Boise National Forest

Transcription

1 Forest Service Boise National Forest 1249 South Vinnell Way, Suite 200 Boise, ID File Code: 1950/2400 Route To: Date: MAY Subject: To: (SIR) for the 2013 Clear Creek Integrated Project Environmental Assessment and Decision Notice and Findings of No Significant Impact Project File Introduction The Clear Creek Integrated Project is located on the Lowman Ranger District of the Boise National Forest (Forest). On September 17, 2013, Deputy Forest Supervisor Marie-Louise Smith signed a Decision Notice and Findings of No Significant Impact (DN/FONSI) authorizing implementation of Alternative C (USDA Forest Service 2013a). That decision included commercial and noncommercial thinning within and outside a wildland urban interface (WUI), prescribed fire, temporary road construction, conversion of unauthorized routes to National Forest System (NFS) roads, road closures and decommissioning, culvert replacement/removal, conversion of NFS roads to designated motorized trails, new mountain bike trail and trailheads, trail reroutes, mitigation measures and design features, and monitoring. The vegetation management decisions have yet to be implemented, while portions of the road and trail activities have been implemented. Policy for New Information or Changed Circumstances Council on Environmental Quality National Environmental Policy Act (NEPA) requirements (40 CFR (c)) and Forest Service NEPA implementing procedures (FSH , Section 18) require that if new information or changed circumstances relating to the environmental impacts of a proposed action come to the attention of the responsible official after a decision has been made and prior to completion of the approved program or project, the responsible official should review the information carefully to determine its importance. In this review, consideration would be given to whether or not the new information or changed circumstances are within the scope and range of effects considered in the original analysis. If, after an interdisciplinary review and consideration of new information, the responsible official determines that the new information falls within the scope and range of the effects considered in the original analysis, a correction, supplement, or revision to an environmental document is not necessary and implementation would continue. Conversely, a supplement or revision to an EA would be needed ifthe interdisciplinary review of the new information or changed circumstances indicates that changes in the EA are needed to address environmental concerns not previously disclosed that have a bearing on the action or its impacts. If it is determined that a supplement or revision to the EA and/or DN/FONSI are required project implementation would cease until the supplementation process is completed. This supplemental impact report (SIR) is not a NEPA document and, therefore, cannot be used to fulfill the requirements for a revised or supplemental environmental assessment (EA). This SIR simply documents the interdisciplinary review and the responsible official's determination as to whether a correction, supplement, or revision of environmental documents is necessary. This SIR will serve as the documentation of the results of the interdisciplinary review and responsible official's determination. 1

2 New Information Following issuance of the September 2013 DN/FONSI, new information and changed circumstances were identified that may have a bearing on the decisions made. This file document was prepared to record changes that occurred during implementation, as well as to consider recommendations to modify the commercial vegetation treatment acres and Design Feature VE-7, and whether these changes would result in effects not previously disclosed. Specifically, this document addresses the following: 1) Are modifications in road and trail management activities that have occurred to date consistent with the 2013 DN/FONSI? 2) Are the effects identified in the biological assessment (BA) and biological evaluations (BEs) still valid, compatible, and consistent with the conservation of threatened, endangered, and Region 4 sensitive species whose status has changed? 3) Should recommendations to reduce acres of commercial vegetation treatments be implemented, and, if they should, will the effects be measurably different from those disclosed? 4) Should adjustments in treatment boundaries be implemented as identified during field layout in 2014 and, if they should, will the effects be measurably different from those disclosed? 5) Should Design Feature VE-7, which pertains to commercial vegetation management treatments, be modified to address the difference in conditions observed in the field in 2014 compared to stand data used in the assessment supporting disclosures, and, if implemented, will the effects be measurably different from those disclosed? Road and Trail Management 1. Are modifications in road and trail management activities that have occurred to date consistent with the 2013 DN/FONSI? National Forest System Road 562C The Clear Creek decision identified that NFS road 562C would be converted to a motorized trail (USDA Forest Service 2013a, p. 55). During the 2014 field season, it was discovered that a portion (~0.4 miles) of this road did not exist on the ground (Figure 1). The discrepancy between the GIS layer (i.e., 2014 [Motor Vehicle Use Map] MVUM) used during planning and on-the-ground conditions were first reported by an employee treating weeds and conducting weed inventories within the project area in At the direction of the District Ranger, the discrepancy was confirmed by the trail crew foreman on October 27, Subsequently, the error was corrected on the annual update to the MVUM, and will be correct on the 2015 MVUM. This change reduced the miles of NFS roads to be converted to motorized trail identified in the 2013 DN/FONSI from approximately 7.6 miles to 7.2 miles. Because the 0.4 miles did not actually exist on the ground, no change in effect would occur because no NFS road existed to convert. The slight reduction in trail miles would not result in a measurable change in the user experience of this trail area. 2

3 Figure 1 Portion of National Forest System road 562c that does not exist on the ground 3

4 National Forest System Road 552 The Clear Creek DN/FONSI identified segments of NFS road 552 would be managed three ways (Figure 2): The end segment, approximately 0.4 miles long, will be decommissioned (USDA Forest Service 2013a, Table DN-7). The middle segment, approximately 0.4 miles long, will be closed (Maintenance Level 1[ML1]) (USDA Forest Service 2013a, Table DN-5). The beginning segment, approximately 0.9 miles long, starting at the junction of NFS roads 552 and 582 and extending to near the first Big Spruce Creek crossing will be seasonally open from April 16 through December 14 (USDA Forest Service 2013a, Table DN-6). Two culverts on Big Spruce Creek and fork will be removed and a barrier will be placed to prevent motorized crossing of the streams and use of the closed segment. During the 2014 field season, Resource Advisory Committee (RAC) funding was received to implement a portion of the transportation and fish habitat improvement work. Work on NFS road 552 was included in a contract that was subsequently awarded and completed during The engineer working on the survey and specifications for the contract package consulted with the District Ranger regarding provisions concerning a camping spot near the end of the road segment that was to remain seasonally open (i.e., bullet 3 above). Providing a camping spot was a point of discussion between the Forest Service and the Boise Forest Coalition during project planning and collaboration for the Clear Creek Project. Essentially, removing the two culverts on Big Spruce Creek and fork will eliminate access to an existing campsite that was located between the two culverts. To address concerns about providing camping in this area, the 2013 DN/FONSI included provisions to provide a turnaround and campsite near the end of the road segment designated as seasonally open. The engineer and District Ranger visited the area in 2014 to determine the best location for the turnaround and campsite, eventually settling on the landing located approximately 0.1 miles from the junction with NFS road 582. This location was selected because of concerns regarding the amount of ground disturbance (bulldozing) required to provide a turnaround and campsite at other locations along the road segment. The road closure point was established just beyond the landing, which was approximately 0.75 miles before the point originally considered in the DN/FONSI. Thus, transportation management for NFS road 552 was implemented as follows: Decommission approximately 0.4 miles (no change) Close approximately 1.1 miles (an increase of 0.75 miles from the DN/FONSI) Open Seasonally approximately 0.1 miles (a decrease of 0.75 miles from the DN/FONSI) The final location of the campsite remained in the vicinity originally planned and was placed in a location requiring less ground disturbing activities to provide for safe ingress and egress. 4

5 Figure 2 National Forest System road 552 management decisions 5

6 Threatened, Endangered, Proposed, and Sensitive Species 2. Are the effects identified in the BA and BEs still valid, compatible, and consistent with the conservation of threatened, endangered, and Region 4 sensitive species whose status has changed? Threatened, Endangered, or Proposed Terrestrial Wildlife Species The U.S. Fish and Wildlife Service (USFWS) concurred with the effects determinations disclosed in the project s BA (project record) on October 24, As summarized below, no new information or changed conditions would result in effects on any species differently from those previously disclosed. Therefore, reinitiating consultation is not necessary. North American Wolverine (Gulo gulo luscus) Wolverine was proposed for listing under the Endangered Species Act (ESA) at the time of the original analysis and DN/FONSI. The USFWS has since withdrawn their proposal for listing (79 FR , August 13, 2014). The Regional Office has not updated their list of threatened, endangered, proposed, and sensitive species since February 2013, and the species is still shown as Proposed. However, once the USFWS withdrew their proposal to list, the species status reverted to Sensitive. Effects to wolverine were considered and analyzed in the Clear Creek Integrated Project EA (USDA Forest Service 2013b). Source habitat is present at higher elevations within the project area. Effects to wolverine from implementing Alternative C were related to a (potential) temporary increase in road and trail density (risk indicator) from the construction of temporary roads for commercial harvest activities. The determination was not likely to jeopardize proposed species or modify proposed critical habitat, language that is specific to a species proposed for listing. With the species status reverting to Sensitive, the appropriate determination language would be may impact individuals but is not likely to cause a trend to federal listing or loss of viability. Yellow-billed Cuckoo (Coccygus americanus) Since the DN/FONSI for the Clear Creek Integrated Project was issued, the status of the yellow-billed cuckoo has changed from a Candidate for listing to listed as Threatened under the ESA. The Final Rule for listing (Western Distinct Population Segment) was published in the Federal Register (Vol. 79, No. 192, pp ) on Friday, October 3, 2014, and became effective on November 3, A new species list was requested for the Clear Creek Integrated Project Area and received from the USFWS on February 25, 2015 (project record). Yellow-billed cuckoo was not on the list. The original biological evaluation considered yellow-billed cuckoo and determined habitat was not present and the species and habitat would not be affected by project activities. A determination of no impact was made based on the species status of Candidate for listing. The appropriate determination language for a species listed as Threatened is no effect. In this case, since the species was not on the official species list received from the USFWS (February 25, 2015) and habitat for the species does not occur in or near the project area, no biological assessment of effects or determination is needed. Sensitive Terrestrial Species No change has occurred since the 2013 DN/FONSI. Threatened, Endangered, or Proposed Fish Species or Designated or Proposed Critical Habitat No change has occurred since the 2013 DN/FONSI. Sensitive Fish Species No change has occurred since the 2013 DN/FONSI. Threatened, Endangered, or Proposed Plant Species or Designated or Proposed Critical Habitat Spiranthes diluvialis (Utes ladies-tresses) Since the DN/FONSI for the Clear Creek Integrated Project was issued, Spiranthes diluvialis has been removed from the USFWS official list of Threatened, 6

7 Endangered, and Proposed (TEP) plants of concern on the Forest. The new species list was requested for the Clear Creek Integrated Project area and received from the USFWS on February 25, 2015 (project record). Since the species was not on the official species list received from USFWS (February 25, 2015) and habitat for the species does not occur in or near the project area, no biological assessment of effects or determination is needed. Silene spaldingii (Spalding s catchfly) Since the DN/FONSI for the Clear Creek Integrated Project was made, Silene spaldingii has been removed from the USFWS official list of TEP plants of concern on the Forest. The new species list was requested for the Clear Creek Integrated Project Area and received from the USFWS on February 25, 2015 (project record). Since the species was not on the official species list received from the USFWS (February 25, 2015) and habitat for the species does not occur in or near the project area, no biological assessment of effects or determination is needed. Sensitive Plant Species No change has occurred since the 2013 DN/FONSI. Vegetation Management 3. Should recommendations to reduce acres of commercial vegetation treatments be implemented, and if they should, will the effects be measurably different from those disclosed? Table DN-1 of the 2013 DN/FONSI (replicated as Table 1 below) identified 706 acres of low to mid-elevation forest would be commercially treated 501 acres outside the WUI and 205 acres within the WUI. Table 1 Summary of vegetative/fuels restoration activities to be implemented in low to midelevation forests Action [Yellow highlighted rows pertain to commercial treatment acres, 706 total] Alternative C (acres) Low- to Mid-elevation Forests 1. Non-Wildland-urban Interface (WUI) Mechanical commercial thin and Noncommercial Thin (NCT) 501 Commercial Tractor logging system 181 Commercial Skyline logging systems Non-WUI Mechanical NCT thinning only 749 In Riparian Conservation Area 125 Outside Riparian Conservation Area IRA Broadcast burning only 84 Subtotal Non-WUI mechanical treatments + IRA broadcast burn only acres 1,334 WUI Mechanical commercial thin and NCT 205 Commercial Tractor logging system 87 Commercial Skyline logging systems 118 WUI Mechanical NCT only 291 a. In Riparian Conservation Area 94 b. Outside Riparian Conservation Area 197 Subtotal WUI Mechanical Treatments 496 TOTAL low- to mid- elevation mechanical + IRA broadcast burn treatments 1,830 7

8 Following layout of commercial treatment units in 2014, the resulting acres of commercial vegetation treatment to be implemented was reduced to 388 acres of those identified in the DN/FONSI planned 265 acres outside the WUI and 123 acres within the WUI. This difference reduces commercial vegetation treatments by 318 acres ( 45%) 236 fewer acres ( 47%) outside of the WUI and 82 fewer acres ( 40%) within the WUI. Table 2 explains why acres were removed. Table 2 Change in acres to be commercially treated from those identified in the 2013 Decision Notice and Findings of No Significant Impact to those identified during the 2014 layout Reason for Removing Commercial Treatment Acres Outside the Wildland Urban Interface ( 236 acres) Within the Wildland Urban Interface ( 82 acres) Total Acres (%) Acres Total Acres (%) Acres Economics Low volume Low volume/desired condition Operational constraints Riparian Conservation Areas Summer homes TOTAL Note: Economics = Stand had volume but cost of extraction exceeded the benefits of treatment; Low Volume = no volume, openings, or plantations existed; Low Volume/Desired Conditions = volume not available mainly due to no excess stocking, stand at or near desired Basal Area; Operations = operability issues with the logging system or minor layout issues; Riparian Conservation Areas = no commercial treatments within RCAs were included in the 2013 Decision Notice and Findings of No Significant Impact (see USDA Forest Service 2013a, Table DN-1); Summer Homes = dropped because of facilities, safety issues, risk of property damage, road work required to facilitate removal, and need. Table DN-1 in the DN/FONSI (USDA Forest Service 2013a) for the Clear Creek Integrated Project was developed from model runs/datasets that cannot account for resource constraints such as the 6 categories identified above and, thus, overestimated what would actually be treated. During the 2014 field season, layout personnel discovered portions of forested stands identified in the Decision to be commercially treated within and outside the WUI, were in reality, not in need of treatment or not practicable for treatment for one of the reasons identified in Table 2 (refer to Figure 3). As identified in the DN/FONSI, all acres planned to be commercially treated, including those removed for the reasons identified above, will be reviewed for implementation of non-commercial treatments. Non-commercial treatments will be implemented in forest stands where, as intended in the 2013 DN/FONSI, such treatments will move stand structure, species composition, and/or densities toward conditions identified in the project purpose and need. Non-commercial treatments, including fuel management activities, are expected to have beneficial effects that fall within the range of effects disclosed in the EA for Alternative C (USDA Forest Service 2013a), the selected alternative in the DN/FONSI. 8

9 Figure 3 Contract commercial harvest units laid out in 2014 compared to original stand boundaries 9

10 4. Should adjustments in treatment boundaries to include areas outside areas proposed for treatment under the 2013 DN/FONSI be implemented, and if they should, will the effects be measurably different from those disclosed? (refer to Figure 3) During layout in 2014, it was identified that boundaries of forested stands identified through aerial photo for purposes of forest stand analysis in support of the 2013 EA were not fully consistent with field conditions (e.g., boundaries did not account for the full extent of a forest stand with similar characteristics, boundaries did not follow logical topographic features such as ridgelines or RCA boundaries adjacent to a drainage). As a result, crews made adjustments in the field during the layout of contract units in These adjustments added 80 acres across 28 units that had originally fallen outside stand boundaries delineated from aerial photos (see Figure 3). When added to the 388 acres to be treated (of the original 706 acres identified in the DN/FONSI under #3 above), the total acres to be commercially treated is now 468 acres. Adjustments in the field during field layout to provide for more logical unit boundaries based on conditions observed is typical and essential to ensuring treatment objectives are met while also meeting other resource design features/mitigation. Treatments in these 80 acres (e.g., silivicultural prescriptions, logging systems, temporary road miles, and fuels treatments) would be the same as identified for areas immediately adjacent because the observed conditions of these two areas were the same once laid out in the field. Thus, based on review by resource specialists, the effects of treating the 388 acres plus the additional 80 acres (total 468 acres) would fall within the effects disclosed in the 2013 EA. 5. Should design feature VE-7 which pertains to commercial vegetation management treatments be modified to address the difference in conditions observed in the field in 2014 compared to stand data used in the assessment supporting disclosures, and if implemented, will the effects be measurably different from those disclosed? Design Feature VE-7 in the 2013 DN/FONSI states the following: VE-7 Retain all trees greater than or equal to the diameter at breast height displayed in Table DN-9 in forested stands proposed to be commercially harvested, except where removal is required for safety mitigation or operational purposes such as landings or yarding trails/corridors and associated with road construction, road reconstruction, and road maintenance. Table DN-9. Diameter retention by treatment and species Acres Ponderosa Pine Diameter Retention (dbh in inches) Douglas-fir Diameter Retention (dbh in inches) Other Species Diameter Retention (dbh in inches) Restoration Prescriptions a Total for Noncommercial 1, Thinning Prescriptions a Restoration Prescription: Low- to mid-elevation forests in project area, including Wildland Urban Interface (WUI) (706 acres total in Potential Vegetation Groups (PVGs) 1, 2, and 3 [habitat types in PVG 3 where ponderosa pine is a primary species]). While the narrative for Design Feature VE-7 1 would remain unchanged, Table DN-9 would be modified as noted below. 1 VE-7 Retain all trees greater than or equal to the diameter at breast height displayed in Table DN-9 in forested stands proposed to be commercially harvested, except where removal is required for safety mitigation or operational purposes such as landings or yarding trails/corridors and associated with road construction, and road maintenance. 10

11 Table DN-9 (updated). Proposed modification in diameter retention (in diameter at breast height [dbh]) by stratum and species for noncommercial thinning prescriptions Acres Ponderosa Pine Diameter Retention (dbh in inches) Douglas-fir Diameter Retention (dbh in inches) Other Species Diameter Retention (dbh in inches) Restoration Prescriptions a Stratum A Stratum B Stratum C Stratum D Stratum E TOTAL per Stratum 468 Total for Noncommercial Thinning Prescriptions 1, a Restoration Prescription: Low- to mid-elevation forests in project area, including Wildland Urban Interface (WUI) (706 acres total in Potential Vegetation Groups (PVGs) 1, 2, and 3 [habitat types in PVG 3 where ponderosa pine is a primary species]). The data included in the original Table DN-9 was developed from the model runs, which indicated that no trees larger than the referenced diameter retentions would be removed. During the 2014 field season, the silviculturist and layout personnel discovered the diameter retention design feature limited their ability to promote ponderosa pine (desired major early seral species) retention and to develop desired group and clump structure within areas noted above (strata B and D). The modifications are proposed so that species composition and stand structure (grouping/clumping) objectives identified in the 2013 EA and DN/FONSI can be met. The proposed modification would raise the ponderosa pine diameter retention to >16 inches dbh (stratum B only) and the non-ponderosa diameter retention to >24 inches dbh (strata B and D). The modifications are proposed to better promote ponderosa pine (desired seral, fire resistant species) retention; reduce ladder fuels and competition surrounding legacy and large ponderosa pine; and better develop and promote desired clumping and grouping structural components within stands. Table 3 provides a post-treatment crosswalk between the layout strata timber cruise data (proposed modification) and the data used during the original analysis (Clear Creek Integrated Project EA [USDA Forest Service 2013b]) for the wildlife resource. The two sets of data were collected for different purposes and were processed by different programs. Nonetheless, several attributes used in the wildlife analysis can be generated from both sets of data. The attributes included in Table 3 are those used to model white-headed woodpecker habitat during the analysis for the EA. The original wildlife analysis clearly stated that the data used during analysis had limitations and the analysis accurately reflected trends in habitat abundance, quality, and patch size and distribution. A comparison between the analyses found in the EA with that based on layout strata (Table 3) shows a similar outcome in vegetation conditions between the proposed modification and the analysis that the DN/FONSI was based on. Stand canopy cover was one attribute that could not be determined from the cruise data because only data for trees 8 inches dbh are collected. Stand canopy cover is based on all trees 0.1 inches dbh. The larger trees in mature stands (large and medium tree size classes) are likely major contributors to stand canopy, so it was assumed that if other attributes were similar (e.g., basal area, number of large trees, tree size class), stand canopy would also be comparable. 2 Strata is a grouping of similar or like stand conditions and stand components used to define statistical outcomes for various metrics of interest. In this case the stratification was for the purpose of determining values and associated statistics for commercial sawlog removal. Stratification allows for a refinement of the original treatment acres on a site-by-site basis. 11

12 Table 3 Crosswalk from layout strata to analysis stands Layout Stratum Stratum B 13.7 acres (WUI) acres (Restoration) Stratum D 75 acres (Restoration) Layout Strata Post-Treatment General Description with Proposed Diameter Limit Changes (based on data collected for layout stratification) Potential Vegetation Group (PVG): Described as PVG 2 with a good representation (>40%) of ponderosa pine. No additional habitat type data taken. Was based on site and tree species observations made by experienced layout personnel. Tree Size Class: Large b Large Trees per Acre: 12+ b Large Ponderosa Pine per Acre: 7+ Percent of medium and large trees that are ponderosa pine: 67% c Basal Area of Ponderosa Pine Trees 8 inches dbh (per acre): 47 ft 2 Basal Area of all trees 8 inches dbh: 71 ft 2 Stand canopy cover not generated attribute based on all trees >0.1 inch dbh. Timber cruise data is only collected for trees >8.0 inches dbh. PVG: Described as PVG 2 with a poor representation (<10%) of ponderosa pine. No additional habitat-type data taken. Was based on site and tree species observations made by experienced layout foreman. Tree Size Class: Large b Large Trees per Acre: 18 b Large Ponderosa Pine Trees per Acre: 3 Percent of Medium and Large Trees that are Ponderosa Pine: 20% c Basal Area of Ponderosa Pine 8 inches dbh: 22 ft 2 c Basal Area of all trees 8 inches dbh: 80 ft 2 Stand canopy cover not generated this is based on all trees >0.1 inch dbh. Timber cruise data is only collected for trees >8.0 inches dbh. Analysis Stands a Post-Treatment General Description based on Wildlife Analysis for the Environmental Assessment (based on stands and stand exam data including MSN that fall within each strata) d PVG: PVGs 3 (66%) and 2 (34%). Tree Size Class: Large (74%) and Medium (26%) Stand Canopy Cover: Ranges from 22% to 33% (weighted average is 28%). Large Trees per Acre: Ranges from 6 to 21 (weighted average is 13). Large Ponderosa Pine per Acre: ranges from 2 to 12 (weighted average is 7) Percent of Medium and Large Trees that are Ponderosa Pine: Ranges from 5% to 80% (weighted average is 46%). Basal Area of Ponderosa Pine Trees >5 inches dbh: Ranges from 12 ft 2 to 60 ft 2 (weighted average is 45 ft 2 ). Basal Area of all trees 5 inches dbh: Ranges from 71 ft 2 to 98 ft 2 (weighted average is 85 ft 2 ). Includes 1 stand ( ) that was assigned Most Similar Neighbor data. This stand represents 36% of the acres included in statistics above. PVG: 3 (100%). Tree Size Class: Large (100%). Stand Canopy Cover: Ranges from 26% to 32% (weighted average is 28%) Large Trees Per Acre: ranges from 13 to 18 per acre (weighted average is 15). Large Ponderosa Pine Trees per Acre: Range of 2 to 5 (weighted average of 3). % Medium and Large Trees that are Ponderosa Pine: Range of 5% to 37% (weighted average is 23%). Basal Area of Ponderosa Pine Trees 5 inches dbh: ranges from 12 ft 2 to 40 ft 2 (weighted average is 27 ft 2 ). Basal Area of all trees 5 inches dbh: Ranges from 79 ft 2 to 86 ft 2 (weighted average is 83 ft 2 ). Includes 2 stands ( and ) that were assigned Most Similar Neighbor data. These stands represent 37% of the acres included in statistics above. a All or portions of the analysis stands may be within the strata. Some stands fall within more than one unit and strata (such as and above). b Value may be slightly low as it was generated from trees in and above the 21 inch diameter class which includes trees with a dbh 20.6 inches. c Value is approximate and used the mid-point of each diameter class as the as the dbh for all trees within the class. d Weighted averages were calculated by multiplying individual stand data by the stand acres included in the strata units, then summing values for the attribute and dividing by the sum of all stand acres within the strata. 12

13 Another difference to note is that basal area for the layout cruise data was determined from trees 8 inches dbh and greater while the original analysis included trees 5 inches and greater in the basal area calculation. This difference would result in a basal area that might be slightly conservative relative to the original analysis if trees between 5 and 8 inches dbh are present in the strata. Unless the smaller trees comprise a large portion of the stand, they likely don t contribute much to the basal area and are likely to be reduced during subsequent noncommercial thinning and broadcast burning. Thus, the conclusion is that the difference in dbh used would not result in a measurable difference in resulting effect. Specifics by stratum: Stratum B As identified in Table 3, most comparative attributes are similar. The attributes that vary the most are basal area and the resulting percentage of ponderosa pine in the medium and large tree size classes. These two factors act in tandem. In order to favor ponderosa pine to a high degree, the representation (basal area) of Douglas-fir is reduced. The proposed modification favors ponderosa pine to a higher degree than the original analysis indicated as evidenced by the percent of medium and large trees that are ponderosa pine attribute. The desired condition for species composition in old forests (where ponderosa pine is a major early seral species and the site is relatively warm and dry) is to have at least 60% of the large trees be ponderosa pine. A primary objective of the project was to promote the development of old forest conditions as defined in Appendix E of the Forest Plan (USDA Forest Service 2010). In practice, when forests are highly departed from historical conditions, moving all desired attributes forward at the same pace is difficult. For strata B stands, the compromise for moving the medium and large trees (tomorrow s large trees) within the desired range for percentage of ponderosa pine in old forest is a reduction in both large tree canopy cover and stand canopy cover (using large trees per acre and basal area of all trees as surrogate indicators for canopy cover). Stratum D Comparative attributes are very similar between layout and analysis data. The primary difference is more large trees and a lower representation of ponderosa pine will remain than considered during the vegetation and wildlife analysis. Based on field reviews completed to date, a higher component of Douglas-fir in Stratum D does not appear to be uncharacteristic for some habitat types in this stratum. Thus, based on 2014 field reviews, retaining more large Douglas-fir trees at higher densities than other strata, such as stratum B, would contribute to meeting treatment objectives. Will the effects from the diameter retention modification fall within the range of effects described for the Environmental Assessment? Based on a comparison of the 2013 analysis data and the 2014 cruise data that reflects postimplementation conditions if the diameter retention modification discussed above is used, the effects with the modification would fall within the range disclosed in the 2013 EA. The rationale is as follows: Vegetation structure within the strata remains very similar to what was considered during analysis (Table 3 and discussion above). The proposed modification would continue to move stands toward desired old forest conditions, recognizing that not all desired attributes can be promoted equally at this time. Some short-term effects within treatment areas, such as reducing large tree and stand canopy cover of later seral species, would occur in order to promote early seral ponderosa pine. The wildlife analysis was conducted at the larger project or landscape area in order to assess patch size and connectivity, which are important to providing habitat and maintaining wildlife populations. Considering that the differences between what was analyzed and what is being proposed (Table 3) are relatively minor and they occur on a small portion (209 acres) of the landscape (acres varied by habitat component and species), they would not measurably affect any habitat trends described for Alternative C. 13

14 The following design features and Forest Plan standards that promote the development and protection of old forest habitat and key attributes still apply: VE-2 Retain all existing forest stands that meet the definition of large tree size class (USDA Forest Service 2010, Appendix A) or old forest habitat (USDA Forest Service 2010, Appendix E). Management actions may occur within these stands as long as they continue to meet the definitions of large tree size class and old forest habitat. [Forest Plan Standards WIST08 and VEST03.] VE-3 Ensure management actions within large or medium tree size class stands (USDA Forest Service 2010, Appendix A) that have the species composition required to achieve old forest habitat (USDA Forest Service 2010, Appendix E) shall contribute to or not preclude restoration of old forest habitat. [Forest Plan Standard WIST09.] VE-4 Designate for retention during sale preparation all ponderosa pine trees meeting the definition of a legacy tree consistent with the Forest s Legacy Tree Guide (USDA Forest Service 2012). In addition, designate for retention Douglas-fir trees that exhibit legacy-like characteristics (Van Pelt 2008). [Forest Plan Standard VEGU08 (ponderosa pine).] WI-5 Retain all snags (>10 inches dbh) unless required to be felled by Occupational Safety & Health Administration (OSHA) standards. Retain felled snags onsite for coarse woody debris component. WI-9 Existing large snags (>20 inches dbh) shall be tagged with Wildlife Tree signs along select roads that are open to the public to reduce loss of this habitat component due to fuelwood gathering. This activity will (1) occur with a predefined road corridor based on topography and logical distances within which snags might be removed for fuelwood, (2) focus on areas of mature forests (large and medium tree size class), and (3) focus on PVGs that develop old forest conditions (PVGs 1 9 and 11). Tagged snags would be monitored (See Section of the project EA [USDA Forest Service 2013a]). The following discussion details three focal species to provide additional support for the above rationale. Two are management indicator species (MIS) and all three are Sensitive species. They were selected because they are associated with old forest habitats and because they show the trade-offs that occur with restoring low elevation forests. White-headed woodpecker is a Sensitive species and a MIS for the Forest. This woodpecker is a member of Family 1, which is a conservation priority habitat group (Low Elevation Old Forest) on the Forest due to a significant decline in habitat across the Forest as well as the Columbia River Basin. Restoring habitat for white-head woodpeckers and other Family 1 species was a primary objective for the restoration treatments (Purpose and Need 1). Three specific purposes were identified: (1) maintain old forest habitat components where present; (2) promote achievement of old forest habitat conditions in the medium and large tree size classes; and (3) increase habitat within identified source habitat blocks for Family 1 with specific emphasis on improving tree size, tree species composition, and within forest stand structure. Alternative C was expected to result in a trend of restore due to increasing source habitat abundance, patch size, and large snag densities. This species is expected to benefit as vegetation conditions in low-elevation forests move toward historical reference conditions (open forests with a dominant component of large, old ponderosa pine). While the proposed modification does reduce the number of large Douglas-fir trees and the potential for recruiting large snags, these outcomes are weighed against the benefit of promoting ponderosa pine, which is also an important component of white-headed woodpecker habitat and provides a source of seed and foraging sites (for insects). While minor, localized structural changes would occur from the modification (Figure 4), they would not change the restoration trend noted for Alternative C, which looked at habitat at a larger scale. 14

15 Figure 4 Proposed changes in treatments and relationship to white-headed woodpecker habitat patches 15

16 Flammulated owl is another Sensitive species and is a member of the Family 2 (Broad Elevation Old Forest) habitat family. Potential habitat for the species overlaps strongly with white-headed woodpecker, however, flammulated owls will utilize forests with higher canopy cover as well as the more mesic habitat types in Potential Vegetation Group (PVG) 3. The species habitat has likely increased due to departures from historical conditions in the low-elevation forests, which has allowed denser stand conditions to develop in these areas. Alternative C was expected to result in a short-term decrease in source habitat abundance and patch size, primarily from moving vegetation conditions within the low elevation forests toward historical and more open conditions. Some indicators related to habitat quality would improve, most of which are tied to abundance and retention of snags important to the species. Source habitat decrease was not a concern as abundant habitat remained within the project area and would contribute to a well-distributed patchwork of habitat across the forest. The proposed modification would not change the habitat trends stated for Alternative C and the project area would continue to contribute to a patchwork of habitat on the Forest. Pileated Woodpecker is a Sensitive species and a MIS for the Forest. The species is also a member of Family 2 and occupies mature forests across a broad range of PVGs. Pileated woodpeckers are capable of taking advantage of habitat conditions outside the historical range of variability (HRV), including departed conditions in the low elevation forests occupied by white-headed woodpeckers. Large snags and logs are an important component of habitat providing nesting, roosting, and foraging sites. Alternative C was expected to reduce source habitat for the species. Restoration and WUI treatments within the low elevation dry forests were expected to reduce stand densities and the suitability of these areas for pileated woodpecker. However, these PVGs did not historically provide habitat for the species and the desired condition was to have less habitat represented by conditions outside the HRV. Alternative C did show a decline in the percent source habitat, from 22.5% to 15%, due to conditions outside the HRV. While habitat was expected to decrease, larger patches of habitat remained would remain within the project area and contribute to a well-distributed patchwork of habitat across the Forest. Several habitat quality indicators related to retention of snags, large snag abundance, large logs, and large tree size class stands were assessed and showed an improving trend in the short and long term. The proposed diameter limit modification would not result in any effects not already considered during the wildlife analysis. Review of Forest Plan Direction as Amended in 2010 Forest Plan Standards and Guidelines The applicable standards and guidelines from the 2010 Forest Plan that may be affected by the change in Design Feature VE-7 are discussed below. WIST08 Retain forest stands that meet the definition of old forest habitat for the applicable PVG (refer to USDA Forest Service 2010, Appendix E). Management actions are permitted in such stands as long as they will continue to meet the definition of old forest habitat. The analysis in the 2013 EA determined none of the units in strata B and D provide old forest habitat as defined in the 2010 Forest Plan. Since none of the units currently provide old forest habitat, this standard is not applicable. However, if following additional field validation, these units are determined to provide old forest habitat, forested stands meeting the old forest habitat definition would be dropped. If acres meeting the definition of old forest habitat are identified after award of the stewardship service contract, which includes tree marking by a third party, contract provisions FAR (Changes clause) and FAR (Termination for Convenience of the Government) would be used, as needed, to remove applicable acres from the contract. 16

17 WIST09 Management actions within large or medium-size class forested stands (USDA Forest Service 2010, Appendix A definition) that have the species composition required to achieve old forest habitat for the applicable PVG (USDA Forest Service 2010, Appendix E definition) shall contribute to or not preclude restoration of old forest habitat. Tree size class for a stand, as defined in the 2010 Forest Plan, is based on the largest diameter trees present in the stand. If the total non-overlapping canopy cover of trees >20 inches dbh is >10%, then the stand would be considered to be in the large tree size class. If not, then if the total non-overlapping canopy cover of trees >12 inches dbh is >10%, the stand would be considered to be in the medium tree size class. The analysis in the 2013 EA determined the proposed treatments would be consistent with this standard. Following review of the effects of the proposed diameter retention modification by the Forest vegetation specialist and wildlife biologist using the original stand data and subsequent cruise data, the finding is that implementing this project would still be consistent with this standard. However, if additional field validation determines that would not be the case, applicable acres would be dropped. If acres are identified after award of the stewardship service contract, which includes tree marking by a third party, contract provisions FAR (Changes clause) and FAR (Termination for Convenience of the Government) would be used, as needed, to remove applicable acres from the contract. VEST03 Retain forest stands that meet the definition of a large tree size class (USDA Forest Service 2010, Appendix A, p. A-6) until forest-wide inventories demonstrate the desired quantity of large tree size class acres within the affected PVG exist across the Forest (USDA Forest Service 2010, Appendix A, Table A-4). Management actions are permitted in such stands as long as they will continue to meet the definition of a large tree size class. Tree size class for a stand, as defined in the 2010 Forest Plan, is based on the largest diameter trees present in the stand. If the total non-overlapping canopy cover of trees >20 inches dbh is >10%, then the stand would be considered to be in the large tree size class. The analysis supporting the 2013 DN/FONSI concluded some units are in the large tree size class. Modeling with FVS indicated that implementing the action as prescribed in 2013 would not shift these units to a smaller tree size class. Review of the effect of modifying Design Feature VE-7 in strata B and D using recently collected cruise data also concluded that units currently in the large tree size class would not fall out of the large tree size class. Therefore, the project proposal with modifications to Design Feature VE-7 would continue to be consistent with this Forest Plan standard. VEGU08 Ponderosa pine and western larch trees fitting the definition of a legacy tree should be retained. The 2010 Forest Plan Glossary provides a general definition of legacy trees (USDA Forest Service 2010). Retention of these legacy trees was not specifically prescribed in To comply with this guideline, any ponderosa pine or western large legacy trees identified during implementation should be retained. Design Feature VE-4 included in the 2013 DN/FONSI remains in place and would be implemented in Strata B and D, and thus would be unaffected by the proposed modification. VE-4 Designate for retention during sale preparation all ponderosa pine trees meeting the definition of a legacy tree consistent with the Forest s Legacy Tree Guide (USDA Forest Service 2012). In addition, designate for retention Douglas-fir trees that exhibit legacy-like characteristics (Van Pelt 2008). [Forest Plan Standard VEGU08 (ponderosa pine).] 17

18 S11pph111ental il?for111at1011 Repvrt Conclusion Based on the above documentation, I have determined the following: 1) Modifications in road and trail management activities that have occurred to date are consistent with my 2013 DN/FONSI and the resulting effects fall within those disclosed in the supporting 2013 EA. 2) The effects identified in the BA and BEs are still valid, compatible, and consistent with the conservation of threatened, endangered, and Region 4 sensitive species whose status has changed. 3) Recommendations to reduce acres of commercial vegetation treatments should be implemented for the six reasons identified during layout in By continuing to implement the noncommercial treatments on acres dropped from commercial treatment, stand structure, species composition, and/or densities are still expected to move toward conditions identified in the EA. Thus, with implementation of non-commercial treatments, including fuel management activities, the beneficial effects of treatments would be expected to fall within the range of effects disclosed in the EA, including accomplishment of project purpose and need. 4) Adjustments in treatment boundaries should be implemented as identified during field layout in These changes were made to address on-the-ground conditions consistent with the intent of treatment prescriptions described in the EA (see Attachment A ofthis document) and implementation of design features pertaining to wildlife, hydrology, fisheries, and the WUI infrastructure. 5) Design Feature VE-7, which pertains to commercial vegetation management treatments, should be modified to address the difference in conditions observed in the field in 2014 compared to stand data used in the assessment supporting disclosures. As identified above, this change is important to meeting vegetation treatment objectives for improvements in stand structure, species composition, and/or tree density and, based on review by interdisciplinary team resource specialists, would not measurably change the effects as disclosed in the EA for other resources (i.e., wildlife). Therefore, I have concluded that a supplement or revision to the 2013 NEPA documentation is not necessary and implementation of this project may continue. I am instructing the interdisciplinary team to incorporate this letter into the project's planning record and proceed with implementation. &~ CECILIA R. SEESH Forest Supervisor cc: Randall Hayman John Kidd Clint VanZile John Riling Nadine Hergenrider 18

19 List of Interdisciplinary Reviewers/Preparers The following members of the Interdisciplinary Team have revievved and/or contri buted to the compmisons, summaries, and conclusions disclosed in this doc ument and associated attachment Clint VanZile North Zone TMA S/J1/ts Date John Riling North Zone Silviculturist Date Nadin M. Hergenri er Low an RD Wildlifi Biologist Date Randall R. Hayman Boise NF Forest Planner Date 19

20 References Cited USDA Forest Service Boise National Forest land and resource management plan. Boise, ID: USDA Forest Service, Boise National Forest. USDA Forest Service Legacy Tree Guide for the Boise National Forest, Version 1.4, November Boise, ID: USDA Forest Service, Boise National Forest. USDA Forest Service. 2013a. Decision notice/fonsi for the: environmental assessment for the Clear Creek integrated project. Boise, ID: USDA Forest Service, Boise National Forest. USDA Forest Service. 2013b. Review environmental assessment: Clear Creek integrated project. Boise, ID: USDA Forest Service, Boise National Forest. Van Pelt, R Identifying Old Trees and Forests in Eastern Washington. Olympia, WA: Washington State Department of Natural Resources. 166 p. 20