If there is insufficient suitable habitat for designating a PAC within the 1.5-mile radius, the PAC may be removed from the network. Direction for Spotted Owl Habitat Areas (SOHAs) is found in the HFQLG FEIS (USDA 1999a, Appendix Q) to determine if a SOHA should be retained or removed from the network. After analyzing the evaluation criteria found in appendix Q and determining that areas of the SOHA are rendered unsuitable, salvage harvest is acceptable in those areas but not in the remainder of the SOHA. If the SOHA is determined to be 100 percent unsuitable then salvage may occur within the entire SOHA. Purpose and Need The Moonlight and Wheeler Project is proposed to respond to the goals and objectives of the Plumas National Forest Land and Resource Management Plan (PNF LRMP)(USDA 1988) as amended by Herger-Feinstein Quincy Library Group (HFQLG) Final Supplemental Environmental Impact Statement (FSEIS) and (ROD) (USDA 1999a, 1999b, 2003b, 2003c), and the Sierra Nevada Forest Plan Amendment (SNFPA) FSEIS and ROD (USDA 2004a, 2004b). Comparison of the existing condition and the desired conditions for the PNF LRMP, as amended, indicates a need to address undesirable resource conditions as a result of the Moonlight and Antelope Complex Fires. The SNFPA ROD (2004) identifies the need to incorporate ecosystem restoration following catastrophic events (D. Management Standards and Guidelines, Salvage, pages 52 and 53). This project specifically includes eliminating roadside safety hazards for public safety, recovering the economic value of fire-killed trees, and planting conifer seedlings. Harvesting hazard trees along roads will meet the need to eliminate those public safety hazards. The action of recovering economic value of dead trees will contribute to the need for wood supply for local manufacturers and sustaining a part of the employment base in rural communities. The action of conifer seedling planting will meet the reforestation need to reestablish forested conditions. Purpose 1: Remove roadside safety hazards Objective: Remove hazardous trees with structural defects likely to cause failure in all or part of the tree, which may fall and hit the road prism. Need for action: The Forest Service is required to maintain roads for access and safety, and the Agency routinely removes hazardous trees as part of road maintenance (23 Code of Federal Regulations (CFR) , 36 CFR 212.4, Forest Service Manual (FSM) 7700, Forest Service Handbook (FSH) , 27.62d, PNF Roadside/Facility Hazard Tree Abatement Action Plan 2008). It is not uncommon for high, gusty winds associated with winter or summer storms to suddenly blow down many such hazardous trees at one time, posing an unacceptable risk to forest workers and visitors alike. It is important to remove these hazardous trees in a timely, efficient, and cost-effective manner so that access to affected areas can be restored and normal National Forest operations can be resumed. Measurement indicators: Acres/miles of National Forest System (NFS) roads treated for hazard tree removal 2

6 Purpose 2: Recover the value of fire-killed trees Objective: Recover the value of fire-killed trees before natural deterioration occurs in the treatment areas. Need for action: The Forest Service has a role to play in providing a wood supply for local manufacturers and sustaining a part of the employment base in rural communities (SNFPA ROD 2004, page 4). The SNPFA provides for salvage logging following wildfires with the objective of recovering economic value from fire-killed trees (SNFPA ROD 2004, page 52). Based on Geographic Information Systems (GIS) and cruise plot data, it is estimated that approximately 549,000 mbf in sawlogs exist in areas that burned with high vegetation burn severity within the Moonlight and Wheeler Fires. Roads and landings are absent in several areas of the project. Temporary road and landing construction (with decommission after use) is needed to permit the removal of fire-killed trees. Measurement indicators: Acres of public land treated for salvage recovery Acres/miles of roads treated for hazard tree removal Volume (thousand board feet - mbf) of salvage and hazard tree timber recovered from public land Net value (dollars) of salvage and hazard tree sawlogs recovered from public land Combined (sawlog and biomass) net value (dollars) recovered from public land Total project value (dollars) Total full-time jobs (#) Total employee-related income (dollars) The Moonlight and Wheeler Project has incorporated snag retention areas where salvage harvest would not occur (USDA 2004b, page 52). Purpose 3: Re-establish forested conditions Objective: Plant native conifer seedlings to re-establish forested conditions. Need for action: The National Forest Management Act sets policy to maintain appropriate forest cover in accordance with the PNF LRMP. The Moonlight and Antelope Complex Fires burned thousands of acres with high vegetation burn severity resulting in deforested conditions where seed source of desired species is insufficient to naturally regenerate these areas. As a result, shrub species would dominate these areas for decades and delay re-establishment of forested conditions. The early establishment of conifers through reforestation would expedite forest regeneration and the development of forested conditions. In addition, as it relates to wildfires, it is current Agency policy (FSM 2471 and 2472) to consider post-fire salvage harvest the functional equivalent of a regeneration harvest and to make a best effort to re-establish forested conditions within 5 years after salvage harvest. Measurement indicator: Percent of public land reforested within the Moonlight and Antelope Complex Fires perimeters. 3

7 Decision and Rationale for Decision Decision Based on my review of the alternatives, I have decided to implement alternative A as described in the Revised Final Environmental Impact Statement (RFEIS). This decision includes activities to harvest dead (fire-killed) conifer trees on approximately 10,366 acres of the 41,290 acres of high vegetation burn severity areas using the following methods: ground based (4,147 acres), skyline (872 acres), and helicopter (5,347 acres). In addition, this decision harvests dead (fire-killed) and/or dying (fire-injured) conifer hazard trees on 4,389 acres/123 miles of roads. Up to 19 miles of temporary roads and about 14 helicopter landings (30 acres) will be constructed and then decommissioned after use. Conifer seedlings will be re-established on 16,006 acres. The Moonlight and Wheeler Project was designed to minimize impacts to resources and meet PNF LRMP standards and guidelines. Project design features were incorporated into each action alternative and alternatives eliminated from detailed study. Limited operating periods (LOPs) will be implemented for bald eagles and, if needed, for California spotted owls. Specific landing pile prescriptions will be applied during prescribed burning operations to improve mountain yellow-legged frog survival. Standard Management Requirements (SMRs) developed for botanical resources will reduce the introduction and spread of noxious weeds on NFS lands and comply with the Interim Management Prescriptions for Threatened, Endangered, Region 5 Forest Service Sensitive, and Special Interest Plants dated February 20, 2007 (USDA 2007a). SMRs developed for cultural resources will ensure that no activities occur within cultural site boundaries. Best Management Practice (BMP) monitoring will occur prior to and during treatment activities, minimizing erosion and sedimentation. Monitoring will occur for soils, cultural resources, and aquatic wildlife. In addition, timber sale contracts contain provisions for an erosion control plan, road maintenance, and skid trail spacing. Rationale for Decision When compared to the other alternatives, alternative A meets the purposes for the project and is the alternative that best meets the needs identified for this project. My decision is based upon careful consideration of the information and analyses contained in the RFEIS and all of the supporting documentation, including public comments on the Revised Draft Environmental Impact Statement (RDEIS) (February 2009). My conclusions are based on a thorough review of the best available science, consideration of responsible opposing views, and the acknowledgement of incomplete or unavailable information, scientific uncertainty, and risk. I have determined that this project achieves an appropriate balance between safety, benefits to the local economy, maintaining appropriate forest cover, and protection of forest resources. This environmental analysis process was conducted in accordance with the National Environmental Policy Act (NEPA) and the direction provided in the Forest Service Manual. Alternative A is consistent with the goals and objectives of the PNF LRMP, as amended. I recognize that there is controversy surrounding salvage logging in burned forests, as well as replanting, particularly over effects on wildlife habitat and watersheds. The alternatives were evaluated against all three of the purposes and needs for this project: remove roadside safety hazards, recover the value of fire-killed trees, and re-establish forested conditions. This project was designed to ensure protection of forest resources from significant long-term impacts through implementation of BMPs, SMRs, LOPs, and monitoring. In addition, timber harvest for salvage will not occur on the majority of public land in the Moonlight and Antelope Complex Fires under alternative A, providing important habitat for wildlife species that depend on snags and burned forest, and allowing for a natural shrub successional stage in these untreated areas. Also, the 4

8 early establishment of conifers through reforestation will expedite forest regeneration and the development of forested conditions, and accelerate the development of habitat structure benefitting old-forest species. In addition, most of the Fire areas would not receive treatment (between 78 and 94 percent of the total public land in the watershed analysis area). Related to Purpose and Need 1. Remove roadside safety hazard trees with structural defects likely to cause failure in all or part of the tree, which may fall and hit the road prism. This decision will eliminate danger trees along 123 miles of roads (4,389 acres) in order to provide safe passage along roads used by the public and Agency employees. The Forest Service is required to maintain roads for access and safety, and the Agency routinely removes incidental hazardous trees as part of road maintenance (23 CFR , 36 CFR 212.4, Forest Service Manual (FSM) 7700, Forest Service Handbook (FSH) , 27.62d, PNF Roadside/Facility Hazard Tree Abatement Action Plan 2008). There exists a critical and urgent need at this time to remove hazard trees on a large scale because the fire-killed/fire-injured trees are continuing to deteriorate. The incidence of falling trees will increase disproportionately as deterioration progresses. As the hazard trees deteriorate they become structurally weak, the limbs fall and the trees break apart. It is also common for high, gusty winds in this area to blow down such hazardous trees. This unpredictability is a hazard to public safety on the roads. Falling trees may injure or kill individuals, damage property or entrap people in the area. In addition, the merchantability of the hazard trees reduces as the deterioration increases. Recent 2009 field data on merchantability shows there is still a financial incentive in timber value for private companies to remove the hazard trees, but as time passes and the trees deteriorate, that incentive decreases. Because the Plumas National Forest does not have adequate road maintenance funds to fall and leave 123 miles of hazard trees in place, and complete the work itself, merchantability of the trees is an important consideration in my decision for the safe and effective removal of these hazard trees. Removal of dead and dying hazard trees versus fall- andleave on 123 miles of road is also important to manage fuels in these areas. It is important to remove these hazardous trees in a timely, efficient, and cost-effective manner so that safe access to affected areas can be restored and normal National Forest operations can continue. For hazard trees not removed by commercial timber sales, service contracts or other means will be used to abate roadside hazard trees. Alternatives A, C, D, and E Alternatives A, C, D, and E remove roadside safety hazard trees with structural defects, likely to cause failure in all or part of the tree that may fall and hit the road prism. Danger to the public from falling dead trees would be significantly reduced along roads. The ability for firefighters to safely access areas within the Moonlight Fire and prevent any further forest resource losses in the event of another wildfire is also greatly increased. Log truck traffic would increase during removal operations, but congestion and safety should not be an issue due to traffic laws and contract specifications. While it is generally recognized that larger snags have longer snag fall rates, it may be difficult to predict exactly when a particular snag may fall. I considered the many variables that contribute to the rate at which hazard trees may fall including conifer species, structural defects, site conditions such as slope and soil properties, as well as weather events, particularly wind. In addition, trees may fail entirely or in part. While snag fall rates usually focus on the entire stem of the tree, parts such as limbs and tops may fail much sooner than timeframes described in the scientific literature for snag fall rates. Hazard tree removal guidelines recognize that failing limbs and tops represent a hazard as does the entire tree. Hazard tree guidelines allow for a more 5

9 systematic approach to managing road systems for safety and access and focus on identifiable criterion that can be observed and measured. Also, timber sales are an important tool to assure that workers with the necessary skills conduct the felling of hazard trees, while at the same time helping to sustain the local industry infrastructure that is necessary to forest management. Alternative B No-Action Due to safety concerns, the Forest may be forced to restrict road use/access until such time as enough appropriated dollars could be obtained to treat the roadside hazards. Falling and leaving hazard trees in place is estimated to cost $961,000 (36 CFR (b)), Moonlight and Wheeler Fires Recovery and Restoration Project, Letter of June 4, 2009). This would mean that the purpose and need to improve public safety may not be fulfilled because of excessive cost. Also, this falling and leaving hazard trees would not mitigate the fuel build-up along roads. Road closure is not a practical or effective solution due to the need for continuing access for private landowners, mining claims, and other entities requiring access into and through the area. Under the no-action alternative, normal recurring activities will continue in the short-term, such as firewood cutting, fire suppression, Christmas tree cutting, recreational use, right-of-way maintenance for telephone and power lines, road maintenance, access to private inholdings, mining claims, and grazing permits. In the long-term, as deterioration progresses and trees fall, roadside hazard trees could hamper these activities. Road closure would also fail to address our need to accomplish necessary road and culvert maintenance work to minimize watershed impacts in this severely burned area. Under alternative B (no-action alternative), all roadside dead and dying trees would be retained, posing a very high risk to the public and forest workers as time goes on. The public would be at high risk from snags falling into roads as they drive by or park on the roadside to recreate. Activities such as fishing and camping would be dangerous where dead trees are numerous. The Forest Service would not fulfill its responsibility of maintaining roads for safety and access (Forest Service Manual sections , , 7731, ). In addition, Forest Service employees and contractors would be at great risk of injury or death from falling snags and breaking limbs and tops. Small snags would pose a risk in approximately one to three years. Larger snags may become a high risk after two or more years. By six years, over half of the snags may have fallen (Landram et al. 2002). Future seedling tending, thinning, and prescribed burning would be high-risk endeavors, and may be precluded due to the risk to workers. The same is true for road maintenance work, which is essential to watershed protection. Hazard trees also compromise the safety of firefighters and affect fire suppression tactics and strategies. Firefighters typically need to fell snags near firelines as they are hazardous to personnel on the ground and, if ignited, may contribute to spot fires across the firelines. Due to the abundance of snags, conditions would be unacceptably dangerous, resulting in the firefighters retreating to areas of low to no snags for effective and safe fire fighting. When the 2007 Antelope Complex Fires burned into the untreated areas of the 2001 Stream Fire, conditions were so hazardous due to burning and falling snags, that fire crews were removed from this area after a firefighter was injured. Consequently, the Fire was allowed to burn uncontrolled until crews could re-engage the fire and fight it from a safer location. The safety risks posed by breaking and falling snags would ultimately preclude safe fire fighting, tree planting, fuel treatment, road maintenance and other uses of the Fire areas. 6

10 Log truck traffic would not increase under the no-action alternative and this alternative would not contribute to additional safety concerns from traffic accidents, as there would be no additional vehicle traffic due to removal operations. 2. Recover the value of fire-killed trees before natural deterioration occurs in the treatment areas. My decision to choose alternative A will recover the economic value of fire-killed trees before natural deterioration occurs in the treatment areas. The Forest Service has a role to play in providing a wood supply for local manufacturers and sustaining a part of the employment base in rural communities (SNFPA ROD 2004, page 4). Based on GIS and cruise plot data, it is estimated that approximately 549,000 mbf in sawlogs in the Moonlight and Wheeler Fires burned with high severity. Under alternative A, the proposed action is to remove 120,194 mbf (22 percent) of the sawlogs. Removal will include construction of temporary roads and landings (with decommission after use). The merchantable volume will deteriorate and economic value will decrease over time, which underscores the time-sensitivity of fire salvage treatments. The revenue generated will also depend on the availability of logging equipment, haul distances to available mills, and fuel prices. The appraisal displayed in Table 1 assumes haul to the closest sawmills. However, haul to other mills is feasible, as evidenced by past and current timber sales. Table 1 summarizes the economic effects on the local economy that would occur from implementation of alternatives A, B, C, D, or E. The local industry infrastructure has the capacity to complete this work as evidenced by the increase in salvage timber operations that occurred on private lands within the Fire areas. 7

11 Table 1. Comparison of economic effects by alternative. Volume/ Revenue & Alternatives Cost/ Employment A B C D E Burned Area 1 Sawlog Volume Biomass Volume Total Sawlog and Biomass Value 120,194 mbf 0 mbf 57,987 mbf 23,135 mbf 14,013 mbf 549,534 mbf 161,000 tons 0 118,000 tons 36,000 tons 0 tons $32,339,549 $0 $16,468,190 $6,524,329 $3,345,081 $121,007,765 Total Costs $44,226,249 $0 $19,036,931 $7,396,310 $3,944,782 Net Revenue -$11,886,700 $0 -$2,568,742 -$871,982 -$599,701 Percent above value Total direct and indirect jobs Total employeerelated income -37% 0% -16% -13% -18% $86,861,975 $0 $46,326,262 $28,502,986 $21,598,427 1 Gross estimation of volume and value of areas within the Moonlight and Wheeler Fires that burned with high vegetation fire severity (41,290 acres). Alternative A The economic analysis is a preliminary value and cost analysis. The total project value is approximately -$22.7 million dollars (RFEIS, Table 21, page 35). The economic analysis used to determine the project value of -$22.7 million dollars, includes timber value minus harvest costs, road improvement costs, delivery costs to the mill, and reforestation costs. The economic analysis is a broad scale analysis depicting the economics for typical operations and typical equipment product rates and documented values. Interest by prospective purchasers is nonetheless anticipated because of the variables which may effect production and costs. As an example, many operators/purchasers own their equipment and do not carry the equipment cost portrayed in the analysis. Appraisals, which will be completed later, will have a stronger basis for determining value and costs than these estimations. Historically, timber sales have sold, even where economic indicators show poor net revenue. As an example, the estimated cost used for ground-based operations for the analysis is the average cost for Plumas County as reported by the Board of Equalization. Final appraised logging costs range from $10 to $47 per mbf less to log in Plumas County than the Board of Equalization projections (E. Vercruysse, pers comm). In addition, alternative A contributes the most employee related income to hard-hit regional economies. Alternative A will generate 2,020 direct and indirect jobs and approximately $86.9 million dollars in employee-related income (direct and indirect jobs in regional rural communities). 8

12 Of all the alternatives, alternative A treats 14,755 acres and recovers fire-killed and fire-injured timber worth $32.3 million dollars (Table 1) from the landscape. Implementation of alternative A would provide a short term increase in economic recovery of timber products from NFS lands, which would otherwise not produce timber products for decades. Alternative A is a balanced approach to obtain a commodity to stimulate economic stability and potential growth for regional economies, while managing our National Forest. Salvage logs are still being accepted by local regional mills including those in Quincy, Chester, Oroville, Lincoln, and Anderson, California. The mill in Quincy has an annual production of scaled timber of 160,000 mbf. If the Quincy mill were to receive the salvage logs, alternative A would allow this mill to operate at full capacity for approximately 9 months. The mill in Chester has an annual production of scaled timber of 75,000 mbf; however, the mill for the past two years has been operating at 80 percent capacity due to the lack of logs. If the Chester mill were to receive these salvage logs, alternative A would provide 19 months supply of logs allowing for full annual capacity of production. Local jobs will add benefits to the local economy by dollars spent in the area. All action alternatives would create additional employment opportunities in service industries (such as logging supply companies, trucking companies, and fuel suppliers) that serve the timber industry. Wages paid to workers by the primary and service industries would be circulated through the local economy for food, housing, transportation, and other living expenses. The direct and indirect jobs under alternative A represent 18 percent of Plumas County s labor force with a potentially equivalent percent increase in cash flow in the community. I requested an emergency situation determination (ESD) be made for this project because risk to human health and safety and substantial loss of economic value to the federal government will occur if implementation of this decision is delayed (Request for Emergency Situation Determination (36 CFR (b)), Moonlight and Wheeler Fires Recovery and Restoration Project, Plumas National Forest, Letter of June 4, 2009). The Code of Federal Regulations (36 CFR 215.2) defines an emergency situation as a situation on National Forest System lands for which immediate implementation of all or part of a decision is necessary for relief from hazards threatening human health and safety or natural resources on NFS or adjacent lands; or that would result in substantial loss of economic value to the federal government if implementation of the decision were delayed. Delay of implementation will result in substantial timber deterioration before it can be removed. Due to limited winter access to the project area, the majority of operations need to be completed in the fall of 2009, if we are to recover economic value. Given current market conditions, the additional deterioration resulting from the delay greatly increases the risk that the timber may not sell at all. The ability of the Plumas National Forest to accomplish the purpose and need for the project is therefore strongly tied to the timing of the salvage harvest treatments, which in turn is dependent upon the project planning timeline. The estimated loss of timber value resulting from this delay is estimated at $6.25 million, with the resulting economic loss of stumpage receipts to the government estimated at $600,000 (Request for Emergency Situation Determination (36 CFR (b)),, Plumas National Forest, Letter of June 4, 2009). This value, while substantial, does not adequately reflect the importance of this project to the local community and to the larger picture of forest management on the Plumas National Forest. By recovering economic value of burned timber in a portion of the Fire areas, the Moonlight and Wheeler Project plays a vital role in the local economy and will help sustain the infrastructure that is necessary to the management of National Forests. 9

13 Due to litigation on the Plumas National Forest, very little timber has been available to sustain the local economy. This project is vitally important to help sustain the local industry and needed infrastructure to carry out our fuels reduction and forest health objectives, while protecting forest resources. Alternative B No-Action Under Alternative B (no-action alternative), current management plans would continue to guide management of the Moonlight and Antelope Complex Fire areas. Under the no-action alternative, none of the proposed activities would occur. Alternative B would not result in any economic recovery of dead or dying trees, and consequently would not produce timber products for decades, due to the amount of time needed for conifers to recover and reach merchantability. Local communities would not realize jobs or associated employee-related income, compared to those of any of the action alternatives. I did not choose this alternative because it does not remove roadside safety hazards, recover the value of fire-killed trees, nor re-establish forested conditions. Alternative C Alternative C would harvest fire-killed and fire-injured trees on approximately 8,536 acres (4,147 acres of fire-killed trees and 4,389 acres of fire-killed and fire-injured roadside hazard trees) using only a ground based logging system. This acreage yields approximately 57,987 mbf in sawlog volume (Table 1), approximately 11 percent of the total estimated volume available. The total project value is approximately -$8.9 million dollars (RFEIS Table 21, page 35). Alternative C would generate 1,077 direct and indirect jobs and approximately $46.3 million dollars in employee-related income. Alternative C was developed from scoping comments received on the proposed action and includes only ground-based logging. Approximately 6,219 acres that are proposed for salvage harvest under alternative A would not be treated under alternative C. Alternative C treats fewer acres than alternative A, harvests less volume, and generates fewer direct and indirect jobs and less employee-related income. Alternative C would allow the Quincy mill to operate at full capacity for approximately 4 months or the Chester mill to operate at full capacity for approximately 9 months. Alternative D Alternative D would harvest fire-killed and fire-injured trees on approximately 5,656 acres (1,267 acres of fire-killed trees and 4,389 acres of fire-killed and fire-injured roadside hazard trees) using only a ground based logging system and following direction in the 2001 Sierra Nevada Forest Plan Amendment (SNFPA) (USDA 2001a, 2001b). This acreage yields approximately 23,135 mbf in sawlog volume, approximately 4 percent of the total estimated volume available (Table 1). The total project value is approximately -$11.7 million dollars (RFEIS, Table 21, page 35). Alternative D would generate 663 direct and indirect jobs and approximately $28.5 million dollars in employee-related income. Alternative D was developed from comments received on the 2008 Draft Environmental Impact Statement for the Moonlight and Wheeler Project, incorporates direction and standards and guidelines from the 2001 SNFPA, and includes only ground-based logging. Approximately 9,099 acres that are proposed for salvage harvest under alternative A would not be treated under alternative D. Alternative D treats fewer acres than alternative A, harvests less volume, and generates fewer direct and indirect jobs and less employee-related income. 10

14 Alternative D would allow the Quincy mill to operate at full capacity for approximately 2 months or the Chester mill to operate at full capacity for approximately 4 months. Alternative E Alternative E would harvest only fire-killed and fire-injured roadside hazard trees on 123 miles of road (4,389 acres), using a ground-based logging system. This acreage yields approximately 14,013 mbf in sawlog volume (Table 1), approximately 3 percent of the total estimated volume available. The total project value is approximately -$7.5 million dollars (RFEIS Table 21, page 35). Alternative E would generate 502 direct and indirect jobs and approximately $21.6 million dollars in employee-related income. Alternative E was developed to address concerns around fire salvage harvest. Approximately 10,366 acres that are proposed for salvage harvest under alternative A would not be treated under alternative E. Alternative E treats fewer acres than alternative A, harvests less volume, and generates fewer direct and indirect jobs and less employee-related income. Alternative E would allow the Quincy mill to operate at full capacity for approximately 1 month or allow the Chester mill to operate at full capacity for approximately 2 months. 3. Plant native conifer seedlings to re-establish forested conditions. This decision provides for early establishment of conifer seedlings that would expedite the development of forested conditions. The Moonlight and Antelope Complex Fires burned thousands of acres with high severity resulting in deforested conditions where seed source of desired species is insufficient to naturally regenerate these areas. As a result, shrub species would dominate these areas for decades and delay reestablishment of forested conditions. Alternatives A, C, D, and E Alternatives A, D, and E include 16,006 acres of planting native conifer seedlings to recover forested conditions. Alternative C includes 9,306 acres of reforestation. Approximately 6,700 acres that are proposed for reforestation activities under alternative A would not be treated under alternative C. Reforestation activities would have a positive long-term effect by establishing forest vegetation in areas that were forested prior to the Fires. Under alternative B, tree planting would not occur. Without reforestation treatments, these areas would remain as non-forest vegetation types, such as montane chaparral, for substantially longer periods of time. Alternative B No-Action The no-action alternative would solely rely on natural regeneration to re-establish forested conditions on 69 percent of area that burned at high vegetation burn severity. Where natural regeneration does not occur in amounts to re-establish forested conditions, the areas would experience a vegetation type change to brush fields that may persist for decades and potentially more than a century. Related to Effects to Resources Fuels In choosing alternative A, I considered the potential for increased fuel loads related to timber harvest. While surface fuel loads in lop and scatter material may contribute to an increase in flame length immediately post harvest, this effect is not substantially different from the no-action alternative within 10 years post harvest, due to natural breakage of limbs and tops and snag fall of dead trees. In the long-term, alternative A would have lower surface fuel loads than the no-action alternative as a result of removing dead trees. 11

15 I recognize that reforestation with high density plantations with close tree spacing can be at risk of loss if the area re-burns. Reforestation in this project has been designed with widely spaced cluster planting that would reduce the risk of losing the reforestation effort if the area were to burn again. Treatments that reduce snag density in the areas to be reforested, as proposed for this project, also reduce the risk that a re-burn of the area would destroy the regeneration (natural or artificial). As an example, when a portion that was not treated in the 2000 Storrie Fire area reburned during the Fires of 2008, natural regeneration was destroyed and fire management options were greatly impaired by the prevalence of standing and downed trees. Wildlife In choosing alternative A, I considered effects on wildlife habitat. The Moonlight and Wheeler Project RFEIS recognizes that burned forests provide important wildlife habitat. Environmental effects analyses presented in chapter 3 of the Moonlight and Wheeler Project RFEIS (and detailed in the supporting Moonlight and Wheeler Project Biological Assessment/Biological Evaluation and Management Indicator Species Reports) evaluate the direct, indirect, and cumulative effects of snag removal via salvage harvesting and hazard tree removal on habitats for a wide variety of wildlife species that depend, either wholly or in part, on burned habitat conditions as well as snags and large downed logs. Most of the area that burned in the Moonlight and Antelope Complex Fires would not receive salvage harvest treatments. Approximately 68,408 acres of NFS lands lie within the Moonlight and Antelope Complex Fires. The Moonlight and Wheeler Project proposes under alternative A salvage or roadside hazard harvest on approximately 14,755 acres (approximately 22 percent of the National Forest System lands in the Fire areas). The Moonlight and Antelope Complex Fires impacted twenty-five spotted owl protected activity centers (PACs) and Home Range Core Areas (HRCAs) (including five Spotted Owl Habitat Areas (SOHAs)). Of these twenty-five PACs, twenty have been deemed lost due to high severity wildfire effects and have been removed from the PNF spotted owl network. Approximately 8,510 acres of formerly suitable habitat within PACs and HRCAs is proposed for salvage and roadside hazard treatment. Although alternative A will treat the highest number of acres of all action alternatives, relative to effects of the wildfire the determination for all alternatives is the same: may affect individuals, but is not likely to result in a trend toward federal listing or loss of viability for the California spotted owl. Also, the early establishment of conifers through reforestation would expedite forest regeneration and the development of forested conditions, and accelerate the development of habitat structure benefitting old-forest species. Of particular concern, are the effects of salvage harvest on the black-backed woodpecker (BBWO), a management indicator species closely associated with snags in recently burned forests. As a result of the stand-replacing Fires, 32,569 acres of suitable BBWO habitat (forested stands that burned at moderate to high severity) were created. All action alternatives are designed to treat a portion of the burned habitat. Under alternative A, the analysis shows that 38 percent (12,397 acres) of suitable BBWO habitat that was created would be treated for salvage or hazard tree removal. Snag availability under all action alternatives greatly exceeds the snag retention levels stated in management direction (PNF LRMP, as amended). After implementation of treatments proposed under alternative A, the overall large (greater than 15 inches diameter at breast height, or dbh) snag tree density averaged across the public land base would be approximately 11.7 snags per acre. Watershed and Soils In choosing alternative A, I considered effects on watersheds. The Moonlight and Antelope Complex Fires left several analysis watersheds over threshold for potential for impairment to 12

16 downstream beneficial uses. The risk imposed was primarily due to catastrophic ground cover loss that left most project area watersheds below PNF LRMP guidelines. In the nearly two years since the Fires, there has been remarkable recovery, mostly from basal vegetation (shrubs and forbs), on both upland slopes and in riparian corridors. On ground-based units surveyed in June 2009, most ground was above PNF LRMP guidelines (average of 65 percent effective ground cover) and estimated effectiveness of riparian corridors in stopping upslope rilling from reaching stream channels was between 60 and 90 percent. With the implementation of BMPs, which Forest monitoring has shown to have 97 percent effectiveness over recent years, and design features such as sub-soiling of landings and temporary roads immediately after use, the risks of impairment to downstream beneficial uses due to the action alternatives are minimal. Both the initial project soil condition survey in November 2007, and the follow-up in June 2009, found very little rilling of high severity burn hill slopes, as there has been no precipitation event to widely induce overland flow on burned slopes. What rilling was apparent originated from existing roads. Turbidity measurements in Lights Creek in early May 2009, after a rainstorm, did have high counts well over State standards (Feather River Coordinated Resource Management, unpublished data), indicating that there is currently a degree of impairment due to the wildfires. Most of the area within these watersheds and within the burn areas would not receive treatments. The ground excluded from harvest is between 78 and 94 percent of the total public land in the watershed analysis area, varying by alternative. Therefore, the contribution of the Moonlight and Wheeler Project to water quality impacts would be negligible relative to the effect of the Fires. The action alternatives do vary by thousands of acres in total harvest area, well over a 100 percent difference between alternatives E and A, the least and most extensive alternatives, respectively. However, treatment by ground-based methods, by far the most intrusive, within Riparian Habitat Conservation Areas (RHCA), varies by only 160 acres (18 percent) between alternatives E and A. Largely this is because the roadside safety hazard treatment, an element within both E and A, is associated with most of the riparian treatment. On this basis the effects and potential risks to water resources of the various alternatives is actually much closer than total harvest area would imply. Maintenance on roads and associated drainage structures help to prevent erosion and protect water quality. According to the Regional Water Quality Control Board, erosion derived from legacy effects of existing Region 5 NFS roads, including effects associated with road location and original drainage design, is of much greater concern to water quality than silvicultural treatments (D. Coe 2009). Initial estimates of potential soil erosion in the first year after the Fire (Moonlight Burned Area Emergency Rehabilitation (BAER) soils report) were 1-2 orders of magnitude over typical estimates of background erosion on non-disturbed slopes. As stated above, such a level of accelerated erosion did not occur due to the lack of a large runoff event. Subsequent calculations, using June 2009 surveys of ground cover indicate recovery to background rates on high severity burn slopes within 3 years. Harvest occurring prior to the third runoff season after the Fires would set back total recovery by 2 to 3 years on harvest ground. Initial project soil condition surveys found Large Woody Debris (LWD) below USFS regional soil analysis thresholds and PNF LRMP guidelines, as amended. The subsequent June 2009 survey found a greater than anticipated component of down fire-killed trees, at levels at the upper threshold of desired loading. With leave trees (snags) for future recruitment, LWD amounts on treated ground are likely to remain within the recommended range. 13

17 Summary In summary, in choosing to implement alternative A, I have tried to balance the purpose and need for the Moonlight and Wheeler Project with concerns for protection of forest resources from significant long-term impacts. The 2004 SNFPA ROD says that in post fire restoration projects for large catastrophic fires (contiguous blocks of moderate to high fire-kill of 1,000 acres or more), we will generally not conduct salvage harvest in at least 10 percent of the total area affected by the fire. This decision includes activities on approximately 16,006 acres of the 88,000 acres burned by the Antelope Complex and Moonlight Fires of 2007, well within the direction of the 2004 SNFPA ROD. In addition, the Moonlight and Wheeler Project has incorporated snag retention areas where salvage harvest would not occur (USDA 2004b, page 52), as well as numerous measures to minimize impacts to watersheds. While protecting forest resources, this project plays a vital role in contributing wood supply to the employment base in rural communities and helps sustain the local industry needed to carry out our fuels reduction and forest health objectives. Findings Required by Other Laws and Regulations My decision complies with the laws, policies, and executive orders listed below and described in chapter 3 and section 3.15 of the 2009 RFEIS. The decision to implement the Moonlight and Wheeler Project is consistent with the PNF LRMP, as amended. Principle Environmental Laws I have determined that the Moonlight and Wheeler Project meets the requirements of the following laws as described in the 2009 RFEIS (pages ): Endangered Species Act (ESA) Section 7(a)(2) of the Endangered Species Act requires that Federal agencies consult with the United States Fish and Wildlife Service and National Marine Fisheries Service, as appropriate, to ensure that their actions do not jeopardize the continued existence of species listed as threatened or endangered under ESA, or destroy or adversely modify their critical habitat. A biological assessment was prepared for federally proposed, threatened, or endangered wildlife and botany species and their critical habitat. Implementation of the project would have no effect on valley elderberry longhorn beetle and California red-legged frog. No federally proposed, threatened, or endangered botany species were located within the analysis area during past or current surveys. Clean Water Act Federal agencies are required by the Clean Water Act to cooperate with State agencies in preventing, reducing, and eliminating pollution in concert with programs for managing water resources. This project meets this through the incorporation of project design features (RFEIS, chapter 2, section 2.2, pages 11-27), Scientific Analysis Team (SAT) Guidelines for Riparian Habitat Conservation Areas (RHCAs)(USDA 2004b, page 67; USDA 1999a, Appendix L, pages APP L 9-APP L 12), soil standards and guidelines (PNF LRMP, pages ); Best Management Practices, Standard Management Requirements, and monitoring listed in appendix C of the RFEIS. This project meets the Clean Water Act. 14

18 Clean Air Act The Clean Air Act makes it the primary responsibility of States and local governments to prevent air pollution and control air pollution at its source. States must have a plan that provides for implementation, maintenance, and enforcement of the primary ambient air quality standard. The State of California has a plan. The procedures outlined in the RFEIS (chapter 3, section, , pages 76-77; section 3.15, page 263) are sufficient to minimize air quality concerns. This project complies with the Clean Air Act. National Historic Preservation Act It was determined under the First Amended Regional Programmatic Agreement Among the USDA Forest Service, Pacific Southwest Region California State Historic Preservation Officer, and Advisory Council on Historic Preservation Regarding the Process for Compliance with Section 106 of the National Historic Preservation Act for Undertakings on the National Forests of the Pacific Southwest Region (RPA)(March 2001), that the proposed undertakings would have no direct, indirect, or cumulative effect on cultural properties and values. National Environmental Policy Act (NEPA) The NEPA requires that Federal agencies complete detailed statements on proposed actions that significantly affect the quality of the human environment. The Act s requirement to prepare an environmental impact statement is designed to provide decision makers with a detailed accounting of the likely environmental effects of a proposed action prior to adoption and to inform the public of, and allow it to comment on, such effects. The RFEIS does a comprehensive job of analyzing and displaying the alternatives and environmental effects. The procedural requirements of the NEPA have been followed. National Forest Management Act (NFMA) Projects occurring on National Forest System lands must meet minimum specific management requirements under 16 U.S.C (g)(3). This project meets all applicable guidelines for land management plans according to 16 U.S.C (g)(3). Executive Orders Executive orders provide additional direction to federal agencies. I have determined that the Moonlight and Wheeler Project meets the requirements of the following executive orders as described in the RFEIS (chapter 3, section 3.15, page 264). The executive orders that apply to the Moonlight and Wheeler Project proposed action and alternatives are presented below. Consultation and Coordination with Indian Tribal Governments, Executive Order of November 6, Indian Sacred Sites, Executive Order of May 24, Invasive Species, Executive Order of February 3, Recreational Fisheries, Executive Order of June 6, Migratory Birds, Executive Order of January 10, Floodplain Management, Executive Order of May 24, 1977, and Protection of Wetlands, Executive Order of May 24, Environmental Justice, Executive Order of February 11,