RECORD OF DECISION TRAPPER BUNKHOUSE LAND STEWARDSHIP PROJECT. United States Department of Agriculture. Forest Service.

Transcription

1 United States Department of Agriculture Forest Service March, 2008 RECORD OF DECISION TRAPPER BUNKHOUSE LAND STEWARDSHIP PROJECT Darby Ranger District, Bitterroot National Forest Ravalli County, Montana

2 The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion. age, disability, political beliefs, sexual orientation, or marital or family status. (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 (202) (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington, DC or call (202) (voice and TDD). USDA is an equal opportunity provider and employer.

3 Trapper Bunkhouse Land Stewardship Project Record of Decision Bitterroot National Forest Darby Ranger District Ravalli County, MT March 2008 Responsible Agency: Responsible Official: USDA Forest Service David T. Bull Forest Supervisor 1801 N. First Hamilton, MT For Further Information Contact: Chuck Oliver Darby District Ranger 712 N. Main Darby, MT (406)

4 TABLE OF CONTENTS 1.0 DECISION OVERVIEW BACKGROUND ~ WHY HERE? WHY NOW? ~ PURPOSE AND NEED DESCRIPTION OF MY DECISION ALTERNATIVES CONSIDERED ALTERNATIVE 1 NO ACTION {FEIS, P. 2-5} ALTERNATIVE 2 - PROPOSED ACTION {FEIS, PP. 2-5 TO 2-11} ALTERNATIVE 3 - {FEIS, PP TO 2-17} ALTERNATIVE 4 PREFERRED ALTERNATIVE {FEIS, PP TO 2-23} ALTERNATIVES CONSIDERED BUT ELIMINATED {FEIS PP TO 2-42} Meters Around Structure Fuel Reduction And Wildland Fire Use Alternative Burnt Ridge Homeowners Association OHV Alternative Other OHV Alternatives Alternative that Does Not Require Forest Plan Amendments Alternative That Would Generate Enough Revenue For All Fuel Reduction And Resource Opportunities Alternative With Research Plots Only PUBLIC INVOLVEMENT HOW I CONSIDERED PUBLIC COMMENTS RATIONALE FOR MY DECISION MEETING THE PURPOSE AND NEED...20 Reducing The Risk From Stand-Replacing And Uncontrollable Fires...21 Improve Resiliency and Provide Forest Products...22 Fuel Reduction Research...23 Watershed Improvement ADDRESSING ISSUES AND PUBLIC CONCERNS...24 Fisheries and Watershed...24 Soils...24 Wildlife - Old growth and Associated Species...25 Recreation and Roadless...25 Noxious Weeds...25 Economics DECISION FINDINGS RELATED TO LAWS AND REGULATIONS NATIONAL FOREST MANAGEMENT ACT...29 Site-Specific Forest Plan Amendment...29 Forest Plan Consistency NATIONAL FOREST MANAGEMENT ACT (16 USC 1604) CLEAN WATER ACT CLEAN AIR ACT ENDANGERED SPECIES ACT ENVIRONMENTAL JUSTICE ACT MIGRATORY BIRD TREATY ACT NATIONAL HISTORIC PRESERVATION ACT ENVIRONMENTALLY PREFERRED ALTERNATIVE PERMITS REQUIRED APPEAL PROVISIONS...32 Trapper Bunkhouse Land Stewardship Project ROD Page 3

5 10.0 IMPLEMENTATION FURTHER INFORMATION AND CONTACT PERSON LIST OF REFERENCES CITED IN THIS DECISION TABLES TABLE 1: SUMMARY OF ACTIVITIES FOR ALTERNATIVE TABLE 2: VEGETATION MANAGEMENT TREATMENTS APPROVED BY THIS DECISION... 9 TABLE 3: COMPARISON OF ACTIVITIES BY ALTERNATIVE TABLE 4: WHY THE 400 METERS AROUND STRUCTURE ALTERNATIVE WAS NOT ANALYZED IN DETAIL FIGURES FIGURE 1: TRAPPER BUNKHOUSE VICINITY AND PROJECT AREA MAP... 5 FIGURE 2: MAP OF VEGETATION TREATMENTS IN ALTERNATIVE APPENDIX APPENDIX A WATERSHED IMPROVEMENT MITIGATION AND OPPORTUNITIES APPENDIX B ROADS TO BE DECOMMISSIONED OR CLOSED SEASONALLY OR YEARLONG APPENDIX C MITIGATION AND PROJECT DESIGN FEATURES Page 4 Trapper Bunkhouse Land Stewardship Project ROD

6 Figure 1: Trapper Bunkhouse Vicinity and Project Area Map Trapper Bunkhouse Land Stewardship Project ROD Page 5

7 RECORD OF DECISION TRAPPER BUNKHOUSE LAND STEWARDSHIP PROJECT USDA Forest Service Darby Ranger District, Bitterroot National Forest Ravalli County, Montana 1.0 DECISION OVERVIEW After extensive analysis and deliberation I have decided to implement Alternative 4, as described in the Final Environmental Impact Statement (FEIS), for the Trapper Bunkhouse Land Stewardship Project. In making this decision I have given consideration to public input, including the comments received on the Draft Environmental Impact Statement (DEIS), and the analysis by my staff contained in the DEIS and FEIS. I believe my decision is the best balance of the need to eliminate, mitigate, or reduce impacts to the environment while meeting the project objectives of reducing risk from fires in the suitable timber base and the wildland-urban interface (WUI); improving forest resiliency and providing forest products; conducting fuel reduction research; and reducing sediment contributions in South Fork Chaffin and Little Trapper Creeks. The purpose of this Record of Decision (ROD) is to explain the rationale for my decision. The document is organized in the following manner. First, I provide some background information on what led us to propose this work - Why Here, Why Now? and to reiterate our purpose and need. Then, I briefly describe the work I have approved in Alternative 4, followed by a look at the criteria and rationale I considered in selecting that alternative. Next, I describe the public involvement process, followed by my findings of consistency with relevant laws and policies. I conclude with information about implementation of the project and how to contact us for more information. Throughout this decision document I highlight where additional information can be found in the DEIS, FEIS, and the Project File (PF) within {brackets like these}. 2.0 BACKGROUND ~ WHY HERE? WHY NOW? ~ There are numerous reasons why management activities are needed to change the existing conditions in the Trapper Bunkhouse area. The reasons I have decided to actively manage the area by selecting Alternative 4 include: Existing fuel loads (including live trees) pose an unacceptable threat to the public, fire fighters, and natural resources from stand-replacing wildfires. {FEIS, p.1-5} o o o o Large fires that burned on the Bitterroot National Forest in 2000, 2003, 2005 and 2006 missed the Trapper Bunkhouse area. Only one major fire (>100 acres), the Tin Cup Fire in August 2007, has occurred in the Trapper Bunkhouse Project Area (Project Area) since 1910, leaving a large area (approximately 23,000 acres) of unburned fuels that, in the event of a wildfire, could pose a considerable risk to the community, firefighters, and the public. The community of Darby, Montana, located about two miles east of the project boundary (Figure 1) has over 300 people per square mile, while between people per square mile live in the area between Darby and the Project Area boundary. Vegetation has shifted in the Project Area to overstocked, dense stands that are at increased risk of stand-replacing crown fires or intensities that can not be directly attacked by fire fighters. Page 6 Trapper Bunkhouse Land Stewardship Project ROD

8 In the portion of the Trapper Bunkhouse area that is suitable for timber management there are dense or over-stocked stands and insect and disease killed or infested trees. {FEIS, p.1-7} o o Past management practices, harvesting, and about one hundred years of fire suppression have left dense stands with less ponderosa pine than expected naturally, increasing susceptibility to insects and disease. Some trees thinned will have commercial value. With a stewardship contract, these revenues could be used for other resource work such as non-commercial fuel treatments and sediment reduction. Roads are contributing sediment to South Fork Chaffin and Little Trapper Creeks, and two culverts are barriers to westslope cutthroat trout. {FEIS, p.1-8} Research could help answer questions related to fuel reduction on the Bitterroot National Forest. {FEIS, p.1-9} 3.0 PURPOSE AND NEED The four 1 purposes and objectives of this project are: Reduce Risk from Stand-Replacing and Uncontrollable Fires - Reduce the number of acres where stand-replacing crown fires and uncontrollable fire intensities in the suitable timber base and the WUI are likely to occur. This will reduce the risk from fires harming human life (firefighters and the public), private property, and natural resources in the Project Area. Improve Resiliency and Provide Forest Products - Provide economic value to the community and funding opportunities for the activities related to reducing sediment contributions and fuel reduction by capturing economic value of insect or disease killed and/or infested trees and fire-killed trees. Provide for green tree thinning in plantations and at risk areas (dense and overstocked stands with moderateto-high potential for insect and disease outbreaks) outside of plantations to improve resiliency to insects and disease. Fuel Reduction Research - Conduct research to evaluate our ability to influence fire spread rates and severity with vegetation management and the effects of our management on the ecosystem components such as soil productivity and weed invasion. Watershed Improvement - Reduce sediment contribution in South Fork Chaffin and Little Trapper Creeks from the identified high-priority road segments and crossings. Improve aquatic connectivity in South Fork Chaffin Creek. 4.0 DESCRIPTION OF MY DECISION By implementing Alternative 4, the preferred alternative identified in the FEIS, vegetation management treatments will occur on approximately 5,827 acres across the Trapper Bunkhouse landscape. My decision also incorporates watershed improvement mitigations and opportunities, road management, and mitigation and project design features. Table 1 summarizes the activities that will be authorized by this decision; Table 2 shows the vegetation management treatment units. Figure 2 shows a map of the proposed activities. Appendix A lists 1 A fifth purpose and need objective related to managing off-highway vehicle recreation opportunities was included in the proposed action sent to the public during scoping. This purpose and need objective was subsequently dropped from this project. See Section for additional information. Trapper Bunkhouse Land Stewardship Project ROD Page 7

9 the watershed improvement mitigations and opportunities, Appendix B shows the road management actions, and Appendix C lists the mitigation and project design features. Table 1: Summary of Activities for Alternative 4 Activity Acres (% of total acres to be treated) Total Number of Treatment Units 121 Treatments in WUI 5,392 (93%) Proposed Treatments: Aspen Treatments 25 (<1 %) Commercial Thin 2,590 (44%) Salvage/Regeneration and 189 (3%) Commercial Thin Maintenance Burn 562 (10%) Prescribed Burn 743 (13%) Small Tree Thin 232 (4%) Small Tree Thin (Plantations) 1,199 (21%) Slashing 226 (3%) Sanitation and/or Salvage 41 (1%) Research Control 20* (<1%) Total Acres Treated 5,827 Yarding Systems: Skyline 1,576 (56%) Tractor 1,102 (39%) Helicopter 142(5%) Total Commercial Treatments 2,820 (48%) Total Non-Commercial Treatments 3,007 (52%) Helicopter Landings Constructed (and existing landings used) 4** Temporary Road Construction (miles) 2.8 Roads to be decommissioned (miles) 7.4*** Watershed Mitigation (miles) 6.0**** Road management to reduce disturbance to elk (miles): Seasonal Closure (10/15-6/ 15) Yearlong Closure Maintenance Burns in 6-10 years (when fuel conditions are right) after initial treatments. Estimated Timber Harvest Volume (thousands of board feet, MBF) ,577 5,200 * Approximately 120 acres will be used in the research; of that 20 acres = control. The rest is accounted for in other treatment categories: 40 acres=small tree thin, 60 acre =commercial thin; 415 acres remaining outside research plots=commercial thin. ** Four Helicopter Landings analyzed. Only three are likely to be used. *** Roads will be decommissioned as funds become available. **** Tied to commercial timber treatments. If the commercial vegetation treatments are implemented this watershed work will be accomplished. Page 8 Trapper Bunkhouse Land Stewardship Project ROD

10 Table 2: Vegetation Management Treatments Approved by This Decision Unit Planned Treatment* Acres Acres in WUI Which P and N** Yarding System Future Mtn. Burn 2 Prescribed Burn N/A Y 3 Commercial Thin Ground Research Control N/A 5 Research Small Tree Thin , 2, 3 N/A Research Commercial Thin , 2, 3 Skyline and Ground Commercial Thin , 2 Skyline and Ground Y 7 Commercial Thin , 2 Skyline 8 Maintenance Burn N/A Y 9 Commercial Thin , 2 Ground Y 10 Commercial Thin Ground Research Control N/A 11 Research Small Tree Thin , 2, 3 N/A Research Commercial Thin , 2, 3 Skyline and Ground Commercial Thin , 2 Skyline and Ground Y 13 Commercial Thin Skyline and Ground Y 14 Maintenance Burn N/A Y 15 Maintenance Burn N/A Y 17 Commercial Thin Skyline 18 Commercial Thin , 2 Skyline Y 19 Commercial Thin , 2 Skyline Y 20 Commercial Thin , 2 Skyline and Ground Y 21 Commercial Thin 3 3 1, 2 Helicopter Y 22 Commercial Thin , 2 Skyline and Ground Y 23 Prescribed Burn N/A Y 24 Commercial Thin , 2 Ground Y 25 Maintenance Burn N/A Y 26 Fire Salvage/Regeneration and Commercial Thin , 2 Skyline and Ground 27 Commercial Thin , 2 Skyline and Ground 28 Small Tree Thin , 2 N/A 30 Commercial Thin , 2 Ground 32 Commercial Thin Skyline and Ground 33 Small Tree Thin , 2 N/A Y 34 Prescribed Burn N/A Y 35 Slashing N/A 36 Aspen Treatment N/A 38 Commercial Thin , 2 Skyline and Ground 39 Commercial Thin Ground 39a Sanitation and/or Salvage Helicopter 40 Aspen Treatment N/A 41 Aspen Treatment N/A 42 Commercial Thin , 2 Skyline and Ground Y Trapper Bunkhouse Land Stewardship Project ROD Page 9

11 Unit Planned Treatment* Acres Acres in WUI Which P and N** Yarding System Future Mtn. Burn 45 Commercial Thin Helicopter 46 Commercial Thin Helicopter 47 Commercial Thin Helicopter 48 Commercial Thin Helicopter 49 Commercial Thin Helicopter 50 Commercial Thin Helicopter 70 Commercial Thin , 2 Helicopter Y 72 Commercial Thin , 2 Skyline and Ground Y 73 Prescribed Burn N/A Y 74 Commercial Thin , 2 Skyline Y 75 Slashing N/A Y 76 Small Tree Thin , 2 N/A 77 Prescribed Burn N/A Y 78 Commercial Thin , 2 Skyline Y 79 Commercial Thin , 2 Skyline and Ground Y 80 Commercial Thin , 2 Skyline and Ground Y 81 Commercial Thin , 2 Ground Y *** Small Tree Thin (Plantations) 1,199 1,130 2 N/A TOTALS 5,827 5,392 3,577 PERCENTAGES 93% 61% P and N = Purpose and Need; Mtn. = Maintenance; N/A=Not applicable; Y=Yes * Treatments are described in the alternative descriptions {FEIS, pp. 2-8 to 2-9}, Chapter 3, and in the Glossary of the FEIS. ** Purpose and Need: 1=Fuels, 2=Improve Resiliency and Provide Forest Products, 3=Fuel Reduction Research; and 4=Watershed Improvements. *** There are 71 small-tree thinning plantation units. Page 10 Trapper Bunkhouse Land Stewardship Project ROD

12 Figure 2: Map of Vegetation Treatments in Alternative 4 Trapper-Bunkhouse Project Bitterroot National Forest Darby Ranger District Legend Treatment Aspen Treatments Commercial Thin Maintenance Burn R State Land 15 Project Area 14 Wilderness Private Land Roadless nc F er le Litt 25 Tin C C up 29 Wildland-Urban Interface r r o S po 36 nc r 21 McC 70 oy Cr Hwy S Fk Cr, ffin r Cr 39a /13/ :50, tr,e Little Trapper Cr 20 Bit t er roo Trapp e Cha 3 22 ot R Fk Trapp er C r, N 35 erro Bitt Non-FS maintained Roads FS-maintained Roads Chaffin Cr 14 Small Tree Thinning (Plantatio Sects. of Rd. 374 to be Upgraded Small Tree Thin Slashing ^ Darby MONTANA STATE Sanitation and/or Salvage R 17 Salvage/Regen. + Thinning Tin Cup Cr Research (Mixed Treatments) s e Cr Bunkho u 2 rroo t 7 2 rroo t Prescribed Burn Bitte Bitte Bitterroot R, W Fk 26 3 Miles Note: All mapping is approximate, pending ground confirmation. ¹ Fk

13 5.0 ALTERNATIVES CONSIDERED The FEIS analyzed four alternatives in detail. These are briefly described below. Table 3 shows a comparison of the activities by alternative. 5.1 ALTERNATIVE 1 NO ACTION {FEIS, P. 2-5} Alternative 1 prescribes no treatments to reduce the risk from stand-replacing and uncontrollable wildfires, improve resiliency, and provide forest products. Furthermore, it will not conduct fuel reduction research or do any watershed improvement work. The fact that no management activities are proposed under this alternative does not mean that changes will not occur in the Project Area there will be the potential for naturally-occurring events such as blowdown, wildfire, or insect and disease attacks. Under this alternative, current management would continue in the Project Area. 5.2 ALTERNATIVE 2 - PROPOSED ACTION {FEIS, PP. 2-5 TO 2-11} Alternative 2 was developed to meet the project s purpose and need. It would have treated approximately 4,732 acres on National Forest System land. Ninety one percent of the treatments would occur in the WUI. The proposed treatments would have been a combination of aspen treatments, commercial thinning, small tree thinning, thinning of small trees in plantations, fire salvage/regeneration and commercial thinning, maintenance burning, prescribed burning, research plots, and slashing. Approximately 45% of the work would have resulted in saw timber of commercial value; the estimated volume was 3,900 MBF. About 2.7 miles of temporary roads would have been constructed. This alternative would have completed about 6 miles of watershed mitigation (drainage/surface improvements) and 7 miles of road closures, seasonal and yearlong, to reduce elk disturbance. Additional watershed improvement opportunities, including the replacement or removal of culverts which are barriers to fish passage, decommissioning of 7.4 miles of road, and providing for a parking area at the Trapper Peak Overlook, would have been accomplished as funds became available through timber revenues, appropriations, or partnerships. 5.3 ALTERNATIVE 3 - {FEIS, PP TO 2-17} Alternative 3 was designed to strategically place treatment units so the benefits of changing fire behavior were the greatest. It would have treated approximately 3,948 acres on National Forest System land. Ninety one percent of the treatments would occur in the WUI. The proposed treatments would have been similar to those described for Alternative 2, with the exception that approximately 1,199 acres of small tree thinning (plantations) would not occur. Approximately 56% of the work would have resulted in saw timber of commercial value; the estimated volume was 3,900 MBF. Approximately 0.7 miles of temporary roads would have been constructed. Watershed mitigation, road closures, and watershed improvements would have been the same as Alternative ALTERNATIVE 4 PREFERRED ALTERNATIVE {FEIS, PP TO 2-23} Alternative 4 was developed in response to public input on the DEIS. Commenters asked why only 4,732 acres (20%) of the Project Area were proposed to be treated when additional acres could and should be treated. Also, they requested an alternative which would generate additional revenue to be used to fund the watershed improvement opportunities which were not directly tied to commercial harvest. Furthermore, members of the Trapper Bunkhouse Land Stewardship Project ROD Page 13

14 Interdisciplinary Team (IDT) noted that additional benefits could be realized, in terms of fuel management and enhanced forest resiliency, by combining units from Alternatives 2 and 3. Alternative 4 will treat approximately 5,827 acres on National Forest System land. Ninety three percent of the treatments will occur in the WUI. The proposed treatments will be similar to those described for Alternative 2. Approximately 48% of the work will result in saw timber of commercial value; the estimated volume is 5,200 MBF. About 2.8 miles of temporary roads will be constructed. Watershed mitigation, road restrictions, and watershed improvements will be the same as Alternative 2. Table 3: Comparison of Activities by Alternative Activity Alt. 1 Alt. 2 Alt. 3 Alt. 4 Total Number of Treatment Units Acres of Treatments in Wildland Urban 4,297 3,582 5,392 0 Interface (% of total acres treated) (91%) (91%) (93%) Proposed Treatments in acres (% of total acres treated) Aspen Treatments (1%) (0%) (<1%) Commercial Thin 0 1,891 2,174 2,590 (40%) (55%) (44%) Fire Salvage/Regeneration and Commercial Thin (4%) (0%) (3%) Maintenance Burn (12%) (15%) (10%) Prescribed Burn (11%) (18%) (13%) Small Tree Thin (5%) (5%) (4%) Small Tree Thin (Plantations) 0 1, ,199 (25%) (0%) (21%) Slashing (<1%) (5%) (3%) Sanitation and/or Salvage (1%) (1%) (1%) Research Control 0 20* 20* 20* (<1%) (1%) (<1%) Total Acres Treated 4,732 3,948 5,827 Yarding Systems (acres) Skyline 0 1,203 1,345 1,576 (57%) (61%) (56%) Tractor ,102 (38%) (35%) (39%) Helicopter (5%) (4%) (5%) Total Commercial Treatments 0 2,121 2,215 2,820 (45%) (56%) (48%) Page 14 Trapper Bunkhouse Land Stewardship Project ROD

15 Activity Alt. 1 Alt. 2 Alt. 3 Alt. 4 Total Non-Commercial Treatments 0 2,611 (55%) 1,733 (44%) 3,007 (52%) Helicopter Landings Constructed (and existing landings used) 0 4** 4** 4** Temporary Road Construction (miles) Roads to be Decommissioned (miles) 0 7.4*** 7.4*** 7.4*** Watershed Mitigation (miles) 0 6.0**** 6.0**** 6.0**** Road management to reduce disturbance to elk (miles) Seasonal Closure (10/15 6/15) Yearlong Closure Roads Open Yearlong to All Motorized Use to be Closed Yearlong or Decommissioned (miles) Roads Open Yearlong to All Motorized Use to be Closed 10/15-6/15 (miles) Roads Closed to All Motorized Use 10/15-12/1 to be Closed Yearlong (miles) Roads Closed to All Motorized Use 10/15 6/15 to be Closed Yearlong (miles) Roads Closed Yearlong to Full Sized Vehicles and Closed 10/15 6/15 to OHVs to be Closed Yearlong (miles) Roads Closed Yearlong to Full Sized Vehicles with no Restrictions on OHVs to be closed /15 6/15 (miles) Roads Closed to All Motorized Use 10/15 12/1 to be Closed to All Motorized Use 10/ /15 (miles) Roads Closed Yearlong to Full Sized Vehicles with no Restrictions on OHVs to be Closed Yearlong (miles) Maintenance Burns in 6-10 years (when fuel conditions are right) after initial treatments. 0 2,482 3,306 3,577 Estimated Timber Harvest Volume (thousands of board feet, MBF) 0 3,800 3,900 5,200 * Approximately 120 acres will be used in the research; of that 20 acres = control. The rest is accounted for in other treatment categories; 40 acres small tree thin; 60 acre =commercial thin; 415 acres remaining outside research plots=commercial thin. **Four Helicopter Landings analyzed. Only three are likely to be used. *** Roads will be decommissioned as funds become available. **** Tied to commercial timber treatments. If the commercial vegetation treatments are implemented this watershed work will be accomplished. The change in road restrictions on roads that would be used as haul routes would be made by the end of the timber sale, stewardship, or service contract. For information on the specific roads to be restricted, refer to Table 2-8 in the FEIS. Trapper Bunkhouse Land Stewardship Project ROD Page 15

16 5.5 ALTERNATIVES CONSIDERED BUT ELIMINATED {FEIS PP TO 2-42} During project development, and in response to comments submitted on the DEIS, five additional alternatives were considered but dismissed from further analysis. These alternatives, and the reasons for dismissing them, are described below: Meters Around Structure Fuel Reduction And Wildland Fire Use Alternative In response to scoping, commenters offered an alternative to the Proposed Action. Their basis for proposing this alternative included: Improving the protection of homes and communities from wildland fire. Allowing the healthy succession of forest ecosystems, recognizing the positive role of forest insects and tree disease. Allowing fire to play its natural role in the forest ecosystem, and Using contracting and funding flexibility to maximize benefit to sustainable local economy {PF- SCOPE-011, p. 6} There are a number of reasons why, upon preliminary analysis and consideration, the IDT recommended that this alternative not be analyzed in detail {PF-IDT-031}. These reasons are summarized in Table 4: Table 4: Why the 400 Meters Around Structure Alternative Was Not Analyzed in Detail Basic Element of Alternative Improve the protection of homes and communities from wildland fire by thinning from below and hand pruning within 400 meters of structures. Allow the healthy succession of forest ecosystems, recognizing the positive role of forest insects and tree disease. Reasons Not Considered In Detail This alternative would not meet the fuel reduction purpose and need for this project because: 1) it would not treat Mean Travel Time (MTT) and Treatment Optimization Model (TOM) priority areas {FEIS, Chapter 2, page 14}; 2) it would not significantly change the crown fire probability; and 3) some of the areas that fall within the 400 meter area around a structure have already been treated or are scheduled for treatment {PF- ALT-007}. It was determined that allowing all insects and diseaseinfested trees to follow natural succession would not meet the purpose and needs of providing economic value for the community and funding other resource work by capturing the value of dead and dying trees or increasing tree resiliency to insects and disease. The Trapper Bunkhouse project is within the 27% of the Forest where active timber management is allowed and appropriate. The 1.3 million acre Selway-Bitterroot Wilderness is immediately west of the Project Area, and impacts resulting from insects and disease outbreaks are not actively managed in the Wilderness. Page 16 Trapper Bunkhouse Land Stewardship Project ROD

17 Basic Element of Alternative Allow fire to play its natural role in the forest ecosystem. Use contracting and funding flexibility to maximize benefit to sustainable local economy. Reasons Not Considered In Detail The Forest Service is required to suppress all wildfires within the WUI (70% of the Project Area). Wildland fire use is already considered a management strategy for roadless areas, and the wilderness to the west of the Project Area. The proposed action may facilitate more options for fire use in the wilderness, whereas reducing fuels only within 400 meters of structures would not. This is an integral part of Alternatives 2, 3, and 4; therefore a separate alternative to analyze this is not required Burnt Ridge Homeowners Association 2 OHV Alternative Other OHV Alternatives The Trapper Bunkhouse Project scoping document mailed to the public in September 2005 included a fifth purpose and need item related to managing off-highway vehicle recreation opportunities in the Project Area. However, as the Bitterroot National Forest was involved in a comprehensive travel management analysis, which would evaluate wheeled motorized access across the entire Forest, I decided to drop this item from the project. Additionally, members of the public requested that travel management be tabled and removed from the Trapper Bunkhouse project on several occasions. Notes from a meeting facilitated by Dr. Jim Burchfield stated Several local residents expressed concern that the Trapper Bunkhouse decision on motorized use is premature, and it will unnecessarily attract more motorized users than if the designation had occurred as part of a larger, Forest-wide designation package {PF-PUBLIC-051, p.12}. In light of the decision to drop off-highway vehicle (OHV) management from the proposed action, there is no detailed analysis of any OHV alternatives. This included a proposal the Burnt Ridge Homeowners Association submitted in their comments on the Trapper Bunkhouse scoping document {PF-SCOPE-031}. Initial consideration of that proposal occurred, but was not completed, given the decision to remove OHV management from the proposed action {PF-ALT-006}. Also not considered in detail was a proposal, voiced during meetings facilitated by Jim Burchfield on OHV management, to open all existing Forest Service roads {PF-PUBLIC-051}. Under this proposal, drainages that currently meet the elk habitat effectiveness standard contained in the Bitterroot Forest Plan would no longer meet that standard, and other drainages would move further away from the standard. The proposal would also move away from desired conditions for stream sedimentation. Therefore, this alternative was not considered in detail Alternative that Does Not Require Forest Plan Amendments Commenters on the DEIS expressed concern that Without an action alternative that doesn't include amendments, the DEIS does not demonstrate that the proposed Forest Plan Amendments are needed, that the purposes of the project cannot be met without them {DEISCOMM-010, p. 14}. For this reason an alternative that does not require site-specific Forest Plan amendments was considered; however, it was eliminated from detailed analysis for the reasons described below. The existing condition for thermal cover (trees greater than 40 feet in height and greater than 70% crown canopy closure) is well short of the Bitterroot Forest Plan Record of Decision (1987) requirement for maintaining 2 Correspondence from this group uses the names Burnt Ridge Neighborhood Association and Burnt Ridge Homeowners Association Trapper Bunkhouse Land Stewardship Project ROD Page 17

18 thermal cover on at least 25% of big game winter range. This existing condition is analyzed in Alternative 1 (No Action). It is unlikely that the historical condition of forests within the Project Area met this standard due to the high frequency, low-to-mixed severity fire regimes that maintained generally open, park-like characteristics of low elevation ponderosa pine and Douglas-fir forests. An alternative that would meet the thermal cover standard would require extensive planting, fertilizing, and decades (20 60 years) of growth to reach thermal cover conditions. The interim condition would be a dense vegetative condition composed of ladder fuels ranging in size from seedlings to poles. This condition is not consistent with the historical vegetative structure, and, consequently, the Trapper Bunkhouse project was proposed to reduce the risk of catastrophic wildfire within the WUI. For these reasons an alternative that meets the thermal cover requirement was not analyzed further. I considered an alternative that would meet the Forest Plan standard for coarse woody debris. This alternative would leave 25 tons/acre of coarse woody debris in all treatment units in Management Area 2 (USDA 1987, p. III-13). Management Area 2 is big-game winter range primarily occurring below 6,200 feet elevation on the lower forested or grassy foothills (USDA 1987, p. III-9). These sites make up roughly 25% of the Project Area, and are adjacent to private property. In this type of habitat (warm, dry, ponderosa pine and Douglas-fir habitat) Brown (et al 2003) showed that 25 tons per acre is well outside of the range of historical coarse woody debris levels {PF-FIRE-033}. Retaining this amount of coarse woody debris within the WUI, where the project s purpose and need includes the reduction of risk from stand-replacing and uncontrollable fires, is not desirable; therefore, this alternative was not analyzed further. I also considered an alternative that would meet the Forest Plan standard for elk habitat effectiveness (EHE) {PF-ALT-017}. The standard is to maintain 50% or higher EHE in currently roaded drainages (those where more than 25% of the potential road system was in place in 1987), and 60% or higher EHE in drainages where less than 25% of the roads had been built (USDA 1987, p. II-21). The existing condition for EHE does not meet this standard in five of the eight third-order drainages that are wholly or partially within the Project Area. Meeting the standard would result in substantial reductions in the public s ability to access and enjoy portions of the Forest. Access routes open to public motorized travel would largely be limited to the existing main roads; motorized access to several of the major recreation destinations - Baker Lake Trailhead (Trail 234), the Trapper Creek Trailhead (Trail 598), and the Trapper Peak Observation Point - would be closed. Despite not complying with the Forest Plan standard for EHE in all third-order drainages, the Forest Plan objective of maintaining the current (1987) level of big-game hunting opportunities has been achieved and exceeded. The number of hunters, as well as the number of elk, has continued to increase. The fact that the Forest continues to meet and exceed the objective for elk appears to indicate that existing EHE levels are generally not a limiting factor for elk populations in the Bitterroot drainage. For these reasons, an alternative to meet the Forest Plan Standard for EHE within the Project Area was not considered in detail Alternative That Would Generate Enough Revenue For All Fuel Reduction And Resource Opportunities Commenters on the DEIS requested an alternative that would cover all the costs of the non-commercial fuel reduction and resource opportunities identified in the DEIS; or in other words, a 'break-even' alternative {PF- DEISCOMM-9, p.2, DEISCOMM-10, p. 2}. Such an alternative was considered {PF-ALT-008}. A scenario was modeled using a tool called MAGIS {PF-RES-020} that harvested every available additional acre with commercially valuable saw timber. With this scenario there were not enough acres available to generate sufficient revenues to cover the identified non-commercial fuel reduction work and resource opportunities. For this reason this alternative was not analyzed further. The DEIS disclosed that other funding sources would be needed to accomplish all of the non-commercial fuel reduction and resources opportunities identified; the FEIS includes information on potential sources (refer to Table in the Economics and Social Analysis section of the FEIS). Page 18 Trapper Bunkhouse Land Stewardship Project ROD

19 5.5.5 Alternative With Research Plots Only A commenter on the DEIS requested that an alternative be considered which only included the research plots {PF-DEISCOMM-010, p. 14}. Conducting research to evaluate our ability to influence fire spread rates and severity using vegetation management, and studying the effects of management on ecosystem components such as soil productivity and weed invasion, is one of four project objectives. The research plots will total approximately 120 acres, including 20 acres of control plots where no new actions will occur. Reducing fuels and conducting thinning on only 100 acres, in five acre plots, within a 23,140 acre Project Area would not meet the other three objectives of this project. The effects on the remaining 23,040 acres would be substantially the same as for the no action alternative, which is analyzed. Since this alternative would not meet three of four project objectives, and because the effects of the alternative were largely analyzed in Alternative 1 (No Action), it was not analyzed in detail. 6.0 PUBLIC INVOLVEMENT Following the wildfires of the summer of 2000, a series of 14 public meetings was held in the Bitterroot Valley. As a result, the participants reached consensus on five priorities for post-fire recovery; first among them was Manage fuels in burned areas and in green wildland-urban interface. Throughout the winter and spring of , a diverse group worked to collaboratively develop a community plan that would guide valley-wide efforts to better prepare for, and minimize, the risks from the next big fire. This plan, the Bitterroot Community Wildfire Protection Plan (BCWPP), was completed in During the development of the BCWPP, the Trapper Bunkhouse area was identified as a high priority for treatment {PF-FIRE-004}. Initial public involvement for the Trapper Bunkhouse project began during the spring and summer of The Forest Service held four meetings, including a field trip, to collaborate with interested parties on the development of the proposed action. The intent of the meetings was to gain public input on a proposed action which would reflect public interest, while addressing the management needs of the area. A scoping letter which described the project and how to comment/participate in the planning process was mailed to 292 individuals and organizations on September 15, 2005 {PF-SCOPE-012}. A legal notice soliciting public comment on the proposal was published in the Ravalli Republic on September 20, 2005, and a news release was sent to the local media on September 26, On September 27, 2005, a front-page article regarding the project was published in the Ravalli Republic {PF-NEWS-006, 008, 009}. A total of 43 letters, s, and telephone calls with comments were received on the proposed action {PF-SCOPE-001 to 043}. A Notice of Intent to prepare an environmental impact statement was published in the Federal Register on September 21, 2005 {PF-NEWS-007}. An open house was held in Darby, Montana on October 12, 2005, attended by 18 members of the public {PF- SCOPE-015}. A public meeting was held on December 5, 2005, following the close of the scoping period, to clarify those comments received and to discuss the proposed action {PF-PUBLIC-017, 018). The meeting was facilitated by Dr. Jim Burchfield, Associate Dean of College of Forestry and Conservation, and Associate Research Professor of Forest Social Sciences at the University of Montana. During the winter and spring of 2005, the Darby District Ranger held several informal meetings with interested parties A second public field trip was held on August 23, 2006 to discuss the second action alternative {PF-PUBLIC- 019, 020, 021, 035}. In response to concerns raised by some of the participants related to the off-highway vehicle (OHV) management proposal included in the proposed action, the Forest Service contacted Dr. Burchfield to determine his interest and willingness, as a neutral third party, to convene meetings with parties on both sides of the OHV issue to see if an alternative that met all interests could be developed. Dr. Burchfield Trapper Bunkhouse Land Stewardship Project ROD Page 19

20 presided over four meetings {PF-PUBLIC-036, 037, 038, 048, and 051}. No agreements were reached. 3 On several occasions, members of the public requested that the OHV portion of the Trapper Bunkhouse project be considered in the context of the Forest-wide travel planning effort {PF-PUBLIC-051, pp. 10 and 12; PF- SCOPE-043, p. 4; PF-PUBLIC-049, p. 2}. Although the Forest saw benefit to addressing OHV management on a project-specific basis, it also recognized the value in including the Trapper Bunkhouse area in the Forest-wide planning effort. For these reasons the OHV management proposals were removed from this project and will be considered in the Forest-wide planning effort. The DEIS was released for public review and comment in April Fifteen letters were received {PF- DEISCOMM-001 to 015}. During August 2007, the Tin Cup Fire burned approximately 146 acres in the Project Area, including a unit which was included in the Proposed Action. As a result, the silvicultural prescription was changed and temporary road construction was proposed. A letter dated October 23, 2007 {PF-PUBLIC-086} was mailed to the public, informing them of the changes, and asking for comments by November 9, Four letters and three telephone calls were received {PF-UNIT to 005}. 6.1 HOW I CONSIDERED PUBLIC COMMENTS Regardless of the source or form of the correspondence, or whether the comment was received during the official comment periods or afterwards, I considered each piece of correspondence. The public comment process, however, is not a quantitative vote, but rather a qualitative process designed to ensure that all issues and concerns related to the project are considered in the analysis. I have reviewed these issues and concerns, as shown in Section 7.2 titled Addressing Issues and Public Concerns. 7.0 RATIONALE FOR MY DECISION In reviewing the alternatives developed for the Trapper Bunkhouse project, I considered how well they addressed two important criteria: 1) the project s purpose and need for action, and 2) issues and public concerns. I value the continuing support for the project by the residents of the local communities. I gave strong consideration to their concerns about the risk wildfires pose to the values that are important to them. Their needs were expressed through the Bitterroot Community Wildfire Protection Plan. Private land owners living adjacent to the Project Area have created defensible space around their properties. They have requested that I, as the Responsible Official, authorize the reduction of fuels on National Forest System lands that border their property. It is clear, however, that there are differences in opinion as to what the most effective and appropriate manner to accomplish this is. Please refer to Appendix G of the FEIS, which contains public comments on the DEIS, along with the Forest Service s responses. 7.1 MEETING THE PURPOSE AND NEED As noted in Section 3.0 of this document, there were four purposes for undertaking the Trapper Bunkhouse project: 3 See Section 2.5 for Alternatives Considered But Eliminated. One issue was voted on at the last meeting that appeared to pass the groups decision threshold, but discussion immediately following the vote disclosed there was confusion among the members as to the language used in the question which influenced their vote and the facilitator did not see it as an agreement (PF-PUBLIC-051). Page 20 Trapper Bunkhouse Land Stewardship Project ROD

21 Reduce the Risk from Stand-Replacing and Uncontrollable Fires Improve Resiliency and Provide Forest Products Fuel Reduction Research Watershed Improvement - Reduce Sedimentation in Priority Streams and Improve Aquatic Connectivity Measurement indicators were developed for each of the purpose and need statements to provide a way of quantitatively measuring how each alternative responds to the statements. The following section describes the purpose and need statements, lists the measurement indicators, and presents the results for each of the alternatives considered in detail. Reducing The Risk From Stand-Replacing And Uncontrollable Fires The Bitterroot National Forest has been altered by 100 years of fire suppression, insect and disease outbreaks, and logging (Hessburg et al. 1994). The vegetation structure in the majority of the Project Area has shifted to dense, overstocked stands that are at an increased risk of stand-replacing wildfires. Large areas of unburned fuel exist in the Project Area that, in the event of a wildfire, could pose a considerable risk to firefighters, the public, and natural resources. During the summer of 2000, wildfires burned over 307,000 acres on the Bitterroot National Forest, which resulted in losses of residences and property, and caused the evacuation of over 1,000 homes. Those fires, as well as the ones which burned on the Forest in 2003, 2005, and 2006 missed the Project Area. In fact, no major fires (>100 acres) had burned in the Project Area since 1910 until August 2007 when the Tin Cup Fire burned approximately 587 acres of National Forest System, state, and private land. The community of Darby lies two miles east of the Project Area, with a density of over 300 people per square mile; the rural area between the Project Boundary and Darby contains between people per square mile (DNRC et al., 2006, p. Appendix E-4). Any major fire, or multiple ignitions in one day on the Bitterroot Face, has the potential to overwhelm suppression forces and travel unimpeded to the Forest Service/private property boundary. Addressing this situation, to me, is a primary purpose of this project. Unacceptable fire effects in the WUI are defined as loss of life and property, reduction of scenic and recreational values, loss of forest resources and threatened ecosystem components, and compromised safety to the public and firefighters. Taking actions to reduce fuels in the Project Area would set the stage for allowing fire to play its natural role, which historically was non-stand replacing with short-to-moderately short fire free intervals. To achieve this purpose, there is a need to reduce existing fuel loads, including live trees and dead and down woody material. Three measurement indicators were selected to evaluate the effects of the proposed treatments on fuels and fire behavior: Fireline intensity, fire type, and fire s arrival time. They are measures of fire behavior which were chosen based on their relationship to safety and fire effects. Fireline intensity is a function of the rate of spread, the amount of fuel consumed in the flaming front, and the heat content of the fuel. Lower intensity fires are usually easier to suppress, with less probability for torching, crowning, and spotting, which contribute to fire spread. The measurement would be the number of acres with reduced fireline intensity. Alternative 3 would have the greatest reduction in fireline intensity (2,442 acres), followed by Alternatives 4 (2,022 acres) and 2 (1,023 acres). Alternative 1 would have no effect on reducing fireline intensity {FEIS, p }. Fire type refers to the category of fire: surface fire, intermittent crown fire (also described as a torching fire), or a crown fire. A crown fire is one that becomes well established in the tree canopy, and is also referred to as a stand-replacing fire. These fires are of most concern to fire managers because they tend to affect large acreages as they move fast and are usually impossible to control until fuels or weather conditions change their behavior. The intent of the proposed treatments is to decrease the fire type category, going from crowning to Trapper Bunkhouse Land Stewardship Project ROD Page 21

22 torching fire to surface fire. The measurement would be the net desirable change, the difference in the number of acres exhibiting an increase in fire type versus a decrease in fire type. Alternative 3 would result in the largest net desirable change (470 acres), followed by Alternatives 4 (368 acres) and 2 (256 acres). Alternative 1 would have no effect on changing the fire types in the Project Area {FEIS, p }. Fire s arrival time is the amount of time it would take for a fire ignited at a given location to travel to every other location on the landscape, given a constant wind and weather condition. For the Trapper Bunkhouse project, two different ignition scenarios and two different wind directions were modeled. Longer arrival times are more desirable as they indicate slower moving fires what will give fire managers time to implement their strategies. Alternative 3 would result in the longest arrival times, followed by Alternatives 4 and 2. Alternative 1 would have no effect on modifying fire s arrival time {FEIS, p }. Improve Resiliency and Provide Forest Products The greatest changes to the vegetation resource in the Project Area have occurred in the low-to-mid elevation Douglas-fir and ponderosa pine forests, resulting in overly dense stands composed of late seral or climax tree species. These stands historically experienced frequent low-to-mixed intensity fires, resulting in landscapes that were tolerant of fire and insects and disease pathogens. Not only does the increase in tree density result in greater flammability of the forest, but it also creates severe water and nutrient competition among trees, shrubs, and other forest plants that pre-disposes vegetation to attack by insects and diseases. Competition among trees may be exacerbated by increased warming and modified precipitation regimes on forested ecosystems associated with global climate change {FEIS, p }. The measurement indicator chosen to compare how well each alternative improves the resiliency of vegetation to insects and diseases is the number of acres of reduced stocking. Treatments would reduce stocking levels, favoring more disease-resistant tree species, and providing management options to mitigate risk, all of which have an end result of improving vegetative resiliency. Analysis results show that Alternative 4 would result in the greatest number of acres (3,192) of reduced stocking, followed by Alternative 2 (2, 416 acres) and Alternative 3 (1,979). Alternative 1 would have no effect, as there would be no acres treated {FEIS, p }. As described in the Economics and Social Analysis section of the DEIS, the timber program on the Bitterroot National Forest has declined substantially over the last twenty years. However, even at the current level, timber from the Forest plays an important role in the wood and paper products economy of Missoula and Ravalli Counties. The trees that will be harvested to reduce stocking levels and, consequently, reduce the risk of standreplacing wildfires, have commercial value which will contribute to the local economy. Two measurement indicators were selected to compare the alternatives in terms of their effect on economic opportunities. They are total employment, expressed as jobs, and total labor income. It is important to note that these are not new jobs or income, but rather jobs and labor income that can be attributed to the project. With respect to total employment, Alternative 4 would result in 178 jobs, followed by Alternatives 2 and 3 with 126 jobs each. Alternative 1 would not result in any jobs {FEIS, p }. With respect to total labor income, Alternative 4 would result in $4,497,000 over the life of the project, followed by Alternative 2 with $3,136,000 and Alternative 3 with $3,070,000. Alternative 1 would not result in any total labor income {FEIS, p }. As displayed in the DEIS and FEIS, a number of watershed improvement activities and mitigation opportunities were identified. The required mitigation projects would be funded; the improvement opportunities would be implemented as funding is available. Page 22 Trapper Bunkhouse Land Stewardship Project ROD