Ashland Tree Planting Project
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1 DECISION MEMO Ashland Tree Planting Project Ashland Ranger District Custer National Forest USDA Forest Service Powder River and Rosebud Counties, Montana Purpose and Need for Proposing Action Forest cover in the Northern Great Plains is confined to scattered elevated plateaus such as found on the Ashland Ranger District that are dominated by ponderosa pine. Historically, frequent low-intensity fires cleared ponderosa pine forest types of brush and grass but left trees alive and healthy (Graham, et. al, USDA 2004). Extreme fires were uncommon. By excluding fire from the natural cycle through decades of fire suppression, extended drought and other changes, the cumulative effects are greater tree densities and a buildup of flammable vegetation across large areas of the forested landscape resulting in large stand replacement fire. The 2000 Stag and Tobin fires and the 2012 Ash Creek Fire are examples. On July 23 and 26, 2000, thunderstorms moved through the Ashland Ranger District igniting 13 fires that became the Tobin and Ft. Howes wildfire complexes, The two largest fires, Stag and Tobin, eventually totaled over 71,000 acres. During the preparation of the EIS for the Proposed Ashland Post- Fire Project analysis in 2000, it was estimated that 40 to 60% of the fire area experienced stand replacement fire. Sixty one percent of the burn area was in a forested condition pre fire. That equates to 17,000 to 25,500 forested acres experiencing 95 to 100 percent mortality (stand replacement). Since these 2000 fires and up to about 2008 other large fires have occurred across the district and have impacted 25% of the District s 438,075 acres. On June 25, 2012 the Ash Creek Fire started from a dry lightning storm. The following day southeastern Montana saw red flag warnings with 102 degree temperatures and mph winds. These weather conditions produced fire rates of spread ranging from 80 to 110 chains per hour and 30 foot flame lengths. This fire burned on Northern Cheyenne Indian Reservation, BLM, State of Montana, Private and National Forest System lands totaling 244,697 acres. The fire burned 87,821 acres on National Forest System lands of which 42,993 acres were forested. Forty percent was unburned or low intensity (0 to 40% mortality), 36% moderate intensity (40 to 80% mortality) and 24% high intensity (80% plus mortality). Fire Effects on Ponderosa Pine - Ponderosa pine has a thick bark that acts as an insulator and long needles that protect its buds to withstand effects from frequent low intensity fires. During high intensity fires these insulators are ineffective resulting in mortality. Ponderosa pines large seed and cone generally are burned up or destroyed and do not remain viable after stand replacement fire events. An
2 effect from large stand replacement fires is loss (deforestation) of the ponderosa pine forest for long periods of time. This is not a desired condition on the landscape. Ponderosa pines large heavy seed does not have the ability to reseed large disturbance areas in short time frames like other small winged pine species such as lodgepole pine. Seed cast in ponderosa pine averages 100 to 150 feet from live mature cone producing trees. If all the trees have been killed no seed source is available to reforest the area. Large burned areas in the Tobin and Stag fire areas today are demonstrating this. The large burned areas that do not have a seed source are still not reforesting. Left alone and not artificially regenerated these would take several decades to reforest. This loss of the forest has impacts to wildlife that are dependent on forested communities. Benefits forgone if these sites are not replanted will be: elk habitat, mule deer habitat, whitetail deer habitat, goshawk habitat, forestland cover, watershed health, fire rehabilitation, and carbon sequestration. A major benefit for planting these ponderosa pine seedlings is to speed up the recovery of the forested habitat that would otherwise take many decades. Assessments in the Project Area - In the fall of 2000 a reforestation assessment was performed to evaluate reforestation needs across in the 2000 Tobin Ft Howes Fire Complex. This assessment was documented in the Timber Stand Management Records System (TSMRS) and in 2005 the reforestation treatments identified were migrated into the new database of record, the Forest Service Activity Tracking System (FACTS). The assessment identified 6,255 acres of planting, 498 acres of seeding, 4,332 acres of natural regeneration and 25,429 acres of delayed natural regeneration. The 2000 Final Environmental Impact Statement for the Ashland Post-Fire Project evaluated a reforestation strategy of artificial, natural and delayed natural for the identified treatments. A reforestation strategy outside of the proposed treatments was not covered under the FEIS. A Forest Plan Amendment was proposed to reclassify suitable lands within Management Area B to non-suitable to alleviate the five year requirement to restock lands post-harvest for the selected Alternative. This Forest Plan Amendment was not upheld by the Regional Forester during the appeal process and was remanded to the Forest with instructions to determine a strategy for ensuring the fire area was restocked per NFMA, Forest Service Policy and Forest Plan Standards. The FEIS stated without the amendment timely reforestation would occur. The FEIS without the amendment identified 2,941 acres of artificial regeneration, 315 acres of natural regeneration and 1,196 acres of delayed natural regeneration on the proposed treatment acres. The Record of Decision (ROD) for the FEIS indicated that monitoring of reforestation success would allow for changes in reforestation strategies and that additional planting may need to occur outside the proposed treatment units to meet various management objectives. This project proposal moves forward with assuring the restocking of deforested lands within the 2000 fire complex. In 2009 a Rapid Assessment was conducted for the Ashland Ranger District to evaluate existing conditions and prioritize potential management needs and opportunities. Part of this assessment looked at past large fires and the need to restore the forested component due to extensive loss. Areas across large fires since 2000 were identified as restoration needs with priority on the moist aspects favorable for natural reforestation and artificial reforestation success. Restoration areas identified during this assessment incorporate some of the proposed planting areas. Today, reforestation needs on the Ashland Ranger District documented in FACTS total approximately 5,000 acres of planting based on post fire monitoring and rapid assessments. This total includes needs created by fires after 2000 through Page 2
3 Additional reforestation needs have been created from the 2012 fires but assessments have not occurred, pending a larger district wide assessment. Two units that were planted in 2012 were burned over resulting in high mortality of the seedlings and are part of this proposal for replanting. Additional areas within the Ash Creek Fire are also being proposed for planting. In the summer of 2012 the proposed 885 acres of planting units were surveyed for natural regeneration and adequate seed source. All of the units were identified as suitable for planting and determined they did not meet the Forest stocking goals on suitable moist aspects. Proposed Action Ponderosa Pine Planting: The Forest Service, Ashland Ranger District, proposes to plant approximately 425,000 two-year old ponderosa pine seedlings across 885 acres within the 2000 Stag and Tobin Fire and 2012 Ash Creek Fire perimeters over the next two years. This approximates 10 x 10 foot spacing. Planting shall be conducted in the manner to allow for variable spacing to reduce the visual appearance of a uniform plantation. All planting will be done under contractual services using hand tools. To aid in successful establishment of seedlings - up to 18 inches of existing surface vegetation will be scalped (removed) down to mineral soil around each seedling to reduce competition. Seedlings will be planted next to large down woody material or standing large dead trees where available for protection from heat and animal damage. No seedlings will be planted within seven to eight feet of any incidental live seedlings or saplings (0 to 4.9 inches dbh) that are of good form, color, and free of damage. And no seedlings will be planted within 12 feet of live trees five inches and larger that exhibit 50% or greater crown ratio. Existing roads will be used to access the planting units with no off road motorized vehicles allowed. To mitigate the impacts of spreading noxious species all equipment and vehicles to be used shall be cleaned and free of noxious weeds and their seeds prior to entrance onto the forest and job sites. See Appendix C for cleaning requirements. Planting units are located in parts of T5S, R44E, Sections 13, 14, 23, 24, and 25; T5S, R45E, Sections 18, 19, and 20; all in the Paget area of the Stag Fire; T4S, R46E, Sections 11 and 12; T3S, R46E, Sections 25, 26, and 35; T4S, R47E, Sections 31 and 32; all in the Tobin Fire area; and, T6S, R45E, Sections 23, 24, 25; all in the Fort Howes area. See the maps in Appendix A. Decision I decided to issue separate decision memos for the ponderosa pine planting and the hardwood species planting. These actions were scoped in the same scoping and notice of comment and appeal procedures legal notice published in the Billings Gazette, as noted in the public involvement section of this decision memo. The scope of the ponderosa pine planting and hardwood planting has not changed. I decided it would be easier to track the two types of plantings primarily because of differing implementation time frames for each type of planting (two years versus five years). The specialist reports have not been changed to reflect my decision to issue separate decision memos. Page 3
4 I have decided to implement the proposed action as described above and as described in further detail in the Silviculture Report in the project record. The direct effects of the artificial planting will be restoration of the ponderosa pine ecosystem that was removed from the landscape. Indirectly this action will return habitat for those wildlife species that are dependent on a forested landscape and help ensure an even flow of timber products for the future. In Table 1 of the Silviculture Report is a summary of the Forest s stocking goals for the ponderosa pine by habitat and aspect. These stocking goals provide for a diversity of stocking across the landscape. Site and capability for supporting ponderosa pine is inherent in habitat types and aspect. Stocking levels are highest on the moist sites that historically supported full canopied stands of ponderosa pine and lower on dryer sites that historically supported very open canopied and a limited extent of ponderosa pine stands. Using this methodology ensures stocking levels that maintain the health and vigor of growing stands of ponderosa pine as competition will be less. These multiple stocking levels meet wildlife, timber, fuel and range resource goals, objectives and management standards as defined in the Forest Plan. In Table 2 of the Silviculture Report is a summary the specific stocking objectives for the 977 acres proposed planting and the projected suitable planting sites in the Fort Howe s admin site. Monitoring of planting activities will occur after the first and third growing season after implementation to ensure stocking objectives have been met. The potential to spread noxious weeds as a result of this project will be mitigated to the extent possible and practicable by employing best management practices as outlined in Forest Service Manual 2080, and the contractual requirements described in Appendix C. In addition, the Paget Creek area should be planted last as the workers will have to drive through weed infestations. Planting areas in close proximity to the weed infestations in the Paget area should be the last planted. Reducing the travel in and out of the weed area will decrease the chance of spreading the weeds. I have made my Decision based on findings from review of the analysis presented in this Decision Memo; review of Forest Plan goals, objectives, Forest-wide standards, and applicable management area standards; experience with similar past projects; best available science; review of effects of past, present, ongoing, and reasonably foreseeable actions; and project-specific technical specialist input to the planning and analysis process. Scoping and Public Involvement Internal scoping indicated little concern regarding the effects of this proposal. A legal notice announcing the concurrent scoping and notice, comment and appeal procedures was published in the Billings Gazette on December 28, No comments were received regarding the proposal. An interdisciplinary team of Forest Service resource specialists and the responsible official reviewed the project, identified potential issues and concerns and analyzed potential effects of project implementation. Identified issues and concerns were focused on the potential effects of spreading noxious weeds. This issue is addressed by the mitigation measures described in Appendix C, and included as part of my decision. Page 4
5 Findings and Reasons for Categorically Excluding This Action The Council on Environmental Quality (CEQ) regulations at 40 CFR provide that agencies may adopt categories of actions that do not normally have significant impacts on the human environment and that do not require preparation of an environmental assessment (EA) or environmental impact statement (EIS). The Forest Service categories of actions listed in 36 CFR 220.6, as well as in FSH , Chapter 30, is the agency s adoption of actions provided for by the CEQ regulations at 40 CFR I find that this action may be categorically excluded from further analysis and documentation in an EIS or EA if it fits a category listed in 36 CFR 220.6(d) and (e). The proposed action is an action that fits within a category listed at 36 CFR (e) (5): Regeneration of an area to native tree species, including site preparation that does not involve the use of herbicides or result in vegetation type conversion. These actions will not result in uncertain or significant direct, indirect, or cumulative effects; These actions will not have a cause-effect relationship or degree of potential effect that results in the existence of extraordinary circumstances that warrant further analysis and documentation in an EA or an EIS. This tree planting project was analyzed within the scope of the National Environmental Policy Act of 1969 (NEPA). In making my Decision, I considered interdisciplinary analysis of past, present, and reasonably foreseeable actions in and adjacent to the proposed project area that maybe relevant to reasonably foreseeable adverse impacts. Based on analysis in the Project Record, past experience with tree planting projects, and rationale provided in this Decision Memo, I find that my Decision will not result in significant direct, indirect, or cumulative effects that warrant documentation in an EA or EIS. Forest Service procedures related to categorical exclusions require a consideration resource conditions in determining whether there are extraordinary circumstances relating to a proposed action (36 CFR 220.6(b)(1)). The mere presence of one or more of these resource conditions does not preclude use of a categorical exclusion. It is (1) the existence of a cause-effect relationship between a proposed action and the potential effect on these resource conditions and (2) if such a relationship exists, the degree of the potential effect of a proposed action on these resource conditions that determines whether extraordinary circumstances exist. Based on specific analysis of direct, indirect, and cumulative effects, past experience with similar projects, and rationale provided in this Decision Memo, I find that the degree of potential effects of my Decision will not result in effects to resources which constitute an extraordinary circumstance. The conclusions of evaluating resource conditions in determining whether extraordinary circumstances exist are as follows: Federally listed Threatened and Endangered species or their designated Critical Habitat or species proposed for Federal listing, proposed critical habitat, or Forest Service Sensitive Species There is no federally listed threatened and endangered species present in the project area. There is potentially no habitat for federally listed species. There is habitat for sensitive species and management indicator species/key species. Sensitive species are potentially present in the project area and management indicator species/key species are present within the project area. The District biologist has determined that there will be no adverse effects to federally listed species or management indicator/key species. For Page 5
6 the bald eagle, Baird s sparrow, long-eared myotis, Long-legged myotis, Pallid bat, Spotted bat, Townsend s big eared bat, Black-tailed prairie dog, Great Plains toad, Plains spadefoot, Northern Leopard frog, Greater Short-horned lizard, Milksnake, and Western hog-nose snake, all sensitive species, the District biologist determined that the project may impact individuals, but is not likely to cause a trend to Federal listing or loss of viability. This effect is not significant or potentially significant and therefore does not trigger the need for documentation in an EA or EIS, because the project is limited in scope and the potential for impacts to this species is very low. The biological assessment is enclosed as Appendix B. Flood Plains, Wetlands, or Municipal Watershed Planting of ponderosa pine will occur within in the uplands. None of these activities will occur in a flood plain, wetland, or municipal watershed. I find that the degree of effects of my Decision will not result in extraordinary circumstances associated with Flood Plains, Wetlands, or Municipal watersheds. Congressionally Designated Areas, such as Wilderness, Wilderness Study Areas, or National Recreation Areas No Wilderness, or Wilderness Study Areas, are found on the Ashland Ranger District. I find that my Decision will not result in extraordinary circumstances associated with because there are no Wilderness (Forest Plan Management Area I), Recommended Wilderness (Forest Plan Management Area H), Wilderness Study Areas, or National Recreation Areas on the Ashland Ranger District. See Management Area Maps that are part of the Forest Plan and incorporated by reference as part of the Project Record. Inventoried Roadless Areas or potential wilderness area There are three inventoried roadless areas on the Ashland Ranger District, each is allocated to Forest Plan Management Area J, Low Development. No activities from this proposal will occur within any Inventoried Roadless Area (IRA) on the Ashland Ranger District. See Management Area Maps that are part of the Forest Plan and incorporated by reference as part of the Project Record. These maps can also be found on the Custer National Forest website at I find that the degree of effects of my Decision will not result in extraordinary circumstances associated with these areas. Research Natural Areas - There is one research natural area (RNA) on the Ashland Ranger District, the Poker Jim RNA. I find that my Decision will not result in extraordinary circumstances associated with the Poker Jim RNA because project activities will not take place within it. See Management Area Maps that are part of the Forest Plan and incorporated by reference as part of the Project Record. RNAs are allocated to the L Management Area American Indian and Alaska Native religious or Cultural Sites A heritage review was conducted for the proposal. No impacts to American Indian and Alaska Native religious or Cultural resources are anticipated. No extraordinary circumstances associated with these resource values are anticipated from my Decision as documented in the Heritage Resource Review (see Project Initiation Forms (PIF) in the Project Record). Archaeological Sites, or Historic Properties or Areas An intensive heritage inventory was conducted by Forest Archaeologists and all cultural resources located within the planting units were avoided or the planting unit was modified to exclude the cultural resource. All archaeological sites, traditional cultural properties and historic properties will be avoided in accordance with the Montana State Historic Page 6
7 Preservation Office Programmatic Agreement. No extraordinary circumstances associated with archaeological sites or historic properties or areas are anticipated from my Decision as documented in the Heritage Resource Review (The Cultural Resource Report is contained in the Project Record). FINDINGS REQUIRED BY OTHER LAWS National Forest Management Act of 1976 and the Custer Forest Plan I find that my Decision is consistent with the 1986 Custer National Forest Land and Resource Management Plan (Forest Plan, USDA 1986) as required by the National Forest Management Act (1976). The Forest Plan provides forest wide goals and standards specific to management areas. Three management areas encompass the proposed planting units Management Area B, D and G. The following summarizes Forest Plan goals, objectives and management standards, in relevant part, for these activities. Management Area B (MA-B) goal is to provide for the continuation of livestock grazing, implementation of intensive range management systems and the facilitation of minerals and energy development with consideration of other resource needs. In areas not considered key for wildlife, adverse impacts to the wildlife habitat will be mitigated where feasible, but not to the exclusion of range and mineral/energy management and development activities. In key wildlife areas, the habitat may not be adversely impacted from development activities (Custer National Forest and National Grasslands Land and Resources Management Plan, 1987). Management standard for the timber resource in MA-B include: Timber; forested areas will be managed to perpetuate or enhance livestock forage and wildlife habitat values. Management activities may include removal of wood products such as sawlogs, posts and fuelwood or transplant materials. Wildlife and range resources will be protected or enhanced. Silvicultural systems may include either even aged or uneven aged systems. Regeneration systems may be appropriately applied to meet management area goals. The productive forestlands within this area are classified as suitable for timber production. Management Area D (MA-D) is to maintain or improve the long-term diversity and quality of habitat for the selected species identified by Ranger District (Ashland mule deer) as well as accommodating other resource management activities such as timber harvest, livestock grazing, and oil and gas development (Custer National Forest and National Grasslands Land and Resources Management Plan, 1987). Management standard for the timber resource in MA-D include: Timber; this management area contains lands considered suitable for timber management. Silvicultural prescriptions will identify timber treatments that will perpetuate or improve key wildlife habitat and livestock forage. Productive forest lands within this area are suitable for timber production. Silvicultural prescriptions may include either even aged or uneven aged systems. Knutson-Vandenberg funds collected from sale of forest products will first be programmed for regeneration as required by law and than other wildlife improvement treatments will be considered. Page 7
8 Management Area G (MA-G) goal is to manage these areas for the maintenance and improvement of a healthy diverse forest and as a source of wood products for dependent local markets. Silvicultural systems will consider other resource needs such as wildlife habitat, visual impacts, and livestock management (Custer National Forest and National Grasslands Land and Resources Management Plan, 1987). Management standard for the timber resource in MA-G include: Timber; area analysis will be made that consider harvest levels and location, expected oil and gas development, transportation systems to service management needs and other resource conflicts and possible mitigation measures. Even-aged management is the preferred silvicultural system but uneven-aged management may be used where such methods are more appropriate for meeting ecological requirements and management of the species. Clearcutting may be used where it is the optimum regeneration method and meets the objectives for the area. Old growth will be managed to at least meet the habitat requirements for a minimum viable population of old growth dependent wildlife species. Seasons of management may be adjusted on a case-by-case basis to protect wildlife and soil and water values and reduce conflicts with recreation traffic. Silvicultural systems that favor natural regeneration will be emphasized. The objective will be to regenerate harvested areas within five years. Insect and disease infested timber will be treated with an appropriate silvicultural system in coordination with other resource values. Precommercial thinning will be utilized in a cost-effective manner on areas with high site index. Prescribed fire, as well as other management tools may be used to thin stands. Over stocked stands will be evaluated for wildlife needs prior to treatment. This management area includes lands classified as suitable for timber management. Emphasis added. The forest wide timberland management goal is to manage timber within sustained-yield capability to help maintain timber dependent communities, forest health, vigor, productivity, provide vegetative diversity for wildlife, eliminate tree encroachment on selected livestock grazing areas and provide scenic openings (Custer National Forest and National Grasslands Land and Resources Management Plan, 1987). Vegetation management activities of timber harvesting, stocking reduction (thinning) and prescribed fire are tools that can be used to meet the Forest Plan management standards and goals. The forest wide objective of wildlife management is to emphasize active management of wildlife habitat. For the timber resource it is to provide for but not limited to an even flow of timber products, maintain a healthy diverse timber resource, and improve or maintain wildlife habitat. This artificial planting will meet these objectives by returning the ponderosa pine component on these landscapes that the wildfires removed. Endangered Species Act of 1973 Based on input provided by the District Wildlife Biologist, significant impacts to Threatened or Endangered Species or their habitat are not anticipated as a result of my Decision. Other Laws or Requirements I find that this Decision is consistent with all other applicable Federal, State, and local laws or requirements. IMPLEMENTATION DATE ADMINISTRATIVE REVIEW or APPEAL OPPORTUNITIES Page 8
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10 REFERENCES United States Code (USC) USC The National Environmental Policy Act of 1969, as amended (Pub. L , 42 U.S.C , January 1, 1970, as amended by Pub. L , July 3, 1975, Pub. L , August 9, 1975, and Pub. L , 4(b), Sept. 13, 1982). USDA Forest Service. October Record of Decision for the Custer National Forest and National Grasslands, Land and Resource Management Plan. USDA Forest Service, Billings, MT. USDA Forest Service. October Custer National Forest and National Grasslands, Land and Resource Management Plan. USDA Forest Service, Billings, MT 186 pages. USDA Forest Service, December Ashland Post-Fire Project Record of Decision and Final Environmental Impact Statement. US Forest Service, Northern Region, Custer National Forest. USDA Forest Service. 2006a. Custer National Forest Weed Management Record of Decision and Final Environmental Impact Statement. US Forest Service, Northern Region, Custer National Forest. There are eleven acts and a Code of Federal Regulations (CFR's) that give basic authority for silvicultural practices for forested vegetation on National Forest System lands. Organic Administration Act of 1897 (30 Stat. 34, as supplemented and amended; 16 U.S.C ). Knutson-Vandenberg Act of 1930 (46 Stat. 527, as amended; 16 U.S.C b). Bankhead-Jones Farm Tenant Act of 1937 (50 Stat. 525, as amended; 7 U.S.C ). Anderson-Mansfield Reforestation and Revegetation Act of 1949 (63 Stat. 762; 16 U.S.C. 581j-581k). Granger-Thye Act of 1950 (64 Stat. 82, as amended; 16 U.S.C. 490). Multiple-Use Sustained-Yield Act of 1960 (P.L , 74 Stat. 215; 16 U.S.C ). Supplemental National Forest Reforestation Fund Act of 1972 (87 Stat. 242, 245, as amended; 16 U.S.C. 576C-576e). Forest and Rangeland Renewable Resources Planning Act of 1974 (88 Stat. 476, as amended; 16 U.S.C ). National Forest Management Act of 1976 (90 Stat. 2949; 16 U.S.C (note)). Reforestation Trust Fund, Title III - Reforestation, Recreation Boating Safety and Facilities Improvement Act of 1980 (16 U.S.C. 1606a, as amended). Title 36 Code of Federal Regulations, Part Planning. All of these acts and CFR's direct the way the agency implements silvicultural practices. These guide the Forest Service for the harvesting systems in accordance with regeneration requirements and timelines, a continuous supply of timber for the use and necessities for citizens of the United States, allowable collections from purchasers to carry out post sale work, land conservation, land utilization, timber suitability determination, and multiple use and sustained yield of our National Forest resources. Page 10
11 The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual s income is derived from any public assistance. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA s TARGET Center at (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC or call toll free (866) (voice). TDD users can contact USDA through local relay or the Federal relay at (800) (TDD) or (866) (relay voice). USDA is an equal opportunity provider and employer. Page 11
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