ffi Forest Carbon Cyclingo Storâgeo and Climate Change Resource Technical Report ln Support of the Envi ronm enta I Assessment

Transcription

1 USDA United Statos -Department of Agriculture Forest Servlce lntsrmounte n Region Boise National Forest April 2017 ffi Forest Carbon Cyclingo Storâgeo and Climate Change Resource Technical Report ln Support of the Envi ronm enta I Assessment South Pioneer Fire Salvage and Reforestation Project Prepared John Riling, Forest Silviculturist,/,,'t - )oa-. Prepared by: Séott Wagner, Sod{h Zone Silviculturist,l /rrl.*,t Date, v/zt/2ò Ìz

2 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 Table of Contents Table of Contents... i List of Tables... ii 1. Abstract Analysis Questions Relevant Laws, Regulations, and Policy Relationship of this Project to the 2010 Forest Plan Goals, Objectives, and Desired Future Conditions Relevant to this Resource Project Area Description Purpose and Need Alternatives Considered in Detail Project Design Features Analysis Scale, Data Sources, and Methodology Analysis Scale Data Sources and Analysis Methodology Issues, Indicators and Measures Affected Environment Existing Condition Environmental Consequences No Action Alternative Direct and Indirect Effects Cumulative Effects No Action Alternative Conclusion Proposed Action Direct and Indirect Effects Effects of Design Features Cumulative Effects Proposed Action Conclusion Forest Plan Consistency Response to Comments Concerning Climate Change Best Available Science Literature Cited i

4 List of Tables Table 1. Minimum snags retained post-implementation (derived from Forest Plan, Appendix A Table A-6 for the Salvage [Non-Hazard-Tree] PVGs (PVGs 1 4)... 5 Table 2. Resource indicators and measures for assessing effects... 8 Table 3. Projected total average snags, course woody debris and removals for the project area under the No Action Alternative Table 4. Projected total average snags, course woody debris and removals for the project area under the Proposed Action ii

5 1. Abstract This report describes the evidence and rationales why we believe additional analysis of this South Pioneer Fire Salvage and Reforestation Project s effects on carbon storage potential and greenhouse gas emissions are not measureable at this scale. Additionally, the report links climate change to ecosystem resiliency, highlighting how ecosystem resiliency can be improved with reforestation of desired species. The importance of carbon storage capacity of the world s forests is tied to their global role in removing atmospheric carbon that is contributing to ongoing global warming. As presented in this report, meaningful and relevant conclusions on the effects of a relatively minor land management action, such as the proposed project, on global greenhouse gas emissions or global climate change is neither possible nor warranted in this case. Nevertheless, it is recognized that global research indicates the world s climate is warming and that most of the observed 20th century increase in global average temperatures is very likely due to increased human-caused greenhouse gas emissions. 2. Analysis Questions Applicable analysis questions for the Carbon Cycling, Storage, and Climate Change resource for the South Pioneer Fire Salvage and Reforestation Project (South Pioneer Project) were derived from relevant laws/regulations/policy, direction from the Boise National Forest Land and Resource Management Plan (Forest Plan), and effects relating to public concerns identified during scoping. The comment response table can be found in the project record. The following lists examples the comments received regarding climate change: What is the cumulative effect of National Forest logging on U.S. carbon stores? How many acres of National Forest System (NFS) lands are logged every year? How much carbon is lost by that logging? (AWR-18) Is this South Pioneer Project consistent with research recommendations (Krankina and Harmon 2006) for protecting carbon gains against the potential impacts of future climate change? [sic] That study recommends [i]ncreasing or maintaining the forest area by avoiding deforestation, and states that protecting forest from logging or clearing offer immediate benefits via prevented emissions. That study also states that [w]hen the initial condition of land is a productive old-growth forest, the conversion to forest plantations with a short harvest rotation can have the opposite effect lasting for many decades. The study does state that thinning may have a beneficial effect to stabilize the forest and avoid stand-replacing wildfire, but the study never defines thinning. In this project, where much of the logging is clear-cutting and includes removing large trees without any diameter limit, and where the removal of small diameter surface and ladder fuels is an unfunded mandate to the tune of over $3 million dollars, it is dubious whether the prescriptions are the same type of thinning envisioned in Krankina and Harmon (2006). (AWR-19) Disclose the impact of climate change on the efficacy of the proposed treatments. (AWR-53) Disclose the impact of the proposed project on the carbon storage potential of the area. (AWR-54) 1

6 Please disclose the effects of carbon dioxide (CO2) produced in operations and compare to the No Action Alternative. (KR-21) The following analysis questions were addressed in the climate change analysis: 1. What are the effects of the alternatives to carbon storage and cycling? 2. What are the effects of the proposed actions on forest resiliency to disturbances including climate change? 3. Relevant Laws, Regulations, and Policy There are no Forest Plan standards related to greenhouse gas emissions (GHG, e.g., carbon) or climate change. The National Environmental Policy Act (NEPA) requires that agencies consider significant effects of proposed actions on the human environment in our decisions. The purpose of an environmental assessment (EA) is, in part, to determine whether there may be significant effects that warrant the preparation of an environmental impact statement (40 Code of Federal Regulations [CFR] ) Guidance on Consideration of Climate Change in Project- Related NEPA Council on Environmental Quality The Council on Environmental Quality (CEQ) has issued revised draft guidance for public consideration and comment on Consideration of the Greenhouse Emissions and the Effects of Climate Change in NEPA Reviews (Federal Register, Volume 79, No. 247, p ). The draft guidance has not been finalized; rather, CEQ solicited public comment. Regardless, the revised draft guidance was considered and the spirit of that guidance applied during the climate change analysis. Forest Service The Forest Service has prepared agency guidance on Climate Change Considerations in Project Level NEPA Analysis ( In general, that guidance recognizes that while some actions may warrant qualitative or even quantitative analysis of the effects of an action on climate change, some actions are at such a minor scale that the effects would be meaningless to a reasoned decision. Other Contextual Considerations The following factors also indicated that further analysis was not necessary or warranted. The top three anthropogenic (human-caused) contributors to greenhouse gas emissions (from ) are fossil fuel combustion, deforestation, and agriculture (Intergovernmental Panel on Climate Change [IPCC] 2007, p. 36). Burning of fossil fuels accounts for 76% of total anthropogenic GHG emissions and since 2000, GHG emissions have been increasing in all sectors, except in agriculture, forestry and other land use (IPCC 2014, p. 46). Land-use change, primarily the conversion of forests to other land uses (deforestation) is the second leading source of human-caused GHG emissions globally (Denman et al. 2007, p. 512). Loss of tropical forests of South America, Africa, and Southeast Asia is the largest source of land-use change emissions (Denman et al. 2007, p. 518; Houghton 2005). 2

7 Unlike other forest regions that are a net source of carbon to the atmosphere, forests in the United States (U.S.) serve as a strong net carbon sink, absorbing more carbon than they emit (Houghton 2003; U.S. Environmental Protection Agency [USEPA] 2013; Heath et al. 2011). For the period , U.S. forests sequestered (i.e., removed from the atmosphere, net) approximately teragrams (Tg) 1 of CO2 each year, with harvested wood products sequestering an additional 101 Tg each year (Heath et al. 2011). National Forests accounted for approximately 30% of that net annual sequestration. National Forests contribute approximately 3 Tg of CO2 to the total stored in harvested wood products compared to about 92 Tg from harvest on private lands (Heath et al. 2011). Within the U.S., land-use conversion from forest to other uses (primarily for development or agriculture) is identified as the primary human activity exerting negative pressure on the carbon sink that currently exists in this country s forests (McKinley et al. 2011; Ryan et al. 2010; Conant et al. 2007). The Proposed Action does not fall within, and is distinguishable from, the primary contributors of global greenhouse-gas emissions discussed in this section, nor is the Proposed Action similar to the primary human activities exerting negative pressure on the carbon sink that currently exists in U.S. forests, namely land-use conversion. The Boise National Forest (Forest) would remain intact as a forest and not be converted to other land uses. Thus, long-term forest services and benefits would be maintained. 4. Relationship of this Project to the 2010 Forest Plan Goals, Objectives, and Desired Future Conditions Relevant to this Resource The South Pioneer Project is located in the Upper South Fork Payette River Management Area (MA 10). The following goals, standards and guidelines in the Forest Plan (USDA Forest Service 2010) pertain to the South Pioneer Project. Compliance and project-related effects relative to Forest Plan direction are provided in detail in the Vegetation Resource technical report located in the project record. Vegetation Management Goals: VEGO01 The diversity of plant community components, including species composition, size classes, canopy cover, structure, snags, and coarse woody debris fall within the desired range of conditions described in Appendix A and contribute to achievement of Forest Plan multiple-use objectives. VEGO06 Species identified as declining (e.g., whitebark pine, western larch, aspen) are restored to desired levels of representation across the planning unit consistent with that described in Appendix A. VEGO07 Elements of vegetative spatial pattern, such as amount, proportion, size, inter-patch distance, variation in patch size, and landscape connectivity are consistent with the applicable fire disturbance regime and contribute to achievement of Forest Plan multiple-use objectives. 1 1 teragram (Tg) = approximately 2.2 billion pounds 3

8 Forest Plan Vegetation Management Standards and Guidelines related to Climate Change: VEGU07 Live and dead vegetative components should be managed in spatial patch sizes and patterns representative of the appropriate fire regime insofar as current conditions allow. VEGU10 Management activities proposed to maintain or restore vegetative desired conditions should emphasize: Retention of snags away from roads or other areas open to public access to reduce the potential for removal. Retention of large snags of seral species (e.g., ponderosa pine and western larch), consistent with species composition desired conditions, to increase longevity of standing snags. WIST08 Retain forest stands that meet the definition of old forest habitat for the applicable potential vegetation group (PVG) (Appendix E). Management actions are permitted in such stands as long as they will continue to meet the definition of old forest habitat. WIST09 Management actions within large or medium-size class forested stands (Appendix A definition) that have the species composition required to achieve old forest habitat for the applicable PVG (Appendix E definition) shall contribute to or not preclude restoration of old forest habitat. Management Prescription Category (MPC) 5.1 Vegetation Standard 0766 For commercial salvage sales, retain the maximum number of snags depicted in Table 1 within each size class where available. Where large snags (>20 inches dbh) are unavailable, retain additional snags 10 inches dbh where available to meet the maximum total number snags per acre depicted in Table 1. This standard shall not apply to management activities that an authorized officer determines are needed for the protection of life and property during an emergency event, to reasonably address other human health and safety concerns, to meet hazardous fuel reduction objectives within wildlandurban interfaces, or to allow reserved or outstanding rights, tribal rights or statutes to be reasonably exercised or complied with. MPC 5.1 Vegetation Guideline 0767 The personal use firewood program should be managed to retain large snags (>20 inches dbh) through signing, public education, permit size restrictions or area closures, or other appropriate methods as needed to achieve desired snag densities (Table 1). 5. Project Area Description The project area is fully described in Chapter 1 of the environmental assessment (EA). 6. Purpose and Need The purpose and need for this project was developed by the interdisciplinary team and approved by the Responsible Official. Refer to Chapter 1 of the EA for a detailed description of the project purpose and need. 4

9 7. Alternatives Considered in Detail The alternatives considered in detail are fully described in Chapter 2 of the EA Project Design Features The design features applicable to the Proposed Action are fully described in Appendix A of the EA. There are no design features specifically for carbon cycling, storage, and climate change; however, design features related to management and protection of the vegetation resource are addressed in the Vegetation Resource technical report (project record). The following design features may affect carbon cycling, storage and climate change. Fire/Fuels FF-1. Pile and burn or disseminate activity fuels, consistent with Design Features FH-8 and TH-2, where needed to protect NFS improvements and facilities; address public safety; and maintain recreational access, use, and visual quality. No hand piling will occur below the road within riparian conservation areas (RCAs), unless otherwise designated through site-specific evaluation by the Hydrologist or Fish Biologist consistent with Design Feature FH-1. VM-1. Retain at least the maximum number of snags post-implementation depicted in Table 1 (USDA Forest Service 2010, Appendix A) within each size class where available by salvage harvest unit. Table 1. Minimum snags retained post-implementation (derived from Forest Plan, Appendix A Table A-6 for the Salvage [Non-Hazard-Tree] PVGs (PVGs 1 4) Snag Class PVG 1 PVG 2 PVG 3 PVG 4 Snags/Acre Snags/Acre Snags/Acre Snags/Acre inches >20 inches Total Minimum Height 15 feet 30 feet 30 feet 30 feet Where large snags (>20 inches dbh) are unavailable, additional snags (>10 inches dbh) shall be retained where available to meet at least the maximum total number snags per acre depicted in Table 1. If substituting smaller snags for the larger (>20 inches dbh) snag class is necessary, the replacements shall consist of snags from the largest diameters available. The average diameter of retention snags shall be equal to or greater than the average diameter of salvaged snags (i.e., retained snags will be a representative sample of the range of snag diameter at breast height pre-harvest). If a harvest unit includes both hazard tree salvage and salvage outside hazard tree removal areas, then the design feature for minimal snag retention shall be met for the entire harvest unit; however, snags shall be retained in the portion of the unit located away from the open road or trail where hazard trees are a concern. 5

10 Snag species marked for retention will give preference to ponderosa pine first, and then Douglas-fir. In units where ponderosa pine and Douglas-fir are co-dominant, both species will be retained although ponderosa pine representation will be greater. Lodgepole pine snags may also contribute to minimum snags per acre standards in harvest units where lodgepole pine is a major seral component. Snags shall be retained in clumps as well as some individuals scattered across the harvest unit. A portion of the imminently dead trees (90% probability of mortality) shall be retained onsite to meet the minimum snag retention standard. The portion retained should be similar to their representation in the salvage unit (i.e., if 10% of the salvageable trees fall within this group, then approximately 10% of the retained snags would come from this group. 8. Analysis Scale, Data Sources, and Methodology 8.1. Analysis Scale The spatial area in which direct and indirect effects on vegetation are analyzed is the project area (39,100 acres). Stand and site conditions outside of the project area have fewer effects on the areas being considered for treatment within the project area boundary and the impacts of those activities. Similar to that done for forest vegetation, cumulative effects were analyzed based on the subwatershed boundaries (6 field Hydrologic Unit Code) for Pikes Fork, Upper Crooked River, Middle Crooked River, and Lower Crooked River (66,968 acres). This boundary was determined to be an appropriate boundary, as watersheds tend to encapsulate important ecosystem functions and processes related to vegetation resiliency and would provide a relative indicator as to effects on carbon storage and cycling that may contribute to effects at broader scales. The temporal time frames used for analysis are 0 2 years for temporary, 10 years for short term, and 30 years for long term. Because GHG emissions mix readily into the global pool of greenhouse gases, it is not currently possible to ascertain the indirect effects of emission from single or multiple sources; therefore, indirect effects were not analyzed for GHG emissions (USDA Forest Service 2009). Because GHG emissions are integrated across the global atmosphere, it is not possible to determine the cumulative impact on global climate from emissions for any number of projects (USDA Forest Service 2009) Data Sources and Analysis Methodology The methods, information sources, science and assumptions that were used for the analysis were noted in individual sections of this report. It is assumed that the current forest vegetation conditions are the sum of all past actions and the conditions that reflect historical management, the biophysical environment, and forest succession and disturbance processes, including the 2016 Pioneer Fire. The analysis was based on field reconnaissance of the project area, the use of plot data, and a variety of other sources that are noted for the specific topics as they are discussed. If information for was not available or incomplete, it was noted. It is important to understand that future wildfires, insect and or disease epidemics, and even climate change may dramatically influence the vegetation conditions in the future making it difficult to project future impacts. 6

11 The Forest Vegetation Simulator (FVS) (Dixon 2002) was used to simulate growth and treatments on the forested vegetation for a comparative analysis between alternatives. Field Sampled Vegetation (FSVeg) polygon data (i.e., stand exam) was used for all stands with existing data. Inventory dates ranged from 1980 to FSVeg Spatial Data Analyzer v (18) (Data Analyzer) was used to conduct a nearest neighbor analysis (USDA Forest Service 2015). This analysis used Landsat images, digital elevation models and climate data to select a nearest neighbor stand with stand-exam data that was assigned to each stand without stand-exam data. Appendix A of the Forested Vegetation technical report contains a statistical report of the nearest neighbor imputation process. For the South Pioneer Project, there are a total of 1,201 stands covering 39,106 acres, of which 590 stands (20,977 acres) contained valid stand exam data and 534 stands (16,968 acres) lacked standexam data. The remaining 77 stands (1,172 acres) are non-forested. Stands were grown in FVS from the inventory date to the date of the Pioneer Fire (2016), which is the common starting date for the modelling. Cycle dates were set in FVS to project vegetation conditions in 2016 (existing pre-fire condition), 2017 (existing post-fire condition and post-treatment condition on dead vegetation and fuels), 2019 (temporary timeframe), 2026 (short-term timeframe) and 2046 (longterm timeframe). These cycle dates were considered adequate for each specialist to analyze effects and capture the timeframes identified in the Forest Plan. Modeling beyond 30 years from the date of the fire also greatly reduces confidence in results. Natural and artificial regeneration were not simulated in FVS, except in a few representative sites, to predict the effects on stream shading in RCAs. Therefore, this analysis did not include quantitative analysis of the effects of the proposed planting activities on carbon. The Fire and Fuels Extension (FFE) (Rebain 2010) is a postprocessor that runs after FVS processes the data for live vegetation. Therefore, the effects of simulated fires and salvage treatments (the SALVAGE key word is in FFE) on live vegetation do not appear in the data until the following cycle. The effects of simulated fires and salvage treatments on dead vegetation (i.e., snags and woody debris) appear in the data the cycle that the activity occurs. For this reason, the fire was simulated in 2016 and the results are displayed in The proposed salvage and hazard tree felling were modelled in 2017 and the results displayed in The amount of carbon released by the operation of motorized equipment to implement ongoing restoration and public safety activities, and the proposed actions, was not calculated and was not part of this analysis. 9. Issues, Indicators and Measures As indicated in Section 2 (Analysis Questions), the following are the key analysis questions: (1) What are the effects of the proposed actions on carbon storage and cycling? (2) What are the effects of the proposed actions on forest resiliency including climate change? The effects on carbon storage and cycling are represented by the amount of standing and down dead biomass (snags and course woody debris [CWD]) within the analysis area, and the effects on forest resiliency are assessed through reforestation of desirable tree species. 7

12 Table 2. Resource indicators and measures for assessing effects Resource Element Forest composition and impact on resistance from and resiliency toward disturbances, including climate change. Carbon stored in standing dead trees (snags) and course woody debris (CWD) Carbon stored in harvested wood products Resource Indicator Species composition Snags and CWD Harvested biomass Measure (Quantify if Possible) Acres reforested with desirable tree species Average snags/ acre and CWD > 3.0 dia. (tons/acre) Biomass removed (dry tons/acre) Used to address: Purpose and Need, or Key Issue? Yes Yes Yes 10. Affected Environment In 2008, the Forest Service developed a Strategic Framework for Responding to Climate Change in order to continue to meet the agency mission to sustain the health, diversity, and productivity of the Nation s forests and grasslands to meet the needs of present and future generations (USDA Forest Service 2008). This strategy was developed in response to concerns that rates of change in climate would potentially exceed the capability of many ecosystems to naturally adapt, and without a consideration of the potential impacts of climate change, the Forest Service would not be able to fulfill its mission. The strategy identifies the following two components for addressing climate change: Facilitated adaptation defined as actions to adjust to and reduce the negative impacts of climate change on ecological, economic, and social systems because ecosystem services may be lost or significantly altered if ecosystems are left to adapt on their own. Without direct intervention, ecosystem health and resilience, productivity, biological diversity, and carbon storage are unlikely to improve or increase; Mitigation defined as actions to reduce emissions and enhance sinks of greenhouse gases to decrease inputs to climate warming in the long-term and reduce the effects of climate change in the long-term. To significantly reduce greenhouse gas emissions, the United States will need to implement a variety of strategies including carbon conservation; alternative fuels; clean energy; tree planting; sequestration in forests, soils and wood products; product substitutions for energyintensive materials; and increased use of energy from wood (USDA Forest Service 2008). In 2009, the Forest Service developed NEPA guidance on how to consider effects of climate change at the project level. The guidance states that forests should consider two types of climate change effects if appropriate to the type and scale of the project: (1) effects of climate change on projects and (2) effects of projects on climate change. The guidance also states that climate change effects on natural resource management should be addressed at the pre-nepa stage, most appropriately at the Forest Plan level (USDA Forest Service 2009). The Forest Plan (USDA Forest Service 2010) incorporated a strategy for responding to climate change based on the development of adaptive capacities of resistance and resilience. This framework was outlined by Millar and others (2007) and has been used by the Forest Service to identify vulnerable ecosystems and develop climate-informed management strategies (Swanston and Janowiak 2012). Resistance is the ability of a system to withstand effects of climate change and maintain values and ecosystem services within desired conditions and resilience is the ability to absorb effects without irreversible change (Millar et al. 2007; Peterson et al. 2011). Swanston 8

13 and Janowiak (2012) defined a third strategy that they called response, which is the ability of a system to accommodate change to a new condition. The concept of adaptive capacity includes considerations such as altering species composition to more drought-tolerant species, reducing density to decease water stress, maintaining the genetic diversity found in local settings, increasing biodiversity within the landscape, and the development of heterogeneous ecosystem mosaics. According to the Forest Plan (USDA Forest Service 2010, p. 89), the effects of climate change on projects were addressed through the development of forest-wide desired conditions assumed to foster resistance and resilience to disturbance, including those associated with a changing climate. Fulé and others (2009) stated that forests with vegetative conditions similar to historical conditions are more resilient to drought, epidemic levels of insect pathogens, and severe wildfire whose pattern or severity are affected by a change in weather. Stands and landscapes that are more fire resistant would likely also be more resilient and resistant to climate change (Stephens et al. 2012). In line with recommendations from Fulé and others (2009), the desired conditions described in the Forest Plan (USDA Forest Service 2010, Appendix A) were founded on concepts of historical range of variability. Noss (2001) recommends adaptive strategies that align with the conservation principles as an additional mechanism for responding to climate change. He states that climatic change by itself is not the greatest threat to today s forests but is an additional stressor. He suggests that restoration of vegetative conditions and landscape patterns within the historical range of variability would result in more adaptable forests. Though many scientists now question the use of the historical range of variability as the long-term goal for ecosystem management, Peterson and others (2011) contend it is an appropriate near to mid-term (i.e., 2 20 year) planning goal while agencies begin the process of incorporating climate change information and potential impacts at the project level. Therefore, it is concluded that actions that move toward the desired conditions and conservation principles described in the Forest Plan respond to the potential effects of climate change on projects. The second effect described by the 2009 Forest Service guidance addresses the effects of projects on climate change. Forests play a major role in the carbon cycle. The carbon stored in live biomass, dead plant material, and soil represents the balance between CO2 absorbed from the atmosphere and its release through respiration, decomposition and burning. The effects of projects on climate change relates to carbon cycling, which includes carbon sequestration and the release of CO2 and other greenhouse gases (USDA Forest Service 2009). Carbon dioxide is constantly exchanged between forest ecosystems and the atmosphere. Tree growth accumulates CO2 and ecological processes such as respiration, decomposition and combustion release it. Forest management affects the mechanisms associated with carbon gain and loss (Smith and Heath 2008). Examples of management practices that can increase CO2 accumulation include afforestation, increased productivity, reduced conversion to non-forest uses, lengthening harvest rotations, and reducing the impacts of fire and insects (Harmon et al. 2009; Smith and Heath 2008). How much CO2 is stored in managed forests is a function of the interval between harvests and the amount of CO2 removed by disturbance (Harmon et al. 2009) as well as the initial conditions (Harmon and Marks 2002). Harmon (2009), Millar (2007) and others found that altering species composition from slower growing to faster growing species can decrease the time it takes to reach a given level of storage capacity. They also concluded that as much carbon can be stored on a site from frequent partial harvest as can be stored during the interval between complete harvests. Millar and others (2007) stated that a warmer and potentially drier climate could lead to an increase in disturbance rates from fire, drought and insects, which would decrease the storage capacity and increase emissions. 9

14 Harmon (2001) noted that though the mechanisms explaining CO2 storage and release occur at fine-scales (e.g., stands) the consequences occur at broader scales (landscapes). Harmon (2001) and Harmon and Marks (2002) advocated that carbon effects must be addressed at the landscapescale to understand the net effect of storage and release. Solomon and others (2007) stated that temporal scale is also important because, though a disturbance such as wildfire can be a significant source of CO2 emissions annually, CO2 is recaptured on decadal timescales as vegetation regrows. In complex landscapes, effects of stands that are releasing more CO2 than storing it can be offset by stands that are storing more CO2 than releasing. Keith (2009), Turner (1995) and others stated that complex multi-aged mixed species stands produced by disturbances or individual tree gaps that create openings, with or without older trees, generally have higher net primary production levels than even-aged stands, or younger stands resulting from stand-replacing disturbance. Mitchell and others (2009) concluded that effected stand severity from wildfire may be decreased by increasing the removal of understory (e.g., ladder fuels) which can consequently lower overall biomass combustion thereby allowing for an increase overall in carbon storage. However, the researchers stated that this finding is most likely correlated with forests that historically had relatively frequent fire where overall biomass levels may be uncharacteristically high now compared to historical levels. In forests with historically long fire-return intervals, treatments likely do not provide the same benefit since these types of forests are less likely to be departed and fire severity is more often a function of weather (drought) than fuel. (Note: in Mitchell and others study, these ecosystems were located on the west side of the Cascades and Coast Range) Turner and others (1995) described the carbon flux arc at the stand-level as follows: After standreplacing disturbance that results in an early seral stage, forests release more CO2 than they store through decomposition of woody debris; as the canopy cover increases (mid-seral stages) the rate of storage overtakes the rate of release through growth; and in older stands (late seral stages) there is a fluctuating relationship between release through respiration from trees due to the energy costs of maintaining a large organism and/or decreases in growth against the amount of carbon stored in dead wood. The researchers concluded that the rate of potential carbon accumulation on the same land-base is higher with a timber harvest regime than without management, due to removals of carbon as wood products and the time period lands are maintained in mid-seral stages compared to without management where fire and woody debris decomposition would exceed accumulation. For the Rocky Mountain region, they stated that because the land-base is relatively stable, and because both growth and harvest rates are relatively low compared to areas like the Pacific Northwest, the overall carbon flux has likely not changed much over the past several decades. Though there is an increasing body of literature regarding the relationships among CO2 storage, release, management activities and disturbance processes, as described in the 2009 Forest Service guidance the agency currently does not have an accepted tool for analyzing greenhouse gases. Though FVS can estimate total stand carbon, carbon removed over time under different management scenarios and disturbances such as fire, insects and disease, it does not address other types of processes, such as decomposition or respiration that in some ecosystems can be a major source of CO2 release (Turner et al. 1995). FVS also does not address other mechanisms of on-site storage and does not account for CO2 that could be produced from the removal, transportation, and processing, which are CO2 sources many authors contend must be considered. Though the 2009 guidance states that the Agency would continue to invest in developing analysis methods for assessing carbon storage and estimating GHG emissions, the guidance also states that because the scale of most projects, with the potential exception of oil and gas proposals, is extremely small, it is not possible to conduct meaningful quantitative evaluations, particularly without a context at scales above the project level (e.g., state or regional levels), to assess outcomes (USDA Forest Service 2009). Therefore, alternative comparison was limited to a quantitative comparison of the 10

15 amount of dead wood biomass (standing and down) 3.0 inches in diameter to represent the effects of the Proposed Action on carbon storage. However, this measure does not intend to measure the amount of carbon released to the atmosphere, nor does it represent the effects of the project on climate change. The effects of the project on climate change was not evaluated, as allowed by the 2009 guidance Existing Condition Forests are in continual flux, emitting carbon into the atmosphere, removing carbon from the atmosphere, and storing carbon as biomass (sequestration). Over the long term, one or more cycles of disturbance and regrowth (assuming the forest regenerates after the disturbance), net carbon storage is often zero because re-growth of trees recovers the carbon lost in the disturbance and decomposition of vegetation killed by the disturbance (McKinley et al. 2011; Ryan et al. 2010; Kashian et al. 2006). The majority of the project area, and all of the proposed treatment units, were burned by the Pioneer Fire. Prior to the fire, forests were composed of mixed conifer species with a variety densities and structures dominated by mid- to late- seral age classes. At this stage of development, these stands would have been estimated to be net carbon sinks. That is, they were sequestering carbon faster than they were releasing it to the atmosphere. The strength of that sink however has likely been reversed to a source, or at least weakened as a sink, due to recent fire activity which caused tree mortality. Over time, these areas may shift back into a sink stage in their carbon cycle assuming reforestation occurs. Currently an actual value for carbon flux rates has not been calculated for the Forest. The amount of carbon released by a fire and the subsequent indirect source of carbon emissions from long-term decomposition of vegetation killed in the fire depends on the productivity of the ecosystem, the severity of the fire, and the ability of the ecosystem to recover (DellaSala and Hanson 2015). Low severity fires kill understory plants, shrubs, and small trees, which are not a significant portion of total stand carbon storage and do not represent a significant source of carbon emissions when they decomposition. However, high severity fires kill all, or nearly all, overstory trees. Unburned leaf litter and woody debris from fire-killed trees (limbs) have a high turnover (10 20 years). Following the fire, a large pool of woody debris (logs and snags) remains that is a significant source of carbon emissions, releasing (and storing) carbon up to 100 years or more (DellaSala and Hanson 2015). 11. Environmental Consequences No Action Alternative Direct and Indirect Effects No wood products would be harvested or stored (e.g., building materials) under the No Action Alternative, but dead trees (snags) would fall, contribute to down dead wood, and decay over time. Table 2 displays the average number of snags per acre and the average amount of CWD ( 3.0 inches in diameter) in tons per acre. Table 2 would also show the amount of biomass removed, but, as previously mentioned, no material would be removed (harvested) under the No Action Alternative. 11

16 Table 3. Projected total average snags, course woody debris and removals for the project area under the No Action Alternative Year Timeframe Average Snags/Acre 0.1" dbh Average CWD a (tons/acre) 2016 Pre-fire Post-fire and treatment Temporary Short term Long term a CWD = course woody debris, which is down woody material 3.0 inches in diameter No direct human-induced emissions of carbon into the atmosphere would occur under the No Action Alternative. The number of snags per acre peaks in 2017 and then declines during each cycle as snags fall to the ground and add to CWD. Conversely, the total biomass in CWD increases each cycle through the planning period. The total amount of dead biomass ( 3.0 inches in diameter) also peaks in 2017 due to the amount of biomass in standing snags and gradually decreases as a result of decomposition. Table 2 does not reflect the amount of carbon released to the atmosphere, but it does represent the relative amount of carbon stored on-site in standing and down dead wood, which is the measure being used to compare to the Proposed Action. Generally due to fire mortality, the analysis area would continue to function as a carbon source through the planning period, with dead trees releasing carbon into the atmosphere as they decompose. This state would continue until the rate of forest re-growth, assuming trees regenerate, meets and exceeds the rate of decomposition of the killed trees. As stands continue to develop, the strength of the carbon sink would increase and typically peak at an intermediate age, and then gradually decline, but overall remain positive (Pregitzer and Euskirchen 2004). Carbon stocks would continue to accumulate as the stands mature, although at a declining rate, until again impacted by subsequent disturbance. The amount and duration of carbon emissions from long-term decomposition of fire-killed vegetation depends on the productivity of the ecosystem, the severity of the fire, and the ability of the ecosystem to recover (DellaSala and Hanson 2015). Low severity fires kill understory plants, shrubs, and small trees, which are not a significant portion of total stand carbon storage and do not represent a significant source of carbon emissions when they decompose. Unburned leaf litter and woody debris from fire killed trees (needles and limbs) have a high turnover (10 20) years. Following high severity fire which frequently results in mortality of all, or nearly all of overstory trees, a large pool of large woody debris (logs and snags) remains and is a significant source of carbon emissions, releasing (and storing) carbon up to 100 years or more (DellaSala and Hanson 2015). Low productive ecosystems (e.g., interior ponderosa pine) take longer to shift from being a carbon source to carbon sink than high productive forests (e.g., coastal Douglas-fir). Some studies indicate that ponderosa pine and dry mixed forest types may take 40 years to shift from source to sink (DellaSala and Hanson 2015). Though the long-term ability of forests to persist as net carbon sinks is uncertain, drought stress, forest fires, insect outbreaks and other disturbances may substantially reduce existing carbon stock (Galik and Jackson 2009). Climate change threatens to amplify risks to forest carbon stocks by increasing the frequency, size, and severity of these disturbances (Dale et al. 2001; Barton 2002; Breashears and Allen 2002; Westerling and Bryant 2008; Running 2006; Littell et al. 2009; Boisvenue and Running 2010). Recent research indicates that these risks may be particularly acute for forests of the Northern Rockies (Boisvenue and Running 2010). Increases in the severity of disturbances, combined with projected climatic changes, may limit post-disturbance forest 12

17 regeneration, shift forests to non-forested vegetation, and possibly convert large areas from an existing carbon sink to a carbon source (Barton 2002; Savage and Mast 2005; Allen 2007; Strom and Fule 2007; Kurz et al. 2008a,b; Galik and Jackson 2009). Providing for prompt reforestation after disturbance increases the likelihood that forests become sinks again in the future and may increase the rate of carbon storage Cumulative Effects The No Action Alternative does not propose any changes to the existing condition. Dead trees would continue to fall, and these carbon sources would decay and release carbon into the atmosphere. However, the cumulative effects at the regional and global scales would not be discernable on atmospheric concentrations of greenhouse gases or global warming, because of limited changes in both rate and timing of carbon flux predicted in the project area, the global scale of the atmospheric greenhouse gas pool, and the multitude of natural events and human activities that contribute to that pool No Action Alternative Conclusion The effects of the No Action Alternative would be consistent with policy and science regarding ecological conditions and resilience to climate change Proposed Action Direct and Indirect Effects As described in the EA, the Proposed Action includes the following activities that would have direct effects on carbon storage and cycling: Hazard and dead tree salvage on about 5,305 acres Hazard tree fell and leave on about 2,542 acres Salvage dead trees (not hazard trees) on about 3,971 acres Planting of early successional species in priority areas that burned at uncharacteristic severity on about 12,571 acres Planting of blister rust resistant whitebark pine on about 294 acres Planting of riparian trees and shrubs on about 37 acres An estimated 32.4 million board feet (MMBF) of wood products would harvested The Proposed Action includes the following activity that has indirect effects on forested vegetation: Decommissioning of about 4.4 miles of unauthorized routes In large, high severity patches, where limited-to-no seed sources remain, sparse natural regeneration may result in delayed successional trajectories or altered vegetation states (Kemp et al. 2015). Thus, to contribute to accomplishing Need 2, planting of long-lived, early seral species (e.g., ponderosa pine and Douglas-fir) in strategic locations would occur to establish future seed sources, enhancing overall recovery processes and trending the vegetation toward desired future conditions. Areas expected to recover naturally would be monitored and planting could occur in 13

18 selected priority locations, if deemed necessary for other resource priorities (e.g., wildlife habitat, scenic or whitebark pine restoration) FVS projections indicate a fewer average snags per acre across the project area in 2017 (Table 3) under the Proposed Action compared with the No Action Alternative (Table 2), as expected, because of hazard tree removal. A corresponding increase in CWD would be seen after the treatments in 2017 from felling and leaving of hazard trees in RCAs, and limbs and tops left on the ground following the harvest of snags (Table 3). Regardless, the amount of CWD is lower under the Proposed Action compared with the No Action Alternative (Table 2), In the short- and longterms, the average number of snags per acre would continue to decline as the snags fall, while there would be a corresponding increase in CWD. Table 4. Projected total average snags, course woody debris and removals for the project area under the Proposed Action Year Timeframe Average Snags/Acre 0.1" dbh Average CWD a (tons/acre) 2016 Pre-fire Post-fire and treatment Temporary Short term Long term a CWD = course woody debris, which is down woody material 3.0 inches in diameter The Proposed Action would result in an estimated 5.9 bone dry tons per acre of wood products (biomass) harvested from dead trees; the majority of which would be used as building materials and in ways that may store carbon for a longer period than decay rates would allow on the ground. Decommissioning of unauthorized routes would reduce access to fuelwood gathering, which would reduce the number of standing snags that would be removed. This reduction would result in a faster release of carbon into the atmosphere then use of the wood as construction material or if left in the forest. However, the number of variables prohibits the ability to quantify the amount of biomass affected by closure of unauthorized routes. In general, the total amount is small in comparison to the total dead biomass in the project area. All of these amounts represent a miniscule area in the context of regional carbon stores. In the short term, the Proposed Action would remove some carbon currently stored in dead biomass through cutting of hazard trees and fire-killed timber in the salvage units. A substantial portion of this carbon would remain stored for a period of time in wood products (USEPA 2013; Depro et al. 2008). For the short term, on-site carbon stocks may be lower under the Proposed Action than under the No Action Alternative, because the removal of wood contained in roadside hazard trees and from the salvage units would reduce some of the carbon available to be emitted through decomposition of this material. Removing the majority of the burned trees in the salvage units would provide open and safe areas to reforest with native seral species, consequentially speeding up the overall ecosystem recovery with resilient tree species adapted to future disturbances (see the desired conditions and resiliency discussion in the Vegetation Resource technical report in the project record). The proposed reforestation would help ensure these forest stands return to a carbon sink function as quickly as possible. As the stands continue to develop, the strength of the carbon sink would increase until peaking at an intermediate age, and then gradually decline, but remain positive (Pregitzer and Euskirchen 2004). Carbon stocks would continue to accumulate as the stands mature, although at a declining rate, until impacted by future disturbances. 14